The Nuclear Regulatory Commission’s Approach to

Safety Culture

Diane SierackiSenior Safety Culture Program Manager

Office of EnforcementNuclear Regulatory Commission

July 22, 2020

Outline

• NRC’s Safety Culture History• NRC’s Role in Safety Culture• Safety Culture Policy Statement• Safety Culture in the Reactor Oversight Process,

Enforcement and Alternative Dispute Resolution• NRC’s Safety Culture:

– Leadership Model– Differing Views Programs and Assessments

• International Safety Culture Activities

2

NRC’s MissionTo 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.

3

NRC Safety Culture History• Operators inattentive and unprofessional while

on duty at nuclear power plant• Commission Policy Statement: Conduct of

Nuclear Power Plant Operations1989

• 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 culture2002• Commission direction to develop policy

statement on safety culture that applies to all licensees2008

• Final Safety Culture Policy Statement (SCPS) published in the Federal Register2011

4

Safety Culture Policy Statement (SCPS)

– 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.

– Commission agreed that an overarching safety culture addresses both safety and security.

– A robust discussion of security, and the interface between safety and security, was included in a preamble in the Statement of Policy.

5

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.

6

Preamble to the Safety Culture Traits

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 is the Commission’s expectation that all organizations and individuals overseeing or performing regulated activities involving nuclear materials should take the necessary steps to promote a positive safety culture by fostering these traits. Additionally, it should be noted that although the term ”security” is not expressly included in the traits, safety and security are the primary pillars of the NRC’s regulatory program. Consequently, consideration of both safety and security issues commensurate with their significance, is an underlying principle of the Statement of Policy.

7

Safety Culture Traits

Leadership Safety Valuesand Actions

Problem Identification and Resolution Personal Accountability

Leaders demonstrate acommitment 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 focuson 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

8

Outreach and Education Efforts

• SC Educational Resource Workbook– Trait Talks– Metro Case Study– Journeys– SCPS

• Safety Culture in Decommissioning

• Safety Culture Website

9

NRC Approach to Safety Culture

• Licensees bear primary responsibility for safety• NRC’s Safety Culture Policy Statement (SCPS) states

safety culture expectation, but is not a regulatory requirement

• NRC considers safety culture within the Reactor Oversight Process (ROP) for nuclear power reactors– NRC assessment of safety culture is primarily as a result of an

event or degradation in performance – Different levels of inspection activity based on NRC’s overall

assessment of licensee performance• Alternative Dispute Resolution Process can result in

Confirmatory Orders for safety culture activities

10

Safety Culture at the NRC

At the NRC, we foster a culture in which all employees live the NRC’s values, demonstrate a positive safety culture, and adhere to the Principles of Good Regulation to support the NRC’s mission to protect public health, safety, and the environment. The NRC culture includes a system of shared values, beliefs, and behaviors that demonstrate our collective commitment to emphasize safety as the overriding priority in our regulatory decision-making, and that recognizes the important role each of us plays in NRC’s success. We are committed to creating and sustaining a positive work environment to ensure we remain a model regulator.

11

NRC’s Leadership Model

• Efforts to improve the NRC’s organizational culture, to include the development of an explicit leadership model, contribute to the advancement of the Agency’s safety culture.

• NRC’s Leadership Model includes the SCPS definition of Safety Culture for the Agency. – Safety Culture included in the 12 specific

programs/activities that contribute to the NRC Leadership Model.

12

Safety Culture Differing View Programs

NRC mechanisms for expressing and resolving differing views include:

• Open Door Policy• Non-Concurrence Process• Differing Professional Opinions Program

13

Assessing Safety Culture at the NRC

• Safety Culture and Climate Survey

• Federal Employees Viewpoint Survey

• Assessment of Differing Views Programs

14

NRC Training Trust and Safety Culture

• Speed of Trust initiative

• Ongoing Training – Organizational Values Course Revision to include

safety culture aspects from Leadership Model

15

Importance of Safety Culture Activities Internationally

• International Activities– IAEA—current activities

• Common SC Framework—GSR-2• Training course for medical licensees• Safety and Security Culture Interface

16

Importance of Safety Culture Activities Internationally

• International Activities– NEA—current activities

• SC of the Regulator (CNRA/WGSC)– Self-Assessment– Competencies/Training

17

Importance of Safety Culture Activities Internationally

https://www.iaea.org/services/review-missions/independent-safety-culture-assessment-isca

https://www.iaea.org/newscenter/news/iaea-issues-harmonized-model-for-enhanced-safety-culture-in-nuclear-organizations

18

Summary

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

• NRC continues outreach and education • NRC utilizes the Reactor Oversight Process (reactors),

Enforcement and Alternative Dispute Resolution • NRC’s Safety Culture is included in the NRC Leadership

Model• Differing Views Programs consist of three tier approach

– Assessment done through surveys and program reviews

19

For More Information:

• Please visit NRC’s safety culture webpage at: http://www.nrc.gov/about-nrc/safety-culture.html

• Information on the components of organizational culture (NRC Values; Principles of Good Regulation; Open Door Policy; Non-Concurrence Process; and Differing Professional Opinion Program): http://www.nrc.gov/about-nrc/values.html– Leadership Model (brochure)– Leadership Model (full report)

• Contact NRC staff via email at: external_safety_culture.resource@nrc.gov

20

NRC SAFETY CULTURE

QUESTIONS???