Wednesday, November 30, 2016

Here We Go Again: NRC to Inspect Nuclear Safety Culture at Entergy’s Pilgrim Plant

Entergy’s Pilgrim station has been in Column 4 of the Nuclear Regulatory Commission’s (NRC) Action Matrix since September 2015.  Column 4 plants receive more numerous, extensive and intrusive NRC inspections than plants that receive baseline inspections.  Pilgrim is in Column 4 primarily because its Corrective Action Program (CAP) is not effective, i.e., the CAP is not permanently fixing significant plant problems.  Pilgrim’s latest inspection follows NRC Inspection Procedure (IP) 95003.  As part of IP 95003 the NRC will assess the plant’s nuclear safety culture (NSC) to ascertain if a weak NSC is contributing to the plant’s inability or unwillingness to identify, specify, investigate and permanently fix problems.*

Our Perspective

Those are the facts.  Now let’s pull on our really tight crankypants.  Entergy is in a race with the Tennessee Valley Authority (TVA) to see which fleet operator can get into the most trouble with the NRC over NSC issues.  We reviewed Entergy’s NSC problems at its different plants in our April 13, 2016 post.  Subsequently, the NRC published its report on NSC issues at Entergy’s Arkansas Nuclear One (ANO) plant, which also was subject to an IP 95003 inspection.  We reviewed the ANO inspection report on June 16, 2016.  That’s all basically bad news.  However, there is one bit of good news: Entergy recently offloaded one of its plants, FitzPatrick, to Exelon, a proven nuclear enterprise with a good track record. 

Did we mention that Pilgrim is on the industrial equivalent of Death Row?  Entergy has announced its plan to shut down the plant on May 31, 2019.**  Local anti-nuclear activists want it shut down immediately.***  Pilgrim will certainly be under increased NRC scrutiny for the rest of its operating life.  The agency says “Should there be indications of degrading performance, we will take additional regulatory actions as needed, . . . up to and including a plant shutdown order.”****  As readers know, the Safetymatters  founders worked in the commercial nuclear industry and are generally supportive of it.  But maybe it’s time to pull the plug at Pilgrim. 

"Can't anybody here play this game?" — Casey Stengel (1890-1975)

*  “NRC to Perform Wide-Ranging Team Inspection at Pilgrim Nuclear Power Plant; Review Supports Agency’s Increased Oversight,” NRC press release No. I-16-030 (Nov.  28, 2016).  A.L. Burritt (NRC) to J. Dent (Entergy), “Pilgrim Nuclear Power Station – Notification of Inspection Procedure 95003 Phase ‘C’ Inspection” (Oct. 13, 2016).  ADAMS ML16286A592.

**  “Entergy Intends to Refuel Pilgrim in 2017; Cease Operations on May 31, 2019” (April 14, 2016).  Retrieved Nov. 29, 2016.

***  “Protesters Demand Pilgrim Nuclear Power Plant Be Shut Down Now,” (Nov. 28, 2016).  Retrieved Nov. 29, 2016.

****  “Additional NRC Oversight at Pilgrim Nuclear Power Plant,” an NRC webpage.  The quote is under the Assessment Results tab.  Retrieved Nov. 29, 2016.

Monday, November 14, 2016

NRC Identifies Nuclear Safety Culture Problems at Watts Bar. What a Surprise.

Watts Bar
A recent NRC inspection report* was very critical of both the Safety Conscious Work Environment (SCWE) and the larger Nuclear Safety Culture (NSC) at the Tennessee Valley Authority’s (TVA’s) Watts Bar plant.  This post presents highlights from the report and provides our perspective on the situation. 

The inspection was a follow-up to a Chilling Effect Letter (CEL)** the NRC issued to Watts Bar in March, 2016.  We reviewed the CEL on March 25, 2016.

The inspection team conducted focus groups and interviews with staff and management.  “. . . the inspection team identified deficiencies in the safety conscious work environment across multiple departments.  Although nearly all employees indicated that they were personally willing to raise nuclear safety concerns, many [nearly half] stated they did not feel free to raise concerns without fear of retaliation.  In addition, most employees did not believe that concerns were promptly reviewed or appropriately resolved, either by their management or via the Corrective Action Program [CAP].” (p. 5) 

While discussing management’s response to the CEL, employees were cautiously optimistic that their work environment would improve although they could not cite any specific examples of improvements.  Management putting their “spin” on the CEL and prior instances of retaliation against employees contribute to a lack of trust between employees and management. (p. 6)

In general, “. . . most employees also noted that there was a strong sense of production over safety throughout the organization. . . . Focus group participants provided examples of disrespectful behavior [by management], intimidation and shopping around work to other employees or contractors who would be less likely to raise issues. . . . all focus groups stated that they could enter issues into the CAP; however, most believed the CAP was ineffective at resolving issues.  The CAP was characterized as a problem identification, but not a problem resolution tool.” (p. 7)

Employees also expressed a lack of confidence in the plant’s Employee Concerns Program. (pp. 7-8)

Our Perspective

The chilled work environment and other NSC issues described in the inspection report did not arise out of thin air.  TVA has a long history of deficient SC at its plants.  Our March 25, 2016 post included a reference to a 2009 NRC Confirmatory Order, still in effect, covering TVA commitments to address past SCWE issues at all three of their nuclear sites.

Browns Ferry, another TVA plant, was a regular character in our 2012 series on the NRC’s de facto regulation of NSC.  As we noted on July 3, 2012 “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.”  As part of their penance, Browns Ferry management made a presentation on their SC improvement actions at the 2014 NRC Regulatory Information Conference.  See our April 25, 2014 post for details.

For a little icing on the nuclear cake, our March 25, 2016 post also summarized the TVA Chief Nuclear Officer’s compensation plan, which doesn’t appear to include any financial incentives for establishing or maintaining a strong NSC.  .

TVA’s less-than-laser focus on safety is also reflected in their non-nuclear activities.  For example, the Dec. 22, 2008 Kingston Fossil Plant coal fly ash slurry spill was the largest such spill in U.S. history.  It was not some “act of God”; neighbors had noticed minor leaks for years and TVA confirmed there had been prior instances of seepage.***  

Bottom line: This unambiguous and complete inspection report includes multiple, significant deficiencies but it’s not new news.

Postscript:  On April 13, 2016 we asked “Is Entergy’s Nuclear Safety Culture Hurting the Company or the Industry?”  We could ask the same question about TVA.  The answer in TVA’s case is “Probably not” primarily because it is a federal corporation and thus is perceived differently from investor-owned nuclear enterprises.  For political reasons, public entities, including TVA and the Department of Energy’s nuclear facilities, are deemed too important to fail.  As a consequence, the bar for tolerable performance is lower and their shortcomings do not appear to infect the perception of private entities that conduct similar activities.

A. Blamey (NRC) to J.W. Shea (TVA), “Watts Bar Nuclear Plant - NRC Problem Identification and Resolution Inspection (Part 1); and Safety Conscious Work Environment Issues of Concern Follow-up; NRC Inspection Report 05000390/2016007 and 05000391/2016007,” (Oct. 26, 2016).  ADAMS ML16300A409.

Chilled Work Environment for Raising and Addressing Safety Concerns at the Watts Bar Nuclear Plant,” (March 23, 2016).  ADAMS ML16083A479.

Wikipedia, “Kingston Fossil Plant coal fly ash slurry spill.”  Retrieved Nov. 11, 2016.

Thursday, November 3, 2016

Nuclear Safety Culture in the Latest U.S. Report for the Convention on Nuclear Safety

NUREG-1650 cover
The Nuclear Regulatory Commission (NRC) recently published NUREG-1650, rev. 6, the seventh national report for the Convention on Nuclear Safety.*  The report is prepared for the triennial meeting of the Convention and describes the policies, laws, practices and other activities utilized by the U.S. to meet its international obligations and ensure the safety of its commercial nuclear power plants.  Nuclear Safety Culture (NSC) is one of the topics discussed in the report.  This post highlights NSC changes (new items and updates) from the sixth report (NUREG-1650, rev. 5) which we reviewed on March 26, 2014.  The numbers shown below are section numbers in the current report.

8.1.5  International Responsibilities and Activities 

The NRC’s International Regulatory Development Partnership (IRDP) program supports the safe introduction of nuclear power in “new entrant” countries.  IRDP training addresses many topics including safety culture. (p. 99)  Human Resources 

This section was updated to include a reference to the 2015 NRC Safety Culture and Climate Survey.

10.1  Background [for article 10, “Priority to Safety”] 

The report notes “All U.S. nuclear power plants have committed to conducting a safety culture self-assessment every 2 years and have committed to conducting monitoring panels as described in Nuclear Energy Institute (NEI) 09-07, “Fostering a Healthy Nuclear Safety Culture,” dated March 2014.” (p. 120)  We reviewed NEI 09-07 on Jan. 6, 2011.

10.4  Safety Culture

The bulk of the report addressing NSC is in this section and exhibits a significant rewrite from the previous report.  Some of the changes reorganized existing material but there are also new items, discussed below, and additional background information.  Overall, section 10.4 is more complete and lucid than its predecessor.

10.4.1  Safety Culture Policy Statement

This contains material that formerly appeared under 10.4 and has been expanded to include two new safety culture traits, “questioning attitude” and “decisionmaking.”  The NRC worked with licensees and other stakeholders to develop a common language for discussing and assessing NSC; this effort resulted in NUREG-2165, “Safety Culture Common Language.”  We reviewed NUREG-2165 on April 6, 2014.

10.4.2  NRC Monitoring of Licensee Safety Culture 

This section has been edited to improve clarity and completeness, and provide more specific references to applicable procedures.  For example, IP 95003 now includes detailed guidance for NRC inspectors who conduct an independent assessment of licensee NSC.**

New language specifies interventions the NRC may take with respect to licensee NSC: “These activities range from requesting the licensee perform a safety culture self-assessment to a meeting between senior NRC managers and a licensee’s Board of Directors to discuss licensee performance issues and actions to address persistent and continuing safety culture cross-cutting issues.” (p. 128)

10.4.3 The NRC Safety Culture

This section covers the NRC’s efforts to maintain and enhance its own SC.  The section has been rewritten and strengthened throughout.  It discusses the need for continuous improvement and says “Complacency lends itself to a degradation in safety culture when new information and historical lessons are not processed and used to enhance the NRC and its regulatory products.” (p. 130)  That’s true; SC that is not actively maintained will invariably decay.

12.3.5  Human Factors Information System 

This system handles human performance information extracted from NRC inspection and licensee event reports.  The report notes “the database is being updated to include data with a safety culture perspective.” (p. 146)

Institute of Nuclear Power Operations (INPO)

INPO also provides content for the report, basically a description of INPO’s activities to ensure plant safety.  Their discussion includes a section on SC, which is not materially different from their contribution to the previous version of the report.

Our Perspective

Like the sixth national report, this seventh report appears to cover every aspect of the NRC’s operations but does not present any new information.  In other words, it’s a good reference document.

The NSC changes are incremental but move toward increased bureaucratization and intrusive oversight of NSC.  The NRC is certainly showing the hilt of the sword of regulation if not the blade.  We still believe if it reads like a set of requirements, results in enforceable interventions and quacks like the NRC, it’s de facto regulation.

*  NRC NUREG-1650 Rev. 6, “The United States of America Seventh National Report for the Convention on Nuclear Safety” (Oct. 2016).  ADAMS ML16293A104.  The Convention on Nuclear Safety is a legally binding commitment to maintain a level of safety that meets international benchmarks.

**  This detailed guidance is also mentioned in 12.3.6 Support to Event Investigations and For-Cause Inspections and Training (p. 148).