NRC and Safety Culture

, former director, Nuclear Safety Project | November 4, 2014, 6:00 am EDT
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Fission Stories #175

The Nuclear Regulatory Commission (NRC) issued a policy statement on June 14, 2011, stating how swell it would be if the owners of nuclear power plants established and maintained a positive safety culture. The NRC did not require that plant owners obtain and retain positive safety cultures, but expressed how important “a safety-first focus in nuclear work environments for public health and safety.”

Thus, the NRC is officially on record that positive safety cultures are swell and are important for public health and safety but has not taken any steps to require these swell and important things to be implemented.

NRC’s Safety Culture Traits

On its safety culture webpage, the NRC identifies nine very colorful traits needed for a positive safety culture. Like snowflakes, no two of the safety culture trait colors are the same. But because the NRC deems a positive safety culture as swell and important but not mandatory, plant owners need not collect any of these colored traits.

Positive safety culture traits from the NRC website.

Positive safety culture traits from the NRC website. (click to enlarge)

Pot, meet kettle. Or, kettle, meet pot. I’m not really sure which is the NRC and which is a plant owner.

Whether pot or kettle, the NRC is a few colors shy of having a positive safety culture itself. In late 2009, the NRC’s Office of the Inspector General (OIG) released a survey of the NRC’s safety culture. I submitted a request under the Freedom of Information Act for records regarding actions taken by the NRC in response to this safety culture survey.

(I submitted this request on March 22, 2013, but did not begin receiving the requested documents until nearly a year later. See Fission Stories #174 for additional information about the NRC violating federal statutes with its slow FOIA responses.)

NRC Focus Group Results

One of the records I eventually obtained from the lawbreaking NRC was a report by a focus group formed withing the NRC’s Region IV offices in Arlington, Texas, in response to the 2009 safety culture survey. This focus group report does not paint a very colorful picture of a positive safety culture. For example:

(1) The focus group considered the NRC’s Open Door Policy.

During the focus group discussions concerning the Open Door Policy, participants shared multiple occurrences in which retaliation was felt or trust was violated. For example, several experiences were shared in which a manager was approached via the Open Door policy due to issues with the participants’ immediate supervisor. In all shared experiences, the immediate supervisor was advised of the meeting and promptly confronted the staff member. The prompt confrontation response by the immediate supervisor suggests that not only did the manager share the fact that issues had been raised about the immediate supervisor but also identified the person(s) who raised them.

So, scratch out the “Respectful Work Environment” trait.

(2) The focus group probed the NRC’s non-concurrence process where any staffer can formally disagree with a position stated in a document he or she is asked to review.

Furthermore, many participants shared the belief that an unspoken understanding exists in which “You will concur.” Specifically, one individual stated, “the unwritten policy … is you will not — not concur.”

Okay, scratch out the “Questioning Attitude” trait (no questions asked).

(3) The focus group probed the NRC’s differing professional opinion (DPO) process where any staffer can formally disagree with a regulatory decision made by the agency.

The general feeling of some was that if the DPO were used, the end result would carry negative consequences especially if the DPO effort was unsuccessful. For example, one participant stated “I’ll never do it, it’s a black mark if I am not successful” and “If I made everyone work and don’t win, I will see repercussions.”

Well, scratch out the “Environment for Raising Concerns” trait.

(4) The focus group also examined management and leadership issues.

The focus group participants also shared the perception that not all managers really support the Open Door Policy.

Some also thought that the tone of the Region encourages misuse of staff.

Other staff participating in the focus group felt that a different set of rules applies to upper management than the rest of the staff. One individual shared an example involving the behavior of a manager at a facility [licensed by the NRC]. They concluded by saying, “if I would have done that, I would have been fired.”

During the focus group concerning the 2009 OIG safety culture and climate survey, participants felt that the survey will have little or no impact on changing the culture.

The Open, Collaborative Working Environment in Region IV is not meeting the intended vision and correction action is essential in addressing issues identified in this report.

Scratch out the “Leadership Safety Values and Action” trait, at least once.

NRC chart with UCS annotations (click to enlarge)

NRC chart with UCS annotations (click to enlarge)

Our Takeaway

The NRC identifies nine traits needed for a positive safety culture.

But perhaps a positive safety culture is not like baseball. Maybe you really don’t need nine in order to play. Perhaps only a handful of traits yields a positive safety culture.

What was I not thinking?

The NRC does not require that plant owners develop positive safety cultures at their facilities. Therefore, having NONE of the traits is as acceptable to the NRC as having all NINE. Because a positive safety culture is not mandatory, having all nine traits would not even win you an Open Door prize.

By any count or color, the NRC cannot be an effective and efficient safety regulator when its staff does not feel free to raise concern and lacks trust in their managers. If the agency’s workers do not trust NRC managers, why should the U.S. Congress or the American public trust them?


“Fission Stories” is a weekly feature by Dave Lochbaum. For more information on nuclear power safety, see the nuclear safety section of UCS’s website and our interactive map, the Nuclear Power Information Tracker.

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  • Charles Jones

    I always appreciate Dave’s perspective on nuclear reactor safety topics. He also passed my online nuclear safety culture quiz many years ago. Also, I am particularly fond of nuclear safety culture topics since I went to the trouble of writing a short essay on what we did culturally to ensure the success of the Navy’s NIMITZ aircraft carrier and reactor construction and testing back in 1974-1975, where I witnessed an extraordinary management and safety culture, even for the Navy.

    I think you can also strike through “Problem Identification and Resolution” block on the part of the NRC and NEI, if not the rest of the PWR-related commercial reactor world. Over 10 years ago I identified a PWR loss of offsite power/station blackout procedural issue that could lead to core melt. When I brought it up, the NRC reps did not really understand the problem and did not care to investigate it at all, much less thoroughly. I explained it to an NEI rep about a year ago. I am still waiting.

    In my 48 years of doing nuclear work for the Navy, the NRC/Commercial Plants, and the DOE/nuclear weapons facilities and National Laboratories, the NIMITZ PRECOMMUNIT approach was the only one I found to be successful to the point of being adequate to meet all the NRC criteria Dave describes here. NNSA published my short essay on that topic in one of their technical bulletins in 2012, so at least some facilities in DOE/NNSA may have some hope.

    The NRC is simply a top-down politically driven organization, so only the Chairman will be able to improve the culture, and we all know that won’t happen any time soon. The DOE has similar problems, of course, that are well know to the DNFSB, which raised the same kinds of safety culture issues a few years ago. It is easy to identify issues and even quantify them, but fixing them requires true leadership and vigorous involvement from the top, not just a list of the obvious attributes that are usually missing.

    At this time I have to agree that just about every nuclear organization is either failing or at best inconsistent in the nuclear safety culture arena with the possible exception of the Naval Reactors program. The safety programs in other high-hazard programs (eg, NASA and BP/oil rigs) have similar problems, so we might want to start a national safety culture training school!

  • Leslie Corrice

    Another typical, presumptive attack on the regulators by America’s leading NRC basher. Keep on cherry-picking, David…you’re so good at it.