ML20136C904

Requests Info Re Possible Relationship of Human Factor Problems to TMI Accident,On Behalf of Public Interest Committee of Human Factors Soc.June 1979 Newsletter Encl

ML20136C904
Person / Time
Site:	Three Mile Island
Issue date:	07/20/1979
From:	Price H AFFILIATION NOT ASSIGNED
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
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ML20136C901	List: ML20136C904
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NUDOCS 7910170511
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1 Biotechnology, Inc.

3027 ROSEM ARY LANE = FALLS CHURCH, VIRGINIA 22042 (703)573 3700 July 20, 1979 Mr. Victor Stello, Director Operating Reactors Division office of Nuclear Reactor Regulation Phillips Building 7920 Norfolk Avenue Room 528A Bethesda, Maryland 20555

Dear Mr. Stello:

As Chairman of the Public Interest Committee of the Human Factors Society, it is my responsibility to help bridge interfaces that sometimes occur between the pro-fessional interests of Society members and major public issues. The Three Mile Island nuclear power plant accident, for example, is a major public issue which is of concern to the Human Factors Society and its members. I This concern, in part, stems from the possible relation-ship of human factors problems to the accident itself, specifically, such human factors as training, personnel selection, control display requirements, technical procedures adequacy, communication reliability, and  ;

personnel performance in stressful environments.

Since one of the primary concerns of the human  !

factors professional is design of the interface between .

l people and the equipment, environment, information, and ,

organization with which they interact, the Three Mile l Island accident is of particular interest and concern. . .I This is especially true inasmuch as a major priority of professionals working in human factors is to make these interfaces productive, safe, and satisfying by incor-  !

porating knowledge of human capabilities and limitations l into the interface design.

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Mr. Victor Stello July 20, 1979 Page Two It is my duty as Chairman of the Public Interest Committee to collect information available to the public from hearings, investigations, and expert reviews. In this regard, I would like to request from you copies of relevant documents which your Office or Committee has generated. Your cooperation and consideration are appreciated.

Sincerely, c, LLLt &

Harold E. Price HEP:lb P.S. I am enclosing an article from the current Human Factors Society Bulletin. The article emphasizes the need for input from human factors specialists into the design and operation of nuclear facilities.

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. volume 22. number e June 1979 E.c4hM m. Wmcw=c#Ama controls and displays. Human factors problems I 3 usually lie at the root of causative factors such as

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'*- --- - - - these. Thus professional human factors engineming 4 , lI'=='d Human Factors could have precluded or at least ameliorated these effects.

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s In the NEWS Further, a recent synopsis of a report on in=n factors design deficiencies in oudear power plants vs:

l' 1 'l presented by Dr. Stuart Parsons at an Air Fora spon.

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) sored workshop for human factors technology assess.

ment held from January 9 to 11,1979 at Wright Patterson Air Force Base, Ohio. This report indicated HF and Three Mile Island that a frightening potential for human error and The accident at the Three Mile Island nudear plant diifIcult or ineffleient (untimdy) operation exists in the design of current oudent power plant control earlier this year underscores the need to emand the rooms. (Editor's Note: " Human Factors Revsew of haput of human factors specialists into the design and Nuclear Power Plant Control Room Deign," EPRI operation of nuclatr facilities. Gloria Grace. HFS NP.309.SY, Project 301; wnte: Research Reports President, has organized a committer to drqft a Center, P.O. Box 10090, Palo Alto, CA N303: Sum.

formal rerponse to the incident at Three Mile Island. mary Report, $3.10 anduding pastage; Full Rmort, Gloria would welcome comments and suggestions I about the best wayfor the Human Factors Profession $15.83 includingpostage.)

On the basis of the above facts,it is apparent that to deal with the isrues raised by the accident.

I Following are excerpt.s from a series of correspon- very little, if any, professtonnl human factors en-

' dence between John Humes and various government sineering has been applied in the development of nuc! car power plant design and operating procedures.

l agencies concerning the need for enhanced HF This raises the further unsettling question of whether programsin the nuclearindustry. high quality rystem engineering has been applied in i

Frealdent Janses Carts' nudear power plant design, sina among the many The White Hoese .. vital functions of system engineering, as practiced by W ashlagtos. D.C. most major contractors for vital defense systems, is

Dear Mr. President:

the responsibility for ensuring that the entire system

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This letter has two purposes' has been weL! engineered relative to the capabilities (1) to recommend the inclusion of human fac* and limitations of the system operators and main-tors engineering specialists as members of or tenance technscians, contributors to .

The potential for human error or delays to contri.

(a) any committees investigau.ng nudcar bute to nudear acddents should be o,nsiderably powcr plant safety and accidents, reduced and the reliability of nudear power plants (b) the Nuclear Regulatory Commission, should be considerably enhanced by utilising the l and human factors engineering disdpline during the '

(c) any current and future nudear power design process. As long as the United States continues

. plant design development and evalua- to build nudear facilities, we should at least provide -a tion teams; -

. the devdopment of these systems with the same tech.

(2) to recommend the development and applica* nical capabilities as we provide to our vital defense tion of formal, federally sanctioned human systems. .

factors engineering criteria as mandatory Therefore, I strongly urge immediate adoption of requirements or guidelines to be followed in the measures recommended in the first paragraph of the design and operation of all nuclear power this letter. The military design standards Mll H-plants, e . . # ' 46855 and MIL-STD.1472 may be used as interim The news media have reported . hat t the recent guidelines to human factors engineering methodology ciudear accident in Pennsylvania was partially a result and design criteria, respectively, until corresponding of human operator error, operator fatigue combined documents specifically applicable to the nuclear with crisis stress, training deficiencies, faulty or im. power industry can be developed. Human factors properly followed maintenance procedures, lack of engineers with backgrounds and capabilities most crucial information needed by operators but not suitable for working with the nuclear power plant i

provided by the design, and poor design of certain problems may be located through the Human Factors

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Sodary, P.O. Bos IN9, Santa Monka, California contested by an amployer. Tlw Review Commf anion is L  ;

90406. . not connected in any way with the Department of I would appreciate a reply stating your position Labor or OSHA. The Review Commission does not

and/or plans relative to thee recommendadons. have the authority to issue substantive rules govermns j

j Your prompt action and obvious concern during the conditions in the workplace. Thus, the implemmta.

recent acddent were most encouraging and serve as an tion of your proposals under the Occupadonal Safety l Indication that you will seriously consider imploraant. and Health Act would have to be accomplished by the

- ing them. . Occupational Sefety and Health Administration with.

Sieesrely. . .,- ja the Department of Labor.

JebeM. Mamas There is aho a further annplication. It is, at

. . . . . . .. ..~... ... * ' . * . . present, also undear to what extent the Department of Following are two serponser Je copter of the pre. Labor might regulate conditions involving auclear

. ereding hiser which were distributed to etAer power plants. Secdon 4 (b) (1) of the Occupataonal government q//icish. . .. .; . . . . Safety and Health Act reads:

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.. ,* Nothing h IAk Act shall apply so nortbug eenditions of enployeur with report to which ether Federalagender, and State agender arrhig From: Coastems of the Ushed States .

Hoese of Repressstatives . . . . . . . .

mader asedan 2N ef the Atomic Energy Act of Robert E. Badham a  : r.. .. M, su amended (42 U.S.C 2021), eredst detb D6strie'., Cauferula . . . . 888'"'8'1 8"'A*'I'7 88 Prescribe or enforer ,

.; . ,standartis or regulations atffecting acaopetional I s

Dear Mr. Hanne.:

. sqfety or AneltA.

Thank you for your letter urging the implements. I do not at thh time know the degree to which this tion of human factor design engineering in the pro. provision would affect the implementation of your duction of nuclear pa plants. (Editorir mosa: the proposals by the Department of Labor, Nevertheless, spelling qf %nsafm e rezat, the sprang used abould you wish to pursue the maner with OSHA. I m she Aarser.) sugget you write to:

Human factor ensinating k in the daign of aD - - " ~ "

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• 1 uuclear power plants in the United States. As you may Dr.Eals Bisgham I Assistaat Secretary of Laborfor

• know, most of the systems in a nudear power plant

• are automated and nm by computers. There art, of Ocespational Safety & Health sourse, manual override controk. The incident at

• U.S. Department of Labor Thre Mile Island makes k clar that addidonal 200Censtitstion Avemme,N.W.

efforts must be made in the area of human factor Room S 2315 engmeering. Weaklagton, D.C.20210

• I sppreciate your concern in thl Important mattar.

--Robert E. Esdham  ! do recommend that you submit your proposak to the Member of Ceegress .

.. . . , . . . Nuclear Regulatory Commlasion.

. . . .. e. , , , , .r,... I wish you the best ofluck in gettmg the proposals koplemented. If I can be of further assutance, please y,,.. OcespeGonal Safety and Haskt Revizw do not hesitate to write. ..

' Commhdos, , -Timothy F.Omary .- -

Chairmaa, Occepn6ae esteer and Baalth W )

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i Washlagton, DC 20006 '.t# . * 'e .'~ -- C'**I'd*' * *

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Dear Mr. Muses:

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• I am writing in response to your letter of AprU 19, 1979, in which you discussed your recommendations to Prealdent Carter .:garding the ase of busnau factors engineering in the daign and operstlos of .

auclear power plants. Your interest and concern ars sommendable. I find your recommendations to be *

,'. most interesting. The kopiementation of the rusos. r- - - ---- --- ~ '-- - - '

mendadons, however, falh outside the soops of

• I authority of the Review Ca==1-1= < r-c r If your proposals can be adopted under the purview ,

of the Occupational Safety and Health Act of IMO, ,

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., then the proper agency to do so would be the Occupa. I r :" -

g tional Safety and Health Administration (OSHA) of .

the Department of Labor. AB substantive standards ' 1. -

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! , and regulations moder the Act are promulgated by , -]~ . , . , .

Ie OSHA. On the other hand, the Review C"' - 2 ~

i of which I am Chairman, is an independcat agency l

created only to adjudicate individual saforcement

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actions brought by OSHA when the action has base

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