Reactor Oversight Process Initial Implementation Evaluation Panel

The IIEP has concluded that the ROP is a notable improvement over the previous licensee performance assessment program and should be continued. The reactor oversight process has made progress toward achieving the Agency's four performance goals: 1) maintain safety, 2) increase public confidence, 3) increase regulatory effectiveness and efficiency, and 4) reduce unnecessary regulatory burden. In addition, the process provides a more objective, risk-informed, predictable, and understandable approach to the oversight of commercial nuclear reactor facilities. The NRC and the nuclear industry expended substantial time and effort communicating with their staff members and public stakeholders about the process changes and paradigm shifts embodied in the ROP. Although the change-management tools used to communicate and carry out the changes were generally successful, the panel identified continuing tension as a result of three changes in regulatory philosophy: maintaining safety rather than improving safety, applying risk-informed regulation rather than deterministic regulation, and using indicative measures of performance rather than predictive measures of performance. To a large extent, stakeholder concern with these regulatory changes are common denominators for the various issues identified by the panel. The tension created by these underlying changes has affected the degree to which the performance goals of the ROP can ever be fully achieved according to various stakeholders' perspectives about what constitutes a successful oversight process. On the other hand, it is this tension that helps to ensure that the NRC, the industry, and public stakeholders will continue to engage in creative dialogue focused on the safe operations of nuclear power reactors. The panel considers the interaction among stakeholders throughout the development process, and going forward, to be an important feature of the ROP. Continued management attention is needed to sustain genuine and substantive interaction among stakeholders, mindful of the challenges and creative potential inherent in the tensions of the complex nuclear regulatory environment. An ancillary common concern raised by the panel members in evaluating the specific issues discussed in the report is the continuing need for sufficient resources to maintain the formal processes and infrastructure for the ROP. NRC resources are needed to evaluate, pilot, communicate, and implement future enhancements and ensure regional consistency. Although the staff has learned many lessons from the first year's implementation and has already made numerous changes, there are many issues to be resolved and still other issues to be discovered as the ROP continues to evolve. The many issues regarding the significance …