Manual Chapter 2515

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Light-Water Reactor Inspection Program--Operations Phase

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. In certain cases, completion of some inspection requirements may be accomplished through other inspections. See 2515-07.04.

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."

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."

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)--and then let the observed discrepancy or uncertainty lead to evaluation of other associated areas. 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.

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.

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.

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.

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.

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.

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 0610*, "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.

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.

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."

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.

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.