Thursday, January 6, 2011

Nuclear Safety Culture Assessment Manual

July 9, 2012 update: How to Get the NEI Nuclear Safety Culture Assessment Manual

The manual is available in the NRC ADAMS database, Accession Numbers ML091810801, ML091810803, ML091810805, ML091810807, ML091810808 and ML091810809.

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As recently reported at TheDay.com,* NEI has published a “Nuclear Safety Culture Assessment Manual,” a document that provides guidance for conducting a safety culture (SC) assessment at a nuclear power plant.  The industry has issued the manual and conducted some pilot program assessments in an effort to influence and stay ahead of the NRC’s initiative to finalize a SC policy statement this year.  The NRC is formulating a policy (as opposed to a regulatory requirement) in this area because it apparently believes that SC cannot be directly regulated and/or any attempt to assess SC comes too close to evaluating (or interfering with) plant management, a task the agency has sought to avoid. 

Basically, the manual describes an assessment methodology based on the eight INPO principles for creating/maintaining a strong nuclear safety culture.  It is a comprehensive how-to document including assessment team organization, schedules, interview guidance and questions, sample communication memos, and report templates.  The manual has a strongly prescriptive approach, i.e., it seeks to create a standardized approach which should facilitate comparisons between different facilities and the same facility over time. 

The best news from our perspective is that the NEI assessment approach relies heavily on interviews; it uses a site survey instrument only to identify pre-assessment areas of interest.  It’s no secret that we are skeptical about over-inference with respect to the health of a plant’s safety culture from the snapshot a survey provides.  The assessment also uses direct observations of behavior of employees at all levels during scheduled activities, such and meetings and briefings, and ad-hoc observation opportunities.

A big question is: In a week-long self assessment, can a team discern the degree to which an organization satisfies key principles, e.g., the level of trust in the organization or whether leaders demonstrate a commitment to safety?  I think we have to answer that with “Maybe.”  Skilled and experienced interviewers can probably determine the general status of these variables but may not develop a complete picture of all the nuances.  BUT, their evaluation will likely be more useful than any survey.

There is one obvious criticism with the NEI approach which industry critics have quickly identified.  As David Collins puts it in TheDay.com article, “[T]he industry is monitoring itself - this is the fox monitoring the henhouse."  While the manual is proposed for use by anyone performing a safety culture assessment, including a truly independent third party, the reality is the industry expects the primary users to be utilities performing self assessments or “independent” assessments, which include non-utility people on the team. 


*  P. Daddona, “Nuclear group puts methods into use to foster 'a safety culture',” TheDay.com
(Dec 21, 2010).

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