RESPONSE SHEET

TO: Annette Vietti-Cook, Secretary
FROM: Commissioner Baran
SUBJECT: COMSECY-15-0014: PROPOSED ELIMNATION OF

ANNUAL REPORTING REQUIREMENTS FOR
SPECIFIC EVALUATIONS WITHIN THE REACTOR
OVERSIGHT PROCESS SELF-ASSESSMENT
PROCESS

Approved A Disapproved Abstain
Not Participating

COMMENTS: Below < Attached None

| approve the staff's recommendation to eliminate the requirement that the staff provide
the following enclosures to the annual Reactor Oversight Process self-assessment: the
regulatory impact summary, resident inspector demographic analysis, and ROP
resource expenditure analysis. As part of the ongoing evaluation of ROP
improvements, the staff has found that “[t]hese detailed evaluations ... offer limited
insights, are redundant to other processes, and do not appear to return the level of
value as they did when they were initiated.” | appreciate that the staff will remain
focused on these substantive issues, continue to collect the underlying data, and
explore alternative metrics that could provide more valuable insights.

SIGNATURE

Glhre ls
DATE

Entered in “STARS” Yes UA No


RESPONSE SHEET

TO: Annette Vietti-Cook, Secretary
FROM: Commissioner Ostendorff
SUBJECT: COMSECY-15-0014: PROPOSED ELIMINATION OF

ANNUAL REPORTING REQUIREMENTS FOR
SPECIFIC EVALUATIONS WITHIN THE REACTOR
OVERSIGHT PROCESS SELF-ASSESSMENT
PROCESS

Approved XX Disapproved Abstain

Not Participating

COMMENTS: Below XX Attached None

In today’s resource constrained environment, | applaud the staff's efforts to identify activities
that have outlived their necessity. Therefore | approve the staff's request to eliminate annual
reporting of the regulatory impact summary, the ROP resource expenditures analysis, and the
resident inspector demographic analysis. My approval should not be seen as a signal that these
topics are not of importance. For example, it is important for the staff to continue to monitor
appropriate metrics for resident inspector staffing. However, | agree that this would better be
accomplished under the broader umbrella of human capital management. Similarly, reporting
reactor oversight resource expenditures would be better accomplished under the broader
umbrella of the Agency’s planning, budgeting, and performance management process.

SIGNATURE 7”
w/e

DATE

Entered in “STARS” Yes No


RESPONSE SHEET

TO: Annette Vietti-Cook, Secretary
FROM: Chairman Burns
SUBJECT: COMSECY-15-0014: PROPOSED ELIMINATION OF

ANNUAL REPORTING REQUIREMENTS FOR
SPECIFIC EVALUATIONS WITHIN THE REACTOR
OVERSIGHT PROCESS SELF-ASSESSMENT
PROCESS

Approved XX Disapproved Abstain

Not Participating

COMMENTS: Below Attached None XX

tp

~ SIGNATURE

LO June 2015

DATE

Entered in “STARS” Yes x No



RESPONSE SHEET

TO: Annette Vietti-Cook, Secretary
FROM: COMMISSIONER SVINICKI
SUBJECT: COMSECY-15-0014: PROPOSED ELIMINATION OF

ANNUAL REPORTING REQUIREMENTS FOR
SPECIFIC EVALUATIONS WITHIN THE REACTOR
OVERSIGHT PROCESS SELF-ASSESSMENT
PROCESS

Approved XXinPart Disapproved XX InPart Abstain
Not Participating

COMMENTS: Below Attached xx None

NATURE

06/ f /- M5
DATE
Entered in“STARS” Yes SNe


Commissioner Svinicki’s Comments on COMSECY-15-0014
Proposed Elimination of Annual Reporting Requirements for Specific Evaluations Within
the Reactor Oversight Process Self-Assessment Process

| approve in part and disapprove in part. | agree with the staff's assessment that the regulatory
impact summary report has been overtaken by the agency's broader efforts on cumulative
regulatory impact. | approve the elimination of this item as a standalone report. It is essential,
however, that use of NRC Form 649, “Site Visit Observation” be continued, as the staff pledges
to do. This process is the singular means of soliciting feedback on inspector objectivity and
ensuring appropriate actions are taken to address negative feedback, therefore serving an
internal corrective action function. Similarly, the ROP resource expenditure analysis has likely
outlived its usefulness as a standalone item, separate and distinct from the agency's
overarching budgeting and resourcing process. | approve its elimination.

| disapprove, however, the elimination of annual reporting on issues associated with resident
inspector staffing and demographics. To a person, every single Regional Administrator
accounts to me, in our routine meetings, the ongoing challenges associated with this area of
staffing and, by my observation, filling these positions does not seem to be getting any easier.
This is the only position for which the agency has a mandatory rotation policy. Furthermore, it is
a position that is described in every single NRC press release announcing the selection of
resident inspectors as “the agency's eyes and ears” in conducting safety oversight at nuclear
power plants. Consequently, it is essential to keep the Commission's attention on this matter
through routine reporting. If the report on demographics is eliminated, the staff should submit
annually a compilation of four high level summaries — one from each Region — containing the
number of resident inspector positions turned over that year and the number due to turn over in
the coming two years, the number of qualified candidates who applied for each opportunity that
arose and their relevant years of experience, and the number of resident inspectors currently
serving under extension of time (beyond the agency's rotation metric) and how long these
extensions are expected to exist before mandatory rotation can be accomplished.

The staff has made many expressions in this COMSECY regarding the superior nature of the
new self-assessment tools it intends to develop and put in place. As a longtime reader of the
existing self-assessment documents, | look forward to judging the staff's success against this
commitment.

ristine L. Svinicki 06/ Hf 715