ML25230A048

ROP Rebaselining August 20 Public Meeting Presentation

ML25230A048
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Issue date:	08/18/2025
From:	Geary D NRC/NRR/DRO/IRAB
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Public Meeting: Proposed Revision of the ROP Baseline Inspection Program August 20, 2025 Revision of the ROP Baseline Inspection Program

Opening Remarks Philip McKenna Acting Director Division of Reactor Oversight (DRO)

Recap of Ongoing Actions from the ADVANCE Act Section 507

Purpose, Outcome, Plan Purpose of the Presentation

• To discuss proposed revisions to the ROP Baseline Inspection Program.

Desired Outcome

• Communicate proposed revisions and implementation timeline to industry and members of the public.

Agenda 1.

Scope of Review and Background 2.

Recommended Changes 3.

Resource Impact & FTE Savings 4.

Timeline & Next Steps 5.

Q&A / Discussion

Scope of Review and Background These changes represent an evolutionary step, building on nearly 25 years of experience with the Reactor Oversight Process (ROP).

The aim is to eliminate redundant, low value inspection activities, allowing the ROP to more efficiently reflect plant operational performance.

These changes will need Commission approval before implementation can occur (targeted for January 1, 2026)

The proposed revisions to the ROP Baseline Inspection Program were informed by past ROP Enhancement work, ADVANCE Act Section 507 work, and survey responses and inputs from ~200 inspectors and staff across the agency

ROP Baseline Inspection Procedure Changes

Summary of Resident Inspector ROP Baseline Inspection Program Proposed Changes IP Action IP IP samples/hours reduced (by 10-50%

depending on the IP) 71111.04, Equipment Alignment 71111.05, Fire Protection 71111.08, Inservice Inspection Activities 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance 71111.13, Maintenance Risk Assessments and Emergent Work Control 71111.24, Testing and Maintenance of Equipment Important to Risk 71153, Followup of Events and Notices of Enforcement Discretion IPs Eliminated 71111.06, Flood Protection Measures (attributes shifted to.01 and.04) 71111.07, Heat Exchanger/Sink Performance (attributes shifted to.04) 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 PI&R, or other IPs)

IPs Unchanged (sample size already shifted to minimum samples) 71111.01, Adverse Weather Protection 71111.15, Operability Determinations and Functionality Assessments 71111.20, Refueling and Other Outage Activities

ROP Baseline Inspection Procedure Changes IP 71111.01, Adverse Weather

• No change to requirements or guidance based upon operating experience and potential risk significance for several sites. Will add flood protection attributes to procedure.

• Samples will remain at one for severe weather and one for seasonal readiness IP 71111.04, Equipment Alignment

• No substantial change to requirements or guidance due to risk significance. Will add flood protection and heat exchanger attributes to procedure.

• Sample range reduced from 10-14 to 8-12, and one complete walkdown.

IP 71111.05, Fire Protection

• No substantial change to requirements or guidance due to potential risk significance.

• Will revise inspection guidance to recommend that where possible, perform this inspection with the equipment walkdown procedure IP 7111.04 which is already a practice performed by some inspectors.

• Sample range reduced from 16-24 to 12-20

• Fire brigade inspection minimum samples reduced to one. Option allowed to conduct two, if needed, to assess brigade performance.

IP 71111.06, Flood Protection Measures

• Sample attributes absorbed into IP 71111.01 and IP 71111.04

• IP sunset-Bases - Redundant activity to the walkdown procedures IP 71111.01 and IP 71111.04.

IP 71111.07, Heat Exchanger/Sink Performance

• Sample attributes absorbed into 71111.04 and 71111.24.

• IP sunset-Basis - Industry Operating Experience indicates licensee heat exchanger/sink programs are mature/inspector feedback.

ROP Baseline Inspection Procedure Changes IP 71111.08, Inservice Inspection

• Minor enhancement only

• Boric Acid Corrosion review reduced from 10 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

• Remainder of ISI activities maintained due to high risk IP 71111.12, Maintenance Effectiveness

• Sample attributes and requirements will be absorbed into IP 71111.24.

• IP sunset-Bases - Redundant activity to IP 71111.24.

IP 71111.13, Maintenance Risk Assessments and Emergent Work Control

• Slight reduction in sample size - to reflect industry experience regarding risk management activities.

• Inspection activity added-PRA configuration control as an inspection element.

• Bases - The sample addition was the original plan based upon recommendations from the PRA Configuration Control Working Group.

IP 71111.15, Operability Evaluations

• No change to requirements or guidance based upon operating experience and inspector feedback P 71111.18, Plant Modifications

• Sample attributes absorbed into IP 71111.04, IP 71111.11 and new engineering inspection IP

• IP sunset-Bases - Redundant activities contained in IP 71111.04, 71111.11 and engineering inspection program

ROP Baseline Inspection Procedure Changes IP 71111.20, Refueling and Other Outage Activities

• No substantial change to requirements or guidance.

IP 71111.24, Testing and Maintenance of Equipment Important to Risk

• Inspection guidance will be enhanced to include attributes from IP 71111.12.

IP 711151, Performance Indicators

• Reduced verification absorbed into proposed IP 71152 PI&R, plant status

• IP sunset-Bases - No substantial issues identified since commencement of the ROP/inspector feedback IP 71153, Followup of Events and Notices of Enforcement Discretion

• Reduced level of effort based on clarifications on when to shift from using IP 71153 to another baseline IP to inspect the corrective actions as a result of the event and clarification that if an event has already been inspected under a different IP the event should not be re-inspected using IP 71153

Engineering Inspection Changes Option 1, Shift to Annual Cycle

• 2 Engineering inspections per year, each inspection team has 2 inspectors.

• Inspection 1-Engineering Work Product

• Inspection 2-Risk Significant Components

• Overall reduction is 50% (280 hrs/yr to 140 hrs/yr)

Option 2, Maintain the current 4-year cycle for CETI and FEIs

• Reduce CETI team size to 5 inspectors by:

• Removing 50.59 screenings from CETI scope.

• Shifting those samples to resident inspectors.

• Reduce FEIs to 2 per cycle (would change if include cyber as FEI)

• Overall reduction with shift to min samples is 41% (280 hrs/yr to 165 hrs/yr)

Option 3, Shift to Annual Cycle, but retain format that allows for in-depth reviews

• 1 two-week Engineering inspection per year, with the inspection having on average 2.5 inspectors

• Samples will be flexible based on licensee current performance

• Allows for detailed inspection of components if necessary

• Overall reduction is 37% (280 hrs/yr to 175 hrs/yr)

Possible PI&R Inspection Changes Option 1, Move IP 71152B to Appendix C

• Move sample from 71152 Team Inspection as possible samples for the annual 71152 samples:

o Possible sample will include licensee audits and self assessments, licensee use of operating experience, 5-year review, SCWE, and open CAPRs

• Overall assessment of program using team inspection inputs

• Development of objective criteria for implementation of team inspection

• Estimated resource savings (~45%) (219 hours0.00253 days <br />0.0608 hours <br />3.621032e-4 weeks <br />8.33295e-5 months <br /> to 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />)

Possible PI&R Inspection Changes Option 2, Shift PI&R to a 4-year inspection cycle

• Maintain a 4-person team including support from resident inspector

• Introduce a small-scale PI&R inspection that can be upsized based on performance

• Deep dive into aspects of the licensees CAP program

• Inspection can be performed by any fully qualified inspector (preferably a resident inspector during their objectivity visit for KM purposes)

• Estimated resource savings (~41%)

Possible PI&R Inspection Changes Option 3, Shift PI&R team inspection to Triennial

• Team inspection performed on triennial frequency (Initial proposal that was made in 2019)

• Increase annual follow-up samples

• No longer distinguish between 1-, 2-, and 3-unit sites

• Estimated resource savings (~17%)

Licensed Operator Inspection Changes Change 2: For.11Q observations performed by residents: eliminate control room samples and reduce number of training/operating test samples by 50%

o Observations of operator performance in control room happen regardless of this IP; add an option for observing significant evolutions as available oReduce training/exam observations to semi-annual and eliminate need to watch classroom training Change 3: Keep.11B team at 2, but pair one resident inspector with one regional examiner oOL examiner inspects simulator performance, license conditions, written exam and operating test quality oResident inspector performs aspects of the 11B inspection not designated for OL examiner qualified inspector oOL Examiner: 60 +/- 8 hrs, Resident Inspector: 20 +/-4 hrs Change 4: Reduce scope of the.11B inspection of the requalification program o Reductions in observations and quality reviews for simulator scenarios and JPMs, written examination questions and inspections of medical records and other license conditions and simulator performance Reduce 96-hour range for.11B to match actual avg of 80 hrs Change 1

NRR/DRA - Radiation Protection Changes Recommendation

• Priorities oRevise IPs to better risk-inform program oIncentivize adequate licensee response activities through the application of select low-level data oReduce overall regulatory burden on licensees

• Reduce from 7 procedures to 4 (Outage Procedure, 2x On-site procedures and 1x Remote)

• Triennial cycle (assumed 1 RFO per 12 months for hours calculation; however, frequency will be similar to IP 71111.20)

• Some inspection requirements can be modulated based on licensee performance as determined by data/information sets defined in the IP. IPs will provide Region with decisionmaking tools to ensure consistent outcome in evaluating and applying low-level data

• Outage procedure oHighest radiological risk period at plant

NSIR - Security Changes Recommendation: Revise Baseline Security Inspection Program

• Revise IPs to refocus from verifications of compliance with individual regulatory requirements to verifications of licensee performance and compliance with the general performance objectives of 10 CFR 73.55

• Replace existing 11 IPs with 7 focused inspections grouped by common inspection objectives.

o Security Performance and Problem Identification and Resolution o Access Authorization and Fitness for Duty o Security Equipment and Training o Protective Strategy and Target Sets o Cybersecurity o Material Control and Accounting o Force-on-Force

NSIR - Security Changes Recommendation: Revise Baseline Security Inspection Program

• Security inspections will be triennial, except for Security Performance and Problem Identification and Resolution which will remain annual.

• Resident inspectors will be utilized as limited inspection team members to complete inspection requirements that do not require significant additional training. Examples include:

o Review of licensee Target Sets and exercise observation during the protective strategy inspection.

o Verification of testing and maintenance of licensee security power supplies during the security equipment inspection.

• Cybersecurity and Material Control and Accounting will remain within the security suite of inspections but will continue to be performed by regional engineering or resident inspection staff.

NSIR - Emergency Preparedness Changes IP 71114.06 (NRC Resident EP evaluations) o Added more sample options, this has been a recurring issue.

o Frequency change from annual to biennial and scheduled for the off-year, i.e., the year between EP exercises.

IP 71114.02, 71114.03, 71114.04, 71114.05 o Schedule for the off-year, i.e., the year between EP exercises.

o All changes could follow the remote inspection guidance in IM 2515 (note that 71114.08 is already remote).

IP 71114.04 o Frequency change from annual to biennial and scheduled for the off-year, i.e., the year between EP exercises.

PI&R o Remove EP from PI&R as this is being done already during the EP baseline inspections and is redundant.

EP SDP o Revise to focus GTG inspection findings on only those planning standards with direct public impact.

o Revise to enhance the section on dose assessment/radiation instrument issues based on experience and feedback.

NSIR - GOAL of Emergency Preparedness Changes To have 1 year with an EP exercise o Will include detail about team expectations and qualifications as well as direction for how to do this inspection better.

o Expected to save about 10-20 % of time, particularly with inexperienced inspectors.

To have baseline inspections during the off-year o Everything but the exercise, can be done remotely.

o Expected to save a significant amount of time with not needing to travel.

o Regions are very inconsistent in this area, but it is expected that this will result in significant savings (time and FTE).

To have a risk-informed EP SDP o The enhancements to the (b)(9), dose assessment, is expected to save ~10% as well if rad instruments or dose assessment issues occur.

o Currently these take quite a bit of time and FTE.

Overview of Reductions and Impacts

Possible Activities Transferred to Resident Inspectors (to account for the decrease in RI baseline inspection hours) 2 Resident Inspectors maintained per site

• Resident inspector baseline reducon me will be "lled with team inspecons and/or other program inspecon shis Engineering

• Possible participation in annual Engineering inspection Licensed Operator Requalification

• Possibly pair with an OL examiner to complete portions of biannual licensed operator requal inspection NSIR-Security

• Resident inspectors can participate as limited team members on security inspections to perform inspections that require limited additional training o Protective Strategy and Target Set Review: ~10 hours for exercise observation and target set review o Security Equipment: ~2 hours for security backup power if sample is selected by the team

• Other security suite inspections, MC&A and cybersecurity, can be performed by resident inspectors after adequate training NSIR-EP

• Resident inspectors can already participate as EP exercise evaluators for IP 71114.01 and IP 71114.07 (HAB). No additional activities proposed to be transferred to the resident inspectors.

NMSS - ISFSI

• Assist on ISFSI inspection

Possible Overall Impact NSIR New Min Hours Min Hours Nom Hours New Max Hours Max Hours Physical and Cyber Security 155 256.5 287.7 180.3 321.5 EP Hours 73 105.5 144 122 191.5 Total 228 362 432 302 513 NRR New Min Hours Min Hours Nom Hours New Max Hours Max Hours Resident Inspection hours*

764 875 1023 926 1150 Engineering Hours (preferred option) 175 238 280 161 322 RP Hours 71 101 116 78 130 PIR team inspection (preferred option) 0 106 125 0

144 ISI inspectors 33 35 36 42 51 Ops examiners 32.5 40.5 48 47.5 55.5 Total 1076 1396 1628 1231.5 1852.5 NRR reductions 34%

NSIR reductions 47%

Overall reductions 36%

NRR Calculation Details Baseline inspection hours per site drop from 1,628 (current nominal) to 1,076 (updated min) (34%)

Agency-wide resource savings = 29 FTE Nominal inspection hours per site in January 2025 = 1,628 hours0.00727 days <br />0.174 hours <br />0.00104 weeks <br />2.38954e-4 months <br /> New minimum hours = 1,076 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> (1,628 - 1,076)/1,628= 36%

1500 hour0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />s/FTE includes 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of direct inspection 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of indirect inspection (1,628hours - 1,076hours)*53 sites/1000 hrs/FTE = 29 FTE

• Resident inspection hours do not include Plant Status, and was based on a dual unit site, BWR

Timeline and Next Steps Date Milestone Aug 20 Public Meeting to discuss Options for the Revised ROP Baseline Inspection Program Aug 25 EDO Alignment Meeting Aug 26 Draft SECY to DRO Director Sept 18 ROP Bimonthly Public Meeting Sept 19 Regional Administrators and Office Directors complete concurrence on draft SECY September thru December Development, Regional Review, and Issuance of Revised Inspection Manual Chapters (IMCs) and Inspection Procedures (IPs)

Oct 4 SECY to OEDO Oct 15 SECY to the Commission December Inspector training at December Inspector Counterpart Meetings Jan 1, 2026 Issued Revised IPs for the Baseline Inspection Program go into effect (pending Commission approval of Revised ROP)

Questions & Answers Discussion