ML19050A020

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IMC 1245 Appendix C12 Safety Culture Assessor Training and Qualification Journal
ML19050A020
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Issue date: 02/28/2019
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NRC INSPECTION MANUAL IRAB INSPECTION MANUAL CHAPTER 1245 APPENDIX C12 SAFETY CULTURE ASSESSOR TRAINING AND QUALIFICATION JOURNAL Effective Date: 02/28/2019

Table of Contents Introduction ................................................................................................................................ 1 Safety Culture Assessor Competencies.................................................................................. 1 Safety Culture Assessor Qualification Levels.......................................................................... 1 Equivalency Justification Requirements .................................................................................. 2 Review of Completed Training ................................................................................................ 2 Documentation ....................................................................................................................... 2 Qualification Interview ............................................................................................................ 3 Certification ............................................................................................................................ 3 Interview Documentation.......................................................................................................... 3 Safety Culture Assessor Training Courses ................................................................................. 4 Safety Culture in the ROP ...................................................................................................... 4 Focus Group Facilitation ......................................................................................................... 4 Resolving Conflict Through Effective Communication (Senior SCA Only) ............................... 4 Motivating and Engaging Others (Senior SCA Only) ............................................................... 4 Building and Sustaining Teams (Senior SCA Only) .................................................................. 5 Safety Culture Assessor Individual Study Activities (ISAs) ......................................................... 6 ISA-1: Safety Culture in the Nuclear Industry.......................................................................... 6 ISA-2: Survey Overview.......................................................................................................... 8 ISA-3: Safety Culture Assessment Methods ........................................................................... 9 ISA-4: Conducting IP 95003 Inspections ...............................................................................11 ISA-5: Safety Conscious Work Environment (SCWE) Overview ............................................12 ISA-6: Safety Culture Theory and Research (Senior SCA Only) ............................................14 Safety Culture Assessor On-the-Job Training (OJTs)................................................................16 OJT-1: Safety Culture Inspection Activity ...............................................................................16 OJT-2: Review Safety Culture Assessments .........................................................................17 OJT-3: Shadow an Inspection Team Lead (Senior SCA Only) ...............................................19 Signature Card for SCA Qualification ........................................................................................20 Signature Card for Senior SCA Qualification .............................................................................23 Safety Culture Assessor Certificate ...........................................................................................24 Form 1: Safety Culture Assessor Equivalency Justification .......................................................25 : Safety Culture Assessor Competencies and KSAs ....................................... Att1-1 : Improving KSAs for Senior Safety Culture Assessor Qualification ................ Att2-1 : Revision History ........................................................................................... Att3-1 Issue Date: 02/28/19 i 1245 Appendix C12

Introduction The Office of Nuclear Reactor Regulation (NRR) developed this training and qualification program to certify individuals to be Safety Culture Assessors (SCAs) for performing safety culture assessments as outlined in Inspection Procedure (IP) 95002 and IP 95003, and other inspection activities related to safety culture. Any questions related to qualification as an SCA should be directed to the Branch Chief of the safety culture staff in NRR.

This document outlines the specific training and qualification requirements associated with developing safety culture assessment skills through individual study activities (ISAs), formal classroom and computer-based instruction, and on-the-job training (OJT). Training and qualification guidance associated with developing general inspection skills comes from IMC 1245, Appendices A and B. In general, ISA activities should be completed before OJT activities.

The SCA or Senior SCA does not necessarily need fully developed inspector skills since he/she functions as part of a team of inspectors. Therefore, the SCA qualification program only requires partial completion of IMC 1245 Appendix A and B as stipulated herein.

Safety Culture Assessor Competencies Qualification as a SCA requires completion of a variety of activities, each of which is designed to provide knowledge or practice a skill that may be important during an inspection that has a significant focus on safety culture, such as an IP 95002 or IP 95003 inspection. Sets of related knowledge, skills, and abilities required to successfully perform safety culture inspection tasks are referred to as competencies. Attachment 1 describes the competencies and associated knowledge, skills, and abilities (KSAs) for SCAs.

Safety Culture Assessor Qualification Levels The qualification program has two levels based on education and experience: Safety Culture Assessor (formerly known as Level II SCA) and Senior Safety Culture Assessor (formerly known as Level I SCA). Qualification as an SCA will allow participation in inspections with a safety culture focus at licensed or vendor facilities. Qualification as a Senior SCA will allow the candidate to lead safety culture teams during inspections. In order to qualify as a Senior SCA, an individual must have participated as a qualified SCA on a safety culture or SCWE inspection.

Equivalency justification will be considered on a case by case basis.

The factors to be considered in assessing a candidates readiness for qualification as an SCA or Senior SCA will vary on a case-by-case basis. Consideration is also given to the ability of the candidate to effectively carry out safety culture assessment activities specified in IP 95003, such as conducting interviews and focus groups for SCAs, and leading safety culture inspection teams for Senior SCAs. An individual interested in pursuing qualification should meet with their supervisor and the Branch Chief of the safety culture staff in NRR to discuss relevant knowledge and experience to determine the appropriate qualification level to pursue, or identify areas where additional training is needed. The supervisor may choose to delegate this discussion to a qualified Senior SCA in NRR or the Regional office.

Issue Date: 02/28/19 1 1245 Appendix C12

To qualify as an SCA, an individual must possess the KSAs to perform safety culture assessment activities at licensed and vendor facilities under the direction of a Senior SCA (see for complete list of KSAs). This requirement may be satisfied by having recent (i.e., within the last 5 years) training and/or hands-on experience with the types of activities that may be important during an inspection that has a significant focus on safety culture, such as conducting focus groups and interviews, and reviewing causes analyses and organizational assessments for safety culture insights. Completion of the training in this qualification journal is designed to help the candidate develop the required KSAs to qualify as an SCA.

To qualify as a Senior SCA, one must additionally possess the KSAs to plan and lead safety culture assessment activities at licensed and vendor facilities (see Attachment 1 for complete list of KSAs). The KSAs required of a Senior SCA are more extensive than the KSAs required of an SCA because of the need to have a thorough understanding of safety culture theories and methods for assessing safety culture. Generally, Senior SCAs should have specialized experience and education in the areas of safety culture, human factors, and/or organizational factors. This requirement may be satisfied in several ways, including formal education in the social or behavioral sciences, by having hands-on inspection experience at licensed facilities performing safety culture assessment activities, or a combination of both. In addition, because of the responsibilities involved, a Senior SCA must have demonstrated leadership skills (e.g.,

have led activities of similar scope or significance). See Attachment 2 for recommendations for additional training to develop the KSAs needed to qualify as a Senior SCA.

Equivalency Justification Requirements Previous work experience and training may be accepted as evidence of an equivalency justification for SCA or Senior SCA qualification, provided that the candidate already possess the required knowledge and skills normally achieved by completing the training activities. The Branch Chief of the safety culture staff in NRR has the authority to accept previous experience and training as an alternate method for meeting the training activities contained in this training plan. In granting an equivalency justification, the Branch Chief of the safety culture staff in NRR should consider the candidates ability to perform inspection activities without the benefit of the additional knowledge and regulatory perspective that would be gained by completing the specific training activities outlined in this plan. Equivalency justifications should be discussed with either a designated Senior SCA or the Branch Chief of the safety culture staff in NRR.

Justifications can be documented using Form 1, Safety Culture Assessor Equivalency Justification.

Review of Completed Training Training activities must be discussed with a qualified SCA or Senior SCA designated by the candidates supervisor, or with the Branch Chief of the safety culture staff in NRR.

Documentation Documentation of completed training is recorded on the SCA Signature Card. Equivalency justification for formal training courses, individual study activities, and on-the-job activities are recorded on Form 1.

Issue Date: 02/28/19 2 1245 Appendix C12

Qualification Interview All candidates are required to complete a qualification interview with the Branch Chief of the safety culture staff in NRR and a qualified Senior SCA. The qualification interview is used to evaluate how well the candidate can integrate and apply SCA competencies to field situations.

Upon completion of all requirements identified in the qualification journal, the qualification interview will confirm that the candidate has the necessary knowledge, skills, and abilities to independently conduct the prescribed NRC inspections. Review Attachment 1 for an understanding of the KSAs that you will be expected to demonstrate during the qualification interview. Individuals seeking certification as an SCA must successfully pass a qualification interview even if previously qualified as an IMC 1245 inspector.

Certification After successful completion of the qualification interview, the Branch Chief of the safety cCulture staff in NRR certifies the candidates as an SCA or Senior SCA, and documents certification on the qualification signature card. The Branch Chief of the safety culture staff in NRR will prepare the formal certificate for the qualifying SCA or Senior SCA to be signed by the appropriate Division Director in NRR. In addition, a copy of the SCA Signature Card and certificate should be forwarded to the Office of the Chief Human Capital Officer to document the certification in the individuals training file.

Interview Documentation Interview Documentation. The Interviewers recommendations are forwarded to the Division Director in DIRS/NRR for certification. Upon certification, the qualification will be recorded in iLearn by sending a request to TrainingSupport.Resource@nrc.gov.

Issue Date: 02/28/19 3 1245 Appendix C12

Safety Culture Assessor Training Courses Safety Culture in the ROP The purpose of the Safety Culture in the ROP training is to provide you with an overview, basic understanding, and familiarization with safety culture and the Reactor Oversight Process treatment of safety culture. This training includes an online learning resource that allows you to explore safety culture concepts at your own pace. Note that this training is also required as part of ISA-4, Safety Culture in IMC 1245, Appendix B. All candidates for qualification as an SCA or Senior SCA are required to review the online learning resource, regardless of whether they previously completed the training as part of their inspector qualification journal. The training videos can be accessed via iLearn, and the online learning resource can be accessed directly using the link below.

iLearn Training Course ID: 1055 Link to Online Learning Resource: http://papaya.nrc.gov/safetyculture/index.html Focus Group Facilitation The purpose of the Focus Group Facilitation training is to learn how to conduct focus groups to gather the desired information from participants while reducing potential biases in their responses. The recommended training is a 2-day external training course. Alternative training that meets the same objectives as the recommended training may be used as a substitute.

You should meet with your supervisor and the Branch Chief of the safety culture staff in NRR to discuss alternative options. Additional information about the recommended training, including course offerings, is provided in the link below.

Recommended Training (Focus Group Facilitation Foundations): http://www.gdiworld.com/

Resolving Conflict through Effective Communication (Senior SCA Only)

The purpose of the Resolving Conflict through Effective Communication training is to help you improve your conflict resolution and communication skills in preparation for leading safety culture inspection teams. This 2-day classroom course explores the nature of conflict and the role conflict plays in an organization.

iLearn Training Course ID: 166144 Motivating and Engaging Others (Senior SCA Only)

During this 1-day classroom course, you will explore practices you can use to enhance employee engagement and foster motivation. Through discussion and exercises you will learn new tools and techniques for increasing organizational performance by taking a more people-centric approach to leadership.

iLearn Training Course ID: 197146 Issue Date: 02/28/19 4 1245 Appendix C12

Building and Sustaining Teams (Senior SCA Only)

This highly experiential and interactive 2-day course will guide you through a series of exercises that will help you build high-performing teams and sustain team excellence over extended time periods. Through discussion and exercises you will discuss previous teaming experiences, engage in practices you can use to promote successful teaming experiences, and evaluate the strategies you currently use to help your team accomplish their objectives. You will gain insight into your own preferences around organizational issues and explore techniques for improving your skills as a team leader.

iLearn Training Course ID: 197145 Issue Date: 02/28/19 5 1245 Appendix C12

Safety Culture Assessor Individual Study Activities (ISAs)

TOPIC: ISA-1: Safety Culture in the Nuclear Industry PURPOSE: The purpose of this activity is to become familiar with the history of safety culture in the nuclear industry and the NRC approach to addressing safety culture through policies and oversight.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 16 Hours

REFERENCES:

1. January 24, 1989 Policy Statement, Conduct of Nuclear Power Plant Operations, Federal Register, volume 54, page 3424 https://www.nrc.gov/reading-rm/doc-collections/commission/policy/54fr3424.pdf
2. May 14, 1996 Policy Statement, Freedom of Employees in the Nuclear Industry to Raise Safety Concerns without Fear of Retaliation, Federal Register, volume 61, no. 94, page 24336 http://www.nrc.gov/about-nrc/regulatory/allegations/scwe-frn-5 96.pdf
3. June 14, 2011 Policy Statement, Final Safety Culture Policy Statement, Federal Register, volume 76, no. 114, page 34773 http://www.gpo.gov/fdsys/pkg/FR-2011-06-14/pdf/2011-14656.pdf
4. Davis-Besse Special Inspection Report 05000346/2004003, Management and Human Performance Corrective Action Effectiveness https://www.nrc.gov/reactors/operating/oversight/reports/davi_20040 03.pdf
5. Regulatory Issue Summary (RIS) 2006-13, "Information on the Changes Made to the Reactor Oversight Process to More Fully Address Safety Culture" https://www.nrc.gov/docs/ML0618/ML061880341.pdf
6. Institute of Nuclear Power Operations (INPO),12-012 Traits of a Healthy Nuclear Safety Culture, (ML13031A707) https://www.nrc.gov/docs/ml1303/ml13031a707.pdf
7. NUREG-2165, Safety Culture Common Language.

https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr2165/

8. Inspection Manual Chapter 0310, Aspects Within the Cross-Cutting Areas Issue Date: 02/28/19 6 1245 Appendix C12
9. International Nuclear Safety Advisory Group (INSAG)-4, Safety Culture http://www-pub.iaea.org/MTCD/publications/PDF/Pub882_web.pdf
10. INSAG-13, Management of Operational Safety in Nuclear Power Plants http://www-pub.iaea.org/MTCD/publications/PDF/P083_scr.pdf
11. INSAG-15, Key Practical Issues in Strengthening Safety Culture.

http://www-pub.iaea.org/MTCD/publications/PDF/Pub1137_scr.pdf EVALUATION CRITERIA: At the completion of this activity, you should be able to:

1. Understand the evolution in the approach the NRC has taken to address safety culture for nuclear power reactor licensees.
2. Understand how the NRC uses safety culture in the ROP framework.
3. Understand the international approach to addressing safety culture.
4. Understand the nuclear power industrys (i.e., INPOs) approach to addressing safety culture.

TASKS: Perform the following activities:

1. Review the documents listed in the reference section.
2. Review the NRC Safety Culture Webpage
3. Meet with either your supervisor or a designated qualified SCA or Senior SCA to discuss the items listed in the evaluation criteria.

ADDITIONAL READINGS/

REFERENCES:

The following documents are listed for additional information:

1. The Report of the B.P. U.S. Refineries Independent Safety Review Panel (concerning the B.P. Texas City Refinery Process Accident),

January 2007. http://www.csb.gov/assets/1/19/csbfinalreportbp.pdf

2. Center for Chemical Process Safety, Building Process Safety Culture: Tools to Enhance Process Safety Performance, 2005 http://www.aiche.org/CCPS/PSCulture.aspx Issue Date: 02/28/19 7 1245 Appendix C12

Safety Culture Assessor Individual Study Activities (ISAs)

TOPIC: ISA-2: Survey Overview PURPOSE: The purpose of this activity is to become familiar with survey methodology and how to evaluate the quality of surveys.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 6 Hours

REFERENCES:

1. American Association for Public Opinion Research, Best practices for Survey and Public Opinion Research:

http://www.aapor.org/Standards-Ethics/Best-Practices.aspx

2. Scheuren, F., What is a Survey http://www.whatisasurvey.info/
3. Constructing the Survey https://www.socialresearchmethods.net/kb/survwrit.php EVALUATION CRITERIA: At the completion of this activity, you should be able to:
1. Describe what a survey is.
2. Describe the strengths and limitations of surveys.
3. Explain the main steps in developing and administering a survey.
4. Understand what factors to consider in evaluating the quality of surveys.

TASKS: 1. Read the information provided in Best practices for Survey and Public Opinion Research and in Constructing the Survey

2. Read the following chapters from the What is a Survey? booklet:

Chapter 1, What is a Survey Chapter 2, How to Plan Survey Chapter 3, How to Collect Survey Data Chapter 4, Judging the Quality of a Survey Chapter 6, Designing a Questionnaire Chapter 7, How to Conduct Pretesting Chapter 10, What is a Margin of Error

3. Meet with either your supervisor or a designated qualified SCA or Senior SCA to discuss the items listed in the evaluation criteria.

Issue Date: 02/28/19 8 1245 Appendix C12

Safety Culture Assessor Individual Study Activities (ISAs)

TOPIC: ISA-3: Safety Culture Assessment Methods PURPOSE: The purpose of this activity is to become familiar with guidelines for conducting safety culture assessments and various assessment methods.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 18 Hours

REFERENCES:

1. NRC Inspection Procedure 95003.02, Guidance for Conducting an Independent NRC Safety Culture Assessment.
2. Interview Techniques for Assessing Safety Culture (ML071830168).

https://www.nrc.gov/docs/ML0718/ML071830168.pdf

3. NEI 09-07, Revision 1, Fostering a Healthy Nuclear Safety Culture.

https://www.nrc.gov/docs/ML1414/ML14143A085.pdf

4. IAEA Safety Culture Assessment Methods.

https://gnssn.iaea.org/NSNI/SC/TRWSSCA/Presentations/05a%20IA EA%20SCSA%20Assessment%20Methods.pdf

5. IAEA, Self-Assessment of Safety Culture in Nuclear Installations (IAEA-TECHDOC-1321). http://www-pub.iaea.org/MTCD/publications/PDF/te_1321_web.pdf EVALUATION CRITERIA: At the completion of this activity, you should be able to:
1. Understand common strategies used to assess safety culture.
2. Describe the different methods for collecting safety culture data during an IP 95003 inspection and their strengths and weaknesses.

TASKS: Perform the following activities:

1. Review the documents listed in the reference section.
2. Meet with either your supervisor or a designated qualified SCA or Senior SCA to discuss the items listed in the evaluation criteria.

ADDITIONAL READINGS/

REFERENCES:

The following documents are listed for additional information:

Issue Date: 02/28/19 9 1245 Appendix C12

1. IAEA, Safety Culture Assessment Review Team (SCART)

Guidelines http://www-pub.iaea.org/MTCD/publications/PDF/svs_016_web.pdf

2. Canadian Nuclear Safety Commission Discussion Paper DIS-12-07, Safety Culture for Nuclear Licensees.

http://www.nuclearsafety.gc.ca/eng/acts-and-regulations/consultation/history/dis-12-07.cfm

3. Rail Safety and Standards Board (RSSB) Safety Culture Toolkit.

http://www.safetyculturetoolkit.rssb.co.uk/home.aspx

4. Health and Safety Executive (HSE) Safety Culture Checklist.

http://www.hse.gov.uk/foi/internalops/fod/inspect/mast/safetychecklis t.htm

5. Safety Culture Assessment Tools in Nuclear and Non-Nuclear Domains (SCK-CEN-BLG-1085).

http://publications.sckcen.be/dspace/bitstream/10038/7763/1/blg_re port_1085.pdf Issue Date: 02/28/19 10 1245 Appendix C12

Safety Culture Assessor Individual Study Activities (ISAs)

TOPIC: ISA-4: Conducting IP 95003 Inspections PURPOSE: The purpose of this activity is to become familiar with prior IP 95003 inspections to gain appreciation for how the inspections were implemented and the inspection results.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 18 Hours

REFERENCES:

1. Palo Verde 95003 IR (ML080320562 and ML080320590)
2. Browns Ferry 95003 IR (ML13234A539)
3. Browns Ferry Confirmatory Action Letter (ML13232A105)
4. Arkansas Nuclear One 95003 IR (ML16161B279)
5. Arkansas Nuclear One Confirmatory Action Letter (ML16169A193)
6. Pilgrim Nuclear Power Station 95003 IR (ML17129A217)
7. Pilgrim Nuclear Power Station Confirmatory Action Letter (TBA)

EVALUATION CRITERIA: At the completion of this activity, you should be able to:

1. Understand how prior 95003 inspections have been implemented based on the site-specific issues.
2. Discuss what types of inspection and safety culture assessment issues have arisen for prior 95003 inspections.

TASKS: Perform the following activities:

1. Search the IP 95003 inspection reports listed in the references for the relevant sections on safety culture and review the information.

(Note: In the event further information is desired, contact the cognizant 95003 team leader.)

2. Meet with either your supervisor or a designated qualified SCA or Senior SCA to discuss the items listed in the evaluation criteria.

ADDITIONAL READINGS/

REFERENCES:

The following document is listed for additional information:

1. Browns Ferry Inspection Plan (ML13070A377)

Issue Date: 02/28/19 11 1245 Appendix C12

Safety Culture Assessor Individual Study Activities (ISAs)

TOPIC: ISA-5: Safety Conscious Work Environment (SCWE) Overview PURPOSE: The purpose of this activity is to learn the NRCs definition of SCWE and understand how the agency uses Chilling Effect Letters in response to SCWE issues at power reactors and vendor sites.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 24 Hours

REFERENCES:

1. 10 CFR 50.7, Employee Protection
2. May 14, 1996 Policy Statement, Freedom of Employees in the Nuclear Industry to Raise Safety Concerns without Fear of Retaliation, Federal Register, volume 61, no. 94, page 24336 http://www.nrc.gov/about-nrc/regulatory/allegations/scwe-frn-5 96.pdf
3. Regulatory Issue Summary (RIS) 2005-018, Guidance for Establishing and Maintaining a Safety Conscious Work Environment https://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2005/ri200518.pdf
4. NRC Allegation Manual https://www.nrc.gov/docs/ML1700/ML17003A227.pdf
5. IP 93100, Safety Conscious Work Environment Issue of Concern Follow-up
6. NRC Letter to Chicago Bridge & Iron, Chilled Work Environment for Raising and Addressing Safety Concerns, April 2013 (ML13092A077, ML13149A351, ML16166A262) https://www.nrc.gov/docs/ml1309/ml13092a077.pdf
7. NRC Letter to Wolf Creek Operating Corp, Work Environment Issues at Wolf Creek Generating Station - Chilling Effect, August, 2013 (ML13233A208, ML13267A161, ML15090A263, ML1508A560) https://www.nrc.gov/docs/ML1323/ML13233A208.pdf
8. NRC Letter to Watts Bar Unit 1, TVA, Chilled Work Environment for Raising and Addressing Safety Concerns at the Watts Bar Nuclear Plant, March 2016 (ML16083A479) https://www.nrc.gov/docs/ml1608/ml16083a479.pdf EVALUATION CRITERIA: At the completion of this activity, you should be able to:

Issue Date: 02/28/19 12 1245 Appendix C12

1. Describe a Safety Conscious Work Environment (SCWE) and how it relates to safety culture.
2. Understand the legal basis for the importance of SCWE based on employee protection regulations in 10 CFR 50.
3. Describe a chilled work environment and the criteria in the Allegations Manual for determining if there is evidence of a chilled work environment.
4. Describe the circumstances that would prompt the NRC to send a Chilling Effect Letter to a licensed or vendor facility.

TASKS: Perform the following activities:

1. Read 10 CFR 50.7, the 1996 Policy Statement on SCWE, and RIS 2005-018.
2. Review the guidance on SCWE and Chilling Effect Letters in the NRC Allegation Manual.
3. Review past chilling effect letters sent by the NRC to licensed and/or vendor facilities.
4. Review IP 93100, Safety Conscious Work Environment Issue of Concern Follow-up to understand how the NRC would perform a follow-up inspection to investigate SCWE.
5. Meet with the Agency Allegation Advisor to discuss the history of SCWE, indicators of a chilled work environment, and the NRCs use of Chilling Effect Letters.
6. Meet with either your supervisor or a designated qualified SCA or Senior SCA to discuss the items listed in the evaluation criteria.

Issue Date: 02/28/19 13 1245 Appendix C12

Safety Culture Assessor Individual Study Activities (ISAs)

TOPIC: ISA-6: Safety Culture Theory and Research (Senior SCA Only)

PURPOSE: The purpose of this activity is to become familiar with theories and research in safety culture and organizational culture.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 40 Hours

REFERENCES:

1. Schein, E.H., (1990). Organizational Culture. American Psychologist. (Contact a Senior SCA for access to this reference)
2. Guldenmund, F. W. (2000). The nature of safety culture: a review of theory and research. Safety Science, 34(1), 215-257.

https://www.nrc.gov/docs/ML1025/ML102500633.pdf

3. Branch, K. M., and Olson, J. L. (2011). Review of the Literature Pertinent to the Evaluation of Safety Culture Interventions.

http://www.nrc.gov/docs/ML1302/ML13023A054.pdf

4. John P. Kotter (1995), Leading Change: Why Transformation Efforts Fail. Harvard Business Review.

https://cb.hbsp.harvard.edu/resources/marketing/docs/95204f2.pdf

5. Carroll, J. S., and Hatakenaka, S. (2001). Driving Organizational Change in the Midst of Crisis. MIT Sloan Management Review.
6. Morrow, S., Koves, G., & Barnes, V. (2014). The relationship between safety culture and safety performance in U.S. nuclear power operations. Safety Science, 69, 37-47.

https://www.nrc.gov/docs/ML1422/ML14224A131.pdf

7. Sorensen, J. N. (2002). Safety culture: A survey of the state-of-the-art. Reliability Engineering and System Safety, 76, 189-204.

https://www.nrc.gov/docs/ML1024/ML102460761.pdf

8. Ghosh, S.T. and Apostolakis, G.E. (2005). Organizational Contributions to Nuclear Power Plant Safety. Nuclear Engineering and Technology. http://www.kns.org/jknsfile/v37/JK0370207.pdf EVALUATION CRITERIA: At the completion of this activity, you should be able to:
1. Describe Scheins three level model of organizational culture and how it relates to safety culture assessment strategies.
2. Understand past research on safety culture and organizational culture and how culture is theorized to relate to performance.

Issue Date: 02/28/19 14 1245 Appendix C12

3. Understand research related to changing safety culture and the characteristics of good and poor safety culture interventions.

TASKS: Perform the following activities:

1. Review the documents listed in the references.
2. Meet with either your supervisor or a designated qualified Senior SCA to discuss the items listed in the evaluation criteria section.

ADDITIONAL READINGS/

REFERENCES:

The following documents are listed for additional information:

1. Schein, E. H. (2010). Organizational Culture and Leadership, fourth ed. Jossey-Bass, San Francisco.
2. Reason, J. (1997). Managing the Risks of Organizational Accidents.

Ashgate.

3. Dekker, S. (2007). Just Culture: Balancing Safety and Accountability. Ashgate.
4. Perin, C. (2005). Shouldering Risks: The Culture of Control in the Nuclear Power Industry. Princeton University Press.
5. Wiegmann, D.A. et.al (2002). A Synthesis of Safety Culture and Safety Climate Research. Technical Report ARL-02-3/FAA-02-2.

https://www.nrc.gov/docs/ML1025/ML102500649.pdf Issue Date: 02/28/19 15 1245 Appendix C12

Safety Culture Assessor On-the-Job Training (OJT)

TOPIC: OJT-1: Safety Culture Inspection Activity PURPOSE: The purpose of this activity is to familiarize you with safety culture-related inspection tasks. This OJT will prepare you to independently conduct safety culture-related inspection activities.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 40 - 80 Hours

REFERENCES:

1. IP 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input"
2. IP 95002, Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area
3. IP 71152, "Identification and Resolution of Problems"
4. IP 40100, Independent Safety Culture Assessment Follow-up
5. IP 93100, Safety Conscious Work Environment Issue of Concern Follow-up EVALUATION CRITERIA: At the completion of this activity, you should be able to:
1. Describe the safety culture related inspection and assessment activities performed.
2. Demonstrate safety culture assessment skills.

TASKS: Perform the following activities:

1. Participate as a note-taker for safety culture focus groups and/or interviews, and facilitate at least one safety culture or SCWE focus group or interview during an inspection that has a specific focus on safety culture activities. For example, an IP 95003 or IP 95002 inspection, IP 93100, IP 40100, the SCWE portions of IP 71152, a SCWE-related inspection at a vendor facility, or other follow-up inspection activities related to a confirmatory order or confirmatory action letter that have a specific focus on safety culture.
2. Meet with either your supervisor or a designated qualified SCA or Senior SCA to discuss the items listed in the evaluation criteria.

Issue Date: 02/28/19 16 1245 Appendix C12

Safety Culture Assessor On-the-Job Training (OJT)

TOPIC: OJT-2: Review Safety Culture Assessments PURPOSE: The purpose of this activity is to familiarize you with reviewing and understanding licensee third-party and independent safety culture assessments.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 24 Hours

REFERENCES:

1. NRC Inspection Procedure 95003.02, Guidance for Conducting an Independent NRC Safety Culture Assessment.
2. IP 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input"
3. Nuclear Fuel Services Nuclear Safety Culture Assessment, June 2013. https://www.nrc.gov/docs/ML1326/ML13263A009.pdf
4. Prairie Island Nuclear Generating Plant Nuclear Safety Culture Assessment, August 2008.

https://www.nrc.gov/docs/ML1024/ML102460761.pdf

5. Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan for the Davis-Besse Nuclear Power Station, August 2005.

https://www.nrc.gov/docs/ML1024/ML102460761.pdf

6. Independent Assessment of the Davis-Besse Nuclear Power Station Nuclear Safety Culture and Safety Conscious Work Environment, December 2008.

https://www.nrc.gov/docs/ML0902/ML090270490.pdf EVALUATION CRITERIA: At the completion of this activity, you should be able to:

1. Understand the inspection requirements in IP 95003 for evaluating a third party safety culture assessment.
2. Understand the information commonly included in safety culture assessments.
3. Describe the information needed during a safety culture inspection to evaluate a safety culture assessment.
4. Describe good and poor examples of safety culture assessment techniques.

Issue Date: 02/28/19 17 1245 Appendix C12

TASKS: Perform the following activities:

1. Obtain copies of safety culture assessments performed at a licensed or vendor facilities (examples of publicly available assessments are included in the references, contact a Senior SCA for assistance in obtaining access to other assessments).
2. Review the safety culture assessments using the inspection requirements and specific guidance for evaluating the licensees third party safety culture assessment in IP 95003, and Guidance for Evaluating Safety Culture Surveys in IP 95003.02.
3. Meet with either your supervisor or a designated qualified SCA or Senior SCA to discuss the items listed in the evaluation criteria section.

Issue Date: 02/28/19 18 1245 Appendix C12

Safety Culture Assessor On-the-Job Training (OJT)

TOPIC: OJT-3: Shadow an Inspection Team Lead (Senior SCA Only)

PURPOSE: The purpose of this activity is to familiarize you with leading a safety culture assessment functional team.

COMPETENCY AREA: Safety Culture Assessment LEVEL OF EFFORT: 120 Hours

REFERENCES:

1. IP 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input" EVALUATION CRITERIA: At the completion of this activity, you should be able to:
1. Describe effective techniques to direct the conduct of safety culture assessment activities. Describe any situations observed during the inspection where alternative approaches could have been employed to achieve a more desirable outcome.
2. Describe techniques employed to achieve open and effective communications with the team leader, the assistant team leaders, other inspection team members, regional management, and senior plant management.
3. Describe approaches for dealing with unforeseen issues during the inspection and lessons learned.

TASKS: Perform the following activities:

1. Participate on an IP 95002 or IP 95003 inspection (or a combination of other safety culture assessments, SCWE allegation follow-up, etc. using IP 93100 or IP 40100) and shadow the safety culture team leader during the on-site inspection phase. Alternatively, if you are a qualified inspector, you may lead an IP71152 biennial inspection, specifically the SCWE portion. Please discuss other options for fulfilling this task with the Branch Chief of the safety culture staff in NRR.
2. Meet with either your supervisor or a designated qualified Senior SCA to discuss the items listed in the evaluation criteria section.

Issue Date: 02/28/19 19 1245 Appendix C12

Signature Card for Safety Culture Assessor Qualification Employee Supervisor/Subject Initials/Date Matter Expert Employee Name: _______________________________ Signature/Date A. Basic and General Proficiency Inspector Qualification Note: Qualified reactor inspectors should indicate the date of completing all training requirements in IMC 1245 Appendix A and B and skip to Section E.

Candidates who have not previously completed their qualifications in IMC 1245 Appendix A and Appendix B must complete Sections B-D below.

B. Training Courses from IMC 1245, Appendix A and B

1. H-100 Site Access Training
2. R-100 Reactor Concepts
3. G-105 Conducting Inspections
4. Effective Communication for NRC Inspectors
5. Gathering Information for Inspectors through Interviews
6. G-205 Root Cause and Incident Investigation Workshop
7. Ethics Training (web-based)
8. R-104B GE BWR Systems Overview OR R-104P Westinghouse Systems Overview C. Inspection Individual Study Activities (ISAs) from IMC 1245, Appendix A (ISA-3) Inspector Objectivity, Protocol, and Professional Conduct (ISA-4) Fitness for Duty Rule (ISA-5) Allegations Issue Date: 02/28/19 20 1245 Appendix C12

(ISA-6) NRCs Response to an Emergency at a Nuclear Facility (ISA-16) Contacts with the Media (ISA-18) Freedom of Information Act and the Privacy Act (ISA-20) Documenting Inspection Findings (ISA-21) Open Collaborative Working Environment & Ways to Raise Differing Views (ISA-22) Overview of 10 CFR Part 50 (ISA-23) Overview of Parts 19 and 20 Note: Complete the following elements of the ISAs in IMC 1245, Appendix A (ISA-9) Exploring the Operator Reactor Inspection Program: Tasks 1, 2, 4, and 7.

Complete evaluation criteria 1, 2, 3, 4, 5, and 9.

(ISA-15) Interaction with the Public: Tasks 1, 2, 3, 6, and 7, including review of applicable information regarding interacting with the public.

Complete evaluation criteria 1, 2, 3, 7, 8 and 9.

(ISA-19) Entrance and Exit Meetings: Tasks 1 and 4.

Complete evaluation criteria 1 and 2.

(ISA-24) Licensee Specific Regulatory Documents and Procedures: All tasks.

Complete evaluation criteria 6.

(ISA-26) Exploring the Operating Reactor Assessment Program: Task 2.

Complete evaluation criteria 4 and 5.

D. Inspection ISAs from IMC 1245, Appendix B (ISA-4) Safety Culture Issue Date: 02/28/19 21 1245 Appendix C12

E. Safety Culture Assessor Qualification Activities

1. Safety Culture ROP Training (web-based)
2. Focus Group Facilitation Training (ISA-1): Safety Culture in the Nuclear Industry (ISA-2): Survey Overview (ISA-3): Safety Culture Assessment Methods (ISA-4): Conducting IP 95003 Inspections (ISA-5): Safety Conscious Work Environment (SCWE) Overview (OJT-1): Safety Culture Inspection Activity (OJT-2): Review Safety Culture Assessments
  • Supervisors Signature: ______________________________ Date: _____________
  • Supervisors signature indicates successful completion of all required courses and activities listed in this journal and readiness for the qualification interview. Supervisor may delegate this authority to a qualified Senior SCA in NRR or the Regional Office, or to the Branch Chief of the Safety Culture staff in NRR.

The appropriate Form 1, Safety Culture Assessor Equivalency Justification, if applicable, must accompany this signature card and certification.

Copies: Assessor, Office of the Chief Human Capital Officer, Supervisor Issue Date: 02/28/19 22 1245 Appendix C12

Signature Card for Senior Safety Culture Assessor Qualification Employee Supervisor/Subject Initials/Date Matter Expert Employee Name: _______________________________ Signature/Date A. Safety Culture Assessor Qualification Note: Indicate the date when safety culture assessor qualification was completed. Attach safety culture assessor qualification card or equivalency justification.

B. Inspection Experience as SCA Note: Indicate the date of completion of an inspection as a qualified SCA.

Inspection team lead or Senior SCA should provide signature.

C. Training Courses

1. Resolving Conflict Through Effective Communication (166144)
2. Motivating and Engaging Others (197146)
3. Building and Sustaining Teams (197145)

D. Senior Safety Culture Assessor ISAs and OJTs (ISA-6): Safety Culture Theory and Research (OJT-3): Shadow an Inspection Team Lead

  • Supervisors Signature: ______________________________ Date: _____________
  • Supervisors signature indicates successful completion of all required courses and activities listed in this journal and readiness for the qualification interview. Supervisor may delegate this authority to a qualified Senior SCA in NRR or the Regional Office, or to the Branch Chief of the Safety Culture staff in NRR.

The appropriate Form 1, Safety Culture Assessor Equivalency Justification, if applicable, must accompany this signature card and certification.

Copies: Assessor, Office of the Chief Human Capital Officer, Supervisor Issue Date: 02/28/19 23 1245 Appendix C12

Safety Culture Assessor Certification Has successfully completed all of the requirements to become a Safety Culture Assessor Safety Culture Assessor Senior Safety Culture Assessor Branch Chief, Safety Culture staff/NRR Signature: ________________________

Date:____________

Division Director Signature:______________________ Date:____________

Issue Date: 02/28/19 24 1245 Appendix C12

Form 1: Safety Culture Assessor Equivalency Justification Office/Region/Division Branch:______________________

Employee Name: _______________________________

Position: ______________________________________

Supervisor: ____________________________________

Training Journal Requirement(s) to be Waived:

Justification for Waiving Requirement(s) (identify equivalent training and/or experience for which the employee is to be given credit):

Qualifying individuals should discuss the basis for equivalency justification with a qualified SCA before bringing this to supervisor for approval.

Branch Chiefs Recommendation Signature/Date:

Division Directors Approval Signature/Date:

Copies to:

Employee Employee Branch Training File Human Resources Branch Chief for the Safety Culture staff, NRR Issue Date: 02/28/19 25 1245 Appendix C12

Attachment 1 Safety Culture Assessor Competencies and KSAs

1. Understand the legal basis for and the regulatory processes used to achieve the NRCs regulatory objectives:
a. Knowledge of the basis for the authority of the agency (regulatory framework)
b. Knowledge of the processes established to achieve the regulatory objectives (regulatory framework)
c. Knowledge of the NRCs Reactor Oversight Process and applicable inspection requirements (inspection)
d. Knowledge of the NRCs policies regarding safety culture and how safety culture is integrated into oversight activities (safety culture assessment)
2. Master the techniques and skills needed to collect, analyze, and integrate information using a safety culture focus to develop a supportable regulatory conclusion:
a. Ability to independently gather information through objective review, observation, and open communications (inspection)
b. Skill in determining acceptability of information by comparing to established criteria (inspection)
c. Ability to approach problems objectively, gather and integrate information, and develop a comprehensive understanding before reaching a conclusion (problem analysis)
d. Skill in analyzing and integrating information using a safety culture focus to identify the appropriate regulatory conclusion and regulatory response (safety culture assessment)
3. Demonstrate the personal and interpersonal skills needed to carry out assigned regulatory activities, either individually or as part of a team:
a. Ability to clearly express ideas or thoughts, carefully listen, and speak and write with appropriate safety focus and context (communication)
b. Ability to work collaboratively with others toward common objectives (teamwork)
c. Ability to work independently, exercise judgment, and exhibit flexibility in the completion of activities that include difficult or challenging situations (self-management)
4. Understand and effectively implement appropriate methods for gathering information about safety culture:
a. Knowledge of various sources of information that can be used to provide insights about safety culture
b. Knowledge of appropriate methods for gathering safety culture data and their strengths and weaknesses, including:
i. Individual and group interviews ii. Structured and unstructured interviews iii. Questionnaires and surveys iv. Behavioral observations and checklists Issue Date: 02/28/19 Att1-1 1245 Appendix C12
c. Ability to implement the different methods correctly, including, but not limited to:
i. Conducting focus groups and interviews in a manner that elicits the desired information while reducing potential biases in the responses ii. Conducting reliable (i.e., repeatable) structured behavioral observations iii. Conducting content analysis of written documentation and verbal communications
d. Ability to integrate results from applying the different methods to arrive at defensible conclusions
5. (Senior SCAs) Effectively apply theories and research in organizational and human behavior to plan safety culture assessments and evaluate the validity of assessments:
a. Knowledge of theories and research in organizational and human behavior
b. Ability to determine the applicability and likely usefulness of various data-gathering methods under different circumstances
c. Knowledge of the requirements for developing, administering, and analyzing the results of surveys and questionnaires, including:
i. The strengths and weaknesses of different item types (Likert, BARS, forced-choice, etc.)

ii. The requirements for administering a survey to reduce potential biases in the responses iii. Behavioral statistics and the appropriate methods, and their constraints, for analyzing survey data iv. Statistical requirements for the different types of validity and reliability, and appropriate techniques to assess/measure/establish them

d. Knowledge of the rationale for a multiple-measures approach to assessment and the limitations of a single-method assessment
e. Knowledge of statistical and conceptual constraints on determining appropriate sample sizes for different types of data collection methods, and the biases introduced by different sample selection strategies
6. (Senior SCAs) Effectively lead individuals in the performance of safety culture activities:
a. Ability to direct and supervise individuals in performing the safety culture assessment activities
b. Ability to coordinate and communicate effectively with the inspection Team Leader(s), other members of the inspection team, Regional management, and plant senior management
c. Ability to effectively articulate and respond to any questions or challenges from internal and external stakeholders on the safety culture assessment and findings Issue Date: 02/28/19 Att1-2 1245 Appendix C12

Attachment 2 Improving KSAs for Senior Safety Culture Assessor Qualification If an individual does not meet the education and experience requirements to qualify as a Senior SCA, he/she should take additional training or gain relevant experience to develop the KSAs required of a Senior SCA, as described in Attachment 1. In addition to the activities included in the training and qualification journal, advanced training is recommended in focus group facilitation, interviewing techniques, statistics and research methods in the behavioral sciences, and the theories and principles of organizational culture. This can be achieved through formal training and/or by gaining experience in conducting the types of tasks required by IP 95003 for safety culture assessments in similar environments. In addition, the individual should gain experience in leading activities that are of similar scope or significance as IP 95003 safety culture activities.

The individual is also strongly encouraged to take additional courses related to the topics listed below. Although not required, such courses provide additional coverage of the KSAs needed to perform safety culture assessment activities.

Organizational psychology Human factors or human performance Behavioral science Organizational research methods Psychometrics Statistics in social or behavioral science applications Survey administration and research Organizational culture or safety culture Recommended External Training Courses Seminars though ProAct Safety, Inc.:

http://www.proactsafety.com/

National Training Lab Institute: Diagnosing organizations with impact course:

http://www.ntl.org/?page=dowi Center for Chemical Process Safety: Building process safety culture: tools to enhance process safety performance (see case studies for self-study):

http://www.aiche.org/CCPS/PSCulture.aspx National Safety Council: Building a work class safety culture course:

http://www.scnsc.org/#!creating-a-world-class-safety-culture/cg4b George Mason University Department of Psychology courses:

http://www.gmu.edu/catalog/courses/psyc.html Ashford University Online:

http://www.ashford.edu/degrees/online/ba-applied-behavioral-science-courses.htm#IntroductoryCourses o Introduction to Applied Behavioral Sciences (ABS 200) o Statistics for the Behavioral Sciences (PSY 325) o Research Methods in Psychology (PSY 326)

Issue Date: 02/28/19 Att2-1 1245 Appendix C12

University of Maryland Department of Psychology courses:

http://psychology.umd.edu/

Johns Hopkins University Department of Psychology courses:

http://www.psy.jhu.edu/

Catholic University Department of Psychology courses:

http://psychology.cua.edu/

University of Michigan Human Factors Short Course (1-2 weeks) http://www.umich.edu/~driving/shortcourse Any questions related to qualification as a Senior SCA should be directed to a qualified Senior SCA or to the Branch Chief of the Safety Culture staff in NRR.

END Issue Date: 02/28/19 Att2-2 1245 Appendix C12

Attachment 3 Revision History for IMC 1245 Appendix C-12, Safety Culture Assessor Training and Qualification Journal Commitment Accession Description of Change Description of Comment Resolution and Tracking Number Training Required Closed Feedback Form Number Issue Date and Completion Accession Number Change Notice Date (Pre-Decisional, Non-Public Information)

N/A ML11102A124 This is a new document issued for training N/A ML11102A124 10/13/11 and qualifications for safety culture CN 11-020 assessors.

N/A ML12166A543 Updated to add in specific ISAs and OJTs N/A ML12166A508 09/26/12 CN 12-022 N/A ML14084A152 Updated to change Human Factors Branch N/A FBF 1245C12-1889 04/03/14 Chief information and to add in new ML13275A321 CN 14-009 documents related to the Safety Culture FBF 1245C12-1890 Common Language ML13275A330 FBF 1245C12-1891 ML13275A355 N/A ML15114A460 Editorial changes. Resolution of N/A ML1512A195 07/01/15 comments from internal NRC and Regional FBF 1245C12-2010 CN 15-013 Offices. Closure of feedback form ML15182A106 1245C12-2010 NA Ml16020a397 Addition of new Safety Culture Training link NA NA 02/01/16 CN 16-004 N/A ML16259A016 Addition of 2 training courses which were N/A ML16259A018 11/09/16 agreed upon by the IMC 1245 working CN 16-029 group, as well as editorial changes N/A ML17090A254 Added in 2 new ISAs and changed the N/A ML17093A068 05/24/17 OJTs to reflect inspection experience with CN 17-011 safety culture and SCWE. Also made major editorial and administrative changes Issue Date: 02/28/19 Att3-1 1245 Appendix C12

Commitment Accession Description of Change Description of Comment Resolution and Tracking Number Training Required Closed Feedback Form Number Issue Date and Completion Accession Number Change Notice Date (Pre-Decisional, Non-Public Information)

N/A ML18232A402 Divided the qualification card table into 2 N/A N/A 08/23/18 separate tables: one for Safety Culture CN 18-029 Assessors and one for Senior Safety Culture Assessors. Also added in a requirement to serve as an SCA on an inspection team PRIOR to qualifying as a Senior SCA.

N/A ML19050A020 Replaced obsolete iLearn training courses N/A N/A 02/28/19 with current ones.

CN 19-009 Issue Date: 02/28/19 Att3-2 1245 Appendix C12

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