POLICY ISSUE

(Notation Vote) 

August 28, 2015 SECY-15-0108

FOR: The Commissioners 

FROM: Mark A. Satorius 

Executive Director for Operations 

SUBJECT: RECOMMENDATION TO REVISE THE DEFINITION OF DEGRADED 

CORNERSTONE AS USED IN THE REACTOR OVERSIGHT PROCESS 

PURPOSE: 

The purpose of this paper is to request Commission approval to revise the definition of 

degraded cornerstone as used in the Reactor Oversight Process (ROP) Action Matrix. This 

paper does not address any new commitments or resource implications. 

SUMMARY: 

Consistent with the staff’s ROP Enhancement Project, and as recommended by the ROP 

Independent Assessment completed in 2014, the staff reviewed the criteria for a licensee to 

transition to the Degraded Cornerstone column (i.e., Column 3) of the Action Matrix. This 

review focused on whether two White inputs were appropriately indicative of a degraded 

cornerstone. The current technical basis for the criterion of two White inputs in the same 

cornerstone is not well defined or documented. As such, the staff conducted a risk-informed 

evaluation of the criterion using probabilistic risk assessment (PRA) for the applicable ROP 

cornerstones and concluded that three White inputs in the same cornerstone is more indicative 

of a degraded cornerstone. The staff also completed a qualitative review for the more 

deterministic ROP cornerstones and concluded that three White inputs in these cornerstones is 

more indicative of a degraded cornerstone. While there are both pros and cons regarding the 

need to revise the definition of a degraded cornerstone, the staff carefully considered all aspects 

of the matter and recommends that the definition of degraded cornerstone be revised from 

CONTACT: Daniel J. Merzke, NRR/DIRS 

 301-415-1457
The Commissioners - 2 - 

two to three White inputs in the same cornerstone. This change would impact the entry criteria 

for Column 3 and Column 4 of the Action Matrix. If approved, the staff plans to also revise 

Inspection Procedure (IP) 95001, “Supplemental Inspection for One or Two White Inputs in a 

Strategic Performance Area,” to review licensee common cause analyses completed as a result 

of two White inputs in the same cornerstone. Given the potential for programmatic weaknesses 

that may be revealed by two White inputs in the same cornerstone, this revision would increase 

the likelihood of the U.S. Nuclear Regulatory Commission (NRC) identifying potentially broader 

licensee performance issues. The staff intends to assess the efficacy of this and other changes 

being implemented to the ROP as part of the annual self-assessment process and to make 

adjustments as necessary. 

BACKGROUND: 

The current ROP was implemented for all licensees in calendar year 2000. The ROP is 

continuously evaluated, and each year the staff documents its self-assessment of all of the 

major areas of the ROP. Aspects of the ROP have also been assessed several times by the 

Office of the Inspector General, the Government Accountability Office, and most recently by a 

Commission-directed independent review panel. Each report has concluded that the ROP is 

working well. These reports have also included recommendations that the staff has evaluated 

and implemented, as appropriate. The ROP is a mature and effective program. 

The ROP consists of three strategic performance areas: (1) reactor safety, (2) radiation safety, 

and (3) safeguards. Within these strategic performance areas are seven cornerstones of safety: 

(1) initiating events (IE), (2) mitigating systems (MS), (3) barrier integrity (BI), (4) emergency 

preparedness (EP), (5) occupational radiation safety, (6) public radiation safety, and (7) 

security. PRA models are used to inform the determination of the safety significance of 

inspection findings in the IE, MS, and BI cornerstones. The safety significance of inspection 

findings under the other cornerstones, while risk-informed, is conducted using more 

deterministic methods. 

Under the ROP, licensee performance determines predictable regulatory actions as described 

by the Action Matrix. According to Inspection Manual Chapter (IMC) 0305, “Operating Reactor 

Assessment Program” (Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML15089A315), licensees with one White input into the Action Matrix, or two 

White inputs in a strategic performance area (not in the same cornerstone) are placed in 

Column 2, the “Regulatory Response” column. An input is either an inspection finding as 

determined by NRC inspectors, or a performance indicator (PI) reported by NRC licensees. The 

established regulatory action for Column 2 includes the conduct of an inspection under IP 

95001, which has a resource estimate of approximately 40 hours. 

The current criteria for licensee transition to Column 3 of the Action Matrix (i.e., the “Degraded 

Cornerstone” Column) includes one Yellow input, two White inputs in the same cornerstone, or 

three White inputs in the same strategic performance area. A degraded cornerstone is currently 

defined in IMC 0305 to be a cornerstone that has two or more White inputs or one Yellow input. 

Licensees in Column 3 are subject to inspections per IP 95002, “Supplemental Inspection for 

One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area.” White 

inspection findings are characterized as “low-to-moderate” safety significance, and Yellow 

findings are characterized as “substantial” safety significance. The resource estimate for the 

conduct of an IP 95002 supplemental inspection is approximately 200 hours. 
The Commissioners - 3 - 

In 2003, the staff performed an evaluation of the threshold for entering Column 3 (ADAMS 

Accession No. ML031900342). At that time, the staff concluded that reasoned judgement was 

used to support its decision to use two White inputs in the same cornerstone as part of the 

criteria for defining a degraded cornerstone. The staff noted that while a detailed analysis or 

evaluation was not developed to support this decision, staff did not identify data that suggested 

that the criterion was inappropriate. The evaluation also noted that the Action Matrix thresholds 

would continue to be assessed as additional experience with ROP implementation was gained. 

In November 2013 the NRC staff held a public meeting to establish the scope of the 

assessment portion of the ROP Enhancement Project. The meeting summary, dated 

December 5, 2013, can be found at ADAMS Accession No. ML13337A637. The goal of the 

ROP Enhancement Project was to take a fresh look at the ROP to determine what was working 

well, and what needed improvement. During that meeting, industry representatives raised the 

concern that there are very significant resource implications for licensees when they transition 

from Column 2 to Column 3 in the Action Matrix. Industry representatives said the risk 

associated with two White inputs in the same cornerstone was not commensurate with the costs 

associated with the regulatory actions for Column 3 (i.e., unnecessary regulatory burden). 

The Nuclear Energy Institute (NEI) subsequently submitted a position paper to NRC staff, dated 

August 18, 2014 (ADAMS Accession No. ML14246A465), reiterating the industry’s position that 

the threshold for transitioning to Column 3 of the ROP Action Matrix (two White findings in a 

cornerstone) is too low. NEI stated that this threshold motivates licensees to challenge 

“preliminary White” findings aggressively. As a result, both licensees and the NRC often 

expend resources on White findings that are not commensurate with their low-to-moderate 

safety significance. 

In the Staff Requirements Memorandum (SRM) on SECY-12-0081, “Risk-Informed Regulatory 

Framework for New Reactors,” dated October 22, 2012 (ADAMS Accession No. 

ML12296A158), the Commission stated it would benefit from a fresh review of the practices and 

approaches the staff has developed for the ROP over the course of its years. Specifically, the 

Commission directed the staff to conduct an independent review of the program’s objectives 

and implementation, including the relative roles of headquarters and regional staff, interactions 

with industry over PI assessments, and the effectiveness of NRC’s assessment of substantive 

cross-cutting issues. In February 2014, the NRC review team issued the Reactor Oversight 

Process Independent Assessment Report (ADAMS Accession No. ML14035A571). 

Recommendation 5 of the report stated: 

The NRC should review the criteria for transition to Column 3 of the NRC 

Action Matrix against the original ROP program goals to ensure that the 

significance of White inspection findings is not being overemphasized and 

to ensure that agency resources used to process White inspection 

findings are commensurate with findings that, by definition, are of low to 

moderate safety significance. 
The Commissioners - 4 - 

DISCUSSION: 

Working Group Evaluation

Following receipt of feedback from external stakeholders and the recommendation from the 

ROP Independent Assessment, the NRC staff formed a working group to evaluate the criteria 

for licensee transition to Column 3 of the Action Matrix. The purpose of this review was to 

determine if the existing criteria, and specifically the definition of two White inputs in the same 

cornerstone, were appropriate or if a change was warranted. Note that the ROP Independent 

Assessment also recommended a review of agency resources used to process White findings; 

this evaluation was not performed by the working group. In response to SRM-COMSECY-14-

0030, “Proposed Suspension of the Reactor Oversight Process Self-Assessment for Calendar 

Year 2014,” dated September 19, 2014 (ADAMS Accession No. ML14262A078), separate, 

ongoing staff efforts to improve the efficiency and effectiveness of the ROP significance 

determination process (SDP) are being implemented to ensure agency resources used to 

process White inspection findings are commensurate with their significance. The staff response 

to this tasking was provided to the Commission in June 2015. 

As described in IMC 0305, licensees in Column 3 are considered to have met all cornerstone 

objectives with a “moderate degradation” in safety performance. The working group completed 

an extensive review of the history and the basis for the current criteria and determined that there 

was no documented technical basis for the definition of two White inputs in the same 

cornerstone being a degraded cornerstone. The working group interviewed several founding 

members of the current ROP who said the staff considered a range of values for the criterion of 

the number of White inputs in the same cornerstone necessary for transition to Column 3 of the 

Action Matrix. Ultimately, an expert panel made a conservative decision to set the threshold for 

degraded cornerstone at two White inputs in the same cornerstone. 

Risk Analysis

Though not explicitly stated, the current IMC 0305 criteria infer that two White inputs in the 

same cornerstone are equivalent to one Yellow input, indicative of a moderate degradation in 

safety performance. When the ROP was developed, the Advisory Committee on Reactor 

Safeguards commented that “the staff’s judgment is that two White inputs signify a certain 

degradation in performance which is about the same as that corresponding to one Yellow 

finding in the sense that the resulting regulatory response should be the same.” The staff 

responded to this comment in a letter, dated January 10, 2002 (ADAMS Accession No. 

ML013550087), and stated, 

Consideration was also given to the fact that any White finding could have a delta 

CDF [change in core damage frequency] that was almost Green (e.g., 1.1E-06) 

or almost Yellow (9.9E-06) and that an appropriate risk-based response would be 

complicated when combining multiple White issues. The group determined that it 

would be inappropriate to attempt to quantitatively define the agency’s response 

when considering these uncertainties. 

That expert panel also recognized there was considerable uncertainty in determining risk 

significance of findings, particularly if complicated by multiple simultaneous findings. However, 

after 15 years of implementation, a significant amount of historical PRA data now exists that 
The Commissioners - 5 - 

was not available to the framers of the ROP. The working group analyzed the historical data to 

determine how many White inputs are equivalent to one Yellow input using PRA information. 

The working group noted that there is considerable uncertainty in every significance 

determination that relies on PRA models. Using a mean delta CDF for a White finding of 

5E-06/year, the sum of two White findings would characterize licensee performance at the 

White/Yellow threshold (1.0E-05). Yellow risk is a delta CDF greater than 1.0E-05. A third 

White finding would push the overall risk into the very low end of the risk band associated with 

Yellow, or Column 3 of the Action Matrix. The working group noted that similar arguments could 

be raised for transitions to other columns, such as the number of Green findings equivalent to 

one White input or the number of Yellow inputs equivalent to one Red input. However, the 

argument does not apply to Green findings because it was decided not to aggregate Green 

findings when the ROP was formed because of the much wider Green risk range (several 

orders of magnitude). In addition, since Yellow inputs are defined to be of substantial safety 

significance, and are relatively rare, the working group determined that the current criteria of two 

Yellow inputs or one Red input for transition to Column 4 are appropriate. The staff will continue 

to assess the Action Matrix criteria as part of its annual ROP self-assessment to determine if 

any additional changes should be considered. 

Because inputs into the Action Matrix include both inspection findings (processed using the 

SDP) and PIs (with risk-informed performance thresholds), the working group also reviewed the 

risk significance of White PIs to ensure their significance was consistent with the significance of 

White inspection findings. To illustrate, for the MS cornerstone, the primary PIs are the 

Mitigating Systems Performance Index (MSPI) indicators. The MSPI indicators monitor safety 

system unavailability and unreliability over time, which translates to a delta CDF. The 

thresholds for these PIs were established to be equivalent to the risk significance of inspection 

findings. The working group concluded that the safety significance associated with White PIs is 

equivalent to the safety significance of White inspection findings (and therefore the regulatory 

actions for each should also be approximately equivalent). 

The working group also reviewed the final SDP results for licensees that transitioned to Column 

3 based on two White inspection findings in the same cornerstone, or one White inspection 

finding and one White PI in the same cornerstone, to validate the PRA results. The working 

group concluded that none of the licensees that were reviewed exceeded the White/Yellow 

threshold when summing the final SDP results. Because the sample size was small, the 

working group also reviewed the SDP results for all White findings from 2011 through 2014. 

This period provided a statistically-significant sample. Twenty-one White findings were issued 

during that period for which the actual mean delta CDF was 4.4E-06/year. The working group 

determined that the median delta CDF was 4.0E-06/year, indicating that the majority of findings 

were below the mean. Because the actual mean was lower than the assumed mean, the results 

support the conclusion that three White inputs are more equivalent to one Yellow input (vice two 

as currently defined in IMC 0305). 

Qualitative Analysis

The preceding PRA discussion applies to the three cornerstones of safety that most directly rely 

on quantitative risk assessment (IE, MS, BI) for determining significance of findings and PIs. 

For completeness, a more qualitative assessment was needed for the other cornerstones, which 

include EP, Public Radiation Safety, Occupational Radiation Safety, and Security. Since the 
The Commissioners - 6 - 

inception of the ROP, there have been 31 plants that transitioned to Column 3 based on two 

White inputs alone. Twenty-six of the 31 licensees that transitioned to Column 3 because of two 

White inputs did so as a result of their performance in the more quantitative cornerstones. The 

remaining 5 of 31 licensees transitioned to Column 3 under the more deterministic 

cornerstones. Six of the 31 plants would have eventually transitioned to Column 3 using the 

current criteria, either because of additional White findings in the same strategic performance 

area or a Yellow input. 

To determine if a licensee’s actual performance was consistent with the description of the 

performance degradation associated with Column 3 of the Action Matrix, the working group 

completed a review of the resulting IP 95002 supplemental inspection reports from the past 10 

years (notably the same period of time used to evaluate industry-wide performance trends in the 

Industry Trends Program) for those plants that transitioned to Column 3 based only on two 

White inputs. 

The working group recognized that there is considerable subjectivity associated with making a 

determination that a plant had a moderate degradation in safety performance based solely on 

the documentation supplied in the NRC’s supplemental inspection reports. Therefore, the 

working group developed criteria from which to make an informed assessment. Those criteria 

included whether significant programmatic weaknesses were identified from licensee root cause 

evaluations and whether extent-of-condition reviews identified other systems and components 

similarly degraded because of the root cause. The working group judged that significant 

programmatic weaknesses identified by licensee root cause evaluations could be an indicator of 

pervasive performance problems affecting one or more cornerstones. In addition to the above 

criteria, the working group considered whether the programmatic deficiencies identified in the 

inspection reports could have been adequately reviewed through another inspection other than 

the IP 95002 inspection (e.g., IP 71152, “Problem Identification and Resolution (PI&R)” (ADAMS 

Accession No. ML14316A042)), or IP 95001. An important contributor to improving licensee 

performance is for the licensee to self-identify those weaknesses and implement corrective 

actions to eliminate them. Licensee root cause evaluations and corrective actions are 

developed for all inspection findings with greater-than-Green significance, regardless of the type 

of supplemental inspection conducted by the NRC. 

From the IP 95002 inspection report review, the working group concluded that for most 

licensees, there was insufficient documented evidence of the existence of significant 

programmatic weaknesses to support a conclusion that the licensee’s performance was 

consistent with the description of the performance degradation associated with Column 3 of the 

Action Matrix. For example, in the case of one plant in Column 3 because of two White 

findings in the EP cornerstone, the IP 95002 supplemental inspection report stated, “the 

inspectors concluded that the weaknesses were not reflective of significant performance 

issues.” 

The working group recognized that review of the IP 95002 inspection reports for only those 

licensees that entered Column 3 based on two White inputs would yield an incomplete picture. 

Therefore, the working group sampled additional IP 95002 inspection reports for licensees that 

moved to Column 3 from three White inputs or one Yellow input to determine if those reports 

documented licensee performance indicative of a degraded cornerstone. While this review was 

again subjective, the working group concluded that for most of the reports reviewed, there was 

sufficient documentation to support the degraded cornerstone determination. For instance, one 
The Commissioners - 7 - 

report for a licensee with three White inputs stated that the collective risk was in the “Yellow 

band,” and the inspectors considered the NRC’s regulatory response to be appropriate for the 

plant-specific risk consequences. Another inspection report for a licensee with three White 

inputs documented weaknesses in 11 safety culture components and 145 action items were 

identified to address the root and contributing causes, which indicated there were significant 

performance issues for which an IP 95002 inspection was the appropriate regulatory action. 

Although the working group’s conclusions on cornerstone performance drawn from the review of 

the IP 95002 inspection reports are subjective, these inspection reports fully documented the 

root causes and contributing causes of the earlier performance deficiencies, as well as the 

licensees’ “extent-of-condition” reviews. While some may argue that these inspection reports 

may not address licensee efforts to address the performance gaps as they prepared for the 

supplemental inspection, the reports paint a fairly complete picture of licensee performance at 

the time the performance deficiencies were discovered. 

Working Group Recommendation

Upon completion of the risk-based and qualitative reviews and analyses described above, the 

working group recommended revising the two White inputs in the same cornerstone to three 

White inputs in the same cornerstone for transition to Column 3, thus revising the degraded 

cornerstone definition. This change in definition would also impact the number of White inputs 

for licensee transition to Column 4 of the Action Matrix under the criteria of multiple degraded 

cornerstone (requiring one additional White input in each cornerstone) and repetitive degraded 

cornerstone (requiring one additional White input). The working group issued a publiclyavailable report documenting the basis for the recommendation (ADAMS Accession No. 

ML14350B164) and summarizing the data analysis to support this recommendation (ADAMS 

Accession No. ML14350B180). Given the potential for programmatic weaknesses that may be 

revealed by two White inputs in the same cornerstone, the working group recommended a 

revision to the IP 95001 supplemental inspection procedure (conducted following any White 

input) to allow for an increased scope of inspection (to include additional potential common 

cause analyses), to increase the likelihood of the NRC identifying potentially broader licensee 

performance issues. This added inspection activity would provide additional regulatory 

oversight for plants with two White inputs in the same cornerstone that in the past would have 

transitioned to Column 3. 

The staff recognizes that the working group’s recommendation is a reduction of regulatory 

oversight from the currently established levels. However, based on the preceding analysis, the 

change appears to be appropriate from both a quantitative and qualitative assessment. Other 

changes to the ROP made recently or being considered by the staff also tend in the direction of 

perceived or actual reduced oversight. Examples include: (1) a revision to the definition of a 

repetitive degraded cornerstone in IMC 0305 to extend the period before a licensee in Column 3 

is at risk for Column 4 from four quarters to five quarters; (2) a revision of IMC 0305 to increase 

the number of findings with the same cross-cutting aspects required and the duration of those 

aspects before citing a cross-cutting issue; (3) ongoing reviews of the performance thresholds in 

certain deterministic SDPs; and, (4) continuing examination of potential changes to the scope of 

the component design basis IP. The staff did not evaluate the cumulative effects of these 

changes during the development of the Action Matrix recommendation that is the subject of this 

paper. The staff plans to evaluate the efficacy of these changes as part of its annual ROP self-
The Commissioners - 8 - 

assessment and make any necessary adjustments. However, some staff thought the 

cumulative effects should be evaluated before making the change recommended in this paper. 

Outreach

The staff held a public meeting on January 15, 2015, to solicit stakeholder comments on the 

working group’s recommendation. Invitations were sent to several non-governmental 

organizations (NGOs), such as the Union of Concerned Scientists, Beyond Nuclear, Nuclear 

Information and Resource Service and Greenpeace to participate in the public meeting. The 

staff made the working group report and data analysis publicly available in advance of the 

meeting. Because NGOs were unable to attend the public meeting, the staff requested that 

comments on the proposal be submitted electronically. The staff received only positive 

comments from industry stakeholders and other members of the public who attended the 

meeting, but no comments were received from the NGOs. 

Views in Support of Maintaining the Existing Definition (Status Quo)

Some internal stakeholders do not agree with the working group recommendation to change the 

definition of degraded cornerstone. Specifically, these staff members consider the current 

definition to be appropriate and that the working group’s rationale for a change does not 

outweigh the benefits of maintaining the existing level of oversight. 

Some staff noted that, over the 15 years of ROP implementation, the Action Matrix deviation 

process has never been used to preclude a licensee with two White inputs from entering 

Column 3, which might suggest that the greater oversight from the IP 95002 supplemental 

inspection was warranted. 

Some staff disagreed with the working group’s conclusions from the qualitative IP 95002 

inspection report review described above (to determine if a cornerstone was truly degraded) 

because the reports do not account for licensee efforts to address the performance gaps as 

they prepared for the supplemental inspections, and that those inspection reports were not 

written with the contemporary question of a degraded cornerstone definition in mind. The 

criteria developed by the working group for the report reviews were also disputed. 

Some staff suggested that the IP 95002 inspection is the appropriate regulatory engagement for 

a plant with two White inputs because it provides a “deterrent” effect, meaning that the 

licensee’s actions to prepare for an IP 95002 supplemental inspection arrests any further 

performance decline. 

Some staff suggested that the risk argument for summing White inputs to determine how many 

were approximately equivalent to a Yellow input was not consistently applied to the Green/White 

and Yellow/Red thresholds and that this inconsistency does not comport with the guiding 

principles of the ROP, (e.g., risk-informed, objective, predictable, and understandable). 

Finally, some staff suggested that, with the refinements in PRA modeling realized since the 

initiation of the current ROP (which often now include credit for licensee recovery actions), it is 

more difficult for a licensee performance deficiency to be characterized as White. They assert 

that because it has become more difficult to assign a White color to an inspection finding in the 
The Commissioners - 9 - 

risk-informed cornerstones today, the significance of the findings determined to be White have 

greater import than when the ROP was first implemented. 

The staff included these strongly-held views supporting the status quo to ensure the 

Commission has the benefit of various perspectives on this policy issue. 

CONCLUSION: 

Because no documented technical basis for the current definition of a degraded cornerstone 

exists, the working group sought to develop one. The staff carefully considered the working 

group’s technical basis and recommendations, as well as the aforementioned views in support 

of the status quo. While there is merit to both approaches, the staff concluded that the current 

regulatory actions for a licensee in Column 3 of the Action Matrix may not correspond with the 

aggregate safety significance of two White inputs in the same cornerstone (as well as the 

subsequent impact on entry into Column 4). Given that one of the fundamental goals of the 

ROP is to be risk-informed, this recommended change reflects a more risk-informed approach 

to regulatory decision-making within the ROP. For this reason, the staff recommends that the 

definition of a degraded cornerstone be modified. 

Implementation

If the staff’s recommendation is approved, for completeness the staff would also need to amend 

the criteria for licensee transition to Column 2 of the Action Matrix. The current criteria for 

Column 2 are one White input, or two White inputs (in different cornerstones) in a Strategic 

Performance Area. The new criteria for Column 2 would be revised to include up to two White 

inputs in the same cornerstone and up to two White inputs in each Strategic Performance Area. 

Further, the staff would make conforming changes to the definition of repetitive degraded 

cornerstone. A repetitive degraded cornerstone is currently defined as a cornerstone that is 

degraded with two White inputs or one Yellow input in a single cornerstone for more than five 

consecutive quarters with at least one quarter having three or more White inputs or one Yellow 

and one White input (the additional White input can be from any cornerstone). That definition 

would be revised to state, “a cornerstone that is degraded (three open White inputs or one open 

Yellow input in a single cornerstone) for more than five consecutive quarters with at least one of 

the quarters having: (1) four or more White inputs (the additional White input(s) can be from 

any cornerstone), or (2) one Yellow and one White input (the additional white input can be from 

any cornerstone). 

The multiple degraded cornerstone definition would not need to be revised since it currently 

states “two or more cornerstones that are degraded in any one quarter,” however, since the 

definition of degraded cornerstone would change, entry into Column 4 would require an 

additional White input per cornerstone under this definition. 

The staff will also consider renaming Columns 3 and 4 to alleviate any confusion the existing 

names may have created. 

If the recommendation is approved, the Action Matrix deviation process would remain available 

should the staff deem that additional regulatory oversight is warranted for licensees with only 

two White inputs in the same cornerstone. 
The Commissioners - 10 - 

In SRM-SECY-10-0140, “Options for Revising the Construction Reactor Oversight Process 

Assessment Program,” dated March 21, 2011, the Commission approved the staff’s 

recommendation to develop a construction assessment program that includes a regulatory 

framework and the use of a construction Action Matrix to determine the appropriate NRC 

response to construction findings. The construction ROP Action Matrix contains the same 

column entry criteria as that which is contained in the ROP Action Matrix. The staff will 

incorporate into the construction Action Matrix any recommendations in this paper that are 

approved for the ROP Action Matrix criteria. 

A potential consequence of implementing the staff-recommended change would be fewer 

licensees moving to Column 3 of the Action Matrix, with a corresponding reduction in staff 

resources required to review licensee actions in response to two inputs characterized as low to 

moderate safety significance. (This potential resource savings would be partially offset by the 

additional inspection required by the enhanced IP 95001 supplemental IP.) In addition, this 

change, along with the recent revision to the repetitive degraded cornerstone criteria, make it 

less likely that a licensee will meet the criteria for a repetitive degraded cornerstone or multiple 

degraded cornerstones, potentially resulting in fewer licensees moving to Column 4. The staff 

notes, however, that there have only been two licensees since the inception of the current ROP 

that transitioned to Column 4 because of White inputs only, and none in the past 10 years. 

Another potential consequence was suggested by NEI in their position paper dated August 18, 

2014. In that paper, NEI suggested there would be fewer challenges to significance 

determinations for White findings if the criteria for transition to Column 3 were changed to three 

White inputs in the same cornerstone. While this suggestion is theoretical, the staff cannot 

discount the potential for fewer challenges which could result in more timely final significance 

determinations with an attendant reduction in resources expended for both the NRC and 

licensees. 

RECOMMENDATIONS: 

The staff recommends that the Commission approve the proposal to revise the definition of 

degraded cornerstone to three or more White inputs or one Yellow input. If approved, the staff 

would make the aforementioned conforming changes to IMC 0305 and would revise IP 95001 to 

include additional resources and guidance to be used when a licensee has a second White 

input in the same cornerstone. The revision would still be consistent with the ROP goals of 

being objective, risk-informed, understandable, and predictable, as well as the Principles of 

Good Regulation, and aligns with a tenet of the ROP to focus industry and NRC staff resources 

on the most significant safety issues. 

The staff continuously monitors the effectiveness of changes to the ROP using the annual 

self-assessment process. If this recommendation is approved, the staff will use the annual 

self-assessment to report the trends in performance of licensees with two White findings in a 

single cornerstone until statistically meaningful data are available to draw a conclusion 

regarding the impact of this change. 
The Commissioners - 11 - 

 COORDINATION: 

The Office of the General Counsel has reviewed this Commission paper and has no legal 

objection. The Office of the Chief Financial Officer has reviewed this Commission paper and 

determined that it has no financial impact. 

 /RA/

Mark A. Satorius 

Executive Director 

 for Operations 
The Commissioners -11- 

COORDINATION: 

The Office of the General Counsel has reviewed this Commission paper and has no legal 

objection. The Office of the Chief Financial Officer has reviewed this Commission paper and 

determined that it has no financial impact. 

 

 /RA/ 

Mark A. Satorius 

Executive Director 

 for Operations 

ADAMS Accession No.: ML15076A066 *Concurrence via email 

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