NRC Regulation of Safety Culture: How They Do It

We have griped many times about how the NRC does, in fact, regulate (i.e., control or direct) licensee safety culture (SC) even though the agency claims it doesn’t because there is no applicable regulation.

A complete description of the agency’s approach was provided in 2010 NRC staff testimony* before the Atomic Safety and Licensing Board.  Note this testimony was given before the Safety Culture Policy Statement was issued but we believe it depicts current practices.  The key point is that “Oversight of an operating reactor licensee’s safety culture is implemented by the ROP [Reactor Oversight Process].” (p. 17)  Following are some lengthy quotes from the testimony and you can decide whether or not they add up to “regulation.”

“The ROP provides for the oversight of a licensee’s safety culture in four ways.  First, the ROP provides for the review of a licensee’s safety culture in a graded manner when that licensee has significant performance issues.  The level of the staff’s oversight is determined by the safety significance of the performance issues.  This review and evaluation is described in the ROP’s supplemental inspection program . . . An IP 95002 inspection is usually performed when a licensee enters [column 3] . . . of the ROP Action Matrix. . . [In certain circumstances] the NRC will request the licensee to perform an independent safety culture assessment.  An IP 95003 inspection is performed when a licensee enters [column 4] . . . of the ROP Action Matrix.  When this occurs, the NRC expects [emphasis added] the licensees to perform a third-party safety culture assessment.  The staff will review the results of the assessment and perform sample evaluations to verify the results.

“Second, the ROP’s reactive inspection program evaluates a licensee’s response to an event, including consideration of contributing causes related to the safety culture components, to fully understand the circumstances surrounding an event and its probable causes.

“Third, the ROP provides continuous oversight of licensee performance as inspectors evaluate inspection findings for cross-cutting aspects.  Cross-cutting aspects are aspects of licensee performance that can potentially affect multiple facets of plant operations and usually manifest themselves as the root causes of performance problems. . . .**

“Fourth, the ROP provides for the review of a licensee’s safety culture if that licensee has difficulty correcting long-standing substantive cross-cutting issues.  In these cases, the NRC will request the licensee to perform a safety culture assessment, and the NRC Staff will evaluate the results and the licensee’s response to the results.” (pp. 18-19)  In addition, “The ROP assessment process looks at long-standing substantive cross-cutting issues to determine if safety culture assessments need to be performed and reviewed.” (p. 24)  Significantly, “Safety culture is addressed through the use of cross-cutting issues which do not relate to the Action Matrix column that a plant may be placed in.” (p. 32)

Our Perspective

In our opinion, SC is regulated via a linkage to ongoing NRC activities.  Outputs from NRC inspection activities performed under the aegis of regulation (i.e., law) are used to assess licensee SC and force licensees to perform activities, e.g., SC assessments or corrective actions***, that the licensees might not choose to perform of their own free will.

The reality is NRC “requests” or “expectations” are like a commanding officer’s “wishes”; the intelligent subordinate understands they have the force of orders.  Here’s how the agency describes the fist inside the glove: “If the NRC requests a licensee to take an action, and the licensee refuses, the Agency can perform that action (i.e., the safety culture assessment) for them.” (p. 29)  We assume the NRC would invoke its regulatory authority to justify such an assessment.  But what licensee would want an under-experienced posse of federal inspectors, who expect to find problems because why else would they be assigned to the task, running through their organization?

Occasionally, the NRC drops the veil long enough to reveal the truth.  An NRC staffer (one of the witnesses who sponsored the ASLB testimony described above) recently made a presentation to the Korean nuclear regulator.  It included a figure that summarizes the SC aspects of the ROP Action Matrix.  Under columns 3 and 4, the figure says “may request” and “request” the licensee to conduct a SC assessment.  However, on the next page, the presentation bullets are more forthcoming: “For Plants in Columns 3 . . . and 4 . . . NRC requires [emphasis added] Licensee to conduct third party safety culture assessment which is reviewed by NRC.”****

We’re not opposed to the NRC squeezing licensees to strengthen their SC.  We just don’t like hypocrisy and doublespeak.  Perhaps the agency takes this convoluted approach to controlling SC to support their claim they don’t interfere with licensee management.  We don’t believe that; do you?


*  NRC Staff Testimony of V.E. Barnes et al Concerning Safety Culture and NRC Safety Culture Policy Development and Implementation before the Atomic Safety and Licensing Board (July 30, 2010) revised Sept. 7, 2010.  ADAMS ML102500605.

**  The ROP framework includes three cross-cutting areas (human performance, problem identification and resolution, and safety conscious work environment) which contain nine safety culture components. (p. 23)

***  This is another leverage point for the agency.  They make sure SC assessment findings are entered in the licensee’s corrective action program (CAP).  Then they use their regulatory authority over the CAP to ensure it is useful and effective, i.e., that SC corrective actions are implemented. (p. 30)

****  M. Keefe, “Incorporating Safety Culture into the Reactor Oversight Process (ROP),” presentation to the Korea Institute of Nuclear Safety (June 2-3, 2015), pp. 5-6.  ADAMS ML15161A109.

CPUC Proposes to Probe PG&E’s Culture

CPUC Headquarters (Source: Coolcaesar on en.wikipedia)

Yesterday’s edition of a Bay Area newspaper included a report* on a California Public Utilities Commission (CPUC) proposal to undertake a deep review of Pacific Gas & Electric’s (PG&E) culture and governance.  This is part of the long tail of consequences, including fines and criminal charges, the company has experienced in the aftermath of the Sept. 9, 2010 gas main explosion in San Bruno, CA.

The author got a Georgetown law professor (Scott Hempling) to opine on the situation and he had a couple of interesting observations:

“. . . for any utility, perhaps the most significant potential root cause of subpar performance is a culture of a entitlement, arising from the fact that the utility does not have to compete to maintain its monopoly.”

As to whether the CPUC has the authority to order changes at PG&E, he said “If it's not the PUC, then perhaps the state Legislature.  That monopoly that PG&E has was not granted by God.  It's not in the U.S. Constitution.  It is granted either by the PUC or the state Legislature."

What would your state regulator find if they stuck a probe into your organization?  Would there be a significant reading on the entitlement meter?

Diablo Canyon

At Safetymatters our major concern is with nuclear safety culture (SC) so it’s natural to ask how or even if the proposed review could affect Diablo Canyon.  On the surface, the answer is no probable impact.  PG&E’s problems and accidents have been concentrated in its gas business.  And from the get-go, PG&E has worked to isolate Diablo Canyon from the rest of the company.  But the plant’s many implacable opponents constitute a wild card in this situation.  You can bet they will do everything they can to get the scope of any CPUC review to include Diablo Canyon’s SC and operations.


*  G. Avalos, “San Bruno aftermath: PUC eyes broad probe of PG&E,” Contra Costa Times online (Aug. 17, 2015).

For more details on the CPUC proposal, see their press release: “CPUC Set to Consider Investigation into PG&E’S Culture and Governance to Ensure Safety is a Priority” (Aug. 17, 2015).

A Quiet Conclusion to Millstone’s TDAFW Pump Problem

Millstone

On Jan. 15, 2015 we posted about the long time it took Millstone to correctly evaluate and fix a problem with a turbine-driven auxiliary feedwater (TDAFW) pump.  The lengthy problem resolution caught the attention of the plant’s state overseer and the NRC.  We wondered if the event was a harbinger of some slippage in Millstone’s safety culture (SC).

The NRC conducted a supplemental inspection into the pump issue and published their results in late July.*  Because this inspection was conducted using Inspection Procedure 95001, one NRC action was to verify that the licensee’s root cause evaluations appropriately considered SC.  The inspectors’ SC findings, summarized below, are on pp. 7-8 of the report details.

Dominion (Millstone’s owner) identified SC-related weaknesses in three cross-cutting areas:

Problem Identification and Resolution and Human Performance, Conservative Bias

The licensee identified several instances where evaluations of issues or events were not complete, evaluations were less than timely and/or thorough and corrective actions were not sustainable.  In addition, the licensee identified instances of inadequate decision making and bypassing the Corrective Action Program (CAP) program implementation.

The corrective action in both areas was to make changes in the organizational behavior through station leadership stand downs and by improving the scheduling of daily CAP related meetings to ensure adequate engagement in the processing and review of CAP products.

Human Performance, Procedure Adherence

The licensee identified instances where corrective actions were not completed as written. Dominion’s corrective actions include CAP group reviews for specified corrective action assignments, implementing a Corrective Action Review Board coordinator and restricting manager level functions in the central reporting system to department managers.

Overall, the inspectors determined that Dominion’s root cause, extent of condition, and extent of cause evaluations appropriately considered SC components.

Our Perspective

The SC fixes are from the everyday menu: more management involvement, better oversight and improved organizational practices.  The report also mentioned additional traditional fixes (upgraded procedures, more training and the development of relevant case studies) applied to other aspects of how and how well the plant investigated its handling of the pump problem.  Taken together, they are concrete, if not exactly momentous, actions to improve a vital organizational process, i.e., the CAP.  In addition, the fixes are consistent with the plant's position that the TDAFW pump problem was a localized issue.

We would like to see a more systemic investigation of SC-related factors but the actions taken reflect an acceptable SC and reinforce our perception that Dominion (unlike Millstone’s former owner) takes safety seriously.


*  R.R. McKinley (NRC) to D.A. Heacock (Dominion), “Millstone Power Station Unit 3 – NRC Supplemental Inspection Report 05000423/2015010 and Assessment Follow-Up Letter” (July 22, 2015).  ADAMS ML15202A473.

Obtain Better Decisions by Asking Better Questions

We’re currently experiencing a reduced flow of quality feedstock into our safety culture mill.  But we did see a reference to a Harvard Business Review (HBR) article* that’s worth a quick read.

The authors’ thesis is the pressure on business to make decisions ever more quickly means important questions may never get asked, or even considered, which leads to poor decision-making.  Their proposed fix is to ask more, better questions to help frame decisions.  They suggest four types of questions, presented in the consultant’s favorite typology:  the two-by-two matrix.  In this case, one axis is the View of the Problem (wide or narrow) and the other is the Intent of the Question (to affirm or discover), as shown in the following figure.

Types of Questions to Improve Decision Making  (Source Mu Sigma)

Clarifying questions are focused on helping participants or managers understand what has happened so far, e.g., the data gathered or partial decisions already made.  People often don’t ask these questions because of cultural pressures to move forward, or they tend to make assumptions and fill in any missing parts themselves.**

Adjoining questions explore related aspects of the problem utilizing available information, e.g., how the results of this analysis could be applied elsewhere. 

Funneling questions are focused on learning more about the analysis to date.  How was an answer derived?  What were your assumptions?  What are the root causes of this problem?  The authors opine that most analytical teams usually do a good job of asking this type of question.

Elevating questions raise broader issues and create opportunities to make new connections between individual decisions, e.g., what are the larger issues or trends we should be concerned about?

There is a cultural dimension to question asking, particularly the unspoken rules about what types of questions can be asked, and by whom, in the decision making process.  Leaders need to encourage people to ask questions and co-workers need to be tolerant of the question askers rather than pushing to obtain and deliver an answer.

Our Perspective

The information in this article is hardly magical.  Most of us recognize that the best investigators and managers know What kind of questions they are asking and Why.  But we do have a few exercises for you to think about.   

For starters, look at the questions suggested or prescribed in your official problem-solving or problem analysis recipes.  Do they omit any types of questions that could add value to your immediate situation, bigger picture issues or the overall process?

What’s your problem solving culture like?  How are people treated who ask questions, especially devil’s advocate questions, that don’t add instant value to the search for an answer?

Finally, consider Millstone’s issue with a turbine-driven auxiliary feedwater pump (which we reviewed on Jan. 15, 2015).  Could more extensive questioning during the initial analysis phase have more quickly led the investigators to a correct understanding of the problem?    


*  T. Pohlmann and N.M. Thomas, “Relearning the Art of Asking Questions,” Harvard Business Review on-line (Mar. 27, 2015).  The authors are not famous professors.  They are two consultants with a Mu Sigma, a Big Data company, who are publishing under the HBR aegis.  That doesn’t disqualify their work, it’s just something to keep mind as they describe a construct their firm uses.

**  For an informative and entertaining essay on how people develop their own models of what’s going on in the world, even when they are wildly misinformed, check out “We Are All Confident Idiots.”

Fixing General Motors’ Culture—Any Lessons for Nuclear?

GM Headquarters

In a recent interview* with LinkedIn, General Motors CEO Mary Barra discussed her plan for fixing GM’s culture.  The interviewer asked what needs to change, what about known problems like the “GM nod”** and the siloed organization, and what is the key to the improvement process?  The following quotes are excerpted from her answers.  Do they suggest a clear vision for the future culture and/or a satisfactory action plan?

“. . . get everyone engaged, working together, and bringing the best ideas forward[.]”

“. . . I never accepted the GM nod.  If somebody said in a meeting they were going to do something, I expect you to do it.”

“We've got to model [working across the organization].”

“[We have to] own each other's problems.”

“So our goal is to be the safety leader. We're really driving a zero-defect mentality.”

“If we can get in a room and really, you know, argue it out constructively and everybody's views get on the table, we'll make better decisions.”

“. . . we've got to earn the trust of every single employee by demonstrating the way we behave.”

Our Perspective

We realize this was not some carefully crafted article for the Harvard Business Review but there are too many soft spots in this recipe for fixing the culture to let this interview slide by without comment.

Let’s begin with the positives.  Barra promotes respect for ideas; that’s a positive feedback loop and a good thing.  Senior management modeling desired behavior and working to earn employee trust are both essential for cultural change.  Safety leadership is certainly a laudable goal.  

The nod is a little more problematic.  Maybe Barra never accepted the nod but plenty of other folks did.  Is modeling the desired behavior sufficient to create change?  How long will it take?  What else might need to be done?

Shared ownership of problems is a good start but how does GM establish, model and inculcate a process that obtains permanent problem resolutions going forward?

Barra also believes an insider (like her) is better suited for changing the culture than an outsider.  We agree an insider may have a better handle on recognizing when employees are trying to spin a situation in their favor but an outsider can bring a clear view of the performance gap between an organization’s current state (e.g., its characteristics, priorities and processes) and where it needs to be.

Some ingredients are missing.  Most importantly, there is no mention of the powerful cost/finance feedback loop that contributed to GM’s quality problems.  Wringing pennies out of product costs was a major goal for years.  What roles will cost consciousness and management financial incentives play going forward?

In another area, how is the management decision making process changing other than arguing things out?

Bottom line: There are no lessons for nuclear in the GM CEO’s outline of her cultural change initiative.  In fact, her proclamations sound just like nuclear managers’ braying when they try to convince regulators, the media and the public that something, anything is happening to address perceived cultural issues.  But what usually isn’t happening is some in-depth analysis of how their organizational system functions.


*  D. Roth, “Mary Barra's Got a Plan for Fixing GM's Culture (and Only an Insider Can Pull it Off),” LinkedIn interview (July 6, 2015).  Safetymatters co-founder Bob Cudlin first spotted and called attention to this article.

**  The “GM nod” was “where employees would commit to being on board with a decision, then ignore it [later.]”

New Safety Culture Assessment at the Hanford Waste Treatment Plant

Hanford WTP

The Department of Energy (DOE) recently released the latest safety culture (SC) assessment report* for the Hanford Waste Treatment Plant (WTP or “vit plant”) project.  The 2015 report follows similar SC assessments conducted in 2011 and 2014, all of which were inspired by the Defense Nuclear Facilities Safety Board’s scathing 2011 report on SC at the WTP.  This post provides a brief overview of the report’s findings then focuses on the critical success factors for a healthy SC.

Assessment Overview

The 2011, 2014 and 2015 assessments used the same methodology, with multiple data collection methods, including interviews, Behavioral Anchored Rating Scales (BARS)** and a SC survey.  Following are selected highlights from the 2015 report.

DOE’s Office of River Protection (ORP) has management responsibility for the WTP project.  In general, ORP personnel feel more positive about the organization’s SC than they did during the 2014 assessment.  Feelings of confusion about ORP’s more collaborative relationship with Bechtel (the prime contractor) have lessened.  ORP management is perceived to be more open to constructive criticism.  Concerns remain with lack of transparency, trust issues and the effectiveness of the problem resolution process.

Bechtel personnel were more positive than in either previous SC assessment.  Bechtel has undertaken many SC-related initiatives including the promotion of a shared mental model of the project by senior Bechtel managers.  In 2014, Bechtel Corporate’s role in project decision making was perceived to skew against SC concerns.  The creation of a new Bechtel nuclear business unit has highlighted the special needs of nuclear work. (pp. 2, 39)  On the negative side, craft workers remain somewhat suspicious and wary of soft retributions, e.g., being blamed for their own industrial mishaps or having their promotion or layoff chances affected by reporting safety issues.

See this newspaper article*** for additional details on the report’s findings. 

Critical Success Factors for a Healthy SC

We always look at the following areas for evidence of SC strength or weakness: management’s decision making process, recognition and handling of goal conflicts, the corrective action program and financial incentives.

Decision Making

Both ORP and Bechtel interviewees complained of a lack of basis or rationale for different types of decisions. (pp. 9, 16)  Some ORP and Bechtel interviewees did note that efforts to clarify decision making are in process. (pp. 13, 32)  Although the need to explain the basis for decisions was recognized, there was no discussion of the decision making process itself.  This is especially disappointing because decision making is one of the possible behaviors that can be included in a BARS analysis, but was not chosen for this assessment.

Goal Conflicts

Conflicts among cost, schedule and safety goals did not rise to the level of a reportable problem.  ORP interviewees reported that cost and schedule do not conflict with safety in their individual work. (p. 6)  Most Bechtel interviewees do not perceive schedule pressures to be the determining factor while completing various tasks. (p. 23)  Overall, this is satisfactory performance.

Corrective Action Program

We believe how well an organization recognizes and permanently resolves its problems is important.  Problem Identification and Resolution was one of the traits evaluated in the assessment.  ORP interviewees said that current safety concerns are being addressed.  The historical lack of management feedback on problem resolution is still a disincentive for reporting problems. (pp. 8-9)  Some Bechtel interviewees said “issue resolution with management engagement was the single most positive improvement in problem resolution, . . .” (p. 24)  This performance is minimally acceptable but needs ongoing attention.

Financial Incentives

DOE’s contract with Bechtel now includes incentives for Bechtel if it self-identifies problems (rather than waiting for DOE or some other party to identify them).  ORP believes the incentives are a positive influence on contractor performance. (p. 8)  Bechtel interviewees also believe the new contract has had a positive impact on the project.  However, Bechtel has a goal to reduce legacy issues and some believe the contract’s emphasis on new issues distracts from addressing legacy problems. (pp. 24-25)  The assessment had no discussion of either ORP or Bechtel senior management financial incentives.  The new contract conditions are good; ignoring senior management incentives is unacceptable.

Safety Conscious Work Environment (SCWE)

We usually don’t pay much attention to SCWE at nuclear power plants because it is part of the larger cultural milieu.  But SCWE has been a long-standing issue at various DOE facilities, as well as the impetus for the series of WTP SC assessments, so we’ll look at a few highlights from the SC survey data.

For ORP, mean responses to five of the six SCWE questions were higher (better) in 2015 vs 2014, and 2014 vs 2011.  However, for one question “Concerns raised are addressed” the mean is lower (worse) in 2015 vs 2014, and significantly lower in 2015 vs 2011.  This may indicate an issue with problem resolution. (p. B-2) 

For Bechtel, mean responses to all six SCWE questions were significantly higher (better) in 2015 vs 2014.  However, the 2011 data were not included so we cannot make any inference about possible longer-term trends. (p. B-5)  What is shown is good news because it appears people feel freer to raise safety concerns.  Interestingly, Bechtel’s mean 2015 responses were 5-13% higher (better) than ORP’s for all questions.

Both ORP and Bechtel are showing acceptable performance but continued improvement efforts are warranted.

Our Perspective

The Executive Summary and Conclusions suggest ORP and especially Bechtel have turned the corner since 2014. (pp. v, 37)  This is arguably true for SCWE but we’d say the jury is still out on improvement in the broader SC, based on our look at the BARS data.

For ORP, the BARS data mean scores are higher for 4 (out of 10) behaviors in 2015 vs 2014, but only higher for 1 behavior in 2015 vs 2011. (p. B-1)  The least charitable interpretation is ORP’s view of itself has not yet re-achieved 2011 levels.  For Bechtel the BARS data shows a bit brighter picture.  Mean scores are higher for 6 (out of 10) behaviors in 2015 vs 2014, and higher for 4 behaviors for 2015 vs 2011. (p. B-4)

The format of the report is probably intended to be reader-friendly but it mixes qualitative interview data and selected quantitative data from BARS and the survey.  The use of modifiers like “many” and “some” creates a sense of relative frequency or importance but no real specificity.  It’s impossible to say how much (if any) cherry picking of the interview data occurred.****

We also wonder about the evaluation team’s level of independence and optimism.  This is the first time DOE has performed a WTP SC assessment without the extensive use of outside consultants.  Put bluntly, how independent was the team’s effort given DOE Headquarters’ desire to see improvements at WTP?  And it’s not just HQ; DOE is under the gun from Congress, the DNFSB, the Government Accountability Office, and environmental activists and regulators to clean up their act at Hanford.

We want to see a stronger SC at Hanford but we’ll go with Ronald Reagan on this report: “Trust, but verify.”


*  DOE Office of Enterprise Assessments, “Follow-up Assessment of Safety Culture at the Hanford Site Waste Treatment and Immobilization Plant” (June, 2015).  We have followed the WTP saga for years; please click on the Vit Plant label to see our related posts.

**  Behavioral Anchored Rating Scales (BARS) quantitatively summarize interviewees’ perceptions of their organization using specific examples of good, moderate, and poor performance.   There are 17 possible organizational behaviors in a BARS analysis, but only 10 were used in this assessment:  Attention to Safety, Coordination of Work, Formalization, Interdepartmental Communication, Organizational Learning, Performance Quality, Problem Identification and Resolution, Resource Allocation, Roles and Responsibilities and Time Urgency. (p. C-2)

***  A. Cary, “DOE: Hanford vit plant safety culture shows improvement,” Tri-City Herald (June 26, 2015).

****  The report also includes multiple references to the two organizations’ behavioral norms that were inferred from the survey data.  It’s not exactly consultant mumbo-jumbo but it’s too complicated to attempt to explain in this space.

Safety Culture at Arkansas Nuclear One

Arkansas Nuclear One (credit: Edibobb)

Everyone has heard about the March 31, 2013 stator drop at Arkansas Nuclear One (ANO).  But there was also unsatisfactory performance with respect to flood protection and unplanned scrams.  As a consequence, ANO has been assigned to column 4 of the NRC’s Action Matrix where it will receive the highest level of oversight for an operating plant.

When a plant is in column 4 the NRC takes a particular interest in its safety culture (SC) and ANO is no exception.  NRC required ANO to have an independent (i.e., outside third party) SC assessment, which was conducted starting in late 2014.  While the assessment report is not public, some highlights were discussed during the May 21, 2015 NRC staff briefing of the Commissioners on the results of the April 15, 2015 Agency Action Review Meeting.*

NRC Presentation

The bulk of the staff presentation was a soporific review of agency progress in a variety of areas.  But when the topic turned to ANO, the Regional Administrator responsible for ANO was quite specific and minced no words.  Following are the key problems he reviewed.  See if you can connect the dots on SC issues based on these artifacts.

Let’s start with the stator drop.  ANO’s initial root cause evaluation did not identify any root or contributing causes related to ANO’s own performance, but rather focused solely on the contractor.  After the NRC identified ANO’s failure to follow its load handling procedure, ANO conducted another root cause evaluation and identified their own organizational performance issues such as inadequate project oversight and non-conservative decision making. (pp. 28-29)

The stator drop damaged a fire main which caused localized flooding.  This led to an extended condition review which identified various equipment and structures that could be subject to flooding.  The NRC inspectors pointed out deficiencies in the condition review and identified corrective actions that likely would not work.  In addition, earlier flooding walkdowns completed as part of the NRC’s post-Fukushima requirements failed to identify the majority of the flood protection deficiencies.  These walkdowns were also performed by a contractor.  (pp. 29-31)

Finally, ANO did not report an April 2014 Unit 2 trip as an unplanned scram because the trip occurred during a planned down power evolution.  After prodding by the NRC inspectors, ANO reclassified this event as an unplanned scram. (pp. 31-32)

Overall, the NRC felt it was driving ANO to perform complete evaluations and develop effective corrective actions.  NRC believes that ANO’s “cause evaluations typically don't provide for a thorough assessment of organizational and programmatic contributors to events or issues.” (p. 35)  Later, in response to a question, the Regional Administrator said “I think the licensee clearly needs to own the performance gaps, ensure that their assessments in the various areas are comprehensive and then identify appropriate actions, and then engage and ensure those actions are effective. . . . I don't want to be in a position where our inspection activities are the means for identifying the performance gaps.” (p. 44)

Responding to a question about ANO’s independent SC assessment, he said “one of the key findings . . . was that there's an urgent need to internalize and communicate the seriousness of performance problems and engage the site in their strategy for improvement.” (p. 45)

Entergy Presentation

A team of Entergy (ANO’s owner) senior managers presented their action plan for ANO.  They said they would own their own problems, improve contractor oversight, identify their own issues, increase corporate oversight and improve their CAP.

With respect to culture, they said “We're going to change the culture to promote a healthy, continuous improvement and to not only achieve, but also to sustain excellence.” (pp. 70-71)  They are benchmarking other plants, analyzing ANO’s issues and adding resources including people with plant performance recovery experience. 

They took comfort from the SC assessment conclusion “That although weaknesses exist, the overall safety culture at ANO is sufficient to support safe operation." (p. 72)

In response to a question about important takeaways from the SC assessment, Entergy referred to the need for the plant to recognize that performance has got to improve, the CAP must be more effective and organizational programmatic elements are important.  In addition, they vowed to align the organization on the performance gaps (and their significance) and establish a sense of urgency in order to fix them. (pp. 80-81)

Our Perspective

Not to be too cynical, but what else could Entergy say?  When your plant is in column 4, a mega mea culpa is absolutely necessary.  But Entergy’s testimony read like generic management arm-waving invoking the usual set of fixes.

Basically, the ANO culture endorses a “blame the contractor” attitude, accepts incomplete investigations into actual events and potential problems, and is content to let the NRC point out problems for them.  Where did those values come from?  Is “increased oversight” sufficient to create a long-term fix?

ANO naturally gives a lot of weight to the SC assessment because its findings appear relatively simple and apparently actionable.   Somewhat surprisingly, the NRC also appears to give this assessment broad credibility.  We think that’s misplaced.  The chances are slim of such an assessment identifying deep, systemic cultural issues although we admit we don’t know the assessment details.  Did the assessment team perform document reviews, conduct focus groups or interviews?  If it was a survey, it only identified the most pressing issues in the plant’s safety climate.

Taking a more systemic view, we note that Entergy has a history of SC issues over many plants in its fleet.  Check out our Feb. 20, 2015 post for highlights on some of their problems.  Are ANO’s problems just the latest round of SC Whac-A-Mole at Entergy?

Entergy has always had a strong Operations focus at its plants.  The NRC’s confidence in ANO’s operators is the main reason that plant is not shut down.  But continuously glorifying the operators, particularly their ability to respond successfully to challenging conditions, is like honoring firefighters while ignoring the fire marshal.  The fire marshal role at a nuclear plant is played by Engineering and Maintenance, groups whose success is hidden (thus under-appreciated) in an ongoing series of dynamic, non-events, viz., continuous safe plant operation.  That’s a cultural issue.  By the way, who gets the lion’s share of praise and highest status at your plant?


*  “Briefing on Results of the Agency Action Review Plan Meeting,” public meeting transcript (May 21, 2015).  ADAMS ML15147A041.

The Agency Action Review Meeting (AARM) “is a meeting of the senior leadership of the agency, and its goals are to review the appropriateness of agency actions taken for reactor material licensees with significant performance issues.” (pp. 3-4)