SECY-25-0045, Enclosure 1 - Items for Commission Notification
| ML25127A218 | |
| Person / Time | |
|---|---|
| Issue date: | 06/05/2025 |
| From: | NRC/SECY |
| To: | |
| Shared Package | |
| ML25127A212 | List: |
| References | |
| SECY-25-0045 | |
| Download: ML25127A218 (3) | |
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Enclosure 1 Items for Commission Notification The U.S. Nuclear Regulatory Commission (NRC) staff identified the following nine changes that require Commission notification per Management Directive (MD) 8.13, Reactor Oversight Process, before implementation. The level of effort required to implement each action, the estimated cost savings, the timeframe for implementation by calendar year (CY) and the plan for measuring effectiveness for each action is contained in Enclosure 4.
The staff is undertaking a comprehensive review of the Reactor Oversight Process (ROP) to maximize the efficiency of the program consistent with Section 507, Improving Oversight and Inspection Programs, of the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024, and Executive Order 14300, Ordering the Reform of the Nuclear Regulatory Commission. The staff plans to review all inspection procedures, starting with the baseline inspection program and then moving to the reactive and supplemental programs. This review will begin with a complete review of all ROP performance indicators (PIs) with the expectation that some PIs will be adjusted, others eliminated, and new PIs identified to enable reductions in certain inspectable areas. Following completion of the PI review, the staff will review all ROP baseline inspection procedures to validate, eliminate, and adjust inspection samples in a risk-informed, performance-based approach, ensuring that the inspection program complements the revised PIs and allowing the elimination of duplicative oversight activities. The scope of the review will also include the problem identification and resolution inspection program. The staff is also implementing immediate changes to the ROP to gain efficiencies before completing the comprehensive review.
The staff intends to revise guidance1 pertaining to the definition of licensee-identified allowing the staff to grant identification credit for findings resulting from a good questioning attitude by plant staff.
The staff intends to implement ROP team inspections in a hybrid format, with inspectors conducting a portion of the inspections from their respective regional office. During the onsite week, inspectors will perform system walkdowns, verify corrective actions, and hold interviews. The remaining week will be conducted remotely, focusing on document review, which can be completed remotely just as effectively as onsite. Inspection questions and responses can be transmitted and tracked electronically. Technology will be used to interview plant staff if clarification or additional information is needed. This remote approach will reduce travel expenses and allow more time for direct inspection. If any follow-up onsite inspection is required, a portion of the team may travel to the site to complete the inspection. This will reduce the amount of travel required to perform team inspections from 2 weeks onsite to 1 week onsite and 1 week remotely, while also addressing industry feedback on the impacts of onsite team inspections on licensee staff. This will not apply to the Comprehensive Engineering Team Inspection until the engineering inspection program effectiveness review is completed as part of the ROP re-baselining effort in CY 2026, with implementation of any revisions planned for the inspection cycle beginning in January 2027.
1 Inspection Manual Chapter (IMC) 0612, Issue Screening, dated August 9, 2023 (Agencywide Documents Access and Management System Accession No. ML23067A031).
E1-2 The staff intends to eliminate Inspection Procedure 927222 and Inspection Procedure 927233 traditional enforcement violation follow-up inspections and incorporate any relevant inspection guidance into the problem identification and resolution inspection program or Inspection Procedure 92702.4 In CY 2010, the staff revised program guidance to better integrate traditional enforcement outcomes into the assessment process.5 The staff revised IMC 03056 to allow follow-up inspection on all levels of traditional enforcement outcomes using an escalating approach based on the number of, severity level of, and similarities among the violations. Based on its review, the staff determined that these inspection procedures can be eliminated because they are duplicative, their implementation is subjective, and there is the potential for inconsistent application. Inspectors will address the follow-up of traditional enforcement violations using problem identification and resolution samples, including select issue follow-up and semiannual trend reviews, or through Inspection Procedure 92702, which is the procedure for follow-up on traditional enforcement actions. The level of problem identification and resolution review will be commensurate with the severity level and complexity of the associated traditional enforcement issue.
The staff intends to reduce the number of inspectors for the Comprehensive Engineering Team Inspection by one (from seven to six), adjusting the scope and sample requirements as appropriate. This inspection has a current inspection sample range of 19-38 samples with a resource estimate of 490 +/- 74 inspection hours. This change will reduce the sample range to 15-34 and resource estimate to 420 +/- 63 inspection hours and is being implemented to reflect the maturity of licensee engineering programs.
The staff intends to revise the frequency of security baseline Inspection Procedure 71130.077 from biennial to triennial and adjust the duration and staffing levels for these activities. This proposal is based on NRC inspector and licensee feedback, which generally indicated that the interval between inspections is insufficient to correct deficiencies. Conducting the inspections on a triennial periodicity would ensure that the staff and licensees have sufficient time and resources to appropriately address inspection issues and implement corrective actions, when needed.
The staff intends to expand the scope of the Very Low Safety Significance Issue Resolution process in all ROP guidance documents, allowing the staff the ability to discontinue inspection of any issue where it is unclear if a non-compliance exists, provided that the issue is of very low safety or security significance and give guidance on when management should be brought into the decision making process on continued work on the issue. Similar changes would also be made to guidance used by the other business lines. This change will ensure that low-level issues are processed in a timely 2
IP 92722, Follow-Up Inspection for Any Severity Level I or II Traditional Enforcement Violation or for Two or More Severity Level III Traditional Enforcement Violations in a 12-Month Period, dated September 16, 2021 (ML20261H375).
3 IP 92723, Follow-Up Inspection for One Severity Level III and Two Severity Level IV Traditional Enforcement Violations or for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, dated September 16, 2021 (ML20261H378).
4 IP 92702, Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders, dated October 26, 2020 (ML20139A160).
5 SECY-10-0042, Reactor Oversight Process Self-Assessment for Calendar Year 2009, dated April 7, 2010 (ML100550440).
6 IMC 0305, Operating Reactor Assessment Program, dated October 25, 2024 (ML24157A234).
7 IP 71130.07, Security Training, dated January 2, 2024 (ML23290A122).
E1-3 manner across all oversight programs, commensurate with their safety or security significance.
The staff intends to revise the frequency of the cybersecurity baseline inspections8 from biennial to triennial and adjust the duration and staffing levels for these activities. This change will also improve efficiency based on lessons learned from the implementation of the cybersecurity inspection program. Currently, cybersecurity inspections are conducted on a biennial basis, with the second cycle reaching completion in CY 2025.
The staff examined the lessons learned from these activities, including industry feedback, and is planning to implement these changes during the next cycle of inspections starting in CY 2026. The staff is also considering other opportunities to streamline cybersecurity inspections such as clarifying the information requested of licensees in guidance to support inspection activities so that only necessary information is being requested.
The staff intends to revise guidance for when to inspect above minimum samples in an inspection procedure. Currently, the NRCs inspection manual provides an expectation that the regions should normally complete a specified nominal (average) number of inspection samples between the minimum and maximum allowable samples identified in the inspection procedure.
8 IP 71130.10, Cybersecurity, dated December 14, 2021 (ML21271A106).