Meeting On Draft Enhancements 

Reactor Oversight Process Safe

Culture Guidance

with ROP Task Force 

April 17, 2008
Meeting Logistics• Attendance list sign in• Feedback forms available• Bridge line protocol (use mute funct• Use of elevator to ground floor w/o e• Meeting handouts• Limited beverages available in audit

lobby
Opening Management Stateme• NEI• NRC
Purpose• Provide an overview of lessons learned i• Provide drafts of safety culture related ch

to key documents (IP95003 and IMC030

• Provide an overview of some other safet

culture changes in-progress (IMC0305 components and aspects, IMC0612, IP7

• Provide a forum for external stakeholder 

clarifying questions and initial comments

• To discuss next steps including opportun

follow-up external stakeholder comments
Success Statement for Meeting• Open dialogue about draft working l

approaches

• Obtain initial external stakeholder 

questions and comments

• Provide external stakeholders with 

sufficient information to help develofollow-up comments 
Meeting Ground Rules• Meeting between the NRC and the 

Reactor Oversight Process Task Fo

• Opportunities will be provided for 

questions and initial comments from external stakeholders as time permi

• Commenter responsibilities –

identification, conciseness
Caveats / Disclaimers

• Early in the evaluation process• Options are still being developed• Information reflects only working level pr• Need for NRC management reviews• Need for consideration of external stakeh

initial and follow-up feedback

• All current ROP provisions remain in effe

formally changed!
Overall ROP Safety Culture P

• Considering lessons learned over 18-mo

implementation 

• General description will be in 2007 ROP 

assessment Commission paper

• Seeking to identify options to improve 

effectiveness and efficiency of ROP guidrelated to safety culture

• Interacting with internal and external 

stakeholders 

• Plan to roll out changes by the end of Au

08
Safety Culture Lessons 

Learned Evaluation Inputs and Produ

• Inputs: NRC reviews and audits, IP9

implementation feedback, industry surveys, ROP self-assessment survROP internal feedback forms, SafetCulture Focus Team activities, ROP monthly meetings

• Planned revisions to: IMC0305, IP9

IMC0612, IP71152
Sharing Working Level Product• Draft guidance documents – safety 

culture related changes only

• Reflective of working level evaluatio

lessons learned inputs

• Minimal management review• Provides early opportunity for 

consideration of external feedback
Sharing Working Level Documents continued• 4 week follow-up comment period• Staff will consider comments receiv

and revise guidance as deemed appropriate

• Documents will proceed through int

review and concurrence process
Cross-cutting Aspect Review • RIV-led Task Group effort• Cross-cutting aspect assignment re• Focus on regional implementation o

IMCs 0305 (assessment process) a0612 (inspection reports)

• Observation of inspection debriefs a

mid-cycle assessments

• Sample review of inspection reports
Cross-cutting Aspect Review 

Recommendations

• Conduct of inspection debriefs (Out

safety culture scope)

• Augment IMC0612 guidance for 

assigning and documenting cross-caspects (Will present overview of IMC0612 changes related to safety culture)
Cross-cutting Aspect Review Recommendations - continued• Provide periodic training on ROP 

guidance changes (Outside safety cscope)

• Need to clarify cross-cutting theme 

(Change to IMC0305)

• Need to remove duplication betwee

substantive cross-cutting issue Criteand 2 (Change to IMC0305 sections
Palo Verde IP95003 Recommendati• First implementation of IP95003 saf

culture assessment

• 28 discrete recommendations result

from the inspection

• Some are non-safety culture related• Will discuss items related to IMC030

and IP95003 safety culture sections
Overview of Palo Verde IP9500

Recommendations

• Re-examine “Other” cross-cutting compo• Clarify assignment of multiple cross-cutti

aspects to a finding

• Consideration to integrate repetitive subs

cross-cutting issue within the action matr

• More guidance on collective risk assessm
Overview of Palo Verde IP95003 

Recommendations- continued

• Development of NRC endorsed lice

safety culture assessment process fIP95003 and IMC0305 requests

• Allow greater flexibility on IP95003 

inspection timing

• Consider precursors predictive of 

licensee declining performance
Draft ROP Guidance Document• Bar line text shows additions from c

approved version

• Most deletions from current approve

version are in bubbles on right hand of the page

• Comment bubbles are used for 

explanation and noting related lessolearned input
IMC0305 • Response to repetitive substantive c

cutting issue (pages 45 -46) with the same cross-cutting aspect

• For 2nd substantive cross-cutting iss

follow-up with problem identification resolution inspection annual sample review
IMC0305 – continued• For 3rd substantive cross-cutting iss

with the same cross-cutting aspect:

– If in problem identification or resolution 

clarified typical request is for an indeplicensee safety culture assessment
IMC0305 – continued• If licensee resolution for substantive 

cross-cutting issue determined nontimely, conduct a focused problem identification and resolution team inspection on annual basis

• Intent of inspection is to ensure 

appropriate level of licensee oversigcorrective actions
IMC0305 – continued• Recognition that safety conscious work 

environment issues can legitimately take to resolve

• Region can defer conduct of follow-up pr

identification and resolution focused inspand of licensee safety culture assessmenrequest until the 4th consecutive safety 

conscious work environment substantive cutting issue
IMC0305 – continued• Added definition for safety culture assess

(page 3 – 4)

• Clarified self-, independent, and third par

assessor definitions

• Clarified expectations on scope of asses• Clarified expectations for safety culture 

assessor personnel performing the asse
IMC0305 – continued• Added clarification for NRC to use 

appropriate inspection attributes froIP95003 to evaluate a licensee’s saself- and independent safety culture assessment (pages 19 and 45)
IMC0305 – continued• Modified to acknowledge NRC grad

safety culture assessment (page 20

• Based on results of evaluating licen

third party safety culture assessmenmethodology and implementation

• Details in IP95003 to be discussed 
IMC0305 – continued• Inputs for a safety conscious work 

environment substantive cross-cuttiissue (page 37)

• Longer time frame of 3 assessment 

periods

• Allows staff sufficient time to have 

confidence that licensee has made progress in addressing the issue
IMC0305 – components/aspects • Adjustment to safety culture 

components/aspects

• Integration of 4 “Other” safety cultur

components into cross-cutting components
IMC0305 - components/aspects continued• Adjustment to components and asp

to remove duplication, sharpen focuconsideration to reorganize

• Considering assignment to findings 

component level

• Will result in changing substantive c

cutting issue threshold (review of padata)
IMC0305 - components/aspects continued• Possible change in cross-cutting are• Comments on pros/cons to tag findi

component level

• Draft changes to cross-cutting 

components and aspects to be sharduring a future public meeting
Chart 1 - Composite Distribution of Findings by Cross-Cutting Aspect for All Regions

(10/1/2006 - 9/30/2007, run on 11/5/2007)

0

102030405060708090

100

H.1(a)

H.1(b)

H.1(c)

H.2(a)

H.2(b)

H.2(c)

H.2(d)

H.3(a)

H.3(b)

H.4(a)

H.4(b)

H.4(c)

P.1(a)

P.1(b)

P.1(c)

P.1(d)

P.1(e)

P.2(a)

P.2(b)

P.3(a)

P.3(b)

P.3(c)

S.1(a)

S.1(b)

S.2(a)

S.2(b)

S.2(

Cross-Cutting Aspect (IMC 0305)

Number of Findings 
IMC0305 - continued• Opportunity for external stakeholder 

questions and initial comments
IP95003 changes

Concept of a NRC graded safety culture 

assessment (pages 14 – 16 and pages 61)

• Acknowledge potential for developmen

industry methodology for NRC review endorsement

• Shift of focus to evaluate licensee 3rd p

safety culture assessment first to inform safety culture assessment

• Based on evaluation, conduct graded 

assessment activities
IP95003 changes - continued• Depending on timing, i.e., prior to conduct of 3rd 

assessment, engage licensee for NRC review o

– Assessment methodology– Qualifications of team – Any revisions to methodology or team based on NRC 

feedback

• Post-conduct of 3rd party assessment, evaluate 

comprehensiveness of the 3rd party assessmen

change)

– Coverage of all functional groups– Coverage of all levels of organization including corpo– Sufficient sample sizes– Coverage of all safety culture components
IP95003 changes - continued• Evaluate the methodology and tools 

by the 3rd party assessment (no cha

• Review independence and qualifica

of 3rd party personnel (no change)
IP95003 changes - continued• Determine scope of scope NRC saf

culture assessment activities, based evaluation of 3rd party assessment

– Range from limited activities to full NR

independent safety culture assessmen

• Evaluate licensee response and 

corrective actions (no change)
IP95003 changes - continued• If weaknesses not identified with 3rd party 

methods/qualifications, focus will be on licensee response 

• Evaluate licensee progress in:

• Performing evaluation of assessment res• Identifying appropriate corrective actions• Developing action plans• Implementing corrective actions
IP95003 changes - continued• If weaknesses with comprehensiveness, condu

targeted assessment activities focusing on:

– Groups/levels not sufficiently covered or inadequately – Safety culture components inadequately covered

• If weaknesses with methodology/qualification, c

sampling activities to evaluate consistency of re

• Results used to adjust scope of graded assessm

needed

– Up to full NRC independent safety culture assessmen
IP95003 changes - continued• Provision for full NRC independent 

culture assessment 

– Detailed guidance in Enclosures A – F 

relocated to ADAMS

– General guidance in Attachment 2

• Most content moved from current IP 9500• Technical content of Enclosures A – F is 

unchanged from current IP95003
IP95003 changes - continued• Option retained for prompt conduct 

focused strategic performance area aspects and full safety culture assessment to diagnose scope of pperformance issues (page 20)

• Clarified flexibility on timing of inspe

elements (page 20)
IP95003 changes - continued• Amend approach to be more diagno

(page 2)

• As time permits perform Significanc

Determination Process evaluation

• Greater use of Unresolved Items (fo

issues likely to be Green) to defer workload to develop the inspection 
IP95003 changes - continued• Opportunity for external stakeholder 

questions and initial comments
IMC0612

• IMC0612 will be revised consistent with 

IMC0305 changes (potential for cross-cucomponents)

• Adding guidance for determining whethe

cross-cutting aspect is reflective of curreperformance

• Decision cannot be made solely based u

the time when the performance deficiencevent occurred

• Need to determine when the cause of the 

problem occurred
IMC0612- continued• When did the performance deficiency or 

occur?

• If the performance deficiency or event wa

result of a latent issue, when did the cauthe performance deficiency occur?

• If the performance deficiency or event wa

result of a latent issue, did the licensee hreasonable opportunities to identify the problem?

• Have programs, processes or staff chang

such that the problem would not occur to
IMC0612- continued• A performance deficiency identified associated with an in

start of safety–related equipment which occurred a month 

• The inspector determines the actuation was caused by a

inadequate site procedure written six years ago.

• The potential cross-cutting aspect is H.2(c) as the proced

not adequate.

• Since the cause of the performance deficiency occurred s

ago when the inadequate procedure was written the causreflective of current performance.

• If, however, the licensee had an opportunity, within appro

the last two years, to review the technical content of the pand could reasonably have been expected to identify the 

procedural inadequacy then the cause of the performancdeficiency (H.2(c)) would be considered current performa
IMC0612 - continued

• Clarifying guidance on relationship betwe

performance deficiency and cross-cutting aspects

• Augmenting guidance for documentation 

cross-cutting aspects

• Developing guidance to assign cross-cut

aspects to findings with multiple example

• Providing additional documentation guida

when cross-cutting aspect not assigned
IMC0612 - continued• Opportunity for external stakeholder 

questions and initial comments
IP71152 – Identification and Resoluof Problems• Clarify NRC review of licensee safety cu

assessment also to develop overall biennteam safety conscious work environment assessment

• Will evaluate adequacy of licensee corre

actions to address safety culture assessmissues

• Safety conscious work environment 

performance assessment insights gained through NRC interviews and insights from 

licensee safety culture assessment
IP71152 – Identification and resolutproblems - continued• Reference applicable IP95003 evalu

criteria for use when using IP71152 follow-up on request by NRC for licesafety culture assessment
IP71152 – Identification and resolutproblems - continued• Opportunity for external stakeholder 

questions and initial comments
Open Discussions• Opportunity for external stakeholder 

questions and initial comments
Follow-up Comments• Comments in 4 weeks (by May 15th

• E-mail to: robert.gramm@nrc.gov

• Snail mail to:USNRCAttn: Robert Gramm O11A11Washington, DC 20555
Next Actions• Another public meeting [date TBD]• Provide draft IMC0305 cross-cutting 

components and aspects 

• Provide draft IMC0612 (safety cultu

related)

• Provide IP95001, IP95002, and IP7

drafts
Closing