Monday, May 17, 2010

How Do We Know? Dave Collins, Millstone, Dominion and the NRC

This week the issues being raised by former Dominion engineer David Collins* regarding safety culture at Millstone are receiving increased attention. It appears David is raising two general issues: (1) Is Dominion's safety culture being eroded due to cost and competitive pressures and (2) is the NRC being effective in its regulatory oversight of safety culture?

So far the responses of the various players are along standard lines. Dominion contends it is simply harvesting cost efficiencies in its organization without compromising safety and specific problems are isolated events. The NRC has referred the issues to its Office of Investigation thus limiting transparency. INPO will not comment on its confidential assessments of nuclear owners.

What is one to make of this? First we have no special insights into the bases for the issues being raised by Collins. We have interacted with him in the past on safety culture issues and he is clearly a dedicated and knowledgeable individual with a strong commitment to nuclear safety culture. Thus we would be inclined to give his allegations serious consideration.

On the broader issues we see both opportunities and risks. We have emphasized cost and competitive pressures as a key to understanding how safety culture must balance multiple priorities to assure safety. What we do not see at the moment is how Dominion, the NRC or INPO would be able to determine whether, or to what extent, such pressures might be impacting decisions within Dominion. We doubt whether current approaches to assessing safety culture can be determinative; e.g., safety culture surveys, NRC performance indicators, or INPO assessments. In addition a plant-centric focus is unlikely to reveal systemic interactions or top-down signals that may result in decisional pressure at the plant levels. Recall that a significant exogenous pressure cited in the space shuttle Challenger accident was Congressional political pressure.

So while we understand the nature of the processes underway to evaluate Collins’ issues, it would be helpful if any or all the organizations could explain their methods for assessing these type of issues and the objective evidence to be used in making findings. The risk at this point is that the industry and NRC appear to be more focused on negating the allegations than in taking a hard look at their possible merits, including how exactly to evaluate them.

* Follow the link below for an overview of Collins' issues and other parties' responses.

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