On June 9, 2010, a Notice of Violation and Exercise of Enforcement Discretion (Notice) was issued to Global Nuclear Fuels – Americas, LLC (GNF-A). This action was based on a Severity Level III problem involving three violations of regulatory requirements. Specifically, the licensee failed to (1) identify credible accident scenarios as required by the license; (2) characterize criticality accident scenarios in the integrated safety analysis (ISA) as high consequence events as required by the license; and (3) designate engineered or administrative controls as items relied on for safety (IROFS) when necessary to comply with the performance requirements of 10 CFR 70.61(b) – (d), as required by 10 CFR 70.61(e). Because, in part, the NRC staff and the licensee did not share a common understanding of GNF-A's application of its ISA methodology to scenario evaluation and IROFS identification during the ISA summary review and related inspection activities, the NRC concluded that enforcement discretion to forego proposing a civil penalty was appropriate in this case. No actual consequences resulted from these violations because there were no incidents and no existing safety controls were identified as degraded.