A reader sent us a copy of “Safety Assessment Principles for Nuclear Facilities” (SAPs) published by the United Kingdom’s Office for Nuclear Regulation (ONR).* For documents like this, we usually jump right to the treatment of safety culture (SC). However, in this case we were impressed with the document’s accessibility, organization and integrated (or holistic) approach so we want to provide a more general review.
ONR uses the SAPs during technical assessments of nuclear licensees’ safety submissions. The total documentation package developed by a licensee to demonstrate high standards of nuclear safety is called the “safety case.”
The language is clear and intended for newbies as well as those already inside the nuclear tent. For example, “The SAPs contain principles and guidance. The principles form the underlying basis for regulatory judgements made by inspectors, and the guidance associated with the principles provides either further explanation of a principle, or their interpretation in actual applications and the measures against which judgements can be made.” (p. 11)
Also furthering ease of use, the document is not strewn with acronyms. As a consequence, one doesn’t have to sit with glossary in hand just to read the text.
ONR presents eight fundamental principles including responsibility for safety, limitation of risks to individuals and emergency planning. We’ll focus on another fundamental principle, Leadership and Management (L&M) because (a) L&M activities create the context and momentum for a positive SC and (b) it illustrates holistic thinking.
L&M is comprised of four subordinate (but still high-level) inter-related principles: leadership, capable organization, decision making and learning. “Because of their inter-connected nature there is some overlap between the principles. They should therefore be considered as a whole and an integrated approach will be necessary for their delivery.” (p. 18)
Drilling down further, the guidance for leadership includes many familiar attributes. We want to acknowledge attributes we have been emphasizing on Safetymatters or reflect new thoughts. Specifically, leaders must recognize and resolve conflict between safety and other goals, ensure that the reward systems promote the identification and management of risk, encourage safe behavior and discourage unsafe behavior or complacency; and establish a common purpose and collective social responsibility for safety. (p.19)
Decision making (another Safetymatters hot button issue) receives a good treatment. Topics covered include explicit recognition of goal conflict; appreciating the potential for error, uncertainty and the unexpected; and the essential functions of active challenges and a questioning attitude.
We do have one bone to pick under L&M: we would like to see words to the effect that safety performance and SC should be significant components of the senior management reward system.
Helpful nuggets pop up throughout the text. A few examples follow.
“The process of analysing safety requires creativity, where people can envisage the variety of routes by which radiological risks can arise from the technology. . . . Safety is achieved when the people and physical systems together reliably control the radiological hazards inherent in the technology. Therefore the organizational systems (ie interactions between people) are just as important as the physical systems, . . . “ (pp. 25-26)
“[D]esigners and/or dutyholders may wish to put forward safety cases that differ from [SAP] expectations. As in the past, ONR inspectors should consider such submissions on their individual merits. . . . ONR will need to be assured that such cases demonstrate equivalence to the outcomes associated with the use of the principles here,. . .” (p. 14) The unstated principle here is equifinality; in more colorful words, there is more than one way to skin a cat.
There are echoes of other lessons we’ve been preaching on Safetymatters. For example “The principle of continuous improvement is central to achieving sustained high standards of nuclear safety. . . . Seeking and applying lessons learned from events, new knowledge and experience, both nationally and internationally, must be a fundamental feature of the safety culture of the nuclear industry.” (p. 13)
And, in a nod to Nicholas Taleb, if a “hazard is particularly high, or knowledge of the risk is very uncertain, ONR may choose to concentrate primarily on the hazard.” (p. 8)
Most of the content of the SAPs will be familiar to Safetymatters readers. We suggest you skim the first 23 pages of the document covering introductory material and Leadership & Management. SAPs is an excellent example of a regulator actually trying to provide useful information and guidance to current and would-be licensees and is far better than the simple-minded laundry lists promulgated by IAEA.
* Office for Nuclear Regulation, “Safety Assessment Principles for Nuclear Facilities” Rev. 0 (2014). We are grateful to Bill Mullins for forwarding this document to us.
Sunday, March 29, 2015
Wednesday, March 18, 2015
|NRC Public Meeting|
This presentation consisted of one (sic) slide recounting the NRC’s SC outreach program during the past year including the Trait Talk brochures, SC case studies and meetings with other nuclear regulatory bodies.
The presenter provided a list of internal (CAP, Employee Concerns Program )and external (INPO, NRC) information, and management activities (Nuclear SC Monitoring Panel, Site Leadership team, Corporate Nuclear SC Monitoring Panel, Fleet Nuclear SC Monitoring Panel, Executive Nuclear Safety Council) that are used to assess equipment, processes and people across the Duke fleet. There was no information on how these activities are integrated to describe plant or fleet SC, or if any SC issues have been identified or corrective actions taken; the slides were basically a laundry list.
Department of Energy (DOE)
The speaker was from DOE’s Office of Environment, Health, Safety and Security. He reviewed the safety mission and goals related to DOE’s Integrated Safety Management program, DOE’s SC focus areas (leadership, employee/worker engagement and organizational learning) and SC-related activities (extent of condition reviews, self‐assessments, sustainment plans, independent assessments and the SC Improvement Panel.)
The presentation covered the challenges in relating SC to safety management performance (mostly industrial safety metrics) and in implementing cultural changes. Factors that make SC improvement difficult include production vs. safety goal conflict, fiscal pressures, leadership changes and internal inertia (resistance to change).
This presentation covered the basics of SC, as customized for DOE, but had no supporting details or any mention of the SC issues that have arisen at various DOE facilities, e.g., Hanford, Pantex and the Waste Isolation Pilot Plant. We have posted many times on DOE SC; please click on the DOE label to retrieve these posts.
The presenter was Sonja Haber. She reviewed the fundamentals of the linkage between culture, behavior and ultimate performance, and the Schein three-level model of culture.
She also covered the major considerations for conducting SC assessments including having a diversity of expertise in assessing culture, using multiple methods of data collection, understanding how cultural complexity impacts performance and considering the interaction of human, organizational and technological factors.
This was thin gruel compared to the 2014 RIC SC session (which we reviewed April 25, 2014). Based on the slides, there was not much “there” there at this session. The speaker who offered the most was Dr. Haber, not a surprise given that she has been involved in SC evaluations at various DOE facilities and testified at a Defense Nuclear Facilities Safety Board hearing on SC (which we reviewed June 9, 2014).
If a webcast of the SC technical session becomes available, we will review it to see if any useful additional information was presented or arose during the discussion.
* The SC technical session presentations are available on the NRC website.
Friday, March 6, 2015
|Typical NRC Trait Talk brochure|
At that time, only one Trait Talk was available, viz., Leadership Safety Values and Actions. We thought the content was pretty good. The “Why is this trait important?” portion was derived from an extensive review of SC-related social science literature, which we liked a lot and posted about Feb. 10, 2013. The “What does this trait look like?” section (aka attributes) comes from the SC Common Language initiative, which we have reviewed multiple times, most recently on April 6, 2014. The illustrative scenario is new content developed for each brochure.
During 2014 and early 2015, NRC published additional Trait Talk brochures and now has one for each trait in the SCPS.* We reviewed them all and still believe they provide a useful introduction and overview for each trait. Following is our take on each trait’s essence (based on the brochure contents), and each brochure’s strengths and weaknesses.
Leadership Safety Values and Actions
This trait focuses on the responsibilities of leaders to set the tone for SC through their own visible actions. There is a good discussion of how employees at all levels can face goal conflicts, e.g., safety vs. production. The focus of the reward system is on the staff; unfortunately, there is no mention of management’s financial incentives. Although leaders’ decisions set the priority for safety, there is no mention of the decision making process, arguably management’s most fundamental and important function.**
This trait focuses on controlling work. It emphasizes limiting temporary modifications, minimizing backlogs and adhering to procedures, which is all good. It also says “organizations may require strict adherence to normal and emergency operating procedures. However, flexibility may be necessary when responding to off-normal conditions.” This may give the purists heartburn but it reflects reality and is a major observation of the Fukushima disaster.
This trait is about avoiding complacency, watching for abnormalities while going about one’s duties and stopping work if unexpected conditions or results are encountered. The key is ensuring safety has its appropriate priority at all times, which is not easy if a plant is under significant financial or political pressure.
Problem Identification and Resolution
This trait is about identifying and permanently resolving current problems, and anticipating potential future challenges and dealing with them before they manifest. In our view, this is one of the two most important areas (the other being decision making) where everyone sees what a plant’s real priorities are. This Trait Talk covers the topic well.
Environment for Raising Concerns
The trait is about establishing and maintaining a safety conscious work environment (SCWE). The Trait Talk lays out the theory but the truth is whistle-blowers in many industries, including nuclear, become pariahs.
Effective Safety Communication
This trait is about transparency (although the term does not appear in the brochure.) All business communication should be clear, complete, understandable and respectful. The Trait Talk’s discussion on the importance of first-level supervisors being a primary source of information for their employees is very good.
Respectful Work Environment
The title says it all about this trait which overlaps with others, including questioning attitude, SCWE and transparent communications. The Trait Talk has a good discussion of trust, at both the individual and organizational level. One aspect we would add to the trust “equation” is the perception of self-interest vs. concern for others.
This trait is about identifying, obtaining, sharing, applying and retaining new knowledge that can lead to improved individual or organizational performance. This trait overlaps with others, including questioning attitude and a respectful work environment.
This trait is mostly about everyone’s willingness to accept responsibility for safety but it also encompasses assigned individuals’ obligation for specific safety responsibilities. For the latter case, the brochure’s statement that “Personal accountability is not finger pointing, blame, or punishment” is simply not true.
The brochures provide a useful introduction and overview for each trait in the SCPS. The content is generally good, with some weak spots and missing items. These are, after all, four-page brochures and roughly 45 percent of the content is the same in every brochure.
* All the Trait Talk brochures can be downloaded from the SC education materials page on the NRC website.
** Interestingly, Decision Making is included as a tenth trait in NRC NUREG-2165, “Safety Culture Common Language” (Mar. 2014). ADAMS ML14083A200.