United States Nuclear Regulatory Commission

Office of Public Affairs

Washington, DC 20555

Phone 301-415-8200 Fax 301-415-2234

Internet:opa@nrc.gov

No. 97-034 FOR IMMEDIATE RELEASE

(Wednesday, February 26, 1997)

NOTE TO EDITORS:

The Nuclear Regulatory Commission has received a report from

its Advisory Committee on Reactor Safeguards (ACRS). The report,

in the form of a letter, provides comments on the Human Performance

Plan.

The ACRS has also sent Vice-President Al Gore its 1996 report

on the NRC's Safety Research Program.

Attachments:

As stated

#
February 21, 1997

The Honorable Albert Gore, Jr.

President of the United States

Senate

Washington, D.C. 20510

Dear Mr. President:

I am pleased to transmit to the Congress the 1996 report of

the Advisory Committee on Reactor Safeguards on the U. S. Nuclear

Regulatory Commission's Safety Research Program. This report is

required by Section 29 of the Atomic Energy Act of 1954, as amended

by Section 5 of Public Law 95-209.

Sincerely,

/s/

R. L. Seale

Chairman

Enclosure:

U. S. Nuclear Regulatory Commission, "The Advisory Committee on

Reactor Safeguards Report on Nuclear Safety Research and Regulatory

Reform," dated February 1997
3

February 21, 1997

The Honorable Newt Gingrich

Speaker of the United States

House of Representatives

Washington, D.C. 20515

Dear Mr. Speaker:

I am pleased to transmit to the Congress the 1996 report of the Advisory

Committee on Reactor Safeguards on the U. S. Nuclear Regulatory Commission's

Safety Research Program. This report is required by Section 29 of the Atomic

Energy Act of 1954, as amended by Section 5 of Public Law 95-209.

Sincerely,

/s/

R. L. Seale

Chairman

Enclosure:

U. S. Nuclear Regulatory Commission, "The Advisory Committee on Reactor

Safeguards Report on Nuclear Safety Research and Regulatory Reform," dated

February 1997
4

THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS REPORT

ON NUCLEAR SAFETY RESEARCH AND REGULATORY REFORM

The Advisory Committee on Reactor Safeguards, in the past, reported on very

specific reactor safety research issues and programs. In light of the diminished

resources available to support the U.S. Nuclear Regulatory Commission's Safety

Research Program, we have chosen, instead, to report on the potential effects of

a reduced Safety Research Program on regulatory reform and the ability to provide

adequate safety oversight for a changing nuclear industry.

A vigorous research program dealing with the safety of commercial nuclear power

production has served the Nuclear Regulatory Commission and the public well in

the past. The continued availability of unbiased safety research information

will be essential as the Nuclear Regulatory Commission establishes itself as the

leader in the national effort to reform the regulatory process to focus on real

risks, continued safety of operating nuclear power plants, and the performance

of licensees. At the same time, initiatives taken by the commercial nuclear

power industry in response to ongoing and anticipated deregulation of electrical

power generation make it even more important that the Nuclear Regulatory

Commission continue to have a Safety Research Program that provides the

information needed to modify and improve its regulations to protect public health

and safety.

From the inception of the civilian use of nuclear energy to generate electrical

power, public safety has been of paramount concern. Initially, little experience

and few industrial safety standards were available to ensure that nuclear power

could be generated safely. As a result, prescriptive, highly conservative

approaches that blanketed all aspects of nuclear power generation were adopted

by both the regulatory authority and the industry. Faults and vulnerabilities

identified through operation of nuclear power plants were used to add layers of

protection on this regulatory structure. Indeed, regulation of nuclear power

generation has been successful in protecting public safety in this country. But,

safety has been achieved through highly conservative regulation at great cost to

both the producers and consumers of nuclear power.

As nuclear power generation has matured, experience has been gained in our

understanding of the real risks of nuclear power. The Safety Research Program

has enabled the Nuclear Regulatory Commission to develop a method called

probabilistic risk assessment that can provide quantitative measures of these

risks. The sophistication of this understanding has reached the point that it

is now possible to initiate a reformation of the regulatory structure for nuclear

power generation. This reformation will focus attention on what is significant

to safety and at the same time will allow the industry to identify and use costeffective strategies to mitigate risks. Reformation of regulation of all types

to focus on risk is, of course, a national priority. The Nuclear Regulatory

Commission is taking the lead in this national effort with its policy of risk-
5

informed and performance-based regulation. Based on information that has come

from the Safety Research Program, operational experience, and the ability to

quantify risk, the Nuclear Regulatory Commission has been able to set forth

safety goals that define how safe is safe enough. By working with individuals

experienced in plant operations and using the tools of risk analysis the NRC can

now identify regulations that do not contribute to safety, and it will be able

to define a rational, cost-benefit basis for imposing additional regulatory

requirements.

Steps are being taken in the direction of risk-informed and performance-based

regulation. The performance-based maintenance rule (10 CFR 50.65) is a tangible

accomplishment. Rather than imposing bureaucratic prescriptions on every aspect

of safety system maintenance, this rule allows the industry to find creative

strategies to meet performance objectives approved by the Nuclear Regulatory

Commission based on risk information. Satisfactory performance by licensees is

rewarded by reductions in regulatory burdens while performance failures elicit

increased regulatory scrutiny.

The Safety Research Program has aided the Nuclear Regulatory Commission in the

development of standards for regulatory use of risk assessment. This would

permit additional uses of this approach to focus dwindling resources on issues

of most importance for protecting public health and safety. Target applications

of these new standards are in-service inspection, in-service testing, and

technical specifications for reactor safety systems. Continued research will be

essential for further regulatory reforms.

New challenges to the regulation of nuclear power are emerging. These challenges

come from the deregulation of electrical energy production and the need for the

nuclear power industry to become more cost competitive. The nuclear industry is

aggressively pursuing changes to remain economically viable. These changes could

have significant safety implications that will require regulatory approval when

they affect the licensing basis for nuclear power plants. Among the changes

under consideration are increased fuel lifetimes, elevated operating power,

digital instrumentation and control systems, and downsized work forces. Each of

these changes could challenge the existing regulations for the protection of

public health and safety. We believe that applied regulatory research programs

will be required to develop bases/criteria for regulatory approval of these

changes. Of particular importance are the changes that may affect human

performance in the operation of nuclear power plants.

Funding for research activities has fallen by a factor of about 3 over the last

10 years and all evidence points toward continued reductions in the future.

While much of this decrease can be attributed to the maturation of the

technology, funding for the Safety Research Program has been reduced to a level

that may not allow a cost-effective response to these new challenges. The

Nuclear Regulatory Commission now does not have the technical tools needed to

evaluate all of the safety implications of extending fuel lifetimes to the extent

the nuclear industry has requested. It cannot evaluate quantitatively the risk

implications of personnel reductions and modernization that are being proposed

by the nuclear industry. The Safety Research Program will have to be sustained
6

and even augmented if the Nuclear Regulatory Commission is to complete its

transformation to risk-informed and performance-based regulatory approach.

Without the needed research support, the Nuclear Regulatory Commission may be

forced to rely on historical, conservative, costly regulations not necessarily

focused on risks. Safety innovations by the industry may be stifled. The

opportunity to use regulation of nuclear power as an example of successful

regulatory reform may be lost.
7

February 13, 1997

The Honorable Shirley Ann Jackson

Chairman

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Dear Chairman Jackson:

SUBJECT: HUMAN PERFORMANCE PROGRAM PLAN

During the 438th meeting of the Advisory Committee on Reactor Safeguards,

February 6-8, 1997, we completed our review of the NRC activities identified in

the Human Performance Program Plan (HPPP). Our Subcommittee on Human Factors met

on September 20 and December 3, 1996, to review these activities. During these

reviews, we had the benefit of discussions with representatives of the staff.

In your remarks of December 2, 1996, to all NRC employees, you stated:

As we move to an era of nuclear power industry restructuring and

declining NRC and industry resources, it is imperative that we are able

to diagnose potentially declining licensee performance as early as

possible.

We agree with your assessment. We believe that an appropriate HPPP would

contribute significantly to the development of such diagnostic tools.

Conclusions and Recommendations

1. The HPPP is not a plan. It is, instead, an inventory of human performance

projects within the agency. The HPPP should state explicitly what its goals

are, what research efforts will be required to achieve these goals, and when

and how it will be known that they have been achieved. The ownership of the

present plan is diffuse. The success of such a plan as well as its dynamic

nature require that ownership of the entire plan be clearly assigned.

2. A well-planned research effort in human performance is urgently needed to

support both the regulation of plant operations and the transition to riskinformed and performance-based regulation. The overall perspective that can

be provided by high-level models of human performance would be helpful in

the planning of this research effort. A number of such models are reviewed

in NUREG/CR-6350.
-8-

3. The development of indicators of a good safety culture, the design of a

meaningful human performance reporting system, and the impact of downsizing

and deregulation on human performance should be major elements of the

research effort.

Discussion

Operational experience has shown that human performance is a major factor in the

safe operation of nuclear power plants. Understanding what can go wrong at a

plant requires an integrated evaluation of both hardware and human performance;

i.e., the plant must be viewed as a sociotechnical system. In particular, the

term "human error," which carries the implication that the operators are to be

blamed, is inaccurate in many instances and one must investigate and understand

the context within which plant personnel function. This context is determined

by both the design and the physical conditions of the plant, as well as by the

prevailing safety culture.

The development of a plan for research on human factors is certainly not a simple

task. This task would be made easier and the recommendations more convincing if

the task were guided by a high-level model that identifies the important elements

that influence the likelihood of unsafe human acts. Various models and

taxonomies have been proposed in the literature and some are beginning to receive

wide acceptance. Human performance models and error classifications that could

be suitable guides for developing a research plan are being used in other

projects in the Office of Nuclear Regulatory Research. The models discussed in

NUREG/CR-6350, along with insights from operational experience, could serve to

guide the development of an HPPP.

One specific element we would like to see addressed in the HPPP is the impact of

situational assessment on compliance with procedures. Investigations of actual

incidents and simulator exercises from nuclear and other industries have

demonstrated the importance of what Professor James Reason of the University of

Manchester calls "intended violations" (circumventions) of procedures by plant

personnel. The researchers who collected data from simulator exercises point out

that these were not necessarily errors; the operators simply did what they felt

was the optimal response to the evolving accident. We believe there is a need

to understand the reasons for such deviations and how training, procedures, and

the plant safety culture could be modified to eliminate "circumventions" to the

extent possible.

The present HPPP contains elements that are worth pursuing. Other elements that

should be contained in the HPPP include activities to gain a better understanding

of the concept of safety culture and to develop indicators of a good safety

culture. The human reliability analysis research project should also be part of

the HPPP. We will continue to work with the staff in developing an effective

HPPP.

Sincerely,

/s/
-9-

R. L. Seale

Chairman

References:

1. Memorandum dated July 31, 1996, from Cecil Thomas, Office of Nuclear Reactor

Regulation, to John Larkins, ACRS Executive Director, Subject: Forwarding

Human Performance Plan Rev. 1

2. Office for Analysis and Evaluation of Operational Data Report E-95-01,

"Operating Events with Inappropriate Bypass or Defeat of Engineered Safety

Features," July 1995

3. U. S. Nuclear Regulatory Commission, NUREG/CR-6093, "An Analysis of

Operational Experience During LP&S and a Plan for Addressing Human

Reliability Issues," June 1994

4. U. S. Nuclear Regulatory Commission, NUREG/CR-6265, "Multidisciplinary

Framework for Analyzing Errors of Commission and Dependencies in Human

Reliability Analysis," August 1995

5. U. S. Nuclear Regulatory Commission, NUREG/CR-6350, "A Technique for Human

Error Analysis (ATHEANA)," May 1996

6. Reason, J.T., Human Error, Cambridge University Press, Cambridge, United

Kingdom, 1990

7. R. Montmayeul, F. Mosneron-Dupin, and M. Llory, "The Managerial Dilemma

between the Prescribed Task and the Real Activity of Operators: Some Trends

for Research on Human Factors," Reliability Engineering and System Safety,

45:67-73, 1994

8. U. S. Nuclear Regulatory Commission, NUREG/CR-6208, "An Empirical

Investigation of Operator Performance in Cognitively Demanding Simulated

Emergencies," July 1994

9. International Atomic Energy Agency, Vienna, International Nuclear Safety

Advisory Group, "Safety Culture," Report 75-INSAG-4, 1991

10. NRC Chairman Shirley Ann Jackson's remarks to all NRC employees, December

2, 1996