Nuclear, Reactors

An Approach for Plants to Address INPO’s Nuclear Safety Culture Expectations

Issue 5 and Volume 112.

By Teresa Hansen, Senior Editor

The Institute of Nuclear Power Operations (INPO) is a well-respected guiding influence in the nuclear power industry. It was created by nuclear power plant owners to be a self-policing authority aimed at achieving excellence in reactor safety and performance. All operating nuclear power plants strive to receive the coveted INPO “Excellent” rating on their evaluations; therefore, when the organization released the Principles for a Strong Nuclear Safety Culture in late 2004, nuclear power plant owners took notice.

The Utilities Services Alliance Inc. (USA) responded to the INPO document and focused on ensuring its member plants operate in what it calls a “Strong Nuclear Safety Culture.” USA developed the Nuclear Safety Culture Assessment (NSCA) process tool. The tool’s purpose is to evaluate an organization’s overall safety culture and provide an early warning of areas where that culture could be beginning to erode. The tool is a formal mechanism that judges plant personnel’s behaviors to ensure they maintain the appropriate focus on nuclear safety.

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USA is a “fleet” of individual nuclear power sites owned by different corporations that have joined together primarily to reduce operating and maintenance costs, help one another improve performance and provide industry leadership where appropriate. USA members are: American Electric Power’s Cook Nuclear Plant (Michigan); Ameren’s Callaway Station (Missouri), Arizona Public Service’s Palo Verde Station (Arizona), Detroit Edison’s Fermi 2 Nuclear Plant (Michigan); Energy Northwest’s Columbia Generation Station (Washington State); Luminant’s Comanche Peak Nuclear Plant (Texas); Nebraska Public Power District’s Cooper Nuclear Station (Nebraska); Omaha Public Power District’s Fort Calhoun Station (Nebraska); Pacific Gas & Electric’s Diablo Canyon Station (California); PPL’s Susquehanna Nuclear Plant (Pennsylvania); PSEG Nuclear’s Salem and Hope Creek Stations (New Jersey); Southern California Edison’s San Onofre Nuclear Generating Station (California); STP Nuclear Operating Co.’s South Texas Project (Texas); and Wolf Creek Nuclear Operating Co.’s Wolf Creek Generating Station (Kansas).

INPO’s Guiding Principles

Problems related to nuclear safety culture have been primary contributors to plant level operational problems and in some cases have resulted in extended shutdowns. When a deep corrosion-caused hole was discovered in the reactor vessel head at First Energy’s Davis Besse plant in Ohio, INPO took notice. Davis Besse was rated as an “Excellent” or “Good” facility for years and was highly regarded by the Nuclear Regulatory Commission (NRC). It had been regularly audited both internally and externally by INPO and the NRC, yet the plant still had a near-catastrophic safety system failure. This incident illustrated that more than plant operation, maintenance and engineering processes and performance need to be evaluated to ensure an adequate safety culture. Even though the corrosion did not result in an accident at the plant, Davis Bessie was shut down for almost two years for repairs and additional inspections. The discovery also led to a nationwide review of all similar plants to ensure similar conditions were not present.

The NRC and INPO conducted many studies and reviews pertaining to the Davis Bessie discovery and the plant’s operations and safety culture. The discovery prompted INPO to issue Significant Operating Experience Report (SOER) 02-4 Revision 1, “Reactor Pressure Vessel Head Degradation at Davis-Besse Nuclear Power Station,” and ultimately mandate its Principles for a Strong Nuclear Safety Culture.

“INPO developed an expectation that plants assess their nuclear safety culture to make sure production priorities weren’t overriding safety cultures,” said Willis Frick, Nuclear Safety Concerns Program Manager at San Onofre Nuclear Generating Station and USA’s NSCA Program Manager.

INPO defines safety culture as “an organization’s values and behaviors–modeled by its leaders and internalized by its members–that serve to make nuclear safety the overriding priority.” Its Principles for a Strong Nuclear Safety Culture describes “the essential attributes of a healthy nuclear safety culture, with the goal of creating a framework for open discussion and continuing evolution of safety culture throughout the commercial nuclear electric generating industry.” The principles and associated attributes have a strong basis in plant events.

USA’s Assessment Program

In response to INPO’s SOER 02-4 Revision 1, USA member plants collaborated to develop the USA NSCA. They formed a team to develop the self-assessment program. The team developed Phase I of the NSCA based on studies of the INPO documents related to Davis Bessie along with other INPO documents including SOER 02-4, as well as NRC issuances. The team determined that a true safety culture assessment must be more than just audits and inspections aimed at determining if processes and programs are in place and are being followed; it must look at the staff’s attitude. Therefore, USA’s safety assessment process looks for opinions, perceptions, thoughts and feelings. The process evaluates the health of each member plant’s safety culture, identifies strengths and weaknesses and provides recommendations to plant management to improve or sustain this health.

The development tool for USA NSCA Phase I is a self-assessment of the member plants’ safety culture. It includes approximately 90 discrete behavioral attributes that should be present in a culture that has an appropriate focus on nuclear safety.

In Phase I, a team visited 10 of USA’s 11 member plants, as well as other nonmember plants. The team members asked plant personnel from various departments, such as security, engineering and operations, a set of questions, said Rick Burnside, Employee Concerns Program Manager at Diablo Canyon Generating Station and USA’s Assistant Program Manager. The team then used a systematic method to analyze the responses and draw a conclusion about each of the plants’ safety culture.

When INPO decided that the need to conduct a Safety Culture Assessment to meet the requirements of SOER 02-4 Revision 1 Recommendation 2 would be a permanent, periodic requirement and the NRC revised the Reactor Oversight Process to include a strong recommendation to conduct Safety Culture Assessments periodically, USA decided it needed continue and expand its NSCA program. Phase II then began. Phase II is currently being implemented by the USA member plants and several utilities have participated in a NSCA and are using the tool at their facilities.

Phase II changed the interview and observation questionnaire and scoring sheets to capture worker perceptions as they relate to the 71 principles and attributes provided in the INPO’s Principles for a Strong Nuclear Safety Culture. Phase II also incorporates eight INPO principles:

  1. Everyone is personally responsible for nuclear safety
  2. Leaders demonstrate commitment to safety
  3. Trust permeates the organization
  4. Decision-making reflects safety first
  5. Nuclear technology is recognized as special and unique
  6. A questioning attitude is cultivated
  7. Organizational learning is embraced
  8. Nuclear safety undergoes constant examination.

The modifications resulted not only in a change to the interview and observation questions but also to the analysis method. Table 1 (page 70) shows the questions asked of middle management based on the first principle. Figure 1 (page 76) graphs a plant’s interview results based on all eight INPO principles.

The primary goal of the NSCA Phase II process is to assess the site’s overall safety culture, increase management’s awareness of its culture and leave each assessed site with a list of observations that the plant leadership team can use to improve performance.

In Phase II, the assessment team is made up of a mixture of personnel from USA member plants and from the plant being assessed. The individuals interviewed are from a cross-section of plant departments, such as security, engineering, operations and management. They are asked a series of questions that are the same among like groups, but vary somewhat between the different groups. In this way, engineers from Fermi 2 are asked the same questions as engineers from Cooper. Their questions, however, are slightly different than the operators’ questions, Frick said.

The assessment process is the same at each plant. The assessment team is composed of independent and objective subject matter experts who evaluate organizational dynamics using a comprehensive set of attributes. Each assessment is intended to be an “outsider’s” look at how the organization perceives nuclear safety.

The team conducts about 80 interviews from Monday through Thursday. For interviewing, the team is split into pairs (one team member from the plant and one from outside the plant). These pairs ask questions and then evaluate the answers. Each questioner assigns a plus, minus or neutral rating for each answer. These ratings are then analyzed by the entire team. Any attribute with a significant number of negative ratings is tagged for evaluation and discussion by the team, Burnside said.

Although the bulk of the information used to form an assessment comes from the interviews and an optional pre-assessment survey, data review and observations are also included in the process.

The optional survey is an electronic nuclear safety culture survey sent to approximately 10 percent to 20 percent of plant workers. Data from this survey helps the assessment team understand which areas should receive additional focus during the site assessment interviews and observations. The survey data also helps the team members understand interview responses and observations. Observations made by team members during the interview are included in the process, as are observations made during meetings or other events.

The data/documentation review includes pre-screening recent plant history and provides focus areas for the team during assessment week.

The information collected during the week’s assessment is compiled and the team then develops preliminary results and recommendations, which it shares with management. The top issues needing attention are presented because they represent the areas where the plant will gain the most value.

The team leader and host peer provide a final assessment report approximately four weeks after the on-site assessment. The entire assessment team must concur with the final assessment report. The report is fully documented in accordance with the site’s self-assessment process and is usually entered into the plant’s corrective action program.

The final assessment report includes as a minimum:

  • An overall assessment summary with a rollup scoring chart of INPO’s eight principles
  • Assessment results categorized by the eight principles
  • Assessment methodology
  • Assessment results by principle
  • Follow-up of weaknesses from previous nuclear safety culture assessment
  • Positive organizational traits noted during the assessment
  • Summary of recommendations.

Individual plants may ask for the team to look at related matters such as industrial safety, but these issues are addressed separately.

To ensure consistency and a thorough evaluation from site to site, the NSCA team developed an assessment handbook. The handbook is a one-stop reference tool for preparing for an assessment and conducting the on-site review activities, as well as documenting the assessment findings. It contains pre-established guidance for performing the optional pre-assessment survey; conducting assessments, entrance and exits meetings; specific interview checklists covering various levels of management and disciplines; questionnaire scoring sheets; sample graphs of the score sheet input results; and the final report format.

Cost Sharing and Other Benefits

By collaborating on the NSCA tool’s development, USA members were able to share costs and resources. The plants realized substantial savings by using a fleet-wide approach versus each plant developing and implementing its own assessments.

The USA team members estimate the member resources used to develop the NSCA process tool was conservatively 36 weeks. This one-time expenditure saved each participating plant the same amount of resource time, which equates to approximately 300 man-weeks of time saved for each of the 10 members active in the process. The USA membership reported a total savings of $831,000 in 2007 alone from the development of this process.

Another benefit of collaboration includes continuing improvements and objective evaluations. The product’s quality improves continuously through use, feedback and experience. Senior management at all the participating plants agree that these assessments resulted in more objective, critical and meaningful results than those that would have been developed from assessments using only internal personnel.

USA has made the process tool available to other utilities. In addition to the USA member plants, the NSCA style assessments have been conducted at Ontario Power Generation’s Pickering A, Pickering B and Darlington plants, at PSE&G’s Salem/Hope Creek, Arizona Public Service Co.’s Palo Verde Station, Entergy’s Grand Gulf Plant and the University of Missouri’s Research Reactor. The assessment tool also has been shared with Entergy and Southern Co. In addition, USA has received inquiries from companies in Canada, Great Britain, South Africa, Spain, and Slovakia.

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Phase III improvements will be started in 2008. One of the actions considered for Phase III is to further develop the tool related to the NRC’s 13 nuclear safety culture components.

Editor’s Note

In addition to Willis Frick and Rick Burnside, USA program leaders who were interviewed for this article, Ed Peterson, Ombudsman at Wolf Creek Generating Station and an active member of the USA NSCA team, merits a thank-you for his input.