Tuesday, April 26, 2016

A Professor's Essay on Nuclear Safety Culture

Prof. Najmedin Meshkati recently published an article* that reviews how the Chernobyl and Fukushima disasters demonstrated the essential need for a strong safety culture (SC) in the nuclear industry.  The article is summarized below.

He begins by reminding us the root cause of the Chernobyl accident was a deficient SC, a problem that affected not only the Chernobyl plant but also permeated the entire Soviet nuclear ecosystem. 

Fukushima is characterized as an anthropogenic accident, i.e, caused by human action or inaction.  He contrasts the fate of TEPCO’s Fukushima Daiichi plant with the Tohoku Electric Power Company’s Onagawa plant.  Onagawa was closer to the earthquake epicenter than Fukushima and faced a taller tsunami but shut down safely and with limited damage.  The author concludes Tohoku had a stronger SC than TEPCO.  We reviewed Meshkati’s earlier paper comparing TEPCO and Tohoku on March 19, 2014.

He also mentions the 1961 SL-1 reactor accident** and the 1979 TMI accident.  Both presented the opportunity for SC lessons learned but they were obviously not taken to heart by all industry participants.

The author concludes with a cautionary note to newly expanding nuclear countries: human factors and SC are critical success factors “and operators’ individual mindfulness and improvisation potential need to be nurtured and cultivated by the organizations that operate such systems; and regulatory regimes should envision, encourage, and enforce them.”

Our Perspective

There is nothing new here.  The article reads like a reasonably well-researched paper prepared for a college senior seminar, with multiple linked references.***  Meshkati does have the advantage of having been “on the ground” at both Chernobyl and Fukushima but that experience does not inform this article beyond adding a bit of color to his description of the Chernobyl sarcophagus (a “temple of eternal doom”).  Overall, the article does not provide new information or insights for Safetymatters readers who have examined the accidents in any level of detail.

What’s interesting is the platform on which the article appeared.  The WorldPost is produced by The Huffington Post, a politically liberal news and opinion website, and the Berggruen Institute, a political and social think tank.  We would not have expected the HuffPost to be associated with an article that exhibits any faint pro-nuclear flavor, even one as vanilla as this.

We don’t celebrate the anniversaries of Chernobyl and Fukushima but we should certainly remember the events, especially when we see the nuclear industry hubris meter trending toward the red zone.

*  N. Meshkati, “Chernobyl’s 30th Anniversary (and Fukushima’s 5th): A Tale of Preventable Nuclear Accidents and the Vital Role of Safety Culture,” The WorldPost (April 22, 2016).

**  Stationary Low-Power Reactor Number One (SL-1) was a U.S. Army prototype small power reactor.  A Jan. 3, 1961 accident killed its three operators.

***  I looked at all the links but didn’t see anything new for the “must read” list.  However, you might quickly check them out if you are interested in these significant historical events.

Tuesday, April 19, 2016

Faked Radiation Reports at Two German Nuclear Plants: Bad Apples or Nuclear Safety Culture Problem?

According to an article* on German news site The Local, workers at two EnBW** nuclear plants submitted reports for radiation checks that were never performed. 

At the Philippsburg plant, a single subcontractor had been submitting reports based on checks he never carried out.  The consequences were severe—the government has ordered a halt to EnBW’s plans to restart the unit.

At the permanently shutdown Biblis plant, a worker filed faked reports throughout 2014-15.

Our Perspective

Germany intends to shut down all its nuclear plants by 2022.  Perhaps a few employees are shutting down a little early.  Snark aside, maintaining a strong safety culture in the face of an anticipated shutdown (and subsequent job losses) is a significant challenge for any organization in any industry but it is especially acute in the nuclear space where the actions of a single distracted, unmotivated or alienated individual can lead to significant regulatory, political, public relations and/or physical plant problems.

*  “Inspectors faked safety checks at two nuclear plants,” The Local (April 15, 2016).

**  Energie Baden-Württemberg AG, a German electric utility company.

Wednesday, April 13, 2016

Is Entergy’s Nuclear Safety Culture Hurting the Company or the Industry?

Entergy Headquarters  Source: Nola.com
A recent NRC press release* announced a Confirmatory Order (CO) issued to Entergy Operations, Inc. following an investigation that determined workers at Waterford 3 failed to perform fire inspections and falsified records.  Regulatory action directed at an Entergy plant has a familiar ring and spurs us to look at various problems that have arisen in Entergy’s fleet over the years.  The NRC has connected the dots to safety culture (SC) in some cases while other problems suggest underlying cultural issues. 

Utility-Owned Plants

These plants were part of the utility mergers that created Entergy.

Arkansas Nuclear One (ANO)

ANO is currently in Column 4 of the NRC Action Matrix and subject to an intrusive IP 95003 inspection.  ANO completed an independent SC assessment.  We reviewed their problems on June 25, 2015 and concluded “. . . the ANO culture endorses a “blame the contractor” attitude, accepts incomplete investigations into actual events and potential problems, and is content to let the NRC point out problems for them.”

In 2013 ANO received a Notice of Violation (NOV) after an employee deliberately falsified documents regarding the performance of Emergency Preparedness drills and communication surveillances.**

Grand Gulf

We are not aware of any SC issues at Grand Gulf.

River Bend

In 2014 Entergy received a CO to document commitments made because of the willful actions of an unidentified River Bend security officer in March 2012.

(In 2014 the NRC Office of Investigations charged that a River Bend security officer had deliberately falsified training records in Oct. 2013.  It appears a subsequent NRC investigation did not substantiate that charge.***)

In 2012 River Bend received a NOV for operators in the control room accessing the internet in violation of an Entergy procedure.

In 2011 River Bend received a CO to document commitments made because an employee apparently experienced retaliatory action after asking questions related to job qualifications.  Corrective actions included Entergy reinforcing its commitment to a safety conscious work environment, reviewing Employee Concerns Program enhancements and conducting a plant wide SC survey.

In 1999 River Bend received a NOV for deliberately providing an NRC inspector with information that was incomplete and inaccurate.

Waterford 3

As noted in the introduction to this post, Waterford 3 recently received a CO because of failure to perform fire inspections and falsifying records.

Entergy Wholesale Plants

These plants were purchased by Entergy and are located outside Entergy’s utility service territory.


Entergy purchased FitzPatrick in 2000.

In 2012, FitzPatrick received a CO after the NRC discovered violations, the majority of which were willful, related to adherence to site radiation protection procedures.  Corrective actions included maintaining the SC processes described in NEI 09-07 “Fostering a Strong Nuclear Safety Culture.”

Entergy plans on closing the plant Jan. 27, 2017.

Indian Point

Entergy purchased Indian Point 3 in 2000 and IP2 in 2001.

In 2015 Indian Point received a NOV because it provided information to the NRC related to a licensed operator's medical condition that was not complete and accurate in all material respects.

In 2014 Indian Point received a NOV because a chemistry manager falsified test results.  The manager subsequently resigned and then Entergy tried to downplay the incident.  Our May 12, 2014 post on this event is a reader favorite.

During 2006-08 Indian Point received two COs and three NOVs for its failure to install backup power for the plant’s emergency notification system.


Entergy purchased Palisades in 2007.

In 2015 Entergy received a NOV because it provided information to the NRC related to Palisades’ compliance with ASME Code acceptance criteria that was not complete and accurate in all material respects.

In 2014 Entergy received a CO because a Palisades security manager assigned a supervisor to an armed responder role for which he was not currently qualified (see our July 24, 2014 post).

Over 2011-12 a virtual SC saga played out at Palisades.  It is too complicated to summarize here but see our Jan. 30, 2013 post.

In 2012 Palisades received a CO after an operator left the control room without permission and without performing a turnover to another operator.  Corrective actions included conducting a SC assessment of the Palisades Operations department.


Entergy purchased Pilgrim in 1999.

Like ANO, Pilgrim is also in column 4 of the Action Matrix.  They are in the midst of a three-phase IP 95003 inspection currently focused on corrective action program weaknesses (always a hot button issue for us); a plant SC assessment will be performed in the third phase.

In 2013, Pilgrim received a NOV because it provided information to the NRC related to medical documentation on operators that was not complete and accurate in all material respects.

In 2005 Pilgrim received a NOV after an on-duty supervisor was observed sleeping in the control room. 

Vermont Yankee

Entergy purchased Vermont Yankee in 2002.

During 2009, Vermont Yankee employees made “incomplete and misleading” statements to state regulators about tritium leakage from plant piping.  Eleven employees, including the VP for operations, were subsequently put on leave or reprimanded.  Click the Vermont Yankee label to see our multiple posts on this incident. 

Vermont Yankee ceased operations on Dec. 29, 2014.

Our Perspective

These cases involved behavior that was wrong or, at a minimum, lackadaisical.  It’s not a stretch to infer that a weak SC may have been a contributing factor even where it was not specifically cited.

Only three U.S. nuclear units are in column 4 of the NRC’s Action Matrix—and all three are Entergy plants.  Only TVA comes close to Entergy when it comes to being SC-challenged.

We can’t predict the future but it doesn’t take a rocket scientist to plot Entergy’s nuclear trajectory.  One plant is dead and the demise of another has been scheduled.  It will be no surprise if Indian Point goes next; it’s in a densely populated region, occasionally radioactively leaky and a punching bag for New York politicians.

Does Entergy’s SC performance inspire public trust and confidence in the company?  Does their performance affect people's perception of other plants in the industry?  You be the judge.

*  NRC press release, “NRC Issues Confirmatory Order to Entergy Operations, Inc.” (April 8, 2016).  ADAMS ML16099A090.

**  COs and NOVs are summarized from Escalated Enforcement Actions Issued to Reactor Licensees on the NRC website.

***  J.M. Rollins (NRC) to J. McCann (Entergy), Closure of Investigation 014-2014-046 (Jan. 25, 2016.)  ADAMS

Thursday, April 7, 2016

Safety Culture at the 2016 NRC Regulatory Information Conference

RIC program cover
The official evidence of the NRC’s interest in safety culture (SC) at the 2016 Regulatory Information Conference (RIC) consisted of a tabletop presentation on SC training initiatives and support materials.  The tabletop was available during the entire conference and the intent was to engage with participants and make them aware of the SC learning resources that the NRC published this past year.

At past RICs, SC merited a technical session slot in the program, one of thirty-to-forty such sessions at the conference.

Our Perspective

SC has never been an A-list topic at the RIC but we’ll allow that a constant human presence at a tabletop may provide greater opportunities for interacting with conference participants than a single technical session.

We believe SC should get more exposure and promotion at the RIC.  For example, the 2014 RIC had a very good SC panel with three companies that had been (or were still) on the NRC’s SC s___ list making presentations on their get-well efforts.  We reviewed that RIC on April 25, 2014.

Perhaps the NRC could dragoon a few Chief Nuclear Officers to come in and talk about their pay packages and how they are incentivized and rewarded for establishing and maintaining a strong SC.  Now that would be interesting.