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NRC INSPECTION MANUAL IIPB

MANUAL CHAPTER 2515

LIGHT-WATER REACTOR INSPECTION PROGRAM—OPERATIONS PHASE

2515-01 PURPOSE

To establish the policy for the light-water operating reactor inspection program.

2515-02 OBJECTIVES

02.01 To obtain factual information providing objective evidence that power reactor

facilities are operated safely and licensee activities do not pose an undue risk to public

health and safety.

02.02 To determine the causes of declining performance before such performance

reaches a level that may result in an undue risk to public health and safety.

02.03 To identify those safety significant issues that may have generic applicability.

2515-03 APPLICABILITY

This inspection program is implemented when an operating license is issued for a facility.

Portions of the light-water reactor inspection program for the startup phase (IMC 2514) may

also be conducted during the initial operation of a facility. The light-water reactor inspection

program for the preoperational testing and operational preparedness phase (IMC 2513) will

have been completed by the time this program is in effect.

This inspection program will remain in effect until the facility is permanently shut down and

enters the post-operational phase (cf, IMC 2561, "Decommissioning Power Reactor

Inspection Program").

2515-04 DEFINITIONS OF INSPECTION FREQUENCIES

04.01 Triennially or Every Three Years (T). The inspection will be performed at least

once during ROP cycles 1-3, ROP cycles 4-6, ROP cycles 7-9, etc. It is not intended for

this to be based on a rolling 3 year cycle.
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04.02 Biennially or Every Two Years (B). The inspection will be performed at least once

during ROP cycles 1-2, ROP cycles 3-4, ROP cycles 5-6, etc. It is not intended for this to

be based on a rolling 2 year cycle.

04.03 Annually (A). The inspection effort will be performed at least once each calendar

year.

04.04 Semiannually (S). The inspection effort will be performed two times each calendar

year, once each half calendar year.

04.05 Quarterly (Q). The inspection effort will be performed four times each calendar

year, once each calendar quarter.

04.06 As Needed (AN). The inspection effort should be performed when the activity or

event occurs at the facility as specified in the guidance section of specific inspection

procedures (e.g., refueling outages).

04.07 Baseline Inspection Program Completion. Baseline Inspection Program completion

for an ROP annual inspection cycle is defined to be not more than four (4) inspection

procedures not completed, per Region. For the purposes of this definition, each inspection

procedure attachment is counted as a separate inspection procedure.

This sixteen (16) inspection procedure allowance per year nationwide equates to an annual

completion rate greater than 99.5% (assuming an average of 3400 total inspection

procedures/attachments per year nationwide - approximately 33 per year X 103 plants).

This allowance is intended to provide for unanticipated disruptions in inspection scheduling

that unavoidably cause an inspection procedure or attachment to not be completed and

presumes that at least the minimum inspection requirements will otherwise be completed

as soon as possible within the quarter immediately following the annual inspection cycle.

Achieving this level of Baseline Inspection performance provides a basis to conclude that

the intent of the Baseline Inspection Program has been met and therefore, for the purpose

of goal monitoring, can be reported as complete for that annual cycle. 

2515-05 RESPONSIBILITIES AND AUTHORITIES

05.01 Director, Office of Nuclear Reactor Regulation

a. Provides overall program direction for the reactor inspection program.

b. Develops and directs the implementation of policies, programs, and procedures for

inspecting applicants, licensees, and other entities subject to NRC jurisdiction.

c. Assesses the effectiveness, uniformity, and completeness of implementation of the

reactor inspection program.

05.02 Associate Director for Inspection and Programs. Directs the development of the

inspection program within the Office of Nuclear Reactor Regulation (NRR).
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05.03 Director, Division of Inspection Program Management (DIPM). Manages inspection

program development within NRR, develops and prepares revisions to the reactor

inspection program, oversees regional implementation, and serves as the NRR contact with

the regional offices for program development and implementation.

05.04 Directors, Technical Divisions, NRR. Assists the Director, DIPM in developing the

technical content of and reviewing periodic revisions to the requirements and guidance

contained in inspection procedures related to their areas of technical expertise.

05.05 Regional Administrator

a. Provides program direction for management and implementation of the inspection

program elements performed by their regional office.

b. Ensures, within budget limitations, that the regional office staff includes adequate

numbers of inspectors in the various disciplines necessary to carry out the

inspection program described in this chapter, including that which may be needed

for regional supplemental and reactive inspections.

c. Directs the implementation of the supplemental inspection program in accordance

with the guidance in Appendix B of this document.

d. Applies inspection resources, as necessary, to deal with significant issues and

problems at specific plants.

|

e. Ensures that line managers assign inspectors who are appropriately trained and |

have the necessary knowledge and skills to successfully implement inspection |

procedures. |

2515-06 REGULATORY OVERSIGHT FRAMEWORK

The fundamental building blocks that form the framework for the regulatory oversight

process are seven cornerstones of safety; initiating events, mitigating systems, barrier

integrity, emergency preparedness, occupational radiation safety, public radiation safety,

and physical protection. These cornerstones have been grouped into three strategic areas:

reactor safety, radiation safety, and safeguards. This framework is based on the principle

that the agency’s mission of assuring public health and safety is met when the agency has

reasonable assurance that licensee’s are meeting the objectives of the seven cornerstones

of safety. The reactor inspection program is an integral part, along with performance

indicators (PIs), assessment, and enforcement, of the reactor oversight process.

Acceptable performance in the cornerstones, as measured by the PIs and the risk-informed

baseline inspection program, is indicative of overall licensee performance that provides for

adequate protection of public health and safety. The PI program reporting guidelines are

in NEI 99-02, “Regulatory Assessment Performance Indicator Guideline,” which is endorsed

by the NRC.

Another principle of the framework is that there is a level of licensee performance in the

cornerstones above which the NRC does not need to engage the licensee beyond some
2515 - 4 - Issue Date: 07/28/05

minimum level. When this level of licensee performance is reached, the risk-informed

baseline inspection and PI programs are sufficient to provide reasonable assurance of

public health and safety. 

The supplemental portion of the inspection program will provide more diagnostic

inspections of identified problems and issues beyond the baseline. Supplemental

inspections will be planned in response to issues that result in crossing an Action Matrix

threshold. These changes to the inspection program are factored into the inspection

program through the assessment process, as further discussed in Section 8.0, below.

2515-07 OPERATING REACTOR INSPECTION PROGRAM ELEMENTS

The inspection program described in this manual chapter is comprised of the following

three major program elements:

1. Risk-Informed Baseline Inspection Program (Baseline) Inspections

2. Plant Specific Supplemental Inspections

3. Generic Safety Issue, Special, and Infrequent Inspections

Overall, the inspection program emphasizes achieving a balanced look at a cross section

of licensee activities important to plant safety, reliability, and risk. The baseline inspections

constitute an appropriate level of inspection at plants whose overall performance remains

in the licensee response band. Plants, whose performance is outside the licensee

response band, will receive additional plant specific supplemental inspection based on their

assessed performance in the cornerstones of safety. Additionally, Appendix D is provided

for use by the resident inspectors in conducting routine activities such as plant tours that

may assist them in identifying potentially risk significant activities.

The supplemental inspections, described in Appendix B, are only performed as a result of

performance issues that are identified by either performance indicators (PIs), baseline

inspections, or event analysis. The depth and breadth of specific supplemental inspections

chosen for implementation will depend upon the risk characterization of the issues as

shown in the Action Matrix of the reactor assessment program (IMC 0305, “Operating

Reactor Assessment Program”).

The need for additional inspections to address emergent generic safety issues, such as

those that were performed for motor-operated valves and year 2000 issues, will be

assessed on a case by case basis. The need for additional, ad hoc inspections will be

assessed for major licensee evolutions such as independent spent fuel storage facilities

or steam generator replacements.

In addition to the three elements, the inspection program also provides for the agency’s

response to operational events. The guidance for determining the level of response to an

event is contained in NRC Management Directive 8.3, “Incident Investigation Program.”
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07.01 Risk-Informed Baseline Inspections. The baseline inspection program element,

described in Appendix A, is to be performed at all operating reactors. It requires

inspections of licensee performance in the seven cornerstones of safety.

The baseline inspections provide sufficient examination of the plants and licensee activities

to determine, along with performance indicators, whether licensees are meeting the

objectives of all seven cornerstones, and to identify indications of performance problems

to allow further engagement by the NRC before the objectives of the cornerstones are

compromised.

The inspection procedures included in the baseline inspection program are based on

“inspectable areas” for the seven cornerstones of safety. The oversight framework

identified key attributes for each cornerstone that need to be verified to have a reasonable

assurance that the cornerstone objectives are met. Licensee performance within the key

attributes are then measured by either a performance indicator, a risk-informed inspectable

area, or a combination of both indicator and inspection.

The baseline inspection procedures are organized by cornerstone and include the

inspectable areas associated with the cornerstone. The baseline inspections are

performance-based and risk-informed and emphasize the observation and evaluation of

ongoing facility operations and supporting activities affecting the safety function of facility

structures, systems, and components. Appendix D has been provided to assist the resident

inspectors in conducting activities that may identify potentially risk significant activities.

The baseline inspections are risk informed through (1) the inspectable areas, which are

based on their risk importance in measuring a cornerstone objective; (2) the inspection

frequency and sample size for each inspectable area, which are based on risk information;

and (3) sample selection of activities and equipment to inspect in each inspectable area,

which is based on risk insights that will be modified by plant-specific information.

Appendix A contains a list of baseline inspection procedures and specifies the required |

frequency for their performance. The baseline inspection procedures must be completed |

at every plant at a prescribed interval. The expectation is that the regions should normally |

complete the nominal (average) number of inspection samples identified in the inspection |

procedure. The regions may vary the inspection samples within the ranges as indicated |

in each baseline inspection procedure, based on licensee performance and inspector |

insights. For the purposes of completing the baseline inspection program, the number of |

samples completed must be within the range of values specified in each inspection |

procedure. |

Inspection requirements are the controlling factor in determining the amount of inspection

effort necessary to complete the baseline inspections. Appendix A provides an estimate

of the hours associated with each inspection procedure for overall resource planning only.

07.02 Plant Specific Supplemental Inspections

The supplemental element of the inspection program is designed to apply NRC inspection

assets in an increasing manner when performance issues are identified, either by

inspection findings evaluated using the significance determination process (SDP) or when

performance indicator thresholds are exceeded. Accordingly, the NRC regional office will
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assess the need for supplemental inspections after identifying an inspection finding

categorized as risk significant (i.e., white, yellow, or red) with the SDP, or when a

performance indicator exceeds the licensee response band threshold. The scope and

breadth of these inspections will be based upon the guidance provided in the assessment

program’s Action Matrix and expanded upon in the “Supplemental Inspection Selection

Table” included in Appendix B.

Depending on the risk significance and breadth of the identified performance issues, the

supplemental inspections provide a graded response, which includes: oversight of the

licensee’s root cause evaluation of the issues; expansion of the baseline inspection sample

or a focused team inspection (as necessary to evaluate extent of condition); or a broad

scope, multi-disciplined team inspection, which would include inspection of multiple

cornerstone areas and inspection of crosscutting issues. Any new issues identified during

the supplemental inspections will be evaluated by the SDP. The need for additional NRC

actions, including additional supplemental inspections, will be governed by the Action

Matrix.

A supplemental inspection will be performed for all white, yellow, or red issues (either PIs

or inspection findings). The region may choose not to perform a supplemental inspection

for white issues identified as part of a licensee’s self assessment, although such exceptions

are expected to be infrequent. In such instances, the region will still ensure that the issue

is entered into the licensee’s corrective action program and that an appropriate evaluation

is performed. The licensee’s evaluation for such an issue will be reviewed as part of

baseline inspection procedure 71152, “Identification and Resolution of Problems.”

Additionally, the regional offices may choose to propose a deviation from the Action Matrix

when the level of supplemental inspection is not appropriate for the particular

circumstances. Examples of when the level of supplemental inspection may need to be

increased or decreased include (but are not limited to): 1) a single red finding or

performance indicator that does not appear to be indicative of broad programmatic

concerns, 2) a single red inspection finding or performance indicator, particularly those that

meet the criteria for old design issues, 3) multiple examples of non-SDP Severity Level III

or greater enforcement actions, 4) a type of finding unanticipated by the SDP that results

in an inappropriate level of regulatory attention when entered into the Action Matrix. A

deviation from the Action Matrix may be authorized in accordance with IMC 0305,

“Operating Reactor Assessment Program.”

07.03 Generic Safety Issues, Special, and Infrequent Inspections. Concerns with specific

safety issues that arise may be addressed solely through the NRR license review process

and the use of regulatory communications issued to licensees. If the concern is of safety

significance, it may be appropriate to perform a one-time inspection under the safety issues

program element. These inspections will be established by temporary instructions (TIs).

For example, when it is determined that a safety issue addressed in a bulletin or generic

letter requires inspection verification or followup, requirements and guidance for the

inspection will be developed and issued in a TI. Unless such a TI is issued, inspection

followup is not required to verify completion of licensees' actions discussed in a bulletin or

generic letter. When a TI is issued, overall assessment ratings may be considered in

establishing priorities for conducting these inspections. The plants to be inspected will be

designated in the TIs.
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The resources budgeted to safety issues inspections are established by NRR. It is the

intent that the inspections be conducted within the resources budgeted for that element of

the program.

Specific criteria for closing a TI will be addressed in the TI itself. In general, TIs should not

be closed until all relevant safety issue items have been completed by the licensee and

verified by inspection. However, exceptions may be considered when the licensee's

schedule for completing items remaining is acceptable, properly documented, and is not

a critical element to resolving the safety issue.

The need may arise for specific inspections to address major evolutions limited to a few

licensees such as upgrading to a digital control system. The need for these inspections will

also be assessed on a case-by-case basis and conducted under the guidance of a

temporary instruction.

This element of the inspection program also includes other special or infrequently

performed inspections. These inspections may be in response to events, infrequent major

activities at nuclear power plants, or to fulfil the NRC’s obligations under interagency

memoranda of understanding. The applicable procedures are listed in Appendix C,

“Special and Infrequently Performed Inspections.”

07.04 Related Activities Associated with the Reactor Inspection Program. All inspections,

as well as performance indicators reported by licensees, provide input to the plant

performance assessment process. The performance assessment process is to be

conducted in accordance with IMC 0305, “Operating Reactor Assessment Program.”

2515-08 DISCUSSION

08.01 General. The inspection program described in Appendices A, B, and C is intended

to provide the framework for managing inspection resources without being overly

prescriptive. At the same time, a level of inspections necessary to complete pre-defined

objectives at a facility is specified, below which inspection should not decrease. It is

intended to place inspection emphasis on elements of licensee activities most important

to reactor safety, radiation safety, and safeguards.

Using a performance-based, risk-informed approach, inspectors focus their attention on

activities important to safety. Performance-based inspection emphasizes observing

activities and the results of licensee programs over reviewing procedures or records. For

example, an inspector may identify an issue through observing a plant activity in progress,

monitoring equipment performance, or the in-plant results of an activity (e.g. an engineering

calculation). Discussions with plant personnel and reviewing documents should be used

to enhance or verify performance-based observations. These procedures are designed to

emphasize observation of activities, or those portions that are most risk significant in terms

of safety and reliability. It is expected that resident and region-based inspectors will have

the necessary technical capability to accurately observe and evaluate the activity. Regional |

Division Directors and line managers must ensure that inspectors assigned to implement |

the baseline inspection procedures have the necessary training, knowledge, and skills to |

successfully implement the NRR programs. The inspector training and qualification |
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| program will be in accordance with IMC 1245, “Qualification Program for the Office of

| Nuclear Reactor Regulation Programs.” The following baseline inspection procedures will

| normally be performed by regional specialists who have achieved at least Basic

| Certification in accordance with IMC 1245:

|

| • IP71111.02 (Evaluation of Changes, Tests, or Experiments)

| • IP71111.05T(Fire Protection)

| • IP71111.07B (Heat Sink Performance)

| • IP71111.08 (Inservice Inspection Activities)

| • IP71111.11B (Licensed Operator Requalification Program)

| • IP71111.12B (Maintenance Effectiveness)

| • IP71111.17B (Permanent Plant Modifications)

| • IP 71111.21 (Safety System Design and Performance Capability)

| • IP71114 (Reactor Safety Emergency Preparedness - all except attachment 06)

| • IP71121 (Occupational Radiation Safety - all attachments)

| • IP71122 (Public Radiation Safety - all attachments)

| • IP71130 (Physical Protection - all attachments)

|

| The remaining baseline inspection procedures will normally be performed by resident

| inspectors who are at least basic certified. Additionally, based on their qualification and

| experience, regional specialists may also perform baseline inspections other than the ones

| listed above. Likewise, based on their qualifications and experience, resident inspectors

| may also perform baseline inspection procedures normally performed by regional

| specialists.

NRC inspectors perform a basic mission in determining whether a licensee operates the

plant safely and meets current regulatory requirements and commitments. Limiting

inspection to identification of specific instances where a licensee fails to meet such

requirements and commitments could result in correction of symptoms rather than

correction of underlying causes of licensee problems. The inspection and assessment

processes establish thresholds for determining the significance of issues and whether those

issues may require additional evaluation and follow up. Thus, the inspection program

requires that inspectors and their managers evaluate problems to determine if follow up

inspections are necessary to diagnose whether a safety concern represents an isolated

case or may signify a broader, more serious problem based on the evaluated significance

of the issues. Licensee management controls (e.g., QA, safety committees, etc.) may need

to be examined to determine if weaknesses in these controls contributed to identified safety

concerns.

The NRC inspection program covers only small samples of licensee activities in any

particular area. The sample sizes specified in the inspection procedures are based on the

relative importance of the area covered by the procedure to the other areas inspected by

the program. They are also based on the inspectors choosing a “smart” sample instead

of a statistically based random sample because the risk-informed nature of the inspection

program requires the inspections to be focused on those aspects of plant operations and

licensee activities that could pose the greatest risk to public health and safety. The

philosophy behind this concept is that the licensee’s processes are effective if they deal

properly with the items of greatest significance. Some areas (such as reviewing 10 CFR

50.59 evaluations) do not have a direct connection with risk and inspection sample sizes
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in these areas are chosen to provide periodic indications of a licensee’s performance in

those areas.

08.02 Allocation of Resources as a Function of Performance Assessment. The results

of plant performance assessments are an important factor in defining the inspection

program for each plant. The baseline inspections are the level of defined requirements for

all plants and additional regional supplemental inspections will be planned for plants whose

performance is below a certain level, i.e., the licensee response band. The amount and

focus of the additional supplemental inspections will be proportional to the plant’s assessed

performance and the nature of the issues that provide the indication of that performance.

See IMC 0305, “Operating Reactor Assessment Program,” for more detailed guidance on

responding to issues with licensee performance.

Only baseline inspections, applicable generic safety issues, and special and infrequent

inspections will be planned and conducted at plants whose overall performance (all

performance indicators and inspection findings) is determined to be in the licensee

response band.

Plants whose performance is determined to be outside of the licensee response band (see

IMC 0305) should have supplemental inspections planned to examine the root causes of

the change in performance and corrective actions of identified findings or safety issues that

have indicated the performance change.

08.03 Allocation of Resources Among Program Elements. The allocation of resources

among the three principal inspection program elements (baseline, supplemental, and

generic safety issues) is provided for each year in the budget process.

08.04 Completion of Inspection Procedures. The baseline inspection procedures

represent the inspection necessary to allow the NRC to assess performance. This means

that the inspector is to perform the requirements most appropriate to the activity being |

inspected in each inspectable area by completing the number of inspection activities |

(samples) within the range of sample values specified in each inspection procedure, thus |

meeting the objectives of the procedure. Performance of one inspection procedure sample |

may be counted as a sample for another procedure only if completed inspection |

requirements are common to each procedure. The sample size may be reduced to a |

number below the minimum value in situations where there is an insufficient number of |

samples with appropriate risk significance available for inspection (e.g., a reduction of

sample size to zero, if necessary, when no samples exist). Where no sample is specified,

completion of all applicable inspection requirements constitutes completion of the

procedure. The inspection hours estimate, which is included in the inspection procedure

attachments for planning purposes, should not be used to determine whether the

inspection attachment was satisfactorily completed. This estimate is intended to provide

guidelines for inspection planning and budgeting. 

Approval by the Director, Division of Inspection Program Management, NRR, is required

when the inspection requirements in an inspectable area cannot be met. Likewise, each

inspection requirement contained in the supplemental inspection procedures must be

adequately addressed.
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Inspection procedures identify requirements that the inspector must consider while

evaluating the associated area. These requirements may not be the same as NRC

requirements placed on a specific licensee. As such, it is not implied or intended that

inspection program requirements are to be levied on the licensee. Any attempt to force

inspection program requirements on the licensee constitutes misinterpretation of NRC

inspection philosophy and misuse of inspection requirements.

Temporary instructions are issued for specific inspection purposes. For inspections

performed using a temporary instruction, the inspector is expected to complete all

inspection requirements listed.

08.05 Baseline Inspection Credit for Operational Safety Review Team Effort. The

Operational Safety Review Team (OSART) review is performed by senior staff members

from International Atomic Energy Agency member states. The OSART missions offer a

means of assessing licensee performance and reinforcing plant self-assessments through

an independent assessment process. OSARTs focus on the safety and reliability of plant

operation. They review the operation of the plant and the performance of the plant’s

management and staff rather than the adequacy of the plant’s design and compliance with

its licensing basis. Based on a review of sample OSART reports and the OSART

guidelines, the staff determined that although the OSART review is not risk-informed, some

areas of the review overlap with the ROP baseline inspection program. The NRC believes

that it would be beneficial for the U.S. nuclear power industry to continue its participation

in the OSART missions. 

As an incentive to encourage licensee participation in the OSART mission, the NRC grant

a one-time regulatory credit (reduction in baseline inspection program) for those NRC

baseline inspections that overlap, either in part or fully, with the OSART review.

Accordingly, a 25 percent ROP baseline inspection credit shall be given for the following

baseline inspection procedures:

• 71111.22 (Q) “Surveillance Test”

• 71111.5 (Q) “Fire Protection”

• 71121.01 (A) “Access Control to Radiologically Significant Areas”

• 71121.02 (B) “ALARA Planning and Controls”

• 71121.03 (B) “Radiation Monitoring Instrumentation and Protective Equipment”

• 71122.01 (B) “Radioactive Gaseous and Liquid Effluent Treatment and Monitoring

Systems”

• 71122.02 (B) “Radioactive Material Processing and Transportation”

• 71122.03 (B) “Radiological Environmental Monitoring Program and Radioactive Material

Control Program” 

In addition, a 50 percent ROP baseline inspection credit shall be given for the following

inspection procedures:

• IP 71114.03 (B), “Emergency Response Organization Augmentation”

• IP 71114.05 (B) “Correction of Emergency Preparedness Weaknesses and Deficiencies”

• IP 71152 (B) “Identification and Resolution of Problems/Issues”
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In order for the region to take one-time credit for reducing baseline inspections, the areas

for which the credit is to be given must have been documented in the OSART report. In

addition, an NRC staff person should closely monitor the OSART activities, such as

attending the team’s briefings to the licensee. The staff person should assess whether the

regulatory credit assumptions were appropriate. This person also needs a good

understanding of the issues and recommendations made by the OSART. For NRC

planning purposes, this effort is estimated to take approximately 40 hours. Also, the region

should assure that the OSART inspection report is made publicly available. Specific

OSART findings should not normally be referenced or followed-up by the NRC, however,

where a significant safety issue (potentially greater than Green) or a potential violation of

an NRC requirement is identified, the NRC will independently conduct an appropriate

baseline inspection to disposition potential violations and assess the significance of the

finding in accordance with the ROP. These findings will be documented in accordance with

NRC Inspection Manual Chapter (IMC) 0612, “Power Reactor Inspection Reports,” and will

also be processed as performance assessment inputs equivalent to NRC identified findings

in accordance with IMC 0305, “Operating Reactor Assessment Program.” The staff will

perform any additional inspections for those findings that have a significance greater than

Green in accordance with NRC’s Action Matrix. The baseline inspection credit and NRC

staff position described above are communicated to the Commission via a memorandum

dated July 16, 2003 (Adams Accession Numbers: ML031620369, ML030930251,

ML0316020346).

08.06 Baseline Inspection Program Completion and Documentation. The following |

guideline shall be followed when it is expected that required inspection will not completed |

by the end of the calendar year: |

|

a. The missed inspection(s), if any, must be scheduled such that it will be completed |

during the first quarter of the next calendar year. |

b. Inspection procedures which should be implemented during a refueling outage |

cannot be deferred. |

c. Inspections may only be deferred at a plant in the licensee response column of the |

action matrix. |

d. Acceptable reasons for deferring an inspection include unanticipated inspection |

resource demands resulting from providing additional regulatory attention to plants |

which are placed in the IMC-0350 process or in multiple/repetitive degraded |

cornerstone or unacceptable performance columns. (refer to IMC-0305, “Oversight |

of Operating Reactor Facilities in a Shutdown Condition with Performance |

Problems,” for a more detail explanation of these performance columns). |

e. The Director of Division of Reactor Projects (DRP) must notify the Chief of the |

Inspection Program Branch, NRR, via a memorandum if a Region cannot |

complete all the required inspections by the end of the calendar year. This |

memorandum should contain a brief explanation for the reason(s) for deferring the |

inspection(s), the proposed schedule for completing the deferred inspection(s), and |

the tracking method used for completing the required inspections. |

|

In addition, the Regions must maintain an inspection tracking system which will allow them |

to track which inspections cannot be completed in the calendar year so that no more than |

four procedures are deferred for completion in the next ROP cycle. The regions should use |

the guidance provided in IMC 0306, “Information Technology Support for the Reactor |
2515 - 12 - Issue Date: 07/28/05

| Oversight Process,” to track the baseline inspection program completion for each calender

| year and to ensure that the inspection procedures not performed as required by year’s end

| stay within the four-procedure allowance ( but not more than one procedure not done per

| plant). By the end of January of each calender year, the Director of DRP must notify the

| Chief of the Inspection Program Branch, NRR, via a memorandum which states that the

| required baseline inspections have been completed for the previous calender year

| inspection cycle in accordance with IMC 2515. A report that contains the data that

| supports completion of the required inspections (Report 8 from the Reactor Programs

| System, Item Reporting module) should be provided as an attachment to this

| memorandum.

08.07 Program Feedback. The reactor inspection program is expected to be dynamic and

to respond to changes in the nuclear power industry and operational experience.

Therefore, the program office expects the regions and inspectors to identify problems in

implementing the program, and to recommend changes to the program for consideration

by the program office. Any such feedback and recommendations should be submitted to

| IIPB through the associated regional office using the ROP feedback process (IMC 0801).

2515-09 INTEGRATED INSPECTION PLANS

Regional offices must develop annual site-specific inspection plans consistent with the

inspection planning module of the Reactor Program System (RPS) to help manage

inspection resources and monitor the inspection programs. Under circumstances where

the operation of multiple units at a site is not comparable (e.g., Millstone), the inspection

plan should be specific for each unit. The regional integrated inspection plan (i.e., the

integration of individual site or unit plans) should project the planned inspection activities

and available resources for all sites for at least the next 12 months. The integrated plan

should also provide for a summary of the fraction of regional resources allocated to each

of the individual program elements discussed in section 2515-06 of this manual chapter for

each site.

Planning significant alterations to the baseline inspection program for a plant’s annual

inspection plan to accommodate the plant’s particular situation needs the concurrence of

the Chief, Inspection Program Branch. Significant alterations include treating a multi-unit

site as separate single unit sites, or increasing or decreasing the frequency of inspections

or sample sizes from those stated in the baseline inspection procedures. The factors to

consider when planning alterations to the baseline inspection program at a plant site

include (1) known plant activities (or lack thereof), (2) the plant’s size, design, and age, and

(3) complexity of the licensee’s programs.

The results of the end-of-cycle and mid-cycle performance reviews, conducted in

accordance with IMC 0305, shall be used to schedule baseline inspections and to

determine the amount and focus of planned supplemental inspections at each site. The

basis for the allocation or significant reallocation of resources among the sites will be

documented. It is expected that the integrated plans will be living documents and be

reviewed periodically, adjusted, and reissued to reflect shifts in plant performance and

safety concerns. Individual site plans and the regional integrated inspection plan should

be reviewed by regional management and updated at least semiannually as part of the

assessment process that is discussed in IMC 0305.
Issue Date: 07/28/05 - 13 - 2515

2515-10 INDEPENDENT INSPECTION

As a general rule, inspections should be conducted in accordance with inspection

procedures. However, it is not possible to anticipate all the unique circumstances that

might be encountered during the course of a particular inspection and, therefore, individual

inspectors are expected to exercise initiative in conducting inspections, based on their

expertise and experience and risk insights, as needed to assure that all the inspection

objectives are met.

2515-11 INSPECTOR POLICY

11.01 Resident Inspector Policy. The resident inspectors provide the major onsite NRC

presence for direct observation and verification of licensees’ ongoing activities. Appendix

D outlines the responsibilities of resident inspectors for being aware of major activities and

the current status of the plant as NRC’s onsite representative. The resident inspectors also

are primary NRC onsite evaluators for events or incidents. See section 11.3, “Responding

to Events and Event Reports,” below. The greater part of initial event-related inspection

effort will be performed by the resident inspectors, who may be augmented by other

inspectors depending on the type and significance of the event. Regional managers will

decide when normal inspection activities will be resumed by those involved with inspecting

events.

The following is the general policy on the extent to which resident inspectors are to provide

coverage at all sites with one or more units licensed for operation.

1. For sites with at least two resident inspectors, at least one resident inspector or

qualified region-based alternate should provide site coverage during the regular

NRC workday, Monday through Friday. The intent of this guidance is that site

coverage by someone qualified as an inspector not be interrupted for more than

three consecutive NRC working days (n.b., Friday-Tuesday are three consecutive

working days). Consequently, for extended absences of the resident inspectors,

such as for attending inspector counterpart meetings, arrangements should be

made for coverage by region-based staff. The region-based inspectors should be

qualified in accordance with IMC 1245, “Inspector Qualifications.” However, when

qualified region-based inspectors are not available, site coverage can be provided

by an individual that is both knowledgeable and experienced in plant operations,

and capable of communicating with licensee and NRC management on emerging

issues and plant conditions. In order to maximize NRC's efficiency, regional

management should attempt to schedule region-based inspections for this time

period.

2. The Regional Administrator will be notified when the guidance (3 consecutive

working days) cannot be met. All exceptions will be highlighted in the quarterly

update of the regional operating plan.

3. For sites with only a single resident inspector (e.g., because of a vacancy, training,

or extended illness) the guidance described above should be followed to the

maximum extent possible.
2515 - 14 - Issue Date: 07/28/05

4. Inspections performed on Saturdays and Sundays, NRC holidays that are

concurrent with licensee holidays, and weeknight hours between about 10:00 p.m.

and 5:00 a.m., are called “deep” backshift inspections. There are no set hours for

backshift inspections because it is expected that the baseline inspection program

will involve some backshift coverage on a routine basis. Resident inspectors

should collectively devote at least 50 hours of direct inspection and plant status

effort per year per site to deep backshift inspections. (This is a combined effort;

no hours are assigned to an individual resident inspector.) These efforts should

be of at least several hours duration. If deemed appropriate by regional

management, this coverage may be provided by regional inspectors in lieu of or in

addition to that performed by resident inspectors. Credit may be taken for regional

and headquarters inspection coverage in achieving deep backshift coverage goals.

Inspection on holidays will count as deep backshift only if the licensee holiday is

concurrent with the NRC holiday.

5. Inspectors should be sensitive to and avoid being predictable in scheduling their

backshift and deep backshift coverage. In order to maximize the benefit of deep

backshift coverage, inspectors should not develop a predictable pattern. Effort

should be made to spread the deep backshift coverage over a variety of days and

working conditions (outage, normal operations, weekends, nights [including 10 pm

to 5 am], etc.).

6. There is not a specific goal for performing backshift inspections by regional

inspectors, but backshift inspections should be performed whenever required to

complete the intended scope of the inspection.

7. Regional administrators may permanently assign resident inspectors (RIs) to a site

up to 12 months prior to the end of the tour of the incumbent inspector. This limited

“early reassignment” of the resident inspector position, should minimize the

interruption in inspector site coverage that often occurs during the transition of RIs.

Regional administrators may permanently assign senior resident inspectors (SRIs)

to a site up to six months prior to the end of the tour of the incumbent inspector.

This limited “early reassignment” of the senior resident inspector position should

minimize the interruption in inspector site coverage that often occurs during the

transition of SRIs. The “early reassignment” of SRIs should be minimized. 

Personnel actions associated with individuals selected for early assignment will be

the same as those who are assigned to the site to fill a vacant resident inspector

position. However, the regions will use the personnel identification code “PIC”

code “55" for SRIs and “PIC” code “56" for RIs for those who have been early

assigned. The use of these “PIC” codes for the resident inspectors results in the

administrative/overhead fees not being charged to the site. When the departing

RI or Senior Resident Inspector (SRI) leaves the site, the Regions will change the

“PIC” code for the early assigned resident inspectors to “52" or “53,” as

appropriate, within one pay period.

The regions should closely manage the inspection resources at the sites which are

impacted by this program, such that the resources expended to complete the
Issue Date: 07/28/05 - 15 - 2515

NRC’s baseline inspection program are not increased solely as a result of the

additional resident inspector(s) being assigned to the site. 

11.02 Regional Inspector Policy. Regional inspectors conduct inspections as directed by

their supervisors. In addition to baseline inspection program procedures, regional

inspectors often will conduct inspections under other program elements described in this

chapter. Certain aspects of their inspection activity may be conducted in the regional

office; e.g., portions of procedure review and administrative program inspection.

11.03 Inspection Coordination. The senior resident inspector and the regional Division

of Reactor Projects must be kept advised of regional and headquarters inspectors’ activities

at the facility. The associated regional branch chief must ensure coordination of regional

and headquarters inspection activities in accordance with IMC 0301, "Coordination of NRC

Visits to Commercial Reactor Sites."

Regional and headquarters-based inspectors should contact the senior resident inspector

before each inspection to get information concerning the availability of specific licensee

personnel and the status of plant conditions that may affect the planned inspection. In

addition, they should contact the senior resident inspector as soon as is convenient after

they arrive at the site to ensure a coordinated NRC presence at the facility. The visiting

inspectors should advise the senior resident inspector of changes to their planned

inspection effort and schedule for the exit interview with the licensee. The senior resident

inspector should inform the regional and headquarters inspectors of any unique activities

in progress and offer specific inspection suggestions. The regional and headquarters

inspectors should brief the senior resident inspector about the results of their inspection

before the exit meeting with the licensee’s management. The senior resident inspector (or

resident inspector in his absence) should attend all exit meetings where significant issues

are expected to be discussed.

11.04 Third Party Assistance. On occasion licensees ask inspectors for

recommendations for obtaining help solving programmatic problems. Inspectors are

prohibited from recommending the services of individuals or organizations for a project

under NRC regulatory jurisdiction. Providing such a recommendation violates 5 C.F.R.

2635.702, which prohibits Federal employees from using public office for endorsement of

any product, service, or enterprise. For further information refer to the Executive Director

for Operations’ (EDO’s) Field Policy Manual No. 19, "Guidance For Recommending Third

Party Assistance to Licensees," which can found at the following Internet Web address:

(http://www.nrc.gov).

2515-12 GENERAL INSPECTION POLICIES

12.01 Management Entrance and Exit Meetings. Inspectors are required to meet with

licensee management as part of every inspection. Region-based inspectors should hold

an entrance meeting with the senior licensee representative who has responsibility for the

areas to be inspected. Each inspection conducted by resident inspectors and region-based

inspectors must include discussing inspection results with licensee management. At the

conclusion of an inspection, inspectors must discuss their preliminary findings with the

licensee’s management at a scheduled exit meeting. Management and exit meetings with
2515 - 16 - Issue Date: 07/28/05

licensee personnel should be scheduled to have the minimum impact on other licensee

activities necessary to assure the safe operation of the plant.

Time spent on scheduled and periodic entrance and exit meetings (including preparing for

the meetings) is considered part of preparation and documentation of inspections.

Entrance meeting time is charged to preparation and exit meeting time is charged to

documentation. Daily communications with licensee management is considered to be an

integral part of every inspection procedure and the time used for such routine

communications should be charged to the inspection procedures used.

Communicating inspection observations also is an integral and important part of every

inspection, whether done daily during the course of an inspection, or periodically with status

meetings. Many licensees have expressed the desire to hear inspector insights related to

safety/regulatory performance even in instances where they do not reach the threshold for

documentation in an inspection report (see IMC 0612, “Reactor Inspection Reports”).

When deciding which observations and insights to pass on to the licensee, inspectors

should consider the following:

1. Inspectors should share the same insights with their regional managers and the

senior resident inspector.

2. The insights must relate to areas within NRC’s jurisdiction and responsibilities.

3. Comments should be objective and supported with examples when possible. Avoid

generalizations such as “procedure adherence was good.” Instead, just state the

objective facts: “Procedures were followed in each case we observed.” Negative

observations or insights must be supported with specific examples.

4. Inspectors should not express an expectation for actions taken by licensee

managers. The inspector may comment on whether or not the actions comply with

NRC requirements.

5. Inspectors should determine before the exit if the licensee wants to hear the

observations and insights. If the licensee does not want the observations or

insights at the exit meeting, the inspectors should not discuss them.

6. Inspectors should avoid “consulting” for the licensee and not advise them on how

to improve draft documents or in-process work, or pass on to licensees how other

licensees do the same thing.

12.02 Review of Updated Final Safety Analysis Report (UFSAR)

For planning inspections, several baseline inspection procedures specify reviewing

applicable portions of the plant’s UFSAR. This review is intended to provide the inspectors

with design bases insights in preparing for inspections and is not intended to be a review

of UFSAR accuracy. The general focus of the baseline inspection program is to monitor

licensee performance, therefore UFSAR accuracy will not be routinely inspected, although

it is a source of information for inspections.
Issue Date: 07/28/05 - 17 - 2515

However, the NRC does rely on the accuracy of the UFSAR in making informed licensing

decisions on changes; therefore limited requirements for UFSAR accuracy may be

incorporated into specific inspection procedures. Perform these inspection requirements

as directed by the implementing procedure.

12.03 Responding to Events and Event Reports. Routine events of low significance, such

as uncomplicated reactor trips, will be followed up by resident or region-based inspectors

to verify that the events are not complicated by loss of mitigation equipment or other

factors. This event follow up is part of the baseline inspection program, and emphasizes

collecting information about the event for use by risk analysts in evaluating the risk

significance of the event to help regional and headquarters management determine if a

response beyond the baseline program is warranted.

The significance of operational events is evaluated using the Conditional Core Damage

Probability (CCDP) metric, which best reflects the full extent of any loss of defense-in-depth

due to the event, in conjunction with various deterministic criteria to address the most

influential related assumptions and uncertainties. The significance is determined

regardless of whether the cause is due to licensee performance or otherwise.

The agency’s response to significant events is described in NRC Management Directive

8.3, “NRC Incident Response Program.” In general, significant operational events may be

investigated by multi-disciplined Incident Investigation Teams (IITs) that are initiated by the

EDO, and are comprised of both regional and headquarters personnel. Operational events

of lesser significance may be investigated by Augmented Inspection Teams (AITs) that are

initiated by Regional Administrators. Regional Administrators may also initiate special

inspection (SI) teams that use only regional personnel. The applicable procedures for AITs

and SI teams are listed in Appendix C, “Special and Infrequently Performed Inspections.”

In addition, for an event of extraordinary safety significance or profound regulatory

implications, an Accident Review Group may be formed that reports directly to the

Commission, as described in Management Directive 8.9, “Accident Investigation.”

Licensees often notify inspectors of events or conditions in anticipation of the inspectors’

interest in the issue, but such notifications do not exempt the licensee from reporting events

and conditions through the required regulatory processes. The licensee should be made

aware that documents that it gives to inspectors are subject to Freedom of Information Act

requests and may be placed in the Public Document Room.

In addition to reviewing plant events to determine whether the NRC should devote

additional effort and resources to respond to the event, the baseline inspection program

screens for potential risk significance and possible future inspection all written event reports

submitted to the NRC by licensees. The review should be acknowledged in an inspection

report.

12.04 Findings Outside of Inspector’s Qualifications. Inspectors sometimes identify

issues or violations outside of the inspector’s qualifications or expertise. In these cases the

inspector is responsible for (1) determining if an immediate threat to public or worker health

or safety exists, and if one does exist to notify licensee management immediately,

(2) determining if the issue is better addressed by an inspector with different qualifications

(i.e., a specialist inspector). Inspectors may follow issues outside of their qualifications or
2515 - 18 - Issue Date: 07/28/05

expertise with the concurrence of a regional manager responsible for the area associated

with the issue and the inspector’s supervisor.

Such issues are associated with the most applicable cornerstone and inspectable area,

regardless of the baseline inspection procedure in use when the issue is identified. The

inspector’s time associated with the issue is charged to the baseline procedure that best

corresponds to the issue. If the issue is found during inspections other than baseline

inspections, the time is charged to the procedure in use.

12.05 Communication With Local Public Officials. As a matter of management

philosophy, the NRC maintains an “open door” policy with regard to access by the public

or state and local officials to the NRC staff or to publicly available electronic documentation

concerning a licensee's performance. Some local officials may desire increased interaction

with the NRC's regional offices and Resident Inspectors. The degree of interaction that is

considered necessary to enhance public confidence in the NRC is expected to vary widely

dependant upon the situation at each plant. In each case where inspectors are utilized for

this purpose, regional management must carefully balance the use of inspection resources

to complete inspections with the need to enhance public confidence. Any meeting between

local emergency preparedness officials and the NRC must be coordinated with the Federal

Emergency Management Agency (FEMA) in accordance with the Memorandum of

Understanding between FEMA and the NRC. 

2515-13 POST-LICENSE RENEWAL INSPECTIONS

13.01 Post-License Renewal Inspection Effort. Inspection Procedure (IP) 71003, “PostApproval Site Inspection For License Renewal,” is to be implemented to verify that license

renewal programs and activities have been implemented in accordance with the

requirements of Title 10 of the Code of Federal Regulations, Part 54. This inspection will

be performed as a team inspection effort and will be performed just once per unit. For that

reason IP 71003 is listed in Appendix C to this manual chapter.

13.02 Budget Planning. IP 71003 is not part of the baseline inspection program and is

not budgeted as part of the baseline inspection program. Therefore, to ensure that

inspector resources are available to complete this IP when required, planning for its

performance must be projected a minimum of three years in advance of the fiscal year in

which it is planned to be used. 

END

Appendices:

A. Risk-Informed Baseline Inspection Program

B. Supplemental Inspection Program

C. Generic, Special, and Infrequent Inspections

D. Plant Status