International Safeguards Culture - NAYGN

Safety, Security and Safeguards Culture

Todd Cervini

PD Committee Member

NAYGN

International Safeguards Culture

North American Young Generation in Nuclear

Washington, DC

Steve Mladineo

May 12, 2013

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PNNL-SA-.

Safety Culture

• “That assembly of characteristics and attitudes in organizations and individuals which establishes that, as an overriding priority, nuclear plant safety issues receive the attention warranted by their significance.”

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Security Culture

• “The assembly of characteristics, attitudes and behaviour of individuals, organizations and institutions which serves as a means to support and enhance nuclear security.”

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What are International Safeguards?

• By definition, the international safeguards system comprises an extensive set of technical measures by which the IAEA Secretariat independently verifies the correctness and the completeness of the declarations made by States about their nuclear material and activities.

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IAEA Safeguards Agreements • Non-Nuclear Weapon States conclude a Comprehensive

Safeguards Agreement (INFCIRC/153) with the IAEA on all nuclear material and activities in the State.

• Nuclear Weapons States implement Voluntary Offer Agreements with the IAEA to cover parts of their civil nuclear fuel cycles.

• Non-NPT Member States implement item-specific or limited scope safeguards agreements (INFCIRC/66), which cover specified materials, facilities and other items.

• Multi-lateral Safeguards Agreements

• Additional Protocol & Small Quantities Protocol

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Technical Basis of Safeguards • Quantity and timeliness goals are based on the principle that a certain

quantity of fissile nuclear material is needed for a State to manufacture its first nuclear explosive device and that a certain length of time is required to convert nuclear material in various forms into a form suitable for a weapon.

– Significant Quantity: approximate amount of nuclear material for which the possibility of manufacturing a nuclear explosive device cannot be excluded.

– Conversion Time: time required to convert different forms of nuclear material to the metallic components of a nuclear explosive device.

– Detection Time: maximum amount of time that may elapse between diversion and detection of that diversion.

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ESARDA Bulletin

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Safeguards Culture

• Literature Review

• Organizational Culture

• Analysis

• Definitions

• Next Steps

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Suggested Definitions A shared belief among individuals, organizations, and institutions that strict attention to international safeguards requirements and affirmative cooperation with safeguards authorities will enhance their nonproliferation stature and benefit their missions. –Mladineo and Frazar

The assembly of characteristics, attitudes and behavior of individuals, organizations and institutions which serves as a means to support and enhance safeguards or to achieve effective and efficient safeguards. – Naito

A shared belief by IAEA safeguards authorities, inspectors, and analysts that the people, processes, and procedures used by the IAEA to draw safeguards conclusions are effective and efficient. —Mladineo and Frazar

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Safeguards Culture

• Indicators of a State’s safeguards culture can inform the IAEA about the State’s safeguards program, and that this information could be used to help improve a State’s safeguards performance

• These indicators can be used to improve the Safeguards Culture, or Awareness at a Facility

• Practical Application of Theoretical Underpinnings (Edgar Schein)

• Potential Indicators of Safeguards Culture at a Facility

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From Theory …

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ARTIFACTS

ESPOUSED

VALUES

UNDERLYING

ASSUMPTIONS

• THE THREE LAYERS OF CULTURE

…to Practice

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ARTIFACTS

ESPOUSED

VALUES

UNDERLYING

ASSUMPTIONS

• THE THREE LAYERS OF CULTURE

Artifacts that reflect priority on performance:

• Self Inspection Program

• Corrective Action Mechanisms

• Corporate Governance Best Practices

• Proactive Anomaly Resolution

• Meticulous Measurement and Reporting

Processes

Performance Values:

• Accurate and complete reporting

enhances facility’s mission

• Cooperation with the IAEA leads to

effectiveness and efficiency

Underlying Assumptions:

• Compliance with safeguards requirements

is necessary

• Quality of effort is important to the mission

Indicators of Safeguards Culture Strong, Positive

Underlying assumption that compliance is important

Believe quality performance is important to mission

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Strong, Negative

Underlying assumption that compliance is not important

Take steps to hinder safeguards implementation and inspections

Weak, Positive

Underlying assumption that compliance is important

Do not place high priority on good performance

Weak, Negative

Underlying assumption that compliance is not important

Do not take steps to hinder safeguards implementation or inspections

Promoting Safeguards Culture or Awareness at a Facility

• Attain Top Level Management Support

• Establish a Regulatory Basis

– Focus on effective implementation of domestic safeguards

• Identify Target Facilities and their Training Needs

• Encourage management to pay explicit attention to 3S

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Questions?

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Backup Slides

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Next Steps

• Expand discussion about safeguards culture to international experts in safeguards and culture.

• Collaborate with interested facility or regulator partner to develop a more rigorous set of indicators for safeguards culture

• Follow-on collaborations could explore activities that promote strong, positive safeguards culture

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Organizational Culture

• Whatever the type of “culture” one is describing, its basic function is to act as a guide for employee behavior.

• "A pattern of shared basic assumptions that was

learned by a group as it solved its problems of external adaptation and internal integration, that has worked well enough to be considered valid and, therefore, to be taught to new members as the correct way you perceive, think, and feel in relation to those problems.”

Organizational Culture and Leadership, 3rd Ed., Jossey-Bass ISBN 0-7879-7597-4e problems"(Schein, 2004, p. 17).

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http://en.wikipedia.org/wiki/Special:BookSources/0787975974







Security Culture (What is That?)

(Can it be Measured?) Presentation for NAYGN

May 12, 2013 Paul Ebel

BE Inc. (Hilton Head, SC)

Radioactive Sources – Code of Conduct

• Code of Conduct on the Safety and Security of Radioactive Sources (2003)

“Every State should . . . ensure:

(b) the promotion of safety culture and of security culture with respect to radioactive sources.”

What is That?

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Fundamental Principles

• Incorporated in Amendment to the CPPNM, July 2005

• Fundamental Principle F — Security Culture: “All organizations involved in

implementing physical protection should give due priority to the security culture, to its development and maintenance necessary to ensure its effective implementation in the entire organization”.

What is That? 22

IAEA Definition of Nuclear Security Culture

• From IAEA Implementing Guide Section 2 – “The assembly of characteristics,

principles, attitudes and behaviour of individuals, organizations and institutions which serves as a means to support and enhance nuclear security”.

– “Appropriate Nuclear Security

Culture ensures that the implementation of nuclear security measures receive the attention warranted by their significance”.

That’s what it is? 23

Scope of IAEA Implementing Guide • Defines basic concepts and elements of nuclear

security culture

• Provides an overview of the attributes of nuclear security culture

• States that nuclear security culture is influenced by “top down” standards, regulations, and pressure

• Emphasizes that nuclear security ultimately depends on individuals (“bottom up”) – Beliefs and attitudes are the basis

– Stated principles guide behaviour

– Management systems and individual behaviour can be seen and evaluated

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Basis for Nuclear Security Culture

• Edgar Schein model of organizational culture and leadership (1997)

• Layers range from invisible and non-measurable to visible and measurable – Visible layers have performance indicators

– Invisible must be inferred from visible

• Bottom layer is base for other characteristics (invisible) – Credible threat exists

– Nuclear security is important

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Edgar Schien Model of Culture

ARTIFACTS

ESPOUSED VALUES

UNDERLYING ASSUMPTIONS

Simplified Model for Organizations

BEHAVIORS FOSTER

A HEALTHY

SECURITY CULTURE

MANAGEMENT

SYSTEMS ARE WELL

DEVELOPED AND

EFFECTIVE

SIMPLE PRINCIPLES ARE USED TO GUIDE

DECISIONS AND BEHAVIORS

THE ASSUMPTION OF A CREDIBLE THREAT AND

SECURITY IS IMPORTANT - WIDELY SHARED

THE OUTCOME OF AN EFFECTIVE OVERALL

NUCLEAR SECURITY SYSTEM IS ACHIEVED

Assumption

Espoused

Values

Artifacts

Model Tailored to Fit Nuclear Facilities THE OUTCOME OF AN EFFECTIVE NUCLEAR SECURITY SYSTEM IS ACHIEVED

Enhanced Nuclear Security System Performance

MANAGEMENT SYSTEMS ARE WELL-

DEVELOPED AND EFFECTIVE

Visible Security Policy

Staff Code of Conduct

Clear Roles and Responsibilities

Performance Measurement

Good Work Environment

Training and Qualification

Work Management

Information Control

Material Accounting Systems

Cyber-Protection

Staff Screening

Quality Assurance

Change Management

Operating Experience Feedback

Contingency Plans and Drills

BEHAVIORS FOSTER A HEALTHY SECURITY

CULTURE

LEADERSHIP BEHAVIORS

Standards and Expectations

Use of Authority

Decision-Making

Good Supervision

Involvement of Staff

Open Communications

Improving Performance

INDIVIDUAL BEHAVIORS

(Apply to everyone)

Professional Conduct

Personal Accountability

Following Procedures

Teamwork and Collaboration

Questioning and Reporting

Open Communications

NUCLEAR SECURITY CULTURE

FOR NUCLEAR FACILITIES THE ASSUMPTION OF A CREDIBLE THREAT AND SECURITY IS IMPORTANT - WIDELY SHARED

Threats of Malicious Acts by Insiders and Outsiders are Credible

SIMPLE PRINCIPLES ARE USED TO GUIDE DECISIONS AND BEHAVIORS (Examples)

Leadership Commitment to Nuclear Security

Honesty, Integrity, Responsibility

Good Equipment Condition

Commitment to Procedures

Learning and Improvement











Work Management

Information Control


Cyber-Protection

Staff Screening

Quality Assurance

Change Management




CULTURE



Use of Authority

Decision-Making

Good Supervision


Open Communications



(Apply to everyone)






Open Communications


FOR NUCLEAR FACILITIES







THE ASSUMPTION OF A CREDIBLE THREAT AND SECURITY IS IMPORTANT

- WIDELY SHARED












Work Management

Information Control


Cyber-Protection

Staff Screening

Quality Assurance

Change Management




CULTURE



Use of Authority

Decision-Making

Good Supervision


Open Communications



(Apply to everyone)






Open Communications


FOR NUCLEAR FACILITIES THE ASSUMPTION OF A CREDIBLE THREAT IS WIDELY SHARED


SIMPLE PRINCIPLES ARE USED TO GUIDE DECISIONS AND

BEHAVIORS (Examples)









CULTURE



Use of Authority

Decision-Making

Good Supervision


Open Communications



(Apply to everyone)






Open Communications


















Work Management

Information Control


Cyber-Protection

Staff Screening

Quality Assurance

Change Management













Work Management

Information Control


Cyber-Protection

Staff Screening

Quality Assurance

Change Management












BEHAVIORS FOSTER A HEALTHY SECURITY CULTURE



Use of Authority

Decision-Making

Good Supervision


Open Communications



(Apply to everyone)






Open Communications

Model Tailored to Fit Nuclear Facilities









Work Management

Information Control


Cyber-Protection

Staff Screening

Quality Assurance

Change Management




CULTURE



Use of Authority

Decision-Making

Good Supervision


Open Communications



(Apply to everyone)






Open Communications










THE OUTCOME OF AN EFFECTIVE NUCLEAR SECURITY SYSTEM IS

ACHIEVED


Rationale for Evaluation Methodology • IAEA Nuclear Security Series No 7 – Implementing

Guide, Nuclear Security Culture (2008)

– 28 Characteristics of Organizational Security Culture

– 120 Indicators of “Good” Organizational Security Culture

• IAEA Workshop on Nuclear Security Culture (2009)

– Three-Day Workshop

– “Workshop” Implies “Exercises”

– “Exercises” are Artificial Evaluation Tools

– Always asked “Can this be used for Real Evaluation?”

Evaluation Worksheets for Each of

the 28 Characteristics

Collect Data from Worksheets to

Indicate Weak Areas

BATAN‘S Nuclear Facilities

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Serpong, Nuclear

Research Center

Bandung, Nuclear

Research Center

Yogyakarta, Nuclear

Research Center

North Pacific

Ocean

South China

Sea

Malaysia

Malaysia

Brunei

AUSTRALIA

Sumatera Kalimantan Sulawesi

JAWA

Irian

Jaya

Philliphine

http://www.republika.co.id/propinsi.asp?prop_id=8































Self-Assessment Exercise: Scope

Facility Number of

employees

Registered

respondents

Returned

questionnaire

Written

Comments

Yogyakarta 320 192 190 8

Bandung 171 102 102 5

Serpong 544 332 332 22

BATAN Conclusions from Evaluation

• Surprising that communications “down” is poor (started doing something about it immediately)

• Comforted in the fact that most felt security was important.

• Found that incentives for good management suggestions were not understood by Security Personnel.

• Plan to do reevaluation in a year or two to see if things have improved.

• Felt that the process itself was of value

Presentation of the Indonesia Experience in the following:

• NAYGN Meeting in Washington May 2013

• IAEA Technical Meeting (April 2013)

• IAEA Conference on Nuclear Security (July 2013)

• INMM Annual Meeting (July 2013)

So, in Conclusion Security Culture is important

It has finally been defined by the IAEA

It can be measured to some degree Evaluation techniques have been

used in Indonesia.

Thank You for your attention

Anndria Gaerity Director, Emergency Services

PSEG Nuclear, LLC

Susan Landahl

Senior Vice President, Operations, Integration and Business Development

Exelon Nuclear

A Leadership Perspective on Safety, Security, and Safeguards Culture Susan Landahl Senior Vice President Operations Integration and Business Development May 12, 2013

• BGE distributes

electricity to 1.2 million

customers and

distributes gas to

700,000 customers in

Northeast Maryland

Traditional Transmission and Distribution

• ComEd distributes electricity to 3.8 million customers in Illinois

• PECO distributes

electricity to 1.6 million

customers and

distributes gas to

500,000 customers in

Southeast Pennsylvania

• Ranked #1 Gas & Electric Utility in U.S. Fortune 500

• $23.5 billion (USD) in annual revenues

• Over 34,000 MWe of Generating Capacity, of which

over 19,000 MWe is Nuclear

• Exelon Nuclear operates 17

reactors at 10 sites, plus

operation of Fort Calhoun NPP

•U.S. leader in safety, efficiency

and innovation

•Over 16,000 MWe of fossil and

renewable energy

•Joint venture (50.1% Exelon)

•CENG operates 5 reactors at 3

sites

Overview of Exelon

•A leading competitive retail and

wholesale energy supplier

•Over 1 million residential customers

This briefing is unclassified – no safeguards material will be discussed.

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Benefits of Fleet Operations

Exelon Generation uses a comprehensive management system, known as

the Exelon Nuclear Management Model, to manage its fleet of nuclear

plants.

The management model is documented in a suite of standardized policies,

programs and procedures but its success is driven by a strong leadership

team and effective independent oversight.

• Aligns the entire organization with a common vision, shared values, and a

passion for performance excellence and stretch goals

• Fosters a strong safety culture (nuclear, industrial, radiological, environmental)

• Efficiently implements technical solutions through a “design once, install many”

approach

• Uses Peer Groups to collectively drive initiatives and close performance gaps

- Ensure the transfer of best practices and knowledge across the fleet

- Drive continuous performance towards top quartile industry performance


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Exelon Nuclear Security

Established in 2008 due to poor performance at one of our stations

Brought the Security function internal to Exelon - opened up career paths,

promotional opportunities into other Site functions

Security Manager reports to the Site Vice President

Union representation varies depending on the Station

Consistent programs, procedures, organization, performance indicators, etc.

across the Fleet

Strong Corporate Security Organization

• Security Operations

• Access Authorization

• Programs


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Safety, Security, and Safeguards Culture

Exelon uses an integrated approach to promote safety, security

and safeguards at its nuclear facilities

• Safety - the measures used during the performance of all

activities to protect the reactor core, plant systems, and the

health and well-being of the public and Exelon employees.

Programs which contribute to achieving safety include:

- Fostering a Healthy Nuclear Safety Culture

- Maintaining a Safety Conscious Work Environment (SCWE)

- Industrial Safety Programs

48 This briefing is unclassified – no safeguards material will be discussed.

Safety, Security, and Safeguards Culture

• Security - the measures used to assure effective cyber

security, access control, prevention of radiological sabotage,

and prevention of the theft of special nuclear material at

nuclear facilities.

• Safeguards - the measures used (including security plans,

procedures, and equipment) for the physical protection of

source, byproduct, or special nuclear material in quantities

determined by the NRC to be significant to the public health

and safety or the common defense and security.

(Special Nuclear Material: material which can be made into a nuclear

explosive device – plutonium, uranium-233, or uranium enriched in U-233

or U-235)


What is Safeguards Information?

Information not classified as National Security Information or Restricted Data

which specifically identifies detailed control and accounting procedures for

the physical protection of Special Nuclear Material

Detailed security measures (including security plans, procedures, and

equipment) for the physical protection of nuclear material

Security measures for the physical protection of and location of certain plant

equipment vital to the safety of the facility

Any other information that could reasonably be expected to have a significant

adverse effect on the health and safety of the public or the common defense

and security by significantly increasing the likelihood of sabotage or theft or

diversion of source, byproduct, or Special Nuclear Material


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What Drives Nuclear Security in the United States?

Atomic Energy Act of 1954

Energy Reorganization Act of 1974

10 CFR 73 – Physical Protection of Plants and Materials

The Energy Policy Act of 2005

United States Nuclear Regulatory Commission (NRC)

Oversight

United States Department of Energy (DOE) Oversight

10 CFR 810 – Assistance to Foreign Atomic Energy Activities

Bilateral agreements (“123 Agreements”) between the

United States and other countries to allow the exchange of

reactor technology for peaceful purposes


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What Drives Nuclear Security Globally?

IAEA International Conventions and Legal Agreements • The IAEA is the world's center of cooperation in the nuclear field. The

Agency works with its Member States and multiple partners worldwide

to promote safe, secure, and peaceful nuclear technologies

• A chief function of the IAEA is to establish and administer safeguards

designed to ensure that special fissionable and other materials,

services, equipment, facilities, and information are not used in such a

way as to further any military purpose

IAEA NG-G-3.1, Milestones in the Development of a National

Infrastructure for Nuclear Power

• Section 3.2, “Nuclear Safety”

• Section 3.6, “Safeguards”

• Section 3.15, “Security and Physical Protection”


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Nuclear Facility Security

Commercial nuclear power plants have a series of physical

barriers, a trained security force, specific access

authorization criteria, and an ongoing fitness-for-duty

program

Three primary areas of vulnerability: controls on the nuclear

chain reaction, cooling systems, and spent fuel storage

facilities

After the events of 11 September 2001, Nuclear Security was

elevated as a focus area for combating the threat of nuclear

terrorism so as to prevent radiological sabotage – a

deliberate act against a plant that could directly or indirectly

endanger public health and safety through exposure to

radiation


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Nuclear Facility Security (Continued)

Nuclear employees

• Prior to employment, subject to:

– Background Investigation that includes both a criminal

history and credit check

– Fitness For Duty screening

– Clinical/psychological evaluation

– Physical Fitness Test for Security Officer Candidates

• While at work, you are a part of a Behavioral Observation

Program, random Fitness-for-Duty testing and periodic

renewal of background checks and clinical evaluation


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To gain access to a U.S. nuclear facility

• All commercial deliveries inspected

• Personal vehicle search/inspection

• Personnel pass through explosive and metal detectors

• Hand carried items undergo X-ray and random search

• Alarming any detector or failure to follow process results in

a hand pat down search


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To ensure intruders do not

enter

• Multiple vehicle barriers

• Multiple layers of razor fencing

• Intrusion detection prior to

entry

• Camera systems

• Video monitoring

• Armed Officer patrols and

surveillance


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Cyber Security

10 CFR 73.54, “Protection of Digital Computer and Communication

Systems and Networks”

Reg. Guide 5.71, “Cyber Security Programs for Nuclear Facilities”

Elements include:

• Multiple fire walls

• Data Diodes

• Tours and controls of Critical Digital Assets

• Maintenance and tracking protocols for interface with Critical Digital

Assets

• Data Loss Prevention Program

• User understanding and engagement



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“At the Ready”

Periodic Training is Essential

•Integrated into normal shift rotation

Triennial Force-on-Force

exercises

Hostile Action Drills – taking

EP drills to the next level

Local/state/federal agency

participation


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Nuclear Security: Fundamental Beliefs of Leadership

Safety Culture…… “An organization’s values and behaviors modeled by

its leaders and internalized by its members that serve to make nuclear

safety the overriding priority.”

Nuclear safety is a collective responsibility. No one in the organization is

exempt from the obligation to ensure safety first.

Leadership has a critical role for maintaining an unwavering commitment

to nuclear safety – which includes periodic assessments of the health of

the Safety Culture in their organizations

Nuclear safety is our overriding priority


Nuclear Security - Leadership Obligations

Communicate the importance of

Security in protecting and

safeguarding the nuclear facility

• Nuclear technology is recognized as

special and unique

Set the vision and standards

Establish the appropriate

resources – both personnel and

monetary

Include Security as part of the

Team


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Nuclear Security - Leadership Obligations (Continued)

Demonstrate Support

• “Walk the Talk”

• Follow all security policies and

procedures

• Maintain equipment and facilities

• Meet with security personnel to

actively seek out their opinions and

concerns

• Follow up on concerns to ensure

that they are resolved in a timely

manner

• Value the individuals and their roles in

the organization


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What is a “Security Culture?”

“The superior man, when resting in safety, does not forget that

danger may come. When in a state of security he does not

forget the possibility of ruin. When all is orderly, he does not

forget that disorder may come. Thus his person is not

endangered, and his States and all their clans are preserved.”

- Confucius


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Documents

International Safeguards Culture - NAYGN