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ROP Program Evaluations and Stakeholder Feedback

• Annual Self-Assessments
• Independent Evaluations
• Stakeholder Feedback

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Annual Self-Assessments

On February 24, 2000, the staff issued SECY-00-0049, "Results of the Revised Reactor Oversight Process Pilot Program". The resulting staff requirements memorandum (SRM), issued on March 28, 2000, approved initial implementation of the ROP as recommended by the staff. The initial implementation of the ROP began on April 2, 2000. In a followup SRM issued on May 17, 2000, the Commission directed the staff to report on the ROP results after the first year of implementation. The staff did so and documented the results in SECY-01-0114, "Results of the Initial Implementation of the New Reactor Oversight Process", issued June 25, 2001. SECY-01-0114 also noted the staff's intention to continue to perform an annual self-assessment of the ROP. Accordingly, the staff has issued an ROP self-assessment Commission paper each year before the Agency Action Review Meeting (AARM) and has briefed the Commission on the self-assessment results following the AARM.

The objectives and details of the ROP self-assessment program are contained in IMC 0307, "Reactor Oversight Process Self-Assessment Program". The annual ROP self-assessments are summarized in the table below.

Independent Evaluations

In addition to the ROP self-assessment program, several independent evaluations have been performed since the inception of the ROP to analyze its effectiveness and recommend improvements. Over the past several years, the Government Accountability Office (GAO), the Office of Management and Budget (OMB), the Office of the Inspector General (OIG), the Advisory Committee for Reactor Safeguards (ACRS), the Davis-Besse Lessons Learned Task Force (DBLLTF), and the SDP Task Group have all performed evaluations of the ROP. Early on, two evaluation panels performed detailed reviews of the pilot program and initial implementation of the ROP. These evaluations have generally provided favorable results, but have also suggested potential areas of improvement. Several recommendations from these independent evaluations have been incorporated into the ROP as detailed in the annual self-assessments above and staff responses below.

Stakeholder Feedback

External Surveys/Feedback

The staff has published a survey in a Federal Register notice each year since ROP implementation in 2000 to obtain external stakeholder input regarding ROP effectiveness. The annual surveys requested responses to questions corresponding to specific ROP performance metrics as defined in IMC 0307, and also provided an opportunity for open comments on the ROP that may not be directly captured by the specific questions. In an effort to actively solicit feedback on the implementation of the ROP, the staff (1) mails approximately 700 surveys directly to stakeholders, (2) places a direct link to the survey information on both the ROP Web page and the “Documents for Comment” page of the NRC’s external Web site, and (3) issues a press release and posted it on the NRC’s external Web site. In each year since 2002, the NRC acknowledged receipt of each survey response by correspondence indicating that the staff has considered and generally addressed the comments during the annual ROP self-assessment, as appropriate. However, the NRC received feedback in the CY 2004 survey indicating that it was unresponsive to survey comments and decided to consolidate the comments by question and provide a comprehensive response to each question in addition to the acknowledgment letters. The staff received positive feedback on the consolidated response from several stakeholders in the CY 2005 survey, and plans to continue this practice.

External feedback is also solicited through monthly public meetings, special meetings/workshops to discuss specific issues, public meetings in the vicinity of each operating reactor to discuss the results of the NRC's annual assessment of the licensee’s performance, and at the annual Regulatory Information Conference.

Internal Surveys/Feedback

Internal surveys are conducted on a biennial basis to solicit and analyze stakeholder feedback from NRC staff regarding the effectiveness of the ROP. All respondent replies are anonymous and each specific question has five possible answers/ratings. Many of the questions correspond to specific ROP performance metrics as defined in IMC 0307. The final each section of the survey provides space to expound or make additional comments. There have been four internal surveys to date as noted in the following table.

In addition, Office of Nuclear Reactor Regulation (NRR) staff conducts biweekly conference calls with regional division- and branch-level management to discuss current issues associated with the ROP, and meets periodically with regional managers to discuss more complex ROP topics and issues. NRR staff also participates in each regions’ resident counterparts meeting and makes site visits to give regional staff and management the opportunity to discuss ROP implementation and provide feedback. The internal feedback process, as described in Inspection Manual Chapter (IMC) 0801, “Reactor Oversight Process Feedback Program,” also provides a useful means for the NRC staff to identify concerns or issues and recommend improvements related to ROP implementation.

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Wednesday, August 13, 2008