Newly-released documents on safety culture:
U.S. Nuclear Regulatory Commission ignored evidence to OK Davis-Besse start-up
One would think that this would give the NRC decisionmakers pause to reflect, but one would be wrong. Internal documents just released show that in approving FirstEnergy's restarting Davis-Besse, the NRC acted as recklessly as ever.
On March 8, in announcing the go-ahead, NRC Regional Administrator James Caldwell told reporters that NRC's safety-culture assessment found that 100% of Davis-Besse employees said (1) they would raise safety issues, and (2) they thought management would deal with those issues promptly.
That the employees would raise safety issues was no surprise.
The second claim -- about what employees thought management would do in response -- was completely at variance with previous evidence. Caldwell and his staff did not make public the basis for this claim, and said the report was still being written.
Yesterday, almost a month after the decision, the report quietly appeared in the NRC's document system. No evidence to support Caldwell's claim is in it.
To the contrary --
1. The Commission didn't find out whether harrassment, intimidation, retaliation, and discrimination were continuing at this workplace.
Imagine the following exchange at the local hospital:
As absurd as this conversation is, it captures the approach of the NRC study group. Rather than seeing whether harrassment, intimidation, retaliation, and discrimination was occurring, it dwelt on process: paperwork, meetings, procedures, in-plant emails, and so on.
The most minimal assessment of safety culture would have had two steps:
First, the Commission would have repeated the individual surveys of May and November, 2003, which showed actual conditions in the plant bad and getting worse. The Commission would have conducted these surveys with necessary safeguards to guarantee the confidentiality of employee responses.
Second, where employees reported management misconduct, the Commission would have investigated, and taken necessary action against those responsible -- again, with all necessary whistleblower safeguards.
The Commission did neither.
Instead, it looked at, and ratified, the company's process: paperwork, procedures, charts, and so on. Where employees raised management misconduct, the Commission reported it as "actions. . . taken as retaliatory," "statements. . . taken as derogatory, intimidating," (page 1 and throughout).
Such statements and actions either were retaliatory, intimidating, etc, or they weren't. It is a legal matter. If so, they were violating the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974. It the Commission's responsibility, under the same laws, to investigate and take appropriate action.
Instead of investigating the alleged illegal management activity, the Commission examined what was wrong with employees that might have caused them to answer surveys in such a negative way. They concluded, at great length, that the employees were tired and frustrated.
Another explanation is possible: that the employees were telling the truth about the misconduct. The Commission didn't bother to pursue that possibility.
2. The survey the Commission approved was so skewed as to rule out finding out what was going on.
The NRC Inspection Team reviewed a survey conducted in December, 2003, by a contractor working for FirstEnergy and concluded --
"The licensee's contractor interviewed 100% of plant staff, from Quality Assurance, Chemistry, Plant Engineering, Operations, and Maintenance who were onsite and available to be interviewed during the last week of December 2003. The interviews were conducted in group sessions referred to as focus groups. This was an adequate sample based on time and staff availability," (page 5).First, these were not "focus groups."
A focus group is something completely different: it is a small group selected from a wider population for an open discussion of its members' opinions about or emotional response to a particular subject. It is used at the preliminary or exploratory stages of a study to explore or generate hypotheses and develop questions or concepts for future systematic, scientific research.
What does it matter what they called it? It matters because it illuminates why these group interviews are so wrong for the intended purpose:
"The method of focus group discussion may also discourage some people from trusting others with sensitive or personal information. In such cases personal interviews or the use of workbooks alongside focus groups may be a more suitable approach. Finally, focus groups are not fully confidential or anonymous, because the material is shared with the others in the group," ('Focus Groups,' Dr. Anita Gibbs, Research Officer, Probation Studies Unit, Centre for Criminological Research, Oxford University, Oxford, England, 1997).
Second, the most forthright and critical workers were left out of the group-interviews. As above, the group-interviews were of "100% of plant staff, from Quality Assurance, Chemistry, Plant Engineering, Operations, and Maintenance, who were onsite and available to be interviewed during the last week of December 2003."
The report does not mention something that the Commission officials must have known: In the spirit of the season, FirstEnergy had laid off their contract-employees before the holidays, only to rehire them after New Year's. Why? So the company wouldn't have to give them paid holidays.
Previous surveys had shown that the contract-employees at Davis-Besse were much more likely to give straight answers to questions about FirstEnergy management misconduct. This stands to reason, since the contractors were not dependent on management for the long-term.
This means that FirstEnergy's consultants chose to do their interviews during the one week in the year when they could be sure that the most critical employees would not be around.
3. The NRC itself ignored disturbing news from the employees
The NRC Inspection Team conducted its own interviews of 120 people, including 118 FirstEnergy employees and 2 contractors, during its Jan 12 - Feb 12, 2004 visit: