Tuesday, October 29, 2013

NRC Outreach on the Safety Culture Policy Statement

An NRC public meeting
Last August 7th, the NRC held a public meeting to discuss their outreach initiatives to inform stakeholders about the Safety Culture Policy Statement (SCPS).  A meeting summary was published in October.*  Much of the discussion covered what we'll call the bureaucratization of safety culture (SC)—development of communication materials (inc. a poster, brochure, case studies and website), presentations at conferences and meetings (some international), and training.  However, there were some interesting tidbits, discussed below.

One NRC presentation covered the SC Common Language Initiative.**  The presenter remarked that an additional SC trait, Decision Making (DM), was added during the development of the common language.  In our Feb. 28, 2013 review of the final common language document, we praised the treatment of DM; it is a principal creator of artifacts that reflect an organization's SC.

The INPO presentation noted that “After the common language effort was completed in January, 2013, INPO published Revision 1 of 12-012, which includes all of the examples developed during the common language workshop.” (p. 6)  We reviewed that INPO document here.

But here's the item that got our attention.  During a presentation on NRC outreach, an industry participant cautioned the NRC to not put policy statements into regulatory documents because policy statements are an expectation, not a regulation. The senior NRC person at the meeting agreed with the comment “and the importance of the NRC not overstepping the Commission’s direction that implementing the SCPS is not a regulatory requirement, but rather the Commission’s expectations.” (p. 4)

We find the last comment disingenuous.  We have previously posted on how the NRC has created de facto regulation of SC.***  In the absence of clear de jure regulation, licensees and the NRC end up playing “bring me another rock” until the NRC accepts a licensee's pronouncements, as verified by NRC inspectors.  For an example of this convoluted kabuki, read Bob Cudlin's Jan. 30, 2013 post on how Palisades' efforts to address a plant incident finally gained NRC acceptance, or at least an NRC opinion that Palisades' SC was “adequate and improving.”

We'll keep you posted on SCPS-related activities.


*  D.J. Sieracki to R.P. Zimmerman, “Summary of the August 7, 2013, Public Meeting between the U.S. Nuclear Regulatory Commission Staff  and Stakeholders to  Exchange Information and Discuss Ongoing Education and Outreach Associated with the Safety Culture Policy Statement” (Oct. 1, 2013).  ADAMS ML13267A385.  We continue to find it ironic that the SCPS is administered by the NRC's Office of Enforcement.  Isn't OE's primary focus on people and companies who violate the NRC's regulations?

**  “The common language initiative uses the traits from the SCPS as a basic foundation, and contains definitions and examples to describe each trait more fully.” (p. 3)

***  For related posts, please click the "Regulation of Safety Culture" label.

1 comment:

  1. Just a few more comments on items of cognitive dissonance:

    The use of a phone conference in which all the NRC staff are in the same room and virtually all the non-staff participants are remote with no visual feed doesn't seem like very potent engagement in the Broadband era.

    Regarding this quote:
    "Roy Zimmerman agreed with Mr. Link’s comment and the importance of the NRC not
    overstepping the Commission’s direction that implementing the SCPS is not a regulatory
    requirement, but rather the Commission’s expectations. He reiterated the Commission’s
    direction to the staff to engage the regulated industry through outreach and education regarding
    the SCPS."

    As Lew pointed out bureaucratization - particularly in the ROP procedures - is de facto regulation, I wonder though if most of the staff have the breadth of experience with a range of control systems to understand how very tenuous the Commission's election of "expectations" rather than rule-making is.

    Later we hear:

    "OE is also developing studies on each of the nine traits from the SCPS. The definitions of these
    traits were included in the SCPS, but without a “third tier” description of how they might be implemented. These studies will discuss each trait and discuss why it is important and provide
    examples of what it could look like when implemented."

    What was the point of the common language initiative and the three version of "what it looks like?" The folks in OE appear to continue to be off in their international conference playworld. That fact the NRR has created a working group to study how to incorporate the common language into the ROP cross cutting areas is most sensible taken as continued foot-dragging while actual oversight continues under the INSAG definition and framework - not the Commission's policy one. I wonder how much Mr. Zimmerman really understands the "slight of hand?"

    And finally:

    "Mr. Zimmerman indicated that stakeholder feedback on the case studies has been very positive,
    and that the case studies serve as a teaching tool to help demonstrate the importance of a
    positive safety culture. He indicated that we appreciated the feedback on ways to enhance the
    case studies."

    Has he actually looked at the so-called "case studies?" They demonstrate that what ever expertise Dianne Seracki and her office possess, it does not include first hand (i.e. relevant) experience with Complex, High Consequence Circumstance enterprises.

    The interest Mr. Zimmerman expressed in INPO's on-line training - available of course only to dues paying members, provides a great opportunity for Mr. Zimmerman to reach out to the INPO President and ask him: "Why not make that publicly available?" I won't hold my breath on that one.

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