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NEI Safety Culture Presentation for May 2023 ROP Public Meeting
	ML23136A591
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/18/2023
From:	Riti T; Nuclear Energy Institute
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML23136A591 (1)
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Follow-up Discussion on Safety Culture ROP Public Meeting May 18, 2023

Purpose Discuss comments on the NRC Safety Culture Program Effectiveness Review Report1 1 NRC Memorandum - Results of the Safety Culture Program Effectiveness Review, March 20, 2023, ADAMS Accession No. ML22340A452.

Overview As discussed at the April ROP public meeting, we are concerned with the basis and potential impact of the recommendations A letter from NEI was provided to the NRC Director, Division of Reactor Oversight on May 9, 2023, providing detailed comments

Comments There is no acknowledgement in the report of the many means used by the industry to foster and maintain a healthy nuclear safety culture For example,

Safety culture assessments

Performance trending

Corrective action program (CAP) reviews

Root cause evaluations

Senior leadership reviews

Independent external oversight Institute of Nuclear Power Operations (INPO) plays a key role in driving performance excellence including examining nuclear safety culture through peer reviews and performance continuum activities

Comments Recommendations 1 and 3 represent significant impactful changes in safety culture inspection and oversight

Recommendation 1 Inconsistent with graduated regulatory oversight via the supplemental inspection program imposing Column 3 response on Column 2 plants Implies that changes made from SECY-15-0108 did not consider impact on safety culture oversight Introduces additional subjectivity & unpredictability to the ROP

Recommendation 3 Inconsistent with graduated regulatory oversight by significantly expanding NRC inspection and assessment of safety culture for Column 1 plants Contrary to the acknowledgement in the report of cross-cutting issue program effectiveness to identify potential safety culture weaknesses Inconsistent with SECY-04-0111 that recognized the subjective nature of safety culture direct inspection that may detract from the goals of an objective, risk informed, and predictable ROP

Other Recommendations Recommendation 2 Improve training available to inspectors to better meet Commission objectives stated in SRM-SECY-04-0111 Enhanced or additional training, if applied using a systematic approach, is an effective tool to increase knowledge and skills and to help maintain proficiency and should be considered if knowledge gaps exist or there is a recognized benefit to help inspectors meet NRC objectives

Other Recommendations Alternative Recommendation Revise existing assessment guidance to prompt NRC management discussions to encourage licensee action to address safety culture aspects before significant performance degradation occurs Appears to be more aligned with a graded approach to oversight and the principles of good regulation but was only briefly described in the report limiting our feedback

Summary We are concerned with the basis and potential impact of the recommendations from the NRC report Recommendations 1 & 3 represent significant impactful changes to safety culture inspection and oversight that are unwarranted More detailed comments can be found in the NEI letter

ML23136A591

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