The Common Language of Nuclear Safety Culture (and how it affects you!) Tom Houghton Certrec Corporation The Problem: The Uncommon Language of Nuclear Safety NRC looks at inspection results using cross cutting safety culture components and aspects Industry looks at nuclear safety culture issues based on INPO Principles and Attributes Because of the different terminology to describe the same behaviors of interest confusion and wasted time and resources have resulted 2 Many Definitions of Safety Culture INSAG (1991) That assembly of characteristics and attitudes in organizations and individuals which establishes that, as an overriding priority, nuclear plant safety issues receive the attention warranted by their significance. INPO An organization s values and behaviors modeled by its leaders and internalized by its members that serve to make nuclear safety the overriding priority. 3 1
NRC Safety Culture Policy Statements Conduct of Operations expectations (1989) Full attention to safety matters Personal dedication and accountability of all individuals engaged in any activity bearing on nuclear plant safety Management fosters a safety culture and promotes a professional working environment in the control room, and throughout the facility, that assures safe operations Safety Conscious Work Environment (1996) Establish and maintain a SCWE 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 4 NRC Safety Culture 2000: The Reactor Oversight Process 5 Davis Besse Reactor Vessel Head Degradation Event 2002 Cavity in the top of the reactor pressure vessel head caused by corrosion from boric acid deposits Licensee root cause identified a weak safety culture Plant shut down February 2002; restart authorized March 2004 6 2
NRC Safety Culture 2006: Reactor Oversight Process Modified Safety culture definition 13 safety culture components Substantive Cross cutting Issues Requirements added to specifically focus on safety culture evaluation for plants with degraded performance (95002/3) Safety culture training provided to NRC inspection personnel and safety culture features added to selected NRC inspection procedures 7 Among INPO Activities SOER 02 4 Including requirement to conduct safety culture self assessment every other year Principles for a Strong Nuclear Safety Culture Organizational Effectiveness 8 Common Language Initiative Purpose of Common language: Industry (NSIAC) requested activity which, when implemented, will allow for consistency between the NRC and industry assessment activities Align on common language based on policy statement traits, ROP components, INPO principles, and IAEA characteristics 9 3
Common Language and NRC s Safety Culture Policy Statement Then commissioner Jaczko proposed a safety and security policy statement Suggested possible rule Builds on Conduct of Operations and SCWE policy statements Office of Enforcement lead Allowed stakeholders to write definition and traits of nuclear safety culture 10 The Policy Statement Was a Three Year Project With Extensive Public Participation 2008 2009 2010 2011 120 Day Public Comment Period 30 Day Public Comment Period Apr-Nov 2010: NRC Staff Participate in 18 Industry Meetings ROP Safety Culture Definition NRC Authored Safety Culture Definition Workshop Authored Safety Culture Definition Workshop Supported Safety Culture Definition ROP 13 Safety Culture Components NRC Authored 8 Safety Culture Traits Workshop Authored 8 Safety Culture Traits Workshop Supported 8 Safety Culture Traits + Questioning Attitude 11 Statement of Policy Includes safety culture definition and traits Considers interface of safety and security Recognizes diversity of regulated entities Applies to safety related vendors and suppliers Considers negative factors (e.g., incentive goals) Does not address implementation directly Commission did not feel a rule was appropriate 12 4
Statement of Policy 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 13 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 14 Traits 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. Traits Components Principles 15 5
Safety Culture Traits Leadership Safety Values and Actions Leaders demonstrate a commitment to safety in their decisions and behaviors Problem Identification and Resolution Issues potentially impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected commensurate with their significance Personal Accountability 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 harassment, intimidation, retaliation, 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 16 Safety Culture Policy Statement Tiers Safety Culture Definition Tier 1 Tier 2 Overarching definition applicable to all regulated entities Easy to understand Timeless Inclusive Safety Culture Traits High level descriptions of what constitutes a strong safety culture (Not necessarily all inclusive or completely applicable to each particular regulated entity) Contained in the Safety Culture Policy Statement Tier 3 Implementation Translating the Definition and Traits into lower level descriptions that are applicable to different regulated entities Programs, processes, procedures, practices, behaviors, etc. Details vary based on the nature of the regulated entity Complete the Common Language at the Attribute & behavior level (Tier 4) NRC Actions Regulated Entities Actions 17 Common Language Activities NEI, INPO and NRC agreed to work together, with other stakeholders, to create the third tier below the traits by merging the NRC components and INPO attributes Held workshops December 2011 and April 2012 Developed a common set of tier three attributes and definitions for use in NRC and INPO documents 18 6
Work Processes: The process of planning and controlling work activities is implemented so that safety is maintained. Work Management The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work. Design Margins The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense in depth, and safety related equipment. Documentation The organization creates and maintains complete, accurate and up to date documentation. Procedure Adherence Individuals follow processes, procedures and work instructions. 19 Comparison of INPO, NRC and Common Language INPO: 8 principles, 57 attributes NRC: 13 components, 37 aspects Common: 10 traits, 40 attributes 20 Workshop Participants Agreed an Additional Trait Was Needed Decision making: Decisions that support or affect nuclear safety are systematic, rigorous, and thorough Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate Conservative Bias: Individuals use decision making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop Accountability for Decisions: Single point accountability is maintained for nuclear safety decisions 21 7
Next Steps Continue work of NRC and stakeholders to finalize the Common Language document Third workshop is being scheduled for Fall 2012 to provide Tier 4 examples of behaviors NRC will update the Inspection Manual and inspector training NRC will not apply all of the attributes INPO will update its Principles document and evaluation materials Licensees will update training, NEI 09 07 procedures and assessments 22 Backup Slides 23 Four Key Elements of NEI 09 07 Data collection and analysis Nuclear Safety Culture Monitoring Panel Assesses data in holistic fashion to identify strengths and potential concerns Reviews emergent issues Reports to the Site Leadership Team Site Leadership Team Review site performance holistic view Site Response (policy, programs, training) Communication (internal, regulatory, external) External Oversight (Offsite Review Board, NRC, INPO) 24 8
25 The NEI 09 07 Process: Provides a method to identify nuclear safety culture issues and take action Provides a forum for perception issues (i.e., faint signals) to be addressed Is transparent Is well defined and repeatable Promotes management accountability for nuclear safety culture 26 Personal Accountability Standards Individuals understand the importance of adherence to nuclear standards. All levels of the organization exercise healthy accountability for shortfalls in meeting standards Job Ownership Individuals understand and demonstrate personal responsibility for the behaviors and work practices that support nuclear safety. Teamwork Individuals and workgroups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. 9
Leadership Safety Values and Actions Leader Behaviors Leaders exhibit behaviors that set the standard for safety. Roles, Responsibilities, and Authorities Leaders clearly define roles, responsibilities, and authorities to ensure nuclear safety. Strategic Commitment to Safety Leaders ensure plant priorities are aligned to reflect nuclear safety as the overriding priority. Change Management Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Leadership Safety Values and Actions Incentives, Sanctions and Rewards Leaders ensure incentives, sanctions, and rewards are aligned with nuclear safety policies and reinforce behaviors and outcomes which reflect safety as the overriding priority. Field Presence Leaders are commonly seen in working areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Constant Examination Leaders ensure that nuclear safety is constantly scrutinized through a variety of monitoring techniques, including assessments of nuclear safety culture. Resources Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. 29 Respectful Work Environment Respect is evident Everyone is treated with dignity and respect Opinions are valued Individuals are encouraged to voice concerns, provide suggestions, and raise questions. Differing opinions are respected. High level of trust Trust is fostered among individual and workgroups throughout the organization Conflict resolution Fair and objective methods are used to resolve conflict 10
Decision making: Decisions that support or affect nuclear safety are systematic, rigorous, and thorough Consistent Process Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate Conservative Bias Individuals use decision making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop Accountability for Decisions Single point accountability is maintained for nuclear safety decisions Questioning Attitude Nuclear is Recognized as Special & Unique Individuals understand that complex technologies can fail in unpredictable ways Challenge the unknown Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Challenge assumptions Individuals challenge assumptions and offer opposing views when they think something is not correct. Avoid Complacency Individuals recognize and plan for the possibility of mistakes, latent issues, or inherent risk, even while expecting successful outcomes. Human Performance Individuals are aware of and follow human performance standards Continuous Learning Operating Experience The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Benchmarking The organization learns from other organizations to continuously improve knowledge, skills, and safety performance. Self assessments The organization routinely conducts self critical and objective assessments of its programs, practices and performance. Training High quality training maintains a knowledgeable workforce and reinforces high standards for maintaining nuclear safety. 11
Problem Identification and Resolution Identification The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Evaluation The organization thoroughly evaluates issues to ensure that problem resolutions and solutions address causes and extent of conditions, commensurate with their safety significance. Resolution Resolution The organization takes effective corrective actions to address issues in a timely manner, commensurate with their safety significance. Trending The organization periodically analyzes information from the corrective action program and other assessments in the aggregate to identify adverse trends or conditions. Environment for Raising Concerns SCWE Policy The organization effectively implements a policy that supports individual rights and responsibilities to raise safety concerns, and does not tolerate harassment, intimidation, retaliation, or discrimination for doing so. Alternative Process for Raising Concerns The organization effectively implements a process for raising and resolving concerns that is independent of line management influence. Safety issues may be raised in confidence and are resolved in a timely and effective manner. Work Processes Work Management The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work. Design Margins The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense in depth, and safety related equipment. Documentation The organization creates and maintains complete, accurate and up todate documentation. Procedure Adherence Individuals follow processes, procedures and work instructions. 36 12
Effective Safety Communication Expectations Leaders frequently communicate and reinforce the expectation that nuclear safety is the organization s overriding priority. Work Process Communications Individuals incorporate safety communications in work activities. Basis for Decisions Leaders ensure that the bases for operational and organizational decisions are communicated in a timely manner Free Flow of Information Individuals communicate openly and candidly, both up, down, and across the organization, and with oversight, audit, and regulatory organizations. 13