NRC INSPECTION MANUAL IRIB 

MANUAL CHAPTER 0612 

POWER REACTOR INSPECTION REPORTS 
Issue Date: XX/XX/XX 0612 i

CONTENTS

Page

0612-01 PURPOSE ................................................................................................. 1 

0612-02 OBJECTIVES ............................................................................................ 1 

0612-03 DEFINITIONS ............................................................................................ 1 

0612-04 RESPONSIBILITIES.................................................................................. 4 

04.01 General Responsibilities. ........................................................................... 5 

04.02 Inspectors .................................................................................................. 5 

04.03 Branch Chiefs and Division Directors......................................................... 5 

04.04 Division of Inspection and Regional Support. ........................................... 5 

0612-05 SCREENING INSPECTION RESULTS ..................................................... 5 

05.01 Screen for Performance Deficiencies. ....................................................... 6 

05.02 Screen for Traditional Enforcement Action. ............................................... 6 

05.03 Screen for Greater than Minor. .................................................................. 6 

05.04 Screen for Significance.............................................................................. 7 

0612-06 WRITING INSPECTION DETAILS............................................................. 7 

06.01 Inspectable Area....................................................................................... 8 

06.02 Inspection Scope. ..................................................................................... 8 

06.03 Findings. ................................................................................................... 9 

a. Introduction. .................................................................................... 10 

b. Description...................................................................................... 10 

c. Analysis. ........................................................................................ 10 

1. Risk-Informed SDP Results - Results from IMC 0609 

Appendices A, F, G, H and K. ............................................... 10 

2. Non-Risk-Informed SDP Results - Results from IMC 0609 

Appendices B, C, D, E, I, and J.............................................. 11 

3. Non-SDP Findings. ................................................................ 11 

4. Traditional Enforcement......................................................... 11 

5. Findings Related to Cross-Cutting Areas............................... 12 

6. Tracking Non-Regulatory Findings......................................... 13 

d. Enforcement. .................................................................................. 13 

06.04 Tracking. ................................................................................................. 16 

0612-07 DOCUMENTING PERFORMANCE INDICATOR VERIFICATION 

RESULTS ................................................................................................ 17 

07.01 Scope....................................................................................................... 17 

07.02 Findings ................................................................................................... 17 

0612-08 DOCUMENTING UNRESOLVED ITEMS ............................................... 17 

08.01 Opening ................................................................................................... 17 

08.02 Follow-up and Closure............................................................................. 17 
Issue Date: XX/XX/XX 0612 ii

0612-09 DOCUMENTING LERs AND LICENSEE-IDENTIFIED VIOLATIONS ..... 18 

09.01 Licensee Event Reports (LERs)............................................................... 18 

a. LERs without Violations .................................................................. 18 

b. LERs with Violations ....................................................................... 18 

09.02 Licensee-Identified Finding ...................................................................... 19 

0612-10 OTHER GUIDANCE ............................................................................... 20 

10.01 Treatment of Third Party Reviews. .......................................................... 20 

10.02 Non-Routine Inspections.......................................................................... 20 

0612-11 COMPILING AN INSPECTION REPORT................................................ 20 

11.01 Report Organization................................................................................. 20 

11.02 Plant Status. ........................................................................................... 20 

11.03 Summary of Findings. ............................................................................. 21 

11.04 Cover Page.............................................................................................. 22 

11.05 Table of Contents. .................................................................................. 22 

11.06 Exit Meeting Summary. ........................................................................... 22 

11.07 Report Attachments. ............................................................................... 23 

11.08 Cover Letter............................................................................................. 24 

0612-12 ISSUING INSPECTION REPORTS......................................................... 30 

12.01 Report Timeliness.................................................................................... 30 

12.02 Release and Disclosure of Inspection Reports ........................................ 30 
Issue Date: XX/XX/XX 0612 1

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: 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: 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: A performance characteristic that is the most significant contributor 

to a performance deficiency and provides the most meaningful insight for assessing 

performance of the licensee. The cross-cutting aspects which can be ascribed to an 

inspection finding are fully described in IMC 0305, AOperating Reactor Assessment 

Program.@

Deviation: 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: 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 

Deleted: Performance 

characteristics that comprise a crosscutting area component. They are 

associated with inspection findings 

and play a significant role in 

contributing to the performance 

deficiency. 

Deleted: different 
Issue Date: XX/XX/XX 0612 2

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): 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: A finding of very low safety significance. 

Independent Item: 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: A reactor inspection report that combines inputs from 

several inspections (resident, regional, etc.) conducted within a specified period. 

Issue: A well-defined observation or collection of observations that is of concern and may 

or may not result in a finding. 

Licensee-Identified: For the purpose of this inspection manual chapter (IMC), Alicenseeidentified@ 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: 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): 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. 
Issue Date: XX/XX/XX 0612 3

Noncompliance: A violation (regardless of whether it is cited or not), nonconformance, or 

deviation. 

Nonconformance: 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): 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: 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: 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: 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 a cross-cutting aspect, the cross-cutting aspect 

is the most significant contributor to the performance deficiency rather than an independent 

issue. Issues involving 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: 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: A finding of high safety significance. 

Self-Revealing: For the purpose of documentation in the ROP (versus enforcement), selfrevealing 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 

Deleted: related

Deleted: s

Deleted: s

Deleted: are

Deleted: generally considered an 

underlying cause of

Deleted: of
Issue Date: XX/XX/XX 0612 4

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: 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): The process used to characterize the 

importance of an inspection finding using the process described in IMC 0609. 

Substantive: 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): 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): The failure to comply with a legally binding regulatory requirement, such as 

a statute, regulation, order, license condition, or technical specification. 

Weakness: (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: An attitude toward noncompliance with requirements that ranges from careless 

disregard to a deliberate intent to violate or falsify. 

White Finding: A finding of low to moderate safety significance. 

Yellow Finding: A finding of substantial safety significance. 

0612-04 RESPONSIBILITIES 

04.01 General Responsibilities. 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. 
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04.02 Inspectors. 

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. 

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. 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. Determine if a performance deficiency exists. 

a. Answer the performance deficiency question in Appendix B, Section 1. 

Formatted: Bullets and Numbering
Issue Date: XX/XX/XX 0612 6

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 "selfimposed" 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. 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. 

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). 
Issue Date: XX/XX/XX 0612 7

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. 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. 

05.05 Analyze for Cross-Cutting Aspects 

 Assess the cause(s) of the performance deficiency to identify a potential crosscutting aspect using the guidance and questions in section 5 of Appendix B. The 

cross-cutting aspect of a finding is not considered a separate finding but rather a 

performance characteristic that is the most significant contributor to the performance 

EXCEPTION: A minor violation or a finding may be documented when it is 

necessary to close a licensee event report, or to close an unresolved item, or 

if related directly to an issue of agency-wide concern (e.g., in documenting 

the results of a temporary instruction). If it is necessary to document a minor 

violation, then it is done in accordance with the guidance contained in the 

Enforcement Manual.
Issue Date: XX/XX/XX 0612 8

deficiency, if applicable. The intent of identifying the cross-cutting aspect of a 

finding is so that insight can be used in the assessment process. 

 The decision whether the cross-cutting aspect is reflective of current performance 

cannot be made solely based upon the time when the performance deficiency or 

event occurred. The inspector needs to determine when the cause of the problem 

occurred. 

 It is necessary for the staff to make a sound decision based on available information 

on what causes are, and are not, reflective of current licensee performance. The 

inspector’s decision is important so that the assessment process can focus on 

issues that are reflective of current licensee performance. 

 For the specific case where a violation does not have a performance deficiency, the 

cause of the violation does not need to be evaluated for a cross-cutting aspect. This 

violation is not a finding, will not have a cross-cutting aspect, and will be assigned a 

severity level based on the significance determined above. 

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. 

 
Issue Date: XX/XX/XX 0612 9

$ Escalated enforcement actions must reflect the guidance found in the Enforcement 

Manual, Appendix B, AStandard Formats for Enforcement Packages.@

06.01 Inspectable Area. 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 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. 

f. If new information becomes available after the inspection report is issued, which 

results in a change in the cross-cutting aspect of a finding, document the change 

and the reason for the revision in section 4OA5, “Other Activities,” in the integrated 

report that is open at the time of the revision. Also update the original PIM entry 

with the revised cross-cutting aspect. The change in cross-cutting aspect 

assignment should be covered during the exit meeting for the integrated inspection.

06.02 Inspection Scope. 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 the inspection was conducted (i.e., the methods 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 was inspected. Include sufficient detail on which and how many 

samples were inspected. If more than six documents were reviewed, then list the 

items in an attachment and reference the attachment in the Scope section. 
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c. Identify the inspection objectives and the criteria 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 the inspection took 

place. 

06.03 Findings. 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. 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. 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. 
Issue Date: XX/XX/XX 0612 11

Note: An inspector may document a single finding that encompasses related 

multiple green findings. For these occasions, the individual findings share the same 

performance deficiency, cross-cutting aspect (if applicable) and violation (if 

applicable). For greater than Green findings, multiple examples should be 

independently assessed and typically not combined. 

c. Analysis. 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. 

(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. 
Issue Date: XX/XX/XX 0612 12

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. 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. If a finding is dispositioned using traditional 

enforcement, the analysis section should identify: 

EXAMPLE: AUsing the Public Radiation Safety SDP, the finding 

involved radiation material control but transportation was not involved. 

Public exposure was not greater than .005 rem and there were not 

more than 5 occurrences. Therefore, the finding is Green.@
Issue Date: XX/XX/XX 0612 13

$ 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. The third part of the analysis section should include the basis for assigning the 

cross-cutting aspect, if applicable. Specifically: 

 • If the finding has a cross-cutting aspect, inspectors shall restate the 

cross-cutting area, the component, and the cross-cutting aspect as described 

in section 06.07.c of IMC 0305. Additional information is necessary to explain 

how the selected cross-cutting aspect is applicable to the specific 

circumstances of the performance deficiency. The inspectors shall also 

include the corresponding alphanumeric identifier for the cross-cutting aspect. 

• If it was determined the performance deficiency does not have a crosscutting aspect, the analysis section must include a statement briefly stating 

the reason for not assigning a cross-cutting aspect. 

(See sample report for examples) 

6. Tracking Non-Regulatory Findings. 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. 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). 

Deleted: Findings Related to CrossCutting Areas. 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 endof-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).¶

Section Break (Next Page)
Issue Date: XX/XX/XX 0612 14

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 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.@
Issue Date: XX/XX/XX 0612 15

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, 

• 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. 

• 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. 
Issue Date: XX/XX/XX 0612 16

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. 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 NRCidentified 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. 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. 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.@
Issue Date: XX/XX/XX 0612 17

0612-08 DOCUMENTING UNRESOLVED ITEMS 

08.01 Opening. 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. 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). 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. 
Issue Date: XX/XX/XX 0612 18

a. LERs without Violations. 

1. LERs without Findings and with Minor Findings. 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. 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. 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. 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. 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. 

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 
Issue Date: XX/XX/XX 0612 19

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. 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. 
Issue Date: XX/XX/XX 0612 20

10.02 Non-Routine Inspections. 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. 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. 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. 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. 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 
Issue Date: XX/XX/XX 0612 21

assigned a severity level after NRC management review. This explanation is not 

included if no findings were identified. 

c. List of findings. 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 not 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. State the cross-cutting area, 

the cross-cutting component, the cross-cutting aspects of the finding, and the 

alphanumeric identifier or that no cross-cutting aspect was identified. 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. 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. 

Deleted: Highlight the cross-cutting 

aspects of a finding, if appropriate. 
Issue Date: XX/XX/XX 0612 22

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. 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. 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. 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. If the NRC's position on an 

inspection finding changes (including a change in the cross-cutting aspect assigned 

to the finding) 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. 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. 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). 
Issue Date: XX/XX/XX 0612 23

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. 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. 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. 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. 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 crosscutting 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. 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. Write a cover letter to transmit the overall inspection results and 

convey the inspection findings to the licensee. Inspection reports are sent from the 
Issue Date: XX/XX/XX 0612 24

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. 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. 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. 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. 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. Ensure that the salutation follows the subject line. 

f. Introductory Paragraphs. 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. 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: 
Issue Date: XX/XX/XX 0612 28

IF: THEN: 

If there are no 

findings identified 

Insert a separate paragraph stating: 

"Based on the results of this inspection, no findings of 

significance were identified." 

If Green findings are 

identified 

State the number but do not elaborate. Include the 

following statement: 

AThere were [the number] findings of very low safety 

significance (Green) identified in the report." 

If Severity Level IV 

violations or violations 

associated with 

Green findings are 

being dispositioned 

as NCVs or in NOVs 

Document in accordance with the guidance in Appendix 

B, Form 2 of the Enforcement Manual 

If a finding has the 

potential to be greater 

than Green in 

significance 

The cover letter should clearly state 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. 

If a finding appears to 

be greater than Green 

and if an AV is 

involved for which a 

Notice of Violation is 

being considered 

Briefly discuss in the order of significance if more than 

one finding. The appropriate wording for the findings 

that are also violations of requirements can be found in 

the Enforcement Manual. 

If a violation appears 

to be greater than 

Severity Level IV 

Discuss in accordance with the guidance in the 

Enforcement Manual. 

If a violation was 

identified but was not 

associated with a 

performance 

deficiency 

Insert the following paragraph: 

AAlthough this issue constitutes a violation of NRC 

requirements, we have concluded that (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 
Issue Date: XX/XX/XX 0612 29

IF: THEN: 

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.)" 
Issue Date: XX/XX/XX 0612 30

h. Closing. 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. 

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. 

a. General Public Disclosure and Exemptions. 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. Inspection reports for the security 

cornerstone will not 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 be made publicly available. 
Issue Date: XX/XX/XX 0612 31 

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 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/, ASensitive 

Unclassified Non-Safeguards Information (SUNSI).@

c. Release of Investigation-Related Information. 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 

 
Issue Date: XX/XX/XX Att 1-2 061

ATTACHMENT 1 

Revision History - IMC 0612 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

Comment Resolution Accession Number 

N/A 02/10/2006 Revision history reviewed for the last four 

years. 

NO N/A N/A 

N/A 04/29/2002 

CN 02-021 

Initial issue of IMC-0612. Revised from IMC-0610* to address revised documentation requirements of the 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. 

NO N/A N/A 

N/A 02/21/2003 

CN 03-006 

Made editorial changes to Appendix B (Issue Dispositioning Screening) to reflect title changes to standard ROP terminology. 

NO N/A N/A 
Issue Date: XX/XX/XX Att 1-3 061

N/A 05/23/2003 

CN 03-016 

Exhibit 3 (Sample Reactor Inspection Report) revised to not require licensee identified NCV's be put in the PIM. 

NO N/A N/A 

 N/A 06/24/2003C

N 03-021 

IMC 0612 Power Reactor Inspection Reports main body, app appendices and 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. 

NO N/A N/A 

 N/A 01/14/2004 

CN 04-001 

Changed the inspection report timeliness to 45 calendar days for most inspection 

reports, including Special Inspections. 

NO N/A N/A 

 N/A 09/30/2005 

CN 05-028 

Revised to clarify definitions for NRC-identified, self-revealing and licensee identified; to provide additional guidance on how to document cross-cutting issues; to improve guidance 

on LER closure; to update the new report 

YES N/A N/A 
Issue Date: XX/XX/XX Att 1-4 061

timeliness requirement; and to reflect changes made to the document based on inspector feedback. 

N/A 06/22/2006 

CN 06-015 

Revised to provide additional guidance and requirements for documenting crosscutting aspects 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). 

YES 07/01/2006 ML 061510135 

N/A 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, ASignificance Determination Process Basis Document.@

YES 09/06/2006 ML 063000483 

N/A 09/20/07 

CN 07-029 

IMC 0612 has been revised to add guidance on NRC use of INPO documents and on cover letters for security inspections. Also enhanced guidance on NCV=s and SCAQ=s. 

No N/A ML 071560246