D. J. SIERACKI AND M. C. THOMPSON 

1 

U.S. NUCLEAR REGULATORY COMMISSION 

Safety Culture Oversight 

D.J. SIERACKI 

U.S. Nuclear Regulatory Commission 

Washington D.C., USA 

Email: diane.sieracki@nrc.gov 

M. C. THOMPSON 

U.S. Nuclear Regulatory Commission 

Washington D.C., USA 

Email: catherine.thompson@nrc.gov 

U.S. Nuclear Regulatory Commission, Safety Culture Oversight 

The NRC recognizes that it is important for all organizations performing or 

overseeing regulated activities to establish and maintain a positive safety culture 

commensurate with the safety and security significance of their activities and the 

nature and complexity of their organizations and functions. The NRC’s approach to 

safety culture is based on the premise that licensees bear the primary responsibility 

for safety. The NRC provides oversight of safety culture through expectations 

detailed in policy statements, safety culture assessor training for NRC inspectors, the 

oversight processes, and the Allegations and Enforcement Programs. 

1. INTRODUCTION 

Beginning in 1989, the NRC published three policy statements about safety 

culture at nuclear power plants. One described the Commission's expectations for the 

conduct of operations in control rooms; the second established the Commission's 

expectation for maintaining a safety-conscious work environment (SCWE), in which 

workers are able to raise nuclear safety concerns without fear of retaliation. In 2011, 

the NRC published a Safety Culture Policy Statement (SCPS) to establish the 

Commission’s expectations for licensees to maintain a strong safety culture. The 

SCPS has informed the NRC’s oversight process through the common language 

initiative. 

The NRC provides training to inspectors to become qualified as Safety Culture 

Assessors for general safety culture assessments or IP 95003 inspections. This 

qualification requires a firm understanding of both safety culture and inspection skills, 

and is an essential part of the NRC’s oversight of safety culture. 

The Reactor Oversight Process (ROP) is the NRC’s program for assessing the 

performance of operating commercial nuclear power reactors. In 2004, the NRC took 

steps within the ROP to strengthen the agency's ability to detect potential safety 

culture weaknesses during inspections and performance assessments. In 2006, 

guidance and procedures for inspecting and assessing aspects of licensees' safety 
 IAEA-CN-123/45 

 

culture were included in the ROP. In 2014, revisions were made to the ROP based on 

the common language initiative. The Construction Oversight Process (cROP) was 

modeled after the ROP. 

In addition to the oversight processes, the NRC’s Allegation and Enforcement 

Programs address safety culture through the use of Chilling Effect Letters (CEL) and 

Confirmatory Orders (CO). CELs are issued when the NRC has concluded that the 

work environment is “chilled,” (i.e., workers perceive that the licensee is suppressing 

or discouraging the raising of safety concerns or is not addressing such concerns when 

they are raised). The number and nature of allegations received at the NRC, including 

allegations related to discrimination for raising safety related concerns help inform 

the NRC’s decision to send a CEL. COs are issued by the NRC to document 

agreements on specific corrective actions made by the licensee in response to 

inspection findings. 

The information referenced below, including the SCPS, Inspection Manual 

Chapters (IMC), Inspection Procedures (IP), and NUREGs, can be found in the NRC’s 

Agency-wide Documents Access & Management System (ADAMS), or at specific 

websites noted within the sections below. 

2. SAFETY CULTURE POLICY STATEMENT 

The SCPS sets forth the Commission's expectation that individuals and 

organizations establish and maintain a positive safety culture commensurate with the 

safety and security significance of their activities and the nature and complexity of 

their organizations and functions. The SCPS is not a regulation. It applies to all 

licensees, certificate holders, permit holders, authorization holders, holders of quality 

assurance program approvals, vendors and suppliers of safety-related components, 

and applicants for a license, certificate, permit, authorization, or quality assurance 

program approval, subject to NRC authority. In addition, the Commission encourages 

the Agreement States (States that assume regulatory authority over their own use of 

certain nuclear materials), their licensees, and other organizations interested in nuclear 

safety to support the development and maintenance of a positive safety culture within 

their regulated communities. More information on the Agreement States can be found 

on the NRC’s Web page [1]. 

The SCPS addresses both safety and security. Organizations should ensure 

that personnel in the safety and security sectors have an appreciation for the 

importance of each, emphasizing the need for integration and balance to achieve both 

safety and security in their activities. Safety and security activities are closely 

intertwined. While many safety and security activities complement each other, there 

may be instances in which safety and security interests create competing goals. It is 

important that consideration of these activities be integrated so as not to diminish or 

adversely affect either; thus, mechanisms should be established to identify and resolve 

these differences. A safety culture that accomplishes this would include all nuclear 

safety and security issues associated with NRC regulated activities. 
D. J. SIERACKI AND M. C. THOMPSON 

3 

The SCPS defines nuclear safety culture as the core values and behavior 

resulting from a collective commitment by leaders and individuals to emphasize safety 

over competing goals to ensure protection of people and the environment. 

The SCPS includes a list of nine traits further defining a positive safety 

culture. These traits describe patterns of thinking, feeling, and behaving that 

emphasize safety, particularly in goal conflict situations, such as when safety goals 

conflict with production, schedule or cost goals. The traits listed Fig. 1 below are not 

all-inclusive. Some organizations may find that one or more of the traits are 

particularly relevant to their activities. There may also be traits not included in the 

SCPS that are important in a positive safety culture. More information on the SCPS 

can be found on the NRC’s Web page [2]. 

FIG. 1. Safety culture traits and definitions. 

Leadership Safety Values 

and Actions 

Problem Identification and 

Resolution Personal Accountability 

Leaders demonstrate a 

commitment to safety in their 

decisions and behaviors. 

Issues potentially impacting 

safety are promptly identified, 

fully evaluated, and promptly 

addressed and corrected 

commensurate with their 

significance. 

All individuals take personal 

responsibility for safety. 

Work Processes Continuous Learning Environment for Raising 

Concerns 

The process of planning and 

controlling work activities is 

implemented so that safety is 

maintained. 

Opportunities to learn about 

ways to ensure safety are 

sought out and implemented. 

A safety conscious work 

environment is maintained 

where personnel feel free to 

raise safety concerns without 

fear of retaliation, 

intimidation, harassment 

or discrimination. 

Effective Safety 

Communications

Respectful Work 

Environment Questioning Attitude 

Communications maintain a 

focus on safety. 

Trust and respect permeate the 

organization. 

Individuals avoid 

complacency and continually 

challenge existing conditions 

and activities in order to 

identify discrepancies that 

might result in error or 

inappropriate action. 
 IAEA-CN-123/45 

 

3. SAFETY CULTURE COMMON LANGUAGE 

Before work began on the 2011 SCPS, the nuclear power industry approached 

the NRC about starting an effort to develop a shared set of terms to describe safety 

culture. With insights gained during the development of the SCPS, the Office of 

Nuclear Reactor Regulation (NRR), along with Institute of Nuclear Power Operations 

(INPO) and Nuclear Energy Institute (NEI), hosted a series of public workshops 

beginning in December 2011 to discuss the idea of a safety culture common language. 

The intent of this initiative, as requested by the industry, was to align terminology 

between the NRC's inspection and assessment processes within the ROP and the 

industry's assessment process. This initiative was within the Commission-directed 

framework for enhancing the ROP treatment of crosscutting areas to more fully 

address safety culture. 

NUREG-2165, "Safety Culture Common Language," documents the outcomes 

of the public workshops to develop a common language to describe safety culture in 

the nuclear industry. These workshops included panelists from the NRC, the nuclear 

power industry, and the public. NUREG-2165 outlines a suggested common language 

for classifying and grouping traits and attributes of a healthy nuclear safety culture. 

The results of the common language initiative were 10 traits of a healthy safety culture 

(the nine traits from the SPCS plus a 10th trait, decision-making), 40 aspects nested 

under those traits, and numerous examples for each aspect. These common language 

traits and aspects have been incorporated under the three cross-cutting areas of the 

ROP. NUREG-2165 can be found on the NRC’s Web page [3]. 

4. SAFETY CULTURE ASSESSOR TRAINING 

Qualification as a Safety Culture Assessor requires the completion of a variety 

of activities, each of which is designed to help gather information or practice a skill 

that may be important during inspections. When qualified, the Assessor will have 

demonstrated the following competencies: 

- Understand the legal basis for and the regulatory processes used to achieve 

the NRC’s regulatory objectives. 

- Master the techniques and skills needed to collect, analyze, and integrate 

information using a safety culture focus to develop a supportable regulatory 

conclusion. 

- Demonstrate the personal and interpersonal skills needed to carry out 

assigned regulatory activities, either individually or as part of a team. 

All inspectors are required to complete an inspector qualification interview to 

evaluate how well an individual can integrate and apply inspector competencies to 

field situations. Additional information on IMC 1245, Appendix C-12, “Safety 
D. J. SIERACKI AND M. C. THOMPSON 

5 

Culture Assessor Training and Qualification Journal” can be found on the NRC’s Web 

page [4]. 

5. OVERSIGHT PROCESSES 

Reactor Oversight Process (ROP): The NRC’s approach to safety culture is 

based on the premise that licensees bear the primary responsibility for safety. The 

ROP is the NRC’s program for assessing the performance of operating commercial 

nuclear power reactors. The ROP uses inputs from performance indicators and 

inspection findings to develop conclusions about a licensee’s safety performance. 

Performance is evaluated systematically and on a continuous basis through planned 

inspections, and mid-year and end of year assessment meetings. 

The ROP stems from the NRC’s mission to three strategic performance areas, 

and seven cornerstones, as in Fig. 2 below. Each cornerstone has corresponding 

performance indicators and inspection procedures to assess licensee performance. 

Safety culture is considered within three cross-cutting areas of Human Performance, 

Safety Conscious Work Environment, and Problem Identification and Evaluation. 

.

FIG. 2. Reactor oversight framework 

Based on the NRC’s assessment of safety performance, licensees are assigned 

to a column in the ROP Action Matrix, and that placement in the Action Matrix 

determines the level of NRC oversight for that particular licensee. The NRC’s 

approach to safety culture assessment is a graded process, see Fig. 3. The extent and 

complexity of a safety culture assessment is generally based on a licensee’s placement 

in the ROP Action Matrix. The scope and complexity increases with increased 

oversight and the focus of the assessment may be tailored based on the original 

performance deficiency. An assessment may focus more heavily on one part of the 

plant, or on one area of safety culture, such as safety-conscious work environment. 
 IAEA-CN-123/45 

 

FIG. 3. Reactor oversight process

The NRC’s ROP Action Matrix, with the four columns of increasing oversight, 

is based on performance deficiencies. Licensees in column 1 are subject to NRC’s 

baseline inspection program. As licensees move to columns 2, 3, or 4 they are subject 

to addition oversight in the form of supplemental inspections. 

In column 2, as part of IP 95001, inspectors verify that the licensee’s root cause 

analysis appropriately considered safety culture. IP 95001 can be found on the NRC’s 

Web page [5]. 

In column 3, as part of IP 95002, the NRC independently determines whether 

safety culture weaknesses were root or contributing causes and may request that the 

licensee conduct an independent safety culture assessment. IP 95002 can be found on 

the NRC’s Web page [6]. 

In column 4, as part of IP 95003, the NRC will request an independent 

assessment and will perform its own assessment of safety culture. IP 95003 can be 

found on the NRC’s Web page [7]. 

Qualified NRC safety culture assessors evaluate the licensee’s third party 

safety culture assessment, and then determine the scope of the NRC assessment based 

on that evaluation. The NRC assessors conduct the assessment on site, and identify 

and document safety culture themes in the inspection report. The assessors also review 

the licensee’s planned and completed corrective actions to evaluate whether they 

address the identified safety culture themes, and whether the licensee needs to develop 

follow-up actions to address any remaining concerns. A detailed description of the 

ROP can be found on the NRC’s Web page [8]. NUREG 1649, “Reactor Oversight 

Process,” can be found on the NRC’s Web page [9]. 
D. J. SIERACKI AND M. C. THOMPSON 

7 

Construction Oversight Process (cROP): The Office of New Reactors (NR) 

staff completed a revision to cROP based on the ROP assessment program 

methodology, including the use of safety culture traits and cross-cutting issues, and 

completed a pilot of the revised cROP in December 2012. 

Based on the results of the pilot program, NRO revised the construction 

oversight process, including the oversight of safety culture as described in IMC 0613, 

"Documenting 10 CFR Part 52 Construction Inspections," and IMC 2505, "Periodic 

Assessment of Construction Inspection Program Results," to provide guidance to 

assess the safety culture of a construction site. IMC 0613 was revised to provide a 

listing of cross-cutting aspects that can be assigned to inspection findings. Assigned 

cross-cutting aspects, which are generally associated with the root causes of 

performance deficiencies, are evaluated to identify cross-cutting themes which are 

assessed as outlined in IMC 2505. IMC 2505 also includes references to the 

supplemental inspection procedures, which are used when there is a decline in safety 

performance at a construction site. These procedures provide NRC inspectors with 

guidance on how to assess the safety culture at a construction site with escalating 

levels of efforts commensurate with the significance of a site's performance decline. 

The supplemental inspection procedures also provide NRC inspectors with the tools 

to communicate safety culture issues to stakeholders. IMC 0613 and IMC 2505 can 

be found on the NRC’s Web page [10]. Additional information on the cROP can be 

found on the NRC’s Web page [11]. 

6. ALLEGATIONS AND ENFORCEMENT PROGRAMS 

The NRC’s Allegations and Enforcement Programs address discrimination 

against licensee employees for raising safety related concerns, and the potential 

resulting chilling effect on the employee or coworkers. 

Safety Conscious Work Environment (SCWE): The Commission describes a 

safety conscious work environment (SCWE) as a work environment where employees 

are encouraged to raise safety concerns and where concerns are promptly reviewed, 

given the proper priority based on their potential safety significance, and appropriately 

resolved with timely feedback to the originator of the concerns and to other employees 

as appropriate. Fostering an environment for raising concerns continues is an 

important attribute of a positive nuclear safety culture, and is incorporated as one of 

the traits of a positive safety culture in the NRC's SCPS, as “Environment for Raising 

Concerns.” Additional information on Safety Conscious Work Environment can be 

found on the NRC’s Web page [12]. 

The NRC places a high value on nuclear industry employees being free to raise 

potential safety concerns to both licensee management and the NRC, regardless of the 

merits of the concern. Unlawful adverse actions taken against employees for raising 

safety concerns may create a "chilling effect" on the employee or other workers who 
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may wish to raise concerns. That is, the employees may not feel that they are free to 

raise concerns without fear of retaliation. When the chilling effect is not isolated (e.g., 

multiple individuals, functional groups, shift crews, or levels of workers within the 

organization are affected) the NRC refer to the situation as a chilled work 

environment. 

If the NRC suspects there is a chilled work environment in the organization, 

the licensee may be asked for more information or the NRC will investigate through 

follow-up inspections. If the NRC is concerned about the licensee’s awareness of, or 

efforts to address a known chilled work environment, a Chilling Effect Letter (CEL) 

may be issued. A CEL is a public way for the NRC to communicate with the licensee, 

the public, and the licensee’s employees. The intent of such action is, in part, to 

prompt the licensee to take actions to mitigate the chilling effect that the 

discriminatory act or other event has caused. The NRC’s Allegations Program 

includes guidance on the NRC’s Safety Conscious Work Environment Policy and 

CELs, and can be found on the NRC’s Web page [13]. 

In addition to the Allegation Program, the NRC's Enforcement Policy ensures, 

through appropriate enforcement action against a licensee or licensee contractor (and 

when warranted, against the individual personally responsible for the act of 

discrimination), that adverse employment actions taken against licensee or contractor 

employees for raising safety concerns do not have a chilling effect on the individual 

or others who may wish to report safety concerns. The NRC vigorously pursues 

actions against licensees or licensee contractors who discriminate against their 

employees for raising nuclear safety concerns. Acts of discrimination include 

discharge and other adverse actions that relate to an employee's compensation, terms, 

conditions, or privileges of employment. The NRC’s Enforcement Program includes 

information on sanctions for discrimination against employees who raise safety 

concerns, and can be found on the NRC’s Web page [14]. 

Safety Culture Corrective Actions: Through the identification of cross-cutting 

issues, safety culture assessments in supplemental inspections, or findings of 

discrimination or chilling effect, the NRC publicly documents the concerns, and the 

licensee responds to the concerns with planned corrective actions. The NRC may also 

use its post-investigation alternative dispute resolution (ADR) program to resolve 

discrimination cases or other wrongdoing through mediation rather than through the 

NRC’s traditional enforcement processes. The ADR program documents agreements 

between the NRC and the licensee on the licensee’s planned actions, which then 

becomes the basis for Confirmatory Orders (CO). The CO is legally binding, becomes 

part of the licensing basis for that particular plant, and identifies actions that must be 

closed out before a licensee can move back to column 1 in the ROP Action Matrix 

and the baseline inspection program. The NRC conducts follow-up reviews or 

inspections to close the concerns or verify implementation of the actions. More 

information on these enforcement actions can be found on the NRC’s Web page [15]. 
D. J. SIERACKI AND M. C. THOMPSON 

9 

More information on the NRC’s post-investigation ADR program can be found on the 

NRC’s Web page [16]. 

7. CONCLUSIONS 

The NRC communicates safety culture expectations through the SCPS, which 

applies to all organizations overseeing nuclear materials, including licensees, vendors 

and suppliers and Agreement States. The NRC qualifies inspectors to be safety culture 

assessors to facilitate the oversight of safety culture. In addition, safety culture 

oversight is achieved through the ROP and the cROP. Finally, the NRC’s Allegation 

and Enforcement Programs ensure that employees are free to raise safety concerns 

without fear of retaliation and can issue CELs and COs for SCWE and SC corrective 

actions. 

8. REFERENCES 

[1] UNITED STATES NUCLEAR REGULATORY COMMISSION, Agreement 

States Program (2016), http://www.nrc.gov/about-nrc/state-tribal/agreementstates.html. 

[2] UNITED STATES NUCLEAR REGULATORY COMMISSION, Safety Culture 

Policy Statement (2016), http://www.nrc.gov/about-nrc/safety-culture/sc-policystatement.html. 

[3] UNITED STATES NUCLEAR REGULATORY COMMISSION, Safety Culture 

Common Language (NUREG-2165) (2016), http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr2165/. 

[4] UNITED STATES NUCLEAR REGULATORY COMMISSION, Inspection 

Manual Chapters (2016), http://www.nrc.gov/reading-rm/doc-collections/inspmanual/manual-chapter/index.html. 

[5] UNITED STATES NUCLEAR REGULATORY COMMISSION, Inspection 

Procedure 95001 (2016), http://www.nrc.gov/reading-rm/doc-collections/inspmanual/inspection-procedure/ip95001.pdf. 

[6] UNITED STATES NUCLEAR REGULATORY COMMISSION, Inspection 

Procedure 95002 (2016), http://www.nrc.gov/reading-rm/doc-collections/inspmanual/inspection-procedure/ip95002.pdf. 
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[7] UNITED STATES NUCLEAR REGULATORY COMMISSION, Inspection 

Procedure 95003 (2016), http://www.nrc.gov/reading-rm/doc-collections/inspmanual/inspection-procedure/ip95003.pdf. 

[8] UNITED STATES NUCLEAR REGULATORY COMMISSION, Detailed ROP 

Description (2016), http://www.nrc.gov/reactors/operating/oversight/ropdescription.html. 

[9] UNITED STATES NUCLEAR REGULATORY COMMISSION, Reactor 

Oversight Process (NUREG-1649, Revision 5) (2016), http://www.nrc.gov/readingrm/doc-collections/nuregs/staff/sr1649/\ 

[10] UNITED STATES NUCLEAR REGULATORY COMMISSION, Inspection 

Manual Chapters (2016), http://www.nrc.gov/reading-rm/doc-collections/inspmanual/manual-chapter/index.html. 

[11] UNITED STATES NUCLEAR REGULATORY COMMISSION, Construction 

Reactor Oversight Process (cROP) (2016), http://www.nrc.gov/reactors/newreactors/oversight/crop.html. 

[12] UNITED STATES NUCLEAR REGULATORY COMMISSION, Safety 

Conscious Work Environment (2016), http://www.nrc.gov/about-nrc/safetyculture/scwe.html. 

[13] UNITED STATES NUCLEAR REGULATORY COMMISSION, Safety 

Conscious Work Environment Policy Guidance (2016), http://www.nrc.gov/aboutnrc/regulatory/allegations/scwe-mainpage.html. 

[14] UNITED STATES NUCLEAR REGULATORY COMMISSION, Sanctions for 

Discrimination Against Employees Who Raise Safety Concerns (2016), 

http://www.nrc.gov/about-nrc/regulatory/enforcement/sanctions.html. 

[15] UNITED STATES NUCLEAR REGULATORY COMMISSION, Enforcement 

Program Overview (2016), http://www.nrc.gov/aboutnrc/regulatory/enforcement/program-overview.html. 

[16] UNITED STATES NUCLEAR REGULATORY COMMISSION, Post 

Investigation ADR (2016), http://www.nrc.gov/aboutnrc/regulatory/enforcement/adr/post-investigation.html.