ML20134N142

Informs That During 438th Meeting of ACRS on 970206-08, Review of NRC Activities Identified in Human Performance Program Plan Completed

ML20134N142
Person / Time
Issue date:	02/13/1997
From:	Seale R Advisory Committee on Reactor Safeguards
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
References
ACRS-R-1679, FACA, NUDOCS 9702210223
Download: ML20134N142 (3)

Text

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February 13, 1997 l

l The Honorable Shirley Ann Jackson Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

SUBJECT:

HUMAN PERFORMANCE PROGRAM PLAN ,

I During the 438th meeting of the Advisory Committee on Reactor Safeguards, February 6-8, 1997, we completed our review of the NRC activities identified in the Human Performance Program Plan (HPPP) .

Our Subcommittee on Human Factors met on September 20 and December 3, 1996, to review these activities. During these reviews, we had l

the benefit of discussions with representatives of the staff.

In your remarks of December 2, 1996, to all NRC employees, you stated:

As we move to an era of nuclear power industry restructuring and declining NRC and industry resources, it is imperative that we are able to diagnose potentially declining licensee performance as early as possible.

We agree with your assessment. We believe that an appropriate HPPP would contribute significantly to the development of such diagnostic tools.

Conclusions and Recommendations

1. The HPPP is not a plan. It is, instead, an inventory of human performance projects within the agency. The HPPP should state explicitly what its goals are, what research efforts will be required to achieve these goals, and when and how it will be known that they have been achieved. The ownership of the present plan is diffuse. The success of such a plan as well as its dynamic nature require that ownership of the entire plan be clearly assigned.

l 2. A well-planned research effort in human performance is urgently needed to support both the regulation of plant

operations and the transition to risk-informed and l

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performance-based regulation. The overall perspective that

, ' can be provided by high-level models of human performance would be helpful in the planning of this research effort. A 4

number of such models are reviewed in NUREG/CR-6350.

3. The development of indicators of a good safety culture, the

design of a meaningful human performance reporting system, and the impact of downsizing and deregulation on human performance

! should be major elements of the research effort.

Discussion

! Operational experience has shown that human performance is a major 3 factor in the safe operation of nuclear power plants.

Understanding what can-go wrong at a plant requires an integrated evaluation of both hardware and human performance; i.e., the plant

! must be viewed as a sociotechnical system. In particular, the term l " human error," which carries the implication that the operators are i to be blamed, is inaccurate in many instances and one must investigate and understand the context within which plant personnel l function. This context is determined by both the design and the physical conditions of the plant, as well as by the prevailing

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safety culture.

The development of a plan for research on human factors is certainly not a simple task. This task would be made easier and j the recommendations more convincing if the task were guided by a high-level model that identifies the important elements that influence the likelihood of unsafe human acts. Various models and

taxonomies have been proposed in the literature and some are

, beginning to receive wide acceptance. Human performance models and j error classifications that could be suitable guides for developing

a research plan are being used in other projects in the Office of i Nuclear Regulatory Research. The models discussed in i NUREG/CR-6350, along with insights from operational experience, j could serve to guide the development of an HPPP.

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, one specific element we would like to see addressed in the HPPP is j

the impact of situational assessment on compliance with procedures.

Investigations of actual incidents and simulator exercises from nuclear and other industries have demonstrated the importance of j what Professor James Reason of the University of Manchester calls

" intended violations" (circumventions) of procedures by plant i personnel. The researchers who collected data from simulator j exercises point out that these were not necessarily errors; the l a operators simply did what they felt was the optimal response to the i evolving accident. We believe there is a need to understand the j reasons for such deviations and how training, procedures, and the l plant safety culture could be modified to eliminate 4

" circumventions" to the extent possible.

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' The present HPPP contains elements that are worth pursuing. Other elements that should be contained in the HPPP include activities to gain a better understanding of the concept of safety culture and to l develop indicators of a good safety culture. The human reliability l analysis research project should also be part o'f the HPPP. We will

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4 continue to work with the staff in developing an effective HPPP.

Sincerely, i

R. L. Seale j Chairman

References:

I 1. Memorandum dated July 31, 1996, from Cecil Thomas, Office of l Nuclear Reactor Regulation, to John Larkins, ACRS Executive

! Director,

Subject:

Forwarding Human Performance Plan Rev. 1 l 2. Office for Analysis and Evaluation of Operational Data Report

, E-95-01, " Operating Events with Inappropriate Bypass or Defeat

of Engineered Safety Features," July 1995 i 3. U. S. Nuclear Regulatory Commission, NUREG/CR-6093, "An l Analysis of Operational Experience During LP&S and a Plan for

! Addressing Human Reliability Issues," June 1994

4. U. S. Nuclear Regulatory Commission, NUREG/CR-6265,

"Multidisciplinary Framework for Analyzing Errors of l Commission and Dependencies in Human Reliability Analysis,"

J August 1995 i 5. U. S. Nuclear Regulatory Commission, NUREG/CR-6350, "A l Technique for Human Error Analysis (ATHEANA)," May 1996

! 6. Reason, J.T., Human Error, Cambridga University Press, l Cambridge, United Kingdom, 1990

7. R. Montmayeul, F. Mosneron-Dupin, and M. Llory, "The s Managerial Dilemma between the Prescribed Task and the Real j Activity of Operators: Some Trends for Research on Human l Factors," Reliability Encineerina and System Safety, 45:67-73, 2

1994 i 8. U. S. Nuclear Regulatory Commission, NUREG/CR-6208, "An l Empirical Investigation of Operator Performance in Cognitively

Demanding Simulated Emergencies," July 1994 l 9. International Atomic Energy Agency, Vienna, International l Nuclear Safety Advisory Group, " Safety Culture," Report 75-

! INSAG-4, 1991 1 10. NRC Chairman Shirley Ann Jackson's remarks to all NRC employees, December 2, 1996 '

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