View source for NUREG-0985, Responds to Inquiry Re Concerns of Human Factors Activities at Nrc.Most of Recommendations Noted in Human Factor Society Rept Implemented.State of Human Factors Consideration Both by NRC & Nuclear Industry Advanced Significantly Since TMI

{{Adams
| number = ML20245A391
| issue date = 03/20/1987
| title = Responds to Inquiry Re Concerns of Human Factors Activities at Nrc.Most of Recommendations Noted in Human Factor Society Rept Implemented.State of Human Factors Consideration Both by NRC & Nuclear Industry Advanced Significantly Since TMI
| author name = Stello V
| author affiliation = NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
| addressee name = Hornick R
| addressee affiliation = HUMAN FACTORS SOCIETY, INC.
| docket = 
| license number = 
| contact person = 
| case reference number = RTR-NUREG-0985, RTR-NUREG-985, RTR-NUREG-CR-2833
| document report number = GL-82-33, NUDOCS 8703260079
| package number = ML20204E881
| document type = CORRESPONDENCE-LETTERS, NRC TO PROFESSIONAL/INDUSTRIAL ASSOCIATION, OUTGOING CORRESPONDENCE
| page count = 6
}}

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Dr. Richard J.;Hornick, Past-Pres'ident q
        ' Human Factors Society                                                        3
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==Dear Dr. Horn k k:==
q                                                                    i 3            i I am responding to your inquiry rdgerdinS ttw Huran Factors Societv's HFS)-                                                                                          g concerns about hunut factors actWities at tW9!uclear Regulatory Dom (ission (NRC).                      jg                                     ,
I Youstatedtdatyouhavere,asontobelieveth1tthe'NRCIsignorin the HfS ReportandthathumanfactorsconsiderationinP.heNRC,andthe'nucear -
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m industry is close to pre-TMI levels. The NkC has, in fact, implemented mcst of the HFS Report'resemendations. Of the 51 recomendations in.the Reportg 46 were specifica11ydncluded in the NRC's Humar Factors Prog' ram' Pip (HFPP,,
NUREG-0985. Appendu'8 of the orfeinal M?P documents the extensive use by                                                                                             l NRC of the HFS Reptrt' an4 the disposition of each recomendation. Because the Plan is a Civig 4 cutent and almanagement tool to schedule and allocate resources, a decision was' made not to track coroleted actions in the Plan,                                                              s rathercompletedwoYkisidentifiedinAppendiiA(Revision 2)andits
         -bibliography. As e, result, the original Appendix B was'not carried forward in subsequent versions of the Plan. The staff coricluded that 5 of 51 recom-mendations in the HFS Repcrt should not be adopted because:
1
* Two recommendatkons were related to perstnnel" selection whf :h are not properly within the NRC purview.                                 k                                      g The recomendation for better protective clothing, tools,; and instruments, was being accomplished by the nuclear industry.
The HFS recomendstion to tem.nate reseedr. related to human error contributions to suppprt Probabilistic RisktAssasment (PRA) was not adopted based upon the importam.'etRC placed upon PRA.
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* The recommendatIc,n \to perform a system anal need for a Safety Parameter Display Gystem                                                                  SPDS)(ysis  sat:allto determine plants was      the moot since NRC had.1 ,alread! issued regoirements         ,w                                                       for.an SPDS.
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Yourstatementth'at"Nohumanfactorsenginpf.,rygrequirementsh'avebeen established in thelCode of Federal Regulations, implies a concern that NRC has not required 4 man factors engineering be" incorporated, when' appropriate, into the design of nuclear power plants. The MC used a combination of means to implement A man factors eng W erir.g requirements. For licensees of operating plants and applicants'for operating licanses and holders of con-struction pern/ts, the Comission initiated impigentation of human factors engineering ejuirements through issuance of. gen 9hc letters.                                                                                         j' dJ J 'h lf, s
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Specifically, the human factors engineering requirements related to development of Energency Operating Procedures, (E0Ps) 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, confirmatory orders were issued following receipt of licensee-proposed implementation schedules to mandate implementaticn 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-l       ,c     cations were pending, the Comission chose to implement these same requirements s '
by amend: rent 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 Commission 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.
                 ' WehisagreethattheguidelinedocumentsrelatedtotheDCRDRareunenforceable 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.
In regard to the specific questions you posed, the following answers should be considered:
: 1.      "What is the NRC doing to implement the reccmmendations 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 x                       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,
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and the man-machine interfsc'e. T$e.,0fffWof Research expended approximately $1.2 million dollars in Fiscal Year 1986 in support of                                 T     i human factors programs in human reliability and human factors aspects of severe accident research. While the total amount is less than that                                         i programmed in previous fiscal years,' this is occurring because many off ;
I            <<J            the specific tasks identified in the HFPP have been completed.
                                                             ~
: 3.        "What is the status of the;NRC submission of a human factors engineering requirement for the Code of Federal Regulations?"
As noted previously, the NRC has used a combination of means tc require human factors engineering. Based upon the requirements in Generic
                               ,   Letter-82-33 and 10 CFR,50.34, the NRC staff detemined that an amendment to add a Human Factors General Design Criteria to 10 CFR 50, J/(
1
             /                     Appendix A was not required and thus, staff effort on a proposed rule
't change was terminated in Fiscal Year 1986.
: 4.        "What is the National Academy of Sciences charged to.do' th'at was not i                                  already performed by the Society's study team?"'                    *
                                 ;The decision 4to 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 ictivities have become .
part of ongoing NRC efforts related to the reviiw'of applications,
   !,                              amendments to operating licenses, evaluation of incidents and other 3,                              day-to-day oversight of the safety of reactor operations. The objectives l Q~                               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 t.he safe operation of nuclear power plants. The NAS report will be used fto: guide future NRC research. It will not be used to develop research
                                 ~ plans or programs, but only to identify those areas where more information
;                                  cr.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.
Sincerely, 02 f ginal signed by Victor Stolle,, -                g
                                                               ;         Victor Stello, Jr.                's Executive Director, for Operations t                             < ;
,                        cc: Sen. Edward Kennedy
                         *See attached for previous concurrences - RETYPED IN EDO 3/19/87 Revised per Commissioners' & OGC coments.                                           /
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_____:-___________:...__......:....________:____________:._______..__:_ m.________:___________
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:NAME-:DJones*                                           :WRussell*                    :HDenton*         :V :ello ,             :   ,
!   4.__:____________:____..,.                      ____:_,__________:____________:____________:_ ,_________:.________..
DATEL:2/24/87                          :2/24/87.        :2/24/87     :2/27/87         :2/27/87          :3hc /87 ~             :
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                 ,              DISTRIBUTION: ED0-002537/ED0-009533 (letters to Dr. Hornick & Hon. Udall)
NRC PDR Central Files EDO RF
      ,                         VStello 4                JRoe 4-           TRehri Y                JSniezek EBeckjord JTaylor JMurray Denton/Vollmer PPAS
                        ,       MBridgers   ED0 2533 -& 2537 DMossburg~
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      \.....                         ED0 PRINCIPAL CORRESPONDENCE CONTROL suilEUg FROM:                                                   DUE: 03/03/87         EDO CONTROL: 002537 SEN. EDWARD M. KENNEDY                                                           D'OC DT 02/11/87 FINAL REPLY:
TO:
KAMMERER FOR SIONATURE OF:                                        **        OREEN  **       SECY NO: 87-120 DENT 0fr & Db DESC:                                                                         ROUTINO:
ENCLOSES LTR FROM RICHARD J. HORNICK                    " 4N FACTORS         IURLEY SOCIETY RAISING QUESTIONS CONCERNING A COMPREHENSIVE                         BECKJORD LONG-RANGE HUMAN FACTORS PLAN                                                !URRAY DATE: 02/17/87 ACSIONED TO: NRR                    CONTACT:DENTON SPECIAL It4STRUCTIONS OR REMARKS:
REF. ED0 2533.
REPLY.' DIRECT T01 CONSTITUENT WITH:CC T0: .
sSEN(. KENNEDY.7- -
NRR RECEIVED: ,2/18/87 -..
ACTION:        'DHFT: RUSSELL' NRR ROUTING:      DENTGN/VOLLMER PPAS MOSSBURG

             . p                         CORRESPONDENCE CONTROL TICKET                       E MKenn:dy
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        ..        SECY NUPEER:    87-0120                                         LOGGING DATE_ pfi7fny ACTION OFFICE:       ED0 AUTHOR:
Edward Kennedy--Const Ref AFFILIATION:         U.S. Senate--1000 i
2/11/87                                    FILE CODE-LETTER DATE:
l ADDRESSEE:

==SUBJECT:==
Questions concerning a comprehensive human factors plan ACTION:              Direct Reply... Suspense: Mar 3       (11)
DISTRIBUTION:        OCA to Ack SPECIAL HANDLING:    Richard Hornick
                                                                                                        ^
FOR THE COPHISSION SIGNATURE DATE:
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