Friday, January 6, 2017

Reflections on Nuclear Safety Culture for the New Year

The start of a new year is an opportunity to take stock of the current situation in the U.S. nuclear industry and reiterate what we believe with respect to nuclear safety culture (NSC).

For us, the big news at the end of 2016 was Entergy’s announcement that Palisades will be shutting down on Oct. 1, 2018.*  Palisades has been our poster child for a couple of things: (1) Entergy’s unwillingness or inability to keep its nose clean on NSC issues and (2) the NRC’s inscrutable decision making on when the plant’s NSC was either unsatisfactory or apparently “good enough.”

We will have to find someone else to pick on but don’t worry, there’s always some new issue popping up in NSC space.  Perhaps we will go to France and focus on the current AREVA and Électricité de France imbroglio which was cogently summarized in a Power magazine editorial: “At the heart of France’s nuclear crisis are two problems.  One concerns the carbon content of critical steel parts . . . manufactured or supplied by AREVA . . . The second problem concerns forged, falsified, or incomplete quality control reports about the critical components themselves.”**  Anytime the adjectives “forged” or “falsified” appear alongside nuclear records, the NSC police will soon be on the scene.  

Why do NSC issues keep arising in the nuclear industry?  If NSC is so important, why do organizations still fail to fix known problems or create new problems for themselves?  One possible answer is that such issues are the occasional result of the natural functioning of a low-tolerance, complex socio-technical system.  In other words, performance may drift out of bounds in the normal course of events.  We may not be able to predict where such issues will arise (although the missed warning signals will be obvious in retrospect) but we cannot reasonably expect they can be permanently eliminated from the system.  In this view, an NSC can be acceptably strong but not 100% effective.

If they are intellectually honest, this is the implicit mental model that most NSC practitioners and “experts” utilize even though they continue to espouse the dogma that more engineering, management, leadership, oversight, training and sanctions can and will create an actual NSC that matches some ideal NSC.  But we’ve known for years what an ideal NSC should look like, i.e., its attributes, and how responsibilities for creating and maintaining such a culture should be spread across a nuclear organization.***  And we’re still playing Whac-A-Mole.

At Safetymatters, we have promoted a systems view of NSC, a view that we believe provides a more nuanced and realistic view of how NSC actually works.  Where does NSC live in our nuclear socio-technical system?  Well, it doesn’t “live” anywhere.  NSC is, to some degree, an emergent property of the system, i.e., it is visible because of the ongoing functioning of other system components.  But that does not mean that NSC is only an effect or consequence.  NSC is both a consequence and a cause of system behavior.  NSC is a cause through the way it affects the processes that create hard artifacts, such as management decisions or the corrective action program (CAP), softer artifacts like the leadership exhibited throughout an organization, and squishy organizational attributes like the quality of hierarchical and interpersonal trust that permeates the organization like an ether or miasma. 

Interrelationships and feedback loops tie NSC to other organizational variables.  For example, if an organization fixes its problems, its NSC will appear stronger and the perception of a strong NSC will influence other organizational dynamics.  This particular feedback loop is generally reinforcing but it’s not some superpower, as can be seen in a couple of problems nuclear organizations may face: 

Why is a CAP ineffective?  The NSC establishes the boundaries between the desirable, acceptable, tolerable and unacceptable in terms of problem recognition, analysis and resolution.  But the strongest SC cannot compensate for inadequate resources from a plant owner, a systemic bias in favor of continued production****, a myopic focus on programmatic aspects (following the rules instead of searching for a true answer) or incompetence in plant staff. 

Why are plant records falsified?  An organization’s party line usually pledges that the staff will always be truthful with customers, regulators and each other.  The local culture, including its NSC, should reinforce that view.  But fear is always trying to slip in through the cracks—fear of angering the boss, fear of missing performance targets, fear of appearing weak or incompetent, or fear of endangering a plant’s future in an environment that includes the plant’s perceived enemies.  Fear can overcome even a strong NSC.

Our Perspective

NSC is real and complicated but it is not mysterious.  Most importantly, NSC is not some red herring that keeps us from seeing the true causes of underlying organizational performance problems.  Safetymatters will continue to offer you the information and insights you need to be more successful in your efforts to understand NSC and use it as a force for better performance in your organization.

Your organization will not increase its performance in the safety dimension if it continues to apply and reprocess the same thinking that the nuclear industry has been promoting for years.  NSC is not something that can be directly managed or even influenced independent of other organizational variables.  “Leadership” alone will not fix your organization’s problems.  You may protect your career by parroting the industry’s adages but you will not move the ball down the field without exercising some critical and independent thought.

We wish you a safe and prosperous 2017.

*  “Palisades Power Purchase Agreement to End Early,” Entergy press release (Dec. 8,2016).

**  L. Buchsbaum, “France’s Nuclear Storm: Many Power Plants Down Due to Quality Concerns,” Power (Dec. 1, 2016).  Retrieved Jan. 4, 2017.

***  For example, take a look back at INSAG-4 and NUREG-1756 (which we reviewed on May 26, 2015).

****  We can call that the Nuclear Production Culture (NPC).

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