NRC Safety Culture Worksh

NRC Safety Culture Worksh

Bob Link

Manager EHS&L

AREVA NP Inc.
AREVA NP Inc.

Talking from the view point of Fuel Cycle Facilitieso We are a small group of licensees

4-Cat th fl fl hree facilities operating fuel f ba planAREVA(2), Westinghouse, GNF,2- Cat 1 facilities operating fuel Cat 1 facilities operating fuel fab. Plants 

Plants 

1- Converter

2- Operating Enrichers USEC, LES

2- Enrichment Lic. Applicants AREVA, GNF1- MOX Fuel Fabricator lic. applicant

o B t l di t l i f ti b t h But also very diverse not only in function but ho

perform our processes

o And at least three different 10 CFR Parts, 40, 70o And at least three different 10 CFR Parts, 40, 70
continued

• While we strongly support the formation of a 

Culture Policy Culture Policy with appropriate traits or attrib

with appropriate traits or attrib

clarification we have anxiety for its inevitable “Implementation”

• The NRC Staff and Industry has spent many h

days on this initiative, yet if the past is used t

the future, What will the investment be to “implement” this initiative.

• The past has demonstrated that upon implem

the development of guidance, manuals and t

for such for such an initiative an initiative does not match up to th

does not match up to th

challenge.
continued

• Safety Culture in not a simple outcome 

Culture in not a simple outcome 

measured by objective metrics. Our dis

over this last year and over this last year and many before many before it h

,

proven this.

• Therefore the importance to guidance a

the importance to guidance a

training for those involved in the monit

reporting and reporting and “judging judging” the health the health of th

industries Safety Culture is imperative.
continued

• The discussions have also demonstrated the diversity of t

industry across all types of licensees. This adds to the com

th “d l h d l ” he “devil is in the details” aspect of l imp ementation

• So what are the recommendations regarding “Next Steps

o Continue the open and transparent dialogue with segments of the industry – of course this demands ocontinued engagement and participationo Walk before we run – While the “Offices” of the Nbe expected to have a larger roll in the Implementatthere needs to be a commitment of resources to thiactually exceeds the effort that has beendemonstrated in the policy formation.
continued

o There needs to be a balance in both priorities o

initiative and other perhaps more valued initiaother safety issues in the varied Offices’ heavy agendas.

o Continuing oversight at the Agency wide level w

be needed be needed to retain consistency while allowing to retain consistency while allowing

necessary flexibility do to diversity of License t

o Dedicate budg p et for the implementation that is 

for the appropriate implementation
continued

o Don t’ assume that if it has assume that if it has “worked this 

worked this 

in one license segment it will work in an

o Beware of cookie cutter approaches for o Beware of cookie cutter approaches for 

complex issue

o A l KIS h i i ’ k If i ’ Apply KIS otherwise it won’t work. If it’s 

clear and transparent to the average wo

won’ k t wor .