**NRC INSPECTION MANUAL** IRIB

MANUAL CHAPTER 0612

POWER REACTOR INSPECTION REPORTS

**CONTENTS**

*Page*

0612-01 PURPOSE 1

0612-02 OBJECTIVES 1

0612-03 DEFINITIONS 1

0612-04 RESPONSIBILITIES 4

04.01 [General Responsibilities]{.underline}. 5

04.02 [Inspectors]{.underline} 5

04.03 [Branch Chiefs and Division Directors]{.underline} 5

04.04 [Division of Inspection and Regional Support]{.underline}. 5

0612-05 SCREENING INSPECTION RESULTS 5

05.01 [Screen for Performance Deficiencies]{.underline}. 6

05.02 [Screen for Traditional Enforcement Action]{.underline}. 6

05.03 [Screen for Greater than Minor]{.underline}. 6

05.04 [Screen for Significance]{.underline} 7

0612-06 WRITING INSPECTION DETAILS 7

06.01 [Inspectable Area]{.underline}. 8

06.02 [Inspection Scope]{.underline}. 8

06.03 [Findings]{.underline}. 9

> a\. [Introduction]{.underline}. 10
>
> b\. [Description]{.underline}. 10
>
> c\. [Analysis]{.underline}. 10
>
> 1\. [Risk-Informed SDP Results - Results from IMC 0609 Appendices A,
> F, G, H and K]{.underline}. 10
>
> 2\. [Non-Risk-Informed SDP Results - Results from IMC 0609 Appendices
> B, C, D, E, I, and J]{.underline}. 11
>
> 3\. [Non-SDP Findings]{.underline}. 11
>
> 4\. [Traditional Enforcement]{.underline} 11
>
> 5\. [Findings Related to Cross-Cutting Areas]{.underline}. 12
>
> 6\. [Tracking Non-Regulatory Findings]{.underline} 13
>
> d\. [Enforcement]{.underline}. 13

06.04 [Tracking]{.underline}. 16

0612-07 DOCUMENTING PERFORMANCE INDICATOR VERIFICATION RESULTS 17

07.01 [Scope]{.underline} 17

07.02 [Findings]{.underline} 17

0612-08 DOCUMENTING UNRESOLVED ITEMS 17

08.01 [Opening]{.underline} 17

08.02 [Follow-up and Closure]{.underline} 17

0612-09 DOCUMENTING LERs AND LICENSEE-IDENTIFIED VIOLATIONS 18

09.01 [Licensee Event Reports (LERs)]{.underline} 18

> a\. [LERs without Violations]{.underline} 18
>
> b\. [LERs with Violations]{.underline} 18

09.02 [Licensee-Identified Finding]{.underline} 19

0612-10 OTHER GUIDANCE 20

10.01 [Treatment of Third Party Reviews]{.underline}. 20

10.02 [Non-Routine Inspections]{.underline} 20

0612-11 COMPILING AN INSPECTION REPORT 20

11.01 [Report Organization]{.underline}. 20

11.02 [Plant Status]{.underline}. 20

11.03 [Summary of Findings]{.underline}. 21

11.04 [Cover Page]{.underline} 22

11.05 [Table of Contents]{.underline}. 22

11.06 [Exit Meeting Summary]{.underline}. 22

11.07 [Report Attachments]{.underline}. 23

11.08 [Cover Letter]{.underline} 24

0612-12 ISSUING INSPECTION REPORTS 30

12.01 [Report Timeliness]{.underline} 30

12.02 [Release and Disclosure of Inspection Reports]{.underline} 30

**POWER REACTOR INSPECTION REPORTS**

0612‑01 PURPOSE

To define the content and format for reports of power reactor
inspections.

0612‑02 OBJECTIVES

To ensure that inspection reports:

02.01 Clearly communicate significant inspection results in a consistent
manner to licensees, NRC staff, and, where applicable, the public.

02.02 Document the basis for significance determination and enforcement
action.

02.03 Provide inspection results as one input into the Operating Reactor
Assessment Program (IMC 0305) of the Reactor Oversight Process (ROP) and
the Operating Security Assessment Program.

0612‑03 DEFINITIONS

The following terms are applicable for the purposes of documentation:

[AV]{.underline}: An inspection finding which may or may not have
regulatory requirements associated with it and, therefore, may or may
not be a violation, but has been determined to be potentially
greater-than-green in risk significance.

[Closed Item]{.underline}: A matter previously reported as a
noncompliance, an inspection finding, a licensee event report, or an
unresolved item, that the inspector concludes has been satisfactorily
addressed based on information obtained during the current inspection.

[Cross-Cutting Aspect]{.underline}: Performance characteristics that
comprise a cross-cutting area component. They are associated with
inspection findings and play a significant role in contributing to the
performance deficiency. The different cross-cutting aspects which can be
ascribed to an inspection finding are fully described in IMC 0305,
AOperating Reactor Assessment Program.@

[Deviation]{.underline}: A licensee\'s failure to satisfy a written
commitment, such as a commitment to conform to the provisions of
applicable codes, standards, guides, or accepted industry practices when
the commitment, code, standard, guide, or practice involved has not been
made a requirement by the Commission.

[Escalated Enforcement Action]{.underline}: A notice of violation or
civil penalty for any Severity Level I, II, or III violation; a notice
of violation associated with an inspection finding that the significance
determination process characterizes as having low to moderate, or
greater safety significance (White, Yellow or Red finding); or any order
based upon a violation.

[Finding (FIN)]{.underline}: A NRC-identified or self-revealing issue of
concern that is associated with a licensee performance deficiency.
Findings may or may not be associated with regulatory requirements and,
therefore, may or may not result in a violation. Licensee-identified
findings of very low safety significance (Green) that are not violations
of regulatory requirements are not documented in inspection reports.

[Green Finding]{.underline}: A finding of very low safety significance.

[Independent Item]{.underline}: An item used to track information that
does not originate in or is typically not documented as a finding in an
inspection report but may be referenced in an inspection report to
assess plant performance such as an Office of Investigation harassment
and intimidation case.

[Integrated Inspection Reports]{.underline}: A reactor inspection report
that combines inputs from several inspections (resident, regional, etc.)
conducted within a specified period.

[Issue]{.underline}: A well-defined observation or collection of
observations that is of concern and may or may not result in a finding.

[Licensee-Identified]{.underline}: For the purpose of this inspection
manual chapter (IMC), Alicensee-identified@ findings are those findings
that are not NRC-identified or self-revealing. Most, but not all,
licensee-identified findings are discovered through a licensee program
or process. Some examples of licensee programs that likely result in
such findings are post maintenance testing, surveillance testing, ASME
Section XI testing, drills, critiques, event assessments, evaluations,
or audits conducted by or for the licensee. Other examples of
licensee-identified findings are those findings that are identified by
the licensee as a result of their deliberate and focused observation
during the course of performing their normal duties (e.g., plant
operator or other licensee personnel identifying a packing leak on a
valve or identifying a valve out-of-position during a routine tour of
the facility would be considered licensee-identified, although the
individual=s duties at the time may not have been to identify these
types of deficiencies).

[Minor Violation/Finding]{.underline}: A violation or finding that is
less significant than a Severity Level IV violation or less significant
than what the SDP characterizes as Green and is of such low significance
that documentation in an NRC inspection report is not normally
warranted. Although minor violations must be corrected, they are not
usually described in inspection reports (see exception in section
05.03.d).

[Non-Cited Violation (NCV)]{.underline}: A method for dispositioning a
Severity Level IV violation or a violation associated with a finding
that is characterized as Green (very low safety significance). Provided
applicable criteria in the enforcement policy are met, such findings are
documented as violations, but are not cited in notices of violation,
which normally require written responses from licensees.

[Noncompliance]{.underline}: A violation (regardless of whether it is
cited or not), nonconformance, or deviation.

[Nonconformance]{.underline}: A vendor=s or certificate holder\'s
failure to meet contract requirements related to NRC activities (e.g.,
10 CFR Part 50, Appendix B, Part 71, or Part 72) where the NRC has not
imposed requirements directly on the vendor or certificate holder.

[Notice of Violation (NOV)]{.underline}: A formal, written citation in
accordance with 10 CFR 2.201 that sets forth one or more violations of a
legally binding regulatory requirement.

[NRC-Identified]{.underline}: For the purpose of this IMC,
NRC-identified findings are those findings, found by NRC inspectors, of
which the licensee was not previously aware or had not been previously
documented in the licensee=s corrective action program. NRC-identified
findings also include previously documented licensee findings to which
the inspector has significantly added value. Added value means that the
inspector has identified previously unknown weakness in the licensees
classification, evaluation, or corrective actions associated with the
licensee=s correction of a finding.

[Observation]{.underline}: A factual detail noted during an inspection.
Observations are not generally documented in inspection reports but may
be documented in conjunction with and to support a finding.
Additionally, observations may be documented to support the requirements
of temporary instructions and Inspection Procedure (IP) 71152,
AIdentification and Resolution of Problems.@

[Performance Deficiency]{.underline}: An issue that is the result of a
licensee not meeting a requirement or standard where the cause was
reasonably within the licensee=s ability to foresee and correct, and
that should have been prevented. A performance deficiency can exist if a
licensee fails to meet a self-imposed standard or a standard required by
regulation.

If the performance deficiency has related cross-cutting aspects, the
cross-cutting aspects

are generally considered an underlying cause of the performance
deficiency rather than

an independent issue. Issues of problem identification and resolution,
human performance, or establishment of a safety-conscious work
environment, in and of themselves, do not provide the basis for a
performance deficiency.

[Potentially Generic Issue]{.underline}: An inspection finding that may
have implications for other licensees, certificate holders, or vendors
whose facilities or activities are of the same or similar manufacture or
style.

[Red Finding]{.underline}: A finding of high safety significance.

[Self-Revealing]{.underline}: For the purpose of documentation in the
ROP (versus enforcement), self-revealing findings are those findings
that become self-evident and require no active and deliberate
observation by the licensee or NRC inspectors to determine whether a
change in process or equipment capability or function has occurred.
Additionally, self-revealing findings will normally be documented in the
inspection report for the time period in which the self-revealing event
occurred. Self-revealing findings become readily apparent to either NRC
or licensee personnel through a readily detectable degradation in the
material condition, capability, or functionality of equipment or plant
operations. Self-revealing findings are treated the same as
NRC-identified findings for the purposes of documenting them in
inspection reports. Some examples of self-revealing findings include
those resulting from: reactor trips and secondary plant transients;
failure of emergency equipment to operate; unanticipated or unplanned
relief valve actuations; obvious failures of fluid piping or plant
equipment; and identification of large quantities of water in areas
where you would not normally expect such a condition; non-compliance
with high radiation area requirements that was identified through an
electronic dosimeter alarm.

[Significance]{.underline}: A measure of importance. As used in this
IMC, significance involves the consideration of: (1) actual safety
consequences; (2) potential safety consequences, including the
consideration of risk information; (3) potential for impacting the NRC=s
ability to perform its regulatory function; and (4) any willful aspects
of the violation.

[Significance Determination Process (SDP)]{.underline}: The process used
to characterize the importance of an inspection finding using the
process described in IMC 0609.

[Substantive]{.underline}: Involving matters of major or practical
importance; considerable in amount or numbers. In this IMC, substantive
information must be placed in context relative to the inspection scope
and the potential or actual safety significance.

[Unresolved Item (URI)]{.underline}: An issue about which more
information is required to determine if it is acceptable, if it is a
finding, or if it constitutes a deviation or violation. Such a matter
may require additional information from the licensee or cannot be
resolved without additional guidance or clarification/interpretation of
the existing guidance (e.g., performance indicator reporting guidance).

[Violation (VIO)]{.underline}: The failure to comply with a legally
binding regulatory requirement, such as a statute, regulation, order,
license condition, or technical specification.

[Weakness]{.underline}: (Applies to emergency preparedness) A
demonstrated level of performance (e.g., in a drill) that could have
precluded effective implementation of the emergency plan in the event of
an actual emergency.

[Willfulness]{.underline}: An attitude toward noncompliance with
requirements that ranges from careless disregard to a deliberate intent
to violate or falsify.

[White Finding]{.underline}: A finding of low to moderate safety
significance.

[Yellow Finding]{.underline}: A finding of substantial safety
significance.

0612‑04 RESPONSIBILITIES

04.01 [General Responsibilities]{.underline}. Each inspection of a
reactor facility shall be documented in a report consisting of a cover
letter, a cover page, a summary of findings or summary of issues, and
inspection details.

04.02 [Inspectors]{.underline}.

> a\. All NRC power reactor inspectors are required to prepare
> inspection reports in accordance with the guidance provided in this
> manual chapter.
>
> b\. Inspectors have the primary responsibility for ensuring that
> inspection findings are accurately reported, and that referenced
> material is correctly characterized.
>
> c\. Inspectors are responsible for ensuring that the content of the
> inspection report does not conflict with the information presented at
> the exit meeting.

04.03 [Branch Chiefs and Division Directors]{.underline}.

> a\. A manager familiar with NRC requirements in the inspected area
> shall review each inspection report to ensure that the report follows
> the format given in this chapter.
>
> b\. The management reviewer shall ensure that inspection findings are
> consistent with NRC policies and technical requirements and that
> enforcement-related findings are addressed in accordance with the NRC
> Enforcement Policy and the NRC Enforcement Manual.
>
> c\. The management reviewer shall ensure that significance
> determinations made in the inspection report are in accordance with
> IMC 0609.

d.  Regional managers shall establish internal procedures to provide a
    record of inspectors\' and reviewers\' concurrences. The procedures
    should address how to ensure continued inspector concurrence when
    substantive changes are made to the report as originally submitted,
    and how to treat disagreements that occur during the review process.

> e\. The applicable division director or designated branch chief is
> responsible for the report content, tone, overall regulatory focus,
> and timeliness of regional inspection reports.

04.04 [Division of Inspection and Regional Support]{.underline}. The
Reactor Inspection Branch is responsible for providing interpretations
of the information contained in this manual chapter, for answering
questions related to the guidance, and for providing guidance for
situations not covered in this manual chapter.

0612-05 SCREENING INSPECTION RESULTS

The documentation process begins with the screening of inspection
results to determine if an inspection issue must be documented in an
inspection report. Use the process described in the following steps to
screen inspection results.

05.01 [Screen for Performance Deficiencies]{.underline}. Determine if a
performance deficiency exists.

> a\. Answer the performance deficiency question in Appendix B, Section
> 1.
>
> b\. If the answer to the performance deficiency question is ANo,@ then
> the issue is not a performance deficiency. However, if the issue is a
> violation, then review the information with your immediate supervisor
> and the regional enforcement coordinator to determine the appropriate
> action. Go to Section 0612-06.
>
> Note: Inspectors shall use the ROP Feedback Program, IMC-0801, to
> document situations where issues cannot be described in inspection
> reports (issues must result in a greater-than-minor finding) because
> there is no regulation or \"self-imposed\" standard associated with
> the deficient condition.
>
> c\. If the answer to the question is AYes,@ then the issue is a
> finding. Go to Section 05.02 of this chapter.

05.02 [Screen for Traditional Enforcement Action]{.underline}. This
screen is used to determine if a finding warrants consideration of
enforcement action using severity levels and possible civil penalties by
virtue of being in one of the prescribed categories for traditional
enforcement. It is expected that only a small fraction of all identified
findings will be traditional enforcement findings.

> a\. Answer the enforcement questions listed in Appendix B, Section 2.
>
> b\. If the answer to any of the enforcement questions is a AYes,@ then
> the finding should be addressed by traditional enforcement. Discuss
> the finding with management to determine severity level and
> enforcement action. If the finding can also be evaluated with an SDP,
> discuss options with management. Go to Section 0612-06.

05.03 [Screen for Greater than Minor]{.underline}.

> a\. Review the list of sample minor findings listed in Appendix E.
>
> b\. If the finding is similar to the samples listed as being minor,
> then the finding should not be documented.
>
> If the finding is similar to the samples as being greater than minor,
> then describe the set of conditions that make the finding greater than
> minor (e.g., the associated cornerstone attribute and how the
> objective was affected).
>
> c\. If the examples in Appendix E are not applicable, then answer the
> minor questions in Appendix B, Section 3.
>
> If the answer to any of the minor questions is AYes,@ then go to
> section 05.04 of this chapter to determine its safety significance.
> Also, describe the set of conditions that make the finding greater
> than minor (e.g., the associated cornerstone attribute and how the
> objective was affected).
>
> d\. If the answer to all of the minor questions is ANo,@ then do not
> document the finding. See exception in text box noted below.

05.04 [Screen for Significance]{.underline}. Determine the significance
of the greater than minor finding.

> a\. Review the questions contained in Appendix B, Section 4 to
> determine if the finding can be evaluated with an SDP.
>
> b\. If the questions indicate that use of an SDP is appropriate, then
> go to the appropriate section of IMC-0609, process the finding through
> the SDP, determine the color of the finding, and document the finding
> in the appropriate section of the report.
>
> c\. If a finding is greater than minor, but cannot be evaluated by an
> SDP and does not fit traditional enforcement, then submit the finding
> for review by the regional branch chief to ensure that it is of very
> low safety significance (Green). If management review determines that
> the finding has the potential to be greater than Green in
> significance, then the disposition of the finding must be coordinated
> with the Regional Enforcement Coordinator.

Note: For issues involving the maintenance rule, the Quality and Vendor
Branch of Division of Engineering in NRR must be consulted before
finalizing the inspection findings.

0612-06 WRITING INSPECTION DETAILS

After each inspection issue has been screened and the determination has
been made about what must be included in an inspection report, the
details supporting each finding must be documented. The term finding as
used in this section implies that it was determined to be greater than
minor and requires documentation. The Details section of routine and
integrated NRC inspection reports must conform to the standard format
described in this section.

In those cases where a standard format is not readily applied, the most
important subject should be identified first, followed by a discussion
of major topics identified in descending order of significance.

Exceptions to the standard format include:

-   Supplemental inspection reports;

-   Augmented inspection team (AIT) reports;

-   Special inspection reports; and,

-   Other cases where the specifically directed focus of the inspection
    does not easily fit into the standardized report outline (i.e.,
    license renewal inspections).

Additional guidance:

-   Supplemental inspection results must also reflect the additional
    guidance provided in Appendix C.

-   IP 71152, AIdentification and Resolution of Problems,@ results have
    varying thresholds for documentation and must reflect the guidance
    provided in Appendix D.

-   Escalated enforcement actions must reflect the guidance found in the
    Enforcement Manual, Appendix B, AStandard Formats for Enforcement
    Packages.@

06.01 [Inspectable Area]{.underline}. Identify the inspectable area as
defined in Exhibit 1.

> Additional guidance:
>
> a\. Violations of requirements that involve willfulness, actual safety
> consequences, or are potentially the result of impeding the regulatory
> process (i.e., traditional enforcement), are documented in accordance
> with the Enforcement Manual and are reported under the inspectable
> area in which the violation was discovered.
>
> b\. If a violation is not a performance deficiency, and [does
> not]{.underline} involve willfulness, actual safety consequences, or
> impeding the regulatory process, then it is documented in accordance
> with the Enforcement Manual in Section 4OA5 of the inspection report.
> Do not use the four-part format as described in Section 06.03 of this
> manual chapter.
>
> c\. If a violation is unrelated to a specific inspectable area, then
> document the finding in Section 4OA5 of the inspection report.
>
> d\. Individual licensee-identified findings found during drill
> critiques or other evaluations that may be of some value as a
> potential future Problem Identification and Resolution (PI&R)
> inspection sample may be listed as a cross-reference in Section 4OA2
> of the inspection report to findings already documented elsewhere.
> These findings must be greater than minor.
>
> e\. Old design issues that meet documentation screening criteria
> should be documented under the applicable inspectable area. See
> Section 06.06 of IMC-0305, AOperating Reactor Assessment Program,@ for
> additional documentation requirements for old design issues.

06.02 [Inspection Scope]{.underline}. Describe the inspection scope. Do
not repeat any portion of the Scope in the Findings section. The scope
should include the following:

> a\. Identify [how]{.underline} the inspection was conducted (i.e.,
> [the methods]{.underline} of inspection.) Methods can include a
> walk-down, an in-office review, observation of test from the control
> room, discussion with specific personnel, or participation in an
> exercise.
>
> b\. Identify [what]{.underline} was inspected. Include sufficient
> detail on [which]{.underline} and [how many samples]{.underline} were
> inspected. If more than six documents were reviewed, then list the
> items in an attachment and reference the attachment in the Scope
> section.
>
> c\. Identify the inspection [objectives and the criteria]{.underline}
> that were used to determine whether the licensee is in compliance.
>
> d\. Include inspection dates to clarify inspection scope context if it
> helps with understanding the scope. For example, inspection dates may
> be helpful when discussing event follow-up.
>
> e\. If a substantive portion of the inspection activity was conducted
> at a location other than the plant, (e.g., an in-office review), then
> identify [where]{.underline} the inspection took place.

06.03 [Findings]{.underline}. The Findings section of the report is used
to document the following:

-   NRC-identified or self-revealing findings and violations known to be
    Green and minor violations that require documentation,

-   Findings and violations potentially greater than Green (AV),

-   Findings and violations greater than Green, and

-   All unresolved items (see section 08.01 for additional guidance).

If no findings or only minor findings that do not require documentation
were identified within an inspectable area, then state ANo findings of
significance were identified@ in the Findings section of the report.

Present the findings within each report section in order of importance.
USE A FOUR PART FORMAT: an introduction, a description, an analysis, and
a discussion of the enforcement related to each of the findings. For
unresolved items and AVs, clearly state what is needed to close the
issue.

> a\. [Introduction]{.underline}. Begin with one or two sentences that
> provide the overall Abottom line@ results of the inspection in the
> area. This section does not need to stand alone because the
> description that follows will provide the supporting details.
>
> The introduction must include a brief summary of the risk
> characterization, if applicable (i.e., either color or significance)
> and applicable enforcement or severity level.
>
> b\. [Description]{.underline}. Describe the performance deficiency
> that constitutes the basis for the finding. The level of detail in the
> description should reflect the actual or potential safety consequence
> associated with a finding. Potentially significant findings may merit
> more discussion. Uncomplicated Green findings should be succinctly
> described in less than one page. Complex Green findings should be
> described in not more than two pages. More significant findings may
> need more documentation because of their complexity and significance.
>
> If a finding is likely to have generic concerns, then include details
> such as the manufacturer=s name and model number for components,
> specifications, and other names and technical data that identify the
> item of concern.
>
> c\. [Analysis]{.underline}. Describe the logic used to determine the
> significance (color) of the finding. However, do not provide every
> detail of the basis for each assumption. The level of detail must
> allow a knowledgeable reader to reconstruct the decision logic used to
> arrive at the final conclusion. Describe why the finding is important.
> Include a description of any positive licensee performance that
> mitigated a potential problem and influenced the significance of the
> finding.

The following is specific guidance on what to include in the Analysis
section.

> 1\. [Risk-Informed SDP Results - Results from IMC 0609 Appendices A,
> F, G, H and K]{.underline}.

a.  If SDP phase one screening assesses the finding as very low safety
    significance (Green), the analysis should identify:

-   The affected cornerstone;

-   The set of conditions that make the finding greater than minor
    (e.g., the associated cornerstone attribute and how the objective
    was affected);

-   The assumptions used in the determination; and,

-   The phase 1 question that was satisfied that caused the finding to
    be assessed as Green (e.g., AThe loss of function did not exceed the
    allowed out of service time@).

> \(b\) If the SDP phase one screening results in a phase 2 or 3
> evaluation, the analysis should identify:

-   The affected cornerstone(s);

-   The set of conditions that make the finding greater than minor,

-   The assumptions used in the determination;

-   The phase 1 criteria that was satisfied that caused the finding to
    be assessed as Green or above;

-   The most dominant core damage sequences, including the remaining
    mitigation capability that limited the significance; and,

-   The resulting color (i.e., Green, TBD, etc.).

> \(c\) For findings that are greater than Green, the analysis should
> use the risk characterization as determined by the Significance
> Determination Enforcement Review Panel (SERP) as its basis and should
> identify:

-   The exposure time;

-   Recovery credit; and,

-   All sequences greater than Green.

> 2\. [Non-Risk-Informed SDP Results - Results from IMC 0609 Appendices
> B, C, D, E, I, and J]{.underline}.

The analysis should identify:

-   The affected cornerstone;

-   The set of conditions that makes the finding greater than minor
    (e.g., the associated cornerstone attribute and how the objective
    was affected);

-   The SDP used in the determination;

-   Any assumptions used in the determination;

-   The table or flowchart used; and,

-   A description of the path on the flow chart used to arrive at the
    conclusion.

> 3\. [Non-SDP Findings]{.underline}. If a finding is greater than minor
> and not suited for SDP analysis and a regional management review has
> determined that it is Green, then the analysis section must describe
> the basis for the Green significance.
>
> The analysis section should identify:

-   The conditions that make the finding greater than minor, and

-   The set of conditions that would have been needed to make the
    finding greater than very low safety significance, or an explanation
    of why the finding is not greater than very low safety significance.

> The analysis section should include the following statement: AThe
> finding is not suitable for SDP evaluation, but has been reviewed by
> NRC management and is determined to be a finding of very low safety
> significance.@
>
> If management review has determined that the finding is potentially
> greater than Green, then the finding must be reviewed further and the
> regional enforcement coordinator should be informed. The analysis
> section should be used to document the circumstances that require
> further evaluation and should state AThe finding is not suitable for
> SDP evaluation, but is being reviewed by NRC management and
> coordinated with the Office of Enforcement to identify the
> significance and appropriate disposition.@
>
> Once the finding is finalized and determined to be greater than Green,
> the inspection report should describe the basis used for determining
> the significance of the finding.
>
> 4\. [Traditional Enforcement]{.underline}. If a finding is
> dispositioned using traditional enforcement, the analysis section
> should identify:

-   The traditional enforcement criteria that were met,

-   The logic on how the severity level was determined, and

-   The results of any SDP evaluation that was performed, if applicable.

> 5\. [Findings Related to Cross-Cutting Areas]{.underline}. The
> cross-cutting aspect of a finding is not considered a separate
> cross-cutting finding but rather is documented in the inspection
> report as a significant contributing cause of the finding, if
> applicable, by the inspector identifying the finding. The intent of
> identifying the cross-cutting aspect of a finding is to ensure it is
> coded as such in the Plant Issue Matrix (PIM) in order to support the
> assessment process.
>
> All findings with a cross-cutting aspect must meet the following
> requirements:

-   The finding is evaluated as more than minor (note: cross-cutting
    aspect of the finding shall not be used to determine whether the
    finding is greater than minor),

-   Cross-cutting aspect was a significant contributor to the inspection
    finding,

-   The cross-cutting aspect of the inspection finding is reflective of
    current licensee performance, and

-   Cause of the finding is related to one of the three cross-cutting
    areas (Problem Identification and Resolution, Human Performance, or
    Safety-Conscious Work Environment).

> When all of these requirements associated with cross-cutting aspects
> of the inspection finding are met, then describe it in the analysis
> paragraph. Specifically state the relationship between the
> cross-cutting aspect and the cause of the finding.
>
> Inspectors should provide enough information in the inspection
> findings to enable regional management to determine whether a
> cross-cutting theme exists amongst the inspection findings during the
> mid-cycle and end-of-cycle assessment reviews. Specifically, for every
> finding that has a cross-cutting aspect, inspectors should document
> the reasons why that cross-cutting aspect is a significant contributor
> to the finding, using language that parallels the descriptions of
> cross-cutting aspects as discussed in section 06.07.c of IMC 0305 (see
> IMC 0612, Appendix F for examples).
>
> 6\. [Tracking Non-Regulatory Findings]{.underline}. If the finding
> does not involve a violation of regulatory requirements and is Green,
> add the following sentence to the end of the analysis section:
>
> ABecause this finding does not involve a violation of regulatory
> requirements and has very low safety significance, it is identified as
> FIN \[Tracking Number\], Title.@
>
> If the finding is potentially greater than Green, add the following
> sentence to the end of the analysis section:
>
> ABecause this finding does not involve a violation of regulatory
> requirements and has potentially greater-than-Green safety
> significance, it is identified as AV \[Tracking Number\], Title.@
>
> d\. [Enforcement]{.underline}. Findings found or reviewed during
> inspections that also include violations of regulatory requirements
> are documented in accordance with the NRC Enforcement Policy and
> Section 2.13 of the NRC Enforcement Manual. The enforcement discussion
> and subsequent enforcement action must be consistent with the
> significance determination.
>
> Do not speculate or reach conclusions about the intent behind a
> violation. Conclusions about the willfulness of a violation are agency
> decisions, and are normally not made until after the Office of
> Investigations (OI) has completed an investigation. A premature or
> inaccurate discussion of the willfulness of a violation in the
> inspection report could result in later conflicts based on additional
> input and review. Inspection reports that include potentially willful
> violations must be coordinated with OI and the Office of Enforcement
> (OE).
>
> 1\. If there is no violation associated with a finding, the
> enforcement section of the report should include the following
> statement: ANo violation of regulatory requirements occurred@ or
> AEnforcement action does not apply because the performance deficiency
> did not involve a violation of a regulatory requirement.@
>
> 2\. NRC-identified non-cited violations (NCVs) should be considered
> for cited violations of the original requirement if the licensee
> failed to restore compliance within a reasonable time after a
> violation was identified or the licensee did not place the violation
> into a corrective action program to address recurrence (see Section
> VI.A.1 of the NRC Enforcement Policy).
>
> 3\. If a finding is potentially greater than Green, [the Enforcement
> section must clearly state]{.underline} why the finding does not
> present an immediate safety concern, and (if appropriate) that
> licensee compensatory measures are in place while licensee long-term
> corrective measures are being implemented.
>
> 4\. If a violation is of very low safety significance (Green) or
> categorized at Severity Level IV and the criteria specified in Section
> VI.A.1 of the Enforcement Policy does not apply, then the violation
> may be dispositioned as a NCV. Document it in accordance with the
> guidance in Section 3.1 of the Enforcement Manual.
>
> To address recurrence, as the term is used in Section VI.A.1 of the
> NRC Enforcement Policy, means that the licensee enters the issue into
> the established corrective action program for appropriate evaluation
> and corrective action. For the purposes of meeting the NCV criteria,
> the inspectors will ensure that the licensee has placed the violation
> into the corrective action program. Inspectors are not expected to
> evaluate the appropriateness of the licensee\'s plan to address
> recurrence. The actual corrective actions the licensee subsequently
> takes are subject to review during future problem identification and
> resolution inspections and can be evaluated at a later date.
>
> For SDP and management decision findings of very low safety
> significance, state:
>
> ABecause this violation was of very low safety significance and it was
> entered into the licensee=s corrective action program, this violation
> is being treated as an NCV, consistent with Section VI.A.1 of the NRC
> Enforcement Policy.@

For Severity Level IV violations, state:

> ABecause this violation was of very low safety significance, was not
> repetitive or willful, and it was entered into the licensee=s
> corrective action program, this violation is being treated as an NCV,
> consistent with section VI.A.1 of the NRC Enforcemnet Policy.@
>
> 5\. Issue a notice of violation (NOV) if a Severity Level IV violation
> or violation associated with a Green finding meets any one of the
> criteria in Section VI.A.1 of the Enforcement Policy.
>
> 6\. The enforcement section for any described violation must include
> sufficient information, in combination with other sections, to support
> the conclusion that the finding is more than minor and is a violation
> of regulatory requirements. At a minimum the enforcement section
> should state:

-   What requirement was violated;

-   How the violation occurred;

-   When the violation occurred and how long it existed;

-   When the violation was identified;

-   Any actual or potential safety consequence (if not described
    earlier);

-   The root cause or apparent root cause at the time of report writing
    (if identified and not described earlier);

-   What immediate corrective actions were taken to restore compliance
    (if not described earlier) and a reference to the licensee=s
    corrective action document number; and,

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-   Specific enforcement actions (i.e., cited or non-cited) and tracking
    number resulting from the violation.

> 7\. 10 CFR 50, Appendix B, Criterion XVI violations for failure to
> Apreclude repetition@ can only be written for Asignificant@ conditions
> adverse to quality (SCAQ). The inspection report details must clearly
> explain the basis for determining that the previous condition was a
> SCAQ (\"i.e., the condition meets the definition of a SCAQ per the
> licensee\'s corrective action program\"), the relationship between the
> previous SCAQ and the current one, and the corrective actions from the
> previous SCAQ that failed to prevent recurrence.
>
> 8\. AVs that are associated with findings that are either (1)
> preliminarily determined to have more than very low safety
> significance (i.e., White, Yellow, or Red), or (2) greater than
> Severity Level IV in traditional enforcement, should also include the
> following in the enforcement section if available at the time of
> documentation:

-   The significance attributed to the finding by the licensee. If the
    significance is different than that determined by the NRC, then
    describe the assumptions used by the licensee, and identify what the
    licensee considered applicable to its determination that the NRC did
    not consider.

-   The licensee=s position on the NRC=s determination that a
    requirement has been violated.

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-   If appropriate, the section should also identify the licensee=s
    compensatory measures that are in place while the licensee
    implements its long-term corrective measures.

> The significance of the finding is reported as ATo Be Determined
> (TBD).@ Emphasize that the safety characterization is not yet
> finalized.
>
> CAUTION: Do not make direct statements regarding safety significance
> in the inspection report when the agency has not yet reached a
> conclusion. Conclusions about the significance of findings that are
> greater than Green and associated violations are agency decisions and
> are normally not made when the report is issued. A premature or
> inaccurate discussion of the finding in the inspection report could
> become inaccurate as a result of subsequent input and review.

06.04 [Tracking]{.underline}. All NRC-identified and self-revealing
findings, violations, NRC-identified and self-revealing non-cited
violations, AVs, and unresolved items must be assigned a sequential
tracking number. See Exhibit 2 for guidance on the type code to be used
in the Reactor Protection System (RPS). There must be a one-to-one
correlation between the number of item entries in the Reactor Program
System (RPS) and the number of NRC-identified and self-revealing
findings, violations, NRC-identified and self-revealing non-cited
violations, AVs, and unresolved items.

Type code AAV@ should be used for an inspection finding which may or may
not have regulatory requirements associated with it and is being
reviewed by the senior reactor analyst because it may be potentially
greater-than-green in risk significance. Once a final significance
determination is made for an AV, the AV shall be updated in accordance
with IMC 0306, AInformation Technology Support for the Reactor Oversight
Process.@

0612-07 DOCUMENTING PERFORMANCE INDICATOR VERIFICATION RESULTS

All performance indicator (PI) verification baseline inspections shall
be documented under Section 4OA1.

07.01 [Scope]{.underline}. When writing the scope section, include the
time period for which the PI data was verified. Include the criteria
used to verify the PIs. List the PIs verified and the associated
cornerstones. When there are findings to report, list the individual PI
scope and findings separately.

07.02 [Findings]{.underline}. When assessing PIs, if the inspector
identifies an error that, upon correction by the licensee, resulted in
the licensee crossing a PI threshold, the issue needs to be documented
in the Findings section. Briefly describe the circumstances surrounding
the finding in the write‑up. Inaccurate and incomplete PI data
violations should be dispositioned in accordance with the guidance in
Supplement VII of the Enforcement Policy and Section 7.8 of the
Enforcement Manual.

If the inspector disagrees with the licensee=s data or the licensee=s
interpretation of the reporting guidance, the issue will be resolved
using the inspection feedback process or PI frequently asked questions
(FAQs) process and should be identified as an unresolved item. The
region should contact the Performance Assessment Branch of NRR and
submit a feedback form capturing their concerns and perspectives. Upon
resolution of all interpretation issues and the FAQ, the issue should be
closed in accordance with the closure guidance described in IMC 0608,
?Performance Indicator Program.@

0612-08 DOCUMENTING UNRESOLVED ITEMS

08.01 [Opening]{.underline}. Unresolved items are identified for
tracking purposes and are documented only in the body of the inspection
report. Unresolved items are not documented in the summary findings
section or on the inspection report cover letter. Refer to section 06.04
for guidance on how to assign a tracking number. The action of
documenting an unresolved item is a commitment of future resources, and
should only be used when some specific licensee action is pending or
when needed information is not available at the time of the inspection.

Initiate an unresolved item when additional information is required to
determine if it is acceptable, if it is a finding, or if it constitutes
a deviation or violation. An unresolved item should not be opened if the
resolution is likely to result in a minor issue. For an unresolved item,
the report must identify the specific licensee or NRC actions needed to
resolve the issue.

08.02 [Follow-up and Closure]{.underline}. The level of detail devoted
to closing unresolved items

depends on the nature and significance of the additional information
identified. The closure of an unresolved item must summarize the topic,
summarize the inspector\'s follow-up actions, evaluate the adequacy of
any licensee actions, determine if a violation has occurred, and provide
enough detail to justify closing the item. If resolution to an
unresolved item was based on discussions between inspector(s) and NRR
technical staff(s), concisely document the details of these discussions
as the basis for the regulatory decision. Additionally, branch chiefs of
inspector(s) and technical staff(s) who were involved in these
discussions should concur on the inspection report. If a finding is
identified, use the four part format. If multiple unresolved items
exist, a summary of the items may be included at the end of the report.
Document closure in Section 4OA5 or in the inspectable area section.

0612-09 DOCUMENTING LERs AND LICENSEE-IDENTIFIED VIOLATIONS

NRC policy requires that all documented non-compliances be dispositioned
in accordance with the Enforcement Policy, regardless of who identified
them. However, licensee-identified violations that are of very low
safety significance and incorporated into the licensee=s corrective
action program should have minimal documentation. See Section 0612-03
for definitions of Alicensee-identified@ and Aself-revealing.@

09.01 [Licensee Event Reports (LERs)]{.underline}. Document reviews and
closures of LERs, including revisions to LERs, in the inspection report
under Section 4OA3, AEvent Follow‑up.@ If inspection in another
cornerstone area provides a description of the event in the LER (i.e.,
personnel performance during non-routine evolutions), then that section
of the report should be referenced under Section 4OA3 with a very brief
description.

In general, LER reviews should have a brief description of the event and
reference the docketed LER. If an LER review is already documented in a
separate NRC correspondence, then close the LER with a brief statement
in an inspection report referencing the separate correspondence.

> a\. [LERs without Violations]{.underline}.
>
> 1\. [LERs without Findings and with Minor Findings]{.underline}. State
> that the LER was reviewed and that no findings of significance were
> identified and no violation of NRC requirements occurred.
>
> 2\. [LERs with Greater than Minor Findings]{.underline}. For
> NRC-identified or self-revealing findings, the four part format in
> section 06.03 must be followed if not previously documented. For
> licensee-identified Green findings, include the safety significance of
> the event and reference the licensee=s corrective action program
> tracking number. In both cases, include a statement that no violation
> of NRC requirements occurred.
>
> b\. [LERs with Violations]{.underline}. An LER may describe an issue
> that appears to be a violation, but does not clearly state that a
> violation of requirements existed. If the LER states that a violation
> occurred, or if it is obvious that a violation is involved (e.g.,
> Afailure to follow procedures,@ in the title or body of the LER), then
> the violation must be identified clearly in the report as a cited
> violation, non-cited violation or as a minor violation, as
> appropriate, or warranting enforcement discretion if no performance
> deficiency occurred.
>
> 1\. [LERs with Minor Violations]{.underline}. Documenting a minor
> violation may be warranted as part of closing out a Licensee Event
> Report. If it is necessary to document a minor violation then only
> minimal discussion is required. The writeup should state that the
> issue has been addressed by the licensee and should include the
> following: AThis failure to comply with {requirement} constitutes a
> violation of minor significance that is not subject to enforcement
> action in accordance with Section IV of the NRC=s enforcement policy.@
>
> 2\. [LERs with Greater than Minor Violations]{.underline}. For
> NRC-identified or self-revealing violations, the four part format in
> section 06.03 must be followed if not previously documented. For
> licensee identified non-cited violations, safety significance and
> enforcement should be discussed per Section 09.02 of this manual
> chapter and not in the LER closeout section. A statement, such as AThe
> enforcement aspects of this finding are discussed in Section 4OA7,\"
> should be included in the LER closeout section.

09.02 [Licensee-Identified Finding]{.underline}.

> a\. If a licensee-identified finding is a violation, of very low
> safety significance, and the licensee has correctly evaluated the
> finding and has developed appropriate corrective actions, then briefly
> describe the violation in Section 4OA7. Include the requirement(s)
> violated, describe how it was violated, identify the licensee=s
> corrective action tracking number(s), and provide a very brief
> justification why the violation is not greater than Green. A complete
> reconstruction of the SDP logic is not required. However, Section 4OA7
> must include the following introductory paragraph:
>
> AThe following violations of very low safety significance (Green) were
> identified by the licensee and are violations of NRC requirements
> which meet the criteria of Section VI of the NRC Enforcement Policy,
> NUREG-1600, for being dispositioned as a Non-Cited Violation.@
>
> b\. If a licensee-identified finding is not a violation, finding is of
> very low safety significance, and the licensee has correctly evaluated
> the finding and has developed appropriate corrective actions, then the
> finding should not be documented in the inspection report.
>
> c\. If a licensee-identified finding is potentially greater-than-green
> significance then the finding must be analyzed using the SDP, treated
> as a NRC-identified finding, and documented and dispositioned in
> accordance with the guidance in the Enforcement Policy and Enforcement
> Manual.
>
> d\. If a problem exists with the licensee=s evaluation or corrective
> actions associated with the licensee-identified finding and if further
> inspection added significant value, then document the finding as a
> NRC-identified finding under the applicable cornerstone section of the
> report. Documentation should clearly emphasize that the licensee
> identified the finding but failed to recognize the problem identified
> by the inspector.

0612-10 OTHER GUIDANCE

10.01 [Treatment of Third Party Reviews]{.underline}. Detailed NRC
reviews of Institute of Nuclear Power Operations (INPO) evaluations,
accreditation reports, findings, recommendations, and corrective
actions, or other third party reviews with similar information are not
referenced in NRC inspection reports, tracking tools, or other agency
documents unless the issue is of such safety significance that no other
reasonable alternative is acceptable. INPO findings, recommendations and
associated licensee corrective actions are not normally tracked by the
NRC. If a finding warrants tracking, it should be independently
evaluated, documented, and tracked as an NRC finding in Section 4OA5.

However, INPO findings, recommendations, corrective actions, and
operating experience which are placed in the licensee=s corrective
action program, can be considered appropriate for inspection.
Additionally, when documenting review of these issues which originated
from INPO, inspection reports should not refer to any proprietary INPO
reports or documents, INPO reference numbers, or identify specific sites
when referencing operating experience. If it is necessary to document
review of an INPO document (i.e., the condition report referring to the
INPO document was an inspection sample or justification for a
cross-cutting aspect), then state the condition report number and
provide general words for the title. For example, ACondition Report No.
235235 concerning industry information on pumps.@

Include a short statement in the inspection report to document that a
review of a specified INPO evaluation or accreditation report was
completed. Do not include a recounting or listing of INPO findings or
reference a final INPO rating when documenting an INPO evaluation or
accreditation report review. Discuss the specifics of any significant
differences between NRC and INPO perceptions with regional management.

10.02 [Non-Routine Inspections]{.underline}. Document in Section 4OA5
inspection results from IMC 2515 Appendix C, temporary instructions
(TIs) and other non-routine inspection activities not addressed in this
manual chapter.

0612-11 COMPILING AN INSPECTION REPORT

11.01 [Report Organization]{.underline}. Arrange the Report Details in
accordance with the standard report outline shown in Exhibit 1. Each
outline topic does not have to be covered in each report. When an
inspection is performed in a particular area, the resulting details are
placed in the corresponding section of the report.

11.02 [Plant Status]{.underline}. If appropriate, write a Summary of
Plant Status section. If used, briefly describe pertinent operational
events, such as any plant shutdowns or significant changes in power.
This summary is not needed for specialist inspections since plant
operating status may not be relevant to a safeguards or emergency
preparedness inspection.

11.03 [Summary of Findings]{.underline}. The summary should be an
informative but concise overview of the significant inspection findings
contained in the details of the report. It will also be used for entries
to the Agency-wide Documents Access and Management System (ADAMS) and
the RPS Plant Issues Matrix (PIM).

> a\. The first paragraph of the summary of findings section is used to
> describe the inspection report in ADAMS (title value field in ADAMS).
>
> The paragraph must include the following, in order:

-   the inspection report number (See Exhibit 3 for format),

-   the dates of the inspection,

-   the name of the site, and

-   the titles of only the inspection procedures or attachments in which
    findings were identified (e.g, equipment alignment, fire protection,
    operability evaluations).

> If no findings were identified, the general inspection area should be
> listed (e.g, radiation specialist report, or resident inspector
> report, or environmental report).
>
> For non-routine inspections, the same format should be followed to
> identify the report number, unit names, and dates of inspection. These
> are followed by the title of the inspection and a list of findings.
> (See Appendix D for examples.)
>
> b\. [Summary Paragraph]{.underline}. The summary paragraph follows the
> ADAMS template paragraph and describes who conducted the inspection
> (i.e., resident and/or specialist inspectors), the number of findings,
> and violations.
>
> The summary also includes an explanation that the significance of most
> findings is indicated by their color (greater than Green, or Green,
> White, Yellow, Red); that the significance was determined using IMC
> 0609, ASignificance Determination Process@ (SDP); and that findings
> for which the SDP does not apply may be Green or be assigned a
> severity level after NRC management review. This explanation is not
> included if no findings were identified.
>
> c\. [List of findings]{.underline}. Compile a list of findings by
> reviewing the details developed for each report section. Write a two
> paragraph summary for each issue that is designated a finding (FIN),
> violation (VIO), AVs, or non-cited violation (NCV). The text of the
> summaries must be consistent with the corresponding details in the
> inspection report.
>
> [Do]{.underline} [not]{.underline} document the following in the
> summary of findings: licensee-identified NCVs; unresolved items; and
> Green findings associated with LERs.
>
> 1\. First Paragraph: Begin the summary for each finding with the
> significance color. Use TBD for those findings where the significance
> or severity level has not yet been determined and for findings with a
> preliminary color greater than Green. Then, describe the finding
> including any enforcement action, the specific requirement violated,
> and identification credit for the finding. Include a brief description
> of the corrective actions completed or planned by the licensee, if
> applicable. If the planned corrective action is still being evaluated,
> a sentence stating such is sufficient.
>
> Second Paragraph: The second paragraph should briefly summarize the
> finding=s significance from the analysis section. Highlight the
> cross-cutting aspects of a finding, if appropriate. Each summary must
> end with a reference to the section of the report in which the finding
> is discussed.
>
> 2\. Group the findings summaries by cornerstones in the order
> specified in Exhibit 1.
>
> 3\. If a licensee-identified finding resulted in a violation, include
> the following boilerplate paragraph as the last paragraph of the
> summary of findings:
>
> AViolations of very low safety significance, that were identified by
> the licensee have been reviewed by the inspectors. Corrective actions
> taken or planned by the licensee have been entered into the licensee=s
> corrective action program. These violations and corrective action
> tracking numbers are listed in Section 4OA7 of this report.@

11.04 [Cover Page]{.underline}. The report cover page gives a succinct
summary of information about the inspection. It contains: the docket
number(s), license number(s), report number, licensee name, facility
name, facility location (city and state), dates of the inspection, names
and titles of participating inspectors (and may include names of those
inspectors who have achieved basic inspector certification but are not
yet fully qualified), and name and title of the approving NRC manager.
See Exhibit 3 for format.

The inspection report number is to be identified in the following form
as required by IMC 0306:

> Docket No./Year \[sequential number of the report in that year\]

(e.g., 05000410/2003001)

11.05 [Table of Contents]{.underline}. If a report is considered
complicated or of significant length, then develop a table of contents.
If the inspection report, from the Report Details section to the exit
interview section, is more than 20 pages long, a table of contents
should be considered.

11.06 [Exit Meeting Summary]{.underline}. Write a brief summary of the
exit meeting in Section 4OA6. This information will also be described in
the first paragraph of the cover letter. The summary must identify the
most senior licensee manager who attended the meeting and must include
the following information:

> a\. [Absence of Proprietary Information]{.underline}. At the exit
> meeting, the inspectors will verify whether the licensee considers any
> materials provided to or reviewed by the inspectors to be proprietary.
> If the licensee did not identify any material as proprietary, include
> a sentence to that effect in the exit meeting summary. See IMC 0620,
> AInspection Documents and Records,@ for actions to take if the report
> includes proprietary material.
>
> NOTE: When an inspection is likely to involve proprietary information
> (i.e., given the technical area or other considerations of inspection
> scope), handling of proprietary information should be discussed at the
> entrance meeting.
>
> b\. [Subsequent Contacts or Changes in NRC Position]{.underline}. If
> the NRC\'s position on an inspection finding changes after the exit
> meeting, conduct an additional exit meeting to discuss that change
> with the licensee. Also, document the additional exit meeting in the
> inspection report.
>
> c\. [Characterization of Licensee Response]{.underline}. Do not
> characterize a licensee=s exit meeting response. If the licensee
> disagrees with an inspection finding, this position may be
> characterized by the licensee in its formal response to the inspection
> report, if applicable.
>
> d\. [Oral Statements and Regulatory Commitments]{.underline}. Do not
> attempt to characterize or interpret any oral statements the licensee
> makes, at the exit meeting or at any other time during the inspection,
> as a commitment. Licensee commitments are documented by licensee
> correspondence, after which they may be referenced in the inspection
> report. Oral statements made or endorsed by a member of licensee
> management authorized to make commitments are not regulatory
> commitments unless they are documented as such by the licensee. For
> further guidance on licensee commitments, see ADAMS Accession Nos.
> ML003680088 (NEI 99-04), ML003680078 (NEI Cover Letter), and
> ML003679799 (SECY 00-045 endorsing NEI 99-04 guidance).
>
> Because regulatory commitments are a sensitive area, ensure that any
> reporting of licensee statements are paraphrased accurately and
> contain appropriate reference to the licensee=s document.

11.07 [Report Attachments]{.underline}. The attachments discussed below
are included at the end of the inspection report if applicable to the
inspection. The attachments may be combined into a single attachment
entitled \"Supplementary Information.\"

> a\. [Key Points of Contact]{.underline}. List, by name and title,
> those individuals who furnished relevant information or were key
> points of contact during the inspection (except in cases where there
> is a need to protect the identity of an individual). The list should
> not be exhaustive but should identify those individuals who provided
> information related to developing and understanding findings. The list
> includes the most senior licensee manager present at the exit meeting
> and NRC technical personnel who were involved in the inspection if
> they are not listed as inspectors on the cover page.
>
> b\. [List of Items Opened, Closed, Discussed, and
> Updated]{.underline}. The report shall include a quick reference list
> of items opened, closed, and updated, including the item type, the
> tracking number for the item, and a brief phrase matching the title
> used in PIM headers describing the item. Open items that were
> discussed (but not closed) should also be included in this list, along
> with a reference to the sections in the report in which the items are
> discussed. NCVs will normally be opened and closed in the initiating
> inspection report.
>
> c\. [List of Documents Reviewed]{.underline}. A list of the documents
> and records reviewed during an inspection must be publicly available.
> Therefore, include a listing of all the documents and records reviewed
> during the inspection that are not identified in the body of the
> report. \"Reviewed\" in this context means to examine critically or
> deliberately (see IMC 0620). The list does not include records that
> were only superficially reviewed. Lists consisting of more than six
> documents reviewed should be removed from the body of the report and
> included as an attachment.
>
> Documents and records reviewed for Security inspection reports will
> not be made publically available.
>
> If it is necessary to document review of an INPO document (i.e., the
> condition report referring to the INPO document was an inspection
> sample or justification for a cross-cutting aspect), then state the
> condition report number and provide general words for the title. For
> example, ACondition Report No. 235235 concerning industry information
> on pumps.@
>
> d\. [List of Acronyms]{.underline}. Recommend including a list of
> acronyms for any report whose Details section exceeds 20 pages. For
> reports in which a relatively small number of acronyms have been used,
> the list is optional. The list is also optional if more than 20 pages
> and the number of acronyms is relatively small. In all cases, however,
> acronyms should be spelled out when first used in inspection report
> text.

11.08 [Cover Letter]{.underline}. Write a cover letter to transmit the
overall inspection results and convey the inspection findings to the
licensee. Inspection reports are sent from the applicable NRC official
(branch chief, division director, or regional administrator) to the
designated licensee executive. See the inspection report documentation
matrix in Exhibit 2 for what should and should not be documented in the
inspection report cover letter. Examples of inspection report cover
letters can be found in Exhibit 4.

Guidance and cover letter formats for transmitting enforcement actions
vary. Guidance and sample cover letters for enforcement-related
correspondence are found in the Enforcement Manual, Appendix B,
AStandard Formats for Enforcement Packages.@

Cover letter content varies somewhat depending on whether or not the
inspection identified findings. In general, however, every cover letter
has the same basic structure as follows:

> a\. [Date]{.underline}. The NRC seal and address are at the top of the
> first page and are followed by the date on which the report cover
> letter is signed and the report issued.
>
> b\. [Enforcement Action]{.underline}. If the report contains findings
> assigned an enforcement action (EA) number, then the EA number should
> be placed in the upper left-hand corner above the principal
> addressee=s name.
>
> c\. [Addressee]{.underline}. The name and title of the principal
> addressee are placed at least four lines below the letterhead,
> followed by the licensee=s name and address.
>
> d\. [Subject Line]{.underline}. The subject line of the letter should
> state the plant name and inspection subject (e.g.,@XXXXX Generating
> Station - NRC Integrated Inspection Report@) followed by the report
> number. The information presented in the subject line must be in the
> following sequence: plant name, type of inspection, report number. Use
> the official plant name and docket number as described in Section
> 11.04.
>
> The words \"NOTICE OF VIOLATION\" (AEXERCISE OF ENFORCEMENT
> DISCRETION@ or \"NOTICE OF DEVIATION,\" etc.) must be included if an
> enforcement action accompanies the inspection report.
>
> e\. [Salutation]{.underline}. Ensure that the salutation follows the
> subject line.
>
> f\. [Introductory Paragraphs]{.underline}. The first two paragraphs of
> the cover letter should give a brief introduction, including the type
> of report (e.g., license renewal report, integrated inspection report)
> and pertinent dates (i.e., date of final exit meeting with licensee,
> date NRC was informed of licensee readiness for supplemental
> inspections, date decision was made that a reactive inspection would
> be conducted in response to events).
>
> g\. [Body]{.underline}. The body of the letter should discuss the most
> important topics first. The following identifies how different types
> of findings should be reflected in the cover letter to an inspection
> report.

+--------------------+-------------------------------------------------+
| IF:                | THEN:                                           |
+====================+=================================================+
| If there are no    | Insert a separate paragraph stating:            |
| findings           |                                                 |
| identified         | \"Based on the results of this inspection, no   |
|                    | findings of significance were identified.\"     |
+--------------------+-------------------------------------------------+
| If Green findings  | State the number but do not elaborate. Include  |
| are identified     | the following statement:                        |
|                    |                                                 |
|                    | AThere were \[the number\] findings of very low |
|                    | safety significance (Green) identified in the   |
|                    | report.\"                                       |
+--------------------+-------------------------------------------------+
| If Severity Level  | Document in accordance with the guidance in     |
| IV violations or   | Appendix B, Form 2 of the Enforcement Manual    |
| violations         |                                                 |
| associated with    |                                                 |
| Green findings are |                                                 |
| being              |                                                 |
| dispositioned as   |                                                 |
| NCVs or in NOVs    |                                                 |
+--------------------+-------------------------------------------------+
| If a finding has   | The cover letter should clearly state why the   |
| the                | finding does not present an immediate safety    |
| [pote              | concern, and (if appropriate) that licensee     |
| ntial]{.underline} | compensatory measures are in place while        |
| to be greater than | licensee long-term corrective measures are      |
| Green in           | being implemented.                              |
| significance       |                                                 |
+--------------------+-------------------------------------------------+
| If a finding       | Briefly discuss in the order of significance if |
| appears to be      | more than one finding. The appropriate wording  |
| greater than Green | for the findings that are also violations of    |
| and if an AV is    | requirements can be found in the Enforcement    |
| involved for which | Manual.                                         |
| a Notice of        |                                                 |
| Violation is being |                                                 |
| considered         |                                                 |
+--------------------+-------------------------------------------------+
| If a violation     | Discuss in accordance with the guidance in the  |
| appears to be      | Enforcement Manual.                             |
| greater than       |                                                 |
| Severity Level IV  |                                                 |
+--------------------+-------------------------------------------------+
| If a violation was | Insert the following paragraph:                 |
| identified but was |                                                 |
| not associated     | AAlthough this issue constitutes a violation of |
| with a performance | NRC requirements, we have concluded that        |
| deficiency         | (insert name of licensee)=s actions did not     |
|                    | contribute to the degraded condition and, thus, |
|                    | no performance deficiency was identified. Based |
|                    | on these facts, I have been authorized, after   |
|                    | consultation with the, Director, Office of      |
|                    | Enforcement, to exercise enforcement discretion |
|                    | in accordance with Section VII.B.6 of the       |
|                    | Enforcement Policy and refrain from issuing     |
|                    | enforcement action for the violation. An        |
|                    | evaluation was performed and we have determined |
|                    | that this was an issue of very low safety       |
|                    | significance (or, alternatively, definition for |
|                    | the corresponding color). (State here if any    |
|                    | other known agency action has been or will be   |
|                    | taken, e.g., forward to a technical branch,     |
|                    | evaluation by the Generic Safety Issue program, |
|                    | consideration of generic communication, Task    |
|                    | Interface Agreement, etc.)\"                    |
+--------------------+-------------------------------------------------+

> h\. [Closing]{.underline}. The final paragraph consists of standard
> legal language that varies depending on whether enforcement action is
> involved. See the example cover letter in Exhibit 4.
>
> The signature of the appropriate NRC official is followed by the
> docket number(s), license number(s), enclosures, and distribution
> list.

0612-12 ISSUING INSPECTION REPORTS

12.01 [Report Timeliness]{.underline}.

> a\. Most inspection reports, including Special Inspections, should be
> issued no later than 45 calendar days after inspection completion.

b.  Timeliness goals should be accelerated as necessary for inspection
    reports covering potential escalated enforcement actions and as
    specified in Management Directive 8.3 for reactive inspections;
    (e.g., AITs, and IITs.)

> NOTE: For inspections not conducted by a resident inspector,
> inspection completion is normally defined as the day of the exit
> meeting. For resident inspector and integrated inspection reports,
> inspection completion is normally defined as the last day covered by
> the inspection report.
>
> c\. Whenever an inspection reveals findings of significance (i.e.,
> White or higher) or other significant or immediate public health and
> safety concern, an expedited inspection report that is limited in
> scope to the specific findings should be considered.

12.02 [Release and Disclosure of Inspection Reports]{.underline}.

> a\. [General Public Disclosure and Exemptions]{.underline}. Except for
> report enclosures containing exempt information, all final inspection
> reports will be disclosed routinely to the public. IMC 0620,
> \"Inspection Documents and Records,\" gives guidance on acquiring and
> controlling NRC records, including inspection-related documents. In
> general, safeguards information or related sensitive information
> should not be released except as specified by current agency policy.
> Any questions regarding this policy should be referred to the program
> office.
>
> b\. [Security Cornerstone Inspection Reports]{.underline}. Inspection
> reports for the security cornerstone will [not]{.underline} be made
> publicly available. Security-related inspection reports will be sent
> to the respective State Liaison Officers and State Homeland Security
> Advisors, when they have been appointed, authorized, communicated a
> desire to receive the report, and have the resources to control the
> safeguards information. These reports will be controlled as safeguards
> information or exempt under 10 CFR 2.390 based on the level of
> information contained in them. However, the cover letters to the
> reports [will]{.underline} be made publicly available.
>
> The cover letters for security inspection reports will be similar in
> format to other inspection report cover letters (see IMC 0612,
> sections 11.08 a through h), but will not include details or
> descriptions of any inspection findings. The cover letters shall state
> the number of Green findings identified and a brief description of
> cross-cutting aspects, if applicable. However, the letters will
> [not]{.underline} state the number of greater than Green findings (if
> any were identified), only that findings with greater-than-green
> significance have been identified and a brief description of
> cross-cutting aspects, if applicable. See sample cover letter number 3
> of Exhibit 4 for standard paragraphs to include in security report
> cover letters.
>
> The cover letters will be marked for the highest level of controlled
> information contained in the inspection report: official use only
> (SUNSI) or safeguards information. The marking requirements for
> safeguards information is in Management Directive 12.6, ANRC Sensitive
> Unclassified Information Security Program,@ and the requirements for
> marking security-related official use only documents is on the Web at:
> [http://www.internal.nrc.gov/sunsi/]{.underline}, ASensitive
> Unclassified Non-Safeguards Information (SUNSI).@
>
> c\. [Release of Investigation-Related Information]{.underline}. When
> an inspector accompanies an investigator on an investigation, the
> inspector must not release either the investigation report or his or
> her individual input to the investigation report. This information is
> exempt from disclosure by 10 CFR 9.5, and must not be circulated
> outside the NRC without specific approval of the Chairman (refer to OI
> Policy Statement 23).

END

EXHIBITS:

Exhibit 1: Standard Reactor Inspection Report Outline

Exhibit 2: Inspection Report Documentation Matrix

Exhibit 3: Sample Reactor Inspection Report

Exhibit 4: Sample Cover Letters

APPENDICES:

Appendix A: Acronyms Used in Inspection Manual Chapter 0612

Appendix B: Issue Screening

Appendix C: Documentation Guidance for Supplemental Inspections

Appendix D: Sample Biennial Inspection Report for AIdentification and
Resolution of Problems@ Inspection Procedure (IP 71152)

Appendix E: Examples of Minor Issues

Appendix F: Examples of Cross-Cutting Aspects

ATTACHMENT 1

Revision History - IMC 0612

+-------+-------+------------------------+-----+-------+------------+
| Commi | Issue | Description of Change  | Tr  | Tra   | Comment    |
| tment | Date  |                        | ain | ining | Resolution |
| Tra   |       |                        | ing | Compl | Accession  |
| cking |       |                        | Nee | etion | Number     |
| N     |       |                        | ded | Date  |            |
| umber |       |                        |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 02/10 | Revision history       | NO  | N/A   | N/A        |
|       | /2006 | reviewed for the last  |     |       |            |
|       |       | four years.            |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 04/29 | Initial issue of       | NO  | N/A   | N/A        |
|       | /2002 | IMC-0612. Revised from |     |       |            |
|       |       | IMC‑0610\* to address  |     |       |            |
|       | CN    | revised documentation  |     |       |            |
|       | 0     | requirements of the    |     |       |            |
|       | 2-021 | revised Reactor        |     |       |            |
|       |       | Oversight Process      |     |       |            |
|       |       | (ROP). This revision   |     |       |            |
|       |       | changed the manner in  |     |       |            |
|       |       | which findings are     |     |       |            |
|       |       | documented, deleted    |     |       |            |
|       |       | \"\"no color\"\"       |     |       |            |
|       |       | findings and the       |     |       |            |
|       |       | requirements to add    |     |       |            |
|       |       | licensee identified    |     |       |            |
|       |       | violations to the      |     |       |            |
|       |       | Plant Issue Matrix.    |     |       |            |
|       |       | Other Major changes    |     |       |            |
|       |       | involved re‑formatting |     |       |            |
|       |       | several sections for   |     |       |            |
|       |       | clarity; provided a    |     |       |            |
|       |       | sample inspection      |     |       |            |
|       |       | report (to be issued   |     |       |            |
|       |       | separately);           |     |       |            |
|       |       | re‑structured and      |     |       |            |
|       |       | revised the thresholds |     |       |            |
|       |       | for documentation      |     |       |            |
|       |       | (Appendix B); provided |     |       |            |
|       |       | numerous new examples  |     |       |            |
|       |       | of minor violations in |     |       |            |
|       |       | Appendix E; and        |     |       |            |
|       |       | provided a revised     |     |       |            |
|       |       | format for documenting |     |       |            |
|       |       | findings.              |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 02/21 | Made editorial changes | NO  | N/A   | N/A        |
|       | /2003 | to Appendix B (Issue   |     |       |            |
|       |       | Dispositioning         |     |       |            |
|       | CN    | Screening) to reflect  |     |       |            |
|       | 0     | title changes to       |     |       |            |
|       | 3-006 | standard ROP           |     |       |            |
|       |       | terminology.           |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 05/23 | Exhibit 3 (Sample      | NO  | N/A   | N/A        |
|       | /2003 | Reactor Inspection     |     |       |            |
|       |       | Report) revised to not |     |       |            |
|       | CN    | require licensee       |     |       |            |
|       | 0     | identified NCV\'s be   |     |       |            |
|       | 3-016 | put in the PIM.        |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 06    | IMC 0612 Power Reactor | NO  | N/A   | N/A        |
|       | /24/2 | Inspection Reports     |     |       |            |
|       | 003CN | main body, app         |     |       |            |
|       | 0     | appendices and         |     |       |            |
|       | 3-021 | exhibits were revised  |     |       |            |
|       |       | to achieve the         |     |       |            |
|       |       | following:             |     |       |            |
|       |       |                        |     |       |            |
|       |       | 1\. Consistency with   |     |       |            |
|       |       | IMC‑0306 (Information  |     |       |            |
|       |       | Technology Support for |     |       |            |
|       |       | the Reactor Oversight  |     |       |            |
|       |       | Process)               |     |       |            |
|       |       |                        |     |       |            |
|       |       | 2\. Presented          |     |       |            |
|       |       | information in the     |     |       |            |
|       |       | order in which the     |     |       |            |
|       |       | activities will        |     |       |            |
|       |       | normally be performed  |     |       |            |
|       |       | in the process of      |     |       |            |
|       |       | developing and         |     |       |            |
|       |       | transmitting a reactor |     |       |            |
|       |       | inspection report.     |     |       |            |
|       |       |                        |     |       |            |
|       |       | 3\. Removed specific   |     |       |            |
|       |       | enforcement guidance   |     |       |            |
|       |       | to ensure consistency  |     |       |            |
|       |       | between the guidance   |     |       |            |
|       |       | in IMCB0612 and the    |     |       |            |
|       |       | Enforcement Policy and |     |       |            |
|       |       | Enforcement Manual.    |     |       |            |
|       |       |                        |     |       |            |
|       |       | 4\. Corrected          |     |       |            |
|       |       | incorrect or           |     |       |            |
|       |       | conflicting            |     |       |            |
|       |       | information.           |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 01/14 | Changed the inspection | NO  | N/A   | N/A        |
|       | /2004 | report timeliness to   |     |       |            |
|       |       | 45 calendar days for   |     |       |            |
|       | CN    | most inspection        |     |       |            |
|       | 0     | reports, including     |     |       |            |
|       | 4-001 | Special Inspections.   |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 09/30 | Revised to clarify     | YES | N/A   | N/A        |
|       | /2005 | definitions for        |     |       |            |
|       |       | NRC‑identified,        |     |       |            |
|       | CN    | self‑revealing and     |     |       |            |
|       | 0     | licensee identified;   |     |       |            |
|       | 5-028 | to provide additional  |     |       |            |
|       |       | guidance on how to     |     |       |            |
|       |       | document cross‑cutting |     |       |            |
|       |       | issues; to improve     |     |       |            |
|       |       | guidance on LER        |     |       |            |
|       |       | closure; to update the |     |       |            |
|       |       | new report timeliness  |     |       |            |
|       |       | requirement; and to    |     |       |            |
|       |       | reflect changes made   |     |       |            |
|       |       | to the document based  |     |       |            |
|       |       | on inspector feedback. |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 06/22 | Revised to provide     | YES | 07/01 | ML         |
|       | /2006 | additional guidance    |     | /2006 | 061510135  |
|       |       | and requirements for   |     |       |            |
|       | CN    | documenting            |     |       |            |
|       | 0     | cross-cutting aspects  |     |       |            |
|       | 6-015 | of inspection findings |     |       |            |
|       |       | and to provide         |     |       |            |
|       |       | guidance on inspection |     |       |            |
|       |       | report approval        |     |       |            |
|       |       | requirements when      |     |       |            |
|       |       | resolution to          |     |       |            |
|       |       | unresolved items are   |     |       |            |
|       |       | based on discussions   |     |       |            |
|       |       | between inspector(s)   |     |       |            |
|       |       | and NRR technical      |     |       |            |
|       |       | staff(s).              |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 11/   | Revised definition of  | YES | 09/06 | ML         |
|       | 02/06 | performance deficiency |     | /2006 | 063000483  |
|       |       | to bring the           |     |       |            |
|       | CN    | definition in          |     |       |            |
|       | 0     | alignment with the     |     |       |            |
|       | 6-033 | basis for performance  |     |       |            |
|       |       | deficiency as          |     |       |            |
|       |       | described in ROP basis |     |       |            |
|       |       | document, IMC-0308     |     |       |            |
|       |       | Attachment 3,          |     |       |            |
|       |       | ASignificance          |     |       |            |
|       |       | Determination Process  |     |       |            |
|       |       | Basis Document.@       |     |       |            |
+-------+-------+------------------------+-----+-------+------------+
| N/A   | 09/   | IMC 0612 has been      | No  | N/A   | ML         |
|       | 20/07 | revised to add         |     |       | 071560246  |
|       |       | guidance on NRC use of |     |       |            |
|       | CN    | INPO documents and on  |     |       |            |
|       | 0     | cover letters for      |     |       |            |
|       | 7-029 | security inspections.  |     |       |            |
|       |       | Also enhanced guidance |     |       |            |
|       |       | on NCV=s and SCAQ=s.   |     |       |            |
+-------+-------+------------------------+-----+-------+------------+