SAFETY CULTURE WITHIN THE NUCLEAR SAFETY REGULATORY ENVIRONMENT

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1 SAFETY CULTURE WITHIN THE NUCLEAR SAFETY REGULATORY ENVIRONMENT O. ŠEŠTOKAS State Nuclear Power Safety Inspectorate (VATESI) Vilnius, Lithuania Abstract Safety culture cannot be easily regulated and controlled taking into account the fact that it is based on the attitudes, beliefs and other psychosociological features of the employees. However, it probably can be regulated and controlled indirectly. The paper provides general understanding of this approach and Lithuanian experience in this area. The safety culture regulatory environment is reviewed through the analysis of three milestones: (1) safety culture of the regulatory authority itself; (2) existing difficulties and possibilities during regulation and supervision of licensee s safety culture; (3) improvement of the regulatory system, including the safety culture regulatory aspects, based on the possibilities provided by and duties derived from the international cooperation. 1. INTRODUCTION On the one hand it is quite easy to discuss about the importance of safety culture in the nuclear safety related activities, but on the other hand it is very difficult to deal with the safety culture itself, to measure, strengthen it or even to try to regulate it. Safety culture can be reviewed from different point of views. Based on the experience of the author this paper provides a short analysis of the legal and regulatory environment what can influence safety culture at nuclear power facilities. Examples will be provided from the Lithuanian experience. Safety culture, as an understanding, is based on the attitudes, beliefs, perceptions and other psychosociological features of the employees. Thus, these features cannot be strictly documented and measured. So, how the safety culture can be regulated and whether it can be regulated at all? It should be believed, that in that case if safety culture cannot be regulated directly, there should be possibilities to influence it in a positive way indirectly. There is also another important question. If we believe that safety culture at the nuclear power facilities can be influenced by the regulatory authority, what tools should be used in order to achieve a tangible result - legal requirements, guidance, international standards, routine inspections, discussions, seminars or other possible measures? Probably, there is no a simple answer and a standard tool. Different tools and measures should be used taking into account specific aspects of a separate case. Regulation and control of the safety culture is quite a complicated task. In order to fulfil this task in a competent way, we shall start from the safety culture of the regulatory authority itself. Regulation and control of the safety related activities shall be based on the proper understanding of the safety culture related issues and proper application of the carefully selected measures. 1

2 The aim of this paper is to analyse existing difficulties which may appear when we seek to regulate safety culture and to identify possible approach, methods and tool what can positively influence the safety culture related issues. 2. REGULATION AND SUPERVISION OF THE SAFETY CULTURE The high level of safety culture shall be ensured throughout the whole lifecycle of the nuclear power plant. Is it a right and good regulatory requirement? The statement itself is good. But is it clear? What does it means the high level of safety culture, what shall the organization do in order to ensure the high level of safety culture? And which organization or organizations are responsible for fulfilment of this requirement during pre-operational stages (which pre-operational stages?) of the nuclear power plant? This slogan type statement is probably good for the high level national legislation, but not for the regulatory requirement if this statement is not explained in much more detailed way. Based on the national legislation, cultural aspects and existing experience in a specific country, safety culture can be regulated in different ways. General requirements can be presented in the top level legislation. More detailed requirements can be presented in the mandatory regulatory documents. And much more detailed safety culture related aspects can be regulated through the non-mandatory guidance type documents. The IAEA standards can be used also as reference requirements or guidance. VATESI has started more active practical work with safety culture regulatory issues in 2002 when it was easy to notice motivation related problems of the Ignalina NPP due to the agreement between Lithuania and EU to shut down Ignalina NPP. It was a political decision and a precondition for accession of Lithuania to EU. It has affected about 5000 of Ignalina NPP employees with clear message that majority of these people in the nearest future will lose their jobs together with a very small possibility, taking into account specific aspects of the local community, to get a new job. The first Ignalina NPP unit had to be shut down in 2004 and the second in In 2004 VATESI has initiated a separate project to cope with this problem PHARE project No Support to VATESI for safety culture and organizational issues specific to the pre-shutdown phase of Ignalina nuclear power plant. In the frame of this project VATESI specialists together with the experts from Sweden, Finland, UK and Italy have investigated specific safety culture related issues, inspection was conducted at Ignalina NPP, seminar was organised for both VATESI and Ignalina NPP specialists, a separate brochure was issued and Guide for management of safety culture issues specific to the pre-decommissioning phase of the Ignalina nuclear power plant were prepared. Critical issues related to safety culture of Ignalina NPP during the pre-decommissioning phase were identified are illustrated in the figure below. 2

3 Issues related to maintaining a high level of Safety Culture during the pre-decommissioning phase of Ignalina NPP 1 The Guide provides description of these safety culture related issues and examples of proper efforts to deal with these issues. Moreover, the following tools, applicable for assessment of these safety culture related issues, were described in the document: Audit; Employee surveys, interviews; Employee surveys, questionnaires; Incident reporting and evaluation; Safety performance indicators; Involvement of employees in safety planning; Personnel statistics; External peer reviews; Periodic reporting. Examples are also provided in the Guide of good practice during application of these tools. It is an example of soft regulation of the safety culture related issues, which successfully was applied about 8-10 years ago. Nowadays, safety culture related regulatory requirements are concentrated in VATESI regulations BSR Requirements for Management System. The separate subchapter for safety culture defines a number of mandatory requirements, for example: - The management system shall enhance safety culture of the organization. In this regard the organization shall: (1) ensure proper understanding of safety culture issues; (2) provide necessary resources and measures to the employees based on the MTO 2 interrelations; (3) promote training in all levels of the organization; (4) systematically evaluate and promote the safety culture. - Management shall evaluate safety culture based on the employee surveys, monitoring, self-assessment results and effectiveness of the management system. NPP operating organization shall organise the employee surveys at least once per 3 years. - Safety culture monitoring criteria and evaluation methodology shall be prepared by licensee and agreed with VATESI. 1 Guide for management of safety culture issues specific to the pre-decommissioning phase of the Ignalina nuclear power plant, The document prepared in the frame of the PHARE project Abbreviation of the Man-Technology-Organization. 3

4 Safety culture mandatory requirements are also presented in the context of the management commitment, responsibilities of the management representative, scope of the management procedures, exchange of the information, requirements for contractors, management of changes, self-assessment, reporting requirements, etc. The Nuclear Safety Law of the Republic of Lithuania has only one statement regarding the safety culture. It states that nuclear facilities operating organizations and other licensees shall ensure high level of safety culture within the organization and its employees. The statement provides a legal basis to describe this understanding in a more detailed way and enables the regulatory authority to control the safety culture related activities. 3. SAFETY CULTURE WITHIN THE REGULATORY AUTHORITY Regulation and control of the safety culture related issues cannot be separated from the safety culture of the regulatory authority itself. It should be difficult to understand proper regulation of the safety culture issues if the regulatory authority is not in the position to ensure that the existing regulatory and control practice is based on the proper application of the safety culture understandings. One issue is to strengthen the safety culture within the nuclear facility, another issue is not to affect it negatively due to the unclear regulations or unnecessary bureaucratic burden, created by the incompetent regulatory authority. The following issues in this respect can be highlighted: 1) Competency of the regulatory staff. This is a basis for all activities of the regulatory authority. A basis for good results and a source, in case of low competence, of a negative influence to the safety culture of licensee and its employees. 2) Properly developed internal management system. It shall define clearly described processes, clear distribution of functions and responsibilities among the employees. The higher level of the management system, the lower possibility of disagreements and conflicts among the employees. Properly developed internal management system essentially contributes to the effectiveness of the regulatory authority and efficiency of its employees. 3) Clear, consistent regulatory documents. The quality of the regulatory documents has two important aspects. It has to be written in such a way that: (1) personnel of the licensee can clearly understand and act based on the explicit regulatory norms, (2) employees of the control institution can understand and be capable to properly apply the regulatory norms during the safety evaluation and inspection activities. 4) Properly oriented regulatory control. It is clear that in this area no space should be left for any corruption or private interest elements of inspectors. It can totally destroy the basis for safety culture. However, there are more realistic and frequent problems in this area related to the possible misinterpretation of the regulatory requirements during the inspection or safety evaluation activities. It is difficult to produce perfect regulatory requirements (especially for small countries). Some of the requirements are not explicit enough, some of the regulations do not cover all necessary safety related issues, and some of the regulations can be simply out-of-date. And it happens that inspector can identify that the licensee has violated a regulatory requirement which, actually, do not create any additional value to the safety assurance. Shall the regulatory sanctions be used in this case? In my personal opinion no. But the national legislation shall allow this type of flexibility. The regulatory decisions shall 4

5 not disorientate the licensee from activities important to safety towards activities important for escape from possible sanctions. It has to be mentioned that the above highlighted issues are interrelated. We cannot achieve good results in one area without having good basis in another. And we can hardly achieve good results in any of these areas, if motivation of the staff in the regulatory authority is below the necessary level. In this context the role of management is crucial. Capabilities, personal features, understanding of psychology and personnel management principals of all level managers are very important. Only properly motivated employees can work for a longer period of time within the regulatory authority and generate a high quality product in their work. Measures for motivation of the personnel can be different. Different personnel management theories are developed and most of them are also easily applicable to the nuclear power sector. 4. THE ROLE OF THE INTERNATIONAL COOPERATION FOR THE IMPROVEMENT OF SAFETY CULTURE One more problem or perhaps a challenge is the fact that the nuclear safety regulatory authority, within the national context, does not have an additional, higher level regulator, which could supervise and control the conduct of the nuclear safety regulatory and control activities. In this context the international cooperation plays an important role, even though no any international institution can be a real supervisor of the nuclear safety regulatory authority because full responsibility for regulation and control of nuclear safety related activities lies under the national jurisdiction. It should be noted that there is quite a wide range of the international enforcement measures that are intended to improve the nuclear safety regulatory system or resolve specific nuclear safety related problems worldwide. However, all these enforcement measures are soft in its nature and cannot resolve the existing problems in the problematic countries. It can be mentioned that there is no an effective control mechanism even within the Nuclear Safety Convention in order to ensure proper implementation of the obligations foreseen in this international instrument. However, international cooperation provides a variety of possibilities to strengthen the national nuclear safety regulatory institutions and increase effectiveness of the regulatory activities, including in the area of safety culture: 1) IAEA safety standards are very useful for preparation of the national regulatory documents. Some of the countries use these documents as reference requirements of guides. 2) IAEA missions are valuable for the assessment of the national regulatory system and compliance of it to the IAEA safety standards. 3) IAEA provides training possibilities and forum for exchange of existing experience that positively influence qualification of the regulatory staff. 4) EU support has provided an essential enhancement of the nuclear safety regulatory institutions within the PHARE and TACIS countries. The latest EU Instrument for Nuclear Safety Cooperation (INSC) extends the area of support or cooperation to practically any country which lacks resources and needs support within the development of the nuclear safety regulatory infrastructure. The safety culture is a priority area for the EU support and cooperation activities. 5) There are also other possibilities through the bilateral and multilateral cooperation among regulatory authorities and with other international institutions. 5

6 After the more detailed review of the international nuclear law and existing international cooperation in the nuclear safety area, it is possible to identify two main elements 3 which force the regulatory authority to create necessary regulatory system and conduct proper nuclear safety, including the safety culture, regulatory and control activities: I. The Internal Aim - implementation of the state national interest to ensure nuclear safety and to use international assistance in this area; and II. The External Pressure - responsibility of the state to fulfil its international obligations. This distinction allows to highlight the differences and links between these two elements and to allow proper application of the enforcement and/or stimulating measures that could increase safety culture in a specific regulatory authority. The enforcement and/or stimulating measures shall be combined and applied in a complex manner, using the existing possibilities of the Internal Aim and the External Pressure. 5. CONCLUSIONS Safety culture, probably, cannot be regulated directly, especially if we speak about psychosociological features of the employees. However, it definitely can be influenced indirectly through the safety culture related issues. When we speak about influence to the safety culture of the licensee, it should be understood that safety culture can be influenced positively or even affected negatively. And in this context competence of the regulatory authority is crucial. The following milestones provide basis for proper safety culture regulatory environment: Safety culture of the regulatory authority itself; Proper identification, regulation and supervision of the licensee s safety culture related issues; and Enhancement of the safety culture regulatory and control activities through the possibilities provided by and duties derived from the international cooperation. 3 Ovidijus Šeštokas. The Impact of International Law during the Development of Nuclear Power. Vilnius: Mykolas Romeris University,