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Public Workshop on Development of a 

Policy Statement on Safety Culture and Security Culture 

February 3, 2009 

Meeting Summary 

Session 2: Safety Culture / Security Culture 

Panelists: 

• Martin Virgilio (NRC), on behalf of the International Atomic Energy Agency (IAEA) 

• Ron Teed, Nuclear Security Association (NSA) 

• Tony Petrangelo, Nuclear Energy Institute (NEI) 

• Shawn Seeley, Organization of Agreement States (OAS) 

• Pete Stockton, Project on Government Oversight (POGO) 

Panelists’ Presentations: 

• M. Virgilio’s presentation on IAEA’s approach to safety culture and security culture 

discussed the challenges with the interface between safety and security. Some of 

these included inadvertent versus malicious intentional acts and sharing information 

freely versus limiting information to a need-to-know basis. IAEA has separate policy 

statements regarding safety and security culture. In part, this is the result of the 

characteristics of safety and security culture and part due to organizational factors at 

the IAEA. 

• NEI does not want separate safety/security culture policy statements. NEI pointed 

out that the various departments within an organization have their own culture, yet 

NRC does not expect to have different policy statements for each department. 

Safety culture integrates various functions, and NRC should ensure that one policy 

statement addresses each function (department). 

• POGO listed several negative security events that they expressed as safety culture. 

These issues include: an unrealistic design basis threat (DBT), excessive overtime 

leading to guard inattentiveness, guards being out-gunned and not prepared to take 

on a surprise attack, not enough training for guards, too much advance notice for 

force-on-force (FOF) exercises, etc. POGO indicated that many of the security 

problems can be attributed to the NRC. POGO had no opinion on either a single or 

two policy statements. 

• OAS expressed that generally one policy statement would be best but is concerned 

that one size does not fit all. Health and safety are already integrated, so security 

should be included since they are all interconnected. 

• NSA wanted a single policy statement because security is well-integrated into plant 

processes already. Separate policies may negatively reinforce the belief that 

security is held to a different standard than safety. Security culture should be 

considered to be a subset of safety culture. Corrective action programs (CAPs), 

employee concerns programs (ECPs), and the NRC are successful avenues to 

address security issues. Current plant surveys and audits review security. Allow 
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licensees to choose different approaches to achieve the overall policy objective. 

Have clear expectations, but do not prescribe the methodology for achieving those 

expectations. 

Stakeholders’ Comments: 

Support for a single policy statement 

• One organization had problems with separating safety and security culture with 

respect to differences in processes causing confusion. They are trying to integrate 

security culture into safety culture. If NRC creates different policies, this would be a 

step backwards and create separation within organizations. There was a suggestion 

to have a regulatory guide for integrating security into plant processes since this 

integration is critical for raising security standards to operations-level standards. 

Having one overall policy would help with this. 

• Support for NEI’s position for one policy statement was expressed because it can be 

confusing to separate security from safety. Security should be raised to the same 

level as human performance standards. 

• There should be one unified policy and allow different implementation. Safety 

integrates all aspects of the organization. 

• There should be one combined policy statement. Security employees should know 

and be trained that they are covered by the same employee protection rights. 

Security organizational structures tend to be more rigid than operations or 

maintenance departments, and security employees may not feel comfortable 

bypassing their chain-of-command regarding raising issues. It’s dangerous to have 

two different standards. Safety does incorporate security. 

• Initial reaction was to have separate policies because a contracted security force will 

have a separate culture from the rest of the plant, but now leaning toward using one 

policy to force integration of the security force into the plant’s culture. By its nature, 

the security force will have a separate culture from the rest of the plant. 

• Have one policy, but acknowledge that safety and security issues need to be 

handled differently. 

• Have one policy, but acknowledge the differences in organization levels. The same 

set of behaviors needs to be achieved throughout organization levels. 

Support for separate policy statements 

• Safety and security discussions should be separate because they are separate 

concepts. Although separate policy statements were suggested, the two should 

have equal importance. 
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Weighting or precedence of safety and security 

• NRC asked that if the NRC promotes one policy statement, should safety and 

security be weighted equally or should one subsume the other or be weighted 

differently. Those that responded to the question directly said that security is a part 

or subset of safety culture. Security is an element of safety culture, not a separate 

entity. Some agreed with this notion. Further, those responding indicated that they 

believed that: the issues cannot be weighted, weighting would depend on the 

individual issue’s significance, an appropriate weighting cannot be quantified, and 

the “one size fits all” approach is not likely to work. 

• The following questions were asked - “Does security have more importance than 

radiation safety, health physics, and other aspects of nuclear power plant operation? 

Are we creating an issue by drawing attention to security?” 

• Issues need to be weighted because the policy could be unfair to small materials 

licensees. 

General comments

• Security issues receive limited discussion during large meetings at licensees, but the 

issues are discussed “off-line.” Safeguards information needs to be controlled, and 

there are means for entering security issues into the Corrective Action program 

(CAP) using the same processes and procedures as other plant issues. Discussions 

can be held off-line with senior-level managers. Security issues entered into the 

CAP are given the same priority as other issues and receive the same level of 

response, but safeguards information needs to be controlled. 

• IAEA’s organizational structure may provide insights as to why they have separate 

safety and security policies. 

• The policy needs to be people-focused versus administratively-focused. Employees 

and supervisors should respond to the policy in the same way. The differences in 

how people in different positions think and act should not be emphasized, but they 

should not necessarily think and act in the same way. 

• Encompassing all levels will be difficult. There may be a “one size fits all” policy for 

top-level people, but top-down differences need to be addressed. 

• NRC should not assume or have confidence that workers use the common means 

for reporting concerns (e.g., CAP, employee concerns program, NRC). One 

organization has received reports from nuclear power plant employees that they are 

not using these avenues, and that employees get the most pressure during outages. 

 
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Session 3A: Materials Area Considerations 

Panelists: 

• Shawn Seeley, State of Maine, representing the Organization of Agreement 

States (OAS) and the Conference of Radiation Control Program Directors 

(CRCPD) 

• Michael Sheetz, University of Pittsburgh 

• John Nagy, Nuclear Fuel Services 

Panelists’ Presentations: 

• The State of Maine expressed the view that security and health and safety go 

“hand-in-hand,” which is the approach that is currently being taken in most of the 

States. NRC’s approach needs to be: (1) performance-based, (2) appropriately 

consider the relative risk of the activities, and (3) generic enough to address the 

range of different types of licensees. The guidance needs to be simplified and 

made un-burdensome, and there is a need for uniformity, based on sound policy. 

The question of whether NRC is reacting to interest of Congress at the expense 

of the States was posed. 

The following suggestions for moving forward with the development of the policy 

statement were made. The NRC should look at vulnerability versus the actual 

risk. The NRC should use data (e.g., the number of devices that have been 

stolen, including attempts to steal the devices before and after the 

implementation of the increased security requirements). The NRC needs to 

listen to the stakeholders and avoid making the presumption that the NRC knows 

best. There is the need to continue to “trust, but verify.” 

• The University of Pittsburg asked the question whether there is data (e.g., 

incidents, regulatory violations) to support a need to increase the level of safety 

for all materials users was posed. Before increasing the focus in the area of 

safety culture, it needs to be justified on the basis of risks and benefits, and 

efforts might be better allocated to areas that pose higher risk. 

In the medical and university environment, safety culture for radiation sources is 

closely linked to the chemical, biological, and patient safety practices. The 

important components for maintaining a culture of safety are: (1) training and 

instruction on policies and procedures, and (2) monitoring compliance through 

audits and surveillance. Nuclear power plants and materials users (e.g., medical 

and academic) are worlds apart. 

One approach to increasing attention to safety culture at materials licensees 

would be through the standards of practice that are developed by professional 

societies (e.g., Society for Nuclear Medicine (SNM), American Association of 

Physicists in Medicine (AAPM), Health Physics Society (HPS), American College 

of Radiology (ACR), and American Society for Therapeutic Radiology and 

Oncology (ASTRO)) and adopted by licensees. 

The level of safety culture being promoted should be proportional to the risk (e.g., 

type, quantity, and use of material). The policy should address performance-
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based goals. It may be difficult to express a single policy that gives appropriate 

weight and balance for safety culture across the range of licensees. 

The security of sources in the medical and academic community presents unique 

challenges and there is difficulty associated with maintaining different levels of 

control while working in open and collaborative environments. The current set of 

increased controls focus on access controls, whereas more effective security 

may be achieved through detection and response. Security requirements for 

licensees should be prescriptive. Prescriptive requirements would eliminate 

differing interpretations. There should be separate safety and security policy 

statements. 

NRC’s interactions with licensees can improve the attention that licensees give to 

maintaining safety and security culture. The following suggestions were 

provided. The NRC should continue to electronically publish NRC Information 

Notices, the Office of Federal and State Materials and Environmental 

Management Programs (FSME) licensee newsletter, and Regulatory Information 

Summaries (it was noted that Agreement States do not provide similar electronic 

publication of their information). NRC should not cite licensee self-identified 

violations, if appropriate corrective action has been taken. A zero-tolerance 

enforcement policy has the potential to negatively affect efforts to maintain a 

culture of compliance. There is a need for consistent safety and security policies, 

and the interpretation and enforcement of radiation protection requirements 

should be the same throughout the country. 

• Nuclear Fuel Services expressed the view that there is a business case for 

maintaining safety culture. At NFS, safety is used to include: (1) health and 

safety, (2) safeguards and security, (3), environmental stewardship, and (4) 

quality. NFS uses one “safety and compliance” policy that adopts the NRC’s 13 

safety-culture components, where safety and security are treated equally as part 

of one culture of compliance, and it is important that all players are involved and 

that both safety and security are open to discussion. 

The safety culture self-assessment performed by NFS provided value and 

resulted in better ownership of the issues by NFS. A third-party assessment 

provided validation of the self-assessment and identified some new areas to be 

addressed. 

Addressing remarks made earlier by University of Pittsburg, NFS indicated that in 

addition to the differences in the classes of licensees, there are vast differences 

within each class of licensee. There is a need to reflect the differences that exist. 

The following suggestions were provided: (1) the policy statement should be 

written as one culture, (2) there should be a single standard (of expectations), 

and 3) safety culture should be incorporated into the Licensee Performance 

Review (LPR) process. Safety culture should not be treated as an “inspection 

area,” because the use of inspections would take the ownership of the issues 

away from plant management. Licensees should conduct self-assessments, so 

that they have ownership of the issues. The NRC can provide their own 

perspective and can evaluate the licensee’s self-assessment. 
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Stakeholder Comments: 

Safety Culture Components 

• The draft safety culture components are general enough so as to be applicable to 

it. 

Need for a Policy Statement 

• There is a need for a policy statement, because historically, there have already 

been some serious mistakes. Being proactive is good, and it also helps the 

bottom line. 

• In response to a question regarding whether there is any indication that there is a 

lack of safety with licensees, NRC responded that there is not a lack of safety but 

there is room for improvement. Examples such as a number of abnormal 

occurrences (AOs) in the medical area, gauge users, a number of near misses 

and extremity over exposures in the radiography area were cited. There was 

consideration given to establishing regulations in response to these incidents, but 

a better way may be a policy statement. 

Prescriptive, Performance-Based, or Graded Approach 

• When moving into regulation and inspection guidance, that is entering a grey 

area, and it is important to be performance based and risk based. 

• Any policy statement needs to be graded. The issues are not with the broad 

statement of policy and general attributes, but in the implementation and 

inspection. If expectations are established in inspections, the graded approach 

may break down. 

• An organization can have very different facilities, where the risk profiles are 

dramatically different. The risk profile needs to be addressed. 

• Understand, but disagree with, University of Pittsburg on whether security should 

be addressed prescriptively and prefers flexibility. 

• There can be different guidance for different types of licensees. 

Consistency 

• It would be almost impossible to develop one interpretation for all 35 Agreement 

States. The policy statement should be generic enough where it can be used as 

concrete guidance. Without a single policy, that would lead having multiple 

policies, which would result in inconsistency. There is a need to enhance the 

policy by making it concrete, and there are a lot of policies out there already. 

• Complexity arises because NRC regulates some activities, and other portions are 

regulated by Agreement States. One organization has been struggling with 

efforts to standardize attributes, such as in areas of their Corrective Action 

Program and Safety Conscious Work Environment. Consistency is preferred. 
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• A question was asked whether there were any thoughts to making the policy a 

matter of compatibility, specifically Category B. 

Other Safety and Security Considerations 

• The difference in safety and security is not a significant issue. In developing a 

training program at one facility, the security staff sit through the discussions of 

safety issues and, similarly, the safety staff sit through the discussion of security 

issues (i.e., all of the staff get training in safety and security). Safety culture is 

built up with training systems in place for years, but that there is not a large 

difference between safety culture and security culture. 

• At one organization, all employees are trained on security and the security staff 

are trained on safety — focusing on the category 2 sources, because, in general, 

the radiation risks are less than the chemical and biological risks for many 

activities. 

• Good training is important, and some training relating to cultural issues (e.g., 

Safety Conscious Work Environment) should be performed. 

One Policy Statement or Separate Policy Statements 

• There should be one policy statement. 

• Regarding including the unique aspects of security, the question whether NRC is 

making security a unique aspect of safety was asked. Other aspects of safety 

programs include criticality safety, environmental protection, and chemical safety. 

How Might NRC Increase Attention to Safety Culture in the Materials Area and 

What Might the NRC do Differently? 

• One organization routinely requests inspections from Agreement States, but the 

Agreement States do not inspect when requested because of a lack of funds. 

The attention to safety culture would be improved, if licensees can get 

Agreement States to inspect when requested, so that problems can be identified 

early. 

• NRC should change the paradigm and reach out more to the regulated 

community, specifically individual doctors and employees (i.e., focusing on 

education and public awareness). NRC should consider developing different 

levels of certifications, such as a indicating a high level of safety conscious 

awareness. 

• NRC should provide positive feedback when licensees are doing well. 

Other Comments 

• NRC could bring people together by establishing common language and 

attributes, but if NRC pushes its policies too far, it could be counter-productive. 

The Institute for Nuclear Power Operations (INPO) and NEI could work within the 

industry to establish such common language. 
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Session 3b: Reactor Area Considerations 

Panelists: 

• Audrey Klett (NRC) 

• Ed Sherer, Southern California Edison (SCE), Regional Utility Group IV 

• Tom Houghton, Nuclear Energy Institute (NEI) 

• Frank Maciuska, Professional Reactor Operator Society (PROS) 

• Billie Garde, of Clifford and Garde, LLP 

Panelists’ Presentations: 

• NRC’s presentation provided an overview and history of how safety culture is 

addressed within the framework of the Reactor Oversight Process (ROP) and 

discussed recent changes to NRC guidance reflecting lessons learned 

implementing the safety culture enhancements. NRC pointed out that the 

Commission directed the staff in 2006 (1) to enhance the ROP’s treatment of 

cross-cutting issues to more fully address safety culture, (2) to include inspection 

requirements to evaluate a licensee’s safety culture for plants with significant 

performance issues, and (3) to ensure that the safety culture enhancements 

were consistent with regulatory principles that guided the development of the 

ROP (i.e., be transparent, understandable, objective, predictable, risk-informed, 

and performance-based). The staff revised the appropriate guidance documents 

accordingly and implemented the enhanced guidance in July 2006. Following an 

18-month initial implementation period, the staff further revised the guidance 

documents based on lessons learned and feedback from interested 

stakeholders. Specifically, the staff revised Inspection Manual Chapter (IMC) 

0305, “Operating Reactor Assessment Program,” and Inspection Procedure (IP) 

95003, “Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple 

Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input,” in January 

2009. In addition, IP 71152, “Identification and Resolution of Problems,” is being 

revised and should be issued shortly. 

• SCE’s presentation focused on an alternate approach for addressing safety 

culture, noting that the industry is responsible for safety and security at their sites 

and the NRC is responsible for oversight. Under this alternative approach, the 

industry would assess the health of its safety culture, and would conduct periodic 

assessments based on the (INPO Principles and Attributes and the Utilities 

Service Alliance (USA) approach. This approach would replace part of the 

parallel NRC process, and it was recommended that the industry and NRC 

employ a common methodology and terminology with respect to safety culture 

assessments. 

• NEI’s presentation provided additional detail to the industry’s proposed 

alternative approach. NEI noted that there is a Nuclear Safety Culture 

Assessment Task Force that is developing a guideline based on the INPO and 

USA approach that could be used for self, independent, and third-party safety 

culture assessments. NEI noted its intention to provide the guideline to the NRC 

for its review and plans to invite the NRC staff to observe the assessment 

approach. 
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• PROS presented their code of ethics emphasizing their commitment to the 

preservation of public health and safety. The differences between a site’s safety 

culture and security culture were emphasized, and the INPO and IAEA principles 

of safety and security culture were compared. PROS indicated that safety 

culture as applied to reactors does not need to be strengthened, because 

although the NRC can be the driver for safety, safety culture stems from the 

values and behaviors of individuals and an organization. 

• B. Garde noted her concerns with both the NRC’s and industry’s approach to 

safety culture and noted disappointment in progress to date. She noted that both 

USA and INPO approaches are missing the safety conscious work environment 

(SCWE) and harassment and intimidation aspects. She felt that NEI/industry 

needs to adapt to meet the NRC expectations. She also noted that four aspects 

over time is not a timely indication of safety culture deterioration, and neither is 

the 2-year biennial self-assessment proposed by industry. She pointed out that it 

takes a long time to repair poor safety culture, but it can deteriorate more rapidly. 

She stated that safety culture issues at Davis-Besse were due to people not 

willing or motivated to report safety concerns. She felt that safety culture needed 

to be resolved prior to new reactor construction, and that she’d welcome the 

opportunity to review the industry's proposal. 

Additional Stakeholder Comments and Discussions: 

• The current ROP safety culture guidance is too narrow and prescriptive and is not a 

leading indicator of declining performance. Precursors of declining performance 

include the physical condition of the plant and the health of a licensee’s corrective 

action program. 

• ROP safety culture guidance and assessment of licensee actions for closing 

substantive cross-cutting issues requires subjective judgments. NRC staff decisions 

are not consistent, predictable, repeatable, nor transparent. 

• The cross-cutting issue process is very complex and could miss a recurrence similar 

to the Davis-Besse plant phenomenon since the NRC focuses additional inspection 

effort on plants with declining performance rather than on plants in the Licensee 

Response column of the ROP Action Matrix. 

• The NRC should continue to evaluate allegations and the SCWE at sites, and 

industry safety culture assessments should be conducted more frequently than once 

every two years. Frequent safety culture surveys may lead to “survey fatigue” and 

will have less meaning and value. 

• The NRC’s proactive safety culture assessment at nuclear power plants should not 

be eliminated. Industry’s attempts to improve the self-assessment process at plants 

are supported, but the industry’s self-assessment process should complement rather 

than replace NRC’s oversight. 

• The NRC and the nuclear industry should adopt a common language to describe 

safety culture attributes and principles. 
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• NRC staff should develop clear expectations and directives for establishing an 

adequate safety culture, including direction on how periodic reviews would be 

performed. 

• The NRC staff should develop a Regulatory Issue Summary or Regulatory Guide 

that explains its expectations. 
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Summary and Wrap-up Session

Summary of Session 3A and 3B 

$ The reactor session highlights summary discussed the key points of the reactor 

session. 

o The NRC has revised the inspection program to include lessons learned 

from implementation of the safety culture changes. No changes were made 

to the safety culture components or aspects currently used under the ROP. 

Once the Agency implements the Policy Statement, the ROP will be 

reviewed for revisions needed to incorporate the Policy Statement guidance. 

o Some believed that the current ROP is narrow and prescriptive and that it is 

not an accurate indicator of performance. There was also a comment about 

the ROP not being a leading indicator for declining performance. 

o The problem identification and resolution (PI&R) program is the cornerstone 

of precursors, but rigor and transparency could be a challenge. 

o Industry believed they should own safety culture and conduct safety culture 

assessments with common and transparent methodology. The industry will 

be developing a safety culture program and will conduct their own safety 

culture assessments, which will be structured on INPO’s principles and 

attributes. The USA methodology could serve as the industry standard, and 

peer-assisted self-assessments could be structured on INPO's Principles 

and Attributes. 

o The industry’s approach is missing the SCWE aspects of safety culture, 

which are covered by NRC’s components and aspects. 

o The human element (people and relationships) is a primary piece of safety 

culture, which is driven by solid leadership. 

o One of the challenges mentioned was that it can take a long time to repair 

safety culture if it is not maintained, but it can deteriorate easily. 

$ The Materials session highlights summary discussed the key points of this area. 

o There was wide participation from a range of stakeholders. The wide variety 

among these licensees but how there are also similarities was discussed. 

o The safety culture components apply to all the licensees. 

o The components should be well defined due to the wide variety of licensees 

and certificate holders and should also give flexibility to be applicable to the 

wide range of materials licensees. 

o There is need for consistency because of differences between the NRC and 

the agreement states. 

o In general, the views expressed indicated that that there should be no 

division between safety and security safety culture. 

o There was concern regarding the implementation of the policy – that there 

could be potential challenges when imposing expectations during 

implementation, such as through inspections activities. 

o The NRC should not only reach out to the licensees but also to reach out to 

the individual licensee employees in order to increase the awareness on 

safety culture. 

o Other ways NRC could increase attention on safety culture to materials 

licensees were discussed. 
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Other Discussion Items 

$ Productive discussions took place and consensus was reached on several 

discussion items. 

$ NRC should explain how it went from the 13 (currently used by the ROP) to the 9 

proposed safety culture components. NRC staff responded that the Commission 

paper would discuss the process used. 

$ In general, most proposed to have one policy statement where the security would 

be a subset of the safety culture. 

$ There were good discussions regarding implementation issues and how licensees 

will affected. 

$ The NRC and the Agreement States should work together on the implementation 

of the Policy Statement. 

$ It was a good workshop that invited open dialogue between the industry, the NRC 

and the Agreement States. 

$ There will be opportunity to comment on the Policy Statement, after the draft is 

reviewed and approved by the Commission. 

Next Steps 

$ The staff discussed the milestones for the development the Commission Paper 

and draft Policy Statement, which will be ready by the end of April. At the end of 

May, there will be a Commission meeting. Following Commission review and 

approval of the draft Policy Statement, it is likely to be published in the Federal 

Register Notice for public comment. 

$ The Commission paper will discuss the comments and the recommendations 

made by stakeholders.