View source for IMC 0310, Aspects within the Cross-Cutting Areas

[[name::Aspects within the Cross-Cutting Areas]]

* [[Issue date::02/25/19]] - [[URL::https://www.nrc.gov/docs/ML1901/ML19011A360.pdf]]

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NRC INSPECTION MANUAL IRAB
INSPECTION MANUAL CHAPTER 0310
ASPECTS WITHIN THE CROSS-CUTTING AREAS

== 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.”

== 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.

== 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.

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.

== 0310-06 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 crosscutting 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) ===
H.1 Resources: Leaders ensure that personnel, equipment, procedures, and other
resources are available and adequate to support nuclear safety (LA.1).
H.2 Field Presence: Leaders are commonly seen in the work areas of the plant observing,
coaching, and reinforcing standards and expectations. Deviations from standards and
expectations are corrected promptly. Senior managers ensure supervisory and
management oversight of work activities, including contractors and supplemental
personnel1
(LA.2).
H.3 Change Management: Leaders use a systematic process for evaluating and
implementing change so that nuclear safety remains the overriding priority (LA.5).
H.4 Teamwork: Individuals and work groups communicate and coordinate their activities
within and across organizational boundaries to ensure nuclear safety is maintained
(PA.3).
H.5 Work Management: The organization implements a process of planning, controlling,
and executing work activities such that nuclear safety is the overriding priority. The
work process includes the identification and management of risk commensurate to the
work and the need for coordination with different groups or job activities2
(WP.1).
H.6 Design Margins: The organization operates and maintains equipment within design
margins. Margins are carefully guarded and changed only through a systematic and
rigorous process. Special attention is placed on maintaining fission product barriers,
defense-in-depth, and safety related equipment (WP.2).
H.7 Documentation: The organization creates and maintains complete, accurate and upto-date documentation (WP.3).
H.8 Procedure Adherence: Individuals follow processes, procedures, and work
instructions (WP.4).
H.9 Training: The organization provides training and ensures knowledge transfer to
maintain a knowledgeable, technically competent workforce and instill nuclear safety
values (CL.4).
H.10 Bases for Decisions: Leaders ensure that the bases for operational and
organizational decisions are communicated in a timely manner (CO.2).
H.11 Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks
are evaluated and managed before proceeding (QA.2).
H.12 Avoid Complacency: Individuals recognize and plan for the possibility of mistakes,
latent issues, and inherent risk, even while expecting successful outcomes.
Individuals implement appropriate error reduction tools3
(QA.4).
H.13 Consistent Process: Individuals use a consistent, systematic approach to make
decisions. Risk insights are incorporated as appropriate (DM.1).
H.14 Conservative Bias: Individuals use decision making-practices that emphasize prudent
choices over those that are simply allowable. A proposed action is determined to be
safe in order to proceed, rather than unsafe in order to stop (DM.2).

1 Adds language from LA.2 example 1 to clarify that this is the appropriate designation for oversight of contractors
2 Adds language from WP.1 example 1 to clarify that this aspect fully retains what was previously included in H.3(b)
3
Incorporates language from QA.4 example 5 to clarify that H.12 is the appropriate designation for issues involving a
failure to use human error reduction techniques that were previously included under H.4(a)

=== 06.02 Problem Identification and Resolution (P) ===
P.1 Identification: The organization implements a corrective action program with a low
threshold for identifying issues. Individuals identify issues completely, accurately,
and in a timely manner in accordance with the program (PI.1).
P.2 Evaluation: The organization thoroughly evaluates issues to ensure that resolutions
address causes and extent of conditions commensurate with their safety significance
(PI.2).
P.3 Resolution: The organization takes effective corrective actions to address issues in a
timely manner commensurate with their safety significance (PI.3).
P.4 Trending: The organization periodically analyzes information from the corrective
action program and other assessments in the aggregate to identify programmatic and
common cause issues (PI.4).
P.5 Operating Experience: The organization systematically and effectively collects,
evaluates, and implements relevant internal and external operating experience in a
timely manner (CL.1).
P.6 Self-Assessment: The organization routinely conducts self-critical and objective
assessments of its programs and practices (CL.2).

=== 06.03 Safety Conscious Work Environment (S) ===
S.1 SCWE Policy: The organization effectively implements a policy that supports
individuals’ rights and responsibilities to raise safety concerns, and does not tolerate
harassment, intimidation, retaliation, or discrimination for doing so (RC.1).
S.2 Alternate Process for Raising Concerns: The organization effectively implements a
process for raising and resolving concerns that is independent of line management
influence. Safety issues may be raised in confidence and are resolved in a timely and
effective manner (RC.2).
S.3 Free Flow of Information: Individuals communicate openly and candidly, both up,
down, and across the organization and with oversight, audit, and regulatory
organizations (CO.3).
Issue Date: 02/25/19 6 0310

=== 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.
X.1 Incentives, Sanctions, and Rewards: Leaders ensure incentives, sanctions, and
rewards are aligned with nuclear safety policies and reinforce behaviors and outcomes
that reflect safety as the overriding priority (LA.3).
X.2 Strategic Commitment to Safety: Leaders ensure plant priorities are aligned to reflect
nuclear safety as the overriding priority (LA.4).
X.3 Roles, Responsibilities, and Authorities: Leaders clearly define roles, responsibilities,
and authorities to ensure nuclear safety (LA.6).
X.4 Constant Examination: Leaders ensure that nuclear safety is constantly scrutinized
through a variety of monitoring techniques, including assessments of nuclear safety
culture (LA.7).
X.5 Leader Behaviors: Leaders exhibit behaviors that set the standard for safety (LA.8).
X.6 Standards: Individuals understand the importance of adherence to nuclear standards.
All levels of the organization exercise accountability for shortfalls in meeting standards
(PA.1).
X.7 Job Ownership: Individuals understand and demonstrate personal responsibility for
the behaviors and work practices that support nuclear safety (PA.2).
X.8 Benchmarking: The organization learns from other organizations to continuously
improve knowledge, skills, and safety performance (CL.3).
X.9 Work Process Communications: Individuals incorporate safety communications in
work activities (CO.1).
X.10 Expectations: Leaders frequently communicate and reinforce the expectation that
nuclear safety is the organization’s overriding priority (CO.4).
X.11 Challenge Assumptions: Individuals challenge assumptions and offer opposing views
when they think something is not correct (QA.3).
X.12 Accountability for Decisions: Single-point accountability is maintained for nuclear
safety decisions (DM.3).

Exhibit 1 – Cross-Reference from Common Language Attributes to New Cross-Cutting Aspects
Common Language
Attribute4
New Cross-Cutting
Aspect
LA.1 H.1
LA.2 H.2
LA.3 X.1
LA.4 X.2
LA.5 H.3
LA.6 X.3
LA.7 X.4
LA.8 X.5
PI.1 P.1
PI.2 P.2
PI.3 P.3
PI.4 P.4
PA.1 X.6
PA.2 X.7
PA.3 H.4
WP.1 H.5
WP.2 H.6
WP.3 H.7
WP.4 H.8
CL.1 P.5
CL.2 P.6
CL.3 X.8
CL.4 H.9
RC.1 S.1
RC.2 S.2
CO.1 X.9
CO.2 H.10
CO.3 S.3
CO.4 X.10
QA.2 H.11
QA.3 X.11
QA.4 H.12
DM.1 H.13
DM.2 H.14
DM.3 X.12

4 NUREG-2165 defines additional attributes beyond those included in the table (e.g., WE.1, WE.2, WE.3,
WE.4, and QA.1). These attributes are not being used for ROP applications.
Issue Date: 02/25/19 8 0310
Exhibit 2 – Cross-Reference from Original Cross-Cutting Aspects to New Cross-Cutting Aspects
Old Cross-Cutting
Aspect
New Cross-Cutting
Aspect
H.1(a) H.13
H.1(b) H.14
H.1(c) H.10
H.2(a) H.6
H.2(b) H.9
H.2(c) H.7
H.2(d) H.1
H.3(a) H.5
H.3(b) H.4, H.5
H.4(a) H.11, H.12
H.4(b) H.8
H.4(c) H.2
P.1(a) P.1
P.1(b) P.4
P.1(c) P.2
P.1(d) P.3
P.1(e) S.2
P.2(a) P.5
P.2(b) P.5
P.3(a) P.6
P.3(b) P.4
P.3(c) P.6
S.1(a) S.1, S.3
S.1(b) S.2
S.2(a) S.1
S.2(b) S.1
S.2(c) S.1
O.1(a) X.1
O.1(b) H.2
O.1(c) X.6
O.2(a) H.9
O.2(b) X.8
O.3 H.3
O.4(a) S.1
O.4(b) H.9
O.4(c) X.2
O.4(d) X.10
Issue Date: 02/25/19 Att1-1 0310
Attachment 1 – Revision History for IMC 0310
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion
Date
Comment and
Feedback Resolution
Accession Number
(pre-Decisional, NonPublic Information)
C1 ML100290993
02/23/10
CN 10-006
Initial Issuance of IMC. Commitment carried
forward from IMC 0305 to enhance ROP to more
fully to address safety culture (SRM 04-0111)
N/A N/A
ML091480473
10/28/11
CN 11-023
Revised definition of Cross Cutting Aspect (FF
0310-1558) and Updated Formatting for improved
usability (no red line for formatting changes, FF
0310-1478).
N/A N/A
ML13351A028
12/19/13
CN 13-029
Revised cross-cutting aspects to align with the
safety culture common language attributes and
the Commission’s safety culture policy statement.
Yes, completed
November and
December 2013
ML14337A018
12/04/14
CN 14-029
Editorial revision to provide a reference and link to
NUREG-2165, “Safety Culture Common
Language” based on FBF 0310-2035.
N/A ML14321A004
0310-2035
ML19011A360
02/25/19
CN 19-008
Editorial revisions based on title change to IMC
0612 and other edits per the NRC Style Guide,
NUREG-1379
N/A N/A
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