Tuesday, January 18, 2011

ACRS and Safety Culture Policy (cont.)

Our previous post reported on the ACRS letter to the NRC endorsing the agency’s approach to developing a safety culture policy.*  We noted the concern of some ACRS members that the policy might be a back door method to impose regulatory requirements while avoiding the requirements of the regulatory process.

The dissenting ACRS members also raised some other interesting issues about the proposed policy.

First, they questioned whether the proposed traits were the most important ones in terms of their contribution to safety.  Why weren’t organizational and individual integrity, and technical competence included?  Good question.  After all, wasn’t an integrity shortfall at the heart of the misleading of the Vermont senate and the willful violations at San Onofre?

Second, they commented “[T]here is faint evidence that the listed traits (individually or collectively) are assured to produce measureable improvements in safety.” (p. 4)  We raised the same issue in our October 22, 2010 post on the NRC safety culture workshop.  What are the linkages, if any, between the traits and measurable or observable safety-related performance?

Our concern about the lack of demonstrated linkages leads to what may be a bedrock question underlying all of the safety culture policy discussion: If the ROP isn’t providing sufficient information to support the NRC’s confidence in a licensee’s safety culture, then how can the agency develop that information in a defined, disciplined and vetted manner?  Is a safety culture policy going to provide that assurance?


*  Letter dated Dec 15, 2010 from S. Abdel-Khalik (ACRS) to G. Jaczko (NRC), subject "Safety Culture Policy Statement," ADAMS Accession Number ML103410358.

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