ML25290A158

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October 21 2025 Reactor Oversight Process (ROP) Public Meeting
ML25290A158
Person / Time
Issue date: 10/17/2025
From: Heather Jones
Office of Nuclear Reactor Regulation
To:
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Download: ML25290A158 (36)
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NRC Public Meeting:

Reactor Oversight Process (ROP)

Baseline Inspection Program Revisions October 21, 2025

Purpose, Outcome, Plan/Agenda Purpose of the Presentation
  • To discuss proposed revisions to the ROP Baseline Inspection Program and the More-than-Minor (MTM) Issue Screening Criteria.

Desired Outcome

  • Communicate proposed revisions to the inspection program, inspection procedures, and MTM issue screening criteria to industry and members of the public.

Agenda 1.

MTM Issue Screening Criteria Discussion 2.

Engineering Inspection Updates 3.

Problem Identification and Resolution Inspection Updates 4.

Security Inspection Updates 5.

ROP Baseline Inspection Program Proposed Revisions 6.

Q&A / Discussion

More-than-Minor Screening Criteria Alex Garmoe Senior Reactor Analyst Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

More-than-Minor Screening Criteria

  • ADVANCE ACT Section 507 prompted review of issue screening process
  • ensure NRCs regulatory oversight is risk-informed and performance-based
  • Prior issue screening updates implemented earlier this year
  • Expanded applicability of VLSSIR
  • Elimination of dual-path TE-ROP screening option for Green issues
  • More-Than-Minor decision-making consistency and efficiency has long been a focus area
  • Questions/criteria involve subjectivity

More-than-Minor Screening: Current State

  • reasonably be viewed as a precursor to a significant event?
  • have the potential to lead to a more significant safety concern?
  • associated with one of the cornerstone attributes and adversely affect the associated cornerstone objective?
  • Use IMC 0612, Appendix E, or the Security Issues Forum process to inform answers to the screening questions listed above.
  • Additional background guidance in IMC 0612 Section 5
  • requires inspectors to apply reasonable judgment
  • some variability will exist whenever different inspectors have to apply judgment to unique and site-specific circumstances

More-than-Minor Screening: Future State

  • Next step in ADVANCE Act Section 507-driven changes to issue screening is improving the MTM determination
  • Address the subjectivity and judgment in current criteria
  • Reduce the level of effort required to make the determination
  • Enhance consistent and predictable outcomes
  • These can be achieved by relocating MTM to IMC 0609 documents
  • Already a familiar tool that is part of issue screening process
  • More objective than the existing MTM questions/criteria
  • Review and revision of IMC 0612 and 0609 documents is underway along with Baseline Inspection Program revisions

More-than-Minor Screening: Current vs Future Issue of Concern Perf.

Deficiency More-than-Minor?

IMC 0612B IMC 0612B IMC 0612B Screen to Green?

IMC 0609.04 IMC 0609_

SDP Router IMC 0612E Issue of Concern Perf.

Deficiency IMC 0612B IMC 0612B Screen to Minor or Green?

IMC 0609.04 IMC 0609_

SDP Router Current State:

Future State:

More-than-Minor Screening Criteria From IMC 0612 to IMC 0609

Impacts of the Proposed Change

  • Replacement of broad criteria with targeted, cornerstone-specific criteria
  • Reduction in the degree of subjectivity and judgment involved
  • Opportunity to revisit the threshold of more-than-Minor
  • Restricted to Minor/Green decision-making, did not consider greater-than-Green threshold under this effort
  • Synced with changes to greater-than-Green criteria in Security and EP that are unrelated to this effort
  • Does not impact overall issue screening process (0612B flowchart)

Impacts of the Proposed Change

  • Document revisions and internal comment are ongoing and specific wording and criteria are not yet finalized
  • Example impacts based on current status:
  • Currently everything entering 0609 appendices is at least Green
  • Proposed Appendix A revisions include 10 questions in which Green becomes Minor
  • Proposed Appendix F revisions include 14 questions in which Green becomes Minor, issues with low degradation rating are now Minor
  • It is anticipated that many of the Green findings associated exclusively with degradations in margin or minor calculational errors, in which operability/functionality/qualifications were maintained, would screen to Minor

Impacts of the Proposed Change

Impacts of the Proposed Change

Impacts of the Proposed Change Revised IMC 0609A Question 1 for Mitigating Systems removes concept of reasonable doubt Existing IMC 0612E example:

Impacts of the Proposed Change

  • It is expected that the number of Green findings will be reduced
  • Intention is to maintain Green findings impacting
  • SSC operability, availability, qualification that would affect performance of intended function (without considering comp measures, mods/repair, etc.)
  • Unplanned dose exposures or rad material release
  • EP: Impact to the 6 planning standards that can still be greater-than-Green
  • Not an all-inclusive list
  • Some future adjustments may be needed given scope and pace of this effort
  • For the same reason, it is expected that some issues may be approved for deviation from the default screening approach
  • Minor violations require correction - CR (number and title) may be included in Inspection Reports

Implementation of Changes

  • Implementation is subject to Commission approval of the approach
  • Request for approval will be contained in ROP Baseline Inspection Program Revision SECY
  • Document revisions are ongoing with regional comment in October and November
  • Revised document issuance throughout December
  • Implementation, pending approval, in January 2026

Questions and Discussion on the Revision to the More-than-Minor Issue Screening Guidance

New Engineering Inspection Doug Bollock Senior Reactor Operations Engineer Reactor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

Elements of New Engineering Inspection Procedure

  • Consolidates previous inspection procedures (e.g., POV, EQ, CGD).
  • Tailored to specific Structures, Systems, and Components (SSCs) being inspected.
  • Inspection Team & Duration:
  • 2-3-member team (includes resident inspector).
  • Onsite for two weeks
  • Inspection can be completed in two consecutive weeks or spread out over some time period within a year, depending on the samples selected.
  • Inspection effort:
  • 175-210 hours (defined in the inspection plan).
  • Flexible Scope & Focus:
  • Inspection scope is adaptable to target problem areas.
  • Specific guidance based on SSCs selected for inspection.
  • Resource Flexibility:
  • Flexibility in inspection resources used to support the effort.

New Engineering Inspection Objectives

  • To assess current engineering performance to maintain risk-significant systems, structures, and components (SSCs) capable of performing their design basis functions under bounding conditions described in the plant design and licensing bases.
  • To assess current engineering performance to maintain SSCs defense-in-depth capability with safety margins provided for in the design and licensing bases.

New Engineering Inspection Procedure Elements

  • The IP is intended to be used to implement the technical requirements and guidance in past engineering inspection procedures (but not limited to):
  • Sample types implemented under this IP will therefore cover several types of samples such as CGD packages, aging-related component reviews, fire protection SSCs and administrative controls, POV design basis evaluations, modifications, 10 CFR 50.59 screenings and evaluations, and operating experience reviews.

IP No.

IP Title 71111.07 Heat Exchanger/Sink Performance 71111.17T Evaluations of Changes, Tests and Experiments 71111.18 Plant Modifications 71111.21M Comprehensive Engineering Team Inspection (CETI) 71111.21N Design Bases Assurance Inspection - Environmental Qualification (EQ) 71111.21N.02 Power-Operated Valves (POV) 71111.21N.03 Commercial Grade Dedication (CGD) 71111.21N.04 Age-Related Degradation (ARD) 71111.21N.05 Fire Protection Team Inspection (FPTI) 71152 Problem Identification and Resolution (PI&R)

New Engineering Inspection Procedure Planning

  • The inspection lead will develop an inspection plan that implements the referenced IP(s) objectives within the resource estimates. There will be an IP attachment that may be used as a reference to build the inspection plan.
  • The inspection lead will gather information from the licensee describing current engineering activities. This activity should commence approximately 180 days and no later than 120 days prior to the scheduled onsite inspection (if inspection scope is known, specific request for information may be sent closer to the inspection date).
  • This can be accomplished by document requests and/or discussions with the site Resident
  • The Regional End of Cycle Meeting can also be used as input to the inspection.
  • Inspection plans should demonstrate a focus on current licensee engineering performance (last 4 years ).
  • During sample selection, the inspection lead should review prior inspection history and consider selecting a sample that has not been reviewed recently at the site.

Problem Identification and Resolution (PI&R)

Inspection Procedure Changes Sarah Obadina Reactor Operations Engineer Reactor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

PI&R Inspection Procedures

  • Minimum Annual Samples will be increased from 4 to 7 with a resource increase from 64 to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />.
  • Current sections of PI&R Team Inspection included as optional samples:
  • Licensee audits and self-assessments
  • Licensee use of operating experience
  • Review of issues that pose challenges to the free flow of information for adequate resolution
  • Entry Criteria
  • Regional Administrator approval

PI&R Team Inspection

  • Two-member team, onsite for one week (Flexibility on inspection resources used)
  • Inspection hours estimate: 60-80 (depending on complexity of the issue(s))
  • Fully qualified inspectors with option to include inspectors with specialized expertise (e.g., qualified safety culture assessor, regional inspectors)
  • Scope of inspection is flexible with options to focus on problem areas
  • CAP effectiveness
  • Licensee audits and self-assessments
  • Licensee use of operating experience
  • Review of issues that pose challenges to the free flow of information for adequate resolution
  • Charter will specify what aspects of the inspection will be performed
  • Regional Administrator approval required

PI&R Team Inspection Entry Criteria

  • Entry Criteria for implementation of team inspection1, as approved by the Regional Administrator
1) Findings:
  • Two or more Greater-than-Green (GTG) findings in the area of PI&R in any 12-month period, or
  • Greater than 5 cumulative findings in the area of PI&R in any 12-month period that the regional office has concerns about the adequacy of the licensees corrective actions
2) Supplemental Inspections:
  • Supplemental inspection identifies and documents a significant weakness in the PI&R program which the licensee did not identify, or
  • Results of a supplemental inspection or IMC 0350 document a SCWE concern2 Notes:

1)

The team inspection will be applicable to Columns 1, 2 & 3 of the Action Matrix. The team inspection is not recommended in Column 4 of the Action Matrix due to duplication in inspection effort for an IP 95003 Supplemental Inspection.

2)

There will be two IMC 2515 App C inspections for SCWE: IP 93100 and this new PI&R team inspection. Only one of these inspections should be conducted for a SCWE issue. The regional administrator should choose the inspection that is most applicable.

Security Inspection Program Update Jeff Bream Senior Security Risk Analyst Security Oversight and Support Branch Office of Nuclear Security and Incident

Response

Elements of New/Updated Security Inspection Procedures

  • Revised IPs will focus on licensee performance and compliance with the general performance objectives of 10 CFR 73.55.
  • Inspectors will be asked to verify the licensees implementation and performance of a security component complies with the security plan and implementing procedures.
  • Inspection sample selection will be different from current methodology
  • Inspection element Tiers have been eliminated.
  • Sampling will be based on overall security system instead of discrete requirements.

Examples will be discussed for each IP.

  • All security inspections will be triennial, except for Security Operational Performance which will be annual.
  • Resident inspectors will be utilized as inspection team members.

New Security Inspection Procedures

  • Verify performance of a sample of three normal daily operational activities.
  • For example: personnel searches, vehicle searches, material searches, alarm station operations, security officer patrols, etc.
  • Verify a sample of security equipment is maintained in a functional condition.
  • Walkdown of one system or a collection of similar systems to verify material deficiencies are identified.
  • Verify security deficiencies are entered into the problem identification and resolution program for appropriate corrective actions.
  • Existing PI&R review moved into one IP for consistency and to eliminate redundancy.
  • Verify a sample of three to five security systems are tested for performance.
  • Inspectors will observe testing of security systems to verify performance.
  • Verify the protected area intrusion detection system is capable of performing its function.
  • Limited performance testing of identified zones to validate detection and assessment.
  • Verification of security training.
  • Initial and annual training is implemented appropriately.

New Security Inspection Procedures

  • IP 71130.17, Design and Implementation of the Protective Strategy
  • Verify the licensee has designed a protective strategy in accordance with the general performance objectives of 73.55(b)
  • Verify implementation of a sample of the protective strategy features.
  • For example: barrier location and construction, responder positions, response equipment, etc.
  • Verification of the licensee performance evaluation program.
  • Verify the licensee maintains site-specific target sets.
  • Focused on verifying that licensees are implementing their target set maintenance program.
  • Designed to be performed at a centralized corporate location, if applicable.

Overall Baseline Inspection Program Update Phil McKenna, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation

NRR IPs Maintained/Sunset IP Title Issue Date Action 71111.01 Adverse Weather Protection 8/1/2022 Maintain 71111.04 Equipment Alignment 9/19/2023 Maintain 71111.05 Fire Protection 8/1/2022 Maintain 71111.06 Flood Protection Measures 8/1/2022 Sunset 71111.07 Heat Exchanger/Sink Performance 8/18/2023 Sunset 71111.08 Inservice Inspection Activities 10/16/2023 Maintain 71111.11 Licensed Operator Requalification Program and Licensed Operator Performance 12/6/2024 Maintain 71111.12 Maintenance Effectiveness 3/31/2021 Sunset 71111.13 Maintenance Risk Assessments and Emergent Work Control 8/1/2022 Maintain 71111.15 Operability Determinations and Functionality Assessments -

Effective January 1, 2026 4/9/2025 Maintain 71111.18 Plant Modifications - Effective Date January 1, 2025 11/21/2024 Sunset 71111.20 Refueling and Other Outage Activities 4/6/2022 Maintain 71111.21M Comprehensive Engineering Team Inspection 6/27/2025 New IP 71111.21N.03 Commercial Grade Dedication 2/16/2023 In new IP 71111.21N.04 Age-Related Degradation 4/9/2025 In new IP 71111.21N.05 Fire Protection Team Inspection (FPTI) 6/12/2019 In new IP 71111.24 Testing and Maintenance of Equipment Important to Risk 3/7/2023 Maintain 71151 Performance Indicator Verification - Effective Date 01/01/2025 12/12/2024 Sunset 71152 Problem Identification and Resolution (PI&R) 10/31/2023 Alter 71153 Follow up of Events and Notices of Enforcement Discretion 9/16/2020 Maintain KEY MESSAGES

  • 21 IPs currently used for the NRR ROP BIP
  • 5 IPs will be sunset
  • 71111.06, Flood Protection Measures (attributes shifted to.01 and.04)
  • 71111.07, Heat Exchanger/Sink Performance (attributes shifted to.24)
  • 71111.12, Maintenance Effectiveness (requirements shifted to.24)
  • 71111.18, Plant Modifications (attributes shifted to.04,.11, engineering inspection)
  • 71151, Performance Indicator Verification (reduced verification shifted to Plant Status, or other IPs)
  • The 5 engineering IPs will be consolidated into one newly developed IP
  • 12 IPs will remain in use

NRR IPs Maintained/Sunset Current IP No Frequency Title Nominal Samples Nominal Hours 71111.01 A

Adverse Weather Protection 3

17 71111.04 A

Equipment Alignment 13 60 71111.05 A

Fire Protection 22 50 71111.06 A

Flood Protection Measures 2

12 71111.07 A

Heat Exchanger 1

7 71111.08 Refuel Inservice Inspection Activities (PWR) 2 86 71111.11B B

Licensed Op Requal & Perform 1

96 71111.11Q A

Licensed Op Requal & Perform 8

32 71111.12 A

Maintenance Effectiveness 9

108 71111.13 A

Maintenance Risk Assessments &

Emergent Work Control 17 85 71111.15 A

Oper Determinations/Functionality 22 122 71111.18 A

Plant Modifications 4

32 71111.20 R

Refueling and Other Outage Activities 1

77 71111.21M Quad Comprehensive Engineering Team Inspection 28 490 71111.21N.

03 Quad Commercial Grade Dedication 12 210 71111.21N.

04 Quad Age-Related Degradation 12 210 71111.21N.

05 Quad Fire Protection Team Inspections (FPTI) 6 210 71111.24 A

Testing and Maintenance of Equipment Important to Risk 41 184 71151 A

Performance Indicator Verification 27 28 71152A A

PI & R Annual 6

74 71152S S

PI & R Semi Annual 2

20 711152B B

PI&R Biennial Team Inspection 1

125 71153 Follow up of Events and Notices of Enforcement Discretion 6

80 Updated IP No Frequency Title Min Sample s

Min Hours 71111.01 A

Adverse Weather Protection 2

10 71111.04 A

Equipment Alignment 9

72 71111.05 A

Fire Protection 13 30 71111.08 A

Inservice Inspection Activities 2

66 71111.11Q A

Licensed Op Requal & Perform 4

9 71111.11B B

Licensed Op Requal & Perform 1

64 71111.13 A

Maintenance Risk Assessments &

Emergent Work Control 12 75 71111.15 A

Operability Determinations/Functionality 19 107 71111.20 R

Refueling and Other Outage Activities 1

62 71111.24 A

Testing and Maintenance of Equipment Important to Risk and Maintenance Effectiveness 34 181 71152A A

PI & R Annual 7

90 71152S S

PI & R Semi Annual 2

20 71153 A

Follow up of Events and Notices of Enforcement Discretion As required 55 71111.11A A

Engineering IP 1

175

EP / Security / RP IPs Proposed Baseline Security Inspection Procedures (71111.30 Series)

Proposed Baseline Radiation Protection Inspection Procedures (71125 Series)

Procedure Number Freq.

Title Min Samples Minimum Procedure Hours New Min Hours (Annualized) 71114.01 B

Exercise Evaluation 1

80 40 71114.02 B

Alert and Notification System Evaluation 1

4 2

71114.03 B

Emergency Response Organization Staffing and Augmentation System 1

4 2

71114.04 B

Emergency Action Level and Emergency Plan Changes 1

12 6

71114.05 B

Maintenance of Emergency Preparedness 1

9 5

71114.06 B

NRC Resident - Evaluation of Emergency Preparedness Program 3

5 3

71114.07 B

Exercise Evaluation - Scenario Review 1

10 5

ANNUALIZED TOTAL 63 Proposed Baseline Emergency Preparedness Inspection Procedures (71114 Series)

Procedure Number Freq.

Title Min Samples Minimum Procedure Hours New Min Hours (Annualized) 71130.03 T

Contingency Response - Force-on-Force Testing 1

180 60 71130.10 T

Cybersecurity 3

63 21 71130.15 A

Security Operational Performance 5

22 22 71130.16 T

Security Equipment Performance and Security Training 5

45 15 71130.17 T

Design and Implementation of the Protective Strategy 4

72 24 71130.18 T

Access Authorization and Fitness for Duty 4

31 10 ANNUALIZED TOTAL 152 Procedure Number Freq Title Min Samples Minimum Procedure Hours New Min Hours (Annualized) 71125.01 R

Radiation Safety Refueling Outage TBD 57 38 71125.02 T

Radiation Protection - Remote Inspection TBD 33 11 71125.03 T

Occupational Radiation Safety Onsite Inspection TBD 33 11 71125.04 T

Public Radiation Safety Onsite Inspection TBD 33 11 ANNUALIZED TOTAL 71

Revised Baseline Inspection Program Procedure Series Current Program Annualized Hours Proposed Program Annualized Hours

% Change Resource Usage Reactor Safety Inspection Procedures (IP 71111 Series) 1143 797

-30%

Emergency Preparedness Inspection Procedures (IP 71114 Series) 144 73

-49%

Radiation Protection Inspection Procedures (IP 71124 Series) 111 71

-36%

Security Procedures Inspection (IP 71130 Series) 287 152

-47%

PI Review, PI&R, Event Follow-Up Inspection Procedures 327 165

-49%

TOTAL 2012 1258

-37%

Timeline Date Milestone September thru December 2025 Development, Regional Review, and Issuance of Revised Inspection Manual Chapters (IMCs) and Inspection Procedures (IPs)

October 2025 SECY to the Commission November 2025 Develop Transition Plan for implementation later than January 1, 2026 November 19, 2025 ROP Bi-Monthly Meeting December 2-4, 2025 Inspector training at December Inspector Counterpart Meetings January 1, 2026 Issue Revised IPs for the Baseline Inspection Program go into effect (pending Commission approval of Revised ROP)

Questions and Discussion on the Revisions to the ROP Baseline Inspection Program

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