ML25064A588
| ML25064A588 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/2025 |
| From: | Gregory Stock NRC/NRR/DRO/IRAB |
| To: | |
| Shared Package | |
| ML25064A585 | List: |
| References | |
| Download: ML25064A588 (1) | |
Text
Calendar Year 2024 Reactor Oversight Process Self-Assessment Metric Overview and Report
I-1 I-2 I-3 I-4 I-5 Completion of the Baseline Inspection Program Resident Inspector Objectivity Through Diverse Experience Inspector Objectivity and Performance Reviews Fully Qualified Inspectors, Examiners, and Senior Reactor Analysts Continuity of RI/SRI Site Staffing Green Green Green Green Yellow O-1 O-2 O-3 O-4 Issuance of Inspection Reports Issuance of Assessment Letters Conduct of Annual Assessment Meetings or Other Engagement Activities Issuance of ROP Public Meeting Notices and Summaries Green Green Green Green E-1 E-2 E-3 C-1 C-2 Completion of Supplemental Inspections Completion of Temporary Instructions SDP Completion Timeliness for Potentially Greater-than-Green Findings Maintenance of ROP Web Pages Maintenance of ROP Governance Documents Green Green Green Green Green R-1 R-2 R-3 Predictability and Repeatability of Significance Determination Results Predictability of Agency Actions and Response Supportability of Inspection Findings Green Green Green CY 2024 ROP Self-Assessment Metrics Overview Openness Metrics Efficiency and Clarity Metrics Reliability Metrics Independence Metrics CALENDAR YEAR 2024 ROP SELF-ASSESSMENT METRICS REPORT REFERENCED TO INSPECTION MANUAL CHAPTER 0307, APPENDIX A This metrics report follows Inspection Manual Chapter (IMC) 0307, Appendix A (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23125A179) to report on the overall implementation of the Reactor Oversight Process (ROP) as measured by the following 17 ROP performance metrics for calendar year (CY) 2024. For more details on each individual metric, including the specific criteria for green, yellow, or red status, the basis, the ROP program area, the data sources, the related ROP goals, and the related ROP intended outcomes, refer to IMC 0307, Appendix A.
0307A-01 INDEPENDENCE PERFORMANCE METRICS (I)
I-1 Completion of Baseline Inspection Program Metric Status:
Green Definition:
The baseline inspection program is completed annually in accordance with program requirements.
Data and Analysis:
In CY 2024, all the regions and the Office of Nuclear Security and Incident Response (NSIR) completed the baseline inspection program. IMC 2515, Section 04.07 states that completion, is defined to be not more than four (4) inspection procedures not completed, per Region (but not more than one procedure not done per plant). In CY 2024, all inspection procedures were completed in accordance with IMC 2515 and its appendices at all operating reactor sites. Each region and NSIR documented in detail their implementation of the baseline inspection program for CY 2024 via memorandum (ML25043A278 for Region I, ML23045A087 for Region II, ML25044A016 for Region III, ML25031A015 for Region IV, and ML25035A094 for NSIR).
The following discussion highlights some items of interest related to baseline inspection completion, but nothing that follows deviates from the overall conclusion that the baseline inspection program was completed in CY 2024.
On July 28, 2023, Vogtle Electric Generating Plant (Vogtle) Unit 4 transitioned from the Construction ROP (cROP) to the ROP. Therefore, CY 2024 was the first full year both Vogtle Units 3 and 4 were under the ROP.
The memorandum Transition to Reactor Oversight Process for Vogtle Electric Generating Plant, Units 3 & 4, dated August 12, 2020 (ML20191A383) describes the overall staff approach for completing the baseline inspection program for both Vogtle Units 3 and 4 for the first operating cycles and incorporates Table 2, Vogtle Unit 3 and Vogtle Units 3
& 4 Resident Inspector Inspection Samples and Hours, (ML20191A398) which delineates both the approved ROP inspection sample ranges for Vogtle Units 3 and 4.
In CY 2024, the staff completed 18 baseline Force-On-Force (FOF) inspections using IP 71130.03 (ML21012A329, nonpublic).
Since the baseline inspection program was completed for all regions, this metric is green, and no region or office has met the individual threshold for evaluation for this metric.
I-2 Resident Inspector Objectivity through Diverse Experience Metric Status:
Green Definition:
Permanently-staffed Senior Resident Inspectors (SRIs) and Resident Inspectors (RIs) spend a minimum of one week each year inspecting at another site.
Data and Analysis:
In CY 2024, 1 of the 116 SRI and RI positions in the agency were not able to complete their required objectivity visits by spending a minimum of one week inspecting at another plant in accordance with IMC 0102.
Since the agency had three or fewer non-compliances, and no region or office had more than two non-compliances, this metric is green, and no region or office will be individually evaluated.
I-3 Inspector Objectivity and Performance Reviews Metric Status:
Green Definition:
Line managers perform annual onsite objectivity and performance reviews of each fully qualified inspector and operator licensing examiner assigned to primarily perform onsite activities at an operating reactor site.
Data and Analysis:
In CY 2024, 1 of 292 qualified inspectors did not have an annual objectivity review.
Since the agency had three or fewer non-compliances, and no region or office had more than two non-compliances, this metric is green, and no region or office will be individually evaluated.
I-4 Fully Qualified Inspectors, Examiners, and Senior Reactor Analysts Metric Status:
Green Definition:
Inspectors, operator licensing examiners, and senior reactor analysts (SRAs) remain fully qualified in accordance with qualification requirements.
Training beyond the 3-year cycle is considered noncompliant regardless of the status of a deviation memo.
Data and Analysis:
In CY 2024, 1 of 319 inspectors, operator licensing examiners, and SRAs were required to have taken either post-qualification or refresher training in accordance with IMC 1245 and its appendices but did not do so.
Since the agency had three or fewer non-compliances, and no region or office had more than two non-compliances, this metric is green, and no region or office will be individually evaluated.
I-5 Continuity of RI/SRI Site Staffing Metric Status:
Yellow Definition:
Permanent inspector staffing levels for both SRIs and RIs are maintained to provide continuity of regulatory oversight at each reactor site.
Data and Analysis:
In CY 2024, the overall permanent resident inspector staffing percentage for the agency was 92.8%. The permanent resident inspector staffing percentages for each region were 96.4%, 95.2%, 95.9%, 82.7% for Region I, Region II, Region III, and Region IV, respectively. In CY 2024, there were nine individual reactor sites which fell below the 90% metric threshold, six of which are in Region IV, and the responsible regions provided a detailed explanation of the specific staffing circumstances at each site.
Since the resident inspector staffing percentage is less than 95%, but greater than or equal to 90% for the agency overall, and the resident inspector staffing percentage is less than 90% for Region IV, this metric is yellow, and Region IV will be individually evaluated. That evaluation is below.
In Region IV, the challenges with this metric in CY 2024 were primarily due to a significant number of vacancies in either the resident or senior resident positions, where several months were needed to permanently fill those vacancies with new staff. In some cases, site coverage was provided by short-term acting residents, for less than six weeks at a time, which does not count for this metric. In three of the six cases, the resident inspector was either promoted to the permanent senior resident position or acted as the senior resident inspector and a backfill was not provided for the resident inspector position. In other cases, backfills were not provided for the resident inspector position, until it was permanently filled. Region IV prioritized permanently filling these resident and senior resident vacancies in 2024 and has also been able to hire more staff into their resident inspector development program. Region IV does not anticipate significant challenges to meeting this metric in CY 2025.
Resident staffing, both recruitment and retention, continues to be a key area of agency focus. This metric first became yellow in CY 2022 which resulted in staff developing actions to arrest the trend. In CY 2024, an annual resident inspector retention incentive was implemented and the first payments will be made in CY 2025. One of the primary goals of this initiative is to reduce resident inspector turnover. While the metric remains yellow, the trend is improving. Additionally in CY 2025, a resident competency-based qualification process, which was piloted in CY 2023, will go into effect which aims to reduce the qualification time required for new staff with previous applicable experience. Further in accordance with SRM-M240711 (ML24214A296) and IMC 0307 Appendix D (ML24352A244), the staff will submit high level summaries of resident inspector staffing in July 2025.
0307A-02 OPENNESS PERFORMANCE METRICS (O)
O-1 Issuance of Inspection Reports Metric Status:
Green Definition:
ROP inspection reports are issued within applicable timeliness goals.
Data and Analysis:
In CY 2024, the agency issued 518 ROP inspection reports. Five of those inspection reports were not issued in accordance with the timeliness requirements of IMC 0611. No single region or NSIR had more than three late inspection reports. Since the agency had fewer than 11 late inspection reports, and no region or office had more than five late inspection reports, this metric is green, and no region or office will be individually evaluated.
O-2 Issuance of Assessment Letters Metric Status:
Green Definition:
Annual and follow-up assessment letters are issued within the applicable timeliness goals.
Data and Analysis:
In CY 2024, the agency issued 55 annual assessment letters and 13 follow-up assessment letters. These letters are listed on the NRCs public website of Assessment Letters. All of these assessment letters were issued on time, in accordance with IMC 0305 requirements. Since the agency had fewer than three late assessment letters, and no region or office had more than one late assessment letter, this metric is green, and no region or office will be individually evaluated.
O-3 Conduct of Annual Assessment Meetings or Other Engagement Activities Metric Status:
Green Definition:
Public assessment meetings or other engagement activities that discuss the results of the NRCs annual assessment of the licensees performance, are conducted annually for all sites.
Data and Analysis:
In CY 2024, the agency held public assessment meetings or other engagement activities for 54 reactor sites, in accordance with IMC 0305.
Some of these assessment meetings or activities were held virtually by NRC staff to interact with public stakeholders, and in some regions the public engagement activities for the majority of sites were held as a single combined meeting. Since all operating reactor sites had appropriate public engagement in CY 2024, this metric is green.
O-4 Issuance of ROP Public Meeting Notices and Summaries Metric Status:
Green Definition:
ROP-related public meetings are noticed prior to the meeting and meeting summaries are posted after the meeting within the applicable timeliness requirements.
Data and Analysis:
In CY 2024, the Office of Nuclear Reactor Regulation (NRR), NSIR, and regional staff held 62 ROP-related public meetings, some of them held virtually or as hybrid meetings. The staff noticed and summarized these public meetings within the established timeliness goals (e.g., 10 calendar days prior to a public meeting for meeting notices) for all of the public meetings held, with the exception of two meeting notices. These late meeting notices were for meetings held by NSIR. In CY 2024, 96.8% of ROP-related public meeting notices and summaries were on-time.
Since the percentage of timely notices and summaries is greater than 95%,
and no region or office had more than two untimely notices or summaries, this metric is green, and no region or office will be individually evaluated.
0307A-03 EFFICIENCY PERFORMANCE METRICS (E)
E-1 Completion of Supplemental Inspections Metric Status:
Green Definition:
Exit meetings for supplemental inspections are completed within 180 days from licensee notification of readiness.
Data and Analysis:
In CY 2024, the agency completed eight supplemental inspections at Calvert Cliffs Nuclear Power Plant, Millstone Power Station, V.C. Summer Nuclear Station, Watts Bar Nuclear Plant, North Anna Power Station, River Bend Station, and Waterford 3 Steam Electric Station. The exit meetings for these supplemental inspections were completed within the timeliness goal of 180 days from the date of licensee readiness. Since no more than one exit meeting did not meet the timeliness goal for the agency and no more than one exit meeting did not meet the timeliness goal for any region or office, this metric is green, and no region or office will be individually evaluated.
E-2 Completion of Temporary Instructions Metric Status:
Green Definition:
Temporary Instruction (TI) inspections associated with IMC 2201 and IMC 2515 are completed within the required TI completion time.
Data and Analysis:
In CY 2024, there were no TIs in effect.
E-3 SDP Completion Timeliness for Potentially Greater-than-Green Findings Metric Status:
Green Definition:
The time from the identification date (i.e., the date the issue of concern was brought to the licensees attention by the NRC, the date the performance deficiency was self-revealed, or the date the licensee documented the condition resulting from the performance deficiency in the corrective action program) to the date a final significance determination is issued for all potentially greater-than-green findings is within 255 days.
Data and Analysis:
In 2024, the agency issued 14 final significance determinations for issues that were initially transmitted to the licensees as potentially greater-than-green (GTG). None of these 14 findings exceeded the 255-day timeliness goal between identification date and final issuance. Since no issues exceeded the timeliness goal, this metric is green.
DRO staff continue to engage with the regions on potentially GTG issues and independently track these issues against the 255-day timeliness goal.
In addition, as a result of the CY 2022 SDP timeliness review (ML22335A003) the staff made five recommendations to improve the SDP and the timeliness of potentially GTG findings. Three of these recommendations were implemented in CY 2023 while the remaining two were implemented in CY 2024.
0307A-04 CLARITY PERFORMANCE METRICS (C)
C-1 Maintenance of ROP Web Pages Metric Status:
Green Definition:
ROP-related internal and external NRC Web pages are reviewed at least quarterly, and discrepancies are corrected as necessary to ensure that ROP information is communicated accurately and effectively.
Data and Analysis:
In CY 2024, each region verified that the data available on the NRC public website for their reactor sites/units were accurate, up to date, and had working links. Any discrepancies or errors discovered by the regions were submitted for correction as appropriate. Currently, the page of Inspection Reports is populated with inspection reports by reactor site with links to the individual reports, and the PIM Summary shows an overview of ROP findings by cornerstone on a per unit basis with links to the overall performance summary per unit, as well as links to the list of findings summaries by cornerstone per unit. All of the applicable ROP-related webpages were reviewed by the regions on a quarterly basis.
NSIR staff are responsible for reviewing five ROP-related webpages: the internal security inspection program documents, Generic Communications, the list of Assessment Letters, the list of Inspection Reports, and the PI Data Summary. NRR staff are responsible for reviewing the plant summaries for each operating unit, currently 94 units, along with the PIM Summary, the list of Inspection Reports, the Action Matrix, the list of Assessment Letters, and the Cross Cutting Issues webpages. The staff verify that the data available are accurate, up to date, and have working links. All of these webpages were also reviewed at least quarterly, and any discrepancies or errors discovered by the staff were submitted for correction as appropriate. Since the percentage of ROP-related webpages reviewed at least quarterly by the staff is greater than 90%, this metric is green.
C-2 Maintenance of ROP Governance Documents Metric Status:
Green Definition:
Baseline inspection procedures (BIPs) and other ROP-related Inspection Procedures and Manual Chapters are reviewed at least once every 5 years.
Data and Analysis:
As of December 31, 2024, there were a total of 314 ROP-related IMCs and IPs with 89 of those IMCs and IPs designated as reference documents for the ROP. Publicly available reference IPs are also designated as such on the NRC Inspection Procedures webpage. ROP documents that are reference-only are not subject to the periodic 5-year review cycle in accordance with IMC 0040. Of the 225 documents subject to this metric, 178 were most recently issued between January 1, 2020, and December 31, 2024. Another 37 documents were reviewed by staff in 2024 and were still in the process of being revised and reissued as of December 31, 2024. Ten documents had not been reviewed by staff in 2024 within the five-year review requirement, which also subsequently requires a revision or a reissuance of the document. Since 95.6% of the ROP-related IMCs and IPs subject to this metric have been reviewed, which is greater than or equal to 95%, this metric is green.
Of the ten documents that did not meet this metric, seven are related to the occupational radiation safety cornerstone of the ROP. Many of these procedures have revisions in process. However, most of the revisions are pending additional guidance from ADVANCE Act initiatives. This is to ensure that revisions that are developed are supportive and coherent with any ROP-related changes that are pursued as a result of overall ADVANCE Act efforts.
In CY 2024, the staff has continued to focus on successfully accomplishing the intent of this metric, in having up-to-date and periodically reviewed ROP governance documents. The staff believes that the current process for tracking this metric, which was begun in CY 2021, has improved the overall transparency of the document revision process and status, and has contributed to the relative improvement in this metric.
0307A-05 RELIABILITY PERFORMANCE METRICS (R)
R-1 Predictability and Repeatability of Significance Determination Results Metric Status:
Green Definition:
Potentially greater-than-Green inspection findings and the associated degraded conditions contain adequate detail to enable an independent auditor to trace through the available documentation and conclude that the significance characterization is reasonably justifiable from both programmatic and technical positions. This audit should be documented in a memo that is internally available to the NRC and referenced in the annual metric report.
Data and Analysis:
The staff determined that the 14 potentially GTG findings issued by the NRC in CY 2024 contained adequate detail to enable an independent auditor to trace through the available documentation and conclude that the significance characterization was reasonably justifiable from both programmatic and technical positions. This internal audit was documented in a memorandum dated February 17, 2025 (ML25022A060, nonpublic).
Since zero discrepancies in the significance determination were identified, this metric is green.
R-2 Predictability of Agency Actions and Response Metric Status:
Green Definition:
Deviations from the Action Matrix are expected to be infrequent to ensure reliable and predictable oversight.
Data and Analysis:
In CY 2024, there were zero ROP Action Matrix deviations, so this metric is green.
R-3 Supportability of Inspection Findings Metric Status:
Green Definition:
Inspection findings and violations under the ROP are adequately supported and documented such that findings and violations that are appealed or disputed by licensees are infrequently withdrawn.
Data and Analysis:
In CY 2024, the staff issued a total of three determinations on findings or violations that were contested by licensees under the ROP. A violation at Enrico Fermi Nuclear Generating Station was contested in by the licensee in CY 2023 and was later withdrawn in a Response Letter dated April 1, 2024 (ML24086A573). A violation at Dresden Nuclear Power Station was contested by licensee and upheld in a Response Letter dated July 24, 2024 (ML24180A058). Finally, a violation at Waterford Steam Electric Station was contested by the licensee and upheld in a Response Letter dated September 25, 2024 (ML24229A104).
Since no more than three contested violations were overturned and no more than two contested violations per region/office were overturned, this metric is green, and no region or office will be individually evaluated.