Comments for the NRC’s I

Safety Culture Task Fo

David Lochbaum

Director, Nuclear Safety Proj

December 4, 2008
The NRC deserves credit for taking the has done in recent years regarding safeoperating reactor sites and bringing it iThe NRC also deserves credit for engagstakeholders as part of its internal safetforce efforts. 

Things are on track to a win-win-win o
 Corrective action program Credible Differing Professional Opinion proces

 “Protecting People and the Environment” – NR

people, too, and must be protected

 Non-Concurrence workaround Periodic surveys made publicly available Formal continuous improvement component Communication, communication, communicati
Corrective Action 

St

 Each NRC program office (e.g., NRR, R

NMSS, NRO, NIRS, Region 1, ..., Regioshould have maintain its own corrective process for problems within its area of r

 An overall sponsor, perhaps at the EDO 

should monitor the implementation of tcorrective action processes

 Each corrective action process should p

proper context for each problem identifanswering questions like “could this probeen found sooner?”, “are there related be fixed?”, etc.
St

 DPO program today is reminiscent of S

List yesterday – effort going into determnot matched by effort acting upon the determinations

 “Accepted” recommendations from DP

should be entered into corrective action tracked to expeditious completion

 ACRS should periodically, at least annu

the technical adequacy of a sampling of decisions and recommendation resolutio
Protecting NR

 NRC revised 10 CFR Part 26 to, among 

protect workers at nuclear power plantimpairment from fatigue by (a) limiting working hours, and/or (b) guaranteeing self-declare feeling fatigued

 Anecdotally, it seems that NRC staff lac

comparable protections and must put in long work weeks to meet schedules

 “Do as I say, not as I do” must be done  NRC must manage organizational grow

inherent “musical chairs” without compwork under sustained stress.
Non-Con

El

 Non-Concurrence process is a work-aro

facilitates non-resolution of nuclear safe

 There’s something fundamentally flawe

process allows subject matter experts to opposing something that management tlights – it smacks of the Challenger o-rinon-resolution and other examples of saquestions going unanswered

 The non-concurrence process must be e

revamped to achieve rather than avoid 
Perio

Forc

 Many of NRC’s licensees periodically su

work force – not just as part of the recowell-documented safety culture problemactively for the purpose of avoiding signculture problems

 NRC would reap equal benefits from pe

surveys of its work force

 Absolute quantification of safety cultur

time is difficult, whereas relative measu

 Making survey results public would be 

with NRC’s transparency goals
Continuous Imp

 By procedure, the charter of every augm

inspection team and special inspection tinclude a formal, documented evaluatioagainst the reactor oversight process to the scope, method and frequency of basinspections needs tweaking.

 By procedure, the agency’s actions in re

GAO, OIG, etc. recommendations shouformal, documented evaluation if proceare warranted so as to have staff find anissues instead of GAO or OIG.
Commu

 Failures to communicate form vacuums 

by rumors, innuendoes, and superstitio

 Rumors et al can create safety culture p

when no foundation exists and can turn culture problems into epidemics

 Proper communication is essential to na

between perception and reality and to afrustrating, non-productive effort mitigphantom problems