ML18018B591
| ML18018B591 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/05/1984 |
| From: | Pearson R North Carolina State University, RALEIGH, NC, Advisory Committee on Reactor Safeguards |
| To: | Kerr W, Major R North Carolina State University, RALEIGH, NC, Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-CT-1716, NUDOCS 8403160085 | |
| Download: ML18018B591 (17) | |
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North Carolina State Univeyity,-:.
School of Engineering Department of industrial Engineering Box SS>>
~ Raleigh, itt.c. argo January 5,
1984 MEMORANDUM FROM:
SUBJECT:
Richard Major, Senior Staff Engineer W. Kerr, Chairman, ACRS Shearon Harris Subcommittee Richard G. Pearson, ACRS Consultant ACRS SUBCOMMITTEE MEETING ON SHEARON HARRIS NPP, UNIT 1, APEX r N
C ~ s JANUARY 3 4 r 1 984 The following sections contain my comments on the site visit and operat-ing license hearing.
1.
My impression is that the physical aspects of construction and operation were generally addressed in a satisfactory manner.
- However, I
was most disappointed in the applicant's response (or lack thereof) to questions relating to the "human" (behavioral) side of the picture.
The reason for this is obvious to me.
In keeping with characteristic organization structures of utilities (which I view as unfortunate) manage-ment expertise, as per CP 6
L organizational
- charts, is represented ex-clusively by personnel with engineering and physical science credentials.
For example, the visibility of such important functions relative to operations as Personnel,
- Medical, and Human Factors Engineering are not identified in any of the organizational charts for the Harris Nuclear Project.
Accordingly one might conclude that such functions are not im-portant to organizational effectiveness.
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- 2. 'he SALP was most critical, and repeatedly so, of management control.
Frequent cases of management oversight were cited.
The theme throughout this document reflects poor coordination and communication by management.
I am not convinced at this point that the efforts by current management to rectify this situation will prevail.
The revisions in organizational structure may be cosmetic.
If the main issue is "people problems",
then I see considerable weakness in this utility's management in terms of a corporate commitment to good personnel practices, human re-source development, and human factors engineering.
You will recall that, when I addressed questions to the utility spokesman in these
- areas, the answer was often referred to someone else in the room for response; often the response was inadequate (recall that on Tuesday they said they had an M.D. on staff; on Wednesday they corrected themselves to say they did not).The utility relies heavily n co s'ultants in the areas mentioned above; it was unfortunate that the consultants (e.g.
Essex) were not represented, or called upon to make presentations.
Notwithstanding I
conclude that the utility itself lacks on-board expertise in these areas to understand and evaluate what their consultants are doing -- whether BZSlGNATED OR1GyNAT; Oe&H'gati R~
North Carolina State Universtfy is tttort~arttt' i inal land-grant institution and is a constituent institution of The University of Nort aiPf~
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memorandum competent support is being provided, etc.
Again, recall the emphasis on "man-machine systems" given during the plant tour; this was not reflected in the presentation at the hearing.
3.
As you may have concluded, I was frustrated in trying to determine the nature of CP 6 L's current human factors engineering effort.
The utility acknowledges that it does not have a person on staff with formal training in this field.
It has relied, in the past, on support from the Essex Corporation.
The Essex group identified for work done 2 to 3 years ago was comprised of some good personnel as known personally by me.
- However, as I understand it, that contract terminated, and the utility operated for a time without such support.
Apparently a new contract now exists with Essex, but many of the people associated with the earlier effort are no longer with Essex.
This firm (Essex) has undergone con-siderable growth in the last two years, thru acquisition and thru expansion of contractual activity with government agencies and DOD departments; several new quality H/F types are now associated with Essex.
To what extent is this expertise devoted to the new contractual effort with CP 6
L2 4.
There is some evidence of good human engineering in the control room panel
- design, but I presume this was due to Westinghouse efforts (Westinghouse has some good H/F types associated. with its efforts).
How-ever, other H/F efforts, which the utility purports are involved in its
- design, are not in evidence so far.
In many areas visite'd during the site tour, anthropometric considerations were not evident, e.g. with regard to
- seating, workplace height dimensions, reach envelopes, etc.
The SALP was critical of the utility's performance at operating sites in the areas of procedures and maintenance.
Both of these areas could benefit from good H/F input.
H/F design for maintainability is relevant here, as is the "design" of maintenance procedures.
The use of two-column format in the operating procedures is a move in the right direction.
However, both operating and maintenance procedures could benefit from the incorporation of pictorials into the text, i.e.
show the display setting, control position
- response, hazard condition, test point, etc.
5.
I "am uneasy about the use of the flow diagrams as operating pro-cedures without validation under plant, operational, emergency conditions.
For one thing, I
am concerned about the size of type and its legibility.
With an aging work force I would be concerned about the near visual acuity of R/0's.
Parenthetically, I also have a concern about operators who wear bi-focals and the problem associated with reading of the overhead annunciators -- both when close to the panel and from a "distance".
I am also concerned regarding the relationshi'p between the flow diagrams and the cognitive skills of the operators.
Do they narrow one's focus to the point of compromising knowledge-based, diagnostic, problem-solving, decision-making, analytical skills2 Someone needs to have the big picture in mind.
Will the SPDS help2 How do the flow chart procedures and SPDS data interact2 6.
In the area of training, the utility emphasizes its technical and teaching skills.
What was not addressed is perhaps more important, i.e.
of the training program.
The ~oal is ~ualit personnel in operations and maintenance, and a reduction in potential for human error.
A recent, separate memorandum written by me for the ACRS Subcommittee on Human Factors addresses this issue; a copy is attached.
This memorandum also addresses
1
.Nemorandum the qualifications of the training manager in terms of a revised RG 1.8.
(which qualifications, as stated, I do not feel are adequate).
The CP 6 L training manager, it appears, would not meet proposed (or enhanced) quali-fications with regard to draft additions to 10 CFR Part 50.
In this same regard I would doubt that CP 6 L has the expertise to implement the "Systems Approach to Training that is embraced by the "306" package.
- 7..In the area of Selection the validity of psychological tests used by CP 6
L was not addressed.
Also, the qualifications of its consultant (Dr. Hoffie) were not presented.
While perhaps not pertinent to NRC licensing I wonder if the test battery is in accord with EEOC guidelines.
8.
The form provided by CP 6 L to me, which is purportedly used to evaluate on-the-job performance of operators, appears to be a standard, merit-rating, type of form for all "Non-Supervisor" personnel (copy attached).
Desirably, a performance appraisal approach should be used -- one that is based upon a task analysis for operators -- with items keyed to control room performance.
Such a good performance appraisal system can serve as a
criterion measure for validation of selection and training methods.
9.
Apart from my general concerns regarding the utility's organiza-tion and management (see further NUREG - 0731, "Guidelines for Utility Nanagement Structure and Technical Resources" )
I have considerable con-cern regarding the composition of the PNSC (Plant Nuclear Safety Committee) and of the ISEG.
In neither case is there evidence of direct representation by personnel whose prime concern is the "people" problems, i.e. personnel, medical, and human factors engineering.
For the sake of informed, creative solutions to people problems I would recommend that committee representation include personnel who can competently address such areas as human performance, selection, training program evaluation, medical
- problems, performance
- criteria, and human factors engineering.
Currently I see no expertise in these committees who can effectively address such performance determinants as vision of operators,
- noise, illumination, glare, work-rest schedules, shift schedules, stress and
- boredom, job performance aids, display factors, and control design.
10.
- Finally, I
am somewhat concerned about the quality ofthe NRC evaluation contributed to the SER (2 pages) in the areas of human factors engineering as per many of the points I have addressed above.
I sincerely hope that SER supplements will assuage these concerns.
In terms of H/F qualifications I note that with respect to membership in the U.S.
Human Factors Society, neither the NRC's Senior Human Factors Analyst (SER Appendix E), nor staff of LLNL who participated in the onsite audit, are so identifiable.
'I appreciate the opportunity to make my views known, and hope that both NRC staff and the utility will address my concerns at a future hearing with greater specificity.
Certainly I will want to see what the final control room and new simulator are like.
Attachments:
1.
Nemorandum, December 6,
1983, to ACRS Subcommittee on Human Factors, subject "Critique of '306'ackage".
2.
CP 6 L, Form 1559
a North Carolina State University School of Engineering l)l'pdrtrrt<'nt <<f Iii<hi<tridlErtt(in<<'ing 8<<q;<;fr. BJI< it(I<..'b (:.
-tip December 6,
1983 MEMORANDUM FOR:
Dave Ward, Chairman ACRS Subcommittee on Human Factors FROM'UBJECT'r.
Richard G. Pearson, ACRS Consultant "TRAINING NAhtAGER" UALIFICATIONS NOW'EMBER 30th
.'1EETING.
Insofar as this nackage embraces a systems approach to training at nucl'ear power plants I find it represents a most positive step in the specification of accepted and much needed human factors engineering methodologv for the industry.
However I do find major deficiencies in the package relative (a) to the inaporopriate (M
to the lov. level of educational requirements specified in the proposed revision of Reg.
Guide l.8.
My objections to these deficiencies are strong, and I wish my views, articulated below, to be presented to the ACRS Full Committee meeting on December 15-17, 1983.
The sections which prompt my concern need rtainr revision and strengthening before final approval of the package; otherwise the intent and success of implementation of the 306 package may be seriously compromised from its inception.
With regard to the items reviewed at our November 30th meeting my critique is as follows:
1.
Enclosure F
"Regulatory Analysis of Training and Qualifications Rule and Operator Licensing Examination Changes" (Analysis and Technolopv, Inc. report), while otherwise generally well done, contains no discussion (ser se) of the qualifications (and cost/impact) of a sualified training director/nanager on behalf of ~direct<a the proposed gAT effort.
This document
- does, however, admirably recognize (on p.
112) the existence of a "lack of personnel adequately trained and experienced in the implementation and operation of"...the systems approach to training.
The same para-graph concludes with the sentence:
"Hence, personnel experienced in these approaches represent a resource requirement constraint for the industrv."
I couldn't agree more with these two points.
My concern is that the utilities will use unqualified people in this critical job North Carnlinu Stat<'nit<frsity is Nnrth Curnlina's original land.grant institutinn
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0 Memorandum for'- Dave Ward, Chairman ACRS Subcommittee on Human Factors December 6, 1983 page 2
a )ob that should be given higher status in their organizations.
I am all too familiar with the FAA's practice of assigning "old" air traffic controllers to the )ob of center training director, and fear that utilities will assign "old" reactor operators or "new" nuclear engineers to this
)ob.
Special qualifications are needed, as I vill address below.
2.
Enclosure C, "Revised Regulatory Guide 1.8, Personnel Qualification and Training for Nuclear Power Plants."
Section 4.2e5 (Training Manager),
of the endorsed
- standard, ANSI/ANS-3.1-1981, is also of major concern, to me.
The section on education mentions "Bachelor degree including courses in education and technical sub)ects."
This is much too weak and non-
'specific as a specification for the expert person needed to do the )ob.
Further, I assert that the requirement for NPP operational experience in paragraph b is unnecessary, since a professional person qualified in train-ing program design,
- conduct, and evaluation can do the Job without the operational experience.
Such individuals (including myself) have proved their worth in industries across the country vithout having "relevant" operating experience.
Yes, it is important to "know the language," "learn the territorv," etc.,
to do a good fob but let's not put the cart before the horse!
- Besides, is it not assumed that the SAT program will have quali-fied R/0 personnel to aid in developing instructional (including simulator) material?
Section 4.4.7 of the standard answers this question in the affirmative 3.
Enclosure B, "The Application of. a Systems Approach to Qualifications and Training at Nuclear Power Plants."
The definition of "Training Specia-list (Instructional Technologist)" needs to be reworded and strengthened.
It should include such phrases as:
knowledge of the human learning and evaluation methods;
~knowled e of transfer-of-~trainin and of information m
mental descri tive and inferentia statistics Apart from my critique above I wish to elaborate on my vievs for the benefit of NRC Staff relative to the revisions which I feel are critical.
My comments are as follows.
l.
One of the ]ohs of 'the Training Director is that of ~Tralnln
~pro ram ~Deaf The attached flow diagram, taken from RDRRO-CR-2333 Volume 3, traces the many critical ingredients of a quality, necessary program for NPP operator training.
Note the emphasis upon such topics, as:
develop training devices; develop JPAs (Job Performance Aids);
developing training management svstem; and performance criteria (develop-ment).
Just these few topics alone indicate the need for a highly qualified professional with expertiee in training proFram design.
2.
The second attachment (Selection, Training, and Performance Relationships) should be readily comprehensible to any well-trained in-dustrial psychologist.
This diagram depicts, for example, necessary relationships (correlations) vhich should be computed in order to validate
Memorandum for: Dave Ward, Chairman ACRS Subcommittee on Human Pactors December 6,
1983 page 3
the effectiveness of various ingredients along the training path; for
'xample, the validity and difficulty of test items themselves, the reliability and validity of parallel forms of examinations administered to trainees, and the development of instructor rating forms and perfor-mance appraisals which effectively discriminate good trainees and operators from the "not-so-good" ones.
The goal is that positive correlations would obtain among all the pathways indicated.
Por the Training Director here the qualifications presume knowledge of: psychometric techniques; 'reliability and validity concepts; rating scale and performance appraisal evaluation methodologies; transfer-of-training concepts; and correlational and regression techniques.
In the behavioral sciences, these topics involve a ma)or amount of graduate-level study.
From the perspective of the Training Director we are talking here about evaluation skills which are a traditional concomitant to the ~desi n skills of an industrial psychologist.
That is.
one doesn'
~esi n a program (with ~predictor elements) without considering the evaluation of it (involving criterion elements).
3.
Finally, I feel it is important to clarify a distinction between the professional status appropriately attributed to B. S.
degree engineers, as contrasted with degrees in psychology', in the latter case, the professional "tag" is commonly attributed only to the holder of a Ph.
D. degree.
It takes (for most students) that level of education to acquire the necessary scientific (or clinical) skills.
The competent industrial psychologist will have had specialized courses in selection, training methods,
)ob
- analvsis, psychometrics, statistics, computer science, and survey techniques.
Precious few U. S. universities have quality program to produce such expertise at the doctoral level. It would be rare to find someone at the M. S. level graduating with such expertise.
In conclusion, the overall ob)ectives of the 306 package are noble.
However, for the program, when implemented, to succeed in terms of improved (safe)
NPP operations, my opinion is that:
(a) the status of Training Director must be upgraded within the management structure; and (b) the educational requirements I have outlined must be adhered to so that the critical expertise (as mandated by the SAT approach) can be acquired to do the job which, after all, is the keystone to the whole effort.
If not, my pro)ection is that the program is doomed to failure.
RGP:co cc:
R. Praley G. Salvendy A. Debons D. Pischer Attachments:
(2)
0 7
PERSONNEL SELECT SELECTION PERSONNEL REQUIREMENTS
{FOR EACH TRACK)
DEVELOP P'Ae I'ERSONNEL O.A. {TEST ANO EVALUATION PERSONNEL REQUIREMENTS INITIAL SELECTION CRITERIA
{INCOMING SKILLS ANO KNOWLEDGES)
DEVELOP bEHAVIORAL ObJECTI VE5 DEVELOP TRAINING REQUIREMENTS
{OILIECTIYES)
DEVELOP INSTRUC TIONAL SYSTEM DEVELOP SYLLASI
{FOR EACH TRACK)
DEVELOP I.ESSON SPECS.
SELECT INSTRUCTIONAl.
STRATEGIES AND SPECIFY MEDIAANO EOUIPMENT PERFORM ANCE CRITERIA SYLLASUS EXAMS LICENSING EXAM5 DEVELOP SIMULAT DEVELOP TRAINING V
E DEVELOP TRAINING MANAG M Y
DEVELOP IN5TRUCTOR AND STUDENT AIDS AND MATERIA TRAIN PERSONNE ANALYZE TA5KS CERTIFICATION AND LICENSING CRITERIA FtGURE 2. TRA)NINGSYSTEM FLOiVOIAGRAM
L
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'D F
SELECTII CRITERIA TEST ITPIS TRAINING EXNINATIIS INSTRtjCTOR RATINGS (5 $8 PER FENCE St'PERVISOR RATINGS ITPI DIFFICOLTY; ITPI Vk.IDITY PNALLEL FOR%
RFLIABILITY VALIDITY OR.
RtCHARO G.
PEARSON tNOUSTRtAL ENGlNEERING N.
C.
STATE UNIVERSlQ RALBGH, N. C.
'IDUN-2 8 1984 DISTRIBUTION CDocument Control 50=400 8,
PRC System JLee (2)
DOCKET NO(S).
The Honorable Richard Ottinger, Chairman Subcommittee on Energy Conservation and Power Committee on Energy and Commerce United States House of Representatives IJashington, D.C.
20515
SUBJECT:
CAROLINA POINTER AtID LIGHT COt/IPANY, ET AL SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1
, dated The following documents concerning our review of the subject facilityare transmitted for your information.
Notice of Receipt of Application.
Draft/Final Environmental Statement, dated Notice of Availabilityof Draft/Final Environmental Statement, dated Safety Evaluation Report, or Supplement No.
, dated Notice of Hearing on Application for Construction Permit.
Notice of Consideration of Issuance of Facility Operating License.
Application and Safety Analysis Report, Volume Amendment No.
to Application/SAR dated iIIj Constroctton Permit No. CPPR-188, Amendment No.
Facility Operating License No.
, Amendment No.
, dated Order Extending Construction Completion Date, dated Other (Speci fy)
Enclosures:
As stated Office of Nuclear Reactor Regulation cc:
Representative Carlos I/loorhead bcc:
OCA OFFICEIIr SURNAME/
DATE/
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NRC FORM 318 (10/80) NRCM 0240 OFFICIAL RECORD COPY
dN28 884 DISTRIBUTION CDOCUMENT-CONTROL SO=SOO, PRC System JLee (2)
DOCKET NO(S).
5O-4OO The Honorable Alan Simpson, Chairman Subcommittee on Nuclear Regulation Committee on Environment and Public Ilorks United States Senate Washington D.C.
20515
'AROLINA PONER
& LIGHT COMPANY, ET AL SHEARON HARRIS NUCLEAR POWER PLANT, UNIT )
The following documents concerning our review of the subject facilityare transmitted for your information.
Notice of Receipt of Application.
Draft/Final Environmental Statement, dated Notice of Availabilityof Draft/Final Environmental Statement, dated Safety Evaluation Report, or Supplement No.
, dated Notice of Hearing on Application for Construction Permit.
Notice of Consideration of Issuance of Facility Operating License.
Application and Safety Analysis Report, Volume Amendment No.
to Application/SAR dated Kl Construction Permit No. CPPR-l5B, Amendment No. 3,dated Facility Operating License No.
, Amendment No.
Order Extending Construction Completion Date, dated Other (Specil'y)
, dated
Enclosures:
As stated cc:
Senator Gary Hart i.ice:. 'ggA Office of Nuclear Reactor Regulation OFFICE SURNAME)
DATEP J
ch 6f/
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'NRC FORM 318 n0/80) NRCM 0240 OFFICIAL RECORD COPY
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