NRC staff proposed to the Commission (see SECY-2019-067) certain changes to the Reactor Oversight Process (ROP) on June 28. Overall, these changes, if approved by the Commission, will result in a net reduction in the amount of time the NRC spends on planning and implementing certain inspections, and how it addresses the results of those inspections in the ROP. Proposed focus areas are as follows:
- Eliminate the minimum four-quarter requirement for consideration of greater-than-Green inspection findings
- Revise greater-than-Green–related performance indicator treatment
- Change the description of a White inspection finding from "low to moderate" safety significance to "low" safety significance, and change the description of a Yellow inspection finding from "substantial" to "moderate" safety significance
- Revise the sample sizes, which action is expected to reduce NRC inspection person-hours for several common inspections
- Revise the frequency of the Problem Identification & Reporting inspection from two three years
- Revise the Emergency Planning Significance Determination Process to focus more heavily on functions that have the greatest impact on public health and safety
The staff review identified several ROP changes that it believes require Commission approval, some enhancements that require Commission notification prior to implementation, and some actions that it believes can be implemented by the staff without Commission approval or advance notification. These conclusions are based on guidelines in Management Directive (MD) 8.13, "Reactor Oversight Process," dated January 16, 2018. Under MD 8.13, the proposed individual changes to inspection procedures generally require Commission notification, but not approval. However, the staff stated that it is seeking Commission approval beyond what would appear to be required because it considers these changes, when considered in the aggregate, to represent a significant modification of inspection-related policies.
In addition, the paper requests Commission approval to revise the enforcement policy to make conforming changes to the qualitative descriptions of White and Yellow inspection findings noted above.
The staff also noted in the paper that the staff widely agreed that the proposed changes are consistent with the NRC’s Principles of Good Regulation and will ensure that the ROP continues to provide appropriate oversight. However, we note that some external organizations have already questioned whether the proposed initiatives, if adopted, would go too far in decreasing the level of oversight via the NRC inspection process. We will continue to report on this matter as the Commission weighs the staff proposals and votes on any related inspection strategy modifications.