Tuesday, July 22, 2014

The European Union Shows Stronger Interest in Nuclear Safety Culture

Council of the EU building
The Council of the European Union (EU) recently updated its 2009 Nuclear Safety Directive.  The revised directive’s objectives include strengthening national regulatory authorities, increasing public transparency on nuclear safety matters and promoting an effective nuclear safety culture.  The last objective caught our eye and is the subject of this post.

Safety Culture in the 2009 Nuclear Safety Directive*

Safety culture (SC) did not get a lot of attention in the 2009 directive.  Specifically, “The establishment of a strong safety culture within a nuclear installation is one of the fundamental safety management principles necessary for achieving its safe operation.” (p. L 172/19)  That was it.

Safety Culture in the 2014 Amended Directive**

SC treatment in this version is more expansive.

“Indicators for an effective nuclear safety culture include, in particular: the commitment at all levels of staff and management within an organisation to nuclear safety and its continuous improvement; the promotion of the ability of staff at all levels to question the delivery of relevant safety principles and practices to continuously improve nuclear safety; the ability of staff to report safety issues in a timely manner; the identification of the lessons learnt from operational experience; and the systematic reporting of any deviation from normal operating conditions or arrangements relevant to accident management that have the potential to have an impact on nuclear safety.” (p. 10)

The foregoing is then restated in the form of requirements.  “Member States shall ensure that the national framework requires that the competent regulatory authority and the licence holder take measures to promote and enhance an effective nuclear safety culture. Those measures include in particular:

(a) management systems which give due priority to nuclear safety and promote, at all levels of staff and management, the ability to question the effective delivery of relevant safety principles and practices, and to report in a timely manner on safety issues, in accordance with Article 6(d);

(b) arrangements by the licence holder to register, evaluate and document internal and external safety significant operating experience;

(c) the obligation of the licence holder to report events with a potential impact on nuclear safety to the competent regulatory authority; and,

(d) arrangements for education and training, in accordance with Article 7.” (p. 28)

Our Perspective

We are pleased to see the EU strengthen its position on SC’s role in promoting and maintaining safe nuclear operations.  The 2014 version of the safety directive is obviously a major improvement over 2009.  The paragraph on management systems gives “due priority” to safety and reflects the notions of a Safety Conscious Work Environment and an Employee Concerns Program.

The other requirements on recording operating experience, reporting significant events and arranging training create a minimally acceptable framework for nuclear operations.

We recognize that this EU directive is a top-level policy document so we don’t expect any specifics but there are two other SC-related items that merit mention at the policy level.

One, the management system should have a top-level goal of identifying and correcting problems in a timely manner.  This is perhaps the most important artifact of a strong SC.  Such a goal should not be limited to issues like equipment problems but cover everything from plant siting to daily operations.

Two, the management system should include reference to an executive compensation scheme that rewards safety performance and the maintenance of a strong SC.

*  “Council Directive 2009/71/EURATOM of 25 June 2009 establishing a Community framework for the nuclear safety of nuclear installations,” Official Journal of the European Union (July 2, 2009).

**  Council of the European Union, “Council Directive amending Directive 2009/71/Euratom establishing a Community framework for the nuclear safety of nuclear installations,” Interinstitutional File: 2013/0340 (June 30, 2014)

1 comment:

  1. Of interest in the review of this Directive is the norm of ultimate "protection and safety" afforded by conformance with the standard and its intent. In this regard there appears to be a division of opinion that is somewhat glossed over in the treatment of what is "reasonably practicable."

    In the preamble to the description of specific directive changes we find:

    "(19) Where 'reasonably practicable' is used in this Directive it should be applied in accordance
    with established definitions, in particular the WENRA and IAEA definitions."

    However, a little research of the IAEA Glossary (PUB 1290 circa 2007) indicates that the term ALARA is defined, but not ALARP.

    WENRA in its establishment of recommendations that new plants be designed such that significant offsite consequences be "practically eliminated" ["In this context, the possibility of certain conditions occurring is considered to have been practically eliminated if it is physically impossible for the conditions to occur or if the conditions can be considered with a high degree of confidence to be extremely unlikely to arise (from IAEA NSG1.10)."]

    Interestingly, ALARP is a legal term of art in the UK; although challenged by the European Commission as not satisfying the more absolutist statements of an employer's Duty of Care for health and safety, as seen here [Reference: http://en.wikipedia.org/wiki/ALARP] this challenge was rebuffed by the EU Courts.

    Unlike the US, the Europeans via WENRA opted to rely upon a qualitative expression of its Reactor Safety Objective/Goals. And the directive establishes a "continuously improved" requirement upon all aspects of Nuclear Safety achievement which seems very far removed from "risk-informed" regulation.

    Given the context of the Fukushima lesson learned regarding the perils of nuclear safety responsible government parties "over-promising," that is, a level of "optimization" which lacks any historical precedent of achievement, I find it hard to take the added language regarding Nuclear Safety Culture as much more than Marketing and window-dressing.

    The question I would like to ask is this: Why ALARA for cumulative exposure of workers? There doesn't appear to be any opening to do that.


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