ML21326A291

IMC 2901 Team Inspections

ML21326A291
Person / Time
Issue date:	05/20/2022
From:	Shawn Campbell NRC/NRR/DRO/IRIB
To:
Stephen.Campbell@nrc.gov 301-415-3353
Shared Package
ML22119A270, ML21328A172, ML22098A222	List:
References
CN 22-010, DC 21-023, DC 22-007
Download: ML21326A291 (5)

Text

NRC INSPECTION MANUAL IRIB MANUAL CHAPTER 2901 TEAM INSPECTIONS 2901-01 PURPOSE To capture key items that should be considered when performing team inspections at operating power reactor licensee facilities.

2901-02 OBJECTIVES 02.01 To specify the responsibilities and authorities for team inspections.

02.02 To provide guidance on the key elements of a team inspection.

2901-03 DEFINITION Team Inspection. For the purposes of this chapter, a team inspection is a major activity that is subject to the scheduling controls defined in IMC 0301, Coordination of NRC Visits to Commercial Reactor Sites. and IMC 0305, Operating Reactor Assessment Program. Team inspections at operating power reactor facilities are typically scheduled, planned, and conducted by regional inspectors and by some headquarters program offices. An inspection is considered a team inspection when designated as such by the lead office (typically involves three or more inspectors).

2901-04 RESPONSIBILITIES AND AUTHORITIES 04.01 Program Offices

a. Coordinate contractor technical assistance for team inspections within allocated funds.

b. Coordinate regional requests for Headquarter Staff to participate in the conduct of inspection activities (see IMC 2515, Light Water Reactor Inspection Program Operations Phase for additional details).

04.02 Branch Chiefs

a. Ensure team inspections are coordinated and scheduled in accordance with IMC 0301, and 0305.

b. Ensure team inspections are properly scheduled in Reactor Program System -

Inspections module (RPS-Inspections) and time charges accurately accounted for in Human Resources Management System (HRMS) in accordance with IMC 0306, Planning, Scheduling, Tracking and Reporting of the Reactor Oversight Process (ROP).

Issue Date: 05/20/22 1 2901

04.03 Inspection Team Leader and Members

a. The team leader serves as the technical supervisor of the team and directs inspector activities and responsible for direct oversight of contractor support. The team leader should not conduct activities which are reserved for NRC management (i.e., approving overtime, taking disciplinary action, or changing/approving leave).

b. During all phases of the team inspection (preparation, on-site inspection activities, and documentation), team members should report to the team leader.

To ensure inspectors are as efficient and effective as possible while performing their assigned activities during the inspection, they should not work on other assignments to the extent possible. All team members need to accurately report time spent performing all inspection activities in accordance with IMC 0306 and by the Office of the Chief Financial Officer.

2901-05 GENERAL GUIDANCE 05.01 Scheduling of Team Inspections

a. Attempts should be made to avoid performing team inspections during outages and other site activities that would limit or prevent the licensee from supporting the team when on-site. See IMC 0306 for additional details concerning the scheduling of inspection activities.

b. Sufficient time for inspection preparation and documentation should be scheduled for all inspectors. Consideration should be given to holidays, leave, and training activities to ensure that these activities do not detract from inspection preparation and documentation efforts.

05.02 Planning and Preparation for Team Inspections

a. The team leader and/or one or more team members may choose to perform pre-inspection preparation activities (aka bagman trip). This typically consists of a visit to the facility to establish contacts, gather background information that is needed for inspection preparation, and define what support (e.g., office space, information technology, contacts, etc..) the NRC may need from the licensee for the team inspection.

Coordinating and collecting information can also be accomplished remotely through electronic means. See IMC 0620, Inspection Documents and Records, for additional details on requesting, creating, controlling, and dispositioning documents and records collected as part of the inspection. The licensee should receive sufficient advance notification to ensure that materials needed for the inspection will be available.

The resident inspection staff should be consulted to gain their insights into licensee performance and equipment issues. Senior Risk Analysts should also be consulted to assist in identifying risk significant systems, components, and structures.

b. The team leader is responsible for developing an inspection plan that contains technical and logistical details of the inspection. The team leader should also verify that the inspection has been properly scheduled in RPS in accordance with IMC 0306.

Issue Date: 05/20/22 2 2901

c. Each team member dedicates sufficient time to inspection preparation so that they can conduct inspections effectively. Preparation includes becoming familiar with the licensees organization and processes; history of problems at the plant; recent inspection findings; licensee work underway or planned; operating experience, and relevant documents.

Based on their review each inspection team members should develop individual inspection plans for their specific inspection areas assigned to them by the team leader, including the inspection samples and documents to be reviewed.

05.03 Communication During Team Inspections IMC 0620 provides guidance regarding team meetings, licensee, vendor, or applicant debrief, and exit meetings.

a. At the start of the inspection, the team leader should conduct an entrance in meeting in accordance with IMC 2515 with key licensee personnel and management. Entrance meetings provide an opportunity for team leader to communicate with licensees and may include introducing team members, clarifying the scope of the inspection, and confirming licensee and NRC points of contacts, and other logistical items relevant to the inspection.

b. The team leader should conduct daily team meetings to coordinate activities and identify problem areas that may need additional inspection effort. The synergism of team meetings allows related inspection findings in different areas to be brought together. It also provides team members insights through interfacing with other disciplines.

c. The team leader should conduct daily debriefs with the key licensee personnel, such as regulatory assurance to provide a status of the inspection and to communicate any potential issues.

d. At the conclusion of the inspection, the team should conduct an exit meeting with a member of the licensees senior management team and other key personnel involved with the inspection to provide a summary of the inspection results. The exit meeting provides an opportunity to communicate issues with the licensee, such as Findings, Violations, and Observations and to acknowledge whether the team was in position of any proprietary or safeguarded information, and that publicly available information would be shared with the public when appropriate. The team leader, in consultation with their management, has the responsibility to decide what to include in the NRC's presentation to the licensee and which team members should make presentations at the exit meeting.

The team leader should verbally debrief the resident inspectors on the results of the inspection prior to the exit; and provide them the exit meeting logistical details so they can attend if needed.

05.04 Documenting Results of the Inspection

a. Document the inspection results per the requirements of the applicable team inspection procedure, and IMC 0611, Power Reactor Inspection Reports. All performance deficiencies identified by the team need to be reviewed in accordance with IMC 0612, Issue Screening.

Issue Date: 05/20/22 3 2901

b. All inspections are to be documented in RPS-Inspection Module in accordance with IMC 0306.

2901-06 REFERENCES IMC 0301, Coordination of NRC Visits to Commercial Reactor Sites IMC 0305, Operating Reactor Assessment Program IMC 0306, Planning, Scheduling, Tracking and Reporting of the Reactor Oversight Process (ROP)

IMC 0611, Power Reactor Inspection Reports IMC 0612, Issue Screening IMC 0620, Inspection Documents and Records IMC 1245, Qualification Program for Reactor Inspectors.

IMC 2201, Appendix A, Security Baseline Inspection Program IMC 2515, Appendix A, Risk-Informed Baseline Inspection Program END Issue Date: 05/20/22 4 2901

Attachment 1: Revision History for IMC 2901 Commitment Accession Number Description of Change Description of Comment Resolution Tracking Issue Date Training and Closed Feedback Number Change Notice Required and Form Accession Completion Date Number (Pre-Decisional Non-Public Information)

N/A Completed 4-year CN historical Change Notice N/A Search N/A ML21326A291 Significant update to align with current practices N/A ML22098A227 05/20/22 and clarified Purpose, Objective, Definition, and CN 22-010 Responsibilities and Authorities sections so that the document provides high-level guidance applicable to all team inspections. Incorporated in Section 05.02 a. the ability to coordinate and collect information remotely via electronic means.

Issue Date: 05/20/22 Att1-1 2901