4.0 Summary of Major DCISC Review Topics, 17th Annual Report - July 1, 2006 thru June 30, 2007
4.5 Health, Nuclear Safety Culture, and Safety Conscious Work Environment
4.5.1 Overview and Previous Activities
The foci of Health, Nuclear Safety Culture, and Safety Conscious Work Environment are twofold: 1) the health of the individual employee, and 2) nuclear and personnel safety as the context and requirement for all DCPP Employees. Included in this area are all health related issues and actions. This section also focuses on safety as a contextual cultural requirement.
In the previous period (2005-2006) the DCISC reviewed the following:
- Overview of DCPP Culture as a Learning Organization
During previous reviews, PG&E appeared conscious about monitoring and improving employee health, enhancing safety culture, and its safety conscious work environment.
4.5.2 Current Period Activities
During the current period (2006-2007) the DCISC reviewed the following Health and Safety Conscious Work Environment item:
- Employee Concerns and Differing Professional Opinion Programs
- Safety Culture and Safety Conscious Work Environment
Employee Concerns and Differing Professional Opinion Programs
The DCISC met with Rick Burnside, Employee Concerns (EC) Program Supervisor at the DCISC August 2-3, 2006 Fact-finding Meeting (Volume II, Exhibit D.1, Section 3.6) to review the status of the Employee Concerns and Differing Professional Opinion Programs.
The EC group has received 3 formal allegations from the NRC that were raised by the public. None of these concerns were substantiated by DCPP EC group. One internal concern was raised which was not substantiated. They have had 28 low-level contacts that were looked into. They normally have about 30 to 70 low-level contacts each year.
NRC tracks all allegations they receive for all nuclear power plants including:
- 1) total reactor allegations,
- 2) reactor allegations from on-site sources,
- 3) reactor discrimination allegations,
- 4) reactor open allegations,
- 5) reactor allegations substantiated, and reactor allegations substantiated with enforcement.
DCPP was at the low end of numbers of allegations compared to the other plants.
Even though DCPP does not receive very many concerns, they believe there is no problem with employees raising concerns. A mini-survey of employees in June 2006 included no problems raised about safety culture. Mr. Burnside believes employee moral is improving.
The last time the Differing Professional Opinion Program was used was in 2004. The program has never had much activity since 2004 with the exception of one in 2007 regarding the new steam generator controls. Apparently differences in Professional Opinion are being resolved within the departments.
DCPP believes employees feel free to raise concerns within their departments and accept the response. There have not been many concerns raised at DCPP in the last few years. The Employee Concerns Program is available if any employee needs to contact it.
Safety Culture and Safety Conscious Work Environment
The DCISC Fact-finding Team had a discussion with Rick Burnside, Supervisor of the Diablo Canyon Employee Concerns Program (ECP) at the September 6-7, 2006 Fact-finding Meeting (Volume II, Exhibit D.2, Section 3.8), to discuss Safety Culture and Safety Conscious Work Environment (SCWE) at Diablo Canyon.
DCPP has a new Program Directive on Nuclear Safety Culture and a new Administrative Procedure on SCWE. The Program Directive sets forth the commitment to maintain a healthy nuclear safety culture, and a SCWE. The document defines Organizational Culture, Safety Culture, and SCWE.
Safety Culture is defined 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". SCWE is defined as "An environment in which employees feel free to raise concerns to their management, the Employee Concerns program (ECP), and the Nuclear Regulatory Commission (NRC) without fear of harassment, intimidation, retaliation, or discrimination. A SCWE is a critical element of a healthy Safety Culture". The eight INPO Safety Culture Attributes are adopted verbatim in the directive.
The Administrative Procedure focusing on Safety Culture and SCWE covers:
- The roles and responsibilities for leadership, management, individual contributors, and supplemental personnel in supporting and maintaining a healthy Safety Culture and SCWE.
- Requirements for performing biennial Self-Assessments to determine management’s effectiveness in fostering a healthy Safety Culture and a SCWE.
- Training for employees and supplemental personnel in Safety Culture and in SCWE.
DCPP plans to conduct employee surveys on plant safety culture to be conducted quarterly probably beginning in October 2006 and will each sample 10-20% of the plant population. The surveys will be based on the eight INPO Safety Culture Attributes. A test survey has been completed. Survey results will be discussed with managers and likely be put into the Corrective Action Program for action. Mr. Burnside has been involved in the development and administration of the USA Safety Culture Assessment which will be administered January 2008.
NRC data regarding Reactor Allegations received by NRC from 2002 to 2006 showed no Reactor Discrimination Allegations at Diablo Canyon, and there were no Reactor Open Allegations for Diablo Canyon. There was one DCPP Reactor Allegation Sustained with Violation Enforcement, occurring in 2003. Total Reactor Allegations received were: four in 2002; five in 2003; four in 2004; five in 2005; and one in 2006. Reactor Allegations sustained over this time period were: two in 2002; two in 2003; zero in 2004; one in 2005; and zero in 2006. Comparative data was also provided in each area for all Nuclear Power Plants, and Diablo Canyon was in the quartile with the fewest Reactor Allegations in all categories.
NRC, based on interviews conducted during its June 2006 Biennial Problem Identification and Resolution Inspection and Assessment of Safety Conscious Work Environment, concluded that “. . . a positive safety conscious work environment existed at Diablo Canyon Power Plant. The [NRC] team determined that employees felt free to raise safety concerns to station managers and supervisors, the employee concerns program, and the NRC. However, the team noted two isolated incidents regarding the environment that did not foster openly raising safety concerns. The licensee [DCPP] had already taken actions to address these concerns. All interviewees believed that potential safety issues were being addressed.”
The DCISC Fact-finding Team later met with Rick Burnside and Julie Simko, of the DCPP Employee Concerns Program (ECP), at the March 21-22, 2007 (Volume II, Exhibit D.7, Section 3.1) to review the first two safety culture surveys performed at DCPP in November 2006 and February 2007.
DCISC review of those surveys shows them to be fairly constant over that period. In general, the results indicate that those responding are well aware of, sensitive to, and diligent about safety culture matters. The results also point out some specific areas where some management attention may be warranted such as:
- Leadership visibility and presence
- Human Resources practices and organizational issues (staffing, rewards, sanctions)
- Divergent views and respectful communications, and
- Communicating crucial information during change.
Greater emphasis is now being placed at DCPP on management visibility throughout the plant on a daily basis as part of the Management Observation Program.
DCPP has formalized their Safety Culture and Safety Conscious Work Environment programs and has begun conducting quarterly surveys to gauge the safety culture throughout the organization. The DCISC will review the results and trends of these surveys (and resulting actions designed to improve the culture) following the 4th quarter 2007 survey.
4.5.3 Conclusions and Recommendations
- Conclusions:
- DCPP has formalized their Safety Culture and Safety Conscious Work Environment programs and has begun conducting quarterly surveys to gauge the safety culture throughout the organization. The DCISC will review the results and trends of these surveys (and resulting actions designed to improve the culture) following the 4th quarter 2007 survey.
- Recommendations: None