ML20236X629
| ML20236X629 | |
| Person / Time | |
|---|---|
| Issue date: | 03/24/1986 |
| From: | Tambling T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Berson B, Davis A, James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20195F761 | List:
|
| References | |
| FOIA-87-714 NUDOCS 8712090346 | |
| Download: ML20236X629 (29) | |
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UNITED STATES
+'g 68 88Cg' ', NUCLEAR REGULATORY COMMisslON
[ 'r , k REClON lif 7.
- -l 7ss noostvcov moAo g GLcN ELLYN, ILUNOl$ 601 U March 24, 1986 MEMORANDUM FOR: Those on Attached List FROM: T. N. Tambling, Director, Enforcement and Investigation Coordination Staff
SUBJECT:
BACKFIT RULE AND NRC MANUAL CHAPTER 0514 Tom Cox of the ED0's office presented a talk during the recent Resident Seminar on the new Backfit Rule anti the NRC Manual Chapter 0514 for implementing the rule. Copies of his viewgraphs were not available at the time of the talk.
Some of these viewgraphs provide an excellent summary or highlight significant points. Attached for your reference and use are copies of some of these viewgraphs.
. . { bc T. N. Tambling N Director, Enforcement and Investigation Coordination Staff
Attachment:
As stated
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8712090346 871204 PDR FDIA ,
WEISS87-714 # j
.PDR f'
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Multiple Addressee March 24, 1986 Addressees James G. Keppler, Regional Administrator A. Bert Davis, Deputy Regional Administrator Bruce A. Berson, Regional Counsel Jack A. Hind. Director, Division of Radiation Safety i and Safeguards Charles E. Norelius, Director, Division of Reactor Projects Carl J. Paperiello, Director, Division of Reactor Safety N. J. Chrissotimos, Deputy Director, Division of Reactor Safety Edward G. Greenman, Deputy Director, Division of Reactor Projects Cordell C. Williams, Special Technical Assistant, DRS DRP Branch Chiefs DRS Branch Chiefs DRSS Branch Chiefs DRP Section Chiefs DRS Section Chiefs DRSS Section Chiefs ..
Senior Resident Inspectors
OBJECTIVES OF REVISED MC-0514 l
- 1. CLARIFY THAT BACKFITTING IS A NECESSARY AND PROPER REGULATORY ACTIVITY
- 2. ESTABLISHED EDO-LEVEL FRAMEWORK FOR GENERAL POLICY
- 3. IMPROVE MANAGEMENT OVERSIGHT OF BACKFITTING PROCESS
- 4. EMPHASIZE THAT THE BACKFITTING PROCESS IN NO WAY RELIEVES THE LICENSEE OF ITS OBLIGATION TO COMPLY WITH NRC REQUIREMENTS
- 5. ARTICULATE THE BACKFITTING PROCESS TO NRC STAFF, INDUSTRY AND THE PUBLIC
- 6. ENHANCE PUBLIC HEALTH AND SAFETY
- 7. IMPROVE REGULATORY STABILITY AND PREDICTABILITY
- 8. PROMOTE CONTINUED NORMAL DIALOGUE BETWEEN REVIEWER / INSPECTOR AND LICENSEE 3/19/86
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4 MAJOR FEATURES OF PLANT-SPECIFIC BACKFITTING PROCESS
- 1. APPLICABLE TO ALL PLANTS
- 3. ADDRESSES 50.54(f) REQUESTS WHICH MAY BE PLANT-SPECIFIC BACKFITS
- 5. A REGULATORY ANALYSI5 IS REQUIRED PRIOR TO IMPOSING A BACKFIT
- 6. REGULATORY ANALYSIS APPROVAL BY OFFICE DIRECTOR / REGIONAL l ADMINISTRATOR PRIOR TO TRANSMITTING TO LICENSEE
- 7. PROVIDE FOR AGENCYWIDE RECORDKEEPING SYSTEM - REAL TIME ACCESS
- 8. APPEAL PROCESS IN REGION AND HEADQUARTERS
- 9. FINAL REGULATORY APPROVAL AUTHORITY IN OFFICE WITH PROGRAMMATIC RESPONSIBILITY
- 10. MANAGEMENT ACCOUNTABILITY THROUGH SES CONTRACTS 3/19/86 l
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GENERAL TERMINOLOGY BACKFIT - A STAFF _ POSITION THAT CAUSES A LICENSEE TO CHANGE DESIGN, CONSTRUCTION OR OPERATION OF A FACILITY FROM THAT CONSISTENT WITH ALREADY APPLICABLE STAFF POSITIONS, AFTER CERTAIN REGULATORY MILESTONES ARE COMPLETED (052) l APPLICABLE REGULATORY STAFF POSITION - A POSITION ALREADY SPECIFICALLY IMPOSED UPON OR COMMITTED TO BY A LICENSEE AT THE TIME OF IDENTIFICATION OF A PLANT-SPECIFIC BACKFIT (053)
GENERIC BACKFIT - APPLYING THE SAME NEW NRC STAFF POSITION ON MORE THAN ONE UNIT ( Od u'MT1- W" .1 b. ; e M ' E'^' " A" # '
u PLANT-SPECIFIC BACKFIT - APPLYING A NEW NRC STAFF POSITION ON A SINGLEUNITfdigdv ' W di L ' 8 V* ' ' '
i LICENSEE - CP HOLDER, OL HOLDER, PDA/FDA FOR STANDARDIZED PLANT l
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BACKFIT MD 0514-052 BACKFITTING IS DEFINED AS THE MODIFICATION OF OR ADDITION TO ,
SYSTEMS, STRUCTURES, COMPONENTS, OR DESIGN OF A FACILITY; OR THE DESIGN APPROVAL OR MANUFACTURING LICENSE FOR A FACILITY; OR THE PROCEDURES OR ORGANIZATION REQUIRED TO DESIGN, CONSTRUCT OR OPERATE A FACILITY; ANY OF WHICH MAY RESULT FROM A NEW OR AMENDED PROVISION IN THE COMMISSION RULES OR THE IMPOSITION OF A REGU-LATORY STAFF POSITION INTERPRETING TIIE COMMISSION RULES THAT IS EITHER NEW OR DIFFERENT FROM A PREVIOUSLY APPLICABLE STAFF POSITION AFTER CERTAIN SPECIFIED DATES. BACKFITTING IS " PLANT-I
$PECIFIC" WHEN IT INVOLVES THE IMPOSITION OF A POSITION THAT IS UNIQUE TO A PARTICULAR UNIT.
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s APPLICABLE REGULATORY STAFF POSITIONS o THOSE ALREADY IMPOSED UPON OR COMMITTED TO BY A LICENSEE l
o THREE BASIC TYPES l
- 1. LEGAL REQUIREMENTS SUCH AS IN EXPLICIT REGULATIONS, ORDERS, PLANT LICENSES (AMENDMENTS, CONDITIONS, TECHNICAL SPECIFICATIONS). NOTE THAT SOME REGULATIONS HAVE UPDATE FEATURES BUILT IN; AS FOR EXAMPLE, 10 CFR 50.55A, CODES AND STANDARDS. SUCH UPDATE REQUIREMENTS ARE APPLICABLE AS DESCRIBED IN THE REGULATION.
- 2. WRITTEN COMMITMENTS SUCH AS CONTAINED IN THE FSAR, LERs, AND DOCKETED CORRESPONDENCE, INCLUDING RESPONSES
.,TO IE BULLETINS, RESPONSES TO GENERIC LETTERS, RESPONSES TO INSPECTION REPORTS, OR RESPONSES TO NOTICE OF VIOLATIONS, AND CONFIRMATORY ACTION LETTERS.
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'4 APPLICABLE REGULATORY STAFF POSITIONS (CONTINUED)
- 3. NRC STAFF POSITIONS THAT ARE DOCUMENTED, APPROVED, EXPLICIT INTERPRETATIONS OF THE MORE GENERAL REGULATIONS, AND ARE CONTAINED IN DOCUMENTS SUCH AS THE SRP, BRANCH TECHNICAL POSITIONS, PEGdLATORY GUIDES, GENERIC LETTERS AND IE BULLETINS, AND TO WHICH A LICENSEE HAS PREVIOUSLY COMMITTED TO OR RELIED UPON.
HOWE"/ER , SUCH POSITIONS AS THESE ARE NOT CONSIDERED APPLICABLE STAFF POSITIONS TO THE EXTENT THAT NRC STAFF HAS, IN A PREVIOUS LICENSING OR INSPECTION ACTION, TACITLY OR EXPLICITLY EXCEPTED THE LICENSEE FROM PART OR ALL OF THE POSITION.
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. 10 TIME OF ISSUANCE THOSE TIMES AFTER WHICH A STAFF POSITION WILL BE CONSIDERED A BACKFIT: .,
- 1. AFTER THE DATE OF ISSUANCE OF THE CONSTRUCTION PERMIT FOR .l THE FACILITY (FOR FACILITIES HAVING CONSTRUCTION PERMITS ISSUED AFTER MAY 1, 1985); OR I
- 2. AFTER 6 MONTHS BEFORE THE DATE OF DOCKETING OF THE OL-APPLICATION FOR THE FACILITY (FOR FACILITIES HAVING CONSTRUCTION PERMITS ISSUED BEFORE MAY 1, 1905); OR
- 3. AFTER THE DATE OF ISSUANCE OF THE OPERATING LICENSE FOR THE FACILITY (FOR FACILITIES HAVING AN OPERATING LICENSE OR MAY 1, 1985); OR
- 4. AFTER THE DATE OF ISSUANCE OF THE DESIGN APPROVAL UNDER 10 CFR 50, APPENDICES M, N OR O.
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' tg INFORMATION REQUESTS
- 1. 10 CFR 50.54(f) HAS BEEN REVISED
- 2. GENERALLY REQUIRES THAT NRC PREPARE REASONS FOR ISSUING INFO REQUESTS
- 3. PLANTS IN CONSTRUCTION - EVALUATION OF REASONS FOR REQUEST NECESSARY ONLY IF REQUEST IS NOT PART OF ROUTINE LICENSING OR INSPECTION REVIEW
- 4. PLANTS IN OPERATION - ONLY 50.54(f) INFO REQUESTS SEEKING TO VERIFY COMPLIANCE WITH CURRENT LICENSING EASIS ARE EXEMPT FROM PREPARATION OF REASONS FOR REQUEST
- 5. OFFICE DIRECTORS / REGIONAL ADMINISTRATORS - WILL INCLUDE TREATMENT OF 50.54(f) INFO REQUESTS IN OFFICE PROCEDURES
- 6. 50.54(f) INFO REQUESTS REQUIRING EVALUATION MUST BE APPROVED PRIOR TO TRANSMITTAL TO LICENSEE l
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INFORMATION REQUESTS (CONTINUED) o
- 7. EVALUATION ELEMENTS:
.A. PROBLEM STATEMENT B. ACTIONS REQUIRED BY LICENSEE C. ANTICIPATED SCHEDULE FOR NRC USE OF INFORMATION 3/19/86
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IDENTIFYING PLANT-SPECIFIC BACKFITS (041)
A. STAFF HAS PRIMARY RESPONSIBILITY:
- 1. INTERNAL DECISION PROCESS
- 2. REGULATORY ANALYSIS
- 3. MANAGEMENT APPROVAL PRIOR TO COMMUNICATING BACKFIT
- 4. NO ANALYSIS NECESSARY UNDER CERTAIN CONDITIONS B. LICENSEE MAY CLAIM BACKFIT:
- 1. SEND TO OFFICE DIRECTOR / REGIONAL ADMINISTRATOR, WITH COPY TO EDO
- 2. NRC STAFF INTERNAL PROCESS
- 3. BACKFIT DETERMINATION
- 4. REPORT TO EDO WITHIN 3 WEEKS OF RECEIPT OF CLAIM i
- 5. LICENSEE INFORMED 3/19/86 i
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WHEN A POSITION IS NOT A BACKFIT
- 1. MODIFICATION IS NECESSARY TO BRING FACILITY INTO COMPLIANCE WITH A LICENSE OR RULES OR ORDERS OF THE COMMISSION, OR
- 2. MODIFICATION IS NECESSARY TO BRING FACILITY INTO CONFORMANCE WITH WRITTEN COMMITMENTS BY THE LICENSEE, OR
- 3. DIRECTOR OF NRR, NMSS, OR IE DETERMINES THAT BACKFIT IS NECESSARY TO ENSURE THAT FACILITY POSES NO UNDUE RISK TO PUBLIC HEALTH AND SAFETY.
I j- NO REGULA, TORY ANALYSIS IS REQUIRED, BUT APPROPRIATE OFFICE DIRECTOR MUST ?ROVIDE A DOCUMENTED EVALUATION TO SUPPORT THE ACTION TAKEN.
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REGULATORY ANALYSIS (043)
- 1. ANALYZE EFFECTS ON PROTECTION OF PUBLIC HEALTH AND SAFETY
- 2. ANALYZE COST OF IMPLEMENTATION OVER PLANT LIFETIME
- 3. OFFICE DIRECTOR / REGIONAL ADMINISTRATOR MUST APPROVE REGULATORY ANALYSIS MAKE BACKFIT DETERMINATION AND FORWARD COPY TO EDO BEFORE TRANSMITTAL TO LICENSEE
- 4. NUREG/BR-0058, REV. 1, REGULATORY ANALYSIS GUIDELINES OF THE U.S. NUCLEAR REGULATORY COMMISSION
- 5. NUREG/CR-3568, A HANDBOOK FOR VALUE-IMPACT ASSESSMENT
- 6. NOT REQUIRED WHEN IMPOSITION OF POSITION IS NECESSARY TO ASSURE NO UNDUE RISK, OR TO COMPLY WITH RULES OR ORDERS, OR TO CONFORM WITH WRITTEN LICENSEE COMMITMENTS 3/19/86
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CONTENT OF REGULATORY ANALYSIS (043)
- 1. STATEMENT OF SPECIFIC OBJECTIVE, BRIEF BACKFIT DESCRIPTION AND HOW SAFETY IS SUBSTANTIALLY IMPROVED
- 2. GENERAL DESCRIPTION OF ACTIVITY REQUIRED OF LICENSEE
- 3. SAFETY IMPACT OF CHANGES IN DESIGN OR OPERATIONAL COMPLEXITY
- 5. COST-BENEFIT ANALYSIS A. PUBLIC RISK IMPACT FROM ACCIDENTAL OFFSITE RELEASES i
B. IMPACT ON OCCUPATIONAL EXPOSURE TO ONSITE WORKERS C. DOLLAR COST OF INITIAL AND CONTINUING IMPLEMENTATION D. RESOURCE COST TO NRC AND AVAILABILITY OF RESOURCES 3/19/86
l CONTENT OF REGULATORY ANALYSIS (043)
- 6. QUALITATIVE FACTORS BEARING ON NEED FOR BACKFIT (OPERATIONAL TRENDS, MANAGEMENT EFFECTIVENESS, SALP, ETC.)
- 7. AFFIRMATION OF INTEROFFICE COORDINATION
- 8. SCHEDULE FOR LICENSEE IMPLEMENTATION AND BASIS
- 9. SCHEDULE FOR STAFF ACTIONS
- 10. PRIORITIZATION IN LIGHT OF OTHER SAFETY RELATED ACTIVITIES I
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FINDINGS OF REGULATORY ANALYSIS
- 1. REGULATORY ANALYSIS SHALL HAVE A
SUMMARY
SECTION STATING OFFICE DIRECTOR / REGIONAL ADMINISTRATOR FINDINGS AND CONCLUSIONS
- 2. TO PROCEED WITH IMPOSITION OF STAFF POSITION, MUST FIND THAT THE POSITION WOULD PROVIDE SUBSTANTIAL INCREASE IN OVERALL PROTECTION AND THAT DIRECT AND INDIRECT COSTS ARE JUSTIFIED IN VIEW OF THE INCREASED PROTECTION.
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APPEAL PROCESS (044)
- 2. TWO KINDS OF APPEALS
- TO REVERSE A STAFF DENIAL OF CLAIM OF BACKFIT TO MODIFY OR WITHDRAW STAFF PROPOSED BACKFIT
- 3. LICENSEE TO ADDRESS APPEALS TO OFFICE DIRECTOR / REGIONAL ADMINISTRATOR (COPY TO EDO)
- 4. WITHIN 3 WEEKS, OFFICE DYRECTOR/ REGIONAL ADMINISTRATOR REPORT TO EDO PLAN FOR RESOLUTION (PROMPTLY INFORM LICENSEE) m
- 5. DECISION ON APPEALS WILL BE MADE BY OFFICE DIRECTOR RESPONSIBLE FOR PROGRAM AREAS UNLESS RESOLVED BY RA OR OTHER MANAGEMENT LEVEL l'
- LICENSING RELATED - NRR EXCEPT FOR SAFEGUARDS (NMSS), QA (IE), EP (IE)
ENFORCEMENT RELATED - IE
- INSPECTION RELATED - IE 1
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i APPEAL PROCESS (044)
- 7. SUMMARIES OF ALL APPEAL MEETINGS SHALL BE PROVIDED TO LICENSEE AND PDR
- 8. APPEAL PROCESS SHOULD FOCUS ON WHETHER OR NOT SAFETY IMPROVED
.SUBSTANTIALLY AT A REASONABLE COST AS DESCRIBED IN REGULATORY ANALYSIS
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IMPLEMENTATION OF BACKFIT (045)
- 2. LICENSEE MAY EITHER APPEAL OR IMPLEMENT
- 3. SCHEDULE FOR IMPLEMENTATION SHOULD BE DEVELOPED IN CONSULTATION WITH LICENSEE
- 4. PROMPT IMPOSITION WITHOU" CONDUCT OF REGULATORY ANALYSIS MUST BE APPROVED BY PROGRAM OFFICE DIRECTOR AND EDO NOTIFIED
- 5. UNLESS PROMPT IMPOSITION NECESSARY, POSITIONS ARE NOT TO BE IMPOSED, PLANT OPERATIONS ARE NOT TO BE INTERRUPTED OR DELAYED DURING REGULATORY ANALYSIS AND APPEAL PROCESSES 3/19/86
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RECORDKEEPING AND REPORTING (046)
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- 1. PLANT-SPECIFIC BACKFIT SYSTEM (PSBS) WAS ON-LINE IN OFFICES AND REGIONS IN JUNE 1985
- 2. EACH OFFICE ADMINISTRATIVELY MANAGES THE SYSTEM
- 3. PROVIDES FOR PROMPT RETRIEVAL / CURRENT STATUS
- 4. SYSTEM CONTENT ;
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- PLANT ID
- SUBSTANCE OF BACKFIT ISSUE STAFF / LICENSEE IDENTIFIED FOR EACH BACKFIT PROCESS ACTIVITY i
o RESPONSIBLE NRC PERSON o PLANNED SCHEDULE o ACCOMPLISHED SCHEDULE o REFERENCES
- FINAL DISPOSITION 3/19/86
FUNDAMENTAL CONCEPTS IN DETERMINING WHETHER A STAFF ACTION IS A BACKFIT
- 1. IS THE POSITION A PREVIOUSLY APPLICABLE REGULATORY STAFF l
POSITION?
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- 2. TIMING OF THE POSITION RELATIVE TO REGULATORY MILESTONES.
- 3. HAS THE LICENSEE REALLY VOLUNTEERED TO TAKE ACTION? l
- 4. ACTIONS PROPOSED BY LICENSEE RESULTING FROM NORMAL STAFF /
LICENSEE DISCUSSIONS CONCERNING AN ISSUE ARE NOT BACKFITS.
- 5. WOULD THE STAFF POSITION CAUSE THE LICENSEE TO CHANGE DESIGN, CONSTRUCTION OR OPERATION?
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- 6. IS THE STAFF ACTION DIRECTING, TELLING OR COERCING, OR MERELY SUGGESTING OR ASKING THE LICENSEE TO CONSIDER THE STAFF PROPOSED ACTION?
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- 7. IS THE LICENSEE IN NONCOMPLIANCE WITH AN NRC REQUIREMENT?
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- 8. IS THE LICENSEE MEETING WRITTEN COMMITMENTS TO THE NRC?
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' SPECIFIC APPLICATIONS INSPECTIONS .
- 1. INSPECTION OF ANY ITEM / ACTIVITY IS NOT BY ITSELF A BACKFIT.
- 2. IDENTIFICATION OF DEFICIENCIES AND DISCUSSIONS WITH LICENSEES REGARDING THE DEFICIENCIES ARL' NOT BACKFITS.
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- 3. LICENSEE AGREEMENT TO TAKE ACTION IN RESPONSE TO INSPECTOR FINDINGS IS NOT A BACKFIT PROVIDED THE LICENSEE IS NOT FACED WITH AN ULTIMATUM.
- 4. IF THE STAFF INDICATES A CERTAIN ACTION IS THE ONLY WAY FOR TaE STAFF TO BE SATISr1ED. THAT ACT10N 15 A BACxrIT. j.
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l SPECIFIC APPLICATIONS INSPECTION (CONTINUED)
EXAMPLES LICENSEE COMMITS TO ANSI-N18.7 IN SAR
- 1. IMPLEMENTING PROCEDURES DO NOT CONTAIN ALL N18.7 REQUIRED ELEMENTS.
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- 2. TELLING LICENSEE HE MUST INCLUDE THEM IS NOT A BACKFIT.
- 3. . IMPLEMENTING PROCEDURES DO NOT CONTAIN CERTAIN N18.7 OPTIONAL -
ELEMENTS. ]
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- 4. TELLING LICENSEE HE MUST INCLUDE THEM I$ A BACKFIT. J
- 5. DISCUSSION WITH THE LICENSEE REGARDING THE MERITS OF INCLUDING THE OPTIONS ITEMS IS NOT A BACKFIT.
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ENFORCEMENT
- 1. ENFORCEMENT OF NRC REQUIREMENTS IS NOT A BACKFIT 2.
A NOTICE OF VIOLATION (NOV) REQUESTING DESCRIPTION OF CORRECTIVE ACTION IS NOT A BACKFIT 3.
LICENSEE COMMITMENTS IN RESPONSE TO NOV ARE NOT BACKFITS.
4.
DISCUSSIONS DURING ENFORCEMENT CONFERENCES AND RESPONSES TO REQUESTS FOR ADVICE ARE NOT BACKFITS.
5.
A STATEMENT TO A LICENSEE DIRECTING A SPECIFIC ACTION TO SATISFY THE STAFF IS A BACKFIT.
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l REANALYSIS OF ISSUES i
OCCASIONALLY THE NRC STAFF MAY CONCLUDE THAT A PREVIOUSLY APPROVED LICENSEE FROGRAM DOES NOT SATISFY A REGULATION, LICENSE CONDITION OR COMMITMENT.
A SUBSEQUENT STAFF SPECIFIED CHANGE IS A BACKFIT
- A LICENSEE VOLUNTARY CilANGE IS NOT A BACKFIT l
EXAMPLE
- 1. LICENSEE IN THE SAR COMMITS TO A CARDOX SYSTEM IN CAPABLE SPREADING ROOM.
- 2. STAFF PUBLISHES AN SER ACCEPTING SYSTEM AND ' LICENSEE (NSTALLS THE SYSTEM.
- 3. STAFF SUBSEQUENTLY REEVALUATES ORIGINAL POSITION AND DECIDES WATER SUPPRESSION SYSTEM IS NEEDED.
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C LICENSING - USE OF SRP
- 1. SRP DELINEATES MANAGEMENT APPROVED SCOPE AND DEPTH OF REVIEW TO GIVE REASONABLE ASSURANCE THAT LICENSEE WILL SATISFY NRC REQUIREMENTS.
- 2. APPLICATION OF A CURRENT SRP IN AN OL REVIEW IS NOT A BACKFIT IF THE SRP WAS EFFECTIVE 6 MONTHS PRIOR TO START OF THE OL REVIEW (6 MONTHS PRIOR TO DOCKETING OL APPLICATION).
- 4. STAFF DISCUSSIONS WITH LICENSEES REGARDING THE MERITS OF j 1
ACTIONS WHILH /h BEYOND SRP CRITERIA ARE NOT BACKFITS UNLESS l THE STAFF LEAVES THE LICENSEE NO OTHER REASONABLE ALTERNATIVE.
- 5. APPLICATION OF SRP CRITERIA TO AN OPERATING PLANT GENERALLY IS CONSIDERED A BACKFIT UNLESS THE SRP WAS SPECIFICALLY APPROVED FOR OPERATING PLANT IMPLEMENTATION.
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- * ,5 m's PLANT-SPECIFIC ORDERS
- 1. AN ORDER ISSUED TO CAUSE A LICENSEE TO TAKE ACTIONS WHICH ARE NOT OTHERWISE APPLICABLE REGULATORY STAFF POSITIONS IS A BACKFIT.
- 2. AN ORDER ISSUED TO CONFIRM A LICENSEE COMMITMENT IS NOT A BACKFIT.
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SUMMARY
- 1. BACKFITTING IS AN EXPECTED STAFF ACTIVITY ,
- 2. BACKFITTING IS TO BE CONDUCTED IN A CONTROLLED MANNER
- 3. BACKFITTING CONCEPTS ARE STRAIGHTFORWARD
- IS POSITION A PREVIOUSLY APPLICABLE STAFF POSITION?
- STATUS OF LICENSEE IN REGULATORY PROCESS.
- IS LICENSEE BEING COERCED?
IS COMPLIANCE /CONFORMANCE INVOLVED?
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- 4. BACKFIT PROCESS l l
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- IDENTIFY AND DETERMINE
- REGULATORY ANALYSIS
- MANAGEMENT APPROVAL l
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- TRANSMITTAL TO LICENSEE
- IMPLEMENT OR APPEAL FINAL DISPOSITION l
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