Issue Date: 09/28/1998

NRC INSPECTION MANUAL PIPB


MANUAL CHAPTER 2515



Light-Water Reactor Inspection Program - Operations Phase

2515-01 PURPOSE

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

2515-02 OBJECTIVES

02.01 To obtain sufficient information, primarily through direct observation and verification of licensee activities, to ascertain whether reactor facilities are being operated safely and in compliance with license and regulatory requirements.

02.02 Ensure that the licensee's systems and techniques for conducting internal inspections and maintaining control result in safe operations.

02.03 Find and resolve plant-specific safety concerns that have generic significance.

02.04 Identify significant declining trends in licensee performance and perform inspections to verify that the licensee has resolved these trends before performance declines below an acceptable level.

02.05 Evaluate a licensee's ability to respond to the external design basis threat by focusing on: (1) the interactions between a licensee's operations and security departments in establishing priorities for protecting equipment and (2) the protective strategies used.

02.06 Review the impact of security measures on safe plant operations.

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) will 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 (c.f., IMC 2561, "Decommissioning Power Reactor Inspection Program").

2515-04 DEFINITIONS OF INSPECTION FREQUENCIES

SALP Cycle (C): The inspection effort should be performed during every SALP evaluation period. Normally, the inspection effort would be performed approximately every 18 months; however, the inspection period may be shorter or longer when the SALP evaluation period has been adjusted by the Regional Administrator.
Every Other SALP Cycle (O): The inspection effort should be performed during every other SALP evaluation period.
Every Two Years (Z): The inspection effort should be performed every 2 years so that the interval between inspection is no less than 21 months and no greater than 27 months.
Annually (A): The inspection effort should be performed every year so that the interval between inspections is no less than 9 months and no greater than 15 months.
Semiannually (S): The inspection effort should be performed two times each year so that the interval between inspections is no less than 4 months and no greater than 8 months.
Quarterly (Q): The inspection effort should be performed four times each year so that the interval between inspections is no less than 2 months and no more than 4 months.
Bimonthly (B): The inspection effort should be performed approximately every two months so that the interval between inspections is no less than 1 month and no more than 3 months.
Monthly (M): The inspection effort should be performed approximately on a monthly basis so that the interval between inspections is no less than 20 days and no greater than 40 days.
Weekly (W): The inspection effort should normally be performed at least once every week.
Biweekly (X): The inspection effort should normally be performed at least once during each two weeks.
When Required (R): 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.
Nominal (N): The inspection effort should be performed in 7-year intervals.

2515-05 RESPONSIBILITIES AND AUTHORITIES

05.01 Director, Office of Nuclear Reactor Regulation
    a. Provides overall program direction for the reactor inspection program.
b. Selects, subject to review and approval by the Commission, the area to receive special emphasis under the generic safety issue team inspection program element.
c. Develops and directs the implementation of policies, programs, and procedures for regional and headquarters inspection of applicants, licensees, and other organizations subject to NRC jurisdiction.
d. Assesses the effectiveness, uniformity, and completeness of regional implementation of the reactor inspection program.
05.02 Director, Division of Inspection and Support Programs.

Manages inspection program development within NRR, develops and prepares revisions to the reactor inspection program, and serves as the NRR contact with the Regional Offices in the area of program development.

05.03 Directors, Technical Divisions, NRR.

Develop the technical content and prepare periodic revisions to the requirements and guidance contained in inspection procedures related to their areas of responsibility.

05.04 Regional Administrator
    a. Provides program direction for management and implementation of the inspection program elements performed by the 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 initiatives and reactive inspections.
c. Determines whether inspections conducted under inspection program elements other than those in the core program may satisfy core inspection requirements and, at his discretion, takes credit for those core program inspection procedures whose requirements have been satisfied.
d. Applies inspection resources, as necessary, to deal with issues and problems at specific plants.
05.05 Chief, Safeguards Branch, NRR
    a. Provides direction for management and implementation of the Operational Safeguards Response Evaluation (0SRE) program.
b. Has primary signature authority for OSRE reports.
c. Issues OSRE reports with the concurrence of the Associate Director for Projects, or the Director, Division of Reactor Projects.

2515-06 OPERATING REACTOR INSPECTION PROGRAM ELEMENTS

The inspection program described in this manual chapter is comprised of the following three major program elements:

1. Core Inspections
2. Plant Specific Regional Initiative Inspections
- Regional Initiative Inspections
- Reactive Inspections
- Team Inspections (IP 938XX Series)
3. Safety Issue Inspections
The core inspection program element, described in Appendix A, is to be performed at all operating reactors. It requires inspections of licensee performance in functional areas, such as plant operations, maintenance, engineering, and plant support. Safety issue inspections are performed at designated reactors. The plant specific regional initiative inspections described in Appendix B and later in this section, are to be performed based of plant performance in each functional area, and s needed to follow up on operational events and safety issues and to further investigate the root causes and corrective actions related to inspection findings.
Each of the three major inspection program elements is important in achieving the objectives of this manual chapter. The core and generic safety issues inspections constitute an adequate level of inspection at the top performing plants in the country (i.e., plants with SALP Category 1 ratings in most areas). All other plants will receive additional plant specific regional initiative inspection effort based on their performance in various SALP functional areas.
Overall, the inspection program emphasizes achieving a balanced look at a cross section of licensee activities important to plant safety and reliability, and at other licensee activities that may warrant additional attention. The inspection program provides Regional Administrators flexibility in the application of inspection resources to deal with issues and problems at specific plants.
06.01 Core Inspections.

The core inspections provide a minimum cross section examination of licensee activities in order to confirm licensee performance and identify potential problems in their early stages. The core inspections are performed by the resident and region-based inspectors. It is the intent of the program that in-depth examinations of specialty areas, such as radiological controls, emergency preparedness, and physical security, will be performed by region-based specialists. Problem identification in the early stage could result in additional in-depth inspection by assignment of additional regional or NRR resources under other program elements, usually regional initiative. When problems with licensee performance are identified, these inspections should, where applicable, examine root causes and the failures in licensee management controls (including quality programs) which allowed these problems to occur.

The core inspection procedures must be completed at every plant at a prescribed interval. In certain cases, completion of some inspection requirements may be accomplished through other inspections. See 2515-07.05. The inspection procedures included in the core inspections are based on experience relative to (1) the safety significance of the area to be inspected, (2) the need to ensure that all SALP areas are inspected at every plant, (3) the limitations imposed by available resources, (4) an appropriate balance of resources between the various parts of the overall inspection program, and (5) the general and plant specific perspectives from probabilistic risk assessments. The results of inspections performed under the core inspection program element provide the bases to assess plant performance by focusing the inspection process on functional areas that affect plant safety and reliability. The core inspections are performance-base and mphasize the observation and evaluation of ongoing facility operations and supporting activities affecting the safety function of facility structures, systems, and components. The core inspections also emphasize the effectiveness of program implementation and minimize detailed reviews of program descriptions and related procedures.

The programmatic requirements of the core inspection program element are controlled to be consistent with allocated resources. The inspection procedures included in the core inspection program element are reviewed periodically by NRR and the Regional Offices and revised as necessary to enhance the program for the early identification of safety problems.

Appendix A contains a list of core inspection procedures and specifies the required frequency for their performance. Some functional areas allow use of different inspection procedures to satisfy core inspection requirements. For example, in the engineering area, core inspection requirements are satisfied through completion of either inspection procedures IP 37550, IP 93801, or IP 93809. The selection of which IP will be used is determined the region as part of the periodic Plant Performance Review (PPR) process. Any of these IP inspections are to be conducted in a team format. IP 37001 will also be performed in conjunction with either IP 37550, IP 93801, or IP 93809.

Appendix A also provides an estimate of the hours associated with each inspection procedure. These hours refer to the estimated average times to complete an inspection procedure at single, dual, and triple unit sites. The estimates include consideration of the effort needed for the early identification of problems and detection of declining performance. These estimates are not goals, standards, or limitations; rather, they are included to assist in planning resource allocations, and will be revised periodically, based on actual performance experience. It is expected that the actual hours required to complete an inspection procedure at a particular plant may vary from the estimate.

Actual inspection hours expended on the core program can be more or less than the estimates contained in Appendix A. The inspection hours allocated for the core program in each inspection procedure are only an estimate for a typical plant for budgeting purposes. In reality, there is a range of expected inspection effort for each inspection procedure. Most inspections at superior performers would generally be completed in less that the estimated hours. The superior performers normally have better defined and documented programs and should be easier to inspect. However, all of the objectives of the core program inspection procedures must be met. It is very important that a minimum set of inspection procedure attributes be inspected so that valid conclusions can be reached. The hours expended during an inspection should be tailored for the licensee and accurately recorded.

06.02 Plant Specific Regional Initiative Inspections
    a. General. The Regional Administrator has been allocated a specific quantity of discretionary inspection program resources to apply to plants that require additional inspection effort. The additional inspection is based on plant performance in each functional area. It is expected that facilities that have received new operating licenses will require additional inspection for at least the first two operational SALP cycles, particularly when the reactor is the first reactor at a multi-unit site to reach this phase.
b. Regional Initiative Inspections. The Regional Administrator identifies the specific inspection activities and the plants at which regional initiatives apply. The need to perform regional initiatives can be based on several factors, particularly the results of other inspections, licensee performance, and the results of interactions with licensees. In order to provide structure to the program, the additional inspection effort should be preplanned utilizing selected inspection procedures not included in the core inspection program element. Appendix B is a list of inspection procedures that may be used for regional initiative inspections.
c. Reactive Inspections. Reactive inspections are generally unplanned inspections which are conducted as determined by the Regional Administrator in response to events or issues. This part of the program includes review of allegations and activities performed under Augmented Inspection Team (AIT) procedures. Reactive inspections may also be conducted to follow up on findings from other inspections that require immediate attention.
d. Team Inspections. Team inspections are those which are multi-disciplined in both scope of the inspection and composition of the team. They require a team leader to manage the inspection, coordinate inspection results daily during the inspection, and prepare the inspection report based on input from team members. The Division of Inspection and Support Programs (DISP) is responsible for the development of team inspection procedures.
Team inspections provide an independent, in-depth, and balanced assessment of one or more aspects of licensee performance. These inspections are conducted by headquarters teams (HT) and by regional office teams (RT). The teams under the team inspection element may be comprised of NRR personnel, resident and region-based inspectors, and contractors. Team inspections are scheduled as necessary and within the limitations of IMC 0301, "Coordination of NRC Visits to Commercial Reactor Sites." Team inspections are generally those listed in the 938XX series of inspection procedures. For a uniquely designed team inspection, time should be charged to the 938XX procedure most representative of the inspection performed.
Note that team inspections do not include those inspections in which a group of inspectors is assembled to complete a number of inspection procedures or to perform a broad or in-depth examination of a particular functional area, for example, a health physics inspection. These inspections are normally conducted to complete a scheduled regional initiative inspection or, in some cases, a mixture of regional initiative and core inspection elements.
06.03 Safety Issues Inspections.

As concerns arise with specific safety issues, they may be addressed solely through the NRR license review process and the use of communications issued to the licensee. If the concern is of safety significance, it may be appropriate to initiate a one-time inspection effort under the safety issues program element. These inspection efforts 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 Temporary Instruction. 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, SALP ratings should be considered in establishing priorities for conducting these inspections. Plants to be inspected will be designated in the Temporary Instruction.

The budget resources applied 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. Thus, if requirements exceed resources, it may be necessary to defer or cancel certain TIs or reduce the scope of selected TIs.

Specific criteria for closing a TI will be addressed in the TI itself. In general, TIs should not be closed out until 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 the remaining items is acceptable, properly documented, and is not a critical element to resolving the safety issue.

06.04 Related Activities Associated with the Reactor Inspection Program.

All inspections, as well as many NRR and regional office review activities, provide input to the SALP program evaluations. SALP is an important and integral part of the overall inspection program and evaluation process, and resources are budgeted for this function under inspection programs. The SALP program is to be conducted in accordance with NRC Management Directive 8.6.

06.05 Operational Safeguards Response Evaluation.

On a nominal frequency, usually once every 7 years, or as needed, an OSRE is conducted at a power reactor to affirm a licensee's program for protection against the design basis threat, as described in 10 CFR 73.1(a), and to assess a licensee's access authorization system, as described in 10 CFR 73.55(d)(7)(ii), to verify prompt access to vital equipment during emergency conditions or situations that could lead to emergency conditions. OSREs will also be conducted as needed when significant fundamental changes occur in a licensee's protective strategy or when adverse performance indicators diminish the Commission's confidence that the strategy can be implemented in a reliable and satisfactory manner. NRR leads and usually initiates an OSRE.

An OSRE is a performance-based evaluation that is conducted by a team which usually consists of NRR personnel, a region-based inspector, and contractor personnel. The purpose is to identify weaknesses which could impact a licensee's capability to protect against the design basis threat (DBT). Because licensees' plans seldom contain specific commitments related to performance, OSRE findings are seldom violations. If a performance weakness is such that there is not high assurance the licensee has the capability to protect against the DBT, enforcement action would be taken. Less significant weaknesses are identified in the OSRE report and a response from the licensee is required to address corrective actions planned. Regional inspectors verify implementation of corrective measures during subsequent routine inspections. Any violation identified during an OSRE will be addressed in the OSRE report and enforcement action will be initiated consistent with agency enforcement policy.

2515-07 DISCUSSION

07.01 General.

The inspection program described in Appendices A and B is intended to provide the framework for managing inspection resources without being overly prescriptive. The program allows variations in manpower availability to be accommodated by a specified corresponding program level of effort. At the same time, a minimum level of inspection objectives at a facility is specified, below which inspection must not decrease. It is intended to place inspection emphasis on elements of licensee activities most important to reactor safety and to recognize licensee performance as the basis to manage inspection resources.

Using a "performance-based" approach, inspectors focus their attention on activities important to safety and reliability. Performance-based inspection emphasizes field observation over in-office procedural review or record reviews. 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)--and then let the observed discrepancy or uncertainty lead to evaluation of other areas. Discussions with plant personnel and document reviews 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.

NRC inspectors perform a basic mission in determining that 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 NRC inspection program covers only small samples of licensee activities in any particular area. Thus, the inspection program requires that inspectors and their management evaluate and conduct followup inspections as necessary to evaluate root causes of problems in order to determine whether a safety concern represents an isolated case or may signify a broader, more serious problem. Licensee management controls (e.g., QA, safety committees, etc.) should be examined to determine if weaknesses in these controls contributed to the safety concerns.

07.02 Allocation of Resources as a Function of SALP Rating.

The results of SALP evaluations are an important factor in defining the inspection program for a particular plant.

For a plant rated as SALP 1 in a functional area, it may be appropriate to perform only the core inspection procedures in that area plus any needed generic safety issue inspections. Regional initiatives may be performed as a result of potential problems identified during other inspections or as a result of reported events. The core inspection procedures should be performed to the extent needed to verify that there has not been a significant decline in performance.

For a functional area rated as SALP 2, additional regional initiative should be performed, as may be needed, to examine root causes and corrective actions of identified findings or safety issues.

For a functional area rated as SALP 3, or a plant with most areas rated as SALP 2 or SALP 3, additional regional initiative inspection will be necessary. In addition, the Regional Administrator should consider the use of a team inspection where a number of areas are rated as SALP 3, or are bordering on that rating, and the use of a multi-disciplined team appears to be efficacious in arriving at an integrated assessment of the root causes of prevailing problems.

07.03 Allocation of Resources Among Program Elements.

The allocation of resources among the three principal inspection program elements (core, plant specific regional initiative, and safety issues) is provided for each year in the budget process, with most of the resources allocated to the core program and regional initiative inspections.

07.04 Completion of Inspection Procedures.

Each inspection procedure usually contains many specific inspection requirements. These inspection requirements define those areas to be considered by the inspector, in the performance of the procedure, in order to make a determination that the objective(s) of the procedure have been met. In performing inspection procedures listed in Appendix B (Regional Initiative), regional management may want the inspector to perform just a portion of the procedure or the entire procedure; however, for core inspection procedures, all inspection requirements are to be considered. This means that the inspector is to perform each core procedure inspection requirement to the extent necessary to conclude that the objectives of the inspection procedure have been met. In some cases, this may mean that a specific inspection requirement need not be addressed because the inspector is satisfied from examinations already conducted or from other information that indicates the licensee's activities are acceptable.

For inspections conducted under the plant specific regional initiative and reactive inspection program elements, there is no programmatic degree of completion that must be attained. Rather, the amount of inspection and the degree of completion should be commensurate with the purpose of conducting the particular inspection and should normally be planned before the inspection. This could result in an inspector spending more or less time on the procedure than is indicated in the resource section of the procedure.

Inspection procedures identify requirements that the inspector must consider while evaluating the functional area inspected. 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.

07.05 Completion of Core Inspection Procedures Through Other Inspections.

Inspections conducted under other program elements (e.g., regional initiative and reactive inspections, team inspections, and safety issues inspections) may satisfy some inspection requirements under the core inspection program element. For generic safety issue inspections, early planning is essential to identify those core inspection procedures or parts thereof that will be completed during the inspection.

In addition, Diagnostic Evaluation Team (DET) efforts under the direction of AEOD may satisfy some inspection requirements. Following each diagnostic evaluation, AEOD will convene a meeting among the designated regional office representative, DET functional area leaders, and the DET manager to discuss the scope and depth of the evaluation as it relates to completion of required core or safety issue inspection procedures. The DET manager and the designated regional office representative will jointly sign a memorandum to the Regional Administrator which lists the inspection procedures that may be considered for partial or full credit.

In all these cases, following an assessment of whether a need still exists to complete the core inspection procedures in those areas, the Regional Administrator may take credit for those core inspection requirements satisfied by other inspections. The Master Inspection Plan (2515-08) is appropriately updated by the regional office.

07.06 Feedback Process.

It is through the inspection activity that inspectors evaluate licensed activities as a basis for recommending changes to inspection program requirements. Inspectors must determine whether a matter affecting safety exists and whether substantial additional protection is required. Identification of a safety issue where no licensee commitments or specific regulatory requirements apply is appropriate for inclusion in the feedback process. On the other hand, specific inspection findings that do not point to a safety issue are not appropriate for this feedback process or for enforcement action.

2515-08 INSPECTION PLANS

To facilitate management of inspection resource allocation and tracking of inspection programs, regional offices shall develop site-specific inspection plans consistent with the Master Inspection Planning System (MIPS). Under circumstances where the operation of multiple units at a site is not comparable (e.g., Indian Point), the inspection plan should be specific for each unit. The inspection plans will use core inspections as their base, and will add specific inspection activities (e.g., plant specific regional initiatives, team inspections), to define an overall inspection program for each facility. The regional master 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 master plan should also provide for a summary of the fraction of regional resources allocated to each of the individual program elements discussed in this manual chapter for each site.

The results of the latest SALP evaluation and plant performance review (PPR) shall be used to determine the amount and direction of planned initiative inspection activities at each site. However, the performance-determined inspection activities should be tempered by other circumstances, such as current operational issues, recent events, and trends indicated by recent inspections. The basis for the allocation or significant reallocation of resources among the sites will be documented. It is expected that the master plans will be living documents and be reviewed periodically, adjusted, and documented to reflect shifts in plant performance and safety concerns. However, periodic management reviews and updates of individual plans and the regional master inspection plan should be accomplished at least semiannually as part of the PPR process that is discussed in IMC 0304, "Plant Performance Review." The regional office should maintain contact with the appropriate NRR projects staff to ensure that any new NRR perspectives on plant performance are considered in the development of inspection plans.

2515-09 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, as needed to assure that all the inspection objectives are met.

There is no numeric goal or minimum requirement for independent inspection by any inspector. Independent inspection effort is to be charged to the procedure the inspector has been assigned to conduct, since the effort is directed toward the objectives of that particular procedure. If in the course of conducting an inspection, potential safety concerns outside the scope of the procedure being executed are identified, the concerns should be pursued to the extent necessary to characterize the issues to the inspector's supervisor so that a determination can be made as to the need for and timing of further followup inspection.

2515-10 RESIDENT INSPECTOR POLICY

The resident inspectors provide the major onsite NRC presence for direct observation and verification of licensee ongoing activities. The resident inspectors also are primary NRC onsite evaluators for site events or incidents. The greater part of initial event-related inspection effort will be performed by the resident inspectors, who may be supplemented by other inspectors, depending on the type of 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 during late evening and early morning hours and weekends at all sites with one or more units licensed for operation.

2515-11 REGIONAL AND HEADQUARTERS INSPECTOR POLICY

11.01 Inspection Assignments.

Regional inspectors conduct inspections as directed by their supervisors. In addition to core 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, i.e., portions of procedure review and administrative program inspection.

11.02 Backshift Inspections.

There is not a specific goal for performance of backshift inspections by regional and headquarters inspectors, but such efforts should be performed whenever required to complete the intended scope of the inspection.

11.03 Inspection Coordination.

The senior resident inspector and the Regional Office projects division must be kept apprised of regional and headquarters inspector activities at the facility. The appropriate section chiefs shall 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 the inspection to obtain 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 their arrival at the site to ensure a coordinated NRC presence at the facility. They should advise the senior resident inspector of changes to their planned inspection effort and schedule for the licensee exit interview. 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 interview with licensee management. The senior resident inspector 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. This can create problems inasmuch as inspectors are prohibited from recommending the services or one or more people 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 EDO Field Policy Manual No. 19, "Guidance For Recommending Third Party Assistance to Licensees."

2515-12 GENERAL INSPECTION POLICIES

12.01 Management Entrance and Exit Meetings.

Inspectors are required to conduct meetings with licensee management as part of every inspection. Region-based inspectors should hold an entrance meeting with the appropriate senior licensee representative who has responsibility for the areas to be inspected. Each inspection conducted by resident inspectors and region-based inspectors must include the discussion of inspection results with licensee management. This communication of inspector observations is an integral and important part of every inspection, whether done daily during the course of an inspection, or periodically via status meetings. At the conclusion of an inspection, inspectors must discuss their preliminary findings with licensee management at a scheduled exit meeting. Management and exit meetings with 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 routine entrance and exit meetings and other communications with licensee management is considered to be an integral part of every inspection procedure. The time used for such communications should be charged to the inspection procedures utilized.

12.02 Screening Written Reports.

The core inspection program element provides for inspection of plant events under IP 93702, "Prompt Onsite Response to Events at Operating Power Reactors." The subsequent review of licensees' written reports (IP 90712, Appendix B) should consider the results of prior inspections, as applicable. If warranted, additional inspection may be conducted under the regional initiative program element of this Manual Chapter.

12.03 Probabilistic Risk Assessments.

The results of probabilistic risk assessments (PRAs) provide information relative to plant design, operation, and safety that may not have been explicitly identified previously. This information enhances understanding of weaknesses and strengths of plant hardware and operational activities.

In accordance with the guidance in Appendix C and to the extent that plant-specific risk information is available in usable form, these PRA insights should be considered, along with information on plant experience, in planning the scope of inspections to be conducted under any of the program elements discussed in this chapter, in assessing the significance of identified issues, and in assessing licensee use of PRA insights.

12.04 Review of Updated Final Safety Analysis Report (FSAR).

For each inspection, the inspector will review selected UFSAR commitments for verification. The inspector will review the applicable portion(s) of the UFSAR that relate to inspection activities and verify that the UFSAR commitments have been properly implemented into plant practices. The goal of this effort is to determine the accuracy of the UFSAR regarding existing plant practices and is not intended to change the scope or focus of any planned inspection. This effort is not an attempt to judge the overall completeness of the UFSAR, rather, it is intended to focus on identifying differences between the UFSAR description and the plant.

The type and scope of the inspection must be factored into determining what parts of the UFSAR should be reviewed. For example, when inspecting a maintenance activity on a service water pump, the UFSAR review would be limited to discussions on the service water pump and maintenance activities. However, for a service water team inspection, the entire UFSAR chapter on service water and other related information would be included in the review. Specific attention should be given to the review of operational aspects of systems or equipment which may be described in the USFAR, especially on more recently licensed plants which may have an extensive discussion on the operational modes of systems.

Inspector judgement will be required when determining the scope of the UFSAR review to ensure that excessive time is not spent in this area. The UFSAR review will normally occur while planning/preparing for an inspection; however, for some instances, the review may occur following the actual inspection activity.

12.05 Event Reporting.

NRC regulations require licensees to report various events and conditions to the NRC either through immediate notification or followup reports. Many licensees inform inspectors of events or conditions in anticipation of their interest in the issue. At no time does licensee notification of an individual inspector replace or exempt the licensee from reporting events and conditions through the normal regulatory notification processes. The inspector will remind the licensee of its responsibility to formally notify the NRC when required. Inspectors shall routinely check information received during an inspection and independently determine whether NRC reporting requirements apply.

Similarly, when inspectors are given copies of licensee reports and documents there is an implied agreement to read, digest, and understand such reports. The licensee should be aware that all documents provided to inspectors are subject to Freedom of Information Act requests and may be placed in the Public Document Room. Inspectors do not concur on licensee documents. Inspectors must make licensees aware that their reviews are conducted to judge the adequacy of licensee actions, they do not provide advice on issues, and that the inspector's views are not necessarily final agency positions.

12.06 Inspector Conduct While in the Control Room.

Control room observations and inspections are an integral part of verifying safe plant operations. Inspectors are expected to independently observe operator actions and plant responses as part of control room inspections during both normal and transient conditions. For plant events, inspectors must develop their own independent assessment of licensee performance and plant conditions which will be used as a primary input for NRC response decisions. Activities that form the basis for these assessments may include independent measurements, verifying the accuracy of information, control broad walkdowns (to observe annunciators, process parameters, switch positions, and other instrumentation), or assessment of licensed operator knowledge and involvement of ongoing activities.

The NRC's goal is to perform monitoring and assessment functions with as little impact on the licensee as possible and at the same time ensure NRC evaluations are timely and accurate. During plant events, timely and independent inspector assessments are crucial, however, the degree of interaction with operators may be limited in light of ongoing control room activities. A great deal of inspector judgement must be exercised in establishing a balance between obtaining necessary information and not being intrusive in licensee response activities. The appropriate balance involves numerous variables, including safety significance of the event, complexity of the event, time constraints, and available staffing.

The following guidance is provided to establish a degree of consistency for inspector conduct in the control room. When the NRC activates it's emergency response plan, inspectors should follow the guidance in the applicable emergency response procedure. This guidance is intended for use in situations where the NRC has not activated it's emergency response plan, however an off-normal event has occurred at the plant. Inspectors should note that some of the guidance, such as inspector location in the control room and not interrupting operators, apply to all emergency situations. While this guidance deals mainly with event responses, specific attributes are applicable to inspector interaction with operators during normal conditions in the control room and outside the control room.

    a. During the initial response to events, the assigned Senior Resident Inspector (SRI) or the inspector acting in this capacity is in charge of all other NRC inspectors. These inspectors will respond to the direction of the SRI.
b. The number of inspectors in the control room at any given time should be the minimum number needed to accomplish the agency's work. During an event, there should typically be only one inspector in the control room, unless special circumstances warrant additional inspectors. If multiple inspectors and/or other NRC personnel are in the control room during an event, the SRI or resident inspector will be in charge and will determine and communicate to the other inspectors/personnel what, if any, assistance is needed.
c. Inspectors will adhere to licensee established administrative policies regarding entry into the restricted or "at the controls" area of the control room. For example, the inspector may need to ask the control room SRO or RO for permission to enter the restricted area. Under no circumstances should the inspector demand entry into the "at the controls" area. If such entry is denied, the inspector should escalate the request to license management and inform NRC management of the issue. For general access to the control room the licensee's policy should recognize that inspector access will be unannounced. For inspectors who do not routinely enter the control room, the inspector's identity should be established with the operators during control room entries.
d. While observing ongoing activities in the control room, the inspector should be in a location which is out of the way of operators and does not obstruct their view of the reactor controls and instrumentation, yet the location provides the inspector with a broad view of the control room. An acceptable location outside the restricted "at the controls" area is preferable. It is recognized that short amounts of time in the restricted area may be necessary at appropriate stable time periods to verify significant parameters.
e. Operators should not be interrupted, questioned or otherwise distracted from performing their duties while responding to an event or while performing other duties where their attention must be focused on the task at hand. Also, inspectors should not interfere, interrupt, or otherwise disturb communications between operators and communications between operators and their supervision.
f. If an inspector identifies a significant problem or question about plant or operator safety, which needs to be addressed in an urgent manner, then a discussion should be held in a quiet and quick manner at a time where it will not interrupt ongoing operator actions. This discussion should be held with the shift supervisor or emergency response manager. Non-urgent questions should be held to a more appropriate time.
g. NRC communications with off-site organizations should be conducted by personnel outside the control room if more than one inspector is available. Possible locations would be the NRC phone in the TSC or other phones outside the control room that have been agreed upon with the licensee. This guidance does not prohibit inspectors from making phone calls from the control room. For those occasions where only one inspector is available, initiating a phone call from the control room is acceptable provided the licensee agrees on the use of the phone and the phone conversation will not disrupt control room activities.
h. Because of the authoritative role of the NRC, licensees listen carefully to inspectors and may interpret statements, side remarks, or observations as directives or requirements. Consequently, open, clear, and direct communications between inspectors and licensees are particularly important during events.
12.07 Conference Calls With Licensees During an Ongoing Event.

When initially responding to an event the NRC is dependent upon information provided by licensees and inspectors at the plant (typically resident inspectors). This information is used for initial assessments and response decision-making. Licensee information is typically provided via notification to the NRC Operations Center pursuant to 10 CFR 50.72 and/or conference calls between the staff and the licensee. The NRC values conference calls as an efficient method of obtaining accurate and timely information. Also, they promote a mutual understanding of the facts and any concerns.

When conference calls are held during an ongoing event or situations where heightened licensee attention is being directed to a plant evolution, caution is needed in scheduling and conducting the call. While information obtained in a conference call is extremely valuable to the NRC's overall understanding of a plant event, the overwhelming goal is that a conference call will not interfere or detract from the licensee's ability to safely operate the plant. The following guidance should be utilized for conducting conference calls with licenses during abnormal plant conditions. Examples of abnormal plant conditions would be the declaration of a Notification of Unusual Event (NOUE) or an Emergency Operating Procedure (EOP) currently being utilized.

    a. NRC management should decide whether a conference call with the licensee is needed and if conducting a conference call is appropriate at that particular time. NRC management may want to discuss with senior licensee management the possibility of conducting a conference call. The stability of the plant is the primary factor in deciding on a conference call. Other factors to be considered in this decision include: the current level of NRC staff understanding and information available for the event; the safety significance of the event; the complexity of the event; and the current level of licensee activity in mitigating the event.
b. For the majority of occurrences the licensee should be informed of the NRC's desire to have a conference call by the senior resident inspector or resident inspector if they are available. When scheduling the time for the call, the licensee must be included in deciding the most appropriate time, such that the call does not interfere with plant response activities. Also the licensee should decide which individuals from their staff will participate in the call.
c. When requesting the conference call, the licensee must be clearly informed of the NRC's desire that the conference call will not interfere with their plant response activities and that delaying the call is a continuous option on their part.
d. Appropriate NRC technical staff and management should participate in the conference call to ensure proper questioning and understanding of the event/issues. The senior NRC manager on the call should be identified and responsible for ensuring conference call discussions are properly focused on important issues and that side issues are discussed at a more appropriate time.
e. If time is available, an agenda for the conference call should be developed to ensure the call remains properly focused. The licensee should be informed of the proposed discussion topics and planned NRC participants for their preparation for the call.
f. Any followup actions resulting from the conference call should be summarized by an NRC manager at the end of the call to ensure the licensee clearly understands and agrees with these actions.

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Appendix A: Core Inspection Program Procedures


Appendix B: Regional Initiative and Reactive Inspection Program Procedures


Appendix C: Risk-Based Inspection Guides