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| {{NRC Inspection Manual 0612}}
| | #REDIRECT [[NRC Inspection Manual 0609/Appendix B]] |
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| IMC 0612 Appendix B – Issue Screening
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| Issue Date: 09/07/12 B-1 0612 App B
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| Figure 1: Issue Screening
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| ?
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| Issue of concern identified
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| Is there a performance deficiency? Yes
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| Document violation per 0612-13 (Section 4OA7)
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| No finding. Minor violations may be documented in some cases per 0612-14
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| Does the finding screen to green? Is the finding licensee- identified? Yes
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| Identify appropriate cross-cutting aspect(s)
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| Document per 0612-06 or 08
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| No
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| Pending significance determination Assess for cross-cutting aspect(s) under Block 6 Document FIN(TBD) or AV per 0612-06 or 08
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| 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)
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| Consider a URI 2 3 4 Is the performance deficiency More- than- Minor?
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| TE1
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| 6
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| TE2
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| 5
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| 1
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| No
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| Yes Performance deficiency is a finding
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| Follow both paths
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| Does traditional enforcement or enforcement discretion apply?
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| Continue with ROP path
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| No
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| Yes No willfulness
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| Screen performance deficiency when directed by Figure 2
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| Yes
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| No
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| No finding. Document those violations without a performance deficiency per 0612-09 absence specific and overriding enforcement guidance.
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| Yes
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| No
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| Determine willfulness and if screening can proceed without delay Go to Figure 2 A From Figure 2 B
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| From Figure 2 C
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| Assess violation in accordance with the Enforcement Policy Go to Figure 2 D
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| No
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| Is there a potentially willful violation?
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| 7
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| Can significance be resolved before issuing the report? Yes
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| Conduct SERP or SRA reviews as appropriate (follow outcome path)
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| Green finding
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| Finding with preliminary significance
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| Yes ? Yes
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| No
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| ROP path Traditional enforcement path No
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| No
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| Issue Date: 09/07/12 B-2 0612 App B
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| Figure 2: Issue Screening (Traditional Enforcement)
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| Consider a URI Screen performance deficiency Figure 1 Block 3
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| Determine willfulness and if screening can proceed without delay From Figure 1 A
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| Goto Figure 1 B
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| Goto Figure 1 C
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| 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)
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| TE4 TE3 TE5
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| Yes Does a SL-IV or greater violation exist?
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| 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
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| Can screening proceed without compromising investigation? Wait for completion of investigation. Does investigation confirm a willful violation? Yes
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| Yes Screen any performance deficiency without potential traditional enforcement violation
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| No
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| No willfulness No
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| Screen performance deficiency (confirmed)
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| Is OI investigation warranted? Prepare and conduct ARB.
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| Determine the severity level of the violation (Work with OE via the Regional Enforcement Coordinator)
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| No
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| Follow both paths
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| ?
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| Yes
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| Consider URI for potential violation
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| Does the violation warrant enforcement discretion? No
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| 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
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| TE8
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| Follow both paths TE7 TE6 7
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| 7
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| Issue Date: 09/07/12 B-3 0612 App B
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| Additional Guidance to Clarify Figures
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| 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
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| performance deficiencies if any exist. Inspectors will separate traditional enforcement violations
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| from their underlying performance deficiencies and screen those traditional enforcement
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| violations using the examples and guidance in the Enforcement Manual and Enforcement
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| Policy.
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| When dispositioning performance deficiencies associated with traditional enforcement
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| violations, inspectors will not consider the traditional enforcement aspect as part of the ROP
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| performance deficiency.
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| Figure 1, “Issue Screening”
| |
| | |
| ==Block 1 Issue of concern identified==
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| An issue of concern is a well-defined observation or collection of observations that may have a
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| bearing on safety or security which may warrant further inspection, screening, evaluation, or
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| regulatory action.
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| For issues of concern with multiple examples, inspectors will screen each example separately.
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| 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
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| backfit process due to its perceived impact on safety or security. Inspectors identifying such an
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| issue of concern should raise the concern to management and refer to Management
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| Directive 8.4, “Management of Facility-specific Backfitting and Information Collection.”
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| Block TE1 Is there a potentially willful violation?
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| Although inspectors screen issues of concern for indications of potentially willful violations, the
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| determination of willfulness is a legal decision that can only be made by the Office of the
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| General Council (OGC) using facts developed during an investigation conducted by Office of
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| Investigations (OI), normally at the recommendation of the Allegation Review Board (ARB).
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| See the Enforcement Policy, Enforcement Manual, and Allegation Manual for additional insights
| |
| involving willfulness. See 10 CFR 50.5 for regulations addressing deliberate misconduct.
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| Block TE2 Does traditional enforcement or enforcement discretion apply?
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| 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.
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| 1. Was there a violation that impacted the regulatory process? Examples:
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| Failure to provide complete and accurate information
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| 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
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| Reporting failure, etc.
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| Issue Date: 09/07/12 B-4 0612 App B
| |
| Block TE2 Does traditional enforcement or enforcement discretion apply?
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| 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?
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| 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:
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| Specific cases for which temporary Enforcement Guidance Memoranda prescribes
| |
| enforcement discretion
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| Non-minor violations absent a performance deficiency
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| Violations identified during extended shutdowns or work stoppages
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| Violations involving old design issues
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| Violations identified because of previous enforcement action
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| 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?==
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| 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.
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| (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.
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| (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.
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| 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?==
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| 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.
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| 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
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| the end of this attachment and did the performance deficiency adversely affect the
| |
| associated cornerstone objective?
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| Inspectors should consider using IMC 0612, Appendix E, “Examples of Minor Issues,” to
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| inform answers to the screening questions listed above.
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| | |
| ==Block 4 Does the finding screen to Green?==
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| 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).
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| | |
| ==Block 5 Is the finding licensee-identified?==
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| In determining whether a finding is licensee-identified, NRC-identified, or self-revealing, a
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| 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)==
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| To identify an appropriate cross-cutting aspect for a finding, the inspector will:
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| Review applicable causal information related to the finding to identify the cause(s) of the
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| performance deficiency. (To identify causes, inspectors need not perform independent
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| Issue Date: 09/07/12 B-6 0612 App B
| |
| | |
| ==Block 6 Identify appropriate cross-cutting aspect(s)==
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| causal evaluations beyond what would be appropriate for the complexity of the issue.
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| For the most-complex issues, inspectors may need to complete informal apparent-cause
| |
| evaluations.)
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| 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.
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| 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
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| cross-cutting aspect provides the most meaningful insight into why the finding occurred.)
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| 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.
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| Note that:
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| Typically, the staff will assign no more than one cross-cutting aspect to a finding. On
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| 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
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| Assessment Branch Chief (NRR/DIRS/IPAB) for concurrence.
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| 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.
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| (Unless examples have the same cross-cutting aspect, they can‟t be examples of the
| |
| same finding.)
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| | |
| ==Block 7 Consider a URI==
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| 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
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| 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.
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| 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?===
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| Each issue of concern warranting a willfulness investigation triggers a process to determine
| |
| whether disposition of the associated ROP performance deficiency may proceed without
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| compromising the OI investigation.
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| Generally, to preclude the possibility of compromising an ongoing willfulness investigation,
| |
| inspectors should suspend ROP disposition activities that require licensee interaction until the
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| investigation is complete. However, because SDP insights developed during issue
| |
| dispositioning are integral to dispositioning most traditional enforcement violations, inspectors
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| 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
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| 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
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| investigation. The parties involved in this decision should ensure that their specific concerns
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| 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.
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| 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
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| is warranted.
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| Block TE4 Wait for completion of investigation
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| This block requires enhanced coordination to preclude the possibility of compromising an
| |
| ongoing investigation by proceeding, prematurely, with ROP disposition activities while
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| simultaneously assuring that ROP disposition activities are not delayed longer than necessary.
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| Block TE5 Does investigation confirm a willful violation?
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| In accordance with the Enforcement Policy and Enforcement Manual, OI, upon concluding its
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| investigation will issue a conclusion about willfulness based on the facts collected/developed
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| during investigation. Using the facts/conclusion above, OGC will make a final determination
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| about willfulness.
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| Block TE6 Screen performance deficiency (Figure 1 Block 3)
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| The absence of a finding may influence but does not preclude the potential to confirm a willful
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| violation, though it may influence the determination of its severity level and/or civil penalty.
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| Similarly, the presence of a finding does not preclude the potential to confirm no willful violation.
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| However, if a willful violation is determined to exist, it may influence the determination of its
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| severity level and/or civil penalty.
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| | |
| ===Block TE7 Confirmed willful violation===
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| To disposition violations involving confirmed willfulness, inspectors shall coordinate with the
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| Office of Enforcement through the Regional Enforcement Coordinator. Additional guidance is
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| contained in the Enforcement Policy and Enforcement Manual.
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| A violation may be considered more significant than the underlying noncompliance if involves
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| Issue Date: 09/07/12 B-8 0612 App B
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| 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.
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| 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.
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| 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.
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| 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.
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| Block 7 Consider a URI
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| See Block 7 for Figure 1
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| Issue Date: 09/07/12 B-9 0612 App B
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| Cornerstone Objectives and Attribute Tables
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| Cornerstone REACTOR SAFETY – Initiating Events
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| Objective To limit the likelihood of events that upset plant stability and challenge
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| critical safety functions during shutdown as well as power operations.
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| Attributes Areas to Measure
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| Design Control Initial Design and Plant Modifications
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| Protection Against
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| External Factors
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| Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, Switchyard
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| Activities, Grid Stability
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| Configuration Control Shutdown Equipment Lineup, Operating Equipment Lineup
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| Equipment
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| Performance
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| Availability, Reliability, Maintenance, Barrier Integrity (SGTR, ISLOCA,
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| LOCA (S,M,L)), Refueling/Fuel Handling Equipment
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| Procedure Quality Procedure Adequacy (Maint, Test, Ops)
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| 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,
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| 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
| |