1

 Version 3 - Revised 3/11/09 

to include additional comments 

Safety Culture Policy Statement (Safety & Security) Comments

I. Mr. James D. Boyd 

California Energy Commission 

Commissioner and Vice Chair 

State Liaison Officer to the 

U.S. Nuclear Regulatory Commission 

Introduction 

The State of California appreciates the opportunity to comment on the U.S. Nuclear 

Regulatory Commission’s (NRC) development of a policy statement on safety culture 

and security culture and the opportunity to participate in the public workshop on 

February 3, 2009.1

 One of the most important factors affecting plant safety is maintaining 

a robust safety culture at each plant. We strongly support NRC’s efforts to enhance the 

safety culture and the safety conscious work environment at nuclear power plants. 

NRC’s efforts to improve the safety culture at nuclear power plants stem from NRC’s 

direction, based on the Davis-Besse experience, to improve the NRC Reactor Oversight 

Process (ROP) to more fully address safety culture, ensure that inspectors are properly 

trained, and develop a process for determining the need for a specific safety culture 

evaluation of plants in a degraded cornerstone. Since the Davis-Besse event, NRC staff 

implemented several improvements to the ROP that relate to safety culture. In addition, 

NRC developed a web-based training program for inspectors and managers based on 

the Columbia Space Shuttle accident which demonstrated the importance of maintaining 

a questioning attitude toward safety and how shortcomings in an organization’s safety 

culture can lead to technological failures. 

California has two operating nuclear power plants – Diablo Canyon and the San Onofre 

Nuclear Generating Station (SONGS) -- which account for 12% of the state’s electricity 

generation. Their safe and reliable operation is an ongoing concern for California. Our 

comments below on the proposed safety culture policy statement are based, in part, 

upon two major reports on these plants which the California Energy Commission 

completed in 2008.2

 These reports, as required by California Assembly Bill 1632, 

assessed the potential vulnerability of Diablo Canyon and San Onofre to a major 

disruption due to a seismic event or plant aging and assessed the impacts of such a 

disruption on system reliability, public safety, and the economy. These reports included 

an examination of the safety culture programs at Diablo Canyon and San Onofre, as well 

as at Palo Verde. 

 

1

 NRC defines “safety culture” as the “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.” 

2 An Assessment of California’s Nuclear Power Plants: AB 1632 Report, November 2008, CEC-100-2008- 

009- CMF, California Energy Commission and AB 1632 Assessment of California’s Operating Nuclear 

Plants: Final Consultant Report, October 2008, CEC-100-2008-005-F, California Energy Commission.
 2

GENERAL COMMENTS 

1. Although NRC has taken a proactive approach to improve its Reactor 

Oversight Process (ROP), improvements are still needed in assessing the 

safety culture and address shortcomings at nuclear power plants. 

NRC has improved its Reactor Oversight Process (ROP), which began in 2000, although 

continued efforts are needed to address shortcomings, particularly improving NRC’s 

ability to identify and address early indications of declining plant safety performance.3

NRC has undertaken a major initiative to improve its ability to address the safety culture 

at nuclear power plants. NRC has increased its focus on crosscutting safety issues – 

issues that comprise many of the elements of safety culture—and has developed new 

requirements under the ROP to more directly assess safety culture at poorer performing 

plants.’ The Davis-Besse incident in 2002 (the unexpected discovery of a football-sized 

hole due to corrosion in the reactor vessel head) represents a significant breakdown in 

safety standards at all levels and exposed a failure by the NRC to assure that plants are 

operated safely. Just before the discovery of the damaged reactor-vessel head, the 

Davis-Besse plant received the highest ratings possible in the NRC ROP, with “green” 

ratings in all 17 performance indicators. After reviewing the Davis-Besse incident, the 

NRC Inspector General found that: 

“The fact that (the licensee) sought and the [NRC] staff allowed Davis-Besse to operate 

past December 31, 2001, without performing these inspections was driven in large part 

by the desire to lessen the financial impact on (the licensee) that would result in an early 

shutdown.”4

NRC conducted a “lessons learned” review of the Davis-Besse event and published a 

report with recommendations and action plans including substantive changes to the 

ROP and NRC’s internal procedures. However, the Keystone Center’s Nuclear Power 

Joint Fact-Finding Report in June 2007 concluded that some members of their Project 

Team maintained that these “lessons learned” have not addressed a fundamental 

weakness in the regulatory process itself regarding the inclination of some NRC staff 

and Commissioners “to favor the financial interests of the nuclear power industry, 

sometimes at the expense of public health and safety.” 

In addition, the NRC uses an approach that involves “cross-cutting” issues that may be 

hidden in a complex array of the plant “performance indicators”. The concern is that 

NRC requires a determination of “substantive cross-cutting issues” to trigger special 

NRC enhanced safety culture investigations. However, there may be a single DavisBesse-type phenomenon occurring at a plant that does not lend itself to being identified 

as a “substantive cross-cutting issue”. 

The NRC should develop clear expectations for an adequate safety culture at nuclear 

power plants. These NRC expectations should be supported by a strong enforcement 

and/or incentive program to help ensure that these expectations are being met.

 

3

 U.S. Government Accountability Office, “Oversight of Nuclear Power Plant Safety Has Improved, but 

Refinements Are Needed”, September 2006, GAO-06-1029, p. 5. 4

 NRC Inspector General, “NRC’s Regulation of Davis Besse Regarding Damage to the Reactor Vessel 

Head.” Dec. 30, 2002. P. 23. 
 3

Similarly, we believe that it is essential that NRC continue to evaluate the adequacy of a 

safety conscious work environment at plants.5

 The nuclear industry has proposed that 

sites conduct safety culture self-assessments every two years. However, we believe that 

safety culture assessments should be conducted at more frequent intervals than every 

two years. If a Davis-Besse-type phenomenon is developing at a plant that could 

compromise plant safety, routine and frequent assessments are necessary in order to 

avoid a more serious problem that might jeopardize plant safety. 

2. NRC’s pro-active safety culture assessment at nuclear power plants should 

not be eliminated. 

During the public workshop on February 3, 2009, the nuclear industry and Southern 

California Edison proposed relying upon plant self-assessment and eliminating NRC’s 

pro-active safety culture assessments at nuclear power plants. However, the DavisBesse discovery in 2002, the guards found sleeping while on duty at the Peach Bottom 

plant in 2007, safety culture problems at plants including Palo Verde and San Onofre, 

and the control room operators found sleeping at the Peach Bottom plant in 1987 

highlight the importance of a strong independent safety culture oversight program rather 

than relying on plant self-assessments. 

The experience at Palo Verde indicates that safety culture issues can be very far 

reaching and difficult to address. The Energy Commission’s 2008 report concluded that 

self assessment at Palo Verde was insufficient to correct safety culture issues, and that 

problems have persisted there for years after they were originally identified in 2004. It is 

not clear how effective Arizona Public Service’s safety culture action plan will be at 

correcting the safety culture problems at Palo Verde and the Arizona Corporation 

Commission expects Palo Verde to remain in the Multiple/Repetitive Degraded 

Cornerstone category for years to come. Self assessment in some plants may be 

insufficient to proactively identify problems and deal with lapses in safety culture before 

a serious safety problem develops. 

Therefore, we conclude that NRC’s pro-active safety culture assessment at nuclear 

power plants should not be eliminated. Although we support industry’s attempts to 

improve the self assessment process at plants, we do not agree that a self-assessment 

process should replace the parallel NRC process for safety culture assessments or 

result in NRC not performing proactive safety culture assessments. Instead, the industry 

self-assessment process should complement NRC oversight. 

 

5 NRC defines a Safety Conscious Work Environment and an environment in which employees are 

encouraged to raise safety concerns, are free to raise concerns both to their own management and to the 

NRC without fear of retaliation, where concerns are promptly reviewed, given the proper priority, and 

appropriately resolved, and timely feedback is provided to those raising concerns. 
 4

3. NRC should continue to strengthen oversight and assessment of the adequacy 

of the safety culture and safety conscious work environment at reactors.

As reported in the Keystone Center’s Nuclear Power Joint Fact-Finding Report, while 

there is agreement that a strong safety culture is necessary to ensure the protection of 

public health and safety, not all believe that it is strong enough at all the U.S. nuclear 

plants.6

 There is some concern that there are “outlier” plants that lack a strong safety 

culture. Davis-Besse is cited as the example of safety culture problems due primarily to 

organizational and leadership issues. Much of NRC’s focus is on identifying plants with 

poorer scores in the ROP. NRC’s response is to increase the amount of inspection and 

evaluation (increase above the base level of 2,000 inspection hours each year) at those 

plants with poorer scores. 

The Keystone Report concluded that there is a high degree of disagreement as to how 

appropriately and effectively the NRC has responded to safety issues. Although there 

was broad agreement as to the capability and dedication of the NRC working-level staff, 

there was no such agreement regarding the Commission and the senior management 

staff. While some of the Keystone Report Project Team believed that most 

Commissioners, responding in part to Congressional oversight, have emphasized 

industry economic and promotional interests inappropriately in relation to public 

protection, others believed that the NRC has made significant strides in balancing the 

public interest in nuclear safety with the operational interests of the industry.7

4. NRC should continue to strengthen its oversight of the safety culture and 

safety conscious work environment at California nuclear power plants.

Although Diablo Canyon Nuclear Power Plant has not received any significant 

enforcement actions from the NRC since 1995, there has been an increase in safety 

allegations regarding Diablo Canyon. For example, the San Luis Obispo Mothers for 

Peace (MFP) filed an allegation in April 2008 saying that it had received information from 

Diablo Canyon employees reporting that workers perceive a high likelihood of 

managerial retaliation if they raise safety concerns. In addition, MFP alleged that 

workers have lost trust in the Employee Concerns group and that PG&E has skirted 

qualifications requirements in hiring new supervisors and managers. In December 2008, 

PG&E employees picketed at Diablo Canyon to call attention to what they claim are 

unsafe working conditions. 

NRC over the past decade has issued several enforcement actions and notices of 

violations for operations at the San Onofre Nuclear Power Plant. Among the findings, the 

NRC identified crosscutting aspects of human performance, problem identification and 

resolution, and work practices as safety culture issues. As a result of several incidents 

and violations at San Onofre, there has been increasing concern about an underlying 

 

6

 Keystone Center, Nuclear Power Joint Fact-Finding Report, 2007. 7

 Examples provided in the Keystone Report of the NRC inappropriately emphasizing industry economics 

and promotional interest over public health included the NRC assessment of its own safety culture in 2002 

which found that slightly more than half of its employees feel that it was “safe to speak up” in the NRC, an 

improvement from a similar survey done four years earlier. Also, former Senator Pete Domenici in his book 

claimed that by threatening to cut its budget by one-third during a 1998 meeting with the then NRC chair, he 

successfully persuaded the NRC to make changes to its regulatory approach which some consider 

weakened NRC safety oversight. In addition, Davis – Besse received the top rating in all 18 categories of 

NRC’s performance owner/operator rating system just before it was discovered to have a hole in the 

pressure vessel head. 
 5

problem with safety culture at SONGS. Both NRC and the Energy Commission have 

expressed concern to SCE regarding reports of lapses in the safety culture. In January 

2008, the NRC ordered SCE to undertake a series of tasks to improve SONGS safety 

culture. 

In September 2008, the NRC noted new instances of employees not being provided with 

adequate procedures or work instructions and of corrective action programs failing to 

address the root causes of problems. Concerned with the persistence of these problems, 

the NRC requested that SCE address these safety culture issues at a public meeting 

with the NRC. 

NRC should continue to strengthen its oversight in reviewing the safety culture and the 

safety conscious work environment at California’s nuclear power plants. This oversight 

should include continued NRC review and assessment of plant worker safety 

allegations. 

5. NRC oversight of security measures at commercial nuclear power plants may 

need improvement. 

The Government Accountability Office has posed questions about the NRC’s oversight 

of security measures at commercial nuclear power plants. GAO found that NRC 

inspectors often used a process involving “non-cited violations” that may have minimized 

licensee attention to security problems.8

 Also, NRC has no routine, centralized process 

for collecting, analyzing, and disseminating security-inspection findings that may be 

common to other plants. GAO noted potential issues in NRC security inspections; for 

example, a lapse in the protection of information about the planned scenario for a mock 

attack may have given the plant’s security officers knowledge that allowed them to 

perform better than they otherwise would have.9

NRC Commissioner Gregory Jaczko noted his concern that NRC has not yet completed 

a rulemaking to add new security requirements for nuclear power plants.10 We concur 

that it is important that this rulemaking be completed to strengthen security requirements 

for currently operating reactors and new reactors. 

6. Safety culture assessments should be a major component of plant license 

renewal reviews and evaluations. 

NRC plant license renewal reviews currently emphasize the hardware and equipment of 

a plant and whether plant components, that are subject to age-related degradation, can 

continue to operate safely for an additional 20 years with license extension. We believe 

that the safety culture at a plant, the safety conscious work environment, and the 

adequacy of plant maintenance programs are also critical to the safe and reliable 

operation of a plant for an additional 20 years. Therefore, an evaluation of the adequacy 

of a plant’s safety culture and safety conscious work environment should be included in 

license renewal reviews. 

 

8

 See Nuclear Regulatory Commission: Oversight of Nuclear Power Plant Safety Has Improved, But 

Refinements are Needed. September 2006. GAO-06-1029. 

9 http://www.gao.gov/new.items/d06388.pdf

10 Testimony before the Senate Committee on Environment and Public Works, Subcommittee on Clean Air 

and Nuclear Safety, February 28, 2008.
 6

In its 2008 Integrated Energy Policy Report, the Energy Commission recommended that 

the California utilities’ license renewal feasibility studies for the California Public Utilities 

Commission should address the adequacy of the plants’ maintenance programs and 

safety cultures.11 In addition, in light of the critical importance of the safety culture at 

nuclear power plants to help ensure their safe and reliable operation, the Energy 

Commission has asked the utilities to report to the Energy Commission on their safety 

culture programs as part of the Energy Commission’s 2009 Integrated Energy Report 

process. 

ANSWERS TO SPECIFIC QUESTIONS 

1. How should the Commission communicate a common understanding of the 

components of safety/security culture? 

The NRC should provide clear guidelines and expectations for the safety/security culture 

at nuclear power plants and for safety/security culture assessments. The Resident 

Inspector, to the extent these guidelines provide more detail than current inspector 

guidelines, should include them as a component of his/her inspections and oversight at 

the plant. The plant owner/operator should be required to follow these guidelines and 

meet NRC’s safety culture and security culture expectations. 

2. Should there be new regulatory requirements specifically addressing safety culture? 

If so, please explain. Or, how should safety culture insights to be used, e.g., to inform 

regulatory response to findings or violations within existing requirements? 

Yes. The NRC should clearly describe in new regulatory requirements its safety culture 

and safety conscious work environment expectations for power plants and explain how a 

plant’s performance in meeting these expectations will be evaluated and enforced. 

In addition, new regulatory requirements should address nuclear plant license renewal 

reviews. NRC should require a thorough evaluation of a plant’s safety culture and safety 

conscious work environment during plant license renewal reviews. Currently plant 

license reviews focus on plant hardware and equipment and age-related plant 

component degradation. However, the adequacy of a plant’s safety culture is also a 

significant factor in determining whether a plant can safely operate an additional 20 

years. 

3. Given the range of NRC licensees and certificate holders, how can the Commission 

best communicate its expectations regarding the scope of programs and processes 

to address safety/culture in a manner that appropriately considers the different 

licensee and certificate holders environment? 

Similar to NRC’s post-9/11 security directives that were issued by each general licensee 

category, NRC might consider issuing enhanced safety culture and security culture 

expectations and directives to each major licensee category. 

 

11 California Energy Commission 2008, 2008 Integrated Energy Policy Report Update, , CEC-100-2009-008-

CNF, 
 7

4. In the following situations the NRC may/or will request a licensee to perform a safety 

culture assessment (licensee self-assessment, independent assessment, or a thirdparty assessment): 

 a. The same substantive cross-cutting issue had been identified in three 

consecutive assessment letters (generated from assessments conducted at 6 

month intervals); 

 b. A 95002 inspection (inspection for One Degraded Cornerstone or Any Three 

White Inputs in a Strategic Performance Area) that confirmed the licensee had 

not identified a safety culture component that either caused or significantly 

contributed to the risk-significant performance issue that resulted in the 

supplemental inspection. 

 c. A plant enters Column 4 of the Action Matrix. 

 Under what other situations should the NRC consider requesting that a licensee 

perform a safety culture assessment? 

NRC should require safety culture assessments as part of license renewal applications 

and evaluations. 

5. What additional safety culture related ROP changes could help the NRC to improve 

the focus of NRC and licensee attention on site safety culture issues? 

NRC should include in the ROP specific safety culture and security culture directives and 

expectations for nuclear power plants including how periodic reviews will be performed 

and how these expectations will be encouraged through incentives and/or penalties. 
 8

II. Mr. Ronald Teed 

Director – Fleet Nuclear Security 

Constellation Energy 

Safety Culture Policy Statement Stakeholder Workshop 

Proposed Questions for Safety/Security Issue 

Key question: 

Should NRC combine its expectations in the policy statement for safety culture and 

security culture or should NRC keep its expectations separate? 

a. The policy statement for safety culture should be a single statement that 

addresses safety culture expectations for all personnel with unescorted access to 

a nuclear power station. Security should not be addressed separately within that 

single statement. Security forces are in most cases fully integrated into the plant 

processes, procedures, and expectations for safe operation and protection of 

public health and safety. Significant progress has been made in recent years to 

ensure security personnel have the same expectations regarding a nuclear 

safety culture that other plant workers involved in safety related activities have. 

They have the same processes available to report nuclear safety issues or 

concerns. These expectations and processes are routinely reinforced through 

training and refresher materials. To address security in a separate policy or 

within a single policy may only provide negative reinforcement that security is 

held to a different standard and current proven processes are not sufficient. This 

would be an undesirable outcome. 

Sub-questions:

1. Within organizations, one can think about safety and security in different ways. For 

example, safety may take precedence over security, security may take precedence 

over safety, or both may be treated equally. Different types of licensees, certificate 

holders and organizations have a variety of experiences and perspectives. How 

does your organization view the relationship or hierarchy between safety and 

security functions and decision making? 

a. Safety and security work together to provide protection of public health and 

safety. NRC regulations require integration to ensure they both remain effective 

across a wide range of normal and contingency events. Security works closely with 

station operations and ultimate authority and responsibility is given to the Operations 

Shift Manager to assure that both disciplines work together to assure nuclear safety 

is maintained during a contingency event. This is another reason to ensure that 

security is fully integrated into plant processes as they provide a uniform and 

controlled mechanism to maintain nuclear safety. 

2. While efforts to maintain safety and security have the same common goal of 

protecting public health and safety, there can be distinct differences in the approach 

used to achieve that goal and that may have competing outcomes. One example is 

how information is shared to mitigate risks, where increased sharing of information 

may contribute to maintaining safety, but presents increased security risks. What are 

other examples where efforts to maintain safety and security require different 
 9

approaches or result in competing outcomes that need to be addressed to achieve 

the desired outcome or goal? 

a. Meeting nuclear safety objectives and assuring security measures are 

maintained is not particularly difficult to manage. As the first sentence in this 

question states, they have the same common goal. The key is to integrate and 

manage processes as outlined in the answer to question #.1. Leaders at the 

stations recognize the importance of security in the safe operation of their plants 

and expectations are established that all plant disciplines work with security to 

assure work is well planned and executed without compromising security 

objectives. Similarly, security activities are planned and executed in a manner 

that doesn’t compromise the ability to conduct work and maintain nuclear safety. 

All personnel are expected to have a “security culture” as well as a “safety 

culture”. 

3. When resolving differences or conflicts while seeking to maintain safety and security 

— such as when managing risk, sharing information, planning work, correcting 

problems, etc. — and where changes or actions that are taken to address either a 

safety issue or a security issue could have an adverse effect on the other (i.e., 

security or safety, respectively); what challenges does your organization face? 

a. When issues arise that have the potential to negatively impact on either 

discipline, they are entered into the station’s corrective action system for 

resolution and to prevent recurrence. Although the corrective action program is 

the preferred, and in most cases the most effective, means to resolve potential 

conflicts, a variety of avenues are available to any individual that may wish to 

identify a issue or concern. Some of these include reporting the issue to their 

supervisor, reporting the issue to operations or plant leaders, utilizing the 

employee concerns program, and reporting the issue to NRC. If the individual 

raising the concern would prefer anonymity, several of these processes can 

accommodate it. 

4. What challenges or complexities arise when licensees and certificate holder’s work 

with contractors and vendors where the organizations either take different 

approaches to resolving conflicting outcomes when they seek to maintain safety and 

security or the organizations may balance the conflicting outcomes of efforts to 

maintain safety and security differently? 

a. The licensee is ultimately responsible for the safe and secure operation of the 

plant. Licensees are responsible to establish and enforce expectations related 

to nuclear safety and security. Contracts are established that contain these 

expectations and training and licensee oversight, is provided to assure that 

contractors and vendors meet station expectations. Oversight of contractors is 

provided by observation of work by licensee supervisors, QA surveillance, 

management observation tours, behavior observation programs, and security 

observations, among other methods. Contractors and vendors have access to 

processes and programs provided by the licensee or have equivalent processes 

to promote a nuclear safety culture. Issues are entered into the station corrective 

action program or reported through the other processes previously discussed. 
 10

5. What practices have been used to effectively address the conflicts to achieve the 

desired outcomes or goals? 

a. Use of the corrective action program, reporting an issue to a supervisor, reporting 

an issue to operations or plant leaders, utilizing the employee concerns program, 

and reporting the issue to NRC have all been successfully used to resolve issues 

and achieve desired outcomes. All of these processes are provided to 

individuals in training and periodically reinforced through refresher information 

and recurring training. Health of the programs is monitored by station 

management through surveys and audits. 

6. Given that there are several ways to think about safety culture and security culture 

within organizations, the NRC wishes to express a policy in a way that best furthers 

its goals of protecting the public and environment and ensuring the secure use and 

management of radioactive materials. If the above issues are viewed in terms of 

safety culture and security culture implementation, what benefits or challenges would 

licensees, certificate holders, Agreement States, or others foresee with a single 

policy statement? Two separate policy statements? 

a. See the answer to the key question. 

7. How can the NRC best express a policy that gives appropriate weight to safety 

culture and security culture across the range of licensees and certificate holders? 

Given the diversity among the licensees and certificate holders regulated by the NRC 

and the Agreement States, how should the policy statement address any differences 

in emphasis on safety and security at the different types of licensees and certificate 

holders? 

a. Diversity among licensees and certificate holders should not result in differing 

standards when it comes to maintaining a nuclear safety and security culture that 

protects the health and safety of the public. The policy should be written at a 

level that allows licensees to choose differing approaches to achieve the same 

objectives. Different approaches may be required for organizations of different 

sizes, management structures, regulatory requirements, site configurations, etc. 

However, the overarching objective of maintaining a strong safety and security 

culture can be met regardless of these differences if the policy is constructed in a 

manner that sets clear expectations for maintaining processes and procedures 

that promote a healthy nuclear safety culture, but does not prescribe 

methodology. 
 11

III. Mr. Jim Lieberman 

Regulatory and Nuclear Consultant 

I have reviewed the draft proposed Safety Culture Components. Thinking back on my 

more than twenty years of involvement in NRC inspection findings and enforcement 

actions between 1977 to 1999, many of the root causes of the findings can be traced 

back to aspects of the proposed safety culture components that were not met. In my 

view it is an excellent document. However, I would modify: 

 1) PIE to add the need for employees to be aware of and understand the processes for 

problem identification and that they be used. 

PIE1 – (low threshold/wide scope) Problem identification processes (e.g., raising 

issues to management, the corrective action program – CAP, self- and independent 

assessments, oversight groups, any alternative processes for raising concerns) are 

understood and used by employees, and have a low threshold and wide scope for 

identifying issues. Personnel identify issues promptly, completely and accurately, 

including fitness-for-duty, radiological, industrial, or chemical safety concerns, and 

nuclear safety and security issues. 

1) PR to add a provision addressing the tracking of concerns so that employees can 

know what is happening to concerns that are raised. 

PR1 – (timeliness) The licensee implements actions, in a timely manner, to address 

 safety/security issues and adverse trends (both of which may be identified from any 

source, such as the CAP, reviews of internal lessons learned and lessons learned by 

others, self- and independent assessments, input from oversight groups, or 

alternative processes for raising safety and security concerns and resolving differing 

professional opinions), commensurate with their significance and complexity. 

Concerns are tracked from initiation to closure in a way that employees can monitor 

the company’s treatment of their concerns. 

I do not believe that there should be a general regulatory requirement for safety culture. 

However, maintaining a robust safety culture is fundamental to successful operation and 

good regulatory compliance. A policy statement is warranted similar to the 1996 policy 

statement on safety conscious work environment. Since the root cause for many 

violations can be related to aspects of failure to consistently achieve a proper site wide 

safety culture, NRC should be monitoring licensees’ safety cultures. I recommend that 

NRC do this by documenting in inspection reports attributes of lack of a safety culture 

that appear to be root causes of violations. The standard letter should be asking 

licensees to address NRC findings as part of the response to the NOV pursuant to 

section 182 of the AEA. This would provide for a process to track NRC perspectives on 

the site’s safety culture and provide a mechanism for the licensee to dispute the NRC 

findings if warranted. 

While I do not support a general requirement for a safety culture, NRC does have the 

authority to order a licensee to adopt a program to improve its safety culture if based on 

sufficient violations with root causes that demonstrate the lack of a safety culture. NRC 

in the past has issued orders to licensees to address performance issues by requiring 
 12

actions tailored to the issues at the particular sites and should continue to do so when 

needed. 

I would treat safety and security together. Licensees’ employees involved in safety are 

diverse. Engineers, operators, mechanics, HP’s, EP’s, etc. Security staffs are just 

another group of employees. 
 13

IV. Mr. Robert Lommler 

Radiation Safety Officer 

 Illinois Emergency Management Agency 

Topic 1 Comment 

When I was in the military the combination of safety and security cultures was called 

surety. At various times I was part of the Chemical Weapons and Nuclear Weapons 

Surety Programs. The way expectations were addressed was a goal system. 

Expectation is a term a lawyer uses and not the people who deal with the day-to-day 

safe and secure use of radioactive material. Culture is a way of life. Creating an 

organization work environment that keeps people focused on safety and security is 

difficult in a recession where there is no assurance a job or company will exist the next 

day. Life is uncertain in this environment. The confidence to freely express safety and 

security concerns with the assurance of no adverse personnel action occurring is 

strongly lacking everywhere. 

Under such conditions and with its definite lack of experience, the NRC should 

concentrate on defining safety and security policies separately. Obvious conflicts should 

be avoided between the statements. A method of resolving conflicts in these policies 

found by licensees should be implemented and allow resolution at the lowest possible 

level, such as the Agreement State. 

Topic 2 Comment 

Sending an email with only a few days to comment definitely shows licensees that it is 

business as usual at the NRC. The NRC has increased our attention for all the wrong 

reasons by such an action. It demonstrates a lack of an overall safety and security 

culture at the NRC. Everything is in its own compartment based on materials use. 

Having regional meetings with materials licensees and other stakeholders would have 

indicated a more serious concern. The previous meetings appear to only address fuelcycle licensees at fuel-cycle meetings and not the bulk of the radioactive materials 

licensees that need addressed at this time. 

Topic 3 Comment 

I can only comment that the safety culture, at whatever location, should be part of a 

continuous improvement process. 
 14

V. Mr. Thomas C. Houghton 

 Nuclear Energy Institute 

 Director, Strategic Regulatory Programs 

 Nuclear Generation Division 

 On behalf of the nuclear industry, the Nuclear Energy Institute (NEI)1

 offers the following 

comments in response to the January 23, 2009 Federal Register Notice (FRN) (4260 

volume 74) regarding the development of an NRC Safety Culture Policy Statement. The 

industry appreciated the opportunity to participate with other stakeholders in the public 

meeting held February 3, 2009. This letter provides our response to the three key 

questions posed in the FRN, and enclosure (1) has more detailed comments, including 

our perspective on the revised safety culture components. 

1. Should NRC combine its expectations in the policy statement for safety culture and 

security culture or should NRC keep its expectations separate? 

The NRC should issue one policy statement on safety culture that incorporates 

expectations for security for all personnel with unescorted access to a nuclear power 

station. Industry efforts are underway to better integrate security officers into the plant 

processes, procedures and expectations for safe operation, and protection of public 

health, safety, and common defense and security. Significant progress has been made 

in recent years to ensure security personnel have the same expectations regarding a 

nuclear safety culture that other plant workers involved in safety-related activities have. 

They have the same processes available to report nuclear safety issues or concerns. 

These expectations and processes are routinely reinforced through training and 

refresher materials. To address security in a separate policy statement may only provide 

negative reinforcement that security is held to a different standard and current proven 

processes are not sufficient. This would be an undesirable outcome. 

2. How should NRC increase attention by licensees and certificate holders to safety 

culture in the materials area? 

In the area of fuel-cycle and byproduct materials licensees, we offer the following 

specific points. First, consistent with the position of the commercial nuclear power 

industry, there is general consensus among materials licensees that a single policy 

statement be drafted to address both safety and security. The policy should clearly state 

the Commission’s expectation that licensees and certificate holders ensure that an 

appropriate safety culture, that includes a security culture component, exists at each 

facility. This approach would reflect the fact that safety programs in place today are 

comprised of several components, e.g., radiation protection, chemical safety, security, 

etc. Second, the policy should recognize and allow for a graded approach to facility 

safety and security culture based on the relative risks of the authorized materials and 

activities. For example, the sophistication, formality and level of detail in an effective 

safety culture program at a uranium enrichment plant would far exceed the program at a 

 

1

 NEI is the organization responsible for establishing unified industry policy on matters affecting the nuclear 

energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members 

include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant 

designers, major architect/engineering firms, fuel fabrication facilities, nuclear materials licensees, and other 

organizations and entities involved in the nuclear energy industry. 
 15

facility that manufacturers tritium exit signs. Third, more coordination with the Agreement 

States and the wide variety of fuel-cycle and byproduct materials licensees is needed 

prior to finalizing and implementing a policy statement. The purpose of such coordination 

would be to gain additional insights on existing safety and security cultures to better 

define and articulate the agency’s specific goals and expectations regarding 

enhancements to the current safety and security culture at regulated facilities. 

3. Does safety culture as applied to reactors need to be strengthened? 

The nuclear power industry believes that a strong nuclear safety culture is an essential 

element in the safe and reliable production of electricity and that leadership at each site 

is the appropriate body to take responsibility for setting and implementing expectations 

for nuclear safety culture. The industry employs the INPO Principles for a Strong Nuclear 

Safety Culture to provide a common language for all employees to understand their 

responsibilities and the importance of effective processes and procedures in assuring 

nuclear safety. The industry also believes that it is the responsibility of the NRC to 

oversee the licensees’ safe operation of the stations and adherence to regulations. The 

current NRC approach to safety culture is too limited in that it only looks at a limited set 

of data (10-15 findings that occur at a plant over a year) and makes subjective 

judgments on this very limited set of data every six months. This approach is backwardlooking and distracts industry and NRC management from their appropriate roles of 

direct responsibility for nuclear safety culture and oversight of industry, respectively. The 

industry has proposed an alternative approach which will strengthen nuclear safety 

culture. This approach was discussed at the public meeting and is described in 

enclosure (2) to this letter. The industry alternative uses all the data that is available 

(inspection results, culture surveys/assessments, employee concerns, industry 

evaluations, quality assurance audits, self assessments, operating experience, 

performance trends, etc.) to the site leadership team to provide a holistic and integrated 

look at nuclear safety culture and to act in a timely manner to correct weaknesses. The 

NRC’s appropriate regulatory footprint will remain its baseline and supplemental 

inspection program, with, we believe, an enhanced Problem Identification and 

Resolution inspection procedure which will look at the effectiveness of the nuclear safety 

culture program. We recommend that the NRC staff work with the industry to transition 

from the NRC’s current approach to the industry proposed alternative, an effort which 

will include a pilot program. In addition, we believe that the NRC and industry should be 

using a common language to describe the elements of nuclear safety culture. We 

recommend that the NRC safety policy statement support both of these efforts. 

Enclosure (1) Comments: 

Topic 1: Should NRC combine its expectations in the policy statement for safety 

culture and security culture or should NRC keep its expectations separate? 

The policy statement for safety culture should be a single statement that addresses 

safety culture expectations for all personnel with unescorted access to a nuclear power 

station. Security should not be addressed separately within that single statement. 

Security forces are in most cases fully integrated into the plant processes, procedures, 

and expectations for safe operation and protection of public health and safety. 

Significant progress has been made in recent years to ensure security personnel have 

the same expectations regarding a nuclear safety culture that other plant workers 
 16

involved in safety related activities have. They have the same processes available to 

report nuclear safety issues or concerns. These expectations and processes are 

routinely reinforced through training and refresher materials. To address security in a 

separate policy or within a single policy may only provide negative reinforcement that 

security is held to a different standard and current proven processes are not sufficient. 

This would be an undesirable outcome. 

1. Within organizations, one can think about safety and security in different ways. 

For example, safety may take precedence over security, security may take 

precedence over safety, or both may be treated equally. Different types of 

licensees, certificate holders and organizations have a variety of experiences 

and perspectives. How does your organization view the relationship or 

hierarchy between safety and security functions and decision making? 

The safety and security organizations work together to provide protection of public 

health and safety. NRC regulations require integration to ensure they both remain 

effective across a wide range of normal and contingency events. Security works 

closely with station operations and ultimate authority and responsibility is given to the 

Operations Shift Manager to assure that both disciplines work together to assure 

nuclear safety is maintained during a contingency event. This is another reason to 

ensure that security is fully integrated into plant processes as they provide a uniform 

and controlled mechanism to maintain nuclear safety. 

2. While efforts to maintain safety and security have the same common goal of 

protecting public health and safety, there can be distinct differences in the 

approach used to achieve that goal and that may have competing outcomes. 

One example is how information is shared to mitigate risks, where increased 

sharing of information may contribute to maintaining safety, but presents 

increased security risks. What are other examples where efforts to maintain 

safety and security require different approaches or result in competing 

outcomes that need to be addressed to achieve the desired outcome or goal? 

Meeting nuclear safety objectives and assuring security measures are maintained is 

not particularly difficult to manage. As the first sentence in this question states, they 

have the same common goal. The key is to integrate and manage processes as 

outlined in the answer to question 1. Leaders at the stations recognize the 

importance of security in the safe operation of their plants and expectations are 

established that all plant disciplines work with security to assure work is well planned 

and executed without compromising security objectives. Similarly, security activities 

are planned and executed in a manner that doesn’t compromise the ability to 

conduct work and maintain nuclear safety. 

The NRC has a Draft Regulatory Guide DG-5021, “Managing the Safety/Security 

Interface.” This document is expected to be issued final in April 2009. The 

approaches and examples described in this guidance provide a method of 

compliance for the interface between safety and security. Each licensee is 

responsible for balancing the needs of both safety and security to ensure that it can 

and will meet all program goals, requirements, and procedures. The guidance in this 

regulatory guide is intended to facilitate the effective interface between safety and 

security to ensure that a licensee can implement changes to its safety and security 
 17

programs without adversely affecting its other site programs and its ability to satisfy 

NRC regulations. 

The intended purpose of establishing the effective interface between safety and 

security is to ensure that the respective staffs coordinate and assess planned and 

emergent safety- or security-related changes and activities at the facility to identify 

potential adverse effects on safety and security measures before implementation of 

the proposed changes or activities. 

Licensees of operating power reactors currently have management controls or 

processes for reviewing, assessing, and managing plant activities or changes to 

provide continued assurance of adequate safety and security. 

3. When resolving differences or conflicts while seeking to maintain safety and 

security — such as when managing risk, sharing information, planning work, 

correcting problems, etc. — and where changes or actions that are taken to 

address either a safety issue or a security issue could have an adverse effect 

on the other (i.e., security or safety, respectively); what challenges does your 

organization face? 

When issues arise that have the potential to negatively impact on either discipline, 

they are entered into the station’s corrective action system for resolution and to 

prevent recurrence. Although the corrective action program is the preferred, and in 

most cases the most effective, means to resolve potential conflicts, a variety of 

avenues are available to any individual that may wish to identify a issue or concern. 

Some of these include reporting the issue to their supervisor, reporting the issue to 

operations or plant leaders, utilizing the employee concerns program, and reporting 

the issue to NRC. If the individual raising the concern would prefer anonymity, 

several of these processes can accommodate it. 

4. What challenges or complexities arise when licensees and certificate holder’s 

work with contractors and vendors where the organizations either take 

different approaches to resolving conflicting outcomes when they seek to 

maintain safety and security or the organizations may balance the conflicting 

outcomes of efforts to maintain safety and security differently? 

The licensee is ultimately responsible for the safe and secure operation of the plant. 

Licensees are responsible to establish and enforce expectations related to nuclear 

safety and security. Contracts are established that contain these expectations and 

training and licensee oversight is provided to assure that contractors and vendors 

meet station expectations. Oversight of contractors is provided by observation of 

work by licensee supervisors, QA surveillance, management observation tours, 

behavior observation programs, and security observations, among other methods. 

Contractors and vendors have access to processes and programs provided by the 

licensee or have equivalent processes to promote a nuclear safety culture. Issues 

are entered into the station corrective action program or reported through the other 

processes previously discussed. 
 18

5. What practices have been used to effectively address the conflicts to achieve 

the desired outcomes or goals? 

Use of the corrective action program, reporting an issue to a supervisor, reporting an 

issue to operations or plant leaders, utilizing the employee concerns program, and 

reporting the issue to NRC have all been successfully used to resolve issues and 

achieve desired outcomes. All of these processes are provided to individuals in 

training and periodically reinforced through refresher information and recurring 

training. Health of the programs is monitored by station management through 

surveys, assessments and audits. 

6. Given that there are several ways to think about safety culture and security 

culture within organizations, the NRC wishes to express a policy in a way that 

best furthers its goals of protecting the public and environment and ensuring 

the secure use and management of radioactive materials. If the above issues 

are viewed in terms of safety culture and security culture implementation, what 

benefits or challenges would licensees, certificate holders, Agreement States, 

or others foresee with a single policy statement? Two separate policy 

statements? 

The policy statement for safety culture should be a single statement that addresses 

safety culture expectations for all personnel with unescorted access to a nuclear 

power station. Security should not be addressed separately within that single 

statement. Security forces are in most cases fully integrated into the plant processes, 

procedures, and expectations for safe operation and protection of public health and 

safety. Significant progress has been made in recent years to ensure security 

personnel have the same expectations regarding a nuclear safety culture that other 

plant workers involved in safety related activities have. They have the same 

processes available to report nuclear safety issues or concerns. These expectations 

and processes are routinely reinforced through training and refresher materials. To 

address security in a separate policy or within a single policy may only provide 

negative reinforcement that security is held to a different standard and current 

proven processes are not sufficient. This would be an undesirable outcome. 

Regarding fuel cycle and materials licensees and certificate holds, the industry 

supports a single policy statement to establish the expectation that the safety culture 

inherently includes a security culture as an integral and necessary component. 

Extraction of one key component, such as security, chemical safety, or radiation 

protection, from the overall facility safety program would potentially result in a 

disproportionate level of resources being devoted to one program component that 

could have a negative impact on the overall safety program. Such program elements 

must be integrated to ensure that the overall safety goal is met. As such, two 

separate policy statements, one for safety and one for security, could cause 

confusion and create conflicts regarding the level of emphasis to be placed on each 

component of the safety culture. 
 19

7. How can the NRC best express a policy that gives appropriate weight to safety 

culture and security culture across the range of licensees and certificate 

holders? Given the diversity among the licensees and certificate holders 

regulated by the NRC and the Agreement States, how should the policy 

statement address any differences in emphasis on safety and security at the 

different types of licensees and certificate holders? 

The policy should be written at a level that allows licensees to choose differing 

approaches to achieve the same objectives. Different approaches may be required 

for organizations of different sizes, management structures, regulatory requirements, 

site configurations, etc. However, the overarching objective of maintaining a strong 

safety and security culture can be met regardless of these differences if the policy is 

constructed in a manner that sets clear expectations for maintaining processes and 

procedures that promote a healthy nuclear safety culture, but does not prescribe 

methodology. 

8. Given the diversity among the licensees and certificate holders regulated by 

the NRC and the Agreement States, how should the policy statement address 

any differences in emphasis on safety and security at the different types of 

licensees and certificate holders? 

 Diversity among licensees and certificate holders should not result in differing 

standards when it comes to maintaining a nuclear safety and security culture that 

protects the health and safety of the public. 

Topic 2: How should NRC increase attention by licensees and certificate holders 

to safety culture in the materials area? 

In the area of fuel-cycle and byproduct materials licensees, we offer the following 

specific points. First, consistent with the position of the commercial nuclear power 

industry, there is general consensus among materials licensees that a single policy 

statement be drafted to address both safety and security. The policy should clearly state 

the Commission’s expectation that licensees and certificate holders ensure that an 

appropriate safety culture, that includes a security culture component, exists at each 

facility. This approach would reflect the fact that safety programs in place today are 

comprised of several components, e.g., radiation protection, chemical safety, security, 

etc. Secondly, the policy should recognize and allow for a graded approach to facility 

safety and security culture based on the relative risks of the authorized materials and 

activities. For example, the sophistication, formality and level of detail in an effective 

safety culture program at a uranium enrichment plant would far exceed the program at a 

facility that manufacturers tritium exit signs. Third, more coordination with the Agreement 

States and the wide variety of fuel-cycle and byproduct materials licensees is needed 

prior to finalizing and implementing a policy statement. The purpose of such coordination 

would be to gain additional insights on existing safety and security cultures to better 

define and articulate the agency’s specific goals and expectations regarding 

enhancements to the current safety and security culture at regulated facilities. 
 20

1. What is the NRC doing that is working well to help materials licensees and 

certificate holders to maintain their safety culture and security culture? 

 To date, NRC has not developed rules, regulations or guidance on safety and 

security culture in the materials area. Such a performance-based approach allows 

licensees and certificate holders the necessary flexibility to implement safety culture 

components specific to their facility and make changes to their programs in response 

to events, self assessments or other initiators without prior NRC approval or 

coordination. We appreciate that NRC has not dictated a specific approach or criteria 

which may work for some licensees but would be detrimental for others. We believe 

that this performance-based approach is working well and is beneficial to both NRC 

and the regulated community both from a safety and resource perspective. 

2. What might the NRC do differently, or that it is not currently doing, to increase 

NRC, licensee, or certificate holder attention to safety culture at materials 

licensees and certificate holders?

The question implies that the current level of attention to safety culture at regulated 

facilities by the licensee or certificate holder is inadequate. We are not aware of any 

data to support this assumption. We also disagree with the NRC comment made 

during the February 3, 2009 workshop that the number of Abnormal Occurrences 

(AO) reported annually to Congress is the basis for an increased NRC regulatory role 

in safety and security culture. In fact, the probability of an AO occurring at a 

regulated facility is extremely low (11 in 2007) when compared to the extremely high 

volume of regulated activities, uses and applications of licensed material on a daily 

basis (e.g., >10,000 medical dosages nationwide). 

We suggest that NRC consider revising its current approach to enforcement action 

when assessing the safety and security culture at a facility. Specifically, in a few 

cases, the NRC’s involvement has been detrimental to the safety and security culture 

at a regulated facility. Licensees work very hard to engrain in their workers the 

responsibility to report safety violations or unsafe conditions. However, NRC 

inspection reports and License Performance Reports very seldom acknowledge 

program successes, highlights or best practices. Instead, the NRC inspection report 

focuses only on potential violations, thereby diminishing the level of effort to 

implement and maintain an effective safety and security culture. Industry also 

believes that there is a negative impact on the program when NRC inspectors mine 

the facility’s corrective action files and internal audits and include such findings in 

their reports as if the NRC had identified them. Finally, NRC should consider not 

citing a violation that is self-identified and where NRC determines that effective 

correction action was taken to prevent a recurrence. Such a performance-based and 

more cooperative approach to safety culture would encourage facilities to more 

routinely self-audit and self-identify potential violations and this approach would likely 

enhance safety culture at regulated facilities. 

3. How could the NRC better interact with materials licensees and certificate 

holders to help them to pay greater attention to maintaining their safety culture 

and/or security culture? 

As stated previously, certain NRC questions imply that the current level of safety and 

security at regulated facilities is inadequate. That being said, NRC could better 
 21

interact with licensees and certificate holders by acknowledging the success of 

maintaining safe and secure operation of these facilities today and by engaging 

licensees to gain specific insights on the safety and security culture in place today 

and our mutual goals for culture enhancements. A more cooperative approach 

whereby the regulator and regulated work together to meet their common goal of 

safe and secure operations would, in the end, achieve loftier results. 

4. If the NRC expresses a policy for materials licensees and certificate holders to 

maintain safety culture and security culture, or made its references to safety 

culture and security culture more explicit in its interactions with these 

licensees and certificate holders, how would their performance change? 

The current level of performance would likely not change at many facilities or change 

very little at best. The biggest concern is that any policy statement or guidance from 

the NRC on safety and security culture could be detrimental to existing programs if it 

is prescriptive, focuses more on one aspect of safety culture to the detriment of 

others, or does not provide the facility with flexibility to make changes to safety 

culture components as needed without NRC approval or coordination. 

5. What should the NRC consider when developing policy statement(s) on safety 

culture and security culture? 

The first question that NRC should consider is, “What problem or perceived problem 

is NRC attempting to address?” Many regulated facilities have been operating safely 

under existing safety and security cultures for decades. That being said, facilities 

recognize, as with any program element, there is always room for improvement. 

Toward this end, NRC should work more closely with the Agreement States and the 

regulated community to determine key components of safety culture and incentives 

for facilities to more routinely conduct self-assessments or periodic independent 

audits to identify enhancements, in the absence of a requirement to do so. A lot can 

be shared and learned from site to site and, even between categories of licensees. 

Further, it would be beneficial if NRC recognized that facility operators work diligently 

each day to ensure safe and secure operations at regulated facilities because doing 

otherwise is unacceptable and in no one’s best interest. 

 5.1 What is the current level of understanding of materials licensees and 

certificate holders of the NRC’s expectations that they maintain a safety 

culture that is cognizant of issues relating to security? How does this 

level of understanding change with the type of licensee or certificate 

holder? 

 The licensees understanding of the NRC’s expectation for maintaining a safety 

culture and cognizant of the security aspect is that the licensee will develop 

and maintain a safety culture which includes a security component. To date, 

this approach appears adequate and recognizes that the level of program 

complexity varies depending on the category of licensee and inherent risks, 

e.g., from a fuel fabrication facility to an industrial gage user. 

 5.2 How should the NRC consider the different activities (e.g., risk, type of 

material, quantities of materials, how the material is used, location, etc.) 
 22

conducted at materials licensees and certificate holders when evaluating 

whether, or how, to express its policy? 

 The policy should be generic and not express specific expectations for one 

licensee category versus another. However, the policy should recognize that 

due to the risks associated with different categories of regulated facilities, “one 

size does not fit all” and include the expectation that individual licensees or 

certificate holders will use their intimate knowledge of regulated activities to 

determine the specific necessary attributes or components of a successful 

safety and security culture. 

5.3 How should NRC consider differences in the materials licensees and 

certificate holders (e.g., size of workforce, relationship to activities not 

regulated by the NRC, etc.) when evaluating whether, or how, to express 

its policy? What differences should the NRC consider? 

 As stated in response to question 5.2., the policy should be generic, not 

express specific expectations for one licensee category versus another, and 

recognize that “one size does not fit all.” The policy should also include the 

expectation that individual licensees or certificate holders will use their intimate 

knowledge of regulated activities to determine the specific necessary attributes 

or components of a successful safety and security culture. 

5.4 What are the unique aspects of security at materials licensees and 

certificate holders that the NRC should consider when expressing its 

policy? 

 Material licensees cover the extremes from facilities which have “Design Basis 

Events” to facilities which have basic industrial security provisions. The NRC 

policy needs to recognize that this extreme exists and not, as stated previously, 

apply a “one size fits all” mentality except to state its expectation that licensees 

ensure an appropriate safety and security culture commensurate with regulated 

activities. 

5.5 What topics should be addressed in the policy statement(s) that would be 

of value to materials licensees and certificate holders? 

 It would be most valuable if the policy recognized that NRC and the Agreement 

States cannot and should not regulate the safety and security culture at 

facilities but they can and should encourage facilities to develop and implement 

effective programs, and build and maintain safety culture through periodic self 

assessments or audits. It should be recognized that it is not in anyone’s best 

interest to have performance problems at regulated facilities due to the safety 

or security culture. Licensees work diligently through their corrective action 

programs, employee concern programs, their day-to-day operations, 

management controls, etc to help ensure that an appropriate culture exists. 
 23

5.6 How could the policy statement(s) effectively address issues that involve 

both safety and security (at the safety/security interface) at materials 

licensees and certificate holders? 

 The policy should recognize that security culture is one of several integrated 

parts of safety culture, i.e. there is no real distinction between cultures, there is 

not a standalone radiation safety culture, a nuclear criticality safety culture, a 

fire safety culture, or an environmental protection culture. All of these programs 

are focused on safety for a particular discipline; the licensee safety culture is 

approached in an integrated manner across discipline boundaries. 

5.7 How can the NRC best express a policy that gives appropriate weight to 

safety culture and security culture across the range of licensees and 

certificate holders? 

 The policy should state the Commission’s expectation in generic terms and 

encourage a performance-based approach to maintaining and enhancing the 

safety and security culture at regulated facilities. The NRC should not indicate 

that there is a distinction between safety and security, just like it does not 

distinguish between nuclear safety and radiation protection. There is a 

recognized difference between the facility which processes high-enriched 

uranium and a facility which processes Mo-99 generators or manufactures 

tritium exit signs. The risks at each facility cover an extremely broad range but 

the safety culture is based on the risks specific to the facility. 

5.8 Given the diversity among the licensees and certificate holders regulated 

by the NRC and the Agreement States, how should the policy statement 

address any differences in emphasis on safety and security at the 

different types of licensees and certificate holders? 

 As stated previously, the NRC policy should be generic such that the 

differences between licensees are recognized, allowed for and can be 

accommodated by both NRC and the regulated facility. 

6. How should the NRC work with the Agreement States to encourage increased 

attention being focused on safety culture, including the unique aspects of 

security, at Agreement State licensees? 

The NRC should use existing mechanisms to solicit Agreement State input on their 

programs and their understanding of Agreement State licensee programs to better 

inform the NRC’s draft policy statement. Such mechanisms include NRC-Agreement 

State working groups, task forces, steering committees, phone surveys, public 

meetings, workshops, etc. After all, Agreement State licensees make up ~80% of 

byproduct materials licensees nationwide so it is imperative that they be involved to 

ensure attention to these matters nationwide. Also, some NRC licensees work within 

Agreement State jurisdiction and vice versa. Therefore, it is in everyone’s best 

interest that further coordination occurs and that any NRC policy is adopted in a 

similar manner by the Agreement States. 
 24

6.1 What is the level of understanding at Agreement State licensees 

regarding the value in maintaining safety culture and security culture? 

 

 This question is best answered by the Agreement States or their licensees but 

we believe that most, if not all, Agreement State licensees value the 

development and maintenance of a safety culture and its relevance to security 

culture. There is no reason to believe that a licensee located in Delaware is any 

less focused on safety and security at its facility than a licensee located next 

door in Maryland. 

 6.2 What is the level of understanding of safety culture and security culture 

within the Agreement States? 

 Again, this question is best answered by the Agreement States but we believe 

that the Agreement States have a similar understanding and appreciation for 

safety culture and security culture as the NRC and licensees nationwide. 

6.3 How do the Agreement States view the NRC’s goal of increasing the 

attention paid to safety culture and security culture at materials licensees 

and certificate holders? 

 Again, this question is best answered by the Agreement States but we believe 

that the Agreement States value NRC’s efforts and goal to help ensure safety 

culture and security culture at regulated facilities. We also believe that many if 

not all Agreement States would support a limited role for the regulator while 

supporting a performance-based approach that recognizes the wide variety in 

regulated facilities. 

6.4 What topics do the Agreement States believe should be addressed in the 

policy statement(s)? 

 Again, this question is best answered by the Agreement States but we have no 

reason to assume that the Agreement States would offer topics for the policy 

statement that would be unique to them or their licensees since they regulate in 

a manner that is compatible with NRC. 

6.5 How could the NRC help the Agreement States to increase attention to 

safety culture and security culture at their licensees? 

 Again, this question is best answered by the Agreement States but we believe 

that NRC needs to utilize existing coordination mechanisms as discussed in the 

response to question 6 to solicit input from Agreement States, their licensees 

and thereby increasing attention to the need for an adequate safety and 

security culture at regulated facilities. 

6.6 How should the NRC address safety culture and security culture at 

Agreement State licensees that engage in activities within NRC 

jurisdiction under reciprocity? 

 As stated previously, the policy statement should include the expectation that 

the Agreement States will implement an approach to safety and security culture 
 25

that is similar to NRC’s approach on this matter. As we have stated in earlier 

communication with NRC on other matters, we encourage the NRC and 

Agreement States to find additional tools and mechanisms to share information 

of mutual interest regarding performance of licensees who work within both the 

NRC and Agreement State jurisdictions, e.g., industrial radiographers, mobile 

medical services. Information sharing in the areas of inspection and 

enforcement are particularly important for ensuring worker and public health 

and safety. 

6.7 How might NRC use stakeholder involvement to increase the attention 

that materials licensees and certificate holders give to maintaining a 

safety culture, including the unique aspects of security? 

 NRC should share information, as it becomes available, in the form of a 

Regulatory Issue Summary or Information Notice that regulated facility 

operators could consider for incorporation into their programs to enhance the 

safety and security culture. Sharing of information between licenses and 

between categories of licensees is extremely useful and provides an incentive 

for facilities to periodically assess their programs for enhancements. As such, 

NRC could consider holding workshops across the nation with various 

categories of licensees and certificate holders to share information on safety 

and security culture, best practices, lessons-learned, etc to better inform NRC 

as it considers a policy statement and to provide a forum for the regulated 

community to share information on this important topic. 

Topic 3: Does safety culture as applied to reactors needs to be strengthened? 

The nuclear power industry believes that a strong nuclear safety culture is an essential 

element in the safe and reliable production of electricity and that leadership at each site 

is the appropriate body to take responsibility for setting and implementing expectations 

for nuclear safety culture. The industry employs the INPO Principles for a Strong Nuclear 

Safety Culture to provide a common language for all employees to understand their 

responsibilities and the importance of effective processes and procedures in assuring 

nuclear safety. The industry also believes that it is the responsibility of the NRC to 

oversee the licensees’ safe operation of the stations and adherence to regulations. The 

current NRC approach to safety culture is too limited in that it only looks at a limited set 

of data (10-15 findings that occur at a plant over a year) and makes subjective 

judgments on this very limited set of data every six months. This approach is backward 

looking and distracts industry and NRC management from their appropriate roles of 

direct responsibility for nuclear safety culture and oversight of industry, respectively. The 

industry has proposed an alternative approach which will strengthen nuclear safety 

culture. This approach was discussed at the public meeting and is described in 

enclosure (2) to this letter. The industry alternative uses all the data that is available 

(inspection results, culture surveys/assessments, employee concerns, industry 

evaluations, quality assurance audits, self assessments, operating experience, 

performance trends, etc.) to the site leadership team to provide a holistic and integrated 

look at nuclear safety culture and to act in a timely manner to correct weaknesses. The 

NRC’s appropriate regulatory footprint will remain its baseline and supplemental 

inspection program, with, we believe, an enhanced Problem Identification and 

Resolution inspection procedure which will look at the effectiveness of the nuclear safety 

culture program. We recommend that the NRC staff work with the industry to transition 
 26

from the NRC’s current approach to the industry proposed alternative, an effort which 

will include a pilot program. In addition, we believe that NRC and industry should be 

using a common language to describe the elements of nuclear safety culture. We 

recommend that the NRC safety policy statement support both of these efforts. 

 

A number of enhancements were made to the ROP in 2006 to address safety 

culture (for example: safety culture cross-cutting aspect assignment to findings; 

identifying substantive cross-cutting issues; performing an independent NRC 

safety culture assessment for column 4 plants). 

1. What are the strengths and weaknesses of the current approach for evaluating 

licensee safety culture in the ROP?

 Industry believes the current NRC approach is ineffective: (1) The approach is limited 

to one set of data (inspection findings) and does not consider data on culture, such 

as attitudes, values, behaviors, and also does not consider other sources of data, 

such as industry evaluations, quality assurance audits, employee concerns program, 

operating experience, site performance indicators, benchmarking, etc. (2) 

Conclusions on a plant’s safety culture, and whether there is a “crosscutting issue” 

(which implies a cultural problem across departments or across processes), are 

based only on four inspection findings in a year’s time. (3) NRC decisions whether 

adequate action has been taken are not predictable or transparent. Neither licensees 

nor the public can understand how decisions are made. 

 

 For example, one of the most common crosscutting issues is procedure adherence. 

Four usually green (very low significance) inspection findings in procedure 

adherence in an entire year is weak evidence of a crosscutting problem at a site 

where there are several hundred procedures carried out every day, 365 days a year. 

 During the 18 month initial implementation period, the number of substantive 

crosscutting issues (SCCIs) more than doubled, and after 24 months more than a 

third of the sites in the industry had one or more SCCI. During this same time period, 

industry performance, as measured by the ROP performance indicators and 

inspection findings and the INPO performance indicators, continued to improve in 

safety. There is no apparent relationship between measured plant performance and 

the significant increase in SCCIs. 

 Despite this anomaly, the NRC has not conducted an assessment of the 

effectiveness of the SCCI approach, although the NRC had stated that it would do so 

in RIS 2006-13, Information on the changes made to the reactor oversight process to 

more fully address safety culture (page 6)1. An assessment would include answers 

to such questions as: Did the new process meet intended objectives and outcomes? 

Did it predict safety problems? Was the threshold for substantive crosscutting issues 

appropriate? Did it add value above its cost in NRC and licensee resources? Before 

implementing the ROP and the MSPI the NRC conducted pilots and an extensive 

assessment. The SCCI approach similarly warrants a hard look, not just public 

meetings to roll out lessons learned changes. 

 The founding principles of the ROP are to be transparent, understandable, objective, 

predictable, risk informed and performance based. Based on industry experience 

with the NRC’s safety culture approach, it fails to meet these principles. Industry 
 27

believes that it diverts both industry and NRC resources from their primary focus on 

plant safety equipment performance and essential plant procedures and processes. 

In the area of people (safety culture), it relies on limited insights from inspection 

findings (only four, usually green inspection findings in an entire year) in order to 

draw conclusions regarding issues with safety culture across an entire site. 

2. How has the use of safety culture cross-cutting aspects that are assigned to 

inspection findings helped to identify potential safety culture issues? Suggest 

any alternative approaches that licensees could use to identify potential safety 

culture issues. 

 The nuclear power industry believes that a strong nuclear safety culture is an 

essential element in the safe and reliable production of electricity and that leadership 

at each site is the appropriate body to take responsibility for setting and 

implementing expectations for nuclear safety culture. The industry employs the INPO 

Principles for a Strong Nuclear Safety Culture to provide a common language for all 

employees to understand their responsibilities and the importance of effective 

processes and procedures in assuring nuclear safety. The industry also believes that 

it is the responsibility of the NRC to oversee the licensees’ safe operation of the 

stations and adherence to regulations. The industry has proposed an alternative 

approach which will strengthen nuclear safety culture. This approach was discussed 

at the public meeting and is described in enclosure (2) to this letter. The industry 

alternative uses all the data that is available (inspection results, culture 

surveys/assessments, employee concerns, industry evaluations, quality assurance 

audits, self assessments, operating experience, performance trends, etc.) to the site 

leadership team to provide a holistic and integrated look at nuclear safety culture and 

to act in a timely manner to correct weaknesses. The NRC’s appropriate regulatory 

footprint will remain its baseline and supplemental inspection program, with, we 

believe, an enhanced Problem Identification and Resolution inspection procedure 

which will look at the effectiveness of the nuclear safety culture program. We 

recommend that the NRC staff work with the industry to transition from the NRC’s 

current approach to the industry proposed alternative, an effort which will include a 

pilot program. In addition, we believe that NRC and industry should be using a 

common language to describe the elements of nuclear safety culture. We 

recommend that the NRC safety policy statement support both of these efforts. 

3. What may be better or more effective methods or tools that the NRC could use 

to help identify precursors to future plant performance deficiencies? 

A more effective tool to identify precursors is to focus more on the physical condition 

of the power plant and the operation of the licensee’s corrective action program. 

Inspectors should have more of their time allocated to ensuring that the licensee is 

appropriately identifying and prioritizing adverse conditions, analyzing the cause of 

the condition, including extent of cause and extent of condition, developing 

appropriate corrective actions and implementing corrective actions in a timely 

manner. This is the key to identifying precursors and would have been effective in 

the Davis Besse case. 
 28

4. In the following situations the NRC may/or will request a licensee to perform a 

safety culture assessment (licensee self-assessment, independent 

assessment, or a third-party assessment): (a) the same substantive crosscutting issue had been identified in three consecutive assessment letters 

(generated from assessments conducted at 6 month intervals); (b) a 95002 

inspection (Inspection for One Degraded Cornerstone or Any Three White 

Inputs in a Strategic Performance Area) that confirmed the licensee had not 

identified a safety culture component that either caused or significantly 

contributed to the risk-significant performance issue that resulted in the 

supplemental inspection; and (c) a plant enters Column 4 of the Action Matrix. 

Under what other situations should the NRC consider requesting that a 

licensee perform a safety culture assessment? 

Licensees currently are required by INPO to conduct a safety culture assessment on 

a biennial basis. Industry is developing a guideline which will use the same 

methodology but apply greater levels of independence moving from self to 

independent to third party. (See enclosure 2.) INPO also assesses safety culture in 

its biennial evaluations, so there is now an annual assessment of safety culture. 

Another ROP enhancement was for the NRC to perform an independent safety 

culture assessment for plants that enter the multiple repetitive/degraded 

cornerstone column (column 4). 

5. In what other circumstances might the NRC consider performing an 

independent safety culture assessment? 

Industry believes that once the industry has put in place its guideline on conducting 

nuclear safety culture assessments, including third party assessments, the 95003 

inspection procedure should be revised to consist of evaluating the licensee’s 

assessment and not conducting its own assessment. 

6. What other entity, other than the NRC, could perform an independent safety 

culture assessment or simply verify the results of the licensee’s assessments 

and corrective actions? 

The industry guideline on conducting nuclear safety culture assessments will provide 

for independent and third party assessments. 

7. What additional safety culture related ROP changes could help the NRC to 

improve the focus of NRC and licensee attention on site safety culture issues? 

See questions 1 and 2. 
 29

The NRC has held public meetings where draft changes to several ROP guidance 

documents resulting from a lessons learned evaluation of the initial 

implementation period of the ROP safety culture enhancements have been made 

available for public comment. 

8. What areas beyond the draft changes (for example, a provision in IP95003 for 

the NRC to be able to conduct a graded safety culture assessment) presented 

by the NRC have the potential to further enhance how the ROP addresses 

safety culture? 

Please see question 2 and enclosure (2). 

 The NRC has not conducted an assessment of the effectiveness of the SCCI 

approach, although the NRC had stated that it would do so in RIS 2006-13, 

Information on the changes made to the reactor oversight process to more fully 

address safety culture (page 6)2. An assessment would include answers to such 

questions as: Did the new process meet intended objectives and outcomes? Did it 

predict safety problems? Was the threshold for substantive crosscutting issues 

appropriate? Did it add value above its cost in NRC and licensee resources? Before 

implementing the ROP and the MSPI the NRC conducted pilots and an extensive 

assessment. The SCCI approach similarly warrants a hard look, not just public 

meetings to roll out lessons learned changes. 

 8.1 How would these potential changes enhance or improve how the NRC 

addresses safety culture through the ROP? Under the industry approach, 

the NRC would focus on oversight, especially through the Problem 

Identification and Resolution inspection procedure, which includes both routine 

and biennial review of the corrective action system. Safety culture concerns will 

be entered into the CAP. 

9. In what ways does the current process lead to consistency/predictability of 

implementation by the NRC? Provide examples to support your view. 

It is not consistent and predictable across plants and regions. 

9.1 In what ways does it lead to inconsistency or unpredictability? 

 Assignment of aspects or not is dependent on individual inspectors and is not 

consistent or repeatable. The decision whether the licensee has adequately 

assessed and taken action to correct a crosscutting issue (four or more 

aspects) is not consistent across regions and is not predictable. It is not 

understood by the public or licensees. 

10. How effective is the ROP in addressing security culture issues? 

The ROP includes a performance indicator, inspection, significance determination, 

assessment and enforcement of security. In addition, safety culture aspects are 

sometimes applied to inspection findings. As stated earlier, industry believes the 

industry approach to assessing safety culture is preferable to the NRC approach; the 

industry approach includes assessing the security department. Substantial progress 

has been made over several years toward the goal of fully integrating security into 
 30

plant processes. Effectiveness would not be enhanced by a separate set of security 

culture aspects. 

 10.1 What ROP changes could help the NRC to improve the focus of NRC and 

licensee attention on site security culture issues? 

 Industry does not believe there should be a distinction made between safety 

and security culture issues. A security culture is one important element of a 

safety culture. If a station has a good safety culture, it would include personnel 

at the site understanding their role in supporting security as a component of 

nuclear safety. 

In previous public meetings, the NRC has discussed using the Reactor Oversight 

Process safety culture components and modified aspects as a tool to understand 

the challenges to safety culture during new reactor construction. 

11. How can challenges to safety culture in new reactor construction be identified 

and addressed in regulatory oversight? 

 Safety culture for construction differs from an operating plant environment. For a 

construction environment, safety culture can be inferred from three basic 

programmatic elements: a safety conscious work environment, quality assurance, 

and the Occupational Safety and Health Administration (OSHA) program. 

Questions on Safety Culture Components 

1. Is there an area(s) important to safety or security culture that does not appear 

to be captured by the set of nine components? Is the missing area(s) relevant 

to a particular set of licensees or certificate holders? Or is it generically 

applicable? If so, please specify. 

Industry has not had sufficient time to review the new set of nine components. They 

appear to cover the same areas as the previous set of thirteen. Industry believes that 

the best approach for the ROP and the industry would be to use a common set of 

components and aspects or principles and attributes so that we are speaking with a 

common language. Industry would be pleased to work with the NRC to achieve that 

goal. 

2. Of the identified components, is there a safety culture component(s) that you 

consider to not be important, or to not contribute, to safety culture and should 

therefore be dropped? If so, please specify. 

See question 1. 

 

3. How should the Commission communicate a common understanding of the 

components of safety/security culture? 

We should be communicating with the same language. 
 31

4. How should the Commission, through the policy statement, influence licensee 

and certificate holders to use their understanding of safety/security culture to 

improve performance? 

The policy statement should encourage industry to take the lead in developing 

common guidelines for assessing safety culture and correcting weaknesses. 

5. Should there be new regulatory requirements specifically addressing safety 

culture? If so, please explain. Or, how should safety culture insights to be 

used, e.g., to inform regulatory response to findings or violations within 

existing requirements? 

Industry does not believe that there should be regulatory requirements in the area of 

safety culture. 

6. Given the range of NRC licensees and certificate holders, how can the 

Commission best communicate its expectations regarding the scope of 

programs and processes to address safety/security culture in a manner that 

appropriately considers the different licensee and certificate holders 

environment? 

 Industry believes there should be a graded approach based on the size and type of 

safety issues involved in the facility. 

7. How should the Commission define the components of safety and security 

culture (i.e., one set of components addressing both safety and security 

culture in an integrated manner or two sets of components, one to address 

safety culture and another to address security culture)? What are the risks and 

benefits of combining or separating them? 

Regarding making distinctions between safety and security culture please see the 

responses to topic 1 questions. Industry believes there should be one set, and that 

the industry and NRC should work toward a common set of components or 

principles. 
 32

Enclosure (2) Comments: 

I. Description of Industry Approach 

The industry approach to assessing and addressing nuclear safety culture issues places 

primary responsibility on line management, and in particular, on the site leadership team. 

The objective is to provide an objective, transparent and safety-focused process, which 

uses all of the resources available (e.g., performance trends, NRC inspections, industry 

evaluations, nuclear safety culture assessments, self assessments, audits, operating 

experience, employee concerns program, etc.) to provide an early indication of potential 

problems, develop effective corrective actions and monitor the effectiveness of the 

actions. 

While it is not possible to directly measure culture, and thus there must be some 

subjectivity, there are aspects of plant conditions which can be trended to provide a 

warning to site leadership to determine if cultural issues contributed to the condition. 

Process weaknesses, discovered through audits, self assessments, inspections, etc., 

also can provide symptoms of cultural problems. Similarly, the attitudes and behaviors of 

site personnel can be assessed through surveys, interviews and behavioral 

observations. It is the responsibility of the site leadership team to employ all of these 

tools and take effective action. 

Overview of Proposed Industry Process 

The proposed process is shown below and is comprised of eight distinct elements. 

1. Process Inputs 5. Site Response 

2. Corrective Actions 6. Communication 

3. Other Input Sources 7. External Input 

4. Site Leadership Team 8. Regulatory Oversight 

Industry Nuclear Safety Culture Process 
 33

1. Process Inputs 

The following are the inputs to the nuclear safety culture process. For each input, there 

are data (e.g., deficiencies, violations, or weaknesses) which can be reviewed in 

combination with data from other inputs to determine whether there is a nuclear safety 

culture issue. The INPO Principles for a Strong Nuclear Safety Culture describes the 

essential attributes of a healthy nuclear safety culture. They provide a useful framework 

for assessing and categorizing the data, and in combination, are used to identify 

potential cultural issues for action. Using a consistent model and terminology throughout 

the entire process will allow clear communication of cultural issues which the entire site 

can understand and respond to. Each input has an owner whose responsibilities include 

assessing the data against the INPO principles and attributes and reporting their results 

to the site leadership team on a periodic basis. 

NRC inspection results. These include the baseline inspections of plant and processes 

(especially the problem identification and resolution inspection which also looks at safety 

conscious work environment and any past safety culture assessments), supplemental 

inspections, event follow-up, etc. These are extremely valuable inputs for the site. 

Nuclear Safety Culture Assessment. Using a common industry guideline, sites 

conduct a self assessment of nuclear safety culture on a biennial basis. This is already 

an INPO SOER 02-4 requirement. What has been added is a common industry 

approach. The proposed approach is discussed in Section III. 

Industry Evaluations. For example, INPO evaluations are conducted on an 

approximately biennial basis, in the alternate year from the culture assessment. Included 

in the INPO evaluation is an assessment of nuclear safety culture. Thus the site would 

receive a nuclear safety culture assessment almost every year. These industry 

evaluations are available to NRC on site. 

Operating Experience. Data on previous deficiencies (such as operations, design, and 

equipment) are used to improve procedures and processes and to avoid future 

problems. Information from OE can also be used to look for nuclear safety culture 

issues. 

QA/Self Assessment/Benchmarking. Each site requires a variety of self reviews. 

These include audits required in the quality assurance programs, department self 

assessments, and benchmarking of other sites in the industry (or other industries). 

Employee Concerns Program. This required program looks at the site’s safety 

conscious work environment. It may not be appropriate to enter some of the ECP issues 

in the corrective action program, but the issues will be considered by the site leadership 

team. 

Site Performance Trends. Each site has a broad suite of indicators which it uses to 

assess performance. They do not include ROP performance indicators which generally 

measure plant-wide outcomes, but rather they provide intermediate outcomes, which, if 

not corrected, could lead to safety system failures, scrams or events. Trends can be 

developed in these indicators and the cause of the trend – be it process or design 

deficiencies, training, resources, or nuclear safety culture issues – can be examined and 

corrective action taken. 
 34

Examples include operator workarounds, control room deficiencies, preventive 

maintenance deferred, open positions, etc. These trends would not be reported to NRC, 

because they are not performance outcomes. They would be available to NRC on site. 

• Note that a site may have additional process inputs that it finds effective in helping to 

assess nuclear safety culture. 

2. Corrective Actions 

Problems in all of these areas are fed into the site’s corrective action program where 

they are assessed for significance, including whether apparent cause or root cause 

analyses will be conducted. Both apparent and root cause analyses will include an 

assessment against the INPO principles and attributes. In some cases, the corrective 

action program is not the appropriate location for the problem; for example, some ECP 

issues, allegations, perhaps some nuclear safety culture assessment issues, and some 

organizational or personal issues. Cultural and organizational issues may more 

appropriately be placed in the Site Improvement Plan, or whatever term the site uses. 

3. Other Inputs 

There may be additional inputs that come directly to the attention of the site vice 

president, such as allegations or other sensitive information, which are not appropriate to 

be handled through the corrective action program. 

4. Site Leadership Team 

The Site Leadership Team is responsible for reviewing plant performance and taking a 

holistic view of all of the potential indications of nuclear safety culture. The team should 

be guided by the INPO principles and attributes. In addition to having very subtle issues 

which the team discerns from several inputs, the team will also, of course, have 

situations which are more direct, such as ECP and nuclear safety culture surveys and 

assessments. While maintaining an ongoing sensitivity to nuclear safety culture issues, 

the team will also meet quarterly to discuss and assess cultural issues. Reports from the 

managers responsible for each of the process inputs will provide information for the 

team. 

5. Site Response 

The Site Leadership Team is responsible for determining what actions are necessary to 

address any nuclear safety culture issues. In addition, the team is responsible for 

assessing the effectiveness of prior actions and redirecting these actions where 

appropriate. Site Response suggests some actions that might be taken: changes in 

policies, program modifications, training, additional assessments, benchmarking, etc. 

The site responses, of course, provide feedback into the process inputs and into the 

corrective action program and/or site improvement plan. 

6. Communication 

The Site Leadership Team is responsible for ensuring there is appropriate 

Communication of its conclusions and actions. This communication is internal to the 

site workforce and if appropriate, corporate, and external, if appropriate, to the public. 

Raw data and reports, such as the INPO evaluation and the nuclear safety culture 

assessment would be available on site for NRC review. 
 35

7. External Input 

The Nuclear Safety Review Board (or equivalent) provides an additional perspective to 

the site leadership team. The experience and outside eyes of the board can assist the 

site leadership team in many ways, including bringing a fresh look at cultural problems 

which may be invisible to those living in the culture day to day. Corporate organizations 

or fleets may also be used to provide external input. 

8. NRC Oversight 

The NRC retains a Regulatory Oversight footprint in the process through its residents 

and baseline and supplemental inspections. While inspectors will not assign crosscutting 

aspects to inspection findings, their observations can provide valuable insight to the 

licensee. In particular, the Identification and Resolution of Problems (IP 71152) 

inspection procedure objectives are: 

01.01 To provide for early warning of potential performance issues that could result in 

crossing thresholds in the action matrix. 

01.02 To help the NRC gage supplemental response should future action matrix 

thresholds be crossed. 

01.03 To provide insights into whether licensees have established a safety conscious 

work environment. 

01.04 To allow for follow-up of previously identified compliance issues (e.g., NCVs). 

01.05 To provide additional information related to the crosscutting areas that can be 

used in the assessment process. 

01.06 To determine whether licensees are complying with NRC regulations regarding 

corrective action programs. 

01.07 To verify that the licensee is identifying operator workarounds at an appropriate 

threshold and entering them in the corrective action program.” 

This inspection procedure includes specific questions related to raising safety questions. 

(Upon adoption, this procedure and other NRC internal guidance would need to be 

revised to remove the references to crosscutting themes and aspects.) Additionally, the 

inspectors review any safety culture assessments which have been performed. The 

NRC footprint would also include observation on site of various aspects of the industry 

safety culture approach. NRC communicates results to the public through inspection 

reports, assessment letters and public meetings. 

Comparison with Reactor Oversight Process 

The industry nuclear safety culture process, in many respects, mirrors the Reactor 

Oversight Process, which is shown below. In both processes a range of inputs (in the 

case of the ROP, performance indicators and inspection findings) are individually 

reviewed for significance. In the site process, deficiencies and weaknesses are entered 

into the corrective action process. They are assessed for significance, extent of condition 

and cause. Actions are developed to preclude recurrence and implemented. In both the 

ROP and the industry process, all of the information is assessed in combination to 

determine what actions should be taken by the responsible management. In the ROP 

case, senior NRC management determines the additional inspection and communication 

that are appropriate. For the site nuclear safety culture process, the site leadership team 
 36

is responsible for determining the appropriate action. (Of course, in a broader sense, the 

nuclear safety culture model reflects how site leadership oversees all of the site 

activities, not just safety culture.) 

Advantages of Industry Process 

The advantages of this process are many. The process is built around the INPO 

principles and attributes which emphasize that EVERYONE is responsible for nuclear 

safety. The principles provide a common language across the site and across the 

industry so that communication and actions are understood. The process uses a broad 

spectrum of input available from plant condition, process and people issues. In addition, 

the majority of the data were already in use at the site, albeit for other purposes. Finally, 

the process places clear responsibility on line management, with the site leadership 

team at the top. 

The NRC approach uses a different set of attributes, and a different language, than the 

industry. Many of NRC attributes may not be nuclear safety cultural issues at all. They 

may be training or procedures, or process weaknesses as opposed to cultural issues. 

Unfortunately, the NRC sampling approach relies on categorizing violations, of which 

there are on average only 15 or so a year per site, whereas the industry approach has 

literally thousands of inputs. The NRC counting scheme for assessing a “crosscutting 

theme” is only four data points in a year. When NRC is not convinced that the site has 
 37

taken sufficient action for these four (usually) safety-insignificant violations, it issues a 

“substantive crosscutting issue” which can divert precious resources and management 

time away from safety significant issues and ensuring that processes and procedures 

are being effectively implemented. It also presents a distorted and negative image of the 

site which is misleading to the public. NRC resources are also diverted from their 

attention on inspecting plant and processes toward subjective judgments on minor 

inspection findings and attempting to assess the culture based on limited data. Then 

more senior NRC management is diverted by having to make subjective judgments on 

whether cultural issues have been resolved. 

A more appropriate role, or footprint, for the NRC is focus on objective, tangible 

evidence of plant safety, compliance with the regulations and using risk-informed tools to 

determine significance and regulatory response. It should use its inspections of the 

corrective action program to determine if plant and process deficiencies are being 

corrected in a timely manner and that events are being properly evaluated. The 

corrective action program inspection also can look at the site’s actions to correct safety 

culture issues which have been identified. The NRC informs the public through its 

inspection reports, assessment letters and public meetings. 

Conclusion 

The industry nuclear safety culture process provides a structured approach of looking at 

multiple inputs to assess the culture using the “lens” of the INPO principles and 

attributes. It looks at plant conditions, processes, and people’s attitudes, opinions and 

behaviors. It appropriately places responsibility for assessing and improving nuclear 

safety culture on the line management, while emphasizing that everyone on site is 

responsible for nuclear safety. 

II. Nuclear Safety Culture Assessment Including Third Party Assessments 

Introduction 

This section discusses current requirements for nuclear safety culture assessments, and 

a graded nuclear safety culture assessment guideline. The objective is to: 

Create a consistent, quality guideline and approach for conducting nuclear safety culture 

assessments which will be used across industry and will be used for self assessment, 

independent assessment and third party assessment. 

The approach was developed by an NEI task force, building on a very successful 

assessment process developed and implemented over the past five years by the Utilities 

Service Alliance (USA) member stations. 

Current Requirement for Nuclear Safety Culture Assessment 

INPO SOER 02-4 calls for a nuclear safety culture assessment every other year. There 

are no specific requirements. Some utilities do an assessment entirely in house using 

company resources (either all on site resources, or a combination of fleet resources); 

some are in the USA program 17 stations) which include both internal assessors and 

external loaned utility assessors; some use consultants (cost varies but is in the range of 

$100,000 to $150,000); and there may be other variations. 

NRC demands a third party nuclear safety culture assessment for plants in column 4 of 

the action matrix and has required an independent assessment in certain other 

instances when it is concerned about performance and “significant crosscutting issues.” 
 38

These assessments are ad hoc and usually do not build on the same model as the self 

assessments, resulting in no economies of scale and difficulty in comparing the two 

assessments. (This is often the case because self assessments commonly use the 

INPO nuclear safety culture model of principles and attributes, whereas the independent 

or third party assessments are organized around specific issues and the NRC’s nuclear 

safety culture aspects.) 

Graded Nuclear Safety Culture Assessment Guideline 

The industry nuclear safety culture assessment guideline is built on the successful USA 

approach which uses the industry standard INPO principles and attributes for surveys, 

interviews, and behavioral observations. The USA self assessment approach differs 

from some utilities’ self assessments in that it uses a team made up of half site 

assessors, and half independent assessors. The strength of this team structure is that 

there are people on the team with site knowledge, and independent assessors who may 

be more sensitive to cultural issues on site because they are not a part of that culture. 

The assessors conduct interviews of senior managers and managers, first line 

supervisors, various departments and craft groups, security and oversight in two person 

teams, usually with one onsite and one offsite member. Two person teams allow greater 

reliability in assessing nuclear safety culture attributes, and also allow for one person to 

take notes while the other person conducts the interview. The team also conducts 

behavioral observations (e.g., morning meeting, CARB, pre-job briefs, control room). 

Usually there are four two-person teams. In addition there is a team host, an external 

team executive, an external team lead, and two site administrative support staff. More 

details are provided in the table below. 

The self assessment approach can be readily adapted to the needs of an independent 

assessment (requested by a site VP who requires a deeper or more specific review), or 

to a 95003 assessment. The differences between the variations between self, 

independent and third party assessments are an increase in sample size, more 

independence by the assessment team and additional focus on areas of concern. 
 39

Graded Nuclear Safety Culture Assessment 

 Self Assessment Independent 

Assessment 

Third Party Assessment 

Purpose To meet INPO SOER 02-4 

(Davis Besse) biennial 

assessment 

Requested by Site VP who 

wants deeper/more 

specific review 

95003: Plant in Column 4 

of action matrix 

Base Assumptions Standard Assessment (presurvey1

, document review, 

interviews, behavioral 

observation, four 2 person 

teams, exit, written report) One 

week. 

Standard Assessment plus 

review of additional area(s) 

of concern to Site VP 

Could require an additional 

team of assessors to 

address issues. Typically 

one week. 

Standard Assessment plus 

review of additional areas 

of concern determined by 

Site VP and Team Leader. 

Two weeks. 

Work Product Assessment Report, including: 

executive summary, survey and 

interview results by principle and 

attribute, follow-up from previous 

assessment, positive traits 

observed, conclusions and 

recommendations for 

improvement. 

Same as Standard 

Assessment, with 

conclusions and 

recommendations on 

additional topic requested 

by Site VP. 

Same as Standard 

Assessment with 

conclusions and 

recommendations 

addressing 95003 issues. 

Coverage INPO principles and attributes; 

minimal additional topics. 

Typically 60-85 interviews, 15 

observations, survey offered to 

100%; goal of 70% response 

(including write in comments) 

Same as self assessment 

with coverage of additional 

areas of concern and 

perhaps 20% more 

interviews and 

observations. 

INPO principles and 

attributes and additional 

topics selected to address 

95003 issues. 

Approximately twice the 

number of interviews and 

observations as self 

assessment 

Team Makeup Team Leader (outside utility) 

Team Executive (outside utility) 

4 external assessors (fleet or 

outside) 

4 internal assessors 

1 Host peer 

2 admin (host station) 

Team Leader (outside 

utility) 

Team Executive (outside 

utility) 

8-10 external assessors 

(at least half outside utility, 

remainder fleet) 

1 Host peer 

2 admin (host station) 

Optional: Behavioral 

scientist (MA level) 

Team Leader (outside 

utility) 

Team Executive (outside 

utility) 

10 external assessors 

(outside utility) 

1 Host peer 

2 admin (host station) 

Behavioral scientist (MA 

level) 

 

1

 Surveys performed by contractors may be substituted for the USA survey if the results are provided to the 

assessment team in terms of the INPO principles and attributes. 
 40

 Self Assessment Independent 

Assessment 

Third Party Assessment 

Team Roles Team Leader: Interfaces with 

host site and team members 

prior to the assessment; 

conducts 1⁄2 day training with 

team Sunday before 

assessment; 

leads team to ensure adequate 

number of interviews and 

observations are conducted; 

briefs site management; 

conducts exit; prepares report 

obtaining team concurrence. 

Team Executive: Provides 

senior oversight of the team; 

preferred attendance for entire 

week; required Wed-Friday. 

Interfaces with site VP. 

Assessors: Conduct interviews 

and observations as two person 

teams; develop conclusions and 

findings 

Host Peer: Ensures logistics 

including badging, interview and 

observation scheduling; 

coordinates survey 

administration 

Admin: Ensure smooth 

execution of assessment and 

manage data collection 

Same as Self Assessment. 

Behavioral scientist 

works at the direction of 

the Team Leader. Can 

provide insights into data 

analysis, interviewing 

techniques, and team 

findings and 

recommendations. 

Same as Self Assessment. 

Behavioral scientist 

works at the direction of 

the Team Leader. Can 

provide insights into data 

analysis, interviewing 

techniques, and team 

findings and 

recommendations. 

 

Training Team Leader: Industry 

workshop training and previous 

assessor experience 

Assessors: Interviewing skills 

training (or experience in 

conducting evaluations which 

involve interviewing) and 1⁄2 day 

team training prior to the 

assessment. 

Admin: orientation by qualified 

Team Leader 

Same. 

Behavioral scientist will 

be familiar with 

assessment methodology. 

Same. 

Behavioral scientist will 

be familiar with 

assessment methodology. 

Document Review CAP, root cause evaluations 

past 2 years, policies on nuclear 

safety culture and SCWE, site 

process PIs, QA audits, self 

assessment and benchmarking 

reports, last nuclear safety 

culture assessment, NRC 

assessment letters, review ROP 

results on NRC website. 

Same, with any additional 

materials provided by Site 

VP. 

Same, with any additional 

materials provided by Site 

VP, and 95003 related 

reports. 
 41

Activities Necessary to Enhance the USA product for Nuclear Safety Culture 

Assessments for Industry Use (including 95003 third party nuclear safety culture 

assessments) 

The Utilities Service Alliance has created an excellent nuclear safety culture assessment 

product which it has been implementing and improving over the past five years. A team 

of leaders of the USA effort reviewed the current product and considered what additional 

improvements would be necessary. These enhancements include: 

1. Modify document to reflect three levels of assessment (self, independent, and third 

party). 

2. Update survey tool to distinguish between departments and respondent’s 

organization level. 

3. Develop survey criterion and content validity. 

4. Upgrade to Microsoft Access 2007. 
 42

VI. Mr. William D. (Bill) Shaeffer 

 Employee Concerns Manager 

 Energy Northwest – Columbia Generating Station 

 

QUESTIONS ON SAFETY CULTURE COMPONENTS 

1. Is there an area(s) important to safety or security culture that does not appear to be 

captured by the set of nine components? Is the missing area(s) relevant to a particular 

set of licensees or certificate holders? Or is it generically applicable? If so, please 

specify. 

 Response: No 

2. Of the identified components, is there a safety culture component(s) that you consider 

to not be important, or to not contribute, to safety culture and should therefore be 

dropped? If so, please specify. 

 Response: No 

3. How should the Commission communicate a common understanding of the 

components of safety/security culture? 

 Response: Regulatory Issue Summary (RIS) 

4. How should the Commission, through the policy statement, influence licensee and 

certificate holders to use their understanding of safety/security culture to improve 

performance? 

 Response: Clearly define safety and security culture as “Priority 1”, in everything the 

industry does. 

5. Should there be new regulatory requirements specifically addressing safety culture? If 

so, please explain. Or, how should safety culture insights to be used, e.g., to inform 

regulatory response to findings or violations within existing requirements? 

 Response: No, continue with the revised ROP (need more run time) 

6. Given the range of NRC licensees and certificate holders, how can the Commission 

best communicate its expectations regarding the scope of programs and processes to 

address safety/security culture in a manner that appropriately considers the different 

licensee and certificate holders environment? 

 Response: If the incorporation of security is kept at the same high level in the policy 

statement as nuclear safety there shouldn’t be a reason to have to 

address the different licensees individually. 

How should the Commission define the components of safety and security culture (i.e., 

one set of components addressing both safety and security culture in an integrated 

manner or two sets of components, one to address safety culture and another to address 

security culture)? What are the risks and benefits of combining or separating them? 

Response: See attachment below 
 43

CODE OF FEDERAL REGULATIONS (CFR)

“PROTECTION OF PUBLIC HEALTH AND SAFETY, COMMON DEFENSE AND SECURITY” 

NUCLEAR SAFETY CULTURE NUCLEAR SECURITY CULTURE

“Nuclear Safety Culture is 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.”* 

Nuclear Security Culture is that assembly of 

characteristics and attitudes in organizations 

and individuals which establishes that, as an 

overriding priority, nuclear plant security issues 

receive the attention warranted by their 

significance. 

NRC SAFETY CULTURE COMPONENTS 

1. Safety Conscious Work Environment (SCWE) – Management maintains a SCWE in which 

personnel feel free to raise concerns without fear of retaliation. 

2. Accountability (A) – Roles, responsibilities and authorities for safety and security are clearly 

defined and reinforced. 

3. Licensee Decision-Making (LDM) – Licensee decisions ensure that safety and security are 

maintained. 

4. Work Practices (WP) – As individual contributors, personnel demonstrate ownership for safety 

and security in their day-to-day work activities. 

5. Work Planning and Control (WPC) – Processes for planning and controlling work ensure that 

individual contributors, supervisors and work groups communicate, coordinate, and execute 

their work activities in a manner that supports safety and security.

6. Problem Identification and Evaluation (PIE) – Management ensures that issues potentially 

impacting safety or security are promptly identified and fully evaluated, commensurate with their 

significance. 

7. Problem Resolution (PR) – The licensee ensures that safety and security issues are promptly 

addressed and corrected, commensurate with their significance. 

8. Continuous Learning Environment (CLE) – Management maintains a continuous learning 

environment in which opportunities to improve safety and security are sought out and 

implemented. 

9. Resources (R) – The licensee ensures that the personnel, equipment, procedures, and other 

resources needed to assure safety and security are available. 

*Adopted from the IAEA’s International Nuclear Safety Advisory Group (INSAG) as presented in 

INSAG-4 publication
 44

VII. Mr. Peter Stockton 

 Project On Government Oversight 

 

⇒ Great job staff for recognizing there is a security problem at the power plants. 

Unfortunately, they were voted down on recent DBT increase and security 

information transparency issue. 

⇒ We are agnostic on a policy statement. The current one states that reactor 

operators should not be drunk or asleep in the control room. The policy 

statement seems self-evident. But, the process of trying to identify these culture 

problems can be productive. 

⇒ Problem starts at the top with NRC Commissioners 

o A year ago POGO interviewed each Commissioner. Some simply don’t 

believe there is a serious terrorist threat to the nuclear power plants. One 

measure of this problem is the vote last week to turn down the staff 

recommendation to make the DBT more robust (the number of 

adversaries included and number of lethal weapons available to terrorists, 

50 cal. Bangalore torpedoes and RPGs). 

o One Commissioner made misleading and disparaging remarks to 

Congress about a security whistleblower in a Senate Peach Bottom 

hearing, that lead to an IG investigation 

o Recently, Commissioners voted against increasing the transparency and 

public information about the results of security inspections. (TA-18) 

o President Obama should appoint someone to the Commission who has a 

commitment to nuclear security. This is an opportunity to show that he is 

serious about his commitment to prevent nuclear terrorism. 

⇒ Since 2002, POGO has interviewed or met with several hundred security officers. 

From those interviews, we believe security culture is a real problem. 

⇒ Security officers recognize that the DBT is unrealistic and that they would be 

cannon-fodder in a real attack. They refer to the DBT as the “Dollar Based 

Threat.” 

o BRE - are iron coffins 

o They know they won’t get effective outside help because of timelines 

o They know they will be outgunned 

o Excessive overtime leads to lack of attentiveness 

o When questioned about the lame DBT—NRC claims, “that is all you can 

expect of private guard force.” This is dangerous. This attitude trickles 

down to create a culture. 

⇒ There is too much advance notice of security tests (force-on-force). There is a 

culture of wanting the plants to look good. Not a culture of: How well protected 

are the power plants? Should win overwhelmingly-no surprise, no speed, or no 

violence of action (the major advantages that terrorists have). 

 

⇒ NFS/BWXT serious problems with DBT 
 45

⇒ Security officers’ concerns are not taken seriously by the security contractor or 

the licensees. Security officers stop bringing up issues when nothing gets 

addressed. In a number of cases they are afraid to bring up issues because the 

fear of retaliation, including the threat to their jobs. 

⇒ No real whistleblower protections. 

⇒ Contractor and licensee responses to problems that are raised by saying “we 

don’t have the money” or “we’re in compliance with NRC regulations.” 

⇒ At Peach Bottom, security officers went to the press instead of the NRC—didn’t 

trust the NRC 

⇒ Regional offices 

o McGaffigan experiences with Region 1 at Salem Hope Creek 

o Peach Bottom OIG report, no heads roll 

o March 2007 “no safety problems,” but then in September 2007, hearing 

about a potential video, it then became “possible safety problems” 

⇒ Enforcement/Fines $65K, sleeping guards cost NRC $500K for investigations 

VIII. Mr. Greg Yuhas 

 

Safety Culture Comments: 

It’s all about profit, pressure and pain. 

Profit is the driving force that ultimately controls the resources allocated to safety. It 

doesn’t matter if the profit is monetary, as in private industry; prestige as in educational 

institutions or budget/mission as found in government and non-profits. In the end if you 

can’t make money, attract students, stay within your budget, or successfully complete 

your mission, your organization will fail. 

Pressure is a force that can change direction. It can be a simple as a road sign warning 

of a sharp curve ahead. 

Pain is the antithesis of profit. It is the counter weight that must be heavy enough to 

balance the primal urge for profit. If you ignore the warning signs and there is no 

consequence or pain, you may come to believe you don’t have to heed the warnings. 

Safety culture is an organizational paradigm that represents a level of pressure in the 

decision making process. It’s a set of procedures that help us recognize warning signs 

and act accordingly. 

NRC should prepare and promulgate a Regulatory Guide presenting the programs and 

procedures commonly found in organizations with effective safety cultures. Since 

Regulatory Guides are not mandatory, they represent a form of pressure. License 

reviewers, inspectors, and senior managers should point to the Regulatory Guide rather 

than offering their own ideas of what procedures or programs should be present in 
 46

fostering an effective safety culture. NRC must avoid the temptation to co-manage 

licensees’ activities. 

However, it’s up to NRC to establish clear, performance based safety significant 

regulations that are consistently and effectively enforced. NRC and the Agreement 

states are ultimately responsible for providing sufficient pain to balance the profit 

incentive if we are to have the public believe radioactive materials can be safely utilized. 

IX. Mr. Earl Fordham

 Conference of Radiation Control Program Directors (CRCPD) 

Overriding comment: One statement combining safety and security 

General comments: 

 

1) There is room for safety and security improvement at reactor facilities. With the 

understanding regulators and regulations can only go so far, the utility remains ultimately 

responsible for safety environment. Utility owners/managers must see an economic 

benefit to the safety and security development. The NRC should develop policies to 

promote the culture from within. 

2) Emphasis on human performance issues. Utility employees should be actively 

engaged in the process with training. Feedback (e.g., surveys) should be encouraged. 

The message (in documents and presentations) needs to use plain English principles. 

X. T. Moser 

 Chairman 

 STARS Integrated Regulatory Affairs Group 

Reference: 

1) 74 FR 04260, Safety Culture Policy Statement Development: Public 

Meeting and request for Public Comments, dated January 23, 2009. 

NRC-2009-0013 

2) 74 FR 05192, Safety Culture Policy Statement Development: Public 

Meeting and Request for Comments; Correction, dated January 29, 

2009. NRC-2009-0013 

The Strategic Teaming and Resource Sharing (STARS)1

 alliance submits the enclosed 

comments in response to the referenced Federal Register notices soliciting comments 

on the Commission’s development of a Safety Culture Policy. The STARS alliance 

applauds the Staff’s evaluation and public outreach in this effort. As the comments 

generally reflect, STARS takes seriously the responsibility of the licensee in establishing 

and maintaining a strong nuclear safety culture. Further, STARS believes that the best 

approach is strong licensee ownership of the assessment and ownership of the 

resolution of any identified deficiencies. 

1

 STARS consists of thirteen plants at seven stations operated by Luminant Power, 

AmerenUE, Wolf Creek Nuclear Operating Corporation, Pacific Gas and Electric 
 47

Company, STP Nuclear Operating Company, Arizona Public Service Company, and 

Southern California Edison. 

Safety Culture Policy Comments 

The following comments are provided regarding the current implementation of the NRC’s 

initiative on safety culture. 

1. The policy statements for safety culture should not differentiate between 

organizations. STARS feels that the defined set of safety culture attributes are 

transferable across all organizations. Security has long been recognized as a key 

element to safe facility operation and radiation protection. The artificial creation of a 

distinction based on safety culture will likely induce unintended divisions. There should 

be one defined statement and policy. 

2. For power reactors subject to the Reactor Oversight Process (ROP), the set of 

attributes defining nuclear safety culture should align with those developed by the 

Institute of Nuclear Power Operations (INPO). This set of attributes has well-established 

definitions, clear evaluation criteria, and comprehensive implementation guidance. 

Moreover, STARS feels that the INPO evaluations or independent safety assessments 

by third parties are more comprehensive and better at determining a station’s safety 

culture performance. The NRC’s use of different terminology and binning criteria, such 

as the assigned cross-cutting aspects, has created confusion and uncertainty in 

communications. 

3. The STARS alliance encourages the NRC to consider other approaches, such as the 

Industry’s Alternative Nuclear Safety Culture Approach. This approach emphasizes the 

licensee’s responsibility for the identification of safety culture performance issues. This 

proposal makes clear that the burden for establishing and maintaining an appropriate 

safety culture rests with licensee management. This approach acknowledges two critical 

elements, that safety culture is a licensee responsibility and that it cannot be inspected 

or regulated into a station. The approach helps strengthen station ownership through the 

use of robust assessments such as the Utilities Service Alliance self-assessment and 

the station’s ownership of issue resolution using its Corrective Action Program. We 

understand the NRC will remain engaged in safety culture but consideration of the 

approach described above emphasizes a licensee ownership of safety culture. 

4. For power reactors the NRC assigns Substantive Cross Cutting Issues (SCCI) based 

on the number findings with particular cross-cutting aspects. These aspects are 

frequently assigned absent a full understanding of the cause(s) of the condition(s). As 

such, associated SSCIs may improperly characterize station performance weaknesses, 

resulting in the diversion of significant resources away from key performance issues, 

aggravating performance on those issues. If the process is to be continued, more rigor is 

needed in the assignment of cross-cutting aspects. Further, there is no defined appeal 

process for disagreements over the assignment of cross-cutting aspects. Such a 

process is necessary such that consensus on performance issues is achieved. 

5. Absent changes to either the thresholds for assigning cross cutting aspects to findings 

or the threshold for issuing SCCIs, the Staff’s proposed reduction in the number of 

crosscutting component areas will effectively increase the number of SCCIs. This, in 
 48

turn, will result in the diversion of licensee resources to these issues and away from 

more fundamental elements of performance. For example, currently under the Human 

Performance Area of Work Practices there are the Aspects of H.4 (a) for Error 

Prevention tools and H.4 (b) for Procedural Compliance. These are both high use 

aspects that are commonly assigned to findings. Under the new Safety Culture 

Component plan these are combined into the one aspect WP1 under the component of 

Work Practices. This will greatly increase the likelihood of reaching the number defining 

a cross cutting theme. This would result in an increase in the number of plants that 

require Regional Assessment of their actions to determine if a Substantive Cross Cutting 

Issue should be issued. If this change is implemented, then a change to increase the 

number that defines a common theme should be considered. 

STARS appreciates the NRC’s request for stakeholder input and would welcome further 

interaction with the NRC staff. 

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