October 1, 2013 

MEMORANDUM TO: Roy P. Zimmerman, Director 

Office of Enforcement 

FROM: Diane J. Sieracki, Sr. Safety Culture 

 Program Manager /RA by Stephanie Morrow for/ 

Concerns Resolutions Branch 

Office of Enforcement 

SUBJECT: SUMMARY OF THE AUGUST 7, 2013, PUBLIC MEETING 

BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION 

STAFF AND STAKEHOLDERS TO EXCHANGE INFORMATION 

AND DISCUSS ONGOING EDUCATION AND OUTREACH 

ASSOCIATED WITH THE SAFETY CULTURE POLICY 

STATEMENT 

The U.S. Nuclear Regulatory Commission (NRC) staff met with stakeholders on August 7, 2013, 

at NRC headquarters in Rockville, MD. The purpose of the meeting was to 1) update 

stakeholders on the ongoing activities and related materials the NRC staff has engaged in, and 

is developing, to support continued education and outreach for the Safety Culture Policy 

Statement (SCPS); and 2) obtain feedback from stakeholders regarding their experiences 

applying the SCPS and associated traits within their organizations. This meeting was noticed 

as a Category 2 public meeting and the meeting agenda is available in the Agencywide 

Documents Access and Management System (ADAMS) under Accession Number 

ML13199A466. The enclosure provides a list of those in attendance at the meeting. The 

discussions that occurred during the meeting are summarized below. 

Opening Remarks – Roy Zimmerman, Office of Enforcement (OE) Director

Roy Zimmerman opened the meeting and thanked the participants for joining the meeting. Mr. 

Zimmerman stated that we looked forward to catching each other up on our respective activities 

in the safety culture area. Following introductions by the participants and recognizing that this 

was a Category 2 public meeting where members of the general public would have several 

opportunities to ask questions or make comments, he introduced Diane Sieracki as the first 

presenter on the agenda. 

CONTACT: Diane J. Sieracki, OE/CRB Stephanie L. Morrow, OE/CRB 

 (301) 415-3297 (301) 415-1986 
R. Zimmerman - 2 - 

Safety Culture Outreach – Diane Sieracki, OE

Diane Sieracki discussed the various outreach activities OE staff has supported for the SCPS. 

The following are examples of conferences/workshops at which OE staff provided outreach on 

the SCPS: 

• Waste Management Conference, February, 2013 

• G8 Safety and Security Group, October, 2012 

• DevonWay Continuous Improvement Conference in September, 2012 

• Visit with Japanese regulator in March, 2012 

Upcoming conferences that OE staff will be participating in to talk about safety culture and the 

SCPS include: 

• DevonWay Continuous Improvement Conference, September, 2013 

• Argonne National Lab for new countries embarking on nuclear power, September, 2013 

• National Transportation Safety Board Forum on Safety Culture, September, 2013 

• American Nuclear Society Risk Management Meeting, November, 2013 

Ms. Sieracki also mentioned a number of international outreach activities: 

• G8 Safety and Security Group presentations related to NRC’s SCPS. This group 

recommended endorsement of the International Atomic Energy Agency (IAEA) Action 

Plan for Nuclear Safety in Light of the Fukushima Event by all member countries. 

• IAEA meetings related to the IAEA Action Plan for Nuclear Safety have included 

presentations by NRC staff on the SCPS. The most recent meeting was related to 

human and organization factors in safety culture in May, 2013 

• Maintaining involvement with IAEA in the safety culture area by assisting with 

development of IAEA documents such as Technical Documents and Report Series 

documents. The most recent consultancy meeting was held for the development of a 

common questionnaire/survey to be used in assessing safety culture in August, 2013. 

 

Ms. Sieracki provided information on the interaction of NRC safety culture staff with other 

regulators involved in discussions related to safety culture and High Reliability Organizations 

(HRO). These government regulators meet periodically, and NRC will host the next HRO 

meeting to be held late in 2013 or early 2014. NRC staff provided information and gave 

presentations related to the SCPS at past HRO meetings, including: 

• HRO meeting hosted by Department of Transportation in January, 2013 

• HRO meeting hosted by Department of Energy in June, 2013 

Ms. Sieracki also noted that the Bureau of Safety and Environmental Enforcement has adopted 

the NRC SCPS definition and traits in the development of their own policy statement for the 

offshore oil and gas industry. 
R. Zimmerman - 3 - 

Bob Link cautioned that a survey for assessing safety culture on an international level may not 

be appropriate for individual countries. Diane Sieracki acknowledged Mr. Link’s comment by 

explaining that the international work is typically guidance and options to use rather than 

requirements. 

Safety Culture Outreach – Cindy Flannery, Office of Federal and State Materials and 

Environmental Management Programs (FSME)

Cindy Flannery indicated that FSME has been focusing on safety culture training with a new 

training course under development. The objective is to: 1) provide consistent message for 

Agreement State regulators/personnel on what the SCPS says and means and how to 

implement it; and 2) communicate expectations for Agreement State personnel for what they 

should know and what they should share with their licensees related to the SCPS. The training 

will be presented as a webinar and is planned for September 2013. 

Safety Culture Common Language Initiative – Molly Keefe, Office of Nuclear Reactor Regulation 

(NRR)

Molly Keefe described recent efforts to develop a common language for safety culture in the 

nuclear power industry. The initiative included a working group with participants from the 

Institute of Nuclear Power Operations (INPO), Nuclear Energy Institute (NEI), all four NRC 

Regional offices and several offices within NRC Headquarters. This initiative was requested by 

the industry in order to align terminology between the NRC’s Reactor Oversight Program (ROP) 

inspection and assessment processes and the industry’s assessment process. It began before 

the development of the SCPS and was put on hold until after the SCPS was finalized. The 

common language initiative uses the traits from the SCPS as a basic foundation, and contains 

definitions and examples to describe each trait more fully. During the development of the 

common language, the workshop participants determined that due to some recent events in the 

industry an additional trait, Decision Making, was needed. This trait was added to the common 

language terminology. The common language was finalized in January 2013. Since completion 

of the common language, NRR has put together a working group to determine how best to 

adopt the new language into the framework of the cross-cutting areas in the ROP. Next steps 

include incorporation of the language into a permanent NRC document, incorporation of the 

relevant parts into the ROP, and development of training for NRC inspectors. The Common 

language is available in ADAMS, on the INPO website and will be on the NRC’s Safety Culture 

Website. 

 
R. Zimmerman - 4 - 

Safety Culture Outreach – Josie Piccone, Office of Nuclear Material Safety and Security 

(NMSS)

Josie Piccone stated that NMSS is continuing in the education and outreach mode by giving 

presentations at staff meetings, licensee and industry meetings, and workshops. A recent 

example is the June, 2013 Fuel Cycle Information Exchange, which included a poster and 

takeaway materials and two presentations: a presentation by NRC staff, “Safety Culture: A 

Continuous Journey,” addressing the NRC’s ongoing focus on safety culture, and “Raising the 

Bar,” a presentation by a fuel facility representative (Global Nuclear Fuel – Americas (GNFA)) 

on their safety culture program. Also, over approximately the past 6 months, most public 

meetings in the spent fuel storage and transportation area have included key messages from 

the SCPS and inspectors have distributed copies of the SCPS brochure. 

Additional current and future activities include: consideration of areas/issues that are informed 

by the SCPS in the staff’s plan to revise the Fuel Cycle Oversight Process; further outreach 

efforts through sharing key messages and outreach products during licensing and inspection 

meetings; and consideration of incorporating a general discussion of the SCPS in future 

revisions of licensing guidance, noting that a policy statement is not a regulation, but an 

expectation. 

Bob Link cautioned not to put policy statements into regulatory documents, because policy 

statements are an expectation, not a regulation. If the SCPS is included in guidance documents 

it may appear to be de facto regulation. Ms. Piconne acknowledged the comment. 

Roy Zimmerman agreed with Mr. Link’s comment and the importance of the NRC not 

overstepping the Commission’s direction that implementing the SCPS is not a regulatory 

requirement, but rather the Commission’s expectations. He reiterated the Commission’s 

direction to the staff to engage the regulated industry through outreach and education regarding 

the SCPS. 

Education Tools – Catherine Thompson, OE

Catherine Thompson discussed educational tools OE is developing as part of ongoing outreach 

and education. OE has developed four case studies which are on the NRC’s public safety 

culture website. Three of the case studies are based on an accident or event that resulted, in 

part, from a weak safety culture. The fourth case study is an event where tragedy was 

prevented because of a positive safety culture. 

OE is now focusing on developing case studies that are longitudinal; that is, they follow an 

organization’s response to an accident over time to demonstrate the dynamic nature of safety 

culture. These studies will identify initiatives and actions taken by the organization to strengthen 

their safety culture. 
R. Zimmerman - 5 - 

OE is also developing studies on each of the nine traits from the SCPS. The definitions of these 

traits were included in the SCPS, but without a “third tier” description of how they might be 

implemented. These studies will discuss each trait and discuss why it is important and provide 

examples of what it could look like when implemented. 

Finally, OE is considering developing a safety culture newsletter focusing on the agency’s 

external safety culture activities that would provide an overview of program office safety culture 

activities, IAEA safety culture activities, and other relevant safety culture issues that are in the 

news around the world. 

Mr. Zimmerman indicated that stakeholder feedback on the case studies has been very positive, 

and that the case studies serve as a teaching tool to help demonstrate the importance of a 

positive safety culture. He indicated that we appreciated the feedback on ways to enhance the 

case studies. He supports the staff’s intent to develop additional case studies. 

Effectiveness Review/Survey – Stephanie Morrow, OE and June Cai, FSME

Stephanie Morrow described a two-part project OE is undertaking in collaboration with FSME 

and NMSS to evaluate the effectiveness of the NRC’s outreach and education activities 

associated with the SCPS. The goals of the project are to: 1) benchmark how the NRC’s 

approach to communicating safety culture expectations compares to other regulatory agencies 

and non-government organizations; and 2) identify strengths and potential areas of 

improvement in the NRC’s current approach to communicating safety culture expectations to the 

materials licensee community. The project will include a survey to get feedback from FSME’s 

materials licensees, NMSS’s fuel cycle licensees, and licensees from any Agreement State 

volunteers. The survey will evaluate the effectiveness of the NRC’s outreach and education 

efforts and identify potential areas for improvement in the current approach to communicating 

about safety culture. 

June Cai added that FSME recently sent a letter to the Agreement States asking for volunteers 

to participate in the survey effort. FSME asked the Agreement States to respond by September 

13th. The request stresses that the survey will be voluntary, information will be collected 

confidentially by a third party contractor, and the survey will focus on feedback regarding NRC 

outreach and education efforts, not licensee activities. The timeline for administering the survey 

is still tentative as it will require clearance from the Office of Management and Budget which can 

take from six weeks to multiple months depending on the type of clearance for this activity. 

Agreement State Implementation of Safety Culture – Lee Cox, North Carolina

Lee Cox indicated that his state is using the SCPS as an opportunity to develop common 

language across all materials regulated by his Agreement State. North Carolina has used the 
R. Zimmerman - 6 - 

NRC safety culture brochure as a basis for communicating with all materials stakeholders. They 

changed their mission statement to incorporate the safety culture language, and last year the 

governor of North Carolina proclaimed January as radiation safety month. They are also using 

the brochure to educate leaders at exit inspections, and they have been giving presentations 

and distributing brochures at locations that use nuclear materials such as dental offices, vet 

clinics, and chiropractor offices. Mr. Cox suggested that NRC should look at how safety culture 

can be brought into the emergency response world and discussed in that context. In addition, 

as licensees are trained on new requirements they should also learn about safety culture, which 

could include incorporating safety culture into the Part 37 Steering Committee activities. 

Mr. Cox indicated that he found the brochure to be useful and a big success early on. Twenty 

different Agreement States have asked how North Carolina used the brochure for its specific 

needs. Mr. Cox also noted that he gets a lot of questions about applying the SCPS to X-ray 

programs. The SCPS language has helped bring North Carolina’s X-ray program up to par with 

its radioactive materials program. 

Public Comments/Questions:

Billie Garde made the suggestion to include a safety culture panel discussion at the next 

American Petroleum Institute conference. Diane Sieracki will contact Billie Garde for details. 

Power Reactor Safety Culture Initiatives – Ken Koves, Institute for Nuclear Power Operations 

(INPO)

Ken Koves reported that the new INPO document 12-012, “Traits of a Healthy Nuclear Safety 

Culture” was published in December, 2012. After the common language effort was completed 

in January, 2013, INPO published Revision 1 of 12-012, which includes all of the examples 

developed during the common language workshop. INPO also rolled out Addendum 1, which 

includes the examples organized by leadership level. Addendum 2 is a cross-walk of the new 

common language traits to the old INPO principles and IAEA characteristics, and Addendum 2-2 

is the pocket guide of the traits document. As part of the roll out of the new language, INPO 

held five meetings across the country and invited power reactors and vendors to talk about the 

new language. INPO also rolled out online training for the traits on July 1, 2013. The training 

covers each of the traits and related them back to the old INPO principles. 

Dr. Koves noted that INPO has also worked with vendor suppliers to take the common language 

and apply it to their organizations. INPO officially started using the traits on July 1, and has 

asked power reactors to also begin transitioning to the common language traits. 

Molly Keefe asked if Dr. Koves could provide more information about the online training offered 

by INPO. Dr. Koves stated that the online training is through the National Academy for Nuclear 

Training e-Learning, and INPO members and international members have access to the system. 
R. Zimmerman - 7 - 

The training starts with the Davis Besse event to explain why INPO is talking about safety 

culture, then the training relates the traits back to the INPO principles, then it details the 

attributes under each trait. Most licensees are doing annual or biannual training about Davis 

Besse, and this training might become part of that required training, but it is not currently. 

Roy Zimmerman indicated that the NRC would be interested in seeing the online training that 

INPO developed, and Dr. Koves indicated his preliminary willingness to support the request. 

Diane Sieracki will follow-up with Dr. Koves. 

Additional Comments – Rebecca Carr, Bechtel

Rebecca Carr indicated that Bechtel has been engaged in rolling out the SPCS traits to their 

management. Ms. Carr asked if the NRC intended to update the SCPS in light of the tenth trait, 

“Decision Making” that was added as a result of the common language workshops with the 

reactor community and the NRC. 

Diane Sieracki noted that the SCPS states that the nine (9) traits may not be all inclusive. Some 

of the traits may resonate with some licensees and not others. Ms. Sieracki further indicated 

that the reactor community felt strongly about adding “Decision Making,” but that did not mean 

that some of the materials licensees would see that as a high enough priority to rise to the level 

of adding another trait. She further indicated that some regulated communities may find other 

areas that rise to trait level for their organizations. Ms. Sieracki indicated that there were no 

current plans to update the SCPS. 

Closing Remarks – Roy Zimmerman, OE:

Mr. Zimmerman praised the participants for their voluntary initiatives and efforts to support the 

SCPS and associated traits. He indicated that the staff continues to recognize that a “one size 

fits all” approach isn’t the best option for the regulated community to voluntarily implement the 

SCPS, but rather each organization needs to tailor it to fit their situation and needs. He further 

stated that staff will continue to update the safety culture website periodically and staff is 

available to assist in getting the message out, should stakeholders request NRC involvement 

through speaking engagements, training activities, etc. Mr. Zimmerman suggested, and 

received agreement from the participants, that similar public teleconferences/meetings about 

twice a year would be beneficial. Lastly, he thanked the participants a final time for their efforts 

and for joining this public meeting. He stated that the Commissioners continue to follow the 

staff’s and regulated communities’ activities in the safety culture area with interest. 

 
R. Zimmerman - 8 - 

Ms. Sieracki indicated she would send all meeting attendees the ADAMS Accession number for 

the common language workshop results, along with the dates for the HRO public meeting to be 

hosted by the NRC, and the meeting feedback form. 

Public meeting was adjourned. 

Enclosure: 

1. Meeting Participants 
R. Zimmerman - 7 - 

Ms. Sieracki indicated she would send all meeting attendees the ADAMS Accession number for 

the common language workshop results, along with the dates for the HRO public meeting to be 

hosted by the NRC, and the meeting feedback form. 

Public meeting was adjourned. 

Enclosure: 

1. Meeting Participants 

DISTRIBUTION:

ACampbell, OE CThompson, OE DSieracki, OE 

JPiccone, NMSS SMorrow, OE CMiller, FSME 

PHabighorst, NMSS JGiitter, NRR KO’Sullivan, FSME 

MDiaz, NMSS UShoop, NRR CFlannery, FSME 

CMorell, NMSS MKeefe, NRR JCai, FSME 

SPeters, RES MThaggard, NSIR MHayes, NRO 

VBarnes, RES AStang, NSIR LDudes, NRO 

ABolger, NRR LWert, RII MLemoncelli, OGC 

OWFN Receptionist TWFN Receptionist 3WFN Receptionist 

ADAMS Package No.: ML13267A379 

OFFICE OE/CRB OE/CRB OE/CRB: BC OE:D 

NAME SMorrow DSieracki 

/RA/SMorrow for/

DSolorio RZimmerman 

DATE 9/24/13 9/25/13 9/25/13 10/1/13 

OFFICIAL RECORD COPY
ENCLOSURE 

Meeting Participants 

Name: Organization

Roy Zimmerman NRC-Office of Enforcement (OE) 

Diane Sieracki NRC-OE 

Catherine Thompson NRC-OE 

Kaydian Beckford NRC-OE 

Stephanie Morrow* NRC-OE 

Marilyn Diaz NRC-Office of Nuclear Material Safety and Security 

(NMSS) 

Kevin Ramsey NRC-NMSS 

Josie Piccone NRC-NMSS 

Allyce Bolger NRC- Office of Nuclear Reactor Regulation (NRR) 

Molly Keefe NRC-NRR 

Len Wert* NRC-NRR (RII) 

Val Barnes* NRC- Office of Nuclear Reactor Research (RES) 

Sean Peters* NRC-RES 

June Cai* NRC-Office of Federal and State Materials and 

Environmental Management Programs (FSME) 

Cindy Flannery* NRC-FSME 

Mark Thaggard* NRC-NSIR – Office of Nuclear Security and 

Incident Response 

Michelle Hayes* NRC- Office of New Reactors 

James Slider NEI 

Janet Schlueter* NEI 

Curtis Wright* Scientech 

Ken Koves* INPO – Institute of Nuclear Power Operations 

Tom Houghton* Certrec 

Rebecca Carr* Bechtel 

Bob Link* AREVA 

Lee Cox* Organization of Agreement State 

Billie Garde* Law Offices of Clifford and Garde 

George Marshall* American Portable Nuclear Gauge Association 

*Participated via telephone