|An NRC public meeting|
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.