ML20133J339
| ML20133J339 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1985 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Sheehy E AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8510180384 | |
| Download: ML20133J339 (6) | |
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DCT 151985 Mr. Edward J. Sheehy Post Office Box 539 Norris, Tennessee 37828
Dear Mr. Sheehy:
I have been asked to respond to your letter of September 3,1985 to Chairman Palladino in which you expressed concern over the delay in rulemaking action for the proposed human factors general design criterion.
You indicated that you had been told this rulemaking was being delayed ror at least three years. This information is not accurate.
The NRC staff is draf ting a proposed rule that would estab'.ish a general design criterion, GDC, on human factors considerations. Th.'s propn,ed GDC would not impose new requiremants but would recognize in a Gl,C, numan factor design considerations required by NRC since the TMI accident. The proposed GDC is currently being reviewed within the NRC as part of the ruiemaking process.
Thank you for your thought on this matter.
I hope I have allayed your concerns regarding a GDC on human factors.
Sincerely, WWW William T. Russe 11, Acting Director Division of Human Factors Safety Office of Nuclear Reactor Regulation ig3 (h
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fir. Edward J. Sheehy P.O. Box 539 Norris, TN 37828
Dear Mr. Sh'eehy:
I have been asked to respond to your letter of Septer.ber 3,1985 to Chairman Palladino in which you expressed concern over the delay in rulenaking action for the proposed human factors general design criterion.
You indicated that you had been told this rulemaking was being delayed for at least three years.\\ This information is not accurate.
The NRC staff is draf ting a proposed rule that would establish a general design criterion, GDC, on hur.an factors considerations. Thi! proposed GDC would not impose new requirenents but would recognize in a GDC, human factor design considerations required by NRC since the THI accident. The proposed GDC is currently being reviewed within the NRC as part of the rulemaking process.
Thank you for your thought on this ' natter.
I hope I have allayed your concerns regarding a GDC on human fac' tors.
NN Sincersi,y,
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ililliamT.Russhl,ActingDeputyDirector Division of HumanN{ actors Safety Office of Nuclear Reactor Regulation
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Mr. Edward J.'Sheehy p.0. Co.v 539 Norris, TN 37828
Dear Fr. Sheehy:
I have been asked to respond to your letter of September 3,1985 to Chairman Palladino in which you expressed concern over the delay in rulemaking action for the proposed huncn factors general design criterion.
You indicated that you had been told this rulemaking was being delayed for at least three years. This infonration is not accurate.
The NRC staff has developed a proposed rule that would establish a general design criterion, GDC, on human factors considerations. This proposed GDC requires consideration of the human factors inherent in plant operation, maintenance, surveillance, and testing. The proposed GDC is currently being reviewed within the flRC as part o'f the rulenaking process.
N Thank you for your thought on this natter.
I hope I have allayed your concerns regarding a GDC on human factors.
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Sincehely, Willian T. Russell, Actino Deputy Director Divisionof\\HumanFactorsSafety Office of Nu'elear Reactor Reaulation C2 MS2/Istra m slFrirt H DIFS: ADD o,,,c. )
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FROM:
DUE:
EDO CONTROL: 001004 i
10/18/85 nnC DT: 69/o3/85 l
EDWARD J.
SHEEHY FINAL RFPLY:
NORRIS, TN 4
l TO:
CHAIRMAN PALLADINO
[ QO FOR SIGNATURE OF:
GREEN SECY NO: 85-795 DESC:
/0 g CONCERN OVER DELAY OF RULEMAKING ACTION FOR THE TAYLOR
[O PROPOSEC HijMAN FACTORS CRITERION TO GENERAL DESIGN MINOGUE
/
CRITERIA IN lo CFR 50 GCLINNINGHAM /
/
STELLO DATE: 09/19/85 ASSIGNED TO: NRR CONTACT: DENTON j
SPECIAL INSTRUCTIONS OR REMARKS:
FOR APPROPRIATE ACTION N'
NRR RECEIVED: 09/20/85.
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ROUTING:: DENTON/EISENHUT ACTION:
DHFS, W. RUSSELL
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SECY NUPSER:
85-795 LOGGING DATE 9/17/85 0FFICE OF THE SECRETARY ACTION OFFICE:
ED0 AUTHOR:
Edward J. Sheehy AFFILIATION:
llorris, TN LETTER DATE:
9/3/85 FILE CODE ADDRESSEE:
Palladino Delay of RM action for the pro human factors criterion SU8 JECT:
to gen design criteria in 10CFR50 ACTION:
Appropriate docket DISTRIBUTION:
None SPECIAL HANDLING:
- P SIGNATURE DATE:
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SEP 03 #
a Edward J. Sheehy geg0t P.O. Box 539 gg0 Norris, TN 37828 o @Qu
- h. / 150 The Honorable Nunzino J. Palladino r
0hC8 Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Chairman:
RE: CONCERN OVER DELAY OF RULEMAKING ACTION FOR ' DIE PROPOSED HUMAN FACTORS CRITERION TO GENERAL DESIGN CRITERIA IN 10CFR50 I have just finished reading Inspection and Enforcement Information Notice 85-50 about a complete loss of feedwater at Davis-Besse Nuclear Plant.
Despite the fac t tha t this event has attracted a lot of attention, there really was nothing unexpected in the notice. Once again, an operator error played a key role in an event scenario. Once again, an unplanned operator ac tion saved the day.
For a long time now, the risk assessment literature (e.g., NUREC/CR-1278, Handbook of Human Reliability Analysis with Emphasis on Nuclear Power Plant Applications) has estimated human error probability as being about 10-Z failures per demand. This stands in sharp contrast to the less then 10-6 failures per demand typically expected of safety functions being accomplished by hardware systems. Human error is very likely.
Because of this, it would be expected that nuclear power plant designs be required by law to minimize the likelihood of human error (e.g., all cases where plants do not comply with good human engineering practice such as those contained in NUREC-700, Guildelines for control Room Design Revleus should be corrected or justified). Another logical expectation is that accident analysis for licensing would postulate and evaluate human error in mch the same way as the less likely hardware failures are required to be considered.
Expectations are of ten cold and empty however. The facts are that there are no laws that require anything of this sort at all.
Progress has been made since Three Mile Island first forced awareness in this area. Just how nuch progess is a matter of perspective. You can, as the industry has chosen to do, focus on the fac t that there now exists industry working groupa and useable guidelines where before for all practical purposes there was total unawareness. From this perspective, there has been a lot of progress. On the other hand, you can consider _ actual need versus the ef fectiveness of the various methods currently being used for implementation of good human engineering practice. These ad hoc methods are resolving problems, but only to an extent determined by the personalities of the individual NRC reviewers and the utilities' representatives. Practically, this amounts to utilities taking action to reduce human error when it is convenient to do no rather than when it is needed to protect the health and safety of the public. This situation is unlikely to change as long as utility and NRC safety reviewers have no legal bases to require problem resolutions.
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i A high-level legal requirement to consider the human element in power plant design is needed. After many unwarranted delays, it. looked like some progress was being made in neeting this need via a human factors criterion which was to be added to Title 10, Part 50 of the Code of Federal Regulations. This proposed criteria was scheduled to go to rulemaking this fall. I have been told, however, that your staf f intends to kill any consideration of this critically needed rulemaking for at least three years.
There still exists considerable industry-wide resistance to dealing seriously with reduction of human error. The fact that it is necessary today, in light of all the studies which were made of the Three Mile Island incident, to present additional arguments on the need for rulemaking in this area is in itself an indication of this resistance.
When one considers the proposed criterion 65 would, like all the other general design criteria, be stating something so basic that no one would seriously argue against it only two conclusions are possible. The first is the requirement is trivial and would have no bapset because everyone complies anyway. The second is that an industry and' regulatory " stonewall" has been erected to delay the impact of compliance.
Chairman Palladino, the impact of noncompliance may be much larger than compliance. I am sure you are aware that a principle conclusion of all the major reports on Three Mile Island was that the event was caused by disregard of what amounts to a natural law that governs nuclear power plant operations, "Thou shalt assure operator integrity at all times." (Operator integrity is the ability of members of an operating crew to utilize their understanding and training of plant procedures, hardware, and operations to maintain the plant within the limits of safety system requirements.) The purpose of this letter is to point out that a major gap still exists between this natural law and the legal codes which control plant design.
The consequence of this gap is that safety reviewers within the NRC and utilities alike have no legal ground to stand on when dealing with conditions that preclude operator integrity. Just now the only thing we can cite as being violated is common sense. Common sense, however, is not law. Because of this, it is often necessary to accept " band-aids" on symptons rather than root problems being addressed. This situation is setting the nuclear industry up for another incident comparable to Three Mile Island. When (not if) this event take-place, nuclear power will die as an energy option for our nation.
Mr. Chairman, I urge you to proceed with rulemaking on this (tom wit.out delay.
The view and opinions expressed in this letter are my own and not necessarily those of my employer, the Tennessee Valley Authority.
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Sincerely b,
E. J. Shdey
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