ML17270A062

Comment (2) of Greg Cameron on Behalf of Nuclear Energy Institute Identifying and Reporting Human Performance Incidents

ML17270A062
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/21/2017
From:	Cameron G Nuclear Energy Institute
To:	Cindy Bladey Rules, Announcements, and Directives Branch
References
82FR39915 00002, NRC-2017-0181
Download: ML17270A062 (3)

Text

Page I of I As of: 9/26/17 11 :25 AM C).tJ/7 Received: September 21, 2017

. Status: Pending Post PUBLIC SUBMISSIQ~sEP 20 AM 11: 3L; Tracking No. 1kl-8ysq-zhqy Comments Due: September 21, 2017 Submission Type: Web Docket: NRC-2017-0181 pr=r:!=l\/!=D Identifying and Reporting Human Performance Inddehl"s .._... . . 1. __

Comment On: NRC-2017-0181-0001 Identifying and Reporting Human Performance Incidents; Draft Regulatory Issue Summary for Comment Document: NRC-2017-0181-DRAFT-0003 Comment on FR Doc# 2017-17678 Submitter Information Name: Greg Cameron Poz-/00/7 Organization: Nuclear Energy Institute E£r0 87p0-General Comment See attached file.

Attachments 09-21 NRC- NEI Comments on Draft RIS 2017-xx IDENTIFYING AND REPORTING HUMAN PERFORMANCE INCIDENTS SUNSI Review Complete Template =ADM - 013 E-RIDS= ADM-03 Add=~- rrcvrv/._~v Ce!Jtf r 3)

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GREGORY R. CAMERON Senior Project Manager, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004

~I NUCLEAR ENERGY INSTITUTE P: 202.739.8105 grc@nei.org nei.org September 21, 2017 Ms. Cindy K. Bladey Chief, Rules, Announcements, and Directives Branch (RADB)

Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

NE! Comments on Draft Regulatory Issue Summary (RIS) 2017-XX, Identifying and Reporting Human Performance Incidents, 82 FR 3991~ Docket ID NRC-2017-0181 Project Number: 689

Dear Ms. Bladey:

On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1 appreciates the opportunity to

. provide comments on the subject RIS 2017-XX, "Identifying and Reporting Human Performance Incidents,"

as requested in the subject Federal Register Notice.

The industry takes seriously any plant events which require a Licensee Event Report (LER) in accordance with 10 CFR 50. 73, including those events which involve aspects of human performance as a root or contributing cause. Depending on the complexity or severity of the event, plants utilize a variety of evaluative tools to understand the impact of human performance and take corrective actions as necessary.

The industry shares the results of these evaluations openly with the NRC not only by inclusion in the LER but also by providing other documents and discussions in order to support the agency's review of these matters.

The draft RIS appears to set a new standard for the level of information required in LERs to support the Human Factors Information System without sufficient justification. The RIS relies on just two examples and identifies the need for additional information in only one (labeled "Example Two" in the RIS). Example Two 1

The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

NUCLEAR. CLEAN AIR ENERGY

• Ms. Cindy K. Bladey September 21, 2017 Page 2 describes an event with a procedural deficiency as a root cause, and the associated LER provides a detailed narrative of those procedural deficiencies and corrective actions. Personnel error is not a root cause of this event; human performance-related contributing causes are "discussed as appropriate" in accordance with the requirements of NUREG-1022, "Event Reporting Guidelines: 10 CFR 50.72 and 50.73".

Example Two should be removed from the RIS and replaced with a more applicable event with a human performance-related root cause. Furthermore, the NRC should re-evaluate the need for a RIS which is only supported by one example of inadequate information.

It is important to note that LERs are reviewed and closed by resident and regional inspectors with full access to supporting evaluations and documents used as source material for the LER. Closure of the LER indicates that an acceptable level of information has been provided. The draft RIS may* be interpreted to create new expectations or an additional level of review without justification.

We encourage the NRC to reconsider the need for this draft RIS given the lack of applicable examples of inadequate performance and the sufficiency of existing information available to the agency as part of the LER review process. If you have any questions concerning these industry comments, please contact me.

Sincerely, Gregory R. Cameron