ML26072A219
| ML26072A219 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/2026 |
| From: | Correll J Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| OLMC-160 | |
| Download: ML26072A219 (0) | |
Text
OLMC-160 March 2026 1
REPORT ON INTERACTION PROCESS A.
PURPOSE The purpose of this operator licensing manual chapter (OLMC) is to establish a system for processing the interactions regarding operator licensing between the regional offices and the Office of Nuclear Reactor Regulation (NRR) such that the following criteria are met:
1.
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.
2.
Program interpretations applicable to the operator licensing (OL) process are only made by the program office in NRC headquarters, the Operator Licensing and Human Factors Branch (IOLB) and are consistently implemented by all the regional offices.
3.
Non-routine deferral, excusal, and waiver requests, as described in NUREG 1021, shall be submitted to the program office for review and approval.
B.
BACKGROUND 1.
Pursuant to ADM-200, Delegation of Signature Authority, the branch chief of the OL program office will provide response to requests from regions for support for examining, licensing and re-licensing power reactor operators and senior operators in accordance with 10 CFR 55. The program office is responsible for ensuring that the regional offices consistently implement the OL process in accordance with established procedures and regulations.
2.
Frequent interactions occur between the regional offices and the program office dealing with the interpretation of the OL program, guidance associated with applicant eligibility, and other aspects of the OL process.
3.
The formal Report on Interaction (ROI) system was established to document these interactions and to assist in consistent implementation of the OL program 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 the OL program by the program office and the regional offices.
OLMC-160 March 2026 2
C.
IMPLEMENTATION 1.
Interactions requiring the ROI system:
Note: During non-emergent situations, the program office staff will not provide a decision based on informal telephone or email requests for program interpretation.
However, informal communications with the program 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.
a.
All OL interactions with the regional offices that require a formal interpretation of the OL program, practices, regulations, NUREGs, or other applicable directives, shall be documented and submitted to the program office via the ROI process.
b.
Interactions such as excusal and waiver requests by license applicants, deferrals of experience or eligibility requirements that are beyond the scope of the region to approve, as described in NUREG-1021.
c.
NUREG-1021 identifies certain conditions or situations that require the regional office to consult the NRR OL program office. In these situations, the regional office should first contact the program office chief, or their designee, to discuss the specific situation. The outcome of the consultation may be documented by email, with the consent of both the program office and the regional office and filed in the facility exam file and/or applicants docket file, as applicable.
Whether documentation is handled by email or through a ROI should be determined based on the specifics of the case. An ROI is required if the situation meets the established ROI criteria (e.g., items a or b above).
2.
General Guidance on initiating a ROI:
a.
The IOLB SharePoint ROI tracker is the main user interface for ROIs. ROIs are submitted via the Submit an ROI link on the IOLB SharePoint home page. IOLB manages submitted ROIs via the ROI Tracker SharePoint List.
The ROI Excel Indices tracker is automatically updated to reflect the SharePoint list and is to be used by the region for reference only.
Do NOT manually update the ROI Excel Indices tracker. The information in the indices automatically updates via Power Automate. If there is an error in the content, notify IOLB staff to correct the SharePoint ROI tracker.
b.
Before drafting the ROI, check the yearly ROI Index on the IOLB SharePoint website and review any previously drafted ROIs to prevent duplication.
IOLB SharePoint ROI Index can be referenced at: ROI Indices
OLMC-160 March 2026 3
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.
o Regional examiners should contact IOLB staff if they do not have access to the ADAMS ROI folder.
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, but they do not provide approval of future actions.)
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 sufficient time to prepare the ROI response. Once the final applications are received, and the experience/eligibility matches the stated conditions in the ROI, the program office will issue the final ROI.
OL processes may require that Personally Identifiable Information (PII) is utilized. However, the ROI should NOT include PII to the maximum extent possible. Individual docket numbers are not on their own PII and can be referenced in ROIs.
o Redact all PII before submitting the ROI to the program office.
o Do NOT enter PII into the ROI tracker. Contact the program office prior to submitting the ROI for instructions on how to provide the PII details directly.
o Program office will evaluate the need to include PII with the ROI and provide additional guidance for ROI submittal.
c.
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:
OLMC-160 March 2026 4
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.
OL program office branch chief cannot initiate an ROI. Program office staff will initiate the ROI.
ROIs generated in the program office will be approved by the program office branch chief.
3.
Roles and Responsibilities a.
ROI Submitter The initiator must provide or attach sufficient background information with a recommended solution for the program office to understand and resolve the issue. Include any recent similar ROI numbers to assist enable efficient review and resolution. The initiator should also propose a reasonable due date for response to ensure appropriate resources and priority of the ROI.
b.
Regional Operations Branch Chief Review and approve regional ROI submittals.
Distribute finalized ROIs to regional OL staff.
Provide any changes to the regional branch members to IOLB staff to ensure necessary access to ROI files through IOLB SharePoint Team member access.
c.
Division of Reactor Oversight (DRO) Division Director Per ADM-200, division director approval is required if the issue involves policy guidance or programmatic direction (e.g., a policy change, policy interpretation) or when determined necessary based on the complex nature of the issue.
d.
Program Office Branch Chief Review and assign program office staff for ROI submittals.
Review and approve final ROIs.
Ensures an update is performed for any program clarification or interpretation (generally in the form of a question and answer) on the OL feedback web site: https://www.nrc.gov/reactors/operator-licensing/prog-feedback.html.
OLMC-160 March 2026 5
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 OL program office branch chief.
The OL 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.
e.
Program Office OLA Ensure ROI numbering within the tracker and indices are consistent. This includes updating ROI titles for revised ROIs (refer to Section 8).
f.
Program Office Assigned Staff Completes the assigned ROI by the due date assigned by the OL BC.
Routes the completed ROI to Office of the General Counsel (OGC), as required.
Completes and processes the completed ROI and memo to the DRO tracker for e-concurrence.
Update ROI Index (SharePoint Tracker Index) with ADAMS accession number.
g.
Program Office AA The AA enters the approved ROI into ADAMS in accordance with Section C.6.
Routes and processes the e-concurrence file for final routing.
Distributes the ROI ADAMS Accession Number to all operator licensing branch chiefs and OLAs via email.
4.
Initiating a ROI:
a.
ROIs are generated through the Submit an ROI link on the IOLB SharePoint Website home page.
The Official IOLB ROI tracker can be found here:
https://usnrc.sharepoint.com/teams/NRR-Operator-Licensing-Branch/Lists/ROI%20Tracker/AllItems.aspx
OLMC-160 March 2026 6
NOTE: When revising an existing ROI, include REVISION in the Title/Subject (ref C.8)
Do NOT include PII in the ROI tracker. Send PII directly to the program office staff.
b.
The ROI initiator will submit an ROI by selecting Submit an ROI on the IOLB SharePoint site and fill out the following sections:
Title/Subject To/From Date Submitted Submitters Supervisor Requested Due date Type of Action Background Information Recommended Action/Resolution Add an attachment, if applicable c.
Once submitted, the submitter will receive an automated email acknowledging the ROI submittal and that the ROI is now with the submitters supervisor for approval.
d.
The proposed ROI will be automatically sent to the submitters supervisor listed on the ROI tracker via email (<flow-noreply@microsoft.com) requesting review and approval.
- The email contains two links:
o The title of the ROI, which is a link to the proposed ROI for review and, if necessary, editing or adding comments to the ROI.
o A link to approve or reject the ROI.
e.
Once a submitted ROI is approved by the submitters supervisor:
An ROI number is automatically generated by the ROI tracker list.
A Microsoft Teams Power Automate Card is sent to the OL Branch Chief.
f.
The program office branch chief assigns a program office staff member to review the ROI as well as a proposed due date via the prompted Teams Card.
g.
Upon program office branch chief assignment:
An ROI template is auto populated with the information provided by the submitter, ROI Number, assigned staff and due date and saved for staff reference on the OL SharePoint site: Here: ROIs auto generated The program office staff member assigned to the ROI is notified via email of the assignment.
OLMC-160 March 2026 7
5.
Program Office completion of the ROI a.
The program office staff reviews the ROI and works to complete it within the assigned due date or coordinates with the regional staff if the due date cannot be met.
b.
The template of the ROI auto populated in step 4.g should be used to draft the ROI response.
Upon completion of the draft ROI, provide the draft ROI to the program office branch chief for preliminary review.
After BC comments are resolved, the staff shall continue to the next appropriate step.
6.
a.
OGC No Legal Objection (NLO) Reviews:
Every ROI shall be provided to OGC for NLO review unless the program office determines that OGC review is not warranted (for example, OGC has previously provided advice on another, similar ROI precedent). An ROI may be exempted from OGC review, even without a similar precedent, if the emergent nature of the issue prevents timely review and division management approves the exemption.
If an ROI is not sent for OGC review, the program office must provide a justification.
Any ROI resolution that involves an interpretation of a regulation will be sent to the OL contact in the OGC for legal review (and subsequent NLO).
The OL program office staff is to send proposed ROIs to OGC via the following form: OGC Work Request OGC review 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
OLMC-160 March 2026 8
ROI with resolution resulting in a substantial departure from the processes specified in NUREG-1021.
b.
OGC Congressional Review Act (CRA) Reviews:
NRC documents that provide or endorse new interpretations of regulatory requirements, as well as policy statements, and changes to the NRCs procedural, organizational, or practice requirements that have substantial effects outside the agency require OGC CRA review.
ROIs that do not meet the CRA criteria or have past similar ROI precedent reviews do not require another CRA review.
The OL program office staff is to send proposed ROIs to OGC via the following form: OGC Work Request.
If OGC NLO and CRA review are required, it is recommended that OGC reviews are submitted separately, meaning OGC NLO review is completed first, and then request for OGC CRA review is submitted via a new OGC Work Request. ROI review timeliness and deadlines should be considered when submitting for NLO and CRA reviews.
7.
Processing an ROI with an approved final resolution into ADAMS:
a.
The program office staff will submit the final resolution via the Complete an ROI link on the IOLB SharePoint Site.
The link is available here: Complete an ROI (note there will be nothing here if there are no ROIs assigned to you) b.
The following guidance is provided to assist in completing the Complete an ROI application:
To edit the ROI data, select the Edit button on the upper right side.
Fill out the following sections:
o Final Action/Resolution. Input the program offices recommended action/resolution as agreed upon.
o OGC NLO Review Required. If yes, provide OGC reviewer name and the OGC review form number.
o OGC CRA Review Required. If yes, provide OGC reviewer name and the OGC review form number.
o OLPF Entry. If yes, provide details on the OLPF entry in the text box.
OLPF entry should be considered for generic issues or program guidance that should be reviewed for dissemination to the industry via the OLPF process.
o Division Director Review Required. If yes, enter Division Directors name.
OLMC-160 March 2026 9
o Click Submit for Supervisor Review Once submitted, the program office staff will receive an acknowledgement email confirming the ROI has been routed. The OL BC, and Division Director (if applicable), will receive an email notification with instructions on review and approving the ROI.
o The email contains two links:
The title of the ROI, which is a link to the proposed ROI for review and, if necessary, editing or adding comments to the ROI.
A link to approve or reject the ROI.
Once approved, the program office staff will receive an email notification with a link to the finalized pdf version of the ROI.
o If denied, the ROI will be routed back to the program office assignee c.
Submit the final pdf of the ROI to the DRO Document Tracker in accordance with NRC Form 665 and using the guidance provided on NRC Form 665, Instruction and Cheat Sheet, ML15313A310.
Include instructions for the AA to distribute the ROI to the submitter, the OL BCs and OLAs.
d.
The following guidance is provided to assist in completing NRC Form 665 pertaining specifically to ROIs:
ROIs are submitted to the ADAMS Main Library under NRR/NRR-DRO/NRR-DRO/IOLB/ROIs.
The Document Title for the ROI will be in the format: ROI-YY-##: [Brief Title].
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.
All ROIs are designated as Non-Publicly Available.
Sensitivity classifications as follows:
o B.1: Non-Sensitive - no PII information is included o
A.5: Sensitive - Privacy Act (if PII information is included)
OLMC-160 March 2026 10 e.
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:
o NRR Admin o
Document Processing Center o
OL program office branch chief (by name) o IOLB Generator of Response (by name)
List the following as Viewer:
o NRR-Operator Licensing Group f.
Upon completion of the e-concurrence process, the program office AA will distribute the final ROI to all operator licensing branch chiefs, each regional OLA and the NRR program office OLA, as noted on DRO Tracker.
All completed ROIs are filed by calendar year and by ROI number in ADAMS.
g.
The NRR program office assigned staff will update the SharePoint ROI tracker with the ML#.
h.
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.
8.
Revising an ROI after initial submittal:
a.
For ROIs that require changes after their initial submittal, a new ROI may be submitted to revise the prior ROI.
b.
When submitting the new revised ROI, the submitter should indicate this by putting REVISION in the Title/Subject section of the ROI tracker.
c.
A note will be added to the ROI tracker stating that the original ROI was cancelled upon receipt of the revised ROI (i.e., ROI 14-08 revised on receipt of ROI xx-xx).
d.
The original ROI will be moved to the ADAMS folder for archived and superseded ROIs if it was previously approved and issued. Process the revised ROI in accordance with the applicable portions of this OLMC.
9.
Withdrawing an ROI prior to obtaining final resolution:
OLMC-160 March 2026 11 a.
If a region submitting an ROI wishes to withdraw an ROI without obtaining a final resolution, the following guidance will be used:
The branch chief from the region that submitted the original request may submit a request (email is acceptable) to withdraw an ROI for which a final resolution has not been issued. This request will be considered a withdrawal.
The withdrawal request will be sent to the OL program office branch chief and to the NRR program office OLA.
Once a withdrawal request is received, the program office staff will route the withdrawn ROI through the Complete an ROI application using section 7, and process the withdrawn ROI into ADAMS for record retention.
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]).
The NRR program office staff will update the withdrawn ROI in the SharePoint ROI tracker from COMPLETE to WITHDRAWN and add the ML #.
- 10. Eliminating/Partially Eliminating a previously resolved ROI:
a.
If a region submitting an ROI wishes to eliminate the ROI, the following guidance will be used:
The branch chief from the region that submitted the original request may submit a request (email is acceptable) to eliminate an ROI for which a final resolution has been issued, but the guidance is no longer applicable.
A partial elimination is also acceptable. This request will be considered an elimination, or a partial elimination.
The elimination/partial elimination request will be sent to the OL program office branch chief and to the NRR program office OLA.
Once an elimination or partial elimination request is received, the program office will confirm the information is no longer applicable (e.g., it has been superseded or it has been incorporated into NUREG-1021).
The eliminated ROI will be moved to the ADAMS folder for archived and
OLMC-160 March 2026 12 superseded ROIs. For partial eliminations, a revised ROI should be issued in accordance with C.8 above such that the revised ROI does not include the information that is not applicable.
The NRR program office OLA will ensure that the eliminated/partially eliminated ROI is annotated in the SharePoint ROI Index as ELIMINATED, or PARTIALLY ELMINATED(REVISED) (may be performed as part of the quarterly update) with the reason for elimination/partial elimination.
If the program office issues ROI guidance that supersedes a previous ROI, 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 program office may take action to eliminate or partially eliminate an ROI. The program office will follow the same steps as listed above.
ATTACHMENT:
1.
Report On Interaction Form
OLMC-160 March 2026 2024 13 ATTACHMENT 1: Report On Interaction Form Note: The official ROI form is on the IOLB SharePoint Site. This form is for backup use only.
OPERATOR LICENSING REPORT ON INTERACTION (ROI) FORM
Subject:
Subject ROI No.: Number From: From Date: Date submitted Type of Action: Type of Action Proposed Due Date: Due Date Background / Issue:
Background
OLMC-160 March 2026 2024 14 Recommended Action/Resolution:
Proposed Solution Final Action/Resolution:
OLPF Review:
OGC CRA Review:
BC Approval:
DRO Division Director Approval: