The Components of IMS and SC Oversight Programme The Swiss Approach to Regulation and Inspection

1. The Components of IMS and SC Oversight ProgrammeThe Swiss Approach to Regulation and Inspection Regional Training Course on Transition to IMS Approach Supporting the Development of a Strong Safety CultureJiujiang City 8-12 November 2010 Albert Frischknecht Swiss Federal Nuclear Safety Inspectorate (ENSI)

3. Beznau: 2 PWR 1969/71 (2x365MWe) Goesgen, PWR 1979 (1020MWe) Central Intermediate Storage Facility 2001 Mühleberg, BWR 1972 (355MWe) Leibstadt, BWR 1984 (1165MWe)

4. 1959 Atomic Law 1986 Regulatory Guideline on the organisation of NPPs HSK-R-17 Regulatory Guideline on the training and qualification of licensed control room personnel 2002 Issue of a Revision of HSK-R-17. Concentration on Safety Management. New Chapter on Management of Change 2004 Intension to write a Regulatory Guideline on Safety Culture (demonstrating how the Regulator deals with the SC of licensees) 2005 New Nuclear Energy Act, new Ordinance on Nuclear Energy Requirement to develop and to maintain Safety Awareness 2006 Ordinance on Requirements on Training and Qualification of NPP Personnel Legal Context

5. Issue of a complete revision of HSK-R-17: New Guideline HSK-G07 „Organisation of Nuclear Installations“ Compatibility with new legal framework Safety Culture 2008 Introduction of site inspectors (follow the „daily life“ in the NPPs) Legal Context

6. Regulatory body becomes independent from bodies fostering Nuclear Energy. HSK  ENSI. Independent from the Office of Energy. Agency under public law, responsible directly to the Federal Council 2010 Within the next few months: Publication of an ENSI Position Paper on Safety Culture (demonstrate to the public ENSI‘s understanding of SC. Common understanding between ENSI and operators) Legal Context .

7. Regulator’s Experience with „Safety Culture“ in Switzerland • Identified Problems in the Past • Development of a Concept • Solution • What we do • What we plan to do • Summary

8. HF Identified Problems in the Past: • „Safety Culture“ is often used as „trash bin“ for complex HF-issues

9. Identified Problems in the Past: • „Safety Culture” is often used as „trash bin“ for complex HF-issues • „Safety Culture“ is often used in a generalized, unspecific way (non-specific statements on „what happened“) „they have no safety culture“

10. Identified Problems in the Past: • „Safety Culture“ is used as „trash bin“ for complex HF-issues • „Safety Culture“ is used in a generalized, unspecific way • „Safety Culture“ is used in the wrong context (general conclusion from an individual failure to the culture of the organization)

11. Identified Problems in the Past: • „Safety Culture“ is used as „trash bin“ for complex HF-issues • „Safety Culture“ is used in a generalized, unspecific way • „Safety Culture“ is used in the wrong context • Expectations to „measure“ Safety Culture

12. Identified Problems in the Past: Not everything that can be counted counts and not everything that counts can be counted. .

13. Development of a Concept • Literature Studies • Participation in international Meetings • Internal Workshops • Use of Experts (Social Scientists) • Modified view about „Safety Culture“ and Concept for Regulation and Inspection (Regulatory Oversight)

14. Development of a Concept Principles used (outcome of an IAEA Consultants Meeting): • The “Responsibility” Principle (Operator ist responsible for safety) • The “Don't Make it Worse” Principle (everything the regulator does, influences the safety culture of the licensee) • The "Foster Organisational Learning” Principle • The “Regulatory Balance” Principle (expert role, authority role, public role) Consistent application of Edgar Schein‘s Model on Organizational Culture.

15. Safety Culture Policy • Architecture and design • Regulations and procedures • Housekeeping • Condition of techn. systems Artifacts • Safety is the top priority • Blame-free work environment • Errors are a learning opportunity • Fostering team work Espoused Values • - Predominant image of man • „Accidents are caused by carelessness“ • „Automation is more reliable than humans“ Basic Assumptions visible, difficult to decipher not visible,but accessible unconscious, difficultto access

16. Artifacts Espoused Values Visibility Safety Culture Basic assumptions „Essence“ of the Culture

17. Regulation and Inspection in the area of Safety Culture needs an approach that is different from that in the technical area. Safety Culture cannot be an issue for direct regulation by the safety authority, because… Safety Culture cannot be prescribed, There is no „best way“ in the area of Safety Culture, The accessibility to Safety Culture by the regulator is limited, The safety authority must not take the responsibility from the operator, Self-regulation and self-assessment by the operator increases it‘s motivation. Problems in the area of Regulation and Inspection on Safety Culture:

18. Artifacts Safety Management Espoused Values Visibility Safety Culture Basic assumptions .

19. Conclusion: Oversight on Safety Culture Safety Culture is a very important aspect of ENSI regulatory oversight activities, however… • Concept of Safety Culture has a complex nature Its assessment is subjective and arbitrary to some extent • Distance between Regulator and Licensee Distance as well as methodological reasons make it difficult to assess Safety Culture systematically • Culture – including Safety Culture – cannot be prescribed  ENSI: No direct regulatory oversight on Safety Culture, but regulatory oversight on Safety Management

20. Solution:Oversight on Safety Management ENSI-G07Organisation of NPPs

21. ENSI-G07 • General requirements on Structures and Processes • Requirement to analyse the own Safety Culture • Define activities to foster a good safety awareness • Maintain a Mission Statement on Safety Culture (common understanding of SC, basic principles of the SC to aspire, means to foster good safety awareness, how to assess the effectivity of these means and activities) • Leadership (Managers demonstrate in their activities their commitment to the Mission Statement on Safety Culture) .

22. What we do: Regular Inspections on Safety Management according ENSI-G07 (proactive and reactive)Safety Relevant Processes (e.g. decisions, modifications, tag-out, operational experience feedback, etc.) - Suitability of Structures and Processes - Systematic Applicaion of Processes by the NPP - Outcome of the Processes In the case of deviations: Requirement of investigation and corrective action on this specific (and similar) subject! Results are used for systematic Safety Evaluation!

23. Regular and thorough Event Investigationswe investigate: Technical issues Contributions of Human and Organizational Factors (Work environment, Procedures, Training, Human System Interface, Work Organization, Communication, etc.) to the event Decisions in the contributing factors to the event Decisions during the event Implementation of corrective actions Decision in defining and implementing corrective actions Evaluation of the corrective actions What we do (ct΄d):

24. Annual Management Meeting (ENSI - NPP) Vision, Objectives, Changes Safety Culture Activities (overview) Specific Observations in the area of SC (if any) What we do (ct΄d):

25. What we do (ct΄d): Biennial Discussions on Safety Culture Topics (proactive) • Discussion and reflection of the topic (audience: Managers, Members of the Safety Culture Working Group, etc.) • Analysis of the gathered Data Development of Hypotheses • Presentation of the Hypotheses to the Plant (same audience) Discussion of the Hypotheses with the audience

26. What we do (ct΄d): Biennial Discussions on Safety Culture Topic (proactive) Expectations of ENSI: - Foster a common understanding of Safety Culture issues - Get an impression how the plant deals with Safety Culture issues - Foster the self-reflection process at the NPP Results of discussions are NOT used for systematic Safety Evaluation!

27. In preparation: ENSI Opinion Paper on Safety Culture Demonstrate to the NPPs and to the Public ENSI‘s understanding of Safety Culture Demonstrate to the NPPs and to the Public ENSI‘s activities in the area of Safety Culture Foster a common understanding of Safety Culture issues between ENSI and NPPs What we do (ct΄d):

28. Gathering information from technical inspections During technical inspections a vaste amount of information on Safety Culture may be gathered by technical inspectors in meetings, in observations during tests, in discussions, in coffee breaks, etc. Precondition to do this: Competence of the Inspector in Human and Organizational Factors (HOF) Sensibility to these issues Insight and distance to the organization A tool to systematically collect and group this information A specialized section (HOF-Specialists) within the Regulatory Body to analyse the information Ressources What we plan to do (ct΄d):

29. Gathering information from operator‘s applications for approval The quality of the information contained in applications for approval (e.g. for plant modifications, etc.) shows the carefulness the operator devotes to safety issues (safety analysis, quality of the analysis, quality of the documents). So, information from safety reviewers at the regulatory body may give information for safety culture characteristics. Again, this information has to be collected and analysed systematically. What we plan to do (ct΄d):

30. Summary • We don‘t rate safety culture • We don‘t assess the overall safety culture • We don‘t give a general statement on Safety Culture • Instead: • We do assess and evaluate specific findings, observations in Safety Management • We do address these specific findings and we require corrective actions if we detect deficiencies • We do follow up the implementation of solutions