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Nuclear
Plant Safety Culture
While it is easy to list all of the desirable
characteristics of a good Nuclear Safety Culture, it is
difficult to implement those characteristics. This
difficulty makes it possible for outsiders to claim an
ability to, at least, identify and, possibly, even measure
the culture shortfalls. Once identified and measured, there
remains the problem of implementation. Without an
understanding of what implementation means, the processes of
identification and measurement can be a waste of money.
As an initial step, implementation of the "discretely
separable" Nuclear Safety Culture upgrades identified
by outsiders can create a patchwork of improvements that are
superior to what was previously in place. Nevertheless,
achieving a good "systemic" nuclear safety culture
requires internal changes that are not feasible unless
started at and sustained from the top managers.
It is well recognized that the top nuclear manager plays a
critical role in achieving nuclear safety excellence and,
thus, plays the key role in making nuclear power plant
profitability possible. With these thoughts in mind, we can
easily conclude that the best nuclear managers have a clear
awareness of what is required and what comes first. A strong
nuclear safety culture enables reliability and
profitability, not the reverse.
A plant that has the right culture and still is not able to
achieve profitability should be shut down for cost reasons.
Likewise, the plant that is profitable yet fails to achieve
a good level of safety should be shutdown for safety
reasons. When a nuclear utility fails in either the safety
or reliability arena, then there are outsiders who are ready
to step in and shut down the plant. It is just a matter of
time.
A good culture enables good operational performance. Yet it
is not enough for a nuclear plant manager to have the right
culture. The manager also should have the required technical
competence to make technical decisions at a level that
exceeds, at least, the ability of the outside regulators to
contradict those decisions. It is the manager who must make
the necessary tradeoffs that arise
daily and who must define, achieve, and sustain the safety
and operability models as a single mental picture.
The manager's mental picture provides the optimal basis for
plant success, but only if it is the best one available. The
manager who has the best technical and cultural picture is
the manager with the best chance of making the plant a
success, concurrently optimizing safety and reliability. If
the top manager has to rely too much on lower level
managers, the picture becomes fuzzy, resulting in
opportunities for poor management decisions.
Even when a good safety culture is somehow ensured, overall
plant success is not ensured. The safest nuclear plant is
the one that never starts up, but we have to start them up
to meet our power needs and to minimize energy-induced
environmental pollution. Thus, once the big picture is
understood, the nuclear power plant manager's task is to
produce power, achieving what is needed in all areas and
optimizing that picture.
None of this is a big intellectual mystery, but even with
such a strong and capable leader in place, it is a matter of
proper implementation. Leadership is the top-down portion of
safety culture implementation, but the plant culture that is
most important is the one that springs from the bottom up,
reflecting management's leadership. A good nuclear safety
culture can be encouraged and facilitated but not ensured.
We know how to encourage and facilitate, but we are weak on
putting it all together to the point that it is ensured.
Multi-Functional Performance
and Multi-Functional Assessments
There is no shortage of guidance out there, either for
nuclear safety or reliability. When something adverse comes
up at one plant, all plants have to pay attention. Even if
your plant were perfectly safe and reliable, you must still
react to the failings at other plants. Moreover, your
reaction must be documented to be credible and auditable.
You can not just sit there in total competence and be
successful in a regulatory environment.
Since the regulators can not possibly track a safety model
that is dozens of times more complex than that being tracked
by the management each utility, the regulators must rely on
"vertical slice" assessments that address a single
plant's safety system. Even then, the regulators must rely
on outside consultants to supply some of the functional area
technical knowledge and assessment process labor. The plant
managers often do their own pre-assessment when they know
what type of assessment the regulators are planning.
The managers of the ideal plant would not have any reason to
prepare to any significant degree simply to deal with a
planned examination. Indeed, the managers of the ideal
nuclear plant would welcome assessments by outside
regulators and even demand more assessments rather than
less. It is only because of management's inability to
embrace and implement the entire reach of their technical
responsibilities on a continuing basis that they find
themselves abhorring the prospect of a regulatory
interaction.
This lack of management's ability leads to lack of
confidence, which results in poor technical and culture
decisions in the first place and in being overly concerned
with regulatory interactions in the second place.
Extraordinary steps must be taken at some point to get ahead
of all of the possible adverse consequences of this
self-imposed, weak management environment. The costs
associated with these extraordinary steps are what make
nuclear plants unprofitable, assuming nothing else has
already done so.
Getting Ahead and Staying
Ahead
Now that the nuclear safety regulatory environment is
starting to shift to something new and more realistic,
perhaps it will be easier to stay out of trouble with the
regulators. While there is the possibility that the
regulatory process has shutdown safe plants, it is just as
likely that it also shut down a few that were not so safe.
Getting the regulators to scale back their intrusiveness may
cause
pendulum overshoot.
Nuclear utilities must be very circumspect if they actually
get what they say they want. It will become even more
important for each and every nuclear plant to operate safely
without outside regulation. Without the artificial nuclear
safety culture imposed from the outside, the poorly
performing plants that have previously been shutdown for
real safety reasons could eventually drag the good ones down
with them. Even if the industry escapes being painted with
the same brush as accident-prone nuclear plants in other
countries, the local brush remains poised for
broad-brushing. Any increased level of freedom may be
temporary.
With increased freedom comes increased responsibility, but
this responsibility must be viewed as an industry-wide
responsibility. It is like the nuclear industry is learning
collectively to ride a two-wheeler. Every plant will be more
on its own, but all the training wheels for all the plants
will continue to be in standby. The industry energy that was
once spent inefficiently in dealing with the regulatory
process must now be spent on making sure that each plant is
the best safety and reliability performer that it can be. No
exceptions can be allowed.
Avoiding Exceptions
The first thing we need to realize is that we probably do
not know how to avoid the exceptions to the nuclear industry
safety norms. Just as we do not know how to achieve
perfection, we do not know how to avoid the other end of the
bell curve, the poor performers. Thus, in the absence of
universal excellence, the regulators will still be in
business.
Unless the nuclear industry is prepared to claim that all
the previous problem plants were unfair aberrations of over
regulation, the industry must be prepared to do something
different. Without the industry doing something different,
the probability that the regulatory pendulum will swing back
is very high. With luck, the pendulum will be gentle, but
there is no guarantee. Thus, the industry should do what it
can to make the pendulum a thing of the past.
The good news is that nuclear safety is a lot better than it
was twenty years ago. After many nuclear plant upgrades, it
is increasingly difficult to believe that a major accident
is even possible. Yet, even with such a self-serving
assumption, there continues to be the system reliability and
overall production profitability issue. The emphasis on
profitability will continue to be inconsistent with
maintaining safety margins.
So, what can the industry do to avoid negative safety
trends? How can it police itself to continue positive safety
trends with less effort and expense?
What to do, what to do...
The list of things that need to be done is as long or short
as the level of depth being considered. Regardless of the
length of any lists, there continues to be a big difference
in knowing what needs to be done and in actually achieving
what needs to be done.
Achieving nuclear plant excellence requires many things, but
a good nuclear safety culture is fundamental. Again, an
effective nuclear plant's safety culture is continually
dependent on the ability of its top managers to deal
effectively with the technology while concurrently creating
and nurturing the necessary safety culture. This ability
does not grow on trees, nor does it appear suddenly as a
result of many years of random experience. Moreover, with
the expected regulatory changes, the definition of success
and the credentials needed to achieve success may also
change.
So, perhaps the best industry response to less external
regulation is more internal or self regulation, at least in
the short term in which significant changes and
vulnerabilities are expected. Some plants will pursue
excellence more efficiently with less outside interference,
while other plants will simply fail faster.
Failure avoidance requires the presence of at least one
capable nuclear manager at the top. Yet, we are not quite
sure what qualifies that manager to be in charge. Just like
we must train and certify reactor operators, we ought to
have to train and certify all senior nuclear managers.
Some such managers would be beside themselves if they had to
actually make a technical decision since they are not really
technically competent. Yet, they readily make cultural
decisions all the time. The perception is that culture is
common sense and the technical stuff is too hard.
Fortunately or unfortunately, the culture drives the
technical results. This means that technical success may or
may not be present as a result of the culture, but the
manager does not recognize that technical success or have
confidence in it. When the regulators come up with a new
list of deficiencies, the top manager is not able to deal
with the list, except to add it to the current master list
and leave it to middle managers to work the list.
Dealing with Lists
It is the senior manager's job to be intimately familiar
with every item on a deficiency list associated with the
plant. Moreover, it is the manager's challenge to become an
expert on the technical basis for each item. It must also be
assumed that every deficiency has a root cause in
management. Said another way, any deficiency that is not a
result of mismanagement is probably not a
deficiency. For example, normal plant degradations (wear and
tear) are not deficiencies unless they (somehow) are not
expected. Then they become deficiencies because managers
failed to anticipate the obvious.
Lists are long because root causes are not recognized,
accepted, and dealt with. Management deficiencies are
particularly difficult to root out because management is
accustomed to viewing itself as being without fault or is
simply not able to deal with its faults properly. Few
managers volunteer to be replaced, especially the bad
managers. When plants are really under the gun, the first
step in recovering is often to replace all the managers with
more competent managers, those who understand the technology
and the required culture.
Again, we get to the point of needing the right kind of
people in charge of these nuclear plants. There are not
enough of them around, and the industry is not particularly
focused on how to come up with more of them. Now is the time
to focus on such fundamentals if ever there was such a time.
Our Capabilities
Just like every other consulting company, we have developed
an amazingly long list of details that need to be addressed
at every nuclear plant. If you want to-do lists, we can give
them to you. We have even made them available on the
Internet for those who think lists are the answer. Lists do
not create culture or success, but they are better than
doing nothing at all (usually). No guarantees, but lists at
least give us something to do until the next assessment.
Our lists are also some of the most sophisticated and
complex lists that you will ever find in the nuclear
industry. We can assess any aspect of your plant and add to
your already long list of things that you do not have time
to sort out and fix.
Unlike other consulting companies, we would really rather
work for those companies that see the benefits to them of
challenging us on the fundamentals described above. We would
like to be used as long-term mentors to those very senior
managers, focusing on developing their capabilities even
further than may have resulted from their many years of
nuclear experience. The good part is that you can tell us to
leave, and we promise not to be offended. We learn something
new with each turn in the road, just like you.
We would really prefer to address more significant questions
to every nuclear plant manager: Want a better process to
deal with deficiencies? Want a better scoring method at the
regulatory interface? Want to work on developing a better
culture and technical management environment? Want to stay
ahead of the regulators?
If so, perhaps we have something in common.
Our Philosophy or Yours
All of these thoughts constitute our philosophy, and we
expect that it is not very different from your own
philosophy. Nevertheless, while philosophy comforts us with
noble feelings, nothing is accomplished at a nuclear plant
without vigorous action. The first action is to call us.
The MDI Team
Dr. Jonathan M. Wert provides top-down organizational
support and Charles R. Jones provides the bottom-up
counterpart. Each of us has more than 20 years of applicable
experience, and that experience is diverse rather than
repetitive. We complement each other's capabilities, with a
minimum of redundancy.
Our primary area of overlap is in the area of nuclear plant
safety culture, but even our safety culture perspectives are
based on a wealth of different experiences. We have
witnessed the best and the worst management organizations
and nuclear safety cultures. Both of us have extensive
experience in multi-functional evaluations and upgrade
programs.
Management Diagnostics, Inc.
P.O. Box 240, Port Royal, PA 17082-0240
Tel: 717-527-4399 Fax: 717-527-4398
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