**NRC INSPECTION MANUAL**	IRAB

INSPECTION MANUAL CHAPTER 0310

ASPECTS WITHIN THE CROSS-CUTTING AREAS

Table of Contents0310-01	PURPOSE	10310-02	OBJECTIVES	10310-03	APPLICABILITY	10310-04	DEFINITIONS	1	04.01	Cross-Cutting Area	1	04.02	Cross-Cutting Aspect	1	04.03	Nuclear Safety Culture	10310-05	RESPONSIBILITIES AND AUTHORITIES	1	05.01	Executive Director for Operations (EDO)	1	05.02	Director, Office of Nuclear Reactor Regulation (NRR)	1	05.03	Regional Administrators	1	05.04	Director, Division of Inspection and Regional Support (NRR/DIRS)	2	05.05	Director, Office of Nuclear Security and Incident Response (NSIR)	2031006	 CROSS-CUTTING AREAS AND ASPECTS	2	06.01		Human Performance (H)	4	06.02		Problem Identification and Resolution (P)	5	06.03		Safety Conscious Work Environment (S) 	5	06.04		Supplemental Cross-Cutting Aspects (X)	6Exhibit 1 – Cross-reference from Common Language Attributes to New Cross-Cutting Aspects	7Exhibit 2 – Cross-reference from Original Cross-Cutting Aspects to New Cross-Cutting Aspects	8

Issue Date:  02/25/19	i	0310

# 0310-01	PURPOSE

The purpose of this Inspection Manual Chapter (IMC) is to provide a listing of cross-cutting aspects that can be assigned to inspection findings, in accordance with IMC 0612, “Issue Screening.”  Assigned cross-cutting aspects, which are generally associated with the root causes of performance deficiencies, are evaluated to identify cross-cutting themes, which are assessed as outlined in IMC 0305, “Operating Reactor Assessment Program.” 

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# 0310-02	OBJECTIVES

To define the cross-cutting aspects that are associated with inspection findings and used in the evaluation conducted to identify cross-cutting themes.

0310-03	APPLICABILITY 

The cross-cutting aspects described in this IMC are applicable to inspection findings identified through the implementation of the NRC inspection program described in IMC 2515, “Light-Water Reactor Inspection Program-Operations Phase.”  The contents of this IMC do not restrict the NRC from taking any necessary actions to fulfill its responsibilities under the Atomic Energy Act of 1954 (as amended).  

0310-04	DEFINITIONS

04.01	Cross-Cutting Area.  Fundamental performance characteristics that extend across all of the Reactor Oversight Process (ROP) cornerstones of safety.  These areas are human performance, problem identification and resolution, and safety conscious work environment (SCWE).

04.02	Cross-Cutting Aspect.  The performance characteristic of a finding that is either the primary cause of the performance deficiency or the most significant contributing cause.

04.03	Nuclear Safety Culture.  The core values and behaviors resulting from a collective commitment by leaders and individuals to emphasize safety over competing goals, to ensure protection of people and the environment.

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# 0310-05	RESPONSIBILITIES AND AUTHORITIES  

05.01	Executive Director for Operations (EDO).  Oversees the activities described in this IMC.

05.02	Director, Office of Nuclear Reactor Regulation (NRR).  Implements the requirements of this IMC within NRR.

05.03	Regional Administrators.  Implement the requirements of this IMC within their respective regions.

Issue Date:  02/25/19	3	0310

05.04	Director, Division of Inspection and Regional Support (NRR/DIRS).  Collects feedback from the regional offices on IMC implementation for consideration as part of the ROP continuous improvement process.

05.05	Director, Office of Nuclear Security and Incident Response (NSIR).  Ensures uniform IMC implementation for security related inspection findings.

031006	 CROSS-CUTTING AREAS AND ASPECTS 

Cross-cutting areas contain the fundamental performance characteristics that extend across all of the ROP cornerstones of safety.  These areas are human performance (H), problem identification and resolution (P), and safety conscious work environment (S).  Within each cross-cutting area are aspects of performance related to that cross-cutting area.  

NUREG-2165, “Safety Culture Common Language,” describes the essential traits and attributes of a healthy nuclear safety culture.  NUREG-2165 is based on the common language that was agreed to by NRC staff members, industry representatives, and members of the public who participated in a series of workshops.  The common language was finalized during the 

January 2013 public workshop, and was documented in the enclosure to the meeting summary (Agency Document Access and Management System Accession No. ML13031A343).  The Institute for Nuclear Power Operations (INPO) has also published this common language in INPO 12-012, “Traits of a Healthy Nuclear Safety Culture.”  Selected attributes have been incorporated into this IMC to establish common terms for both the NRC and the nuclear industry.  The cross-cutting aspects in this manual chapter are defined consistent with the attributes in the common language document.  The common language has been well-vetted and approved, and therefore is not subject to change without going through a change to the NUREG.  In deciding which aspect is most appropriate to assign to an inspection finding, inspectors should reference the numerous relevant examples provided in the NUREG.

The NRC assigns cross-cutting aspects to inspection findings, in accordance with IMC 0612, “Issue Screening.”  The NRC reviews cross-cutting aspects for cross-cutting themes and potential cross-cutting issues, in accordance with IMC 0305, “Operating Reactor Assessment Program,” to provide licensees the opportunity to address performance issues before they result in more significant safety concerns.  Although the presence of CCAs or the assignment of a cross-cutting issue may be indicative of a potentially degraded safety culture, the NRC draws conclusions about safety culture based on the results of licensee and NRC safety culture assessments conducted by qualified staff, not based on the presence of CCAs or cross-cutting issues.

The “Supplemental Cross-Cutting Aspects” listed in Section 06.04 are not applied to inspection findings under the baseline inspection program.  However, these aspects are indicators of a healthy safety culture and should be considered for safety culture assessments performed or reviewed during supplemental inspections.  While they are important characteristics of safety culture, some attributes from NUREG-2165 are not included as cross-cutting aspects and are considered to be outside the scope of the reactor inspection program.  Exhibit 1 provides a cross-reference from the common language attributes to new cross-cutting aspects.  Exhibit 2 provides a cross-reference from the original cross-cutting aspects to the new cross-cutting 

aspects resulting from the common language initiative.  The common language attributes also are provided at the end of the descriptions in Sections 6.01 through 6.04, and are subsets of the following traits:  

· Leadership Safety Values and Actions (LA);

· Problem Identification and Resolution (PI);

· Personal Accountability (PA);

· Work Processes (WP);

· Continuous Learning (CL);

· Environment for Raising Concerns (RC);

· Effective Safety Communication (CO);

· Respectful Work Environment (WE);

· Questioning Attitude (QA); and

# · Decision Making (DM).

06.01	Human Performance (H)

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06.02	Problem Identification and Resolution (P)

06.03	Safety Conscious Work Environment (S)

06.04	Supplemental Cross-Cutting Aspects (X) 

The supplemental cross-cutting aspects are to be considered only when performing or reviewing safety culture assessments during the conduct of the supplemental inspections.

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# Exhibit 1 – Cross-Reference from Common Language Attributes to New Cross-Cutting Aspects 

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# Exhibit 2 – Cross-Reference from Original Cross-Cutting Aspects to New Cross-Cutting Aspects 

Attachment 1 – Revision History for IMC 0310

Issue Date:  02/25/19	Att1-1	0310