Monday, April 22, 2013

IAEA on Safety Culture in New Plant Design and Construction

The International Atomic Energy Agency (IAEA) has a 2012 publication* that provides guidance on establishing a strong safety culture (SC) during the design and construction of new nuclear power plants.  The report's premise, with which we agree, is a weak SC during plant design and construction can lead to later problems during plant operations.   

Major issues can arise during plant design and construction.  For example, the numerous organizations involved may have limited direct experience and/or insufficient knowledge of nuclear safety requirements, or projects may be located in countries with no existing nuclear industry or countries may have a nuclear industry but no recent construction experience.

The report attempts to cover the different needs, challenges and circumstances that may face project participants (governments, regulators, owners, designers, builders, manufacturers, etc.) anywhere in the world.  Most of the content addresses generic issues, e.g., understanding SC, the role of leadership, appropriate management systems, or communication and organizational learning.  Each issue is discussed in terms of specific challenges, goals, and recommended approaches and methods.  However, in their effort to attain maximum coverage (scope) IAEA sacrifices depth.  For example, the discussion of leadership covers five pages of the report but scarcely mentions the two most important activities of leaders: decision making and modeling safety-focused behavior.

If we look at the report's specific advice and recommendations, we see uneven coverage of the observable artifacts we consider essential for a strong SC: a decision making process that appropriately values safety, an effective corrective action program and financial incentives that reward safety performance. 

Decision making process

 
One overall challenge facing new projects is “Conflicts between schedule, cost and safety objectives can adversely affect conservative decision making and the maintenance of a questioning attitude, or impair the ability to perceive links between short term actions and their long term consequences.” (p. 2)

That's a good starting point but what are the characteristics of an appropriate decision making process?  It seems that decision making should be “conservative” (pp. 32, 34, 39), “broad” (p. 43) and “risk informed” (pp. 50, 51) but the terms are not defined. 
More specificity on how the decision making process should handle competing goals, set priorities and assign resources would be useful.
 
What about the decision makers?  Leaders should be able to “Explain the relationships between time periods/horizons and decision making to help resolve competing priorities.” (p. 41)  That's OK but the need goes beyond time periods.  The manager must be able to explain the rationale for significant decisions related to safety.  What were the considerations, assumptions, priorities, alternatives, decision factors and their relative weights, and the applicable laws, rules and regulations?  How should leaders
treat devil’s advocates who raise concerns about possible unfavorable outcomes?  Do leaders get the most qualified people involved in key decisions?
 
In addition, leaders should “Simulate decision making in a fast paced, complex environment to help leaders identify risks in their own approaches.”  (p. 41)  This is an excellent approach and we wholeheartedly support it. 

Corrective action

“Ineffective problem identification, inadequate reporting and inadequate corrective actions” (p. 9) were identified in a 2006 investigation as causal factors of construction problems at a nuclear plant site.  But there is no follow-up to describe the characteristics of an effective corrective action program.  There should be more about the CAP's ability to recognize and diagnose problems, formulate and implement solutions that consistently and appropriately consider safety, and monitor the effects of corrective actions. The importance of robust cause analysis, i.e., analysis that finds the real causes of problems so they do not recur, should be mentioned.  This would not be an unreasonable level of detail for this general report.

Financial incentives

The report correctly notes that “In construction environments, cultural attributes such as schedule awareness, cost focus and urgency of problem resolution are reinforced because they are rewarded by immediate measures of success.” (p. 8)  This becomes a specific challenge when “Contractor incentives are often driven by cost and schedule rather than by safety culture performance.” (p. 26).  A recommended fix is to “Establish a reward and incentive programme [sic] for the overall project, with objectives for safety performance and rewards that are either monetary or in the form of future contracts as a long term partner.” (p. 27).  This will probably result in a focus on industrial safety performance rather than the overall SC but it may be the best practical solution.  Periodic assessment of key contractors' SC should be used to identify any general SC issues. 

Our perspective

In prior posts, we have taken the IAEA to task for their overly bureaucratic approach.  So we're pleased to report this document actually provides some useful, sensible guidance (albeit often in an unprioritized, laundry list style) applicable to both countries initially embarking on the nuclear road and more experienced countries experiencing a nuclear renaissance.

The report makes a few important points.  For example, IAEA proposes a systems approach to thinking about all the project participants and the varied work they must accomplish.  “In the case of NPP projects, the ‘system’ involves human–social systems, work processes, complex technologies and multiple organizations in a global economic, energy, environmental and regulatory context.” (p. 11)  This is a viewpoint we have repeatedly advocated in this blog.
 

Overall this report is satisfactory and it does refer the reader to other IAEA publications for additional information on specific subjects.  But in trying to provide relevant material to a plethora of stakeholders, the report gives shorter shrift to factors we consider vital to establishing and maintaining a strong SC. 


*  M. Haage (IAEA), “Safety culture in pre-operational phases of nuclear power plant projects” (Vienna : International Atomic Energy Agency,  2012).

1 comment:

  1. Biblical exegesis does not a modern faith make.

    It would seem to me that we've got another example of "nuclear safety culture" spreading like kudzu into domains where there was no previous nor recently demonstrated need.

    Considering the availability of independently certified design, configuration managed electronically in far more dependable and easy to maintain ways and the whole of 3D design - plus the thousands of highly engineered facilities and aircraft designed and built since the last wave of nuclear design and construction it's hard to see the value added of "nuclear safety culture."

    I for one would say that its introduction in the context of the Hanford WTP has been a serious source of distraction from the very serious problem of discovering and developing solutions to the chemistry problems.

    There is a need for rigorous attention to quality control and conventional design QA, but I've not seen the evidence that these challenges are structurally any more pressing than they were in 1975. In fact with modern data management systems the ability to collect incidental analytics on design and fabrication work (e.g. how many changes per designer or department vs. per design - captured and displayed in real time).

    Plant design and construction are the most compliance bound and record of accomplishment intensive periods in the life cycle of the plant. Setting "expectations" regarding the temporary arrangements, particularly wrt to thousands of suppliers being integrated at a major construction site is taking anyone's understanding of culture into entirely uncharted territory.

    Again why do it when it isn't indicated by the evidence. If IAEA were providing a summary of lessons learned from other technological sectors with extensive ongoing experience in the period between say 1985 and the present then this might be a useful document. Looking at the list of contributors it is difficult to identify any such experience - certainly Monica Haage doesn't have it.

    Sorry, but this blight is killing the industry by turning into a compliance enterprise, instead of an energy enterprise. Look at the Shaw NOV and Chilled Work Environment letters just issued by NRC - can we really say that this is effective oversight?

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