How Do You Actually Implement the NRC’s Safety Culture Policy Statement?

As we all know the NRC issued a policy statement on safety culture almost two years ago, presumably to set expectations for the industry to maintain strong safety cultures.  The policy statement is long on fuzzy things like traits and values but unfortunately short on specific “what do we do’s”.  The biggest hint may be in the invocation to accord safety issues the priority warranted by their significance.  Sounds right in theory but how does this actually get operationalized?

We are going to suggest a specific approach to apply safety culture policy in day-to-day nuclear management decision making.  As we’ve argued many times, focusing on specific decisions moves safety from the realm of theory to practice.  In general we think there may be significant advantages for organizations to do more to highlight, document and measure decisions involving safety considerations.  The benefit will be insight and emphasis on the “how and why” decisions are made and whether they achieve the safety balance envisioned by the NRC - and more importantly by the organization’s leadership.

We start with a numeric scale for what we call “decision quality”.  In our minds quality means how well a decision balances the priority accorded safety in light of the significance of the issue being addressed; in other words how well the decision does what the policy statement asks.  Conceptually this implies that an optimal decision achieves just the right balance for safety and that other decisions could under or over-shoot the optimal balance.  Can there be too much priority for safety?  Sure - remember the goal is to perform the nuclear mission safely, not to just pursue safety itself.  Here is the scale:

The scale sets a 0 value as the measure of an optimal balance of safety - meaning that it meets the expectation of the policy statement to give the priority warranted by safety significance.  Increasing positive values are associated with decisions that accord extra weight to safety; increasing negative values accord too little.  Use of a quantitative scale is the first step in being able to grade, track and provide feedback on decisions on a consistent basis.  When coupled with discussion of how significance was assessed and what the appropriate safety response needs to be, it provides many opportunities for a check and adjust process and organizational learning.

This leads to the next question which is: how should significance be determined?  There is of course NRC guidance via the significance determination process (SDP), including the red, yellow, white and green rainbow of significance levels, and this is our starting point.  The SDP include both qualitative (e.g. significant reduction in safety margin) and quantitative criteria (e.g. values of delta CDF and delta LERF).  While qualitative criteria may seem to some as lacking specificity, we’re fine with their use and in any event they are endemic in safety regulation.  We’re actually not that fond of the quantitative criteria since they are inherently hardware centric and do not encompass the complexity of the overall “system” that ultimately determines safety.  To provide quantification our approach is to again create a scale that correlates numeric values with the qualitative criteria.  Such “anchored scales” are a common and effective tool in decision analysis.  In addition we feel that the significance determinations need to be supplemented with an assessment of their uncertainty. 

It doesn’t take reviewing many event reports to see that judgments about safety significance are not always clear cut or unambiguous.  This variability in the adjudged significance can be the enabling mechanism for safety to not receive the appropriate priority - not because the priority doesn’t match the significance but because the significance has been discounted to justify a lower priority.  The catalysts can be as simple as overly optimistic thinking, normalization of deviation, complacency, or failing to ensure that the burden is on showing that something is safe versus showing that it is unsafe.  Our approach is to explicitly address the uncertainty of safety significance by introducing a second quantitative scale for this purpose.  When used together a judgment regarding significance would include both a nominal value (per SDM) and an uncertainty value.  These scales are illustrated below:

For decision making purposes the three scales would operate together to help arrive at appropriate decisions.  The significance scale would provide a nominal risk value.  If there was a little uncertainty in the assessed significance then the objective would be to make a decision that scores approximately “0” on the balance scale.  If there was greater uncertainty in the assessed significance the objective would be to select a decision option that scored higher on the balance scale; essentially giving safety higher priority to accommodate the potentially greater significance.  Decision options that rated negative balance values would avoided.

We see much of the value in this approach to be the focus on making the decision formation process more explicit, transparent and measurable.  Over time this structure provides greater opportunities for the organization to understand decisions and learn from the process not just the outcomes.  We also believe it may provide the basis for inferring and trending the safety culture within an organization.

In an upcoming post we’ll apply these decision scales to a specific plant situation to see how they might work in practice.

NRC Regulatory Information Conference (RIC) - Safety Culture (cont.)

Last week we previewed the safety culture (SC) content of the then-upcoming NRC RIC.  The Idaho National Lab speaker's slides were not available at that time but they are now and his presentation is reviewed below.  The focus is on the Advanced Test Reactor Programs but I think it's fair to infer that the thinking is representative of a wider swath of the DOE complex.

The presentation opens with five lengthy quotes from Admiral Rickover's November 1983 assessment of GPU and its competence to operate TMI-1.  The apparent intent is to illustrate that the principles for safe nuclear operations have been known (or at least available) for a long time.  Coincidentally, we posted on the Rickover assessment two months ago, and focused on one of the same quotes.  If you aren't acquainted with Rickover's seven principles, you really should read the introduction to the assessment, which is available from the Dickinson College library.

The presentation describes components of the new DOE Cross Cutting Performance Areas for category 1, 2 and 3 nuclear facilities:  Evaluating the effectiveness of operations, maintenance, engineering and training programs; developing, monitoring and evaluating SC; and evaluating issue identification and resolution activities, including the significance determination process and the evaluation and resolution process for high significance issues.

The presentation concluded with a list of areas being emphasized at the Idaho lab: What is the right (as opposed to allowable) thing to do, educating leaders, communications, and decision making that reflects a learning organization and doesn't result in safety drift.

The presentation hit most of the right notes, a major exception being no mention of management or contractor financial incentive plans.  However, the unmistakable tone is there is really nothing new required of the lab, just a refinement of past and current practices.  Perhaps that's true for them but I have limited confidence in DOE entities' ability to self-evaluate.  We're pretty sure SC issues exist or have existed at other DOE facilities, especially the Vit Plant (click the label in the top right-hand column to pull up our posts).

NRC Regulatory Information Conference (RIC) - Safety Culture Preview

The RIC is this week, March 12-14.  The teaser on the NRC blog says the technical sessions will include safety culture (SC) policies.  Let's look at the program agenda and see what's in store for SC.

There will be 36 technical sessions.  I reviewed all the titles and drilled down into sessions that might make some mention of SC, e.g.,  T4 - Construction Inspection Experience–The First Year and T7 - Human Impacts.  However, I could find no mention of SC in any of the currently available slide presentations.

That left the last technical session on the agenda: TH36 - The NRC’s Safety Culture Policy Statement–Domestic and International Initiatives.  Following is a summary of the available presentations for this session.

The introductory remarks summarize the development of the SC policy statement and its implementation.  There is no news here.

The SC common language presentation reviews the history of this initiative (which we have previously reviewed here and here).  The presentation has one quotable statement: “NRR will work to incorporate language into the ROP guidance documents and inspection procedures, as appropriate.”  Does that sound like back door regulation of SC to you?

A presentation on domestic and international cooperation reviews the relationship between NRC and INPO, NRC and IAEA, and others.  As an example of cooperation, the authors summarize the INPO SC survey data that were collected from operating plants and then analyzed by INPO (and later NRC) to show “statistically significant relationships between safety culture survey results and measures of plant performance.”  We commented on this work when it first appeared in 2010, congratulating INPO for making the effort and agreeing with some of the findings but finally concluding that the analysis was incomplete and potentially misleading.   

An industry presentation by Nuclear Fuel Services Inc. (NFS) describing their SC improvement program is worth a look.  It lists almost two dozen program components, none of which is a trivial undertaking, which suggest how much work is involved in changing an existing SC.  (I have no idea if NFS is actually pursuing the listed activities or how well they're doing.)

All in all, it's probably not worth traveling to Bethesda if you're seeking enlightenment about SC. 

The Safety Culture Common Language Path Forward (Update)

The intent of the NRC's Safety Culture Common Language Path Forward initiative is to describe safety culture (SC) attributes at a more detailed level than the NRC’s SC policy statement.  On January 29-30, 2013 the NRC held a public workshop to finalize the draft SC common language.*  The document they issued after the workshop** contains attribute definitions and examples of behavior and artifacts that support or embody each attribute.  This document will be used by the NRC to develop a NUREG containing the final common language.

Last March we posted on a draft produced by previous workshops, focusing on areas we consider critical for a strong SC: decision making, corrective action, management incentives and work backlogs.  In that post, our opinion was that decision making and corrective action were addressed in a satisfactory manner, the treatment of incentives was minimally acceptable and backlogs were all but ignored.

So, how does the “final” language treat the same subject areas?  Is it better than the draft comments we reviewed last March?  The arrows indicate whether the final version is better ↑, the same → or worse ↓.

Decision making – Good↑.  Decision making incorporates “. . . a consistent, systematic approach to make decisions” (p. 51) and a conservative bias, i.e., “. . . decision-making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop.” (p. 52)  In addition, communicating, explaining and justifying individual decisions is mentioned throughout the document. 

Goal conflict is addressed under leader behavior “. . . when resolving apparent conflicts between nuclear safety and production” (p. 12) and leaders “avoid unintended or conflicting messages that may be conveyed by operational decisions” (p. 37); work process “activities are coordinated to address conflicting or changing priorities.” (p. 23) 

Corrective action – Satisfactory→.  The section on problem identification and resolution (pp. 13-17) is suffused with desirable characteristics of corrective actions and the CAP.  A good CAP has a low threshold for identifying issues and problems are thoroughly evaluated.  Corrective actions are timely, effective and prevent recurrence of problems.  Periodic analysis of CAP and other data is used to identify any programmatic or common cause issues.

Management incentives – Unsatisfactory↓.  The section on incentives appears to focus on workers, not managers: “Leaders ensure incentives, sanctions, and rewards are aligned with nuclear safety policies and reinforce behaviors and outcomes which reflect safety as the overriding priority.” (p. 7)  This is even less complete than the single sentence that appeared in last year's draft: “Senior management incentive program [sic] reflect a bias toward long-term plant performance and safety.”*** The failure to mention the senior management incentive program is a serious shortcoming.

Backlogs – Minimally Acceptable↑.  Backlogs are specifically mentioned in maintenance and engineering (p. 24) and document changes (p. 25).  In addition, problem evaluation, corrective actions, CAP trending analyses, operating experience lessons and many administrative activities are supposed to be addressed in a “timely” manner.  I hope that implies that backlogs in these areas should not be too large.     

But attention to backlogs is still important.  Repeating what we said last year, “Excessive backlogs are demoralizing; they tell the workforce that accomplishing work to keep the plant, its procedures and its support processes in good repair or up-to-date is not important.  Every “problem plant” we worked on in the late 1990s had backlog issues.”

Conclusion

Overall, this latest document is an improvement over the March 2012 version but still short of what we'd like to see.


*  M.J. Keefe (NRC) to U.S. Shoop (NRC), “Summary of the January 29-30, Workshop to Develop Common Language for Safety Culture” (Feb. 7, 2013)  ADAMS ML13038A059.

**  Nuclear Safety Culture Common Language 4th Public Workshop January 29-31, 2013  ADAMS ML13031A343.

***  U.S. Shoop (NRC) to J. Giitter (NRC), “Safety Culture Common Language Path Forward” (Mar. 19, 2012) p. 12.  ADAMS ML12072A415.

NRC Non-Regulation of Safety Culture: Third Quarter Update

On March 17 we published a post on NRC safety culture (SC) related activities with individual licensees since the SC policy statement was issued in June, 2011.  On July 3, we published an update for second quarter 2012 activities.  This post highlights selected NRC actions during the third quarter, July through September 2012.

Our earlier posts mentioned Browns Ferry, Fort Calhoun and Palisades as plants where the NRC was undertaking significant SC-related activities.  It looks like none of those plants has resolved its SC issues and, at the current rate of progress, I’m sure we’ll be reporting on all of them for quite awhile.

Browns Ferry

As we reported earlier, this plant’s SC problems have existed for years.  On August 23, TVA management submitted its Integrated Improvement Plan Summary* to address NRC inspection findings that have landed the plant in column 4 (next to worst) of the NRC’s Action Matrix.  TVA’s analysis of its SC and operational performance problems included an independent SC assessment.  TVA’s overall analysis identified fifteen “fundamental problems” and two bonus issues; for SC improvement efforts, the problems and issues were organized into five focus areas: Accountability, Operational Decision Making (Risk Management), Equipment Reliability, Fire Risk Reduction and the Corrective Action Program (CAP).

The NRC published its mid-cycle review of Browns Ferry on September 4.  In the area of SC, the report noted the NRC had “requested that [the Substantive Cross-Cutting Issue in the CAP] be addressed during your third party safety culture assessment which will be reviewed as part of the Independent NRC Safety Culture Assessment per IP 95003. . . .”**

Fort Calhoun

SC must be addressed to the NRC’s satisfaction prior to plant restart.   The Omaha Public Power District (OPPD) published its Integrated Performance Improvement Plan on July 9.***  The plan includes an independent safety culture assessment to be performed by an organization “that is nationally recognized for successful performance of behavior-anchored nuclear safety culture assessments.” (p. 163)  Subsequent action items will focus on communicating SC principles, assessment results, SC improvement processes and SC information.

The NRC and OPPD met on September 11, 2012 to discuss NRC issues and oversight activities, and OPPD’s performance improvement plan, ongoing work and CAP updates.  OPPD reported that a third-party SC assessment had been completed and corrective actions were being implemented.****

Palisades

The NRC continues to express its concerns over Palisades’ SC.  The best example is NRC’s August 30 letter***** requesting a laundry list of information related to Palisades’ independent SC assessment and management's reaction to same, including corrective actions, interim actions in place or planned to mitigate the effects of the SC weaknesses, compliance issues with NRC regulatory requirements or commitments, and the assessment of the SC at Entergy’s corporate offices. (p. 5)

The NRC held a public meeting with Palisades on September 12, 2012 to discuss the plant’s safety culture.  Plant management’s slides are available in ADAMS (ML12255A042).  We won’t review them in detail here but management's Safety Culture Action Plan includes the usual initiatives for addressing identified SC issues (including communication, training, CAP improvement and backlog reduction) and a new buzz phrase, Wildly Important Goals.

Other Plants

NRC supplemental inspections can require licensees to assess “whether any safety culture component caused or significantly contributed to” some performance issue.#  NRC inspection reports note the extent and adequacy of the licensee’s assessment, often performed as part of a root cause analysis.  Plants that had such requirements laid on them or had SC contributions noted in inspection reports during the third quarter included Brunswick, Hope Creek, Limerick, Perry, Salem, Waterford and Wolf Creek.

One other specific SC action arose from the NRC’s alternative dispute resolution (ADR) process at Entergy’s James A. FitzPatrick plant.  As part of an NRC Confirmatory Order following ADR, Entergy was told to add a commitment to maintain the SC monitoring processes at Entergy’s nine commercial nuclear power plants.##

The Bottom Line

None of this is a surprise.  Even the new Chairman tells it like it is: “In the United States, we have . . . incorporated a safety culture assessment into our oversight program . . . . “###  What is not a surprise is that particular statement was not included in the NRC’s press release publicizing the Chairman’s comments.  Isn’t “assessment” part of “regulation”?

Given the attention we pay to the issue of regulating SC, one may infer that we object to it.  We don’t.  What we object to is the back-door approach currently being used and the NRC’s continued application of the Big Lie technique to claim that they aren’t regulating SC.


*  P.D. Swafford (TVA) to NRC, “Integrated Improvement Plan Summary” (Aug. 23, 2012)  ADAMS ML12240A106.  TVA has referred to this plan in various presentations at NRC public and Commission meetings.

**  V.M. McCree (NRC) to J.W. Shea (TVA), “Mid Cycle Assessment Letter for Browns Ferry Nuclear Plant Units 1, 2, and 3” (Sept. 4, 2012)  ADAMS ML12248A296.

***  D.J. Bannister (OPPD) to NRC, “Fort Calhoun Station Integrated Performance Improvement Plan Rev. 3” (July 9, 2012)  ADAMS ML12192A204.

**** NRC, “09/11/2012 Meeting Summary of with Omaha Public Power District” (Sept. 25, 2012)  ADAMS ML12269A224.

*****  J.B. Giessner (NRC) to A. Vitale (Entergy), “Palisades Nuclear Plant – Notification of NRC Supplemental Inspection . . . and Request for Information” (Aug. 30, 2012)  ADAMS ML12243A409.

#  The scope of NRC Inspection Procedure 95001 includes “Review licensee’s evaluation of root and contributing causes. . . ,” which may include SC; IP 95002’s scope includes “Determine if safety culture components caused or significantly contributed to risk significant performance issues” and IP 95003’s scope includes “Evaluate the licensee’s third-party safety culture assessment and conduct a graded assessment of the licensee’s safety culture based on evaluation results.”  See IMC 2515 App B, "Supplemental Inspection Program" (Aug. 18, 2011)  ADAMS ML111870266.

##  M. Gray (NRC) to M.J. Colomb (Entergy), “James A. FitzPatrick Nuclear Power Plant - NRC Integrated Inspection Report 05000333/2012003” (Aug. 7, 2012)  ADAMS ML12220A278.

###  A.M. Macfarlane, “Assessing Progress in Worldwide Nuclear Safety,” remarks to International Nuclear Safety Group Forum, IAEA, Vienna, Austria (Sept. 17, 2012), p. 3 ADAMS ML12261A373; NRC Press Release No. 12-102, “NRC Chairman Says Safety Culture Critical to Improving Safety; Notes Fukushima Progress in United States” (Sept. 17, 2012) ADAMS ML12261A391.

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.

The Safety Culture Common Language Path Forward—and the Broken Window at the Nuclear Power Plant

The NRC has an initiative, the Safety Culture Common Language Path Forward, to describe safety culture (SC) elements at a more detailed level than the NRC’s SC policy statement.  There was a workshop for agency and industry representatives, and a conference call was scheduled for today to discuss next steps.  The draft “elements” from the workshop are a mélange of polished bureaucratese, company policy proclamations and management homilies.*

I was curious to see how they treated the areas I have been harping on as critical for effective SC: decision making, corrective action, management incentives and work backlogs.  Following is my very subjective rating of how well the draft elements cover the key subject areas.

Decision making – Mostly Satisfactory.  “The licensee makes safety-significant or risk-significant decisions using a systematic process.” (Shoop, p. 18)   We agree; in fact, we think ALL significant decisions should be made using a systematic process.  Why “systematic”?  To evidence transparency and robustness, i.e., to maximize the odds that a different decision-maker, if faced with a similar situation, will reach the same or similar answer.  However, one important type of decision, the resolution of goal conflict needs improvement.  Goal conflict appears focused on personal or professional disagreements; the big picture potential conflict of safety vs production, cost or schedule gets slight mention.

Corrective action – Satisfactory.  There are a lot of words about corrective action and the CAP and they cover the important points.  A minor gripe is the term “safety” may be overused when referring to identifying, evaluating or correcting problems.  A couple of possible unintended consequences of such overuse are to create the impression that (1) only safety-related problems need such thorough treatment or (2) anything someone wants done needs some relation, no matter how tenuous, to safety.

Management incentives – Minimally acceptable.  “Senior management incentive program [sic] reflect a bias toward long-term plant performance and safety.” (Shoop, p. 12)  One could say more about this topic (and we have, including here and here) but the statement gets over the bar. 

Backlogs – Unsatisfactory.  The single mention of backlogs is “Maintaining long term plant safety by . . . ensuring maintenance and engineering backlogs which are low enough [to] support safety” (Shoop, p. 32) and even that was the tail end of a list of contributing factors to plant safety.  Backlogs are much more important than that.  Excessive backlogs are demoralizing; they tell the workforce that accomplishing work to keep the plant, its procedures and its support processes in good repair or up-to-date is not important.  Every “problem plant” we worked on in the late 1990s had backlog issues.  This is where the title reference to the broken window comes in. 

“. . . if a window in a building is broken and is left unrepaired, all the rest of the windows will soon be broken. . . . one unrepaired broken window is a signal that no one cares, and so breaking more windows costs nothing.”**

Excessive backlogs are a broken window. 


*  NRC memo from U.S. Shoop to J. Giitter, “Safety Culture Common Language Path Forward” (Mar. 19, 2012) ADAMS ML12072A415.

**  J.Q. Wilson and G.L. Kelling, “Broken Windows: The police and neighborhood safety,” The Atlantic Monthly (Mar. 1982).

The NRC Does Not Regulate Safety Culture, Right?

Last March, the NRC approved its safety culture policy statement.*  At the time, a majority of commissioners issued supplemental comments expressing their concern that the policy statement could be used as a back door to regulation.  The policy was issued in June, 2011.  Enough time has lapsed to ask: What, if anything has happened, i.e., how is the NRC treating safety culture as it exercises its authority to regulate licensees?

We examined selected NRC documents for some plants where safety culture has been raised as a possible issue and see a few themes emerging.  One is the requirement to examine the causes of specific incidents to ascertain if safety culture was a contributing factor.  It appears some (perhaps most or all) special inspection notices to licensees include some language about "an assessment of whether any safety culture component caused or significantly contributed to these findings."  

The obvious push is to get the licensee to do the work and explicitly address safety culture in their mea culpa to the agency.  Then the agency can say, for example, that "The inspection team confirmed that the licensee established appropriate corrective actions to address safety culture."**  A variant on this theme is now occurring at Browns Ferry, where the “NRC is reviewing results from safety culture surveys performed by the plant in 2011.”*** 

The NRC is also showing the stick, at least at one plant.  At Fort Calhoun, the marching orders are: “Assess the licensee’s third party evaluation of their safety culture. . . . If necessary, perform an independent assessment of the licensee’s safety culture using the guidance contained in Inspection Procedure 95003."****  I think that means: If you can't/won't/don't perform an adequate safety culture evaluation, then we will.  To back up this threat, it appears the NRC is developing procedures and materials for qualifying its inspectors to evaluate safety culture.

The Alternative Dispute Resolution (ADR) process is another way to get safety culture addressed.  For example, Entergy got in 10 CFR 50.7 (employee protection) trouble for lowering a River Bend employee’s rating in part because of questions he raised.  One of Entergy's commitments following ADR was to perform a site-wide safety culture survey.  It probably didn’t help that, in a separate incident, River Bend operators were found accessing the internet when they were supposed to be watching the control board.  Entergy also has to look at safety culture at FitzPatrick and Palisades because of incidents at those locations.***** 

What does the recent experience imply?

The NRC’s current perspective on safety culture is summed up in an NRC project manager’s post in an internet Nuclear Safety Culture forum: “You seem to [sic] hung up on how NRC is going to enforce safety culture.  We aren't.  Safety culture isn't required. It won't be the basis for denying a license application.  It won't be the basis for citing a violation during an inspection.  However, if an incident investigation identifies safety culture as one of the root causes, we will require corrective action to address it.”  (Note this is NOT an official agency statement.)

However, our Bob Cudlin made a more expansive prediction in his January 19, 2011 post: “. . . it appears that the NRC will “expect” licensees to meet the intent and the particulars of its policy statement.  It seems safe to assume the NRC staff will apply the policy in its assessments of licensee performance. . . . The greatest difficulty is to square the rhetoric of NRC Commissioners and staff regarding the absolute importance of safety culture to safety, the “nothing else matters” perspective, with the inherently limited and non-binding nature of a policy statement.”

While the record to date may support the NRC PM’s view, I think Bob’s observations are also part of the mix.  It’s pretty clear the NRC is turning the screw on licensee safety culture effectiveness, even if it’s not officially “regulating” safety culture.


*  NRC Commission Voting Record, SECY-11-005, “Proposed Final Safety Culture Policy Statement” (March 7, 2011).  I could not locate this document in ADAMS.

**  IR 05000482-11-006, 02/07-03/31/2011, Wolf Creek Generating Station - NRC Inspection Procedure 95002 Supplemental Inspection Report and Assessment Followup Letter (May 20, 2011) ADAMS ML111400351. 

***  Public Meeting Summary for Browns Ferry Nuclear Plant, Docket No. 50-259 (Feb. 26, 2012) ADAMS ML12037A092.

****  Fort Calhoun Station Manual Chapter 0350 Oversight Panel Charter (Jan. 12, 2012) ADAMS ML120120661.

*****  EN-11-026, Confirmatory Order, Entergy Operations Inc.  (Aug. 19, 2011)  ADAMS ML11227A133; NRC Press Release-I-12-002: “NRC Confirms Actions to be Taken at FitzPatrick Nuclear Plant to Address Violations Involving Radiation Protection Program” (Jan. 26, 2012) ADAMS ML120270073; NRC Press Release-III-12-003: “NRC Issues Confirmatory Orders to Palisades Plant Owner Entergy and Plant Operator” (Jan. 26, 2012) ADAMS ML120270071.

Regulatory Assessment of Safety Culture—Not Made in U.S.A.

Last February, the International Atomic Energy (IAEA) hosted a four-day meeting of regulators and licensees on safety culture.*  “The general objective of the meeting [was] to establish a common opinion on how regulatory oversight of safety culture can be developed to foster safety culture.”  In fewer words, how can the regulator oversee and assess safety culture?

While no groundbreaking new methods for evaluating a nuclear organization’s safety culture were presented, the mere fact there is a perception that oversight methods need to be developed is encouraging.  In addition, outside the U.S., it appears more likely that regulators are expected to engage in safety culture oversight if not formal regulation.

Representatives from several countries made presentations.  The NRC presentation discussed the then-current status of the effort that led to the NRC safety culture policy statement announced in June.  The presentations covering Belgium, Bulgaria, Indonesia, Romania, Switzerland and Ukraine described different efforts to include safety culture assessment into licensee evaluations.

Perhaps the most interesting material was a report on an attendee survey** administered at the start of the meeting.  The survey covered “national regulatory approaches used in the oversight of safety culture.” (p.3) 18 member states completed the survey.  Following are a few key findings:

The states were split about 50-50 between having and not having regulatory requirements related to safety culture. (p. 7)  The IAEA is encouraging regulators to get more involved in evaluating safety culture and some countries are responding to that push.

To minimize subjectivity in safety culture oversight, regulators try to use oversight practices that are transparent,  understandable, objective, predictable, and both risk-informed and performance-based. (p. 13)  This is not news but it is a good thing; it means regulators are trying to use the same standards for evaluating safety culture as they use for other licensee activities.

Licensee decision-making processes are assessed using observations of work groups, probabilistic risk analysis, and during the technical inspection. (p. 15)  This seems incomplete or even weak to us.  In-depth analysis of critical decisions is necessary to reveal the underlying assumptions (the hidden, true culture) that shape decision-making.

Challenges include the difficulty in giving an appropriate priority to safety in certain real-time decision making situations and the work pressure in achieving production targets/ keeping to the schedule of outages. (p. 16)  We have been pounding the drum about goal conflict for a long time and this survey finding simply confirms that the issue still exists.

Bottom Line

The meeting was generally consistent with our views.  Regulators and licensees need to focus on cultural artifacts, especially decisions and decision making, in the short run while trying to influence the underlying assumptions in the long run to reduce or eliminate the potential for unexpected negative outcomes.

*  IAEA Technical Meeting on Safety Culture Oversight and Assessment, Vienna, Feb. 15-18, 2011.

**  A. Kerhoas, "Synthesis of Questionnaire Survey."

“what people do, not why they do it…”

Our perseverance through over three hours of the web video of the Commission meeting on the proposed safety culture policy statement was finally rewarded in the very last minute of discussion.  Commissioner Apostolakis reiterated some of his concerns with the direction of the policy statement, observing that the NRC is a performance-based agency and:

“...we really care about what people do and maybe not why they do it….”

Commissioner Apostolakis was amplifying his discomfort with the inclusion of values along with behaviors in the policy as values are inherently fuzzy, not measurable, and may or may not be a prerequisite to the right behaviors.  Perhaps most of all, he believed omitting the reference to core values would not detract from the definition of safety culture. 

Earlier in the meeting Commissioner Apostolakis had tried to draw out the staff on whether the definition of safety culture needed values in addition to behaviors [at time 2:34:58], and would it be a fatal flaw to omit “core values”.  The staff response was illuminating.  The justification offered for retaining values was “stakeholder consensus”, and extensive outreach efforts that supported inclusion.  (But why was it so important to stakeholders?)  The staff went on to clarify: “culture does not lend itself to be inspectable”, but “having values with behaviors is what culture is all about”.   Frankly we’re not sure what that means, but we do know that safety culture behaviors are inspectable because they are observable and measurable.

That much of the staff’s justification for including values in the policy statement seemed to reside in the fact that all the stakeholders had agreed received positive endorsement by Chairman Jaczko when he observed:  “...Commissioner Magwood I think made a profound point that there was value in this process here that may be tremendously more important than the actual policy statement was the fact that people got together and started talking about this and realized that across this wide variety of stakeholders, there was pretty good agreement about the kinds of things that we were talking about.”

Chairman Jaczko also weighed in on the values-behaviors contrast, coming down firmly on the inclusion of values and offering the following justification:

“...not all entities with a good safety culture will have necessarily the right values…”

Respectfully, we believe at a minimum this will further confuse the NRC’s policy on safety culture, and in all likelihood places emphasis in exactly the wrong place.  Is the Chairman agreeing all that matters is what people do?  Or is he suggesting that the NRC would find fault with a licensee that was acting consistent with safety but did not manifest the “right” values.  And how would the NRC reach such a finding?  More fundamentally, isn’t Commissioner Apostolakis correct in his blunt statement - that we [NRC] don’t care why they [licensees] do it?

NRC Policy Statements

For some time we have been thinking about one of the underlying aspects of the NRC’s current safety culture initiative which is to establish a “policy statement” for nuclear safety culture.  As we know the use of a policy statement in this area dates back to 1989.  A subtext to this approach is whether the NRC should “regulate” nuclear safety culture, presumably through the issuance of regulatory rules and requirements.  We recognize that the “regulate” issue is very much a hot button and we are not addressing it at this time.  Instead we thought it might be worthwhile to consider in some detail just what is a Commission policy statement and what it might or might not accomplish.

On the NRC website we looked at what was available regarding policy statements.  There is a Commission Policy Statements page with a listing of the current set of policy statements, organized by topic.  However, most policy statements relate to the conduct of business by the NRC itself with fewer statements addressing substantive regulatory and safety criteria.  We could not locate on the website information regarding how policy statements are intended to be used in the regulatory process.  For that we turned to recent NRC Issuances,* which are adjudicatory decisions by Atomic Safety and Licensing Boards and the Commission itself, to obtain guidance on the applicability and weight accorded NRC Policy Statements. 

“Policy Statements are neither rules nor orders, and therefore do not establish requirements that bind either the agency or the public.”**

This comes from a Commission decision for a case involving the scope of environmental review for an early site permit.  The Commission references a D.C. Circuit Court case that found:

“A general statement of policy . . . does not establish a ‘‘binding norm.’’ It is not finally determinative of the issues or rights to which it is addressed. The agency cannot apply or rely upon a general statement of policy as law because a general statement of policy only announces what the agency seeks to establish as policy.” (p. 240)

In its decision, the Commission goes on to state:

“For the [Atomic Safety and Licensing] Board to suggest that the strictures of the Policy Statement may be enforced as law, or that it in some way creates a substantive mandate, accords too much weight to the Policy Statement.” (p. 240) 

So far so good.  But after finding that the staff’s review satisfied applicable statutory and regulatory requirements (but did not comport with the letter of the policy statement), the Commission ends its decision on a more confusing note.

“We expect conformance with the Policy Statement, and relevant associated guidance, in future licensing actions of this magnitude.” (p. 248)

In another matter involving a policy statement governing the admissibility of contentions in license renewal proceedings, Commissioners Merrifield and McGaffigan joined in a concurring opinion to observe:

“If we are not willing to enforce our policy statements, the statements become meaningless.”***

Finally, an earlier ASLB decision seems to address policy statements on a practical level, where the Board feels “compelled” by Commission policy: 

Notwithstanding these clear inconsistencies, we find ourselves compelled by Commission rulings and policy statements to accept this approach by the Staff because the Commission has advised that their ‘‘longstanding practice . . . grounded in sound policy’’ is to ‘‘leave [ ] to the expert NRC technical staff prime responsibility for technical fact-finding on uncontested matters.’’****

Based on all of this what is the likely impact of the safety culture policy statement on NRC license holders?  On the one hand it appears that the NRC will “expect” licensees to meet the intent and the particulars of its policy statement.  It seems safe to assume the NRC staff will apply the policy in its assessments of licensee performance.  On the other hand, if a licensee does not meet some aspect of the policy it could find solid footing in a challenge to the enforceability of the policy statement.  The greatest difficulty is to square the rhetoric of NRC Commissioners and staff regarding the absolute importance of safety culture to safety, the “nothing else matters” perspective, with the inherently limited and non-binding nature of a policy statement.


*  NRC Issuances are published as NUREG-0750.  Individual volumes are available here. 

**  66 NRC 215 (2007) at 217, In the Matter of: DOMINION NUCLEAR NORTH ANNA, LLC (Early Site Permit for North Anna ESP Site) CLI-07-27 Nov 20, 2007.

***  65 NRC 1 (2007) at 8, In the Matter of: ENTERGY NUCLEAR VERMONT YANKEE, LLC, and ENTERGY NUCLEAR OPERATIONS, INC. (Vermont Yankee Nuclear Power Station) CLI-07-1 Commissioner Jeffrey S. Merrifield, with Whom Commissioner Edward McGaffigan, Jr. Joins, Concurring Jan 11, 2007.

****  64 NRC 460 (2006) at 492, ATOMIC SAFETY AND LICENSING BOARD In the Matter of EXELON GENERATION COMPANY, LLC (Early Site Permit for Clinton ESP Site) Dec 28, 2006.

ACRS and Safety Culture Policy (cont.)

Our previous post reported on the ACRS letter to the NRC endorsing the agency’s approach to developing a safety culture policy.*  We noted the concern of some ACRS members that the policy might be a back door method to impose regulatory requirements while avoiding the requirements of the regulatory process.

The dissenting ACRS members also raised some other interesting issues about the proposed policy.

First, they questioned whether the proposed traits were the most important ones in terms of their contribution to safety.  Why weren’t organizational and individual integrity, and technical competence included?  Good question.  After all, wasn’t an integrity shortfall at the heart of the misleading of the Vermont senate and the willful violations at San Onofre?

Second, they commented “[T]here is faint evidence that the listed traits (individually or collectively) are assured to produce measureable improvements in safety.” (p. 4)  We raised the same issue in our October 22, 2010 post on the NRC safety culture workshop.  What are the linkages, if any, between the traits and measurable or observable safety-related performance?

Our concern about the lack of demonstrated linkages leads to what may be a bedrock question underlying all of the safety culture policy discussion: If the ROP isn’t providing sufficient information to support the NRC’s confidence in a licensee’s safety culture, then how can the agency develop that information in a defined, disciplined and vetted manner?  Is a safety culture policy going to provide that assurance?


*  Letter dated Dec 15, 2010 from S. Abdel-Khalik (ACRS) to G. Jaczko (NRC), subject "Safety Culture Policy Statement," ADAMS Accession Number ML103410358.

ACRS Weighs In on Safety Culture Policy

In mid-December the Advisory Committee on Reactor Safeguards (ACRS) provided the results of its review of the NRC’s proposed nuclear safety culture policy in a letter to NRC Chairman Jaczko.*  The letter reiterated the approach and general structure of the proposed policy and reached a favorable conclusion.  Perhaps the most interesting comment in the main body of the letter is the following:

“Well-intentioned attempts at improving safety and effectiveness have faltered through efforts to overly prescribe correct behavior and to apply rigid scoring systems. We urge that the staff encourage approaches that emphasize thinking and safety awareness over scorecards of metrics that can induce complacency and rote compliance. Issuance of a policy statement, rather than a regulation, is likely to be a more effective way to appropriately engage all the stakeholders.” (p. 4)

The statement is a bit cryptic and we can only guess what the ACRS has in mind when it refers to “scorecards of metrics” or “overly prescribing behavior”.  Are they referring to the ROP?  Is the ACRS concerned that reliance on the ROP metrics (and their almost uniformly green status) may be lulling the industry and the NRC into complacency?  Equally uncertain is why the ACRS believes that a policy statement will lead to more effective results. 

Apparently we are not the only ones to suffer uncertainty.  The ACRS letter includes “Additional Comments” (read: dissenting comments) by three members** who state:

“It is not entirely clear to us what is meant by implementing a policy statement that lacks the authority of regulation. It appears that implementation of the safety culture policy statement may be an indirect method of imposing requirements on licensees without the discipline of the regulatory process. This, of course, is not acceptable.” (p. 4)

Part of the confusion may lie in the intent and authority associated with NRC policy statements.  It appears that the dissenting members feel that a policy statement would be a back door method to impose “requirements”.  Is that true?  We will follow with a detailed look at policy statements and their effect.


*  Letter dated Dec 15, 2010 from S. Abdel-Khalik (ACRS) to G. Jaczko (NRC), subject "Safety Culture Policy Statement," ADAMS Accession Number ML103410358.

** D.A. Powers, J.S. Armijo and J.L. Rempe.

Nothing Else Matters

In early December NRC Commissioner Ostendorff provided the keynote speech at Nuclear Energy Asia.*  A significant portion of his remarks addressed the importance of safety culture to nuclear safety.  In terms of safety culture insight I think it is fair to say there wasn’t much new here.  However the continued emphasis by the NRC at the Commissioner level may be signaling how they may choose to proceed with regulation of nuclear safety culture.

“Decades of experience in the nuclear field have shown that regulators have to do more than simply establish standards. Rather, I believe it to be more appropriate for a regulator to establish a high-level expectation or policy to help foster the development and maintenance of a strong safety culture.” (p. 2)

This sounds consistent with the current safety culture policy track being followed by the NRC staff.  But just preceding this comment, Ostendorff said: 

“Within the national nuclear safety infrastructure, I believe that a strong safety culture is the key foundation. Without this one essential cornerstone – a strong safety culture – nothing else matters.” (p. 2)

This echoes statements by other Commissioners, and in regulatory actions for specific licensees, that safety culture is essential to nuclear safety.  If that is the case, doesn’t it set the bar very high in terms of regulatory responsibility for ensuring adequate safety culture?   And with the bar set so high, is it sufficient for the NRC to just establish a policy or “expectations” for safety culture, but not rules or regulatory requirements?  We will present a much more detailed look at NRC policy making in an upcoming post.


*  W.C. Ostendorff, "Regulatory Perspectives on Nuclear Safety," International Keynote Address, Nuclear Energy Asia 2010, Hong Kong, China (Dec 7, 2010) ADAMS Accession Number ML103420523.

NRC Safety Culture Workshop

The information from the Sept 28, 2010 NRC safety culture meeting is available on the NRC website.  This was a meeting to review the draft safety culture policy statement, definition and traits.

As you probably know, the NRC definition now focuses on organizational “traits.”   According to the NRC, “A trait . . . is a pattern of thinking, feeling, and behaving that emphasizes safety, particularly in goal conflict situations, e.g., production vs. safety, schedule vs. safety, and cost of the effort vs. safety.”*  We applaud this recognition of goal conflicts as potential threats to effective safety management and a strong safety culture.

Several stakeholders made presentations at the meeting but the most interesting one was by INPO’s Dr. Ken Koves.**  He reported on a study that addressed two questions:

• “How well do the factors from a safety culture survey align with the safety culture traits that were identified during the Feb 2010 workshop?
• Do the factors relate to other measures of safety performance?” (p. 4)

The rest of this post summarizes and critiques the INPO study.

Methodology

For starters, INPO constructed and administered a safety culture survey.  The survey itself is interesting because it covered 63 sites and had 2876 respondents, not just a single facility or company.  They then performed a principal component analysis to reduce the survey data to nine factors.  Next, they mapped the nine survey factors against the safety culture traits from the NRC's Feb 2010 workshop, INPO principles, and Reactor Oversight Program components and found them generally consistent.  We have no issue with that conclusion. 

Finally, they ran correlations between the nine survey factors and INPO/NRC safety-related performance measures.  I assume the correlations included in his presentation are statistically significant.  Dr. Koves concludes that “Survey factors are related to other measures of organizational effectiveness and equipment performance . . . .” (p. 19)

The NRC reviewed the INPO study and found the “methods, data analyses and interpretations [were] appropriate.” ***

The Good News

Kudos to INPO for performing this study.  This analysis is the first (only?) large-scale attempt of which I am aware to relate safety culture survey data to anything else.  While we want to avoid over-inferring from the analysis, primarily because we have neither the raw data nor the complete analysis, we can find support in the correlation tables for things we’ve been saying for the last year on this blog.

For example, the factor with the highest average correlation to the performance measures is Management Decision Making, i.e., what management actually does in terms of allocating resources, setting priorities and walking the talk.  Prioritizing Safety, i.e., telling everyone how important it is and promulgating safety policies, is 7th (out of 9) on the list.  This reinforces what we have been saying all along: Management actions speak louder than words.

Second, the performance measures with the highest average correlation to the safety culture survey factors are the Human Error Rate and Unplanned Auto Scrams.  I take this to indicate that surveys at plants with obvious performance problems are more likely to recognize those problems.  We have been saying the value of safety culture surveys is limited, but can be more useful when perception (survey responses) agrees with reality (actual conditions).  Highly visible problems may drive perception and reality toward congruence.  For more information on perception vs. reality, see Bob Cudlin’s recent posts here and here.

Notwithstanding the foregoing, our concerns with this study far outweigh our comfort at seeing some putative findings that support our theses.

Issues and Questions

The industry has invested a lot in safety culture surveys and they, NRC and INPO have a definite interest (for different reasons) in promoting the validity and usefulness of safety culture survey data.  However, the published correlations are moderate, at best.  Should the public feel more secure over a positive safety culture survey because there's a "significant" correlation between survey results and some performance measures, some of which are judgment calls themselves?  Is this an effort to create a perception of management, measurement and control in a situation where the public has few other avenues for obtaining information about how well these organizations are actually protecting the public?

More important, what are the linkages (causal, logical or other) between safety culture survey results and safety-related performance data (evaluations and objective performance metrics) such as those listed in the INPO presentation?  Most folks know that correlation is not causation, i.e., just because two variables move together with some consistency doesn’t mean that one causes the other but what evidence exists that there is any relationship between the survey factors and the metrics?  Our skepticism might be assuaged if the analysts took some of the correlations, say, decision making and unplanned reactor scrams, and drilled into the scrams data for at least anecdotal evidence of how non-conservative decision making contributed to x number of scrams. We would be surprised to learn that anyone has followed the string on any scram events all the way back to safety culture.

Wrapping Up

The INPO analysis is a worthy first effort to tie safety culture survey results to other measures of safety-related performance but the analysis is far too incomplete to earn our endorsement.  We look forward to seeing any follow-on research that addresses our concerns.


*  “Presentation for Safety Club Public Meeting - Traits Comparison Charts,” NRC Public Meeting, Las Vegas, NV (Sept 28, 2010) ADAMS Accession Number ML102670381, p. 4.

**  G.K. Koves, “Safety Culture Traits Validation in Power Reactors,” NRC Public Meeting, Las Vegas, NV (Sept 28, 2010).

***  V. Barnes, “NRC Independent Evaluation of INPO’s Safety Culture Traits Validation Study,” NRC Public Meeting, Las Vegas, NV (Sept 28, 2010) ADAMS Accession Number ML102660125, p. 8.

Testing Positive - the NRC on Safety Culture

We have been spending some time with the NRC’s draft statement of policy on safety culture published in the Federal Register on November 6, 2009.*

The initial Commission policy statement on safety culture in 1989 simply referred to “safety culture”. The current statement initially refers to the need for a “strong” safety culture (“It is the Commission’s policy that a strong safety culture is an essential element for individuals . . . .”) but then settles on “positive” safety culture as the fundamental expectation of the policy (“licensees . . . should foster a positive safety culture in their organizations and among individuals . . . .”) (p. 57526) The NRC provides its definition of “safety culture” in the draft policy but does not specifically define “strong” or “positive” safety culture. The NRC states that “certain organizational characteristics and personnel attitudes and behaviors are present in a positive safety culture.” (p. 57528) It also notes that “The INSAG definition emphasizes that in a positive safety culture, the goal of maintaining nuclear safety receives the highest priority in the organization’s and individuals’ decision-making and actions when faced with a conflict with other organizational or individual goals.” (p. 57527)

We found the use of the term “positive” potentially ambiguous and decided to explore its possible meaning(s) as applicable to safety culture and what might be the NRC’s intent in using it to describe safety culture.

First of all we note the use of “positive” in this context is as an adjective. Complicating matters a bit from the start is that there are eight definitions of the adjective, positive. A few are readily dismissed such as where positive refers to the charge of electricity associated with a proton or having higher electric potential. But many remain. The definitions of positive that could be applicable to nuclear safety culture include:

• prescribed, or formally laid down and imposed;
• unconditioned or independent of changing circumstances;
• real, not fictitious and being effective in a social circumstance;
• contributing toward or characterized by increase or progression;
• favorable, having a good effect.

Consulting with Black’s Law Dictionary, the term positive is defined as:

“Laid down, enacted, or prescribed. Direct, absolute, explicit.” Sounds close to the first definition above.So what did the NRC intend by the usage of positive to modify “safety culture”? The short answer is we don’t know. The various definitions imply several possible interpretations. Perhaps the more straightforward is the “prescribed” definition. It would require licensees have an explicit and prescribed policy for safety culture at its facilities, and the policy would need to address elements of safety culture as laid out in the policy statement. This interpretation might also imply that the safety culture is unconditioned and independent of changing circumstances; i.e., enduring. The other possibility is that the NRC intends the “favorable” and “increasing and progressing” safety culture. This meaning has more of a dynamic implication and is similar to continuous improvement. The NRC’s alternate use of the term “strong” in the introduction to the policy doesn’t help much either. Strong can mean the “power to resist or endure” so it could be consistent with the first definition that safety culture should be enduring. But it also implies “resistant to change” which could be good or bad, depending on the current state of safety culture and any need to change (improve) it.

Where does this leave us? As a minimum it would appear necessary that the NRC amplify its use of these modifiers of safety culture and the specific meanings that are intended. Better yet, the NRC could not use these terms and simply rely on an old regulatory standby such as “adequate” safety culture.

* Draft Safety Culture Policy Statement: Request for Public Comments NRC-2009-0485-0001

Well Done by NRC Staffer

To support the discussion items on this blog we spend time ferreting out interesting pieces of information that bear on the issue of nuclear safety culture and promote further thought within the nuclear community. This week brought us to the NRC website and its Key Topics area.

As probably most of you are aware, the NRC hosted a workshop in February of this year for further discussions of safety culture definitions. In general we believe that the amount of time and attention being given to definitional issues currently seems to be at the point of diminishing returns. When we examine safety culture performance issues that arise around the industry, it is not apparent that confusion over the definition of safety culture is a serious causal issue, i.e., that someone was thinking of the INPO definition of safety culture instead of the INSAG one or the Schein perspective. Perhaps it must be a step in the process but to us what is interesting, and of paramount importance, is what causes disconnects between safety beliefs and actions taken and what can be done about them?

Thus, it was heartening and refreshing to see a presentation that addressed the key issue of culture and actions head-on. Most definitions of safety culture are heavy on descriptions of commitment, values, beliefs and attributes and light on the actual behaviors and decisions people make everyday. However, the definition that caught our attention was:

“The values, attitudes, motivations and knowledge that affect the extent to which safety is emphasized over competing goals in decisions and behavior.”

(Dr. Valerie Barnes, USNRC, “What is Safety Culture”, Powerpoint presentation, NRC workshop on safety culture, February 2010, p. 13)

This definition acknowledges the existence of competing goals and the need to address the bottom line manifestation of culture: decisions and actual behavior. We would prefer “actions” to “behavior” as it appears that behavior is often used or meant in the context of process or state of mind. Actions, as with decisions, signify to us the conscious and intentional acts of individuals. The definition also focuses on result in another way - “the extent to which safety is emphasized . . . in decisions. . . .” [emphasis added] What counts is not just the act of emphasizing, i.e. stressing or highlighting, safety but the extent to which safety impacts decisions made, or actions taken.

For similar reasons we think Dr. Barnes' definition is superior to the definition that was the outcome of the workshop:

“Nuclear safety culture is the core values and behaviors resulting from a collective commitment by leaders and individuals to emphasize safety over competing goals to ensure protection of people and the environment.”

(Workshop Summary, March 12, 2010, ADAMS ACCESSION NUMBER ML100700065, p.2)

As we previously argued in a 2008 white paper:

“. . . it is hard to avoid the trap that beliefs may be definitive but decisions and actions often are much more nuanced. . . .

"First, safety management requires balancing safety and other legitimate business goals, in an environment where there are few bright lines defining what is adequately safe, and where there are significant incentives and penalties associated with both types of goals. As a practical matter, ‘Safety culture is fragile.....a balance of people, problems and pressures.’

"Second, safety culture in practice is “situational”, and is continually being re-interpreted based on people’s actual behaviors and decisions in the safety management process. Safety culture beliefs can be reinforced or challenged through the perception of each action (or inaction), yielding an impact on culture that can be immediate or incubate gradually over time.”

(Robert Cudlin, "Practicing Nuclear Safety Management," March 2008, p. 3)

We hope the Barnes definition gets further attention and helps inform this aspect of safety culture policy.