Topic Questions 

U.S. Nuclear Regulatory Commission 

Public Workshop on Development of a Policy Statement 

On Safety Culture and Security Culture 

February 3, 2009 

Guidance for Submitting Comments 

Your input is requested on the attached questions! 

 When providing written comments, please list the relevant topic and question numbers 

when appropriate. 

 When commenting, please exercise caution with regard to site-specific security-related 

information. Comments may be made available to the public in their entirety. 

 Optional – please consider including your contact information with your submission: 

name, affiliation, email, and phone number. Note that personal information will not be 

removed from your submission if it is made public. 

You are encouraged to provide your comments to the following contact by February 11, 2009, 

to ensure the consideration of your comments. Comments received after this date will be 

considered if it is practical to do so. 

June Cai 

U.S. Nuclear Regulatory Commission 

Mail Stop O4 A15A 

Washington, DC 20555 

june.cai@nrc.gov 

(301) 415-5192 

Website Resource

Visit the NRC Safety Culture public website at: http://www.nrc.gov/aboutnrc/regulatory/enforcement/safety-culture.html to review background/historical information and 

to keep up-to-date on NRC activities in this area. 
PUBLIC WORKSHOP ON THE DEVELOPMENT OF A POLICY STATEMENT(S) ON 

 SAFETY/SECURITY CULTURE, FEBRUARY 3, 2009 - TOPIC QUESTIONS 

The NRC is seeking input on key topics related to the direction from the Commission on Safety 

Culture Policy Statement development. Specifically, the NRC is seeking input on the following 

topics: 

1. Should NRC combine its expectations in the policy statement for safety culture and security 

culture or should NRC keep its expectations separate? 

2. How should NRC increase attention by NRC, licensees, and certificate holders to safety 

culture in the materials area? 

3. Does safety culture as applied to reactors needs to be strengthened? 

Topic 1: Should NRC combine its expectations in the policy statement for safety culture 

and security culture or should NRC keep its expectations separate? 

Q1.1. Within organizations, one can think about safety and security in different ways. For 

example, safety may take precedence over security, security may take precedence over safety, 

or both may be treated equally. Different types of licensees, certificate holders and 

organizations have a variety of experiences and perspectives. How do you generally view the 

relationship or hierarchy between safety and security functions and decision making? 

Q1.2. While efforts to maintain safety and security have the same common goal of protecting 

public health and safety, there can be distinct differences in the approach used to achieve that 

goal and that may have competing outcomes. One example is how information is shared to 

mitigate risks, where increased sharing of information may contribute to maintaining safety, but 

presents increased security risks. Are there other examples where efforts to maintain safety and 

security require different approaches or result in competing outcomes that need to be 

addressed to achieve the desired outcome or goal? 

Q1.3. When resolving differences or conflicts while seeking to maintain safety and security — 

such as when managing risk, sharing information, planning work, correcting problems, etc. — 

and where changes or actions that are taken to address either a safety issue or a security issue 

could have an adverse effect on the other (i.e., security or safety, respectively); what challenges 

does your organization face? 

Q1.4. What challenges or complexities arise when licensees and certificate holders work with 

contractors and vendors where the organizations either take different approaches to resolving 

conflicting outcomes when they seek to maintain safety and security or the organizations may 

balance the conflicting outcomes of efforts to maintain safety and security differently? 

Q1.5. What practices have been used to effectively address the conflicts to achieve the desired 

outcomes or goals? 

Q1.6. Given that there are several ways to think about safety culture and security culture within 

organizations, the NRC wishes to express a policy in a way that best furthers its goals of 

protecting the public and environment and ensuring the secure use and management of 

radioactive materials. 

If the above issues are viewed in terms of safety culture and security culture implementation, 

what benefits or challenges would licensees, certificate holders, Agreement States, or others 

foresee with a single policy statement? Two separate policy statements? 
Q1.7 How can the NRC best express a policy that gives appropriate weight to safety culture 

and security culture across the range of licensees and certificate holders? 

Q1.8. Given the diversity among the licensees and certificate holders regulated by the NRC 

and the Agreement States, how should the policy statement address any differences in 

emphasis on safety and security at the different types of licensees and certificate holders? 

Topic 2: How should NRC increase attention by licensees and certificate holders to 

safety culture in the materials area? 

Q2.1. What is the NRC doing that is working well to help materials licensees and certificate 

holders to maintain their safety culture and security culture? 

Q2.2. What might the NRC do differently, or that it is not currently doing, to increase NRC, 

licensee, or certificate holder attention to safety culture at materials licensees and certificate 

holders? 

Q2.3. How could the NRC better interact with materials licensees and certificate holders to help 

them to pay greater attention to maintaining their safety culture and/or security culture? 

Q2.4. If the NRC expresses a policy for materials licensees and certificate holders to maintain 

safety culture and security culture, or made its references to safety culture and security culture 

more explicit in its interactions with these licensees and certificate holders, how would their 

performance change? 

Q2.5. What should the NRC consider when developing policy statement(s) on safety culture 

and security culture? 

Q2.5.1. What is the current level of understanding of materials licensees and certificate 

holders of the NRC’s expectations that they maintain a safety culture that is cognizant of issues 

relating to security? How does this level of understanding change with the type of licensee or 

certificate holder? 

Q2.5.2. How should the NRC consider the different activities (e.g., risk, type of material, 

quantities of materials, how the material is used, location, etc.) conducted at materials licensees 

and certificate holders when evaluating whether, or how, to express its policy? 

Q2.5.3. How should NRC consider differences in the materials licensees and certificate 

holders (e.g., size of workforce, relationship to activities not regulated by the NRC, etc.) when 

evaluating whether, or how, to express its policy? What differences should the NRC consider? 

Q2.5.4. What are the unique aspects of security at materials licensees and certificate 

holders that the NRC should consider when expressing its policy? 

Q2.5.5. What topics should be addressed in the policy statement(s) that would be of 

value to materials licensees and certificate holders? 

Q2.5.6. How could the policy statement(s) effectively address issues that involve both 

safety and security (at the safety/security interface) at materials licensees and certificate 

holders? 
Q2.5.7. How can the NRC best express a policy that gives appropriate weight to safety 

culture and security culture across the range of licensees and certificate holders? 

Q2.5.8. Given the diversity among the licensees and certificate holders regulated by the 

NRC and the Agreement States, how should the policy statement address any differences in 

emphasis on safety and security at the different types of licensees and certificate holders? 

Q2.6. How should the NRC work with the Agreement States to encourage increased attention 

being focused on safety culture, including the unique aspects of security, at Agreement State 

licensees? 

Q2.6.1. What is the level of understanding at Agreement State licensees regarding the 

value in maintaining safety culture and security culture? 

Q2.6.2. What is the level of understanding of safety culture and security culture within 

the Agreement States? 

Q2.6.3. How do the Agreement States view the NRC’s goal of increasing the attention 

paid to safety culture and security culture at materials licensees and certificate holders? 

Q2.6.4 What topics do the Agreement States believe should be addressed in the policy 

statement(s)? 

Q2.6.5. How could the NRC help the Agreement States to increase attention to safety 

culture and security culture at their licensees? 

Q2.6.6. How should the NRC address safety culture and security culture at Agreement 

State licensees that engage in activities within NRC jurisdiction under reciprocity? 

Q2.6.7. How might NRC use stakeholder involvement to increase the attention that 

materials licensees and certificate holders give to maintaining a safety culture, including the 

unique aspects of security? 

Topic 3: Does safety culture as applied to reactors needs to be strengthened? 

A number of enhancements were made to the ROP in 2006 to address safety culture (for 

example: safety culture cross-cutting aspect assignment to findings; identifying substantive 

cross-cutting issues; performing an independent NRC safety culture assessment for licensees in 

Column 4 of the ROP Action Matrix). 

Q3.1. What are the strengths and weaknesses of the current approach for evaluating licensee 

safety culture in the ROP? 

Q3.2. How has the use of safety culture cross-cutting aspects that are assigned to inspection 

findings helped to identify potential safety culture issues? Suggest any alternative approaches 

that licensees could use to identify potential safety culture issues. 

Q3.3. What may be better or more effective methods or tools that the NRC could use to help 

identify precursors to future plant performance deficiencies? 
Q.3.4. In the following situations the NRC may/or will request a licensee to perform a safety 

culture assessment (licensee self-assessment, independent assessment, or a third-party 

assessment): (a) the same substantive cross-cutting issue had been identified in three 

consecutive assessment letters (generated from assessments conducted at 6 month intervals); 

(b) a 95002 inspection (Inspection for One Degraded Cornerstone or Any Three White Inputs in 

a Strategic Performance Area) that confirmed the licensee had not identified a safety culture 

component that either caused or significantly contributed to the risk-significant performance 

issue that resulted in the supplemental inspection; and (c) a plant enters Column 4 of the Action 

Matrix. Under what other situations should the NRC consider requesting that a licensee perform 

a safety culture assessment? 

Another ROP enhancement was for the NRC to perform an independent safety culture 

assessment for plants that enter the multiple repetitive/degraded cornerstone column (column 

4). 

Q3.5. In what other circumstances might the NRC consider performing an independent safety 

culture assessment? 

Q3.6. What other entity, other than the NRC, could perform an independent safety culture 

assessment or simply verify the results of the licensee’s assessments and corrective actions? 

Q3.7. What additional safety culture related ROP changes could help the NRC to improve the 

focus of NRC and licensee attention on site safety culture issues? 

The NRC has held public meetings where draft changes to several ROP guidance documents 

resulting from a lessons learned evaluation of the initial implementation period of the ROP 

safety culture enhancements have been made available for public comment. 

Q3.8 What areas beyond the draft changes (for example, a provision in Inspection Procedure 

95003 for the NRC to be able to conduct a graded safety culture assessment) presented by the 

NRC have the potential to further enhance how the ROP addresses safety culture? 

Q3.8.1. How would these potential changes enhance or improve how the NRC 

addresses safety culture through the ROP? 

Q3.9. In what ways does the current process lead to consistency/predictability of 

implementation by the NRC? Provide examples to support your view. 

 

Q3.9.1 In what ways does it lead to inconsistency or unpredictability? 

Q3.10 How effective is the ROP in addressing security culture issues? 

Q3.10.1. What ROP changes could help the NRC to improve the focus of NRC and 

licensee attention on site security culture issues? 

In previous public meetings, the NRC has discussed using the ROP safety culture components 

and modified aspects as a tool to understand the challenges to safety culture during new reactor 

construction. 

Q3.11. How can challenges to safety culture in new reactor construction be identified and 

addressed in regulatory oversight?