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How NRC deals with "safety culture"
>From the Davis-Bessie list:
"collidm " wrote:
> The most critical nuclear plant safety system is also the most poorly
> maintained.
>
> All of the safety systems at all of the nuclear plant in the world
> are all designed around the same thing: preventing core damage. The
> metric to assess the likelyhood of core damage is called "core melt
> frequency". The engineering discipline of PRA, or probabilistic risk
> assessment, evaluates every plant safety system CMF to ensure it is
> adequately designed. Every safety system, except for one: the
> organizational behavior system known as safety culture.
>
> Why? One reason is the industry is managed and operated by engineers,
> not psychologists. The safety systems that engineer relate are of the
> electro-mechanical variety. Emergency power systems. Auxiliary
> feedwater systems. Automatic reactor shutdown systems. In the
> engineering world these are sacred systems, treated with very special
> care. So vital to safety that they are in fact referred to as
> the "vital systems". Plant managers sometimes hand out little plastic
> cards to all the engineers that list these vital systems. The cards
> have colorful pie charts and bar graphs that rank the systems
> according to core melt frequency, their relative "vitalness" so
> engineers remain vigilant of just how important proper operation of
> these systems is to safety.
>
> Problem is, the system most vital to safety does not even appear on
> the cards.
>
> Davis Besse is only the most recent nuclear event in the US industry,
> it is not the first, it is not the most serious, and it is certainly
> not the last. If you look at the majority of the twenty most serious
> nuclear plant events in the US Nuclear Power Industry since 1974,
> they were not caused by improper maintenance of vital systems. The
> most frequently identified cause had nothing to do with the
> maintenance of any electro-mechanical systems. Yet electro-mechanical
> systems are the in toto focus of both the NRC and plant management.
>
> The most frequently identified cause was personnel not having an
> appreciation of the risks associated with their actions, or not
> exhibiting or encouraging a sufficient questioning attitude toward
> these risks. This condition was a factor in 14 of the 20 events (70%)
> and frequently resulted in a non-conservative approach toward reactor
> safety.
>
> In other words, the plant not having an adequate safety culture. So
> how important is the management of safety culture?
>
> If you were to ask senior plant managers they would tell you that
> nothing is more important than maintaining a healthy safety culture.
> If you were to ask the NRC commissioners, they would tell you the
> same. However, if you were to ask a number of senior plant managers
> to define a safety culture for you, you would get as many different
> answers. And if you were to ask a number of NRC senior officials, you
> would get the same.
>
> To manage something properly, you have to be able to measure it. To
> measure something properly, you have to be able to define it. The NRC
> points to the fundamental problem of measuring safety culture as
> being that the concept of safety culture has never been crisply
> defined. In the words of Dr. Richard Meserve, the Chairman of the NRC
> Commission, in a November 8, 2002 speech to the Institute of Nuclear
> Power Operations CEO Conference in Atlanta Georgia:
>
> "Let me start the examination of this question by exploring the
> reasons for the Commission's past decision to forego the direct
> regulation of safety culture. This reluctance stems from actions
> arising before my arrival at the Commission, but seems to derive from
> several related considerations.
>
> First, there is the concern that any attempt to regulate and evaluate
> safety culture is necessarily very subjective. The concept of safety
> culture has core ingredients on which perhaps all can agree, but the
> precise limits of this somewhat amorphous concept are hard to
> discern. Moreover, given that the concept is not crisply defined, it
> is not surprising that neither the NRC nor other organizations have
> found an unambiguous way to measure it. the driving forces for the
> development of the Reactor Oversight Process was the desire to
> provide a more objective and transparent method of performance
> assessment that could be applied equitably and uniformly over the
> entire industry. The inclusion of safety culture as a direct element
> of regulation and inspection is inconsistent with this objective to
> the extent that safety culture does not lend itself to objective
> measurement."
>
> Is Meserve's statement true? That safety culture is an amorphous and
> undefinable concept? Let me ask you a simple question - how many
> undefinable concepts do you know?
>
> In reality, it is of course not true that safety culture is an
> undefinable concept. Something entirely different is going on. The
> current chair of the NRC Advisory Committee on Reactor Safeguards,
> Dr. George Apostalakis of MIT, says what we need to start measuring
> for safety culture is attitude. Sounds perfectly reasonable to me.
> The NRC ACRS knows how to approach the problem, so what is stopping
> the NRC? What is really going on?
>
> What has been going on is this. Every time the NRC ACRS research gets
> close to developing an appropriate method to define, measure, and
> manage culture, the NRC Commission cuts research funding. Why?
> Because the Commission is not interested in getting into a major
> protracted battle with the powerful industry group NEI - the Nuclear
> Energy Institute. The NEI for years have been lobbying strongly
> against anything that even sounds like the NRC is preparing to be
> prescriptive on safety culture. So the result is that we don't
> regulate or manage safety culture in this country. The NRC is afraid
> to even study it. Of course, what is really happening is, the NRC is
> not doing it's job.
>
> Someone whom I know extremely well is one of the leading
> psychologists in the US and in the world. This person is the director
> of a psychometric methodology center at an Ivy League school, and
> someone who obviously knows a little about methods for measuring
> human behavior. This person tells me if attitude is something that
> can't be measured, then about 4 billion dollars worth of solid
> behavioral research performed every year in this country is invalid.
>
> Of course safety culture can be crisply defined. Of course safety
> culture can be objectively measured. Of course the organizational
> behavior system known as "safety culture" can be appropriately
> managed.
>
> The sad truth is, the NRC is avoiding doing it's job in this area,
> and has been avoiding doing it's job for a very, very long time.
>
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>
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