ML060180160
| ML060180160 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/18/2006 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| Schoenfeld I | |
| References | |
| Download: ML060180160 (13) | |
Text
Industry Safety Culture Presentation January 18, 2006 Public Meeting
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Background===
Industry made significant improvements to safety culture oversight z
Davis-Besse lessons learned training conducted by all licensees (SOER 02-04) z Self-assessments of safety culture performed by all licensees (SOER 02-04) z Industry Safety Culture Principles document issued z
INPO Evaluation process specifically address Safety Culture Principles and Attributes z
INPO evaluates industry OE against Safety Culture Principles and Attributes z
INPO evaluates SOER 02-04 recommendations 1&2 during every plant evaluation z
INPO changes to evaluation, assistance, training, and operating experience cornerstones
NRC made significant changes to ROP cross-cutting areas post Davis-Besse z
Re-defined sub-components z
Established threshold (3+) for substantive issue analysis z
PI&R changes specifically address long-term unresolved issues z
PI&R changes specifically address deferred plant modifications z
PI&R changes specifically address operator work-arounds z
Recent changes to Engineering Inspection procedure
Industry Position 1.
Adequate NRC oversight of Licensee Safety Culture is provided by:
a.
Existing regulatory framework (50.7, 50.65, Appendix B, ROP, etc.)
b.
Enhancements already made to cross-cutting areas and their associated sub-components c.
The following additional enhancements proposed in 12-21-2005 Staff paper i.
Long-standing cross-cutting issues (assessment process) ii.
Column 2 reviews of root causes (95001) iii.
Column 3 and 4 interventions (95002, 95003) 2.
Development of Safety Culture Components is premature until agreement is reached on usage. Any Safety Culture Components list developed should be used to guide the staffs evaluation of the quality of licensee safety culture assessments and to perform its own assessments.
3.
Staff proposed cross-cutting area changes are not necessary/desirable because:
a.
Item A. process meets the direction in December 21 SRM b.
Current cross cutting areas provide meaningful safety culture insights c.
Introduce unnecessary complexity and instability d.
Inconsistent with ROP principles of predictable, transparent, risk-informed, and objective
Existing vs. Proposed Subcomponents PI&R PI&R CAP Operating Experience Self &
Independent Assessment PI&R Identification Evaluation Corrective Action What We Have What Is Being Proposed
Inspection Insights Performance Indicator Insights PI&R Insights Safety Culture Insights Existing PI&R process provides valuable insights with respect to a licensees safety culture.
Safety Culture is that assembly of characteristics and attitudes in organizations and individuals which establishes that, as an overriding priority, nuclear plant safety issues receive the attention warranted by their significance.
PI&R Goal:
establish confidence licensee is detecting and correcting problems in a manner that limits risk
PI&R Inspection Foundation Minimum 100, up to 400 baseline inspection hours PER YEAR to PI&R z Verify equipment, human performance, and program issues are being identified at appropriate threshold and being entered into licensees PI&R process.
z Verify corrective actions commensurate with significance of issue have been identified and implemented
PI&R Inspection Procedure Fundamental Principle IP 71152-03 General Guidance Process focuses on identification of problems and effectiveness of corrective actions for risk significant issues rather than administrative aspects of program
ALL elements of staff proposed sub-components are covered in existing IP 71152 z CAP - IP 71152 - all sections, significant scope changes already made z Operating Experience - IP 71152 Section -03.5 z Self and Independent Assessment IP 71152 Sections 02.01d, 02.03.c, -03.6 One important lesson from Davis Besse:
Quality of IMPLEMENTATION is more important than quality of PROGRAM Existing vs. Proposed Subcomponents PI&R - Industry Review
Existing vs. Proposed Subcomponents Human Performance What We Have What Is Being Proposed Work Control Worker Practices Resources Decision Making Personnel Resources Organization
Proposed vs. Existing Subcomponents Human Performance (Worker Practices) Personnel (Resources) Resources (Decision Making) Organization (Work Control) - combination of PI&R, Resources, and Personnel
Human Performance Industry Analysis Existing Human Performance sub-components more closely reflect typical industry models of performance Proposed sub-components z Are inconsistent with any Human Performance Model currently being used z Add further subjectivity to the existing process z Dont fully capture important Human Performance factors z Will not provide benefit over current sub-components as binning tools
Existing vs. Proposed Subcomponents SCWE What We Have What Is Being Proposed Willingness to raise concerns Preventing and detecting retaliation An environment in which employees feel free to raise safety concerns, both to their management and to the NRC, without fear of retaliation.
Current process provides adequate insights Proposed sub-component definitions are inaccurate reflection of SCWE because they eliminate the causal connection Threshold proposed by component definitions for findings in SCWE too low (one) and inconsistent with cross-cutting principles Existing vs. Proposed Subcomponents SCWE - Industry Perspective