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“SAFETY CULTURE BEGINS WITH SAFETY”

Daily newsbrief journal for February 2012, also see http://www.usdemocrats.com/brief for a global 100-page perpetual brief and follow twitter @usdemocrats


“SAFETY CULTURE BEGINS WITH SAFETY”

Postby admin » Wed Feb 29, 2012 7:39 pm

“SAFETY CULTURE BEGINS WITH SAFETY”Prepared Remarks for The Honorable Gregory B. JaczkoChairmanU.S. Regulatory Commissionat theNational Association of Employee Concerns ProfessionalsFebruary 29, 2012Good morning. I am pleased once again to have a chance to speak to this group ofdedicated professionals whose work helps promote safety conscious work environments at ournation’s nuclear power plants and other facilities that use nuclear materials. The existence of ahealthy work environment, in which employees are free to raise safety concerns, is a vital underpinning of the NRC’s regulatory oversight. As you know, the NRC can’t be everywhere. Our independent inspection efforts rely on sampling a small percentage of the work activities performed by our licensees. We need to knowthat employees are doing the right things when we are not looking over their shoulder. And we need to know that if their co-workers are not doing the right thing, that they feel free to raise those concerns to their management without fear of reprisal. Your work to establish and maintain an open and collaborative work environment directly supports our mission of protectingpublic health and safety. Shortly after I came to the NRC, we received the results of our agency’s 2005 internalsafety culture and climate survey. One of the findings in that report that caught my attention wasthat, despite a clear focus on safety from the NRC employees, some of our staff felt that schedule pressures contradicted their job of raising safety issues. As compared to the survey three yearsprior, more employees in certain work groups felt they sacrificed the quality of their work in order to meet budget constraints. As Chairman, I have always been sensitive to that concern and tried to do whatever I could to shield staff from those pressures.Nonetheless, it is no secret there have been questions raised about the safety culture at theNRC in the last few months. But let’s keep in mind, safety culture begins with safety and there have been no concerns that the employees at the NRC are reluctant to raise safety issues. In fact,NRC NEWSU.S. NUCLEAR REGULATORY COMMISSIONOffice of Public AffairsTelephone: 301/415-8200Washington, D.C. 20555-0001E-mail: opa.resource@nrc.gov Site: www.nrc.govBlog: http://public-blog.nrc-gateway.govNo. S-12-004
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2the evidence is quite to the contrary. The most recent results of the 2009 internal safety cultureand climate survey, have shown substantially improving trends regarding the willingness ofemployees to speak up at the NRC, or to raise concerns via one of the many avenues we have available, such as the Differing Professional Opinions program or the non-concurrence program.Even more recently, the 2011 Federal Employee Viewpoint Survey performed by theOffice of Personnel Management and the Partnership for Public Service, rated the agency one ofthe best places to work in the federal government, including ranking the NRC number one in allfour major survey categories, including leadership and knowledge management, results-oriented performance culture, talent management, and job satisfaction.That said, I am well aware of the effects that the December Congressional hearings might have had on the staff at the NRC, and I continue to take steps to ensure the staff is able to remainfocused on their safety mission. I am a very focused person – especially when it comes to thingsthat are important to me, as well as to the agency as a whole, like our safety mission. I have metwith the senior managers of the agency and let them know how critically importantcommunication is – and that the communication has to be two-way. If someone interprets myfocus on an issue as anything other than that, I would need to know that in order to be able to address it immediately. I believe strongly in openness. Shortly after becoming a Commissioner, Iblocked out a weekly timeslot on my calendar for employees to come to my office and discuss any matter with me. I always enjoy those exchanges, even with those who disagree with me or when the topics stray quite a bit from safety issues. I would also add that the Commission has consistently continued to focus on its job and has done so quite successfully. We continue to hold Commission meetings, meet one-on-one with each other, and vote on the many policy matters that come before us. I have great respectfor the experience and expertise of my colleagues, and I am committed to working effectivelywith them to continue fulfilling our critical safety and security mission. We can disagree and we do, and I certainly don’t have to tell the folks in this room that there is nothing wrong with differing views! I look forward to continue working with my colleagues on the many important policy matters we have before us in the months ahead. But despite the agency’s continued success with safety culture anecdotally and asevidenced by survey results, as with everything this agency does, our culture just doesn’t allowus to sit back and assume our job is done. Instead we strive for continuous improvement. Withthat in mind, we’ve dissected the studies and attempted to identify ways we could do even better. I look forward to the results of the next safety culture survey, scheduled to be conducted this fall. As always, the agency will look closely at these results and propose initiatives to makeimprovements as necessary. I am pleased to have the opportunity today to talk a bit about the programs we haveavailable internal to the NRC to voice a concern, as well as to reemphasize the importance of a positive safety culture in the nuclear industry. In recent years, the agency has undertaken newinitiatives to strengthen the safety culture within our staff. I am a strong supporter of ourdiffering professional opinion and non-concurrence programs. These programs offer employees
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3clearly defined, alternative processes to raise concerns. At the same time, we must ensure that employees feel free to use ordinary management channels to raise concerns. To do this, we must maintain a work environment that encourages open communication, trust and respect. To further the goal of strengthening the NRC’s safety culture, in 2009 the agency had aninternal task force assess our safety culture and make recommendations for improvement. The task force proposed recommendations to further strengthen our safety culture by establishingan agency-wide framework to express our expectations and effectively communicate them toreinforce our safety-first focus. Some of the results of these efforts can be viewed on the NRCpublic website under the title of OCWE, or Open Collaborative Work Environment. This webpage provides a list of the range of avenues available for an employee to raise a concern orsuggestion, including the DPO process, the nonconcurrence process, and the formal Open Doorpolicy. Across the agency, there are more than two dozen different programs at the agency oroffice levels to address an employee’s concerns, questions or suggestions. Several of these programs have counselors, stewards, or champions to advocate for the programs or act as subjectmatter experts for employees. The staff is working diligently to better advertise internally all of the available avenues tocommunicate and resolve questions, concerns, and suggestions in a consolidated format goingforward. The agency is also doing evaluations in this area to identify gaps in these programs aswell as the agency’s overall approach in this area, and is currently making enhancements to several of these programs. We are eager to fill in any potential gaps, should that be necessary. Fortunately, the triennial safety culture and climate surveys have shown steady improvement since 2002 in staff knowledge of the many programs as well as their comfort and willingness toraise issues to their supervisor and to management. We must continue that progress goingforward. As you know, one key to the success of these programs is for employees to feel respectedand appreciated for bringing forth issues, versus feeling like an “outcast.” To that end, theagency created a Team Player Award in 2008. This award is designed to recognize and showappreciation for individuals who have supported an Open Collaborative Work Environment byexhibiting team player behaviors identified on our “Be a NRC Team Player” poster. Thisincludes promptly raising differing views, fairly considering differing views, and respectingdiffering views. Any employee can nominate another employee or group to recognize and value the power of considering varied approaches during the decision-making process.I encourage you to visit the NRC public website and view our prior award winners, aswell as read their individual “catches” and success stories. Our staff has struggled with makingthe “tough calls” on a number of occasions. While some of these become high-profile cases,most of the examples on our website show those cases that are resolved promptly and lessformally.One interesting example is that of an employee who was involved in the creation of theNRC’s Safety Culture Policy Statement and who actually refused to concur in its originalwording. The agency’s Non-Concurrence Process allows an individual to formally indicatedisagreement with a document in the concurrence process that he/she had a role in creating or
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4reviewing. The NRC team eventually resolved this matter in a way that positively changed thewording of the policy statement with regard to the nine inherent traits of a positive safety culture. We have extremely dedicated and talented staff at the NRC who work every day to make these programs and our agency stronger, and we all benefit from their hard work. I believe the clearest evidence of their success are the real-life examples where staff at the NRC has done the right thing for safety regardless of the schedule or other pressures to do otherwise.A prime example is the resolution of the structural issues with the Westinghouse AP1000 shield building design, which included a personal meeting between me and the engineer whofiled a differing professional opinion in this matter. While the resolution of this complex matterobviously took time to resolve, it ensured the safety of the final design prior to construction. Italso reiterated to the industry and the staff that the NRC will do what it takes to ensure safetyover cost and schedule pressures. Another example of where the staff did the right thing was in the Spring of 2010encouraging Davis-Besse to commit to replacing its reactor vessel head with a newly fabricatedhead at a mid-cycle outage due to premature deterioration on the one acquired from the cancelledMidland station following the 2002 event. The staff dispatched a team of specialist inspectors toclosely scrutinize FENOC’s analysis of the head inspections and repairs, given the extent of theproblems noted after such a short period of service. The technical uncertainties in this matterwarranted a cautious safety approach, and the staff did not hesitate to proceed in that manner. Another clear example was the response to the nuclear accident at Fukushima Daiichi last March. This tragedy was clearly one of the most significant events in the history of nuclearpower, and it required the NRC to take prompt, decisive, and effective action to make needed safety changes. The agency’s Near-Term Task Force was directed to review the insights gained from the Fukushima accident and make recommendations to the Commission for enhancingreactor safety. Within 90 days, the Task Force reported back to the Commission with acomprehensive set of 12 safety recommendations that they believe are needed to strengthennuclear safety. Their report included a bold recommendation to reexamine our existingregulatory framework for ensuring adequate protection that appropriately balances defense-in-depth and risk considerations. They certainly knew at the time that there would be push-back on some of theirrecommendations, but they did the right thing in making the recommendations that they believed were important and necessary, and they did not hesitate to take a strong stance for safety.Up to this point, I have only focused on safety culture internal to the NRC. Let me nowsay a few words about the industry and the importance of safety culture overall. Organizationsthat lose that safety focus may very well profit in the short-term, but tend to pay dearly for it in the long-term. The concerns and allegations you receive, and the results of the investigations you conduct, are a good barometer of the safety culture within your organization. I know howimportant your job is, and how critical is it for you to help keep our licensees’ “eyes on the ball.”
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5My sense is the number of allegations the NRC receives from the licensee have historically shown some correlation to both the safety culture within the organization as well asthe performance of the licensee. For the benefit of your Employee Concerns Programs, as well asto aid in achieving the agency’s safety mission, the NRC publishes the number of allegationsreceived at each facility, and we have done that for many years. We also identify facilities that are statistical outliers from the rest of the industry to determine if the number of allegations is anindication of a chilled work environment. We urge you to mine that data for insights into yourprogram. Large numbers of concerns processed by your ECP in relation to the number of allegations received by the NRC suggests confidence and trust in your program. The reverse maysuggest that either your program is not well known, or that employee confidence and trust in theprogram could be lacking. With the examples I mentioned previously of how the NRC continues to put safety first, I believe it is entirely appropriate for us to push for the same from our licensees. And that is whythe first time I spoke with you, in 2007, I discussed the need for the agency to develop acomprehensive policy statement on safety culture. I believed it was an appropriate time to complement related policy statements in 1989 and 1996, and to provide a broad statement for allNRC licensees, not just reactors, on the Commission’s expectations for a healthy safety and security culture. This policy statement was carefully crafted by the staff and put out for crucialinput from the public and reactor licensees. The Commission finalized that Policy Statement inJanuary of this year and by all indications it has been a huge success. Since 2007, the NRC staff has also been evaluating safety culture in our ReactorOversight Process. The Oversight Process was modified to provide a transparent, objective, and predictable measure of safety culture. Essential safety culture components were identified basedon an assessment of the characteristics of a positive safety culture. These components are subjectto NRC inspections which can identify potential weaknesses. Safety culture assessments are tools used to determine the state of the existing safety culture and to assess whether corrective actions have resulted in demonstrative improvements. With the combination of the Safety Culture Policy Statement and the focus on evaluatingthe safety conscious work environment at reactor licensees via the Reactor Oversight Process, we hope that we have increased attention on this important area. We have seen an increasing numberof licensees conducting periodic safety culture self-assessments, independent of our regulatoryoversight. Additionally, we are gaining valuable information about safety culture at nuclearfacilities as we apply the oversight process. We are able to use that information to continuouslyrefine and improve our safety culture efforts going forward, and use that information as we dealwith those licensees that are currently struggling in this area.For materials licensees, improvements to the fuel cycle oversight process currently beingworked on by our agency will be informed by the Safety Culture Policy Statement. The activitiesperformed at materials licensee facilities benefit from a strong safety culture just like nuclearpower plants do. Many of these licensees, such as radiographers, are very small operations where the culture is set by one or two people. They often work with small, intense radioactive sourcesin areas that are open or not under the rigid controls in a nuclear station. Hence these licenseestend to be the source of greatest overexposures we deal with.
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6I hope that you will agree that whether we are discussing nuclear power plants ormaterials licensees, safety culture at the NRC or safety culture in the industry, the beginning and the end of all of our efforts must be safety. I appreciate the efforts of every one of you at this forum to support and strengthen a safety conscious work environment. In doing this work, I think the future will even be more interesting as we all move forward in what is an evolving field. Above and beyond our day-to-day work to build and maintain a strong safety culture, we need to remember that we are allworking for the same ultimate goal – nuclear safety and security. Thank you for inviting me to share my thoughts with you today, and I’ll be happy to answer any questions you may have.
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