NRC INSPECTION MANUAL NMSS/FCSE

INSPECTION MANUAL CHAPTER 2630

MIXED OXIDE FUEL FABRICATION FACILITY

CONSTRUCTION INSPECTION PROGRAM
Issue Date: 09/20/16 i 2630

Table of Contents

2630-01 PURPOSE.................................................................................................................. 1

2630-02 OBJECTIVES............................................................................................................. 1

2630-03 APPLICABILITY ......................................................................................................... 2

2630-04 DEFINITIONS............................................................................................................. 2

2630-05 RESPONSIBILITIES AND AUTHORITIES.................................................................. 6

2630-06 BACKGROUND AND OVERVIEW ............................................................................. 9

2630-07 GENERAL INSPECTION POLICY.............................................................................10

2630-08 BASIC REQUIREMENTS FOR INSPECTION PROGRAM........................................14

2630-09 INSPECTOR TRAINING AND QUALIFICATIONS.....................................................16

2630-10 INSPECTION FINDINGS AND ENFORCEMENT ......................................................16

2630-11 ASSESSMENT..........................................................................................................18

2630-12 TRANSITION TO OPERATIONS ACTIVITIES...........................................................24

2630-13 INTERFACE WITH RELATED PROGRAMS .............................................................25

2630-14 REFERENCES..........................................................................................................25

Appendix A Inspection Procedures

Appendix B Documenting Inspection Results

Appendix C Independent Verification Plan (IVP) Process

Appendix D Principal Systems, Structures, and Components (PSSCs) Families

Appendix E Prioritization of Items Relied on for Safety (IROFS)

Appendix F Level of Inspection Effort (LOIE) Methodology

Appendix G Digital Information Archive for Mixed Oxide Fuel Fabrication Facility (MFFF)

and Online Normalized Database (DIAMOND)

Appendix H Operational Readiness Reviews (ORRs)

Exhibit 1 Construction Action Matrix

Attachment 1 Revision History Page
Issue Date: 09/20/16 1 2630

2630-01 PURPOSE

The purpose of this Inspection Manual Chapter (IMC) is to define the Construction Inspection 

Program (CIP) for the Mixed Oxide (MOX) Fuel Fabrication Facility (MFFF). Specifically, the 

CIP will:

01.01 Verify that the design bases of the principal systems, structures, and components 

(PSSCs) and the Quality Assurance (QA) Program are adequately implemented during 

construction to provide reasonable assurance of protection against natural phenomena and the 

consequences of potential accidents. 

01.02 Verify that the construction of the PSSCs and items relied on for safety (IROFS) have 

been completed in accordance with the construction authorization and the design basis as 

contained in the license application to possess and use special nuclear material in the MFFF. 

01.03 To establish a record of the inspection and technical review activities, applicant/licensee

actions taken and technical issues resolved to support the decision for authorizing the use of 

special nuclear material.

2630-02 OBJECTIVES

The primary objective of this manual chapter is to establish a CIP for inspecting PSSCs and 

IROFS and associated activities that are conducted by the applicant/licensee and their

consultants, contractors, and suppliers, to support the decision on issuance of a license to 

possess and use special nuclear material in the MFFF. The following objectives are included in 

the CIP:

02.01 Provide reasonable assurance that regulatory requirements and applicant/licensee

commitments for design bases, quality assurance, and management measures are adequately 

included in the design, procurement, and construction of the MFFF.

02.02 Provide reasonable assurance that the MFFF and the associated PSSCs and IROFS 

were constructed in accordance with the QA program, construction authorization, and the 

design basis sections in the license application to possess and use special nuclear material.

02.04 Verify the effective implementation of the QA program as specified in the MOX Project 

Quality Assurance Plan (MPQAP) and that it includes timely implementation of organizational 

staffing, procedures, instructions, QA activities, and administrative controls necessary to 

achieve quality objectives important to safety.

02.05 Verify that the applicant/licensee is identifying conditions that may adversely affect 

public and worker safety so that appropriate corrective actions can be taken.

02.06 Conduct risk-informed and performance based inspections across key functional areas 

to support the decision on issuance of a license to possess and use special nuclear material in 

the MFFF.
Issue Date: 09/20/16 2 2630

02.07 Provide guidance on disposition and documentation of inspection findings.

02.08 Provide guidance on a MFFF-specific assessment program to identify performance

trends and determine if an expansion of U.S. Nuclear Regulatory Commission (NRC) 

inspections is necessary based on inspection findings.

02.09 To verify the operational readiness of the MFFF.

2630-03 APPLICABILITY

03.01 This IMC was developed to provide inspection program guidance for the MFFF CIP. 

The MFFF CIP applies to all construction activities, including, the design, procurement, 

fabrication, construction, and pre-operational testing and readiness activities. Implementation of 

this IMC began at the NRC issuance of the construction authorization, and will continue through 

facility construction activities, pre-operational testing and readiness activities.

03.02 As necessary, archived IMCs, inspection procedures (IP) and temporary instructions 

(TI) may be re-issued and used to perform the required inspections or reviews of outstanding 

design, licensing, and regulatory issues for the MFFF CIP.

03.03 The MFFF remains within the scope of the Commission's current Enforcement Policy 

for fuel cycle facilities in the construction phase. Traditional enforcement, i.e. the use of 

Severity Levels (SL), will be used for any SL IV and above non-compliances that are identified 

during inspections. SL IV violations identified by the NRC or applicant/licensee at the MFFF 

(under construction, including design, procurement, fabrication, construction, pre-operational 

testing, and readiness activities) will be dispositioned in accordance with the Commission's 

current Enforcement Policy for non-cited violations1. 

03.04 The transition of the MFFF to the full oversight provided by IMC 2600 will be a phased 

approach and is described in 2630-12 of this IMC.

2630-04 DEFINITIONS

04.01 Application. Application means the safety functions and design bases provided in the 

Construction Authorization Request (CAR) and further refined in the license application (LA) to 

possess and use radioactive material at the MFFF. Generally, those PSSCs defined in the CAR 

correspond to IROFS in the LA.

04.02 Completion of Construction. Completion of construction means that the system, 

structure, or component is able to perform its safety function as defined in the application, and 

can be verified by inspection or technical review2.

 

1 Letter from USNRC to Shaw Areva MOX Services, dated February 14, 2013 (ML13030A333)

2 For the purpose of meeting 10 CFR 70.23(a)(8), testing and completion of activities supporting the 

startup of the facility are not necessary to make the staff’s determination that the requirements of 10 CFR 

70.23(a)(8) have been met. Pre-operational inspections and evaluations will be made during NRC’s 

operational readiness review. 
Issue Date: 09/20/16 3 2630

04.03 Construction. 10 CFR Part 70.4 provides a definition for construction. Construction

means the installation of foundations, or in-place assembly, erection, fabrication, or testing for 

any structure, system, or component of a facility or activity subject to the regulations in this part 

that are related to radiological safety or security. The term "construction" does not include:

a. Changes for temporary use of the land for public recreational purposes;

b. Site exploration, including necessary borings to determine foundation conditions or 

other preconstruction monitoring to establish background information related to the 

suitability of the site, the environmental impacts of construction or operation, or the 

protection of environmental values;

c. Preparation of the site for construction of the facility, including clearing of the site, 

grading, installation of drainage, erosion and other environmental mitigation measures, 

and construction of temporary roads and borrow areas;

d. Erection of fences and other access control measures that are not related to the safe 

use of, or security of, radiological materials subject to this part;

For the purpose of this program, construction refers to the analysis, design, procurement, 

manufacture, fabrication, quality assurance, placement, erection, installation, modification, and 

inspection, of a system, structure, or component that has been defined as a PSSC. 

04.04 Construction Authorization Request (CAR). Document(s) submitted by the 

applicant/licensee providing a description of the facility site; a description and safety 

assessment of the design bases of the PSSCs of the facility; and a description of the MPQAP.

04.05 Design Bases. Design bases are information which identifies the specific functions to 

be performed by a structure, system, or component of a facility, and the specific values, or 

ranges of values chosen for controlling parameters as reference bounds for design3. These 

values may be: (1) restraints derived from generally accepted “state of the art” practices for 

achieving functional goals, or (2) requirements derived from analyses (based on calculation 

and/or experiments) of the effects of a postulated accident for which a structure, system, or 

component must meet its functional goals to provide an acceptance level of safety.

04.06 DIAMOND. The Digital Information Archive for MFFF and Online Normalized Database 

(DIAMOND) is a tool that is used to manage, document, organize, and track the MFFF PSSC 

verification information obtained during inspections and technical reviews. The NRC staff (staff) 

uses DIAMOND to (1) plan their inspections, (2) access technical documents, (3) input 

inspection report (IR) data and staff reviews, (4) track progress toward inspection verification 

program completion, and (5) monitor status of open items. DIAMOND is discussed in 

Appendix G. 

 

3 See NUREG 1718
Issue Date: 09/20/16 4 2630

04.07 Independent Verification Plans (IVP). Inspection or technical review planning 

documents that describe the PSSCs identified in the CAR and prioritize the IROFS from the 

Integrated Safety Analysis Summary (ISAS). The IVPs also prioritize the IROFS components

that are associated with the IROFS, and provide guidance to the inspection staff on the level of 

inspection effort. 

04.08 In-Office (or Field) Review. Assessments, audits, or reviews conducted to assess 

licensing related activities.

04.09 Inspection. (1) An NRC activity consisting of examination, observation, or 

measurement to determine applicant/contractor/vendor (licensee/applicant oversight of vendors) 

conformance with requirements and/or standards. (2) Applicant/licensee/contractor/vendor 

activity consisting of examination, observation, or measurements to determine the conformance 

of materials, supplies, components, parts, systems, processes or structures, including IROFSs 

to pre-determined quality requirements.

04.10 Inspection Attribute. A specific element or area of applicant/licensee performance such 

as design control (please see Appendix E for a complete list of the inspection attributes) that 

can be inspected or assessed to identify, analyze, and document potential weaknesses or 

deficiencies that may result in a failure to comply with NRC requirements. Assessment or 

inspection of these attributes supports the intent of this IMC by reducing the likelihood of an 

undetected PSSC flaw that could adversely affect the public’s health and safety. The inspection 

attributes specified in Appendix E are derived from the inspection procedures listed in 

Appendix A.

04.11 Items Relied on for Safety (IROFS). Structures, systems, equipment, components, and 

activities of personnel that are relied on to prevent potential accidents at a facility that could 

exceed the performance requirements in 10 CFR 70.61 or to mitigate their potential 

consequences. This does not limit the applicant/licensee from identifying additional structures, 

systems, components, or activities of personnel (i.e., beyond those in the minimum set 

necessary for compliance with the performance requirements) as IROFS.

04.12 Level of Inspection Effort (LOIE). A methodology that prioritizes the value of inspecting 

construction activities pertaining to PSSCs. This methodology determines the scope of each 

PSSC IVP and supports inspection planning and scheduling. This methodology will provide 

reasonable assurance that the construction of the PSSC has been completed in accordance 

with the application (as required by 10 CFR 70.23(a)(8)) by using a risk-informed approach to 

determine the LOIE value for each PSSC. The LOIE value is defined as the likelihood of an 

undetected construction error (“L” value) times the consequence of failure to detect the error 

(“C” value). The LOIE methodology is discussed in Appendix E. 

04.13 Management Measures. The functions performed by the applicant/licensee, generally 

on a continuing basis, which are applied to IROFS, to ensure the items are available and 

reliable to perform their functions when needed. Management measures include configuration 

management, maintenance, training and qualifications, procedures, audits and assessments, 

incident investigations, records management, and other QA elements. Commitments related to 

management measures are contained in the LA.
Issue Date: 09/20/16 5 2630

04.14 MFFF Assessment and Review Group (MARG). An assessment group comprised of 

representatives from the Office of Nuclear Material Safety and Safeguards’ (NMSS) Division of 

Fuel Cycle Safety, Safeguards, and Environmental Review (FCSE) MFFF project staff and the 

Division of Construction Projects in Region II, that has the responsibility to oversee the

development and implementation of the program to verify that the construction of the MFFF 

PSSCs was completed in accordance with the application. The effort is focused on ensuring 

that the licensing and inspection programs will collect the information necessary for the 

Commission to make a determination that the requirements of 10 CFR 70.23(a)(8) for issuing a 

10 CFR Part 70 license have been met. The MARG has the responsibility to oversee project 

completion and serve as the focal point for status of the project and for coordination between 

the Region and NMSS at Headquarters.

04.15 MFFF startup. Activities associated with the cold start-up or hot start-up of the MFFF 

as defined below.

a. Cold Start-up. In-plant testing, inspection, or measurement activities not involving the 

use of licensed material on MFFF process systems or components. This phase also 

includes the reference period, as defined by the applicant/licensee, in which all safety 

and operations programs have been implemented.

b. Hot Start-up. Pre-operational inspection, testing, or measurement activities involving 

the use of NRC licensed material in MFFF systems or components. This phase occurs 

after the reference period.

04.16 Mixed Oxide (MOX) Fuel. For the purposes of this manual chapter, a mixture of 

plutonium dioxide (PuO2) in a depleted or natural uranium oxide (UO2) matrix. Approximately 

95% of the MOX material is composed of UO2. The MOX fuel is characterized in terms of 

plutonium isotopics as reactor-grade or weapons-grade.

04.17 MOX Project Quality Assurance Plan (MPQAP). The applicant/licensee’s plan that 

defines the actions taken by applicant/licensee management and personnel during the 

performance of quality-affecting activities on the project to ensure QA requirements are 

consistently met. 

04.18 Operational Readiness Review (ORR). A disciplined, systematic, documented, 

performance-based examination of facilities, equipment, personnel, procedures, and 

management control systems to provide reasonable assurance that a facility will be operated 

safely within its approved safety envelope as defined by the facility safety basis. A graded 

approach will be used in defining the depth of the ORR based on these core requirements. In 

order to support a decision to possess and use special nuclear material, NRC will review and 

assess the state of readiness of facility operation based on the results of the ORR inspections. 

04.19 Principal Systems, Structures, and Components (PSSCs). PSSCs are safety controls 

that are identified in the design bases as providing protection against the consequences of 

accidents or natural phenomena. PSSCs may be engineered controls (active or passive), or 

administrative (procedural) controls. Controls may be either preventive or mitigative. The 
Issue Date: 09/20/16 6 2630

PSCCs were defined by Chicago Bridge & Iron Company (CB&I) AREVA MOX Services4(MOX 

Services or applicant/licensee) in the CAR and approved by the staff, in the safety evaluation 

report (SER) for the CAR (NUREG-1821).

04.20 PSSC Verification Program. The PSSC Verification Program is a process that

incorporates one or more of the following activities: (1) PSSC field inspections; (2) technical 

staff reviews and evaluations; and (3) staff review of applicant/licensee PSSC completion 

bases. The verification of the construction of a PSSC will vary depending on the type and 

nature of the system, structure, or component. A sample of IROFS component types, 

procedures or documents should be selected and verified for each prioritized IROFS in the IVP 

in order to complete the PSSC verification process. This is necessary to provide reasonable 

assurance that the construction of the PSSCs has been completed in accordance with the 

application. In order to complete the IVP process for a particular PSSC or PSSC family, a 

minimum number of inspection attributes needs to be inspected or reviewed. The LOIE value

lists provided in the IVPs correlate to a range of attributes that should be inspected or reviewed 

as part of the verification process.

04.21 Quality Assurance (QA) Program. The applicant/licensee’s overall QA program to be 

applied to the design, fabrication, construction, testing, and operation of the PSSCs. This 

includes the MPQAP, QA procedures, and supporting procedures and program activities. The 

QA program also provides a management control system to assure the attainment of quality 

objectives.

04.22 Reference Period. A time frame defined by the applicant/licensee where the final step 

in the ORR is conducted. The following activities occur during the reference period: (1) 

simulated integrated operation of entire facility; (2) plant turned over to operations; (3) utilities 

and balance of plant systems running in normal mode; and (4) security and 

radiation/contamination boundaries enforced.

2630-05 RESPONSIBILITIES AND AUTHORITIES

05.01 Office of Nuclear Material Safety and Safeguards (NMSS).

a. Responsible for regulatory oversight of the MFFF Project.

b. Responsible for the overall safety inspection program policy, guidance, and approval.

c. Responsible for preparing a Safety Evaluation Report Supplement that documents the 

overall finding of verification of construction of PSSCs as required in 

10 CFR 70.23(a)(8).

d. Lead responsibility for reviewing administrative controls in support of the PSSC 

verification program.

 

4 CB&I AREVA MOX Services was previously known as Shaw AREVA MOX Services.
Issue Date: 09/20/16 7 2630

e. Provides technical expertise, as needed, to support the inspection program of the 

MFFF.

f. Assigns MFFF project staff to support the MARG for PSSC verification.

g. Authorizes the possession and use of special nuclear materials at the MFFF.

05.02 Office of Nuclear Security and Incident Response (NSIR).

a. Responsible for the overall safeguards inspection program policy, guidance, and 

approval.

b. Concurs on the approval of this IMC and inspection procedures for activities relating to 

the safeguards aspects of the MFFF.

05.03 Director, Office of Enforcement (OE).

a. Ensures consistent application of the enforcement process to violations of NRC 

regulations with the appropriate focus on the severity level of the finding.

b. Provides representatives as necessary to support the Escalated Enforcement process 

in order to ensure consistent application of the enforcement process.

05.04 Regional Administrator, Region II (RII).

a. Provides program direction for management and implementation of the inspection 

program elements performed by the regional office.

b. Ensures, within budget limitations, that the regional office staff includes adequate 

numbers of inspectors in the various disciplines necessary to carry out the inspection 

program described in this chapter, including those needed for regional supplemental 

and reactive inspections. 

c. As necessary, directs the implementation of the supplemental inspection program.

d. As necessary, applies inspection resources to deal with significant issues and problems 

at the MFFF. 

e. Makes the decision to authorize the commencement of operations at the MFFF with the 

concurrence of the Director, NMSS.

05.05 Director, Division of Construction Projects, RII.

a. Ensures that adequate resources necessary to carry out the inspection program 

described in this IMC are provided to the staff.

b. Responsible for the planning, performance, documentation, and enforcement 

associated with the aspects of the inspection program that are performed by Region II.
Issue Date: 09/20/16 8 2630

c. Responsible for coordinating with NMSS in the development and maintenance of the 

procedures to implement the CIP for the MFFF Project.

d. Concurs on the approval of this IMC and inspection procedures for activities relating to

the MFFF.

e. Responsible for preparing a report for each PSSC or PSSC family requiring inspections

that documents the completion of inspection activities in accordance with the IVPs. 

f. As requested by FCSE, assigns inspection staff to support the MARG for PSSC 

verification.

g. Coordinates with the Division of Fuel Facility Inspection (DFFI) to ensure the transition

from construction to operations. 

05.06 Director, Division of Fuel Facility Inspection, RII.

a. Ensures that adequate operational resources are assigned to support the ORR program 

and implement the operations inspection program described in IMC 2600.

b. As requested by FCSE, assigns inspection staff to support for ORR inspections.

c. Coordinates with the Division of Construction Projects (DCP) to ensure the transition

from construction to operations. 

d. Coordinates with DCP for the planning, performance, documentation, and enforcement 

associated with the aspects of the Material Control and Accounting inspection program.

05.07 MFFF Assessment and Review Group (MARG). The MARG is a working group 

comprised of representatives from the NMSS Division of Fuel Cycle Safety, Safeguards, and 

Environmental Review (FCSE) MFFF project staff and Region II, Division of Construction 

Projects. The MARG was formed and tasked with developing and implementing a program to 

verify that the construction of the MFFF PSSCs is/was completed in accordance with the license 

application. The MARG has responsibilities in the following areas:

a. Oversees project completion.

b. Serves as the focal point for status of the project and for coordination between the 

Region and the NMSS program office.

c. Ensures that the licensing and inspection programs will collect, document, assess, and 

review the information necessary for the Commission to make a determination that the 

requirements of 10 CFR 70.23(a)(8) for issuing a Part 70 license have been met. 

d. Ensures that the IVP program for verifying the construction of PSSCs as it relates to the 

licensing process and compliance with 10 CFR 70.23(a)(8) has been implemented. 

e. Requests the participation of other Divisions on an as needed basis. 
Issue Date: 09/20/16 9 2630

f. Periodically reviews the information contained in DIAMOND (and supporting documents 

if needed) to support a determination of inspection attribute completion. 

g. A MARG-specific charter may be created to provide additional information for the group, 

including organization and reporting responsibilities.

h. Recommends to management, with supporting documentation, when a PSSC has been 

verified to be constructed in accordance with the application. 

2630-06 BACKGROUND AND OVERVIEW

Under a U.S. Department of Energy (DOE) initiative to determine options for the disposition of 

surplus plutonium from the weapons program, DOE selected an approach of fabricating mixed 

oxide fuel for use in commercial nuclear power plants, and selected the Savannah River Site for 

the MFFF. The Defense Appropriations Act of 1999, Section 202 of the Energy Reorganization 

Act of 1974, was amended to require NRC licensing of the facility for fabricating mixed 

plutonium-uranium oxide nuclear reactor fuel for use in commercial nuclear reactors. NRC will 

perform the licensing under the provisions of 10 CFR Part 70.

Before an applicant/licensee is granted a license to operate a plutonium processing and fuel 

fabrication plant, the Commission must verify that the construction of the PSSCs has been in 

accordance with the application (10 CFR 70.23(a)(8)). In addition, the LA includes a description 

of the applicant/licensee's safety program and a separate summary of the Integrated Safety 

Analysis (ISA). The safety program demonstrates that each IROFS will perform its intended 

function to limit risks at the facility. The safety program is composed of process safety 

information, the ISA, and management measures. The PSSCs for the facility were reviewed 

and approved by the NRC and are documented in the SER for the CAR (NUREG-1821) and the 

Construction Authorization. In addition, the staff reviewed the LA and issued an SER in 

December 2010.

06.01 Non-Reduction in Commitments and Changes to the MPQAP. Changes in 

commitments made to the ancillary codes, standards, and specifications identified in the 

American Society of Mechanical Engineers NQA-1-1994, Quality Assurance Requirements for 

Nuclear Facility Applications, Part II, are not necessarily a reduction in commitment. If the 

applicant/licensee can justify that a deviation or change to a code or standard is not a reduction 

in commitment and documents the basis justifying that the change or deviation provides an 

equivalent commitment, the change would not have to be reviewed by NRC staff prior to its 

implementation. 

A footnote in Section 7, “Referenced Codes, Standards, and Specifications,” of the Introduction 

to NQA-1-1994, Part II, states in part, that “Users of this part [Part II] should review the 

acceptability of the date or edition to be referenced with the regulatory and enforcement 

authorities having jurisdiction at the nuclear facility.” NRC staff will have the opportunity to 

review all changes that are not reductions in commitments as discussed in the following section. 

Further, while this footnote may be interpreted by some to require NRC approval of codes, 

standards, and specifications included in NQA-1, Part II; NRC prior approval is only required for 

changes that reduce commitments. It is noted that this footnote was removed in a subsequent 
Issue Date: 09/20/16 10 2630

version of NQA-1, and that Regulatory Guide 1.28, Quality Assurance Program Criteria (Design 

and Construction) Revision 4, endorses a version of NQA-1 that does not contain this footnote.

Further, it is noted that several of the ancillary documents contained in NQA-1-1994, Part II, 

contain both technical and quality provisions for accomplishing work activities. Where the 

technical requirements in the NQA-1-1994, Part II may differ from the technical requirements 

contained in the MFFF licensing documents, the technical requirements in the licensing 

documents (MPQAP and LA) shall govern.

The staff may, at any time, review changes to the MPQAP whether they are or are not 

reductions to commitments. Further, changes made by the applicant/licensee, identified as 

being a non-reduction in commitment change, may be subject to review during an inspection by 

the Region II staff or by the resident inspectors.

The applicant/licensee is required to submit all changes to the MPQAP in accordance with 

10 CFR Part 70. NMSS/FCSE staff will review the updates to the MPQAP, including nonreduction in commitment changes. During this review, staff may sample or conduct a full review 

of all non-reduction in commitment changes. It is anticipated that these reviews will take place 

in conjunction with the annual MFFF LA update review submitted in accordance with 

10 CFR 70.34.

06.02 Non-Conformance to Provisions Contained in NQA-1-1994, Part II. MFFF construction 

work activities can result in the identification of non-conformances to the provisions contained in 

the codes, standards, and specifications of NQA-1-1994, Part II. The processing of such nonconforming conditions should be in accordance with the applicable requirements of Appendix B 

to10 CFR Part 50 and the provisions contained in the MPQAP, including the applicant’s 

procedures. 

It should be noted that this discussion is applicable only to non-conforming conditions that arise 

due to circumstances such as worker errors, unexpected inspection and test results, and for 

material, equipment, parts, and/or services that do not conform to established technical and 

quality requirements. As a rule, for normal construction activities, the processing of these nonconforming conditions would not require NRC approval nor result in a change to the MPQAP. 

However, should there be instances where the nonconformance is significant enough that a 

change to the MPQAP or portions of the licensing application may be necessary, the 

applicant/licensee may need to interact with NRC licensing staff to determine the proper course 

of action.

Intentional departure from the technical and quality requirements contained in procurement 

documents, and provisions contained in the MPQAP, NQA-1, or other work-controlling 

documents without prior documentation, review, and approval is not applicable to the above 

discussion.

2630-07 GENERAL INSPECTION POLICY

07.01 Inspection Planning and Scheduling Considerations. The MFFF construction phase 

inspection schedule should be based on the applicant/licensee’s construction schedule, should 
Issue Date: 09/20/16 11 2630

be modified and updated periodically during the entire construction period, and should take into 

account the total estimated resources allotted in the budget developed jointly by Region II and 

NMSS.

Inspections should be coordinated and scheduled such that the efficiency and effectiveness of 

the inspection effort is enhanced and unnecessary burden to the applicant/licensee is 

minimized. To the extent practicable, the construction and pre-operational inspections should 

be coordinated with the applicant/licensee to ensure that key construction inspection activities 

are synchronized with the site construction project schedule. 

Emphasis should be placed on early identification of problems. Inspections will be conducted 

periodically throughout construction. Inspections will be scheduled early in the implementation 

of individual construction activities to develop confidence that specific construction activities 

were adequately accomplished at all stages of construction.

Comprehensive construction program reviews aimed at determining underlying causes and 

extent of problem areas should be conducted if NRC management concludes significant 

deficiencies are occurring. Inspection depth and frequencies may be expanded to ensure 

problem areas have been corrected. Corrective action programs are essential to effective 

resolution of individual deficiencies and programmatic issues. Inspection effort should be 

planned to specifically evaluate corrective action program effectiveness.

NRC RII DCP will develop, maintain and implement a Master Inspection Plan (MIP) and 

schedule for the MFFF construction inspection project. The MIP will include the targeted PSSC 

specific inspections identified in the IVPs, the programmatic inspections, and the inspection 

procedures that will be used for the inspections. The list of procedures for conducting 

inspections is provided in Appendix A of this IMC. The MIP will provide flexibility to address 

emerging issues that require changes in inspection efforts, receipt of allegations, changes in 

funding activities by DOE or NRC, or changes in scheduling activities by the applicant/licensee.

07.02 Inspection Procedures. A list of IPs for conducting inspections is provided in 

Appendix A of this IMC. Not all of the procedures or portions of the procedures listed in 

Appendix A will be applicable. The IPs are not a listing of applicant/licensee requirements and 

should not be used as such. The IPs provide inspection guidance to inspectors to help them 

develop their inspection plans. Inspectors should review the licensing basis documents (LA, 

MPQAP etc.) to identify the specific license requirements that should be included in the 

inspection plans.

The focus of this CIP is not completion of the IPs, but rather verification that IROFS sampled for 

inspection were constructed in accordance with license requirements, and that safety programs 

are effectively implemented. The IPs listed in Appendix A should be used in conjunction with 

the appropriate IVP found in DIAMOND. The completion of the CIP for the MFFF is not 

dependent on completion of the IPs listed in Appendix A. It should be noted that the NRC CIP 

for the MFFF will use the IVPs to verify that the construction of each PSSC listed in Table 5.6-1 

of the MFFF CAR has been completed in accordance with the application and provide 

reasonable assurance that the design basis safety function can be met. For further information 

on the use of the IVPs, please refer to Appendix C of this IMC. The resource estimate in each 

IP is an estimate for planning purposes; it is not an expected level of inspection effort. 
Issue Date: 09/20/16 12 2630

07.03 Resident Inspector Program. As determined by NRC management, resident 

inspector(s) may be assigned to the site, as needed, during various phases of construction. 

The senior resident Inspector would normally be the primary interface with the 

applicant/licensee for coordination of inspection scheduling for specific construction activities. 

The resident inspector(s) may also participate in inspections within their areas of qualification 

using the inspection procedures listed in Appendix A and coordinate the preparation of 

integrated IRs. Resident inspector(s) may be assigned to the site on a rotational basis during 

construction, and may be changed periodically, based on the type of construction activities 

being conducted. Length of service at the site will be in accordance with agency policy. 

07.04 Inspection and Technical Personnel Considerations. Inspectors and technical 

representatives will be assigned responsibility for performing inspections consistent with their 

qualifications. In addition, inspectors performing MFFF inspection activities will either be 

provided familiarization training on this IMC and related procedures or become familiar with the 

requirements of this IMC and the applicable requirements of 10 CFR Part 70.

07.05 Findings Outside of Inspector’s Qualifications. Inspectors sometimes identify issues or 

violations outside of the inspector’s qualifications or expertise. In these cases, the inspector is 

responsible for (1) determining if an immediate threat to the public or worker health or safety 

exists, and if one does exist to notify applicant/licensee management immediately; and (2) 

determining if the issue is better addressed by an inspector with different qualifications (i.e., a 

specialist inspector). 

07.06 Management Entrance and Exit Meetings. Inspectors are required to meet with 

applicant/licensee management as part of every inspection. Inspectors should hold an entrance 

meeting with the senior applicant/licensee representative who has responsibility for the areas to 

be inspected. Each inspection must include the discussion of inspection results with 

applicant/licensee management. At the conclusion of an inspection, inspectors must discuss 

their preliminary findings with the applicant/licensee’s management at a scheduled exit meeting. 

Management entrance and exit meetings with applicant/licensee personnel should be scheduled 

to minimize the impact on other applicant/licensee activities necessary to ensure the safe and 

proper construction of the facility.

07.07 Communication with Local Public Officials. As a matter of NRC philosophy, the NRC 

maintains an open door policy with regard to access by the public or federal, state and local 

officials to the NRC staff and to publicly available electronic documentation concerning an 

applicant/licensee's performance. The degree of interaction that is considered necessary to 

enhance public confidence in the NRC is expected to vary widely dependent upon the situation 

at each facility. Guidance pertaining to communication with stakeholders external to the NRC 

can be found in the latest revision of the Communication Plan for the MFFF and applicable 

regional office procedures.

07.08 Inspector Functions During Period of NRC Lapsed Appropriation. NRC Management 

Directive 4.5, Contingency Plan for Periods of Lapsed Appropriations, has defined the resident 

and selected region-based inspector function as an excepted NRC activity that will continue 

during the period of restricted NRC operations. Both resident and region-based inspectors will 

continue with their respective functions defined below. 
Issue Date: 09/20/16 13 2630

a. Region-based inspection function:

1. Includes event response requiring regional specialist expertise.

2. Does not include the approval or issuance of inspection reports.

b. Resident inspection function includes the following activities:

1. Completion of all of the following activities that are normally assigned to a 

resident inspector; including the performance of this manual chapter and its 

appendices.

2. Completion of reactive inspection activities pursuant to NRC Management 

Directive 8.3, NRC Incident Investigation Program. The decision to initiate a 

reactive inspection shall be made in consultation with the “excepted function” 

Regional and Program Office managers.

3. Completions of core, reactive and supplemental inspection activities not covered 

above that had been or are approved by regional management as being within 

the technical expertise of the residents at the site and that are scheduled for 

completion during the period of lapsed appropriation.

4. Emergency response, incident response, allegation, enforcement, public 

communication, and support for emergency licensing action activities that are 

typically performed by resident inspectors.

c. The ‘resident inspection function’ does not include program activities that require 

substantial support or approval from the Regional Office or Program Office. This 

exclusion includes the issuance of inspection reports under IMC 0616, “Fuel Cycle 

Safety and Safeguards Inspection Reports.” The resident inspectors do no inherit 

signature authority unless it is covered by separate authorization. 

07.09 Resident Inspector Relocation. All resident inspector assignments will stipulate a 

seven-year maximum tour length. This policy does not preclude resident inspectors from 

relocating for promotions, voluntary reassignments, or management-directed reassignments. 

a. Resident inspectors are expected to relocate from the site assignment after 7 years. 

Resident inspectors due to rotate during the winter months or early spring may be 

granted an extension to the summer months with Regional Administrator approval. Any 

other extensions beyond the 7-year maximum tour length must be approved by the 

Deputy Executive Director for Materials, Waste, Research, State, Tribal, Compliance, 

Administration, and Human Capital Programs (DEDM).

b. As resident inspectors approach the 7-year point at a site, the agency will consider 

inspector requests for a lateral transfer. Earlier transfers can be made when consistent 

with agency needs. In either case, resident inspectors are encouraged to make their 

desires and career goals known to their management as far in advance as possible.
Issue Date: 09/20/16 14 2630

c. Resident inspectors should not normally be reassigned to the same facility even after 

an intervening assignment. Reassignments may be made to co-located facilities that 

would cause resident inspectors to interact with a different licensee.

d. This policy applies to total site tour length and it is not affected by a promotion from 

resident inspector to senior resident inspector at a site.

e. Resident inspectors should not be assigned to a different location within the first four 

years after relocating unless specifically approved by the DEDM based on identified 

agency needs. 

2630-08 BASIC REQUIREMENTS FOR INSPECTION PROGRAM

08.01 General. The MFFF CIP provides the inspection requirements for selectively assessing 

the adequacy of the regulatory and safety-related programs, and verifying the construction of 

PSSCs and IROFS. This includes the implementation of the applicant/licensee’s QA program 

and other management measures used to ensure the availability and reliability of safety and 

safeguards IROFS. Substantial emphasis is to be placed on the inspection of the IROFS that 

are most important for reducing the likelihood of high- and intermediate- consequence accidents 

through the implementation of commitments made by the applicant/licensee in the MPQAP and 

the LA.

Emphasis is also to be placed on the applicant/licensee’s activities that ensure principal 

contractors delegated authority to conduct activities related to safety are implementing an 

acceptable QA program in accordance with the applicant/licensee’s QA program. The 

inspection program provides for the direct inspection throughout all stages of construction, 

including equipment fabrication, assembly and installation, and structural construction activities 

as may be necessary to ascertain whether elements of the QA program are effectively 

implemented.

The applicant/licensee is ultimately responsible for the safety of the nuclear facility. The NRC 

assures through an audit type of inspection program that the responsibility is carried out in an 

effective manner during the activities of facility construction. The CIP presented in this manual 

chapter is considered the minimum necessary to achieve an acceptable level of confidence as 

to the adequacy of construction at the facility.

This IMC emphasizes a systematic evaluation of the adequacy and effectiveness of the 

applicant/licensee’s QA and construction programs and their implementation. NRC will perform 

inspections of selected activities at the applicant/licensee’s project offices at the MFFF site and, 

as necessary, other project facilities. Inspections will also be performed, as necessary, at the 

facilities of the applicant/licensee’s consultants, contractors, and suppliers. This IMC 

establishes priorities for inspection by planned sampling of IROFS and related activities 

consistent with their importance to safety and should consider the performance of the 

applicant/licensee in the areas inspected. 
Issue Date: 09/20/16 15 2630

08.02 Program Areas. The specific areas to be inspected will include a sampling of the 

applicant/licensee’s IROFS and regulatory and safety commitments as identified in the design 

basis section of the LA and the approved MPQAP. IROFS for inspection will be chosen based 

on information contained in the IVPs (discussion of IROFS prioritization can be found in

Appendix E).

The NRC will periodically inspect the applicant/licensee’s programs for adequate assurance that 

IROFS are designed, procured, fabricated, and installed in accordance with approved design 

bases. The inspections will also ensure that as-built construction meets the approved design. 

In addition, the applicant/licensee’s design change and design control process will be reviewed 

to gain additional assurance that the design process used for the facility effectively implemented 

NRC requirements and other licensing design commitments made by the applicant/licensee. 

These reviews may be accomplished by multi-disciplinary technical review and/or inspection 

teams to verify the quality of design products and, inferentially, the entire facility design. 

08.03 Implementation. The RII DCP is responsible for managing and implementing the 

inspection program described in this IMC. This IMC is intended to provide the framework for 

managing the inspection effort. Where needed, sample sizes, frequencies of periodic 

inspections, and the time frame when certain inspection activities are to be performed are 

provided in the appropriate IP, IVP and/or inspection plan.

The inspection staff is expected to plan and conduct inspections based on risk considerations, 

current activities, and applicant/licensee performance. The DCP staff should develop, on at 

least an annual basis, a schedule of inspections to be conducted, based on the anticipated site 

activities that are to be performed in the upcoming year. The DCP staff should review and 

revise the schedule as needed to account for changes in site activities. The DCP staff should 

coordinate with FCSE on inspection program changes and document any changes from the 

planned inspections. The activities for conducting inspections should include the following:

a. Developing and documenting detailed inspection plans.

b. Scheduling and coordinating inspection activities in accordance with this IMC.

c. Communicating inspection results, findings, and open items to appropriate NRC and 

applicant/licensee management.

d. Documenting completed inspections, findings, and open items.

Inspection issues related to occupational health and safety should be evaluated in accordance 

with IMC 1007, Interaction Activities between Regional Offices of NRC and Occupational Safety 

and Health Administration (OSHA).

08.04 Inspection Requirements. Inspections will be based on 10 CFR Part 70 and other 

applicable regulations, commitments, conditions, the license application, MPQAP, and the 

construction authorization. Inspections will confirm that applicable regulations, requirements, 

and commitments have been met. Selection of inspection attributes will be based on safety 

considerations, status of work activities, and performance and are discussed in the IVPs.
Issue Date: 09/20/16 16 2630

08.05 Level of Effort. The level of effort will be determined by Region II by taking into account 

the total estimated resources allotted in the budget developed jointly by Region II and NMSS. 

Inspectors should charge to the IPs listed in Appendix A and other applicable TIs and activity 

codes provided by the DCP. 

2630-09 INSPECTOR TRAINING AND QUALIFICATIONS

Only staff members who have been previously qualified as inspectors through IMCs 1245, 1246, 

1247 or 1252 will be qualified to implement this IMC. The training completed by fully qualified 

inspectors combined with their field experience can be used, at management’s discretion, to 

establish equivalency for many of the activities specified therein. The initial training and 

qualification requirements are divided into two phases: the construction phase and the postconstruction phase. Refresher and continuing training activities are required as a means for 

updating and maintaining qualification to keep up-to-date on changes to the inspection program 

and as a result of lessons learned from industry events and agency activities. Just-in-time 

training and additional specialized training may also be required to support critical inspection 

activities. 

2630-10 INSPECTION FINDINGS AND ENFORCEMENT

10.01 Reports. Routine MFFF integrated construction IRs will normally be issued on a 

quarterly basis, unless otherwise determined by RII management. The inspection findings 

should be integrated into a single inspection report to encompass findings from resident 

inspections, in-office reviews, and/or one or more visits by regional or headquarters inspectors 

over a specific period of time (e.g., a 13-week period). Special inspections may be documented 

in a separate inspection report. IRs should identify specific PSSCs verification activities that 

were inspected. During the construction of the PSSCs, Appendix B of this IMC will be used to 

evaluate and document construction inspection observations and to classify them as findings, if 

appropriate, after they have been placed in context and assessed for significance. Inspection 

findings identified during the pre-operational periods will be documented in accordance with 

Appendix B of this IMC, IMC 0616, Fuel Cycle Safety and Safeguards Inspection Reports, 

and/or any other format as directed by regional management, after they have been placed in 

context and assessed for safety significance. The findings will then be categorized as violations 

(VIO), non-cited violations (NCV), minor violations, inspector follow-up items (IFI), unresolved 

items (URI), or notice of deviations (DEV). The disposition of minor issues and minor violations 

will be in accordance with the screening guidance in IMC 0613, Power Reactor Construction 

Inspection Reports. 

Traditional enforcement will be in effect for the construction of the MFFF as discussed in this 

IMC. Findings from inspections will be processed in accordance with 10 CFR Part 2 and 

applicable enforcement guidance using traditional enforcement tools, e.g., the use of severity 

levels and civil penalties as appropriate. The determination of the severity level of an apparent 

violation should consider its significance per Appendix B of this IMC and the Commission’s 

current Enforcement Policy and Enforcement Manual. 
Issue Date: 09/20/16 17 2630

10.02 Open Items. It is important to note that the applicant/licensee has been granted the 

authorization to construct the MFFF, and if the NRC determines that the construction is not in 

accordance with the applicant/licensee's commitments, then the operating license may be 

denied (see 10 CFR 70.23(a)(8)). The failure of the applicant/licensee to meet commitments 

specified in the LA shall be documented in the IRs as noted above. It is imperative that open 

items be appropriately documented in the IRs so that subsequent inspections can verify whether 

or not the applicant/licensee took the appropriate corrective actions. The failure of the 

applicant/licensee to take the appropriate corrective actions to address the open items by the 

end of the construction phase could result in either a denial to issue the operating license or a 

delay in the issuance of the operating license. 

Any open items, and their closure, (e.g. violations, unresolved items, inspector follow-up items, 

allegations etc.) that affects PSSC verification, will be tracked in DIAMOND and will be 

monitored by DCP and NMSS staff. The DCP staff will work with the appropriate inspection 

staff to develop a plan to close any open items in the most efficient and effective method. 

10.03 NRC Identified and Self-revealing NCVs. NRC identified and self-revealing NCVs will 

be documented in an IR. The description of the corrective actions taken or planned to take by 

the applicant/licensee, if known at the time the NCV is documented, should be in accordance 

with the Commission’s current Enforcement Policy and Enforcement Manual. NCVs will be 

closed based on the applicant/licensee entering them into their corrective action program and 

their corrective actions will be sampled during NRC corrective action program inspections. The 

documentation should include the requirement(s) violated, describe how it was violated, identify 

the applicant/licensee’s corrective action tracking number(s), and provide a very brief 

justification why the violation is greater than a minor violation and why the violation is not 

greater than SL IV. The following introductory paragraph should be included:

“This finding was determined to be a severity level (SL) IV violation using Section 6.5 of the 

Enforcement Policy. Because this was a SL IV violation and the example supporting the 

violation was entered into the applicant/licensee’s corrective action program (corrective action 

tracking number(s)), this violation is being treated as a non-cited violation (NCV), consistent with 

the NRC Enforcement Policy.”

10.04 Applicant/licensee-identified Violations. Applicant/licensee-identified violations are 

those items found through their own efforts rather than NRC inspections. The NRC will consider 

not issuing a Notice of Violation (NOV) for applicant/licensee-identified violations that would fall 

into the SL IV category and if the NCV criteria of the Commission’s current Enforcement Policy 

are met. This consideration will be based on the results of the NRC’s review of the 

applicant/licensee’s corrective action program. Applicant-identified violations that are SL III or 

higher will be documented in an Inspection Report and a NOV will be issued. 

Applicant/licensee-identified NCVs identified and corrected as part of the applicant/licensee’s 

self assessment program will not normally be documented in the inspection report. When an 

applicant/licensee-identified SL-IV/NCV is documented in an inspection report, then the 

description of the corrective actions taken by the applicant/licensee in the inspection report 

should be in accordance with the Commission’s current Enforcement Policy and the guidance in 

the current Enforcement Manual. The documentation should include the requirement(s) 
Issue Date: 09/20/16 18 2630

violated, describe how it was violated, identify the applicant/licensee’s corrective actions that 

have been taken or plans to take and the corrective action tracking number(s), and provide a 

very brief justification why the violation is not greater than SL IV. The following introductory 

paragraph should be included:

“The following violation of low safety significance was identified by the applicant/licensee and is 

a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for 

being dispositioned as a Non-Cited Violation.”

2630-11 ASSESSMENT

11.01 Overall Assessment Process. Typically, the regional office will conduct an 

applicant/licensee performance review (APR) using the inspection findings compiled over the 

previous 12 months (four quarters). This review should consider activities identified in the 

previous APR. The output of this review is an APR assessment letter to the applicant/licensee. 

The 12-month assessment cycle will be from January 1 through December 31 of each year. 

The assessments will be based on the findings and conclusions documented in NRC IRs and 

any feedback on licensing performance received from the NMSS program office. Overall 

applicant/licensee performance will be based on the severity level and number of violations. 

The Agency’s response and communication of applicant/licensee performance will follow the 

guidance in the Construction Action Matrix (CAM) (Exhibit 1 of this IMC). 

11.02 Performance Reviews. The assessment process consists of a series of reviews which 

are described below.

a. Periodic Review. The DCP staff, resident inspector(s), regional inspectors and the 

Branch Chiefs who participated in inspection activities during the quarter and the Chief, 

Construction Projects Branch 1 (CPB1) may optionally conduct a periodic review using 

the inspection findings and IRs conclusions compiled over the previous quarter. An 

assessment follow-up internal memo should be issued if the periodic review identified 

significant performance issues that resulted in changes to planned inspections. If 

applicant/licensee performance has declined resulting in changes to the planned 

inspections, an assessment follow-up letter to the applicant/licensee should be 

considered.

b. End-of-Cycle Review. Region II will conduct an end-of-cycle review using documented 

inspection findings and inspection report conclusions compiled over the assessment 

period (typically a calendar year). This review incorporates activities from the periodic

reviews.

In preparation for the end-of-cycle review, Region II will prepare a summary of 

inspection findings and documented conclusions related to applicant/licensee

performance conducting special programs, a summary of allegations received and/or 

closed, and proposed inspections.
Issue Date: 09/20/16 19 2630

The end-of-cycle review is normally chaired by the Chief, CPB1 or his/her designee. If 

applicant/licensee performance has degraded to Column 2 or higher of the Construction 

Action Matrix (see Exhibit 1 of this IMC), then the end-of-cycle review should be chaired 

by the Division Director, Division of Construction Projects or, if appropriate, the Region 

II Deputy Regional Administrator for Construction or his/her designee. In cases of 

degraded performance, the DCI branch chiefs should coordinate with the Chief, CPB1, 

to provide adequate support for the presentation and development of the revised 

inspection plan. Other routine participants should include representatives from the 

NMSS/FCSE program office, applicable regional and resident inspectors, and any other 

additional participants deemed necessary by the regional office. The following 

representatives should also participate if there are pertinent performance issues that 

should be factored into the performance assessment: the regional Allegations 

Coordinator or the Agency Allegations Advisor, Office of Investigations, Office of 

Enforcement, and Office of Nuclear Security and Incident Response.

The assessment letter should be issued within nine weeks of the end of the assessment 

cycle. 

11.03 Public Meeting with Applicant/licensee. Typically, Region II will conduct an end of cycle 

public meeting in the vicinity of the MFFF to communicate the results to the applicant/licensee

and members of the public; however, other methods such as webinars may also be used. 

Region II will coordinate with NMSS/FCSE for their participation in the meeting. If held, the 

meeting should be scheduled within 16 weeks of the end of the cycle. If a public meeting is 

conducted, Region II may consider using applicable portions of IMC 0305, Operating Reactor 

Assessment Program, or IMC 2604, Licensee Performance Review, as guidance for conducting 

this meeting. 

The involvement of the public in the results of the NRC’s assessment of applicant/licensee

performance is intended to provide an opportunity for the NRC to engage interested 

stakeholders on the performance of the facility and the role of the NRC in ensuring safe and 

quality conduct of construction activities. 

The assessment letter provides the minimum performance information that should be conveyed 

to the applicant/licensee in a public meeting, if conducted. However, this does not preclude the 

presentation of additional facility performance information when placed in the proper context.

The applicant/licensee should be given the opportunity to respond at the meeting to any 

information contained in the assessment letter. The applicant/licensee should also be given the 

opportunity to present to the NRC any new or existing programs that are designed to maintain 

or improve their current performance.

If a meeting is held with the applicant/licensee, it will be a Category 1 public meeting in 

accordance with the Commission’s policy on public meetings, with the exception that the 

meeting must be closed for such portions which may involve matters that shall not be publicly 

disclosed under Section 2.390 of Title 10 of the Code of Federal Regulations (10 CFR 2.390). 

Members of the public, the press, and government officials from other agencies are considered 

as observers during the conduct of the meeting. However, attendees should be given the 

opportunity to ask questions of the NRC representatives after the conclusion of the meeting.
Issue Date: 09/20/16 20 2630

Public involvement in the results of the NRC’s assessment of applicant/licensee performance 

should focus on topics of interest to the public. In lieu of a public meeting, the format for the 

public involvement could include an open house, round table discussion, or poster board 

session. For higher-profile interactions, consideration should include NRC or non-NRC 

facilitators.

11.04 Assessment Areas. The following assessment areas and associated attributes should

be used to assess MFFF performance. Depending on the stage of the construction project, not 

all assessment areas would be applicable during a given assessment period.

a. Quality Assurance Program. The requirements of the QA program are effectively 

implemented, including design control. Design control activities are conducted in 

accordance with facility procedures and the QA plan. Engineering activities are 

effective in ensuring the plant is constructed in accordance with the approved design 

and authorized design changes.

b. Construction Oversight.

1. Construction Activities. Construction activities are conducted in accordance with 

the construction authorization and QA program. The applicant/licensee

recognizes non-routine events affecting safety and effectively implements the 

corrective action program. 

2. Maintenance Activities. Maintenance activities, including PSSC maintenance 

activities (when applicable) are conducted in accordance with the 

applicant/licensee’s maintenance procedures and the QA program. Activities are 

effective in preparing PSSCs and IROFS for operation. 

c. Pre-operational Oversight.

1. Pre-Operational Activities. Pre-operational activities (when applicable) are 

effective and ensure systems and components important to the safety of the 

facility are fully tested to demonstrate that they satisfy design requirements. 

Management controls and procedures necessary for operation of the facility are 

effectively implemented. 

2. Startup Testing Activities. Startup testing activities (when applicable) are 

effectively implemented to provide for the safe startup testing of the facility during 

both routine and upset conditions, to recognize non-routine events affecting 

safety, use an internal reporting system, and to identify and execute corrective 

actions to return the facility to a safe and secure pre-operational condition after 

possible upsets. 

3. Training and Qualification of Plant Personnel. The training and qualification 

program (when applicable) is effective in training of personnel including 

managers, designers, technical staff, construction personnel, technicians, 

inspectors and other personnel whose level of knowledge is relied on for safety. 
Issue Date: 09/20/16 21 2630

d. Operational Readiness Activities. Activities completed during the operational 

preparedness phase to support the transition from construction to operation. The 

following performance areas should be coordinated with DFFI and NSIR to assess 

applicant/licensee performance:

1. Safety Operations. The safety operations performance area includes the 

inspectable areas pertaining to plant operations, nuclear criticality safety, and fire 

protection. 

2. Safeguards. The safeguards performance area includes the inspectable areas 

pertaining to material control and accounting (MC&A), physical protection of 

special nuclear material, and classified material and information security. 

3. Radiological Controls. The radiological controls performance area includes the 

inspectable areas pertaining to radiation protection, environmental protection, 

waste management, and transportation. 

4. Facility Support. The facility support performance area includes the inspectable 

areas pertaining to maintenance and surveillance of safety controls, 

management organization and controls, operator training, emergency 

preparedness, emergency exercise evaluation, and permanent plant 

modifications. 

e. Other Areas. This performance area is intended to include special issues that may 

arise on an occasional basis, but are not included in the review on a routine basis 

unless the significance of the issue rises to a level that is perceived to affect the quality 

of applicant/licensee performance. Examples include quality of licensing submittals, 

deviations from commitments in confirmatory action letters or confirmatory orders, 

licensing of new processes at an existing facility, and labor difficulties. 

11.05 NRC Actions in Response to Applicant/licensee Performance Issues. The optional 

quarterly or the end-of-cycle assessment panels will determine the NRC response to significant 

performance issues. The staff may consider performance issues that extend across two or 

more performance areas and/or across two or more areas within a single performance area. 

Significant performance issues are defined as Severity Level I, II, and III violations.

a. Description of the CAM. The CAM (Exhibit 1) was developed with the philosophy that, 

within a certain level of performance (i.e., Column I), applicant/licensees would address 

their performance issues without additional NRC engagement beyond the routine 

inspection program. Agency action beyond the routine inspection program will normally 

occur only if assessment input thresholds are exceeded. The CAM identifies the range 

of NRC and applicant/licensee actions and the appropriate level of communication for 

varying levels of applicant/licensee performance. 

Overall response to applicant/licensee performance will be determined by the number 

and severity of violations. The CAM uses a graded approach in determining the 
Issue Date: 09/20/16 22 2630

response to the identified issues. This graded approach will result in an increase in 

sampling in the area(s) of concern, an increase in the IROFS being inspected, and/or 

the issuance of a Confirmatory Action Letter (CAL), Demand for Information, and/or the 

issuance of an Order. Increased inspection will be conducted through the use of 

supplemental construction inspections. 

b. Expected Responses for Performance in Each CAM Column. The CAM lists expected 

NRC and applicant/licensee actions based on the inputs to the assessment process. 

Actions are graded such that the agency becomes more engaged as applicant/licensee

performance declines. Listed below are the ranges of expected NRC and 

applicant/licensee actions for each column of the CAM:

1. CAM Column I. Violations that are not greater than SL IV. The 

applicant/licensee will receive only the routine inspection program and identified 

deficiencies will be addressed through the applicant/licensee’s CAP.

2. CAM Column II. There are no more than two SL III violations. The 

applicant/licensee is expected to place the identified deficiencies in its CAP and 

perform an evaluation of the root and contributing causes. The 

applicant/licensee’s evaluation will be reviewed during subsequent inspections. 

Following completion of the inspections, the branch chief or division director 

should discuss the performance deficiencies and the applicant/licensee’s 

proposed corrective actions with the applicant/licensee, typically during an 

inspection exit meeting, at a periodic NRC management visit, or during a 

conference call with the applicant/licensee. 

3. CAM Column III. A combination of three SL III violations or one SL II violation. 

The applicant/licensee is expected to place the identified deficiencies in its CAP 

and perform an evaluation of the root and contributing causes for both the 

individual and the collective issues. 

The applicant/licensee’s evaluation will be reviewed during subsequent 

inspections. Also, an independent assessment of the extent of condition will be 

performed by the region. Following completion of the inspections, the Deputy 

Regional Administrator for Construction (DRAC), or designee, should discuss the 

performance deficiencies and the applicant/licensee’s proposed corrective 

actions with the applicant/licensee, typically during a public meeting with the 

applicant/licensee. 

4. CAM Column IV. One SL I violation, multiple SL II violations, or a combination of 

the following: one SL II and a total of four SL III violations; or a total of seven or 

more SL III violations. The applicant/licensee is expected to place the identified 

deficiencies in its CAP and perform an evaluation of the root and contributing 

causes for both the individual and the collective issues. This evaluation may 

consist of a third party assessment.
Issue Date: 09/20/16 23 2630

Inspection(s) will be performed to review the breadth and depth of the 

performance deficiencies. The construction supplemental inspection plan must 

be approved by the appropriate regional division director with concurrence of the 

Director, FCSE.

Following the completion of the inspection, the Regional Administrator (or 

designee) and the Director, NMSS will decide whether additional agency actions 

are warranted. These actions could include additional construction supplemental 

inspection, a Demand for Information, a CAL, or issuance of an Order, up to and 

including a stop work order. At a minimum, the regional office will issue a CAL to 

document the applicant/licensee’s commitments as discussed in their 

Performance Improvement Plan, as well as any other written or verbal 

commitments. The Regional Administrator should document the results of their 

decision in a letter to the applicant/licensee. Typically, these results will be 

discussed during a public meeting between the applicant/licensee and the 

Regional Administrator (or designee).

Due to the depth and/or breadth of performance issues reflected by a plant being 

in Column IV of the CAM, it is prudent to ensure that actual performance 

improvements have been made prior to closing out the violations and exiting 

Column IV of the CAM. In making this determination, the regional office should 

consider whether:

(a) New site issues or violations do not reveal similar significant performance 

weaknesses;

(b) The applicant/licensee’s performance improvement program has 

demonstrated sustained improvement; 

(c) NRC supplemental construction inspections show applicant/licensee

progress in the principal areas of weakness;

(d) There were no issues that led the NRC to take additional regulatory 

actions beyond those already taken due to the applicant/licensee being in 

Column IV of the CAM. Additionally, the applicant/licensee has made 

significant progress on any regulatory actions that were imposed (e.g., 

CALs, orders) because of the performance deficiencies that led to the 

Column IV designation.

After the original violations have been closed out, the applicant/licensee

will return to the CAM column that is represented by the other outstanding 

Note: Other than the CAL, the regulatory actions listed in this column of the 

CAM are not mandatory. However, the regional office should consider each 

of these regulatory actions when significant new information regarding 

applicant performance becomes available.
Issue Date: 09/20/16 24 2630

inputs to the CAM. Additionally, for a period of up to one year after the 

initial violations have been closed out, the regional office may use some 

actions that are consistent with Column III or Column IV of the CAM in 

order to ensure the appropriate level of agency oversight of 

applicant/licensee improvement initiatives. These actions, which do not 

constitute a deviation from the CAM, include senior management 

participation at periodic meetings/site visits focused on reviewing the 

results of improvement initiatives (such as efforts to reduce corrective 

action backlogs and progress in completing the applicant/licensee

Performance Improvement Plan) and CAL follow-up inspections. The 

actions taken above those required by the CAM shall be discussed at the 

next APR meeting to ensure an appropriate basis for needing the 

additional actions to oversee the applicant/licensee improvement 

initiatives. These actions will also be described in subsequent 

performance review assessment letters until the NRC determines the 

actions have been completed in a satisfactory manner. 

5. The regional office must convey the specific actions that the applicant/licensee

needs to address to resolve the violations that caused the applicant/licensee to 

enter Column IV. Until the violations are addressed, the applicant/licensee will 

remain in Column IV.

2630-12 TRANSITION TO OPERATIONS ACTIVITIES

12.01 Operational Readiness Reviews. The NRC may consider the use of phased ORR 

inspections as a tool to provide input for NRC decisions regarding the operational readiness of 

MFFF areas or processes. In order to support a decision on issuance of a license to possess 

special nuclear material, NRC senior management reviews and assesses the state of readiness 

of facility operation based on the results of the ORR inspection(s). The status of previously 

identified inspection findings are also considered during the decision-making process. 

Appendix H provides guidance related to the ORR.

12.02 The overall approach for transitioning to operations activities will be in accordance with 

this IMC as stated below.

a. The transition of the MFFF to operations will be a phased approach. The basis for why 

a certain program will be declared ready to be monitorable under IMC 2600, Fuel 

Cycle Facility Operational Safety and Safeguards Inspection Program, will be 

contained in the MFFF Transition Plan which shall be developed by Region II prior to 

the beginning of implementation of IMC 2600 at the MFFF.

b. The Region II MFFF Transition Plan will adhere to the guidelines stated in this IMC 

and will be composed of transition tables. Each transition table will contain the records 

that verify that a program is fully monitorable (what inspection criteria were performed 

and when; whether inspection criteria were completed in their entirety or just in part 

with any exceptions or deviations noted; what significant open items, startup issues, 
Issue Date: 09/20/16 25 2630

licensing actions, or regulatory issues were resolved; the identified inspection findings 

and the corresponding applicant/licensee corrective actions). Based on the decision of 

Region II management with the concurrence of NMSS, that program will be placed 

under the oversight of IMC 2600.

c. The MFFF Transition Plan should specify the required inspection procedures to be 

performed, when one or more programs are ready to be monitored by IMC 2600. The 

transition plan should also include a determination that startup issues, if applicable, 

have been resolved and confirm that the applicant/licensee’s corrective actions were 

effective. 

d. The transfer of the MFFF to the full oversight of IMC 2600 will be by written approval of 

the Regional Administrator with the concurrence of NMSS. This transfer may occur 

even if all safety programs are not available, provided compensatory inspections are 

conducted as provided for by IMC 2600. Prior to this point in time, identifying the need 

for additional NRC inspections and determining the response to inspection findings or 

events will be by the assigned Region II branch chiefs in accordance with the 

assessment process in Section 11 of this IMC. Subsequently, IMC 2600 will dictate 

what inspections should be implemented and what safety programs should be 

reviewed in determining the performance of the MFFF and also what will be the 

regulatory response for inspection findings or events.

2630-13 INTERFACE WITH RELATED PROGRAMS

13.01 Security and Safeguards Inspections. As with all other program areas, Region II will 

determine, as early as possible, when security program areas are ready to be monitored under 

the IMC 2600 baseline. NMSS and Region II will work closely with NSIR to ensure physical 

protection inspections are appropriate for any specific MFFF activities that are unique to the 

MFFF.

13.02 Operational Safety Inspections. Region II will determine, as early as possible, when the 

operational safety program areas are ready to be monitored under the IMC 2600 baseline. 

NMSS/FCSE and Region II/DCP will work closely with DFFI to ensure the operational safety 

inspections are implemented appropriately to ensure an effective transition from construction to 

operations (see Section 2630-12). 

2630-14 REFERENCES

Duke, Cogema, Stone, and Webster (DCS), “Mixed-Oxide Fuel Fabrication Facility Construction 

Authorization Request,” February 9, 2005 (latest revision accepted by NRC)

CB&I AREVA MOX Services, “Integrated Safety Analysis (ISA) Summary for the Mixed Oxide

(MOX) Fuel Fabrication Facility (MFFF),” Aiken, SC (latest version)

CB&I AREVA MOX Services, “License Application for the Mixed Oxide (MOX) Fuel Fabrication 

Facility (MFFF),” Aiken, SC (latest version)
Issue Date: 09/20/16 26 2630

U.S. Code of Federal Regulations, Title 10, Part 50, Appendix B, “Quality Assurance Criteria for 

Nuclear Power Plants and Fuel Reprocessing Plants”

U.S. Code of Federal Regulations, Title 10, Part 70, “Domestic Licensing of Special Nuclear 

Material”

U.S. Nuclear Regulatory Commission, “Enforcement Manual,” Revision 9, September 9, 2013

U.S. Nuclear Regulatory Commission, “Enforcement Policy,” (latest version)

U.S. Nuclear Regulatory Commission, “Standard Review Plan for the Review of an Application 

for a Mixed-Oxide Fuel Fabrication Facility,” NUREG-1718, August 2000

U.S. Nuclear Regulatory Commission, “Final Safety Evaluation Report for the License 

Application To Possess and Use Radioactive Material at the Mixed Oxide Fuel Fabrication 

Facility in Aiken, SC,” December 2010

U.S. Nuclear Regulatory Commission, “Final Safety Evaluation Report on the Construction 

Authorization Request for the Mixed Oxide Fuel Fabrication Facility at the Savannah River Site, 

South Carolina,” NUREG-1821, March 2005

END
Issue Date: 09/20/16 A-1 2630

Appendix A

Mixed-Oxide (MOX) Fuel Fabrication Facility Inspection Program

Construction Phase Inspection Procedures

Inspection procedures may be added or deleted to the inspection program as required.

QA Inspection Procedures

IP 88106 Quality Assurance: Program Development and Implementation

IP 88107 Quality Assurance: Design and Documentation Control 

IP 88108 Quality Assurance: Control of Materials, Equipment, and Services

IP 88109 Quality Assurance: Inspection, Test Control, and Control of Measuring and 

Test Equipment

IP 88110 Quality Assurance: Problem Identification, Resolution, and Corrective Action

IP 88111 10 CFR Part 21 Inspection-Facility Construction

IP 88112 Software Quality Assurance (under development)

IP 88113 Control of the Electronic Management of Data

IP 88114 Quality Affecting Item Procurement (10 CFR Part 21) and 

Commercial Grade Item Dedication Process (Reactive)

IP 88115 Supplier/Vendor Inspection

IP 88117 Facility Change Process 

Resident Inspector Procedures

IP 88130 Resident Inspection Program for On-Site Construction Activities at the Mixed 

Oxide Fuel Fabrication Facility

Construction Inspection Procedures

IP 88131 Geotechnical/Foundation Activities

IP 88132 Structural Concrete Activities

IP 88133 Structural Steel and Supports Activities

IP 88134 Quality Assurance: Piping Relied on For Safety

IP 88136 Mechanical Components

IP 88137 Electric Cable
Issue Date: 09/20/16 A-2 2630

IP 88138 Electrical Components and Systems

IP 88139 Ventilation and Confinement Systems

IP 88140 Instrumentation and Control Systems

IP 88143 Pipe Supports and Restraints

IP 55050 Nuclear Welding General Inspection Procedure

IP 55100 Structural Welding General Inspection Procedure

IP 88141 Fire Prevention and Protection

IP 88142 Underground Fire Water Loop and Equipment Installation

END
Issue Date: 09/20/16 B-1 2630

Appendix B

Documenting Inspection Results

1. PURPOSE

To provide guidance for documenting Mixed Oxide (MOX) Fuel Fabrication Facility (MFFF) 

construction inspection results.

2. BACKGROUND

The MFFF is a plutonium processing and fuel fabrication plant under construction that is 

currently inspected under the 10 CFR Part 70 construction inspection program. Inspectors 

should refer to Inspection Manual Chapter (IMC) 0616, Fuel Cycle Safety and Safeguards 

Inspection Reports, for guidance on inspection report (IR) content, format, and style. During the 

construction of the principal systems, structures and components (PSSCs), this appendix 

(Appendix B) will be used as supplemental guidance to evaluate and document construction

inspection observations and findings after they have been placed in context and assessed for 

significance. In addition, the applicable portions of IMC 0613, Power Reactor Construction 

Inspection Reports, should be used to disposition minor issues and minor violations. For the 

purposes of this IMC, a minor violation is defined as a violation that is less significant than a 

Severity Level IV violation, is not the subject of formal enforcement action, and is not usually 

documented or described in an IR or inspection record.

With regard to the disposition of non-cited violations (NCVs), the Nuclear Regulatory 

Commission (NRC) Enforcement Policy was revised on January 28, 2013, and allows licensees 

and non-licensees to receive NCVs in lieu of cited violations, if certain criteria are met. The most 

significant of these criteria is that the licensee or non-licensee has a corrective action program 

(CAP) that has been inspected and found to meet regulatory guidance, industry standards, or 

both. In a letter dated February 14, 20135, the NRC staff determined that MOX Services had 

established a documented CAP as part of its NRC approved quality assurance (QA) program 

that complies with Appendix B to 10 CFR Part 50. The NRC has performed annual 

programmatic inspections of MOX Services’ CAP, since nuclear construction began in 2007. 

Based on input from these inspections, the NRC staff determined that MOX Services has 

established a CAP that is consistent with the commitments in the NRC-approved QA program 

and meets Appendix B to 10 CFR Part 50. The change in the Enforcement Policy allows NRCidentified Severity Level IV violations to be treated as NCVs at the MFFF.

3. DEFINITIONS

Refer to IMCs 0616 and 0613 for applicable definitions of terms used in this appendix. 

 

5 Letter from USNRC to Shaw Areva MOX Services, dated February 14, 2013 (ML13030A333)
Issue Date: 09/20/16 B-2 2630

4. RESPONSIBILITIES

NRC inspectors conducting inspections at the MFFF are required to prepare IRs in accordance 

with the guidance provided in this appendix. General and specific responsibilities are listed 

below.

4.01 General Responsibilities. Each inspection of the MFFF should be documented in a report 

consisting of a cover letter, a cover page, an executive summary, and inspection details.

4.02 Report Issuance. The inspector’s branch chief is responsible for the report content, 

conclusions, and overall regulatory focus. For integrated construction IRs, the Construction 

Projects Branch 1 (CPB1) branch chief is responsible for issuing the report to the 

applicant/licensee.

4.03 Report Timeliness.

a. General Timeliness Guidance. Integrated construction IRs should be issued no later 

than 45 calendar days after inspection completion. RII management may provide 

additional guidance on IR issuance timeliness goals. 

NOTE: Inspection completion is normally defined as the day of the exit meeting. For 

integrated IRs, inspection completion is normally defined as the last day covered by the 

inspection report.

b. Reports Preceding Escalated Enforcement Actions. Timeliness goals should be 

accelerated for IRs covering potential escalated enforcement actions. For specific 

enforcement timeliness goals, see the NRC Enforcement Manual.

c. Expedited Reports for Significant Safety Issues. Whenever an inspector identifies an 

issue involving significant or immediate public health and safety concerns, the first 

priority is facility and public safety; issues of documentation or enforcement action are 

secondary. Based on the circumstances of the case, an expedited inspection report 

may be prepared that is limited in scope to the issue, or expedited enforcement action 

may be taken before the inspection report is issued. The NRC Enforcement Manual 

provides additional guidance on matters of immediate public health and safety concern.

5. GUIDANCE - INSPECTION REPORT CONTENT

This section relates primarily to matters of content in the inspection report details. For guidance 

on the content of report cover letters, IR content, format, and style, refer to IMC 0616. The IR 

should include a paragraph for programmatic area(s) inspected; each principal system, 

structure, and component inspected; and inspection attributes. The IR should also list the 

inspection procedure, temporary instruction or generic communication inspected. The 

paragraphs should be organized in ascending order.

5.01 Narrative Report Details. The detailed discussion in the Narrative Report provides the 

information which forms the bases upon which the other sections of an inspection report are 

developed. In most cases, the detailed discussion will be organized into one or more sections, 
Issue Date: 09/20/16 B-3 2630

each addressing an area of inspection. Report details should be structured in terms of the 

areas inspected, as noted below. 

The first section and subsequent sections should address the following: 

1. Summary of Facility Status

2. Routine Resident Inspector Activities (list inspection procedure(s) used)

3. PSSC Related Inspections

a. PSSC-00x

(1)Attribute (and inspection procedure(s) used)

a) Scope and Observations

b) Conclusions

4. Programmatic Inspections

a. Program Area (and inspection procedure(s) used)

(1)Scope and Observations

(2)Conclusions

5. Follow-up of Previously Identified Items

a. (Item Status - Closed, Open, or Reviewed) Item Type (VIO, NCV, URI, or IFI), 

Item Tracking Number, Item Description 

(1)Scope and Observations

(2)Conclusions

6. Exit Interviews

Normally, each following section should be divided into two parts: 1) Scope and Observations; 

and 2) Conclusions. Scope and Observations should consist of paragraphs that describe the 

scope of the inspection followed by the observations and resultant findings within the defined 

scope of that paragraph. Observations should be factual and not hunches, speculation, 

unsubstantiated hearsay, or unverified opinions and they should only be documented in the 

report when they are relevant to the inspection program or support a PSSC-specific or 

programmatic conclusion. The section ends with a stated conclusion based on the inspector’s 

observations and findings. In general, conclusions should focus on the capability of the 

program or activity to accomplish its design basis function. In assessing this capability, the 

conclusion statements may take various forms, but they should in all cases be concrete and 

supportable.

5.02 Thresholds of Significance. As part of maintaining a focus on safety, inspectors 

continually use NRC requirements, inspection procedures, industry standards (as required), 

regional and headquarters guidance, and their own training and insight to make judgments 

about which issues are worth pursuing and which are not.

To communicate effectively, IRs must give evidence of that judgment and prioritization, 

discussing significant safety issues in appropriate detail, treating less significant issues 

succinctly, and avoiding excess verbiage. To maintain some consistency in how minor issues 

are treated, report writers must recognize certain "thresholds of significance": that is, they must 

use similar criteria in deciding whether an issue is important enough to document, track or follow 

up. 
Issue Date: 09/20/16 B-4 2630

The NRC Enforcement Policy acknowledges that some violations of minor safety, 

environmental, and regulatory concerns are below the level of significance of SL IV violations. 

Because of their minor nature, these minor violations are not the subject of formal enforcement 

action and are not usually documented in IRs.

NOTE: For additional guidance in this area, see the NRC Enforcement Manual and IMC 0613.

a. Minor Violations--Determining Significance. Use IMC 0613 to determine the 

significance of the violations. 

b. Minor Violations--Determining Whether to Document. In general, minor violations 

should not be documented; however, certain exceptions apply as stated in the 

Enforcement Policy and Enforcement Manual. While the violation itself is minor, the 

associated technical information may relate directly to an issue of agency-wide 

concern (e.g., the inspection was performed in response to an NRC Temporary 

Instruction.) Documenting a minor violation may be warranted as part of closing out a 

licensee event report (LER) or unresolved item. Licensees are required to correct 

minor violations. When it is necessary to document a minor violation, only minimal 

discussion is required. Briefly describe the issue of concern, state that the issue has 

been addressed by the applicant/licensee and include a reference to Section IV of the 

NRC Enforcement Policy. For example, “This failure to comply with [requirement] 

constitutes a violation of minor significance that is not subject to enforcement action in 

accordance with the NRC’s Enforcement Policy.”

Minor violations related to the resolution of an allegation should not be documented in 

the inspection report.

c. Applicant/licensee Identified Violations. Under certain circumstances, even a violation 

that could be classified as SL IV (“more-than-minor”) need not be documented. This is 

generally justified when the violation has been identified and corrected as part of an 

applicant/licensee self-assessment effort. As a matter of policy, NRC enforcement 

seeks to encourage applicant/licensee self-assessment efforts, and seeks to avoid the 

negative impact that can result from a redundant NRC emphasis on problems which 

the applicant/licensee’s responsible action has already identified and corrected.

For example, suppose that while evaluating the applicant/licensee’s QA efforts in the 

fire protection area, an inspector reviews relevant audits and surveillances conducted 

over the previous year. The review reveals that the audits have been probing and 

thorough; the findings are well-developed and technically sound, and include six 

noncompliance issues, four of which might be classified at SL IV.

In such a case, the inspector should follow up on the noncompliances and other audit 

findings to ensure that causes have been appropriately assessed, that appropriate 

and comprehensive corrective actions have been taken, and that no new examples of 

the violations exist. Normally, the inspector would not cite the four violations 

individually or report the details of those violations in the inspection report assuming 

that no new issues are revealed by this follow-up. Instead, the inspection report 
Issue Date: 09/20/16 B-5 2630

findings and conclusions should assess the adequacy of the applicant/licensee’s QA 

efforts, including a clear reference to the name, dates, and general subject matter of 

the audit or self-assessment.

NOTE: This expectation only applies to SL IV violations. Even when identified 

through an applicant/licensee self-assessment, violations that could be categorized at 

SL III or above must be documented in the inspection report and given appropriate 

follow-up.

The violation must be clearly dispositioned in the report if, for any reason, the 

inspector decides to discuss a particular applicant/licensee’s self-assessment or audit 

finding in the inspection report and that finding involves a violation. The SL IV 

violation should be documented as an NCV if the criteria of the latest revision to the 

NRC Enforcement Policy have been met (including applicant/licensee corrective 

action, etc.). 

NOTE: The NRC Enforcement Manual provides additional guidance on documenting and 

dispositioning violations.

5.03 Level of Detail. Just as inspectors must use judgment in determining what issues are 

worth including in the inspection report, they must also determine the appropriate level of detail 

for issues that are included. Some issues should be discussed in more detail than others, 

based on safety or regulatory significance, technical complexity, and other factors.

a. Level of Detail on Inspection Scope and Observations. The level of detail for the scope 

should include the following:

1. Identify how the inspection was conducted (i.e., the methods of inspection.) 

Methods can include a walk-down, an in-office review, an observation of tests

from the control room, or discussion with specific personnel.

2. 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 and 

Observations section.

3. Identify the inspection objectives and the criteria that were used to determine 

whether the applicant/licensee is in compliance. 

4. 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.

5. 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.
Issue Date: 09/20/16 B-6 2630

b. Once the inspector has decided that an observation or a finding is important enough to 

be included in the report, the same questions used in making that decision can assist in 

determining the appropriate level of detail. The following guidance applies for the level 

of detail:

1. The degree of actual or potential safety consequence associated with a finding 

should be a primary consideration in determining the level of appropriate detail. 

Items of higher significance generally merit more discussion.

2. If the inspector has concluded that a finding has programmatic aspects (e.g., 

multiple examples of the problem, a related series of failures, an underlying 

procedure or training deficiency, or diverse effects resulting from the same root 

cause), enough detail should be given to support this conclusion.

3. Findings of greater technical significance—that is, findings that give insights into 

items relied on for safety (IROFS) or human performance issues, or findings that 

could have generic significance—should be discussed in sufficient detail to 

communicate those insights.

4. When initiating an unresolved item or inspection follow-up item, the issue 

description should provide enough background information that a different 

inspector, using that information, would be equipped to perform the follow-up 

inspection.

5.04 Documenting Noncompliances. When documenting noncompliances in the inspection 

report, the NRC staff will consider the use of four part write-ups. The primary guidance for 

matters related to enforcement, including documentation, is given in the NRC Enforcement 

Policy and the NRC Enforcement Manual. These documents can be found at 

http://www.nrc.gov/about-nrc/regulatory/enforcement/guidance.html. The following discussion 

summarizes certain aspects of that guidance related to IRs.

a. Types of Noncompliances. The manner of documenting a noncompliance in the 

inspection report depends on how that noncompliance will be dispositioned. A 

noncompliance may be addressed as a non-escalated enforcement action (i.e., a SL IV 

violation or a nonconformance); as an escalated enforcement action (i.e., an apparent 

SL I, II, or III violation); or as an NCV.

A finding or observation is not discussed in the IR if a violation does not exist (e.g., no 

requirement exists for the area). 

1. Non-Escalated Enforcement Actions. Most violations of very low significance 

(i.e., more than minor concerns) fall into the SL IV category. If at the time of 

issuing the inspection report a violation has been categorized at SL IV, and it

does not meet the criteria for an NCV, then an NOV is generally sent out with the 

inspection report as a non-escalated enforcement action. The cover letter for 

reports that include non-escalated enforcement actions should follow the 

appropriate NRC Enforcement Manual guidance.
Issue Date: 09/20/16 B-7 2630

2. Potential Escalated Enforcement Actions. When an issue is being considered for 

escalated enforcement action, the inspection report narrative should refer to the 

potential noncompliance as an apparent violation. The report details should not 

include any speculation on the severity level of such violations nor on expected 

NRC enforcement sanctions. Potential escalated actions, by their nature, require 

further agency deliberation (and, usually, additional applicant/licensee input) to 

determine the appropriate severity level and NRC action. 

Similarly, report narratives that discuss apparent violations should be carefully 

constructed to avoid making explicit conclusions (i.e., final judgments) about the 

safety significance of the issue. The report should include any available details 

that give evidence of safety significance, or that would help in making such a 

decision; however, since a potential escalated enforcement action automatically 

entails further evaluative steps, neither the inspection report details nor the 

accompanying cover letter should present a final judgment on the issue. The 

accompanying cover letter should include the escalated enforcement action (EA) 

number obtained from the Enforcement and Investigation Coordination Staff 

(EICS). 

3. Non-Cited Violations. Per the NRC Enforcement Policy, SL IV violations can be 

dispositioned as NCVs. When SL IV violations are dispositioned as NCVs, the 

report should briefly describe their circumstances and the description of the 

corrective actions taken or planned to be taken by the applicant/licensee, if 

known at the time the NCV was documented in the inspection report, and should 

be in accordance with the Commission’s current Enforcement Policy. The report 

should clearly state what regulatory requirements were not met.

4. Minor Violations. Minor violations are not normally documented in IRs. 

However, to the extent that documentation is necessary, the standard language 

should be used: “This failure constitutes a violation of minor significance and is 

not subject to formal enforcement action;” and the report should clearly state why 

the violation was of minor significance.

END
Issue Date: 09/20/16 C-1 2630

Appendix C

Independent Verification Plans (IVPs)

1. PURPOSE

The purpose of the IVP is to provide an efficient, effective, and auditable method for 

implementing the Mixed Oxide (MOX) Fuel Fabrication Facility (MFFF) Construction Inspection 

Program (CIP) as it relates to the licensing process and compliance with 10 CFR 70.23(a)(8) for 

the MFFF. 10 CFR 70.23(a)(8) states that an application for a license will be approved if the 

Commission determines that, where the proposed activity is the operation of a plutonium 

processing and fuel fabrication plant, construction of the principal systems, structures, and 

components (PSSCs) approved pursuant to 10 CFR 70.23 (b) has been completed in 

accordance with the application. Thus, in accordance with 10 CFR 70.23(a)(8), the staff has 

determined that the license to possess and use special nuclear material will not be issued 

before a determination that construction of the principal structures, systems, and components 

approved pursuant to section § 70.23(b) is in accordance with the application.” 

2. IVP PROGRAM6

The verification of the construction of a PSSC will vary depending on the type and nature of the 

system, structure, or component. In some cases, a PSSC may be an administrative control 

(e.g., combustion loading controls for fire prevention), an active or passive engineering control, 

use of an approved item (e.g., 3013 transport cask approved under 10 CFR Part 71), or some 

combination of the above. Verification of PSSCs includes evaluations of procedures associated 

with administrative controls as well as engineered controls. To support the verification, 

inspection planning associated with PSSCs also includes construction scheduling provided by 

the applicant/licensee such as the installation of safety related tanks in process cells that will be 

inaccessible for inspection after process cells are sealed.

As applicable to the specific type of PSSC, NRC construction inspection and/or the technical 

review programs will verify that the construction of each PSSC listed in Table 5.6-1 of the MFFF 

Construction Authorization Request (CAR) have been completed and the design basis safety 

function can be met. The item relied on for safety (IROFS) related to a specific PSSC can 

range from one to several thousand and will be inspected based on a prioritized sampling 

approach to ensure that there is reasonable assurance that the PSSC construction is completed 

and is in accordance with the application. 

Section 1 of the IVP contains a description of the PSSC or PSSC family (a table of PSSC 

families can be found in Appendix D of this IMC) including a discussion of the integrated safety 

analysis (ISA) events related to the PSSC and the safety functions as stated in the CAR and the 

license application (LA). The IVPs show the prioritized integrated safety analysis summary 

(ISAS) IROFS and the IROFS components from which a sampling will be inspected by regional 

 

6 The IVPs were categorized as, “Official Use Only – Security Related Information, Pre-Decisional” due to 

the proprietary and security related information contained in the ISAS.
Issue Date: 09/20/16 C-2 2630

inspectors or the resident inspectors, as appropriate. Additionally, a sampling of prioritized 

administrative control IROFS to be reviewed by headquarters technical reviewers is included. 

Technical staff will use a specific administrative control review procedure for reviewing 

administrative controls associated with the PSSCs.

Section 4 of the IVP also provides the level of inspection effort (LOIE) values and appropriate 

attributes to select in the inspection or review for each PSSC within the family. The LOIE values 

are also maintained in the PSSC Central section in Digital Information Archive for MFFF and 

Online Normalized Database (DIAMOND). The LOIE for each PSSC indicates the number of 

attributes that should be inspected (see Appendix F of the IMC).

Sections 2 and 5 of the IVP discusses the inspection activities to be performed to verify the 

construction of the PSSCs has been completed in accordance with the application. The 

inspectors should select the corresponding inspection procedures based on the attributes 

selected from the LOIE section. The attributes listed in the IVP should be selected in the ranges 

provided for each PSSC. 

Section 6 of the IVP contains information on the associated PSSC IROFS and families. There 

are several IROFS that are identified in the IVP which are associated with another IVP or IVPs. 

The inspection or review results from correlated IVPs needs to be documented and inspection 

or review information needs to be included or referenced in the verification documentation. The 

IVP also identifies where associated PSSCs or IROFSs have been evaluated. 

Section 7 of the IVP is “Other Planning Considerations.” The section states that, as applicable, 

inspection results from previously performed programmatic inspections, such as quality

assurance (QA) program or correction action program, may be used or referred to during the 

conduct of the onsite inspections to inform inspections and support verification. 

Section 8.1 of the IVP, entitled “Regional Inspections,” includes the details of the type of 

inspections and IROFS component types that should be inspected as part of the verification 

activities. The list of inspections selected was based on the Office of Nuclear Material Safety 

and Safeguards (NMSS)/Region II staff evaluation of the prioritization of IROFS components 

and a determination of the most appropriate inspection activities for regional inspectors. The 

IVPs leave flexibility for the inspectors as to the selection of inspection attributes and the 

sampling of prioritized IROFS or components.

Section 8.2 of the IVP, entitled “Resident Inspector Activities,” discusses the inspection that the 

resident inspectors should perform onsite using applicable portions of the inspection procedures 

for IROFS or components that are not being inspected or attributes not evaluated as part of 

regional inspections. The resident inspectors should evaluate the appropriate number of 

attributes listed in Section 4 (LOIE). The inspectors should also examine, on a sampling basis, 

the IROFS and components listed in the IVP. The sampling should include at least one IROFS 

component from each prioritized ISAS IROFS.

The inspector should consider inspections for component receipt, comparing the design or 

installation drawings to the as-built condition, onsite component fabrication/construction 

(welding) activities and installation activities. Also, the resident inspectors should inspect the 

IROFS that may not be readily accessible during operation. 
Issue Date: 09/20/16 C-3 2630

Section 8.3 of the IVP, entitled “Headquarters Activities,” lists the prioritized administrative 

IROFS that can be sampled and reviewed by Headquarters using the specific administrative 

control review inspection procedure.

Section 8 of the IVP will also be used by the regional project inspector (RPI) to track the 

completion progress of PSSC inspection activities.

USE OF THE IVPs

The IVP is a summary planning document that the staff has developed to document what 

inspection or review activities of PSSCs are needed to make a finding with respect to 

10 CFR 70.23(a)(8). The IVP documents the regional inspections that need to be performed, 

the inspection attributes that need to be selected, the IROFS components that are to be 

evaluated on a sampling basis by the inspection staff, and the administrative IROFS that will 

also be reviewed by technical staff. 

The latest revisions of the IVPs are maintained in DIAMOND. The RPI is responsible for 

planning and developing the master inspection plan (MIP) for the MFFF. The scheduled 

inspections include those identified in the IVPs as well as programmatic inspections that support 

the PSSC verifications including the QA program and corrective action program. The MIP is 

designed to ensure that the inspections identified in the IVPs are completed. These details and 

scheduling of the identified inspections are coordinated with the RPI, resident inspectors, and 

the applicant/licensee.

Once an inspection is scheduled by the RPI, a lead inspector will be identified to either conduct 

or lead a team inspection. This individual and his/her inspection team are chosen based on the 

technical expertise required to perform the inspection. The RPI will verify that the appropriate 

inspection as identified in the IVP and MIP will be performed.

The lead inspector should review the IVP and prepare the inspection plan based on the IROFS 

component types, inspection attributes and other information that is identified in the IVP. The 

lead inspector should also review the applicable portions of the PSSC scoping documents that 

were prepared by the applicant/licensee and are located in DIAMOND, as well as the other 

information related to verification of the specific PSSC. The lead inspector has the flexibility to 

scope out the inspection to include a sampling of the appropriate attributes for the particular 

inspection. The inspection plan should include a rationale for the selected attributes. 

Additionally, the IVP lists the ISAS IROFS and the IROFS component types that relate to the 

ISAS IROFS. The plan should consider an appropriate sampling of the IROFS components as 

identified in the IVP. The inspector has the flexibility to choose the appropriate IROFS 

components to be inspected. However, at least one IROFS component type should be selected 

for each ISAS IROFS. 

The inspection plan and inspection reports (IRs) should identify the PSSCs that will be/were

inspected and the inspection attributes that were selected. The documentation should include 

any conclusions (and basis for the conclusion) regarding the specific attribute that was 

inspected. For example, the reports should say the NRC has examined the installation attribute 

of the IROFS of PSSC-xxx (also include a brief description of the IROFS that was inspected). 
Issue Date: 09/20/16 C-4 2630

Based on the sampling and inspection findings, the staff has reasonable assurance that the 

IROFS was installed in compliance with applicant/licensee procedures and QA program and 

meets the requirements of 10 CFR Part 70 (identify any specific regulatory or QA requirement 

that has been met). The inspector or technical reviewer is only responsible for the conclusions 

for the specific inspections that they have performed. The RPI will track the completion of the 

identified inspections for the overall PSSC verification program. This completion information will 

be tracked in DIAMOND. The RPI will be responsible for confirming that the required inspection 

activities have been completed in order to verify that the IVP has been completed.

The Resident Inspectors should perform onsite inspections using the applicable portions of the 

inspection procedures (IPs) for their assigned IROFS. Of the IROFS identified in Section 2 of 

the IVP, the resident inspectors should evaluate a sampling of the attributes provided in Section 

4. Resident inspectors should inspect, using one or more of the specified attributes, a sampling 

of IROFS components from the list in Section 2 of the IVP. The sampling should include at least 

one IROFS component from each prioritized ISAS IROFS. 

The inspectors should coordinate with technical staff in NMSS and RII to select the inspection 

sample if the inspector is not familiar with the IROFS or the components and their safety 

function or priority. 

Headquarters reviewers will use the IVP to identify the prioritized administrative controls for 

review. The review of the administrative controls, generally facility procedures, will be 

performed using guidance from the administrative control review procedure. After review of the 

administrative controls, the Headquarters technical staff will document their review as specified 

in the procedure. The reviewer will forward the written evaluation to the NMSS project manager 

and the RPI for insertion into DIAMOND.

The evaluations prepared should include any conclusions (and the basis for the conclusion) 

regarding the procedure that has been reviewed. For example, the evaluations could say “the 

NRC has examined the xxx administrative control procedure. Based on the review of the 

document, the staff has reasonable assurance that the xxx administrative control procedure is in 

compliance with applicant/licensee QA program and meets the requirements of 10 CFR Part 70 

(identify any specific regulatory of QA requirement that has been met).” The headquarters 

reviewer is only responsible for its conclusions for the review that they have performed. The 

RPI and NMSS Project Manager (PM) will track the completion of the identified inspections for 

the overall PSSC verification program. This completion information will be tracked in 

DIAMOND. 

In some IVPs, there are specific verification activities that were identified in the technical review 

and were identified in the Safety Evaluation Report (SER). The technical reviewer will perform 

technical reviews/inspection activities to verify that items identified in the SER are verified. The 

reviews should be documented similar to that for administrative controls and will also be tracked 

in DIAMOND.

Occasionally, the inspection or technical review staff may identify issues or inconsistencies with 

the IVPs that would necessitate a revision. In order to capture feedback from the inspection or 

technical review staff, a feature has been added to DIAMOND under the “Knowledge 
Issue Date: 09/20/16 C-5 2630

Management” section to efficiently capture and track IVP change requests. This request should 

be made in DIAMOND under the “Knowledge Management” section and categorized as an “IVP 

Change Request.” 

It is anticipated that the MFFF Assessment and Review Group (MARG) will meet on a periodic 

basis to plan out the anticipated inspection activities based on actual construction progress. 

The MARG will also meet periodically to review the appropriateness of the LOIE values, revise 

the IVPs based on feedback from the inspection or technical review staff, review inspection and 

technical review data in DIAMOND, and monitor PSSC verification activities.

3. INSPECTIONS IDENTIFIED BY INSPECTION OR TECHNICAL REVIEW STAFF THAT 

ARE NOT CONTAINED IN AN IVP

In the event that an inspector or technical reviewer identifies that additional inspections or 

reviews, beyond those identified in the IVP, are needed in order the verify the construction of 

the PSSCs, then the additional recommended inspections should be documented along with the 

need and bases for the additional inspections. This request should be made in DIAMOND 

under the “Knowledge Management” section and categorized as a “MIP Change Request.” The 

document should be transmitted to the RPI for consideration. The RPI will convene the MARG 

to evaluate whether the recommended inspections should be added to the IVP and MIP. The 

MARG will consider whether the additional inspection is needed to verify the PSSC. This 

evaluation will include the safety significance of the items proposed for inspection, as well as the 

overall resource implication. 

4. ASSESSMENT

Requests for additional inspections or technical reviews will be evaluated as part of the 

continuous assessment process. It is expected that the basis for requesting the additional 

inspections will be discussed by the requestor or designee at the periodic assessment meeting. 

The review of the request by the MARG will also be discussed and a recommendation regarding 

the additional inspections will be made to regional management. A decision regarding the 

additional request will normally be made during the assessment meeting.

If it is determined that additional inspections are needed, with management concurrence, the 

IVP and the MIP will be revised to reflect the changes.

5. FOCUS OF INSPECTIONS 

In order to effectively and efficiently allocate inspection resources, the NRC will perform 

sampling-type inspections to verify that the applicant/licensee is in compliance with NRC 

regulations. A combination of IROFS sample selection, statistical methods, risk-informed 

approaches, and inspections of the QA program, will be used to help determine the necessary 

level of inspection effort.
Issue Date: 09/20/16 C-6 2630

Inspection of all IROFS is not required for providing reasonable assurance that construction of 

the PSSCs was completed in accordance with the application. The NRC has historically relied 

on a sample-based inspection program to get a representative evaluation that can be applied 

across similar areas. The staff’s chosen approach for a particular PSSC will be that which best 

fits the nature of the PSSC, can be practically performed, and will provide reasonable assurance 

that the PSCC can perform its safety function. In some cases, generic programmatic 

inspections will be performed to assess the implementation of key supporting programs 

supporting the performance of PSSCs, such as configuration management or quality assurance. 

In a coordinated effort, the MARG considered the following attributes in selecting IROFS to be 

inspected in order to appropriately focus inspection resources: (1) safety significance; (2) 

propensity for errors; (3) construction and testing experience; and (4) opportunity to verify by 

other means. The NRC will focus its inspection resources on activities contributing to IROFS 

determined to have higher inspection value. This inspection sample will include both 

observation of IROFS-related work at the MFFF construction site, vendor facilities, and review 

of calculations and analyses by NMSS technical staff including administrative controls. These 

inspection targets will define the minimum sample set the NRC will inspect. This will provide the 

staff with a comprehensive sample based on inspection and technical review for IROFS. 

It should be noted that some of the PSSCs described in the MFFF CAR have only one safety 

function and have only a few IROFS associated with that safety function. In that scenario, the 

inspection target sample size may be equal to the number of IROFS. The verification process 

will incorporate one or more of the following methods: (1) PSSC field inspection results; (2) 

technical staff reviews and evaluations; and (3) staff review of applicant/licensee PSSC 

completion bases. For example, the inspections should include reviews of procedures; design 

verification and engineering reviews; vendor and procurement inspections; receipt inspections; 

installation inspections; reviews of inspection, test control, and control of measuring and test 

equipment; and control of materials, equipment, and services inspections. 

The inspection program will also focus inspections on QA program implementation. Inspection 

activities should emphasize the early identification of problem areas. It is important that 

inspectors evaluate whether noted problems represent isolated cases or are symptomatic of 

more systemic problems. 

6. PSSC VERIFICATION ACTIVITIES

a. Attribute Completion.

In order to complete the IVP process for a particular PSSC or PSSC family, a minimum 

number of attributes should be inspected or reviewed. The LOIE value lists provided in 

the IVPs correlate to a range of attributes that should be inspected or reviewed as part 

of the verification process. For each PSSC, the minimum number of attributes identified 

should be evaluated through inspection or technical review. The attributes inspected 

should be identified in the IRs, and will be tracked in DIAMOND. The RPI will verify that 

the minimum number of attributes have been inspected for each PSSC. It should be 

noted that some attributes, such as the corrective action program and QA, will be 
Issue Date: 09/20/16 C-7 2630

evaluated by programmatic inspections of the MFFF programs and applied to all 

applicable PSSCs. DIAMOND will also be used to track these programmatic 

inspections, and credit will be taken in the verification of each PSSC, as applicable.

The MARG will periodically review the information contained in DIAMOND (and

supporting documents, if needed) to support a determination of attribute completion. 

The MARG will examine the inspection and technical review information on individual 

attributes against the IVP. The results of the MARG meetings will be contained in a 

summary document that will include the decision making process and basis for the 

completion of an attribute for a PSSC/PSSC family. This documentation will be 

included in DIAMOND and will be the basis for indicating the completion of attributes. 

Additionally, the number of attributes examined for each PSSC will be tracked and the 

MARG will verify that the minimum number of attributes have been evaluated for each 

PSSC. 

b. Sample Selection.

A sample of IROFS component types, procedures or documents should be selected 

and verified for each prioritized IROFS in the IVP in order to complete the PSSC 

verification process. This is necessary to provide reasonable assurance that the 

construction of the PSSCs has been completed in accordance with the application. The 

IVPs identify the ISAS level IROFS, IROFS component types, and in some cases 

specific parts of the facility (e.g., purification (KPA)) that should be examined. The 

inspection sampling should be selected from one or more (as appropriate) of the 

prioritized IROFS component types or specific components as identified in the IVP. The 

sample size of the inspection will vary depending on the complexity of the system, 

inspection findings, and inspector judgment. 

c. Applicant/licensee’s PSSC Completion Letter

It is the applicant/licensee’s responsibility to complete the construction of each PSSC. 

The applicant/licensee has developed scoping documents that associates the ISAS 

IROFS with the 53 PSSCs described in the CAR. These scoping documents were 

prepared for each PSSC also correlate the events contained in the CAR to the ISAS. 

These documents also provide the ISAS events, ISAS IROFS, IROFS component 

types, and the specific IROFS components. The listing of administrative IROFS is 

separate and is not provided in the scoping documents. 

The applicant/licensee’s completion of a PSSC is based solely on the construction of 

the PSSC. The ability of the PSSC and its associated IROFS to function properly will 

be addressed as part of the operational readiness review (ORR). The detailed plan to 

perform the ORR at the MFFF will be documented separately from the PSSC 

verification program (see Appendix H). PSSC completion will vary based on the nature 

of the PSSC. The following are some unique aspects of completion for various PSSCs:

1. PSSC-002: 3013 Transport Cask - Completion of the 3013 transport cask is 

contingent upon the existence of a Certificate of Compliance, approved under 10 

CFR Part 71, for transport of the 3013 canisters. The applicant/licensee would 
Issue Date: 09/20/16 C-8 2630

not be required to have the transport package constructed by the time of PSSC 

verification.

2. PSSC-027: Hazardous Material Delivery Controls – This PSSC consists of 

administrative controls. For this PSSC to be completed, the applicable 

administrative controls and associated procedures would have to be completed 

and documentation issued by the applicant/licensee. A sampling of 

administrative controls will be reviewed by NRC technical reviewers as identified 

in the associated IVP. 

3. For PSSCs that consist of engineered and administrative IROFS, the IROFS 

would have to be constructed and installed as part of PSSC completion. 

However, operational testing would not need to be performed at the time of

PSSC completion. For example, for one of the confinement systems, the fans 

and other IROFS components would need to be constructed and installed. The 

PSSC must be capable to perform its safety function even though operational 

testing had not yet been completed. This would mean that the confinement 

system that had been constructed has the capability to be balanced in order to 

perform its safety function of providing negative pressure. This would meet the 

requirements specified for verification of construction as part of PSSC 

verification. However, the verification of whether the system is indeed balanced 

would be part of the ORR. As noted in item b above, administrative controls and 

associated procedures will have been prepared and issued by the 

applicant/licensee as part of the PSSC verification.

Following completion of construction of the PSSC, the applicant/licensee has 

volunteered to submit a letter to the NRC NMSS program office stating that the PSSC is 

complete and ready for NRC to make a verification determination. This letter will 

contain the specific details for the staff to determine whether or not PSSC construction 

has been completed. It is expected that prior to such a letter being submitted, that the 

MARG and any additional inspection staff will meet, if necessary, with the 

applicant/licensee to identify whether there are any gaps in the applicant/licensee’s 

PSSC completion that may impact the staff’s ability to make a verification 

determination.

d. Review and Data Analysis.

The MARG, with any additional staff resources as needed, will review and analyze the 

data stored in DIAMOND to ensure that the required information has been collected to 

determine that construction of a PSSC is complete. Inspection records, supplemental 

information, and the verification activities summaries will be considered by the MARG. 

Technical reviewers, assigned to this review by their respective branch chiefs, may be 

required to provide input regarding the decision on the closure of verification activities of 

a PSSC. 

This review process of inspection results and verification status will be performed 

continuously and will be the subject of meetings between the MARG and appropriate 

inspection staff. 
Issue Date: 09/20/16 C-9 2630

Region II RPI and the RPI’s Branch Chief will certify to NMSS the verification of 

construction completion for PSSCs subject to verification through inspection. The 

certification process will include the issuance of a PSSC construction completion report 

following this verification. This certification should indicate that there is reasonable 

assurance that the construction of the PSSC or PSSC family is complete based on a 

comprehensive inspection verification process that includes references to the relevant 

IRs. 

NMSS will certify the verification of completion of PSSCs that are administrative in 

nature, as indicated in the IVPs. This includes those that reference an approved item 

such as the transportation package and other PSSCs that consist of only administrative 

controls. This certification should indicate that there is reasonable assurance that the 

construction of the PSSC or PSSC family is complete based on the reviews that were 

performed and should include references to the evaluation reports.

Both NMSS and Region II RPI and the RPI Branch Chief will jointly certify the 

verifications of PSSC completions for those PSSCs (or families) that include both 

administrative controls and controls that were verified by inspections and will be 

documented as discussed above.

The verification of completion reports should reference the inspections and reviews that 

were performed to support the verification finding (this information should be in 

DIAMOND). The documents should include the basis for the staff’s findings and should 

clearly state that construction of the particular PSSC has been verified. The report 

should follow a standard PSSC verification completion document format (under 

development). The verification documents should be signed by the branch chief in DCP 

responsible for the MFFF project. The individual PSSC verification documents should 

be submitted to the NMSS PM. The verification report may be prepared for individual 

PSSCs or a PSSC family as appropriate.

NMSS will maintain the status of the verification of construction completion for the 

PSSCs. NMSS will file a notice advising the Atomic Safety Licensing Board (ASLB) (if 

the record is still open) or the Commission (if the record is closed) once all information 

relevant to the verification of construction completion is before the agency and will 

prepare a Safety Evaluation Report Supplement following completion of the PSSC 

verification program.

e. Approval.

Following receipt of the voluntary completion letter(s) for the PSSCs from the 

applicant/licensee, the staff will perform a final review and data analysis of the PSSCs. 

Additionally, a final walk down inspection by the resident inspector(s) and other 

appropriate staff may be performed if deemed appropriate. Additionally, in-office 

reviews between the MARG, the resident inspectors, and the applicant/licensee may be 

held to review the final aspects of the applicant/licensee’s completion determination. In 

the event that the staff believes that it cannot make a positive verification finding 

regarding completion of construction of a particular PSSC, then staff will document the 
Issue Date: 09/20/16 C-10 2630

information that is still needed in the form of a request for additional information (RAI) 

which will be prepared by the NMSS PM. The staff will follow standard practices 

regarding resolving RAIs (i.e., written documentation, in-office reviews, inspections, 

etc.) prior to making a final determination.

Due to the expected length of time between the applicant/licensee’s voluntary submittal 

of the first PSSC completion letter and the last PSSC completion letter, it is anticipated 

that the applicant/licensee will submit a final completion letter for all PSSCs to the 

NMSS program office. Following the applicant/licensee’s voluntary submittal of the final 

PSSC completion letter and the staff’s completion of the PSSC verification documents, 

the NMSS/FCSE PM will prepare an SER supplement which will summarize the 

documents and will provide the staffs overall finding regarding PSSC verification as per 

10 CFR 70.23(a)(8). 

END
Issue Date: 09/20/16 D-1 2630

Appendix D

Principal Systems, Structures, And Components (PSSCs) Families

IVP Number Family (if applicable) PSSC Number and Name

IVP-001 Process & Chemical 

Safety

PSSC-003 Backflow Prevention Features

PSSC-007: Chemical Safety Control

PSSC-038: Process Off-gas System

PSSC-045: Process Safety Control 

Subsystem

IVP-002 Containment Systems PSSC-004: C2 Confinement System 

PSSC-005: C3 Confinement System

PSSC-006: C4 Confinement System

PSSC-033: Material Maintenance & 

Surveillance Program

PSSC-044: Process Cell Exhaust System

IVP-003 Fire Barriers and 

Control

PSSC-008: Combustible Loading Controls

PSSC-021: Fire Barriers

PSSC-022: Fire Detection and Suppression

PSSC-043: Process Cell Fire Prevention

PSSC-046: Seismic Monitoring and 

Associated Seismic Isolation Valves

IVP-004 Criticality Safety 

Controls

PSSC-009: Criticality Safety Controls

PSSC-032: Material Handling Equipment

IVP-005 Process Vessels and 

Pipe

PSSC-010: Double Walled Pipe 

PSSC-023: Fluid Transport Systems 

PSSC-041: Process Cells

IVP-006 Electrolyzer 

Components

PSSC-011: Electrolyzer Structure

PSSC-026: Guide Sleeves

PSSC-039: PTFE Insulator

IVP-007 Emergency Systems PSSC-012: Emergency AC Power System

PSSC-014: Emergency Control System

PSSC-015: Emergency DC Power System

PSSC-018: Emergency Diesel Generator 

Fuel Oil System

IVP-008 Air Systems PSSC-013: Emergency Control Room Air 

Conditioning System

PSSC-017: Emergency Generator 

Ventilation System

PSSC-028: Instrument Air System

PSSC-050: Supply Air System

IVP-009 Building Structures PSSC-016: Emergency Generator Building 

Structure

PSSC-035: Missile Barriers

PSSC-036: MFFF Building Structure

IVP-010 Facility Worker Action PSSC-019: Facility Worker Action
Issue Date: 09/20/16 D-2 2630

IVP-011 Gloveboxes PSSC-024: Glovebox

PSSC-025: Glovebox Pressure Controls 

IVP-012 MFFF Tornado 

Dampers

PSSC-034: MFFF Tornado Dampers

IVP-013 Sintering Furnace PSSC-048: Sintering Furnace

PSSC-049: Sintering Furnace Pressure 

Controls

IVP-014 Waste and Transfer 

container

PSSC-051: Transfer Container

PSSC-052: Waste Containers 

IVP-015 Waste Transfer Line PSSC-053: Waste Transfer Line

IVP-016 3013 Canister PSSC-001: 3013 Canister

IVP-017 3013 Transport Cask PSSC-002: 3013 Transport Cask

IVP-018 Facility Worker 

Controls

PSSC-020: Facility Worker Controls

IVP-019 Hazardous Material 

Delivery Controls

PSSC-027: Hazardous Material Delivery 

Controls

IVP-020 Laboratory Material 

Controls

PSSC-029: Laboratory Material Controls

IVP-021 Maintenance Activity 

Controls

PSSC-030: Maintenance Activity Controls

IVP-022 Material Handling 

Controls

PSSC-031: Material Handling Controls

IVP-023 MOX Fuel Transport 

Cask

PSSC-037: MOX Fuel Transport Cask

IVP-024 Pressure Vessel 

Controls

PSSC-040: Pressure Vessel Controls

IVP-025 Process Cell Entry 

Controls

PSSC-042: Process Cell Entry Controls

IVP-026 Sintered Silicon Nitride 

Barrier

PSSC-047: Sintered Silicon Nitride Barrier

END
Issue Date: 09/20/16 E-1 2630

Appendix E

Prioritization of Items Relied on for Safety (IROFS)

1. PURPOSE 

This section provides a discussion of the risk-informed methodology used for prioritizing IROFS. 

The overall objective of this prioritization is to define those IROFS that are most risk significant 

for each principal systems, structures and components (PSSCs). This prioritization was needed 

to optimize Nuclear Regulatory Commission (NRC) resources, while providing reasonable 

assurance that a significant flaw by the applicant/licensee does not go undetected. 

2. BACKGROUND

Table 5.6-1 of the Mixed Oxide (MOX) Fuel Fabrication Facility (MFFF) Construction 

Authorization Request (CAR) lists the 53 PSSCs and their associated safety functions. The 

PSSCs are identified as administrative controls, active engineered controls or passive 

engineered controls. Since the approval of the MFFF CAR on October 30, 2002, the 

applicant/licensee has identified, in the Integrated Safety Analysis Summary (ISAS), 

approximately 250 IROFS designated to perform the design basis safety functions of the 

PSSCs. 

The staff’s findings as documented in the MFFF construction authorization, stated “in 

accordance with 10 CFR 70.23(b), on the basis of information described in the CAR, as revised, 

and the additional statements and commitments heretofore made by DCS, the design bases of 

the PSSCs for the proposed MFFF and the quality assurance (QA) program, provide reasonable 

assurance of protection against natural phenomena and the consequences of potential 

accidents.” The applicant/licensee submitted an License Application (LA) to possess and use 

special nuclear material on September 26, 2006 (as supplemented). The LA includes the 

detailed safety functions and design bases of the IROFSs for the MFFF. Additionally, the ISAS 

provides the IROFS for the facility that support the performance of the MFFF’s safety functions. 

These IROFS perform the safety functions needed to satisfy the design bases defined in the 

CAR.

3. DISCUSSION

As part of the technical review of the MFFF LA and ISAS, the NRC staff performed a vertical 

and horizontal slice review of various aspects of the design. This first consisted of reviewing the 

LA and ISAS that were submitted by the applicant/licensee. The ISAS discussed the events 

that could cause a release of hazardous material or a radiation dose that could produce an 

intermediate or high consequence (as defined in 10 CFR 70.61) to affected workers or the 

public. The ISAS included over 200 IROFS which were applied by the applicant/licensee to 

make the identified events highly unlikely. The ISAS IROFS are more general in nature and 

include many categories of IROFS components (such as favorable geometry tanks, double 

walled pipe, and instrumentation). The ISAS did not discuss the specifics of each of the 
Issue Date: 09/20/16 E-2 2630

individual IROFS components. The specifics for IROFS components are provided in the 

process safety information required by the applicant/licensee to be maintained on site. For the 

prioritization of IROFS for the MFFF, the staff used terms to identify IROFS which range from a) 

the general categories identified in the ISAS (ISAS IROFS); b) the categories of IROFS 

components types (i.e., tanks, valves, instrumentation, pipes, vessels, etc.); and c) specific

IROFS components.

As part of the licensing review, the staff also reviewed a sampling of the applicant/licensees’ 

process safety documents for the ISAS. These documents included Nuclear Safety 

Evaluations, Nuclear Criticality Safety Evaluations, calculations, what if checklists, drawings, 

etc. These reviews allowed the staff to have a good understanding of the types of events that 

could cause releases with intermediate or high consequences and which events were either 

determined by the applicant/licensee to be not credible or were determined to be of low 

consequence. 

With this understanding, the staff selected the events that were determined to be of higher risk 

significance to perform a more detailed review. For example, in the review of chemical safety, 

the applicant/licensee outlined explosion events that could potentially occur at the MFFF and 

applied IROFS to make those events highly unlikely. Based on staff expertise and experience, 

knowledge of potential events at other fuel cycle facilities, potential consequences of the event, 

complexity of the system, and actual examples of incidents that have occurred around the world 

in the fuel cycle and chemical industry, the staff narrowed the list of events to review in more 

detail to the ones that were most significant. For these events of greater risk and significance, 

the technical reviewers performed detailed reviews of the calculational bases for the event. 

Known as horizontal and vertical slice reviews, these reviews looked at possible events in a 

general way (horizontal) and details of individual events (vertical) in a specific way. Specifically, 

for example, the chemical technical review staff spent more review effort on explosion events 

related to hydroxyl amine nitrate (HAN) and “Red Oil.” 

Following a similar approach as the technical reviewers, the staff used the same set of priorities 

to evaluate the ISAS IROFS. For the prioritized ISAS IROFS, the staff outlined the IROFS 

component types. These IROFS component types provide the basis for the development of the 

staff’s independent verification plans (IVPs) for PSSCs which are implemented via inspections 

and reviews of administrative controls. 

The evaluation of the prioritization of the ISAS IROFS can be found in DIAMOND. This 

spreadsheet lists the ISAS IROFS associated with each PSSC. The document also shows the 

results of the staff review to identify the prioritized ISAS IROFS and provides a discussion of the 

prioritization bases by PSSC. The staff then took this document and prepared the IVP basis 

spreadsheet. This spreadsheet lists the prioritized ISAS IROFS by PSSC and includes the 

IROFS component types. These spreadsheets can be found in the reference section of 

DIAMOND. This document was used as the basis for development of the IVPs. 

END
Issue Date: 09/20/16 F-1 2630

Appendix F

Level of Inspection Effort (LOIE) Methodology

1. PURPOSE

The staff developed a process called LOIE to prioritize the level of inspection effort and the 

number of inspection attributes that will be used to verify completion of each principal systems, 

structures and components (PSSCs). 

2. METHODOLOGY

LOIE is a methodology that prioritizes the value of inspecting construction activities pertaining to 

PSSCs. This methodology determines the scope of each PSSC Independent Verification Plan 

(IVP) and supports inspection planning and scheduling. This methodology will provide 

reasonable assurance that the construction of the PSSC was completed in accordance with the 

application (as required by 10 CFR 70.23(a)(8)) by using a risk-informed approach to determine 

the LOIE value for each PSSC. The LOIE value is defined as the likelihood of an undetected 

construction error (“L” value) times the consequence of failure to detect the error (“C” value). 

The Mixed Oxide (MOX) Fuel Fabrication Facility Assessment and Review Group (MARG), 

consisting of staff from the Office of Nuclear Material Safety and Safeguards’ Division of Fuel 

Cycle Safety, Safeguards, and Environmental Review (NMSS/FCSE) and the Region II Division 

of Construction Projects (RII/DCP) determined both the “L” values and “C” values. The “C” 

values were determined by considering the impact of the loss of the PSSC’s safety function and 

on the following:

 Impacts public (C = 3; high consequence)

 Impacts off-site workers and facility workers (C = 2; medium consequence)

 Impacts only facility workers (C = 1; low consequence)

 No consequence (C = 1; low consequence)

The consequence value was obtained from the review of the applicant/licensee’s Integrated 

Safety Analysis Summary (ISAS). The ISAS presents the events that could cause either an 

intermediate or high consequence event (radiation dose or chemical exposure) as required by 

10 CFR Part 70. The events are shown in areas such as explosion events, criticality, loss of 

confinement, et al. The ISAS further discussed the potential consequences of the events, the 

items relied on for safety (IROFS) applied to make the event highly unlikely, the applicable 

codes and standards, the application of quality assurance (QA) requirements, and the use of 

management measures. The events related to individual PSSCs were identified in the staff’s 

technical review and were used in the development of LOIE values for each PSSC.

For the determination of likelihood, the MARG used the considerations listed below to determine 

the “L” values as part of the LOIE calculation. 

 Error propensity

 Complexity of construction
Issue Date: 09/20/16 F-2 2630

 Fabricator/vendor performance

 Quality of materials

 One-of-a-kind item

 Commercial grade dedication process

 Construction testing experience

 Licensee oversight

 QA organization

 Defense in depth

 Operating experience

 Likelihood that the error would be detected by other means (self-revealing, pre-op 

testing, etc.)

The MARG examined the individual PSSCs and the IROFS that relate to the PSSCs. The 

MARG used the above factors in order to determine the likelihood for an undetected PSSC 

error. The values used in the determination are: 

 High likelihood (L=3)

 Moderate likelihood (L=2)

 Low likelihood (L=1)

Table 1 shows the relationship between likelihood, consequence, and the LOIE value. Note that 

a LOIE value of “1” would necessitate the least amount of inspection resources, while a LOIE 

value of “9” would require the greatest amount of inspection resources. By definition, a LOIE 

value of “0” would not be possible. 

Table 1- LOIE value prioritization matrix

Consequence

Likelihood Low

(C=1)

Medium

(C=2)

High

(C=3)

High (L=3) 3 6 9

Medium (L=2) 2 4 6

Low (L=1) 1 2 3

The LOIE value for each PSSC was translated into inspection attributes. Refer to Table 2 to 

obtain the correlation between the LOIE value and the number of inspection attributes. The 

inspection attributes are units that allow meaningful comparison of PSSCs. The inspection 

attributes were derived from the inspection procedures listed in Appendix A of this IMC and will 

determine the scope of the verification activities. The inspection attributes are defined below:
Issue Date: 09/20/16 F-3 2630

 Quality Assurance 

 Design Control

 Control of Materials, Equipment, and Services

 Test Control

 Corrective Action Program

 Installation

 Procurement 

 Fabrication

 Procedures

 Vendor Oversight / Inspection

 Software Quality Assurance Program

 Quality Assurance Interfaces

 As-built / Functional Arrangement of IROFSs

 Special Processes (e.g. welding)

 10 CFR 21 – Construction

Depending on the LOIE value for each PSSC; the number of inspection attributes is shown in 

Table 2.

Table 2- Correlation of LOIE Value to Inspection Attributes

LOIE # of Attributes

(Determines the Scope of the IVP)

1 1-5

2 2-6

3 3-7

4 4-8

6 6-11

9 10-15

Additionally, to ensure that the scope of the inspection program evaluates all PSSCs, C=0 and 

L=0 were not considered. This is conservative and ensures that each PSSC is assigned a nonzero LOIE score and will receive an inspection of at least one attribute.

3. REVIEW AND ASSESSMENT

Periodically, the MARG will review the LOIE values as described in Figure 1 and determine if 

the likelihood values need to be revised based on inspection experience, new information 

received from the applicant/licensee, vendor performance, or operating experience. The basis 

for revising the likelihood values will be documented in DIAMOND as well as any subsequent 
Issue Date: 09/20/16 F-4 2630

changes to the LOIE. Changes to the LOIE value will result in adjusting the number of 

inspection attributes and the scope of the inspections described in the IVP. The MARG will 

determine if the IVP and the Master Inspection Plan (MIP) should be revised to reflect the 

changes. The inspection staff should be kept apprise of any adjustments to the LOIE as well as 

changes to the IVP or MIP.

END
Issue Date: 09/20/16 F-5 2630

Obtain the consequences 

(C) from the ISA and NMSS 

technical reviewers and 

likelihood of undetected 

construction error (L).

&

Create a joint panel (MARG) consisting of technical 

reviewers and project inspectors. 

Evaluate the consequences to the facility workers, off-site 

workers, and individuals outside the controlled area for 

each accident sequence. The L value should be 

determined from industry and inspection experience data. 

Note that some PSSCs may be used to mitigate several accident sequences. Usually those PSSCs have a 

higher risk, because if that PSSC fails to perform its intended safety function, several accident sequences 

could occur. Assign a consequence ranking of 1 – 3. 

Calculate the level of inspection effort (LOIE) for each PSSC: LOIE = L x C

PSSC Grouping

Active Engineered Controls Passive Engineered Controls Administrative Controls

Evaluate the complexity, 

understanding of the process, 

level of detail and reliability, 

including:

 Error propensity

 Complexity of construction

 Fabricator performance

 Quality of materials

 One-of-a-kind item

 Commercial grade 

dedication process

 Construction testing 

experience

 Licensee oversight

 QA organization

Evaluate the complexity, 

understanding of the 

process, level of detail and 

reliability. For example, for 

active engineered controls, 

the expert panel could verify 

the type of activation used by 

the control (thermal, electric, 

etc.), type of logic, interfaces 

(alarms, valve actuators, 

etc.). Also, consider the 

factors listed under passive 

engineered controls.

Evaluate the complexity, 

understanding of the 

process, level of detail and 

reliability. For example, for 

admin controls, the expert 

panel could verify the 

following:

 Number of actions 

required by the operator.

 Degree of training

 Work conditions

 Routine (normal 

operating conditions.

 Emergency

 Human factors

For each PSSC, determine an L value of 1 - 3 using the data obtained in the previous step.

An L value of 3 means a high likelihood of an undetected construction error. An L value of 1 may be 

considered as the baseline inspection program. 

Calculate the appropriate LOIE value for each PSSC to determine the number of inspection attributes. 

Incorporate the LOIE value and choice of inspection attributes into the PIVP.

Periodically review the L values for each PSSC to determine if changes occurred that would increase or 

decrease the L value (likelihood of an undetected construction error).

Figure 1: Level of Inspection Effort (LOIE) Flowchart for MFFF PSSCs
Issue Date: 09/20/16 G-1 2630

Appendix G

Digital Information Archive for the Mixed Oxide Fuel Fabrication Facility (MFFF)

and Online Normalized Database (DIAMOND)

1. PURPOSE 

This section provides general information regarding DIAMOND and how it will be used to 

document and track the principal systems, structures and components (PSSCs) verification 

activities. These activities include inspections and reviews by regional and resident inspectors 

and headquarters technical staff. This documentation will be used as the basis for the 

determination that the applicant/licensee has met the requirements of 10 CFR 70.23(a)(8).

2. BACKGROUND 

DIAMOND is a tool that will be used to input and manage inspection data, as well as track the 

progress of the completion status of the MFFF PSSC verification inspection program. Staff will 

use DIAMOND to (1) plan their inspections, (2) access technical documents, (3) document 

inspection reports and staff reviews, (4) track progress toward inspection verification program 

completion, (5) allocate inspection resources, (6) monitor status of open items, and (7) prepare 

status reports. 

Access to this tool is located on the Office of Nuclear Material Safety and Safeguards’ internal 

SharePoint Site and access is controlled. Only authorized inspectors and personnel can access 

DIAMOND. This tool has been designed specifically for the verification program for the MFFF. 

Since this is a SharePoint site, it is relatively easy to use, and assistance can be provided by the 

Agency-wide SharePoint Help-Desk. The SharePoint Help Desk may be reached by dialing 

301-415-1234, option #5- “EPM and SharePoint” or by email: SharePoint.Help@nrc.gov. 

3. DOCUMENTATION IN DIAMOND 

Proper documentation of the verification activities is essential to accomplish an effective 

implementation of the MFFF inspection program and provide documentation for demonstrating 

compliance with 70.23(a)(8). Once an inspection report has been prepared and declared in 

ADAMS, it will be added to DIAMOND. A summary of the verification activities for each PSSC 

will be entered to the system. Inspection items (e.g. open, closed and discussed items) must be 

added (or updated) into DIAMOND as well. The information entered in DIAMOND should be 

concise and precise. The user should keep in mind that the information in DIAMOND will be 

used to make the final licensing decision for the MFFF. The regional project inspector is 

responsible for entering information into DIAMOND.

If LOIE values are updated or require change (based on inspection experience), the LOIE value 

information should be promptly updated in DIAMOND. The basis for the changes will be 

documented and approved by the Mixed Oxide (MOX) Fuel Fabrication Facility Assessment and 

Review Group (MARG) prior to any changes being made. When the verification activities have 
Issue Date: 09/20/16 G-2 2630

been completed for a particular PSSC, staff will update DIAMOND to show that the PSSC has 

been verified.

Specific details about DIAMOND can found in the DIAMOND User’s Guide which can be 

accessed in the “Reference” section of DIAMOND. 

END
Issue Date: 09/20/16 H-1 2630

Appendix H

Mixed Oxide Fuel Fabrication Facility

Operational Readiness Review

RESERVED
Issue Date: 09/20/16 Exh1-1 2630

Exhibit 1: Construction Action Matrix

Column I Column II Column III Column IV

RESULTS

Only Severity Level (SL) IV violations 

or non-cited violations

NRC requirements fully met

One or two SLIII violations 

NRC requirements met with some 

challenges to applicant/licensee

Three SL III violations or one SL II 

violation, or a combination of the 

above.

NRC requirements met with some 

significant challenges to 

applicant/licensee 

(Degraded Performance)

One SL I violation, multiple SL II violations, or a 

combination of the following: one SL II and a 

total of four or more SL III violations; or a total of 

seven or more SL III violations

Loss of confidence to construct within NRC 

requirements in areas of concern 

(Unacceptable Performance)

RESPONSE

Regulatory 

Performance

Meeting

None Branch Chief or Division Director 

meets with applicant/licensee.

Deputy Regional Administrator for 

Construction (DRAC) or designee 

meets with senior applicant/licensee 

management.

Regional Administrator (RA) or designee meet 

with senior applicant/licensee management.

Applicant/licensee 

Action

Applicant/licensee corrective actions Applicant/licensee root cause 

evaluation and corrective action with 

NRC oversight.

Applicant/licensee cumulative root 

cause evaluation with NRC oversight.

Applicant/licensee Performance Improvement 

Plan and independent inspection with NRC 

oversight.

NRC Inspection Routine inspection program Limited increase in NRC oversight of 

area(s) of concern. 

Expanded NRC oversight in area(s) of 

concern. Inspection sample increased

as appropriate. 

Reactive team inspection in area(s) of concern. 

Regulatory 

Actions

None

Additional actions considered for sites 

exiting Column III or Column IV. 

Additional inspection only. Additional 

actions considered for sites exiting 

Column III or Column IV.

Additional inspection only. (Additional 

actions considered for sites exiting 

Column IV).

At minimum, issue confirmatory action letter. 

Evaluate need for Demand for Information 

and/or Order. 

COMMUNICATION

Assessment 

Letters

If needed, Branch Chief or Division 

Director reviews/signs assessment 

report.

Division Director reviews/signs 

assessment report.

DRAC or designee reviews/signs 

assessment report.

Regional Administrator reviews/signs 

assessment report.

Annual Public 

Meeting

Senior Project Inspector or Branch 

Chief meets with applicant/licensee.

Branch Chief or Division Director 

discusses performance with 

applicant/licensee.

DRAC or designee discusses 

performance with applicant/licensee.

Regional Administrator or designee discusses 

performance with applicant/licensee.

Commission 

Involvement

None None None Consider Commission meeting with senior 

applicant/licensee management

INCREASING SAFETY/REGULATORY SIGNIFICANCE
Issue Date: 09/20/16 Att1-1 2630

Attachment 1 - Revision History for IMC 2630

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of Training 

Required and 

Completion Date 

Comment and 

Feedback Resolution 

Accession Number

(Pre-Decisional, NonPublic)

N/A ML051450201

05/18/05

CN 05-013

New Inspection Manual Chapter None N/A

N/A ML14028A249

05/09/14

CN 14-011

Completely revised to incorporate 

inspection documentation requirements 

for inspections of principal systems, 

structures, and components; assessment 

process; independent verification plan 

process; level of inspection effort 

methodology; use of inspection data 

management tools; and prioritization of 

items relied on for safety. 

None ML14055A375

N/A ML15134A068

09/24/15

CN 15-018

Included Resident Inspection Relocation 

section per instruction of January 13, 2009 

memo, Analysis of Options and 

Recommendations for Management the 

Field Policy Manual (ML090070444).

Included section on Lapsed 

Appropriations in reference to changes in 

MD 4.5 and Oct 4, 2013 briefing memo 

(ML13276A057) as required by SRMCOMSECY-14-0017 (ML14196A064)

None ML15134A071
Issue Date: 09/20/16 Att1-2 2630

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of 

Training Required 

and Completion Date 

Comment and 

Feedback Resolution 

Accession Number

(Pre-Decisional, NonPublic)

N/A cont. Changed FCSS to FCSE and updated 

Divisional name.

Removed implementation of MC&A 

inspection program from FCSE 

responsibilities and added it to RII/DFFI.

Removed documentation of minor 

violations associated with allegations.

None ML15134A071

N/A ML16245A788

09/20/16

CN 16-023

Updated the inspection planning section to 

include consideration of NRC budgeted 

resources when scheduling inspections. 

This update completes implementation of 

SECY-16-0009 Enclosure 1 C-List 

Implementation Item #145.

Updated the resident inspector program 

section to include NRC management in 

determining the assignment of a resident 

inspector as needed. 

None N/A