March 7, 2011 

MEMORANDUM TO: R. W. Borchardt 

 Executive Director for Operations 

FROM: Annette L. Vietti-Cook, Secretary /RA/ 

SUBJECT: STAFF REQUIREMENTS – SECY-11-0005 – PROPOSED FINAL 

SAFETY CULTURE POLICY STATEMENT 

The Commission has approved publication of the proposed final safety culture policy statement 

in the Federal Register, subject to the comments and changes noted below. The Commission 

expressed concern regarding the lack of specificity now available in the approach to 

implementing this policy statement. The staff should continue to engage with all stakeholders to 

communicate the contents of the policy statement, to educate stakeholders, and to ensure they 

have the necessary support to effectively employ the policy statement as they deem 

appropriate. 

Since the policy statement is not a regulation or a requirement, staff activities beyond 

communication and education should not be pursued without further specific Commission 

approval. 

Before staff implements new initiatives based on the policy statement, it should seek 

Commission policy review of its plan, including short-term and long-term goals, for 

implementation and the vision for each program office’s oversight. 

Changes to the final safety culture policy statement

1. On page 2, in the section on SUPPLEMENTAL INFORMATION, insert the standard 

Federal Register notice language regarding ADAMS. Throughout this notice, preface all 

“ML” numbers with “ADAMS Accession No.” 

2. On page 3, revise line 3 from the top to read ‘ ... certificate holder, as they ....’ 

3. On page 4, 1st full paragraph, revise line 5 to read ‘ ... questions, including ....’ 

4. On page 6, paragraph C., revise line 5 to read ‘ ... traits (previously referred to as 

“characteristics”) that ....’ Revise line 7 to read ‘ ... the Agreement Sstates, including ....’ 

5. On page 14, last paragraph, revise line 2 to read ‘ ... organizations performing regulated 

activities establish and ....’ Revise line 8 to read ‘ ... Agreement States, Agreement 

State licensees and other ....’ Revise line 10 to read ‘ ... of Policy, within their regulated 

communities.’ 

6. On page 14, last paragraph, delete the last sentence (The NRC will ... management 

processes.) 
7. On page 15, 1st full paragraph, revise line 1 to read ‘The Commission defines Nuclear 

Safety Culture is defined as ....’ Revise lines 4 and 5 to read ‘ ... responsibility for safety 

and security safely handling and securing these materials.’ Delete the last sentence 

(The Commission, ... safety culture.) and replace it with “The performance of individuals 

and organizations can be monitored and trended and, therefore, may be used to 

determine compliance with requirements and commitments and may serve as an 

indicator of possible problem areas in the organization’s safety culture. NRC will not 

monitor or trend values. These will be the organization’s responsibility as part of its 

safety culture program.” The staff may need to make corresponding changes to other 

sections of the Federal Register notice to ensure consistency of message. 

8. On page 16, next to last paragraph, revise 2nd sentence to read ‘ It should also be noted 

that these traits were are not necessarily inspectable and were not developed for that 

purpose to be used for inspection purposes.’ 

9. On page 16, last paragraph, revise lines 1 and 2 to read ‘It is the Commission’s 

expectation The Commission expects that all individuals and organizations, performing 

or overseeing regulated activities involving nuclear materials, should will take the ....’ 

10. On page 16, last paragraph, revise line 2 to read ‘ ... activities should will take the ....’ 

cc: Chairman Jaczko 

 Commissioner Svinicki 

 Commissioner Apostolakis 

 Commissioner Magwood 

 Commissioner Ostendorff 

 OGC 

 CFO 

 OCA 

 OPA 

 Office Directors, Regions, ACRS, ASLBP (via E-Mail) 

 PDR