July 18, 2008 

MEMORANDUM TO: Peter Habighorst, Chief /RA/ 

Fuel Manufacturing Branch 

Division of Fuel Cycle Safety 

 and Safeguards, NMSS 

FROM: Amy M. Snyder, Senior Project Manager /RA/

Fuel Manufacturing Branch 

Division of Fuel Cycle Safety 

 and Safeguards, NMSS 

SUBJECT: JUNE19, 2008: SUMMARY OF THE OFFICE OF NUCLEAR MATERIAL 

SAFETY AND SAFEGUARDS, SAFETY CULTURE PILOT WORKSHOP 

Enclosed is the summary of the June 19, 2008, Office of Nuclear Material Safety and 

Safeguards (NMSS), Safety Culture Pilot (Pilot) Workshop, conducted as part of the 2008 Fuel 

Cycle Information Exchange (FCIX) Conference. The purpose of the workshop was to inform 

stakeholders of the NMSS Safety Culture Pilot Phase I accomplishments, and to obtain input 

regarding the options for the Pilot. The workshop was facilitated by Lance Rakovan, from the 

Office of the Executive Director for Operations, Communication Innovation Budget Branch. 

Approximately 50 people attended the workshop which lasted the full 2.5 hours. 

As indicated at the Workshop, the summary will be placed on the FCIX Conference and the 

Office of Enforcement’s Safety Culture Web sites within 30 days of the workshop. 

CONTACT: Amy Snyder, NMSS/FCSS 

 (301)492-3225 

Enclosure: 

Workshop Summary 

cc: Lance Rakovan 

 Isabelle Schoenfeld 

Tina Ghosh 

 June Cai 

 James Firth 

 Jay Henson 

 Nilda Rivera 

 Amy Lueberring 

 Ray Wharton 
 

July 18, 2008 

MEMORANDUM TO: Peter Habighorst, Chief /RA/

Fuel Manufacturing Branch 

Division of Fuel Cycle Safety 

 and Safeguards, NMSS 

FROM: Amy M. Snyder, Senior Project Manager /RA/

Fuel Manufacturing Branch 

Division of Fuel Cycle Safety 

 and Safeguards, NMSS 

SUBJECT: JUNE19, 2008: SUMMARY OF THE NUCLEAR MATERIAL SAFETY 

AND SAFEGUARDS, SAFETY CULTURE PILOT WORKSHOP 

Enclosed is the summary of the June 19, 2008, Office of Nuclear Material Safety and 

Safeguards (NMSS), Safety Culture Pilot (Pilot) Workshop, conducted as part of the 2008 Fuel 

Cycle Information Exchange (FCIX) Conference. The purpose of the workshop was to inform 

stakeholders of the NMSS Safety Culture Pilot Phase I accomplishments, and to obtain input 

regarding the options for the Pilot. The workshop was facilitated by Lance Rakovan, from the 

Office of the Executive Director for Operations, Communication Innovation Budget Branch. 

Approximately 50 people attended the workshop which lasted the full 2.5 hours. 

As indicated at the Workshop, the summary will be placed on the FCIX Conference and the 

Office of Enforcement’s Safety Culture Web sites within 30 days of the workshop. 

CONTACT: Amy Snyder, NMSS/FCSS 

 (301)492-3225 

Enclosure: 

Workshop Summary 

cc: Lance Rakovan 

 Isabelle Schoenfeld 

Tina Ghosh 

 June Cai 

 James Firth 

 Jay Henson 

 Nilda Rivera 

 Amy Lueberring 

 Ray Wharton 

DISTRIBUTION: 

FCSSr/f 

ML081990028 

OFFICE FMB FMB FMB FFLD 

NAME ASnyder VCheney PHabighorst MTschiltz 

DATE 07/17/08 07/17/08 07/18/08 07/18/08 

 OFFICIAL RECORD COPY
 

Summary of US Nuclear Regulatory Commission 

Office of Nuclear Material Safety and Safeguards Safety Culture 

Workshop at the 2008, Fuel Cycle Information Exchange 

June 19, 2008 

The purpose of the June 19, 2008, meeting was to discuss with stakeholders the Office of 

Nuclear Material Safety and Safeguards (NMSS) Division of Fuel Cycle Safety and Safeguards 

(FCSS) Safety Culture pilot. The US Nuclear Regulatory Commission (NRC) staff presented 

preliminary results from the data gathering activities in Phase I of the pilot, and solicited input 

from stakeholders on options for implementation of the pilot. NRC’s presentation slides are 

available at: http://www.nrc.gov/public-involve/conferences.html (under Fuel Cycle Information 

Exchange – 2008) and http://www.nrc.gov/about-nrc/regulatory/enforcement/safety-culture.html

(under Public Meetings and Materials). 

During the NRC presentation on the background for the pilot, a stakeholder asked what 

endpoint the NRC is trying to achieve, and what specific direction was provided to the NRC 

staff. The NRC staff explained that the goal is to assess whether the current fuel cycle 

inspection and assessment program could be enhanced with respect to safety culture, and 

whether lessons learned could be applied from the safety culture reactor oversight process 

(ROP) safety culture enhancements. The NRC staff discussed a Commission Staff 

Requirements Memorandum that referred to continuing the initiative after it had begun, and 

Martin Virgilio’s speech at the 2006 Fuel Cycle Information Exchange about operating 

experience that shows safety culture contributes to events. 

A couple of stakeholders expressed concern that the initiative may not be consistent with a 

regulator’s role, which is to set requirements and make sure licensees follow them. A 

stakeholder expressed concern that this initiative seemed like it was moving beyond regulatory 

space and trying to add safety margin. There were also questions about what the NRC means 

when it says it will not regulate a licensee’s safety culture. The NRC staff explained that the 

goal is to improve NRC’s regulatory process and develop tools to make better use of insights 

from inspections, but that NRC would not take action unless there are regulatory violations. 

Safety culture enhancement of the FCSS inspection program could provide an additional layer 

of insights to help NRC focus on problem areas (based on violations, and their causal factors) 

before a serious problem (like the Davis Besse event) can arise. Another stakeholder 

expressed concern that licensees feel that the safety culture enhanced oversight approach for 

reactors is not working. NRC staff responded that through the Reactor Oversight Process 

(ROP) self-assessment program the NRC is currently assessing all feedback, including that 

from the Nuclear Energy Institute and the Regional Utilities Groups; some changes are planned, 

but the feedback does not indicate that the process is not working. In addition, the NRC staff 

stated that the goal is not to impose the ROP on fuel cycle facilities, but rather to assess 

whether the similar beneficial oversight tools in the area of safety culture could be developed 

and used for fuel cycle facilities, and take advantage of lessons learned from the ROP 

enhancements. 

A couple of stakeholders asked about the appropriate role of the Institute of Nuclear Power 

Operations (INPO) versus the NRC with regard to licensees’ safety culture, and suggested that 

perhaps it is more appropriate for INPO to use its existing safety culture criteria and apply it to 

fuel cycle facilities. NRC staff responded that NRC worked with INPO during the development 

of safety culture enhancements for the ROP, and changed some of the wording of the safety 

Enclosure 
 

culture components after comparing them to INPO’s safety culture principles and attributes, to 

gain commonality. Because of the NRC’s need to be transparent as a regulator, it would be 

challenging to rely on INPO’s processes which are non-public and confidential. In addition, 

INPO’s focus is on excellence, which goes beyond adequate safety. The NRC recognizes that 

INPO supports nuclear safety, but NRC and INPO’s roles are different. 

One stakeholder stated that INPO and the utilities expended many resources to formulate good 

safety culture components, and the result is that the INPO attributes are easily understood. The 

stakeholder expressed concern that in comparison, the NRC’s components are confusing. The 

NRC staff responded that NRC is in the process of revising the components and there will be 

opportunity for stakeholder feedback. Some of the key issues that are planned to be addressed 

in the revision include: reducing redundancy, including security where appropriate, reducing 

confusion for inspectors in deciding which aspect within a component is appropriate, clarifying 

the components, and merging safety-conscious work environment and problem identification 

and resolution. 

A stakeholder asked whether the NRC would use safety culture information in deciding whether 

the corrective action for a violation is adequate. NRC staff responded that one of the options 

NRC will explore includes reviewing and assessing the enforcement process to identify any 

beneficial enhancements. 

During the discussion of the pilot implementation options, many stakeholders expressed their 

agreement that safety culture is important. One stakeholder further expressed that arriving at a 

common understanding of safety culture concepts and terminology in the fuel cycle facility 

community, and increased education for inspectors and staff, would be beneficial. However, 

stakeholders expressed a number of concerns about the NRC’s potential direction in enhanced 

oversight, which is discussed below. 

A number of stakeholders supported the “No Action” alternative and offered various reasons. 

One stakeholder expressed concern that NRC might inappropriately delve into the realm of 

management, or that the NRC’s enhanced oversight process might have the inadvertent 

consequence of undermining management strengths at licensee facilities. One stakeholder 

expressed concern that increased inspector focus on the corrective action process, self 

assessments, and other safety culture component areas, could have a chilling effect on workers 

and the unintended consequences of reduced reporting (of problems or issues). A couple of 

stakeholders expressed concern that adding safety culture insights to inspection procedures 

would be subjective and result in disagreements between the NRC and licensees. One 

stakeholder expressed that safety culture can not be inspected, but rather assessed; hence it 

would be difficult to tie safety culture to inspection procedures. One stakeholder expressed the 

view that appropriate mechanisms to detect problems are already in place in NRC’s current 

oversight program. One stakeholder recommended exploring the increase use of the Alternate 

Dispute Resolution (ADR) process and considering whether the program could be expanded to 

address safety culture issues, and pointed to the Nuclear Fuel Services (NFS) ADR case as an 

example. The NRC staff responded that although the NFS ADR result was positive, it was 

complicated and it is not clear whether that is a case to emulate. In response to the other 

concerns, the NRC staff responded that the safety culture components and any changes in the 

inspection programs will be used in a pilot format, and stakeholder feedback will be collected 

periodically during identification and development of any potential enhancements. In addition, 

whatever option is selected for the pilot will have accompanying inspector and staff training to 

ensure consistent understanding and application. 

-2- 
 

Stakeholders expressed a number of concerns during the discussion of Option 2. One 

stakeholder commented that the 13 safety culture components are subjective and some areas 

are very sensitive, and the proposed approach, would add more burden in the regulatory 

process with little value. One stakeholder expressed the view that what NRC can do in terms of 

conducting assessment of safety culture is not as strong as what the licensees can do for 

themselves, and it would be difficult for inspectors to make cogent assessments of safety 

culture issues. One stakeholder expressed the view that there needs to be an incentive for sites 

that are not making an adequate effort in safety culture assessments. One stakeholder 

commented that although the INPO process is not transparent to the public, that lack of 

transparency is important to the critical feedback that can be provided to the site. One 

stakeholder stated that licensees have made improvements without being forced, through their 

corrective action programs, and expressed concern that the NRC enhancements might hurt 

management culture at the licensee facilities. One stakeholder stated that all safety culture 

components are important, there should not be too much focus on a subset of components, and 

that safety culture goes beyond the 13 components identified by the NRC. The NRC staff 

responded that more detailed definitions (aspects) are available for each component but not 

provided at this meeting; these details were developed for reactors but are yet to be developed 

for the FCSS environment. In addition in the ROP, certain thresholds must be reached before 

actions are taken by the NRC (i.e., one safety culture aspect contributor to one inspection 

finding does not automatically result in required actions by the licensee). NRC also agreed that 

all components are important. 

During discussion of Option 3, a stakeholder stated that NRC needs to be clear about inspection 

versus assessment, and felt that it would be naïve to believe safety culture could be directly 

translated into the inspection program. 

During discussion of Option 5, one stakeholder asked why this option includes security and 

safeguards specifically while the other options do not. NRC responded that Option 5 is an 

integrated, comprehensive option. Other stakeholders commented that safety culture is not 

limited to just nuclear safety, and it is not possible to have a strong safety culture without 

consideration of security; and that NRC should be careful in using the words, and distinguishing 

between, safeguards and security. The NRC staff stated that during the interviews of both NRC 

staff and site licensee staff, interviewees were able to see the applicability of the safety culture 

components to security. 

In the closing discussion, a stakeholder asked whether the interview questions used during the 

information collection phase of the pilot will be provided in the final report, and NRC staff 

answered affirmatively that they would be. Another stakeholder asked who would be writing the 

Temporary Instruction (TI) for implementation of the pilot and whether regional staff would be 

involved. NRC staff responded that yes, Region II had been fully engaged throughout the 

activities and would be part of the team developing the TI, if management selected an option 

that involved such an activity. One stakeholder expressed the concern that causal analysis 

takes teams of people over weeks of time, and if inspectors are expected to identify causal 

factors, adequate resources will need to be built into the process. 

The NRC staff closed with the reminder that this was the first of many planned interactions 

where stakeholder input will be sought, and encouraged stakeholders to provide any written 

feedback to the NRC project lead by July 21, 2008. 

 -3-