December 1, 2005 

MEMORANDUM TO: Luis A. Reyes 

Executive Director for Operations 

FROM: Stephen D. Dingbaum/RA/

Assistant Inspector General for Audits 

SUBJECT: STATUS OF RECOMMENDATIONS: AUDIT OF NRC 

BASELINE INSPECTION PROGRAM (OIG-05-A-06) 

REFERENCE: DIRECTOR, OFFICE OF NUCLEAR REACTOR 

REGULATION, MEMORANDUM DATED OCTOBER 13, 

2005 

Attached is the Office of the Inspector Generals (OIG) analysis and status of 

recommendations as discussed in the agencys response dated October 13, 2005. 

Based on this updated response, recommendations 5, 6, 7 and 8 are now closed. 

Recommendations 1, 9 and 10 were closed previously. Recommendations 2, 3, and 4 

remain in a resolved status. Resolved recommendations will be closed when OIG 

receives information confirming that corrective action has been completed on each. 

Please provide an updated status of all recommendations by May 31, 2006. 

If you have any questions or concerns, please call me at 415-5915. 

Attachment: Status of Recommendations 

 cc: W. Dean, OEDO 

M. Malloy, OEDO 

P. Tressler, OEDO 
Audit Report 

Audit of NRC Baseline Inspection Program 

OIG-05-A-06 

Status of Open Recommendations 

Recommendation 2: Develop guidance on how to identify human performance trends and how 

that information should be integrated into the reactor oversight process 

(ROP). 

Agency’s Updated Response 

Of October 13, 2005: 

Enhancements to the ROP treatment of cross-cutting issues to more 

fully address safety culture are being made as a result of the Staff 

Requirements Memorandum (SRM)/SECY-04-0111, “Recommended 

Staff Actions Regarding Agency Guidance in the Areas of Safety 

Conscious Work Environment and Safety Culture,” dated August 30, 

2004. In response to the SRM, the Agency established the Safety 

Culture Working Group with the goal of enhancing the Agency’s 

evaluation of a licensee’s safety culture through the Reactor Oversight 

Process’ (ROP) treatment of cross-cutting issues and inspection 

procedures. 

The Safety Culture Working Group developed the Safety Culture 

Response Plan [ML052150352] to identify activities in support of the 

Commission’s SRM. Human performance, an ROP cross-cutting area, 

is an important part of Safety Culture and will be evaluated and 

assessed as part of this effort to enhance the ROP. In general, the 

Response Plan indicates that the Safety Culture Working Group will (1) 

identify Safety 

Culture Attributes and Elements, and associated Inspection Information 

and Measures, (2) determine if they are currently included within the 

ROP Cross Cutting Areas or the inspection procedures, (3) propose 

modifications to enhance the ROP to more fully address safety culture 

and (4) train NRC inspectors on the enhanced ROP processes. 

In a letter to OIG dated July 26, 2005, we stated that the target date for 

developing an action plan to address Recommendation 2, was 

December 31, 2005. The staff believes that the Safety Culture 

Response Plan will address OIG’s recommendation by assessing the 

human performance cross-cutting area and identifying inspection 

information and measures to objectively assess this area to provide 

insights into a licensee’s safety culture. Hence the Response Plan 

[ML052150352] is submitted as our action plan in support of 

Recommendation 2. 

Our target date for completing this action remains September 28, 2007.
OIG Analysis: Based on the agencys response and the additional information provided 

at an October 31, 2005 meeting with NRR staff, OIG agrees that progress 

is being made to bring this recommendation to closure. OIG will close 

this recommendation when all actions are complete. 

Status: Resolved. 
Audit Report 

Audit of NRC Baseline Inspection Program 

OIG-05-A-06 

Status of Open Recommendations 

Recommendation 3: Develop and implement guidance for documenting, tracking, and trending 

informal inspection issues. 

Agency’s Updated Response 

Of October 13, 2005: 

 No change since NRR memorandum dated July 26, 2005 

 [ML051880296]. 

 Our target date for completing this action is December 31, 2005.

OIG Analysis: Based on the agency’s response and a discussion of this issue with NRR 

staff on October 31, 2005, OIG continues to note the progress being 

made to bring this recommendation to closure. OIG will close this 

recommendation when the agency completes, and OIG has reviewed, the 

proposed actions. 

Status: Resolved. 
Audit Report 

Audit of NRC Baseline Inspection Program 

OIG-05-A-06 

Status of Open Recommendations 

Recommendation 4: Define effectiveness as it pertains to the ROP and establish 

performance measures and targets to demonstrate that the baseline 

inspection program meets that definition. 

Agency’s Updated Response 

Of October 13, 2005: 

 No change since NRR memorandum dated July 26, 2005 

 [ML051880296]. 

 Our target date for addressing the recommendation and completing the

 revision to IMC 0307 is December 31, 2005.

OIG Analysis: The agency’s proposed actions to address this recommendation were 

discussed in detail during a meeting between NRR and OIG staff on 

October 31, 2005. Based on that discussion, OIG acknowledges the 

further progress made in efforts to bring this recommendation to closure. 

OIG will close this recommendation once the proposed revisions to IMC 

0307 are completed and OIG has reviewed the updated version. 

Status: Resolved. 
Audit Report 

Audit of NRC Baseline Inspection Program 

OIG-05-A-06 

Status of Open Recommendations 

Recommendation 7: Provide guidance for vendor-specific training in resident inspector training 

requirements. 

 

Agency’s Updated Response 

Of October 13, 2005: 

 We recognize the importance of training resident inspectors to 

 understand the specific reactor technology at their plants. The staff 

developed a feedback form (1245-850) to address this 

recommendation. In May 2005, the IMC 1245 management steering 

group (MSG), consisting of regional division and deputy division 

directors and the program office branch chief, discussed the feedback 

form. The MSG decided to revise IMC 1245 to require vendor-specific 

training for operations inspectors and that the training be completed 

within 2 years of the assignment to a new location. The 2 year 

timeframe was selected based on the availability of some of the courses 

(some courses are only taught once per year) and the need for resident 

coverage (7 weeks away from the site is a significant commitment and 

the potential need for backfill coverage should be considered). 

On September 2, 2005, we issued a revision to IMC 1245 (Change 

Notice 05-024) [ML052580111] to require that the vendor-specific 

training be completed within 2 years of assignment. 

Awaiting OIG decision on closure.

OIG Analysis: NRR staff provided OIG with a copy of the revision to IMC 1245 at a 

meeting on October 31, 2005. During subsequent discussion, OIG 

acknowledged that the limited availability of training courses and the need 

to backfill for resident inspectors attending a course are key factors in the 

2-year timeframe allowed for meeting this new requirement. However, 

OIG remains concerned with having resident inspectors on-site for up to 2 

years without the necessary, and now required, vendor-specific training. 

Nonetheless, the agency’s completed revisions to IMC 1245 satisfied the 

actions necessary to close this recommendation. 

Status: Closed. 
Audit Report 

Audit of NRC Baseline Inspection Program 

OIG-05-A-06 

Status of Open Recommendations 

Recommendation 8: Improve baseline inspection program guidance to include: 

 a. direction for implementing a baseline inspection program 

 completion tracking process using RPS (Reactor Program 

 System) to collect inspection completion data at a plant level 

and in real-time, 

 b. how to document completion and sample sizes in inspection 

 reports, and 

 c. whether performance of one inspection procedure sample can 

 be counted as a sample for another. 

 

Agency’s Updated Response 

Of October 13, 2005: 

 a. Closed. OIG documented closure of part a of this 

 recommendation in a memorandum from Stephen D. Dingbaum 

 to Luis A. Reyes, dated September 16, 2005 [ML052630188]. 

 b. We have revised IMC 0612 to require sample sizes be stated as

 part of inspection documentation. The revised guidance requires

 inspectors to identify what was inspected and how many 

 samples were inspected. 

 The revision to IMC 0612 was issued on September 30, 2005 

 (Change Notice 05-028) [ML052730498]. 

 

 Awaiting OIG decision on closure. 

 c. Closed. OIG documented closure of part c of this 

 recommendation in a memorandum from Stephen D. Dingbaum 

 to Luis A. Reyes, dated September 16, 2005 [ML052630188].

 

OIG Analysis: At a meeting on October 31, 2005, NRR staff provided OIG with a copy of 

the revision to IMC 0612, effective 9/30/05. Upon OIG review, the 

agency’s completed revision to IMC 0612 satisfies the action necessary 

to close subpart 8b of this recommendation. Therefore, recommendation 

8 is now closed in its entirety. 

Status: Closed.