May 29, 2008 

MEMORANDUM TO: James W. Andersen, Chief 

 Performance Assessment Branch 

 Division of Inspection and Regional Support 

 Office of Nuclear Reactor Regulation 

FROM: Nathan Sanfilippo, Reactor Operations Engineer /RA/ 

 Performance Assessment Branch

 Division of Inspection and Regional Support 

 Office of Nuclear Reactor Regulation 

 

SUBJECT: SUMMARY OF THE REACTOR OVERSIGHT PROCESS WORKING 

 GROUP PUBLIC MEETING HELD ON MAY 14, 2008 

On May 14, 2008, the staff hosted the monthly Reactor Oversight Process (ROP) Working 

Group public meeting. The attendance list for the meeting is contained in Enclosure 1 and the 

agenda is contained in Enclosure 2. 

Discussions by the meeting attendees included: potential non-safety culture related changes to 

Inspection Manual Chapter (IMC) 0305, “Operating Reactor Assessment Program;” potential 

changes to IMC 0608, “Performance Indicator Program,” an update on the Task Interface 

Agreement (TIA) process; an update on NRC actions regarding RIS 2007-21, “Adherence to 

Licensed Power Limits;” potential changes to IMC 0612, “Power Reactor Inspection Reports;” 

and various proposed changes to Nuclear Energy Institute (NEI) 99-02, “Regulatory 

Assessment Performance Indicator Guidance.” 

Continuing previous months’ dialogue on non-safety culture related changes to IMC 0305, the 

staff presented more specific details on the upcoming revision. These included double counting 

in the action matrix, closing parallel white performance indicator and greater than green 

findings, the timing of findings leading to the repetitive degraded cornerstone column, and the 

timing of supplemental inspections. The staff is looking to make these changes in the 

August/September timeframe. Additional detail on these proposals will be distributed during the 

June ROP Monthly Meeting. 

The staff also discussed some longer-term considerations for IMC 0305. These considerations, 

which are currently not addressed in the upcoming revision to IMC 0305, included: whether 

substantive cross cutting issues be accounted for in the action matrix; whether precursors 

should be used in the assessment process; the definition of column 4; whether greater than 

green PIs that go in and out should be held open until the supplemental inspection is completed; 

whether greater than green PIs can be closed after the supplemental inspection is complete; 

and the link between traditional enforcement and the action matrix. 

CONTACT: Nathan Sanfilippo, DIRS/NRR 

 301-415-3951 
J. Andersen 

 

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NEI provided Enclosure 3 to propose changes to IMC 0305 addressing protracted performance 

indicator results. The staff will consider this information as it moves forward with draft changes 

to IMC 0305. 

NRC staff from the Division of Policy and Rulemaking discussed with the industry the Office of 

Nuclear Reactor Regulation’s (NRR) new Task Interface Agreement (TIA) process, NRR Office 

Instruction COM-106, Revision 3. Staff informed the industry that from a regulatory standpoint, 

a TIA is roughly equivalent to inspection guidance, and the focus of the NRR review is to add 

value by finding the applicable regulatory position that is within durable regulatory documents. 

The goal of the NRR TIA review is not to develop an NRC staff position that backfits new 

requirements upon the industry. 

Furthermore, the DPR staff informed the industry that enhancements to the COM-106 process 

were developed within Revision 3. These enhancements included a single point of contact for 

all TIAs (the TIA PM), a single management chain, new TIA metrics, and an innovative, 

streamlined method for accomplishing TIAs. Given these changes, and the year-long piloting 

process, the NRR staff has improved overall TIA effectiveness by focusing upon the applicable 

regulatory position and by improving timeliness from one-year reviews to reviews only 

encompassing a few days. In the conclusion of the DPR presentation, the two most recent TIAs 

completed by the NRC staff were shared with industry. These TIAs were completed within two 

weeks and one week, respectively, and are attached as Enclosure 4 and 5. 

NRC staff provided a status update of activities surrounding RIS 2007-21. The staff has 

reviewed draft guidance for plants that go above the maximum thermal power limits submitted 

by NEI, and has formally responded to NEI. The staff will conduct a public meeting on June 12, 

2008, to further discuss its proposed guidance. 

The staff then discussed a path forward to make changes and enhancements to IMC 0612. 

NRC markup of draft changes will be presented during a public meeting in August, with the 

intent to issue the revision by the end of 2008. IMC 0612 items which NEI has previously 

sought NRC consideration for revision will be addressed during the afternoon of the June ROP 

Monthly Meeting. 

The NRC staff presented potential changes to IMC 0608, “Performance Indicator Program,” 

which are attached as Enclosure 6. These changes are being developed to address how a 

plant coming out of extended shutdown – or a newly constructed plant – is transitioned into the 

performance indicator program. The changes to IMC 0608 were based on recent staff actions 

to incorporate Browns Ferry Unit 1 into the performance indicator program. The staff asked for 

working group comments on this proposal. 

Staff and industry then discussed various changes to NEI 99-02. The NRC staff introduced a 

whitepaper on proposed changes to the Alert and Notification System (ANS) performance 

indicator, which is included as Enclosure 7. This whitepaper addresses situations where the 

ANS could be preconditioned by conducting maintenance tests just prior to performance 

indicator reliability tests. The NEI emergency preparedness task group will review the NRC’s 

proposal and report back to the working group at the June ROP monthly meeting. 

Staff and industry then discussed clarifications to NEI 99-02 relating to the definition of “time of 

discovery” for the Mitigating Systems Performance Index (MSPI). The NRC proposed resolution 
J. Andersen 

 

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that was included as part of the April ROP Monthly Meeting summary was agreed upon by NEI. 

In June, this guidance change will be incorporated as an FAQ. 

The next topic involved the status of a proposed revision to the MSPI diesel generator mission 

time measurement. The industry continues to research what they feel is an appropriate 

algorithm to allow licensees to reduce their mission time from 24 hours. Once this algorithm is 

created, industry will bring this issue back to the ROP working group. 

NEI provided Enclosures 8 and 9 to propose clarifications to NEI 99-02 relating to MSPI failures 

due to human error, and maintenance-induced damage/issues found during post-maintenance 

testing prior to returning the component to functional status. Discussion ensued and the staff 

expressed concern over the overlap of these two proposals. Further investigation into the 

impacts of each of these proposals will be pursued by NRC and industry. These issues will be 

discussed at future ROP Monthly Meetings. 

NEI provided Enclosure 10 to introduce a proposed change to guidance on monitored 

components for the MSPI – specifically, whether control switches are counting within the 

component boundary in various situations. The staff will consider these changes and respond 

during the June ROP Monthly Meeting. 

NRC staff inquired about NEI plans for issuance of a revision to NEI 99-02. NEI responded that 

they plan to begin work on such a revision with a target to publish by the end of 2008. 

The attendees then discussed open performance indicator FAQs as provided by NEI in 

Enclosure 11. FAQs 76.0, 77.0, 78.1, 79.0, 79.2, 79.3, 81.0, and 81.1 were given final approval. 

FAQ 80.1 was discussed and no decision was made. FAQs 81.3 and 81.4 were introduced and 

discussed; however, no decision was made. 

The status of the open draft FAQs are as follows: 

TempNo. PI Topic Status Plant/ Co. 

76.0 IE03 Discovery of an Off-normal 

condition 

Final Approval Quad Cities 

77.0 IE03 Grassing Event Final Approval Salem 

78.1 IE03 Storm Induced 

Marine/Biological Intrusion 

Final Approval Diablo Canyon 

79.0 IE03 Over-Voltage due to 

Lightening 

Final Approval Robinson 

79.2 IE03 Threadfin Shad Run Final Approval Browns Ferry 

79.3 IE03 Historical Downpowers Final Approval Browns Ferry 

80.1 IE01 Reactor Power Indication Discussed Columbia 

81.0 EP01 ERO Assignment Final Approval Generic 

81.1 MS04 Run Hours Final Approval Generic 

81.3 IE03 Raccoon Intrusion Introduced 

and 

Discussed 

Grand Gulf 

81.4 IE03 Environmental FAQ Introduced 

and 

Generic 
J. Andersen 

 

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TempNo. PI Topic Status Plant/ Co. 

Discussed 

The date for the next meeting of the ROP Working Group is June 18, 2008. Future ROP 

monthly meeting dates include July 16, 2008, August 27, 2008, and September 24, 2008. 

The purpose of the meeting’s afternoon session was for the staff to provide draft changes in 

safety culture related Reactor Oversight Process (ROP) guidance documents and to obtain 

initial external stakeholder questions and comments. The presentation slides for this portion of 

the meeting are attached as Enclosure 12. The staff provided working drafts of IMC 0612, 

“Power Reactor Inspection Reports”, IMC 0612 Appendix B, “Issue Screening” and Inspection 

Procedure (IP) 71152, “Identification and Resolution of Problems.” The draft changes and the 

reasons for proposing the changes were discussed with the external stakeholders. These 

documents are attached as Enclosures 13, 14, and 15, respectively. 

The staff explained that contrary to the meeting agenda, that IP 95001, “Inspection of One or 

Two White Inputs In A Strategic Performance Area” and IP 95002, “Inspection for One 

Degraded Cornerstone Or Any Three White Inputs In a Strategic Performance Area” would not 

need to be discussed as the staff currently believes no safety culture related changes are 

necessary for those IPs to provide guidance on performing follow-up inspections of licensee 

safety culture assessments. The current staff thinking is that the follow-up inspection guidance 

can all be located in another IP, such as IP 71152. The staff additionally explained that the 

effort to re-write the safety culture components and aspects is still ongoing, and they were not 

ready to be shared with external stakeholders. The meeting date to share the component and 

aspect re-write is to be determined. 

The staff discussed draft safety culture related changes in IMC 0612 which were identified 

during an NRC audit of inspection report cross-cutting aspect documentation. The staff noted 

that the draft IMC 0612 changes will need to be aligned with any related changes that could 

result from the ongoing re-write of the cross-cutting components and aspects for IMC 0305, 

“Operating Reactor Assessment Program.” The staff outlined that the IMC 0612 draft changes 

are intended to provide amplified guidance for inspectors: to promote consistent documentation 

of the cross-cutting aspects throughout the inspection report sections; to make decisions on 

whether cross-cutting aspects are reflective of current performance or not; to clarify the 

distinction between performance deficiencies and cross-cutting aspects; to clarify that for Green 

findings with multiple examples, the examples share the same cross-cutting aspect; to briefly 

describe a decision to not assign a cross-cutting aspect to a finding; and to ensure that multiple 

cross-cutting aspects are only assigned in rare situations. 

The industry noted that a very high percentage of inspection findings are assigned cross-cutting 

aspects. The staff responded that the proposed guidance will assist in the determination of 

whether a cross-cutting aspect is reflective of current performance, which should help the staff 

make more consistent decisions. The staff also commented that the intent is not for all findings 

to have cross-cutting aspects assigned to them. 

Some of the initial stakeholder comments on the IMC 0612 draft changes included: 1) that the 

guidance for determining whether a cross-cutting aspect is reflective of current performance 

include that it has occurred within approximately two years; 2) questioned whether greater than 

Green findings could also have multiple examples that share the same cross-cutting aspect; 3) 
J. Andersen 

 

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that requiring inspectors to describe why they didn’t assign a cross-cutting aspect could lead the 

inspectors to defaulting to assigning cross-cutting aspects to essentially all findings; instead the 

inspector should simply document that cross-cutting aspects were considered and were 

determined not to be applicable (reason why does not need to be provided); 4) that the industry 

will provide a mark-up to improve the proposed wording for the cross-cutting aspect and 

performance deficiency definitions; 5) that the sample inspection report under development by 

the staff should include multiple examples of situations where performance deficiencies do not 

warrant assignment of cross-cutting aspects, particularly in cases where the cross-cutting 

aspect is reflective of current performance; and 6) that the draft guidance for documenting 

changes in assignment of cross-cutting aspects in section 11.06.b should be comparable in 

level of detail as that in section 06.01.f. 

The staff presented an overview of the various types of licensee safety culture assessments 

ranging from the periodic self-initiated assessments, to NRC requests for licensees to perform 

self-assessments or independent assessments, and finally an NRC request that a licensee 

perform a third party safety culture assessment. The staff provided an overview of the 

associated inspection procedure that would be utilized to perform follow-up inspections of the 

various types of licensee safety culture assessments. The staff explained that for periodic 

licensee self-initiated assessments that the NRC inspection focus in IP 71152 is on how the 

licensee handled the issues identified during the assessment. For self- and independent 

assessments the draft IP 71152 provides guidance referenced from IP 95003, “Supplemental 

Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple 

Yellow Inputs or One Red Input,” for the staff to perform a limited sample review of how the 

licensee conducted the safety culture assessment. The main focus of the staff’s review would 

be on the licensee handling of the issues identified by the assessment. The staff was asked if 

another utility not part of the licensee’s organization could conduct the third party safety culture 

assessment, and the staff agreed. [Additional note, staff clarification following the meeting: 

However in this situation, it is expected that the assessors from the other utility are appropriately 

qualified and this should be guided by the IP 95003 guidance on evaluating the qualifications of 

the safety culture assessment team.] 

For the draft IP 71152, the staff noted that options are still being considered to provide the 

safety culture follow-up inspection guidance in another IP, such as a new IP that could be 

included in IMC 2515, “Light-Water Reactor Inspection Program -- Operations Phase” Appendix 

C, “Special and Infrequently Performed Inspections.” In addition, the level of inspection 

resources to perform the safety culture follow-up inspection has not yet been determined. 

The staff reviewed proposed changes to IP 71152 not related to performing follow-up inspection 

of NRC requested licensee safety culture assessments. Draft changes are proposed to clarify 

that the biennial team inspection review of licensee self-initiated safety culture assessments is 

from the problem identification and resolution perspective. That is, evaluating the licensee’s 

handling of issues identified by the assessment. The staff was questioned whether it is 

considered necessary for all issues from the licensee’s safety culture assessment to be input 

into the 10 CFR 50, Appendix B quality assurance corrective action program. The staff agreed 

with the commenter that not all issues identified by a safety culture assessment are appropriate 

to be handled by the Appendix B corrective action program. The staff agreed that sensitive 

personnel issues for example could be handled through alternative site processes (e.g. an 

Employee Concerns Program). In general, the staff would be focusing on if the licensee took 

appropriate actions, which will vary depending on the circumstances, to address the issues 
J. Andersen 

 

- 6 -

identified by the assessment. The staff also discussed proposed guidance that the bi-ennial 

team inspection assessment of licensee performance in the Safety Conscious Work 

Environment (SCWE) area is developed through both insights from the staff’s SCWE interviews 

along with the staff’s review of the licensee’s safety culture assessment. 

The staff then explained the proposed changes to IP 71152 to include new guidance on how a 

follow-up inspection would be performed of NRC requested licensee self or independent safety 

culture assessments. This guidance references selected sections in IP 95003 that would be 

used. The staff would perform a limited review of the licensee safety culture assessment scope, 

methodology, and assessment tools. The primary focus of the staff’s evaluation would be on 

the results of the licensee’s safety culture assessment, the licensee’s evaluation of the results, 

the licensee’s plans to address any identified weaknesses, and the licensee’s progress to 

address the noted weaknesses. 

Some of the initial comments on the IP 71152 draft changes included: 1) the need for describing 

in a greater level of detail what the NRC inspectors would actually evaluate when performing a 

follow-up on a licensee self-assessment or independent assessment, 2) the need for a better 

understanding of what the NRC expectations are for a licensee self- or independent safety 

culture assessment and whether the IP 95003 expectations are appropriate for the different 

types of assessments, 3) that having the follow-up guidance in IP 71152 for self and 

independent licensee assessments could be confusing to inspectors when they are evaluating 

licensee self-initiated safety culture assessments during biennial team inspections, and 4) that 

better wording could be used to describe the added tools for following up on a substantive 

cross-cutting issue. 

The staff explained that at the current time, the major variable between a self, independent, and 

third party safety culture assessment is the degree of separation of the assessors from the site 

activities they are assessing. The staff indicated that the protocol for the licensee conducting 

the various assessments is thought to be very similar in terms of scope and the assessment 

methodology and tools used by the licensee. Several licensee participants noted that they 

would expect some variances between the different types of licensee safety culture 

assessments, as well as with the depth and scope of NRC follow-up for the different types of 

assessments. The stakeholders were asked to provide comments on the differences they 

would expect between the different types of licensee assessments as well as how NRC followup inspections would vary depending on assessment type. The staff suggested the industry 

initiative to develop standard methodology for safety culture assessments include guidance on 

this issue. 

The staff indicated their tentative plans to present the remaining ROP safety culture draft 

document changes (IMC 0305 safety culture components) during a yet to be determined ROP 

monthly public meeting. 

The staff indicated that the comment period for the IMC 0612 safety culture related draft 

changes and the IP 71152 draft changes will last until June 27, 2008. In addition, the final 

comment period for the previously discussed IMC 0305 material will end on June 27, 2008. 

 
J. Andersen 

 

- 7 -

The staff thanked the external stakeholders for their participation and constructive initial 

comments on the draft guidance document changes. 

Enclosures: 

1. Attendance List – May 14, 2008 

2. Agenda – May 14, 2008 

3. NEI Proposed Guidance Change to IMC 0305 to Address Protracted PI Results 

4. Palisades TIA 

5. Arkansas Nuclear One TIA 

6. NRC Proposed Additions to IMC 0608 

7. NRC Whitepaper on Proposed ANS PI Change 

8. NEI MSPI Human Error Whitepaper 

9. NEI Proposed Change to NEI 99-02 to Address Failures Identified During PMT 

10. NEI Proposal for MSPI Monitored Components 

11. FAQ Log 

12. Safety Culture Enhancements – Meeting Slides 

13. Proposed Markup to IMC 0612 

14. Proposed Markup to IMC 0612, Appendix B 

15. Proposed Markup to IP 71152 
J. Andersen - 7 -

The staff thanked the external stakeholders for their participation and constructive initial 

comments on the draft guidance document changes. 

Enclosures: 

1. Attendance List – May 14, 2008 

2. Agenda – May 14, 2008 

3. NEI Proposed Guidance Change to IMC 0305 to Address Protracted PI Results 

4. Palisades TIA 

5. Arkansas Nuclear One TIA 

6. NRC Proposed Additions to IMC 0608 

7. NRC Whitepaper on Proposed ANS PI Change 

8. NEI MSPI Human Error Whitepaper 

9. NEI Proposed Change to NEI 99-02 to Address Failures Identified During PMT 

10. NEI Proposal for MSPI Monitored Components 

11. FAQ Log 

12. Safety Culture Enhancements – Meeting Slides 

13. Proposed Markup to IMC 0612 

14. Proposed Markup to IMC 0612, Appendix B 

15. Proposed Markup to IP 71152 

DISTRIBUTION: 

PUBLIC

DRoberts 

ABoland DDube 

AVegel ACampbell DAyres 

GShear PAppignani IPAB Distribution 

CPederson DLew IRIB Distribution 

DChamberlain HChristensen RCaniano 

ISchoenfeld LWert MGamberoni 

JClifford KKennedy SWest 

TPruett RCroteau 

ADAMS Accession No.: Package - ML081440435 Memo - ML081440468 Enclosure 3 - 081440498 

 Enclosure 4 - ML081300096 Enclosure 5 - ML080300554 Enclosure 6 - ML081440500 

 Enclosure 7 - ML081440479 Enclosure 8 - ML081440501 Enclosure 9 - ML081440505 

 Enclosure 10 - ML081440521 Enclosure 11 – ML081440528 Enclosure 12 - ML081400363 

 Enclosure 13 - ML081330462 Enclosure 14 - ML081330485 Enclosure 15 – ML081290285 

OFFICE NRR/DIRS NRR/DIRS NRR/DIRS

NAME NSanfilippo TKobetz JAndersen

DATE 05/23/08 05/29/08 05/28/08

OFFICIAL RECORD COPY 
 ENCLOSURE 1 

ATTENDANCE LIST 

INDUSTRY/STAFF ROP PUBLIC MEETING 

May 14, 2008 

NAME AFFILIATION 

1 John Butler NEI 

2 Sue Simpson NEI 

3 Mike Cheok NRC 

4 Jeff Thomas Duke 

5 Duane Kanitz STARS 

6 Al Haeger Exelon 

7 Robin Ritzman FENOC 

8 Fred Mashburn TVA 

9 Bob Gramm NRC 

10 Jim Peschel FPL 

11 Bryan Ford Entergy 

12 Mike Case NRC 

13 Tim Kobetz NRC 

14 Nathan Sanfilippo NRC 

15 Julie Keys NEI 

16 Ken Heffner Progress 

17 Sean Peters NRC 

18 Bob Hanley Dominion 

19 Ned Tyler Constellation 

20 Glen Masters INPO 

21 Tim Kolb NRC 

22 Isabelle Schoenfeld NRC 

23 John Thompson NRC 

24 Jim Isom NRC 

25 Eric Bowman NRC 

26 Don Dube NRC 

27 Dave Midlik Southern Nuclear 

28 Gerald Sowers APS 

29 Roy Linthicum Exelon 

30 Doug McKinney SNC 

31 Patrick Boyle NRC 

32 Steve LaVie NRC 

33 Bob Kahler NRC 

34 David Allsopp NRC 

35 Carl Schulten NRC 

36 Chris Cauffman NRC 

37 Yeon-Ki Chung NRC 

38 Molly Keefe NRC 
- 2 - 

39 Bob Pascarelli NRC 

40 Mark Rendmeyer Centrec 

41 Jenny Weil McGraw-Hill 
 ENCLOSURE 2 

REACTOR OVERSIGHT PROCESS (ROP) 

MONTHLY PUBLIC MEETING 

AGENDA

May 14, 2008 - 9:00 AM – 4:00 PM – NRC OWFN Commissioners’ Hearing Room 

9:00 – 9:05 AM Introduction and Purpose of Meeting 

9:05 – 9:35 AM Discussion of Performance Assessment Branch Topics 

1. Possible changes to Inspection Manual Chapter (IMC) 0305, 

“Operating Reactor Assessment Program” – non-safety culture 

2. Other 

9:35 – 10:00 AM Reactor Inspection Branch Topics 

1. Regulatory Issue Summary (RIS) 2007-21 (update) 

2. General topics of interest in the inspection area 

3. Other 

10:00 – 10:30 AM Discussion of Performance Indicator Topics 

1. Potential NEI 99-02 guidance changes 

• MSPI time of discovery 

• MSPI mission time 

• MSPI EDG test failures 

• Maintenance-induced PMT issues 

• Environmental unplanned power changes 

• EP – Counting ERO participation for members in training 

• EP – Siren Preconditioning 

10:30 – 10:45 AM Break 

10:45 – 11:15 AM Performance Indicator Topics continued 

11:15 – 11:30 PM Future Meeting Dates, ROP Working Group Action List Status, and 

Future Topics 

11:30 – 11:45 AM Public Input 

11:45 – 12:45 PM Lunch 

12:45 – 1:45 PM Discussion of Open and New PI Frequently Asked Questions (FAQs) – 

Note topic may be moved before lunch if meeting is ahead of schedule 

The latest draft FAQs are located on the public web at 

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/draft_faqs.pdf 

This list is subject to change the day before the meeting based on 

availability of new draft FAQs provided by the Nuclear Energy Institute. 
- 2 - 

1:45 – 2:00 PM Break 

2:00 – 2:10 PM Introduction to Safety Culture Enhancements 

2:10 – 2:40 PM Discuss Draft IP 71152 and Initial External Stakeholder Comments 

2:40 – 3:00 PM Discuss Draft IMC 0612 Safety Culture Changes and Initial External 

Stakeholder Comments 

3:00 – 3:15 PM Discuss Draft IP 95002 and IP 95001 and Initial External Stakeholder 

Comments 

3:15 – 4:00 PM Opportunity for External Stakeholder Comments and NRC Request for 

Written Comments on Draft Revisions