Issue Date: 01/14/04 i 0612

NRC INSPECTION MANUAL IIPB

MANUAL CHAPTER 0612

POWER REACTOR INSPECTION REPORTS 
0612 ii Issue Date: 01/14/04

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Issue Date: 01/14/04 iii 0612

CONTENTS

Page

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

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

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

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

04.01 General Responsibilities. .................................... 4

04.02 Inspectors ................................................ 4

04.03 Branch Chiefs and Division Directors............................ 4

04.04 Program Office. ........................................... 5

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

05.01 Screen for Performance Deficiencies. .......................... 5

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

05.03 Screen for Minor Issues. ..................................... 6

05.04 Screen for Significance. ..................................... 6

0612-06 WRITING INSPECTION DETAILS FOR NRC-IDENTIFIED FINDINGS

AND VIOLATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

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

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

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

a. Introduction .......................................... 9

b. Description ........................................... 9

c. Analysis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

(1) Risk-Informed SDP Results - ( Results from IMC 0609

Appendices A, F, G and H) .......................... 9

(2) Non-Risk-Informed SDP Results - Results from IMC 0609

Appendices B, C, D, E, and I . . . . . . . . . . . . . . . . . . . . . . . . 10

(3) Non-SDP Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

(4) Findings Related to Cross-Cutting Areas . . . . . . . . . . . . . . 11

d. Enforcement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

06.04 Tracking. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

0612-07 DOCUMENTING PERFORMANCE INDICATOR VERIFICATION

RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

0612-08 DOCUMENTING UNRESOLVED ITEMS . . . . . . . . . . . . . . . . . . . . . . 15
0612 iv Issue Date: 01/14/04

0612-09 DOCUMENTING LERs AND LICENSEE-IDENTIFIED DEFICIENCIES . 15

09.01 Events and Licensee Event Reports (LER) . . . . . . . . . . . . . . . . . . . . . . 15

a. LERs without Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

b. LERs with Violations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

09.02 Licensee-Identified Deficiency. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

0612-10 OTHER GUIDANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

10.01 Treatment of Third Party Reviews. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

0612-11 COMPILING AN INSPECTION REPORT . . . . . . . . . . . . . . . . . . . . . . . 18

11.01 Report Organization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

11.02 Plant Status. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

11.03 Summary of Findings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

11.04 Cover Page. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

11.05 Table of Contents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

11.06 Exit Meeting Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

11.07 Report Attachments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

11.08 Cover Letter. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

0612-12 ISSUING INSPECTION REPORTS . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

12.01 Report Timeliness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

12.02 Release and Disclosure of Inspection Reports . . . . . . . . . . . . . . . . . . . 25
Issue Date: 01/14/04 1 0612

POWER REACTOR INSPECTION REPORTS

0612-01 PURPOSE

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

0612-02 OBJECTIVES

To ensure that inspection reports:

02.01 Clearly communicate significant inspection results in a consistent manner to

licensees, NRC staff, and the public.

02.02 Document the basis for significance determination and enforcement action.

02.03 Provide inspection results as one input into the Operating Reactor Assessment

Program (IMC 0305) of the Reactor Oversight Process (ROP). 

0612-03 DEFINITIONS

The following terms are applicable for the purposes of documentation:

Apparent violation (AV): A potential noncompliance with a regulatory requirement,

regardless of possible significance or severity level, that has not yet been formally

dispositioned by the NRC.

Closed Item: A matter previously reported as a noncompliance, an inspection finding, a

licensee event report, or an unresolved item, that the inspector concludes has been

satisfactorily addressed based on information obtained during the current inspection.

Credible: A scenario offering reasonable grounds for being realistic (given a set of existing

conditions postulating a scenario with no more than one “if”).

Deficiency: (When applied to emergency preparedness) A demonstrated level of

performance (e.g., in a drill) that would likely have adversely impacted effective

implementation of the emergency plan in the event of an actual emergency.(See 10 CFR

50.54(s)(ii).)

Deviation: A licensee's failure to satisfy a written commitment, such as a commitment to

conform to the provisions of applicable codes, standards, guides, or accepted industry

practices when the commitment, code, standard, guide, or practice involved has not been

made a requirement by the Commission.

Escalated Enforcement Action: A notice of violation or civil penalty for any Severity Level

I, II, or III violation (or problem); a notice of violation associated with an inspection finding

that the significance determination process characterizes as having low to moderate, or
0612 2 Issue Date: 01/14/04

greater safety significance(white, yellow or red finding); or any order based upon a

violation.

Finding (FIN): An issue of concern that is related to a licensee performance deficiency.

Findings may or may not be related to regulatory requirements and, therefore, may or may

not be related to a violation.

Green Finding: A finding of very low safety significance.

Independent Item: An item used to track information that does not originate in or is

typically not documented as a finding in an inspection report but may be referenced in an

inspection report to assess plant performance such as an Office of Investigation

harassment and intimidation case. 

Inspector-Identified: For the purpose of this Manual Chapter, inspector-identified findings

are those findings found by NRC inspectors that the licensee had not previously

documented in a corrective action program; had not been identified by a licenseesponsored program, evaluation, or audit designed to identify deficiencies; and would not

reasonably have been otherwise identified in the licensee’s normal processes or reviews.

Inspector-identified findings also include previously documented licensee findings to which

the inspector has added new value .

Integrated Inspection Reports: A reactor inspection report that combines inputs from

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

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

or may not result in a finding.

Licensee-Identified: For the purpose of the Manual Chapter, “licensee-identified” findings

are those findings identified through a licensee program or process that are specifically

intended to identify the problem. Some examples of licensee programs that likely result

in such findings are post maintenance testing, surveillance testing, ASME Section XI

testing, drills, critiques, event assessments, evaluations, or audits conducted by or for the

licensee. Most green findings documented in the licensee’s corrective action program are

considered licensee-identified. 

Minor Violation/Finding: A violation or finding that is less significant than a Severity Level

IV violation or less significant than what the SDP characterizes as green and is of such low

significance that documentation in an NRC inspection report is not normally warranted.

Although minor violations must be corrected, they are not usually described in inspection

reports.

Non-cited Violation (NCV): A method for dispositioning a Severity Level IV violation or a

violation associated with a finding that is characterized as green (very low safety

significance). Provided applicable criteria in the enforcement policy are met, such findings

are documented as violations, but are not cited in notices of violation, which normally

require written responses from licensees.
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Noncompliance: A violation (regardless of whether it is cited or not), nonconformance, or

deviation.

Nonconformance: A vendor’s or certificate holder's failure to meet contract requirements

related to NRC activities (e.g., 10 CFR Part 50, Appendix B, Part 71, or Part 72) where the

NRC has not imposed requirements directly on the vendor or certificate holder.

Notice of Violation (NOV): A formal, written citation in accordance with 10 CFR 2.201 that

sets forth one or more violations of a legally binding regulatory requirement.

Observation: A factual detail noted during an inspection. Observations are not generally

documented in inspection reports but may be documented in conjunction with and to

support a finding.

Performance Deficiency: An issue that is the result of a licensee not meeting a

requirement or standard where the cause was reasonably within the licensee’s ability to

foresee and correct, and which should have been prevented. Issues related to crosscutting areas are generally considered an underlying cause of a performance deficiency

rather than an independent issue. Issues of problem identification and resolution, human

performance, or establishment of a safety-conscious work environment, in and of

themselves, do not provide the basis for a performance deficiency.

Potentially Generic Issue: An inspection finding that may have implications for other

licensees, certificate holders, and vendors whose facilities or activities are of the same or

similar manufacture or style.

Red Finding: A finding of high safety significance.

Self-Revealing: For the purpose of documentation in the ROP (versus enforcement), selfrevealing findings are those findings that reveal themselves to either the NRC or licensee

through a change in process, capability or functionality of equipment, operations, or

programs during routine operation. For the purposes of determining significance and

documenting in inspection reports, self-revealing findings are treated the same as

inspector-identified findings. 

Significance: The quality of being important. As used in this inspection manual chapter

(IMC), significance involves the consideration of (1) actual safety consequences;

(2) potential safety consequences, including the consideration of risk information;

(3) potential for impacting the NRC’s ability to perform its regulatory function; and (4) any

willful aspects of the violation.

Significance Determination Process (SDP): The process used to characterize the

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

Significant: Significance determined to be greater than green or a violation determined to

be greater than Severity Level IV.
0612 4 Issue Date: 01/14/04

Substantive: Involving matters of major or practical importance; considerable in amount

or numbers. In this inspection Manual Chapter, substantive information must be placed

in context relative to the inspection scope and the potential or actual safety significance.

Unresolved Item (URI): An issue about which more information is required to determine

if it is acceptable, if it is a finding, or if it constitutes a deviation or violation. Such a matter

may require additional information from the licensee or cannot be resolved without

additional guidance or clarification/interpretation of the existing guidance (e.g.,

performance indicator reporting guidance).

Violation (VIO): The failure to comply with a legally binding regulatory requirement, such

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

Weakness: (Applies to emergency preparedness) A demonstrated level of performance

(e.g., in a drill) that could have precluded effective implementation of the emergency plan

in the event of an actual emergency.

Willfulness: An attitude toward noncompliance with requirements that ranges from

careless disregard to a deliberate intent to violate or falsify.

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

Yellow Finding: A finding of substantial safety significance.

0612-04 RESPONSIBILITIES

04.01 General Responsibilities. Each inspection of a reactor facility shall be documented

in a report consisting of a cover letter, a cover page, a summary of findings or summary

of issues, and inspection details. 

04.02 Inspectors

a. All NRC power reactor inspectors are required to prepare inspection reports in

accordance with the guidance provided in this manual chapter. 

a. Inspectors have the primary responsibility for ensuring that inspection findings are

accurately reported, and that referenced material is correctly characterized. 

c. Inspectors are responsible for ensuring that the content of the inspection report

does not conflict with the information presented at the exit meeting. 

04.03 Branch Chiefs and Division Directors.

a. A manager familiar with NRC requirements in the inspected area shall review each

inspection report to ensure that the report follows the format given in this chapter.

b. The management reviewer shall ensure that inspection findings are consistent with

NRC policies and technical requirements and that enforcement-related findings are
Issue Date: 01/14/04 5 0612

addressed in accordance with the NRC Enforcement Policy and the NRC

Enforcement Manual.

b. The management reviewer shall ensure that significance determinations made in

the inspection report are in accordance with IMC 0609.

d. Regional managers shall establish internal procedures to provide a record of

inspectors' and reviewers' concurrences. The procedures should address how to

ensure continued inspector concurrence when substantive changes are made to

the report as originally submitted, and how to treat disagreements that occur during

the review process. 

e. The applicable division director or designated branch chief is responsible for the

report content, tone, overall regulatory focus, and timeliness of regional inspection

reports. 

f. The Director, Division of Reactor Projects (DRP), or the designated branch chief

is responsible for issuing integrated reports in accordance with timeliness

guidance.

04.04 Program Office. The program office is responsible for providing interpretations of

the information contained in this manual chapter, for answering questions related to the

guidance, and for providing guidance for situations not covered in this manual chapter.

0612-05 SCREENING INSPECTION RESULTS

The documentation process begins with the screening of inspection results to determine

if an inspection issue must be documented in an inspection report. Use the process

described in the following steps to screen inspection results.

05.01 Screen for Performance Deficiencies. Determine if a performance deficiency

exists. 

a. Answer the performance deficiency questions in Appendix B section 1.

b. If the answer to both of the performance deficiency questions is “No”, then the

issue is not a performance deficiency. However, if the issue is a violation, then

review the information with your immediate supervisor and the regional

enforcement coordinator to determine the appropriate action.

c. If the answer to both questions is “Yes”, then go to section 05.02 of this chapter.

05.02 Screen for Traditional Enforcement Action. Determine if a finding warrants

enforcement action using severity levels and possible civil penalties. It is expected that

only a small fraction of all identified findings will be traditional enforcement findings.

a. Answer the enforcement questions listed in Appendix B section 2.
0612 6 Issue Date: 01/14/04

b. If the answer to the enforcement questions is “Yes”, then the issue should be

addressed by traditional enforcement. Discuss the issue with management. If the

issue can be evaluated with an SDP, complete the evaluation of the finding and

coordinate with the regional enforcement coordinator for assignment of severity

level.

c. If the answer to the enforcement questions is “No”, then go to section 05.03 of this

chapter.

05.03 Screen for Minor Issues. Determine if the issue is minor. 

a. Review the list of sample minor findings listed in Appendix E.

b. If the issue is similar to the samples, then the issue is minor and should not be

documented. See exception in text box noted below.

c. If the samples in Appendix E are not appropriate, then answer the minor questions

in Appendix B section 3. Remember that a greater than minor finding must be

associated with an ROP cornerstone attribute and must affect a cornerstone

objective. In all cases, minor findings should have no actual safety consequences,

little or no potential to impact safety, no impact on the regulatory process, and no

willfulness. 

d. If the answer to all of the minor questions is “No”, then do not document the

finding. See exception in text box noted below.

e. If the answer to any of the minor questions is “Yes”, then go to section 05.04 of this

chapter.

05.04 Screen for Significance. Determine the significance of the greater than minor

finding.

a. Review the questions contained in Appendix B section 4 to determine if the issue

can be evaluated with a Significance Determination Process.

b. If the questions indicate that use of an SDP is appropriate, then go to the

appropriate section of IMC-0609, process the finding through the SDP, determine

the color of the finding, and document the finding in the appropriate section of the

report. 

EXCEPTION: A minor violation can be documented when it is necessary to

close a licensee event report or when the information related directly to an

issue of agency-wide concern (e.g., in documenting the results of a

temporary instruction.) If it is necessary to document a minor violation, then

it is done in accordance with the guidance contained in the Enforcement

Manual.
Issue Date: 01/14/04 7 0612

c. If a finding is greater than minor and warrants documentation, but cannot be

evaluated by an SDP and does not fit traditional enforcement, then submit the

finding for review by the regional branch chief to ensure that is is of very low safety

significance (green). If management review determines that the finding has the

potential to be greater than green in significance, then disposition of the issue

must be coordinated with the regional enforcement coordinator.

0612-06 WRITING INSPECTION DETAILS FOR NRC-IDENTIFIED FINDINGS AND

VIOLATIONS

After each inspection issue has been screened and the determination has been made

about what must be included in an inspection report, the details supporting each finding

must be documented. The Details section of routine and integrated NRC inspection

reports must conform to the standard format described in this section. 

In those cases where a standard format is not readily applied, the most important subject

should be identified first, followed by a discussion of major topics identified in descending

order of significance.

Exceptions to the standard format include:

• major team inspection reports, 

• augmented inspection team (AIT),

• special inspection reports, and

• other cases where the specifically directed focus of the inspection does not easily

fit into the standardized report outline. 

Additional guidance:

• Supplemental inspection results must also reflect the additional guidance provided

in Appendix C. 

• Inspection Procedure (IP) 71152, "Problem Identification and Resolution” results

must also reflect the guidance provided in Appendix D. 

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

Manual, Appendix B, “Standard Formats for Enforcement Packages.”

06.01 Inspectable Area. Identify the inspectable area in which the finding was found.

See Exhibit 1 for the list of inspectable areas. 

a. Violations of requirements that involve willfulness, actual consequences, or are

potentially the result of impeding the regulatory process, are documented in

accordance with the Enforcement Manual and are reported under the inspectable

area in which the violation was discovered. 

b. If a violation is not a performance deficiency, and does not involve willfulness,

actual consequences, or impeding the regulatory process, then it is documented

in accordance with the Enforcement Manual and is reported in Section 4OA5.
0612 8 Issue Date: 01/14/04

c. If a violation is unrelated to a specific inspectable area, then document the finding

in Section 4OA5. 

d. Individual licensee-identified findings found during drill critiques or other

evaluations that may be of some value as a potential future PI&R inspection

sample, may be listed as a cross-reference in Section 4OA2 to findings already

documented elsewhere. These findings must be greater than minor.

e. Repetitive occurrences of the same findings should be documented as an

inspector-identified PI&R finding in Section 4OA2. 

f. Document old design findings that meet IMC 0612 Appendix B documentation

screening criteria under the applicable inspectable area. 

06.02 Inspection Scope. Describe the inspection scope. Do not repeat any portion of

the Scope in the Findings section. The scope should include the following:

a. Identify how the inspection was conducted (i.e., the methods of inspection. 

Methods can include a walkdown, an in-office review, observation of test from the

control room, discussion with specific personnel, or participation in an exercise. 

b. Identify what was inspected. If more than six condition reports, procedures, or

documents were reviewed, then list the items in an attachment and reference the

attachment in the Scope section.

c. Identify the inspection objectives and the criteria to determine whether the licensee

is in compliance. 

d. If there were findings identified, state approximately when the inspection activity

was performed which identified the finding. If there are no findings, the dates of

the inspection report are sufficient.

e. If the inspection activities were conducted at a location other than the plant, (e.g.,

an in-office review), then identify where the inspection took place.

06.03 Findings. The Findings section of the report is used to document the following

three things:

• findings and violations known to be green or greater than green and minor

violations that require documentation

• enforcement actions resulting from violations

• unresolved items for which the significance has or has not been evaluated by the

SDP.

If no findings or only minor findings that do not require documentation were identified within

an inspectable area, then state “No findings of significance were identified” in the Findings

section of the report.
Issue Date: 01/14/04 9 0612

If there are findings other than minor findings, present the findings within each report

section in order of importance. Provide an introduction, a description, an analysis, and a

discussion of the enforcement related to each of the findings.

 

a. Introduction. Begin with one or two sentences that provide the overall “bottom

line” results of the inspection in the area. This section does not need to stand

alone because the description that follows will provide the supporting details.

The introduction must include a brief summary of the risk characterization (i.e.,

color or significance) and/or applicable enforcement or severity level.

b. Description. Describe the finding. The level of detail in the description should

reflect the actual or potential safety consequence associated with a finding.

Potentially significant findings merit more discussion. Uncomplicated green

findings should be succinctly described in less than one page. Complex green

findings should be described in not more than two pages. More significant findings

may need more documentation because of their complexity and significance.

If a finding is likely to have generic concerns, then include details such as the

manufacturer’s name and model number for components, specifications, and other

names and technical data that identify the item of concern.

c. Analysis. Describe the logic used to determine the significance (color) of the

finding. However, do not provide every detail of the basis for each assumption.

The level of detail must allow a knowledgeable reader to reconstruct the decision

logic used to arrive at the final conclusion. Describe why the finding is, or is not,

important. Include a description of any positive licensee performance that

mitigated a potential problem and influenced the significance of the finding.

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

(1) Risk-Informed SDP Results - ( Results from IMC 0609 Appendices A, F, G

and H)

(a) If SDP phase one screening assesses the finding as very low

significance (green), the analysis should identify: 

• the affected cornerstone, 

• the set of conditions which make the finding greater than minor

(e.g., the associated cornerstone attribute and how the objective

was affected), 

• the assumptions used in the determination, and 

• the phase 1 question which was satisfied that caused the finding

to be assessed as green (e.g., “The loss of function did not

exceed the allowed out of service time”). 

(b) If the SDP phase one screening results in phase 2 or 3 evaluation, the

analysis should identify: 

• the affected cornerstone(s), 

• the set of conditions which make the finding greater than minor,
0612 10 Issue Date: 01/14/04

• the assumptions used in the determination, 

• the phase 1 criteria which was satisfied that caused the finding

to be assessed as green or above, and 

• the most dominant core damage sequences, including the

remaining mitigation capability that limited the significance. 

(c) For findings that are greater than green, the analysis should use the

risk characterization as determined by the Significance Determination

Enforcement Review Panel (SERP) as its basis and should identify:

• the exposure time

• recovery credit, and 

• all sequences greater than green.

(d) If multiple independent and concurrent findings have added

significance on the basis of risk, then that perspective should be

explained. For example, if two components with separate but

concurrent reliability problems are related by a dominant core damage

event sequence, the treatment of the SDP for each finding in

accordance with IMC 0609 guidance should be explained.

(2) Non-Risk-Informed SDP Results - Results from IMC 0609 Appendices B, C,

D, E, and I

The analysis should identify: 

• the affected cornerstone,

• the set of conditions which make the finding greater than minor (e.g.,

the associated cornerstone attribute and how the objective was

affected), 

• the SDP used in the determination, 

• any assumptions used in the determination,

• the table or flowchart used, and 

• a description of the path on the flow chart used to arrive at the

conclusion. 

(3) Non-SDP Findings. If a finding is greater than minor and not suited for SDP

analysis, and a regional management review has determined that it is green,

then the analysis section must describe the basis for the green significance.

The analysis section should identify: 

• the conditions which make the finding greater than minor and

• the set of conditions which would have been needed to make the

finding greater than very low safety significance, or an explanation of

why the finding is not greater than very low significance. 

EXAMPLE: “Using the Public Radiation Safety SDP, the finding

involved radiation material control but transportation was not involved. 

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

more than 5 occurrences. Therefore, the finding is green.”
Issue Date: 01/14/04 11 0612

If management review has determined that the finding is potentially greater

than green, then the finding must be reviewed further and regional

enforcement coordinator should be informed. The analysis section should be

used to document the circumstances that require further evaluation. 

(4) Findings Related to Cross-Cutting Areas. The cross-cutting aspect of a

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

documented as a contributing cause of the finding, as appropriate. If a

finding is evaluated as being more than minor and if the cause of the finding

is related to Problem Identification and Resolution, Human Performance, or

Establishment of a Safety-conscious Work Environment, then describe the

cross-cutting aspect of the finding in the analysis paragraph. Specifically

state the relationship between the cross-cutting area and the cause or subcauses of the finding. 

Findings with cross cutting aspects must also be briefly referenced in Section

4OA2.

d. Enforcement. Findings found or reviewed during inspections that also include

potential violations of regulatory requirements are documented in accordance with

the NRC Enforcement Policy (NUREG-1600) and in Section 3.12 of the NRC

Enforcement Manual. The enforcement discussion and subsequent enforcement

action must be consistent with the significance determination. 

Do not speculate or reach conclusions about the intent behind a violation.

Conclusions about the willfulness of a violation are agency decisions, and are

normally not made until after the Office of Investigations (OI) has completed an

investigation. A premature or inaccurate discussion of the willfulness of an

apparent violation in the inspection report could result in later conflicts based on

additional input and review. Inspection reports that include potentially willful

violations must be coordinated with OI and the Office of Enforcement (OE).

(1) If there is no violation associated with a finding, the enforcement section of

the report should include the following statement: “No violation of regulatory

requirements occurred. “

(2) If a finding involves a violation, but the finding is not suitable for evaluation

using the SDP, and management review has confirmed a very low safety

significance, then the enforcement section should include the following

statement: “The finding is not suitable for SDP evaluation, but has been

reviewed by NRC management and is determined to be a green finding of

very low safety significance.” 

If the management review has determined that additional evaluation is

needed to identify the safety significance, then the enforcement section of

the report should state: “The finding is not suitable for SDP evaluation, but

is being reviewed by NRC management and coordinated with the Office of

Enforcement to identify the significance and appropriate disposition.”
0612 12 Issue Date: 01/14/04

(3) If a finding is potentially greater than green, the enforcement section must

clearly state that the finding does not present an immediate safety concern.

(4) If a violation is associated with a finding of was very low safety significance

(green) and meets the criteria in Section VI.A.1 of the Enforcement Policy

(i.e., 1) identified by the NRC, 2) the information was subsequently

incorporated into the licensee’s corrective action program, and 3) did not

involve willfulness), and guidance in Section 4.2.1 in the Enforcement

Manual, then the violation may be dispositioned as a Non-Cited Violation

(NCV). Document it in accordance with the guidance given in Sections 3.12.2

and 4.3.2 of the Enforcement Manual. 

(5) If a violation is categorized at Severity Level IV and meets the criteria in

Section VI.A.1 of the Enforcement Policy, and guidance in Section 4.2.1 in

the Enforcement Manual, then the violation may be dispositioned as a NonCited Violation (NCV). Document it in accordance with the guidance given in

Sections 3.12.2 and 4.3.2 of the Enforcement Manual. 

(6) Issue a Notice of Violation (NOV) if a Severity Level IV violation or violation

associated with a green finding meets any one of the applicable criteria in

Section VI.A.1 of the Enforcement Policy. 

(7) The enforcement section for any described violation, including minor

violations that warrant documentation must include sufficient information to

support the conclusion that the finding is more than minor and is a violation

of regulatory requirements. At a minimum the enforcement section should

state:

• what requirement was violated

• how the violation occurred

• when the violation occurred and how long it existed

• when the violation was identified

• any actual or potential safety consequence

• the root cause or apparent root cause at the time of report writing (if

identified)

• all information required to complete the SDP (this requirement does not

apply to minor violations that warrant documentation)

• what corrective actions have been taken or planned (For licensees with

adequate corrective action programs, it is acceptable to only verify that

the licensee has entered the finding in its corrective action program for

findings that are of very low safety significance (green)

(8) Apparent violations that are associated with findings that are either (1)

preliminarily determined to have more than very low safety significance (i.e.,

white, yellow, or red), or (2) greater than Severity Level IV in Traditional

Enforcement, should also include the following in the enforcement section

if available at the time of documentation:

• The significance attributed to the finding by the licensee. If the

significance is different than that determined by the NRC, then

describe the assumptions used by the licensee, and identify what the
Issue Date: 01/14/04 13 0612

licensee considered applicable to its determination that the NRC did

not.

• The licensee’s position on the NRC’s determination that a requirement

has been violated.

• If appropriate, the section should also identify the licensee

compensatory measures that are in place while the licensee’s

implementing its long-term corrective measures. 

(9) If a finding is initially categorized as having a potential safety significance of

greater than very low safety significance (green) but the significance has not

yet been determined, then the significance of the finding is reported as “To

Be Determined (TBD).” If a violation, including violations involving Traditional

Enforcement, appears to be associated with the finding, it should be

documented as an “apparent violation.” Emphasize that the safety

characterization is preliminary and not yet finalized. 

CAUTION:

• Do not make direct statements regarding safety significance in the

inspection report when the agency has not yet reached a conclusion.

Conclusions about the significance of findings that are greater then

green and associated violations are agency decisions and are normally

not made when the report is issued. A premature or inaccurate

discussion of the finding and an apparent violation in the inspection

report could become inaccurate as a result of subsequent input and

review.

06.04 Tracking. All findings, violations, non-cited violations, apparent violations, and

unresolved items must be assigned a sequential tracking number. See IMC 0306,

“Information Technology Support for the Reactor Oversight Process,” for guidance.

a. When an inspection involves multiple violations (or multiple examples of a single

violation), there must be a one-to-one correlation between the number of item

entries in the Reactor Program System (RPS) and the number of "contrary to"

statements in the accompanying notice of violation. 

b. The close-out description of a violation should be brief if the licensee's response

to the notice of violation already has given an accurate description of the root

cause, corrective actions taken, and other aspects of the condition causing the

violation, and the inspector identifies no other instances of the violation. 

c. NCVs will normally be opened and closed in the initiating inspection report. 

d. Enforcement Action (EA) numbers are assigned to SDP issues that are addressed

in SDP/enforcement panels, whether or not the case results in enforcement action.

EA numbers are assigned to potential escalated enforcement actions. EA

numbers are also assigned to other specific cases as addressed in Section 3.10.1

of the Enforcement Manual.
0612 14 Issue Date: 01/14/04

0612-07 DOCUMENTING PERFORMANCE INDICATOR VERIFICATION RESULTS

07.01 Scope. When writing the scope section, include the time period in which the PIs

were verified. Data reported prior to January 2000 is considered historical and should not

be reviewed unless necessary to verify the PI value. Include the criteria used to verify the

PIs. List the PIs verified and the associated cornerstones. When three or more PIs are

being verified and there are findings to report, list the scope and findings separately.

07.02 Findings. When writing the findings section, include only those occurrences that

could potentially cause a PI to cross a threshold. Document findings that could potentially

cause a PI to cross a threshold as an unresolved item (i.e., “The resolution of this item is

pending a response from Headquarters.”) An item number must be identified for tracking.

Document issues related to inaccurate reporting of PI data. Briefly describe the

circumstances surrounding the finding in the write-up. If the case involves an interpretation

of the reporting guidance, the region should submit a feedback form capturing their

concerns and perspectives to the NRR Inspection Program Branch, (IIPB). Upon

resolution of all interpretation issues and frequently asked questions (FAQs), the issue

should be closed out in accordance with the closure guidance described in IMC 0608,

"Performance Indicator Program.”

Inaccurate and incomplete PI data violations should be dispositioned in accordance with

the guidance in Supplement VII of the Enforcement Policy and Section 7.8 of the

Enforcement Manual.

Due to difficulties encountered with the SSU PI, T/2 fault exposure hours in which the time

of failure is not known have been excluded from the indicator calculation. The licensee

should document fault exposure hours accumulated in the comment field of the PI

Performance Summaries displayed for the individual facilities at the following web

address: http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/index.html in accordance with

NEI 99-02. Further information on verifying the accuracy of this PI in the area of T/2 fault

exposure hours is contained in IP 71151, Section 3.01.

0612-08 DOCUMENTING UNRESOLVED ITEMS 

08.01 Tracking. Unresolved items are identified for tracking in accordance with the

guidance in IMC 0306. The action of documenting an unresolved item is a commitment

of future resources, and should only be used when some specific licensee action is

pending, or when needed information is not available at the time of the inspection. 

A potential noncompliance should not be identified as unresolved if it likely results in a

minor issue. If additional information may reveal the finding to be a matter of

noncompliance, initiate an unresolved item. For an unresolved item, the report must

identify the actions or additional inspection effort needed to resolve the issue.

08.02 Follow-up and Closure. The level of detail devoted to closing unresolved items

depends on the nature and significance of the additional information identified. The

closure of an unresolved item must summarize the topic, summarize the inspector's follow-
Issue Date: 01/14/04 15 0612

up actions, evaluate the adequacy of any licensee actions, determine if a violation has

occurred, and provide enough detail to justify closing the item. If multiple unresolved items

exist, a summary of the items may be included at the end of the report.

0612-09 DOCUMENTING LERs AND LICENSEE-IDENTIFIED DEFICIENCIES 

NRC policy requires that all instances of noncompliance that are documented, be

dispositioned in accordance with the Enforcement Policy, regardless of who identified

them. However, licensee-identified deficiencies which are of very low significance and

incorporated into the licensee corrective action program should have minimal

documentation. See Section 0612-03 for definitions of licensee-identified deficiency and

self-revealing deficiency.

09.01 Events and Licensee Event Reports (LER). All LERs must be at least screened

by an inspector and closed in an inspection report. LERs are initially screened using an inoffice review and can be closed based upon the inspector’s engineering judgment.

However, nothing in this section precludes the NRC from initiating a greater-the-green

finding for issues identified in LERs, regardless of who identified the issue, and

independent of whether the LER has been reviewed and closed in an inspection report.

Follow-up inspection may be conducted at a facility whenever an LER involves complex

events, is immediately recognized as greater than very low safety significance, causes a

performance indicator to exceed a threshold, or as directed by IMC 2515, “Light-Water

Reactor Inspection Program,” IP 71153, “Event Follow-up”, and IP 71111.14, “Personnel

Performance During Non-Routine Plant Evolutions.” 

Document Events and LERs, including revisions to LERs, in the inspection report under

Section 4OA3, “Event Follow-up.” If inspection in another cornerstone area provides a

description of an event, or an event for which an LER is issued (i.e., personnel

performance during non-routine evolutions), then that section of the report should be

referenced under Section 4OA3 with a very brief description. 

In general, LER reviews should have a brief event description, reference the docketed

LER, and require little discussion other than the significance evaluation and reference to

the licensee’s corrective action program (CAP) system tracking number for the finding.

a. LERs without violations. If no violation occurred then include a statement “This

event did not constitute a violation of NRC requirements." as the last statement

of the section. 

(1) LERs without Findings. State that the LER was reviewed and that no findings

were identified. 

(2) LERs with Minor Findings. When closing LERs involving minor findings,

state that the LER was reviewed and no findings of significance were

identified, and note that the finding is captured in the licensee’s corrective

action program. If an LER review is already documented in a separate NRC

correspondence, then close with a brief statement in an inspection report.
0612 16 Issue Date: 01/14/04

(3) LERs with Greater than Minor Findings. If an LER involves more than a

minor finding, including green findings (very low safety significance) which

the licensee identified and entered into their corrective action program, then

treat the finding as an NRC identified finding and include the following in the

inspection report:

• safety significance of the event

• the corrective actions (referencing the licensee’s CAP tracking number)

• the licensee’s determination of the apparent cause

• a summary of the inspection follow-up actions

• any required enforcement actions. 

If any other inspection was conducted which provided information regarding

this event, the inspection report number should be referenced.

b. LERs with Violations. An LER may describe an issue that appears to be a

violation, but does not clearly state that a violation of requirements existed. If the

issue readily appears to be of no more than very low safety significance, then,

based on the NRC regulations and the content of the LER, determine if a

noncompliance occurred. This determination should be made without gathering

additional details

(1) LERs with Minor Violations. If the issue is a minor violation, then do not

document the violation but close the LER with a brief statement.

(2) LERs with Greater than Minor Violations. If the LER states that a violation

occurred, or if it is obvious that a violation is involved (e.g., “failure to follow

procedures,” in the title or body of the LER), then the violation must be

identified clearly in the report as a cited violation or non-cited violation as

appropriate, or warranting enforcement discretion if no performance

deficiency occurred. Violations should be documented in accordance with

the enforcement guidance and should include the licensee’s corrective action

program tracking number. 

09.02 Licensee-Identified Deficiency.

a. If a licensee-identified deficiency is a violation, is of very low safety significance,

and the licensee has correctly evaluated the finding and has developed

appropriate corrective actions, then briefly describe the violation in Section O4A7.

Include the list of requirement(s) violated, describe how it was violated, identify the

licensee’s corrective action tracking number(s), and provide a very brief justification

why the violation is not greater than green. A complete reconstruction of the SDP

logic is not required. However, Section 4OA7 must include the following

introductory paragraph: 

“The following violations of very low safety significance (green) were

identified by the licensee and are violations of NRC requirements which meet

the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for

being dispositioned as a Non-Cited Violation.”
Issue Date: 01/14/04 17 0612

b. If a licensee-identified deficiency is a violation, and if the finding appears to be of

greater significance than the licensee’s characterization, or if it has more than a

very low significance, then the deficiency must be analyzed using the SDP, treated

as an NRC-identified finding, and documented and dispositioned in accordance

with the guidance in the Enforcement Policy and Enforcement Manual. 

c. If a problem exists with the licensee’s evaluation or corrective actions associated

with the licensee-identified finding and if further documentation can add value,

then discuss the finding under the applicable cornerstone section of the report,

regardless of who identified it. Documentation should clearly emphasize that the

licensee-identified the finding but failed to recognize the deficiency or its

relationship to the problem identified by the inspector. If the additional information

provided by the inspector is associated with PI&R, then reference the cornerstone

under Section 4OA2.

0612-10 OTHER GUIDANCE 

10.01 Treatment of Third Party Reviews. Detailed NRC reviews of Institute of Nuclear

Power Operations (INPO) evaluations, accreditation reports, findings, recommendations,

and corrective actions, or other third party reviews with similar information are not

referenced in NRC inspection reports, tracking tools, or other agency documents unless

the issue is of such safety significance that no other reasonable alternative is acceptable.

INPO findings, recommendations and associated licensee corrective actions are not

normally tracked by the NRC. If a finding warrants tracking, it should be independently

evaluated, documented, and tracked as an NRC finding under 4OA5. 

Include a short statement in the inspection report to document that a review of a specified

INPO evaluation or accreditation report was completed. Do not include a recounting or

listing of INPO findings or reference a final INPO rating when documenting an INPO

evaluation or accreditation report review. Discuss the specifics of any significant

differences between NRC and INPO perceptions with regional management.

0612-11 COMPILING AN INSPECTION REPORT

11.01 Report Organization. Arrange the Report Details in accordance with the standard

report outline shown in Exhibit 1. Each outline topic does not have to be covered in each

report. When an inspection is performed in a particular area, the resulting details are

placed in the corresponding section of the report.

11.02 Plant Status. If appropriate, write a Summary of Plant Status section. If used,

briefly describe pertinent operational events, such as any plant shutdowns or significant

changes in power. This summary is not needed for specialist inspections since plant

operating status may not be relevant to a safeguards or emergency preparedness

inspection. 
0612 18 Issue Date: 01/14/04

11.03 Summary of Findings. The summary should be an informative but concise

overview of the significant inspection findings contained in the details of the report. It will

also be used for entries to the Agencywide Documents Access and Management System

(ADAMS) and the RPS Plant Issues Matrix (PIM). 

a. ADAMS Template. The first paragraph of the summary of findings is used as a

report summary in the title value field of ADAMS template NRC-002. This

information must be a concise, single paragraph because the field in the ADAMS

template is limited to 256 characters. 

The paragraph must include the following, in order: 

• the inspection report number (See Exhibit 3 for format)

• the dates of the inspection

• the name of the site

• the titles of only the inspection procedures or attachments in which findings

were identified (e.g, equipment alignment, fire protection, operability

evaluations). 

If no findings were identified, the general inspection area should be listed (e.g,

radiation specialist report, or resident inspector report, or environmental report).

For non-routine inspections, the same format should be followed to identify the

report number, and unit names, and dates of inspection. These are followed by

the title of the inspection and a list of findings. (See Appendix D for examples.)

b. Summary Paragraph. The summary paragraph follows the ADAMS template

paragraph and describes who conducted the inspection (i.e., resident or specialist

inspectors), the number of findings and violations. 

The summary also includes an explanation that the significance of most findings

is indicated by their color (greater then green, or green, white, yellow, red); that the

significance was determined using IMC 0609, “Significance Determination

Process” (SDP); and that findings for which the SDP does not apply may be

“green” or be assigned a severity level after NRC management review. This

explanation is not included if no findings were identified.

c. List of findings. Compile a list of findings by reviewing the details developed for

each report section. Write a summary for each issue that is designated a finding

(FIN), violation (VIO), apparent violation (AV), or non-cited violation (NCV).

Highlight the cross cutting aspects of a finding, as appropriate. 

Do not document the following in the summary of findings: licensee-identified

deficiencies resulting in NCVs, green findings associated with LERs, and inspector

identified unresolved items that could result in an acceptable conclusion. 

(1) Begin the summary for each finding with the significance color. Use TBD for

those findings where the significance and/or severity level has not yet been

determined and for findings with a preliminary color greater than green.

Then, describe the finding, briefly describe any enforcement action, and
Issue Date: 01/14/04 19 0612

either cite violations of specific requirements, where applicable, or describe

the results of the safety evaluation of the finding. Include a brief description

of the corrective actions completed or planned by the licensee.

If the finding was not analyzed by the SDP, the second paragraph should

describe why the finding is considered to have significance. The text of the

summaries must be consistent with the corresponding details in the

inspection report. Each summary must end with a reference to the section

of the report in which the finding is discussed.

(2) Group the findings summaries by cornerstones in the order specified in

Exhibit 1. 

(3) If a licensee-identified deficiency resulted in a violation include the following

boilerplate paragraph as the last paragraph of the summary of findings:

“Violations of very low safety significance, which were

identified by the licensee have been reviewed by the

inspectors. Corrective actions taken or planned by the

licensee have been entered into the licensee’s corrective

action program. These violations and corrective action

tracking numbers are listed in Section 4OA7 of this

report.”

11.04 Cover Page. Compile the cover page. The report cover page gives a succinct

summary of information about the inspection. It contains: the docket number(s), license

number(s), report number, licensee name, facility name, facility address, dates of the

inspection, names and titles of participating inspectors, and name and title of the approving

NRC manager. See Exhibit 3 for format.

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

0306:

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

(e.g., 05000410/2003001) 

11.05 Table of Contents. If a report is considered complicated or of significant length,

then develop a table of contents. If the Report Details section to the exit interview section

is more than 20 pages long, a table of contents should be included.

11.06 Exit Meeting Summary. Write a brief summary of the exit meeting. This information

will also be described in the first paragraph of the cover letter. The summary must identify

the most senior licensee manager who attended the meeting and must include the

following information:

a. Absence of Proprietary Information. At the exit meeting, the inspectors verified

whether the licensee considers any materials provided to or reviewed by the

inspectors to be proprietary. If the licensee did not identify any material as

proprietary, include a sentence to that effect the exit meeting summary . See IMC

0611 on actions to take if the report includes proprietary material.
0612 20 Issue Date: 01/14/04

NOTE: When an inspection is likely to involve proprietary information (i.e., given

the technical area or other considerations of inspection scope), handling of

proprietary information should be discussed at the entrance meeting.

b. Subsequent Contacts or Changes in NRC Position. Briefly discuss any contact

with the licensee management after the exit meeting to discuss new information

relevant to an inspection finding. In addition, if the NRC's position on an inspection

finding changes after the exit meeting, discuss that change with the licensee

before the report is issued.

CAUTIONS:

• Characterization of Licensee Response. Do not characterize a licensee’s

exit meeting response. If the licensee disagrees with an inspection finding,

this position may be characterized by the licensee in their formal response

to the inspection report, if applicable. 

• Oral Statements and Regulatory Commitments. Do not attempt to

characterize or interpret any oral statements the licensee makes, at the exit

meeting or at any other time during the inspection, as a commitment. 

Licensee commitments are documented by licensee correspondence, after

which they may be referenced in the inspection report. Oral statements made

or endorsed by a member of licensee management authorized to make

commitments are not regulatory commitments unless they are documented

as such by the licensee. For further guidance on licensee commitments, see

ADAMS Accession Nos. ML003680088 (NEI 99-04), ML003680078 (NEI

Cover Letter), and ML003679799 (SECY 00-045 endorsing NEI 99-04

guidance).

Because regulatory commitments are a sensitive area, ensure that any

reporting of licensee statements are paraphrased accurately, and contain

appropriate reference to the licensee’s document.

11.07 Report Attachments. The attachments discussed below are included at the end

of the inspection report if applicable to the inspection. The attachments may be combined

into a single attachment entitled "Supplementary Information."

a. Key Points of Contact. List, by name and title, those individuals who furnished

relevant information or were key points of contact during the inspection (except in

cases where there is a need to protect the identity of an individual). The list

should not be exhaustive but should identify those individuals who provided

information related to developing and understanding findings. The alphabetized

list includes the most senior licensee manager present at the exit meeting and

NRC technical personnel who were involved in the inspection if they are not listed

as inspectors on the cover page.

b. List of Items Opened, Closed, and Discussed (Optional). The report may include

a quick-reference list of items opened and closed, including the item type, the

tracking number for the item, and a brief phrase matching the title used in PIM

headers describing the item. Open items that were discussed (but not closed)
Issue Date: 01/14/04 21 0612

should also be included in this list, along with a reference to the sections in the

report in which the items are discussed. 

c. List of Documents Reviewed. A list of the documents and records reviewed during

an inspection must be publicly available. Therefore, include a listing of all the

documents and records reviewed during the inspection that are not identified in the

body of the report. (See IMC 0620, "Inspection Documents and Records”.)

"Reviewed" in this context means to examine critically or deliberately. The list does

not include records that were only superficially reviewed. Lists consisting of more

than six condition reports, documents reviewed or procedures, etc., should be

removed from the body of the report and included as an attachment.

d. List of Acronyms. Include a list of acronyms for any report whose Details section

exceeds 20 pages. For reports in which a relatively small number of acronyms

have been used, the list is optional. In all cases, however, acronyms should be

spelled out when first used in inspection report text.

11.08 Cover Letter. Write a cover letter to transmit the overall inspection results and

convey the inspection findings to the licensee. Inspection reports are sent from the

applicable NRC official (branch chief, division director, or regional administrator) to the

designated licensee executive. See the inspection report documentation matrix in Exhibit

2 for what should and should not be documented in the inspection report cover letter. A

sample inspection report cover letter can be found in Exhibit 4.

Guidance and cover letter formats for transmitting enforcement actions vary. Guidance

and sample cover letters for enforcement-related correspondence are found in the

Enforcement Manual, Appendix B, “Standard Formats for Enforcement Packages.” 

Cover letter content varies somewhat depending on whether the inspection identified

findings. In general, however, every cover letter has the same basic structure, as follows:

a. Date. The NRC seal and address is at the top of the first page and is followed by

the date on which the report cover letter is signed and the report issued.

b. Enforcement Action. If the report contains findings assigned an enforcement

action (EA) number, then the EA number should be placed in the upper left-hand

corner above the principal addressee’s name.

c. Addressee. The name and title of the principal addressee are placed at least four

lines below the letterhead, followed by the licensees name and address.

d. Subject Line. The subject line of the letter should state the plant name and

inspection subject (e.g.,”XXXXX Generating Station- NRC Integrated Inspection

Report”) followed by the report number. The information presented in the subject

line must be in the following sequence: plant name, type of inspection, report

number. Use the official plant name and docket number as described in Section

11.04.
0612 22 Issue Date: 01/14/04

The words "NOTICE OF VIOLATION" (“EXERCISE OF ENFORCEMENT

DISCRETION” or "NOTICE OF DEVIATION," etc.) must be included if an

enforcement action accompanies the inspection report. 

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

f. Introductory Paragraphs. The first two paragraphs of the cover letter should give

a brief introduction, including the type of report (i.e., license renewal report,

integrated inspection report, etc.).

g. Body. The body of the letter should discuss the most important topics first. The

following identifies how different types of findings should be reflected in the cover

letter to an inspection report. 

IF: THEN:

If there are no

findings identified

Insert a separate paragraph stating: 

"On the basis of the results of this inspection, no

findings of significance were identified."

If green findings are

identified

State the number but do not elaborate. Include the

following statement:

“There were [the number] findings of very low safety

significance (green) identified in the report."

If Severity Level IV

violations or violations

associated with green

findings are being

dispositioned as

NCVs or in NOVs

Document in accordance with the guidance in

Appendix B, Form 2 of the Enforcement Manual

If a finding has the

potential to be greater

than green in

significance

The cover letter should clearly state why the finding

does not present an immediate safety concern, and (if

appropriate) that licensee compensatory measures are

in place while licensee long-term corrective measures

are being implemented.

If a finding appears to

be greater than green

and if an apparent

violation is involved

for which a Notice of

Violation is being

considered

Briefly discuss in the order of significance if more than

one finding. The appropriate wording for the findings

that are also violations of requirements can be found in

the Enforcement Manual. 

If a violation appears

to be greater than

Severity Level IV

Discuss in accordance with the guidance in the

Enforcement Manual. 
IF: THEN:

Issue Date: 01/14/04 23 0612

If their are crosscutting elements

related to findings of

white or greater

significance

Briefly mention in the cover letter within the discussion

of the cause of the finding

If a violation was

identified but was not

associated with a

performance

deficiency

Insert the following paragraph: 

“Although this issue constitutes a violation of NRC

requirements, we have concluded that (insert name of

licensee)’s actions did not contribute to the degraded

condition and, thus, no performance deficiency was

identified. Based on these facts, I have been

authorized, after consultation with the, Director, Office

of Enforcement, to exercise enforcement discretion in

accordance with Section VII.B.6 of the Enforcement

Policy and refrain from issuing enforcement action for

the violation. An evaluation was performed and we

have determined that this was an issue of very low

safety significance (or, alternatively, definition for the

corresponding color). (State here if any other known

agency action has been or will be taken, e.g., forward

to a technical branch, evaluation by the Generic Safety

Issue program, consideration of generic

communication, Task Interface Agreement, etc.)"

h. Closing. The final paragraph consists of standard legal language that varies

depending on whether enforcement action is involved. See the example cover

letter in Exhibit 4.

The signature of the appropriate NRC official is followed by the docket number(s),

license number(s), enclosures, and distribution list.

0612-12 ISSUING INSPECTION REPORTS

12.01 Report Timeliness

a. Inspection reports should be issued no later than 45 calendar days after inspection |

completion (30 calendar days for reactive inspections). |

NOTE: For inspections not conducted by a resident

inspector, inspection completion is normally

defined as the day of the exit meeting. For

resident inspector and integrated inspection
0612 24 Issue Date: 01/14/04

reports, inspection completion is normally defined

as the last day covered by the inspection report.

b. Timeliness goals should be accelerated for inspection reports covering potential

escalated enforcement actions.

c. Whenever an inspection reveals findings of significance (i.e., white or higher) or

other significant or immediate public health and safety concern, an expedited

inspection report that is limited in scope to the specific findings should be

considered. 

12.02 Release and Disclosure of Inspection Reports

a. General Public Disclosure and Exemptions. Except for report enclosures

containing exempt information, all final inspection reports will be disclosed routinely

to the public. IMC 0611, "Review and Distribution of Inspection Reports,"

describes the various types of exempt information. IMC 0620, "Inspection

Documents and Records," gives guidance on acquiring and controlling NRC

records, including inspection-related documents. Safeguards information or related

sensitive information should not be released per current agency policy. Any

questions regarding this policy should be referred to the program office.

b. Release of Investigation-Related Information. When an inspector accompanies

an investigator on an investigation, the inspector must not release either the

investigation report or his or her individual input to the investigation report. This

information is exempt from disclosure by 10 CFR 9.5, and must not be circulated

outside the NRC without specific approval of the Chairman (refer to OI Policy

Statement 23).

END

EXHIBITS:

Exhibit 1: Standard Reactor Inspection Report Outline

Exhibit 2: Inspection Report Documentation Matrix

Exhibit 3: Sample Reactor Inspection Report

Exhibit 4: Sample Cover Letters

APPENDICES:

Appendix A: List of Acronyms Used in IMC 0612

Appendix B: Issue Screening

Appendix C: Documentation Guidance for Supplemental Inspections

Appendix D: Guidance For Documenting Inspection Procedure 71152

 “Identification and Resolution of Problems”

Appendix E: Examples of Minor Issues