The NRC recently approved the most substantial revisions to the Reactor Oversight Process (ROP) since its April 1, 2000 implementation. In SRM-SECY-26-0014, the Commission approved revisions to the ROP’s baseline inspection program and the inspection finding screening process applicable to the current fleet of large, light-water power reactors. In SRM-SECY-26-0015, the Commission approved revisions to the security baseline inspection program, including the force-on-force inspection program. The revisions reflect an approximately 38% reduction in safety inspection resources and 50% reduction in security inspection resources.
As a general matter, the safety performance of the current US operating fleet is high; that performance is owed to many contributors. Nuclear plant operators are fundamentally responsible for their performance. Nongovernmental industry organizations, including the Institute of Nuclear Power Operations, also serve to enhance the safety, reliability, and operational performance of the fleet, independent of the NRC’s oversight activities.
The NRC’s oversight process is another important component. As observed by Chairman Nieh in his vote on the matter, “[t]he ROP is a living program that can be adjusted accordingly based on staff self-assessment activities and trends in licensee safety performance.”
As described in the staff’s recommendations to the Commission, the NRC is retaining the three existing strategic performance areas and seven associated safety cornerstones as well as the basic “inspectable areas” originally identified as areas warranting NRC oversight. And the revisions reflect the NRC’s foundational assumption that it will continue to station at least two resident inspectors at every operating reactor.
The agency considered trends in licensee performance and conducted a comprehensive review of inspection findings, scrams, performance indicator data, and accident sequence precursor events since the ROP’s implementation. The staff also acknowledged a shift that it made in 2025 that has reduced inspection hours by guiding inspectors to complete the “minimum” number of samples per inspection procedure instead of a “nominal” number between the minimum and maximum numbers.
With this background in mind, the Commission approved the following key revisions to the baseline inspection program:
- Reactor Safety Inspection Program – Resident Inspector Baseline Inspections: The NRC eliminated five inspection procedures (IPs), with their risk-significant attributes or requirements shifted into other IPs. The eliminated IPs have not identified many performance issues. Eight IPs were retained, either unchanged or with minor updates. Because these changes result in a net reduction in inspection hours, the resident inspectors will support engineering inspections and serve as surge capacity for broader ROP activities.
- Reactor Safety Inspection Program – Engineering Baseline Inspections: Recognizing the shift in engineering inspections from confirming compliance with the original design bases to evaluating the maintenance of risk-significant equipment consistent with design and operational requirements, the staff recommended that the IPs governing the Comprehensive Engineering Team Inspection (CETI) and Focused Engineering Inspections be combined into a single CETI that would be conducted annually. The proposal would reduce annualized engineering inspection hours from 280 to 175. The Commission (at the behest of Chairman Nieh, as reflected in his vote) approved the revised inspection, to be conducted every three years. The Chairman observed that engineering work products can be effectively sampled through other baseline IPs as needed. The Commission directed the staff to conduct an effectiveness review 24 months after implementation of the new engineering inspection program.
- Reactor Safety Inspection Program – Licensed Operator Requalification Baseline Inspections: Approved changes to the IP include a reduction in scope of the biennial inspection focused on the licensed operator requalification review.
- Emergency Preparedness Inspection Program: The Commission approved two key changes: first, performance of three IPs (addressing drill evaluation, emergency action levels and emergency plan changes, and maintenance of emergency preparedness, respectively) on a biennial, instead of annual, frequency; and second, incorporation of the consideration of fleet performance into applicable IPs (that is, where activities have been centralized at the fleet level, they need only be inspected once during the inspection period).
- Radiation Protection Inspection Program: The Commission approved reducing the radiation protection inspection program from seven to four IPs. One IP will be conducted during each outage, focusing on radiologically significant outage work; the other three triennial IPs will be sequenced to inspect certain aspects of the radiation protection program nominally once a year. One of the triennial IPs will be designed to be conducted remotely, thereby permitting a reduction in on-site inspection sampling and reducing regulatory burden in areas where inspection relies on document reviews and data verification (e.g., internal dosimetry, source term characterization).
- Problem Identification and Resolution (PI&R) Inspection Program: Observing that the highest number of inspection findings were identified under the PI&R procedure, the staff recommended that all inspection attributes of the biennial PI&R team inspection be consolidated into the PI&R annual samples. Recognizing that an effective PI&R program is key to licensee performance in all cornerstone areas, the Commission approved maintaining the PI&R team inspection, but shifting it to a triennial frequency, reducing the team size from four to two members, and narrowing the scope of the inspection to licensee corrective action programs. The Commission also approved changes to inspection finding screening criteria. The staff has used so-called “more than minor” screening criteria to determine if an inspection issue is “more than minor” and warrants documentation in an inspection report. The Commission approved revisions to the screening criteria to reduce subjectivity, improve consistency, and better align enforcement actions with their actual impact to public health and safety. As the NRC acknowledges, this change will mean fewer documented findings of very low safety significance—and fewer resources expended on low-safety-significance issues.
Recognizing that regional staffing will be significantly affected by the changes, the Commission directed the staff to develop a strategy for expanding the skillsets of regional inspection staff to enable their deployment across NRC licensing programs “as the agency’s resource focus shifts from oversight to licensing,” consistent with the administration’s restructuring directive in EO 14300, Ordering the Reform of the Nuclear Regulatory Commission. While not specifically stated in SRM-26-0014, because IPs will require revision we expect changes to be implemented in the next baseline inspection cycle.
For security baseline inspections, the Commission approved the staff’s recommendations in SECY-26-0015 as follows:
- Eight of 11 security IPs will be replaced with two new annual IPs addressing security operations and security performance. The new inspections will focus on risk-significant activities and programs, with an emphasis on observing licensee security performance.
- The material control and accounting IP will be retained as a new procedure, to be performed “as needed” instead of on a triennial basis. The procedure would be implemented if predefined criteria associated with special nuclear handling or fuel reconstitution activities are met.
- Cybersecurity inspections will be retained but performed on a triennial, instead of biennial, basis. The agency seeks to reduce its reliance on contractor support for cybersecurity inspections; the Commission also directed the staff to assess its ability to transition cybersecurity inspection support functions in-house by the start of the next triennial inspection cycle in 2029.
Force-on-force (FOF) inspections are governed by Section 170D of the Atomic Energy Act of 1954, as amended. The provision calls for security evaluations that include FOF exercises “not less often than every 3 years.” FOF exercises shall, “to the maximum extent practicable, simulate security threats in accordance with any design basis threat applicable to the facility.” For the current triennial NRC-conducted inspection cycle, the Commission approved one exercise per inspection.
The Commission also approved allowing licensees, at their option, to have an increased role in scenario development. The NRC will identify target sets and attack vectors and select the design-basis threat attributes; the licensee will then use these inputs to develop the exercise scenario, mission narrative, and exercise controller matrix, subject to NRC review. Finally, the Commission approved changing how exercise outcomes are characterized to focus the inspection on overall readiness, continuous learning, and correction of weaknesses.
After the current triennial cycle, the NRC will transition to observing and inspecting a single licensee-conducted exercise. By June 2028 (prior to the transition), the staff will provide a paper to the Commission describing its plan, and it will engage stakeholders during the transition period to identify and mitigate any unintended consequences or burdens of moving away from the current NRC-provided equipment and mock adversary forces. As with the safety inspection staff, the professional security staff will be provided developmental pathways beyond the security oversight program.
As a whole, these revisions are part of an ongoing effort begun in earnest in 2024 following passage of the ADVANCE Act. Section 507 of the ADVANCE Act directed the NRC to submit a report to Congress identifying improvements for nuclear reactor and materials oversight and inspection programs. Shortly thereafter, Section 5(g) of EO 14300 directed the NRC to “[r]evise the Reactor Oversight Process . . . to reduce unnecessary burdens and be responsive to credible risks.”
The report submitted by the NRC to Congress in July 2025 outlined a number of proposed changes that required Commission approval, and others within the staff’s authority that were implemented, following Commission notification, as of July 1, 2025.
Early this year, the Commission approved three smaller program revisions:
- Revising the treatment of licensee-identified “White” inspection findings (that is, findings of low-to-moderate safety or security significance) such that they will not be Action Matrix inputs but would still be closed out through follow-up inspection; this change is intended to incentivize licensee identification of White findings
- Revising the Action Matrix (the ROP’s risk-informed framework that links plant performance to NRC oversight actions) criteria so that multiple White Action Matrix inputs in Column 2 do not aggregate to result in assessment in Column 3; this change better aligns White findings to their safety and security significance
- Revising the Agency Action Review Meeting (AARM) Commission meeting requirements to only conduct a standalone AARM Commission meeting when a licensee meets certain criteria (this meeting was held annually for many years)
Looking Ahead
Further revision to the ROP may be forthcoming. The staff observed in SECY-26-0014 that additional recommendations for revising the ROP may be submitted in the future as the staff continues its work to address Section 5(g). The advanced reactor oversight program, for example, remains under development; as briefly acknowledged by the staff in SECY-26-0014, that oversight may look significantly different, e.g., resident inspectors may not be needed for next-generation reactors.
Importantly, future revisions to the ROP will be in the hands of the staff. In response to SECY-25-0045, the Commission directed the staff to modify its internal ROP guidance to make clear that ROP changes currently requiring Commission approval will in the future be information items communicated via either Commissioners’ Assistants notes (which are not always publicly released) or Information Paper.
This decision reflects the Commission’s determination that future ROP revisions are no longer matters of policy, unless a majority of the Commission determines that a particular planned staff revision warrants conversion to a policy matter. Acknowledging this decision, the Commission directed the staff, in response to both SECY-26-0014 and SECY-26-0015, to adjust the ROP as needed going forward. Adjustments on an as-needed basis will ensure that the ROP remains an effective risk-informed, performance-based oversight process.
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