As approved by the Commission, COMSECY-16-0022 memorializes criteria that the NRC staff should use when determining whether Commission approval should be sought for certain types of changes to the ROP.
The Commission also approved criteria that NRC staff should apply when making changes to the ROP that do not require approval prior to implementation but still require Commission notification.
ROP changes that require prior Commission approval are the following:
- Changes to fundamental elements of the ROP framework—e.g., cornerstones, cross-cutting areas, assessment inputs
- Addition, deletion, or significant modification to oversight processes—e.g., cross-cutting issues process, significance determination process (SDP)
- Changes to ROP thresholds, including but not limited to SDP thresholds and performance indicator (PI) thresholds
- Changes to the number of inputs needed to make column changes in the Action Matrix
- Addition, deletion, or significant revision of PIs
- Specific ROP-related safety culture activities beyond communication and education
- Initiation of any pilot projects involving the items above
- Items specifically identified by the Commission
ROP changes that require only Commission notification (but not approval) are the following:
- Significant changes to the implementation of existing ROP programs—e.g., baseline and supplemental inspection procedures, implementation of the assessment program
- Changes to definitions affecting the Action Matrix other than threshold changes
- Addition, deletion, or significant revision of baseline inspections
- Initiation and completion of Temporary Instructions
These lists will now be incorporated into Management Directive 8.13, “Reactor Oversight Process.” Criterion 7 (initiation of any pilot projects) was added by the Commission in response to a comment from Commissioner Jeff Baran. NRC staff noted that Criterion 8 (items specifically identified by the Commission) was added to capture Commission precedent regarding the Safety Culture Policy Statement issued in 2011. In the Safety Culture Policy Statement, the Commission expressly stated that because the Safety Culture Policy Statement was not a regulation or requirement, “staff activities beyond communication and education should not be pursued without further specific Commission approval.”
These memorialized criteria hopefully will result in better consistency for more material changes to the ROP. We will continue to monitor NRC activities for further important developments in the ROP space.