ML25213A059
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| Issue date: | 08/04/2025 |
| From: | Hughes Green N, Stephanie Morrow Office of Nuclear Regulatory Research |
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Morrow, S., and Hughes Green, N. (2025). Translating human factors research to regulatory guidance in the nuclear industry. Proceedings of the 69th Human Factors and Ergonomics Society International Annual Meeting (Vol. 69, No. 1).
Sage CA: Los Angeles, CA: Sage Publications.
Translating Human Factors Research to Regulatory Guidance in the Nuclear Industry Stephanie Morrow 1, Niav Hughes Green 1 1U.S. Nuclear Regulatory Commission, Washington, DC The human factors staff of the United States Nuclear Regulatory Commission (NRC) reviews nuclear power plant control room designs and modifications to verify that they incorporate human factors principles to support safe and reliable performance. Applying a standardized approach to guidance development is critical to ensure the regulatory review process is transparent, consistent, and technically defensible. The fundamental steps involved in the NRCs human factors guidance development methodology include, (1) user needs analysis, (2) technical basis and guidance development, (3) peer review, and (4) guidance integration and publication. Yet there is also nuance in applying these steps depending on the topic, maturity of the state of knowledge, and applicability of past research to the nuclear industry. This paper expands on the 4-step process to highlight areas important to the translation of research into guidance, especially as the complexity and interactions among technical areas increase with more advanced concepts of operation.
INTRODUCTION Translation of research findings into use by practitioners and policymakers is a critical stage in the research lifecycle, effectively bridging the gap between research and practice. Yet, it is also often an overlooked part of the process. On one side, researchers may not realize how to best characterize their findings in a manner that is tailored to the potential audiences that would most benefit from use of the findings. On the other side, practitioners may not make the best use of research due to lack of awareness, challenges with integrating results across different studies, or difficulties interpreting results for practical decision-making.
In this paper we present a case study of how human factors research is translated into regulatory guidance in the nuclear industry. We focus on the process used to develop guidance and explore lessons learned from applying this standardized process to a variety of topics.
We also discuss the importance of following a standardized process for establishing transparent, consistent, and technically defensible guidance for making regulatory decisions about whether human factors principles are appropriately integrated into nuclear power plant design and operation in a manner that ensures public health and safety.
BACKGROUND The United States Nuclear Regulatory Commission (NRC) is responsible for regulating the civilian use of nuclear power to ensure public health, safety, and security. The role that humans play in the operation of a nuclear power plant is an important consideration for nuclear safety. Factors such as the design and layout of the control room, the audio and visual alarm systems, lighting, procedures, communication, and training can all impact human performance (NRC, 2025).
The NRC human factors staff reviews nuclear power plant control room designs and modifications to verify that they incorporate human factors principles to support safe and reliable performance. The NRCs human factors engineering (HFE) review guidance specifies the criteria that NRC reviewers use to enable structured, predictable, and risk-based reviews founded on sound human factors principles. The Standard Review Plan in NUREG-0800 provides a high-level framework for conducting HFE reviews (NRC, 2016). The HFE program review model in NUREG-0711 covers the HFE design process, verification and validation of the final design, its implementation, and ongoing performance monitoring across operational contexts (OHara et al., 2012). The detailed design review guidelines in NUREG-0700 cover interfaces between plant personnel and the plants systems and components, user interface interactions, alarms, displays, computer-based procedures, automation, communications, workstations, and HSI support systems (OHara & Fleger, 2020). Recently, the NRC developed a more flexible approach for conducting HFE reviews for simpler, lower-risk designs proposed by advanced reactor developers. The approach uses a scaled process to develop a facility-specific review plan that focuses on aspects of the facilitys design and operational characteristics that include a human role in safety (NRC, 2023). These reviews collectively support regulatory decisions to license nuclear power plants.
APPROACH Applied human factors researchers at the NRC are responsible for translating human factors research into review guidance. The NRCs human factors guidance and evaluation tools are regularly reviewed and updated to reflect the state-of-the-art in human factors research and application. Updates may be needed to incorporate new research findings, advances in HFE methods and tools, or new technologies and concepts of operations being employed in plant and control room design. As nuclear reactor technologies, and the ways in which humans interact with those technologies, evolve there is a greater need to translate research into review guidance to ensure safe and reliable performance.
The NRCs approach to developing and maintaining human factors review guidance includes a multi-step process that focuses on establishing internal and external validity. In this context, internal validity refers to the degree to which the individual guidelines are linked to a clear, well-founded, and traceable technical basis.
External validity refers to the degree to which the guidance is supported by independent peer review (OHara & Fleger, 2020).
What constitutes a technical basis can vary depending on the topic and the state of knowledge about the topic. A technical basis may be formed from existing standards or guidelines, an analysis of empirical literature, use of expert judgment, or some combination of these approaches. Generally, existing HFE standards and guidelines are prioritized because they tend to exhibit more internal and external validity. As they are based on consensus, they also tend to be more broadly applicable to different contexts, depending on the scope of the standard. In contrast, the validity as well as the generalizability of individual research studies may be highly dependent on correspondence between the studys design and the intended real-world application of the guidance. Use of industry experience to inform guidance development can be useful for its direct applicability to nuclear operations but is less useful when experience is limited. The rapid evolution of technology can often outpace the development of consensus standards and other synthesized research products (e.g., meta-analyses). As such, we must often use a combination of technical sources to develop appropriate and timely guidelines that support ensuring safety without unnecessarily stifling progress.
Advances in nuclear reactor technologies and increasing use of digital technologies, including automation, continue to evolve the role of humans in nuclear power operations. This has served to increase the complexity of how human performance may be addressed in new designs. There can be myriad ways in which design features interact to affect human performance and ultimately the safety of the plant. For instance, while characterizing the human factors for remote operations, an interplay between remote operation, use of autonomy, and control of multiple units was identified (Hughes Green, Morrow, Mortenson, Mohon, & Kovesdi, in press). The implementation of different levels and combinations of these features may lead to unique implications for human performance. The guidance that is developed and used to evaluate the safety of these features must be sufficiently robust to provide reasonable assurance of safety, while still flexible enough to address a variety of design configurations.
The NRCs Human Factors Guidance Development Methodology The fundamental steps involved in the NRCs human factors guidance development methodology (OHara &
Higgins, 2010) include, (1) user needs analysis, (2) technical basis and guidance development, (3) peer review, and (4) guidance integration and publication.
This basic methodology has been well-documented and discussed within the human factors technical community (OHara & Fleger, 2020; OHara, Higgins, & Fleger, 2010).
Based on lessons learned through repeated application of this process, we have found that there is nuance in applying this basic framework to different topics, particularly with regard to the technical basis and guidance development in step 2 of the methodology.
Variations in how to approach the technical basis and guidance development may depend on the maturity of the state of knowledge about the topic, level of consensus among experts, and relevance of existing information to applications in the nuclear industry. As a result, we have sought to expand on the methodology by explicitly outlining a series of sub-steps that are critical to the formation of a robust, technically defensible basis for guidance. This expanded methodology is presented in Figure 1.
Figure 1 NRC's Expanded HFE Guidance Development Methodology Step 1: user needs analysis. The first step in the process involves identifying a need for guidance. This involves obtaining feedback from users of the guidance (e.g., NRC reviewers, vendors and utilities, other regulatory agencies) to identify technology trends in new nuclear reactor designs and anticipated changes in human-system interactions or human performance.
Potential needs are then prioritized by users and other subject matter experts to identify the topics to be addressed based on the anticipated need for guidance.
Step 2: technical basis and guidance development.
The second step is where research is translated into guidance. A critical sub-step at this juncture is step 2.1, characterize the topic for which guidance is needed.
This sub-step involves defining the topic, its relevant characteristics and functions, and how it relates to human performance in nuclear operations. The purpose of the topic characterization sub-step is to establish a scope and framework for developing and organizing the guidance. The topic characterization can also serve as a roadmap to aid HFE reviewers in asking questions about a particular HFE activity or system design.
After characterizing the topic, step 2.2 is to assess the need for new guidance by reviewing existing guidelines to assess their suitability in addressing the unique characteristics and human performance considerations for the topic of interest. This may include reviews to determine whether the guidelines are sufficient to address the new features or technologies being introduced in the control room design or concept of operations. Areas where there are gaps in guidance are then targeted for technical basis development. Step 2.2 is particularly important when novel technologies or concepts of operation are being proposed. The apparent novelty of a concept may suggest the need for an overhaul of existing guidance, yet on closer examination the existing guidance may provide an adequate framework for evaluating the new concept without significant alteration. For example, when reviewing the suitability of HFE guidance for remote operations, where a control room would be located off-site and geographically distant from the nuclear reactor, we found that the majority of the existing review criteria would apply as-written (Hughes Green et al., in press).
Although remote operation is a very novel concept for the nuclear industry, the application of HFE principles and HSI design criteria would not be significantly different for a remotely situated control room. Instead, our guidance development activities have focused on
highlighting unique considerations of remote operations to supplement existing guidance and aid reviewers in asking appropriate questions when a plant design includes remote operation.
At step 2.3, we review sources to establish a technical basis by gathering information from existing standards and guidelines, HFE handbooks and texts, and basic research literature. The technical basis development can be a particularly challenging activity as research findings must be interpreted in the context of real-world tasks and systems based on professional and operational experience. Generally, we consider existing HFE standards and guidelines first in this process because they often represent a peer-reviewed synthesis of research, operational experience, and subject matter expertise. The information in standards is also easily translated into a format suitable for NRC review guidelines or acceptance criteria. HFE handbooks and textbooks can also provide a valuable source of synthesized information on a topic. When those sources are not sufficient to cover all aspects of the topic of interest, then we look at the basic research literature to inform technical basis development. There is often a greater need to rely on basic research literature for new and emerging topics of interest. However, greater effort must be taken to integrate and generalize findings from basic research and then translate that information into suitable guidelines or review criteria. If there is a lack of research on a particular topic, we may also gather industry experience based on interviews, case studies, walk-through exercises, or expert knowledge elicitation techniques.
When needed, the NRC may also commission original research to inform guidance development. For example, the NRCs human performance test facility (HPTF), an experimental research simulator targeted at understanding operator performance in a nuclear control room environment, was developed to address a need for nuclear specific human performance data to support regulatory decision-making (Hughes et al., 2022). The NRCs HPTF examines topics related to the introduction of new technologies in the control room and how new technologies affect operator workload and performance.
One study found divergence between workload and performance when comparing different user interface input modes (i.e., keyboard and mouse versus touchscreen). Subjective measures of workload suggested that participants found the touchscreen easier to use. On the other hand, participants were more successful at completing the navigation tasks when using the desktop mouse input than when using the touchscreen. Planned and ongoing control room modernization activities in operating nuclear plants are incorporating a mixture of traditional and touch-based input devices, and each of those design changes must be reviewed by the NRC staff. The research finding of differences between preference and performance for different interface types provides an important data point for the NRC staff when reviewing the human performance implications of digital technology upgrades (Hughes et al., 2022).
In step 2.4 we identify unresolved issues. This sub-step serves to acknowledge that while guidance is developed based on the best available information at the time, there may be areas where guidance is more conservative because information is limited. It may include areas where there is not sufficient technical basis to form new guidance, where more research is needed, or where more information might allow for better refinement of guidance over time.
Step 2.5 is to develop draft guidance based on the available technical basis information. This sub-step involves translating the technical basis into appropriate guidance for NRC reviewers and assembling it into a standard format. The results of the technical basis and guidance development step are then documented in one or more reports.
Step 3: peer review. Once the draft guidance is developed, the staff solicits peer review by subject matter experts in human factors and the nuclear industry to evaluate its scope, comprehensiveness, technical content, and usability. The peer review process is an important opportunity for the NRC to involve experts from the broader human factors research community as well as human factors practitioners in the nuclear industry whose products might be reviewed by the NRC as part of a licensing application.
Step 4: guidance integration and publication. After comments and recommendations from the peer review are resolved, the guidance is finalized and integrated into appropriate documents for use by NRC reviewers. For example, guidelines related to human-system interfaces may be incorporated into NUREG-0700, whereas review criteria for one or more aspects of an applicants HFE program may be incorporated into NUREG-0711.
CONCLUSIONS The NRC is increasing efforts to develop guidance that address new designs and concepts of operations that pose vastly different approaches to nuclear operations.
Some of the areas that the NRC human factors staff has identified for future guidance development include remote and autonomous operations, multiunit operation, modern methodologies for function allocation, use of artificial intelligence to support plant operations, and human-automation teaming in highly automated environments.
The NRC staff is using the methodology described in this paper to characterize these topics and gather information. From a regulatory guidance perspective, the sources of information that are most useful include consensus standards, handbooks or texts that synthesize research literature, meta-analyses, and empirical research specific to the nuclear industry or industries that are relevant surrogates for nuclear. The NRC human factors staff would welcome information exchanges with researchers to support the guidance development process or assist with peer reviews of guidance in these areas.
Sharing case studies and lessons learned from translating research into guidance can help researchers and practitioners communicate and coordinate their efforts to enable more efficient and effective use of research findings. The guidance development process employed by the NRC human factors staff ensures that HFE review guidance is both practically applicable and based on sound technical grounds. This is particularly important in high-stakes and safety-critical industries. It also establishes a generalizable process that can be applied to any aspect of a human factors engineering program or human-system integration technology.
Applying a standardized approach to guidance development is critical for establishing a regulatory review process that is transparent, consistent, and technically defensible.
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