Many requirements are specified in licensee written administrative controls. There may be conditions where licensee administrative controls are informal and appear to be inadequate for the task, or where they simply do not exist. In these instances, the inspector should, as generally directed throughout the inspection program, continue to verify licensee activities through performance based inspection observations. If the licensee is performing the function safely and in accordance with the requirements, regardless of the formality or quality of their administrative controls, the inspector should find this acceptable. Problems in procedure implementation should be brought to the attention of appropriate regional management and the NRR project manager.
Procedures provide an approved method of conducting activities and reduce reliance on memory.
Their use minimizes rapid analysis and judgments, which could lead to problems. The level of procedural controls will depend on the type and extent of use of non-power reactor. The licensee should not be required to have the procedure open and follow specific steps sequentially if the activity is being conducted by a qualified operator, and if the specific steps are routine, within the skill of the trade, and can be memorized easily. In these observations the inspector should consider licensee past performance, that is, were activities properly accomplished. A facility that is used only for routinely repeated functions and has a low operator turnover should have simple, less detailed procedures.