Thursday, September 16, 2010

Missing the Mark at SONGS

In our September 13, 2010 post on the current situation at SONGS we commented on the (in our opinion) undue focus on “leadership” as the sine qua non of safety culture.  Delving into the details of the most recent NRC inspection report* we came across another perplexing organizational response.  This time the issue was deliberate non-compliance.  While deliberate violations do not often get a lot of visibility, we find them potentially useful for illustrating safety culture dynamics.

First the SONGS experience.  Recall that it was a series of deliberate violations by fire watch personnel in the 2001-2006 time frame that started to crystallize safety culture concerns.  To address the problem, SCE committed to providing Corporate Ethics training to managers, supervisors and other specified employees.  The training was completed in 2008.  In 2009 additional ethics training was given to all employees including a SONGS-specific case study.  In addition monitoring programs were enhanced to better detect deliberate violations.

How effective was the training?  As reported in the NRC inspection report, between January 2008 and mid-2010, nine additional instances of deliberate non-compliances were identified.  The inspection report went on to say: “In response to these nine deliberate non-compliances, the licensee performed an Apparent Cause Evaluation….This evaluation identified the need to continue the training and monitoring programs which were developed in response to the Confirmatory Order.”

Did the NRC agree?  “The inspectors determined that this large number of deliberate non-compliances indicated that training on ethics and the disciplinary policy had not been fully effective in eliminating deliberate non-compliances.”  But in a bewildering twist, the NRC goes on to sign off on the issue because actions taken to detect and address deliberate violations have been effective...and the licensee intended to continue taking actions to prevent further instances from occurring. 

Perhaps both SCE and the NRC might have found our recent posts on current academic thinking on the subject of teaching ethics to be of value.  The Yale School of Management’s authors [see our August 30,2010 post] indicated: the concern arises when values are taught in the abstract and reliance is placed on commitments to high ethics without the contextual conflicts that will arise in the real world.  And the MIT article cited in our September 1, 2010 post bluntly reminds us “a decision necessarily involves an implicit or explicit trade-off of values.”  and that companies typically drill employees on values statements and codes of conduct, which have a more “symbolic than instrumental effect”.

We don’t have access to the ethics training provided by SCE but our suspicion is that it probably misses the target in the manner described in these management papers.  In the case of deliberate violations can there be any question that a trade-off of values is occurring?  And if trade-offs are occurring, then one has to ask, Why?  If situational forces are driving behavior, and training was not effective the first time, will repeating the training produce a different result?  

* Letter dated Aug 30, 2010 from R.E. Lantz (NRC) to R.T. Ridenoure (SCE), subject "SAN ONOFRE NUCLEAR GENERATING STATION – NRC FOCUSED BASELINE INSPECTION OF SUBSTANTIVE CROSS-CUTTING ISSUES INSPECTION REPORT 05000361/2010010 and 05000362/2010010," ADAMS Accession Number ML102420696.

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