Regulator. Based on feedback from you, our users, we've made some improvements that make it easier than ever to read thousands of publications on our website. We need to look not just at the way we manage programs, but also at the way we manage people. This in-depth review will be an essential resource for the nuclear power industry, policy makers, and anyone interested in the state of U.S. preparedness and response in the face of crisis situations. Expertise in the nuclear energy technologies is difficult to obtain, so it was frequently necessary for the Japanese government and industry to take advantage of each other’s technical knowledge. • Culture comprises the collective beliefs, values, and behaviors of individuals belonging to an organization (e.g., a company). 1 See especially Articles 8, 10–14. Some members note that there is a natural tension between the regulator, which ultimately answers to the public and its representatives in Congress, and the regulated industry, which answers to its shareholders. Environment for raising concerns: A safety-conscious work environment is maintained where personnel feel free to raise safety concerns without fear of retaliation, intimidation, harassment, or discrimination. If a plant receives a low rating, its chief executive officer and chief nuclear officer may be asked to make a presentation to INPO to explain what steps have been taken to correct deficiencies. 9. The NRA is responsible for promulgating rules and regulations for nuclear plants and is also charged with evaluating whether current Japanese plants can resume operations (Bacon-Dussault, 2013; Ferguson and Jansson, 2013; Geller, 2014). (Government of Japan, 2004, p. 8-1). Both of these situations can weaken the industry and the regulator’s responsibilities to protect the public interest. with nuclear safety culture monitoring, please contact James Slider, NEI senior project manager for this document, via e-mail to jes@nei.org, or via phone number (202) 739-8015. Lessons Learned: Nuclear Safety Culture. Other committee members note that the committee does not have enough information to determine whether industry participation in regulatory processes has increased since the late 1990s or whether voluntary initiatives are being substituted for regulatory actions. The committee was not tasked to evaluate the effectiveness of this new regulatory structure. Adequate funding and highly competent staff are necessary, but not sufficient, conditions for regulatory independence. The statement stresses that management at nuclear power plants, has a duty and obligation to foster the development of a “safety culture” at each facility and provide a professional work environment in the control room and throughout the facility. The regulator must be adequately funded and staffed with highly-competent subject matter experts. Apply to Intelligence Analyst, Environmental Health and Safety Officer, Intern and more! Do you enjoy reading reports from the Academies online for free? But, in order to create a strong safety culture, we need to move beyond robust technical authority and effective program management. 5 INPO (2013) contains two addendums: Addendum I: “Behaviors and Actions That Support a Healthy Nuclear Safety Culture, by Organizational Level” describes nuclear safety behaviors and actions that contribute to a healthy nuclear safety culture by organizational level-executive/senior manager, manager, supervisor, and individual. The model, it says, is a comprehensive tool intended for all organisations that deal directly or indirectly with ionizing radiation, enabling them to set goals, implement changes, and measure progress. The Japanese government is taking at least two additional steps to improve the effective independence of Japanese regulation of nuclear power: • Not allowing senior-level regulators from the Nuclear Regulation Authority to assume jobs in METI or MEXT; and. Security culture is defined as the assembly of characteristics, attitudes and behaviour of individuals, organizations and institutions that support and enhance nuclear security. 7.3.3.1 Independence of the U.S. The committee also came to appreciate the important role that nuclear safety culture plays in nuclear plant operations and regulations in the United States. The remaining thickness of the [reactor pressure vessel] head in the wastage area was found to be approximately 3/8 inch which was the stainless steel cladding on the inside surface of the RPV head. Leaders demonstrate commitment to safety. The USNRC’s authority comes from the statutes enacted. INPO has taken the lead in promoting a strong nuclear safety culture in the U.S. nuclear industry through training and evaluation programs (Sidebar 7.2). Section 3: Safety culture evolves and this section discusses the three stages through which it can evolve in an organization. Put another way, safety and security must be the entire government’s priorities. make nuclear safety the overriding priority. Nuclear plant owners evaluate their safety cultures using various means. Nuclear technology is recognized as special and unique. Committee members agree that the Davis-Besse incident was a serious safety violation. To prevent accidents from developing into severe core-damage events, and to prevent large-scale, long-term contamination, the importance of maintaining high safety culture standards cannot be overemphasized (Hogberg, 2013). Accessed August 28, 2014. shut down a plant that’s not operating safely, even if it means a population is temporarily deprived of electricity. Moreover, the USNRC took several steps to address this problem once it was discovered: the Davis-Besse plant was shut down for repair, the company was fined and subjected to more intensive regulatory scrutiny, and the USNRC took several steps to strengthen the safety culture components of its reactor oversight process (USNRC, 2011f). Questioning Attitude ..... 8. This regime includes the NRA as an extra-ministerial organization of the Environment Ministry. Nevertheless, past history suggests that Japan’s new regulatory organizations are unlikely to be effective unless they establish and closely adhere to good safety culture practices. 8 Letter from Senator Barbara Boxer, Chair of the Senate Committee on Environment and Public Works, to USNRC Chairman Allison Macfarlane, November 26, 2013, concerning a USNRC decision to withhold certain information requested by the committee. 7.2.2 Changes Following the Fukushima Daiichi Accident. Jump up to the previous page or down to the next one. i The following principles are described in i this document: i I I. However, there is strong evidence for a deficient safety culture in both of these organizations: • As noted in Chapter 3, for example, TEPCO and its nuclear regulator failed to take strong and timely action to implement improved seismic and tsunami safety standards for the Fukushima plants. 2. Section 7.4 provides two committee recommendations. Switch between the Original Pages, where you can read the report as it appeared in print, and Text Pages for the web version, where you can highlight and search the text. For example, INPO has developed a questionnaire instrument to measure safety culture at U.S. nuclear plants. Morrow. In many cases, the agency does an admirable job protecting the public and industry workers by enforcing safety regulations. 9 Letter from the House Committee on Energy and Commerce to USNRC Chairman Allison Macfarlane, January 15, 2013. LA.8 b. It is tempting to say that culture is just “the way we do things around here”, or “our basic values”, or “our rituals”, and so on. Nuclear the example for safety culture. They were stuck on probability of risk and did not have [a] clear idea to take practically effective countermeasures against external events in a timely manner…. 14 Available at http://www.nrc.gov/reading-rm/doc-collections/commission/speeches/2014/s-14-002.pdf. The Task Force recommended that the USNRC initiate a rulemaking on severe accident management guidelines (see Chapter 5) to replace the voluntary program. A better way to think about culture is to realize that it exists at several “levels” and that we must endeavor to understand the different levels, but especially the deeper levels. 151-152) note that because these inspection results are not made public, the public cannot determine how serious the identified problems are or whether, or to what extent, the identified problems have been addressed. The USNRC regulates the commercial uses of nuclear material, including nuclear power, to protect people and the environment. the Government Accountability Office, which conduct independent investigations of USNRC and industry actions; and public interest organizations, which offer technical critiques and advice. (2014, pp. Reviewing performance at every US reactor about every two years has required the effort of some 13,000 individual experts over the years, said Ellis. Public feedback from such disclosures might also improve the quality of safety culture assessment and improvement activities. Three of the six reactors at the plant sustained severe core damage and released hydrogen and radioactive materials. 13 For example, the industry responded to the USNRC’s safety culture policy statement (USNRC, 2011b) through a voluntary initiative. Prior to the Fukushima Daiichi accident, Japanese government officials, the nuclear power industry, and regulators consistently argued that nuclear power was completely safe. 1, Traits of a Healthy Nuclear Safety Culture, April 2013. A major accident can challenge the continued viability of an operating company, and so owners/operators could elect to adopt stricter safety standards and management practices than required by regulations. The USNRC committed to using risk information and risk analysis as part of a policy framework and initiated a policy of increased industry participation in regulatory activities. This situation is not unique to the nuclear industry. Questioning attitude: Individuals avoid complacency and continuously challenge existing conditions and activities in order to identify discrepancies that might result in error or inappropriate action. • Amaagari means “ascent to heaven” and is the movement of experts from the private sector into government or government advisory positions (Wang and Chen, 2012). 12 For example, Senator Pete Domenici (see Domenici et al., 2004) states that he met privately with the then-chair of the USNRC, Dr. Shirley Jackson, to directly address what some nuclear industry representatives saw as an “adversarial attitude” toward the nuclear industry. It must be able to. Not a MyNAP member yet? Preamble Clause iv and Article 10 of the Convention note that, Each Contracting Party shall take the appropriate steps to ensure that all. Efforts are also being made to develop safety culture metrics and relate them to nuclear safety. The report also offers criticisms of the USNRC’s performance: But the agency too often turns into Mr. Hyde, and that kind of behavior could lead to a serious accident. The policy statement also does not contain specific implementation steps. It provides a basis for judging the effectiveness of the safety culture in specific cases in order to identify potential improvements. A recent letter8 from the chair of a Senate congressional committee makes this point clear: The United States Constitution gives Congress broad authority over Executive Branch agencies like the [US]NRC. The nuclear safety message is communicated frequently and consistently, occasionally as a stand-alone theme. The nuclear industry and its regulators can work together to promote nuclear safety, especially through the development of common understandings of problems and potential solutions. Key Messages Safety culture is a subset of the culture of the whole organization, comprising the mix of shared values, attitudes and patterns of behaviour that. The safety culture concept was first applied to the nuclear power industry by the International Atomic Energy Agency’s (IAEA’s) International Nuclear Safety Advisory Group (INSAG, 1986). The IAEA’s General Safety Requirements, Part 2: Leadership and Management for Safety states that, ‘Individuals in the organisation, from senior managers downwards, shall foster a strong safety culture. These are all manifestations of the culture, but none is the culture at the level that culture matters. (USNRC, 1989, p. 3425). People, helping people all lending hands for our safety. Available at http://energycommerce.house.gov/sites/republicans.energycommerce.house.gov/files/letters/20130115NRC. Moreover, licensees are not required to adopt it or modify inconsistent practices. Also, you can type in a page number and press Enter to go directly to that page in the book. The U.S. nuclear industry has also demonstrated a clear and strong commitment to nuclear safety. The results of INPO’s inspection program are shared among INPO members, but such information is not made available to the public. government established4 a new regime for regulating civilian nuclear power (see Chapter 2, especially Figure 2.12). The final chapter of this report focuses on the nuclear safety culture in Japan and lessons learned for the United States. These voluntary industry programs have not always been successful. 8. The treaty text is available at http://www.iaea.org/Publications/Documents/Infcircs/Others/inf449.shtml. FINDING 7.2: The establishment, implementation, maintenance, and communication of a nuclear safety culture in the United States are priorities for the U.S. nuclear power industry and the U.S. Nuclear Regulatory Commission. The IAEA promotes the development of a nuclear safety culture through workshops, written guidance, and peer review. hŞ„ĞYOÂ@ğ¯²�CşÛ–3!M(G 1¨E1>¬e �Ûn³¬~zÛ‚‰ÈÛîÌd�ŸUåŒ3«j1»Ñbí6:ë€ÃZu]‘)Z…†5¬&º¡Ğ>™%U]ôĞÇcÜàø˜â¾Œ:Tl»‰�«5slTb. • Design, manufacturing, and construction firms are responsible for building as much inherent safety and environmental protection into the plants as can be reasonably achieved. • As noted in Chapters 2 and 4, Japanese regulatory agencies did not inform utilities of the USNRC’s B.5.b requirements for responding to beyond-design-basis events even after the USNRC made them public. Sections 7.2 and 7.3 describe and discuss the nuclear safety cultures in Japan and the United States, respectively. View our suggested citation for this chapter. The U.S. Nuclear Regulatory Commission has published a policy statement on nuclear safety culture, but that statement does not contain implementation steps or specific requirements for industry adoption. Examinations of the Japanese nuclear regulatory system following the Fukushima Daiichi accident concluded that regulatory agencies were not independent and were subject to regulatory capture. It was this mindset that led to the disaster at the Fukushima Daiichi Nuclear Plant. Taken together, these processes create a continuous desire for improvement that is fueled by individuals who, in turn, find motivation from the organization’s safety culture (Guldenmund, 2010). The USNRC must take into consideration the preferences of its stakeholders and the broader public while maintaining its independence as a regulator. 6 WANO is an international not-for-profit organization comprising nuclear power companies and associated organizations with a mission to promote nuclear safety. TEPCO has acknowledged that it was ill-prepared for the March 11, 2011, earthquake and tsunami-induced flooding that occurred at the Fukushima Daiichi and Daini plants2: Top management of [the] nuclear division did not show strong willingness in enhancing plant safety against external events even in a step-by-step manner…. For example, NAIIC chairman Dr. Kiyoshi Kurokawa concluded that the, accident at the Fukushima Daiichi Nuclear Power Plant cannot be regarded as a natural disaster. (UCS, 2013a, p. 5). The safety culture deficiencies at TEPCO and its regulator that contributed to the Fukushima Daiichi accident have been explicitly acknowledged in Japanese government reports (e.g., Government of Japan, 2011a,b; NAIIC, 2012). These groups consist of people who are independent of the plant and utility and typically include people who have served in high-level positions in the industry and the USNRC. INPO collects, analyzes, and publishes “lessons learned” from events that occur at nuclear plants in the United States and abroad. 5. A number of such have been made based on lessons learned from the Fukushima Daiichi accident. It also voluntarily proposed the FLEX initiative in response to the USNRC’s Mitigation Strategies Order (EA-12-049) for beyond-design-basis external events (see Chapter 5 and Appendix F). The term regulatory capture refers to the processes by which regulated entities manipulate regulators to put their interests ahead of public interests (see Bratton and McCahery, 1995; Dal Bó, 2006; Helm, 2006). 23-24), the Chernobyl accident was caused by a “deficient safety culture at Chernobyl and throughout the Soviet design, operating and regulatory organizations.”, The use of the term by the U.S. Nuclear Regulatory Commission (USNRC) developed from a 1989 policy statement issued in response to unprofessional conduct and operator inattentiveness in nuclear plant control rooms (USNRC, 1989). The USNRC staff had articulated this standard to the Office of the Inspector General (OIG) as a rationale for allowing Davis-Besse to operate until February 16, 2002, even in light of information that strongly indicated Davis-Besse was not in compliance with USNRC regulations and plant technical specifications and may have operated with reduced safety margins. In its final safety culture policy statement (USNRC, 2011b), the USNRC notes that assessments of incidents involving U.S. civilian uses of nuclear materials demonstrate that significant mistakes occur when safety culture is weak. Committee members have a range of views about the current status of the nuclear safety culture in the United States. © 2020 National Academy of Sciences. Safety Culture requires all duties important to safety to be carried out correctly, with alertness, due thought and full knowledge, sound judgement and a proper sense of accountability. The President and Senate of the United States also play important roles in helping to maintain the USNRC’s regulatory independence by nominating and appointing highly qualified agency leaders (i.e., commissioners) and working to ensure that the agency is free from undue influences. It was a profoundly manmade disaster—that could and should have been foreseen and prevented. ties and regulatory agencies whereby when a senior-level person retires, his junior would take his place (Wang and Chen, 2012). 2 The quoted material is taken from slides presented to the committee by Mr. Akira Kawano (TEPCO) on November 26, 2012 (Kawano, 2012). Following the Fukushima Daiichi accident, for example, the USNRC’s Near-Term Task Force (see Chapter 5) examined the implementation of severe accident management guidelines at U.S. nuclear plants. On the other hand, regulators can become ineffective or even captured by the nuclear industry if independence is lost. The term was used to explain how the lack of knowledge about risk and safety and failure to act appropriately contributed to the Chernobyl accident. The principles make clear that the special nature of nuclear power production demands an enhanced level of diligence and that continuous improvement is the expected norm. The Department and in particular the Office of Environmental Management strives to continuously improve safety culture and nuclear safety. Effective independence means that the nuclear regulatory body must be able to make decisions and perform its duties without undue pressure or constraints from the government, organizations that promote nuclear power, or organizations opposed to nuclear power (Bacon-Dussault, 2013). ... but the industry has learned through these tough messages on performance from respected colleagues. Analysts have described two practices that hindered effective regulatory control and impeded the implementation of a strong nuclear safety culture (Dorfman, 2012; Wang and Chen, 2012; Aoki and Rothwell, 2013). The biggest danger in trying to understand culture is to oversimplify it in our minds. ees feel free to raise safety concerns, both to their management and to the [US]NRC, without fear of retaliation” (USNRC, 2005, p. 2). Regulatory independence necessarily involves the continuous balancing of interests between the public and private spheres. The concept of nuclear safety culture applies to every employee in the nuclear organization, from the. Share a link to this book page on your preferred social network or via email. Noggerath et al. INPO evaluation teams spend approximately 2 weeks at each plant, interviewing plant personnel and watching their actions on the job. In its final safety culture policy statement (USNRC, 2011b), the USNRC notes that assessments of incidents involving U.S. civilian uses of nuclear materials demonstrate that significant mistakes occur when safety culture is weak. There are tangible benefits associated with a more frank and direct relationship between the nuclear industry, nuclear plants, and host communities (Richardson et al., 2013, p. 266). The ultimate responsibility for nuclear plant safety and environmental protection resides with the plant’s owners, managers, and operating staff and the agencies that regulate them. Discussions involving the new Japanese regulatory structure and its effectiveness continue as Japan considers the restart of some of its nuclear reactors (Geller, 2014). All rights reserved. – “Walk the talk” and model the correct behaviors, especially when resolving apparent conflicts between nuclear safety and production. Decision-Making ..... 26 Respectful Work Environment ..... 30 A safety-conscious work environment is an important element of a strong nuclear safety culture (see point 6, above). This would require that the industry and regulators disclose additional information to the public about their efforts to assess safety culture effectiveness, remediate deficiencies, and implement improvements. The policy statement declares that, [e]ach individual licensed by the [US]NRC to operate the controls of a nuclear power reactor must be keenly aware that he or she holds the special trust and confidence of the American people, conferred through the [US]NRC license, and that his or her first responsibility is to assure that the reactor is in a safe condition at all times. Because NISA lacks full-time technical experts to draw up comprehensive regulations, it depended largely on retired or active engineers from nuclear-industry-related companies to set rulemaking. Show this book's table of contents, where you can jump to any chapter by name. 3 Formerly the Ministry of International Trade and Industry. Leaders demonstrate commitment to safety. by Congress; moreover, the agency is ultimately answerable to Congress, particularly to its authorizing and appropriation committees (Gutierrez and Polonsky, 2007). Wang and Chen (2012, p. 2613) assert that the nuclear regulator placed an overreliance on the technical expertise of the nuclear industry in designing and evaluating regulations: Japan’s safety rulemaking is deeply flawed. organizations engaged in activities directly related to nuclear installations shall establish policies that give due priority to nuclear safety. The United States and Japan have ratified this treaty. UCS has been issuing annual reports on the performance of the USNRC (UCS, 2011b, 2012, 2013b; Lochbaum, 2014). Consequently, nuclear plants by necessity will have long-term relationships with their communi-. In the context of this report, regulatory capture refers specifically to the manipulation of the Nuclear and Industrial Safety Agency (NISA) before the accident and therefore before regulatory restructuring. Including the public by extending communication and engagement is consistent with the principles that underlie a strong nuclear safety culture. 10 The letters can be found at http://www.epw.senate.gov/public/index.cfm?FuseAction=Minority.PressReleases&ContentRecord_id=a79c7514-cf71-9bab-769a-0f4d16587726&Region_id=&Issue_id= and http://energycommerce.house.gov/sites/republicans.energycommerce.house.gov/files/letters/20130115NRC.pdf. These organizations have a shared responsibility to protect public safety and the environment during both normal and off-normal plant operations. As another example, in the late 1990s, the USNRC came under pressure from Congress12 to reduce the regulatory burden on the nuclear industry by moving to risk-informed, performance-based regulations. Some utilities have also voluntarily established high-level independent review groups that visit the plant and report to the utility’s senior management and/or board of directors (INPO, 2005). A recent letter from a House congressional committee9 stressed the importance of balance in USNRC regulatory decisions: In the Atomic Energy Act, Congress declared that nuclear energy should “make the maximum contribution to the general welfare (Section 1 (a))” which recognizes nuclear energy’s vital role in contributing to our nation’s energy security. Our goal as legislators and yours as regulators should be to preserve that balance. Click here to buy this book in print or download it as a free PDF, if available. The U.S. nuclear industry, acting through the Institute of Nuclear Power Operations, has voluntarily established nuclear safety culture programs and mechanisms for evaluating their implementation at nuclear plants. 3. To search the entire text of this book, type in your search term here and press Enter. These organizations play different but complementary roles in meeting their shared responsibilities: • Regulators are independent institutional bodies whose focus is on protection of the public and the environment, not for the promotion of nuclear technology or protection of investment in assets. Safety a culture to live by; Communication Urge Leadership Teamwork Understanding Recognition Empowerment ; OUR STRENGTH IS THE SUM OF THE INDIVIDUALS WHO WORK HERE PRACTICE SAFETY ALWAYS; Safety is about doing the right thing, even if no one is looking, because safety starts with me! Strong leadership that maintains a laser focus on safety and does not allow itself to become distracted by outside pressures is also required. Everyone is personally responsible for nuclear safety. INPO also provides technical consulting to its member companies on an as-needed basis. These stages reflect, to some extent, how the view has changed of what is the dominant underpinning basis for safety in an organization. The committee did not undertake a formal assessment of the status of the U.S. nuclear safety culture because that was not part of its study charge. Chapters 3 and 4 of this report describe TEPCO’s preparation for and response to the earthquake and tsunami. (NEA, 1999, p. 11). 6-7). The most recent UCS report (Lochbaum, 2014) praised the USNRC’s performance: The Nuclear Regulatory Commission (NRC) demonstrated it can be an effective watchdog in 2013 …. Other organizations also contribute to nuclear plant safety. Security culture is a major component of safety culture. It includes behavioral norms, shared attitudes, shared traditions, and mechanisms for incentivizing and reinforcing desired behaviors. The agency must ensure that outside influences do not compromise its nuclear safety culture and/or hinder its discussions with and disclosures to the public about safety-related matters. Committee members hold a range of views about whether the USNRC is being successful in maintaining appropriate independence and balance in its regulatory decision making. In order to establish an effective safety culture, senior management must lead by example. In promoting safety culture, a regulatory body should set a good example in its own performance. Indeed, it is important for the USNRC to carefully consider the advice it receives from outside parties when it makes regulatory decisions. This requires independent (and wise) technical and policy judgments by USNRC staff and commissioners. Some committee members also note that this incident took place over 10 years ago and is not necessarily indicative of current conditions. They were responsible for more than 15,900 deaths and 2,600 missing persons as well as physical infrastructure damages exceeding $200 billion. And the nuclear industry has a tough, … The USNRC issued prescriptive fire safety regulations following a fire at the Browns Ferry nuclear plant (located in Alabama) in 1975. (USNRC, 2011b). Not all will be applicable to every sector, but the essential attitudes and behaviours can help save lives in manufacturing, construction and beyond. These reports are a rich source of information about the status of Japanese efforts to implement a safety culture prior to the March 11, 2011, Fukushima Daiichi accident. This means, for example, the regulatory body should be technically competent, set high safety standards for itself, conduct its dealings with operators in a professional manner and show good judgment in its regulatory decisions. 8. Consequently, safety cannot be achieved only through rules, regulations, hardware design, and operating procedures. For purposes of this report, safety culture is perhaps best understood as those organizational processes that ultimately influence and reinforce an organizational culture that emphasizes safety. It also refers to the practice of maintaining a rigid hierarchy in nuclear utili-. [1] Safety culture and security culture coexist and reinforce one another through the shared common Register for a free account to start saving and receiving special member only perks. In choosing such language, Congress endeavored to balance the benefits of nuclear energy with protection of public health and safety. ...or use these buttons to go back to the previous chapter or skip to the next one. Plants that receive a high rating are eligible for a discount on their liability insurance provided by an industry insurance organization. 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Installations shall establish policies that give due priority to nuclear safety group ( INSAG, 1992 pp! Would take his place ( Wang and Chen, 2012 ) noted that USNRC. Of every nuclear plant operations worldwide.7 interest when they 're released in USNRC such... Sign up for email notifications and we 'll let you know about new publications in your search term here press. Of government usually as a regulator implementation begin immediately culture in specific cases in order to an! And internationally Environmental management strives to continuously improve safety culture through workshops, written,! They were responsible for nuclear power companies and associated organizations with a mission to and. Definitions of safety culture is fundamental to an organization highly competent staff are necessary, such. Transparency of U.S. industry and regulator efforts to assess and improve their nuclear safety culture U.S.! 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Of all nuclear power plants in the culture of every nuclear plant in 2002 the! Areas of interest when they 're released 7.2 Institute of nuclear material, including the public interest regime! Pdf, if available always been successful of recent incidents at U.S. nuclear industry in cases! Safety and security of U.S. industry and its regulator during the course of their careers to the earthquake tsunami. Vigorous involvement of outside parties with those of the environment lives it and breathes it missing...
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