1

1

Meeting On Draft Enhancements to 

Reactor Oversight Process Safety 

Culture Guidance

with ROP Task Force 

May 14, 2008

2

Purpose

• Provide drafts of safety culture related 

changes to ROP guidance documents 

(IMC0612 and IP71152) 

• Provide a forum for external stakeholder 

clarifying questions and initial comments

• To discuss next steps including 

opportunity for follow-up external 

stakeholder comments
2

3

Success Statement for Meeting

• Open dialogue about draft working level 

approaches

• Obtain initial external stakeholder 

questions and comments

• Provide external stakeholders with 

sufficient information to help develop 

follow-up comments 

4

Overall ROP Safety Culture Plan

• Considering lessons learned over 18-month 

implementation 

• General description is in 2007 ROP self-assessment 

Commission paper (SECY-08-0046)

• Seeking to identify options to improve effectiveness and 

efficiency of ROP guidance related to safety culture

• Interacting with internal and external stakeholders 

• Plan to roll out changes by the end of August 08
3

5

Sharing Working Level Documents

• Options are still being developed

• Information reflects only working level 

draft products

• Need for NRC management reviews

• Need for consideration of external 

stakeholder initial and follow-up feedback

• All current ROP provisions remain in 

effect until formally changed!

6

Sharing Working Level Documents -

continued

• Follow-up comment period – June 27th

• Staff will consider comments received 

and revise guidance as deemed 

appropriate

• Documents will proceed through internal 

review and concurrence process

• Resolution of comments will be made 

available
4

7

IMC0612

• Proposed changes to IMC0612 resulting 

from NRC cross-cutting review and audit 

of sample inspection reports

• IMC0612 will be revised as-needed 

consistent with any related IMC0305 

changes (potential for tagging findings 

with cross-cutting components)

8

IMC0612- continued

• Adding guidance for determining whether 

cross-cutting aspect is reflective of 

current performance (App. B page B-7)

• Decision cannot be made solely based 

upon the time when the performance 

deficiency or event occurred

• Need to determine when the cause of the 

problem occurred
5

9

IMC0612- continued

Questions for considering if the cross-cutting aspect is 

reflective of current performance:

• When did the performance deficiency or event occur?

• If the performance deficiency or event was the result of 

a latent issue, when did the cause of the performance 

deficiency occur?

• If the performance deficiency or event was the result of 

a latent issue, did the licensee have reasonable 

opportunities to identify the problem?

• Have programs, processes or organization changed 

such that the problem would not reasonably occur 

today?

10

IMC0612 - continued

• Clarifying guidance on relationship 

between performance deficiency and 

cross-cutting aspects (pages 1, 3, 7, 

Appendix B page B-6)

• Augmenting guidance for documentation 

of cross-cutting aspects (page 13)

• Developing guidance for assigning crosscutting aspects to findings with multiple 

examples (page 11, App. B page B-7)
6

11

IMC0612 - continued

• Provide feedback and transparency if 

assigned cross-cutting aspect changes 

(page 9, 22)

• Providing additional documentation 

guidance when cross-cutting aspect not 

assigned (page 13, 21)

• Strengthened controls for consideration 

of multiple cross-cutting aspects (App. B 

page B-6)

12

IMC0612 - continued

• Opportunity for external stakeholder 

questions and initial comments
7

13

NRC Follow-up of Safety Culture Assessments

1) evaluation of the third-party assessment 

methodology, 2) evaluate the licensee’s evaluation 

of results and adequacy of corrective action 

plans/actions, 3) perform NRC graded safety culture 

assessment

IP95003 (new 

graded approach) 

In Multiple/repetitive Degraded 

Cornerstone column of the ROP 

action matrix

Licensee third 

party assessment

4

1) limited review of how the safety culture 

assessment was performed, 2) primary focus on the 

licensee’s evaluation of results and adequacy of 

corrective action plans/actions

IP71152 with 

reference to 

relevant IP95003 

guidance (new)

3rd consecutive repetitive PI&R 

substantive cross-cutting issue

OR

IP95002 inspection identified 

that safety culture components 

not properly evaluated by 

licensee

Licensee 

independent 

assessment

3

1) limited review of how the safety culture 

assessment was performed, 2) primary focus on the 

licensee’s evaluation of results and adequacy of 

corrective action plans/actions

IP71152 with 

reference to 

relevant IP95003 

guidance (new)

3rd consecutive repetitive 

human performance or SCWE 

substantive cross-cutting issue

Licensee selfassessment 2

1) how has licensee handled results from PI&R 

perspective, 2) derive insights for SCWE review

IP71152 (existing) 

biennial team 

inspection

Periodic licensee None, licensee initiated

self-initiated 

1

NRC Draft NRC Review Focus 

Review Guidance 

Location 

Trigger for NRC request for 

licensee to perform a SC 

assessment 

Type of Licensee 

Safety Culture 

Assessment 

Case

14

IP71152 – Identification and Resolution 

of Problems

• Considering locating guidance about 

follow-up on a NRC requested licensee 

safety culture assessment in another IP

• Possibly a new IP in 2515 Appendix C 

since rarely/infrequently used

• Providing draft 71152 safety culture 

assessment follow-up guidance for 

comment
8

15

IP71152 – Identification and Resolution 

of Problems - continued

• Will evaluate adequacy of licensee corrective 

actions to address periodic self-initiated safety 

culture assessment issues (page 13)

• Clarify NRC review of licensee safety culture 

assessment also to develop overall biennial 

team safety conscious work environment 

performance assessment (page 16 and 17)

• Safety conscious work environment 

performance assessment insights gained 

through NRC interviews and insights from 

licensee safety culture assessment (page 16)

16

IP71152 – Identification and resolution of 

problems - continued

• Reference applicable IP95003 evaluation 

criteria for use when using IP71152 to 

follow-up on request by NRC for licensee 

safety culture assessment (page 13-14)

• Limited sample review of licensee safety 

culture assessment scope, methodology, 

and tools.
9

17

IP71152 – Identification and resolution of 

problems - continued

Focus of NRC review is on: 

• The results of the licensee’s safety culture 

assessment

• The licensee’s evaluation of the assessment 

results

• The licensee’s plans to address the 

weaknesses identified

• The licensee’s progress in implementing 

effective actions to address the weaknesses

18

IP71152 – Identification and resolution of 

problems - continued

• Opportunity for external stakeholder 

questions and initial comments
10

19

Follow-up Comments

• Comments by June 27th

• E-mail to: robert.gramm@nrc.gov

• Mail to:

USNRC

Attn: Robert Gramm O11A11

Washington, DC 20555

20

IMC0305 - next actions 

• Follow-on public meeting [TBD]

• Provide draft IMC0305 cross-cutting 

components and aspects 

• Request external stakeholder comments 

by June 27th on IMC0305 draft material 

presented at April ROP meeting

• Requested external stakeholder 

comments by May 23rd on IP95003 draft
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21

Closing