FAQs for New Reactor Operator Licensing
Introductory Note and Disclaimer
This summary of operator licensing and human factors topics covers recent public discussions of issues related to licensing new power reactor facilities. The summary also provides information that touches on general-interest topics from recent interactions. This summary is not regulatory guidance, compliance with the information provided is not required, the information is subject to change, and the summary should not be considered an official position of the U.S. Nuclear Regulatory Commission (NRC). Legally binding regulatory requirements are stated only in laws, NRC regulations, licenses, including technical specifications, or orders. Additional questions should be directed to the NRC's Operator Licensing and Human Factors Branch Contact Us page.
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Operator Licensing and Human Factors Topics for New Power Reactor Licensing
1. From a Part 50 facility licensing standpoint (i.e., a Construction Permit followed by an Operating License), what specific tests or validations are required to achieve a "plant referenced simulator?"
As a matter of process, the facility license applicant will determine when a plant referenced simulator has been established; this is referred to as "declaring" a plant referenced simulator. Thus, completion of a performance testing regimen like that described under ANSI/ANS-3.5, and resolution of identified discrepancies, remains an appropriate step towards preparing for an Inspection Procedure (IP) 41502 inspection. The facility may choose to use another method of testing but would need to provide the basis describing how the regulatory requirements of Part 55 are met.
Please refer to "Charter: Declaration of Plant-Referenced Simulators and Qualification of Commission-Approved Simulation Facilities to Support the Cold Licensing Process - Tasks & Recommendations: Task 2" for additional insights.
2. What is the expectation for simulator validation testing under a Part 50 facility licensing approach?
This is an area in which parallel operator licensing and human factors engineering processes exist and must be considered. Question 1 provides a discussion about declaring a plant-referenced simulator. A similar process would likely be used for a Commission-approved simulator for the purposes of operator licensing. However, it must be kept in mind that human factors engineering validation testing involving a simulator testbed is a distinct process. NUREG-0711, "Human Factors Engineering Program Review Model," Revision 3, and, in particular, chapter 11 of that document discuss validation activities within this context.
3. How will the NRC determine if the simulator meets the requirements for a plant-referenced simulator for use in operator licensing examinations and reactivity manipulations?
Once the facility determines the simulator is a plant-referenced simulator, the NRC would then perform Inspection Procedure (IP) 41502, " This inspection confirms that the simulator is acceptable for the purposes of use within regulated contexts (e.g., reactivity manipulations for licensed operator applicant experience, initial operator licensing exams, etc.). It is important to recognize that the scope of this inspection procedure is closely linked to the performance testing methods described under ANSI/ANS-3.5-2009, which the agency has previously endorsed under RG-1.149, "Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements" (Rev. 4). This standard only represents one means of meeting the relevant requirements of § 55.46. While a facility license applicant would be free to propose alternatives to RG-1.149, the applicant must then adequately justify how the proposed alternative represents an acceptable equivalent. The NRC would then review that justification to determine if the regulatory requirements of Part 55 are met.
4. What are some considerations for the tracking and resolution of simulator issues under a Part 50 facility licensing approach?
Simulator issues occurring during the licensing of a new facility fall into categories of simulator performance discrepancies and Human Engineering Discrepancies (HEDs). The tracking and resolution of each is covered by separate requirements and guidance (e.g., § 50.34(f)(2)(iii), 55.46, NUREG-0711, RG-1.149, etc.).
A substantive difference between the Part 50 and Part 52 facility licensing processes is that Part 50 does not include ITAAC. The post-TMI requirement of § 50.34(f)(2)(iii), however, does require "…a control room design that reflects state-of-the-art human factor principles..." The expectation of the Commission is that applicants will comply with those post-TMI requirements that are technologically relevant to the design in question, and thus commercial power reactor applicants are expected to incorporate state-of-the-art HFE processes into their control room designs. The current NRC guidance that covers such HFE design processes is NUREG-0711, "Human Factors Engineering Program Review Model," Revision 3, which includes the identification and resolution of HEDs as a component of verification and validation. Thus, while Part 50 lacks the ITAAC mechanism of Part 52, satisfactory HFE design processes will necessarily include HED identification, tracking, analysis, and resolution mechanisms.
Both simulator performance discrepancies and HEDs entail mechanisms that serve to drive the resolution of simulator-related issues prior to a facility commencing operations under Part 50. Simulator performance discrepancies may affect the ability a plant referenced simulator to both be declared and satisfactorily inspected. While representing a distinct pathway towards establishing a simulation facility, similar performance testing related considerations would also be expected to exist within the context of a Commission-approved simulator as well. Because of this, such identified issues must be resolved to the extent necessary to support the completion of these activities.
HEDs are systematically assessed to determine if improvements should be made to the HFE design, provided that such changes are feasible and that modification to the HFE design is the most appropriate approach to addressing the discrepancy. Importantly though, the implementation of an adequate HED process will be needed to support the adequacy of an applicant's overall HFE program.
5. Are specific qualifications, such as an "operator certification" required to perform simulator validation activities for establishing a plant referenced simulator?
In general, simulator validation activities are conducted by either operators who are licensed on the reference plant or by instructors who are certified, such as by the vendor, on the reference plant. While the NRC regulates training programs, the agency does not confer certifications. While the needed sequencing of activities during facility licensing precludes licensed operators from being available prior to the establishment of either a plant referenced or commission-approved simulator, it is still feasible to train staff to a degree adequate for "vendor-provided operator certification" on a design. Therefore, although a specific qualification is not required, validators should be adequately trained such that they are able to implement validation activities to ensure that the validators possess the knowledge, skills, and abilities needed to implement procedures, operate the human-system interfaces, and identify both simulator performance and HFE design issues.
6. What are the planned updates to operator licensing-related regulations associated with the Parts 50 & 52 Lessons Learned rulemaking?
When this document was issued, the NRC staff was continuing the Part 50 & 52 alignment (aka "Lessons Learned") rulemaking, with the proposed rule before the Commission (SECY-22-0052 for approval. If approved for publication in the Federal Register as a proposed rule, a formal public comment period precedes finalization during this type of rulemaking. The proposed rule would in part:
- clarify the definition of "plant referenced simulator" to apply to reactors under construction,
- allow a plant-referenced simulator to be declared before the completion of plant construction at a new build,
- amend Part 55 to permit alternatives to the plant walkthrough portion of the operating test during construction, and
- permit waivers of examination requirements for multiple unit sites of the same design.
7. What considerations led to the use of a Commission-Approved Simulator (CAS) during the licensing of Vogtle 3 & 4?
The Combined Operating License (COL) application for Vogtle 3 & 4 was made under Part 52 and included the use of Design Acceptance Criteria (DAC) under which a completed control room design was not required for the COL to be issued. As such, the control room design had not yet been completed when Southern Nuclear Company (SNC) requested that the Commission approve the Vogtle 3 & 4 simulation facility based on what was, at the time, an unfinalized control room configuration. SNC requested approval to use a Commission-approved simulation facility for conducting operator licensing examinations until such time as the simulator was accepted as a plant-referenced simulator.
At that point in time, the simulation facility for Vogtle 3 & 4 did not yet meet the NRC's requirements for plant-referenced simulators because the design activities required by the AP1000 design certification to establish the human factors engineering (HFE) design for the main control room were in progress but had not yet been completed. Please refer to the NRC's Safety Evaluation for Vogtle 3&4 CAS for further insights.
It is important to recognize that the need for a CAS is driven by a combination of factors that a facility license applicant has a measure of control over. These factors include whether:
- the application used Part 50 or Part 52
- the application used DAC in the control room design
- the control room design is complete prior to when a plant-referenced simulator is needed to support licensing operators
It is also important to distinguish between simulators used for human factors engineering testing, simulators used for operator training and licensing, and the various requirements for both. Importantly, the simulator used for operator licensing exams should be derived from the control room design that results from human factors engineering testing and issue resolution.
8. Is there guidance on simulator use for multi-unit facilities as it relates to supporting both control room staffing analyses and operator initial licensing?
NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)" (issued July 2005), is based on a methodology capable of addressing staffing analyses, including validation activities, within the context of multi-unit SMR control rooms. In a supplemental manner, HFE related considerations for multi-unit operations are also contained under NUREG/CR-7202, "NRC Reviewer Aid for Evaluating the Human-Performance Aspects Related to the Design and Operation of Small Modular Reactors" (issued June 2015), and under NUREG/CR-7126, "Human-Performance Issues Related to the Design and Operation of Small Modular Reactors" (issued June 2012). NUREG-0800 chapter 18, Revision 3, Attachment B, "Methodology to Assess the Workload of Challenging Operational Conditions in Support of Minimum Staffing Level Reviews," provides additional guidance that includes considerations relevant to multi-unit SMRs. Although the above guidance is used by the staff to evaluate facility submittals, it may provide useful insights to the facility during design and development. From a simulator adequacy standpoint, RG-1.149 provides guidance on an acceptable means of meeting § 55.46 though application of the ANSI/ANS-3.5 standard. NUREG-0711 chapter 11 also references this standard in its consideration of the suitability of validation testbeds.
While there are some significant differences between the design certification and construction permit processes, the following application and evaluation examples may provide relevant insights:
9. What are the expectations for a KA catalog for use in initial operator licensing examination for new reactors that do not fall under an existing, NRC-approved KA catalog (such as NUREG-1122), especially as relates to multi-unit operations?
From an operator licensing standpoint, a knowledge and abilities list is a fundamental component of the program. This list evolves out of the broader task analysis that will need to be conducted as part of both the HFE design process and licensed operator training program development. In conducting this task analysis (refer to NUREG-0711), tasks such as normal, abnormal, and emergency operations, including those tasks specific to multi-unit operations, will need to be identified and should subsequently inform the content of the developed knowledge and abilities list. The operator licensing examination process bases its composition upon a representative sampling of this knowledge and abilities list, thereby linking the exam content back to design-specific tasks. It must be emphasized that a rigorous and high-quality task analysis is essential to making this process work effectively. The process for determining this list would be reviewed and approved by the NRC, as well as sampling of specific KA items to ensure they meet requirements. A specific KA catalog, in the format of a NUREG, such as NUREG-1122, would not be required provided the necessary information is provided in a readable format (for example, a printout from a program that contains all the KAs in an electronic form).
Development of this list should include the use of subject matter experts, including those with prior work experience at an operating nuclear reactor, to determine the scope of systems/procedures to be included as well as rating the importance of topical items/statements with respect to safe operation of the facility. The scoping criteria should not limit systems/procedures to those related to protecting the reactor core/containment. The scoping criteria should allow for inclusion of any systems/procedures important to overall safe plant operation. The description should also include a requirement to link statements to the applicable § 55.41, "Written Examination: Operators," § 55.43, "Written Examination: Senior Operators," or § 55.45, "Operating Tests," to establish the regulatory basis for examination content validity.
10. From a Part 50 facility licensing perspective, what are the expectations from the NRC regarding Construction Permit (CP) contents of application as it relates to supporting a subsequent exemption request from 10 CFR 50.54(m) staffing requirements?
In short, nothing specific is required in this area at the CP stage and, from a practical standpoint, the state of design development at time of CP submittal might not support completing the performance-based testing of NUREG-1791. Broadly speaking, a § 50.54 exemption request may only be submitted after an Operating License (OL) is issued to the facility licensee. This exemption request must have its supporting information provided in a docketed form.
11. How would a Part 50 facility licensee request an exemption from 10 CFR 50.54(m) staffing requirements after the OL is issued?
There are options for how to do this. One approach would be to for the facility licensee to embed the information needed to support the exemption within the OL application itself and reference this information in the exemption request. The material would be evaluated by the staff in conjunction with the OL application review. Another approach would be to submit the exemption justification in the form of a topical report separately from the OL application; this would allow the staff to evaluate that material outside of the OL application review itself. A staff-evaluated topical report could then be incorporated by reference into the subsequent exemption request.
Please keep in mind that § 50.34(a)(6) requires preliminary safety analysis reports (PSARs) to contain a "preliminary plan for the applicant's organization, training of personnel, and conduct of operations." Guidance regarding aspects of such content can be found in both NUREG-0800 chapter 13 and RG-1.170.
12. For an exemption request to the 10 CFR 50.54(m), minimum staffing requirements (refer to NUREG-1791), are references to Result Summary Reports (such as those described by NUREG-0711) sufficient justification or does the exemption request need to contain those portions of each report needed to support the exemption?
The key point is that the exemption request will need to contain (or reference) sufficient docketed material for the staff to be able to make a finding on whether it can be granted. Result Summary Reports (RSRs) are typically non-docketed material that the staff audits to support their findings. However, the exemption request process will require some subset of the RSRs' contents (but not necessarily the RSRs in their entirety) to be docketed in order to support the request. Therefore, the exemption request needs to contain enough information from the RSRs such that the docketed body of information will support a finding.
When the NRC staff make a finding under a licensing action, that finding needs to be based upon docketed information. Beyond that, the staff do also audit non-docketed material of a confirmatory nature and use those audit observations to provide added support to their findings. However, these audits cannot be used in isolation for an exemption request. Broadly speaking, the staffing-related exemption request evaluation process reflects this general approach.
More specifically, Implementation Plans (IPs) described under NUREG-0711 would be expected to be included as part of the OL application and be docketed (although they could potentially be submitted earlier if desired by the applicant, such as via a topical report). Subsequently, RSRs described under NUREG-0711 need to be submitted prior to the completion of the staff's evaluation of the OL application.
13. Administration of the first operator licensing examinations prior to fuel load at a new facility.
Both descriptions of and timelines for establishing the testable content for initial operator licensing examinations should be developed. This may include development of a knowledge and abilities catalog, or similar mechanism to identify the items that will be tested on initial licensing examinations and to determine the importance ratings and basis for these items. This is discussed further in the answer to Question 9. The testable content for initial operator licensing examinations based on this catalog/list will need to be developed prior to administering initial operator licensing examinations. In general, there should be a description of how the Systems Approach to Training (SAT) was used for determining the job tasks to assist in developing the testable content, including the examination methods.
A request for exemption from the use of the criteria in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," per § 55.40(a) should be accompanied by a description of the examination methods, such as multiple-choice written questions, job performance measures, or scenarios, as well as the structure, such as the number of written questions. A passing score for the applicable sections of the examination should be proposed. Also, the basis for how the chosen examination methods, structure, and passing score(s) support examination validity, reliability, and fairness should be provided. In general, the requirements in § 55.41, 55.43, and 55.45 will apply unless an exemption from these requirements is also requested and granted.
Special considerations may be needed in the case of procedures that are considered draft but are approved for use to support examinations. In general, procedures used to support examination material should receive: (1) an administrative review to verify that the procedure meets the facility licensee's writer's guide requirements and satisfies all technical specifications and final safety analysis report requirements, and (2) a technical review to verify the procedure is correct for proper operations of plant systems and equipment. Procedures provided to the NRC for each initial operator licensing examination should be approved by the facility management.
A description of the simulation facility to be used to administer initial operator licensing examinations should be provided. The simulation facility will need to meet the requirements of § 55.46(c) or be approved by the Commission under § 55.46(b) prior to administering any operator licensing examinations.
Timelines for the initial operator licensing examinations needed prior to fuel load should be provided, as well as the anticipated number of individual license operator applicants, in order to determine the NRC staff resources that will be required to meet those needs.
14. Implementation of training programs at new facilities.
Applicants should make available a description and schedule for establishing the initial training programs for reactor operators and senior reactor operators that meet the requirements in Part 55 with milestones for implementation during construction. Applicants should describe how the requirements for a SAT-based training program are met. This should also include the details of individuals' qualifications for entry into the program, details on courses of instruction to be administered by the facility, the nature of training to be provided by the facility, and startup and shutdown experience provided. In lieu of these details, the application may state that the applicant will seek accreditation from the National Academy of Nuclear Training (NANT). If accreditation is selected but it is not achieved prior to the administration of the first initial operator licensing examination, then the NRC staff will need to complete an inspection of the applicant's training program prior to the first examination. As an option to addressing the licensed operator training criterion, the applicant may provide a commitment to meet the guidelines of Nuclear Energy Institute (NEI) 06-13A, "Template for an Industry Training Program Description," Revision 2, for its licensed operator training program.
A description should also be provided for the licensed operator requalification program required in §§ 50.54(i-1) and 55.59, "Requalification," including the first anticipated requalification period per § 55.59(a)(1). If there is a significant time lag between the examination and license issuance, due to reasons such as needing to complete cold licensing experience requirements related to preoperational testing, applicants should consider how operator license applicants will maintain knowledge, skills, and abilities following successful completion of the initial operator licensing examination.
15. Simulation facilities during construction of a new facility.
Applicants should address the use of a simulator, including whether a plant referenced simulator or Commission-approved simulator will be used for operator licensing examinations. If a plant referenced simulator will be used, applicants would need to inform the NRC when they determine the simulation facility meets the requirements to be a plant-referenced simulator. This notification should occur well in advance of the first scheduled operator licensing examination.
For Commission-approved simulators, applicants should describe the items listed in § 55.46(b), including a description of the components of the simulation facility intended to be used, a description of the performance tests for the simulation facility as part of the request and the results of these tests, and a description of the procedures for maintaining examination and test integrity per § 55.49, "Integrity of examinations and tests." Additionally, the description should provide the following information: how the simulator allows for performance of actions necessary to accomplish a representative sample of the 13 items listed in § 55.45(a), that the simulator response will model that of the reference plant during operating tests, that the simulator can perform a sufficient number of operating tests such that the examination is not predictable, and that any open simulator discrepancies will not negatively affect the examination. If these items are not yet available, the description should include a proposed timeline for when the items will be available for review by the Commission.
16. Issuance of operator licenses prior to fuel load at a new facility.
Applicants or facility licensees must ensure that operator licenses will be maintained active per the requirements of § 55.53(e) prior to initial fuel load. This may include operators on shift performing the functions of a reactor operator or senior reactor operator by performing meaningful duties analogous to the minimum licensed positions under technical specifications. This may include operating the controls and apparatus during preoperational testing that, once fuel is loaded and plant startup occurs, will directly affect reactivity or power level.
17. Non-licensed personnel training at new facilities.
The training program for non-licensed nuclear plant personnel will need to meet the requirements of § 50.120(b)(2) and (b)(3) and be derived from a systems approach to training as defined in 10 CFR Part 55, "Operators' Licenses."
A description should be provided of the program to be used for the periodic evaluation of the non-licensed plant staff training programs by individuals other than those directly responsible for the training. Such evaluations should include an assessment of program effectiveness in developing the trainees' ability to meet performance requirements of the job. The program should be periodically revised and updated, to reflect the result of program evaluations, industry experience, and changes to the facility, procedures, regulations, and quality requirements.
Also, a description should be included for the initial training, periodic retraining, and qualification that are required for non-licensed plant staff. An applicant may also provide a commitment to meet the guidelines of NEI 06-13A, "Template for an Industry Training Program Description," for its non-licensed plant staff training program.
18. Control room staffing and associated exemption requests for new facilities.
The requirements in § 50.54(k) and 50.54(m) identify the minimum number of licensed operators who must be on site, in the control room, and at the controls. The requirements are conditions in every nuclear power reactor operating license issued under 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." The requirements are also conditions in every COL issued under 10 CFR Part 52; they are only applicable, however, after the Commission makes the finding under § 52.103(g) that the acceptance criteria in the COL are met.
In general, applications should describe the functions, responsibilities, and authorities of the following plant positions:
- operations supervisors,
- operating shift supervisors/managers,
- shift technical advisors,
- reactor operators and senior operators,
- non-licensed operators.
For each position listed above, a description should be provided of:
- the interfaces with offsite personnel or key management positions. Such interfaces include defined lines of reporting responsibilities (e.g., from the plant manager to the immediate superior), lines of authority, communication channels, and roles in risk-informed evaluations and decision making.
- the authority that may be granted to operations supervisors; to operating crew shift supervisors/managers, including the authority to issue standing or special orders; and to reactor operators and senior operators.
- additional areas, including shift position titles and their applicable operator licensing requirements and minimum numbers of personnel planned for each shift for all combinations of modules/units proposed to be at the station in either operating or safe shutdown mode.
- shift crew staffing plans unique to refueling operations and the proposed means of assigning shift responsibility for implementing the radiation protection and fire protection programs.
If the facility is planned to contain power generating facilities other than those specified in the application (e.g., fossil-fueled units), a description should be provided of:
- interfaces with the organizations operating the other facilities
- any proposed sharing of personnel between the units
- duties of any shared personnel
- proportion of the time any shared personnel will be assigned to the non-nuclear units.
To provide regulatory certainty on the issue of licensed operator staffing, a Construction Permit (CP), Design Certification (DC), or Standard Design Approval (SDA) application should address licensed operator staffing. It should be noted that the staffing requirements in § 50.54(k) and (m) do not apply to applicants for a CP, DC, or SDA. However, the staff expects that these applicants have considered the minimum licensed operator staffing needed at the facility because, as a practical matter, staffing is a necessary consideration when designing and constructing a facility. Additionally, when the proposed licensed operator staffing for the facility will not meet the requirements in § 50.54(k) and (m), and in the absence of alternative requirements (discussed in the next paragraph), future licensees of these facilities will need to request an exemption from these staffing requirements.
A DC applicant could propose for certification as part of the DC rulemaking an alternative control room staffing level requirement that a facility licensee could satisfy in lieu of § 50.54(m). The DC applicant can provide the technical basis for rulemaking language that would address control room staffing in conjunction with control room configuration as part of the DCA. A future licensee that follows the certified facility-specific staffing requirements will not need an exemption from § 50.54(m) because the DC rule will address the applicability of the regulation. Paragraph V, "Applicable Regulations," of the DC rule in the applicable Part 52 appendix will include the alternative staffing requirement rule language, including the requirement provisions, staffing table, and appropriate table notes. If a DC applicant chooses this approach, then it should include the requirement provisions, staffing table, and appropriate table notes with the DCA.
Another option is that a DC, SDA, and CP applicant may provide the technical basis for a future exemption from § 50.54(m) and/or 50.54(k) in the application. Under this approach, the DC, SDA, or CP applicant would not request an exemption from §50.54(m) and/or 50.54(k) in its application but would include the technical basis a future COL or OL applicant would need to request an exemption. A COL or OL applicant would use the technical basis documented in the DC, SDA, or CP application as the justification for the exemption.
NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)" (issued July 2005), provides guidance for developing the technical basis to support alternatives to the minimum staffing requirements.
Simulator performance discrepancy – Simulator performance discrepancies impact their functionality and occur when a simulator does not accurately replicate the expected or actual performance and/or configuration of the reference plant. This can occur when a component or indication not operating as it would in the reference plant, incorrect labeling of control room indications, an automatic calculation not working properly, the simulator incorrectly modeling core physics, or inconsistent indications (reference: NUREG-0711, Section 10.4.2)
Human engineering discrepancy – HEDs are identified during verification and validation activities (namely during the Integrated System Validation stage) and are interrelated with the adequacy of the HFE design. While HEDs may include certain simulator performance discrepancies (i.e., the two are neither synonymous nor mutually exclusive), HEDs serve instead to remedy issues in the control room design that might contribute to human error (reference: NUREG-0711, Section 11.4.4)
Vendor-provided operator certification – training given by the design vendor on system design, operation, and draft procedures such that the individuals can perform the draft procedures on the simulation device and identify performance or design issues. The NRC does not confer a "vendor certification"