ML102500664

NRC000041-SRM-SECY-0975 Safety Culture Policy Statement (October 16, 2009)

ML102500664
Person / Time
Site:	Prairie Island
Issue date:	10/16/2009
From:	Annette Vietti-Cook NRC/SECY
To:	Borchardt R NRC/EDO
SECY RAS
Shared Package
ML102500654	List: ML102500655 ML102500657 ML102500660 ML102500663 ML102500664 ML102500666 ML102500667 ML102500668 ML102500670 ML102500671 ML102500672 ML102500675 ML102500676 RIS 2006-13, 2006/07/31-Intervenor-Exhibit 10-Information On The Changes Made To The Reactor Oversight Process To More Fully Address Safety Culture, Regulatory Issue Summary 2006-13, U.S. NRC RIS 2006-13, NRC000046-NRC Regulatory Issue Summary 2006-13, Information on the Changes Made to the Reactor Oversight Process to More Fully Address Safety Culture SECY-04-0111, NRC000044-SRM-SECY-04-0111 - Recommended Staff Actions Re Agency Guidance in the Areas of Safety Conscious Work Environment & Safety Culture SECY-05-0187, NRC000045-SRM-SECY-05-0187 Status of Safety Culture Initiatives and Schedule for Near-Term Deliverables (December 21, 2005) SECY-09-0075, NRC000040-SECY-09-0075 Safety Culture Policy Statement (March 18, 2009)
References
50-282-LR, 50-306-LR, ASLBP 08-871-01-LR-BD01, RAS 18574, SECY-09-0075 SRM-SECY-09-0075
Download: ML102500664 (19)

Text

NRC000041 October 16, 2009 MEMORANDUM TO: R. W. Borchardt Executive Director for Operations FROM: Annette L. Vietti-Cook, Secretary /RA/

SUBJECT:

STAFF REQUIREMENTS - SECY-09-0075 - SAFETY CULTURE POLICY STATEMENT The Commission has approved publication of the draft Safety Culture Policy Statement in the Federal Register for no less than a 90-day public comment period, subject to the changes noted in the attachment.

The staff should consider incorporating suppliers and vendors of safety related components into the Safety Culture Policy Statement.

During the public comment period, the staff should continue to engage a broad range of stakeholders, including the Agreement States and other organizations with an interest in nuclear safety to ensure the final policy statement presented to the Commission benefits from consideration of a spectrum of views and provides the necessary foundation for safety culture applicable to the entire nuclear industry.

In developing the draft final policy statement and while making the necessary adjustments to encompass security within the statement, the staff should seek opportunities to comport NRC terminology, where possible, with that of existing standards and references maintained by those that NRC regulates.

The public comment period should be extended to no less than 90 days as a substantial increment of this time will likely be used just in building awareness of the draft statement and the opportunity for comment.

Attachment:

Changes to the Federal Register notice in SECY-09-0075 cc: Chairman Jaczko Commissioner Klein Commissioner Svinicki OGC CFO OCA OPA Office Directors, Regions, ACRS, ASLBP (via E-Mail)

PDR

NRC000041 DRAFT FEDERAL REGISTER NOTICE NO TICE NUCLEAR REGULATORY COMMISSION IN

[NRC-2009-xxxx]

RC-2009-xxxx]

Draft Safety Culture Policy Statement:

Requ Request est for Public Comments AGENCY AGENCY:: Nuclear Regulatory Commission (NRC). (NRC).

ACTION ACTION:: Issuance of draft safety culture policy statement and notice of opportunity for public comment.

'10

')0 requested ~days from the date of this Federal Register Notice.

DATES : Comments are requested..:r5"1::!ays Notice Comments received after this date will be considered if it is practica practicall to do so, but the NR NRC C is ab le to assure consideration only for comments received on or before this dale.

able date. Please refer to the Supplementary Information sect section io n for add additional including itional information includi questions ng quest ions for which wh ich the NRC is requesting comment.

ADDRESSES:: Members of the pub ADDRESSES publiclic are invited and encouraged to subm submitit comments by 75 days from the date of th is Federa(

this Federal Register Notice, Notice, by mail to Isabelle Isabell e Schoenfeld, Schoenfeld , Office of Enforcement, E Mailil Stop 0-4 A nforcement, Ma 15A,, U.S. Nuclear Regu A15A Regulatory Commission, latory Comm ission, Washington , DC 20555-0001 , or bye-mail 20555-0001, by e-mail to Isabelle.schoenfeld@nrc.qov.

isabelle.schoenfe ld@nrc.gov.

Enclosure 1

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SUMMARY

The NRC is issuing a draft policy statement that sets forth the Commission's that a/l licensees and certificate holders 1 establish maintain a positive safety that protects public health and safety and the common defense and security when out activities. The Commission defines safety culture as that assembly characteristics, attitudes, and behaviors in organizations and individuals, which tAat that, as an overriding priority, nuclear and nuclear security the attention warranted by their significance. Commission considers nuclear safety and security issues to equally important in a positive safety culture. importance treating safety security in an equal manner within NRC's regulatory framework is clearly evident in our mission strategic goals. shown that certain organizational characteristics and personnel attitudes behaviors are present in a positive safety culture. These include, but are not limited to, individuals demonstrating ownership and personal responsibility day-to-day work activities; the implementation of maintaining safety and security in their day*to-day processes for planning and controlling work activities that safety and security are maintained; a work environment in which personnel to safety and security concerns without of retaliation; prompt thorough identification, evaluation, and resolution of commensurate with significance; the availability of the resources to ensure that and security are maintained; decision-making that protect and clearly roles and for maintaining safety and security; the seeking out implementation of opportunities to improve and security. NRC expects its and certificate holders to foster 1 Throughout this document, the phrase "licensee and holders" includes permit holders, authorization holders, holders of quality assurance program for a or quality assurance program Throughout this document, the terms or "nuclear .. or "nuclear security," and "safety culture" are used. These terms refer to matters that are related to including radiation protection, safeguards, material control and physical protection, and emergency

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characteristics, attitudes, behaviors in their ns and individuals who are overseeing or performing regulated activities commensurate with safety and significance of their activities and nature and complexity of organization and functions.

NRC is requesting on safety culture policy and questions.

SUPPLEMENTARY INFORMATION:

(1)

The Commission long its for culture in previous policy In 1989, the Commission its "Policy Statement on the Conduct Nuclear Plant (54 3424; January 24, 1989) make Commission's licensed operators with to conduct of operations. policy statement stated, phrase culture to a very matter, personal dedication and accountability of individuals engaged in any activity which has a bearing on the safety of nuclear power plants." policy statement stated that the Commission issued the policy statement to help foster development and maintenance of a culture at facility by the In 1996, the a policy of Employees in the Nuclear to Without Retaliation" (61 FR 24336; May 14, 1996), to set forth its expectations that licensees and other employers subject to NRC authority will establish and maintain safety-conscious environments in which employees free to safety concerns, both to management and to the

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without fear of retaliation. policy to activities of all licensees their contractors and A work environment is an important attribute of safety culture and is one of safety culture in the safety culture policy statement.

The importance of a positive safety culture for activities involving uses of radioactive materials and potential hazards demonstrated anum significant, high-visibility events world-wide that have occurred in the period since the Commission published its 1989 policy statement addressing safety culture in nuclear power plants. The events occurred across multiple industries including nuclear power plants, cycle facilititSJnd in other ind such as chemical processing and Examples nuclear industry events include those that occurred at the Davis-Nuclear Power Station and the Peach Bottom Atomic Power Station. Workers at Nuclear ..... n'.,"'r Station discovered a in vessel caused boric acid corrosion developed over a period of several but was discovered before the cavity developed. The licensee's analysis of the event identified weaknesses in the station's culture as the root cause of event It particularly noted that prioritized "production over safety." the Bottom Atomic .... ""AllOr Station, np,'<:f)nn,:::'1

,-,"'A/or ne,'",,,,,,,,,,:>, to of plant were identified, specifically, inattentiveness by security Other licensees have had recurring problems resulting in violations NRC regulations.

Through a Commission confirmatory order, a fuel cycle facility licensee; Nuclear Fuel

~f¥H,**,r;-ff*i-:-;-

aef¥H;er,-tf~ committed to having a third-party assessment of its safety culture to determine the causes of its continuing problems aM in to establish appropriate corrective actions, third-party assessment weaknesses in ev-Elf-Y-areas

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im portant to-safety culture.

important culture . In add ition, weaknesses in the safety culture of licensees and addition, certificate holders have contcontributed ributed to unscheduled events or incidents that the Commission has determined to be sign significant ificant from the standpoint of public health and safety.

safety. Examples linked to characteristics and attitudes in organ izations and individuals organizations associated with weak safety cultures include inadequate procedures; procedures ; procedures not being followed; followed: inadequate supervision; decision-making that does not ensure ens ure that safety and security are maintained; and ineffective problem identification, evalu evaluation, ation. and resolution.

resolution.

They have included medical misadmin istra tions (such as giving iodine-131 to lactating misadministrations females that res ulted in the uptake by their infants and multiple events associated with resulted prostate brachytherapy treatment) and overexposures arising from the loss of control of radiography or well logglogging ing sources .,

(2) Statement of Policy ills It is the CommiSSion Commission 's policy that a strong safe ty culture is an essential element for safety individuals, both Internal to external , perform 10 the NRC and external. ing or overseeing regulated performing activities ., As such ., the NRC will include appropriate means to monitor safety culture in Its its oversight programs and Internal management processes {PBl {PBL Edit} The NRC 'definesdefines safety culture as that assembly of characteristics, attitudes, and behaviors in organizations and individuals.

individuals, which U:lat-establishes tHat-.establishes th that, priority, nuclear safety and at, as an overriding priority, nl::lclear nuclear security issues receive the attention warranted by their significance. +He Comm ission also con Commission sisers nuc considers lear safety and nuclear security ;ssl:les nuclear issuos to be bo equally eql:lally im portant in a positiovo important positive safety Gu lture.. Further, culture Further, it is important for all organ organizations licensoos izations liconsees and certificate holders to provide personnel in the safety and security sectors with an appreciation for the importance of each each,, emphasizing Ihe the need for integration and balance to achieve optimized protection.

prolection . Safely Safety and security activities are close ly intertwined, and it closely

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is consideration be integrated so as not to diminish or adversely either safety or A safety culture that accomplishes this would include nuclear safety and f"H:t':7I6(:tf issues associated with NRC-regulated activities including radiation protection, material accounting, physical protection, and issues among that receive attention as a matter of priority.

The regulations are to protect both public workers radiation from the use of materials. The of responsibility includes regulation of nuclear power plants; test, and nuclear fuel cycle faCilities, medical, academic, and industrial uses of materials; and the transport, storage, and disposal of radioactive materials and wastes. Commission carries out responsibilities in numerous ways including through such ulatory activities as ""r.,,,,,,,nro licensed and activities; analyzing, and information safety and security; nuclear ,n,...,nonre developing policy and providing direction on issues.

The Commission believes that, and certificate use or provide services to the use of they responsibility for safely therefore, each and responsibility to maintain a positive culture, mat that nuclear safety and nuclear security as an overriding priority, the attention warranted by significance. and certificate should foster a culture in among individuals who are overseeing or activities. as the

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regulatory the ion has an independent oversight role (through inspection processes) including addressing I and certificate holder?

performance related to areas important to safety " '"

(3)

In 1991, as a result of the 1986 Chernobyl accident, the International Nuclear Safety (INSAG) emphasized the concept of safety culture the nuclear industry in its report, INSAG-4, "Safety Culture." INSAG is an advisory group to the International Atomic Agency (IAEA). The INSAG-4 definition of safety "that assembly characteristics attitudes in individuals which that. as an overriding priority, nuclear plant receive attention warranted by their significa nce."

in the INSAG definition of safety culture is the recognition that every organization is continually faced with resolving among its goals for cost, ule, and quality (or safety). The organization's members (groups and individuals) also conflicts different in performing jobs. Management the framework (management systems, programs, processes) and communicates its priorities for resolving conflicts among different goals. Members of the organization work within that framework and a nd are influenced by management's priorities, but they their own beliefs about what is important and individual on how to proceed faced with multiple competing INSAG definition that in a safety culture, the goal of maintaining nuclear priority in the organization's and individuals' decision~making and when faced with a conflict with other organizational or individual goals,

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Commission modified the INSAG definition safety culture which refers to "nuclear safety." The Commission is strongly committed to promoting positive cultures among reactor however, the Commission regulates many other and involving civilian uses of radioactive These regulated activities include industrial services; clinics individual practitioners involved in medical uses of radioactive ' research and reactors; fuel fabrication as well as nuclear power plants. Commission regulates the construction of new facilities where operations will involve radioactive materials with potential to public health and and the common defense and Therefore, by ng the INSAG definition of safety to replace with safety," Commission is it expects all licensees highest on nuclear with the in the activities.

The Commission modified definition to uately capture or communicate the eq importance of n security and safety in a positive safety culture.

Following the terrorist attacks of Septem 11, 2001, the Commission increased attention to the important role of in regulated whose can have an impact on public health and safety. The issued enhancing security at NRC-regulated facilities to further ensure public health and the common defense and One of gained from emphasis on security is the of incorporating into a safety culture and effectively the safety a In general, and security refers to the organizational and individual awareness that of safety and must be together so that to of functions

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goals and goa ls do not inadvertently compromise the other. other. Therefore, Therefore , to emphasize the equa equall importance of nuclear security and nuclear safety in a positive safety culture culture,, the Commission has added "nuclear security" to the safety culture definition. The NRC's modified INSAG definition is provided in the Statement of Policy section above .

(4) Stakeholder Outreach The Commission's February 28, 2009,, Staff Requirements Memorandum (SRM)-COMG8J 28 , 2009 (SRM)-COMG6J-08-0001, "A Commission Policy Statement on Safety Cu 08-0001. Culture, lture ,"" slated stated in part that the staff should,, as part of its public stakeholder outreach should outreach,, reach out to all Iypes types of licensees and holders. In the development of the draft policy statement, the NRC staff sought certificate holders.

stakeholders.. This was accomplished by providing information insights and feedback from stakeholders in a variety of forums such as stakeholder organization meetings, newsletters, and teleconferences and by pub lishing questions in Federal Register Notices entitled "Safety publishing Culture Policy Statement: Public Meeting and Request for Public Comments" (74 FR 4260; 4260; January 23,23, 2009, 2009, and 74 FR 6433; February 9, 2009) Ihat that were related 10 to Ihe the Commission's SRM. In addition.

addition, a significant significan t stakeholder outreach activity was accomplished by a public workshop held on February 3, 3, 2009 2009,, at NRC Headquarters in Maryland . The staff reviewed and considered the stakeholder feedback derived Rockville, Maryland.

from these different forums and incorporated it into the development of the draft policy pol icy statement and recommendations.

(5) Safety and Security Culture In SRM-COMGJ8-08-0001, SRM-COMGJ B-08-0001, the Commission also considered whether whelher publishing the Ihe NRC's expectations for safety and security culture is best accomplished in one safety/security

NRC000041 10 cu lture sta culture tement or in two separate statements , one each for safety and security, statement security. while wh ile sti stillll considering the safety and security interface interface..

Based on a variety of sources including document reviews and stakeholder feedback, the Commission concluded there is no one definitive view of this issue, but the results results weighed heavily heavi ly toward a single policy statement \0 to be titled a "Safety Culture Policy Statement. "

Document reviews and stakeholder feedback suggested that a single policy statement bu ilds on the fact thaI (1) builds that safety and security have the same ultimate ultima te purpose of protecting people and the environment from unintended radiation exposure and (2) encourages attention to the ways safety and security interface. interface . For these reasons , the CommissionCommisSion determmed that I+he t+he term "safety cul ture"" should Include both safety and secunty culture security eege consid considered ered as all encomp assing becau encompassing becausose thoro thero would be no need for security secu rity pertaining perlaining to radioactivo material if it 'Nere not for radioactive mat the use of radioactive tho erial used by liconseos material licensees ana and certificato holdors co rl ifica to hold ers .

Safety and security have been the primary pillars of NRC's regulatory programs. programs. However, in the current heightened he ightened threat environment , there has been a renewed focus on security, and the staff has imp lemented a number of efforts to enhance security and strengthen the implemented safety and security interface.

interface , It is important to understand that both safety and security share a common purpose of protecting public hea lth and safety health safe l y,. In today today's 's environment ,

closel~

safety and security activities are closell0fflelcw",e,edt.el=tvv:1 ed,, and it is critical that tha t cons ideration of

/'

these activities be integrated so as to omPlrmen each olher 10 ompirmen other and not -Ie te diminish or i.i adversely impact either safe ly or security.

safety urther, it is important Important for licensees and certificate holders to provide personnel in the safety and security sectors with an appreciation apprec iation for the importance of each , emphasizing emphaSizing the need for integration and balance ba lance to achieve optim ized protection . The importance of both safety and security in an equa optimized equall

NRC000041 11 and balanced manner wi th in NRC within NRC's 's regu latory framework is clearly evident in the regulatory Commission Commission's 's mission and strateg strategic goals..

ic goals While Whi le many safety and security activities comp complement lement each other or are synergistic synergistic,, there rem remain potential conflicts may arise differences . It is then impera ain areas where potential tive th imperative at that mechanisms be established to resolve these potential conflicts to differences E1itferencos if wo /flusl we must assure the adequate protection of public publ ic health and safety and promote the common defen sGe and security.

defensc Hence , safety and security have implications for each other in security . Hence, connection with all aspects of nuclea nuclearr activities activ ities . For example.

oxamf310 , the enhancod enhanced risk of a sabotage ovent has highlighted the sabotago event tho importance of in tog rating safety and security in the field integrating of protection and of iden tifying areas where they need to GempleFflont identifying complement each other otho r 60 so that a terrorist event can be dealt doalt withwit h in as seamless a fash fashionion as possible.

possible .

important difference or challenge is the way in One potential iFflportanl in which which individuals involved invo lved in safety and security act activities approach ivities app roach the goal riskk mitigation and protection of public goa l of ris pub li c safety . The safety staff health and safety. slaft is typically typica lly focused focu sed on preventing errors that tha t would result in an an inadvertent accident while the security slaH staff is focused on preventing deli berate deliberate attacks or diversion of certa certain in materials that couldcou ld cause harm.

harm. Anothor

/\nother difference differonco is the tho way in wh ich indl>"iduals which individuals involved in safoty safety and security act ivities approach inform activities atio n Information sharing . Tho The safety staff promotes information sharing and collaboration collabora tion while s~curity wh ile the security stall staff promotes the sensitivity of information and a noed need to know.

know . These differencos differences as we wellll as any others identified through stakeholder interactions wou would neod to be rosol'.'od ld noed resolved and managed.. Another ch managed allenge is that the organization/facility must ensure that the exis challenge existence tence mo tivated and capable persons with in of motivated ill intent is recognized recogn ized and that th thee importance of nucl ear security to prevent such persons from unauthorized access is nuclear understood .

is understood. ~

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'-AGee for SA

--!::ioee Bt=! ~ sensltlvliy to tile iml'fUVed sensitivity COifeel"it! thf~Vironment the COil tto.reat1friwonmen! is exacerbated by the b) lAC- X

-eigl"lifict!lr'lt §f9Wth

..eigAificMt growth in Rudest Ruelee, utilization vool WtJrl9wi~

is wid..e.. To manage these potential conflicts or X

challenges , the Agency has recently Issued challenges, issued regulations regu lations on the safety/security Interface An overarchlng safety culture policy statement whIch which encompasses security supports and further enhances those regulations .

Based on the above consideratconsiderations ions , the Commiss Commission ion concluded that a single popolicy licy statement would acco mp lish its goal accomplish goa l that, that , as an overriding priority.

priority, safety issues and security issues receive the atlention attention warranted by their significance.

significance . Although, in some cases , issues relating to security might be handled differently than issues related to safety.

cases, A single policy statement recogn izes there is one overarching culture in an organiza recognizes tion;;

organization however.

however, safety and security functions fUnctions and goals must be treated equally within that overarching overarch culture .

ing safety culture.

Characteristics (6) Characteri sti cs of a Pos Positive itive Safety Culture Experience has shown that certain organizational attributes and personne personnell attitudes and behaviors are present in a positive safety culture culture.. Therefore.

Therefore , in 2006.

2006, when the NRC implemented an enhanced reactor oversight process (RaP) (ROP ) that more fully addressed safety culture, cu lture, it identified and incorporated safety culture components that are overarching characteristics of a positive safety culture, culture . The NRC based its development of the safety culture components on a review of a variety of sources of information including the Institute of Nuclear Power Operat ions ; the IAEA; Operations; IAEA; the Nuclear Energy Agency; Age ncy; the regulatory approaches of other domestic and international organizations :; and the organizational behaVior , safety culture, behavior, culture , and safety climate cl imate research literature . The Commission presented

NRC000041 13 drafts of the safety culture components and aspects in frequent public meetings and modified mod ified them in response 10 to stakeholder feedback feedback..

For the purpose of this policy statement, statement. the NRC modified the ROP safety culture (termed "safely components {termed characteristics") to explicitly address security in the "safety culture characteristics"}

safety culture characteristics descriptions, descriptions, create a more generic description for each safety safely culture characteristic that would apply to the range of NRC licensees and certificate holders, and maintain all the safety culture concepts in the safety culture components. The staff presented the draft safety culture characteristics for stakeholder comment in a February 3, 2009, public workshop and on the NRC's public safety culture Web site 3, 2009.

(http://www .nrc.gov/about-nrc/reg ula tory/e nforcementlsafety-culture..hlml).

(http://www.nrc.gov/about-nrc/regulatory/enforcemenVsafety-culture h1mI).

Although the safety culture characteristics themselves are applicable to all licensees and certificate holders holders,, there may be other examples that more specifically address the unique characteristics of a licensee's or certificate holder's environment (i.e.,(i.e ., unique for medical and industrial applications , operating reactors, reactors, research and test reactors, fuel cycle facilities , and new reactor construction environments).

environments). Hence, the Commission Comm ission recognizes that these safety culture characteristics are not all ali inclusive; inclusive: other characteristics and attitudes in organizations and individuals may be indicative of a positive safety culture.

However, the Commission expects its licensees and certificate holders 10 to consider the extent to which these characteristics and attitudes are present in their organizations and exlentto among individuals who are overseeing or performing regulated activities and to take steps, if necessary, necessary, to foster a positive safety cu culture lture commensurate with the safety and security significance of activities and the nature and complexity of Ihe the licensee licensee's 's or certificate holder's organization and functions .

NRC000041 14 The following characteristics that are indicative of a positive safety culture , are relevant across the broad range of licensoes licensees and SAg certificate holders holders activities eamed carried out by the nuclear Industry, industry, the Agreement States and the NRC , and address the importance of nuclear safety and security:

• Personnel demonstrate ownership for nuclear safety and security in their the ir day-to-day day-la-day by,. for example, work activities by example , ensuring that their day-la-day day-to-day work activities and products meet professional standards commensurate with the potential impacts of their work on safety and security . They proceed with caution when making safety- or security-related decisions and question their the ir assumptions , especially when faced with uncertain or unexpected cond itions, to ensure that safety and security are ma conditions, maintained.

intained.

• Processes for plann planninging and controlling work ensure that individual contributors contributors,,

supervisors, and work groups communicate , coordinate , and execute their work activities in a manner that supports safety and security. For example, individuals and work groups communicate and cooperate during work projects and activities to ensure their actions do not interact with those of others to adversely affect safety or security. In addition, addition ,

managers and supervisors are accessible to oversee work activities activities,, includ including ing those of contractors or vendors , and they challenge work activities and work products that do not meet their standards .

• The organization licensee certificate Roh30r licenseo or cortificate holder maintains a safety conscious work environment in which personnel feel free to raise safety and security concerns without fear of retaliation . For example , claims of harassment, harassment, intim intimidation, idation, retaliation, and discrimination are investigated consistent with the regulations regarding employee protection . If an instance of harassment, harassment, intimidation , retaliation, retaliation , or discrimination for

NRC000041 15 raising a safety or security concern is identified, corrective actions are taken in a timely manner.

• The organization licensoe licensee or certificate holder ensures that issues potentially impacting safety or security are promptly identified, fully evaluated, evaluated , and promptly addressed and corrected,, commensurate w corrected with ith their significance.

• The organizatIon organization licensee or certificate cortificate holder ensures that the personnel personnel,, equipment, tools, procedures., and other resources needed to assure safety and security are tools , procedures available.. For example , training is developed and implemented or accessed to ensure available personnel competence competence.. Procedures Procedures,, work instructions, instructions, design documentation, drawings, drawings, databases, and other job aids and reference materials are complete. complete , accurate, accurate , and up up*

to-date to*date .

• The organIzation's organization's licensee or certificate holderholdor decisions ensure that safety and security maintained. For example, are maintained. example , production , cost, cost, and schedule goals are developed, developed, communicated,, and implemented in a manner which demonstrates that safety communicated safely and overriding security are overrid ing priorities.

priorities .

• Roles,, responsibilities, Roles responsibilities , and authorities for safety and security are clearly defined and reinforced. For example, personnel understand their roles and responsibilities in maintaining safety and security security.. Programs, Progra ms, processes, processes , procedures, and organizational interfaces are clearly defined and implemented as designed. designed. Leaders at all levels of the organization consistently demonstrate that safety and security are overriding priorities priorities..

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• The organization licensoe licensee or certificate certificalo holder mainta maintains ins a continuous learn ing learning environment in wh ich opportunities which opportun ities to improve safety and security are sought out and implemented implemented.. For example . individuals are encouraged to develop and maintain curren! current the ir profess their ional and technical knowledge . skill professional skillss,. a nd abilities and abili ties and to rema remainin knowledgeable of industry standards and innovative practices. practices . Personnel seek ou outt and implement im opportunities plement opportun ities to improve safety and security performance .

(7) Implementation Impl ementation of Policy Poli c y Th is policy statement describes This descnbes areas important to safety culture culture., but it does not address how the nuclear IndustryIndustry. the Agreement statet Slate&) nd the NRC liconsee licensee or certificate hold or holder should establis ma in ta in a pos establishh and maintain iti ve safety culture in i46 positive ito theIr organizations organizations. licensees, Licensees, and certlfiGale holder6 The nuclear Industry, certificate holders industry, the Agreement State~nd the NRC differ in X

)c their size and complexity complexity., infrastructure, in frastructure, and organ izational frameworks organizational frameworks.. Therefore Therefore., a single approach for establishing establi sh ing and maintaining maint aining a positive safety cu culture lture is not possible possible..

Nevertheless, Neverthe Commission less, the Comm ission expects that nuclear safety and security issues receive the attentionn warranted by their significance.

attentio significance , and all organizatIons licensee or all orgamzatlons certificate er certifica holder te hold er consider and foster foste r the safety culture ch characteristics (commensurate aracteris tics (commensu rate with with the safety and security significance of act ivi ties and the nature and complexity of their organi activities za tion and organization functions) functions ) in carrying out their the ir day-to-day work activities and decisio decisions ns..

QUESTIONS FOR WHICH NRC IS SEEKING INPUT:

(1) The draft policy statement provides a description of areas importanl important to safety culture ,.

(i .e.,

(i. e., safety cuculture characteristics)).. Are there any characteristics relevant to a particu lture characteristics particular lar

NRC000041 17 of or holder (if so, please specify which type) that do not appear to be addressed?

(2) Are there safety culture as r1<:>c:rrll')Qr1 in draft policy statement that you believe do not contribute to culture and, therefore, should not included?

(3) Regarding the understanding of what Commission means by a culture, would it help to include the culture characteristics in the Statement of Policy in policy statement?

(4) draft policy statement includes the following definition of safety culture: "Safety culture is that assembly of behaviors in organizations and individuals, which as an overriding priority, nuclear and fH::H~!If fH::H~:I+

security receive the attention warranted by their significance." Does this definition need further clarification to useful?

(5) The draft policy statement "All and certificate holders should consider and foster the safety culture characteristics (commensurate with the safety and security significance of activities and nature and complexity of their organization and functions) in carrying out their day-to-day work activities and decisions." Given diversity among the and certificate holders regulated by the NRC and the reement does this statement need further clarification?

(6) How well does the draft safety culture policy statement enhance licensees' and certificate holders' understanding of the NRC's that maintain a safety culture that includes related to security?

NRC000041 18 (7) In addition to issuing a safety culture policy statement, what might the NRC consider doing, or doing differently, to increase licensees' and certificate holders' attention to safety culture in the materials area?

(8) How can the NRC better involve stakeholders to culture, including security, for all NRC Agreement and holders?

To ensure efficient consideration of your comments, please identify the question numbers with your comments when applicable. When commenting, caution with regard to site-specific security-related information. Comments will made available to the public in their entirety. Personal information such as your name, address, telephone number, and e-mail address will not be removed from your submission.

For the Nuclear Regulatory Commission.

Cynthia A. Carpenter, Director Office of Enforcement Dated at Rockville, Maryland, _____ _,, 2009.