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February 19, 1999 Dr. William D. TraversExecutive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Dear Dr. Travers: SUBJECT: SECY-98-244, "NRC HUMAN PERFORMANCE PLAN" During the 459th meeting of the Advisory Committee on Reactor Safeguards, February 3-6, 1999, we reviewed the current version of the NRC Human Performance Plan (HPP) contained in SECY-98-244 and the staff's strategy for completing the development of the HPP. Since February 1996, we have held several meetings with the staff to discuss various versions of the HPP and have issued three reports. During our most recent review, we had the benefit of discussions with representatives of the staff and of the documents referenced. Observations and Recommendations
- review of the Accident Sequence Precursor (ASP) data to identify the contribution of human performance to significant events, and - interaction with other organizations, such as the Institute of Nuclear Power Operations (INPO), that have a strong focus on human performance. Discussion The staff has formulated an interim process for prioritizing human performance activities within the agency. This approach was based on the judgments of managers using information and knowledge available to them. The product of this "modified Delphi" process is a prioritized list of human performance activities with highest priorities assigned mostly to near-term activities. Of more importance, the staff has formulated a disciplined strategy to develop a more technically defensible HPP. The future development of the HPP will begin with the identification of agency needs in the field of human performance. These identifications will be made quantitatively where possible. The ASP data for events, over the last five years, with conditional core damage probabilities greater than 10-5 will be reviewed to isolate the human performance contributions. Licensee event reports, insights from individual plant examinations, NRC inspection reports, and results of system studies performed by the then Office for Analysis and Evaluation of Operational Data will also be reviewed . The findings from these efforts will be augmented by human reliability analysis sensitivity studies. We believe that these findings should be compared to error classifications available in the literature. This strategy will lead to the formulation of a list of agency needs that can be justified by NRC line organizations and understood by stakeholders. The list of human performance needs for NRC will be prioritized by a process now being developed within the Office of Nuclear Regulatory Research. Requirements and closure conditions for the priority activities will be defined, quantitatively where possible, using regulatory analysis guidelines and risk criteria such as those described in Regulatory Guide 1.174. There are additional steps that will have to be defined to complete the process for the disciplined planning of technically justified work in human performance. Strategies to develop alternative candidate solutions to the prioritized needs will have to be developed. Testing and validation of solutions, as well as requirements for the interfaces among elements of the plan, will also have to be developed. We were pleased to see that the staff plans to interact with INPO in the search for agency needs and candidate solutions. We are looking forward to the development and implementation of the proposed approach, and plan to hold future meetings to review progress in completing the development of the Human Performance Plan. Sincerely, /s/ Dana A. Powers |