The NRC’s Office of Enforcement (OE) recently issued an enforcement guidance memorandum (EGM) to reinforce the NRC’s Enforcement Policy (Policy) and earlier guidance on identifying and documenting findings and associated violations in inspection reports. The need for this EGM arose after OE became “aware that some inspection staff may be misinterpreting and misapplying” the Policy and guidance by documenting all issues of concern, regardless of significance.
The EGM rejects that inspection staff misinterpretation and makes it clear that the inspection program is not meant to document all findings (and associated violations). Instead, inspection findings and associated violations are to be identified and documented as specified in the Inspection Manual, which follows the Policy and earlier OE guidance. OE reinforcement of this violation documentation policy provides licensees with a basis for challenging inspector inclusion of low-level, non-safety-significant findings or violations in an inspection report.