NUREG-1358, Comments on B Lal Paper Re Review of Operating Events at Plants & Relation to Human Performance.Issues Identified in Paper Correct

Comments on B Lal Paper Re Review of Operating Events at Plants & Relation to Human Performance.Issues Identified in Paper Correct

ML20034D510
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	12/07/1992
From:	Russell W Office of Nuclear Reactor Regulation
To:	Lal B MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
References
RTR-NUREG-1358 NUDOCS 9212290144
Download: ML20034D510 (2)

Text

.

Ms. Bhavya Lal Department of Nuclear Engineering 4

Massachusetts Institute of Technology 77 Massachusetts Ave.

Room 24-302

$0 LO Cambridge, MA 02139

Dear Ms. Lal:

After having read your paper and discussed several of the points with you, I believe that the issues you have identified are correct. A " context" is needed for the conduct of event reviews in order to benefit from operating experience at other plants. Regulatory requirements as well as good practices can and must be implemented in the context of a particular plant.

An example of regulatory information recently issued by the NRC that contains guidance on both content and context is NUREG-1358, Supplement No.1, " Lessons Learned from the Special Inspection Program for Emergency Operating Procedures." The specific technical directions (i.e., content) in emergency operating procedures are unique to an individual plant. However, as NUREG-1358, Supplement No.1 points out, the human factors aspects of the presentation of the information (i.e., context) is equally important. A copy of NUREG-1358, Supplement No.1 is enclosed for your information.

One area that deserves additional consideration is how requirements (i.e.,

content) are effectively implemented (i.e., context) at various plants. A study of the varied approaches to implementation of a requirement may provide some insight to the development of an appropriate context. You may also want to look at operating experience feedback related to human error.

In general, we find that the content of a Licensee Event Report (LER) discussing human error is adequately documented; however, the context is often missing. The method and reason for a licensee's determination that training or procedures require revision because of an operating event is often not clearly documented in LERs. Understanding what must be revised in training or procedures, and why, is an important part of gaining any benefit from the experiences of others. However, it is not clear to me whether or not the hypertext-based method used in your original research would also be applicable to these areas of consideration.

Your paper has caused me to reflect on how the NRC currently collects information on operating events, particularly with respect to human I-tave passed your paper on to other members of my staff, and we performance.

L will consider your ideas in our efforts to disseminate operating experience.

ORIGINAL SIGNED BY Sincerely, W. T. RUSSELL j

l William T. Russell, Associate Director jl" for Inspection and Technical Assessment

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Ms. Bhavya Lal Department of Nuclear Engineering Massachusetts Institute of Technology i

77 Massachusetts Ave.

Room 24-302 l

Cambridge, MA 02139

Dear Ms. Lal:

-j After having read your paper and discussed several of the points with you, I l

believe that the issues you have identified are correct. A " context" is needed for the conduct of event reviews in order to benefit from operating i

experience at other plants. Regulatory requirements as well as good practices can and must be implemented in the context of a particular plant.

i An example of regulatory information recently issued by the NRC that contains guidance on both content and context is NUREG-1358, Supplement No.1, " Lessons Learned from the Special Inspection Program for Emergency Operating i

Procedures." The specific technical directions (i.e., content) in emergency operating procedures are unique to an individual plant. However, as NUREG-1358, Supplement No.1 points out, the human factors aspects of the presentation of the information (i.e., context) is equally important. A copy-

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of NUREG-1358, Supplement No.1 is enclosed for your information.

j One area that deserves additional consideration is how requirements (i.e.,

content) are effectively implemented (i.e., context) at various plants. A study of the varied approaches to implementation of a requirement may provide some insight to the development of an appropriate context. You may also want

• i to look at operating experience feedback related to human error.

In general, we find that the content of a Licensee Event Report (LER) discussing human error is adequately documented; however, the context is often missing. The method and reason for a licensee's determination that training or procedures

. require revision because of an operating event is often not clearly documented in LERs. Understanding what must be revised in training or procedures, and why, is an important part of gaining any benefit from the experiences of others. However, it is not clear to me whether or not the hypertext-based i

method used in your original research would also be applicable to these areas of consideration.

1 Your paper has caused me to reflect on how the NRC currently collects 1

information on operating events, particularly with respect to human performance.

I have passed your paper on to other members of my staff, and we will consider your ideas in our efforts to disseminate operating experience.

t Sincerely, 4. r. / A William T. Russell, Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation.

Enclosure As stated i

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