ML23200A341

National Organization of Test, Research, and Training Reactors 2023 Annual Conference Presentation by Carleen Parker on NRC Oversight of Safety Culture

ML23200A341
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Issue date:	06/20/2023
From:	Carleen Parker NRC/OE
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Download: ML23200A341 (1)

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The Nuclear Regulatory Commissions Oversight of Safety Culture Carleen Parker, Allegation Coordinator Headquarters Allegations Team Office of Enforcement U.S. Nuclear Regulatory Commission 1

Outline

• NRCs definition of nuclear safety culture

• NRCs approach to safety culture

- Oversight process

- Event, allegation, or degradation in performance

- Chilling effect letters

• Safety culture concern follow-up 2

NRC Safety Culture History

• Operators inattentive and unprofessional while 1989 on duty at nuclear power plant

• Commission Policy Statement: Conduct of Nuclear Power Plant Operations

• Workers retaliated against for whistleblowing 1996

• Commission Policy Statement: Freedom to Raise Safety Concerns Without Fear of Retaliation 2002

• Davis-Besse reactor head degradation event

• NRC revised Reactor Oversight Process (ROP) to more fully address safety culture 2008

• Commission direction to develop policy statement on safety culture that applies to all licensees 2011

• Final Safety Culture Policy Statement (SCPS) published in the Federal Register 3

Safety Culture Policy Statement (SCPS)

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.

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Nuclear 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 Commissions Safety Culture Policy Statement (76 FR 34773; June 14, 2011) 5

Safety Culture Traits Leadership Safety Values Problem Identification and Resolution Personal Accountability and Actions Issues potentially impacting safety are Leaders demonstrate a commitment to promptly identified, fully evaluated, and All individuals take personal responsibility for safety in their decisions and behaviors promptly addressed and corrected safety commensurate with their significance Work Processes Continuous Learning Environment for Raising Concerns A safety conscious work environment is The process of planning and controlling work Opportunities to learn about ways to ensure maintained where personnel feel free to raise activities is implemented so that safety is safety are sought out and implemented safety concerns without fear of retaliation, maintained intimidation, harassment or discrimination Effective Safety Communications Respectful Work Environment Questioning Attitude Individuals avoid complacency and continually challenge existing conditions and Communications maintain a focus on safety Trust and respect permeate the organization activities in order to identify discrepancies that might result in error or inappropriate action 6

Safety Culture Common Language Initiative

• A common language for safety culture was developed in 2013

- includes 10 traits of a healthy safety culture, 40 attributes (performance characteristics) representing those traits, and numerous examples

• NUREG-2165 was completed in 2014 7

NRC Approach to Safety Culture

• Licensees bear primary responsibility for safety

• NRCs Safety Culture Policy Statement states safety culture expectations but is not a regulatory requirement

• NRC considers safety culture within oversight processes for research and test reactors

• NRC assessment of safety culture is primarily a result of an event, allegation, or degradation in performance 8

Event Follow-up

• Inspectors will review the licensees root cause evaluation to ensure that all safety culture contributors are identified and documented

• If the licensee is issued escalated enforcement and participates in the Alternative Dispute Resolution process, corrective actions associated with safety culture may be included

• All agreed upon corrective actions would be included in a Confirmatory Order and would be inspected 9

Allegations Follow-up

• If NRC receives allegations at your site stating that employees are hesitant to raise nuclear safety concerns (SCWE), the NRC will follow up

• The NRC may send a Request for Information (RFI) or conduct a follow up inspection

• The RFI may request the licensee employ a third party to evaluate the SCWE concern

• Inspection- qualified safety culture assessors will inspect the SCWE at your site 10

Safety Conscious Work Environment (SCWE) Issues

• If SCWE concerns are substantiated by the licensee or by the NRC, the licensee will be expected to take adequate corrective actions

• The NRC will monitor the SCWE at the licensee

• If the SCWE is not corrected, the NRC may send the licensee a Chilling Effect Letter 11

Chilling Effect Letters (CEL)

• A Chilling Effect Letter:

- Publicly notifies licensee of NRCs concern that employees are hesitant to raise nuclear safety concerns

- Informs workforce of concern

- Formally requests information and a response including corrective actions 12

Safety Culture Policy Statement Educational Tools

• Safety Culture Educational Resource Workbook

• Trait Talks

• Case Studies

• SCPS 13

Trait Talk and Licensee or Community Scenario

• TTRAIT LICENSEE OR COMMUNITY SCENARIO TRAIT LICENSEE/COMMUNITY SCENARIO

• Leadership Safety Values and Actions Power Reactors

• Work Processes Radiography

• Questioning Attitude Medical/Brachytherapy

• Problem Identification and Resolution Power Reactors

• Environment for Raising Concerns Research Reactors

• Effective Safety Communication Fuel Cycles

• Respectful Work Environment Gauges

• Continuous Learning Construction

• Personal Accountability Vendors 14

Summary

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

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

• NRC may also address safety-conscious work environment concerns through Chilling Effect Letters

• Licensees can learn more about maintaining a healthy safety culture using NRCs educational tools 15

For More Information

• Please visit NRCs safety culture webpage at:

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

• Or contact NRC staff via email at: NRC.Allegation@nrc.gov 16