NUREG-1791

Guidance for Assessing

Exemption Requests from the

Nuclear Power Plant

Licensed Operator Staffing 

Requirements Specified in

10 CFR 50.54(m)

Final Report

U.S. Nuclear Regulatory Commission

Office of Nuclear Regulatory Research

Washington, DC 20555-0001
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NUREG-1791

Guidance for Assessing 

Exemption Requests from the

Nuclear Power Plant

Licensed Operator Staffing

Requirements Specified in

10 CFR 50.54(m)

Final Report

Manuscript Completed: July 2005

Date Published: July 2005

Prepared by

J. Persensky, A. Szabo/U.S. Nuclear Regulatory Commission

C. Plott, T. Engh/Micro Analysis & Design

V. Barnes/Performance, Safety, & Health Associates

A. Szabo, NRC Project Manager

J. Persensky, Senior Technical Advisor

Prepared for

Division of Risk Analysis and Applications

Office of Nuclear Regulatory Research

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

iii

ABSTRACT

Regulations set forth by the U.S. Nuclear Regulatory Commission (NRC) prescribe the qualifications and

staffing levels for licensed operating personnel for nuclear power plants. The introduction of advanced

reactor designs and increased use of advanced automation technologies in existing nuclear power plants

will likely change the roles, responsibilities, composition, and size of the crews required to control plant

operations. Current regulations regarding control room staffing, which are based upon the concept of

operation for existing light-water reactors, may no longer apply. Therefore, applicants for an operating

license for an advanced reactor, and current licensees who have implemented significant changes to

existing control rooms, may submit applications for exemptions from current staffing regulations. The NRC

staff is responsible for reviewing the exemption requests and must determine whether the staffing proposals

provide adequate assurance that public health and safety will be maintained at a level that is comparable to

that afforded by compliance with the current regulations.

This guidance provides a process for systematically reviewing and assessing these submittals. It details the

information, data, and review criteria necessary to review the exemption request. The information and data

from an exemption request could include (1) the description of the request, the concept of operations, and

operational conditions considered, (2) supporting analyses and documentation from operating experience,

functional requirements analysis and function allocation, task analysis, job definition, and staffing plan, and

(3) data and analysis from validation exercises performed to demonstrate the effectiveness and safety of the

proposed staffing plan.

The information collections contained in this guidance are covered by the requirements of 10 CFR Part 50,

which were approved by the Office of Management and Budget, approval number 3150-0011.

Public Protection Notification

The NRC may neither conduct nor sponsor, and a person is not required to respond to, a request for

information or an information collection requirement unless the requesting document displays a currently

valid OMB control number.

v

FOREWORD

This document provides guidance for the NRC staff to systematically review and assess requests by

licensees of nuclear power plants for exemption from the licensed operator staffing requirements of Title 10,

Part 50 of the Code of Federal Regulations (10 CFR 50) contained in 10 CFR 50.54(m). The purpose of the

NRC’s review is to ensure public health and safety by verifying that the applicant’s staffing plan and

supporting analyses sufficiently justify the requested exemption. 

The increased use of advanced automation technologies in existing nuclear power plants and the

introduction of advanced reactor designs will likely change the roles, responsibilities, composition, and size

of the crews required to control plant operations. Current regulations regarding control room staffing, which

are based on the concept of operation for existing light-water reactors, may no longer apply. Licensees of

nuclear power plants who have implemented significant changes to existing control rooms or who have

introduced increased use of advanced automation technologies may submit applications for exemption from

the requirements. Likewise, because of the anticipated changes in operator roles and responsibilities in

new reactor designs, an applicant for an operating license for a new reactor may wish to seek exemption

from the current licensed operator staffing requirements. 

This document identifies the type of information and data that should be considered in a regulatory review of

an exemption request which includes: (1) the description of the request, the concept of operations, and

operational conditions considered, (2) supporting analyses and documentation from operating experience,

functional requirements analysis and function allocation, task analysis, job definition, and staffing plan, and

(3) data and analysis from validation exercises performed to demonstrate the effectiveness and safety of the

proposed staffing plan. The review process described in this document addresses all of these elements and

includes guidance for each review step.

In reviewing exemption requests, the NRC staff must determine whether the licensees’ staffing proposals

provide adequate assurance that public health and safety will be maintained at a level that is comparable to

compliance with the current regulations. This guidance provides a strong technical basis to inform the

decision-making process and allow the staff to make good technical judgments. This approach is consistent

with the performance goals of the NRC’s Strategic Plan for Fiscal Years 2004–2009 (NUREG-1614, Vol. 3,

as well as Chapter 18.0 of the NRC’s Standard Review Plan (NUREG-0800) and Rev. 2 of NUREG-0711,

“Human Factors Engineering Program Review Model.” It is also consistent with NUREG/IA-0137, “A Study

of Control Room Staffing Levels for Advanced Reactors.”

 

Carl J. Paperiello, Director

Office of Nuclear Regulatory Research

U.S. Nuclear Regulatory Commission

vii

CONTENTS

Page

Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xv

Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xvii

PART I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-1

1. Overview of the Guidance Document . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-1

1.1 Purpose and Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-1

1.2 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-1

1.3 Impact of New Technologies on the Roles and Responsibilities of Licensed Personnel . I-1-1

1.4 Limitations of the Current Regulatory Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-3

1.5 Implications for the Review of Exemption Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-5

1.6 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-6

1.7 Organization of the Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-6

2. Overview of the Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-2-1

PART II. EVALUATION OF EXEMPTION REQUESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1-1

1. Review the Exemption Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1-1

1.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1-1

1.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1-2

1.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1-3

1.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1-3

2. Review of the Concept of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2-1

2.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2-1

2.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2-1

2.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2-2

2.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2-2

3. Review the Operational Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3-1

3.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3-1

3.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3-1

3.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3-1

3.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3-3
viii

Page

4. Review Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-4-1

4.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-4-1

4.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-4-1

4.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-4-2

4.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-4-3

5. Review the Functional Requirements Analysis and Function Allocation . . . . . . . . . . . . . . . . . . II-5-1

5.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-5-1

5.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-5-2

5.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-5-3

5.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-5-3

6. Review the Task Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6-1

6.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6-1

6.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6-1

6.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6-5

6.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6-5

7. Review the Job Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-7-1

7.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-7-1

7.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-7-2

7.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-7-2

7.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-7-3

8. Review the Staffing Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8-1

8.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8-1

8.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8-1

8.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8-2

8.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8-2

9. Review of Additional Data and Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-9-1

10. Review the Staffing Plan Validation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10-1

10.1 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10-1

10.2 Applicant Submittals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10-5

10.3 Review Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10-6

10.4 Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10-8

11. Determine the Acceptability of the Exemption Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-11-1

Appendices

A. Review Checklists . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

B. Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

C. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1
ix

Page

Figures

1 Relationship of this Document to Current Regulations and Other Guidance . . . . . . . . . . . . . . . . I-1-6

2 The Exemption Request Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-2-2

Tables

1 Minimum Requirements Per Shift for On-Site Staffing of Nuclear Power Units by Operators and

Senior Operators Licensed Under 10 CFR Part 55 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1-4

2 Task Performance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6-2

xi

EXECUTIVE SUMMARY

U.S. Nuclear Regulatory Commission (NRC) regulations prescribe the qualifications and staffing levels for

licensed operating personnel for nuclear power plants. The design features and concepts of operation for

new generations of advanced reactors, as well as the increased use of advanced, automated, and digital

systems in existing plants, may lead applicants to request variations in the prescribed number, composition,

or qualifications of licensed personnel. This will require applicants to submit exemption requests from

applicable regulations included primarily in Title 10, Section 50.54(m), of the Code of Federal Regulations

(10 CFR 50.54(m)).

Staff of the NRC will review these exemption requests to determine their acceptability. The purpose of this

review is to ensure public health and safety by verifying that the applicant’s staffing plan and supporting

analyses sufficiently justify the requested exemption. The applicant’s submittal should include (1) the

description of the request, the concept of operations, and operational conditions considered, (2) supporting

analyses and documentation from the operating experience, functional requirement analysis and function

allocation, task analysis, job definition, and staffing plan, and (3) data and analysis from validation exercises

performed to demonstrate the effectiveness and safety of the proposed staffing plan.

This document describes a review process that addresses all of these elements and includes the following

guidance for each review step:

• a discussion of the review step and why it needs to be addressed

• data and information required to support the review step

• review criteria for evaluating the submittals

• additional information that may be useful in performing the review

The guidance also includes, in Appendix A, a series of checklists for each review step. Appendix B

provides a glossary of terms used in the guidance, and Appendix C offers a list of references.

The review steps are as follows:

(1) Review the Exemption Request

The NRC staff conducts a general review of the requested exemption(s) to determine the scope of the

request(s). As part of this review, the staff also identifies any new or modified concepts, or changes in

meanings for terms included in the regulations (e.g., operator, control room, unit) introduced as part of the

application.

(2) Review the Concept of Operations

The purpose of reviewing the concept of operations is to gain an understanding of the role of control

personnel in overall plant operations. Understanding the applicant’s intended concept of operations also

establishes the context for subsequent steps in the review.
xii

(3) Review the Operational Conditions

The purpose of the review of the operational conditions is to ensure that the applicant analyzed the

operational conditions which present the greatest potential challenges to the effective and safe performance

of control personnel, under the conditions of the requested exemption, and that the analysis supports the

exemption request. The staff evaluates the operational conditions defined by the applicant for

completeness and uses them with the other review steps to assess the exemption request.

(4) Review Operating Experience

The staff reviews the operating experience to ensure that the applicant has performed a review of relevant

operational experience to identify and address staffing-related lessons learned that may be important to the

exemption request. This review may include plants with similar designs, plants that have implemented

similar technologies, or similar concepts of operation from other industries.

(5) Review the Functional Requirements Analysis and Function Allocation

This review has two purposes. The first purpose is to ensure that the applicant has defined and evaluated

the impact of the exemption request on the plant/system functions that must be performed to satisfy plant

safety objectives. The second purpose is to ensure that the allocation of functions to humans and systems

has resulted in a role for personnel that uses human strengths, avoids human limitations, and can be

performed under the operational conditions evaluated in the exemption request.

(6) Review the Task Analysis

The purpose of the task analysis review is to ensure that the applicant’s analysis identifies the specific tasks

that are needed to accomplish functions and their staffing implications. For each task, the applicant should

address the information, control, and task-support requirements in its task analysis, as applicable. The

reviewer will ensure that the applicant identified any issues related to task timing, workload, situation

awareness, and resource conflicts that would affect staffing assignments.

(7) Review the Job Definitions

The purpose of the job definition review is to confirm that the applicant has established clear and rational job

definitions for the personnel who will be responsible for controlling the plant, in the case of a new plant

design. For an existing plant in which new systems will be implemented, the purpose of the review is to

ensure that the applicant has retained clear and rational job definitions for control room personnel.

(8) Review the Staffing Plan

The purpose of the staffing plan review is to ensure that the applicant has systematically analyzed the

requirements for the numbers of qualified personnel that are necessary to operate the plant safely under the

operational conditions analyzed. 
xiii

(9) Review of Additional Data and Analyses

The reviewer may find that additional data and types of reviews may be needed to complete the review of

the exemption request(s). The reviewer could require data from areas such as human reliability analysis;

human-system integration; knowledge, skills, and abilities; procedures; and training analysis. Data

submitted by the applicant for these review areas would provide further justification in support of the

exemption request.

(10) Review the Staffing Plan Validation

The most important step is the review of the applicant’s staffing plan validation. The purpose of reviewing

the validation of the staffing plan is to ensure that the applicant fully considered the dynamic interactions

between the plant design, its systems, and control personnel for the operational conditions identified for the

exemption request.

(11) Determine Acceptability of the Exemption Request

In this step, the NRC staff makes a final decision regarding the acceptability of the exemption request. The

decision will be based on the aggregate findings from the previous steps of the review.

xv

ACKNOWLEDGMENTS

We would like to acknowledge the following people who provided valuable feedback during the early

development of this document as members of our peer review committee:

Joseph DeBor Consultant

Richard Eckenrode Office of Nuclear Reactor Regulation, NRC (retired)

Robert B. Fuld Westinghouse Nuclear Automation

Greg Galletti Office of Nuclear Reactor Regulation, NRC

Lew Hanes Electric Power Research Institute

John Hawley Army Research Laboratory

Jacques Hugo Pebble Bed Modular Reactor

Scott Malcolm Atomic Energy of Canada Limited

John O’Hara Brookhaven National Laboratory

Kevin Williams Office of Nuclear Reactor Regulation, NRC

We would also like to acknowledge the following people who provided valuable feedback during the internal

review of this document:

Matthew Chiramal Office of Nuclear Reactor Regulation, NRC

James Bongarra Office of Nuclear Reactor Regulation, NRC

xvii

ABBREVIATIONS

CFR Code of Federal Regulations

HFE human factors engineering

HSI human systems interface

KSA knowledge, skills, and abilities/aptitudes

NRC U.S. Nuclear Regulatory Commission

NUREG NRC technical report designation (Nuclear Regulatory Commission)

PRA probabilistic risk assessment

RAI request for additional information

SA situation awareness

I-1-1

PART I

INTRODUCTION

1. OVERVIEW OF THE GUIDANCE DOCUMENT

1.1 Purpose and Scope

The purpose of this document is to provide the staff of the U.S. Nuclear Regulatory Commission (NRC) with

a process for evaluating requests for exemption from one or more of the requirements specified in Title 10,

Section 50.54(m) of the Code of Federal Regulations (10 CFR 50.54(m)). Other regulations may be

impacted by a request for exemption from the current staffing regulations. For example, a request for

exemption may be based on the implementation of advanced technologies that change the roles and

responsibilities of personnel licensed under 10 CFR Part 55. Because the nature of potential exemption

requests based on advanced technologies is currently unknown, this guidance provides a flexible review

process and a set of systematic methods that the NRC can use to evaluate a wide range of staffing-related

exemption requests. 

1.2 Background

The introduction of advanced reactor designs and the increased use of advanced automation in existing

nuclear power plants will likely change the roles, responsibilities, composition, and size of the crews

required to control plant operations. The design features and concepts of operation for new generations of

advanced reactors, as well as the introduction of new automated or digital systems into existing plants, may

lead to reductions in staff size and a changing role for the operator. For the purposes of this guidance

document, the term, concept of operation, refers to a description of how a licensee’s or applicant’s

organizational structure, staffing, and management framework relate to the systems, design, and

operational characteristics of the plant. Current regulations regarding control room staffing, which are

based upon the concept of operation for existing light-water reactors, may no longer apply. Therefore,

applicants for an operating license for an advanced reactor, and current licensees who have implemented

significant changes to existing control rooms, may submit applications for exemptions from current staffing

regulations. The NRC staff will review the exemption requests and determine whether the staffing

proposals will provide adequate assurance that public health and safety will be maintained at a level that is

comparable to compliance with the current regulations.

1.3 Impact of New Technologies on the Roles and Responsibilities of Licensed Personnel

There is a relatively wide range of potential changes to reactor designs and to the technologies that will be

available for maintaining operational control of new and existing nuclear power plants. Simplified designs

and operations, increased use of advanced automation, and new technologies for human-system interfaces

(HSIs) will change the role of the human in plant operations.

Many advanced reactor designs incorporate passive safety features that require minimal operator

intervention to mitigate accidents in the event of malfunction. These passive safety features are based on

natural forces, such as convection and gravity, making safety functions less dependent on active systems
I-1-2

and components, such as pumps and valves. The passive features allow operators more time to perform

safety actions. The increased time available to respond to events could reduce the number of personnel

required on each shift, because there would be time to augment the control staff to respond to the event.

For both advanced plant control room designs and some potential upgrades to existing control rooms, the

increased use of automated control, monitoring, and protection systems will bring the plant back to normal

conditions or to a safe shutdown state without the need for operator action. In addition, this reduced need

for human intervention may, in turn, reduce the number of people required to control plant operations.

Automated systems that support and supplement human cognitive functions associated with controlling the

plant may also affect staffing configurations in both advanced and existing plant control rooms. 

Technological advances, such as intelligent agents, computer-supported cooperative work, knowledge

engineering, and knowledge-based systems, are leading to designs of automated systems that enhance

control room personnel capabilities for monitoring, disturbance detection, situation assessment, response

planning, and response execution.

Along with these advances in automation technology, new HSI technologies are also emerging. Rather

than having control rooms with panels full of controls and displays, there will be “control suites,” consisting

of a set of computer displays and input devices. Information can be displayed dynamically across the

monitors in the display and enhanced auditory signals, such as speech, will be possible. An array of input

capabilities including touch, gesture, and speech are also possibilities. Intelligent support systems can

enhance the timing and form of information provided to operations personnel and the management of both

automated and manual actions. These advances may reduce the number of plant personnel required to

maintain operational control of a single reactor or may allow plant personnel to maintain control of multiple

units from one control suite.

In addition, advances in the bandwidth and reliability of telecommunications technologies (including

wireless) create the possibility of remote operations from both remote control suites and from portable

devices, such as laptop computers or personal digital assistants. Telecommunications technologies may

allow personnel to monitor and control multiple reactors from remote locations, though security constraints

may limit the use of these technologies.

Implementation of advanced technologies may change some or all of the HSI elements upon which current

staffing approaches are based. The advanced technologies will likely result in changes to the allocation of

functions and tasks among personnel and systems. The character of the functions and tasks may also

change, resulting in changes to the number and qualifications of personnel needed. For example, because

monitoring of plant parameters and most control tasks may be fully automated, on-site operations personnel

may be able to perform the majority of site maintenance tasks or other tasks that are currently assigned to

other plant personnel.

Some of these potential changes to plant designs and to the systems used to control plant operations may

make obsolete the concept of a traditional reactor control room staffed by a crew of licensed operators. To

summarize, the possible changes to current control room staffing approaches include the following (among

others):

• smaller control room crews than currently required

• smaller, or similarly sized, crews that are responsible for a greater number of reactors
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• control suites that allow operational control of multiple reactors with the same set of controls and displays

• offsite operations of one or more reactors

• the introduction of new staff positions with new qualifications

1.4 Limitations of the Current Regulatory Structure

The current requirements for control room staffing are primarily contained in 10 CFR 50.54(m). For

convenience, Table 1 presents the requirements of 10 CFR 50.54(m)(2)(i) which prescribe licensed operator

staffing levels. Several limitations in the scope of these requirements, as well as the requirements of 10

CFR 50.54(m)(2)(ii), (iii), and (iv), exist. Some key assumptions are also implicit in the requirements. These

limitations and assumptions include:

• there is a maximum of three units and three control rooms

• the number of control rooms does not exceed the number of units

• there are no more than two units per control room

• there is always at least one operator at the controls for each unit (10 CFR 50.54(m)(2)(iii))

• there is always at least one, and sometimes two additional operator(s) on site, for each unit

in operation

• there is at least one senior operator on site at all times (10 CFR 50.54(m)(2)(ii))

• there is one senior operator in the control room for each unit in operation (10 CFR 50.54(m)(2)(iii))

• there is one more senior operator than the number of units operating when multiple units are in

operation in more than one control room, except when three units are in operation in two control

rooms

• operator and senior operator are the only two job functions addressed by the Code of Federal

Regulations, and their roles, responsibilities, and qualifications are as defined in 10 CFR Part 55
I-1-4

Table 1. Minimum Requirements(1) Per Shift for On-Site Staffing of Nuclear Power Units 

by Operators and Senior Operators Licensed Under 10 CFR Part 55

Number of

Nuclear Power

Units

Operating(2) Position

One Unit Two Units Three Units

One 

Control

Room

One

Control

Room

Two

Control

Rooms

Two

Control

Rooms

Three

Control

Rooms

None Senior Operator 1 1 1 1 1

Operator 1 2 2 3 3

One Senior Operator 2 2 2 2 2

Operator 2 3 3 4 4

Two Senior Operator 2 3 3(3) 3

Operator 3 4 5(3) 5

Three Senior Operator 3 4

Operator 5 6

1 Temporary deviations from the numbers required by this table shall be in accordance with criteria established in the unit’s technical

specifications.

2 For the purpose of this table, a nuclear power unit is considered to be operating when it is in a mode other than cold shutdown or refueling,

as defined by the unit’s technical specifications.

3 The number of required licensed personnel when the operating nuclear power units are controlled from a common control room is two senior

operators and four operators.

Finally, 10 CFR 50.54(m)(2)(iv) requires the following:

Each licensee shall have present, during alteration of the core of a nuclear power unit (including fuel

loading or transfer), a person holding a senior operator license or a senior operator license limited to

fuel handling to directly supervise the activity and, during this time, the licensee shall not assign other

duties to this person.

These assumptions and limitations reflect a concept of operation that is consistent with the design and

operation of conventional light-water reactors. Also reflected is a “margin of safety” policy that suggests that

there should be a sufficient number of operators and senior operators to safely operate the plant, plus one

more, in case something happens to one of them.
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1.5 Implications for the Review of Exemption Requests

Advanced reactor designs and the implementation of advanced technologies in existing plants will result in

staffing configurations for operations that were not anticipated by the current regulations. As a result,

licensees may request exemptions from current requirements as new technological innovations and

concepts of operations are introduced. Licensees must submit these requests to the NRC for review.

When evaluating the exemption requests, reviewers will assess the impact of the staffing proposals on

safety issues, such as the following:

• operators taking less active roles for ensuring the safety of the plant.

• operators having a greater range of roles and responsibilities in addition to their safety-related roles

and responsibilities

• the need for operators to maintain situation awareness across a number of units and to potentially

manage simultaneous operations across these units

• changes in the response times required from responsible personnel

• plant control capabilities provided by smaller, portable, or remote HSIs

• the interaction between the control room personnel and advanced HSIs, including intelligent support

systems

• capabilities for managing and coordinating control functions among personnel who may be located

remotely from each other

• changes in the qualifications of responsible personnel

• effective scheduling of a reduced number of personnel to optimize cognitive workload, minimize

fatigue, and support situational awareness

In addition, concepts such as “the control room,” “a unit,” “at the controls,” and “operator” may take on

entirely new meanings that may require a new approach to licensing reviews regarding the personnel

responsible for the safe operation of the plant.
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1.6 Applicability

The guidance presented in this document is applicable when a request is submitted for an exemption from

the requirements of 10 CFR 50.54(m). When an exemption is requested in accordance with 10 CFR 50.12,

the applicant must submit evidence that the staffing proposal is adequate for the safe operation of the plant

under all relevant operational conditions.

Within the overall regulatory framework, this guidance document presents a more detailed process for

implementing the guidance contained in Section 6, “Staffing and Qualifications,” of NUREG-0711, “Human

Factors Engineering Program Review Model” (NRC, 2004). It is based on the guidance provided in

Sections 13.1.2–13.1.3, “Operating Organization,” and Chapter 18.0, “Human Factors Engineering,” of

NUREG-0800, “Standard Review Plan.” (NRC, 2004). Figure 1 illustrates the relationship of this document

to current regulations and other related guidance.

Figure 1. Relationship of this Document to Current Regulations and Other Guidance

1.7 Organization of the Guidance

In subsequent sections of this document, each step of the review process is presented in greater detail. 

For each review step, the guidance discusses background information on the step, defines important terms

used in the review process, and presents criteria for conducting the review. When appropriate, the

document discusses the types of data to be submitted by the applicant for each step and, at the end of each

section, presents a listing of resources that may provide useful additional information to the reviewer. 

Appendix A includes checklists that may assist in organizing the reviewer’s task. Appendix B provides a

glossary of terms used in the guidance and Appendix C contains a list of references. If an applicant fails to

provide sufficient information to perform the review, the staff should generate a request for additional

information (RAI) to describe the needed data or information.

Title 10 Code of Federal Regulations

NUREG-0800 Standard Review Plan

NUREG 0711-Human Factors

Engineering Program Review Model

Training

NUREG-1220

Procedures

NUREG-0899

Staffing

NUREG-1791

HSI

NUREG-0700

Operator 

Actions

NUREG-1764
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2. OVERVIEW OF THE REVIEW PROCESS

NUREG/CR-6838, “Technical Basis for Regulatory Guidance for Assessing Exemption Requests from the

Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m),” provides

methods, measures, criteria, and rationale for reviewing exemption requests, and comprises the basis for

the guidance presented here. The process for reviewing staffing-related exemption requests consists of 11

steps. Figure 2 illustrates the overall flow of the review process.

The first step of the review process is to review the exemption request, which is a general review of the

requested exemption(s), to determine the scope of the request(s). In addition, the staff identifies any new or

modified concepts, or changes in meanings for terms included in the regulations (e.g., operator, control

room, unit), introduced as part of the application.

The next step is to review the concept of operations to gain an understanding of the role of plant personnel

in overall plant operations. Understanding the applicant’s intended concept of operations also establishes

the context for subsequent steps in the review.

The third step is to review the operational conditions considered by the applicant to justify the requested

exemption(s). Of particular interest are those operational conditions that present the greatest challenges to

the performance of licensed personnel working under the conditions included in the exemption. The staff

evaluates the operational conditions defined by the applicant for completeness and uses them to assess the

exemption request.

The next five steps focus on reviewing the required data and analyses from the submittals to verify that they

are complete and provide adequate support for the exemption request. The following areas will be

reviewed, as applicable:

• operating experience

• functional requirements analysis and function allocation

• task analysis

• job definitions

• staffing plan

The reviewer may find that additional data and types of reviews may be needed to complete the review of

the exemption request(s). These additional reviews could require data from areas such as human reliability

analysis, human-system integration, and knowledge, skills, and abilities (KSA) analysis. Data submitted for

these review areas would provide further justification in support of the exemption request.

The most important step is the review of the applicant’s staffing plan validation. Staffing plan validation

refers to an evaluation using performance-based tests to determine whether the staffing plan meets

performance requirements and acceptably supports safe operation of the plant. The final step in the review

process is the final assessment of the exemption request to determine whether it is acceptable. 
I-2-2

Figure 2. The Exemption Request Review Process

1. Review the Exemption Request

2. Review the Concept of Operations

3. Review the Operational Conditions

4. Review Operating Experience

5. Review the Functional Requirements

 Analysis and Function Allocation

6. Review the Task Analysis

7. Review the Job Definitions

8. Review the Staffing Plan

9. Review of Additional Data and Analyses

10. Review the Staffing Plan Validation

11. Determine Acceptability of the Exemption

Request
II-1-1

PART II 

EVALUATION OF EXEMPTION REQUESTS

1. REVIEW THE EXEMPTION REQUEST

1.1 Discussion

There are two reasons for performing an overall review of the exemption request. The first is to ensure that

the reviewer understands the scope of the request. The second is to ensure that the applicant has

submitted the necessary information to perform the review.

1.1.1 Scope of the Exemption Request

The applicant’s request for exemption should be clear and specific about the portion(s) of Title 10, Section

50.54(m), of the Code of Federal Regulations (10 CFR 50.54(m)) from which an exemption is requested. 

The exemption request could include the following straightforward variations on the requirements of 10 CFR

50.54(m):

• a greater number of units controlled per control room

• a greater number of units for which an operator or senior operator is responsible

• changes in the responsibilities or qualifications of the control personnel, such as combining the

responsibilities for operations and fuel handling

Applicants may also submit more complex requests, such as the following:

• the definition of new jobs that include functions not currently assigned to licensed operators

• control of operations at multiple sites from one control room

• an expanded definition of “at the controls” to include portable monitoring devices that would allow

responsible personnel to monitor plant parameters and maintain operational control from either

outside the control room or offsite during normal operations

These latter, nontraditional concepts of operations may result in the need to redefine terms such as “control

room,” “operator,” and “at the controls.” They may also result in the need for new operational terms and

definitions. When this is the case, the applicant must indicate the need for, and provide definitions for,

these new ideas and terms as part of the exemption request. When this type of information is not provided,

or when the reviewer is uncertain of what is being requested, the staff should request clarification from the

applicant.
II-1-2

An additional element of this portion of the review is to assess whether further exemptions from the

regulations may be required. Given the number of possible types of exemptions that might be requested

and the interrelationship of 10 CFR Part 50.54(m) to other NRC regulations, it is possible that exemptions

from other regulations may also be required.

1.1.2 Information Completeness

The amount and level of detail required for the review will depend upon the nature of the exemption request.

The reviewer may need a comprehensive physical representation (e.g., mockup, simulation) of the design of

the proposed plant and its systems, as well as descriptions of plant responses to inputs and expected

response times. The staff may also need detailed control room and human-system interface (HSI)

representations. If only a few systems are being upgraded in an existing plant, the reviewer will require less

extensive information, although detailed HSI representations for the new systems may be necessary. 

These representations may be needed to allow the reviewer to understand and evaluate the impact(s) of the

requested exemption(s).

In addition, the reviewer should verify that the applicant’s submittal meets the data requirements for the

subsequent steps in the review process. Although the reviewer’s information needs for subsequent steps

may not be fully known during this initial step, by comparing the applicant’s submittal against the data

requirements for later steps in the review process, the reviewer may identify areas in which an RAI to the

applicant will be necessary.

1.2 Applicant Submittals

The request for exemption should include the following elements:

• a description of the specific aspects of 10 CFR 50.54(m) from which an exemption is requested

• a physical representation of the plant and systems involved

• descriptions of plant/system responses to inputs and expected equipment response times

• a detailed representation of the control room, control suites, and/or the HSI to be used for monitoring

and control actions

• definitions of any new terms used or definitions of terms whose meanings are changed

• information to meet the data requirements of subsequent review steps
II-1-3

1.3 Review Criteria

The reviewer should ensure that each of the following criteria has been met:

• Confirm that one or more exemptions to 10 CFR 50.54(m) is required.

• Confirm that exemptions from other, related regulations are either unnecessary or have been

appropriately identified and described by the applicant. If additional exemptions are required that

have not been identified by the applicant, the applicant should be informed and the review should be

stopped until a complete request for exemptions is submitted.

• Confirm that the terms used in the submittal are fully defined.

• Confirm that adequate data and information have been submitted to meet the data requirements for

the remainder of the review.

1.4 Additional Resources

The impact of the requested exemption on the following regulations and guidelines should be considered:

• 10 CFR 50.54(i), which states that, “except as provided in 55.13 of this chapter, the licensee may not

permit the manipulation of the controls of any facility by anyone who is not a licensed operator or

senior operator as provided in Part 55 of this chapter.”

• 10 CFR 50.54(j), which states that, “apparatus and mechanisms other than controls, the operation of

which may affect the reactivity or power level of a reactor shall be manipulated only with the

knowledge and consent of an operator or senior operator licensed pursuant to Part 55 of this chapter

present at the controls.”

• 10 CFR 50.54(k), which states that, “an operator or senior operator licensed pursuant to part 55 of

this chapter shall be present at the controls at all times during the operation of the facility.”

• 10 CFR 50.54(l), which states that, “the licensee shall designate individuals to be responsible for

directing the licensed activities of licensed operators. These individuals shall be licensed as senior

operators pursuant to Part 55 of this chapter.”

• 10 CFR 55.4, which provides definitions for controls, facility, licensee, operator, and senior operator.

• 10 CFR 55.41 and 55.43, which provide the operator and senior operator examination requirements,

respectively.

• The “Policy Statement on Engineering Expertise on Shift,” published in the Federal Register (50 FR

43621) on October 28, 1985, which gives licensees the option to combine the senior operator and

shift technical advisor into a “dual role” position.
II-1-4

• NUREG-0800, “Standard Review Plan,” Section 13.1.2-13.1.3, “Operating Organization,”

Acceptance Criterion C.1, which requires that a shift supervisor with a senior operator’s license, who

is also a member of the station supervisory staff, be on site at all times when at least one unit is

loaded with fuel.

• NUREG-0800, “Standard Review Plan,” Section 13.1.2-13.1.3 “Operating Organization,” Acceptance

Criterion C.2, which requires that an auxiliary operator (nonlicensed) be assigned to the control room

when a reactor is operating.

• NUREG-0800, “Standard Review Plan,” Section 13.1.2-13.1.3 “Operating Organization,” Acceptance

Criterion C.6, which requires that, “Assignment, stationing, and relief of operators and senior

operators within the control room shall be as described in Regulatory Guide 1.114.”

• NUREG-0800, “Standard Review Plan,” Section 13.1.2-13.1.3 “Operating Organization,” Acceptance

Criterion D, which requires that staffing plans include total complements of licensed personnel of no

less than that required for five shift rotations.

• NUREG/CR-6838, “Technical Basis for Regulatory Guidance for Assessing Exemption Requests

from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR

50.54(m),” which provides the technical basis for the guidance presented in this document.
II-2-1

2. REVIEW OF THE CONCEPT OF OPERATIONS

2.1 Discussion

The purpose of reviewing the concept of operations is to provide the reviewer with a more comprehensive

understanding of how the proposed staffing and associated exemption requests fit into the overall design

and operation of the plant. At the most general level, the term, concept of operations refers to a description

of how the design, systems, and operational characteristics of a plant, such as an advanced reactor, relate

to a licensee’s or applicant’s organizational structure, staffing, and management framework.

Concept of operations may also be used when discussing a system. For example, an applicant may intend

to add an intelligent monitoring system that will monitor plant parameters and take control actions that were

previously performed by an operator in response to certain conditions. The concept of operations in this

case would describe the purpose of the new system, its relationship to other systems, the system’s

characteristics and operations, and user interactions with the system, as well as training and procedures

requirements.

2.2 Applicant Submittals

The applicant should submit a concise, but complete, description of how the plant or system design,

operation, and management necessitate the exemption request and where supporting information is

available in the applicant’s overall submittal. Also, any new or redefined terms should be discussed as they

apply within the concept of operations. The concept of operations should describe the following elements:

• the primary design and operating characteristics of the plant or system and the specific staffing goals

and assumptions necessary to implement the concept of operations

• the number of personnel who will have plant monitoring and operational control responsibilities on

each shift (i.e., “control personnel”) and staffing levels for these personnel across shifts

• the roles and responsibilities of each individual designated as control personnel, if that individual is

responsible for control and monitoring plant or unit operations

• the training and qualifications required for control personnel.

• the overall operating environment and primary HSIs to be used by control personnel

• the interaction of control personnel with automated systems, including responsibilities for monitoring,

operating, and overriding automated systems

• the interaction of control personnel with automated support systems and the role of these systems in

the overall management and control of the plant
II-2-2

• other mechanisms that enable or support control personnel responsibilities for monitoring,

disturbance detection, situation assessment, response planning, response execution, and the

management of transitions between automatic and manual control

• the interactions of control personnel with each other and with people not directly responsible for the

control and safe operation of the plant

• multi-unit operations

• modular unit operations

• operations during construction of additional units

2.3 Review Criteria

The reviewer should confirm that the applicant’s description of the concept of operations for the plant or

system is complete and that the applicant has addressed each of the aspects of operations and roles of the

control personnel.

2.4 Additional Resources

• AIAA G-043-1992: Guide for the Preparation of Operational Concept Documents, (American Institute

of Aeronautics and Astronautics, 1993).

• NUREG-0711: Human Factors Engineering Program Review Model, Section 8.4.2 Concept of

Operations, (NRC, 2004).
II-3-1

3. REVIEW THE OPERATIONAL CONDITIONS

3.1 Discussion

The purpose of the review of the operational conditions is to ensure that the operational conditions which

present the greatest potential challenges to the effective and safe performance of control personnel, under

the conditions of the requested exemption, were analyzed by the applicant and support the exemption

request. During the normal course of the licensing process, an applicant is required to analyze the full

range of operational conditions that personnel will be required to manage. For the purpose of justifying a

given exemption or set of exemptions to 10 CFR 50.54(m), however, it may be unnecessary to analyze the

full range of potential conditions.

NUREG-0711, Section 11.4.1, “Operational Conditions Sampling,” provides a robust set of guidelines for

identifying operational conditions for use in the verification and validation of control room designs. This

same guidance can be used for the purpose of reviewing requests for exemptions from 10 CFR 50.54(m). 

The focus of the sampling should be adjusted to the conditions requested in the exemption and the

emphasis should be on those operational conditions known to present the greatest challenges to human

performance.

The exemption request should provide a discussion of the rationale for selecting specific conditions and for

not analyzing others. The reviewer should assess whether or not this set of operations is reasonable,

based on the design of the plant, the concept of operations, and the range of operational conditions that

could be considered. The reviewer should request additional clarification or justification if the applicant’s set

of operational conditions is incomplete.

3.2 Applicant Submittals

At a minimum, this section of the exemption request should include the following elements:

• a description of the operational conditions selected for analysis

• the rationale for selecting the operational conditions analyzed and for excluding others that could

have been analyzed

3.3 Review Criteria

The reviewer should be able to ensure that the applicable criteria described in the following sections have

been met.
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3.3.1 Operational Conditions Sampling for an Advanced Reactor Design

The reviewer should confirm that the following operational conditions were analyzed or that an adequate

rationale for not analyzing the conditions was provided:

• normal operational events, including plant startup, shutdown, or refueling, and significant changes in

operating power

• failure events, including instrument failures and HSI failures

• transients and accidents

• reasonable, risk-significant, and beyond-design-basis events, derived from the plant-specific

probabilistic risk assessment (PRA)

• conditions that challenge plant safety functions as a result of interconnections and interactions

among systems

The reviewer should confirm that the following types of personnel tasks were included in the analysis:

• risk-significant human actions

• difficult tasks identified through the operating experience review

• a range of procedure-guided tasks that are well defined by normal, abnormal, emergency, alarm

response, and test procedures

• a range of knowledge-based tasks that require greater reasoning about safety and operating goals

and the various means of achieving them

• a range of human cognitive activities, including decision-making

• a range of human interactions, including tasks performed by individual control personnel and any

tasks performed by personnel acting as a crew

• tasks that are performed with high frequency

• tasks that are important or difficult, but infrequently performed
II-4-1

The reviewer should confirm that the analysis included the following situational factors that are known to

challenge human performance:

• operationally difficult tasks

• error-forcing contexts

• high-workload conditions

• varying-workload situations

• fatigue and circadian factors

• environmental factors

Finally, the reviewer should confirm that the range and combination of operational conditions considered by

the applicant are appropriate and adequate.

3.3.2 Special Considerations for Plant Modification Programs

The reviewer should confirm that the following criteria have been fulfilled:

• the operational conditions selected include the tasks that are affected by the modification, rather

than the entire range of tasks required to analyze a plant design

• transfer of learning effects on human performance were assessed when a new system is replacing

an existing HSI, when procedures have been modified, or when personnel will be required to use

both the new system and an existing HSI

• the potential for deactivated HSIs that will be left in place to interfere with task performance was

considered

• the range and combination of operational conditions considered by the applicant were appropriate

and adequate

3.4 Additional Resources

• NUREG-0711: Human Factors Engineering Program Review Model, Section 11.4.1 Operational

Conditions Sampling, (NRC, 2004).

• NUREG-1513: Integrated Safety Analysis Guidance Document, (NRC, 2001).

• NUREG/CR-6393: Integrated System Validation: Methodology and Review Criteria, (O’Hara et al.,

1997).
II-4-2

4. REVIEW OPERATING EXPERIENCE

4.1 Discussion

The purpose of this step of the review is to ensure that the applicant has performed a review of relevant

operating experience to identify and address staffing-related lessons learned that may be important to the

exemption request. The purpose of the applicant’s review of operating experience should be to identify

previous staffing-related problems in order to avoid repeating them, should the exemption request be

approved. It is also used for identifying similar staffing practices that have proven to be effective and

successful implementations of similar technologies and concepts of operation.

The amount of relevant operating experience available will vary, depending upon whether the exemption

request involves new reactor designs or the introduction of new systems into an existing plant. The greatest

amount of information will be available for systems and staffing practices that have been implemented in

other nuclear power plants. Information regarding new system designs and staffing practices should also

be sought from other industries in which similar systems or practices have been implemented (e.g.,

chemical manufacturing plants, other types of power generating plants, some military systems).

The results of the applicant’s operating experience review may be used as input to several of the exemption

request analyses. For example, the applicant’s operating experience review may identify problematic

operations and tasks that should be considered in the selection of operational conditions and tasks to be

analyzed. Experience regarding the impacts of staffing shortfalls may also be useful in the task analysis, for

defining jobs, and in developing the staffing plan. Effective implementations of technologies may be used

as the basis for allocating functions between the technologies and control personnel. Operating experience

may also provide data to support the staffing plan verification and validation process.

4.2 Applicant Submittals

Operating experience may be available from the following sources:

• predecessor plants or systems

• plants or systems using similar technologies, practices, or concepts of operation

• recognized industry human performance and staffing issues

• issues identified by predecessor or similar plant personnel

• prototype or experimental plants/systems

• experience from other industries
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4.3 Review Criteria

The reviewer should be able to ensure that each of the criteria below has been met, as applicable:

• Predecessor or similar plants and systems included in the analysis are identified and their similarities

and differences from the exemption under consideration are described.

• Any recognized industry issues with the plant or system design are identified.

• Any recognized industry issues with staffing for similar plants, systems, or technologies are

identified.

• Other sources of operating experience data are identified, along with any limitations of their use in

performing the review for the exemption requested.

• The applicant has reviewed the staffing goals and numbers of control personnel for each of the

related plants or systems selected.

• The process used by the applicant for identifying issues during the operating experience review

includes a description of the assumptions, criteria, and constraints used in selecting issues and

developing interviews of control personnel.

• The applicant has identified the risk-important actions associated with existing plants, systems, or

relevant technologies that could potentially be a problem if the requested exemption is granted.

• The operating experience review was of sufficient scope to identify the most important relevant

information and that the applicant’s rationale for excluding some experience that could have been

analyzed is reasonable.

Examples of effective implementations of technologies, practices, or concepts of operation included as

support for the exemption are fully substantiated and documented.
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4.4 Additional Resources

• IAEA Safety Series No. I 75-INSAG-3: Basic Safety Principles for Nuclear Power Plants,

(International Atomic Energy Agency, 1988).

• IEEE Standard 845-1999 IEEE Guide to Evaluation of Human-System Performance in Nuclear

Power Generating Stations, (Institute of Electrical and Electronics Engineers, 1999).

• NUREG-0711: Human Factors Engineering Program Review Model, Section 3 Operating Experience

Review, (NRC, 2004).

• NUREG/CR-6400: HFE Insights for Advanced Reactors Based Upon Operating Experience, (Higgins

and Nasta, 1996).
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5. REVIEW THE FUNCTIONAL REQUIREMENTS ANALYSIS 

AND FUNCTION ALLOCATION

5.1 Discussion

There are two purposes for this step of the review. The first purpose is to ensure that the applicant has

defined and evaluated the impact of the exemption request on the plant/system functions that must be

performed to satisfy plant safety objectives. The second purpose is to ensure that the allocation of functions

to humans and systems has resulted in a role for control personnel that uses human strengths, avoids

human limitations, and can be performed under the operational conditions evaluated in the exemption

request. A function is a process or activity that is required to achieve a desired goal.

Functional requirements analysis is the identification of functions that must be performed to prevent or

mitigate the consequences of postulated accidents that could damage the plant or cause undue risk to the

health and safety of the public. The functional requirements analysis is also conducted to identify and

define functions for all other normal operating conditions with the goal of achieving effective, efficient, and

safe operations. A functional requirements analysis is conducted to achieve the following objectives:

• determine the objectives, performance requirements, and constraints of the design

• define the high-level functions that have to be accomplished to meet the objectives and desired

performance

• define the relationships between high-level functions and plant systems responsible for performing

the function

• provide a framework for understanding the role of controllers (whether personnel or system) in

controlling the plant

Function allocation is the analysis of the requirements for plant control and the assignment of control

functions to personnel (e.g., manual control), system elements (e.g., automatic and passive control, selfcontrolling phenomena), and combinations thereof (e.g., shared control and automatic systems with manual

backup).

Functional requirements and function allocation analyses are also required when implementing new

systems in existing plants. Plant modifications may change the level of automation of the original design

and change the functions that are allocated to systems and personnel, leading to an exemption request.
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5.2 Applicant Submittals

The functional requirements analysis and function allocation data submitted in support of the exemption

request should include the following:

• the set of functions identified as being relevant to the exemption request

• the sequence of performance of the functions, triggering events for their initiation, and conditions for

their completion or suspension

• minimum function performance requirements in terms of time, timing, and accuracy

• identification of functions that include risk-important human actions and the consequences (e.g.,

error rates or estimates of error rates) of not performing those actions, performing them

incompletely, or not performing them within the time required

• a description of the allocation of functions to control personnel, automated systems, or a

combination of the two

• a description of how the allocation of functions supports integrated control staff roles across

functions and systems

• a description of how control personnel functions relate to the functions performed by other plant

personnel

• identification of functions that can be reallocated across or between control personnel, automated

systems, or other plant staff, and a description of the strategies and criteria employed for reallocation

• identification of functions with risk-important human actions that may be reallocated with a

description of how the risks are managed through the reallocation

• identification of function allocations that may affect the roles, responsibilities, or qualifications for

licensed control personnel

• identification of function allocations to any new control personnel jobs

• applicable supporting data from the concept of operations, the operational conditions defined, and

the operating experience review

5.3 Review Criteria
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The reviewer should be able to ensure that each of the criteria below has been met:

• The set of functions identified as applicable to the analysis is complete and appropriately

characterized.

• All functions have been allocated to control personnel, automated systems, or a combination of the

two, and that the strategies and criteria for the allocations are clear and met.

• The function allocations support integrated control staff roles across functions, systems, and other

plant personnel.

• Any new or modified licensed control personnel positions resulting from the function requirements

analysis and function allocation have been identified and characterized.

• The data analyses were performed using appropriate parameters and methods.

• The assumptions and estimates used in conducting the analyses were documented and appropriate.

5.4 Additional Resources

• IAEA-TECDOC-668: The Role of Automation and Humans in Nuclear Power Plants, (International

Atomic Energy Agency, 1992).

• IEEE Std. 1023-1988: IEEE Guide to the Application of Human Factors Engineering to Systems,

Equipment, and Facilities of Nuclear Power Generating Stations, (Institute of Electrical and

Electronics Engineers, 1988).

• NUREG-0711: Human Factors Engineering Program Review Model, Section 4 Functional

Requirements Analysis and Function Allocation, (NRC, 2004).

• NUREG/CR-3331: A Methodology for Allocation of Nuclear Power Plant Control Functions to Human

and Automated Control, (Pulliam et al., 1983).
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6. REVIEW THE TASK ANALYSIS

6.1 Discussion

The purpose of the task analysis review is to ensure that the applicant’s analysis identifies the specific tasks

that are needed to accomplish functions and their staffing implications. The functions allocated to plant

personnel define their jobs. Human actions are performed to accomplish these functions. Human actions

can be further divided into tasks. A task is a group of related activities that have a common objective or

goal. Task analysis is the identification of requirements for accomplishing these tasks (i.e., for specifying

the requirements for the displays, data process, controls, and job aids needed to accomplish tasks).

The scope of the task analyses performed by an applicant will vary, depending upon the nature of the

design or system(s) for which the exemption request has been initiated. In the case of a modification to an

existing plant, the task analysis should address the tasks that have changed. In the case of a new plant

control room design, the task analysis should address the set of tasks that control personnel will be required

to perform for the defined operational conditions.

For each task, the information, control, and task support requirements should be addressed by the

applicant’s task analysis, as applicable. The information should be used to identify issues of task timing,

workload, and situation awareness and to determine resource conflicts that would affect staffing

assignments.

A number of acceptable methods exist for conducting task analyses. The reviewer should ensure that the

applicant has used a generally recognized acceptable approach.

6.2 Applicant Submittals

The task analysis data submitted in support of the exemption request should include the following, as

applicable:

• the set of tasks identified as being relevant to the exemption request

• the sequence of performance of the tasks, triggering events for their initiation, and conditions for

their completion or suspension

• minimum task performance requirements in terms of time, timing, accuracy, or other relevant criteria,

as identified in Table 2

• identification of tasks that include risk-important human actions and the consequences (e.g., error

rates or estimates of error rates) of not performing those actions, performing them incompletely, or

not performing them within the time required

• identification of tasks that may affect the roles, responsibilities, or qualifications for licensed control
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personnel

• identification of tasks for any new control personnel jobs

• applicable supporting data from the concept of operations, the operational conditions defined,

function requirements analysis and function allocation, and the operating experience review

Table 2. Task Performance Requirements

Category Data Item Requirements

Information Requirements Alarms and alerts Any alarms and alerts that would

trigger a task to start

Parameters Any parameters that would indicate

the task is appropriate for

performance

Feedback needed to indicate

adequacy of actions taken

Any parameter that the operator

would need to monitor during the

task to ensure the task is correctly

executed

Decision making Requirements Decision type (relative, absolute,

probabilistic)

Explanation of how and when

decisions between alternative tasks

are made

Evaluations to be performed Parameters that must be evaluated

in the decision and how they are

applied

Coordination Decisions that must be made or

approved by others

Response Requirements Type of action to be taken A description of the operator action

taken in the task
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Table 2 Task Performance Requirements (Con’t)

Category Data Item Requirements

Response Requirements (Con’t) Task frequency A measurement of how frequently

the task occurs

Task tolerance A measure of the allowable accuracy

for the task to be considered

successfully performed

Task accuracy The expected value of how

accurately the task will be performed

by the operator

Consequences of inaccurate

performance

The effect that inaccurate task

performance has on other tasks in

the scenario

Time available and temporal

constraints

The time allowable for the operator

to complete the task

Time required An estimate of the amount of time

required for the operator to complete

the task. Statistical distributions

should be provided. If distributions

are unavailable, a typical minimum

and maximum time should be

provided.

Physical position The physical position and location

required for the operator to perform

the task

Biomechanics A description of the physical activity

that must be performed (movements)

and the forces required

Communication Requirements Personnel communication for

monitoring or control, including

among control personnel and

directing the activities of others

A description of the participants in

the communication and information

communicated

Personnel communication for

administrative, reporting, and

external communications

A description of the participants in

the communication and information

communicated

Workload Visual A ranking of the visual workload

Auditory A ranking of the auditory workload
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Table 2 Task Performance Requirements (Con’t)

Category Data Item Requirements

Workload (Con’t) Cognitive A ranking of the cognitive workload

Psychomotor A ranking of the psychomotor

workload

Overlap of task requirements An indicator if other tasks may or

may not be run in parallel with this

task

Task Support Requirements Special protective clothing Any clothing that could interfere with

task performance or be required for

task performance

Job aids or reference materials

needed

Any reference materials that could

improve performance, or be required

to perform the task, and any

demands for multiple, concurrent use

Tools and equipment needed Any tools or equipment required to

perform the task

Automation or automated support Any automated support systems that

could affect performance or be

required to perform the task, and any

demands for multiple, concurrent use

Workplace Factors Ingress and egress paths to work

site

Any specific paths an operator must

take to get to the work area

Workspace envelope needed by

action taken

Any space requirements needed to

perform the task

Typical and extreme environmental

conditions

Measures of the typical and extreme

conditions for—

• lighting

• heat

• temperature

• noise
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Table 2 Task Performance Requirements (Con’t)

Category Data Item Requirement

Situational and Performance

Shaping Factors

Stress Level of stress expected based upon

the severity of the scenario or

conditions

Reduced staffing Reasonable expectations about

understaffing in the scenario

Fatigue Typical and extreme conditions for—

• time since last sleep

• point in circadian cycle

Hazard Identification Identification of hazards involved Any hazards that may impair

performance or make an operator

unavailable due to injury

(Adapted from NUREG-0711, Table 5.1, “Task Considerations”)

6.3 Review Criteria

The reviewer should be able to ensure that each of the following criteria has been met:

• The set of tasks identified as applicable to the analysis is complete and appropriately characterized.

• The task performance requirements for each task were comprehensively identified.

• The tasks for any new or modified licensed control personnel positions (as specified in 10 CFR

Part 55) have been identified and characterized.

• The data analyses were performed using appropriate parameters and methods.

• The assumptions and estimates used in conducting the analyses were documented and appropriate.

6.4 Additional Resources

• IEC 964: Design for Control Rooms of Nuclear Power Plants, (International Electrotechnical

Commission, 1989).
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• IEEE Std. 1023-1988: IEEE Guide to the Application of Human Factors Engineering to Systems,

Equipment, and Facilities of Nuclear Power Generating Stations, (Institute of Electrical and

Electronics Engineers, 1988).

• NUREG-0711: Human Factors Engineering Program Review Model, Section 5 Task Analysis, page

21, (NRC, 2004).

• NUREG/CR-3371: Task Analysis of Nuclear Power Plant Control Room Crews, (Burgey et al., 1983).

• NUREG/CR-6690: The Effects of Interface Management Tasks on Crew Performance and Safety in

Complex, Computer-Based Systems, (O’Hara and Brown, 2002).
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7. REVIEW THE JOB DEFINITIONS

7.1 Discussion

The purpose of the job definition review is to confirm that the applicant has established clear and rational job

definitions for the personnel who will be responsible for controlling the plant. For an existing plant in which

new systems will be implemented, the purpose of the review is to ensure that the applicant has retained

clear and rational job definitions for control room personnel. A job is defined as the group of tasks and

functions that are assigned to a personnel position. A job definition specifies the responsibilities,

authorities, knowledge, skills, and abilities that are required to perform the tasks and functions assigned

to a job.

An applicant’s job definitions should describe the impact of the exemption request on each job affected. 

For example, an exemption request could entail redefining and reassigning the functions and tasks of the

current senior operator position. Current senior operator responsibilities for coordinating and overseeing the

activities of reactor operators in a control room located onsite could be eliminated, partially reallocated to

intelligent monitoring systems, and/or assigned to off-site personnel who monitor on-site activities remotely.

Alternatively, a new job could be created that has no analogue in an existing plant or under the current

regulations. As a hypothetical example, a specialist job could be created in which an individual is uniquely

trained and qualified to troubleshoot the software that supports new systems or new HSIs, and to assume

control if systems fail and backups must be used.

A job that consists of interrelated responsibilities and authorities that do not conflict would be coherent. A

classic example of conflicting responsibilities would be a Senior Operator in a traditional control room, who

is charged with maintaining an overview of operational conditions. These additional responsibilities may

compromise his or her ability to maintain “the big picture.” Conflicting responsibilities, in the past, have

included responsibilities for taking control actions or responding to information requests from personnel

outside of the control room. The reviewer should ensure that the applicant’s job definitions appropriately

prioritize the responsibilities of each position and do not incorporate role conflicts.

An important aspect of the job definition review is to ensure that the qualifications required for each position

are delineated. The qualifications required for a plant staff position consist of the knowledge, skills, and

abilities/aptitudes (KSAs) an individual must possess to meet the performance criteria established for the

tasks assigned to the position. The information derived from the function and task analyses should provide

a basis for identifying the required KSAs for each position.

The job definition review will be necessary for all exemption requests. Its scope should be limited to the

jobs of licensed personnel that are impacted by the exemption request. Within a job, the scope of the

review may also be limited by the extent (e.g., only a few job functions or tasks impacted) and character

(e.g., only responsibilities affected, not qualifications) of the exemption request.
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7.2 Applicant Submittals

The job definition data submitted in support of the exemption request should include the following:

• a description of the scope and the impacts of the exemption request on the roles, responsibilities,

and qualifications of control personnel

• identification of any new or modified roles, responsibilities, and qualifications for licensed control

room personnel (under the current requirements) included in the exemption request

• identification of the roles, responsibilities, and qualifications for any new jobs included in the

exemption request

• applicable data from the concept of operations, operational conditions, operating experience,

functional requirements analysis and function allocation, and task analysis for each of the jobs

affected that support the roles and responsibilities identified in the exemption request

• applicable data from the KSA analysis for each of the jobs affected that support the qualifications

identified in the exemption request

• a final job description for each job impacted by the exemption request

• job definitions which appropriately prioritize the responsibilities of each position and that do not

incorporate role conflicts

7.3 Review Criteria

The reviewer should be able to ensure that each of the following criteria has been met:

• The scope and impact of the exemption request is adequately addressed for control personnel jobs.

• Applicable data from the concept of operations, operational conditions, operating experience,

functional requirements analysis and function allocation, and task analysis support the roles and

responsibilities assigned to each impacted job in the exemption request. 

• The KSA analysis is complete, and the KSAs are consistent with the qualifications required for each

impacted job identified in the exemption request.

• Coherent job descriptions are maintained for licensed control room personnel (under the current

requirements), or are defined for any new jobs included as a part of the exemption request.

• The job definitions for control personnel who will work in crews are coordinated.
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7.4 Additional Resources

• Information Notice 93-81: Implementation of Engineering Expertise on Shift, (NRC, 1981).

• Generic Letter 86-04: Policy Statement on Engineering Expertise on Shift, (NRC, 1986).

• NUREG-0711: Human Factors Engineering Program Review Model, Section 6 Staffing and

Qualifications, (NRC, 2004).

• NUREG-1122: Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized

Water Reactors, (NRC 1998).

• NUREG-1123: Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water

Reactors, (NRC, 1998).

• NUREG-1220: Training Review Criteria and Procedures, (NRC, 1993).

• Regulatory Guide 1.149: Nuclear Power Plant Simulation Facilities for Use in Operator License

Examinations, (NRC, 1996).

• Regulatory Guide 1.8: Qualification and Training of Personnel for Nuclear Power Plants, (NRC,

2000).

• Regulatory Guide 1.114: Guidance to Operators and to Senior Operators in the Control Room of a

Nuclear Power Plant, (NRC, 1989).

• Code of Federal Regulations, Title 10, “Energy,” Part 50.120, “Training and qualification of nuclear

power plant personnel.”
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8. REVIEW THE STAFFING PLAN

8.1 Discussion

The purpose of the staffing plan review is to ensure that the applicant has systematically analyzed the

requirements for the numbers of qualified personnel that are necessary to operate the plant safely under the

operational conditions analyzed. That is, the staffing plan should answer the question, “How many

individuals must be qualified and available to fill each job?”

The applicant’s staffing plan should be supported by the results of the functional requirements analysis and

function allocation, task analyses, and the job definitions for each position required under the operational

conditions considered. In addition, the applicant’s submittal should define the proposed shift composition

and shift scheduling. Shift composition refers to the different types of jobs that must be filled on each shift

and the number of personnel required for each of the jobs on a shift. In the case of remote operations or

operations that will take place outside of a traditional control room, the applicant should also define the

locations of the personnel comprising a shift.

8.2 Applicant Submittals

The staffing plan submitted in support of the exemption request should include the following elements:

• the set of operational conditions considered for the staffing plan, to the extent that they differ from

those submitted for other elements of the exemption request

• the proposed staffing levels, shift composition, and shift schedules for the identified operational

conditions

• a description of how the staffing plan supports integrated staff roles across shifts and operational

conditions

• identification of the types of control personnel who can be substituted within each job, given the

concept of operations

• expected travel times or response times for control personnel who need to move to new locations

(e.g., home to the plant or office) or provide other support (e.g., to log in to system control computers

from home), when applicable

• a description of how control personnel staffing relates to the larger plant staffing and the support

roles that control personnel may play in the larger staffing context

• applicable supporting data from the concept of operations, the set of operational conditions

considered, the functional requirements analysis and function allocation, task analysis, job

definitions, and the operating experience review

8.3 Review Criteria
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The reviewer should be able to ensure that each of the following criteria has been met:

• The set of operational conditions identified as applicable to the staffing plan is complete and

representative of the exemption request.

• The staffing plan will provide an adequate number of qualified personnel to operate the plant safely

under the operational conditions considered.

• Roles and responsibilities are integrated across shifts and among personnel.

• Travel and response times are adequate and do not trigger adverse conditions for the safety of the

plant.

• The staffing plan uses data from previous sections in a logical/rational manner.

8.4 Additional Resources

• ANSI/ANS 3.1: Selection, Qualification, and Training of Personnel for Nuclear Power Plants,

(American Nuclear Society, 1993).

• ANSI/ANS 58.8: Time Response Design Criteria for Safety-Related Operator Actions, (American

National Standards Institute, 1994).

• Generic Letter 86-04: Policy Statement on Engineering Expertise on Shift, (NRC, 1986).

• Information Notice 93-81: Implementation of Engineering Expertise on Shift, (NRC, 1981).

• Information Notice 95-48: Results of Shift Staffing Study, (NRC, 1995).

• Information Notice 97-78: Crediting of Operator Actions in Place of Automatic Actions and

Modifications of Operator Actions, Including Response Times, (NRC, 1997).

• NUREG-0711: Human Factors Engineering Program Review Model, Section 6 Staffing and

Qualifications, (NRC, 2004).

• NUREG/IA-0137: A Study of Control Room Staffing Levels for Advanced Reactors, (Hallburt and

Morisseau, 2000).

• Regulatory Guide 1.8: Personnel Selection and Training, (NRC, 2000).

• Regulatory Guide 1.114: Guidance to Operators at the controls and to Senior Operators in the

Control Room of a Nuclear Power Unit, (NRC, 1986).
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9. REVIEW OF ADDITIONAL DATA AND ANALYSES

Applicants may provide additional supporting data and analyses as part of the exemption request

submittals. These additional materials should be reviewed based on their applicability to the requested

exemption and the need for the supporting data and analyses. Additional review may include the following

areas:

• human reliability analysis used to demonstrate the impacts of risk-important human actions

• human-system integration data used to demonstrate that the design of the HSIs supports the

concept of operations, functional requirements analysis and function allocation, task analysis,

staffing plan, and operating experience

• KSA analysis used in support of new or changing job definitions

• KSA analysis used to support modified tasks or human-system interfaces

• procedures and training documentation used to demonstrate the implementation of components of

the concept of operations, functional requirements analysis and function allocation, or task analysis

The reviewer should also consider additional submittals that would be expected, based on the character of

the exemption request. For example, if remote support operations are proposed, data supporting the new

communications skills required for control personnel may be appropriate. NUREG-0711 includes review

criteria for these areas.
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10. REVIEW THE STAFFING PLAN VALIDATION

10.1 Discussion

The purpose of reviewing the validation of the staffing plan is to ensure that the applicant fully considered

the dynamic interactions between the plant design, its systems, and control personnel for the operational

conditions identified for the exemption request. Staffing plan validation refers to an evaluation using

performance-based tests to determine whether the staffing plan meets performance requirements and

acceptably supports safe operation of the plant.

The applicant should provide data or demonstrations that the control personnel specified in the staffing plan

can satisfy the plant and human performance requirements identified in the functional requirements

analysis, function allocation, and task analyses. These data or demonstrations may come from operating

experience, human-in-the-loop simulations, human performance models, or a mix of these methods. The

data or demonstrations should include the full range of operational conditions identified for the exemption

request, as well as a reasonable representation of the human performance variability expected in the

context of the operational conditions.

10.1.1 Operational Conditions Sampling

The applicant should include the operational conditions relevant to the exemption request in the staffing

plan validation. As a practical matter, however, it may be unnecessary to address all of the possible

variations of these conditions. It may be reasonable to combine some of them into scenarios.

The applicant’s submittal should identify the operational conditions included in each scenario. The submittal

should identify the key plant and system parameters relevant to the scenario and the state of these

parameters at the start of the scenario, during critical transition points in the scenario, at times when action

by control personnel is expected, the results of control actions, and the status of the parameters at the end

of the scenario. The submittal should also identify the criteria for determining successful performance of the

plant, system, and control personnel within the scenarios. The submittal should sample a sufficient number

of operational conditions such that the personnel and plant performance are challenged.

10.1.2 Human Performance Measures and Criteria

This section discusses “how” the data may have been collected. The reviewer needs to be aware of the

methods and conditions under which data were collected to be able to assess the analyses. The applicant

needs to identify the measures of human performance used to evaluate individual and crew performance of

the control personnel in the scenarios. Outcome-oriented human performance measures include the

following examples (among others):

• time to complete actions

• timeliness of actions

• accuracy and completeness of actions
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• omitted actions

Outcome measures can usually be observed, measured directly, and be linked to overall plant and system

performance measures. The measures may be aggregated to the crew level in evaluating crew

performance, and ultimately, the adequacy of the staffing plan.

Measures of conditions that can affect the response of control personnel should also be addressed. To the

extent that environmental conditions such as heat, cold, or lighting need to be considered, their impacts on

control personnel performance should be addressed. If shift durations or scheduling have the potential to

cause sleep loss and fatigue among control personnel, these impacts will need to be assessed as well. The

impacts of these types of conditions are most often seen as degradations in control personnel performance,

which may not always result in degraded system performance or failure. Degraded personnel performance

increases the risk of failure, however, so the frequency and extent to which control personnel are exposed

to the adverse conditions should be assessed.

Time and information processing demands placed on the control personnel may also degrade performance. 

The impacts of these types of demands can be assessed using measures of cognitive workload and

situation awareness.

Cognitive workload refers to the degree to which an individual’s cognitive and perceptual capabilities are

taxed during the performance of the tasks that comprise his or her job. Most cognitive workload measures

are structured self-reports from the users of a system regarding the time pressure they experience, the

mental effort involved in performing their tasks, and the amount of stress they experience. Excessive

cognitive workload will lead to performance decrements, such as delays, inaccurate responses, errors in

diagnoses, and omissions.

Situation or situational awareness (SA) is defined as an individual’s mental model of what has happened,

the current status of the system, and what will happen in the next brief time period (Endsley & Garland,

2000). Because the quality of a person’s decision selection and performance is determined by the

“goodness” (accuracy, completeness, relevance) of the internal, or mental, model of the system, it is critical

for control personnel to form and maintain complete and accurate SA. To determine if new plant designs

and/or new staffing arrangements adequately support SA, it is important to evaluate the degree to which all

control personnel demonstrate adequate SA.

In addition to defining the measures of human performance used in validating the staffing plan, the applicant

should identify the criteria established to determine the acceptability of the results obtained. The criteria

may include the following examples:

• Nominal task performance times will not be exceeded by more than 10 percent.

• No more than 60 seconds will be required to begin Task X after Event Y.

• Temperatures will be maintained within ± 5 degrees.

• No actions will be omitted.

Other performance measures and criteria may be derived from relevant requirements in Table 2 of Section 6

of this document.
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10.1.3 Data Sources or Demonstration Methods

The data sources or demonstration methods used by the applicant to validate the staffing plan may include

operating experience, human-in-the-loop simulations, human performance models, or a mix of these

methods. Although the applicant may submit other types of data or demonstrations, the reviewer should

ensure that the submittals assess the dynamic interactions between the plant design, its systems, and

control personnel for the operational conditions identified for the exemption request.

Key considerations for the data sources or methods include the following aspects:

• the range of operational conditions considered

• how well the behavior of the plant or systems is represented

• how well the behavior of control personnel, including a reasonable representation of the human

performance variability that may be expected, is represented

The first two considerations are straightforward to assess. However, a reasonable representation of human

performance variability requires some explanation. First, human performance is variable, both within

individuals and across individuals. Within the context of high reliability systems, such as nuclear power

plants, this variability is generally sufficient to require representation in the analysis of human performance. 

Therefore, the reviewer needs to assure that the applicant considered human performance variability and

describe how it was addressed in the validation process.

The applicant will select among the possible data sources and methods for validating the staffing plan

based upon the availability, quality, and comprehensiveness of the data from each of the possible sources. 

The reviewer should ensure that the applicant has developed and executed a plan for integrating these data

and for demonstrating that the dynamic interactions between the plant design, its systems and control

personnel for the operational conditions defined for the exemption request have been fully considered. 

Finally, the applicant will need to report on the outcomes of the staffing validation in a way that clearly

demonstrates to the reviewer that the staffing plan supports the requested exemption.

10.1.3.1 Data from Operating Experience

Data from operating experience tend to carry high face validity. They are most useful when they are drawn

from similar plants, technologies, or organizations that are implementing similar concepts of operation. The

longer the duration of successful operation or success in mitigating unwanted events, the more support

operating experience can provide to the staffing plan and exemption request. Data from training or licensing

of control personnel that demonstrate effective performance may also be considered, particularly for

operational conditions that have never actually occurred or that have occurred at low frequencies.
II-10-4

10.1.3.2 Data from Human-in-the-Loop Simulations

Using human-in-the-loop simulations for staffing plan validation will often be limited by simulator availability. 

Simulators may be difficult to access for validation purposes since they are often in heavy use for training or

licensing examinations. Further, for new or modified plants or systems, there may be no, or a limited

number of, control personnel who have the qualifications and capabilities to perform the roles of the

“humans” in the loop. These factors may limit the range of human performance issues that can be

assessed.

A key benefit of data from human-in-the-loop simulations is that they can represent a wide range of

operational conditions, often at high levels of fidelity. High-fidelity simulators are often built well in advance

of the actual plants they represent, so that they may be available for use in support of an exemption

request. Simulators with lower levels of fidelity may also be used to provide supporting data. For example,

a simulator that reflects plant or system behavior well, but does not reflect the actual HSI, may be useful for

demonstrating the time and timing of events and available control personnel response times. In either case,

these techniques can be used to capture quantitative, objective measures and criteria to support the

exemption request.

10.1.3.3 Data from Human Performance Models

Human performance models typically require data such as tasks, task times and timing, flow logics, and

error probabilities. Although these data are typically available from the task analysis, some of the data

frequently need to be estimated. The models also require algorithms to represent performance variations,

as well as measures of factors such as cognitive workload. Because the models are projections of human

performance that are often based on a limited amount of concrete data, they are subject to challenge. 

These limitations are moderated by the fact that (1) there are representations for which validation exists,

and (2) the models can be exercised across a range of values for critical parameters to assess the model’s

sensitivity.

Data from human performance models can provide a robust representation of the performance of control

personnel across the range of operational conditions. Models can easily incorporate the various conditions

that may affect human performance, human performance variability, and measures of concepts, such as

cognitive workload and situation awareness. Although human performance models historically have

incorporated plant or system representations of limited fidelity, human performance models can now be

linked to more sophisticated plant or system simulations. The human performance models also make it

relatively easy to assess different staffing alternatives. As with the human-in-the-loop simulations,

quantitative, objective measures and criteria can be captured to support the exemption request.
II-10-5

10.2 Applicant Submittals

The reviewer should confirm that data for the following four areas are provided, as applicable.

10.2.1 Operational Conditions Sampling

The reviewer should confirm that the submittal includes the following information regarding operational

conditions sampling:

• a description of each of the scenarios used in validating the staffing plan

• a description of how the scenarios incorporate the operational conditions relevant to the exemption

request

• a description of system and key plant parameters relevant to the scenarios

• relevant criteria for evaluating successful performance

• scenarios that challenge personnel, plant, and system performance

10.2.2 Human Performance Measures and Criteria

The reviewer should confirm that the submittal includes the following information regarding human

performance measures and criteria:

• a listing of the human performance measures and criteria identified for the validation and a

discussion of the rationale for their inclusion, as well as for the exclusion of other reasonable

measures for the individual and the crew

• descriptions of relationships for those measures and criteria specific to the data sources or methods

used or whose definitions vary across the methods

• identification, description, and definition of any measures and criteria specific to methods or

constructs (e.g., cognitive workload or situation awareness measurement)

• descriptions of environmental or external influences that could impact human performance and how

they are integrated into the assessment

• time and information processing standards and how they are incorporated into the assessment

• the type of data source
II-10-6

10.2.3 Data Sources or Demonstration Methods

The reviewer should confirm that the submittal includes the following information regarding data sources or

demonstration methods:

• a description of the integrated design and execution of the validation using the selected sources and

methods, validation method, or implementation plan description

• a description of the data sources and methods used, the parts of the validation each supports, and

how they have been integrated

• a description of limitations in the scope and data quality (e.g., plant/system similarities and

differences, assumptions, estimates, algorithms, numbers and qualifications of subjects) for each

source

• a description of how dynamic interactions were assessed

10.2.4 Staffing Plan Validation Outcomes

The reviewer should confirm that the submittal includes the following information regarding the outcomes of

the staffing plan validation:

• a description and analysis of the outcomes of the staffing plan validation

• workload demands

• situational awareness

10.3 Review Criteria

The reviewer should be able to ensure that the applicable criteria described in the following sections have

been met:

10.3.1 Operational Conditions Sampling

The reviewer should confirm that the following criteria have been met, as applicable:

• The scenarios fully incorporated the operational conditions relevant to the exemption request.

• Relevant criteria were used to evaluate successful performance.

• Scenarios relevant to the exemption request were used.

• Scenarios that challenge the personnel, plant, and system were used.
II-10-7

10.3.2 Human Performance Measures and Criteria

The reviewer should confirm that the following criteria have been met, as applicable:

• The human performance measures and criteria are relevant to the plant/system concept of

operations.

• At a minimum, the selected human performance measures represent the most important outcome

behaviors.

• The rationale for excluding some potential human performance measures is reasonable.

• The selected measures assess both individual and crew performance, where appropriate.

• Measures specific to data collection methods or constructs have been used appropriately.

• The criteria defined for acceptable human performance on each measure are reasonable.

• Any identified environmental conditions, external conditions, or staffing practices that could

potentially degrade individual or crew performance, are effectively addressed by the staffing plan.

• Valid methods and criteria have been identified.

• The data analyses were performed using appropriate parameters and methods.

• The assumptions and estimates used in conducting the analyses are documented and appropriate.
II-10-8

10.3.3 Data Sources and Demonstration Methods

The reviewer should confirm that the following criteria have been met, as applicable:

• The selected design of the staffing plan validation, the data sources, and the demonstration methods

comprehensively address the dynamic aspects of the staffing plan and support the requested

exemption.

• The data sources and demonstration methods were used appropriately.

• The appropriate quantitative, objective measures and criteria were defined and captured. See

Section 5.2, “Validating Staffing Plans,” of NUREG/CR-6838 for further information.

• The data collection and analysis were conducted appropriately.

• The scope and data quality were adequate.

• The outcomes were reasonable and valid.

10.3.4 Staffing Plan Validation Outcomes

The reviewer should confirm that the following criteria have been met, as applicable:

• The results of analyses demonstrate that control personnel, individually and working in crews, if

applicable, can accomplish their tasks within performance criteria.

• The results of analyses demonstrate that the staffing plan does not result in either excessively high

or minimal workload demands on control personnel for the operational conditions considered.

• The results of the analyses demonstrate that the staffing plan does not compromise control

personnel situational awareness.

• The staffing plan effectively addressed any identified environmental conditions or staffing practices

that could potentially degrade individual or crew performance.
II-10-9

10.4 Additional Resources

• ANSI/AIAA G-035-1992: Guide to Human Performance Measurements, (American National

Standards Institute, 1993).

• IEEE Std. 845-1999: IEEE Guide to the Evaluation of Human-System Performance in Nuclear

Power Generating Stations, (Institute of Electrical and Electronics Engineers, 1999).

• NUREG-0711: Human Factors Engineering Program Review Model, Section 11.4.3 Integrated

System Validation, (NRC, 2004).

• NUREG/CR-6393: Integrated System Validation: Methodology and Review Criteria, (O’Hara et al.,

1997).

• NUREG/CR-6838: Technical Basis for Regulatory Guidance for Assessing Exemption Requests

from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR

50.54(m), (Plott, C., T. Engh, and V. Barnes, 2003). 
II-11-1

11. DETERMINE THE ACCEPTABILITY 

OF THE EXEMPTION REQUEST

In this step, NRC staff must make a final decision regarding the acceptability of the exemption request. The

decision will be based on the aggregate findings from the previous steps of the review. The reviewer should

be able to satisfactorily answer the following questions regarding the acceptability of the exemption request:

• Was sufficient justification provided to ensure that the impacts of the exemption request were

adequately addressed in the following components:

– concept of operations

– operational conditions

– operating experience

– functional requirements analyses and function allocation (or reallocation)

– task analyses

– job definitions

– staffing plan

– additional supporting data and analyses

– verification and validation of the staffing plan

• Were the range and combination of operational conditions considered by the applicant appropriate

and adequate?

• Were the data analyses performed using appropriate parameters and methods?

• Were the assumptions and estimates used in conducting the analyses documented and

appropriate?

• Will acceptance of the exemption request provide at least the same level of assurance that public

health and safety are maintained as the current regulations require?

The reviewer should prepare a summary of the overall findings along with the determination of the

acceptability of the exemption request. If the reviewer determines that there is insufficient evidence to

support the exemption request, the reviewer should identify the limitations of the submittals and the further

analyses, data, or changes in the exemption request that are needed. The reviewer should generate an

RAI and/or develop a letter indicating the weaknesses and strengths of the exemption request.
APPENDIX A

REVIEW CHECKLISTS
Step 1 - 

STEP 1. REVIEW THE EXEMPTION REQUESTPurpose: The review of the exemption request is performed to ensure that the reviewer understands the scope of the request a

has submitted the necessary information to perform the review.Applicability: This section is applicable in all cases for which an exemption from 10 CFR 50.54(m) is requested.

Instructions: Verify that the request includes the following information. If the information is not provided or deemed not applicab

in the comments field.

Y N N/A Data and information contain: Comments

Description of the specific aspects of 10 CFR 50.54(m) from which anexemption is requested.Physical representation of the plant and systems involved.Descriptions of plant/system responses to inputs and expectedresponse timesDetailed representation of the control room, control suites, and/or theHSI to be used for monitoring and control actions.Definitions of any new terms used or redefinitions of terms whosemeanings are changed.Information to meet the data requirements of subsequent review steps.
Step 1 - 

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Y N N/A Review Criteria Comments

One or more exemptions to 10 CFR 50.54(m) is required.Exemptions from other, related regulations are either unnecessary orhave been appropriately identified and described by the applicantThe terms used in the submittal are fully defined.Adequate data and information have been submitted to meet the datarequirements for the remainder of the review.
Step 2 - Revie

Step 2. REVIEW OF THE CONCEPT OF OPERATIONSPurpose: The purpose of reviewing the concept of operations is to provide the reviewer with a more comprehensive understandin

and associated exemption requests fit into the overall design and operation of the plant.Applicability: This section is applicable in all cases for which an exemption from 10 CFR 50.54(m) is requested.

Instructions: Verify that the request includes the following information. If the information is not provided or deemed not applicable

the comments field.

Y N N/A Data and information contain: Comments

The primary design and operating characteristics of the plant or systemand the specific staffing goals and assumptions necessary to implementthe concept of operations.The number of personnel who will have plant monitoring andoperational control responsibilities on each shift (i.e., “controlpersonnel”), and staffing levels for these personnel across shifts.The roles and responsibilities of each individual designated as a controlpersonnel are provided, if that individual is responsible for control andmonitoring plant or unit operations.The training and qualifications required for control personnel.The overall operating environment and primary HSI to be used bycontrol personnel.The interaction of control personnel with automated systems includingresponsibilities for monitoring, operating, and overriding automatedsystems.
Step 2 - Revie

Y N N/A Data and information contain (con’t): Comments

The interaction of control personnel with automated support systemsand the role of these systems in the overall management and control ofthe plant.Other mechanisms that enable or support control personnelresponsibilities for monitoring, disturbance detection, situationassessment, response planning, response execution, and themanagement of transitions between automatic and manual control.The interactions of control personnel with each other and with peoplenot directly responsible for the control and safe operation of the plant.Multi-unit operations.Modular unit operationsOperation during construction of additional units.

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Y N N/A Review Criteria Comments

The applicant’s description of the concept of operations for the plant orsystem is complete.Each of the aspects of operations and roles of the control personnel areaddressed.
Step 3 - Re

Step 3. REVIEW THE OPERATIONAL CONDITIONSPurpose: The purposed of the review of the operational conditions is to ensure that the operational conditions which present the 

the effective and safe performance of control personnel, under the conditions of the requested exemption, were analyzed by the 

exemption request.Applicability: This section is applicable in all cases for which an exemption fro 10 CFR 50.54(m) is requested. However, the revie

upon whether the exemption request is for an advanced reactor control room or for a modification to an existing plant control rooInstructions: Verify that the request includes the following information. If the information is not provided or deemed not applicable

the comments field.

Y N N/A Data and information contain: Comments

A description of the operational conditions selected for analysis.The rationale for selecting the operational conditions analyzed and forexcluding others that could have been analyzed.

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.Use the following criteria for an advanced reactor control room exemption request review:

Y N N/A Review Criteria Comments

Normal operational events, including plant startup, shutdown, orrefueling, and significant changes in operating power were analyzed.

Failure events, including instrument failures and HSI failures, wereanalyzed.
Step 3 - Re

Y N N/A Review Criteria (Con’t) Comments

Transients and accidents were analyzedReasonable, risk-significant, and beyond-design-basis events,derived from the plant-specific PRA, were analyzed.Conditions that challenge plant safety functions as a result ofinterconnections and interactions among systems were analyzed.Risk-significant human actions were included in the analysis.Difficult tasks identified through the operating experience reviewwere included in the analysis.A range of procedure-guided tasks that are well defined bynormal, abnormal, emergency, alarm response, and testprocedures were included in the analysis.A range of knowledge-based tasks that require greater reasoningabout safety and operating goals and the various means ofachieving them were included in the analysis.A range of human cognitive activities, including decision makingwere included in the analysis.A range of human interactions, including tasks performed byindividual control personnel and any tasks performed bypersonnel acting as a crew were included in the analysis.Tasks that are performed with high frequency were included inthe analysis.Tasks that are important or difficult but infrequently performedwere included in the analysis.
Step 3 - Re

Y N N/A Review Criteria (Con’t) Comments

Operationally difficult tasks were included in the analysis.Error-forcing contexts were included in the analysis.High-workload conditions were included in the analysis.Varying-workload situations were included in the analysis.Fatigue and circadian factors were included in the analysis.Environmental factors were included in the analysis.The range and combination of operational conditions consideredby the applicant are appropriate and adequate.

Use the following criteria for modification to an existing plant control room exemption request review:

Y N N/A Review Criteria Comments

The operational conditions selected include the tasks that areaffected by the modification, rather than the entire range of tasksrequired to analyze a plant design.Transfer of learning effects on human performance wereassessed when a new system is replacing an existing HSI, whenprocedures have been modified, or when personnel will berequired to use both the new system and an existing HSI.The potential for deactivated HSI that will be left in place tointerfere with task performance was considered.The range and combination of operational conditions consideredby the applicant were appropriate and adequate.
Step 4 

STEP 4. REVIEW OPERATING EXPERIENCEPurpose: The purpose of this step of the review is to ensure that the applicant has performed a review of relevant operational exp

staffing-related lessons learned that may be important to the exemption request.Applicability: This section is applicable in all cases for which and exemption from 10 CFR 50.54(m) is requested. The amount of 

will vary, depending upon whether the exemption request involves new reactor designs or the introduction of new systems into a

Instructions: Verify that the request includes the following information. If the information is not provided or deemed not applicable

the comments field.

Y N N/A Data and information contain: Comments

Operating experience from predecessor plants or systems.Operating experience from plants or systems using similartechnologies, practices, or concepts of operation.Recognized industry human performance and staffing issues.Issues identified by predecessor or similar plant personnel.Operating experience from prototype or experimental plants/systems.Operating experience from other industries.
Step 4 

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Y N N/A Review Criteria Comments

Predecessor or similar plants and systems included in theanalysis are identified and their similarities and differences fromthe exemption under consideration are described.Any recognized industry issues with the plant or system designare identified.Any recognized industry issues with staffing for similar plants,systems, or technologies are identified.Other sources of operating experience data are identified, alongwith any limitations of their use in performing the review for theexemption requested.For each of the related plants or systems selected, the applicanthas reviewed the staffing goals and numbers of controlpersonnel.The process used by the applicant for identifying issues duringthe operating experience review includes a description of theassumptions, criteria, and constraints used in selecting issuesand developing interviews of control personnel.The applicant has identified the risk-important actions associatedwith existing plants, systems, or relevant technologies that couldpotentially be a problem if the requested exemption is granted.
Step 4 

Y N N/A Review Criteria (Con’t) Comments

The operating experience review was of sufficient scope toidentify the most important relevant information and theapplicant’s rationale for excluding some experience that couldhave been analyzed is reasonable.Examples of effective implementations of technologies, practices,or concepts of operation included as support for the exemptionare fully substantiated and documented.
Step 5 - Review Functional Requirements 

STEP 5. REVIEW FUNCTIONAL REQUIREMENTS ANALYSIS AND FUNCTION ALLOCATIONPurpose: The first purpose of this step of the review is to ensure that the applicant has defined and evaluated the impact of the e

plant/system functions that must be performed to satisfy plant safety objectives. The second purpose is to ensure that the alloca

systems has resulted in a role for control personnel that uses human strengths, avoids human limitation, and can be performed uevaluated in the exemption request.Applicability: This section is applicable in all cases for which an exemption from 10 CFR 50.54(m) is requested.

Instructions: Verify that the request includes the following information. If the information is not provided or deemed not applicable

the comments field.

Y N N/A Data and information contain: Comments

The set of functions identified as being relevant to the exemptionrequest.The sequence of performance of the functions, triggering events fortheir initiation, and conditions for their completion or suspension.Minimum function performance requirements in terms of time, timing,and accuracy.Identification of functions that include risk-important human actions andthe consequences (e.g., error rates or estimates of error rates) of notperforming those actions, performing them incompletely, or notperforming them within the time required.A description of the allocation of functions to control personnel,automated systems, or a combination of the two.A description of how the allocation of functions supports integratedcontrol staff roles across functions and systems.
Step 5 - Review Functional Requirements 

Y N N/A Data and information contain (Con’t): Comments

A description of how control personnel functions relate to the functionsperformed by other plant personnel.Identification of functions that can be reallocated across or betweencontrol personnel, automated systems, or other plant staff, and adescription of the strategies and criteria employees for reallocation.Identification of functions with risk-important human actions that may bereallocated with a description of how the risks are managed through thereallocation.Identification of function allocations that may affect the roles,responsibilities, or qualifications for licensed control personnel.Identification of function allocations to any new control personnel jobs.

Applicable supporting data from the concept of operations, theoperational conditions defined, and the operating experience review.

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Y N N/A Review Criteria Comments

The set of functions identified as applicable to the analysis is completeand appropriately characterized. All functions have been allocated to control personnel, automatedsystems, or a combination of the two, and that the strategies and criteriafor the allocations are clear and met.
Step 5 - Review Functional Requirements 

Y N N/A Review Criteria (Con’t) Comments

The function allocations support integrated control staff roles acrossfunctions, systems, and other plant personnel.Any new or modified licensed control personnel positions resulting fromthe function requirements analysis and function allocation have beenidentified and characterized.The data analyses were performed using appropriate parameters andmethods.The assumptions and estimates used in conducting the analyses weredocumented and appropriate.
Step 

STEP 6. REVIEW THE TASK ANALYSISPurpose: The purpose of the task analysis review is to ensure that the applicant’s analysis identifies the specific tasks that are ne

and their staffing implications.Applicability: This section is applicable in all cases for which an exemption from 10 CFR 50.54(m) is requested.

Instructions: Verify that the request includes the following information. If the information is not provided or deemed not applicable

the comments field.

Y N N/A Data and information contain: Comments

The set of tasks identified as being relevant to the exemption request.The sequence of performance of the tasks, triggering events for theirinitiation, and conditions for their completion or suspension.Minimum task performance requirements in terms of time, timing,accuracy, or other relevant criteria, as identified in the table of taskconsiderations that follow.Identification of tasks that include risk-important human actions and theconsequences (e.g., error rates or estimates of error rates) of notperforming those actions, performing them incompletely, or notperforming them within the time required.Identification of tasks that may affect the roles, responsibilities, orqualifications for licensed control personnel.Identification of tasks for any new control personnel jobs.Applicable supporting data from the concept of operations, theoperational conditions defined, function requirements analysis and

function allocation, and the operating experience review.
Step 

Table of Task Considerations

Y N N/A Category Data Item Requirements Comme

InformationRequirements

Alarms and alerts Any alarms and alerts that would trigger a

task to start.

Parameters Any parameters that would indicate the task is

appropriate for performance.

Feedback needed toindicate adequacy ofactions taken

Any parameter that the operator would needto monitor during the task to ensure the taskis correctly executed.

DecisionmakingRequirements

Decision type (relative,absolute, probabilistic)

Explanation of how and when decisionsbetween alternative tasks are made.

Evaluations to beperformed

Parameters that must be evaluated in thedecision and how they are applied.

Coordination Decisions that must be made or approved by

others.

ResponseRequirements

Type of action to be taken A description of the operator action taken in

the task.

Task frequency A measurement of how frequently the task

occurs.

Task tolerance A measure of the allowable accuracy for the

task to be considered successfully performed.

Task accuracy The expected value of how accurately the

task will be performed by the operator.
Step 

Table of Task Considerations (Con’t)

Y N N/A Category Data Item Requirements Comm

ResponseRequirements(Con’t)

Consequences ofinaccurate performance

The effect that inaccurate task performancehas on other tasks in the scenario.

Time required An estimate of the amount of time required for

the operator to complete the task. Statisticaldistributions should be provided. Ifdistributions are unavailable, a typicalminimum and maximum time should beprovided.

Physical position The physical position and location required for

the operator to perform the task.

Biomechanics A description of the physical activity that must

be performed (movements) and the forcesrequired.

CommunicationRequirements

Personnel communicationfor monitoring or control,including among controlpersonnel and directing theactivities of others

A description of the participants in thecommunication and informationcommunicated.

Personnel communicationfor administrative,reporting, and externalcommunications

A description of the participants in thecommunication and informationcommunicated.

Workload Visual A ranking of the visual workload.

Auditory A ranking of the auditory workloadCognitive A ranking of the cognitive workload
Step 

Table of Task Considerations (Con’t)

Y N N/A Category Data Item Requirements Commen

Workload (con’t)(

Psychomotor A ranking of the psychomotor workloadOverlap of taskrequirements

An indicator if other tasks may or may not berun in parallel with this task.

Task SupportRequirements

Special protectiveclothing

Any clothing that could interfere with taskperformance or be required for taskperformance.

Job aids or referencematerials needed

Any reference materials that couldimprove performance, or be required toperform the task, and any demands formultiple, concurrent use

Tools and equipmentneeded

Any tools or equipment required toperform the task

Automation orautomated support

Any automated support systems thatcould affect performance or be requiredto perform the task, and any demands formultiple, concurrent use

WorkplaceFactors

Ingress and egresspaths to work site

Any specific paths an operator must taketo get to the work area

Workspace envelopeneeded by action taken

Any space requirements needed toperform the task
Step 

Table of Task Considerations (Con’t)

Y N N/

A

Category Data Item Requirements Comme

WorkplaceFactors (con’t)

Typical and extremeenvironmental conditions

Measures of the typical and extremeconditions for—• lighting• heat• temperature• noise

Situational andPerformanceShapingFactors

Stress Level of stress expected based upon the

severity of the scenario or conditions

Reduced staffing Reasonable expectations about understaffing

in the scenario

Fatigue Typical and extreme conditions for—

• time since last sleep• point in circadian cycle

HazardIdentification

Identification of hazardsinvolved

Any hazards that may impair performance ormake an operator unavailable due to injury
Step 

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Y N N/A Review Criteria Comments

The set of tasks identified as applicable to the analysis iscomplete and appropriately characterized.The task performance requirements for each task werecomprehensively identified.The tasks for any new or modified licensed control personnelpositions have been identified and characterized.The data analyses were performed using appropriate parametersand methods.The assumptions and estimates used in conducting the analyseswere documented and appropriate.
Ste

STEP 7. REVIEW THE JOB DEFINITIONSPurpose: The purpose of the job definition review is to confirm that the applicant has established clear and rational job definitions 

responsible for controlling the plant. For an existing plant in which new systems will be implemented, the purpose of the review i

has retained clear and rational job definitions for control room personnel. Applicability: This section is applicable in all cases for which an exemption from 10 CFR 50.54(m) is requested. Its scope should 

personnel that are impacted by the exemption request. Within a job, the scope of the review may also be limited by the extent (e

tasks impacted) and character (e.g., only responsibilities affected, not qualifications) of the exemption request.Instructions: Verify that the request includes the following information. If the information is not provided or deemed not applicable

the comments field.

Y N N/A Data and information contain: Comments

A description of the scope and the impacts of the exemption request onthe roles, responsibilities, and qualifications of control personnel.Identification of any new or modified roles, responsibilities, andqualifications for licensed control room personnel (under the currentrequirements) included in the exemption request.Identification of the roles, responsibilities, and qualifications for any newjobs included in the exemption request.Applicable data from the concept of operations, operational conditions,operating experience, functional requirements analysis and functionallocation, and task analysis for each of the jobs affected that supportthe roles and responsibilities identified in the exemption request.Applicable data from the KSA analysis for each of the jobs affected thatsupport the qualifications identified in the exemption request.
Ste

Y N N/A Data and information contain (Con’t): Comments

A final job description for each job impacted by the exemption request.Job definitions which appropriately prioritize the responsibilities of eachposition and that do not incorporate role conflicts.

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Y N N/A Review Criteria Comments

The scope and impact of the exemption request on control personneljobs.Applicable data from the concept of operations, operational conditions,operating experience, functional requirements analysis and functionallocation, and task analysis support the roles and responsibilitiesassigned to each impacted job in the exemption request. The KSA analysis is complete and that the KSAs are consistent with thequalifications required for each impacted job identified in the exemptionrequest. Coherent job descriptions are maintained for licensed control roompersonnel (under the current requirements), or are defined for any newjobs included as a part of the exemption requestThe job definitions for control personnel who will work in crews arecoordinated.
S

STEP 8. REVIEW THE STAFFING PLANPurpose: The purpose of the staffing plan review is to ensure that the applicant has systematically analyzed the requirements for 

personnel that are necessary to operate the plant safely under the operational conditions analyzed.Applicability: This section is applicable in all cases where an exemption from 10 CFR 50.54(m) is requested.

Instructions: Verify that the request includes the following information. If the information is not provided or deemed not applicable

the comments field.

Y N N/A Data and information contain: Comments

The set of operational conditions considered for the staffing plan, to theextent that they differ from those submitted for other elements of theexemption request.The proposed staffing levels, shift composition, and shift schedules forthe identified operational conditions.A description of how the staffing plan supports integrated staff rolesacross shifts and operational conditions.Identification of the types of control personnel who can be substitutedwithin each job, given the concept of operations.When applicable, expected travel times or response times for controlpersonnel who need to move to new locations (e.g., home to the plantor office) or provide other support (e.g., to log in to system controlcomputers from home).
S

Y N N/A Data and information contain (Con’t): Comments

A description of how control personnel staffing relates to the larger plantstaffing and the support roles that control personnel may play in thelarger staffing context.Applicable supporting data from the concept of operations, the set ofoperational conditions considered, the functional requirements analysis

and function allocation, task analysis, job definitions, and the operatingexperience review.

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Y N N/A Review Criteria Comments

The set of operational conditions identified as applicable to the staffingplan is complete and representative of the exemption request.The staffing plan will provide adequate numbers of qualified personnel tooperate the plant safely under the operational conditions considered.

Roles/responsibilities are integrated across shifts and among personnel.Travel and response times are adequate and do not trigger adverseconditions for the safety of the plant.The staffing plan uses data from previous sections in a logical/rationalmanner.
Step 9 - Revie

STEP 9. REVIEW ADDITIONAL DATA AND ANALYSESPurpose: The purpose of the review of additional data and analyses is to allow the consideration of additional data that is often n

may be applicable, in the review of the exemption request.Applicability: This section is applicable in all cases for which an exemption from 10 CFR 50.54(m) is requested. However, in mos

analyses are unnecessary for the evaluation of staffing. The reviewer must determine if any additional analyses are needed basrequest presented.Instructions: Determine if each of the following additional analyses are necessary. If the analysis is needed, please indicate the r

Y N N/A Additional Analysis Comments

Human reliability analysis used to demonstrate the impacts of riskimportant human actions.Human-system integration data used to demonstrate that the design ofthe HSI supports the concept of operations, functional requirementsanalysis and function allocation, task analysis, staffing plan, andoperating experience.Knowledge, skills, and abilities analysis used in support of new orchanging job definitions.Knowledge, skills, and abilities analysis used to support modified tasksor HSI.Procedures and training documentation used to demonstrate theimplementation of components of the concept of operations, functionalrequirements analysis and function allocation, or task analysis.
Step 10 - Re

STEP 10. REVIEW THE STAFFING PLAN VALIDATIONPurpose: The purpose of reviewing the validation of the staffing plan is to ensure that the applicant fully considered the dynamic 

design, its systems, and control personnel for the operational conditions identified for the exemption request.Applicability: This section is applicable in all case for which an exemption from 10 CFR 50.54(m) is requested.

Instructions: Verify that the request includes the following information. If the information is not provided or deemed not applicable

the comments field.

Operational Conditions Sampling

Y N N/A Data and information contain: Comments

A description of each of the scenarios used in validating the staffingplan.A description of how the scenarios incorporate the operationalconditions relevant to the exemption request.A description of system and key plant parameters relevant to thescenarios.Relevant criteria for evaluating successful performance.Scenarios that challenge personnel, plant, and system performance.
Step 10 - Re

Human Performance Measures and Criteria

Y N N/A Data and information contain: Comments

A listing of the human performance measures and criteria identified forthe validation and a discussion of the rationale for their inclusion, aswell as for the exclusion of other reasonable measures for the individualand the crew.Descriptions of relationships for those measures and criteria specific tothe data sources or methods used or whose definitions vary across themethods.Identification, description, and definition of any measures and criteriaspecific to methods or constructs (e.g., cognitive workload or situationawareness measurement).Descriptions of environmental or external influences that could impacthuman performance and how hey are integrated into the assessment.Time and information processing standards and how they areincorporated into the assessment.The type of data source.

Data Sources or Demonstration Methods

Y N N/A Data and information contain: Comments

A description of the integrated design and execution of the validationusing the selected sources and methods, validation method, orimplementation plan description.A description of the data sources and methods used, the parts of thevalidation each supports, and how they have been integrated.
Step 10 - Re

Y N N/A Data and information contain (Con’t): Comments

A description of limitations in the scope and data quality (e.g.,plant/system similarities/differences, assumptions, estimates,algorithms, numbers/qualifications of subjects) for each source.A description of how dynamic interactions were assessed.

Staffing Plan Validation Outcomes

Y N N/A Data and information contain: Comments

A description and analysis of the outcomes of the staffing planvalidation.Workload demands.Situational awareness.

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Operational Conditions Sampling

Y N N/A Review Criteria Comments

The scenarios fully incorporate the operational conditions relevant to theexemption request.Relevant criteria for evaluation of successful performance were used.Scenarios relevant to the exemption request were used.Scenarios that challenge the personnel, plant, and system were used.
Step 10 - Re

Human Performance Measures and Criteria

Y N N/A Review Criteria Comments

Confirm that the human performance measures and criteria are relevantto the plant/system concept of operations.The human performance measures selected, at a minimum, representthe most important outcome behaviors. The rationale for excluding some potential human performancemeasures is reasonable.The measures selected assess both individual and crew performance,where appropriate.The criteria defined for acceptable human performance on eachmeasure is reasonable.Any identified environmental conditions, external conditions, or staffingpractices that could potentially degrade individual or crew performance,are effectively addressed by the staffing plan.Valid methods and criteria have been identified.The data analyses were performed using appropriate parameters andmethods. The assumptions and estimates used in conducting the analyses aredocumented and appropriate.
Step 10 - Re

Data Sources or Demonstration Methods

Y N N/A Review Criteria Comments

The design of the staffing plan validation, the data sources, and thedemonstration methods selected comprehensively address the dynamicaspects of the staffing plan and support the requested exemption.The data sources and demonstration methods were used appropriately.The data collection and analysis were conducted appropriately.The scope and data quality were adequateThe outcomes were reasonable/valid.

Staffing Plan Validation Outcomes

Y N N/A Review Criteria Comments

The results of analyses demonstrate that control personnel, individuallyand working in crews, if applicable, can accomplish their tasks withinperformance criteria.Results of analyses demonstrate that the staffing plan does not result ineither excessively high or minimal workload demands on controlpersonnel for the operational conditions considered.The results of the analyses demonstrate that the staffing plan does notcompromise control personnel situational awareness.Any identified environmental conditions or staffing practices that couldpotentially degrade individual or crew performance are effectivelyaddressed by the staffing plan.
Step 11 - Determine the Accept

STEP 11. DETERMINE THE ACCEPTABILITY OF THE EXEMPTION REQUESTPurpose: The purpose of this step is to make a final decision regarding the acceptability of the exemption request.

Applicability: This section is applicable in all cases for which an exemption from 10 CFR 50.54(m) is requested.

Instructions: Confirm that each of the following review criteria has been met. If a criterion has not been met or has been deemed 

the reason in the comments field.

Y N N/A Review Criteria Comments

Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the concept ofoperations documentation?Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the operationalconditions documentation?Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the operatingexperience documentation?Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the functionalrequirements analyses and function allocation documentation?Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the task analysesdocumentation?Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the job definitionsdocumentation?
Step 11 - Determine the Accept

Y N N/A Review Criteria (Con’t) Comments

Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the staffing plandocumentation?Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the additionalsupporting data and analyses documentation?Was sufficient justification provided to ensure that the impacts of theexemption request were adequately addressed in the verification andvalidation of the staffing plan documentation?Were the range and combination of operational conditions consideredby the applicant appropriate and adequate?Were the data analyses performed using appropriate parameters andmethods?Were the assumptions and estimates used in conducting the analysesdocumented and appropriate?Will acceptance of the exemption request provide at least the samelevel of assurance that public health and safety are maintained as thecurrent regulations require?
APPENDIX B

GLOSSARY
B-1

GLOSSARY

10 CFR 50.54, Conditions of licenses - The conditions that must be met in a nuclear power plant in order

for a license to be issued.

10 CFR 50.54(m) - The minimum shift staffing requirements that must currently be met for a license to be

issued for a nuclear power plant.

Advanced control room - A control room that is primarily based on digital technology. It typically provides

the primary operator interaction with the plant via computer-based interfaces, such as video display units. 

This is in contrast to “conventional” control rooms, which provide the primary operator interaction with the

plant via analog interfaces, such as gauges.

Advanced reactor - A nuclear power plant design that incorporates new technology such as advanced

automation, passive safety systems, and/or new human system integration concepts.

Algorithm - A step-by-step procedure for solving a problem or accomplishing some task through a process,

especially by a computer.

Cognitive workload - The degree to which a person’s mental capabilities are taxed during the performance

of the tasks that comprise his or her job.

Computer-supported cooperative network - The use of computers and electronic devices as a medium

through which to communicate in real time

Concept of operations - A description of how the design, systems, and operational characteristics of a

plant relate to an organization’s structure, staffing, and management framework.

Control personnel - Individuals licensed to manipulate controls that affect the reactivity or power level of a

nuclear reactor, manipulate fuel, and/or direct the activities of individuals so licensed.

Exemption application - A request for licensing that asks for an exemption from any of the requirements of

10 CFR Part 50.

Function - A process or activity that is required to achieve a desired goal.

Function allocation - The analysis of the requirements for plant control and the assignment of control

functions to personnel or system elements or a combination of personnel or system elements.

Functional requirements analysis - The identification of functions that must be performed to prevent or

mitigate the consequences of postulated accidents that could damage the plant or cause undue risk to the

health and safety of the public.
B-2

Human reliability analysis - The process of evaluating the potential for and mechanisms of human error

that may affect plant safety.

Human-system interface - The part of a system through which personnel interact to perform their

functions and tasks. In this document, “system” refers to a nuclear power plant. Major HSIs include alarms,

information displays, controls, and job performance aids.

Intelligent agent - Any computer system that interacts with a human to assist in cognitive processing

functions or, in some cases, initiate purposeful action as a result of predictions related to the user’s goal (i.e.

computer-supported decision-making)

Integrated system validation - An evaluation using performance-based tests to determine whether an

integrated system design (i.e., hardware, software, and personnel elements) meets performance

requirements and acceptably supports safe operation of the plant.

Job - A group of tasks and functions that are assigned to a personnel position.

Job definition - The responsibilities, authorities, knowledge, skills, and abilities that are required to perform

the tasks and functions assigned to a job.

Light-water reactor - A term used to describe reactors using water as coolant, including boiling-water

reactors and pressurized-water reactors.

Model - A representation of how a complex entity or system is structured and functions.

Operating experience review - A review of relevant history from a plant’s ongoing collection, analysis, and

documentation of operating experiences; including relevant experience from other plants and/or other

industries.

Passive safety feature - Design characteristics that use natural forces, such as convection and gravity,

which are less dependent on active systems and components like pumps and valves to maintain plant

safety.

Performance shaping factors - Factors that influence human reliability through their effects on

performance, including environmental conditions, human-system interface design, procedures, training, and

supervision.

Procedures - Written instructions providing guidance to plant personnel for operating and maintaining the

plant and for handling disturbances and emergency conditions.

Request for exemption - An analogous term to exemption application (above).

Shift composition - The different types of jobs that must be filled on each shift and the number of

personnel required for each of the jobs on a shift.

Simulator - A facility that physically represents the human-system interface configuration and that

dynamically represents the operating characteristics and responses of the plant in real time.
B-3

Situation or situational awareness - An individual’s mental model of what has happened, the current

status of the system, and what will happen in the next brief time period.

Task - A group of related activities that have a common objective or goal.

Task analysis - The identification of requirements for accomplishing tasks (i.e., for specifying the

requirements for the displays, data process, controls, and job aids needed to accomplish tasks.)

Validation - See integrated system validation (above).

Verification - The process by which the design is evaluated to determine whether it acceptably satisfies

personnel task needs and human factors engineering design guidance.

Workload - The physical and cognitive demands placed on plant personnel.
APPENDIX C

REFERENCES
C-1

REFERENCES

American Institute of Aeronautics and Astronautics (1992). Guide for the Preparation of Operational

Concept Documents (AIAA G-043-1992). Reston, Virginia: American Institute of Aeronautics and

Astronautics.

American National Standards Institute/American Nuclear Society (1993). Selection, Qualification, and

Training of Personnel for Nuclear Power Plants (ANSI/ANS 3.1). LaGrange Park, Illinois: American Nuclear

Society.

American National Standards Institute (1993). Guide to Human Performance Measurements (ANSI/ANS

58.8). Washington, DC: American National Standards Institute.

Burgey, D., et al. (1983). Task Analysis of Nuclear Power Plant Control Room Crews (NUREG/CR-3371). 

Washington, DC: U.S. Nuclear Regulatory Commission.

Endsley, M. and D. Garland (2000). Situation Awareness Analysis and Measurement. Mahwah, NJ:

Lawrence Earlbaum.

Hallbert, B. and D. Morisseau (2000). A Study of Control Room Staffing Levels for Advanced Reactors

(NUREG/IA-01378). Washington, DC: U.S. Nuclear Regulatory Commission.

Higgins, J. and K. Nasta (1996). HFE Insights for Advanced Reactors Based Upon Operating Experience

(NUREG/CR-6400). Washington, DC: U.S. Nuclear Regulatory Commission.

Institute of Electrical and Electronics Engineers (1999). IEEE Guide to the Evaluation of Human-System

Performance in Nuclear Power Generating Stations (IEEE Std. 845-1999). New York: Institute of Electrical

and Electronics Engineers.

Institute of Electrical and Electronics Engineers (1988). IEEE Guide to the Application of Human Factors

Engineering to Systems, Equipment, and Facilities of Nuclear Power Generating Stations (IEEE Std. 1023-

1988). New York: Institute of Electrical and Electronics Engineers.

International Atomic Energy Agency (1992). The Role of Automation and Humans in Nuclear Power Plants

(IAEA-TECDOC-668). Vienna, Austria: International Atomic Energy Agency.

International Atomic Energy Agency (1988). Basic Safety Principles for Nuclear Power Plants (IAEA Safety

Series No. I 75-INSAG-3). Vienna, Austria: International Atomic Energy Agency.

International Electrotechnical Commission (1989). Design for Control Rooms of Nuclear Power Plants (IEC

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NRC (2004). Human Factors Engineering Program Review Model. (NUREG-0711, Rev.2 ). Washington,

DC: U.S. Nuclear Regulatory Commission.

NRC (2001). Integrated Safety Analysis Guidance Document (NUREG-1513). Washington, DC: U.S.

Nuclear Regulatory Commission.
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NRC (2000). Qualification and Training of Personnel for Nuclear Power Plants (Regulatory Guide 1.8, Rev.

3). Washington, DC: U.S. Nuclear Regulatory Commission.

NRC (1998). Standard Review Plan (NUREG-0800). Washington, DC: U.S. Nuclear Regulatory

Commission.

NRC (1998). Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors

(NUREG-1123, Rev. 2). Washington, DC: U.S. Nuclear Regulatory Commission.

NRC (1998). Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Operator

Actions, Including Response Times (Information Notice 97-78). Washington, DC: U.S. Nuclear Regulatory

Commission.

NRC (1997). Crediting of Operator Actions in Place of Automatic Actions and Modifications of Operator

Actions, Including Response Times (Information Notice 97-78). Washington, DC: U.S. Nuclear Regulatory

Commission.

NRC (1996). Nuclear Power Plant Simulation Facilities for Use in Operator License Examinations

(Regulatory Guide 1.149, Rev. 2). Washington, DC: U.S. Nuclear Regulatory Commission.

NRC (1995). Results of Shift Staffing Study (Information Notice 95-48). Washington, DC: U.S. Nuclear

Regulatory Commission.

NRC (1993). Training Review Criteria and Procedures (NUREG-1220, Rev. 1). Washington, DC: U.S.

Nuclear Regulatory Commission.

NRC (1989). Guidance to Operators and to Senior Operators in the Control Room of a Nuclear Power Plant

(Regulatory Guide 1.114). Washington, DC: U.S. Nuclear Regulatory Commission.

NRC (1986). Policy Statement on Engineering Expertise on Shift (Generic Letter 86-04). Washington, DC:

U.S. Nuclear Regulatory Commission.

NRC (1985). “Policy Statement on Engineering Expertise on Shift.” Federal Register, Vol. 63, No. 12: p.

43621. October 28, 1985.

NRC (1981). Implementation of Engineering Expertise on Shift (Information Notice 93-81). Washington,

DC: U.S. Nuclear Regulatory Commission.

O’Hara, J. and W. Brown (2002). The Effects of Interface Management Tasks on Crew Performance and

Safety in Complex, Computer-Based Systems (NUREG/CR-6690, Volumes 1 and 2). Washington, DC: U.S.

Nuclear Regulatory Commission.

O’Hara, J., et al. (1997). Integrated System Validation: Methodology and Review Criteria (NUREG/CR6393). Washington, DC: U.S. Nuclear Regulatory Commission.
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Plott, C., T. Engh, and V. Barnes (2003). Technical Basis for Regulatory Guidance for Assessing

Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in

10 CFR 50.54(m) (NUREG/CR-6838). Washington, D.C.: U.S. Nuclear Regulatory Commission.

Pulliam, R., et al. (1983). A Methodology for Allocation of Nuclear Power Plant Control Functions to Human

and Automated Control (NUREG/CR-3331). Washington, DC: U.S. Nuclear Regulatory Commission. 

Code of Federal Regulations, Title 10, “Energy,” Section 50.12, “Specific Exemptions.”

Code of Federal Regulations, Title 10, “Energy,” Section 50.54, “Conditions of Licenses.”

Code of Federal Regulations, Title 10, “Energy,” Section 50.55, “Operators’ Licenses.”

Code of Federal Regulations, Title 10, “Energy,” Section 50.120, “Training and Qualification of Nuclear

Power Plant Personnel.”