ML24157A055
| ML24157A055 | |
| Person / Time | |
|---|---|
| Issue date: | 06/05/2024 |
| From: | Carleen Parker NRC/OE |
| To: | |
| References | |
| Download: ML24157A055 (18) | |
Text
1 The Nuclear Regulatory Commissions Oversight of Safety Culture Carleen Parker, Allegation Coordinator Headquarters Allegations Team Office of Enforcement U.S. Nuclear Regulatory Commission
2 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
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 (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.
5 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)
6 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 (SCWE) 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.
7 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
8 NRC Approach to Safety Culture
- Vendors and 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 vendors and licensees.
- NRC assessment of safety culture at vendors is primarily as a result of an event, allegation, or degradation in performance.
- NRC considers safety culture within the Reactor Oversight Process (ROP) for nuclear power reactors.
9 NRC Reactor Oversight Process (ROP)
- NRCs Performance Assessment Program for operating nuclear power reactors
- Inputs derived from licensee performance indicators and NRC inspection findings
- Licensee performance evaluated continuously
- Including mid-year and end-of-year assessment meetings
- NRC assigns each licensee to a column in the ROP Action Matrix based on performance
- Action Matrix placement determines level of NRC regulatory oversight
10 Safety Culture and the ROP
11 Event Follow-up
- Inspectors will review the vendor and licensees root cause evaluation to ensure that all safety culture contributors are identified and documented.
- If the vendor or licensee is issued escalated enforcement, they will be issued a choice letter.
- Alternative Dispute Resolution (ADR)
- 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.
12 Allegation 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 on the issue.
- The NRC may send a Request for Information (RFI) or conduct a follow-up inspection.
- An inspection will assure qualified safety culture assessors will inspect the SCWE at your site.
13 Safety-Conscious Work Environment (SCWE) Issues
- If SCWE concerns are substantiated by the licensee, the vendor or by the NRC, the licensee or vendor will be expected to take adequate corrective actions.
- The NRC will monitor the SCWE at the licensee or vendor.
- If the SCWE is not corrected, the NRC may send the licensee or vendor a Chilling Effect Letter.
14 Chilling Effect Letters (CEL)
- A Chilling Effect Letter:
- Publicly notifies the vendor or licensee of NRCs concern that employees are hesitant to raise nuclear safety concerns.
- Informs the workforce of the concern.
- Formally requests information and a response, including corrective actions.
15 Safety Culture Policy Statement (SCPS)
Educational Tools
- Safety Culture Educational Resource Workbook
- Trait Talks
- Case Studies
- SCPS
16 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
17 Summary
- NRC communicates safety culture expectations through the Safety Culture Policy Statement.
- NRC assessment of safety culture at a vendor is primarily as a result of an event, allegation, or degradation in performance.
- Safety culture considerations incorporated in the Reactor Oversight Process through cross-cutting areas and supplemental inspection activities.
- NRC may also address safety-conscious work environment concerns through Chilling Effect Letters.
- You can learn more about maintaining a healthy safety culture using NRCs educational tools.
18 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