ML20212Q066
| ML20212Q066 | |
| Person / Time | |
|---|---|
| Issue date: | 03/24/1987 |
| From: | Zech L NRC COMMISSION (OCM) |
| To: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML20209A941 | List: |
| References | |
| NUDOCS 8704010084 | |
| Download: ML20212Q066 (3) | |
Text
-_
t UNITED STATES y
,,4f kg NUCLEAR REGULATORY COMMISSION
. 3 c.t W ASHINGTON, D. C. 20555 C
3 o ! -
% *.~*..
.j March 24, 1987 CHAIRMAN The Honorable Horris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, D. C. 20515
Dear Sir. Chairman:
I am responding to your letter of January 30, 1987 concerning I correspondence you received from the Human Factors Society.
am enclosing a copy of the Executive Director for Operations' (EDO) resnonse to Dr. Richard J. Hornick, Past President of the Society. I assure you that the Commission recognizes the imDact of human factors and human performance to the continued safe operation of nuclear facilities. The Commission will continue to emphasize the importance of these issues in its regulatory program.
Commissioner Asselstine disaarees with this resoonse and will provide his views in a separate letter.
Sincerely,
- b. .
Lando W. Z h,J
Enclosure:
As Stated I
I teal. eeW 4
1
'o UNITED STATES
- 8 o NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D. C. 20665 l 7,
March 20, 1987 i k*...*/ ,
Dr. Richard J. Hornick, Past-President Human Factors Society Post Office Box 1369 Santa Monica, CA 90406
Dear Dr. Hornick:
I am responding to your inquiry regarding the Human Factors Society's (HFS) concerns about human factors activities at the Nuclear Regulatory Comission (NRC).
You stated that you have reason to believe that the NRC is ignoring the HFS Report and that human factors consideration in the NRC and the nuclear industry is close to pre-TMI levels. The NRC has, in fact, implemented most of the HFS Report recomendations. Of the 51 recomendations in the Re 46 were specifically included in the NRC's Human Factors HFPP), Program Pla NUREG-0985. Appendix B of the original HFPP documents the extensive use by HRC of the HFS Report and the disposition of each recomendation. Because the Plan is a living document and a management tool to schedule and allocate resources, a decision was made not to track completed actions in the Plan, rather ccmpleted work is identified in Appendix A (Revision 2) and its bibliography. As a result, the original Appendix B was not carried forward in subsequent versions of the Plan. The staff concluded that 5 of 51 recom-mendations in the,HFS Report should not be adopted because:
- Two recomendations were related to personnel selection which are not properly within the NRC purview.
- The recomendation for better protective clothing, tools, and inttruments, was being accomplished by the nuclear industry.
The HFS recomendation to terminate research related ta human error contributions to support Probabilistic Risk Assessment (PRA) was not adopted based upon the importance NRC placed upon PRA.
' The recomendation to perform a systems analysis to determine the need for a Safety Parameter Display System (SPDS) at all plants was moot since NRC had already issted requirements for an SPDS.
Your statement that "No human factors engineering requirements have been established in the Code of Federal Regulations," implies a concern that NRC has not required human factors engineering be incorporated, when appropriate, into the design of nuclear power plants. The NRC used a combination of means to implement human factors engineering requirements. For licensees of operating plants and applicants for operating licenses and holders of con- l i
struction permits, the Comission initiated implementation of human factors engineering requirements through issuance of generic letters. !
r n
@ MPP2 '(
, , - , a _
4 l
l Specifically, the human factors engineering requirements related to development of Emergency Operating Procedures, (EOPs) Control Room Design Reviews (DCRDR) and Safety Parameter Display Systems (SPDS) were proposed on December 17, 1982 via Generic Letter 82-33 which pursuant to 10 CFR 50.54(f) requested the sub-mittal of schedules for completion of the basic requirements (including human factors engineering requirements) identified in the letter's enclosures. For plants then operating, confimatory orders were issued following receipt of licensee-proposed implementation schedules to mandate implementation of these requirements. The requirements were implemented through license conditions in the initial license issued to applicants which had operating license applications pending at the time. For selected plants, for which construction permit appli-cations were pending, the Comission chose to implement these same requirements by amendment to the NRC's regulations. Section 50.34(f)(2) was revised to require human factors engineering for emergency procedures; control room designs and safety parameter displays. In addition, new sections of the Standard Review Plan (SRP) addressing human factors have been issued; e.g., the new Chapter 18 which is dedicated to Human Factors Engineering. The regulations require under 10 CFR 50.34(g) that an applicant conform to the SRP or identify deviations and discuss how the alternative provides an acceptable method of complying with
- those rules or regulations of the Comission that underlie the corresponding SRP acceptance criteria. Thus, the guidelines in Chapter 18 of the SRP have the practical effect of requiring extensive human factors engineering or licensee justification of how the alternative proposed provides an acceptable method of complying with the regulations cited in SRP, Chapter 18.
We disagree that the guideline documents related to the DCRDR are unenforceable as implied by your letter. The staff chose this regulatory scheme for DCRDR and SPDS human factors engineering requirements to allow advances in human factors engineering especially in the area of computer technology to be incorporated '
into new designs. The staff did not wish to stifle innovation by imposing rigid requirements. With respect to enforcement of human factors requirements, the staff has utilized the full spectrum of enforcement options available under the enforcement policy in 10 CFR Part 2. Appendix C up to and including civil penalties for noncompliance with regulations, orders or license conditions pertaining to such requirements. l In regard to the specific questions you posed, the following answers should be considered:
1 1. "What is the NRC doing to implement the recommendations of the Society's 1982 report to the NRC?"
As discussed above, the NRC has adopted 46 of 51 of the Society's recom-mendations and has amended its regulations to require Human Factors Engineering. NRC believes that human factors has become a part of many ongoing NRC programs and that a separate HFPP is no longer needed.
- 2. "What is the status of NRC funding for the conduct of human factors research?"
During Fiscal Year 1986, the Division of Human Factors Technology expended over a million dollars in research and development activities, primarily in the program areas of licensing examinations, procedures, 1
em, , , - - - - - -,--- ----,, -w--, - -,, . - - - - - - - - , - . - , , _ - . , . , , .--.-e ,- --.m,-_,. , 4,,- ,---- - - - --,-n-.----
4 7
4 f
and the man-machine interface. The Office of Research expended l
approximately $1.2 million dollars in Fiscal Year 1986 in support of human factors programs in human reliability and human factors aspects of
! severe accident research. While the total amount is less than that programmed in previous fiscal years, this is occurring because many of the specific tasks identified in the HFPP have been completed.
4
- 3. "What is the status of the NRC submission of a human factors engineering requirement for the Code of Federal Regulations?"
i As noted previously, the NRC has used a combination of means to require human factors engineering. Based upon the requirements in Generic i.etter 82-33 and 10 CFR 50.34, the NRC staff determined that an amendment to add a Human Factors General Design Criteria to 10 CFR 50, Appendix A was not required and thus, staff effort on a proposed rule j change was terminated in Fiscal Year 1986.
- 4. "What is the National Academy of Sciences charged to do that was not j
already performed by the Society's study team?"
The decision to request the National Academy of Sciences (NAS) to review where we've been and to make recommendations as to where we should go is based upon the continuing need to reassess the scope of human factors research. As described earlier, human factors activities have become part of ongoing NRC efforts related to the review of applications, amendments to operating licenses, evaluation of incidents and other day-to-day oversight of the safety of reactor operations. The objectives
- of the NAS study are to identify areas in the current and recent pro-grams that may have received inadequate attention and to provide guidance to NRC's Office of Nuclear Regulatory Research, and other research and development agencies in government, private industry, and universities regarding an appropriate research program in human factors to enhance the safe operation of nuclear power plants. The NAS report will be used to guide future NRC research. It will not be used to develop research plans or programs, but only to identify those areas where more information
' or research is required.
In conclusion, it is our belief that the state of human factors consideration
~,
both by the NRC and the nuclear industry has advanced significantly since TMI.
i Sincerely, f> (D t A Vict Stello, r.
Executive Director /
/
for Operations cc: Sen. Edward Kennedy
- . . _ _ _ _ _. _. , . , , . _ _ _ __. _ _ _ _ _ ., . _ _ _ _ _ _ _ _ _ _ _ _