Exelon Comments on Draft Changes to 

Inspection Manual Chapter 0612, “Power Reactor Inspection Reports” 

Page 1 Definition of Cross-Cutting Aspect: The change in this definition appears 

to imply that all performance deficiencies would have a cross-cutting 

aspect, since the aspect is now defined as the “most significant” 

contributor to a performance deficiency, where previously the aspect was 

defined as playing a “significant role.” There are many examples of 

performance deficiencies in which the cross-cutting aspects play only a 

minor role; forcing a selection of the most significant of these is 

inappropriate. The definition should retain the original formulation that an 

aspect would only be assigned if it were a significant contributor. 

Page 3 Definition of Performance Deficiency: See Page 1 comment. 

Page 7 Section 05.05: See Page 1 comment. 

Page 11 Note at the end of Section 06.03.b: Combining multiple examples of 

greater than green findings may be appropriate in those cases where the 

examples are associated with the same event and have the same cause, 

performance deficiency, and cross cutting aspect. In these cases, 

counting examples as individual findings would in effect be double 

counting. 

Page 21 Section 11.03.c.1, Second Paragraph: For consistency with Section 

06.03.c.5 (page 13). This section should include the instruction to briefly 

document the reason that no cross-cutting aspect was assigned if 

applicable. 

Page B-6 Section 5.a: Same comment as Page 1. 

Page B-7 Section 5.b.(2): This question describes the screening process slightly 

differently than is implied in the previous descriptions in this document. 

The question asks, “Is the most significant contributor to the performance 

deficiency related to a cross-cutting area ...? This implies that a crosscutting aspect would not be assigned unless the most significant 

contributor is related to a cross-cutting area. The earlier descriptions 

imply that the most significant cross-cutting aspect related to the issue 

would be assigned. This is a subtle but important difference. The various 

descriptions of this issue on Pages 1, 3, 7, B-6, and B-7 should be 

revised to be internally consistent and to emphasize that a cross-cutting 

aspect should only be assigned if the aspect was a significant contributor 

to the performance deficiency. 
Exelon Comments on Draft Changes to 

Inspection Procedure 71152, “Identification and Resolution of Problems” 

Page 5 Section 02.03.d: The meaning of “issues that pose challenges to the free 

flow of information for adequate resolution” is unclear. This needs 

additional specificity. 

Page 13 Section 03.03.b.2: The second to last sentence in this section might 

imply that actions in response to safety culture assessment results would 

be considered as corrective actions that are required per criterion XVI of 

10 CFR 50, Appendix B. Suggest replacing this sentence with the 

following: “Review the adequacy of actions taken by the licensee to 

address the results of periodic safety culture assessment.” 

Page 13 Section 03.03.b.3: Inspection Procedure 95003 was written to evaluate 

third-party safety culture assessments when performance has 

substantially declined. This necessitates a broad scope, multi-disciplined 

team, and a comprehensive assessment methodology. In contrast, selfand independent assessments of safety culture may be requested by the 

NRC in response to an extended substantive cross-cutting issue, which 

could involve as few as four green findings that have a common theme 

and share the same cross-cutting aspect. The approach to assessing 

safety culture in this instance would be different from a third party 

assessment. The focus of the effort would be on the underlying issues for 

the cross-cutting aspect involved and the safety culture implications of 

these issues. This could result in the selection of one assessment 

method, such as surveys, interviews, or focus groups, but would seldom 

require multiple overlapping methods. Thus, it would not be appropriate 

to expect the same scope and methodology for a safety culture 

assessment requested by the NRC as for a 95003 inspection. 

 Additionally, the last paragraph in this section suggests that licensees 

would be expected to conduct additional safety culture assessments to 

address issues or weaknesses identified by the NRC. This paragraph 

should be written more generally to state the licensees would be 

expected to address issues or weaknesses identified by the NRC.