ML19155A036

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LIC-401, Revision 4 NRR Reactor Operating Experience Program
ML19155A036
Person / Time
Issue date: 10/18/2019
From: Eric Benner
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
Issa A, 415-5342, NRR/DIRS
References
LIC-401, Y020190207
Download: ML19155A036 (18)
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OFFICE OF NUCLEAR REACTOR REGULATION LIC-401, Revision 4 NRR Reactor Operating Experience Program Volume 400 Events & Generic Communications Approved By: Eric J. Benner Date Approved: October 16, 2019 Effective Date: October 18, 2019 Certification Date: October 16, 2024 Responsible Organization: DRO Primary

Contact:

Alfred Issa Alfred.Issa@nrc.gov 301-415-5342 Summary: This revision reflects the full integration of construction experience (ConE) into the Operating Experience (OpE) program. The former Center of Expertise (COE) for Operating Experience is no longer needed and all references to it are removed by this revision. This revision also simplifies and clarifies the requirements for ease of use. This issuance incorporates and rescinds the related NRO instruction NRO-REG-112, NRR-NRO Reactor Operating Experience Program, Revision 2.

Training: None ADAMS Accession Number: ML19155A036 TABLE OF CONTENTS

1. POLICY .................................................................................................................................2
2. OBJECTIVES .......................................................................................................................2
3. BACKGROUND ....................................................................................................................2
4. BASIC REQUIREMENTS ......................................................................................................5
5. RESPONSIBILITIES AND AUTHORITIES ..........................................................................12
6. PERFORMANCE MEASURES ...........................................................................................14
7. PRIMARY CONTACT .........................................................................................................14
8. RESPONSIBLE ORGANIZATION .......................................................................................14
9. EFFECTIVE DATE ..............................................................................................................14
10. CERTIFICATION DATE ......................................................................................................15
11. REFERENCES....................................................................................................................15

ML19155A036 OFFICE NRR/DIRS/IOEB NRR/DIRS/IOEB/BC NRR/DIRS:D NRR/DORL:D NRR/DLP:D NAME AIssa RElliott CMiller CErlanger MRoss-Lee DATE 05/23/19 08/22/19 09/30/19 09/09/19 09/06/19 OFFICE NRR/DMLR:D NRR/DSS:D NRR/DRA:D NRR/DE:D NRO/DLSE:D NAME JDonoghue JMarshall MFranovich BSmith ACampbell DATE 09/05/19 09/05/19 08/30/19 08/30/19 09/11/19 OFFICE NRR/DRMA:D NRO/DAR:D NRR:DD NAME TJGorham JMonninger EBenner DATE 10/03/19 09/05/19 10/16/19 NRR Office Instruction LIC-401, Rev. 4 Page 2 of 15

1. POLICY Management Directive (MD) 8.7, Reactor Operating Experience Program, sets forth the policy of the U.S. Nuclear Regulatory Commission (NRC) for an effectively coordinated program to systematically review OpE, assess its significance, provide timely and effective communication to stakeholders and apply its insights to regulatory decisions and programs affecting nuclear reactors. This office instruction is provided to implement this policy. It also implements the policies, applicable to the Office of NRR as described in MD 5.12, International Nuclear Event Scale Participation, and MD 8.1, Abnormal Occurrence Reporting Procedure.
2. OBJECTIVES This office instruction describes a systematic process to implement the requirements of MD 8.7. The objectives of the agencys OpE program include:
  • Collect, evaluate, communicate, and apply OpE Information in a systematic, timely, and coordinated manner to support the agencys goal of ensuring public health and safety. Application includes sharing significant OpE Information with the nuclear industry in a timely manner so that the industry can ensure safety.
  • Coordinate the use of OpE Information to improve the effectiveness, efficiency, and appropriateness of NRC decisions. Evaluations of OpE provide fundamental information necessary to improve safety assessments and help optimize NRC decisions. Lessons learned from OpE evaluations influence regulatory decisions to improve NRC regulatory programs, including licensing and inspection.
  • Facilitate providing the public, Congress, and other external stakeholders with accurate, timely, and balanced OpE Information, including actual or potential hazards to health and safety, thereby enhancing understanding of the performance of both the nuclear industry and licensed plants.

In addition, this office instruction defines the roles and responsibilities of the different offices in support of the OpE program. It also describes the process for fulfilling the requirements of MDs 5.12 and 8.1 by the Generic Communications and Operating Experience Branch (IOEB) staff in the NRR Division of Reactor Oversight (DRO).

3. BACKGROUND OpE includes a wide range of information regarding events and conditions at mainly nuclear power plants and 10 CFR 50 Appendix B vendors of nuclear safety related equipment and services, from numerous domestic and international sources. The NRCs systematic collection and evaluation of such information plays an important role in its mission to protect public health, safety and the environment, and to promote the common defense and security.

NRR Office Instruction LIC-401, Rev. 4 Page 3 of 15 On December 22, 2004, the NRR Director and the Research (RES) Director jointly authorized the implementation of the NRC Reactor OpE Program, as described in the draft policy, program, and procedural documents, in the form of a draft management directive MD 8.7, the associated MD 8.7 Handbook, and NRR Office Instruction LIC-401, NRR Reactor Operating Experience Program (ADAMS Accession No. ML043440295).

In March 2009, NRO staff issued Office Instruction, NRO-REG-112, "New Reactor Construction Experience Program," to describe the process for incorporating OpE and ConE insights obtained from international and domestic sources into the design, construction and testing of new reactors.

On March 28, 2012, NRR and NRO issued a memorandum to the Office of the Executive Director for Operations, Centers of Expertise for Allegations, Operating Experience/

Construction Experience, Electrical Engineering, and Vendor Inspection (ADAMS Accession No. ML12031A191) to increase efficiency and effectiveness while meeting the needs of both offices and ensuring safety is maintained. The OpE/ConE COE led by NRR made ConE an essential part of the agencys Reactor OpE Program.

On October 13, 2019, NRO merged with NRR eliminating the need for the OpE COE. As a result, this revision to LIC-401 rescinds NRO-REG-112 and removes references to the OpE COE.

3.1 Definitions Application of (or applying) OpE information (Section 4.5) - Taking actions, based on insights and/or recommendations resulting from OpE evaluations, that could involve communicating with internal and external stakeholders, taking regulatory actions, and/or influencing agency programs. Applying OpE Information in various forms is used throughout all four phases of the OpE process described in Section 4.

Construction Experience - Construction Experience (ConE) is a subset of the Reactor OpE Program that focuses on insights applicable to new nuclear reactor design, procurement, construction, and pre-operational and hot functional testing also known as the initial testing program.

Evaluation of (or evaluating) OpE information (Section 4.4) - A review of Level 2 screened OpE information by the Issue Manager and/or a review of OpE by the Technical Review Groups in NRR, RES, or Office of Nuclear Security and Incident Response (NSIR) staff to determine the significance of the information and to gain OpE insights that could be used for agency communication or application.

Event - Event refers to an OpE issue of significance that warrants collection and screening.

Issue Manager - An individual within the OpE branch responsible for tracking and project managing an Issue for Resolution through the evaluation and application phases of the OpE process.

Issue for Resolution (IFR) - OpE information that receives a Level 2 screen to be further processed for subsequent evaluation.

NRR Office Instruction LIC-401, Rev. 4 Page 4 of 15 OpE Analysis Team - The OpE Analysis Team continuously reviews operating experience information from various sources in search of adverse trends and indicators of degrading industry performance. It publishes products such as OpE Smart Samples (OpESS), generic communications, end of cycle OpE notes and management briefs. In addition, the analysis team handles special projects such as the production of data analysis tools and search engines. The team is also responsible for international OpE cooperation and for coordination with the Institute of Nuclear Power Operations (INPO).

OpE Clearinghouse - The centralized multi-office team that performs the key functions and activities of the Reactor OpE Program. The OpE Clearinghouse is a critical function of the OpE. Core duties include (1) collecting, storing, screening, prioritizing, and distributing OpE information to interested users; (2) conducting and facilitating OpE evaluation and application activities; (3) facilitating communication of OpE insights; and (4) coordinating NRC OpE activities among organizations performing OpE functions.

OpE Information - Various sources of OpE information include, but are not limited to, Daily Event Notifications (ENs) (10 CFR 50.72), Licensee Event Reports (LERs) (10 CFR 50.73),

information obtained during regional daily events briefings, NRC inspection findings, International Atomic Energy Agency (IAEA) Incident Reporting System (IRS) reports, INPO documents, 10 CFR Part 21 and 10 CFR 50.55(e) notifications, and other internal and external studies.

Operating Experience Smart Sample (OpESS) Program - The intent of the OpESS program is to influence the Reactor Oversight Process (ROP) and/or the construction Reactor Oversight Process (cROP) baseline inspections by providing for consideration sample inspection items stemming from certain OpE which the agency considers to potentially have generic safety implications. Once selected and inspected, the samples are documented in the baseline inspection reports by an OpESS number as described in each OpESS document. The information and trends identified from OpESS inspections may warrant additional agency action (such as the issuance of a Temporary Instruction (TI) or a Generic Communication).

Screening (Section 4.3) - The review of OpE information by the OpE Clearinghouse to determine its potential for significance based on risk assessment, generic applicability, and/or qualitative judgment that considers degradation in safety margin, defense in depth, introduction of a defect (including latent defects) that could adversely affect the ability of a basic component to perform its intended safety function, or other safety or agency concerns.

Screening results in dispositioning the OpE as either a Level 1 or 2 screen.

Technical Review Groups - Technical Review Groups (TRG) provide a valuable evaluation and feedback role for the OpE program. Each TRG is composed of members from across the agency and is led by a TRG lead who is a subject matter expert in a technical topic that is of interest to the OpE program. Periodic reviews are performed to search related OpE data streams, including licensee event reports, inspection findings, international reports, OpE Communications (COMMs) posted on the OpE SharePoint site, and Part 21/10 CFR 50.55(e) notifications. TRG reviews focus on identifying potential significant OpE, adverse OpE trends, and/or pieces of different OpE with a common theme that warrant further NRC review and application. Technical organizations are in the best position to do these focused reviews in their areas of expertise and to identify issues that may supplement the normal OpE Clearinghouse process.

NRR Office Instruction LIC-401, Rev. 4 Page 5 of 15 The TRG process consists of three phases. In phase 1, the TRGs systematically gather applicable OpE. In phase 2, the TRGs prepare and submit the results of their evaluations in a consistent and timely manner to the OpE branch. In phase 3, the OpE branch compiles TRG results, communicates recommendations, if applicable, and tracks their completion.

4. BASIC REQUIREMENTS 4.1 Reactor OpE Program Overview The Reactor OpE Program uses a risk informed decision-making process to evaluate reactor events for safety significance, and to determine if follow-up agency action is required. The program uses both quantitative and qualitative assessment methods to determine the appropriate staff response for each event. This methodology produces a graded approach, where the staff response is tailored to the risk significance of each individual event. The OpE program also considers the potential for generic implications and trending (both positive and negative) when reviewing operating experience. One goal of the OpE program is to help staff to focus their efforts on areas of greatest potential risk significance. And conversely, it helps staff determine when a trend may not have a high level of risk significance.

The OpE SharePoint site provides a central location for NRC staff to locate OpE information required to support their day-to-day work activities. The site contains links to OpE products and OpE activities. It is frequently updated to include new communication tools such as dashboards, apps and search tools, all designed to help users get the most out of OpE data in an efficient and effective way. The OpE SharePoint site contains three categories of domestic and international OpE information.

The first category consists of OpE information sources stemming from NRC regulated activities such as: ENs reported by licensees in accordance with the reporting requirements of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors; LERs reported by licensees in accordance with the reporting requirements of 10 CFR 50.73, License Event Report System; 10 CFR Part 21, Reporting of Defects and Noncompliance reports (including 10 CFR50.55(e) reports); Preliminary Notifications (PNs) issued by the NRC; and inspection findings.

The second category consists of OpE information from external sources available to the NRC such as: INPO event reports and documents and international OpE.

The third category consists of OpE products such as OpE COMMs, IFRs, and OpESS, and related generic communications.

The Operating Experience Staff Handbook (OpE Handbook) posted on the OpE SharePoint site provides detailed step-by-step guidance for implementing the requirements of this office instruction.

The OpE Program involves identifying safety significant issues stemming from domestic and international events as they apply to the US commercial nuclear power industry, taking actions to address these issues and communicating the resulting insights to internal and external stakeholders as required. This may involve regulatory actions and/or influencing programs in support of the agencys mission. Examples include licensing, reactor oversight, rulemaking, incident response and research.

NRR Office Instruction LIC-401, Rev. 4 Page 6 of 15 Numerous organizations within the agency, including NRR, RES, NSIR, and the regions, have substantial responsibilities in supporting the Reactor OpE Program, with the OpE Clearinghouse acting as its focal point. The OpE Clearinghouse provides a centralized function within the agency to collect, store, screen, prioritize, and communicate OpE insights both internally and externally as required. In addition, the OpE Clearinghouse facilitates, tracks and coordinates OpE evaluation and application activities among the various organizations performing OpE functions.

The Reactor OpE process involves four phases (displayed graphically in Figure 1):

(1) Collecting, storing, and making available new OpE information (2) Screening, trending, and communicating OpE information (3) Evaluating OpE information and communication (4) Applying OpE insights from the evaluations The four phases of the Reactor OpE process are discussed below in detail.

Figure 1 - Overview of the Reactor OpE Process Overview of Clearinghouse Operation Process - 4 Phases Phase 1 Phase 2 Phase 3 Phase 4 Section 4.2 Section 4.3 Yes Section 4.4 Section 4.5 Collect Screen Evaluate Apply No Trend Section 4.6 --Communicate 4.2 Reactor OpE ProcessCollect The first phase of the OpE process involves collecting, storing, and making OpE information available to NRC staff. Table 1 below provides a list of the main sources of OpE information. The OpE Clearinghouse is responsible for ensuring that these sources of OpE

NRR Office Instruction LIC-401, Rev. 4 Page 7 of 15 information are made available to the NRC staff through a centralized database (currently housed within the Replacement Reactor Program System) available on the NRCs Intranet.

Table 1. OpE Information Sources Defined Scope of OpE Information Sources New OpE Information Analyzed OpE Information Staff Initiatives Event Notifications Generic Communications Individual staff concerns (10 CFR 50.72) Information Notices (brought to the attention of Regulatory Issue the OpE Clearinghouse)

Licensee Event Summary Reports (10 CFR Generic Letters Staff concerns supported by 50.73) Bulletins branch chief-level or higher management (e.g., staff Preliminary Inspection findings concerns raised through Notifications task interface agreement INPO documents and (TIA) or technical assistance 10 CFR Part 21/10 event reports requests (TAR) for new CFR 50.55(e) Reports reactors that are germane to RES feeds (RES reports OpE, or other management Foreign reports that have been distilled items to be considered INES events and packaged as inputs to under the screening IRS reports the process) process)

ASP reports Daily morning Component and system conference calls with studies regions Generic Safety Issues Various other research studies Significant non-nuclear event OpE insights 4.3 Reactor OpE ProcessScreening Decision The OpE Clearinghouse meets regularly to screen collected OpE information to determine its potential safety significance. These screens are based on risk assessment, generic applicability, and/or qualitative judgment that considers degradation in safety margin or defense in depth, introduction of defects (including latent defects) that could adversely affect the ability of a basic component to perform its intended safety function, or other safety or agency concerns. Screening results in dispositioning the OpE as either a Level 1 or 2 screen. Qualitative and Quantitative criteria designed to assist the Clearinghouse in making screening decisions is provided in this section.

A Level 1 screen reflects those issues that the OpE Clearinghouse staff have determined to be potentially non-safety significant nor generic in nature. Screened Level 1 OpE are

NRR Office Instruction LIC-401, Rev. 4 Page 8 of 15 communicated via summary e-mails and are typically forwarded to NRC staff that have expertise in related technical areas such as TRG leads. Level 1 screens may also be forwarded to NRC staff who have expressed interest in receiving such OpE. Some screened Level 1 OpE, which in the judgment of the OpE Clearinghouse have the potential to lead to more significant events, may be communicated to NRC staff in an OpE COMM.

Note: Procedural guidance related to the initial decision-making process that is required to obtain approval to develop an OpE COMM is provided in the OpE Handbook.

In cases where enough information is not available at the initial screening to make a definitive screen, the OpE item is screened as Level 1 and marked as continue to follow.

The OpE Clearinghouse will rescreen the OpE when enough information becomes available.

An example of an OpE that may be marked as continue to follow is an event that requires a root cause analysis to be performed. The event will be rescreened when the root cause analysis report becomes available.

There will be instances where issues and events that are being provided to the OpE Clearinghouse for screening are also being addressed by another agency program. An important part of the initial screening should include assessing if the candidate issue is being handled by another part of the agency. Some issues and events only receive a Level 1 screen on the basis that other programs or processes within the agency are currently (or will be) resolving them. In these cases, it may be appropriate to capture the data in the OpE database and to consider issuing an OpE COMM to capture and communicate the key operating experience.

A Level 2 screen may be applied to an issue that the OpE Clearinghouse considers to be potentially safety significant or generic in nature and therefore requires further evaluation.

An example of a Level 2 screen would be an OpE event that resulted in dispatching an augmented inspection team (AIT) per MD 8.3. A Level 2 screen may recommend opening an IFR and assigning an Issue Manager. The assigned Issue Manager gathers additional information, as necessary, in preparation for the evaluation phase of the OpE process.

Note: Procedural guidance related to the initial decision-making process that is required to obtain approval to open an IFR and assign an IFR Issue Manager is provided in the OpE Handbook.

NRR Office Instruction LIC-401, Rev. 4 Page 9 of 15 The OpE Clearinghouse should consider the following criteria before making a Level 2 screen decision:

(1) Potential safety significance based on risk or other quantitative factors:

a. risk factor 1 conditional core damage probability (CCDP) 1E-6 or an increase in core damage probability 2 (CDP) 1E-6, or a change in large early release frequency (LERF) 1E-7/yr.
b. other quantitative significance Reactor Oversight or Construction Reactor Oversight Process Significance Determination finding of white or higher (i.e.,

yellow, red), violations of severity level III or higher (i.e. II, I), or INES rating of 1 or higher (2) Qualitative judgment of significance based on the following guidelines:

a. degradation of important SSCs that could lead to a determination of a significant loss of safety function
b. transients that result in unexpected plant response or cause damage to equipment important to safety
c. transients that involve inappropriate operator actions or equipment performance that substantially affect reactor safety
d. potential degradation of fission product barriers
e. reactor scram with significant complications from equipment failure, inappropriate operator actions, or external conditions
f. programmatic breakdown in the areas of design, analysis, or equipment maintenance that will contribute to significant degradation of plant response to transients
g. unplanned radiation dose or radiation dose exceeding administrative or regulatory limits
h. any reactor release of radioactive material from an operating reactor that exceeds regulatory limits
i. potential adverse trendpotential existence of a pattern of similar or recurring events/conditions being observed 1Whenever these or other risk metrics are used to depict the quantitative assessment of safety significance, the associated dominant sequences and dominant cut sets should also be identified. In addition, assumptions applied in the analysis should be identified. Risk measures based on a sensitivity analysis are acceptable if sufficient information is not available to support assumptions applied in the analysis.

2CDP is also known within the agency as incremental conditional core damage probability (ICCDP).

This metric is used to assess the risk associated with a change in plant conditions (typically caused by a failure or unavailability of a piece of equipment or a combination of equipment relied on to mitigate an initiating event), but not the occurrence of an initiating event. Specifically, a calculated CDP depicts an increased difference in the core damage probability caused by a failure/unavailability of such equipment (or a combination thereof) from the nominal core damage probability (for which the same equipment/combination is presumed to be available) for the period/duration of the unavailability.

NRR Office Instruction LIC-401, Rev. 4 Page 10 of 15

j. potential new or novel failure mode, system interaction, material condition or degradation, or other phenomena that may have instructive value for the NRC or the industry
k. a defect (including a latent defect) that could adversely affect the ability of a basic component to perform its intended safety function,
l. other potential agency issues
m. other significant non-nuclear events with the potential for OpE insights that may have instructive value for the nuclear industry or the NRC (examples include aviation, chemical, oil, transportation industry, NASA, Navy reactors, cyber-security events, etc.)
n. potential new or novel items that result in deficiencies with development and implementation of programs for new reactor analysis, design, manufacture, fabrication, quality assurance, placement, erection, installation, modification, inspection, or testing
o. potential for an important to safety item to be counterfeit or fraudulent or a deficiency in safety-related component to be caused by a counterfeit or fraudulent item
p. upon request by a subject matter expert from the cognizant organization or branch for the issue If there are differences of opinion at the OpE Clearinghouse meeting, the team leader should conduct a poll to identify the screening teams recommendations on whether an issue receives a Level 2 screen.

Level 2 screens and IFRs are typically communicated to internal stakeholders by issuing an OpE COMM or sending an informal e-mail to the interested staff members including the affected plant project manager (PM).

The Reactor OpE program is not expected to address and resolve issues of low safety significance. However, events of low safety significance may be reviewed to identify common trends. Trending is performed by the OpE analysis team as the study of historical data and grouping of similar events to identify and evaluate related issues or negative trends. The OpE Analysis Team focus is typically on shorter term, periodic, and specific topic-based analysis and trending products. Trending may also be performed by the TRGs or by RES.

4.4 Reactor OpE ProcessEvaluate As discussed above, Level 2 screened OpE typically results in an IFR that is assigned an issue manager and is communicated to various internal stakeholders. The issue manager, with help from technical staff when required, performs an in-depth evaluation of the subject OpE to clearly determine its impact on plant operation and safety, the extent of its generic applicability, and/or its impact on new reactor construction and design.

The main objective of the evaluation is to formulate recommendations that address the issue at hand and help prevent similar recurrences. These recommendations may include issuing generic communications, completing an OpESS, revising agency programs such as the inspection and licensing review programs and in rare cases rulemaking.

NRR Office Instruction LIC-401, Rev. 4 Page 11 of 15 The Issue Manager is expected to serve as the lead project manager for any assigned IFRs.

The Issue Manager has the overall responsibility for coordinating and packaging the evaluation, including inputs from technical staff when provided. The final evaluation should be included in a closure memorandum addressed to the IOEB Branch Chief (refer to the OpE Handbook for more guidance).

If the Issue Managers recommendation is that no further action is needed, this should be noted in the Issue Managers evaluation and the closure memorandum, including a basis for the recommendation to close the evaluation with no further action.

4.5 Reactor OpE ProcessApply Upon receiving the IFR closure memorandum, the IOEB branch chief decides, in consultation with other appropriate NRC managers when necessary, whether to adopt, in whole or in part, its recommendations.

Possible IFR recommendations include, but are not limited to:

(1) communication of results and insights internally via an OpE COMM and/or externally via generic communications.

(2) taking a regulatory action to require responses from impacted licensees pursuant to 10 CFR 50.54(f) or issuing orders for actions, and/or issuing generic letters or bulletins.

(3) influencing agency programs including those shown in the following table:

Rulemaking Regulatory Guides Standard Review Plan Technical Specifications Generic Safety Issues Inspections Enforcement Actions Research or Long-Term Studies New Reactor licensing and Construction Inspection License Renewal Activities OpE issues that evolve into separate, higher level initiatives outside the scope of the Reactor OpE Program and are better handled by other agency processes or programs, are transferred (handed off) accordingly for further evaluation and application (refer to the OpE Handbook for handoff instructions). Examples include the agencys Generic Issues program, the TIA/TAR process, the LIC-504, Integrated Risk-Informed Decision-Making Process for Emergent Issues process and the rulemaking program.

4.6 Communications OpE communications can be generated at any phase of the OpE program. OpE communications include emails to TRG Leads and applicable staff members, publishing OpE COMMs and OpE Notes, posting significant OpE in ADAMS and/or on the NRCs

NRR Office Instruction LIC-401, Rev. 4 Page 12 of 15 public web site, conducting management briefings and when required issuing Generic Communications (Information Notices).

OpE COMMs are brief and factual documents that are developed and posted over a short period of time. In addition to describing the initiating OpE event, many OpE COMMs contain descriptive attachments and/or photographs and provide insights to inspectors and/or licensing reviewers. They also include supporting references that provide more detailed information. OpE COMMs are applicable to one or more technical fields (COMM groups) as determined by the OpE Clearinghouse. Interested NRC staff who sign up to receive OpE COMMs related to one or more COMM groups automatically receive them via email when they are posted. In addition, OpE COMMs are available for subsequent retrieval by all NRC staff to support various activities such as inspection planning and licensing reviews.

Examples of OpE that may be posted to ADAMS and/or the NRCs public web site include PNs, ENs, LERs and Part 21/50.55(e) notifications.

Note: Procedural guidance related to the initial decision-making process that is required to obtain approval to develop all OpE communication is provided in the OpE Handbook.

Additional guidance related to the development of Generic Communication is found in the Generic Communications Desktop Guide.

The OpE branch shall periodically, or upon request brief NRC management on significant OpE items of interest. Briefing topics typically include data driven results of scrams and adverse trends, safety-significant events including those that involve loss of safety function, and events that may involve generic applicability.

Note: Delivery of OpE management briefings to senior management should always follow the IOEBs organization chain of command. Procedural guidance related to delivering OpE briefings to senior management is provided in the OpE Handbook.

Other OpE communications include inputs to the Abnormal Occurrence program reports when required, inputs to international reports and event reporting to the International Reporting System (IRS).

5. RESPONSIBILITIES AND AUTHORITIES 5.1 Director, Office of Nuclear Reactor Regulation
  • Leads the agencys Reactor OpE Program.
  • Serves as a sponsor for the communication of OpE through the Web and other information technology, in coordination with the Office of the Chief Information Officer (OCIO), as necessary; and ensures review and approval of information technology applied in OpE.

5.2 Director, Division of Reactor Oversight, Office of Nuclear Reactor Regulation

  • Serves as the single point-of-contact to coordinate overall Reactor OpE program activities and to measure effectiveness per MD 8.7.
  • Provides the OpE Clearinghouse to facilitate communication of OpE information and project manage OpE evaluation and application decision-making.

NRR Office Instruction LIC-401, Rev. 4 Page 13 of 15

  • Manages changes to the inspection program that are necessary because of evaluations and associated recommendations for OpE application.
  • Coordinates with NSIR, as necessary, to identify reactor OpE information that could impact nuclear security.
  • Coordinates with Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU), as necessary, to identify reactor OpE information that could impact nuclear security for Non-Power Production and Utilization Facilities.

5.3 Director, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation

  • Provides resources to assist in OpE evaluations when needed and directs any resulting changes to the licensing program.
  • Provides resources to facilitate obtaining additional information from licensees that may be necessary to support evaluations.

5.4 Director, Division of Engineering and External Hazards, Office of Nuclear Reactor Regulation

  • Provides technical support for the evaluation and application of applicable OpE information.
  • Recommends agency application because of evaluations performed by the Division of Engineering and External Hazards (DEX) including evaluations conducted through the TRG process.
  • Interacts with OpE regarding the NRCs process for ongoing assessment of natural hazards information (POANHI) described in LIC-208, including providing analysis and information to OpE or receiving input from OpE as appropriate.

5.5 Director, Division of New and Renewed Licenses, Office of Nuclear Reactor Regulation

  • Ensures that activities that involve new and license renewal issues (e.g., significant trends resulting from inspections or tests related to aging effects during the period of extended operation) that may warrant license program changes or applications (such as generic communications) are appropriately provided as inputs to the OpE Clearinghouse for consideration.
  • Directs changes to the new and license renewal program that are necessary because of evaluations and associated recommendations for application.

5.6 Director, Division of Safety Systems, Office of Nuclear Reactor Regulation

  • Provides technical support for the evaluation and application of applicable OpE information.
  • Recommends agency application because of evaluations performed by the Division of Safety Systems (DSS) including evaluations conducted through the TRG process.

NRR Office Instruction LIC-401, Rev. 4 Page 14 of 15 5.7 Director, Division of Risk Assessment, Office of Nuclear Reactor Regulation

  • Provides technical support for the evaluation and application of applicable OpE information.
  • Recommends agency application because of evaluations performed by the Division of Risk Assessment (DRA) including evaluations conducted through the TRG process.

5.8 Director, Division of Advanced Reactors and Non-Power Production and Utilization Facilities, Office of Nuclear Reactor Regulation

  • Provides technical support for the evaluation and application of applicable OpE information.
  • Recommends agency application because of evaluations performed by the Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU) including evaluations conducted through the TRG process.

5.9 Chief, Generic Communications and Operating Experience Branch, Division of Reactor Oversight, Office of Nuclear Reactor Regulation

  • Responsible for the implementation of the OpE program as directed by the director, DRO.
  • Assists in resolving responsibility issues with respect to evaluation and application of OpE information.
  • Manages the OpE Clearinghouse and analysis functions within a single organization to collect, screen, prioritize, and distribute OpE information to the NRC staff; facilitate and track OpE evaluations, decisions, and applications; assist the communication of OpE insights; assess and trend OpE; and coordinate overall NRC OpE functions.
  • Coordinates the implementation of MD 8.7 and this office instruction.
  • Responsible for effectiveness assessment and periodic process self-assessment. This shall include periodic inter-office effectiveness reviews of the reactor OpE process including NRR OpE branch and other agency offices such as the regional offices, RES, and NSIR.
6. PERFORMANCE MEASURES The OpE Clearinghouse will screen and disseminate >90% of domestic and international operating experience within 10 days, and 100% within 30 days.
7. PRIMARY CONTACT Alfred N. Issa 301-415-5342 Alfred.Issa@nrc.gov
8. RESPONSIBLE ORGANIZATION DRO
9. EFFECTIVE DATE October 18, 2019

NRR Office Instruction LIC-401, Rev. 4 Page 15 of 15

10. CERTIFICATION DATE October 16, 2024
11. REFERENCES
  • MD 5.12, International Nuclear and Radiological Event Scale (INES) Participation, January 30, 2012.
  • MD 8.2, NRC Incident Response Program, June 16, 2006.
  • MD 8.3, NRC Incident Investigation Program, March 27, 2001.
  • MD 8.7, Reactor Operating Experience Program, September 27, 2012.

November 8, 1999. (Note: Attached to this memorandum is the CRGR Charter, Revision 7, dated November 7, 1999.)

  • Staff requirements-SECY-2016-0144 - Proposed Resolution of Remaining Tier 2 and 3 Recommendations Resulting from the Fukushima Dai-ichi Accident, (ADAMS Accession No. ML18282A082)
  • IMC 0309, Reactive Inspection Decision Basis for Reactors, October 28, 2011.
  • IMC 0514, NRC Program for Management of Plant-Specific Backfitting of Nuclear Power Plants, August 26, 1988.
  • IMC 0970, Potentially Generic Items Identified by Regional Offices, December 11, 2000.
  • IMC 1120, Preliminary Notifications, June 9, 2009.
  • IMC 2523, NRC Application of Operating Experience in the Reactor Oversight Process, November 16, 2011.
  • Reactor Operating Experience Task Force Report, November 26, 2003, ADAMS Accession No. ML033350063.
  • Operating Experience Staff Handbook.
  • Generic Communications Desktop Guide

Enclosure:

Appendix - Change History

Appendix - Change History Office Instruction LIC-401 NRR Operating Experience Program LIC-401 Change History - Page 1 of 2 Date Description of Changes Method Training Used to Announce &

Distribute 03/31/2003 This office instruction is an initial issuance of LIC-401 (Draft), which E-mail to None is intended to describe the requirements, roles, and responsibilities NRR staff associated with the current NRR operating experience program activities. It is being issued in draft in light of the ongoing overall review of the agencys operating experience program. This office instruction depicts the various activities of the Operating Experience Branch (IOEB) of the Division of Regulatory Improvement Programs (DRIP), including screening, review, and follow-up of operating experience (OpE) information. Further, it contains current other IOEB activities that are important for NRR implementation of the agencys OpE program.

05/17/2005 This procedure replaces draft LIC-401 (issued on March 31, 2003), E-mail to None which provided operating experience (OpE)-related guidance NRR staff before the work of the Reactor Operating Experience Task Force (ROETF) and the development of Management Directive (MD) 8.7.

Draft LIC-401 had integrated, converted, and streamlined Office Letters/Instructions 503, 1301, 1302, and LIC-403.

03/27/2007 This procedure replaces the current version of LIC-401 (issued on E-mail to None May 17, 2005), which provided operating experience (OpE)-related NRR staff guidance before the work of the Reactor Operating Experience Task Force (ROETF) and the development of Management Directive (MD) 8.7.

11/05/2010 This revision includes the addition of the Operating Experience E-Mail to None Smart Sample (OpESS) process; adds screening criteria for Large NRR Staff Self-study Early Release Frequency (LERF) and numerous other minor for IOEB changes. staff Enclosure

LIC-401 Change History - Page 2 of 2 Date Description of Changes Method Training Used to Announce &

Distribute 05/23/2013 This revision of LIC-401 (NRR) incorporates the guidance E-mail to None contained in NRO-REG-112 (NRO). The objective of this joint NRR Staff Office Instruction is to combine guidance for the NRR Operating Experience and NRO Construction Experience Programs to support the NRCs Center of Expertise for Operating Experience. The revision includes the addition of the Responsibilities and Authorities, adds and clarifies some definitions, and changes some terminology for screening items.

10/16/2019 This revision reflects the full integration of construction experience E-mail to None (ConE) into the Operating Experience (OpE) program. The former NRR staff Center of Expertise (COE) for Operating Experience is no longer needed and all references to it are removed by this revision. This revision also simplifies and clarifies the requirements for ease of use. This issuance incorporates and rescinds the related NRO instruction NRO-REG-112, NRR-NRO Reactor Operating Experience Program, Revision 2.

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