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Cross-cutting Issue Review Effort 

This review group included representatives from each of the regions, the Office of Enforcement, 

and the Office of Nuclear Reactor Regulation. The review evaluated implementation practices 

across the four NRC regions with regard to the assignment of cross-cutting aspects to 

inspection findings, evaluation of cross-cutting aspects in the assessment process, and the 

identification of substantive cross-cutting issues (SCCIs). The review group performed peer 

observations of regional inspection debriefs and regional mid-cycle assessments, performed a 

sample review of inspection reports, solicited feedback from the industry, and assessed 

historical inspection finding data. 

The review determined that the regions are implementing the program in accordance with 

guidance in Inspection Manual Chapters (IMCs) 0612 and 0305. The review group identified 

that during the early stages of implementation there were some issues associated with clearly 

documenting cross-cutting aspects, however, there are indications showing improvement in this 

area. In addition, recent data is revealing that the differences between the regions on the 

number of findings with cross-cutting aspects are narrowing which is indicative of improved 

consistency among the regions. While there were some differences noted in how the regions 

prepared for and conducted the assessments, the differences were not significant and had no 

impact on the overall process. 

While the results of this effort concluded that the regions are appropriately following the 

guidance in IMCs 0612 and 0305 and there were no significant issues identified, there were 

some recommendations to be considered to further enhance the program. 

Cross-cutting Issue Review Recommendations and Lessons Learned 

Recommendations and 

lessons learned 

Appropriate IMC Status 

CI-1. The regions should be 

encouraged to consider 

conducting inspection debriefs 

which involve both reactor 

divisions with attendance 

including staff as well as 

management. 

N/A Several regions have or are 

considering expanding their 

inspection debriefs. 

CI-2. Revise IMC 0612 to 

provide additional guidance 

and examples for assigning 

and documenting crosscutting aspects. 

IMC0612 In-progress 

CI-3. NRR should continue 

their process of providing 

periodic refresher training to 

staff on IMC 0612 and 0305 

as changes are made. 

IMC040 No changes needed. 

CI-4. Clarify that a crosscutting theme needs to involve IMC0305 In-progress 
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four or more inspection 

findings with the same crosscutting aspect (should not 

look for sub-cross-cutting 

aspects) 

CI-5. Identified redundancy in 

the first two criteria for a 

substantive cross-cutting 

issue in the problem 

identification and resolution 

and human performance 

cross-cutting areas. 

IMC0305 In-progress 

Palo Verde NRC Lessons Learned

One of the major ROP safety culture enhancements was an extensive modification to Inspection 

Procedure 95003. The staff added guidance to the inspection procedure to describe how the 

NRC will evaluate a licensee’s third-party safety culture assessment and how the NRC will 

perform its own independent assessment of the licensee’s safety culture. The NRC issued the 

revised inspection procedure in October 2006, and it was used for the first time at the Palo 

Verde site in 2007. As part of the inspection procedure implementation, lessons-learned were 

identified. The staff is considering changes to the inspection procedure to redefine the primary 

focus of the NRC safety culture assessment to be determining the adequacy of the licensee’s 

third-party safety culture assessment methodology and implementation. If the staff’s review of 

the licensee’s third-party assessment methodology is determined to be adequate, NRC safety 

culture assessment resources can be better targeted to focus on areas of identified weaknesses. 
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Palo Verde Lessons Learned Recommendations 

Recommendation Appropriate IMC Status 

PV-1. Consideration should be given to considering 

all 13 safety culture components during 

implementation of the baseline program. Additional 

criteria should be established for when to consider 

a cross-cutting theme for the safety culture 

components of accountability, continuous learning 

environment, organizational change management, 

and safety policies. 

IMC 0305 

In progress, working 

to incorporate the 

other safety culture 

components as crosscutting components. 

PV-2. Consider revising IMCs 0305 and 0612 to 

allow inspectors to assign multiple cross-cutting 

aspects for each safety culture related cause 

associated with a performance deficiency. If the 

result is an increase in the number of cross-cutting 

aspects, then MC 0305 should be revised to raise 

the criteria to satisfy the requirements for a 

substantive cross-cutting issue. In addition, for 

sites with multiple units, consideration should be 

given to raising the criteria to satisfy the 

requirements for a substantive cross-cutting issue. 

IMC 0612 

IMC 0305 

Not adopting this 

recommendation, 

Reinforcing existing 

flexibility to only 

assign multiple crosscutting aspects for 

unusual or complex 

issues. 

PV-3. Cross-cutting safety culture issues challenge 

the ability of the NRC to reach accurate risk 

informed decisions and provide an appropriate 

level of regulatory oversight. Consideration should 

be given to evaluating and developing more 

assertive NRC actions (such as a direct input to the 

ROP action matrix) for repetitive or certain types of 

multiple substantive cross-cutting issues. 

IMC 0305 

In-progress, working 

to slightly modify NRC 

regulatory responses 

to a repetitive 

substantive crosscutting issue. No 

changes proposed to 

the ROP Action Matrix 

inputs. 

PV-4. Consideration should be given to providing 

additional guidance in IMC 0609 on the acceptable 

methods to be used to assess the additional risk 

impact of findings with underlying causes that are 

associated with the safety culture components. 

IMC 0609 

IMC 0305 

IP95003 

In-progress, working 

on amplifying the 

guidance. 

PV-5. Consideration should be given to adding 

specific guidance in IP 95003 that describes the 

acceptable method to be used to perform the 

cumulative risk assessment. 

IP 95003 

In-progress working 

on amplifying the 

guidance. 

PV-6. Consideration should be given to revising IP 

95003 to include an allowance to validate the 

results of the licensee’s root cause investigation in 

lieu of the NRC performing a separate root cause 

investigation. The NRC’s completion of this activity 

should only occur if the licensee’s investigation is 

determined to be incomplete. 

IP 95003 In-progress. 
 4

PV-7. Consideration should be given to describing 

root cause analysis tools other than MORT that 

could be used to complete the collective review of 

the root causes. Additionally, it may be necessary 

to add a root cause specialist to the team to 

complete the review. 

IP 95003 In-progress. 

PV-8. The NRC should consider partnering with 

industry in an effort to develop a standardized 

safety culture assessment process and tools, 

including a survey. 

IMC 0305 

IP95003 Considering this item. 

PV-9. Until an industry/NRC accepted standard is 

developed, the NRC should perform an 

independent detailed analysis of the survey tool 

and analytical techniques when evaluating a 

licensee’s safety culture assessment. 

IP 95003 

In-progress, intend to 

retain elements to 

validate licensee 

safety culture 

assessment methods. 

PV-10. Consider revising IP 95003 to provide the 

flexibility to initiate a variety of inspection 

responses consistent with the performance 

deficiencies at a particular facility. This should 

include an evaluation of the existing IP 95003 

boundary conditions. 

IP 95003 

In-progress, working 

to provide flexibility for 

site situations. 

PV-11. Consider revising IP 95003 to include an 

assessment of outage activities. IP 95003 

In progress, plan to 

amplify outage 

coverage and 

sensitivity of the 

outage inspection 

burden on licensee. 

PV-12. Consider revising IP 95003 to treat the 

activity as a fact finding to understand the depth 

and breadth of performance concerns. This 

includes the potential for greater use of unresolved 

items. 

IP 95003 

In-progress, working 

to amend inspection 

approach. 

PV-13. Consideration should be given to 

establishing and assessing precursors as part of 

the baseline inspection program. These precursors 

should be assessed as part of the IMC 0305 

assessment process. 

IMC 0305 

In-progress, looking at 

correlation of safety 

culture components 

with qualitative 

precursors. 

PV-14. Consideration should be given to 

developing innovative methods to assess the 

effectiveness of inspection program 

implementation. 

IMC 0307 Under consideration. 

PV-15. Consideration should be given to 

permanently changing the resident inspector 

staffing requirements at three unit sites to ensure 

an appropriate level of oversight is maintained. 

(For a 3 Unit Site: 1 - Senior Resident Inspector, 3 

- Resident Inspectors) 

IMC 0102 Under consideration. 
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PV-16. Consideration should be given to providing 

additional guidance to supervisory and 

management personnel for the conduct of 

management site visits at facilities where only a 

few findings have been identified. 

IMC 0102 Under consideration. 

PV-17. Consideration should be given to adding 

one FTE per region to focus on initial and 

continuing training needs of the inspection staff. 

IMC 0102 Under consideration. 

PV-18. Consider revising IP 95003 to require 

implementation of the EP attachment and having 

an EP inspector from another regional office 

perform the attachment. 

IP 95003 Under consideration. 

PV-19. Consideration should be given to evaluating 

the implementation of the EP baseline inspection 

program. 

IP 95003 Under consideration. 

PV-20. IP 95003 boundary conditions (1, 3, and 5) 

should be reevaluated. For condition 1 consider 

adding flexibility to allow the NRC to oversee 

independent inspections performed by a thirdparty. Review consistency with having an 

independent third-party assess the licensee’s 

safety culture. 

For condition 3 consider a revision to increase the 

flexibility of the procedure by allowing the use of 

unresolved items and a separate follow-up 

inspection to resolve the technical concerns (defer 

significance determination process evaluation). 

For condition 5 consider a revision to increase the 

flexibility of the procedure by considering the 

implementation of portions of the inspection 

procedure before the licensee has completed their 

third party safety culture assessment and root 

cause evaluation in order to promptly assess the 

depth and breadth of potential problem areas. 

Additionally, consider a revision to allow for 

periodic NRC assessments during the performance 

of the licensee’s root cause analysis and third-party 

safety culture assessment. 

IP 95003 In-progress. 
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PV-21. IP 95003-02, Inspection Requirements, 

indicates that if the IP 95001 and IP 95002 

supplemental inspections have not been 

performed, then the IP 95003 should include an 

assessment of the licensee’s evaluation of those 

issues. A revision should be made to note that the 

licensee’s evaluation of the IP 95001 and 95002 

issues may not be complete at the time of the IP 

95003 inspection. If so, the review of these issues 

should be included in the Confirmatory Action 

Letter. 

IP 95003 In-progress. 

PV-22. Almost all of the inspection requirements in 

IP 95003 are performed as part of the baseline 

inspection program. However, IP 95003 indicates 

that a duplication of inspection efforts should not 

occur. A revision should be made to delete a 

statement in IP 95003 to prevent duplication of 

other inspection efforts. 

IP 95003 In-progress. 

PV-23. To more efficiently integrate safety culture 

and inspection results, it may be more appropriate 

to embed some safety culture components in the 

key attributes. The additional safety culture 

component assessments should focus on those 

areas where implementation of the inspection 

program yields limited results. For example, most 

problem identification and resolution aspects can 

be evaluated using traditional inspection program 

techniques. Therefore, limited safety culture 

assessment interviews and focus groups are 

needed to assess this area. 

IP 95003 In-progress. 

PV-24. The requirements and guidance in section 

02.07 for conducting the safety culture portion of IP 

95003 should be re-evaluated. If the NRC 

determines that the licensee’s third-party 

assessment was appropriate, then there should be 

no need to conduct an independent assessment of 

all 13 safety culture components. The NRC’s 

assessment should determine which, if any, of the 

13 components have not been adequately 

addressed by the third-party assessment and 

which, if any, of the components are not likely to be 

addressed by the IP 95003 key attributes. The 

NRC should then implement safety culture 

assessment activities to address the remaining 

components that are expected to have insufficient 

data to meet the objectives. 

IP 95003 In-progress. 
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PV-25. Re-evaluate sections 02.07 and 02.08 to 

only include the specific inspection requirements. 

All other items should be moved to the guidance 

section. 

IP 95003 In-progress. 

PV-26. Section 95003-03 for just-in-time training 

should be better designed to meet the needs of the 

inspection teams. The training should include, in 

part, performance issues at the facility, root cause 

refresher training, administrative issues, and the 

conduct of the inspection. 

IP 95003 In-progress. 

PV-27. Regarding team staffing, a qualification 

program for safety culture assessors should be 

institutionalized in a manual chapter. Each region 

should be expected to maintain a cadre of Level 2 

safety culture assessors that are capable of 

implementing most of the IP 95003 inspection 

requirements. Validation of third-party safety 

culture assessment tools and methods requires an 

additional skill set, and can be performed by 

headquarters personnel or contractors. These 

skills may not be needed in every case if the NRC 

and industry develop and implement a 

standardized safety culture assessment tool and 

process. 

IMC TBD Under consideration. 

PV-28. At a minimum, a senior reactor analyst 

should be required to participate in the final onsite 

inspection week in order to collect all of the data 

needed to perform a collective risk assessment of 

the performance deficiencies and assist in 

collecting the data necessary to evaluate 

potentially significant inspection findings. The most 

desirable option would be to have a senior reactor 

analyst lead one of the sub-groups and perform the 

analyst functions as a collateral responsibility. 

IP 95003 Under consideration.