ML20212N577

Affidavit of Jm Taylor Re Health & Safety Basis for Staff Prohibition on Electronic Entertainment Devices in Control Rooms.* Certificate of Svc Encl

ML20212N577
Person / Time
Site:	Prairie Island
Issue date:	03/06/1987
From:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20212N553	List: ML20212N550 ML20212N577
References
EA-86-164, NUDOCS 8703130079
Download: ML20212N577 (16)

Text

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UNITED. STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFDTtR THE COMMISSION

. I'n th'e Matter of -

)

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NORTIIERN STATES POWER COMPANY ) Docket Nos. 50-282 (Prairie Island Nuclear ) 50-306

, Generating Plant, Units 1 & 2) )

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NORTHERN STATES POWER COMPANY ) Docket No. 50-263 (Monticello Nuclear Generating ) EA 86-164 Company) )

AFFIDAVIT OF JAMES M. TAYLOR REGARDING THE HEALTH AND SAFETY BASIS FOR TIIE STAFF'S PROHIBITION ON ELECTRONIC ENTERTAINMENT DEVICES IN CONTROL ROOMS I, James M. Taylor, being duly sworn, do depose and state as follows:

1. I am Director of the Office of Inspection and Enforcement, U.S.

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' ' Nuclear Regulatory Commission. In that capacity, I am responsible for developing and administering the policies and programs for the inspection of NRC licensees to ensure compliance with agency re-quirements for public health and safety. I am also responsible for ensuring that appropriate enforcement actions are taken in those l cases where NRC requirements are violated. A statement of my l

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professional qualifications is attached to this affidavit.

2. The purpose of this affidavit is to present the health and safety l

l basis for the NRC staff's prohibition of electronic entertainment devices in nuclear power plant control rooms, in particuler at the Prairie Island and Monticello nuclear power plants.

8703130079 870306 PDR ADOCK 05000282 G PDR

3. The NRC staff opposes the use of electronic entertainment devices in nuclear power plant control rooms based on the premises that control room operators who are (1) highly trained and qualified, (2) physically _ and mc.ntally fit to carry. out their duties , and (3) attentive to all aspects of plant status are essential to the con-tinued safe operation of these facilities. A fcurth basic premise is that operators must be provided with a work station and environment which is conducive to the effective ~ discharge of their significant responsibilities. The quality and reliability of the human factor in-nuclear operations represents a key element in overall reactor safe-ty. Notwithstandinir the inherent quality and reliability which is

' designed and built into nuclear power plants, mechanical and electri-cal systems and components required for safety can and do fail.

Control room operators use these systems during normal operations and theypre the human backup when things go wrong. Continuous attention to plant and systems status by operators is an integral element to safe routine operations, to the - early identification of degradation in reactor systems, and to prompt and effective human actions when conditions are abnormal.

4. Given the importance of the human factor in reactor safety, it is appropriate that NRC's regulatory policies address the essential I

elements of operator training and qualifications, their fitness to perform required duties, and finally, the environment of the control

, rooms in which operators carry out their routine and hum 9n backup functions. Specific requirements and policies regarding the training

4-and qualifications of NRC _ licensed operators are- described in the

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NRC regulations and in the Commission's _ Policy Statement on Train- l

-l ing and Qualification. Standards on the physical and mental fitness l of operators are also articulated in -the NRC regulations and in the l Commission's Policy Statement on Fitness for Duty of Nuclear Power -

1 Plant Personnel. Based upon human factors considerations, estab-lished NRC regulations and guidance define physical and environmen-tal standards - for control rooms for such matters as emergency atmosphere control and the phycical layout and design of the numer-ous control boards, alarm panels and other displays. The matter of noise levels in the control room is addressed in that the guidance

- states that general background noise shall not . impair oral communi-cation and that noise. distractions shall be minimized. NUREG-0700, Paragraph- 6.1.5.5. In sum, NRC has established requirements and guidance aimed at ensuring th'at only highly competent and fit indi- .

viduals, provided with an appropriate work station and environment, are placed at the controls of nuclear power plants.

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5. With regard to the element of actual operator attentiveness and the control roots environment or decorum necessary to ensure that atten-tiveness, the NRC has not specifically addressed the matter of the I

'.. effect of electronic entertainment devices upon operator attentiveness in formal regulatory requirements. However, there are several established NRC guidelines which are related to this subject. Regu-latory Guide 1.114, entitled " Guidance to Operators at thf Controls

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and to . Senior Operators in the Control Room of a Nuclear Power Unit," states -that:

In order for the operator - at the controls of a nuclear power. unit to be able to carry out these and other respon-sibilities in a timely fashion, his attention must be given to the condition of the unit at all times. He must be alert.to

, ensure that the unit is operating safely and 'must be capable of taking action to prevent any progress toward a condition that may be unsafe.

Clearly, .the level of an operator's attentiveness to the status and trend of plant conditions can be affected by the general standard of professionalism and decorum present in the control room. Over six years ago, in IE Circular 81-02 of February 9,19'81, th'e NRC staff provided guidance to licensees on this matter. The guidance de-

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scribes conditions and practices which NRC believes to be necessary for the maintenance of a professional atmosphere in the control room.

Among other things, the guidance states that:

Potentially distracting activities 'in the control room and other watch stations must be prohibited (for example:

_. radios, TV, alcohol use or drug abuse, games, horseplay, hobbies, and reading that is not directly job related).

The guidance recommended that each power reactor licensee review and revise, as necessary, their administrative controls and proce-dures to ensure that the guidance is incorporated.

6. In early 1985, the NRC staff conducted an informal survey of house-keeping and control room decorum at all licensed operating reactors.

Of 65 reactor stations surveyed, electronic entertainment devices were found to be used at only seven stations (including ,Monticello and Prairie Island) . In July 1985, the NP.C staff reiterated its

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l policy in an Information Notice which, together with a letter from the  !

Executive . Director for Operations, was dispatched to the Chief I l

Executive Officer of each NRC licensed utility. This reminder of the '

staff's policy resulted in the removal of electronic entertainment

. devices from all remaining control rooms, including those at Prairie Island . and Monticello. (This action by the Northern States Power Company led to the filing of a grievance by the Monticello operators and a decision by an arbitrator, which resulted in reinstatement of the radios at both Prairie Island and Monticello).

7. The above events during the 1981-1985 timeframe demonstrate that a significant majority of NRC licensees (those who are ultimately re-sponsible for nuclear safety) have chosen to restrict the use of entertainment devices in their control rooms. The Staff believes that the fact that this policy has been largely. unchallenged throughout l the nuclear industry indicates the broad-based concurrence of nucle-ar industry leaders in the concept- that the use of such devices is not warranted on a safety basis. The Institute of Nuclear Power Operations (INPO), an organization sponsored by the nuclear power industry to independently evaluate safety and promote excellence in nuclear power operations, has also issued guidance on this matter.

- INPO's June 1985 " Guidelines for the Conduct of Operations at Nuclear Power Stations," Chapter III, Control Room Activities, states, "This chapter addresses the important elements of control room activities that are necessary to support safe and efficient plant operation. " The section on Professional Behavior states that

"Potentially. distracting activities- such as ' radio listening, game

. playing, and horseplay. should be prohibited." While it' is empha-sired by NRC staff that strict adherence to this specific provision (as ' well ~ as to other individual INPO guidelines) is not required by INPO, this guideline does. demonstrate that an independent crganiza-tion of nuclear safety professionels does, on the basis of ' safety, consider the playing of radios in control rooms to be counter to excellence in safe nuclear operations.

8. The Staff is not aware of any scientific human factors studies which either address whether the use of electronic entertainment devices specifically have an. impact on safe nuclear power plant control room operations, or attempt to quantify the impact, if any. General studies have been. performed to determine whether there is any effect by background music on human performance; however, those studies have been primarily oriented toward worker satisfaction,-

productivity, and quality of work performance in a factory or office setting (neither of which is analogous to a nuclear power plant control room). While such studies do report that background music can have some positive effects upon classic productivity and worker l'

l satisfaction in settings involving routine, recurring and monotonous work tasks, the studies also report that the quality of work per-l.

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formed can be adversely affected. It is also reported that up to ten I.

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percent ' of workers may b's annoyed by the presence of background music in their workplace. II x

The Staff is also aware that data from NASA's Aviation Safety Re-porting System (ASRS) was relied upon by the FAA when it estab-lished regulations - prohibiting flight crews of commercial aircraft

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(including air taxi onerators) from performing distracting, non-safety related activities during critical phases of flight. EI 45 Fed. Reg. 57684 (August 28, 1980) (proposed rulemaking); 46 Fed.

Reg. 5500 (January 19, 1981) (final rule). According to the FAA, data from the ASRS indicated that many flight crew errors, omissions and non-compliance with Air Traffic control directions were reported-ly due to distractions of flight crew personnel caused by perfor-l mance of non-essential duties and actidties by flight crew members.

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Such distractions included radio communications to confirm connecting flights for passengers, public address announcements regarding sites that the plane was passing over, and "small talk" between flight crew members on such subjects as politics and used cars. While the FAA regulations do not specifically prohibit the use of electronic

-1/ Richard S. Uhbrock, " Music on the Job: Its Influence on Worker Morale and Production," Personal Psychology, A Journal of Applied Research, Volume 14, No.1, Spring 1961.

-2/ Critical phases of flight are defined by the FAA to include all ground operations, including taxing, takeoff and landing, and other in-flight operations execpt for cruising flight. The Staff is. current-ly not in a position to evaluate the comparability of ste'ady state nuclear power operations with an aircraft in " cruise" status;

entertainment devices, they do, in the Staff's judgment, address and prohibit an even lower level of potentially disturbing activity (eg.,

unnecessary oral communications between flight crew members) - as compared to the. Staff's prohibition ' of electronic entertainment

' :. devices.

In sum, there is no information from human factor studies or quanti-tative risk analysis which 'directly quantify or otherwise describe the safety impact of the presence of electronic entertainment in the control room of a nuclear power plant. However, there- is data suggesting that music and other distractions can have an adverse impact on the quality of work. Under these circumstances, prudency suggests that the Staff act conservatively and continue to apply a "no use" standard, as opposed to attempting to specifically define, op the basis of limited study, which of the various kinds of entertainment (controlled,- soft background music vs. hard rock vs.

AM/FM radio, etc.) would be disruptive to control room operations )

and operator attentiveness. While the Staff fully recognizes and .

supports the role of quantitative risk assessment where practicable, human factors considerations are often not amenable to such methods of regulatory decisionmaking. Moreover, such definitive standards probably could not be established with any degree of certainty. The safety advantage of the "no use" standard is that (1) the absence of electronic entertainment does not impose any unreasonable hardship

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I upon operators, yet (2) potential distractions from the , operators' assigned safety tasks are eliminated. This position is consistent L

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' with. the Commission's policy approach on the fitness for duty of nuclear power plant personnel. In adopting a "no use" standard on involvement with illegal drugs, the Commission has likewise prudently decided that any level of drug use by personnel with access to.

nuclear power plants can potentially affect the safety of.' nuclear operations. At the same time, the setting of this standard at the highest level does not impose any unreasonable hardship upon

. employees.

9. In a October 25, 1986 letter to the Vice President of the United States, a Shift Supervisor at the Monticello nuclear station argues

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that since removal of the radio from the control room, "The opera-tors now get to. listen to the hum of many electric relays and the very loud heating and ventilation systems. The radio did provide a soothing background noise that helped with some of the monotonous, .

routine work. It also helped the midnight shift go quicker." This statement, however, also supports the case for the absence of elec-tronic entertainment in the control room. Safe nuclear operation requires that control room operators be, to the extent possible, attuned to all aspects -of plant status and capable of responding promptly to changes in operational status. All of the operator's senses,' including aural, must be used in carrying out this responsi-bility. It is the operator's job to listen to the various sounds of the plant, both routine and as they change. It is not the operator's job to listen to music which might mask out the first indicatfo'ns of an t

adverse safety condition.

10. The Monticello operators and ' others ' have noted that both the Monticello and Prairie Island stations have been recognized by both NRC and INPO as being among the top performing plants in the United States. This is true. The broad based performance .by these Northern States Power facilities in such areas 'as operations,.

maintenance, emergency preparedness, security and quality. .assur-ance- has been such that NRC has determined -that -the level of rou-tine inspection coverage can be reduced relative to that provided at other facilities. No one has argued that this high level of perfor-mance has been achieved throughout the facility as a direct result of

. f the playing of a radio in the control room. Should these stations be allowed to .be exempted from established safety standards, ascribed to by both the NRC staff and INPO, because of this performance?

The . Staff does not support such an approach. NRC has recognized these facilities for their general excellence in safe nuclear opera-Having done so, it is the staff's expectation that the highly tions.

qualified and professional operators at these stations would seek to continue to set and even advance the national standard of excellence -

by accepting and encouraging adherence to the highest levels of safety practice and decorum at all facilities.

11. As noted in the attached statement of professional qualifications, my experience includes eighteen years of direct involvement with the U.S. Navy's nuclear propulsion progrram. From the s, tart , the concepts of strict professional decorum and concentrationrupon the dutics at hand have been fundamental to over thirty years of safe i

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s reactor ' operations in the N iv+ .

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While entertainment devi:es or

- background music might be .apprc;. rate and are uset in some areas of a nuclear powered ship, such ectivities have never been an p?d

.in any part of the nuclear propulsion spaces. My seven years of

. experience in the regulation of commercial nuclear power plants has convinced me that this same approach is applicable to commercial power plant activities, s

12. In conclusion, the Staff's position on the safety basis for denying the use of ' electronic entertainment devices in nuclear power plant control rooms can be summarized as follows:

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The total atmosphere of a control room must be oriented toward an environment which supports the operator's undivided atten-tion to safe operation of the plant.

There is no definitive evidence that electronic entertainment devices enhance the operator's attentiveness to safety responsi-bilities, however, there is some evidence that music from such devices can irritate some individuals, as well as adversly effect the quality of work. The absence of electronic entertainment devices from the control room does not impose any unreasonable hardship on the operators.

Guidance provided by the NRC staff and INPO, together with general voluntary adherence to these guidelines by NRC t

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licensees, indicates that there is broad based . support for- the policy that the use of ' electronic entertainment devices in the control rooms of nuclear power plants is c ehtrary to the best interests of nuclear _ safety.

. The statements above' are true and correct to the best of my knowledge and belief.

mw . '

mes M. Taylp(f, Director Office of Inspedtion and Enforcement

- Signed and Snorn to Before Me this JD day of March,1987.

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PROFESSIONAL QUALIFICATIONS

~ JAMES M. TAYLOR Mr. Taylor joined the NRC in May 1980 as a member of the Senior Executive Service. .The following are positions occupied both in NRC'and prior:to

. joining the agency.

January 1985 - Present Director, Office of Inspection and Enforcement.' Responsible for development-and administration of policies and programs for inspection of materials and facility licenses, and nuclear vendors to ascertain compliance with NRC requirements regarding.

health and safety, protection of the environment, and protection'of material from diversion to unauthorized _uses; investigation of accidents, incidents, and allegations involving licensed materials or facilities; and enforcement of NRC requirements.

October 1983 - January 1985 Deputy Director, Office of Inspection and Enforcement. Management of the-overall inspection and enforcement program for the NRC.

January 1983 - October 1983 Director, Division of Quality Assurance,

Safeguards and Inspection Programs. "

Responsible for NRC inspection programs and for special NRC inspection teams including Performance Appraisal Team'for Operating Reactors,' Construction Appraisal Team, and the Integrated Design Inspection.

January 1982 - January 1983 Director, Division of Reactor Programs.

Responsible for all IE inspection program development and agency-wide quality assurance matters.

November 1980 - December 1981 Deputy Division Director, Division of Reactor Programs. Responsible to Director for all L IE nuclear plant inspection program development l and appraisals. Responsible for initiating

[ original coordination efforts with INPO.

May 1980 - November 1980 Deputy Division Director, reporting to the L

l Director concerning inspection program development for nuclear plants under construction.

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Experience Outside NRC September 1974 - May 1980 Associate Director for High' Speed Submarine Project, Division of Naval Reactors.

Responsible for the.overall development,

" design, construction, and testing of nuclear power plants for attack submarines. (DOE)

Hay 1969 - September 1974 Senior Naval Reactors Representative, Pearl Harbor Naval Shipyard. Responsible for the surveillance and review of all shipyard work relating to naval nuclear propulsion matters.

(USN)

November 1964 - May 1969 Senior AEC Representative, Ingalls Shipbuilding Corporation. Responsible for the surveillance and review of all shipyard nuclear work, including construction.

June 1962 - November 1964 Nuclear Engineering, Office of Naval Reactors.

Engaged in developing plant operating manual and test documents for surface ship reactor plants.

Military Completed 20 years service in the U.S. Navy in June 1976 with rank of Commander.

4 Education / Training U.S. Naval Academy (BS-ENG-1956).

MIT (MS & Engineer's Degrees - 1961).

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'- 00cKETED USHRC UNITED STATES OF AMERICA l l

NUCLEAR REGULATORY COMMISSIOb gs -9 P2:00

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BEFORE THE COMMISSION APFIC# Cf RuttiARY '

1> 0CKEDNG g m CH k SEiWICI-In the Matter of ).

)

NORTHERN STATES POWER COMPANY -) Docket Nos. 50-282  ;

-(Prairie Island Nuclear ) 50-306 Generating Plant, Units 1 & 2) )

)

NORTHERN STATES POWER COMPANY ) Docket No. 50-263

(Monticello Nuclear Generating ) EA 86-164 Company) )

CERTIFICATE OF SERVICE 11 hereby certify that copies of "NRC STAFF EXPLANATION OF THE

- HEALTH AND SAFETY BASI!' mR PROHIBITION OF ELECTRONIC ENTERTAINMENT DEVICES IN NUCLEAR POWER PLANT CONTROL ROOMS" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated -

by an asterisk through deposit in the Nuclear Regulatory Commission's

-internal mail system, this 6th day of March,1987:

Gerald Charnoff Dennis Herling

• Jay Silberg Prairie Island Nuclear 2300 N. Street, N.W. Generating Plant Washington, D.C. 20037 171717akonade Drive East Welch, MN 55084 Samuel J. Chilk Bruce Berson I- Office of the Secretary USNRC, Regional Counsel III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Washington, D.C. 20555* Glen Ellyn, IL 60137

• ' Charles E. Larson David G. McGannon Vice President, Nuclear Generstion Vice President, Law Northern States Power Co. Northern States Power Co.

'- 414 Nicollet Mall 414 Nicollet Mall Minneapolis, MN 55401 Minneapolis, MN 55401 l

Atomic Safety and Licensing Appeal Atomic Safety and Licensing l Board Panel Board Panel j U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission j Washingten, D.C. 20555* Washington, D.C. 205,55*

Docketing and Service Section David M. Musolf Office of the Secretary . _

Manager, Nuclear Support Services U.S. Nuclear Regulatory Commission Northern States . Power Co.

Washington, D.C. 20555* 414 Nicollet Mall Elinneapolis, MN 55401 Maurice W. O'Brien Gordon-Miller-O'Brien

• 1208 Phymouth Building 12 South Sixth Street Minneapolis, MN 55402-529

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Geitry(S. JIizuno Counsst-for NRC Staff 5

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