Decision making, including the treatment of goal conflicts, is Good;
Corrective action, part of problem identification and resolution, is Satisfactory;
Management Incentives is Unsatisfactory because the associated attributes focuses on workers, not managers, and any senior management incentive program is not mentioned; and
Work Backlogs are mentioned in a couple of specific areas so the overall grade is Minimally Acceptable.
But we have one overarching concern that transcends our opinion of common language specifics.
Our biggest issue with the traits, attributes and examples approach is our fear it will lead to the complete bureaucratization of SC evaluation, either consciously or unconsciously. The examples in particular can morph into soft requirements on a physical or mental checklist. Such an approach leads to numerous questions. How many of the 10 traits does a healthy or positive SC exhibit?*** How many of the 40 attributes? Are the traits equally important? How about the attributes? Could the weighting factors vary across plant sites? How many examples must be observed before an attribute is judged acceptably present?
We understand the value of effective communications among regulators, licensee personnel and other stakeholders. But we worry about possible unintended consequences as people attempt to apply the guidance in NUREG-2165, especially in the NRC’s Reactor Oversight Process (ROP).****
* NRC NUREG-2165, “Safety Culture Common Language” (Mar. 2014). ADAMS ML14083A200.
** Nuclear Safety Culture Common Language 4th Public Workshop January 29-31, 2013. ADAMS ML13031A343.
*** The NUREG-2165 text describes a “healthy” SC while the SCPS (published as NUREG/BR-0500, Rev. 1, ADAMS ML12355A122) refers to a “positive” SC. The correct answer to “how many traits?” may be “more than ten” because the authors note “There may also be traits not included in the SCPS that are important in a healthy safety culture.” (p. 2)
**** The common language “initiative is within the Commission-directed framework for enhancing the ROP treatment of cross-cutting areas to more fully address safety culture.” (p. 3) This may require a little linguistic jujitsu since the SCPS says “traits were not developed for inspection purposes.”