ML20169A579
| ML20169A579 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/2020 |
| From: | Travis Iskierka-Boggs NRC/NRR/DRO/IOLB |
| To: | |
| Iskierka-Boggs T | |
| Shared Package | |
| ML20169A574 | List: |
| References | |
| OLMC-160 | |
| Download: ML20169A579 (18) | |
Text
OLMC-160 JuneApril 2020 REGIONAL OFFICE INTERACTIONS REPORT ON INTERACTION PROCESS A. PURPOSE The purpose of this OLMC is to establish a system for processing the interactions regarding operator licensing between the rRegional Ooffices and the Office of Nuclear Reactor Regulation (NRR) such that the following criteria are met:
- New policies or policy changes that affect the procedures and practices for examining, licensing and re-licensing power reactor operators and senior operators, pursuant to Part 55 of Title 10 of the Code of Federal Regulations (10 CFR 55), are consistently implemented by all the regional offices.
- Policy interpretations, applicable to the operator licensing process, are only made by NRC headquarters and are consistently implemented by all the regional offices.
- Non-routine deferral, excusal, and waiver requests, as described in ES-204 of NUREG 1021, shall be submitted to the program officeProgram Office for review and approval. The applicable program office is determined as described in Section B.1, below.
B. BACKGROUND
- Pursuant toer ADM-200, Delegation of Signature Authority, (NRR) the bbranch cchief of the ooperator llicensing pprogram ooffice will provide response to requests from regions for support to the regions for examining, licensing and re-licensing power reactor operators and senior operators in accordance with 10 CFR 55. The program officeprogram office is responsible for ensuring that the regional offices consistently implement the operator licensing process in accordance with established procedures and regulations.
- The Operator Licensing and Human Factors Branch (IOLB) in NRR is the applicable operator licensing program office for power reactor facilities that have not transitioned from a cold-licensing process to a hot licensing process, as specified in the applicable facilitys Final Safety Analysis Report (FSAR), and is the applicable operator licensing program office for all other power reactor facilities with an operator licensing and training program.
- Frequent interactions occur between the regional offices and the program officeprogram office dealing with the interpretation of policy, guidance associated with applicant eligibility, and other aspects of the operator licensing process.
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OLMC-160 JuneApril 2020
- Differences in implementation of program policy have been noted among the regional offices within the operator licensing program.
- The formal Report on Interaction (ROI) system was established to document these interactions and to assist in consistent implementation of program policy among the regional offices. This system includes an efficient and timely means of distribution and filing to minimize the loss or duplication of information. Furthermore, this system facilitates the consistent application of policy by the program officeprogram office and the regional offices.
C. IMPLEMENTATION
- 1. Interactions requiring the Report on Interaction (ROI) system:
- All operator licensing interactions with the regional offices that require a formal interpretation of policies, practices, regulations, NUREGs, or other applicable directives, shall be documented and submitted to the program office on an ROI Form (Attachment 1).
- IAdditionally, interactions such as non-routine excusal and waiver requests by license applicants, deferrals of experience or eligibility requirements, or deviations of the requirements from NUREG 1021 (exemptions), shall be submitted to the applicable program office for approval. .
o During non-emergent situations, tThe applicable program officeprogram office staff will not provide a decision based act on informal telephone or e-mail requests for policy interpretation.
However, informal communications with the applicable program officeprogram office are appropriate to verify that an intended interaction is necessary, to establish a common understanding of the issue, or to solicit assistance in developing a suggested resolution.
- 2. Guidance to individuals initiating a Report on Interaction (ROI):
- Before drafting the ROI, check the yearly ROI Index on the IOLB SharePoint website and review any previously drafted ROIs to prevent duplication.
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OLMC-160 JuneApril 2020 o IOLB SharePoint ROI Index can be referenced at:
https://usnrc.sharepoint.com/:f:/r/teams/NRR-Operator-Licensing-Branch/Shared%20Documents/ROI%20Indices?csf=1&web=1&e=nm hZM6 o The ROI Combined Index and individual folders containing each years ROIs are found in the Agency-Wide Documents Access and Management System (ADAMS) Main Library under NRR/NRR-DRO/NRR-DRO/IOLB/ROIs.
https://adamsxt.nrc.gov/navigator/bookmark.jsp?desktop=ADAMS&re positoryId=MainLibrary&docid=Folder%2C%7BFADD9FBE-4595-43E6-B85B-8F2B7707A2E9%7D%2C%7B08B0EC69-DACE-4C0C-922E-8B667CD38523%7D&template_name=Folder&version=current o If a previous ROI exists that answers the specific issue requiring program office interpretation, then consult that ROI for guidance. If all questions are still not answered for the current interpretation question, then submit a new ROI to the program office. This does not apply for license waivers or deferrals as NUREG-1021 requires these to be approved by the program office. Previous ROIs concerning waivers or deferrals provide precedence, they do not provide approval.
- Contact the program offices Operator Licensing Assistant (OLA) to request the next sequential ROI number. Provide program office OLA with ROI title.
- ROIs that are generated regarding an applicants experience or eligibility should be sent to the program office prior to submittal of applicants final application.
This allows the program office to prepare the ROI. Once the final applications are received, and the experience/eligibility matches the stated conditions in the ROI, the program office will fully process and issue the final ROI.
- Operator licensing processes may require that Personally Identifiable Information (PII) is utilized. However, the Report on Interaction (ROI) should NOT include PII to the maximum extent possible.
o Redact all PII before submitting the ROI to the program office.
o If necessary to include PII, contact the program office prior to submitting the ROI.
o Program office will evaluate the need to include PII with the ROI and provide additional guidance for ROI submittal.
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OLMC-160 JuneApril 2020 Individuals initiating interaction requests should check the yearly ROI Index in Sharepoint and review any previous relevant ROIs to prevent duplication, before contacting the NRR program offices Operator Licensing Assistant (OLA) to request the next sequential ROI number. The ROI Combined Index and individual folders containing each years ROIs are located in the Agency-Wide Documents Access and Management System (ADAMS)
Main Library under NRR/NRR-DIRS/NRR-DIRS/IOLB/ROIs.
- ROI initiator will complete Attachment 1 by filling out the following sections:
o Interaction No.
o Subject o Type of Action (Check appropriate) o From/To o Additional Information o Background o Recommended Action/Resolution
- The initiator must provide orprovide or attach sufficient background information on Attachment 1 for the program officeprogram office to understand and resolve the issue.
- The initiator should also provide a suggested resolution and a reasonable proposed due date.
o The initiator should assess ROI complexity to determine proposed due date. ROIs involving operator eligibility, and OGC concurrence may take longer than other types of submitted ROIs.
- Provide proposed ROI to the regional branch chief for review and concurrence.
- 3. Regional branch chief ROI responsibilities:
- The regional Branch Chief must Review and approve provide concurrence of any ROI that originates in the region and forward a completed copy, electronic or hard copy, of the ROI to the applicable program officeprogram office for final resolution.
- To expedite processing, the ROI and any supporting information should be electronically mailed to the NRR program officeProgram office OLA, who will log it in, and to the applicable and to the program office ooperator llicensing program office Bbranch Cchief. The Branch Chief will assign a staff member to review the 4
OLMC-160 JuneApril 2020 ROI and inform the OLA, who will enter the assignment in the ROI log. For ROIs whose resolution may involve both NRR and NRO, the regional office should discuss which program office will be the lead program office with both the NRR and NRO program office branch chiefs prior to submitting the ROI. The non-lead program office may still be on concurrence for a specific ROI.
- 4. Process for program office generated ROIs:
- Periodically, the program office will determine a need to provide information to the regions through a program office generated ROI.
- The individual initiator process for a program office generated ROI is similar to the individual process described above, with the following exceptions:Any ROI resolution that involves an interpretation of a regulation will be sent to the operator licensing contact in the Office of the General Counsel (OGC) for concurrence. OGC concurrence is not limited to interpretation of a regulation:
Every ROI shall go to OGC unless the applicable program office determines that OGC concurrence is not warranted (for example, OGC has previously provided concurrence on another, similar ROI). If such a determination is made, a justification for not providing the ROI to OGC must be provided. If there is any doubt, the ROI shall go to OGC. OGC may require a formal tasking memorandum before performing any work on the issue, and the expected response time for routine items can be lengthy. The responsible program office staff will coordinate the final resolution of these interactions commensurate with the OGC recommendation. Additionally, the Staff should consider notifying the Commission prior to authorizing any ROI whose resolution would result in a substantial departure from the processes specified in NUREG-1021.
o The initiator of the ROI shall not provide input to the resolution process more than providing information in the Recommended Action/Resolution section of Attachment 1.
o OL program office branch chief cannot initiate an ROI. Program office staff will initiate the ROI.
o ROIs generated in the program office will be approved by the program office branch chief.
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OLMC-160 JuneApril 2020
- 5. NRR program office OLA responsibilities:
o ROI sequential number is obtained via the ROI Index located on IOLB SharePoint site referenced above. OLA should distribute the next ROI number in succession to the ROI initiator.
- Once the regional offices send the ROI to the program office OLA, the ROI is to be forwarded to the operator licensing program office branch chief, if not included in e-mail from region.
- Update ROI Index with ADAMS accession number and date of dispatch received from the administrative assistant (AA).
- Maintain a record of all unresolved draft ROIs and those that have been sent to OGC for concurrence.
- 6. Program office responsibilities for proposed ROIs:
- The operator licensing program office branch chief receives a proposed ROI from regional/HQ offices and ensures the OLA enters it in the ROI assignment tracker.
- The program office staff reviews the ROI and works with the regional staff, as necessary, to facilitate final resolutions and to adjust the due date for any ROI that cannot be completed by the date proposed.
- The program office staff documents final resolution of the ROI and ensures proper admittance to the ADAMS Main Library per instructions provided in Section C.9.
- The ROI is routed for approval via:
o The program office staff routes the ROI with finalized resolution to the operator licensing program office branch chief.
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OLMC-160 JuneApril 2020 o The operator licensing program office branch chief approves and signs the ROI.
o The program office staff routes the approved ROI to the Administrative Assistant for final distribution.
- The operator licensing program office branch chief ensures an update is performed for any policy clarification or interpretation (generally in the form of a question and answer) on the operator licensing feedback web site:
https://www.nrc.gov/reactors/operator-licensing/prog-feedback.html
- Final resolutions that require follow-up action, such as a revision to NUREG-1021, Operator Licensing Examination Standards for Power Reactors, will be reviewed and tracked by program office staff, as designated by the operator licensing program office branch chief.
- The operator licensing program office branch chief periodically reviews the ROI Index record to ensure that ROIs are finalized in a timely manner consistent with the proposed due dates and that any associated follow-up actions are initiated.
- 7. Program office administrative assistant (AA) responsibilities:
- The AA distributes the ROI ADAMS Accession Number to all operator licensing branch chiefs and OLAs via e-mail.
- Every ROI shall go to OGC unless the program office determines that OGC concurrence is not warranted (for example, OGC has previously provided concurrence on another, similar ROI).
o If such a determination is made, a justification for not providing the ROI to OGC must be provided. If there is any doubt, the ROI shall go to OGC.
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OLMC-160 JuneApril 2020
- Any ROI resolution that involves an interpretation of a regulation will be sent to the operator licensing contact in the Office of the General Counsel (OGC) for concurrence.
- The operator licensing program office staff is to send proposed ROIs to OGC via the following e-mail: RidsOgcMailCenter Resource RidsOgcMailCenter.Resource@nrc.gov
- OGC concurrence is not limited to interpretation of a regulation.
- OGC may require a formal tasking memorandum before performing any work on the issue, and it should be noted that the expected response time for routine items can be lengthy.
- The program office staff will coordinate the final resolution of these interactions commensurate with the OGC recommendation.
- Staff should consider notifying the Commission prior to authorizing any ROI whose resolution would result in a substantial departure from the processes specified in NUREG-1021.
The NRR program office OLA will maintain a record of all unresolved draft ROIs and those that have been sent to OGC for concurrence. Both NRR and NRO program office operator licensing Branch Chiefs will periodically review this record to ensure that ROIs are finalized in a timely manner consistent with the proposed due date and that any associated follow-up actions are initiated.
- 9. Processing an ROI with an approved final resolution into ADAMS:
- The applicable program office staff will work with the regional staff, as necessary, to facilitate final resolutions and to adjust the due date for any ROI that cannot be completed by the date proposed. The regional office will request and obtain from the facility licensee any additional information that the applicable program office staff needs to resolve an issue.
The applicable program officeprogram office staff will document the final resolution and add the electronic document and supporting documentation to the ADAMS in accordance with NRC Form 665 and using the guidance provided on NRC Form 665, Instruction and Cheat Sheet, ML15313A310.
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OLMC-160 JuneApril 2020
- The following guidance is provided to assist in completing NRC Form 665 pertaining specifically to ROIs:
o ROIs are submitted to the ADAMS Main Library under NRR/NRR-DRO/NRR-DRO/IOLB/ROIs.
o The Document Title for the ROI will be in the format: ROI-YY-##:
[Brief Title].
o Place the following in the Document Title(s) or Accession No. box beneath the ROI title:
Special Instructions: Please upload the file to the NRR/NRR-DRO/NRR-DRO/IOLB/ROIs/CY 20## folder within ADAMS.
o All ROIs are designated as Non-Publicly Available.
o Sensitivity classifications as follows:
B.1: Non-Sensitive - no PII information is included A.5: Sensitive - Privacy Act (if PII information is included) o Document SECURITY ACCESS LEVEL should be completed as follows:
NRC Users should NOT be checked Check Limited Document Security box List the following individuals as Owner:
- NRR Admin
- Reviewer (by name)
- Document Processing Center
- OL program office branch chief (by name)
- IOLB Generator of Response (by name)
List the following as Viewer:
- NRR-Operator Licensing Group
- The program office administrative assistant will e-mail the ADAMS accession number to all operator licensing Branch Chiefs, each regional OLA and the NRR 9
OLMC-160 JuneApril 2020 Program Office OLA when the ROI is final and has been placed in ADAMS.
Additional distribution will be as listed on the ROI.
o All completed ROIs are filed by calendar year and by ROI number in ADAMS.
o The NRR program office OLA will update the yearly ROI Index in SharePoint on a quarterly basis.appropriate year ROI folder in the ADAMS Main Library under NRR/NRR-DIRS/NRR-DIRS/IOLB/ROIs .
The ROI title in ADAMS will be in the format: ROI-YY-##: [Brief Title]. PII information is not to be shown in the ROI and is to be redacted by the originating region from any provided supporting documentation before such information is submitted to the applicable program office. All ROIs are designated as non-publicly available.
The ADAMS document security must include viewer access for the NRR-Operator Licensing Group, which will allow all examiners (from any region) to view the ROI. Distribution of the ROI will include Regions I, II, III, and IV Operations Branch Chiefs and OLAs. The NRR and NRO operator licensing program offices will be included on distribution.
- ROIs are internal documents and will generally not be publicly available in ADAMS or posted directly on the web site; most ROIs are very specific in nature and do not merit conversion and posting on the web site.
- Per ADM-200, division director approval is required if the issue involves policy guidance or programmatic direction (e.g., a policy change, policy interpretation, new guidance, or significant change to current guidance). Otherwise, the operator licensing program office branch chief may approve the final action.
- All regional operator licensing branch chiefs will ensure that their respective OLA and examiners maintain access to the ADAMS file directory for completed ROIs.
This will ensure that program office policy is consistently implemented and readily available to all operator licensing personnel attached to each region.
Hard copies are not necessary if the files are readily accessible in ADAMS (e.g.,
in a folder/directory to which every examiner in the regional offices has viewer rights).
- The applicable operator licensing program office Branch Chief must approve the final action/resolution and distribution of every ROI, including authorization to post any policy clarification or interpretation (generally in the form of a question and answer) on the operator licensing feedback web site (at http://www.nrc.gov/reactors/operator-licensing/prog-feedback.html ). ROIs are internal documents and will generally not be publicly available in ADAMS or posted directly on the web site; most ROIs are very specific in nature and do not 10
OLMC-160 JuneApril 2020 merit conversion and posting on the web site. Per ADM-200 (for NRR) and ORG-102 (for NRO), Division Director approval is required if the issue involves policy guidance or programmatic direction (e.g., a policy change, policy interpretation, new guidance, or significant change to current guidance). Otherwise, the applicable operator licensing Branch Chief may approve the final action. For ROI resolutions impacting both NRR and NRO operator licensing programs, the non-lead office must concur with the resolution.
- Final resolutions that require follow-up action, such as a revision to NUREG-1021, Operator Licensing Examination Standards for Power Reactors, will be reviewed and tracked by program office staff, as designated by the Branch Chief. NUREG revisions will be processed in accordance with OLMC-110, Control of Operator Licensing Guidance Documents.
- The applicable program office secretary will e-mail the ADAMS accession number to all regional operator licensing Branch Chiefs, each regional OLA and the NRR program office OLA when the ROI is final and has been placed in ADAMS. Additional distribution will be as listed on the ROI.
- All completed ROIs are filed by calendar year and by ROI number in ADAMS, and the NRR program office OLA will update the yearly ROI Index in Sharepoint on a quarterly basis.
- 10. All regional operator licensing Branch Chiefs will ensure that their respective OLA and examiners maintain access to the ADAMS file directory for completed ROIs. This will ensure that program office policy is consistently implemented and readily available to all operator licensing personnel attached to each region. Hard copies are not necessary if the files are readily accessible in ADAMS (e.g., in a folder/directory to which every examiner in the regional offices has viewer rights).
Revising an ROI after initial submittal:
- For ROIs that require changes after their initial submittal, a revised ROI may be submitted by the regional office/program office that submitted the original request.
- The interaction number will be annotated with an R to reflect a revision to the original submittal (i.e., an ROI with an interaction number of 14-08, would be resubmitted by the region as14-08R).
- A note will also be added to the ROI stating that the original ROI was cancelled upon receipt of the revised ROI (i.e., ROI 14-08 cancelled on receipt of ROI 14-08R).
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- In the event thatIf subsequent revisions are required, they will be annotated with the number of the revision following the R, and the ROI will be annotated as above (i.e., ROI 14-08R cancelled on receipt of ROI 14-08R2). Only the current ROI revision will be kept for any ROI.
- 11. Withdrawing an ROI prior to obtaining final resolution:
- In the event thatIf a region submitting an ROI wishes to withdraw an ROI without obtaining a final resolution, the following guidance will be used:
o The OL bbranch cchief from the region that submitted the original request may submit a request (e-mail is acceptable) to withdraw an ROI for which a final resolution has not been issued. This request will be considered a withdrawal.
o The withdrawal request will be sent to the lead OL pprogram ooffice Bbranch Cchief and to the NRR program officeprogram office OLA.
For ROIs that concern both the NRR and NRO OL program offices, the non-lead program office should be copied on any correspondence.
o Once a withdrawal request is received, the lead program officeprogram office will annotate the ROI Final Action/Resolution to capture that the originating region withdrew the ROI, as well as the effective date of the withdrawal (e.g., ROI YY-## withdrawn on
[Month]/[Day]/[Year]).
o The title of the ROI will be updated to include the word WITHDRAWN at the beginning of the title (WITHDRAWN-ROI-YY-
- [Brief Title]).
o The lead OL pprogram ooffice bbranch cchief will approve the ROI (see C.7, above).
o The updated file will be entered into ADAMS, as described above.
previously described.Non-lead OL program office concurrence is not required for withdrawn ROIs.
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OLMC-160 JuneApril 2020 o The NRR program officeprogram office OLA will ensure that the withdrawn ROI is annotated in the yearly ROI Index as WITHDRAWN (may be performed as part of the quarterly update).
- If the program office submitting an ROI wishes to withdraw an ROI without obtaining a final resolution, the following guidance will be used:
o The withdrawal request will be sent to the OL program office branch chief and to the NRR program office OLA.
o Once a withdrawal request is received, the program office will annotate the ROI Final Action/Resolution to capture that the originating region withdrew the ROI, as well as the effective date of the withdrawal (e.g., ROI YY-## withdrawn on [Month]/[Day]/[Year]).
o The title of the ROI will be updated to include the word WITHDRAWN at the beginning of the title (WITHDRAWN-ROI-YY-
- [Brief Title]).
o The OL program office branch chief will approve the ROI.
o The updated file will be entered into ADAMS, as previously described.
o The NRR program office OLA will ensure that the withdrawn ROI is annotated in the yearly ROI Index as WITHDRAWN (may be performed as part of the quarterly update).
- 12. Eliminating/Partially Eliminating a previously resolved ROI:
- In the event thatIf a region submitting an ROI wishes to eliminate thean ROI, the following guidance will be used::
o The OL bbranch cchief from the region that submitted the original request may submit a request (e-mail is acceptable) to eliminate an ROI for which a final resolution has been issued, but the guidance is no longer applicable.
o A partial elimination is also acceptable. This request will be considered an elimination, or a partial elimination.
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OLMC-160 JuneApril 2020 o The elimination/partial elimination request will be sent to the lead OL pprogram ooffice Bbranch Cchief and to the NRR program officeprogram office OLA. For ROIs that concern both the NRR and NRO OL program offices, the non-lead program office should be copied on any correspondence.
o Once an elimination or partial elimination request is received, the lead program officeprogram office will annotate the ROI Final Action/Resolution to capture that the originating region requested to eliminate, or partially eliminate, the ROI, as well as the effective date of the elimination/partial elimination.
o The Final Action/Resolution block will be amended to reflect a strikethrough of the parts of the final resolution that are no longer in effect, and will contain information regarding the portions that are eliminated (e.g., Portions of the final action/resolution for ROI YY-##
eliminated on [Month]/[Day]/[Year] are indicated by a strikethrough due to a request from the originator.).
o The title of the ROI will be updated to include the word(s)
ELIMINATED or PARTIALLY ELMINATED, as applicable, at the beginning of the title (PARTIALLY ELIMINATED-ROI-YY-##: [Brief Title] or ELIMINATED-ROI-YY-##: [Brief Title]).
o The lead OL pprogram ooffice bbranch cchief will approve the ROI (see C.7, above).
o , and the non-lead OL program office branch chief will concur if they provided concurrence on the original resolution. The updated file will be entered into ADAMS, as previously described.described above.
o The NRR program officeprogram office OLA will ensure that the eliminated/partially eliminated ROI is annotated in the yearly ROI Index as ELIMINATED, or PARTIALLY ELMINATED (may be performed as part of the quarterly update).
- In the event that the lead program officeprogram office issues ROI guidance that supersedes a previous ROI; or, guidance provided in an ROI is obsolete; or, ROI guidance has been captured in a permanent revision to NUREG 1021 (i.e., after the revision is published AND in effect), the NRO or NRR OL program officeprogram office may take action to eliminate or partially eliminate an ROI without a request from the originating regional office.
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OLMC-160 JuneApril 2020 o Once an elimination or partial elimination is determined to be necessary by either OL program office, tThe lead program officeprogram office will amend the Final Action/Resolution block to reflect a strikethrough of the parts of the final resolution that are no longer in effect.
o The program office will , annotate the ROI Final Action/Resolution to capture that the ROI was eliminated/partially eliminated with the effective date (e.g., Portions of the final action/resolution for ROI YY-
- eliminated on [Month]/[Day]/[Year] are indicated by a strikethrough.)
o , andThe program office will briefly describe the circumstances of the elimination (e.g., This ROI has been superseded by ROI-XX-XX, or, this ROI has been incorporated into NUREG 1021 Rev XX, etc.).
o The title of the ROI will be updated to include the word(s)
ELIMINATED or PARTIALLY ELMINATED, as applicable, at the beginning of the title.
o The lead OL pprogram ooffice bbranch cchief will approve the ROI (see C.7, above),. and the non-lead OL program office branch chief will concur if they provided concurrence on the original resolution.
o The updated file will be entered into ADAMS, as described above.previously described.
The NRR program officeprogram office OLA will ensure that the eliminated/partially eliminated ROI is annotated in the yearly ROI Index as ELIMINATED, or PARTIALLY ELMINATED (may be performed as part of the quarterly update).
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OLMC-160 JuneApril 2020 ATTACHMENT 1 Report on Interaction Form. If superseding signatures are needed (due to an elimination or partial elimination of an ROI), they may be entered under the original signatures with a corresponding new effective date.
057/201620 Interaction No.:
OPERATOR LICENSING Accession No.: ML REPORT ON INTERACTION (ROI)
Subject:
Type of Action: Waiver: Policy Interpretation: Request for HQ Action:
( Check One )
From: Date:
To: Proposed Due Date:
Additional Info.:
Background / Issue:
1 Attachment
OLMC-160 JuneJuly 201620 Recommended Action/Resolution:
Final Action/Resolution:
(If OGC Concurrence is not obtained, include a justification.)
Distribution: OLBCs, OLAs Signatures / Concurrences Date:
Regional OLBC:
OGC*:
(*A justification must be provided in the Final Date:
Action/Resolution if OGC Concurrence is not obtained.)
Date:
IOLB BC: (may be N/Ad if IOLB is not involved with this ROI)
Formatted Table DRO DD: ( If needed ) (may be N/Ad if HOIB is not involved Date:
HOIB BC: with this ROI) Date:
Distribution Completed by Date:
IOLB AA Date:
( If needed )
(Initials):
DIRS or DCIP DD:
2 Attachment
OLMC-160 JuneJuly 201620 2 Attachment