ML25301A007
| ML25301A007 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/2025 |
| From: | Brian Benney NRC/NRR/DRO/IOEB |
| To: | Philip Mckenna NRC/NRR/DRO |
| References | |
| Download: ML25301A007 (0) | |
Text
December 5, 2025 MEMORANDUM TO:
Philip McKenna, Acting Director Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM:
Brian Benney, Reactor Operations Engineer Generic Communications and Operating Experience Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE REACTOR OVERSIGHT PROCESS REBASELINING PUBLIC MEETING HELD ON OCTOBER 21, 2025 On October 21, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a public meeting with the Nuclear Energy Institutes (NEIs) Reactor Oversight Process (ROP) Task Force executives, senior industry executives, and external stakeholders to discuss the staffs progress on initiatives related to the ROP. The meeting notice and agenda are located at ML25290A332.
More Than Minor Screening Updates A significant portion of the discussion centered on the More-than-Minor (MTM) Issue Screening Criteria. The current process, which relies on subjective criteria, has led to inconsistencies in documented findings. To address this, the NRC proposed relocating the MTM criteria from Inspection Manual Chapter (IMC) 0612 to IMC 0609, which is already a familiar and more objective tool within the issue screening process. This change aims to reduce subjectivity, improve consistency, and streamline the determination process. The proposed revisions would eliminate the examples in Appendix E of IMC 0612 and introduce cornerstone-specific questions to replace the broader criteria. As a result, many findings currently classified as Green may be reclassified as Minor, particularly those involving minor degradation or calculational errors that do not impact operability or functionality. These changes will be pending Commission upon submission of the ROP Baseline Inspection Program revision SECY. If approved, the revision is expected to be implemented in 2026.
During the discussion, the industry asked how the details in the examples currently in appendix E would be used and captured for future reference. The staff stated the information in the examples is being considered when developing the criteria that will be used for IMC 0612 appendices and may keep the information available as a reference.
Engineering Inspection Procedure
The meeting also introduced a new proposed engineering inspection procedure (IP), IP 71111.21A, which references several existing procedures such as those for power-operated valves (POV), environmental qualification (EQ), and commercial grade dedication (CGD). This new IP would require approval from the Commission in the proposed ROP Baseline Inspection Program revision SECY. This new IP is designed to be flexible and tailored to the specific systems, structures, and components (SSCs) being inspected. It will be conducted by a two-to three-member team, including a resident inspector. The inspection can be completed in two consecutive weeks or in separate weeks, depending on the selected samples. The procedure emphasizes assessing engineering performance in maintaining SSCs' design basis functions, defense-in-depth capabilities, and alignment with probabilistic risk assessments (PRAs).
Major proposed updates to the engineering inspection program were discussed, including:
Transition to an annual engineering inspection sample, with 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> of effort allocated per site using 2 to 3 staff resources, with flexibility for sample selection and scheduling.
Inspections would reference previous inspection procedures for specific guidance on inspecting systems, structures and components and with specifics included in the inspection plan.
Regions would begin planning and communicating with licensees 180 to 120 days prior to the first onsite day of the inspection.
The NRC shared the inspection objectives of the new draft engineering inspection procedure.
Industry comments included an interest in having more discussion on the change to engineering inspections to ensure licensees can properly prepare. The NRC plans on sharing the draft of the new engineering inspection procedure by the next ROP monthly meeting in November.
Problem Identification and Resolution Inspection Procedure The staff discussed the proposed changes to IP 71152, Problem Identification and Resolution (PI&R). Specifically, the team inspection is being proposed to be moved to IMC 2515 App C as an infrequently performed inspection. The baseline portion of the inspection will include baseline PI&R reviews, semi-annual trend reviews, and annual followup of selected issues. The number and resource estimate for the annual followup samples was increased from four to seven, with a corresponding increase in inspection hours from 64 to 90. Portions of the team inspection will also be included as optional annual followup samples. In addition, entry criteria were developed for implementation of the team inspection, where the scope and resources used will be defined in a charter approved by the regional administrator.
During the discussion, the industry noted that by having safety conscious work environment (SCWE) as a potential sample during the annual inspection, keeping it in the PI&R follow up inspection that is replacing the team inspection, and maintaining IP 93100 SCWE follow up inspection procedure could be sampled and inspected more often than it is currently today. The staff clarified that that is not the intent of the proposed PI&R inspection revision.
Security Inspection Updates The security inspection program is undergoing a comprehensive update, with the new proposed inspection procedures introduced to focus on licensee performance and compliance with 10 CFR 73.55. The revised approach eliminates the previous tiered inspection elements and shifts to a system-based sampling methodology. All security inspections are now proposed to be triennial, except for the Security Operational Performance inspection, which will remain annual.
New procedures include IP 71130.15 for operational performance, IP 71130.16 for equipment and training, IP 71130.17 for protective strategy design and implementation, and IP 71130.18 for access authorization and fitness for duty. Resident inspectors will play a more active role in these inspections. These new IPs would require approval from the Commission in the proposed ROP Baseline Inspection Program revision SECY.
Other Proposed ROP Baseline Inspection Program Changes The overall Baseline Inspection Program is proposed to be revised with five inspection procedures (IPs) being sunset, including those for flood protection, heat exchanger performance, maintenance effectiveness, plant modifications, and performance indicator verification. Important elements from these IPs will move into other Baseline Inspection IPs.
These changes are part of a broader effort to consolidate and modernize the ROP inspection framework. Five engineering IPs will be merged into a single new procedure, while twelve IPs will remain in use. This restructuring is expected to reduce the total annualized inspection hours by 37%, with notable reductions across reactor safety, emergency preparedness, radiation protection, and security inspection procedures.
The implementation timeline for these changes includes document development and regional review from September through December 2025, submission of a SECY paper to the Commission, development of a scheduling plan, inspector training, and the official rollout of the revised procedures after the staff receives the staff requirements memo (SRM) from the Commission.
The Next ROP Meeting The next regularly scheduled ROP bimonthly public meeting is tentatively scheduled for November 19, 2025.
Communicating with the NRC Staff At the start of all ROP public meetings, the project manager provides contact information for the public to use to provide their name and affiliation as a participant in the meeting. This contact information is also provided for submitting questions and comments to the NRC staff. Please note that any questions and/or comments pertaining to the ROP can be sent to Mr. Brian Benney at Brian.Benney@nrc.gov. The Contact Us about ROP page on the ROP public website can also be used to submit questions and comments regarding the ROP (https://www.nrc.gov/reactors/operating/oversight/contactus.html).
Conclusion The industry representatives expressed appreciation for the open dialogue and willingness of NRC staff to hear industry views. The NRC management stressed the importance of the NRC being focused on providing reasonable assurance of public health and safety when considering changes to the ROP.
The enclosure provides the attendance list for this meeting.
Enclosure:
As stated
- via email OFFICE NRR/DRO/IOEB/BC NRR/DRO/IRIB/BC NRR/DRO/DD NAME BBenney HJones PMcKenna DATE 10/28/2025 12/3/2025 12/5/2025 Enclosure LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING October 21, 2025 - 9:00 AM to Noon NAME Organization1 Alex Garmoe NRC Alex Prada NRC April Nguyen NRC Aron Lewin NRC Bill Rautzen NRC Brian Benney NRC Brian Sentor Southern Brian Yip NRC Brice Bickett NRC Carlos Sisco Winston and Strawn Carrie Seip Xcel Energy Casey Smith NRC Charity Pantalo NRC Cheryl Khan NRC Chris Fisher Cook Christopher Henderson NRC Cindy Rosales-Cooper NRC Daniel Buscher Evergy David Aird NRC David Burke Holtec David Garmon NRC David Hermann US Army David Holman NRC Desiree Davis NRC Don Johnson NRC Douglas Bollock NRC Dwayne Myal NRC Edwin Lyman UCS Elias Haddad NRC Eric Brothman NRC Eric Riggs NRC Eric Schrader NRC Erin Carfang NRC Gladys Figueroa Toledo NRC Heather Jones NRC James Morris PGE Jasmine Gilliam NRC Jason Schussler NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.
2 Jeff Bream NRC Jeff Correll NRC Jefferson Clark NRC Jeremiah Rey NRC Jesse Rollins NRC Jo Ambrosini NRC John Gewargis NRC John Giddens Entergy Josh Rhodes NRC Joy Jiang The Breakthrough Institute Julie Winslow NRC Justin Bouknight Dominion Justin Wearne PSEG Karla Stoedter NRC Kenneth Kolaczyk NRC Kevin Hsueh NRC Larry Sinclair NRC Len Cline NRC Lewis Csedrik Balch Linda Dewhirst NPPD Mark Henrion NRC Matt Rossi Constellation Matthew Hardgrove NRC Maureen Conley NRC Maurin Scheetz NRC Maury Brooks NRC Michael Waters NRC Michael Whitlock NEI Mike McCoppin NRC Mike Stafford NRC Molly Keefe-Forsyth NRC Nadir Chaudhry NRC Nicole Good Stars Alliance Nik Floyd NRC Nikki Warnek NRC Odunayo Ayegbusi NRC Pat Asendorf TVA Peter Boguszewski NRC Phil OBryan NRC Philip McKenna NRC Rebecca Sigmon NRC Rob Berg EPM Sandra Mendez NRC Sarah Obadina NRC Shawn Kirven Stars Alliance Stephanie Roche Rivera NRC Steven Dolley SPGlobal Tanvir Siddiky NRC Tara Inverso NRC
3 Thomas Farina NRC Thomas Hartman NRC Tim Marshall NRC Tim Riti NEI William Garrett Southern