Thursday, June 16, 2016

Nuclear Safety Culture at ANO—the NRC Weighs In

Arkansas Nuclear One (credit: Edibobb)
On June 25, 2015 we posted about Arkansas Nuclear One’s (ANO) performance problems (a stator drop, inadequate flood protection and unplanned scrams) and the Nuclear Regulatory Commission’s (NRC's) reaction.  The NRC assigned ANO to column 4 of the Action Matrix where it receives the highest level of oversight for an operating plant.  As part of this increased oversight, the NRC conducted a comprehensive inspection of ANO performance, programs and processes.  A lengthy inspection report* was recently issued.

According to the NRC press release** the inspection team identified the following major issues:

“Resource reductions and leadership behaviors were the most significant causes for ANO’s declining performance. . . . ANO management did not reduce workloads through efficiencies or the elimination of unnecessary work, . . . Leaders . . . did not address expanding work backlogs***. . . . An unexpected increase in employee attrition between 2012 and 2014 caused a loss in experienced personnel, . . . Since 2007, the reduced resources created a number of changes that slowly began to impact equipment reliability.  The Entergy fleet reduced preventive maintenance and extended the time between some maintenance activities.”

The press release goes on to list numerous ANO corrective actions and NRC observations that suggest the potential for improved plant performance.

What About ANO’s Safety Culture?

The press release also mentions that the inspection team evaluated the adequacy of a 2015 Third Party Nuclear Safety Culture Assessment (TPNSCA) conducted at ANO.  The press release gives short shrift to the key role a weak safety culture (SC) played in creating ANO’s problems in the first place and the extensive SC questions raised and diagnostics performed by the NRC inspection team.

Last June, based on NRC and ANO meeting presentations, we 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.”  These are serious deficiencies.  Do the same or similar problems appear in the inspection report?  To answer that question, we need to dig into the details of the 243 page report.

The Cover Letter

Top-level SC problems are included in the NRC cover letter which says “The inspection team identified what it considered to be missed opportunities for ANO to have promptly initiated performance improvements since being placed in Column 4.  More specifically, ANO: 1) was slow to implement corrective actions to address the findings from the Corrective Action Program cause evaluation and the Third Party Nuclear Safety Culture Assessment; 2) did not perform an evaluation of the causes for safety culture problems; . . .” (letter, p. 2)

Executive Summary

The report's Executive Summary says “The Third Party Nuclear Safety Culture Assessment identified that ANO personnel tolerated, and at times normalized, degraded conditions.”  Expanding on the missed opportunities comment in the cover letter, “the NRC team’s independent safety culture evaluation noted limited improvement in safety culture since the completion of ANO’s independent Third Party Nuclear Safety Culture Assessment.” (report p. 5)  “ANO did not create a specific improvement plan to address the findings of the safety culture assessments, choosing to address selected safety culture attributes that were associated with root cause evaluations rather than treating the findings in the context of a separate problem area.  By not performing a cause evaluation for safety culture, ANO management missed the opportunity to address the full scope of safety culture weaknesses.” (pp. 5-6)

Review of ANO Recovery Plan 

The NRC’s critique of ANO’s Recovery Plan included “The NRC team questioned the recovery team’s decision not to perform casual evaluations of the PAs [Problem Areas].  In response, ANO performed apparent cause evaluations (ACEs) or gap analyses for each PA.  The NRC team questioned the recovery team’s decision not to perform causal evaluations for the safety culture attributes identified in [a 2014] . . . safety culture survey, the TPNSCA, and the RCEs [Root Cause Evaluations].  The team also questioned the recovery team’s decision not to treat safety culture as a separate problem area.” (p. 21)

This is an example where the NRC was still identifying ANO’s overarching problems for the plant staff.

Review of RCEs for Fundamental Problem Areas

“ANO’s Vendor Oversight RCE identified weak implementation of administrative controls and placing undue confidence in vendor services as common cause failures. However, ANO did not assess the underlying safety culture aspects.” (p. 110, emphasis added)

This is not “blame the vendor” but is a different serious problem, viz., an over-reliance on vendor activities to protect the customer.  (This problem is not unique to ANO; it also might exist at the Waste Isolation Pilot Plant.  See our May 3, 2016 post for details.)

Inspection Report Chapter on SC

The NRC team conducted its own assessment of ANO’s SC. The NRC team interviewed personnel at all levels, conducted focus group discussions, performed behavioral observations, reviewed documents and relevant plant programs, and evaluated plant management meetings.  Overall, they assessed all ten SC traits using the full set of SC attributes contained in NRC documentation.  For each trait, the report includes its attributes, inspection team observations and findings, and relevant ANO corrective actions.

The team also reviewed seven RCEs and concluded ANO addressed the major SC attributes identified in each RCE.  However, “The NRC team noted that ANO identified that some safety culture attributes were contributors to several of the RCE problem statements, but ANO did not consider the collective significance.” (p. 184)

ANO took the hint.  “In response to the NRC team’s concerns, ANO performed a common cause analysis of all of the safety culture attributes that were identified in the recovery RCEs in order to assess the collective significance and causes.” (p. 185)  ANO developed a SC Area Action Plan (AAP) and the NRC concluded “The corrective actions identified in the NSC AAP were comprehensive and appropriate to address the causes for safety culture weaknesses.” (p. 186)

“The NRC team’s graded safety culture assessment independently confirmed the results from the TPNSCA.” (p. 188)

“The NRC team was concerned that the SCLT’s [Safety Culture Leadership Team, senior managers] conclusion that ANO’s safety culture was “adequate” in August 2015 did not appropriately reflect the data provided by, or the recommendations from, the NSCMP [Nuclear Safety Culture Monitoring Panel, mid-level personnel].  This SCLT conclusion did not reflect the declining condition with respect to safety culture and indicated a lack of awareness that improvements in safety culture at ANO were needed.”  The SCLT eventually came around and in December 2015 declared that ANO’s SC was not acceptable. (p. 192)

Our Perspective

The NRC is optimistic that ANO has correctly identified the root causes of its performance problems and has undertaken corrective actions that will ultimately prove effective.  We hope so but we’ll go with “trust but verify” on this one.  ANO still exhibits problems with incomplete analyses and leaning on the NRC to identify systemic deficiencies.

The NRC team took a good look at ANO's SC.  Quite frankly, their effort was more comprehensive than we expected.  They used an acceptable methodology for their SC assessment.  The fact that their assessment findings were consistent with the TPNSCA is not surprising.  SC evaluation is a robust social science activity and qualified SC evaluators using similar techniques should obtain generally comparable results.

We believe the NRC’s SC professionals are qualified and competent but probably encouraged to support the overall inspection findings.  The elephant in the room is that SC is a policy, not a regulation.  Would the NRC keep a plant in column 4 based solely on their belief that the plant SC is deficient?  Look at the contortions the agency performed at Palisades as that plant’s SC somehow went from weak, with constant problems, to “improving” and, we inferred, acceptable.  (See our Jan. 30, 2013 post for details.)

There may have been a bit of similar magical thinking at ANO.  In the inspection report, every SC trait had examples of shortcomings but also had “appropriate” corrective actions to improve performance.****  How can this be when ANO (and Entergy) have been so slow to grasp the systemic nature of their SC problems?

Let’s close on a different note.  Earlier this year ANO named a full-time SC manager, a person whose background is in plant security.  On the surface, this is an “unfiltered” choice.  (See our March 10, 2016 post for a discussion of filtering in personnel decisions.)  He may be exactly the type of person ANO needs to make SC improvements happen.  We wish him well.

*  M. L. Dapas (NRC) to J. Browning (ANO), “Arkansas Nuclear One – NRC Supplemental Inspection Report 05000313/2016007 and 05000368/2016007” (June 9, 2016).  ADAMS ML16161B279.

**  V. Dricks, Press Release, “NRC Issues Comprehensive Inspection Report on Arkansas Nuclear One” (June 13, 2015).

***  We have often noted that large backlogs, especially of safety-related work, are an artifact of a weak SC.

****  One trait was judged to have no significant issues so corrective action was not needed.


  1. Lesson to be Learned:

    It is an inescapable fact that things were the way they were for as long as they were that way because INPO wanted them that way, INPO tolerated their being that way, or INPO didn’t know that they were that way.

    How come?

  2. Excellent point. It's interesting that when the stuff begins to fly over long-standing issues, none of it sticks to INPO.


  3. The members of INPO continue to keep INPO in the batter’s box despite more than three strikes: LaSalle Foreign Material Injection Near Miss Fuel Damage 1996, Davis-Besse Near Miss LOCA 2002, Arkansas Nuclear One Fatal Load Drop and Flood Barrier Failures 2015, San Onofre Replacement Steam Generators 2012, Contaminated Groundwater Epidemic, etc.

    How come?
    What are the other INPO “strikes?”


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