ML22045A867

Safety Culture Effectiveness Review Final Approved Charter

ML22045A867
Person / Time
Issue date:	12/21/2021
From:	Office of Nuclear Reactor Regulation
To:
References
Download: ML22045A867 (4)

Text

First Safety Culture Program Effectiveness Review Team Charter I.

Background

The NRC has long recognized the importance of a strong nuclear safety culture. In 1989, in response to an incident at the Peach Bottom Atomic Power Station, the NRC issued Policy Statement on the Conduct of Nuclear Power Plant Operations. This policy statement describes the NRCs expectation that licensees place appropriate emphasis on safety in the operation of nuclear power plants, including personal dedication and accountability of all individuals engaged in any activity that has a bearing on the safety of nuclear power plants. Additionally, the policy statement underscores managements responsibility for fostering the development of a healthy safety culture at each facility and for providing a professional working environment in the control roomand throughout the facilityto ensure safe operations.

In 1996, following an incident at the Millstone Power Station in which workers were retaliated against for whistleblowing, the Commission issued Freedom of Employees in the Nuclear Industry to Raise Safety Concerns without Fear of Retaliation. This policy statement describes the NRCs expectation that all NRC licensees establish a safety conscious work environment (SCWE) in which workers feel free to raise nuclear safety concerns without fear of harassment, intimidation, retaliation, or discrimination. A SCWE is an important attribute of a strong nuclear safety culture.

In 2002, investigations into the discovery of degradation of the reactor pressure vessel head at Davis-Besse Nuclear Power Station revealed that safety culture weaknesses were the root cause of the event. The NRC made significant changes to the Reactor Oversight Process (ROP) to strengthen the agencys ability to effectively monitor licensee performance and detect potential safety culture weaknesses during inspections and performance assessments.

Regulatory Issue Summary 2006-13, Information on the Changes Made to the Reactor Oversight Process to More Fully Address Safety Culture, dated July 31, 2006, provides information to reactor licensees on the revised ROP. Most notably, the NRC revised the existing cross-cutting areas of human performance, problem identification and resolution, and SCWE to incorporate aspects that are important to safety culture. The intent of the revisions to the ROP was threefold:

1. Provide better opportunities for the NRC staff to consider safety culture weaknesses and to encourage licensees to take appropriate actions before significant performance degradation occurs.

2. Provide the NRC staff with a process to determine the need to specifically evaluate a licensees safety culture after performance problems have placed the licensee in the Degraded Cornerstone column of the Action Matrix.

3. Provide the NRC staff with a structured process to evaluate the licensees safety culture assessment and to independently conduct a safety culture assessment for a licensee in the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix.

In 2008, the NRC developed several additional changes to the guidance on oversight of safety culture in the ROP as a result of lessons learned from a supplemental inspection conducted at the Palo Verde Nuclear Generating Station.

The NRCs final Safety Culture Policy Statement (SCPS) was published on June 14, 2011. The SCPS provides the NRCs expectation that individuals and organizations performing regulated activities establish and maintain a healthy safety culture that recognizes the safety and security

2 significance of their activities and the nature and complexity of their organizations and functions.

Because safety and security are the primary pillars of the NRCs regulatory mission, consideration of both safety and security issues, commensurate with their significance, is an underlying principle of the SCPS. The NRC has not conducted an effectiveness review on these changes.

II. Purpose The purpose of this effectiveness review is to evaluate how safety culture is currently incorporated into the ROP and determine whether this is achieving its objective of sufficiently detecting safety culture issues, providing confidence that a licensees safety culture is healthy, and to provide recommendations on any necessary program changes. This review will include:

Understanding how safety culture is currently incorporated in the baseline and supplement inspection procedures and manual chapters and identification of any gaps.

Determining what training is currently provided to inspectors in the area of safety culture and identifying any gaps.

Determining what licensee information is currently available to the inspection staff to determine the health of safety culture at each site.

In 2021, the NRC received fifty-four allegations referring to chilled work environment or other SCWE/safety culture issues. Of those fifty-four, the agency inspected fourteen and substantiated nine. This data indicates that there continue to be concerns with SCWE/safety culture issues at our licensed facilities. This review may enable the staff to develop more comprehensive tools to identify these issues sooner.

III. Tasking A. Review ROP documents describing the Safety Culture program to ensure a clear understanding of the basis for the program and how it is implemented.

IMC 0305 IMC 0310 IMC 0612 IP 40100 IP 71152 IP 71153 IP 93100 IP 93800 IP 93812 IP 95001 IP 95002 IP 95003 and 95003.02 B. Review documentation including inspection reports and lessons learned reports from plants with longstanding performance issues, including those assessed in Column 4 of the Action Matrix including:

Pilgrim 95003 inspection report (ML17129A217)

ANO 95003 inspection report (ML16161B279)

Watts Bar SCWE inspection Reports and Confirmatory Orders

3 (ML16083A479, ML18229A153, ML18073A202, ML18242A458, ML17069A133, ML17208A647, ML19357A240, ML20218A483, ML20310A353, and ML21048A200)

Grand Gulf 95002 inspection report (ML21306A311)

In addition, review the following information:

Operating Experience trends from RRPS related to safety culture and performance SCWE related allegations trending details Cross-Cutting Issues Effectiveness Review Final Report (ML20239A806)

Problem Identification and Resolution Review Final Report (ML20247J59 C. Review safety culture training for inspectors:

IMC 1245 Appendix A and B IMC 1245 Appendix C-12 D. Review the 2018 Safety Culture Common Language effectiveness review (ML18219A687)

E. Use public meetings, such as ROP public meetings in which the Safety Culture program or the Safety Culture program effectiveness review is an agenda topic, to seek feedback on the Safety Culture program and communicate potential recommendations changes.

F. Leverage the work from the recent CCI and PI&R reviews and ROP framework to identify where additional attention to safety culture may be appropriate, such as:

How safety culture is addressed in the baseline inspection program.

How safety culture is addressed in IP95001 for plants in column 2 of the action matrix.

How safety culture is addressed in training activities for inspectors.

G. Identify safety culture inspection activities that affect licensees outside of Operating Reactors, i.e. vendors, research and test reactors, construction, fuels, and materials licensees.

H. Discuss with regional staff and management their experiences with the Safety Culture program to identify examples where it has led to positive outcomes and where it hasnt, and why.

I. Seek internal and external stakeholder views about the effectiveness of the Safety Culture program and recommended changes. External views may be solicited via the monthly ROP public meetings.

J. Determine whether changes should be made to the Safety Culture program objectives, and determine changes needed to ensure intended objectives are achieved. If so, develop specific recommendations including pros and cons of proposed changes to provide to management for decisions.

K. Develop a draft report documenting the teams efforts, conclusions, and recommendations.

An example of an effectiveness review report is the IFRM Effectiveness Review (ML18123A319).

IV. Team Leader Functions Schedule and lead team meetings Ensure action items are identified and tracked Circulate draft products for members to review

4 Present at public meetings to get external stakeholder insight and provide status of review Provide periodic status briefings to the NRR/DRO Director or Deputy Director and the regions of the status of the effectiveness review V. Team Membership Molly Keefe-Forsyth, Safety Culture Program Manager NRR/DRO/IRAB (Team Lead)

Rebecca Sigmon, NRR/DRO/IOEB April Nguyen, Senior RI, RIII Elise Eve-RI Dori Willis, OE/Allegations Team Lead Chris Hunt, RIII Alex Garmoe, NRR/DRO/IRAB (Team consultant)

VI. Duration This charter will remain in effect until the effectiveness review report is issued, which is expected by the end of calendar year 2022.

VII. Level of Effort Members are expected to review reference information, participate in periodic teleconference meetings, and complete action items assigned at team meetings. Travel might be necessary for some team meetings. In addition, team members are expected to dial in or attend public meetings in which the effectiveness review will be discussed.

Estimated Timeline: (Subject to change per DRO/NRR management review)

Review Team Kick-off - January 20, 2022 Review and Assess program - January 20- March 15, 2022 KM session to solicit internal feedback and insights - March/April, 2022 ROP monthly Public meetings to solicit external feedback from industry and public - February 2022 and April 2022 Evaluate program and feedback - May 2022 Brief Internal NRR management - May 2022 Brief Regional management - May 2022 Complete draft report - May 30, 2022 Brief NRR management on draft report - June 2022 Brief Regional management on draft report - June 2022 Brief Regions on draft report in KM session - June 2022 Finalize report and capture decisions in memo - June/July 2022 Present final report at ROP public mtg - July 2022 Disband working group - September 2022