WANO and NEA to Cooperate on Nuclear Safety Culture

World Nuclear News Oct. 4, 2017

According to an item* in World Nuclear News, the World Association of Nuclear Operators (WANO) and the Organisation for Economic Co-operation and Development’s Nuclear Energy Agency (NEA) signed a memorandum of understanding to cooperate on "the further development of approaches, practices and methods in order to proactively strengthen global nuclear safety."

One objective is to “enhance the common understanding of nuclear safety culture challenges . . .”  In addition, the parties have identified safety culture (SC) as a "fundamental subject of common interest" and plan to launch a series of "country-specific discussions to explore the influence of national culture on the safety culture".

Our Perspective

As usual, the press release touts all the benefits that are going to flow from the new relationship.  We predict the flow will be at best a trickle based on what we’ve seen from the principals over the years.  Following is our take on the two entities.

WANO is an association of the world's nuclear power operators.  Their objective is to exchange safety knowledge and operating experience among its members.  We have mentioned WANO in several Safetymatters posts, including Jan. 23, 2015, Jan. 7, 2015, Jan. 21, 2014 and May 1, 2010.  Their public contributions are generally shallow and insipid.  WANO may be effective at facilitating information sharing but it has no real authority over operators.  It is, however, an overhead cost for the economically uncompetitive commercial nuclear industry. 

NEA is an intergovernmental agency that facilitates cooperation among countries with nuclear technology infrastructures.  In our March 3, 2016 post we characterized NEA as an “empty suit” that produces cheerleading and blather.  We stand by that assessment.  In Safetymatters’ history, we have come across only one example of NEA adding value—when they published a document that encouraged regulators to take a systems view of SC.  See our Feb. 10, 2016 post for details.

No one should expect this new arrangement to lead to any breakthroughs in SC theory or insights into SC practice.  It will lead to meetings, conferences, workshops and boondoggles.  One hopes it doesn’t indirectly raise the industry’s costs or, more importantly, distract WANO from its core mission of sharing safety information and operating experience across the international nuclear industry. 


*  “WANO, NEA enhance cooperation in nuclear safety,” World Nuclear News (Oct. 4, 2017).

2016 NEA Report on Fukushima Lessons Learned

Five years after the Fukushima disaster, the Nuclear Energy Agency (NEA) has released an updated report* on Fukushima lessons learned.  It summarizes NEA and member country safety improvements and corrective actions, including “efforts to understand and characterise the importance of strong nuclear safety cultures . . .” (p. 3)

Keep in mind that countries (not plant operators) comprise the NEA so safety culture (SC) discussion centers on government, i.e., regulatory, activities.  Selected SC-related excerpts from the report follow:

“Several NEA member countries have adopted a broad consideration of safety culture characteristics, including human and organisational factors, which include specific safety culture programmes that focus on attitudes towards safety, organisational capability, decision-making processes [including during emergencies] and the commitment to learn from experience.” (p. 11)

“Some [countries] have adopted a systematic consideration of safety culture characteristics in inspection and oversight processes. . . . These include periodic internal and external safety culture assessments.” (p. 29)

Desirable SC characteristics for a regulator (as opposed to a licensee) are discussed on pp. 40-42.  That may seem substantial but it’s all pulled from a different 2016 NEA publication, “The Safety Culture of an Effective Nuclear Regulatory Body,” which we reviewed on Feb. 10, 2016.  That publication had one point worth repeating here, viz., the regulator, in its efforts to promote and ensure safety, should think holistically about the overall regulator-licensee- socio-technical-legal-political system in terms of causes and effects, feedback loops and overall system performance. 

Our Perspective

This report may be a decent high-level summary of activities undertaken around the world but it is not sufficiently detailed to provide guidance and it certainly contains no original analysis.  The report does include a respectable list of Fukushima-related references.

Many of the actions, initiatives and activities described in the report are cited multiple times, creating the impression of more content than actually exists.  For example, the quote above from p. 11 is repeated, in whole or in part, in at least four other places.

If the NEA were a person, we’d characterize it as an “empty suit.”  While the summaries of and excerpts from the references, meetings, etc. are satisfactory, the NEA-authored top-level observations are often pro-nuclear cheerleading or just plain blather, e.g., “NEA member countries have continued to take appropriate actions to maintain and enhance the level of safety at their nuclear facilities, and thus nuclear power plants are safer now because of actions taken since the accident.  Ensuring safety is a continual process, . . .” (p. 11)**


*  Nuclear Energy Agency, “Five Years after the Fukushima Daiichi Accident: Nuclear Safety Improvements and Lessons Learnt,” NEA No. 7284 (2016).  The NEA is an arm of the Organisation for Economic Co-operation and Development (OECD).  This report builds on a 2013 report, “The Fukushima Daiichi Nuclear Power Plant Accident: OECD/NEA Nuclear Safety Response and Lessons Learnt.”

**  As a catty aside, the reputation of the NEA’s relatively new Director-General doesn’t exactly contribute to the agency’s respectability, his having been called “a treacherous, miserable liar,” “first-class rat” and “a tool of the nuclear industry” by an influential U.S. Senator during a 2012 Huffington Post interview.  At that time, the Director-General was a U.S. Nuclear Regulatory Commissioner.

NEA’s Safety Culture Guidance for Nuclear Regulators

A recent Nuclear Energy Agency (NEA) publication* describes desirable safety culture (SC) characteristics for a nuclear regulator.  Its purpose is to provide a benchmark for both established and nascent regulatory bodies.

The document’s goal is to describe a “healthy” SC.  It starts with the SC definition in INSAG-4** then posits five principles for an effective nuclear regulator: Safety leadership is demonstrated at all levels; regulatory staff set the standard for safety; and the regulatory body facilitates co-operation and open communication, implements a holistic approach to safety, and encourages continuous improvement, learning and self-assessment.

The principle that caught our attention is the holistic (or systemic) approach to safety.  This approach is discussed multiple times in the document.  In the Introduction, the authors say the regulator “should actively scrutinise how its own safety culture impacts the licensees’ safety culture.  It should also reflect on its role within the wider system and on how its own culture is the result of its interactions with the licensees and all other stakeholders.” (p. 12)

A subsequent chapter contains a more expansive discussion of each principle and identifies relevant attributes.  The following excerpts illustrate the value of a holistic approach.  “A healthy safety culture is dependent on the regulatory body using a robust, holistic, multi-disciplinary approach to safety.  Regulators oversee and regulate complex socio-technical systems that, together with the regulatory body itself, form part of a larger system made up of many stakeholders, with competing as well as common interests.  All the participants in this system influence and react to each other, and there is a need for awareness and understanding of this mutual influence.” (p. 19)

“[T]he larger socio-technical system [is] influenced by technical, human and organisational, environmental, economic, political and societal factors [including national culture].  Regulators should strive to do more than simply establish standards; they should consider the performance of the entire system that ensures safety.” (p. 20)

And “Safety issues are complex and involve a number or inter-related factors, activities and groups, whose importance and effect on each other and on safety might not be immediately recognisable.” (ibid.)

The Conclusions include the following: “Regulatory decisions need to consider the performance and response of the entire system delivering safety, how the different parts of the system are coupled and the direction the system is taking.” (p. 28)

Our Perspective

Much of this material in this publication will be familiar to Safetymatters readers*** but the discussion of a holistic approach to regulation is more extensive than we’ve seen elsewhere.  For that reason alone, we think this document is worth your quick review.  We have been promoting a systems view of the nuclear industry, from individual power plants to the overall socio-technical-legal-political construct, for years. 

The committee that developed the guidance consisted of almost thirty members from over a dozen countries, the International Atomic Energy Agency and NEA itself.  It’s interesting that China was not represented on the committee although it has world's largest nuclear power plant construction program**** and, one would hope, substantial interest in effective safety regulation and safety culture.  (Ooops!  China is not a member of the NEA.  Does that say something about China's perception of the NEA's value proposition?)


*  Nuclear Energy Agency, “The Safety Culture of an Effective Nuclear Regulatory Body” (2016).  Thanks to Madalina Tronea for publicizing this document.  Dr. Tronea is the founder/moderator of the LinkedIn Nuclear Safety Culture discussion group.  The NEA is an arm of the Organisation for Economic Co-operation and Development (OECD).

**  International Nuclear Safety Advisory Group, “Safety Culture,” Safety Series No. 75-INSAG-4, (Vienna: IAEA, 1991), p. 4.

***  For example, the list of challenges a regulator faces includes the usual suspects: maintain the focus on safety, avoid complacency, resist external pressures, avoid regulatory capture and maintain technical competence. (pp. 23-25)

****  “China has world's largest nuclear power capacity under construction,” China Daily (Dec. 30, 2015).

Regulatory Influence on Safety Culture

In September, 2011 the Nuclear Energy Agency (NEA) and the International Atomic Energy (IAEA) held a workshop for regulators and industry on oversight of licensee management.  “The principal aim of the workshop was to share experience and learning about the methods and approaches used by regulators to maintain oversight of, and influence, nuclear licensee leadership and management for safety, including safety culture.”*

Representatives from several countries made presentations.  For example, the U.S. presentation by NRC’s Valerie Barnes and INPO’s Ken Koves discussed work to define safety culture (SC) traits and correlate them to INPO principles and ROP findings (we previously reviewed this effort here).  Most other presentations also covered familiar territory. 

However, we were very impressed by Prof. Richard Taylor’s keynote address.  He is from the University of Bristol and has studied organizational and cultural factors in disasters and near-misses in both nuclear and non-nuclear contexts.  His list of common contributors includes issues with leadership, attitudes, environmental factors, competence, risk assessment, oversight, organizational learning and regulation.  He expounded on each factor with examples and additional detail. 

We found his conclusion most encouraging:  “Given the common precursors, we need to deepen our understanding of the complexity and interconnectedness of the socio-political systems at the root of organisational accidents.”  He suggests using system dynamics modeling to study archetypes including “maintaining visible convincing leadership commitment in the presence of commercial pressures.”  This is totally congruent with the approach we have been advocating for examining the effects of competing business and safety pressures on management. 

Unfortunately, this was the intellectual high point of the proceedings.  Topics that we believe are important to assessing and understanding SC got short shrift thereafter.  In particular, goal conflict, CAP and management compensation were not mentioned by any of the other presenters.

Decision-making was mentioned by a few presenters but there was no substantive discussion of this topic (the U.K. presenter had a motherhood statement that “Decisions at all levels that affect safety should be rational, objective, transparent and prudent”; the Barnes/Kove presentation appeared to focus on operational decision making).  A bright spot was in the meeting summary where better insight into licensees’ decision making process was mentioned as desirable and necessary by regulators.  And one suggestion for future research was “decision making in the face of competing goals.”  Perhaps there is hope after all.

(If this post seems familiar, last Dec 5 we reported on a Feb 2011 IAEA conference for regulators and industry that covered some of the same ground.  Seven months later the bureaucrats had inched the football a bit down the field.)


*  Proceedings of an NEA/IAEA Workshop, Chester, U.K. 26-28 Sept 2011, “Oversight and Influencing of Licensee Leadership and Management for Safety, Including Safety Culture – Regulatory Approaches and Methods,” NEA/CSNI/R(2012)13 (June 2012).

NEA 2008-2011 Construction Experience Report: Not Much There for Safety Culture Aficionados.

This month the Nuclear Energy Agency, a part of the Organization for Economic Co-Operation and Development, published a report on problems identified and lessons learned at nuclear plants during the construction phase.  The report focuses on three plants currently under construction and also includes incidents from a larger population of plants and brief reviews of other related studies. 

The report identifies a litany of problems that have occurred during plant construction; it is of interest to us because it frequently mentions safety culture as something that needs to be emphasized to prevent such problems.  Unfortunately, there is not much usable guidance beyond platitudinous statements such as “Safety culture needs to be established prior to the start of authorized activities such as the construction phase, and it is applied to all participants (licensee, vendor, architect engineer, constructors, etc.)”, “Safety culture should be maintained at very high level from the beginning of the project” and, from an U.K. report, “. . . an understanding of nuclear safety culture during construction must be emphasized.”*

These should not be world-shaking insights for regulators (the intended audience for the report) or licensees.  On the other hand, the industry continues to have problems that should have been eliminated after the fiascos that occurred during the initial build-out of the nuclear fleet in the 1960s through 1980s; maybe it does need regular reminding of George Santayana’s aphorism: “Those who cannot remember the past are condemned to repeat it.” 


*  Committee on Nuclear Regulatory Activities, Nuclear Energy Agency, “First Construction Experience Synthesis Report 2008-2011,” NEA/CNRA/R(2012)2 (May 3, 2012), pp. 8, 16 and 41.