ML25322A020

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November 19 2025 ROP Bimonthly Public Meeting: NRC Reactor Oversight Process (ROP)
ML25322A020
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Issue date: 11/19/2025
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NRC Reactor Oversight Process (ROP) Bimonthly Public Meeting November 19, 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 Time Topic Presenter 9:00am Introductions and Opening Remarks Phil McKenna and NEI 9:05am Emergency Preparedness Significance Determination Process Update Don Johnson 9:15am Engineering Inspection Procedure Discussion Doug Bollock 9:35am Problem Identification and Resolution Inspection Procedure Discussion Sarah Obadina 9:55am Radiation Protection Inspection Program Updates David Garmon 10:15am Update on the Differing Professional Opinions Process Gladys Figueroa Toledo 10:35am Performance Indicator Discussion and Next Steps NEI 11:00am Updated Information Regarding the Documentation of Findings Manuel Crespo 11:10am ROP Baseline Inspection Program SECY Update Phil McKenna 11:20am Open Discussion NRC, NEI, Industry 11:40am Additional Opportunity for Public Comments Members of the Public 11:55am Action Items & Closing Remarks NRC & NEI Noon Meeting Adjourn

Emergency Preparedness Significance Determination Process Update Don Johnson Senior Emergency Preparedness Specialist Policy and Oversight Branch Office of Nuclear Security and Incident Response

Update on Emergency Preparedness Significance Determination Process

  • Revised to focus the significance determination, for inspection findings, on the planning standards having a direct impact on public health and safety as well as those that have a direct relationship with the effective implementation of these risk significant functions.

Actual event inspections will consider all planning standards.

  • Enhanced the guidance for the significance determination for (b)(9) due to recurring issues with the significance determination for findings related to dose assessment models and radiation monitors.
  • Re-emphasized the importance of using technical judgement when determining the significance of inspection findings, and for ensuring that the determination considers all mitigating factors.

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 effort:
  • 2-3-member team (includes resident inspector). 175-210 hours (defined in the inspection plan).
  • Onsite for two weeks
  • Flexible Scope & Focus:
  • Inspection scope is adaptable to target problem areas.
  • Specific guidance based on SSCs selected for inspection.
  • Inspection can be completed in two consecutive weeks or spread out over some time period within a year, depending on the samples selected.
  • Industry Comments?

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

IP 71152 - PI&R

  • Annual Follow-up
  • Minimum samples increased from 4 to 7 with a resource estimate 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
  • Assessment
  • Semi-annual trend review
  • Five-year review

IP 93816 - 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)

  • Flexible inspection scope 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
  • Entry Criteria

PI&R Inspection Procedures Industry Comments

Documentation of Findings Manuel Crespo Reactor Operations Engineer Reactor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

Documentation of Findings

  • In SECY-25-0045 the staff informed the Commission that NRR would produce guidance to reduce the documentation requirements for Green and Severity Level IV non-cited violations.
  • Notices of Violations (Green and/or Severity Level IV) would maintain the current documentation level.
  • The goal for this action would go into affect for any inspection activity performed in 2026.

IMC 0611 will be revised as on January 1, 2026, but 4th quarter 2025 integrated inspection reports (issued by February 15, 2026), would use the 2025 procedure to document Green findings.

Updated Information Regarding Documentation of Findings Current Introduction Description Corrective Actions Corrective Action References Performance Deficiency Screening Significance Cross-Cutting Aspect Violation Enforcement Action Revised Green/Severity Level IV NCV Introduction Description Corrective Action References Performance Deficiency Significance Determination [IMC only]

Cross-Cutting Aspect [aspect only]

Violation [Contrary to statement only]

Enforcement Action

Updated Information Regarding Documentation of Findings Current Revised Failure to Control Transient Combustible Material Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000XXX/2023 004-01 Open/Closed

[H.2] - Field Presence 71111.05 A Green NRC-identified finding and associated non-cited violation (NCV) of the Unit 1, Renewed Facility Operation License, Condition 2.E, was identified for failure to adhere to the requirements of a transient combustible exclusion zone (TCEZ).

Specifically, on October 17, 2023 and October 19, 2023, Licensee failed to ensure transient combustibles were properly controlled as required by OP-AA-201-009, Control of Transient Combustible Material.

Failure to Control Transient Combustible Material Cornerstone Mitigating Systems Significance Green Cross-Cutting Aspect Human Performance Report Section 71111.05 Attribute Protection Against External Factors Type NCV Tracking Number 05000XXX/20230 04-01 Status Closed A Green NRC-identified non-cited violation (NCV) of the Unit 1, Renewed Facility Operation License, Condition 2.E, was identified when the licensee did not ensure transient combustibles were properly controlled in fire area 39 and 16 as required by OP-AA-201-009, Control of Transient Combustible Material on October 17, 2023, and October 19, 2023, respectively.

Updated Information Regarding Documentation of Findings Current Revised

==

Description:==

On October 17, 2023, inspectors performed a walkdown of the Unit 1, service water pump room, fire area 39, and identified an area beneath a room stairway marked no combustible permanent storage area with transient combustibles stored in the area. Licensee issued AR 4710362 to capture the issue and removed the combustible materials Corrective Actions: Licensee removed the associated transient combustibles from the areas when identified on October 17, 2023 and October 19, 2023. Licensees corrective action for the October 19 transient combustibles included performing a human performance review board.

Additionally, on October 19, 2023, Standing Order 23-13, was issued requiring restricted access to TCEZs, the logging of all transient combustibles into TCEZs, and a supervisor to perform an independent walkdown of the area following the removal of transient combustibles.

Corrective Action

References:

AR 4711095, AR 4710362 Description On October 17, 2023, during a walkdown of the Unit 1, service water pump room (fire area 39), the inspector transient combustibles stored in an unauthorized area. OP-AA-201-009, Control of Transient Combustible Material, Revision 29, step 4.4.1.5, states that combustible material should not be stored Corrective Action

References:

AR 4711095, AR 4710362

Updated Information Regarding Documentation of Findings Current Revised Performance Assessment:

Performance Deficiency: The inspectors determined that Licensees failure to implement OP-AA-201-009 for the control of transient combustibles was a performance deficiency. Specifically Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP.

The finding screened Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations Performance Assessment:

Performance Deficiency: The inspectors determined that Licensees did not properly implement OP-AA-201-009 for the control of transient combustibles.

Significance Determination: IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP.

Cross-Cutting Aspect: H.2 - Field Presence

Updated Information Regarding Documentation of Findings Current Revised Enforcement:

Violation: Unit 1, Renewed Facility Operating License for Licensee Nuclear Power Plant, Condition 2.E., requires, in part, that Licensee implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the License Amendment Request, dated September 24, 2013, and as approved in the NRC Safety Evaluation, dated August 30, 2016.

NRC Safety Evaluation, dated August 30, 2016, stated Contrary to the above, on October 17, 2023 and October 19, 2023, Constellation failed to control transient combustible materials by OP-AA-201-009.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Enforcement Violation: On October 17 and October 19, 2023, the Licensee failed to control transient combustible materials by OP-AA-201-009 as required, in part, by Condition 2.E of the Operating License for Licensee Nuclear Power Plant.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Radiation Protection Inspection Program Update David Garmon, Health Physicist david.garmon-candelaria@nrc.gov Radiaon Protecon and Consequence Branch Division of Risk Assessment Oce of Nuclear Reactor Regulaon November 19, 2025

Radiation Protection Inspection Program Updates

  • Agenda (20 minutes)
  • Updates to the inspection procedures used to assess performance in the occupational and public radiation safety cornerstones
  • Revisions to SDPs methodologies
  • Addition of more-than-minor (MTM) screening guidance
  • Drivers for Change
  • Program-wide initiatives
  • Executive orders
  • Inspection program feedback

Radiation Protection Inspection Program Updates continued

  • Overview of Changes Note - these draft changes are subject to revision as they are finalized
  • Inspection
  • ~30% reduction in planned inspection effort (previous annualized minimum/maximum: 101/130 hours is now 70/86 hours)
  • New inspection procedures (outage procedure and onsite/remote inspections)reduces number of site visits during an inspection cycle
  • Selected changes to inspection guidance (e.g., ALARA, Part 37 etc.)
  • Consideration of current licensee information to modulate inspection effort
  • Gradual adoption of this approachstarting with currently identified situational inspections
  • MTM guidance/threshold

Radiation Protection Inspection Program Updates continued Inspection Procedures

  • IP 71125 - Radiation Safety - Public and Occupational
  • General inspection guidance but contains no inspection requirements
  • IP 71125.01 - Radiological Performance - Refueling Outage
  • IP 71125.02 - Radiological Performance - Remote Inspection
  • Triennial Frequency except for outage inspection (IP 71125.01)

IP 71125.01 - Radiological Performance - Refueling Outages

  • Inspections should be performed during a refueling outage. When appropriately risk-informed samples are not available for inspection follow completion guidance of IMC 0306 section 06.08.f.3.

Radiation Protection Inspection Program Updates continued Requirement language largely unchanged (few exceptions).

Current requirements were established following significant staff effort during the previous revision.

Risk-informed, performance-based inspection. Refueling outages are the periods of most radiological risk at a nuclear facility. No additional inspections will be done during outages.

  • IP 71125.02 - Radiological Performance - Remote Inspection Radiation Protection Inspection Program Updates continued
  • When appropriately risk-informed samples are not available for inspection follow completion guidance of IMC 0306 section 06.08.f.3.

03.08 - Clarify intent of this inspection requirement is to verify the industry continues to implement the Groundwater Protection Initiative (see SECY 11-019 and Commissioners Assistants Note ML12347A290.

Radiation Protection Inspection Program Updates continued

  • IP 71125.04 - Public Radiation Safety On-Site Inspection Radiation Protection Inspection Program Updates continued 03.01 - High-range effluent monitoring inspection guidance modified to remove inspection of emergency action level (EAL) calculation (Emergency Preparedness Cornerstone item) 03.04 - Part 37-related inspection guidance revised Emphasize inspection of material that located outside of the Protected Area; Point to Interim Enforcement Policy (IEP, 89 FR 68083);

Specifically exclude items already covered by Enforcement Guidance Memorandum (EGM) 2014-001/IEP unless significant changes that would necessitate reconsideration of the existing enforcement discretion occurred; No longer review the annual access authorization program review, instead discuss performance with licensee staff 03.06 - Non-excepted package shipments can be inspected either through observation or record review

  • SDP Revisions - IMC 0609, Appendix C Radiation Protection Inspection Program Updates continued Revised Occupational SDP Flowchart More-than-Minor Screening Criteria

Radiation Protection Inspection Program Updates continued More-than-Minor Screening Criteria Revised Public SDP (Fig 1) Flowchart Green 10 mrem MTM Threshold White 100 mrem Public Dose Limit Yellow 500 mrem Red 1,000 mrem Consistent with Enforcement Policy Dose-Based Thresholds

Update on the Differing Professional Opinions Process Gladys Figueroa-Toledo Senior Project Manager Concerns Resolution Branch Office of Enforcement

Performance Indicator Discussion and Next Steps Nuclear Energy Institute

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

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

October November 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 December 2025 Inspector Training on Revised Documentation of Green Findings and Refresher on 2025 ROP Revisions January 2026 Inspector Training on Revised ROP Baseline Inspection Program and Finding Screening More-than-Minor Critieria January 29, 2026 ROP Bi-Monthly Meeting January 1, 2026 After Commission SECY SRM Issue Revised IPs for the Baseline Inspection Program go into effect (pending Commission approval of Revised ROP)

Completion of 2025 ROP Baseline Inspection Program Guidance

  • Acting DRO Director will discuss the guidance.

Baseline Inspection Program Transition in 2026

  • Resident Inspector Baseline IPs: Resident inspectors should complete ROP inspection activities using currently approved inspection procedures (IPs) at the minimum sample size. The limited exceptions include IP 71111.06, Flood Protection Measures; IP 71111.07, Heat Exchanger/Sink Performance; IP 71111.12, Maintenance Effectiveness; and IP 71111.18, Plant Modifications; and IP 71151, Performance Indicator Verification.
  • PI&R Inspection: All scheduled biennial problem identification and resolution (PI&R) team inspections should be deferred for the first half of the calendar year 2026. If the Commission does not approve moving the biennial PI&R team inspection into inspection manual chapter (IMC) 2515, Light Water Reactor Inspection Program Operations Phase, Appendix C, Special and Infrequently Performed Inspections, the biennial PI&R team inspections should be rescheduled and conducted after July 1, 2026 using the currently approved IP 71152, Problem Identification and Resolution (PI&R).

Baseline Inspection Program Transition in 2026

  • Engineering Inspection: All engineering inspection activities planned in calendar year 2026 should be completed as scheduled using the currently approved engineering inspection procedures. For licensees that have a Comprehensive Engineering Team Inspection (CETI) scheduled, the Regions should reduce the inspection scope to three inspectors and complete as many inspection samples as possible with a goal of completing the minimum inspection effort. If the minimum CETI inspection size is not met at a site and the Commission does not approve the proposed revised engineering inspection program, schedule the remaining CETI engineering inspection activities for completion in Calendar Year 2026.
  • Security Inspection Program: With the exception of IP 71130.03, Contingency Response - Force-on-Force testing and IP 71130.10, Cybersecurity, reschedule all first quarter 2026 security inspections for the second quarter of 2026 or later, if possible or unless a licensee specifically requests the IPs be conducted in the first quarter 2026. If the Commission does not approve the proposed revised security inspection program by April 1, 2026, use the currently approved security IPs for the remainder of the calendar year.

Baseline Inspection Program Transition in 2026

  • Emergency Preparedness (EP) Inspection Program: EP IPs should be implemented as scheduled and written. If desired, Regions may defer IP 71114.06, Drill Evaluation, until after July 1, 2026. If the Commission does not approve the proposed EP program, resident inspectors can complete the required IP 71114.06 inspection samples during the 2nd half of calendar year 2026.
  • Radiation Protection Inspection Program: Radiation protection (RP) IPs should be implemented as scheduled and written, with the following additional guidance:
  • Prioritize completion of IP 71124.01, Radiological Hazard Assessment and Exposure Controls, during refueling outages.
  • For the following two IPs, during inspection preparation, if a risk-informed inspection sample is not available for inspection, that inspection requirement should be marked complete per Section 06.08 paragraph f.3 of IMC 0306, Planning, Scheduling, Tracking and Reporting of the Reactor Oversight Process (ROP) and the scope and duration of the inspection is to be reduced commensurately:

IP 71124.04, Occupational Dose Assessment sections 03.03, and 03.04 IP 71124.06, Radioactive Gaseous and Liquid Effluent Treatment section 03.04

  • If desired, the following three IPs can be performed remotely:

IP 71124.04, Occupational Dose Assessment sections 03.01, 03.03, and 03.04 IP 71124.06, Radioactive Gaseous and Liquid Effluent Treatment Occupational sections 03.02, 03.03, and 03.04 IP 71124.07, Radiological Environmental Monitoring Program sections 03.02, and 03.03

  • For IP 71124.08, Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Requirement section 03.04, if an inspection sample is not available for assessment during the inspection, then the requirement shall be marked complete per IMC 0306, Section 06.08 paragraph f.4.

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

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