PROCEDURES ISSUE 9, REVISION 3

COMMITTEE ON NUCLEAR CERTIFICATION

Approved by the Board on Conformity Assessment on February 1, 2011

The American Society of Mechanical Engineers Three Park Avenue New York, NY 10016

PREFACE

These procedures define the scope, responsibilities, organization, and duties of the Committee on Nuclear Certification (CNC). The Committee operates within the Constitution, Bylaws, and Rules of ASME and within the procedures of the Board on Conformity Assessment (BCA). These procedures provide guidelines for the Committee activities, establish policies and procedures, and define the duties of CNC Task Groups and method of their appointments. The interfaces of activities between the Committee, BCA, BPV Committee on Construction of Nuclear Facility Components (Section III), ASME Conformity Assessment staff (ASME staff), Survey Teams, and ASME are also described.

CONTENTS

1 2 3 4 5 6 7 8 9 10 11 12 13 14 Tables 1 2 3

Scope ............................................................................................................................................ 1 Responsibilities ............................................................................................................................ 2 Organization ................................................................................................................................. 3 Duties ........................................................................................................................................... 7 Meetings ....................................................................................................................................... 8 Task Groups ................................................................................................................................. 9 Committee Actions .................................................................................................................... 10 Ballots......................................................................................................................................... 20 Code Interpretations................................................................................................................... 22 Surveys, Audits, Investigations and Interviews........................................................................ 23 Procedural Due Process ............................................................................................................. 24 Public Information ..................................................................................................................... 28 Parliamentary Procedures .......................................................................................................... 29 Revisions .................................................................................................................................... 30

N-Type Nuclear Survey or Audit Team Membership.............................................................. 31 Owner - Interview Team Membership...................................................................................... 31 Material Organization - Nuclear Survey or Audit Team ......................................................... 32

SCOPE The Committee on Nuclear Certification (CNC) is constituted for the purpose of reviewing, and implementing the ASME Nuclear Certification activities established by the BCA and ASME BPV Committee on Construction of Nuclear Facility Components (Section III). These activities are administered and coordinated by the ASME Conformity Assessment staff.

CNC Procedures February 1, 2011 Page 1

2 2.1 2.2

RESPONSIBILITIES The Committee is responsible to the ASME BCA. The Committee is responsible for the issuance, renewal, extension, amendment, withholding, suspension, reinstatement and withdrawal of ASME Nuclear Certificates. The actions are taken on the basis of the Committee's review of Team Reports of each Applicant's Quality Program and its implementation. The Committee is responsible for reviewing and evaluating all apparent Code deficiencies, nonconformances, and alleged violations reported to ASME in connection with the Certificates relating to ASME Nuclear Certification activities and for assuring the resolution of such deficiencies, nonconformances, or alleged Code violations in accordance with these procedures.

2.3

CNC Procedures February 1, 2011 Page 2

3 3.1

ORGANIZATION The Committee shall consist of not less than nine nor more than eighteen voting members. The Chair and Vice Chair of the Committee shall be considered within this membership. The Secretary and Senior Consultant serve without vote and are not included in the count of voting members. Membership on the Committee shall preferably be limited to persons with experience as a member of one or more of the BPV Committee on Construction of Nuclear Facility Components (Section III) or its Subcommittees. Committee members should be encouraged to join ASME if not members when nominated, although ASME membership is not a condition for selection. Voting members, except those representing the Jurisdiction segment of the Enforcement/Regulatory category shall be recommended by the Committee to the BCA for appointment (or reappointment) to a five year term. Voting members from the Jurisdiction segment of the Enforcement/Regulatory category, recommended to CNC by the Conference Committee, shall be recommended by the CNC to the BCA for appointment to serve terms as recommended by the Conference Committee, not to exceed five years. Reappointments need not be submitted to BCA for approval after CNC approval. A reappointment that results in a continued state of imbalance of the CNC membership shall be brought to the attention of BCA for approval.

3.2

3.3

3.4 3.4.1 3.4.2

OFFICERS The officers of the Committee shall consist of a Chair, Vice Chair, and Secretary. The Chair and Vice Chair shall be appointed by the BCA for terms of five years. Such appointment shall initiate a coincident five year term of appointment as a member of the Committee. Nominations to the offices of Chair and Vice Chair by members of the Committee shall be by secret weighted ballot. (a) Before expiration of the terms of the Chair and Vice Chair, the Secretary shall contact all members to determine whether they are willing to serve as a Committee officer, if elected. The Secretary shall then send out to the Committee members a list of all members who have indicated their willingness to serve, with a request that each member mark, in order, their preference for Chair by the numerals 3, 2, and 1, each representing a numerical value which is used to

3.4.3

CNC Procedures February 1, 2011 Page 3

compute the highest number of votes for first choice. Ten days will be allowed for reply. (b) Two names receiving the weighted highest number of votes for first choice or three names if there is a tie for second, shall be the nominees. The Secretary shall then submit the names of the nominees on a ballot to all members, for voting within ten days, and the member receiving the majority (or plurality if there is a tie for second) of votes cast shall be nominated for Chair. (c) Following the nomination of the Chair, a second ballot shall be submitted to all members, for voting for Vice Chair within ten days. Three names are to be placed on this ballot and shall consist of the remaining name or names, if there was a tie for second, from the ballot for Chair and the name or names of the next available individual(s) receiving the weighted highest number of votes in the Committee survey for nomination as Chair. The member receiving the plurality of votes cast shall be nominated for Vice Chair. (d) The nominations for Chair and Vice Chair shall be submitted to the BCA for approval. 3.4.4 If there is a vacancy in the office of the Chair, the name of the Vice Chair will be submitted to the BCA to fill the unexpired term of the Chair. If there is a vacancy in the office of Vice Chair, a new Vice Chair will be nominated by the Committee under the voting procedures of 3.4.3(a) and (b), to fill the unexpired term of the Vice Chair. The Chair and Vice Chair shall not serve more than two consecutive terms in the same office unless such appointment, on the recommendation of the Committee is approved by the BCA, or as otherwise determined by the Standards and Certification Board of Directors (S&C BOD). The Chair shall be an ex-officio member of The Board on Conformity Assessment (BCA). The Chair may nominate an alternate to BCA from within the members of the Committee. The Secretary, who is a member of the Committee without vote, shall be designated from the ASME Codes and Standards Directorate. Members shall not represent particular companies or organizations, but shall have recognized background and work experience by which they would be placed in one of the following interest categories: (a) (b) (c) (d) (e) (f) Manufacturer of products covered by the Code (AK); User of products for which the Code is formulated, except utilities (AW); Manufacturer of material (AM); Enforcement/Regulatory (AT); Insurance Inspection (AH); General Interest (AF);

3.4.5

3.4.6

3.4.7

3.5

CNC Procedures February 1, 2011 Page 4

(g) Designer/Constructor (AC); (h) Utility (AX). There shall be not more than three members representing any one category of interest and all categories of interest should preferably be represented. However, where the limitation to three members in any one category of interest is impractical, the limitation shall be either four members or thirty percent of the membership, whichever is less, in any one interest category. The Committee will take necessary action to fill interest vacancies where possible. Lack of representation in any category shall not preclude the Committee from conducting its business. 3.6 Each member of the Committee shall recommend, within two years of their appointment to the Committee, a person, qualifying within the same interest category, as a permanent alternate to serve in the absence, or at the direction, of the member. Appointment of the permanent alternate shall be by the same procedure as for members. This period of recommending an alternate may be extended by a maximum of one year by the Chair of the Committee. If an alternate is not recommended after the extended period of time, the Chair needs to consult with the member as to maintaining membership on the Committee. Permanent alternates shall have the same privileges and responsibilities as members when serving in the member's capacity. At the discretion of the Chair, when a member is absent at a meeting and not represented by their alternate, the member may be represented by another alternate within the same interest category. If an alternate from the same interest category is not available, then any permanent alternate in attendance may serve as the members alternate, providing the balance of interest is maintained. Service of permanent alternates terminates on formal action by the Committee: (a) upon request of the member; (b) upon request of the permanent alternate; (c) when the person represented by the permanent alternate is no longer a member of the Committee. 3.7 When members and permanent alternates undergo a career move which results in a change of category of interest, they will be requested to submit their resignation to the Committee. Such resignation shall be taken under consideration by the Committee. If the balance required by 3.5 is not affected, the Committee may vote to retain the member and/or alternate. If it is affected, and the Committee does not act in accordance with the alternatives listed in 3.5, then appropriate action will be recommended in accordance with 3.3. The ASME Senior Consultant, who is a member of the Committee without vote, provides the liaison between ASME Team Leaders and the Committee.

3.8

CNC Procedures February 1, 2011 Page 5

3.9

The Chair and Vice Chair of the Committee are encouraged to attend the Consultants' Meetings.

CNC Procedures February 1, 2011 Page 6

4 4.1 4.1.1

DUTIES OFFICERS Chair. The Chair shall preside at meetings of the Committee and shall perform such other duties as are customarily assigned to that office. The Chair shall annually review the record supplied by the Secretary of the activity of each member and alternate of the Committee with regard to the member's and alternates contribution to the work of the Committee, attention to correspondence, and attendance at meetings. Based on such a review, the Chair may recommend to the BCA that the member's or alternates appointment to the Committee be terminated for cause.

4.1.2

Vice Chair. The Vice Chair shall, in the absence of the Chair, fulfill the duties of that office. Secretary. The Secretary shall prepare the agenda and record the minutes of all meetings of the Committee and shall perform such other duties customarily attached to such an office or required by these procedures. In the absence of both the Chair and Vice Chair at a meeting of the Committee, the Secretary shall take the Chair for the purpose of nomination and election of a Chair pro tem, who shall then preside at the meeting. MEMBERS The duty of each member (or the appointed alternate who is serving in the member's absence) is to give thorough consideration to each subject brought before the Committee for action, vote on acceptance or rejection of each proposal, recommend personnel for membership on the Committee, contribute their expertise, and generally assist in carrying out the functions of the Committee. Such duties may be carried out by attendance at meetings, by correspondence, and by telephone. Each newly appointed member and alternate shall participate as an observer, or member of a Survey Team, when eligible, on at least one ASME nuclear survey during the first two years of their initial appointment to the Committee, except that for unusual circumstances, the period may be extended by a maximum of one year by the Chair of the Committee. Participation in an ASME nuclear survey, as an observer or member, within three years prior to appointment on the Committee, may be used for fulfilling this requirement with the Committee's approval. The Chair and Vice Chair of the Committee shall participate on at least one ASME nuclear survey during their term as a Committee officer. On any survey, the number of observers shall be limited to two. In order to sustain the alternates expertise in the procedures of the Committee, it is recommended that the alternate attend a minimum of one meeting per year.

4.1.3

4.2

CNC Procedures February 1, 2011 Page 7

5 5.1

MEETINGS FREQUENCY The Committee will normally meet during the regularly scheduled meetings of the BPV Committee on Construction of Nuclear Facility Components (Section III). It may hold meetings at other times at the call of the Chair or the request of not less than three members of the Committee.

5.2

ACCESS Because of the sensitive nature of its activities, all meetings of the Committee shall be considered closed to all persons except members and alternates of the Committee, members of the ASME staff, members of the ASME Internal Audit Team, and the Chair of the BCA (except for specific individuals invited by the Chair and as specified in Section 11).

5.3 5.3.1

QUORUM At any meeting of the Committee a quorum is established when at least two-thirds of the members of the Committee, or the permanent alternate when a member is absent, are present. The provisions of 3.6 may be invoked to achieve a quorum. In the absence of a quorum, the minutes of the meeting and any voted action shall be subject to ballot approval by the membership. Hearings shall not be conducted at meetings where a quorum is not present. CONFIDENTIALITY Team Reports, minutes, agendas, and material distributed for discussion at a meeting are to be considered confidential and discussion of their contents by members of the Committee with nonmembers is strictly prohibited except for the Chair of BCA, ASME Staff, ASME Nuclear Team Leaders, ASME Internal Audit Team, and ASME Standards and Certification Board of Directors, as appropriate, or as agreed upon by the Committee, as appropriate. Agreeing to comply with these requirements is not to be interpreted as preemption of one's obligation to adhere to the Constitution, Charter, laws or regulations of the country, state, province or municipality of the member's residence.

5.3.2 5.4

CNC Procedures February 1, 2011 Page 8

6 6.1

TASK GROUPS When the Committee agrees on the need, or at the discretion of the Chair, a Task Group and Task Group Chair shall be appointed by the Chair of the Committee. A member of the Task Group may be appointed as Task Group Secretary by the Task Group Chair. The membership shall be selected from the Committee and ASME Consultants may be requested to serve on Task Groups. Task Groups shall meet as often as the workload requires. A Task Group may be selected to handle one or more special subject assignments. The number of members on each Task Group shall be as necessary to perform the assigned task. The size of each Task Group will be limited to numbers which will best serve operational needs. At any time considered beneficial to operation of the Committee, the Task Group may be discharged or new members may be assigned, if necessary. The Task Group shall be dismissed by the Chair when their task is completed. VOTING At Task Group meetings, when discussion indicates general agreement on any question, the Task Group Chair shall call for a formal vote. This vote must be recorded in the meeting report. When two-thirds of the membership of the Task Group register approval for those areas explained above, the action of the Task Group shall be considered as a recommendation to the Committee. If the two-thirds affirmative vote is not received in the recorded vote, the action is defeated and the question must be reconsidered. The Task Group Chair will submit the voted recommendations of the Task Group to the Committee.

6.2

6.3

6.4 6.4.1

6.4.2

6.4.3

CNC Procedures February 1, 2011 Page 9

7 7.1 7.1.1

COMMITTEE ACTIONS TYPES Actions relating to Certificates such as the following, are subject to the requirements of 7.2.1: (a) (b) (c) (d) (e) (f) (g) (h) issuance of Certificates and Extensions of Corporate Certificates; withholding of Certificates; withdrawing of Certificates; change in scope of Certificates; change in name of the Certified Company transfer of the Certified Companys location; extension of Certificate for job completion; consideration of Team recommendation for resurvey, reaudit, reinterview, investigation or early audit; (i) addition of new locations to Certificate; (j) suspension of Certificates; (k) reinstatement of Certificates.

Except as noted in 7.5, any actions relating to Certificates shall be based on a review by the Committee of a Survey, Audit, or Interview Team Report, as appropriate (as indicated in 7.6 and/or Tables 1, 2 or 3). 7.1.2 Actions relating to matters other than those encompassed in 7.l.l, and which are not related to Certificates are subject to the requirements of 7.2.4. Wherever the term N-Type Certificate is used, it shall refer to an N, NV, NS, NPT, NA or N3 Certificate, as applicable, and not to an Owners Certificate or Quality System Certificate. VOTING REQUIREMENTS AND DISPOSITION OF NEGATIVE VOTES Approval of actions of the type encompassed in 7.1.1 at Committee meetings require a twothirds affirmative vote of the Committee voting membership exclusive of those having a potential conflict of interest (as indicated in 7.4). When the action is submitted for letter ballot (as indicated in Section 8), a single negative vote or lack of two-thirds affirmative vote requires reconsideration of the action, except for the actions covered by 7.2.3. When reconsideration of an action is required (as indicated in 7.2.1), the Chair may (a) Advise staff to ballot the action again when additional information can be furnished which could have a bearing on resolution of negative vote(s).

7.1.3

7.2 7.2.1

7.2.2

CNC Procedures February 1, 2011 Page 10

Reconsideration ballots shall be considered approved if affirmative ballots are received from two-thirds of the Committee membership, exclusive of those having a conflict of interest. (b) Advise staff to place the item on the agenda for the next Committee meeting following the ballot closing date for discussion and resolution of the negative vote(s). (c) Appoint a Task Group consisting of negative voter(s), the Team Leader, and additional Committee members, as appropriate. The Task Group will be charged with the responsibility of reviewing the negative vote(s) and submitting a recommended course of action to the Committee at the next meeting of the Committee. (d) When the negative vote(s) involve withholding a Certificate applied for or withdrawing an existing Certificate without additional survey actions, invite the involved Applicant/Certified Company to the next meeting. The purpose of this meeting will be to discuss the factors involved in the withholding or withdrawing action with the Applicant/Certified Company so that the Committee may render a supplemental decision to withhold, withdraw, resurvey, issue, or reissue a Certificate. 7.2.3 Approval of actions relating to the extension of expiration date of a Certificate, as covered in 7.7.1, or recommendation for a show cause hearing, as covered in 11.2.1, require a twothirds affirmative vote of the Committee voting membership, exclusive of those having a potential conflict of interest (as indicated in 7.4). Approval of actions of the type encompassed in 7.1.2 require a simple majority affirmative vote of the Committee voting membership. VOTING OBLIGATIONS Each Committee member or alternate shall carry out their duties and responsibilities with emphasis on exercising their voting privilege (within prescribed time limits in the case of ballots). For votes taken at a meeting, the Chair may vote (a) to break a tie;or (b) to establish or deny the two-thirds vote required. 7.4 CONFLICT OF INTEREST Any member having a potential conflict of interest related to any action will remove themselves from the voting on that action; in which case, their alternate may act in their stead, unless the alternate also has a conflict of interest..

7.2.4

7.3 7.3.1

7.3.2

CNC Procedures February 1, 2011 Page 11

7.5 7.5.1

ACTIONS DELEGATED TO STAFF N-Type Certificates 7.5.1.1 Name Change. Company name changes on the Certificate may be made by staff upon receipt of a request from the Certificate Holder and a supporting letter from the AIA documenting the following: (a) verification that the AIA has an agreement with the Certificate Holder under the new name; (b) summary of the review conducted by the Authorized Nuclear Inspection Supervisor, including documentation as to how the Certificate Holder's Quality Assurance manual has been revised to reflect the name change and that the ANIS has reviewed and accepted the revisions; (c) verification that this name change does not alter the Certificate Holder's Quality Assurance Program as previously accepted by ASME. In the event the AIA response is negative (a) An announced audit shall be conducted by an ASME Consultant, except that the Certificate Holder shall be given the option of early renewal with a regular survey. (b) The Audit or Survey Report shall be submitted to the Committee for evaluation and action. 7.5.1.2 Address Change - Postal Redesignation. Upon receipt of a request from the Certificate Holder for an address change which involves a postal redesignation of building number or street name, staff may revise the applicable Certificate(s). 7.5.1.3 Address Change - Relocation of Office Functions. Upon receipt of a request for an address change which involves solely a relocation of office functions, the following procedures apply: (a) The staff shall obtain a report from the AIA covering an audit at the new location to verify that the accepted Quality Assurance Program is being followed using previously trained and qualified personnel, that accepted procedures are implemented, and that the address change did not involve change of management or Enforcement Authority. If the AIA chooses not to conduct the required audit or does not respond within thirty days of the request for audit, an ASME Consultant will be assigned to carry out the audit at the Certificate Holder's expense. (b) Upon receipt of a favorable Audit Report from either the AIA or the ASME Consultant, staff may revise the applicable Certificate(s).

CNC Procedures February 1, 2011 Page 12

If an unfavorable report is received, it shall be submitted to the Committee for evaluation and action on the request. 7.5.2 Quality System Certificates (QSC) 7.5.2.1 Name Change. Upon receipt of a request for a name change from a QSC Holder, staff shall obtain a report from the QSC Holder including documentation of the following: (a) the necessary changes have been made to the Quality System Manual to reflect the name change and a copy submitted to ASME for acceptance; (b) confirmation that there have been no changes within the organization, including management, which could affect the implementation of the Quality System Program as accepted by ASME; (c) that the name change does not alter the QSC Holder's Quality System Program as previously accepted by ASME. An ASME Consultant familiar with the QSC Holder shall review the proposed manual changes and determine that the name change is or is not acceptable. Upon favorable recommendation from the ASME Consultant, staff may revise the applicable Certificate(s). If an unfavorable recommendation is made by the ASME Consultant, an announced audit shall be conducted by an ASME Consultant, except that the QSC Holder shall be given the option of early renewal with a regular survey, and the Audit or Survey Report shall be submitted to the Committee for evaluation and action. 7.5.2.2 Address Change - Postal Redesignation. Upon receipt of a request from a QSC Holder for an address change which involves a postal redesignation of building number or street name, staff may revise the applicable Certificate(s). 7.5.2.3 Address Change - Relocation of Office Functions. Upon receipt of a request for an address change from a QSC Holder whose office functions alone have relocated, staff shall obtain a report from the QSC Holder including documentation of the following: (a) the necessary changes have been made to the Quality System Manual to reflect the address change and a copy submitted to ASME for acceptance; (b) confirmation that there have been no changes within the organization, including management, which could affect the implementation of the Quality System Program as accepted by ASME; (c) that the address change does not alter the QSC Holder's Quality System Program as previously accepted by ASME.

CNC Procedures February 1, 2011 Page 13

An ASME Consultant familiar with the QSC Holder shall review the proposed manual changes and determine that the relocation is or is not acceptable. Upon favorable recommendation from the Team Leader, staff may revise and reissue the applicable Certificate. If an unfavorable recommendation is made by the ASME Consultant (a) An announced audit shall be conducted by an ASME Consultant, except that the QSC Holder shall be given the option of early renewal with a regular survey at the new location. (b) The Audit or Survey Report shall be submitted to the Committee for evaluation and action. 7.5.3 Owner's Certificate An Owner's Certificate may be renewed by staff upon receipt of a favorable report submitted by the AIA and completion of necessary administrative requirements. 7.5.4 Extension of Expiration Date The staff may extend the expiration date of Certificates to the expected Committee evaluation completion date, without Committee action, under the following conditions: (a) the Certified Company has made proper application with the required deposit at least five months prior to the expiration date and the staff is unable to provide a Survey or Audit Team due to scheduling difficulty. If the Certificate/QSC Holder refuses or cancels available survey dates, this will not be considered a scheduling difficulty (see last paragraph of 7.5.4); or (b) the Certified Company has made proper application with the required deposit at least five months prior to the expiration date and survey or audit has been performed prior to the expiration date but Committee action has not been completed. When the Certified Company refuses available or cancels assigned dates, and rescheduling cannot provide a survey date prior to the Certificate(s) expiration date or when the Applicant has not made proper application with the required deposit at least five months prior to the expiration date, the staff shall inform the Certified Company by certified mail, return receipt requested, or equivalent communication, that the Certificate(s) will expire on the expiration date unless, within the ten working days of receipt of notification, they request Committee consideration of an extension and state the reason(s) for such request. The staff may extend the expiration date as necessary to allow Committee consideration of the requested extension.

CNC Procedures February 1, 2011 Page 14

7.5.5

Staff shall submit any matter covered in this subsection to the Committee if there is reason to question the action. Staff shall report actions taken of the type covered in this subsection to the Committee. Reported actions taken on Certificates shall include the corresponding backup information. OTHER ACTIONS RELATING TO STATUS OF CERTIFICATES N-Type Certificates 7.6.1.1 Address Change - Relocation and/or Additional Shop Facilities. Upon receipt of a request for relocation and/or additional shop facilities (a) Staff shall arrange for an announced audit, at the expense of the Certificate Holder, which shall be conducted by an ASME Consultant, and representatives of the AIA, except that the Certificate Holder shall be given the option of early renewal with a regular survey at the new facility. (b) The Audit or Survey Report shall be submitted to the Committee for evaluation and action. 7.6.1.2 Scope Change - Expansion of Existing Class 1 Authorization. Upon receipt of a request for a scope change to include additional items under an existing Class 1 authorization, staff shall obtain a report from the AIA summarizing the review conducted by the ANIS including documentation as to how the Certificate Holder's Quality Assurance Manual has been revised to reflect this expansion of Class 1 authorization and that the ANIS has reviewed and accepted the revisions. The Certificate Holder's request and AIA Report shall be submitted to the Committee for evaluation and action. The addition of component supports shall require an ASME audit. 7.6.1.3 Scope Change - Addition of Material Organization Activities. Upon receipt of a request from an N-Type Certificate Holder for a scope change to include Material Organization activities (a) An announced audit, at the expense of the Certificate Holder, shall be conducted by an ASME Team Leader and a representative of the AIA, except that the Certificate Holder shall be given the option of early renewal with a regular survey. (b) The Audit or Survey Report shall be submitted to the Committee for evaluation and action. 7.6.1.4 Scope Change Addition of Nonferrous or Ferrous Materials to an Existing Materials Organization Activity Scope. Upon receipt of a request for the addition of nonferrous materials to an existing ferrous material (or vice versa)

7.5.6

7.6 7.6.1

CNC Procedures February 1, 2011 Page 15

(a) An announced audit, at the expense of the Certificate Holder, shall be conducted by an ASME Team Leader and a representative of the AIA, except that the Certificate Holder shall be given the option of early renewal with a regular survey. (b) The Audit or Survey Report shall be submitted to the Committee for evaluation and action. 7.6.2 Quality System Certificates 7.6.2.1 Address Change - Relocation and/or Additional Facilities. Upon receipt of a request for relocation and/or additional facilities (a) An announced audit shall be conducted by an ASME Consultant, except that the QSC Holder shall be given the option of early renewal with a regular survey at the new facility. (b) The Survey or Audit Report will be submitted to the Committee for evaluation and action. 7.6.2.2 Scope Change - Addition of Approval of Suppliers of Source Material and Services, and/or Utilization of Unqualified Source Material. Upon receipt of a request for the addition of approval of suppliers of source material and services, and/or utilization of unqualified source material, to the scope of an existing QSC (a) An audit shall be conducted by an ASME Consultant and will include review of the QSC Holder's Quality System Manual to ensure that the necessary controls have been included in the ASME controlled copy of the Manual, except that the QSC Holder shall be given the option of early renewal with a regular survey. (b) The Audit Report shall be submitted to the Committee for evaluation and action. 7.6.2.3 Scope Change - Addition of Nonferrous Materials to QSC. Upon receipt of a request for the addition of nonferrous material to an existing ferrous material (or vice versa) QSC, staff shall contact an ASME Consultant familiar with the QSC Holder, and if the Consultant recommends favorable action, submit a request to the Committee for evaluation and action. If the ASME Consultant does not recommend favorably, staff shall follow the same steps as 7.6.2.2(a) and (b).

7.7 7.7.1

EXTENSIONS OF EXPIRATION DATE When a survey or audit has been performed and the Team recommendation is unfavorable, the Committee shall act concurrently and individually on

CNC Procedures February 1, 2011 Page 16

(a) the recommendation for resurvey; and (b) extension of the expiration date to complete the evaluation of the resurvey or Reaudit Report by the Committee. In the case of (b), the provisions of 7.2.3 shall apply. 7.7.2 Upon receipt of a request from an N-Type Certificate Holder to extend a Certificate of Authorization expiration date in order to complete Code work-in-progress, the following applies: (a) Such a request must be received at least ninety days prior to the current expiration date. (b) Upon receipt of a request for extension to complete Code work-in-progress, the staff shall request the appropriate AIA to evaluate the present activity of the Certificate Holder. This evaluation shall include the current effectiveness of the management and quality assurance program of the Certificate Holder relative to what was in place and presented to the ASME Survey Team at the last survey. (a) If not included in the request, the staff shall request the Certificate Holder to submit a description of the work to be completed and when it is scheduled for completion. The Certificate Holder shall be advised to copy this communication to the Enforcement Authority for the location of the work-in-progress and the Authorized Inspection Agency. (b) Staff will, concurrent with (b), advise the Certificate Holder that the extension, if granted, will not be for more than six months beyond the Certificate expiration date, and that only Code work described in the request is permitted during the six month extension period. (e) The Certificate Holder's request for extension, with all pertinent information will be presented to the Committee for action. (f) If the request for extension is approved by the Committee, staff will advise the Certificate Holder in writing with copies to the Enforcement Authority and the Authorized Inspection Agency. The Certificate Holder will be requested to advise ASME when the Code work-in-progress has been completed. In this letter, the Certificate Holder will be advised that if continuation as a Certificate Holder beyond the extended expiration date is desired, new application must be made. The current Certificate will not be renewed. (g) If, at the end of five months, the Certificate Holder has not contacted ASME advising that the work is complete, staff will contact the Certificate Holder in writing advising that the Certificate will expire on the designated date. Copies of this notification shall be sent to the Enforcement Authority and the Authorized Inspection Agency.

CNC Procedures February 1, 2011 Page 17

(h) A Certificate Holder who voluntarily terminates a survey shall not be permitted an extension to complete work-in-progress. The Certificate Holder shall be so informed by the Team Leader and be given the opportunity to reconsider. 7.7.3 Upon receipt of a request from a QSC Holder to extend a Certificate expiration date in order to complete Code work/supply-in-progress, the following applies: (a) Such request must be received at least ninety days prior to the current expiration date. (b) If not included in the request, the staff shall request the QSC Holder to submit a description of the work to be completed/supplied and when it is scheduled for completion. (c) Staff will, concurrent with (b), advise the QSC Holder that the extension, if granted, will not be for more than six months beyond the Certificate expiration date, and only Code work described in the request is permitted during the six month extension period. Staff also will advise the QSC Holder that ASME will conduct an announced audit during the extension period at the QSC Holder's expense. (d) The QSC Holder's request for extension, with all pertinent information (including the last audit report and correspondence closing any open findings), will be presented to the Committee for action. (e) If the request for extension is approved by the Committee, staff will advise the QSC Holder in writing. The QSC Holder will be requested to advise ASME when the Code work/supply has been completed. In this letter, the QSC Holder will be advised that if continuation as a QSC Holder beyond the extended expiration date is desired, new application must be made. The current Certificate will not be renewed. (f) If, at the end of five months, the QSC Holder has not contacted ASME advising that the work/supply is complete, staff will contact the QSC Holder in writing advising that the Certificate will expire on the designated date. (g) A QSC Holder who voluntarily terminates a survey shall not be permitted an extension to complete work/supply-in-progress. The QSC Holder shall be so informed by the Team Leader and be given the opportunity to reconsider. 7.8 7.8.1 ACTION TO WITHHOLD OR WITHDRAW If it is the decision of the Committee to withhold or withdraw a Certificate, the ASME staff shall advise the Applicant/Certified Company of such action with a brief but definitive description of the findings upon which the decision was based and information relating to reconsideration or appeal of such decision as described in the Due Process provisions of these procedures (see Section 11).

CNC Procedures February 1, 2011 Page 18

7.8.2

If it is the decision of the Committee to withhold a Certificate until the Applicant/Certified Company agrees to an ASME announced audit at the Applicant's expense, the ASME staff shall advise the Applicant/Certificate Holder of such action with a brief but definitive description of the findings upon which the decision was based and information relating to reconsideration or appeal of such decision as described in the Due Process provision of these procedures (see Section 11). ACTION TO SUSPEND OR REINSTATE Suspension of Certificates. The act of suspension will allow the Certified company to retain its Certificate number. However, it will not be able to Code stamp items or certify items until reinstate. Actions leading to the suspension of Certificates shall be based on nonconformance, deviations, and/or deficiencies in the program as a result of a written report by an ASME Survey, Audit, Investigation, or as a result of a hearing.. If it is the decision of the Committee to suspend certification, the ASME staff shall advise the Certified Company of such action with a brief but definitive description of the findings upon which the decision was based and information relating to reconsideration or appeal of such decision as described in the due process provision of these procedures. Reinstatement. The act of reinstatement by CNC requires Committee action with or without a survey or audit.

7.9 7.9.1

7.9.2

CNC Procedures February 1, 2011 Page 19

8 8.1

BALLOTS AUTHORIZATION Staff is authorized to issue ballots relating to actions of the type described in 7.1. In addition, a ballot may be authorized by any of the following: (a) Officers of the Committee; (b) a majority vote of those members present at a meeting of the Committee; or (c) petition of five members of the Committee.

8.2

CONFIDENTIALITY Team Reports and other material included in or with a ballot are to be considered confidential and discussion of their contents by members of the Committee with nonmembers is strictly prohibited. Agreeing to comply with these requirements is not to be interpreted as preemption of one's obligation to adhere to the Constitution, Charter, laws or regulations of the country, state, province or municipality of residence.

8.3 8.3.1

BALLOT PROCEDURES The Secretary shall ensure that all pertinent information is on the ballot or attached thereto to permit proper consideration of the matter at hand by the membership. The action to be voted on will be clearly identified on the ballot. The ballot shall be done through the ASME electronic voting system. However, for secret ballots and for other unusual circumstances, a letter ballot may be conducted. Disapproved, abstain and not voting responses shall be explained by the voting member in the space provided on the ballot. A response of not voting signifies neither approval nor disapproval, but the total voting membership is reduced by one for each not voting ballot on a particular action. A not voting action shall be used when the member determines that voting on the item would create a conflict of interest. A response of abstain signifies neither approval nor disapproval, but the total Committee membership remains unaffected by such action.

8.3.2

8.3.3

The voting period for ballots shall be twenty-one days from the date of issue or as soon as all ballots are returned, whichever comes earlier. A week in which a meeting of the Committee is convened shall not be counted in determining the ballot voting period. Votes will also be accepted by e-mail, fax or mail.

CNC Procedures February 1, 2011 Page 20

8.3.4

The results of all ballots including comments shall be reported to the Committee for resolution and action as required.

CNC Procedures February 1, 2011 Page 21

9 9.1

CODE INTERPRETATIONS SURVEY TEAM Questions of possible need for Code interpretation raised by the Survey, Audit, Investigation or Interview Teams shall be submitted to the Secretary of the appropriate BPV Standards Committee. The Committee (CNC) will be provided a copy before or at the next meeting of the Committee.

9.2

COMMITTEE Request for Code interpretations generated by the Committee (CNC) shall be presented to the Secretary of the appropriate BPV Standards Committee.

9.3

MONITORING OF INQUIRIES For inquiries submitted by either the Survey Team (Section 9.1) or CNC (Section 9.2), the Secretary of the Committee shall be responsible for maintaining a copy of each inquiry submitted to Standards Developing Committees for interpretation, monitoring the processing of each inquiry until such time as a response is received, and reporting the response received before or at the next meeting of the Committee.

CNC Procedures February 1, 2011 Page 22

10 10.1 10.2

SURVEYS, AUDITS, INVESTIGATIONS AND INTERVIEWS The Survey, Audit and Interview Team Make-up is shown in Tables 1, 2 and 3. Members of the Boiler and Pressure Vessel Standards Committees, the Committee on Boiler and Pressure Vessel Conformity Assessment and voting members of the Committee on Nuclear Certification shall not be used as ASME-paid consultants on ASME Nuclear Survey, Audit, Investigation or Interview Teams. This does not prevent members of the Boiler and Pressure Vessel Standards Committees, the Committee on Boiler and Pressure Vessel Conformity Assessment, or voting members of the Committee on Nuclear Certification from participating in Nuclear audits, interviews, or surveys as (a) observers; or (b) when they serve as representatives of an Authorized Inspection Agency, Enforcement Authority, National Board of Boiler and Pressure Vessel Inspectors or Certified Companies. Members and Alternates of the Committee on Nuclear Certification shall not vote on any CNC actions involving surveys, audits, or interviews in which they participated as a member of the Team.

10.3

It is the responsibility of the ASME Conformity Assessment staff to assign ASME Consultants as Team Leaders and Members as required for surveys, audits, and interviews. The ASME Conformity Assessment staff also has the responsibility for all Administrative items such as scheduling, conduct of surveys, and financial matters. ASME surveys/interviews may be aborted only with the consent of the Certificate/QSC Holder or Applicant. If the Certified Company or Applicant voluntarily terminates the survey, this fact shall be reported to the Committee together with the Team Leader's summary of the survey/interview activities to that point. The Team shall not continue survey/interview related activities after being formally advised that the Certified Company or Applicant desires the survey/interview to be terminated. When the Certified Company or Applicant requests termination of the survey/interview, they shall be advised by the Team Leader of the provisions of 7.7.2(h) or 7.7.3(g), as applicable. When a written complaint is received by ASME or from the Survey Team as a result of a survey, interview, audit, etc. of possible Code violations in the object(s) produced or problems with the Quality Assurance Program, an investigation may be conducted. If the Committee voted action is to conduct an investigation, the organization, conduct and report of such an investigation shall be in accordance with BCAs established procedures on investigation.

10.4

10.5

CNC Procedures February 1, 2011 Page 23

11 11.1

PROCEDURAL DUE PROCESS GENERAL Actions leading to the withholding, withdrawal or suspension of Certificates shall be based on noncompliance with Code requirements; nonconformances, deviations, and/or deficiencies in the Applicant's/Certified Companys Quality Program; and/or lack of implementation of the Quality Program described in a written report of a survey, audit, interview, or investigation.

11.2

SHOW CAUSE

11.2.1 When a Survey/Audit Team Report or report of an investigation recommends withdrawal or suspension of a Certificate and is concurred with by Committee voted action, the staff shall notify the Certified Company of the findings and Committee action. The provisions of 7.2.3 shall apply. The Certified Company will be invited to appear before the Committee to show cause why the recommended action to withdraw or suspend accreditation should not be approved by the Committee. Staff notification shall be by certified mail, return receipt requested or an equivalent communication, and shall provide a date, time, and place of the hearing. The Certified Company shall be invited to provide a written reply to the Secretary prior to the hearing. Copies of such replies shall be provided to the Committee members for review. 11.2.2 The conduct of hearings shall be as set forth in 11.5. 11.3 RECONSIDERATION

11.3.1 Any Applicant/Certified Company who makes a written request, stating their reason, that an adverse action of the Committee be reconsidered, shall be: (a) required to submit their reasons, in writing, to the Secretary, supporting their request for reconsideration of the action by the Committee and of extension of the expiration date of the Certificate(s). Copies of written statements submitted by the Applicant/Certified Company shall be provided to the members of the Committee for review; and (b) granted the privilege of appearing before the Committee. 11.3.2 If such organization requests reconsideration, the expiration date(s) of the Certificates will, if necessary, be extended to the next meeting of the Committee. 11.3.3 The expiration date of the Certificate(s) may be extended by Committee action based on information submitted by staff or the Applicant/Certified Company.

CNC Procedures February 1, 2011 Page 24

11.3.4 The conduct of reconsideration hearings, shall be as set forth in 11.5. 11.4 APPEAL

11.4.1 Any Applicant/Certified Company who makes a written request, may appeal an adverse action of the Committee to the BPV Committee on Construction of Nuclear Facility Components (Section III). Such requests shall be in order only after reconsideration proceedings, as described in 11.3, have been completed if such a reconsideration proceeding has been requested. 11.4.2 The Secretary shall transmit a request for appeal to the Secretary of BPV Committee on Construction of Nuclear Facility Components (Section III), with a copy of the transmittal to the Applicant/Certified Company. The appeal shall be conducted in accordance with the procedures of the BPV Committee on Construction of Nuclear Facility Components (Section III), with the Chair and/or Vice Chair, and Secretary of the Committee attending to represent the Committee. 11.5 CONDUCT OF HEARING

11.5.1 A quorum for the hearing is required (see 5.3). 11.5.2 The hearing shall be closed to all persons except members and alternates of the Committee, members of the ASME staff, members of the ASME Internal Audit Team, ASME Counsel, representatives of the Applicant/Certified Company, and the Team Leader. 11.5.3 At the discretion of the Chair, persons who took part in the survey, audit, or interview may be present during the hearing to answer questions posed by the Committee members or the Applicant/Certified Company. 11.5.4 Prior to the start of the hearing, the Chair shall advise the members and alternates of the conflict of interest provisions in effect during the hearing and request any member or alternate who may be aware of a potential conflict of interest with the matter at hand, to notify the Secretary. Members and alternates who consider themselves in potential conflict of interest shall not vote on any action pertaining to the subject for which the hearing is being held. 11.5.5 Members and alternates who are disqualified from voting due to potential conflict of interest, may participate in the discussion.

CNC Procedures February 1, 2011 Page 25

11.5.6 All persons present at the hearing shall be introduced to the Applicant/Certified Company and their representatives, if any, indicating only their areas of interests and not their employer. 11.5.7 The Chair will explain the pertinent procedures of the Committee and will set forth the reasons for the hearing. The Chair will indicate the right of the Applicant/Certified Company to explain or clarify their position with respect to the matter under question and to question any member of the Committee or of the Team who may be present. The Chair shall also advise that members of the Committee will be permitted to question the Applicant/Certified Company to obtain clarification of items under discussion. 11.5.8 Following completion of the hearing, the Chair shall advise the Applicant/Certified Company that the Committee will go back into executive session for further discussion and to arrive at a decision in the matter and that the Applicant/Certified Company will be advised of the decision by means of an official communication sent within five days from ASME. At this time, the Chair will orally advise the Applicant/Certified Company of their right to request a reconsideration of the decision or to appeal that decision to the BPV Committee on Construction of Nuclear Facility Components (Section III). 11.6 POST HEARING PROCEDURES

11.6.1 Prior to reconvening in executive session, the Chair shall ask all visitors and members and alternates who have identified themselves to be in a potential conflict of interest to leave the meeting. 11.6.2 For a motion to pass, at least two-thirds of the membership eligible to vote must be in the affirmative. Those members who have identified themselves or been established as having a potential conflict of interest and therefore "not voting" shall not be included in the tally of membership eligible to vote. If the two-thirds affirmative requirement is not obtained, the Chair may do one of the following to obtain resolution of the motion: (a) resume discussion with the object of developing a new action which will satisfy the negative vote(s); or (b) appoint a Task Group consisting of the Team Leader, negative voter(s) and additional Committee members, as appropriate. The Task Group will be charged with the responsibility to review the negative vote(s) and provide a proposal to the Committee. 11.6.3 When there is voted action, the staff shall prepare and send a letter within five working days to the Applicant/Certified Company setting forth the Committee's decision. If the decision is adverse to the Applicant/Certified Company, the letter shall be sent by certified mail, return receipt requested, or equivalent communication, and include an explanation of those

CNC Procedures February 1, 2011 Page 26

items on which the Committee based its decision and shall enumerate those steps and actions necessary to retain or reapply for certification. The letter shall also include information regarding the right to request reconsideration by the Committee of an adverse decision or to appeal that decision to the BPV Committee on Construction of Nuclear Facility Components (Section III) within five working days of receipt of the Committee's action. The letter shall also advise the Applicant/ Certified Company that if a request for reconsideration or appeal is desired, it must be sent to the Secretary. Copies of the letter shall be sent to the Enforcement Authority, the Authorized Inspection Agency, and the Chair of the Committee.

CNC Procedures February 1, 2011 Page 27

12 12.1

PUBLIC INFORMATION CERTIFIED COMPANIES Certified Companies shall be either published or posted on ASME Web Site by ASME.

12.2

PUBLIC COMMENTS All public comments objecting to the revisions, renewals, and new Certificates shall be referred to the Committee for consideration. A response will be made to each commenter indicating the action taken and the disposition of these comments.

CNC Procedures February 1, 2011 Page 28

13

PARLIAMENTARY PROCEDURES On questions of parliamentary procedures not covered in these procedures, "Robert's Rules of Order," latest edition, shall prevail.

CNC Procedures February 1, 2011 Page 29

14

REVISIONS Revisions to these procedures are subject to approval by BCA.

CNC Procedures February 1, 2011 Page 30

TABLE 1 N-TYPE NUCLEAR SURVEY OR AUDIT TEAM MEMBERSHIP CERTIFICATE OF AUTHORIZATION OR ACCREDITATION***
Type of Survey Initial Survey for Certificate of Authorization Initial Survey for NS Certificate of Accreditation Renewal of Certificate of Authorization (10), (12) Renewal of NS Certificate of Accreditation Survey for Issuance of Certificate of Accreditation (11); Renewal of Certificate of Accreditation; and Transition from Certificate of Authorization to Certificate of Accreditation Survey for Transition from Certificate of Accreditation to Certificate of Authorization (11) Corporate Certificate for Item Completion at a Site or Shop (Audit) Extension of Shop Certificate for Item Completion at a Site (Audit) Relocation of Office Function Relocation and/or Additional Shop Facilities Certificate Scope Revision * * * * * * (2) (2) * * * * (2) (2) (2) (2) ASME Team Leader (6) ASME Team Member (8) AIA Enforcement Authority

(1)

(2)

(2)

**

(3) (7) *

(3) (7) * (4)

(3)

** **

TABLE 2 OWNER - INTERVIEW TEAM MEMBERSHIP OWNERS CERTIFICATE OF ACCREDITATION***

Type of Survey New (Interview) ASME Member *(5) AIA * (5)

CNC Procedures February 1, 2011 Page 31

TABLE 3

MATERIAL ORGANIZATION - NUCLEAR SURVEY OR AUDIT TEAM QUALITY SYSTEM CERTIFICATE***

Type of Survey ASME Team Leader (6) * (9) ASME Member * (9)

New, Renewal (Survey) or Resurvey Audit During 3-Year Term of Quality System Certificate Relocation and/or Additional Shop Facilities; Revisions to Scope and/or Additions of Significantly Different Product Forms; Addition of Material; Approval of Suppliers of Source Material and Services; and/or Utilization of Unqualified Source Material

(9)

(9)

NOTES FOR TABLES 1, 2 & 3: * Mandatory

** Invited to attend by Applicant/Certificate Holder (Location of survey, audit, or interview determines which Enforcement Authority is invited). *** Qualification of ASME Team Leaders and ASME Members shall be in accordance with ASME document Standard Qualification Criteria For Designees for Accreditation Programs. (1) The AIA Team member will consist of only the Authorized Nuclear Inspector Supervisor (ANIS). (2) ASME shall appoint a Team Member in lieu of the Enforcement Authority in the following situations: (a) Where there is no Enforcement Authority, or where the Enforcement Authority elects not to participate, the unavailability of a representative will not be considered as diminishing the effectiveness of the survey nor hinder or cause a change in the schedule. (b) On surveys where the Enforcement Authority is the AIA. (c) The Enforcement Authority is not included on surveys of Applicants located outside the United States or Canada.

CNC Procedures February 1, 2011 Page 32

(3)

Depending on scope and duration of work to be performed, ASME may extend the Shop Certificate to a site on the basis of an audit using ASME Consultants and the AIA, as appropriate, with the Enforcement Authority invited. In lieu of an ASME survey/audit for scope change requests, an AIA audit may be performed under the following conditions: (a) to add items (other than component supports) within a class of construction, within the same Division, already identified in the Certificate scope (e.g. the addition of Class 1 piping systems, when the scope includes another Class 1 item); or (b) to add a lower class (Class 1 is considered the highest) of construction within the same Division, to the Certificate scope (e.g. the addition of Class 2 when the scope includes Class 1 or the addition of class MC when the scope includes Class 2); and (c) a report from the AIA shall be provided to the Committee stating that an audit has been conducted by the AIA, and that all necessary controls are in place and that the manual addresses the new scope. All other requests for scope changes (items, class and divisions) require that a survey or audit be conducted by a Team whose size and makeup will be established by the Committee, when practical, or by the Committee Officers.

(4)

(5)

Interview of the Owner shall be conducted by an ASME Team Leader and the AIA, with the Enforcement Authority (when applicable) invited. A prerequisite for the Owner is to obtain notification from the Regulatory Authority that an application for a construction permit for a specific plant has been docketed. Preferably the Team Leader should be from the original Team for resurveys. Refer to. 7.5.1.3(a). For Section III, Division 2 surveys of Applicant/Certificate Holders, the ASME Team Member shall meet the criteria for Division 2 Consultants, except for metallic parts under Division 2. These activities can be conducted by either an ASME Team Leader or ASME Team Member.

(6) (7) (8)

(9)

(10) At the time of application for renewal, the Certificate Holder and ANIS shall identify to ASME the programmatic changes that have been made and accepted by the ANIS since the issuance of the Certificate of Authorization. Based on ASME staffs evaluation of the provided information and any additional information received from the Applicant, ANIS or

CNC Procedures February 1, 2011 Page 33

from review of the prior Survey Report, when applicable, ASME determines Team size (minimum Team as specified in Table 1). (11) Based on ASME staffs evaluation of information received from the Applicant and/or ANIS, ASME determines Team size (minimum Team is specified in Table 1). (12) Code Case N-520-2 (a) An audit is required when a Certificate Holder elects to suspend Code activity and wishes to retain an active Certificate in accordance with Code Case N-520-2(e), (i) and (j). The Audit Team shall consist of an ASME Team Leader, the Authorized Nuclear Inspector Supervisor (ANIS), the Authorized Nuclear Inspector (ANI) and the Enforcement Authority. An ASME Team Member is not required in lieu of the Enforcement Authority. Where there is no Enforcement Authority, or where the Enforcement Authority elects not to participate, the unavailability of a representative will not be considered as diminishing the effectiveness of the audit nor hinder or cause a change in the schedule. (b) A survey is required when a Certificate Holder elects to resume Code activity on an active Certificate in accordance with Code Case N-520-2(e), (g) and (h). The Survey Team shall consist of an ASME Team Leader, an ASME Team Member, the Authorized Nuclear Inspector Supervisor (ANIS), the Authorized Nuclear Inspector (ANI) and the Enforcement Authority. Another ASME Team Member need not be assigned where there is no Enforcement Authority, or where the Enforcement Authority elects not to participate, the unavailability of a representative will not be considered as diminishing the effectiveness of the survey nor hinder or cause a change in the schedule. (c) A survey is required for the reissuance of an expired Certificate as temporary Certificate under Code Case N-520-2(f). The Survey Team shall consist of an ASME Team Leader, the Authorized Nuclear Inspector Supervisor (ANIS) and the Authorized Nuclear Inspector (ANI) and the Enforcement Authority. An ASME Team Member is required in lieu of the Enforcement Authority. Where there is no Enforcement Authority, or where the Enforcement Authority elects not to participate, the unavailability of a representative will not be considered as diminishing the effectiveness of the survey nor hinder or cause a change in the schedule.

CNC Procedures February 1, 2011 Page 34