ML070880826

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G20070163 - David A. Lochbaum Ltr. from Luis Reyes Re.: Nrc'S Thundering Silence - Safety Culture Problems at Point Beach
ML070880826
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 04/26/2007
From: Reyes L
NRC/EDO
To: Lochbaum D
Union of Concerned Scientists
Mark King, NRR, 301-415-1150
Shared Package
ML070880869 List:
References
G20070163, TAC MD4818, TAC MD4819
Download: ML070880826 (5)


Text

April 26, 2007 Mr. David A. Lochbaum Union of Concerned Scientists 1707 H Street, NW, Suite 600 Washington, D.C. 20006-3919

Dear Mr. Lochbaum,

Thank you for your letter dated March 13, 2007. The Nuclear Regulatory Commission (NRC) staff agrees with your concern that it would be, very wrong for the NRC to run its generic communications program with a myopic focus on equipment problems, and that we should, alert licensees to safety culture problems. In fact, NRC has alerted licensees at all U.S. plants of the need to address attributes and elements important to safety culture (i.e., safety culture components). The enclosure provides a list of recent generic communications and information available on the NRC Web site related to safety culture components and non-equipment issues, as well as information made available to the public related to recent Point Beach issues.

Regarding your request for a specific Point Beach generic communication, we have reviewed your examples and Point Beachs history in this area, and determined that the specific issue related to safety culture at Point Beach does not have enough generic applicability to warrant a formal generic communication at this time. The most recent Point Beach annual assessment letter, dated March 2, 2007, to the licensee also stated . . . the NRC does not have a concern with the scope of your [Point Beach] efforts in addressing both the specific discrimination issue and the less than favorable results of the culture surveys. During the 2007 assessment period, the NRC will review the progress of your [Point Beach] efforts to address these issues and a determination will be made whether additional action by the NRC is warranted. This would include review and consideration for any formal generic communications, if appropriate.

Based on NRC review of your specific request and given the information provided in the documents in the enclosure, particularly the NRC Regulatory Issue Summaries (RIS 2006-13, Information on the changes made to the reactor Oversight Process to more fully address Safety Culture, dated July 31, 2006 and RIS 2005-18, Guidance for Establishing and Maintaining a Safety Conscious Work Environment, dated August 25, 2005) addressing safety culture, my staff has determined the NRCs generic communication program is being appropriately implemented for both equipment and non-equipment issues. The NRC agrees that it is important that non-equipment issues and safety culture issues be considered for generic communications and my staff will continue to look for opportunities to do so now that we have implemented changes to the Reactor Oversight Program to more fully address safety culture. Several groups in the NRC perform these reviews and will continue to assess these types of issues. When warranted, the NRC will issue the appropriate generic communication.

D. Lochbaum Thank you for your interest in the NRC generic communication process and how it relates to safety culture. If you have additional questions related to this subject, please contact Mary Jane Ross-Lee, Operating Experience Branch Chief, of the Office of Nuclear Reactor Regulation at 301-415-3281.

Sincerely,

/RA Martin J. Virgilio Acting for/

Luis A. Reyes Executive Director for Operations

Enclosure:

Generic Communications and Information Related to Safety Culture Point Beach and Non-Equipment Issues

D. Lochbaum Thank you for your interest in the NRC generic communication process and how it relates to safety culture. If you have additional questions related to this subject, please contact Mary Jane Ross-Lee, Operating Experience Branch Chief, of the Office of Nuclear Reactor Regulation at 301-415-3281.

Sincerely,

/RA Martin J. Virgilio Acting for/

Luis A. Reyes Executive Director for Operations

Enclosure:

Generic Communications and Information Related to Safety Culture Point Beach and Non-Equipment Issues DISTRIBUTION: G20070163 RidsEdoMailCenter RidsNrrOd RidsNrrAdro RidsNrrAdes RidsNrrAdra RidsOpaMail RidsOgcMailCenter RidsSecyMailCenter RidsOcaaMailCenter RidsNrrWpcMail RidsNrrAdroIeob ADAMS: Package : ML070880869, Incoming: ML070740477, Response: ML070880826,*via email OFFICE DIRS/IOEB TL:DIRS/IOEB BC:DIRS/IOEB BC:PGCB:DPR DIRS:PAB NAME MKing JDozier MJRoss-Lee CJackson RGramm (JDozier for)

DATE 03/30/07 04/02/07 04/17/07 03/30/07 04/09/07 OFFICE DIRS:IPAB* R-III:DRP* R-111* OE D:NRO NAME DAllsop MKunowski JCaldwell LJarriel BBorchardt DATE 03/29/07 04/02/07 04/02/07 04/13/07 04/16/07 OFFICE D:DIRS D:NRR EDO NAME ECollins JDyer LReyes DATE 04/18/07 04/24/07 04/26/07 OFFICIAL RECORD COPY

Generic Communications and Information Related to Safety Culture Point Beach and Non-Equipment Issues The NRC Generic Communication program is used to communicate with the nuclear industry on a broad spectrum of matters having generic applicability. Generic Communications range from informing the nuclear industry of recently-identified significant operating experience to items requiring responses under oath or affirmation. In the past several years, there have been a number of generic communications that addressed non-equipment issues. There have been Generic Communications that addressed security, emergency preparedness, as well as attributes or elements important to safety culture (i.e., safety culture components).

1.) A Regulatory Issue Summary (RIS) is a form of generic communication. In the past two years, the NRC has issued two Regulatory Issue Summaries that directly relate to establishing and maintaining a safety conscious work environment, and to the changes made to the Reactor Oversight Process (ROP) to more fully address safety culture:

NRC Regulatory Issue Summary 2006-13: Information on the changes made to the Reactor Oversight Process to more fully address Safety Culture, dated July 31, 2006.

This Regulatory Issue Summary describes the changes to the ROP, which was developed with stakeholder input, to enhance the treatment of safety culture, (ADAMS Accession No. ML061880341);

NRC Regulatory Issue Summary 2005-18: Guidance for Establishing and Maintaining a Safety Conscious Work Envrionment, dated August 25, 2005. This RIS was issued to provide licensees, applicants for a license, holders of certificates of compliance, and their contractors, detailed guidance on establishing and maintaining a safety conscious work environment, (ADAMS Accession No. ML052220239).

Changes were made to a number of NRC Inspection Procedures to more fully address safety culture components and issued for public comment, including NRC Inspection Procedure 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input," revised on October 26, 2006 to include inspection guidance to: (a) assess the licensees third party safety culture assessment and (b) independently assess the licensees safety culture, (ADAMS Accession.

ML062970393).

2.) Examples of generic communications issued this year that address non-equipment related issues, and/or safety culture components include:

NRC Information Notice 2007-12, Tactical Communications Interoperability Between Nuclear Power Reactor Licensees and First Responders, dated March 15, 2007, (ADAMS Accession No. ML070710233);

NRC Information Notice 2007-11, Recent Operator Performance Issues at Nuclear Power Plants, dated March 6, 2007, (ADAMS Accession No. ML070440238);

Enclosure

NRC Infomation Notice 2007-04: Construction Experience Related to the Assurance of Quality in the Construction of Nuclear Faciities, dated February 5, 2007. This IN discussed recent quality assurance and safety culture issues noted during foreign reactor construction, i.e., a failure to establish an atmosphere that encourages problem reporting and resolution at all levels of the organization. (ADAMS Accession No. ML063040426);

NRC Regulatory Issue Summary 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, dated February 2, 2007, (ADAMS Accession No. ML062370311).

3.) There are several pages on the NRC public website that have been posted that also provide information related to safety culture to the public and the industry including:

NRC Safety Culture webpage has been established and is available at:

http://www.nrc.gov/about-nrc/regulatory/enforcement/safety-culture.html. This webpage provides information detailing the staffs process in revising the ROP to more fully address safety culture and includes materials from public meetings, links to the revised Inspection Manual Chapters and Inspection Procedures, and training materials. It is periodically updated.

A link to NRC Commissioner Gregory B. Jaczkos speech given on February 13, 2007 at the Employee Concerns Forum titled: The Future of Safety Culture Regulation."

A link to the nuclear industry Institute of Nuclear Power Operations (INPO) publication, dated November 2004, is provided on the NRC website: Principles for a Strong Nuclear Safety Culture.

4.) Information related to the Point Beach Site available on the NRC public website includes:

A Point Beach Summary Webpage that provides numerous links to documents related to the Point Beach site including: Public Meeting on Safety Culture dated April 3, 2006 and the Apparent Violation of Employee Protection Requirements , dated August 22, 2006.

The Reactor Oversight Process (ROP) Webpage provides direct access to all the plants regarding recent plant performance indicators, inspection findings, inspection reports, and NRC assessment letters. For the Point Beach units they are available at:

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/POIN1/poin1_chart.html http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/POIN2/poin2_chart.html The NRC NEWS Webpage regularly provides electronic news releases / updates such as:

NRC to discuss 2005 Performance Assesement and Review Safety Culture Survey for Point Beach Nuclear Power Plant, dated 3/15/2006 and, NRC Returns Point Beach to Routine Oversight, dated 12/4/2006.