ML20056C532
| ML20056C532 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1993 |
| From: | Ward D Advisory Committee on Reactor Safeguards |
| To: | Carroll J Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-CT-2062, NUDOCS 9306240429 | |
| Download: ML20056C532 (3) | |
Text
0h Adb8 cave wasssmates ine so3 279ess3 createe Wednesday Man 1019931s 07 AM Page 1 of 3 6/s//93 cc: Herman Aldbrman-3/10/93 To:
Jay Carroll, Chairman ACRS Human Factors subcommittee From: Dave Ward, ACRS consultant
Subject:
Comments on your 3/2/93 draft of OFR letter I think it is a good letter and ' agree with the recommendations.
I have reread my memo of 2/12/93 to you commenting on an earlier draft, and I stand behind those comments.
You have not incorporated my main point into the new draft.
That's your privilege, of course.
[Or maybe you can't figure out what it is!]
My main point is that the centerpiece of the staff SECY, the reason they give for ending the program is specious.
You quote their reason in lines 18 22 of your recent draft letter.
there is a relatively low cost effectiveness until it can be.. integrated into PRA models."
This in nonsense.
As a way of getting at this in the letter, I suggest you substitute the following for your short paragraph, lines 144 148:
Continuation of this pregram has potential for providing important benefits to the staff and industry.
The staff submits that the program has "relatively low cost-e ffe ctive ne ss".
We submit that the staff has no basis for this statement. beyond their internal judgment.
Their reasons for holding this opinion have not been given exposition nor de bated.
In a technical.
I quantitative sense, whether Organizational Factors Research is presently " cost effective" in unknowable.
Policy makers will have l
to decide whether further research is prudent and wise.
That. in
)
y @e itself, is not unusual.
The danger is that policy makers may be y
g unduly influenced by Staff allusions to technical evidence that the 8
program has "relatively low cost effectiveness", when there is. in p
$rn fact.
none.
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\\letely integrating new information on organization factors into Ei
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8 PRA will have little influence on plant safety, so the benefits in 4
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any cost benefit equation from just that are bound to be smali.
However, the OFR may lead to insights and understandings which g8
Cave Ware Associates Inc.8c3 279-8513 Created Wednescay Van.n 10199311 C6 AM. Dage 2 of 3 will influence actual behaviors at ope ratin g plants.
e.g.
how people and organizations deal with and reaci to a whole range of normal and abnormal situations.
If meritorious actual changes at plants are, in the next 30 years. influential in preventing a serious accident. the OFR which has produced those changes will clearly have been " cost effective
- This is the whole point a bout the need and merit of continuing OFR.
Successful integration of organizational factors in formation into PRA would help policy makers make a decision about whether OFR should be continued.
That is the sort of thing that can be expected from PRA and all that can be expected.
B ut. whether that can be done and when it will be aane is difficult to estimate.
and a decision whether to continue OFR should be made now.
The basis for the decision should be whether it is judged that information from OFR can be expected to influence the behaviors of future operators and organizations at plants in such a way as to help prevent serious accidents in the future.
It would.be agreeable if PRA could be of some help in making this decision.
It probably cannot at present, and time spent worrying about that is ill spent.
This is not to say that an effort to use PRA in assessing organizational performance is wron g.
PRA and the risk perspective can help to bring discipline and a rational perspective to the OFR and its applications, just as it has to many other technical areas related to reactor safe ty.
However, the focus of OFR should not be merely to supply input to PRA. but to provide guidance to the institutions responsible for plant safety in how best to optimize organizational performance.
I recognize this is rather long.
But, it is an important point, and while I have been unsuccessful in condensing it into a single pithy paragraph, perhaps you all can. I hope so.
I A few other comments on the draft letter:
(
Line 48 Foreign programs in OFR are apparently not aimed exclusively at PRA.
Good for them.
cavd Watts Assocates inc 803 279-8513 Created Wecnesday Maren 10199311 C6 AM Dage 3 Of 3
_______________________________________________________________________________________l Line 55 Many other areas of NPP safety have benefited from a " scholarly examination", why should not organizational performance?
Line 91 93 1 don't see how ACRS can agree that this effort would be " resource intensive" What do the words mean?
Whose resources?
3 Intensive compared to what
- QA?
i
- S ALP? -
diagnostic inspections?
- LER requirements?
-i What does this mean in plain English?
i i