NRC Inspection Manual 0612 Appendix B: Difference between revisions

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#REDIRECT [[NRC Inspection Manual 0609/Appendix B]]
 
IMC 0612 Appendix B – Issue Screening
Issue Date: 09/07/12 B-1 0612 App B
Figure 1: Issue Screening
?
Issue of concern identified
Is there a performance deficiency? Yes
Document violation per 0612-13 (Section 4OA7)
No finding. Minor violations may be documented in some cases per 0612-14
Does the finding screen to green? Is the finding licensee- identified? Yes
Identify appropriate cross-cutting aspect(s)
Document per 0612-06 or 08
No
Pending significance determination Assess for cross-cutting aspect(s) under Block 6 Document FIN(TBD) or AV per 0612-06 or 08
Did the finding involve a violation? No further evaluation or documentation Is information required to determine if a violation exists? Evaluate using the SDP. (See IMC 0609)
Consider a URI 2 3 4 Is the performance deficiency More- than- Minor?
TE1
6
TE2
5
1
No
Yes Performance deficiency is a finding
Follow both paths
Does traditional enforcement or enforcement discretion apply?
Continue with ROP path
No
Yes No willfulness
Screen performance deficiency when directed by Figure 2
Yes
No
No finding. Document those violations without a performance deficiency per 0612-09 absence specific and overriding enforcement guidance.
Yes
No
Determine willfulness and if screening can proceed without delay Go to Figure 2 A From Figure 2 B
From Figure 2 C
Assess violation in accordance with the Enforcement Policy Go to Figure 2 D
No
Is there a potentially willful violation?
7
Can significance be resolved before issuing the report? Yes
Conduct SERP or SRA reviews as appropriate (follow outcome path)
Green finding
Finding with preliminary significance
Yes ? Yes
No
ROP path Traditional enforcement path No
No
Issue Date: 09/07/12 B-2 0612 App B
Figure 2: Issue Screening (Traditional Enforcement)
Consider a URI Screen performance deficiency Figure 1 Block 3
Determine willfulness and if screening can proceed without delay From Figure 1 A
Goto Figure 1 B
Goto Figure 1 C
Assess violation in accordance with the Enforcement Policy From Figure 1 D Minor violation or no violation. Minor violations may be documented in some cases per 0612-14 Document violation per 0612-13 (Section 4OA7)
TE4 TE3 TE5
Yes Does a SL-IV or greater violation exist?
No Is the violation a licensee identified SL-IV NCV? Yes Document violation per 0612-07 or 0612-08 absent specific and overriding enforcement guidance. No
Can screening proceed without compromising investigation? Wait for completion of investigation. Does investigation confirm a willful violation? Yes
Yes Screen any performance deficiency without potential traditional enforcement violation
No
No willfulness No
Screen performance deficiency (confirmed)
Is OI investigation warranted? Prepare and conduct ARB.
Determine the severity level of the violation (Work with OE via the Regional Enforcement Coordinator)
No
Follow both paths
?
Yes
Consider URI for potential violation
Does the violation warrant enforcement discretion? No
Document violations receiving enforcement discretion in accordance with specific and overriding enforcement guidance. Document those violations without a performance deficiency per 0612-09 absence specific and overriding enforcement guidance. Yes
TE8
Follow both paths TE7 TE6 7
7
Issue Date: 09/07/12 B-3 0612 App B
Additional Guidance to Clarify Figures
Inspectors will not use the Reator Oversight Process (ROP) screening process to screen
traditional-enforcement violations, but will use that process to screen their underlying
performance deficiencies if any exist. Inspectors will separate traditional enforcement violations
from their underlying performance deficiencies and screen those traditional enforcement
violations using the examples and guidance in the Enforcement Manual and Enforcement
Policy.
When dispositioning performance deficiencies associated with traditional enforcement
violations, inspectors will not consider the traditional enforcement aspect as part of the ROP
performance deficiency.
Figure 1, “Issue Screening”
 
==Block 1 Issue of concern identified==
An issue of concern is a well-defined observation or collection of observations that may have a
bearing on safety or security which may warrant further inspection, screening, evaluation, or
regulatory action.
For issues of concern with multiple examples, inspectors will screen each example separately.
On rare occasions, an inspector may identify an issue of concern that is neither a regulatory
requirement nor an accepted licensee standard which may warrant consideration under the
backfit process due to its perceived impact on safety or security. Inspectors identifying such an
issue of concern should raise the concern to management and refer to Management
Directive 8.4, “Management of Facility-specific Backfitting and Information Collection.”
Block TE1 Is there a potentially willful violation?
Although inspectors screen issues of concern for indications of potentially willful violations, the
determination of willfulness is a legal decision that can only be made by the Office of the
General Council (OGC) using facts developed during an investigation conducted by Office of
Investigations (OI), normally at the recommendation of the Allegation Review Board (ARB).
See the Enforcement Policy, Enforcement Manual, and Allegation Manual for additional insights
involving willfulness. See 10 CFR 50.5 for regulations addressing deliberate misconduct.
Block TE2 Does traditional enforcement or enforcement discretion apply?
If any of the following questions can be answered „yes‟, the inspector will compare the violation
with examples in the Enforcement Policy to determine if the violation rises to SL-IV or above
and thus constitutes a non-minor traditional enforcement violation.
1. Was there a violation that impacted the regulatory process? Examples:
Failure to provide complete and accurate information
Failure to receive prior NRC approval for changes in licensed activities
Failure to notify the NRC of changes in licensed activities
Failure to perform 10 CFR 50.59 analyses
Reporting failure, etc.
Issue Date: 09/07/12 B-4 0612 App B
Block TE2 Does traditional enforcement or enforcement discretion apply?
2. Was there a violation that contributed to actual safety consequences? Examples:
Actual onsite or offsite releases of radiation exceeding regulatory limits
Onsite or offsite radiation exposures exceeding regulatory limits
Accidental criticalities
Core damage
Loss of significant safety barriers
Loss of control of radiological material exceeding regulatory limits for public dose
Radiological emergencies
3. Is there a SL-IV or greater violation with no associated performance deficiency?
Circumstances may arise where enforcement discretion should be considered or exercised to
either escalate or mitigate enforcement sanctions or otherwise refrain from taking enforcement
action for a particular violation. The Enforcement Policy and Enforcement Manual describe
situations where this may apply. Specific circumstances may include:
Specific cases for which temporary Enforcement Guidance Memoranda prescribes
enforcement discretion
Non-minor violations absent a performance deficiency
Violations identified during extended shutdowns or work stoppages
Violations involving old design issues
Violations identified because of previous enforcement action
Violations involving certain discrimination issues
Note: Independent spent fuel storage installations (ISFSI), and nuclear materials facilities are
not subject to the Significance Determination Process (SDP) and, thus, traditional enforcement
will be used for these facilities and their associated license.
 
==Block 2 Is there a performance deficiency?==
The issue of concern is a performance deficiency if the answer to both of the following
questions is “yes”:
Was the issue of concern the result of the licensee‟s failure to meet a requirement or
standard? (A standard includes a self-imposed standard such as a voluntary initiative or
a standard required by regulation)
Was the cause of the issue of concern reasonably within the licensee‟s ability to foresee
and correct and should the issue of concern have been prevented?
Notes: (1) The performance deficiency is the proximate cause of the degraded condition and is
not the degraded condition. To determine this cause, inspectors need not complete a rigorous
root-cause evaluation, but instead may complete an evaluation based on reasonable inspector
assessment and judgment.
(2) Inspectors should not define a performance deficiency at a fundamental level, such as
defining a performance deficiency as a management weakness or as a cross-cutting area.
(3) Enforcement Manual Section 2.13.8 discusses grouping closely related violations into an
enforcement “problem”. Considering this guidance, inspectors or SERP members may define
or redefine a performance deficiency at the problem level and thereby create a relationship
between one performance deficiency and many violations.
When evaluating the licensee‟s failure to meet a requirement or standard, the inspector should
consider the licensee‟s intent:
Issue Date: 09/07/12 B-5 0612 App B
Block 2 Is there a performance deficiency?
By definition, the licensee intends to meet regulatory requirements, including license
conditions and Technical Specifications.
The inspector can generally conclude the licensee intends to meet standards
established in current licensing basis documents. LIC-100, “Control of Licensing Bases
for Operating Reactors,” provides insights into what documents may constitute current
licensing basis.
Failure to meet an industry standard constitutes a performance deficiency only if the
licensee intended to meet that standard. Inspectors may reasonably conclude that
standards implemented via licensee procedures or as Nuclear Energy Institute (NEI)
initiatives committed to by the industry are standards that the licensee intended to meet.
The inspector should focus on whether the licensee met regulatory requirements in an
acceptable manner rather than whether the licensee met the requirements in a manner
specifically approved in a generic communication.
 
==Block 3 Is the performance deficiency More-than-Minor?==
If the answer to any of the following questions is “yes,” then the performance deficiency is
More-than-Minor and is a finding. If the answer to all of the following questions is “no,” then
the performance deficiency is minor and is not a finding.
Could the performance deficiency reasonably be viewed as a precursor to a significant
event?
If left uncorrected, would the performance deficiency have the potential to lead to a more
significant safety concern?
Does the performance deficiency relate to a performance indicator that would have
caused the performance indicator to exceed a threshold?
Is the performance deficiency associated with one of the cornerstone attributes listed at
the end of this attachment and did the performance deficiency adversely affect the
associated cornerstone objective?
Inspectors should consider using IMC 0612, Appendix E, “Examples of Minor Issues,” to
inform answers to the screening questions listed above.
 
==Block 4 Does the finding screen to Green?==
Inspectors will screen all findings using IMC 0609, Attachment 4, “Phase 1 – Initial Screening
and Characterization of Findings” worksheet. Any finding which cannot be determined to be
Green will require a Significance Enforcement Review Panel (SERP).
 
==Block 5 Is the finding licensee-identified?==
In determining whether a finding is licensee-identified, NRC-identified, or self-revealing, a
measure of subjectivity is anticipated and accepted. To make these determinations, inspectors
and regional staff should consider not only the definitions of these terms, but also past
experience, related precedents, and the over-arching regulatory message that the determination
could send.
 
==Block 6 Identify appropriate cross-cutting aspect(s)==
To identify an appropriate cross-cutting aspect for a finding, the inspector will:
Review applicable causal information related to the finding to identify the cause(s) of the
performance deficiency. (To identify causes, inspectors need not perform independent
Issue Date: 09/07/12 B-6 0612 App B
 
==Block 6 Identify appropriate cross-cutting aspect(s)==
causal evaluations beyond what would be appropriate for the complexity of the issue.
For the most-complex issues, inspectors may need to complete informal apparent-cause
evaluations.)
Among those causes, identify the performance characteristic that is the either the
primary cause of the performance deficiency or the most-significant contributor to it.
Select the cross-cutting aspect listed in IMC 0310 that best reflects the performance
characteristic that is the most significant contributor to the finding (i.e., determine which
cross-cutting aspect provides the most meaningful insight into why the finding occurred.)
A cross-cutting aspect is a finding characteristic which inversely relates to the reason
why the performance deficiency occurred. The cross-cutting aspect is not a finding.
Note that:
Typically, the staff will assign no more than one cross-cutting aspect to a finding. On
rare occasions, when the regional staff considers that a unique or complex inspection
finding warrants more than one cross-cutting aspect, before associating more than one
cross-cutting aspect to any finding, the regional office will contact the Performance
Assessment Branch Chief (NRR/DIRS/IPAB) for concurrence.
For a finding to have multiple examples, the same cross-cutting aspect should be
associated with each example, consistent with Enforcement Manual Section 2.13.7.
(Unless examples have the same cross-cutting aspect, they can‟t be examples of the
same finding.)
 
==Block 7 Consider a URI==
Inspectors should open a Unresolved Item (URI) when an inspection must exit pending receipt
of information required to determine one of the following:
If there is a performance deficiency
If the performance deficiency is More-than-Minor
If the issue of concern is a violation
Note: Inspectors may not use a URI to obtain more information to determine the significance of
a finding.
Issue Date: 09/07/12 B-7 0612 App B
Figure 2, “Issue Screening (Traditional Enforcement)”
 
===Block TE3 Can ROP screening proceed without compromising investigation?===
Each issue of concern warranting a willfulness investigation triggers a process to determine
whether disposition of the associated ROP performance deficiency may proceed without
compromising the OI investigation.
Generally, to preclude the possibility of compromising an ongoing willfulness investigation,
inspectors should suspend ROP disposition activities that require licensee interaction until the
investigation is complete. However, because SDP insights developed during issue
dispositioning are integral to dispositioning most traditional enforcement violations, inspectors
should disposition ROP performance deficiencies in a timely manner. So, to balance these
competing considerations, whenever ROP disposition activities could possibly compromise an
ongoing investigation, the Directors (or their designees) of the OI Field Office, DIRS, the
associated Regional Division of Reactor Projects or Safety, and OE should reach a consensus
decision on whether ROP dispositioning should be suspended or may proceed during the
investigation. The parties involved in this decision should ensure that their specific concerns
are considered in order to achieve the two desired agency outcomes – a valid and defendable
ROP finding and a valid and defendable violation within the enforcement program.
If the decision is to suspend ROP dispositioning, then as soon as the investigation is sufficiently
complete or whenever new information arises that might otherwise warrant reevaluating that
decision, the parties involved in the decision should revisit the decision, and change it if change
is warranted.
 
Block TE4 Wait for completion of investigation
This block requires enhanced coordination to preclude the possibility of compromising an
ongoing investigation by proceeding, prematurely, with ROP disposition activities while
simultaneously assuring that ROP disposition activities are not delayed longer than necessary.
Block TE5 Does investigation confirm a willful violation?
In accordance with the Enforcement Policy and Enforcement Manual, OI, upon concluding its
investigation will issue a conclusion about willfulness based on the facts collected/developed
during investigation. Using the facts/conclusion above, OGC will make a final determination
about willfulness.
 
Block TE6 Screen performance deficiency (Figure 1 Block 3)
The absence of a finding may influence but does not preclude the potential to confirm a willful
violation, though it may influence the determination of its severity level and/or civil penalty.
Similarly, the presence of a finding does not preclude the potential to confirm no willful violation.
However, if a willful violation is determined to exist, it may influence the determination of its
severity level and/or civil penalty.
 
===Block TE7 Confirmed willful violation===
To disposition violations involving confirmed willfulness, inspectors shall coordinate with the
Office of Enforcement through the Regional Enforcement Coordinator. Additional guidance is
contained in the Enforcement Policy and Enforcement Manual.
A violation may be considered more significant than the underlying noncompliance if involves
Issue Date: 09/07/12 B-8 0612 App B
Block TE7 Confirmed willful violation
willfulness. When determining the severity level of a willful violation, the NRC, in addition to
considering the willful aspects, considers the (1) actual safety consequences, (2) potential
safety consequences, including the consideration of risk information, and (3) potential for
impacting the NRC‟s ability to perform its regulatory function. A notice of violation is normally
required for a willful violation. However, a non-cited violation may still be appropriate. Refer to
the Enforcement Policy for additional guidance.
The approval of the Director, Office of Enforcement, with consultation with the Deputy Executive
Director as warranted, is required for dispositioning willful violations as non-cited violations.
Block TE8 Does the violation warrant enforcement discretion?
For violations involving enforcement discretion, inspectors shall coordinate their actions with the
Regional Enforcement Coordinator. Additional guidance is contained in the Enforcement Policy
and Enforcement Manual.
Some enforcement discretion decisions are made on a case-by-case basis in consultation with
the Office of Enforcement, while others may be instituted under a temporary Enforcement
Guidance Memorandum.
Block 7 Consider a URI
See Block 7 for Figure 1
Issue Date: 09/07/12 B-9 0612 App B
Cornerstone Objectives and Attribute Tables
Cornerstone REACTOR SAFETY – Initiating Events
Objective To limit the likelihood of events that upset plant stability and challenge
critical safety functions during shutdown as well as power operations.
Attributes Areas to Measure
Design Control Initial Design and Plant Modifications
Protection Against
External Factors
Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, Switchyard
Activities, Grid Stability
Configuration Control Shutdown Equipment Lineup, Operating Equipment Lineup
Equipment
Performance
Availability, Reliability, Maintenance, Barrier Integrity (SGTR, ISLOCA,
LOCA (S,M,L)), Refueling/Fuel Handling Equipment
Procedure Quality Procedure Adequacy (Maint, Test, Ops)
Human Performance Human Error
Cornerstone REACTOR SAFETY – Mitigating Systems
Objective To ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences (i.e.,
core damage).
Attributes Areas to Measure
Design Control Initial Design and Plant Modifications
Protection Against
External Factors
Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, Seismic,
Weather
Configuration Control Shutdown Equipment Lineup, Operating Equipment Lineup
Equipment
Performance
Availability, Reliability
Procedure Quality Operating (Post-event) Procedures (AOPs, SOPs, EOPs),
Maintenance and Testing (Pre-event) Procedures
Human Performance Human Error (Post-event), Human Error (Pre-event)
Cornerstone REACTOR SAFETY – Barrier Integrity
Objective To provide reasonable assurance that physical design barriers (fuel
cladding, reactor coolant system, and containment) protect the public
from radionuclide releases caused by accidents or events.
Attributes Areas to Measure (to Maintain Functionality of Fuel Cladding)
Design Control Physics Testing, Core Design Analysis (Thermal Limits, Core
Operating Limit Report, Reload Analysis, 10 CFR50.46)
Configuration Control Reactivity Control (Control Rod Position, Reactor Manipulation,
Reactor Control Systems), Primary Chemistry Control, Core
Configuration (Loading)
Cladding Performance Loose Parts (Common Cause Issues), RCS Activity Level
Procedure Quality Procedures which could impact cladding
Human Performance Procedure Adherence (FME, Core Loading, Physics Testing, Vessel
Assembly, Chemistry, Reactor Manipulation), FME Loose Parts,
Common Cause Issues
Issue Date: 09/07/12 B-10 0612 App B
Cornerstone REACTOR SAFETY – Barrier Integrity
Objective To provide reasonable assurance that physical design barriers (fuel
cladding, reactor coolant system, and containment) protect the public
from radionuclide releases caused by accidents or events.
Attributes Areas to Measure (to Maintain Functionality of RCS)
Design Control Plant Modifications
Configuration Control System Alignment, Primary/Secondary Chemistry
RCS Equipment and
Barrier Performance
RCS Leakage, Active Components of Boundary (Valves, Seals), ISI
Results
Procedure Quality Routine OPS/Maintenance Procedures, EOPs and related Off-Normal
Procedures invoked by EOPs
Human Performance Routine OPS/Maintenance Performance, Post Accident or Event
Performance
Attributes Areas to Measure (to Maintain Functionality of Containment)
Design Control Plant Modifications, Structural Integrity, Operational Capability
Configuration Control Containment Boundary Preserved, Containment Design Parameters
Maintained
SSC and Barrier
Performance
S/G Tube Integrity, ISLOCA Prevention, Containment Isolation, SSC
Reliability/Availability, Risk Important Support Systems Function
Procedure Quality Emergency and Operating Procedures, Risk Important Procedures
(OPS, Maintenance, Surveillance)
Human Performance Post Accident or Event Performance, Routine OPS/Maintenance
Performance
Attributes Areas to Measure (to Maintain Radiological Barrier Functionality of
Control Room and Auxiliary Building – PWR, and Standby Gas
Trains – BWR only)
Design Control Plant Modifications, Structural Integrity
Configuration Control Building Boundaries Preserved
SSC and Barrier
Performance
Door, Dampers, Fans, Seals, Instrumentation
Procedure Quality EOPs, Abnormal and Routine Operating Procedures, Surveillance
Instructions, Maintenance Procedures
Human Performance Post Accident or Event Performance, Routine OPS/Maintenance
Performance
Attributes Areas to Measure (to Maintain Functionality of Spent Fuel Pool
Cooling System)
Design Control Plant Modifications, Structural Integrity
Configuration Control System Alignment
SSC Performance Pumps, Valves, Instrumentation
Procedure Quality EOPs, Abnormal and Routine Operating Procedures, Surveillance
Instructions, Maintenance Procedures
Human Performance Post Accident or Event Performance, Routine OPS/Maintenance
Performance
Issue Date: 09/07/12 B-11 0612 App B
Cornerstone REACTOR SAFETY – Emergency Preparedness
Objective To ensure that the licensee is capable of implementing adequate
measures to protect the health and safety of the public in the event of
a radiological emergency.
Attributes Areas to Measure
ERO Readiness Duty Roster, ERO Augmentation System, ERO Augmentation Testing,
Training
Facilities and
Equipment
ANS Testing, Maintenance Surveillance and Testing of Facilities,
Equipment and Communications Systems, Availability of ANS, Use in
Drills and Exercises
Procedure Quality EAL Changes, Plan Changes, Use in Drills and Exercises
ERO Performance Program Elements Meet 50.47(b) Planning Standards, Actual Event
Response, Training, Drills, Exercises
Offsite EP FEMA Evaluation
Cornerstone RADIATION SAFETY – Occupational Radiation Safety
Objective To ensure the adequate protection of the worker health and safety
from exposure to radiation from radioactive material during routine
civilian nuclear reactor operation.
Attributes Areas to Measure
Plant
Facilities/Equipment
and Instrumentation
Plant Equipment Instrumentation, (ARM Cals & Availability, Source
Term Control), Procedures (Radiation Protection and Maintenance)
Program & Process Procedures (HPT, Rad Worker, ALARA); Exposure/Contamination
Control and Monitoring (Monitoring and RP Controls), ALARA Planning
(Management Goals, Measures - Projected Dose)
Human Performance Training (Contractor HPT Quals, Radiation Worker Training,
Proficiency)
Cornerstone RADIATION SAFETY – Public Radiation Safety
Objective To ensure adequate protection of public health and safety from
exposure to radioactive materials released into the public domain as a
result of routine civilian nuclear reactor operation.
Attributes Areas to Measure
Plant
Facilities/Equipment
and Instrumentation
Process Radiation Monitors (RMS)
(Modifications, Calibrations, Reliability, Availability), REMP Equipment,
Meteorology Instruments, Transportation Packaging, Procedures
(Design/Modifications, Equipment Calculations, Transportation
Packages, Counting Labs)
Program & Process Procedures (Process RMs & REMP, Effluent Measurement QC,
Transportation Program, Material Release, Meteorological Program,
Dose Estimates), Exposure and Radioactivity Material Monitoring and
Control (Projected Offsite Dose, Abnormal Release, DOT Package
Radiation Limits, Measured Dose)
Human Performance Training (Technician Qualifications, Radiation & Chemical Technician
Performance)
Issue Date: 09/07/12 B-12 0612 App B
Cornerstone SAFEGUARDS – Security
Objective To provide assurance that the licensee‟s security system and material
control and accountability program use a defense-in-depth approach
and can protect against (1) the design basis threat of radiological
sabotage from external and internal threats, and (2) the theft or loss of
radiological materials.
Attributes Areas to Measure
Physical Protection
System
Protected Areas (Barriers, Alarms, Assessment), Vital Areas (Barriers,
Alarms, Assessment)
Access Authorization Personnel Screening, Behavior Observations, Fitness for Duty
Access Control Search, Identification
Response to
Contingency Events
Protective Strategy, Implementation of Protective Strategy
Material Control and
Accounting
Records; Procedures, Inventories
Issue Date 09/07/12 Att1-1 0612 App B
Attachment 1 – Revision History for IMC 0612 Appendix B - Issue Screening
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Training
Required
and
Completion
Date
Comment and
Feedback
Resolution
Accession
Number
11/01/2006 Revision history reviewed for the last four years. No
04/29/2002
CN 02-021
Appendix B was removed as an attachment to IMC-0612 and
was issued as stand alone document.
No
ML051400254
05/19/2005
CN 05-014
Revised to add Question No. 5 to Minor Questions in Section 3
and Question No. 6 to the SDP Questions in Section 4 to reflect
the new maintenance risk assessment and risk management
SDP, IMC 0609, Appendix K, “Maintenance Rule Risk
Assessment and Risk Management.”
No
ML052700266
09/30/2005
CN 05-028
Revised to clarify the definition of a performance deficiency and
a functionality of the control room. Also, the auxiliary building
attribute was added to the cornerstone and objective section.
No
ML060400499
11/02/06
CN 06-033
Revised definition of performance deficiency to bring the
definition in alignment with the basis for performance deficiency
as described in ROP basis document, IMC-0308 attachment 3,
“Significance Determination Process Basis Document.”
Yes
09/06/2006
ML063000483
ML071720417
09/20/07
CN 07-029
Revised flow chart and Section 3 guidance to address feedback
forms. Corrected formatting error on page B-7.
No
ML082310381
12/04/08
CN 08-034
Revised Guidance and Flow Chart to be consistent with changes
to IMC 0612. Updated Cornerstone Objectives and Attributes to
be consistent with IMC 0308.
Yes
12/03/2008
ML083220751
ML091590496
12/24/09
CN 09-032
Rewrite Guidance and Flow Charts to:
1. Implement enhanced Traditional Enforcement (TE)
integration in ROP
2. Enhance organization and access
3. Incorporate IMC 0305 Cross-Cutting Aspect inspection
guidance
Yes
12/10/2009
ML091480470
Issue Date 09/07/12 Att1-2 0612 App B
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Training
Required
and
Completion
Date
Comment and
Feedback
Resolution
Accession
Number
4. Address (in part) the following 0612-related ROP Feedback:
a. 1303 - enhance App E Maintenance Rule (MR)
examples, remove MR specifics from App B
b. 1355 –enhance Performance Deficiency guidance (e.g.
what constitutes a "standard")
c. 1362 - enhance MR minor screening guidance (see 1303)
d. 1366 - enhance minor screening guidance for improved
consistency
e. 1398 - improve alignment between 0612 and
Enforcement Policy (e.g. minor TE Violations)
f. 1418 – enhance minor screening guidance to reduce
subjectivity per 2008 Consolidated ROP Internal Selfassessment
(CRIS-08)
g. 1419 - enhance guidance for differentiating self-revealing
vs. NRC- vs. License ID per CRIS-08
h. 1425 - resolve CCA guidance cross-reference errors
5. Consolidate screening guidance from Section 0612-05
„Screening Inspection Results,‟ of IMC 0612-proper into
Appendix B screening guidance.
ML12080A204
09/07/12
CN 12-020
Complete Reissue. Simplified guidance. Added enforcement
discretion path to traditional enforcement.
ML12205A244
FF 0612B-
1398, 1439,
1483, 1496,
1507, 1591,
1679, 1680,
1683, 1700,
1703

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