ML102500664
Text
October 16, 2009
MEMORANDUM TO: R. W. Borchardt Executive Director for Operations
FROM: Annette L. Vietti-Cook, Secretary
/RA/
SUBJECT:
STAFF REQUIREMEN TS - SECY-09-0075 - SAFETY CULTURE POLICY ST ATEMENT The Commission ha s approved publication of the draft Safety Culture Policy Statement in the Federal Register for no less than a 9 0-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, includ ing 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 state ment, 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 likel y be used just in building awareness of the draft statement and the opportunity for comment.
Attachment:
Changes to the Federal Register not ice in SECY-09-0075
cc: Chairman Jaczko Commissioner Klein Commissioner Svinicki OGC CFO OCA OPA Office Directors, Regions, ACRS, ASLBP (via E-Mail)
PDR DRAFT FEDERAL REGISTER NUCLEAR REGULATORY Draft Safety Culture Policy Request for Public AGENCY: Nuclear Regulatory Commission (NRC). ACTION: Issuance of draft safety culture policy statement and notice of opportunity for public comment. '10 DATES: Comments are requested from the date of this Federal Register Notice. Comments received after this date will be considered if it is practical to do so, but the NRC is able to assure consideration only for comments received on or before this date. Please refer to the Supplementary Information section for additional information including questions for which the NRC is requesting comment. ADDRESSES:
Members of the public are i nvited and encouraged to submit comments by 75 days from the date of this Federal Register Notice, by mail to Isabelle Schoenfeld, Off i ce of Enforcement , Mail Stop 0-4 A 15A, U.S. Nuclear Regulatory Commission, Washington , DC 20555-0001 , or bye-mail to isabelle.schoenfe l d@nrc.gov. Enclosure 1 DRAFT FEDERAL REGISTER NO TICE NUCLEAR REGULATORY COMMISSION IN RC-2009-xxxx]
Draft Saf e ty Culture Policy Statem e nt: Requ e st for Public Comments AGENCY: N uc l ear Regulatory Commission (N RC). ACTION: Issuance of draft safety culture po lic y statement and notice of opportunity for pub lic comment. ')0 DATES: Comments are requested..:r5"1::!ays from the date of th i s Federal Regis t er Not ic e Comments received after this date w ill be cons i dered if i t is practica l to do so, but the NR C i s ab l e to assure consideration only for comments received on or before this dale. Please refer to the Supplementary Informat io n sect io n for add i tional information i ncludi n g quest i ons for wh ic h the N RC i s requesting comment. ADDRESSES: Members of the pub l i c are inv i ted and encouraged to subm i t comments by 75 days from the date of th i s Federa( Register Notice , by mail to Isab e ll e Schoenfeld , Off i ce of E nforcement, Ma il Stop 0-4 A15A , U.S. N uclear R egu l atory Comm i ssion, Washington , DC 20555-0001, or by e-mail to Isabelle.schoenfeld@nrc.qov.
Enc l osure 1
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 maintaining safety and security in their day-to-day work activities; the implementation of 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 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 resolution of 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 2
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 maintaining safety and security in their day*to-day work activities; the implementation of 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 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 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 3 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 questions.
on safety culture policy and 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 Nuclear to a policy Without of Employees in the 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 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 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, 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 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 4 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 ,-,"'A/or Station, np,'<:f)nn,:::'1 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 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 important to-safety culture. In addition, weaknesses in the safety culture of licensees and certificate holders have contributed to unscheduled events or incidents that the Commission has determined to be significant from the standpoint of public health and safety. Examples linked to characteristics and attitudes in organizations and individuals associated with weak safety cultures include inadequate procedures; procedures not being followed; inadequate supervision; decision-making that does not ensure that safety and security are maintained; and ineffective problem identification, evaluation, and resolution.
They have included medical misadministrations (such as giving iodine-131 to lactating females that resulted in the uptake by their infants and multiple events associated with prostate brachytherapy treatment) and overexposures arising from the loss of control of radiography or well logging sources. (2) Statement of Policy It i s the Commiss i on 's policy that a s t rong safe t y culture i s an essential element for i ndiv i duals , both Internal t o the NRC and external , perform i ng or overseeing regulated activities. As such. the NRC will i nclude appropriate means to monitor safety culture in its overs i ght programs a n d Internal management p r ocesses {PBL Edit} The NRC defines safety culture as that assembly of characteristics, attitudes, and behaviors in organizations and individuals. which tHat-.establishes that, as an overriding priority, nuclear safety and nuclear security issues receive the attention warranted by their significance.
+He Commission also considers nuclear safety and nuclear security issuos to be equally important in a positive safety culture. Further, it is important for a ll organ i zations liconsees and certificate holders to provide personnel in the safety and security sectors with an appreciation for the importance of each, emphasizing the need for integration and balance to achieve optimized protection.
Safety and security activities are closely intertwined, and it 5 im portant to-safety culture. In add ition, weaknesses in the safety culture of licens ee s and c ertif ic ate holders h ave cont r ibuted to unscheduled events or inc idents that the Commiss i on h as determined to be sign i ficant from the standpoint o f public health and safety. Examp les linked to ch aracter istics and attitudes in organ i zat ions a nd in dividuals asso ciat ed w i th weak safety cultures i nclude in adequate procedures
- procedures not be ing followed
inad e qu ate supervision; decision-making that does not ens ure that safety a nd security are maintained; and i neffect i ve prob l e m i dentification, eva lu ation. a n d reso l ution. They h ave included medical misadmin i stra tions (such as giving io dine-131 to lact a ting females that res ulted in the uptake by their inf ants and multiple events ass oc iated w ith pr os tate brachyt h erapy treatment) and overexposures arising from the loss of control of radiography or we ll logg ing sources , (2) Statement of Policy ills the CommiSSion
's policy that a strong safety culture is an essential element for individuals , both Internal 10 the NRC and external.
performing or overseeing regulated activities , As such , the NRC will include appropriate means to monitor safety culture in Its oversight programs and Internal management processes
{PBl Edit} T h e NRC'defines safety culture as that assembly of characteristics, attitudes, and behaviors in organizations and i n dividuals , which U:lat-estab lish es th at , as an overriding priority , nucl ear safety and nl::lclear security i ss ues receive the attent ion warranted by the i r significance.
+He Comm i ssion also con s i sers nuc l ear safety and nuclear security ;ssl:les to bo eql:lally im portant in a positiovo safety Gu ltu re. Further , it is import ant for all organizations licensoos and certif ic ate holders to provide personnel in the safety and security sectors with an apprec i at ion for the impo rtance of each , emphasiz in g Ihe need for integration and balance to achieve opt i mi z ed prolection. Safely and security act ivities are cl ose ly intertwined, and it is consideration adversely either safety or include nuclear safety and f"H:t':7I6(:tf activities including radiation protection, physical protection, and attention as a matter of priority.
The regulations are radiation from the use of responsibility includes regulation of be integrated so as not to diminish or A safety culture that accomplishes this would issues associated with NRC-regulated material accounting, issues among that receive to protect both public workers materials.
The 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 security; nuclear ,n,...,nonre issues. The Commission believes that, services to the use of safely responsibility to mat that nuclear safety priority, the attention warranted by certificate should foster a individuals who are overseeing or information safety and developing policy and providing direction on and certificate they therefore, each maintain a positive and nuclear security significance.
culture in activities.
use or provide responsibility for and culture, as an overriding and among as the is consideration adversely either safety or include nuclear safety and f"H:t':7I6(:tf activities including radiation protection, physical protection, and attention as a matter of priority.
The radiation regulations are from the use of responsibility includes regulation of 6 be integrated so as not to diminish or A safety culture that accomplishes this would issues associated with NRC-regulated material issues among to protect both materials.
The public nuclear power plants; accounting, that receive workers of 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; security; analyzing, and nuclear ,n,...,nonre issues. The Commission believes that, services to the use of safely responsibility to mat that nuclear safety priority, the attention warranted by certificate should foster a individuals who are overseeing or information safety and developing policy and providing direction on and certificate use or provide they responsibility for therefore, each and maintain a positive culture, and nuclear security as an overriding significance.
and culture in among activities.
as the 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 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' and when faced with a conflict with other organizational or individual goals, (3) 7 regulatory the ion has an independent oversight role (through inspection processes) including addressing I and certificate holder? " '" performance related to areas important to safety 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 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' and when faced with a conflict with other organizational or individual goals, 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 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 8 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 the of incorporating the safety a In general, emphasis on security is into a safety culture and effectively and security refers to the organizational and individual awareness that of safety of functions and must be together so that to and goals do not inadvertently compromise the other. Therefore, to emphasize the equal importance of nuclear security and nuclear safety in a positive safety 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 08-0001, "A Commission Policy Statement on Safety Culture," stated in part that the staff should, as part of its public stakeholder outreach, reach out to all types of licensees and certificate holders. In the development of the draft policy statement, the NRC staff sought insights and feedback from stakeholders.
This was accomplished by providing information in a variety of forums such as stakeholder organization meetings, newsletters, and teleconferences and by publishing questions in Federal Register Notices entitled "Safety Culture Policy Statement:
Public Meeting and Request for Public Comments" (74 FR 4260; January 23, 2009, and 74 FR 6433; February 9 , 2009) that were related to the Commission's SRM. In addition, a significant stakeholder outreach activity was accomplished by a public workshop held on February 3, 2009, at NRC Headquarters in Rockville, Maryland. The staff reviewed and considered the stakeholder feedback derived from these different forums and incorporated it into the development of the draft policy statement and recommendations.
(5) Safety and Security Culture In SRM-COMGJ8-08-0001, the Commission also considered whether publishing the NRC's expectations for safety and security culture is best accomplished in one safety/security 9 and goa l s do not inadvertently compromise the other. Therefore , to emphasize the equa l im portance of nuclear security and nuclear safety in a positive safety culture , the Commission has added " nuclear secur i ty" to the safety cu l ture defin iti on. The NRC's modified I N SAG definition is provided in the Statement of Policy section above. (4) Stakeholder Outreach The Commission's February 28 , 2009 , Staff Requ i rements Memorandum (SRM)-COMG6 J-08-0001. " A Commission Policy Statement on Safety Cu l ture ," slated in part that the staff should , as part of i ts pub li c stakeholder outreach , reach out to all Iypes of licensees and certificate ho l ders. In the development of the draft policy statement, the N RC staff sought insights and feedback from stakeholders. This was accomplished by providing information in a variety of forums such as stakeholder organ i z ation meetings, newsletters, and teleconferences and by pub li shing questions in Federal Register Notices entitled " Safe t y Culture Policy S t a t ement: Public Meeting and Request for Public Comments" (74 F R 4260; J anuary 23 , 2009 , and 74 FR 6433; February 9 , 2009) Ihat were related 10 Ihe Commission's SRM. In addition.
a significan t s t akeholder outreach activity was accomplished by a pub li c workshop held on F ebruary 3 , 2009 , at N RC Headquarters in R ockville, Maryland. The staff reviewed and cons i dered the stakeho l der feedback derived from these different forums and incorporated it into the development of the draft pol icy statement and recommendat i ons. (5) Safety and Security Culture I n SRM-COMGJ B-08-0001, the Commission a l so considered whelher publishing Ihe N R C's expectations for safety and security culture is best accomplished in one safety/s ecurity culture statement or in two separate statements , one each for safety and security, wh i le still considering the safety and security 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 weighed heavily toward a single policy statement to be titled a " Safety Culture Policy Statement." Document reviews and stakeholder feedback suggested that a single policy statement (1) bu i lds on the fact that safety and security have the same ultimate purpose of protecting people and the environment from unintended radiation exposure and (2) encourages attention to the ways safety and security interface. For these reasons , the Commission determmed that t+he term " safety culture" should Include both safety and security ee considered as all encompassing becauso thoro would be no need for security pertaining to tho use of radioactivo material if it 'Nere not for radioactive material used by licensees and certificato holdors. Safety and secur i ty have been the primary pillars of NRC's regulatory programs.
However , in the current he i ghtened threat environment , there has been a renewed focus on security, and the staff has imp l emented a number of efforts to enhance security and strengthen the safety and security i nterface.
It is i mportant to understand that both safety and security share a common purpose of protecting public health and safety. In today's environment , safety and security activities are ed, and it i s cr i tical tha t cons i deration of /' i these activities be integrated so as to omPl r men each other and not -Ie diminish or adversely impact either safety or security. urther, i t i s important for licensees and certificate ho l ders to provide personnel in the safety and security sectors w i th an appreciation for the importance of each , emphasizing the need for integration and balance to achieve optimized protection . The importance of both safety and security in an equal 10 cu l ture sta t ement or in two separate s t atements , one each for safe t y and security.
w h i le sti ll conside r ing t he safety and security in terface. B ased on a variety of sources inc l uding document reviews and stakeholder feedback, the Commission concluded there is no one defin i tive view o f this issue, but the resul t s weighed heavi l y toward a single pol i cy statement
\0 be titled a " Safety Culture Policy Statement." Document reviews and stakeholder feedback suggested that a s ingl e po li cy s t atement (1) bu i lds on the f act thaI safety and security h ave the same ultima t e purpose of protec t ing people and the environment from unintended radiation exposure and (2) encourages attention to the w ays safety and secur i ty i nterface.
For these reasons , the CommisSion determmed that I+he t erm "safety cul t ure" should Include both safety and secunty ge consid e red as all encomp a ss i ng becau s e th e ro w oul d be no n e ed fo r s e cu r ity p e rlaining t o t h e use o f radio a ctive mat e rial i f it 'N ere not for radioac t ive mat e rial u s ed b y licons eo s ana co rl ifica t o hold e rs. Safety and secur i ty have been the primary pillars of N R C's regulatory programs. However , in the current he i ghtened threat environment , there has been a renewed focus on security, and the staff has imp l emented a number of efforts to enhance security and strengthen the safety and security i nterface , It is important to understand that both safety and security share a common purpose of p r otecting public hea l th and safe l y , In today's env i ronment , safety and security activities are c l osell0fflelcw",e,ed , and it is cr i tical that cons i deration of these activ i ties be i ntegrated so as 10 ompi r men each olher and no t te d imi nis h or i. adversely i mpact either safe l y or security. urther, it i s Important for li censees and cert i ficate ho l ders to provide personnel i n t he safety and security sectors w i th an apprec i at i on for the importance of each , emphaSiz in g the need for int egration and ba l ance to achieve optim i zed protection The importance of both safety and security in an equa l 11 and balanced manner within NRC's regulatory framework is clearly evident in the Commission
's mission and strategic goals. While many safety and security activities complement each other or are synergistic, there remain areas where potential conflicts may arise differences. It is then imperative that mechanisms be established to resolve these potential conflicts to differences if we must assure the adequate protection of publ i c health and safety and promote the common defen s G e and security. Hence , safety and security have implications for each other i n connection with all aspects of nuclear activit i es . For example. the enhanced risk of a sabotago event has highlighted the importance of integrating safety and security in the field of protection and of identifying areas where they need to complement each other so that a terrorist event can be dealt with in as seamless a fashion as possible. One potential important difference or challenge is the way in which individuals involved in safety and security activities approach the goal of risk mitigation and protection of public health and safety. The safety staff is typically focused on preventing errors that would result in an inadvertent accident while the security staff is focused on preventing deliberate attacks or diversion of certain materials that could cause harm. /\nother differonco is tho way in which individuals involved in safety and security activities approach Information sharing. Tho safety staff promotes information sharing and collaboration while the security staff promotes the sensitivity of information and a need to know. These differencos as well as any others identified through stakeholder interactions would neod to be resolved and managed. Another challenge is that the organization
/facility must ensure that the existence of motivated and capable persons with ill intent is recognized and that the importance of nuclear security to prevent such persons from unauthorized access is understood.
11 and balanced m a nner wi th i n NRC's regu l atory framework is clear l y evident in the Commission's mission and strateg ic goals. Whi l e many safety and security act i vit i es comp l ement each other or are synergistic , ther e rem a i n areas where p otenti a l conflicts may arise differences. It is then impera t ive th at m e chan is ms be estab l ished to reso l ve these potential conflicts to E1itferencos if wo /flusl assure t he adequate protection of pub li c health a nd safety and p romo te th e common defen s c* and security. Hence , safety and sec urity h a v e implic atio n s for each other i n connection with all aspects of nucl ea r activ iti es. For oxamf310 , the enhancod risk of a sabotage ovent has highlighted tho importance of in tog rating safety and security in the f i eld of protection and of iden t ifying areas where they need to GempleFflont each o tho r 60 that a terror i st event can be doa l t wit h in as seamless a fash i on as poss i ble. O n e potential iFflportanl d i fference or challenge is t he way i n whic h i ndividu a ls invo l ved in safety and security act iviti es app ro ach the goa l of ris k mitigation and protection of pub li c health and safety. The safety slaft is typica lly focu sed on preventing e r rors t ha t would r es ult in a n in advertent acc i dent while t he security slaH i s focused on preventing d e li berate attacks or div e rsion of certa i n mater i als that cou l d c ause harm. Anothor differe n ce is the way in wh ich indl>"iduals in volved in safoty and secur i ty act i vities approach inform atio n sharing. The safety staff promotes i nformation sharing a nd collabora t i on wh il e the stall promotes the sensit i vity of i nformation and a noed to know. These d i fferences as we ll as a n y others identified through stakeholder i nteract i ons wou l d noed to be rosol'.'od and managed. Another ch a llenge is that the organization/f ac ility mus t ensure that the ex is te nc e of mo tivated and capab l e pers ons with in i nt e n t is r ec ogn i zed and that th e im porta n ce of nucl ear secur i ty to p rev e nt such persons from unauthorized access i s und ers tood.
X '-AGee for SA sensitivity to the COil el it i s exacerbated by ..eigAificMt growth in Ruelee, utilization To manage these potential conflicts or challenges , the Agency has recently issued regu l ations on the safety/security Interface An overarchlng safety culture policy statement which encompasses security supports and further enhances those regulations. Based on the above considerations , the Commission concluded that a single policy statement would accomplish its goal that, as an overriding priority, safety issues and security issues receive the attention warranted by their significance. Although, in some cases , issues relating to security might be handled differently than issues related to safety. A single policy statement recognizes there is one overarching culture in an organization
- however, safety and security functions and goals must be treated equally within that overarching safety culture. (6) Characteristics of a Positive Safety Culture Experience has shown that certain organizational attributes and personnel attitudes and behaviors are present in a positive safety culture. Therefore , in 2006, when the NRC implemented an enhanced reactor oversight process (RaP) that more fully addressed safety culture, it identified and incorporated safety culture components that are overarching characteristics of a positive safety 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 Operations; the IAEA; the Nuclear Energy Agency; the regulatory approaches of other domestic and international organizations
- and the organizational behavior , safety culture , and safety cl i mate research literature. The Commission presented 12 --!
- :ioee for Bt=! iml'fUVed sens l tlvliy to tile C Oife"! tto.reat1friwonmen!
i s exacerbated b) lA C-X -eigl"lifi c t!lr'lt §f9Wth in Rudest utili z a t ion voo l is w id..e.. To manage these potential conflicts or challenges, the Agency has recently Issued regulations on the safety/security Interface An overarchlng safety culture policy statement whIch encompasses security supports and further enhances those regulations Based on the above considerat i ons , the Commiss i on concluded that a single po l icy statement would acco mp lish its goa l that , as an overr i ding priority.
safety issues and secur i ty issues receive the atlention warranted by their significance.
Although, i n some cases, i ssues relating to security might be handled differently than i ssues related to safety. A single policy statement recogn i zes there i s one overarching culture in an organiza t ion; however. safety and security fUnctions and goals must be treated equally within that overarch in g safety culture. (6) Chara c teri s ti cs of a P os itiv e Saf e ty Culture Experience has shown that certain organizational attributes and personne l atti tud es and behaviors are present in a posit i ve safety culture. Therefore.
i n 2006. when the NRC i mplemented an enhanced reactor oversight process (ROP) that more fully addressed safety cu l t ure, i t identified and incorpo rated safety culture components that are overarching character i stics of a positive safety culture, The NRC based its development of the safety culture components on a rev i ew of a var i ety of sources of i nformation including the Institute of N uclear Power Operat i ons; the IAEA; the Nuclear Energy Age ncy; the regulatory approaches of other domestic and international organ i zations: and the organizational behaV i or , safety culture, and safety climate research lit e rature. The Commission presented d r afts of the safety culture components and aspects in frequent public meetings and modified them in response to stakeholder feedback.
For the purpose of this policy statement, the NRC modified the ROP safety culture components (termed "safety culture characteristics")
to explicitly address security in the safety culture characteristics descriptions, create a more generic description for each safety 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 ( http://www . nrc. gov/about-nrc/r eg ula tory/e nforcementlsafety-cultu r e. h 1m I). Although the safety culture characteristics themselves are applicable to all licensees and certificate holders , there may be other examples that more specifically address the unique characteristics of a licensee's or certificate holder's environment (i.e., unique for medical and industrial applications , operating reactors, research and test reactors, fuel cycle facilities , and new reactor construction environments). Hence, the Commission recognizes that these safety culture characteristics are not all inclusive; other characteristics and attitudes in organizations and individuals may be indicative of a positive safety culture. However, the Commission expects i ts licensees and certificate holders to consider the extent to which these characteristics and attitudes are present in their organizations and among individuals who are overseeing or performing regulated activities and to take steps, if necessary, to foster a positive safety culture commensurate with the safety and security significance of activities and the nature and complexity of the licensee's or certificate holder's organization and functions. 13 drafts of the safety culture componen t s and aspects in frequent public meetings and mod i fied them in response 10 stakeholder feedback. For the purpose of this po li cy statement. the N R C modified the ROP safety culture components
{termed " safely culture characterist i cs"} to explicitly address security in the safety culture characteristics descriptions , create a more generic description for each safely culture characteristic that would apply to the range of N R C li censees 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 F ebruary 3 , 2009. public workshop and on the N R C's public safety culture Web site (http://www.nrc.gov/a bout-nrc/regulatory
/enforcemenVsafe t y-culture.h l ml). Although the safety culture characteristics themselves are applicable to all licensees and certificate holders, there may be other examples that more specifically address the unique characteristics of a licensee's or certificate holder's environment (i.e., unique for medical and industrial app li cations , operating reactors , research and test reactors, fuel cycle facilities , and new reactor construction environments).
Hence, the Comm i ssion recognizes that these safety culture characteristics are not ali 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 consider the exlentto which these characteristics and attitudes are present in their organizations and among individuals who are overseeing or performing regulated activities and to take steps, i f necessary , to foster a positive safety cu l ture commensurate with the safety and security significance of activities and the nature and complexity of Ihe l icensee's or certificate ho l der's organization and functions.
The following characteristics that are indicative of a positive safety culture , are relevant across the broad range of licensees' and certificate holders' activities carried out by the nuclear i ndustry , 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 day-to-day work activities by , for example , ensuring that their 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 assumptions , especially when faced with uncertain or unexpected conditions, to ensure that safety and security are ma i ntained. Processes for planning and controlling work ensure that individual 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, managers and supervisors are accessible to oversee work activities , including those of contractors or vendors , and they challenge work activities and work products that do not meet their standards. The organization licensee or certificate 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, intimidation, retaliation, and discrimination are investigated consistent with the regulations regarding employee protection. If an instance of harassment, intimidation , retaliation, or discrimination for 14 The following characteristics that are indicative of a positive safety culture , are relevant across the broad range of licensoes' SAg certificate holders' activities eamed out by the nuclear Ind ustry, the Agreement States and the NRC , and address the importance of nuclear safety and security:
- Personne l demonstrate ownership for nuclear safety and security in the ir day-la-day work activities by. for example, ensuring that the i r day-la-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 the i r assumptions , especially when faced with uncertain or unexpected cond i tions, to ensure that safety and security are m a intained.
- Processes for plann i ng and controlling work ensure that individual contributors, supervisors, and work groups communicate , coordinate , a nd execute thei r 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 interac t with those of others to adversely affect safety or security.
I n addition , managers and supervisors are accessible to oversee work act ivities, includ ing those of contractors or vendors , and they challenge work activities and work products that do not meet their standards.
- The organization lic enseo or cortificate Roh30r 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 , intim i dation, retaliation, and discrimination are investigated consistent with the regulations regarding employee protection. I f an instance of harassment , intimidation , retaliation , or discrimination for raising a safety or security concern is identified, corrective actions are taken in a timely manner.
- The organization licensee or certificate holder ensures that issues potentially impacting safety or security are promptly identified, fully evaluated, and promptly addressed and corrected, commensurate with their significance.
- The organ i zat i on licensee or certificate holder ensures that the personnel, equipment, tools, procedures , and other resources needed to assure safety and security are available.
For example , training is developed and implemented or accessed to ensure personnel competence.
Procedures, work instructions, design documentation, drawings, databases, and other job aids and reference materials are complete , accurate, and to-date.
- The organization
's licensee or certificate holder decisions ensure that safety and security are maintained.
For example, production , cost, and schedule goals are developed, communicated, and implemented in a manner which demonstrates that safety and security are overriding priorities.
- 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.
Programs, processes, procedures, and organizational interfaces are clearly defined and implemented as designed.
Leaders at all levels of the organization consistently demonstrate that safety and security are overriding priorities.
15 raising a safety or security concern is identified, correct i ve actions are taken in a timely manner.
- The organ i zation licensoe or certificate holder ensures that issues potentially impacting safety or security are promptly identified, fully evaluated , and prompt ly addressed and corrected , commensurate w ith their significance.
- T he organ i zatIon licensee or cortificate holder ensures that the personnel , equipment, tools , procedures.
and oth er resources needed to assure safety and security are available. For example , training is developed and impl emented or accessed to ensure personnel competence. Procedures , work instructions , design documentation, drawings , databases, and other job a ids and reference materials are complete.
accurate , and up* to*date.
- The organIzation
's licensee or certificate holdor dec isions ensure that safety and security are maintained. F or example , production , cost , and schedule goals are developed , communicated , and i mplemented in a manner which demonstrates that safely and security are overrid i ng priorities.
- R ol es , respons i bilities, and authorities for safety and security are cl early defined and reinforced.
For example, personnel understand their roles and responsibilities i n maintaining safety and security. Progra ms, processes , procedures, and organizational i nterfaces are clearly defined and implemented as designed. L eaders at all leve ls of the organization consistently demonstrate that safety and security are overriding pr ioriti es.
The organization licensee or certificate holder maintains a continuous learning environment in which opportunities to improve safety and security are sought out and implemented.
For example. individuals are encouraged to develop and maintain current their professional and technical knowledge. skills. and abilities and to remain knowledgeable of industry standards and innovative practices. Personnel seek out and implement opportunities to improve safety and security performance. Implementation of Policy This policy statement descnbes areas important to safety culture. but it does not address how the nuclear Industry the Agreement state t)nd the NRC licensee or certificate holder should establish and maintain a positive safety culture in ito theIr organization s Licensees , and certificate holders The nuclear industry , the Agreement the NRC differ in X their size and complexity.
infrastructure, and organizational frameworks.
Therefore.
a single approach for establishing and maintaining a positive safety culture is not possible.
Nevertheless , the Commission expects that nuclear safety and security issues receive the attention warranted by their significance.
and all organizatIons licensee or certificate holder consider and foster the safety culture character i stics (commensurate with the safety and security significance of activities and the nature and complexity of the i r organization and functions) in carrying out their day-to-day work activities and decisions. QUESTIONS FOR WHICH NRC IS SEEKING INPUT: The draft policy statement provides a descr i ption of areas important to safety culture. (i.e., safety culture character i stics). Are there any character i stics relevant to a particular 16
- The organization licensoe or certificalo holder mainta i ns a cont i nuous learn i ng env i ronment i n wh ich opportun i t i es to i mprove safety and security are sought out and i mp l eme n ted. For example. i ndividua l s are encouraged t o deve l op and mainta i n curren! the i r profess i onal and technical know l edge. ski ll s , a n d abi li ti es and to rema i n knowledgeable of in dustry standards and i nnovat i ve practices.
Personnel seek ou t and im ple m ent opportun i t i es to i mprove safety and secur i t y performance. (7) Impl e ment a tion of Poli c y Th is policy statement describes areas i mportant to safety culture , but i t does not address how the nuclear Industry. the Agreement Slate&nd the NRC liconsee or certif i cate hold or should establis h and ma in ta in a pos iti ve s afety culture in i46 t heIr organization
- s. licensees , and certlfiGale holder6 The nuclear Industry , the Agreement the NRC differ i n )c their s i ze and complexity , in frastructure, and organ i zational frameworks. There fore , a s in gle approach for estab li sh i ng and maint a ining a positive safety cu l ture is not possible. Nevert h e less , the Comm i ssion expects that nuclear safety and security issues receive the attent io n warranted by their significance , and a l l orgamzatlons licensee er certifica t e ho ld er consider a nd f ost e r t he safety cu l t ure ch a r acter is t ics (commensu rate w i t h the safety and security signif ic ance of act i vi t ies a n d t he nature and complexity of the i r organi za tion and functions) i n car r ying out the i r day-to-day work activ i ties and decisio n s. QUESTIONS FOR WHICH NRC IS SEEKING INPUT: (1) The draft policy statement prov i des a descr i pt i on of areas i mport a nl to safety culture , (i.e., safety cu l t u re character i st i cs). Are there any charac ter i stics relevant to a part i cu l ar 17 of or holder (if so, please specify which type) that do not appear to be addressed? 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? 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? 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 security receive the attention warranted by their significance." Does this definition need further clarification to useful? 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? 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?
17 of or holder (if so, please specify which type) that do not appear to be addressed?
(2) Are there safety culture believe do not contribute to as r1<:>c:rrll')Qr1 in draft policy statement that you 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 behaviors in organizations and is that assembly of individuals, which as an overriding priority, nuclear and 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?
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
_____, 2009. Dated at Rockville, Maryland, 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, holders? for all NRC Agreement and 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.
Dated at Rockville, Maryland, For the Nuclear Regulatory Commission.
Cynthia A. Carpenter, Director Office of Enforcement
_____ , 2009.