ML102150390

Applicant-Northard Exhibit 4-INPO V NRC Nuclear Safety Culture Components

ML102150390
Person / Time
Site:	Prairie Island
Issue date:	07/30/2010
From:	- No Known Affiliation
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML102150384	List: ML102150385 ML102150386 ML102150387 ML102150388 ML102150389 ML102150390 ML102150391 ML102150392 ML102150393 ML102150394 ML102150395 ML102150396 ML102150398 ML102150399 ML102150400
References
50-282-LR, 50-306-LR, ASLBP 08-871-01-LR-BD01, RAS 18332
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NRC Nuclear Safety Culture Components INPO Principles for a Strong Nuclear Safety Culture November 2004 Principle 1. Everyone is personally responsible for nuclear safety.

Principle 2. Leaders demonstrate commitment to safety.

Principle 3. Trust permeates the organization.

Principle 4. Decision-making reflects safety first.

Principle 5. Nuclear technology is recognized as special and unique.

Principle 6. A questioning attitude is cultivated.

Principle 7. Organizational learning is embraced.

Principle 8. Nuclear safety undergoes constant examination.

NRC Manual Chapter 0305, Operating Reactor Assessment Program Manual Chapter 0310, Components Within The Crosscutting Areas Problem Identification & Resolution (PI&R)

P1. Corrective Action Program P2. Operating experience P3. Self- and Independent Assessments Human Performance H1. Decision-Making H2. Resources H3. Work Control

NRC Nuclear Safety Culture Components H4. Work Practices Safety Conscious Work Environment S1. Environment for Raising Concerns S2. Preventing, Detecting, and Mitigating Perceptions of Retaliation Other Safety Culture Components D1. Accountability D2. Continuous learning environment D3. Organizational change management D4. Safety policies

NRC Nuclear Safety Culture Components The following matrix lists the INPO Principles and Attributes in the left column by order of Principle. The NRC Safety Culture Components are listed in the right column and are listed in an order that generally matches with the INPO Principle.

INPO Principles NRC Inspection Manual Chapter 0305 (Section 06.07.c and d)

1. Everyone is personally responsible for nuclear safety. D1. Accountability - Management defines the line of authority and Responsibility and authority for nuclear safety are well defined and responsibility for nuclear safety. Specifically (as applicable):

clearly understood. Reporting relationships, positional authority, (a) Accountability is maintained for important safety decisions in staffing, and financial resources support nuclear safety that the system of rewards and sanctions is aligned with responsibilities. Corporate policies emphasize the overriding nuclear safety policies and reinforces behaviors and outcomes importance of nuclear safety. which reflect safety as an overriding priority.

(b) Management reinforces safety standards and displays Attributes:

behaviors that reflect safety as an overriding priority.

3/4 The line of authority and responsibility for nuclear safety is (c) The workforce demonstrates a proper safety focus and defined from the board of directors to the individual contributor.

reinforces safety principles among their peers.

Each of these positions has clearly defined roles, responsibilities, and authorities, designated in writing and understood by the incumbent. D4. Safety policies - Safety policies and related training establish and reinforce that nuclear safety is an overriding priority in that:

3/4 Support groups, such as human resources, labor relations, and business and financial planning, also understand their roles in (a) These policies require and reinforce that individuals have the contributing to nuclear safety. right and responsibility to raise nuclear safety issues through 3/4 People and their professional capabilities, values, and available means, including avenues outside their experiences are regarded as the nuclear organizations most organizational chain of command and to external agencies, valuable asset. Staffing levels are consistent with the and obtain feedback on the resolution of such issues.

demands related to maintaining safety and reliability. (b) Personnel are effectively trained on these policies.

3/4 Board members and corporate officers periodically take steps (c) Organizational decisions and actions at all levels of the to reinforce nuclear safety, including visiting sites to assess organization are consistent with the policies. Production, cost management effectiveness first-hand. and schedule goals are developed, communicated, and implemented in a manner that reinforces the importance of 3/4 The line organization, starting with the chief executive officer, nuclear safety.

is the primary source of information and the only source of direction. Other parties, such as oversight organizations and (d) Senior managers and corporate personnel periodically committees, review boards, and outside advisors, who provide communicate and reinforce nuclear safety such that personnel management information essential to effective self-evaluation, understand that safety is of the highest priority.

NRC Nuclear Safety Culture Components are not allowed to dilute or undermine line authority and accountability.

3/4 All personnel understand the importance of adherence to nuclear safety standards. All levels of the organization exercise healthy accountability for shortfalls in meeting standards.

3/4 Relationships among utilities, operating companies, and owners are not allowed to obscure or diminish the line of responsibility for nuclear safety.

3/4 The system of rewards and sanctions is aligned with strong nuclear safety policies and reinforces the desired behaviors and outcomes.

NRC Nuclear Safety Culture Components

2. Leaders demonstrate commitment to safety. H4. Work Practices - Personnel work practices support human Executive and senior managers are the leading advocates of nuclear performance. Specifically (as applicable):

safety and demonstrate their commitment both in word and action. (a) The licensee communicates human error prevention The nuclear safety message is communicated frequently and techniques, such as holding pre-job briefings, self and peer consistently, occasionally as a standalone theme. Leaders checking, and proper documentation of activities. These throughout the nuclear organization set an example for safety. techniques are used commensurate with the risk of the assigned task, such that work activities are performed safely.

Attributes: Personnel are fit for duty. In addition, personnel do not 3/4 Managers and supervisors practice visible leadership in the proceed in the face of uncertainty or unexpected field by placing eyes on the problem, coaching, mentoring, circumstances. H.4(a) and reinforcing standards. Deviations from station (b) The licensee defines and effectively communicates expectations are corrected promptly. expectations regarding procedural compliance and personnel 3/4 Management considers the employee perspective in follow procedures. H.4(b) understanding and analyzing issues. (c) The licensee ensures supervisory and management oversight 3/4 Managers and supervisors provide appropriate oversight of work activities, including contractors, such that nuclear during safety-significant tests or evolutions. safety is supported. H.4(c) 3/4 Managers and supervisors are personally involved in high-quality training that consistently reinforces expected worker behaviors.

3/4 Leaders recognize that production goals, if not properly communicated, can send mixed signals on the importance of nuclear safety. They are sensitive to detect and avoid these misunderstandings.

3/4 The bases, expected outcomes, potential problems, planned contingencies, and abort criteria for important operational decisions are communicated promptly to workers.

3/4 Informal opinion leaders in the organization are encouraged to model safe behavior and influence peers to meet high standards.

3/4 Selection and evaluation of managers and supervisors consider their abilities to contribute to a strong nuclear safety culture.

NRC Nuclear Safety Culture Components

3. Trust permeates the organization. S1. Environment for Raising Concerns - An environment exists in A high level of trust is established in the organization, fostered, in which employees feel free to raise concerns both to their part, through timely and accurate communication. There is a free management and/or the NRC without fear of retaliation and flow of information in which issues are raised and addressed. employees are encouraged to raise such concerns. Specifically Employees are informed of steps taken in response to their (as applicable):

concerns. (a) Behaviors and interactions encourage free flow of information related to raising nuclear safety issues, differing professional Attributes: opinions, and identifying issues in the CAP and through self 3/4 People are treated with dignity and respect. assessments. Such behaviors include supervisors responding 3/4 Personnel can raise nuclear safety concerns without fear of to employee safety concerns in an open, honest, and non-retribution and have confidence their concerns will be defensive manner and providing complete, accurate, and addressed. forthright information to oversight, audit, and regulatory organizations. Past behaviors, actions, or interactions that 3/4 Employees are expected and encouraged to offer innovative may reasonably discourage the raising of such issues are ideas to help solve problems. actively mitigated. As a result, personnel freely and openly 3/4 Differing opinions are welcomed and respected. When communicate in a clear manner conditions or behaviors, such needed, fair and objective methods are used to resolve conflict as fitness for duty issues that may impact safety, and and unsettled differing professional opinions. personnel raise nuclear safety issues without fear of retaliation.

3/4 Supervisors are skilled in responding to employee questions in S.1(a) an open, honest manner. They are recognized as an important (b) If alternative processes (i.e., a process for raising concerns or part of the management team, crucial to translating safety resolving differing professional opinions that are alternates to culture into practical terms. the licensees corrective action program or line management) 3/4 The effects of impending changes (such as those caused by for raising safety concerns or resolving differing professional sale or acquisition, bargaining unit contract renegotiations, and opinions exists, then they are communicated, accessible, have economic restructuring) are anticipated and managed such an option to raise issues in confidence, and are independent, that trust in the organization is maintained. in the sense that the program does not report to line management (i.e., those who would in the normal course of 3/4 Senior management incentive programs reflect a bias toward activities be responsible for addressing the issue raised).

long-term plant performance and safety.

S.1(b) 3/4 Complete, accurate, and forthright information is provided to oversight, audit, and regulatory organizations. S2. Preventing, Detecting, and Mitigating Perceptions of 3/4 Managers regularly communicate to the workforce important Retaliation - A policy for prohibiting harassment and retaliation decisions and their bases, as a way of building trust and for raising nuclear safety concerns exists and is consistently reinforcing a healthy safety culture. Worker understanding is enforced in that:

periodically checked.

(a) All personnel are effectively trained that harassment and

NRC Nuclear Safety Culture Components retaliation for raising safety concerns is a violation of law and policy and will not be tolerated. S.2(a)

(b) Claims of discrimination are investigated consistent with the content of the regulations regarding employee protection and any necessary corrective actions are taken in a timely manner, including actions to mitigate any potential chilling effect on others due to the personnel action under investigation. S.2(b)

(c) The potential chilling effects of disciplinary actions and other potentially adverse personnel actions (e.g., reductions, outsourcing, and reorganizations) are considered and compensatory actions are taken when appropriate. S.2(c)

D3. Organizational change management -Management uses a systematic process for planning, coordinating, and evaluating the safety impacts of decisions related to major changes in organizational structures and functions, leadership, policies, programs, procedures, and resources. Management effectively communicates such changes to affected personnel.

NRC Nuclear Safety Culture Components

4. Decision-making reflects safety first. H1. Decision-Making - Licensee decisions demonstrate that nuclear Personnel are systematic and rigorous in making decisions that safety is an overriding priority. Specifically (as applicable):

support safe, reliable plant operation. Operators are vested with the (a) The licensee makes safety-significant or risk-significant authority and understand the expectation, when faced with decisions using a systematic process, especially when faced unexpected or uncertain conditions, to place the plant in a safe with uncertain or unexpected plant conditions, to ensure safety condition. Senior leaders support and reinforce conservative is maintained. This includes formally defining the authority and decisions. roles for decisions affecting nuclear safety, communicating these roles to applicable personnel, and implementing these Attributes: roles and authorities as designed and obtaining 3/4 The organization maintains a knowledgeable workforce to interdisciplinary input and reviews on safety significant or risk-support a broad spectrum of operational and technical significant decisions. H.1(a) decisions. Outside expertise is employed when necessary. (b) The licensee uses conservative assumptions in decision 3/4 Managers, supervisors, and staff clearly understand and making and adopts a requirement to demonstrate that the respect each others roles in decision-making. proposed action is safe in order to proceed rather than a 3/4 Plant personnel apply a rigorous approach to problem-solving. requirement to demonstrate that it is unsafe in order to Conservative actions are taken when understanding is disapprove the action. The licensee conducts effectiveness incomplete. reviews of safety-significant decisions to verify the validity of the underlying assumptions, identify possible unintended 3/4 Single-point accountability is maintained for important safety consequences, and determine how to improve future decisions, allowing for ongoing assessment and feedback as decisions. H.1(b) circumstances unfold.

(c) The licensee communicates decisions and the basis for 3/4 Candid dialogue and debate are encouraged when safety decisions to personnel who have a need to know the issues are being evaluated. Robust discussion and healthy information in order to perform work safely, in a timely manner.

conflict are recognized as a natural result of diversity of H.1(c) expertise and experience.

3/4 Decision-making practices reflect the ability to distinguish between allowable choices and prudent choices.

3/4 When previous operational decisions are called into question by new facts, the decisions and associated underlying assumptions are reviewed to improve the quality of future decisions.

NRC Nuclear Safety Culture Components

5. Nuclear technology is recognized as special and unique. H2. Resources - The licensee ensures that personnel, equipment, The special characteristics of nuclear technology are taken into procedures, and other resources are available and adequate to account in all decisions and actions. Reactivity control, continuity of assure nuclear safety. Specifically, those necessary for:

core cooling, and integrity of fission product barriers are valued as (a) Maintaining long term plant safety by maintenance of design essential, distinguishing attributes of the nuclear station work margins, minimization of long-standing equipment issues, environment. minimizing preventative maintenance deferrals, and ensuring maintenance and engineering backlogs which are low enough Attributes: to support safety. H.2(a) 3/4 Activities that could affect core reactivity are conducted with (b) Training of personnel and sufficient qualified personnel to particular care and caution. maintain work hours within working hour guidelines. H.2(b) 3/4 Features designed to maintain critical safety functions, such as (c) Complete, accurate and up-to-date design documentation, core cooling, are recognized as particularly important. procedures, and work packages, and correct labeling of 3/4 Design and operating margins are carefully guarded and are components. H.2(c) changed only with great thought and care. Special attention is (d) Adequate and available facilities and equipment, including placed on maintaining fission product barriers and defense-in- physical improvements, simulator fidelity and emergency depth. facilities and equipment. H.2(d) 3/4 Equipment is meticulously maintained well within design requirements. H3. Work Control - The licensee plans and coordinates work 3/4 Insights from probabilistic risk analyses are considered in daily activities, consistent with nuclear safety. Specifically (as plant activities and plant change processes. applicable):

3/4 Plant activities are governed by comprehensive, high-quality (a) The licensee appropriately plans work activities by processes and procedures. incorporating H.3(a):

3/4 Employee mastery of reactor and power plant fundamentals,

• risk insights; as appropriate to the job position, establishes a solid

• job site conditions, including environmental conditions foundation for sound decisions and behaviors. which may impact human performance; plant structures, systems, and components; human-system interface; or radiological safety; and

• the need for planned contingencies, compensatory actions, and abort criteria.

(b) The licensee appropriately coordinates work activities by incorporating actions to address H.3(b):

• the impact of changes to the work scope or activity on the plant and human performance,

NRC Nuclear Safety Culture Components

• the impact of the work on different job activities, and the need for work groups to maintain interfaces with offsite organizations, and communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance,

• the need to keep personnel apprised of work status, the operational impact of work activities, and plant conditions that may affect work activities,

• the licensee plans work activities to support long-term equipment reliability by limiting temporary modifications, operator workarounds, safety systems unavailability, and reliance on manual actions.

Maintenance scheduling is more preventive than reactive.

NRC Nuclear Safety Culture Components

6. A questioning attitude is cultivated. P1. Corrective Action Program - The licensee ensures that issues Individuals demonstrate a questioning attitude by challenging potentially impacting nuclear safety are promptly identified, fully assumptions, investigating anomalies, and considering evaluated, and that actions are taken to address safety issues in potential adverse consequences of planned actions. This attitude is a timely manner, commensurate with their significance.

shaped by an understanding that accidents often result from a series Specifically (as applicable):

of decisions and actions that reflect flaws in the shared assumptions, (a) The licensee implements a corrective action program with a values, and beliefs of the organization. All employees are watchful low threshold for identifying issues. The licensee identifies for conditions or activities that can have an undesirable effect on such issues completely, accurately, and in a timely manner plant safety. commensurate with their safety significance. P.1(a)

(b) The licensee periodically trends and assesses information Attributes:

from the CAP and other assessments in the aggregate to 3/4 While individuals expect successful outcomes of daily identify programmatic and common cause problems. The activities, they recognize the possibility of mistakes and worst- licensee communicates the results of the trending to applicable case scenarios. Contingencies are developed to deal with personnel. P.1(b) these possibilities.

(c) The licensee thoroughly evaluates problems such that the 3/4 Anomalies are recognized, thoroughly investigated, promptly resolutions address causes and extent of conditions, as mitigated, and periodically analyzed in the aggregate. necessary. This includes properly classifying, prioritizing, and 3/4 Personnel do not proceed in the face of uncertainty. evaluating for operability and reportability conditions adverse to 3/4 Workers identify conditions or behaviors that have the potential quality. This also includes, for significant problems, conducting to degrade operating or design margins. Such circumstances effectiveness reviews of corrective actions to ensure that the are promptly identified and resolved. problems are resolved. P.1(c) 3/4 Employees understand that complex technologies can fail in (d) The licensee takes appropriate corrective actions to address unpredicted ways. They are aware that latent problems can safety issues and adverse trends in a timely manner, exist, and they make conservative decisions considering this commensurate with their safety significance and complexity.

potential. P.1(d)

(e) If an alternative process (i.e., a process for raising concerns 3/4 Group-think is avoided through diversity of thought and that is an alternate to the licensees corrective action program intellectual curiosity. Opposing views are encouraged and or line management) for raising safety concerns exists, then it considered.

results in appropriate and timely resolutions of identified problems. P.1(e)

NRC Nuclear Safety Culture Components

7. Organizational learning is embraced. P2. Operating experience - The licensee uses operating experience Operating experience is highly valued, and the capacity to learn from (OE) information, including vendor recommendations and experience is well developed. Training, self-assessments, corrective internally generated lessons learned, to support plant safety.

actions, and benchmarking are used to stimulate learning and Specifically (as applicable):

improve performance. (a) The licensee systematically collects, evaluates, and communicates to affected internal stakeholders in a timely Attributes: manner relevant internal and external OE. P.2(a) 3/4 The organization avoids complacency and cultivates a (b) The licensee implements and institutionalizes OE through continuous learning environment. The attitude that it can changes to station processes, procedures, equipment, and happen here is encouraged. training programs. P.2(b) 3/4 Training upholds management standards and expectations.

Beyond teaching knowledge and skills, trainers are adept at D2. Continuous learning environment - The licensee ensures that instilling nuclear safety values and beliefs. a learning environment exists. Specifically (as applicable):

3/4 Individuals are well informed of the underlying lessons learned (a) The licensee provides adequate training and knowledge from significant industry and station events, and they are transfer to all personnel on site to ensure technical committed to not repeating these mistakes. competency.

3/4 Expertise in root cause analysis is applied effectively to identify (b) Personnel continuously strive to improve their knowledge, and correct the fundamental causes of events. skills, and safety performance through activities such as 3/4 Processes are established to identify and resolve latent benchmarking, being receptive to feedback, and setting organizational weaknesses that can aggravate relatively minor performance goals. The licensee effectively communicates events if not corrected. information learned from internal and external sources about industry and plant issues.

3/4 Employees have confidence that issues with nuclear safety implications are prioritized, tracked, and resolved in a timely manner.

NRC Nuclear Safety Culture Components

8. Nuclear safety undergoes constant examination. P3. Self- and Independent Assessments - The licensee conducts Oversight is used to strengthen safety and improve performance. self- and independent assessments of their activities and Nuclear safety is kept under constant scrutiny through a variety of practices, as appropriate, to assess performance and identify monitoring techniques, some of which provide an independent fresh areas for improvement. Specifically (as applicable):

look. (a) The licensee conducts self-assessments at an appropriate frequency; such assessments are of sufficient depth, are Attributes: comprehensive, are appropriately objective, and are self-3/4 A mix of self-assessment and independent oversight reflects critical. The licensee periodically assesses the effectiveness of an integrated and balanced approach. This balance is oversight groups and programs such as CAP, and policies.

periodically reviewed and adjusted as needed. P.3(a) 3/4 Periodic safety culture assessments are conducted and used (b) The licensee tracks and trends safety indicators which provide as a basis for improvement. an accurate representation of performance. P.3(b) 3/4 The pitfalls of focusing on a narrow set of performance (c) The licensee coordinates and communicates results from indicators are recognized. The organization is alert to detect assessments to affected personnel, and takes corrective and respond to indicators that may signal declining actions to address issues commensurate with their performance. significance. P.3(c) 3/4 The insights and fresh perspectives provided by quality assurance, assessment, employee concerns, and independent oversight personnel are valued.

3/4 Senior executives and board members are periodically briefed on results of oversight group activities to gain insights into station safety performance.

NRC Nuclear Safety Culture Components NR C Inspection M anual Chapter 0305 Perform ance Safeguards Reactor S afety Radiation Safety A reas:

O ccupational Public C onerstones: Physical Initiating M itigating Barrier Em ergency R adiation Radiation Protection Event System s Integrity Preparedness Safety Safety "C ross-C utting" Areas Cross-C utting Areas:

Problem Identification H um an Safety C onscious

& R esolution (P) Perform ance (H ) W ork Environm ent (S)

C orrective Action D ecision M aking (H 1) Environm ent for Program (P1) R aising C oncerns C ross-C utting Area C om ponents: (S1)

R esources (H 2)

O perating Experience (P2)

Preventing, Detecting, W ork C ontrol (H 3) and M itigating NR C 's 13 Safety Self and Independent Perceptions of C ulture C om ponents Assessm ents (P3) R etaliation (S2)

(SC C ) W ork Practices (H 4)

C ontinuous Learning O rganizational O ther Safety C ulture Accountability (D 1) Safety Policies (D 4)

Environm ent (D 2) C hange M anagem ent C om ponents: (D )

(D 3)

Safety Conscious Work Environment SCWE The Nuclear Regulatory Commission provides guidance on their expectations for each nuclear power plant to maintain a Safety Conscious Work Environment. This guidance is provided in NRC Regulatory Issue Summary 2005-18. The following elements are detailed in this guidance as fundamental to a safety conscious work environment:

3/4 Employees Are Encouraged To Raise Safety Concerns 3/4 Management Is Promptly Notified of Concerns 3/4 Concerns Are Promptly Prioritized and Reviewed 3/4 Timely Feedback Is Provided to the Concerned Individual 3/4 Appeal Process for Concerns 3/4 Self-Assessments of Problem Identification and Resolution (PI&R)

Processes 3/4 An Alternative Process to Line Management (Employee Concerns Program)

Management Behaviors in support of SCWE:

3/4 Managers have an open-door policy in the office and make themselves available in the field.

3/4 Managers are aware of employees potential reluctance to raise concerns.

3/4 Managers understand the importance of identity protection.

3/4 Managers have good basic listening skills, seek and express appreciation of employees who raise concerns.

Employee Behaviors in support of SCWE 3/4 Taking individual responsibility for reporting concerns.

3/4 Clearly communicating the concern and confirming that the person who receives the concern understands it.

3/4 Being willing to suggest resolutions to concerns and participate in their resolution.

3/4 Following up to ensure the concern is adequately addressed.

3/4 Showing respect for other employees who identify concerns.