ML18150A369

The Nuclear Regulatory Commissions Approach to Safety Culture (Diane Sieracki)

ML18150A369
Person / Time
Issue date:	06/14/2018
From:	Diane Sieracki NRC/OE
To:
Diaz-Castillo Y, NRO/DCIP
References
Download: ML18150A369 (17)

Text

The Nuclear Regulatory Commissions Approach to Safety Culture Diane Sieracki Senior Safety Culture Program Manager Office of Enforcement Nuclear Regulatory Commission US NRC -- Vendor Conference June 14, 2018

Outline

• NRC Safety Culture Roles and Responsibilities

• NRCs Safety Culture History

• NRCs Role in Safety Culture

• Safety Culture Policy Statement

• Safety Culture in the Reactor Oversight Process, Fuel Cycles, Alternative Dispute Resolution

• International and other U.S. Regulators

• Summary 2

NRC Safety Culture Roles and Responsibilities OE NRR NRO NMSS RES NSIR Support Offices Program Offices External Safety Culture Policy Lead Operating Reactors New Reactors Fuel Processing, Transportation

& Storage Agreement States Licensee Groups Medical Uses OCHCO Internal Safety Culture Lead Program Offices lead the implementation of Safety Culture for their Licensees 3

NRC Safety Culture History

• Operators inattentive and unprofessional while on duty at nuclear power plant

• Commission Policy Statement: Conduct of Nuclear Power Plant Operations 1989

• Workers retaliated against for whistleblowing

• Commission Policy Statement: Freedom to Raise Safety Concerns Without Fear of Retaliation 1996

• Davis-Besse reactor head degradation event

• NRC revised Reactor Oversight Process (ROP) to more fully address safety culture 2002

• Commission direction to develop policy statement on safety culture that applies to all licensees 2008

• Final Safety Culture Policy Statement (SCPS) published in the Federal Register 2011 4

Safety Culture Policy Statement Sets forth the Commissions expectation that individuals and organizations performing regulated activities establish and maintain a positive safety culture commensurate with the safety and security significance of their actions and the nature and complexity of their organizations and functions Commission Direction to Develop Policy Draft Policy Statement for Public Comment Public Workshops for Stakeholder Input Final Safety Culture Policy Statement Published Commission Direction to Continue Outreach

& Education 2008 2009 2010 2011 2012 Timeline 5

Safety Culture Definition 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 6

Preamble to the Safety Culture Traits A trait, in this case, 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. It is the Commissions expectation that all organizations and individuals overseeing or performing regulated activities involving nuclear materials should take the necessary steps to promote a positive safety culture by fostering these traits. Additionally, it should be noted that although the term security is not expressly included in the traits, safety and security are the primary pillars of the NRCs regulatory program.

Consequently, consideration of both safety and security issues commensurate with their significance, is an underlying principle of the Statement of Policy.

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Safety Culture Traits Leadership Safety Values and Actions Problem Identification and Resolution Personal Accountability Leaders demonstrate a commitment to safety in their decisions and behaviors Issues potentially impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected commensurate with their significance All individuals take personal responsibility for safety Work Processes Continuous Learning Environment for Raising Concerns The process of planning and controlling work activities is implemented so that safety is maintained Opportunities to learn about ways to ensure safety are sought out and implemented A safety conscious work environment is maintained where personnel feel free to raise safety concerns without fear of retaliation, intimidation, harassment or discrimination Effective Safety Communications Respectful Work Environment Questioning Attitude Communications maintain a focus on safety Trust and respect permeate the organization Individuals avoid complacency and continually challenge existing conditions and activities in order to identify discrepancies that might result in error or inappropriate action 8

Outreach and Education Efforts Interactions with Licensees and External Stakeholders International Involvement Conferences and Training Educational Tools

- Brochures

- Case Studies

- Trait Talk

- Posters and support materials Safety Culture Website http://www.nrc.gov/about-nrc/safety-culture.html 9

Outreach and Education Efforts

• SC Educational Resource Workbook

- Trait Talks

- Metro Case Study

- Journeys

- SCPS

• Safety Culture in Decommissioning

• Safety Culture Website http://www.nrc.gov/about-nrc/safety-culture.html 10

NRC Approach to Safety Culture

• Licensees bear primary responsibility for safety

• NRCs Safety Culture Policy Statement (SCPS) states safety culture expectation, but is not a regulatory requirement

• NRC considers safety culture within the Reactor Oversight Process (ROP) for nuclear power reactors

- NRC assessment of safety culture is primarily as a result of an event or degradation in performance

- Different levels of inspection activity based on NRCs overall assessment of licensee performance

• Alternative Dispute Resolution Process can result in Confirmatory Orders for safety culture activities 11

Reactor Oversight Action Matrix

NRC Allegation and Enforcement Programs

• Addresses safety culture through use of Chilling effect letters (CELs).

• Uses Confirmatory Orders (COs) in the ADR Program to resolve discrimination and wrongdoing cases.

Fuel Cycle Facilities

• Oversight of fuel cycle facilities

- Corrective Action Program Focus with Inspection Procedure 88161.

Importance of Safety Culture Activities Internationally and with other Regulators

• International Activities

- IAEA:

• Action Plan for Nuclear Safety

• Development of Technical Documents

• Common Language Framework efforts

- NEA:

SC of the Regulator

• Other U.S. Regulators

Summary

• NRC communicates safety culture expectations through the Safety Culture Policy Statement

• NRC continues outreach and education

• NRC direct involvement in safety culture assessment is graded, based on licensee performance through the ROP and safety culture can be addressed through the allegation and enforcement processes.

• NRC staff continues working with U.S. regulators and the international community 16

For More Information:

• Please visit NRCs safety culture webpage at:

http://www.nrc.gov/about-nrc/safety-culture.html

• Contact NRC staff via email at:

external_safety_culture.resource@nrc.gov