Learning About Nuclear Safety Culture from the Web, Maybe

The Internet  Source:Wikipedia

We’ve come across some Internet content (one website, one article) that purports to inform the reader about nuclear safety culture (NSC).  This post reviews the content and provides our perspective on its value.

NSC Website

It appears the title of this site is “Nuclear Safety Culture”* and the primary target is journalists who want an introduction to NSC concepts, history and issues.  It is a product of a group of European entities.  It is a professional looking site that covers four major topics; we’ll summarize them in some detail to show their wide scope and shallow depth. 

Nuclear Safety Culture covers five sub-topics:

History traces the shift in attitudes toward and protection from ionizing radiation as the possible consequences became better known but the story ends in the 1950s.  Key actions describe the roles of internal and external stakeholders during routine operations and emergency situations.  The focus is on power production although medicine, industrial uses and weapons are also mentioned.  Definition of NSC starts with INSAG (esp. INSAG-4), then adds INPO’s directive to emphasize safety over competing goals, and a familiar list of attributes from the Nuclear Safety Journal.  As usual, there is nothing in the attributes about executive compensation or the importance of a systems view.  IAEA safety principles are self explanatory.  Key scientific concepts cover the units of radiation for dose, intake and exposure.  Some values are shown for typical activities but only one legal limit, for US airport X-rays, is included.**  There is no information in this sub-topic on how much radiation a person can tolerate or the regulatory limits for industrial exposure.

From Events to Accidents has two sub-topics:

From events to accidents describes the 7-level International Nuclear Event Scale (from a minor anomaly to major accident) but the scale itself is not shown.  This is a major omission.  Defence in depth discusses this important concept but provides only one example, the levels of physical protection between a fuel rod in a reactor and the environment outside the containment.

Controversies has two sub-topics:

Strengths and Weaknesses discuss some of the nuclear industry’s issues and characteristics: industry transparency is a double-edge sword, where increased information on events may be used to criticize a plant owner; general radiation protection standards for the industry; uncertainties surrounding the health effects of low radiation doses; the usual nuclear waste issues; technology evolution through generations of reactors; stress tests for European reactors; supply chain realities where a problem anywhere is used against the entire industry; the political climate, focusing on Germany and France; and energy economics that have diminished nuclear’s competitiveness.  Overall, this is a hodgepodge of topics and a B- discussion.  The human factor provides a brief discussion of the “blame culture” and the need for a systemic view, followed by summaries of the Korean and French document falsification events.

Stories summarizes three events: the Brazilian theft of a radioactive source, Chernobyl and Fukushima.  They are all reported in an overly dramatic style although the basic facts are probably correct.

The authors describe what they call the “safety culture breach” for each event.  The problem is they comingle overarching cultural issues, e.g., TEPCO’s overconfident management, with far more specific failures, e.g., violations of safety and security rules, and consequences of weak NSC, e.g., plant design inadequacies.  It makes one wonder if the author(s) of this section have a clear notion of what NSC is.

It isn’t apparent how helpful this site will be for newbie journalists, it is certainly not a complete “toolkit.”  Some topics are presented in an over-simplified manner and others are missing key figures.  In terms of examples, the site emphasizes major accidents (the ultimate trailing indicators) and ignores the small events, normalization of deviance, organizational drift and other dynamics that make up the bulk of daily life in an organization.  Overall, the toolkit looks a bit like a rush job or unedited committee work, e.g., the section on the major accidents is satisfactory but others are incomplete.  Importantly (or perhaps thankfully) the authors offer no original observations or insights with respect to NSC.  It’s worrisome that what the site creators call NSC is often just the safety practices that evolved as the hazards of radiation became better known. 

NSC Article

There is an article on NSC in the online version of Power magazine.  We are not publishing a link to the article because it isn’t very good; it looks more like a high schooler’s Internet-sourced term paper than a thoughtful reference or essay on NSC.

However, like the stopped clock that shows the correct time twice per day, there can be a worthwhile nugget in such an article.  After summarizing a research paper that correlated plants’ performance indicators with assessments of their NSC attributes (which paper we reviewed on Oct. 5, 2014), the author says “There are no established thresholds for determining whether a safety culture is “healthy” or “unhealthy.””  That’s correct.  After NSC assessors consolidate their interviews, focus groups, observations, surveys and document reviews, they always identify some improvement opportunities but the usual overall grade is “pass.”***  There’s no point score, meter or gauge.  Perhaps there should be.

Our Perspective

Don’t waste your time with pap.  Go to primary sources; an excellent starting point is the survey of NSC literature performed by a U.S. National Laboratory (which we reviewed on Feb. 10, 2013.)  Click on our References label to get other possibilities and follow folks who actually know something about NSC, like Safetymatters.


*  Nuclear Safety Culture was developed as part of the NUSHARE project under the aegis of the European Nuclear Education Network.   Retrieved June 19, 2017.

**  The airport X-ray limit happens to be the same as the amount of radiation emitted by an ordinary banana.

***  A violation of the Safety Conscious Work Environment (SCWE) regulations is quite different.  There it’s zero tolerance and if there’s a credible complaint about actual retaliation for raising a safety issue, the licensee is in deep doo-doo until they convince the regulator they have made the necessary adjustments in the work environment.

Korean Perspective on Nuclear Safety Culture

Republic of Korea flag

We recently read two journal articles that present the Korean perspective on nuclear safety culture (NSC), one from a nuclear research institute and the other from the Korean nuclear regulator.  Selected highlights from each article are presented below, followed by our perspective on the articles’ value.

Warning:  Although the articles are in English, they were obviously translated from Korean, probably by a computer, and the translation is uneven.  However, the topics and references (including IAEA, NRC, J. Reason and Schein) will be familiar to you so with a little effort you can usually figure out what the authors are saying.

Korean NSC Situation and Issues*

The author is with the Korea Atomic Energy Research Institute.  He begins by describing a challenge facing the nuclear industry: avoiding complacency (because plant performance has been good) when the actual diffusion of NSC attributes among management and workers is unknown and major incidents, e.g., Fukushima, point to deficient NSC has a major contributor.  One consequence of this situation is that increased regulatory intervention in licensee NSC is a clear trend. (pp. 249, 254)

However, different countries have differing positions on how to intervene in or support NSC because (1) the objectification of an essentially qualitative factor is necessarily limited and (2) they fear diluting the licensee’s NSC responsibilities and/or causing unintended consequences. 

The U.S. NRC’s NSC history is summarized, including how NSC is addressed in the Reactor Oversight Process and relevant supplemental inspection procedures.  The author’s perception is “If safety culture vulnerability is judged to seriously affect the safety of a nuclear power plant, NRC orders the suspension of its operation, based on the judgment.” (p. 254)  In addition, the NRC has “developed and has been applying a licensee safety culture oversight program, based on site-stationed inspector's observation and assessment . . .” (ibid.)

The perception that the NRC would shut down a plant over NSC issues is a bit of a stretch.  While the agency is happy to pile on over NSC shortcomings when a plant has technical problems (see our June 16, 2016 post on ANO) it has also wrapped itself in knots to rationalize the acceptability of plant NSC in other cases (see our Jan. 30, 2013 post on Palisades).   

There is a passable discussion of the methods available for assessing NSC, ranging from observing top management leadership behavior to taking advantage of “Big data” approaches.  However, the author cautions against reliance on numeric indicators; they can have undesirable consequences.  He observes that Europe has a minimal number of NSC regulations while the U.S. has none.  He closes with recommendations for the Korean nuclear industry.

Regulatory Oversight of NSC**

The authors are with the Korea Institute of Nuclear Safety, the nuclear regulatory agency.  The article covers their philosophy and methods for regulating NSC.  It begins with a list of challenges associated with NSC regulatory oversight and a brief review of international efforts to date.  Regulatory approaches include monitoring onsite vulnerabilities (U.S.), performing standard reviews of licensee NSC evaluations (Canada, Korea) and using NSC indicators (Germany, Finland) although the authors note such indicators do not directly measure NSC. (pp. 267-68)

In the Korean view, the regulator should perform independent oversight but not directly intervene in licensee activities.  NSC assessment is separate and different from compliance-based inspection, requires effective two-way communications (i.e., a common language) and aims at creating long-term continuous improvement. (pp. 266-67)  Their NSC model uses a value-neutral definition of NSC (as opposed to strong vs. weak); incorporates Schein’s three levels; includes individuals, the organization and leaders; and emphasizes the characteristics shared by organization members.  It includes elements from IAEA GSR Part 2, the NRC, J. Reason's reporting culture, DOE, INPO, just culture and Korea-specific concerns about economics trumping safety. (pp. 268-69)***

In the detailed description of the model, we were pleased to see “Incentives, sanctions, and rewards correspond to safety competency of individuals.”  (p. 270)  An organization’s reward system has always been a hot-button issue for us; all nuclear organizations claim to value NSC, few are willing to pay for achieving or maintaining it.  Click the “Compensation” label to see all our posts on this topic.

The article presents a summary of an exercise to validate the model, i.e., link model components to actual plant safety performance.  The usual high-level mumbo-jumbo is not helped by the rough spots in the translation.  Inspection results, outage rates, scrams, incidents, unplanned shutdowns and radiation doses were claimed to be appropriately correlated with NSC model components.

There should be no surprise that the model was validated.  Getting a “right” answer is obviously good for the regulator.  We routinely express some skepticism over studies that validate models when we can’t see the actual data and we don’t know if the analysis was independently reviewed by anyone who actually understands or cares about the subject matter.

During the pilot study, several improvement areas in Korean NPP's safety culture were identified.  The approach has not been permanently installed.

Our Perspective

These articles are worth reading just to get a different, i.e., non-U.S., perspective on regulatory evaluation of (and possible intervention in) licensee SC.  It’s also worthwhile to get a non-U.S. perspective on what they think is going on in U.S. nuclear regulatory space.  Their information sources probably include a June 2015 NRC presentation to Korean regulators referenced in our Aug. 24, 2015 post.  

It’s interesting that Europe has some regulations that focus on ongoing communications with the licensees.  In contrast, the U.S. has no regulations but an approach that can stretch like a cheap blanket to cover all possible licensee situations.

Afterword

We haven’t posted for awhile.  It’s not because we’ve lost interest but there hasn’t been much worth reporting.  The big nuclear news in the U.S. is not about NSC, rather it’s about plants being scheduled for shutdown because of their economics.  International information sources have not been offering up much either.  For example, the LinkedIn NSC forum has pretty much dried up except for recycled observations and consultants’ self-serving white papers.


*  Y-H Lee, “Current Status and Issues of Nuclear Safety Culture,” Journal of the Ergonomics Society of Korea vol. 35 no. 4 (Aug 2016) 247-261.

**  YS Choi, SJ Jung and YH Chung, “Regulatory Oversight of Nuclear Safety Culture and the Validation Study on the Oversight Model Components,” Journal of the Ergonomics Society of Korea vol. 35 no. 4 (Aug 2016) 263-275.

***  Korea has had problems, mentioned in both articles, caused by deficient NSC.  Also see our Aug. 7, 2013 post for related information.