Issue Date: 03/16/15 1 IP 88003

NRC INSPECTION MANUAL NMSS/FCSE

INSPECTION PROCEDURE 88003

REACTIVE INSPECTION FOR EVENTS AT FUEL CYCLE FACILITIES

PROGRAM APPLICABILITY: 1301, 2600 and 2683

88003-01 INSPECTION OBJECTIVES

01.01 This inspection procedure applies to the inspection of events, involving safety or 

safeguards that occur at Nuclear Regulatory Commission (NRC)-regulated nuclear fuel cycle 

facilities. NRC management must determine the need to dispatch one or more regional or 

Headquarters inspectors to conduct a reactive inspection after an event occurs. The events to 

be inspected under this procedure include those that are considered significant enough to 

warrant reactive inspections to determine the operational status of safety and safeguards, but 

are not of such a nature as to require Incident Investigation Team (IIT) or an Augmented 

Inspection Team (AIT) inspection. Typically, the procedure will be used in response to: over 

exposures; losses or releases of significant quantities of radioactive materials; fires or toxic 

chemical spills that threaten losses of safety or safeguards controls, or that significantly 

increase the risks of such losses or releases; or actual losses of safety controls -- but its use is 

not limited to these types of events. The need for such an inspection may be strengthened by 

the occurrence of one or more previous events that may share a common root cause.

01.02 The objectives of the procedure are to assist the inspector to:

a. Determine the safety or safeguards risk revealed by the event, and ensure that the 

current facility condition is safe. Determine that any compensatory measures taken in 

response to the event are adequate to ensure safety and safeguards until corrective 

actions are implemented, or that already implemented corrective actions are effective.

b. Ensure that the licensee has considered possible generic implications of the event for 

the facility, and identify any generic implications for other NRC-regulated fuel cycle

facilities.

c. Assess the licensee’s progress in conducting a root cause analysis of the event to 

determine if it is adequate to correctly identify direct, contributing, and root causes; 

likely precursors; and corrective actions to prevent recurrence.

d. Monitor the licensee’s treatment of any previously unknown risk-significant system 

interactions revealed by the event, to ensure that the interactions will be incorporated 

into the facility’s safety basis [e.g., Integrated Safety Analysis (ISA)], and that the 

facility’s safety basis will be updated accordingly, if one has been completed.

e. Verify that the licensee responded to the event appropriately, in accordance with 

established emergency and safeguards contingency plans.
Issue Date: 03/16/15 2 IP 88003

01.03 The primary emphasis of the inspection is on safety and safeguards, not compliance. 

Compliance issues are to be addressed only after all current safety and safeguards issues and 

program weaknesses related to the event are identified and clearly understood.

88003-02 INSPECTION REQUIREMENTS

A reactive inspection in response to an event, or series of related events, at a fuel cycle facility, 

includes the following:

02.01 Pre-Inspection Preparation and Notifications. Review event information collected by

regional and Headquarters management, and the resident inspector, if any, which resulted in a 

determination of the need for the reactive inspection. Establish a clear understanding of the risk 

significance of the event with reference to the facility’s licensing documents and ISA. Notify 

licensee management of the inspection; ascertain the current status of the facility; and make 

logistical arrangements with the licensee. Determine, through discussions with the licensee and 

NRC management, if any equipment has been or should be quarantined. 

02.02 Entrance Meeting. Conduct an initial meeting with the licensee's management, on 

reaching the site, to explain the purpose of the NRC reactive inspection, to obtain requested 

documentation, ascertain the availability of interviewees, and identify important licensee

contacts.

02.03 Facility Tour. Tour and inspect the areas of the facility affected by the event.

02.04 Interviews. Conduct interviews of licensee personnel to develop an understanding of 

the event, personnel actions, and facility system configuration and operations.

02.05 Documentation. Assemble and review the necessary documentation to characterize 

the event and its causes.

02.06 Sequence of Events. Develop an understanding of the sequence of actions or 

occurrences leading up to the event. Verify that licensee actions were consistent with 

established plans and procedures.

02.07 Assess Licensee’s Root Cause Analysis. Assess the technical merit of the licensee's

identification of direct, contributing, and root causes of the event; event precursors; and the 

corrective actions determined by the licensee. Verify that the licensee’s compensatory 

measures and corrective actions are adequate to ensure facility safety and safeguards and 

prevent recurrences of the type of event that occurred, before leaving the site. As part of the 

assessment, review the licensee’s consideration of possible generic issues at the facility, and 

consider whether issues arising from the event may apply at other NRC-regulated facilities.

02.08 Licensee and NRC Management Briefings. Meet periodically with the licensee's

management and key personnel involved in the event, as the inspection continues, to provide 

the licensee with feedback, alert the licensee to any additional safety or safeguards issues 

discovered, and request additional documents, or other support, as needed. Periodically inform
Issue Date: 03/16/15 3 IP 88003

appropriate NRC management of the progress of the inspection and alert management to 

possible generic issues that could affect other fuel cycle facilities.

02.09 Exit Meeting. Meet with the highest level of the licensee's management available at the 

site, to present the inspection findings, as the last activity before leaving the site.

88003-03 INSPECTION GUIDANCE

03.01 Pre-Inspection Preparation and Notifications. Review event information so that all 

parties have a clear understanding of the safety or safeguards significance of the event.

Review relevant sections of the regulations, licensing documentation, and ISA.

The reactive inspection should be announced. The assigned (lead) inspector should contact the 

licensee's management, to address issues requiring planning or preparation, to facilitate the 

inspection (e.g., information on current safety or safeguards status of the facility, any ongoing 

safety or safeguards issues, entrance meeting arrangements, identifying individuals to be 

interviewed, documents to be made available, and a facility tour).

Discuss equipment or operations that are quarantined or unavailable. Determining the 

necessity for quarantining the area affected by the event, and making the appropriate 

arrangements with the licensee, should have been addressed by NRC management, as part of 

the process of determining whether a reactive inspection should be performed.

03.02 Entrance Meeting. No additional guidance.

03.03 Facility Tour. The purpose of a facility tour is to help reconstruct the actions and 

occurrences leading to the event, to place all items and persons involved in proper spatial 

perspective, and to attempt to identify any factors, relating to the facility or equipment, that may 

have contributed to the event. A knowledgeable licensee representative may be able to point 

out relevant items involved in the event, detail the path followed by involved persons, explain 

the layout of equipment and materials at the time of the event, or recount any equipment 

settings that may be relevant to the inspection.

03.04 Interviews. Interview persons at the site knowledgeable of, or involved in, the event 

(e.g., maintenance; health physicists; process and system engineers; authors of involved 

procedures; nuclear criticality safety or other analysts who authored approval documents or 

reports around which the safety issues of the event revolve; people responsible for facilities, 

hardware, software, and/or supplies involved in the event; or supervisors, managers, and 

assistants whose responsibilities are connected with the systems or persons involved in the 

event). The depth of the interviews will vary, depending on the proximity of the interviewee’s 

activities, or responsibilities, in the event.

During the interviews, note the extent to which the persons interviewed are aware of the 

circumstances directly or indirectly connected to the event. Determine whether their knowledge 

and awareness are commensurate with their responsibilities in the organization and consistent 

with known facts.
Issue Date: 03/16/15 4 IP 88003

03.05 Documentation. During the course of the inspection, determine the necessary 

documents to review. These may include documents indicating the overall quality of the 

licensee's operation, as well as those directly related to the event. Documents to review may 

include the following:

a. Procedures for activities related to the event 

b. Training and Qualifications Records

c. Maintenance, Surveillance, Functional Test, Calibration, and Quality Control Records

d. Records of the Event

e. Records of Recovery

03.06 Sequence of Events. Develop a sequence of actions and occurrences leading to the 

reported event, based on available information (e.g., interviews, logs, control room computer 

entries, strip chart recordings, etc.). This could include annotations of relevant details, such as 

postings in the area, instrument readings, procedures and equipment used, when equipment 

was turned on/off, etc. For a significant event, documentation of areas where there is 

disagreement or lack of information on what actually happened, can help illuminate problems 

with procedures or controls that may have permitted the event to occur. Record the involved 

staffs’ bases for actions taken and note any developing conclusions as they become apparent.

Note where the licensee’s actions may have departed from established licensee plans for 

incident response. Inappropriate responses to minor occurrences sometimes can lead to more 

serious events. Also, literal implementation of an established incident response plan can lead to 

events, if the plan is defective. Comparison of the licensee’s actions with established plans can 

help to identify where improvements in response plans may be needed as a corrective action.

03.07 Assess Licensee’s Root Cause Analysis. The licensee should have begun an analysis 

of the causes of the event, as soon as the facility was determined to be safe. Since this 

procedure will be in use only in cases where no AIT or IIT investigation is determined 

necessary, no significant effort should be required for event mitigation and cleanup, and

substantial progress in the licensee’s investigation can be expected to occur while the reactive

inspection is in progress.

Inspectors should be cognizant of the licensee’s effort to conduct a root cause analysis, as it 

proceeds. Inspectors should eventually be aware of corrective actions determined by the 

licensee. As the licensee’s analysis progresses, compare the findings of the inspectors and 

those of the licensee, and assess the pace and adequacy of the licensee’s analysis. 

The licensee’s determination of root cause may not become known until after the inspectors 

leave the site, and may not even be available before the inspection report is issued. If this is the 

case, the inspection report may be issued with a preliminary determination of root cause. The 

inspector(s) should ensure that incomplete determinations of root cause and corresponding, 

safety-significant corrective actions are completed by the licensee within a reasonable time. 

The inspectors should consider specifying these activities as inspector follow-up items, if 

appropriate.
Issue Date: 03/16/15 5 IP 88003

03.08 Licensee and NRC Management Briefings. Inspectors should meet periodically with 

licensee staff, during the inspection, to exchange information on the course of their 

investigations, and ensure there are no surprises at the end of the inspection. Periodically, 

during the inspection, the lead inspector should notify the appropriate regional or Headquarters 

management of the status of the inspection and inspection findings. Notify NRC management if, 

at the end of the inspection, the licensee and the inspectors do not substantially agree on the 

causes of the event, on the adequacy of the licensee’s determination of corrective actions, or if

conclusions have not yet been reached on these issues. If the inspectors do not believe the 

facility is in a safe or secure condition, they should inform the appropriate NRC management 

immediately and explain their position. 

Based on NRC and licensee findings, inspectors should immediately notify appropriate NRC 

management if they identify any generic issues that could affect safety or security at other NRCregulated fuel cycle facilities.

03.09 Exit Meeting. No additional guidance.

88003-04 RESOURCE ESTIMATES

Inspector effort should correspond to the risk significance and complexity of the event and 

associated inspection. Inspection hours may be between 8 hours for a less significant event 

and 72 hours for a significant operational event.

88003-05 REFERENCES

NRC Inspection Manual Chapter 1301, “Response to Radioactive Material Incidents That Do 

Not Require Activation of the NRC Incident Response Plan”

NRC Inspection Manual Chapter 2600, “Fuel Cycle Facility Operational Safety and Safeguards 

Inspection Program”

NRC Inspection Manual Chapter 2683, “Material Control and Accounting Inspection of Fuel 

Cycle Facilities”

88003-06 PROCEDURE COMPLETION

Implementation of this IP is complete when each inspection requirement has been addressed. 

The individual samples to be inspected, and the breadth of the review will be determined by the 

inspector based on the degree of compliance with the requirements observed, the risksignificance of the activity, and the extent of the activity or records available.

END
Issue Date: 03/16/15 6 IP 88003

ATTACHMENT 1

Revision History for IP 88003

Commitm

ent 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of

Training Required 

and Completion 

Date

Comment and Feedback 

Resolution Accession 

Number (Pre-Decisional, 

Non-Public)

N/A 08/10/98 Initial issuance of IP 88003. None --

N/A ML15005A310

03/16/15

CN 15-004

Editorial changes made:

 Modified to be in compliance with format 

requirements of IMC 0040

 Removed the requirement to perform an 

independent root cause analysis. Performing an 

independent one requires significant resources 

that are beyond the scope of reactive inspections 

(i.e. inspections below the level of AIT).

 All references to allegation related material have 

been removed as they were redundant to 

guidance routinely offered by allegation support 

staff and training taken by NRC staff.

 Replaced the “special inspection” with “reactive 

inspection” to stay in line with the title of the 

procedure and not to create a Special Inspection 

Procedure only.

 Removed the definitions sections that did not add 

value to the procedure.

 Added IMC 2683, “Material Control and 

Accounting Inspection of Fuel Cycle Facilities” to 

referenced documents.

None ML15005A324