Enclosure 4: Exelon Presentation

Meeting Summary of July 28, 2010 

Public Meeting with NEI

Dated August 4, 2010
Braidwood Nuclear Safety 

Culture Pilot

Ron Gaston

Regulatory Assurance Manager

July 28, 2010
NEI 09-07 Implementation at Braidwood 2

 Site specific procedure developed based on 

existing Exelon practices and NEI guidance

 Braidwood implemented all three phases 

• 4 Monitoring Panel Meetings

• 1 Semi-Annual Senior Leadership Team (SLT) Review

• 1 Independent Nuclear Safely Culture Assessment 

(NSCA)

 All three phases assessed data against the INPO 

Nuclear Safety Culture Principles and Attributes

 NRC observed implementation of all three phases 
Monitoring Panel 3

 Consists of Plant Manager, Oversight Manager, HR 

Manager, Regulatory Manager, and Performance 

Improvement Manager

 Meetings held on a two month frequency

 Process inputs provided in advance for review and 

preliminary binning

• Condition reports tagged with Safety Culture trend code 

• CAP investigations (Root Cause, Apparent Cause) and feedback

• NRC findings and violations, referred allegations

• Nuclear Oversight elevations, assessments and audits, concerns

• HR investigations / disciplines and ECP cases

• Offsite Review Committee minutes and findings

• Selected site performance indicators 
Monitoring Panel 4

 Meeting involves process input reviews to identify issues 

at low level and provide oversight of corrective actions

• Discussion of previous actions items / trend reviews

• Collegial review of each individual input

• Bin inputs that represent a weakness in a safety culture principle

• Identify issues for short term actions

 Monitoring Panel provides a forum for regular reflection 

and assessment of safety culture health 

• Aggregate review of broad scope of inputs provided oversight and 

engagement on safety culture

• Identified specific departments or plant issues influencing safety 

culture
SLT Semi-Annual Review 5

 Utilized Monitoring Panel data and SLT judgment 

to reach consensus on site's implementation of 

each safety culture principle

 Identified safety culture improvement opportunities

• Principle 3 – Organizational Trust

Long-term issues not being resolved

Communication challenges

• Principle 5 – Nuclear is Recognized as Special

Cross-functional human performance issues

• Principle 7 – Organizational Learning

Investigation and issue resolution weaknesses
Nuclear Safety Culture Assessment 6

 Independent assessment against the eight INPO 

principles

 Two phases: Survey (65% response) and Onsite 

Assessment 

 Onsite Assessment 

• 74 interviews of site personnel and 4 meeting 

observations

• Interview questions based on INPO safety culture 

principles and attributes

 3 Positive Observations, 5 Negative 

Observations, and 4 General Observations 
Braidwood Results 7

 Monitoring Panel identified safety culture weaknesses in 

specific departments and with specific site issues

 Monitoring Panel binning and focus areas were consistent 

with independent NSCA observations

 SLT review challenged sites actions / progress related to 

resolving NSCA negative observations

 SLT review identified Improvement Opportunity in 

Principle 7 – Organizational Learning

• Consistent with Oversight / Offsite Review Board feedback of 

recent decline in CAP performance

 NSCA and SLT review noted effective site action and 

improvements in decision making – consistent with recent 

NRC feedback related to existing SCCI
Braidwood Improvements / Lessons Learned 8

 Monitoring Panel bin process now inputs to the 

safety culture attribute level

 Insights from line organization department heads 

presented to Monitoring Panel 

 Bin positive behaviors against safety culture 

principles to identify areas to leverage / 

benchmark

 Periodic challenge of site disposition of SLT 

improvement opportunities / NSCA observations

 Improved communication of results to requisite 

levels of the organization 
Braidwood Insights 9

 The NEI 09-07 guidance provides a structured 

and tiered process that drives the site to own and 

actively monitor / improve safety culture

 Use of a broad range of process inputs allows for 

identification of potential safety culture issues:

• As a leading indicator of performance

• At the precursor / low level

• Related to a specific department or targeted population

 Provides transparency

• NRC observations of all three phases

• NRC review of inputs, binning results, meeting minutes, 

and assessment reports 

• NRC tracking of site actions through CAP