Tuesday, July 3, 2012

NRC Non-Regulation of Safety Culture: Second Quarter Update

NRC SC poster, ADAMS ML120810464.
On March 17th we published a post on NRC safety culture (SC) related activities with individual licensees since the SC policy statement was issued in June, 2011.  This post is an update, highlighting selected NRC actions from mid-March through June. 

Our earlier post mentioned Browns Ferry, Fort Calhoun and Palisades as plants where the NRC was undertaking SC related activities.  It looks like none of those plants has resolved its SC issues. 

For Browns Ferry we reported that the NRC was reviewing the plant’s 2011 SC surveys.  Turns out that was just the tip of the iceberg.  A recent PI&R inspection report indicates that the plant’s SC problems have existed for years and are deep-rooted.  Over time, Browns Ferry has reported SC issues including production and schedule taking priority over safety (2008), “struggling” with SC issues (2010) and a decline in SC (2011).  All of this occurred in spite of multiple licensee interventions and corrective actions.  The NRC’s current view is “Despite efforts to address SC issues at the site, the inspectors concluded that the lack of full confidence in the CAP has contributed to a decline in the SC since the last PI&R inspection.”*  We don’t expect this one to go away anytime soon.

Fort Calhoun management had said that SC deficiencies had contributed to problems in their CAP.  During the quarter, they presented actions planned or taken to remediate their SC deficiencies.  On June 11th, the NRC issued a Confirmatory Action Letter with a lengthy list of actions to be completed prior to plant restart.  One item is “OPPD will conduct a third-party safety culture assessment . . . and implement actions to address the results . . . .”**  It looks like Fort Calhoun is making acceptable progress on the SC front and we’d be surprised if SC ends up being an item that prevents restart.  Last April we provided some additional information on Fort Calhoun here.

In Palisades’ case, the NRC is asking for an extensive set of information on the actions being taken to improve SC at the site.  The last item on the long list requests the latest SC assessment for Entergy’s corporate office.  (This is not simply a fishing expedition.  Entergy is in trouble at other nuclear sites for problems that also appear related to SC deficiencies.)  After the information is provided and reviewed, the NRC “believe[s] that a public meeting on the safety culture assessment and your subsequent actions would be beneficial to ensure a full understanding by the NRC, your staff, and the public.”***  Back in January, we provided our perspective on Palisades here and here.

New NRC SC activity occurred at Susquehanna as part of a supplemental inspection related to a White finding and a White performance indicator.  The NRC conducted an “assessment of whether any safety culture component caused or significantly contributed to the white finding and PI.”  The assessment was triggered by PPL’s report that SC issues may have contributed to the plant’s performance problems.  The NRC inspectors reviewed documents and interviewed focus groups, individual managers and groups involved in plant assessments.  They concluded “components of safety culture identified by PPL did not contribute to the White PI or finding, and that the recently implemented corrective actions appear to being well received by the work force.”****  We report this item because it illustrates the NRC’s willingness and ability to conduct its own SC assessments where the agency believes they are warranted.

Our March post concluded: “It’s pretty clear the NRC is turning the screw on licensee safety culture effectiveness, even if it’s not officially “regulating” safety culture.”  That still appears to be the case.

*  V.M. McCree (NRC) to J.W. Shea (TVA), Browns Ferry Nuclear Plant - NRC Problem Identification and Resolution Inspection Report 05000259/2012007, 05000260/2012007 and 05000296/2012007 and Exercise of Enforcement Discretion (May 28, 2012) ADAMS ML12150A219.

**  E.E. Collins (NRC) to D.J. Bannister (OPPD), Confirmatory Action Letter – Fort Calhoun Station (June 11, 2012)  ADAMS ML12163A287.

***  G.L. Shear (NRC) to A. Vitale (Entergy), Request for Information on SC Issues at Palisades Nuclear Plant (June 26, 2012) ADAMS ML12179A155.

**** D.J. Roberts (NRC) to T.S. Rausch (PPL Susquehanna), Susquehanna Steam Electric Station – Assessment Follow-Up Letter and Interim NRC 95002 Supplemental Inspection Report 05000387/2012008 (May 7, 2012) ADAMS ML12125A374.

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