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Safety Culture Oversight Framework:
Korea’s Approach and Current Status
IAEA TM on SC, 2014.10.6~10.8
Su Jin Jung, [email protected]
Korea Institute of Nuclear Safety
2 In the past
Requirements for management effectiveness
Technical capabilities for operation
Organization, Qualification and Training, Human Factors Management,
Operating Procedures, Operating Experience Feedback, Testing/
Monitoring/Inspection and Maintenance.
Quality assurance requirements
Safety culture not enforced by regulators
There was no regulatory requirement for licensee’s safety culture although Safety
policy statement of 1994 addresses the importance of SC.
Safety culture has been considered as what should be managed by licensees
themselves.
A change in regulatory position about SC oversight was made after an event of
station black out cover-up in Kori unit 1 considering lessons from Fukushima and
several events in other countries.
3 Changes in the role of Regulator regarding SC
Issues in Korea
Station Black Out Concealment event in Kori unit 1 (Feb. 2012)
Plant manager’s decision not to report it resulted in subsequent violations.
After a month, revealed by an outside person and then publicized.
The Use of Falsified quality documents was revealed by whistleblower’s tip (Nov.
2012, April. 2013).
Root Cause
Moral hazards and complacency encouraged by good performance of NPPs
Lack of questioning attitude and problem in raising safety concerns
Korean regulator concluded that safety culture aspects were not properly managed
by licensee and therefore minimum requirements should be imposed on.
Concealment shows the importance of Leadership and Management, and Safety
Culture.
Consideration should be given to the whole aspects of the organization’s safety culture.
4
Action plan to foster SC were included in the First Comprehensive Safety Plan
for 2012-2016 established by NSSC in 2012.
NSSC was established in Oct. 2011, aftermath of Fukushima.
National mid-term plan on safety culture oversight (2012~2016)
Regulatory oversight of Licensee’s Safety Culture is decided in 2012
Pilot safety culture inspection program for all NPPs started in the late 2013
Special Safety culture inspection in KHNP head office performed in 2014
Legal basis for safety culture oversight will be developed till 2015
Regulatory Oversight including Regular Inspections is expected from 2016
National mid-term plan to foster safety culture
Research project to develop SC oversight framework (2013 – 2016)
Selection and verification of safety culture components
Development of methodologies to support regulatory oversight
Development of integrated safety culture assessment system
Conceptual framework of SC oversight, Prime focus area, Specific details on
regulatory expectations are being developed along with the pilot program
5 Safety Culture – Korea’s preliminary definition for oversight
Safety Culture is that
Assembly of Behavioral patterns, Core values and Basic beliefs
Shared by Individuals in organization
about the Importance of Safety
Safety Culture positive weak
IAEA, NRC, INPO
Value-neutral expression
3-level model of organizational culture (E. Schein, IAEA, J. Reason..)
Shared value in the organization
possibility of change due to external adaptation, organizational learning
Individuals in organization : top management(leader), manager, staff
vs. leaders and individuals (NRC), organizations and individuals (IAEA), senior
management and entire personnel (STUK)
6
SCWE
Basic approach
1. SC is a basic
prerequisite to make
DID effective and
influences each of
defenses. [INSAG-10]
2. There exist always
errors in defenses.
[J. Reason]
4 Organizational elements and SC management system, are derived to maintain and
strengthen the integrity of DiD
External Oversight
Internal Oversight
Management
Individual
3. Cultural factors can
be organized into
organizational barriers
against active and
latent errors.
7
Leadership and Org. Control
Organizational Barriers : SC Components
* OEF: Operating Experience Feedback, PI&R : Problem Identification and Resolution, ECP: Employee Concerns Program
Human Performance
Management for Improvement
Internal Oversight (SCWE)
OEF, PI&R, Diagnosis & Improvement
Policy/System, ECP, Just Culture
Decision Making, Work Mgt., Work Practice, Resource Mgt.
Safety Leadership, Org. Competence, Change Mgt.
SC Model,
SC Organization
Implementation system
(Assessment, Monitoring, Analysis,
Corrective Measures)
Licensee’s
Safety Culture
Mgt. System
Error prevention
Detection & correction of errors
Raising safety concerns
Corporate’s governance
The four basic areas of prime focus are;
Human performance(individual), management for improvements(MS),
Safety Conscious Working Environment(int. oversight), leadership &
organizational control(ext. oversight)
It is expected that these basic elements shall be managed by licensee’s safety
culture management system.
8 Map for SC intervention
SCWE OEF Management for
Improvement
Leadership & Org.
control
Reactive Proactive
top management
manager
staff
SC
management
system
Organizational
Level
Human
performance
Just Culture
Reporting Culture
Learning Culture
Informed Culture
Culture
Development
Time Flexible Culture
9 Implementation, Monitoring and Assessment Process
Periodic Safety Review
Self Assessment
Inspection
at Site
Overall
Assessment
Observation
at Site In-depth
Examination
Observation of
long-term Change
Periodic Inspection Daily Inspection
Event
Report
SC
related
Event
Safety Culture Monitoring
- Identification of Deficiencies
- Monitoring of Performance Degradation
Observation
Result Findings,
Recommendations
Root Causes of
Event
Improvement Items
Safety Culture is included in
Periodic Safety Review,
according to IAEA SSR -25
Previous Regulation Scope
10 Decision Making Process (draft)
11 Pilot safety culture Inspection program
SC Inspections at 3 sites and KHNP head office (‘13.10~’14.9)
For 2~3 days at each sites
Objective
To verify the feasibility and effectiveness of regulatory oversight
To obtain baseline data of licensee’s status with regard to the preliminary
regulatory expectations of SC
To develop SC infrastructure of both regulators and operators and to have
common understanding, methodologies, competencies, etc.
Method
Interview with resident inspectors to collect insights from daily inspections and
observations
Document review
Interview with top manager, plant managers and employees
12 Major Findings from Inspections
Major Findings and Areas for Improvement in Special Inspection on KHNP’s
Safety Culture
Human
Performance
Management for
Improvement
SCWE
Leadership and
Org. Control
SC
Mgt. System
Analysis of Behavioral Observations
Control of Org. Psychology
RCA of Significant events into SC
Management of Corrective Actions
Policy and Efforts for Just Culture
Implementation of ECP
Organizational Change Management
Management for Competency/Ethics
Alignment of SC Program between
head office & NPP Sites
SC Assessment Procedure
Contractor’s SC
* RCA: Root Cause Analysis, ECP : Employee Concerns Program
13
Management of Organizational Competency and Organizational Change
to prevent further events
Forced rotation of technical staffs, High rate of newcomers, Job security
Regulatory Oversight of Licensee’s Head office is crucial
Leadership for Safety, Management System for SC, Organization
management come from top level of the corporate
Alignment of SC Management system between head office & NPP Sites
Regulator’s preparedness is essential
Interview method & skills, Utilizing insights of resident inspectors
Reviewing the higher level framework to analyze institutional aspects
Changes in Regulator’s attitude
Regulatory body influences operator’s safety and safety culture.
Regulatory body should foster it’s own safety culture and proactive approach
to safety.
Lessons learned
14 Future Plan
KINS (1990~) NSSC
(2011~)
Policy setting, authorization, and enforcement actions
Technical decision through review and assessments, inspections and R&D
Sharing of operating experience on safety culture
Database build-up
SC of regulatory body (2015~)
Expert role vs. Authority role
Ongoing effort to develop SC oversight
framework (~2016)
Validity assessment of SC components
Development of an integrated SC assessment
system including inspection guides and a site
observation manual
Requirements for enforcing “proactive”
corrective actions
Independent assessment tool
Infrastructure for regulatory oversight such as
education and training