Proposed NRC Safety Culture Policy Statement

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Presentation transcript:

Proposed NRC Safety Culture Policy Statement Eric Fries Safety Culture Program Manager, OE IRPA Workshop on Radiation Protection Culture February 10, 2011

Presentation Overview NRC’s Mission and Responsibility Safety Culture Background Draft Safety Culture Policy Statement Current Status Next Steps

The U.S. NRC’s Mission To license and regulate the Nation’s civilian use of byproduct, source, and special nuclear materials to ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment.

NRC Scope of Regulatory Responsibility Reactors: commercial reactors for generating electric power and non-power reactors used for research, testing, and training Materials: uses of nuclear materials in medical, industrial, and facilities that produce nuclear fuel Waste: transportation, storage, and disposal of nuclear materials and waste, and decommissioning of nuclear facilities from service

Importance of Safety Culture Operating experience has demonstrated nexus between safety culture and events Safety culture contributes to the safe and secure use of radioactive materials NRC recognizes that licensees bear the primary responsibility for the safe use of nuclear materials while the NRC, as the regulator, must consider the importance of safety culture in its oversight programs  

NRC Safety Culture Background Overview 1989: Conduct of Operations Policy Statement 1996: Safety Conscious Work Environment (SCWE) Policy Statement 2000: Reactor Oversight Process Implemented 2006: Reactor Oversight Process Enhanced 2008: Commission direction to develop a Safety Culture Policy Statement (SCPS) 2009: Draft SCPS 2011: Revised Draft SCPS

NRC Safety Culture Background 1989: Conduct of Operations Policy Statement Expectations for a Safety Culture: Full attention to safety matters Personal dedication and accountability of all individuals engaged in any activity which has a bearing on nuclear power plant safety Management fosters the development of a ‘safety culture’ at each facility and promotes a professional working environment in the control room, and throughout the facility, that assures safe operations

NRC Safety Culture Background 1996: Safety Conscious Work Environment (SCWE) Policy Statement Establish and maintain a SCWE Intended to assure the freedom of employees in the nuclear industry to raise safety concerns without fear of retaliation Applies to all NRC-regulated activities of licensees, contractors, and applicants

NRC Safety Culture Background 2000: Reactor Oversight Process Implemented Monitors the “Cornerstones” that are the basis of plant safety: Reactor safety Radiation safety Safeguards “Cross-Cutting” areas: Human performance SCWE Problem Identification and Resolution (PI&R) Reactor Safety: Initiating Events -> Mitigating Systems -> Barrier Integrity Emergency Preparedness Radiation Safety: Public Rad Safety Occupational Rad Safety Safeguards: Security

NRC Safety Culture Background 2006: Reactor Oversight Process Enhanced Safety culture definition 13 safety culture “components” Requirements added to specifically focus on safety culture evaluation for plants with degraded performance (columns 3 and 4 of the Action Matrix) Safety culture training provided to NRC inspection personnel Safety culture features added to select NRC inspection procedures Decision-Making. - Decisions demonstrate that nuclear safety is an overriding priority. Resources - The personnel, equipment, procedures, and other resources are available and adequate to assure nuclear safety. Work Control - The planning and coordination of work activities is consistent with nuclear safety. Work Practices - Personnel work practices support human performance.  Corrective Action Program - Issues potentially impacting nuclear safety are promptly identified, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their significance.   Operating experience - Operating experience (OE) information, including vendor recommendations and internally generated lessons learned, is used to support plant safety.  Self- and Independent Assessments - Self- and independent assessments are conducted to assess performance and identify areas for improvement. Environment for Raising Concerns - An environment exists in which employees feel free to raise concerns both to their management and/or the NRC without fear of retaliation. Employees are encouraged to raise such concerns. Preventing, Detecting, and Mitigating Perceptions of Retaliation - A policy prohibiting harassment and retaliation for raising nuclear safety concerns exists and is consistently enforced  Accountability - Management defines the line of authority and responsibility for nuclear safety.   Continuous learning environment - A learning environment exists.  Organizational change management Safety policies - Safety policies and related training establish and reinforce that nuclear safety is an overriding priority.

NRC Safety Culture Background 2008: Commission Direction (SRM-COMGBJ-08-0001A) Develop a draft safety culture policy statement Address the unique aspects of security Applicable to all licensees and certificate holders Increase attention to safety culture in the material area We began this safety culture initiative dating back to February 2008 with: February 2008 COMGBJ-08-0001: Review reactor process (ROP) Include materials areas and Agreement States Consider security May 2009 SECY 09-0075: ROP is effective Plan to include materials areas and Agreement States One policy statement for both safety and security (stakeholder involvement in February 2009 workshop) October 2009 SRM: Publish one policy statement in the FRN Consider vendors and suppliers Comport terminology Engage broad range of stakeholders

NRC Safety Culture Background 2009: Further Commission Direction (SRM-SECY-09-0075) Publish the draft safety culture policy statement for public comment Continue to engage a broad range of external stakeholders and the Agreement States Seek opportunities to achieve common safety culture terminology with existing standards and references Consider making the policy statement applicable to vendors and suppliers We began this safety culture initiative dating back to February 2008 with: February 2008 COMGBJ-08-0001: Review reactor process (ROP) Include materials areas and Agreement States Consider security May 2009 SECY 09-0075: ROP is effective Plan to include materials areas and Agreement States One policy statement for both safety and security (stakeholder involvement in February 2009 workshop) October 2009 SRM: Publish one policy statement in the FRN Consider vendors and suppliers Comport terminology Engage broad range of stakeholders

Draft Safety Culture Policy Statement Timeline Sep 2010 Public Meeting (Workshop) Jul 2010 Public Meeting (Workshop) Nov 2009 Federal Register Notice Sep 2010 Federal Register Notice Feb 2008 Commission Direction May 2009 Draft Policy Statement Oct 2009 Commission Direction Mar 2010 Commission Briefing Jan 2011 Commission Briefing Feb 2010 Public Workshop Feb 2009 Public Meeting Nov 2010 Final Draft PS Feb 2011 IAEA Feb 2011 IRPA Mar 2011 RIC 2008 2009 2010 2011 120 Day Public Comment Period Apr-Nov 2010: NRC Staff Participate in18 Industry Meetings 30 Day Public Comment Period ROP SC Definition 13 SC Components Our numerous outreach activities included: Staff published the draft SCPS, as directed by the Commission, in the November 2009 FRN for public comment. Staff conducted a 3-day workshop with a panel of 16 stakeholders representing various regulated entities, as well as members of the public, resulting in the development of a safety culture definition and traits describing safety culture in an effort to come to a common terminology. Staff spent time reaching out to stakeholders through various forums, such as speaking at industry conferences. James Firth, FSME, will be providing details relates to these outreach activities later in this presentation. With all of the input from the 3-day workshop as well as feedback from other outreach activities, the staff published a revised draft SCPS in the FR in September 2010 and held an additional one-day public meeting out west to obtain input through public comments and discussion. NRC Authored SC Definition NRC Authored 8 SC Traits Workshop Authored SC Definition Workshop Authored 8 SC Traits Workshop Authored SC Definition Workshop Authored 8 SC Traits + Questioning Attitude

Draft Safety Culture Policy Statement Timeline Sep 2010 Public Meeting (Workshop) Jul 2010 Public Meeting (Workshop) Nov 2009 Federal Register Notice Sep 2010 Federal Register Notice Feb 2008 Commission Direction May 2009 Draft Policy Statement Oct 2009 Commission Direction Mar 2010 Commission Briefing Jan 2011 Commission Briefing Feb 2010 Public Workshop Feb 2009 Public Meeting Nov 2010 Final Draft PS Feb 2011 IAEA Feb 2011 IRPA Mar 2011 RIC 2008 2009 2010 2011 120 Day Public Comment Period Apr-Nov 2010: NRC Staff Participate in18 Industry Meetings 30 Day Public Comment Period ROP SC Definition 13 SC Components Our numerous outreach activities included: Staff published the draft SCPS, as directed by the Commission, in the November 2009 FRN for public comment. Staff conducted a 3-day workshop with a panel of 16 stakeholders representing various regulated entities, as well as members of the public, resulting in the development of a safety culture definition and traits describing safety culture in an effort to come to a common terminology. Staff spent time reaching out to stakeholders through various forums, such as speaking at industry conferences. James Firth, FSME, will be providing details relates to these outreach activities later in this presentation. With all of the input from the 3-day workshop as well as feedback from other outreach activities, the staff published a revised draft SCPS in the FR in September 2010 and held an additional one-day public meeting out west to obtain input through public comments and discussion. NRC Authored SC Definition NRC Authored 8 SC Traits Workshop Authored SC Definition Workshop Authored 8 SC Traits Workshop Authored SC Definition Workshop Authored 8 SC Traits + Questioning Attitude

Outreach Activities February 2009 public meeting November 2009 Federal Register Notice February 2010 public workshop April-November 2010 NRC staff presentations and communications September 2010 Federal Register Notice September 2010 public meeting Our numerous outreach activities included: Staff published the draft SCPS, as directed by the Commission, in the November 2009 FRN for public comment. Staff conducted a 3-day workshop with a panel of 16 stakeholders representing various regulated entities, as well as members of the public, resulting in the development of a safety culture definition and traits describing safety culture in an effort to come to a common terminology. Staff spent time reaching out to stakeholders through various forums, such as speaking at industry conferences. James Firth, FSME, will be providing details relates to these outreach activities later in this presentation. With all of the input from the 3-day workshop as well as feedback from other outreach activities, the staff published a revised draft SCPS in the FR in September 2010 and held an additional one-day public meeting out west to obtain input through public comments and discussion.

Proposed Statement of Policy Includes definition and traits Interface of safety and security considerations Preamble addresses “security” Recognizes diversity of regulated entities Vendors and suppliers included Consider negative factors (e.g., incentive goals) Implementation not directly addressed Although the term “security” is not expressly included in the traits, safety and security are the primary pillars of the NRC’s regulatory mission. Consequently, consideration of both safety and security issues, commensurate with their significance, is an underlying principle of this Statement of Policy.

Safety Culture Policy Statement: Requirement or Expectation? “The Commission expects that all individuals and organizations performing regulated activities will take the steps necessary to promote a positive safety culture by fostering these traits as they apply to their organizational environments.”

Proposed Statement of Policy Sets forth the Commission’s 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 Statement of Policy Applicability Licensees Certificate Holders Permit Holders Authorization Holders Holders of QA Program Approvals Applicants Vendors and Suppliers of Safety-Related Components

Applicability to Agreement States The Commission encourages the Agreement States and other organizations interested in nuclear safety to support the development and maintenance of a positive safety culture, as articulated in the Statement of Policy, within their regulated communities

Proposed 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.

Proposed Preamble Experience has shown that certain personal and organizational traits are present in a positive safety culture. A trait, in this case, is a pattern of thinking, feeling, and behaving that emphasizes safety, particularly in goal conflict situations, e.g., production vs. safety, schedule vs. safety, and cost of the effort vs. safety. It should be noted that although the term “security” is not expressly included in these traits, safety and security are the primary pillars of the NRC’s regulatory mission. Consequently, consideration of both safety and security issues, commensurate with their significance, is an underlying principle of this Statement of Policy.

Proposed 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 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 Experience has shown that certain personal and organizational traits are present in a positive safety culture. A trait, in this case, is a pattern of thinking, feeling, and behaving that emphasizes safety, particularly in goal conflict situations, e.g., production vs. safety, schedule vs. safety, and cost of the effort vs. safety. Stipulation on Traits (from the Statement of Policy” “There may be traits not included in this Statement of Policy that are also important in a positive safety culture.” “It should also be noted that these traits are not necessarily inspectable and were not developed for that purpose.”

Tiers for Development of the Policy Statement Safety Culture Definition Overarching definition that applies to all of the nuclear industry Easy to understand Timeless Inclusive Tier 1 Definition and Traits Safety Culture Traits Set of high level descriptions of what constitutes a strong safety culture Applies to everyone who engages in NRC licensed activities Speak to all levels of the organization Tier 2 Application Illustrates how the high level descriptions are translated to lower level descriptions that are applicable to different environments Describes programs, processes, procedures, practices, behaviors, etc. Details may vary depending on licensee type and environment (potential for different sets) Next Steps Tier 3

“Leadership” Trait Exercise Example of Tier 3 Leadership Safety Values and Actions Leaders demonstrate a commitment to safety in their decisions and behaviors Management in the field enforcing standards Commitment to maintaining equipment Resolves conflict Actions match words Rewards (incentives) and sanctions used to reinforce desired positive nuclear safety behaviors Respects differing opinions Schedules are realistic and do not challenge safety standards Tier 2 Tier 3 These Tier 3 behaviors were developed through an “affinity diagraming” exercise by external stakeholders at an NRC-sponsored public workshop in February 2010. They are provided as an example of how behaviors could be developed and do not constitute an all-inclusive or NRC-endorsed listing.

Current Status The Commission has been briefed (January 24, 2011) on the proposed safety culture policy statement The staff is awaiting further direction

NRC: Next Steps (Projected)

Today’s Question: What’s the relationship between Safety Culture and Radiation Protection Culture?

Resources NRC safety culture website: http://www.nrc.gov/about-nrc/regulatory/enforcement/safety-culture.html Policy Statement meeting summaries Regulatory Issue Summary – 2006 changes made to the Reactor Oversight Process to more fully address safety culture Eric Fries, Safety Culture Program Manager (e-mail: eric.fries@nrc.gov or external_safety_culture.resource@nrc.gov)