NMSS Safety Cultur

Pilot Workshop 

Amy M. SnyderOffice of Nuclear Material Safety and Safeguards (NMSS)Division of Fuel Cycle Safety and Safeguards (FCSS)Fuel Manufacturing Branch (FMB)

June 19, 2008
Topics

• Background

• Information Gathering Activities and 

Insights

• Draft Pilot Options• Stakeholder Input• Schedule
Background

• NRC’s Position on Safety Culture• Objectives/Scope• Safety Culture Components • Schedule
Background (continued)

NRC’s Position on Safety Culture

Safety Culture- “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.”
Background (continued)

NRC’s Position on Safety Culture

•Licensees should support a safety 

culture. 

•NRC will not regulate a licensee’s 

safety culture.
Background (continued)

Pilot Objective• Determine how to enhanc

current Fuel Cycle InspecOversight Program for adsafety culture.

-Knowledge Transfer-Lessons Learned
Background (continued)

Pilot Scope• Fuel Fabricatio• Other Material • Two Phases
Background (continued)

13 Safety Culture Components

• Decision making• Resources• Work Control• Work Practices• Corrective Action Program• Operating Experience• Self and Independent 

Assessments

• Environment for Raising 

Concerns

• Preventing, Detec

Mitigating PercepRetaliation

• Accountability• Continuous Learn

Environment

• Organizational Ch

Management

• Safety Policies
Information Gathering (continued)

Insights
Information Gathering (continued)

• FCSS inspection program 

document

• Review of FCSS inspection 

procedures (~50) 

• Event Reports (40)• Generic Communication (60)• Staff interviews (~35)• External interviews (~50)• Site visits (2 sites, 2 days/ea.)
Information Gathering (continued)

Insights - Safety Culture Components• All safety culture components are implicitly 

addressed in FCSS regulatory oversight:

• programmatic documents • procedural documents 

• not explicitly defined or referenced as safety culture components• Some occur in multiple procedures

• Level of depth of coverage - varies• Guidance - varies
Information Gathering (continued)

Insights - Safety Culture Components• License

–

• Some safety culture components are implicitly 

addressed in licenses but not consistently

• Terminology 

–

• Safety culture component related terms were not always familiar to interviewees, although concepts wfamiliar.
Information Gathering (continued)

Insights – Programs• Routine Inspections – no programmatic mechanism to 

document most information related to safety culture components 

• Reactive Inspections – provides greater focus for 

information related to safety culture components than routine inspections.

• License Performance Review – no explicit guidance 

addressing safety culture components.
Information Gathering (continued)

Insights – Programs (continued)• Event Reporting – causes not described in enough de

to assess safety culture component contributors.

• Enforcement –several decisions points are directly rel

to several safety culture components, but not called ousuch.

• Generic Communication – level of coverage

varies.
Information Gathering (continued)

Insights – Site Visits• Safety Culture – applies to all safety functions, progra

and processes. 

• Programs and Processes Related to Safety Culture 

Components – exist, but vary in scope and formality

• Safety Culture Components

–

•apply to fuel cycle facilities•comprehensive 
Information Gathering (continued)

Considerations to Inform Decision Makin• Identify an approach considering different types of licensees (Pa

Part 40, Part 76).

• Develop training for inspectors for the pilot (depending on opti

selected)

•how to use the safety culture components •how to document•how to trend/assess information •how to communicate results

• Involve stakeholders –

•Mechanisms for engaging stakeholders•Orientation for Pilot licensees
Draft Pilot Options

1. No Action2. Explicitly Apply Safety Culture Components within 

Current Inspection and Assessment Program

3. Develop and Implement a Separate Safety Culture 

Inspection and Assessment Procedure

4. Apply Safety Culture Components only in Reactive 

Inspections

5. Develop and Implement a More Comprehensive 

Integration of Safety, Security, and Safeguards Cultu

in the Areas of the Revised Inspection and Assessmen

Process and the Licensing and/or Rulemaking Proces
Draft Pilot Options (continued)

1. No ActionPros: The current Fuel Cycle Inspection a

Assessment -

• Program applies oversight to areas related to safety 

culture components, including licensee corrective aprograms.

• Framework identifies trends in a licensee’s safety 

performance and allows inspectors to act accordingaddress safety issues promptly.
Draft Pilot Options (continued)

1. No ActionCons:• Not responsive to the Commission direction to consider the on

assessment of safety culture components of the ROP and the FCycle Facility Pilot and their potential applicability to other NRlicensees.

• Does not use stakeholder input effectively to address safety cu• Does not take advantage of insights gained from the Reactor 

Oversight Process (ROP) on safety culture

• Does not take advantage of inspection and program insights fr

Phase I NMSS Safety Culture Pilot Efforts.

• Safety culture components are not consistently applied through

the current Fuel Cycle inspection and assessment program.
Draft Pilot Options (continued)

2. Explicitly Apply Safety Culture 

Components within the Current Inspectiand Assessment Program

• Modify the safety culture component definitions at th

aspect (example) level, as needed, so that they are mo

specific to fuel cycle facilities;

• Assess potential violations for safety culture compon

contributors.

• Modify the assessment process to address issues 

associated with safety culture components and determappropriate actions.
Draft Pilot Options (continued)

2. Explicitly Apply Safety Culture 

Components within the Current Inspectioand Assessment Program

Pros:• Within the current Fuel Cycle inspection and assessment framewo• Expands insights on performance in areas important to safety cultu

and in timeliness to detect safety performance decline earlier.

• Adds predictability and transparency to Fuel Cycle inspection and 

assessment program by explicitly and consistently applying safety culture components.

• Takes advantage of lessons learned (ROP, international, etc.)• Allows for the effective use of stakeholder input.
Draft Pilot Options (continued)

2. Explicitly Apply Safety Culture 

Components within the Current Inspectand Assessment Program

Con:• Incorporating the safety culture components in the fu

cycle environment, in a more formalized way, maybe challenging and may be different for fuel cycle facili
Draft Pilot Options (continued)

3. Develop and Implement a Separate Safety 

Culture Inspection and Assessment Procedure

• Modify the safety culture definitions at the aspect 

(example) level, as needed, so that they are more speto fuel cycle facilities;• Develop criteria related to safety culture componeinspection procedure that inform the assessment and enforcement processes.• Incorporate safety culture components in a safety culture inspection temporary instruction that would applied as a routine inspection procedure in the Pilo
Draft Pilot Options (continued)

3. Develop and Implement Separate Safety Cul

Inspection and Assessment Procedures

Pros:• Efficiently enhances the inspection and assessment program, w

regard to safety culture, into one inspection and one assessmentprocedure.

• Is responsive to the Commission direction to consider the ongoi

assessment of safety culture components of the ROP and the FuCycle Facility Pilot and their potential applicability to other NRlicensees.

• Should improve NRC’s ability to detect weaknesses prior to vio• Allows for the effective use of stakeholder input to address safeculture for all NRC licensees, including fuel cycle licensees.
Draft Pilot Options (continued)

3. Develop and Implement a Separate Safe

Culture Inspection and Assessment Procedure

Cons:• Could be misinterpreted as regulating safety culture.• Requires additional considerations, such as how to ass

safety culture component deficiencies found through thuse of such a procedure.
Draft Pilot Options (continued)

4. Apply Safety Culture Components only in 

Reactive Inspections

• Apply safety culture components only to reactive inspections.• Modify the safety culture definitions at the aspect (example) leve

needed, so that they are more specific to fuel cycle facilities.

• Assess violations for safety culture component contributors in fin

from reactive inspections only.

• Modify the assessment process to address issues associated with 

culture components and determine appropriate actions for reactivinspections.

• Incorporate safety culture components for the Pilot to “safety cul

inform” the FCSS inspection and assessment program 

that address reactive inspections only.
Draft Pilot Options (continued)

4. Apply Safety Culture Components only in 

Reactive Inspections

Pros:• Focus on safety culture components during significant safety, secur

safeguards events to inform the cause analyses.

• Is responsive to the Commission direction to consider the ongoing 

of safety culture components of the ROP and the Fuel Cycle Facilit

their potential applicability to other NRC licensees.

• Could be applied within the current inspection and assessment fram

• Allows for the effective use of stakeholder input to address safety c

all NRC licensees including fuel cycle licensees.
Draft Pilot Options (continued)

4. Apply Safety Culture Components only in 

Inspections

Cons• Reactive inspections occur infrequently; NRC attention to safety c

too late to prevent significant safety, security, or safeguards events deterioration.

• Does not take advantage of insights gained from the ROP on safet

initiative during routine inspections.

• Does not take advantage of insights from Phase I of the NMSS Sa

Pilot for routine inspections.

• Less opportunity for NRC to expand insights on safety, security, o

performance related to areas important to safety culture and timely 

detection of performance decline.
Draft Pilot Options (continued)

5. Develop and Implement a More 

Comprehensive Integration of Safety, Security, and Safeguards Culture

...

In the areas of the:• Revised inspection and assessment process• Licensing and/or Rulemaking processes
Draft Pilot Options (continued)

5. Develop and Implement a More 

Comprehensive Integration of Safety, Security, and Safeguards Culture 

...

Pros• Is responsive to the Commission direction to consider 

ongoing assessment of safety culture components of tROP and the Fuel Cycle Facility Pilot and their poten

applicability to other NRC licensees.

• Provides the most comprehensive consideration of sa

security, and safeguards culture, including managememeasures needed to ensure the availability and 

reliability of Items Relied On For Safety.
Draft Pilot Options (continued)

5. Develop and Implement a More 

Comprehensive Integration of Safety, Security, and Safeguards Culture

...

Pros (continued)• Recognizes the importance of safety culture from the 

beginning of the process to encourage licensees and applicants to consider it well before beginning operatof a particular nuclear process and before adverse performance trends.

• Allows for the effective use of stakeholder input in 

developing the regulatory framework for safety, 

security, and safeguards culture.
Draft Pilot Options (continued)

5. Develop and Implement a More 

Comprehensive Integration of Safety, Security, and Safeguards Culture 

...

Cons• Goes considerably beyond the safety culture initiative 

under the ROP.

• Could be seen as too invasive affecting the managem

prerogative of licensees and an unjustified regulatory burden.
Stakeholder Input

Draft Pilot Options 1. Comments on draft pilot options pros and cons? 

• Workshop discussion today• Written comments by July 21 (see contact information on next slide).

2. New options? 3. Will be provided for management review as they 

are considering options

Workshop Discussion:

• Summarized and placed on website within 30 days.
Contact Information

Amy M. SnyderNMSS Safety Culture Pilot LeadUS NRCWashington, D.C. 20555MS EBB2-C40M301 492-3225Fax 301 492-3359Amy.Snyder@nrc.gov
Schedule

Phase I Information Gathering (5/07 – 6/08) (~1 year)

NRC Document ReviewInterview NRC Staff (2/08)Site Visits (2/08)Data Evaluation (3/08)Data Report (6/08)Communicate Results to Stakeholders (6/08)

Phase II Pilot Implementation and Assessment(6/08 – 6/10) (~2 

Develop Implementation Strategy (06 – 08/08)- Based on Results of Phase I- Stakeholder Input

Develop Technical Instructions (TI) 8/08 -10/08

-Communicate/Concurrence-Train Staff on TI 10/08 -12/08 - Implement TI (~ 1year)

Evaluate and Refinement (3 months or more)Communicate Results/ConcurrenceModify Program Documents
Questions