ML19309F949

Discusses Encl Revised Procedures for Endorsement of Research & for Processing Research Requests.Recommends Approval.Supportive Memos Also Encl

ML19309F949
Person / Time
Issue date:	11/28/1979
From:	Levine S NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
Shared Package
ML19309F950	List: ML19309F949 ML19309F954 ML19309F958 ML19309F960 ML19309F963
References
SECY-79-635, NUDOCS 8005020054
Download: ML19309F949 (15)

Text

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800s0 0 054 2

November 28, 1979 SECY-79-635 COMMISSIONER ACTION For:

The Commissioners From:

Saul Levine, Director Office of Nuclear Regulatory Research Me300 Thru:

Lee V. Gossick j,

g Executive Director for Operahop

Subject:

REVISED PROCEDURES FOR END0RSEMENT OF RES RESEARCH AND FOR PROCESSING RESEARCH REQUESTS

Purpose:

To obtain Comission approval of the revised procedures for the endorsement of RES research and for processing of research requests.

Discussion:

In order to improve RES's ability to meet the agency's needs in the area of nuclear regulatory research, RES has prepared revised procedures for the endorsement of research and for the processing of research requests.

In the revised policy statement, the procedures have been clarified and expanded upon to be more responsive to NRC's overall needs and result in the following approach:

(1) the bulk of our research projects will still be endorsed and processed under the existing procedures (SECY-77-1308), including specific provisions to allow multi-year endorsement; (2) the proposed procedures would now permit the programatic endorsement of a RES program, developed in response to a user request which may involve several projects and several years of effort; (3) the flexibility which allows the RES Director to endorse research programs / projects within specific limits.

It has been noted by ACRS, EDO and other Program Offices that the current procedures (SECY-77-130B) are restrictive and lack flexibility.

In addition, OPE /0GC has stated:

"the current user requirement l

Contact:

R. M. Scroggins, RES

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2 formulation deprives the agency of the potential benefits from a more independent research program formulation..." While much of the underlying philosophy

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that the Commission adopted in SECY-77-130B has been retained, the revised procedures are intended to provide RES with more flexibility in initiating programs and in the endorsement of requested research

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programs. The new procedure provides accountability

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on programs initiated by RES and continues to provide assurances that research programs and projects conducted by RES are responsive to NRC's overall needs.

In particular, the nature of endorsement, the relationship to the budget process, and specific l

endorsement steps are clarified and spelled out clearly.

The main specific change that we are seeking is as i

follows: the new procedure allows for the endorsement of RES research programs / projects by the RES Director i

up to a limited percentage of the total RES budget, (between 15 and 30 percent) with specific limits on the size of any one program annually, to below a million dollars. Programs endorsed in this way would also t.e subject to the same budgetary and administrative constraints as the rest of the RES budget. Concurrent with the initiation of any contractual action on any program / project endorsed by the RES Director, the ED0 and other relevant Program Offices would be informed of the program, including objective (s), funding level and estimated completion date. This action allows RES to initiate programs of:

(1) an exploratory nature that may lead to the discovery of gaps in safety protection that are not currently recognized with sufficient clarity; (2) programs of high potential and high uncertainty as to the nature and usefulness of the results; (3) long term programs whose usefulness transcends immediate regulatory needs; (4) programs that may provide insights, perceptions, and radically new approaches to dealing with the issues involved.

The proposed procedure would also permit the programatic endorsement of an RES program developed in response j

to a user request. A programmatic endorsement is one that covers several individual but closely associated research projects (such as the many

9 3

projects comprising the LOFT program).

The usual endorsement, which has been in use up to now, will continue; that is, on an individual project-by-project basis as is done under the existing procedure (SECY-77-1308). The new procedure also describes how a multi-year endorsement can be generated for efforts that stretch over more than a single fiscal year, but describes checks and balances for such an endorsement. The programmatic endorsement will facilitate the drawing of expertise from multiple sources (National Laboratories, Industry, etc.) in developing a broad program to address a particular perceived objective.

Procedures for transfer and utilization of research results into the regulatory process (Research Information Letters) embodied in SECY-77-130A are not impacted by the user endorsement modification recommended herein.

We believe that the revised procedures will allow the NRC's research program to respond more effectively to the Agency's needs and will improve the benefit of these programs to meeting the NRC's safety mission.

Recommendation:

That the Commission approve the revised procedure presented in the enclosure.

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Coordination:

Concurrence in principle with the concepts in the revised procedure has been obtained from all staff offices. At are specific office comments.

Several offices desired further clarity regarding user office involvement during program implementation; revisions have been made to address these concerns.

Several offices also comented

~on the proposed level of funding available for RES endorsed projects (15-30%).

Scheduling:

It is expected that this matter will not require discussion at a Comission meet' g.

/

Saul Levine, Directbr Office of Nuclear Regulatory Research

Enclosures:

1.

Procedures _for Endorsement of RES Research and for Processing Research Reauests 2.

Office Coments EDO NOTE:

I recomend RES be limited in its authority to approve research programs for which user office endorsements cannot be obtained j

to an aggregate total not to exceed 15% of the Research program support budget, and to projects not exceeding a total cost of

$1 million each.

I believe the Comission will want to discuss this paper at an open meeting and may wish to ask the ACRS to provide its coments on the prooosed arocedures.

A

• /

4e V. Gossick l

Executive Director for Operations i

Comissioners' coments should be provided directly to the Office of the Secretary by c.o.b. Wednesday, December 12, 1979.

Comission Staff Office coments, if any, should be submitted to the Comissioners NLT December 6,1979, with an infonnation copy to the Office of the Secretary.

If the paper is of such a nature that it requires additional time for analytical review and comment, the Comissioners and the Secretariat should be apprised of when comments may be expected.

DISTRIBUTION Comissioners Comission Staff Offices Exec Dir for Operations ACRS Secretariat j

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't PROCEDURES FOR ENDORSEMENT OF RES RESEARCH AND FOR PROCESSING RESEARCH REQUESTS I.

Introduction II.

Relationship to the Budget Process III.

Types of RES Research IV.

Sources of Research Goals and Program Ideas V.

Formulation and Implementation of the RES Research Program VI.

Coordination of Research and Technical Assistance Needs VII.

The Formal Research Request Procedure A.

Information Content of Research Requests B.

Processing of Requests for Rt search C.

The Endorsement Step VIII.

The Nature of Endorsement IX.

Research Carried Out By RES Under Its Own Endorsement X.

Implementation of This Policy

r PROCECURES FOR ENDORSEMENT OF RES RESEARCH AND FOR PROCESSING RESEARCH REQUESTS I. INTRODUCT10:4 This procedure defines the process for the endorsement and implemen-tation of research carried out by the Office of Nuclear Regulatory Research(RES).

This endorsement /research request procedure super-sedes the procedure adopted in SECY-77-130B of December 6, 1977, taking into account experience with the research request procedure in the intervening period. This endorsement procedure applies to all RES research projects initiated from this time forward.

Risk assessment research is not included in this procedure.

During the past two years, it has been recognized by RES, ACRS, E00 and other Program Offices that the previous procedures for endorsement of RES research and for processing research requests are restrictive and lack flexibility. This fact was also noted in a recent study by 0PE* which listed three options to improve the operation of RES in meeting the agency's needs.

All of the options discussed in that study called for increased flexibility in the endorsement process. The new procedures will remedy the concerns cited in the report and also address the concerns of other Program Offices on RES's responsiveness to their research needs. The new procedure allows the RES Office Director to endorse RES research programs himself, limited to a percentage of the RES budget and less than a million dollars per program and subject to the same budget review as the rest of the RES budget (See Section IX). Most of the endorsements will be handled as in the past on an individual project by project basis (see Section VIII); however, a benefit of the new procedure is that it allo.fs for programatic endorsement of large RES programs, especially where many of the results are not directly related to specific user needs but are of great importance to the major objectives of NRC's research program (such as LOFT, PBF, Advanced Reactors, etc.)

This procedure must be viewed in relationship to the agency's budget process, which begins with Comission development of priorities and ultimately results (after OMB, Presidential, and Congressional action) in the allocation of funds to the Office of Nuclear Regulatory Research in Decision Unit format.

This procedure includes methods by which requisite endorsement of RES programs occurs so as to assure the relevance and timeliness of the research to the policy directions embodied in the Comission budget detenninations.

Once the budget allocation for a given fiscal year is made, it represents Comission policy approval for the entire RES budget.

• " Review of Delegations of Authority Within NRC." September 1979

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.c It must be recognized that there are countervailing factors in this process. Those which vpear on the surface to make the process most relevant to fulfilling agency needs tend through delays and apparent inefficiencies to inhibit the timeliness and responsive-ness of the RES program; those which ensure timeliness and res-ponsiveness appear to give a somewhat lower assurance of relevance.

A balance must be found between these factors.

In finding such a balance, it is important to understand that, as in all research efforts, once a scope of work is undertaken details of the work can later be defined or modified to ensure adequate responsiveness, if needed.

As used herein, the tenn endorsement refers to a particular approval action that is required before initiation or significant re-direction of a research contract. Endorsement is accomplished by the Director of a sponsor Program Office, including in some cases only the RES Director, or 5y the Executive Director for Operations (ED0), or by Comission approval of a staff japer. This procedure describes the i

various processes whereby research prog-

• and projects receive endorsement befors contracting action begins.

II. RELATIONSHIP TO THE BUDGET PROCESS The budget process is the agency-wide planning process in which the i

Comission, together with the staff, determines the overall priority of agency programs. This process begins with the annual preparation of future plans and requirements by the various NRC Offices. The proposed budget is then reviewed substantively by the Budget Review Group (BRG) prior to ED0 and Commission consideration.

It is in the earliest stages of RES' annual budgetary planning that user office input first comes into play, because such Offices' requirements are considered in the development of the RES budget.

Some RES programs may already have obtained endorsement prior to submission of the RES budget to the BRG if they involve either ongoing work or work already endorsed that is being prepared for initiation.

It is expected that the RES budget will be formulated with significant interaction with other Offices whose recuirements are being supported by the proposed budget: this will facilitate endorsement of much of the RES budget prior to BRG review.

However, as noted earlier, this type of endorsement need not cover all details of proposed programs: this will be discussed further below (seeSectionVIII).

Specific objectives for RES programs and projects will be contained in a program plan which will include statements of work for individual projects specifying the goals, schedules, and deliverables proposed

• A research program represents an ensanble of closely associated research projects. Examples of programs include LOFT and PBF, each of which encompasses a number of related projects.

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by RES.

This plan forms the basis for user office endorsement of the program or project. The objectives should be measurable and attainable wi+hin the approved budget.

It is recognized that there will be some areas of research where

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there will be no endorsement of specific programs / projects prior to annual budget preparation. This will be the case, for example, l

when broad recearch support in a given area is agreed to by a potential sponsor office but a detailed program plan has not yet j

been completed, or when funds are kept in reserve by RES to fill shorter-range needs which experience has shown arise frequently throughout the year, after a budget has been formulated.

In the cases where endorsement is not accomplished prior to development of the RES annual budget, endorsement will be obtained by one of the mechanisms described in Section VII.

III. TYPES OF RES RESEARCH There are three types of research carried out by RES, and they have different relationships to the direct regulatory needs of other NRC Offices:

1.

Some research provides direct support for a present or near-term NRC regulatory function.

This research is characterized by a specific and close relationship with the function or responsibility of another NRC office, and generally encompasses shorter range work at the project level, rather than at the larger program level.

It may also encompass prograc.1 level efforts, however, if a specific and relevant reguletory application exists. A most recent and somewhat special example of this type of research was the development of a number of short tenn projects in response to the accident at Three Mile Island Unit 2.

2.

Some research provides or maintains an NRC capability over a broader range of functions or a longer time period than that usually associated with the operational needs of an individual program or staff office. This research is characterized by its concentration on long-tenn or broad agency objectives, rather than on the short-range program needs or ininediate requirements of any one NRC office.

It thus tends to be broader in scope and longer-range in time than research of the first type.

Examples include long range research on the l

safety of advanced reactors; research on the health effects of low levels of radiation exposure; research carried out over a 1

multi-year time period on major facilities such as LOFT and j

PBF; and research to provide an agency-wide basis for more objective and uniform regulatory decisions in the safeguards a rea.

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3.

Some projects are carried out to permit RES to improve its j

capability to carry out its research mission.

Such research is generally only indirectly related to the needs of other i

offices, and they usually are unlikely to request work of this i

type. This includes research to support other projects, as well as necessary, higher risk research. An example is research to develop advanced instrumentation, based on a concept not yet f Jlly proven, to be used to conduct other usearch.

Another example is research to develop alternative approaches to r sgulatory assessments; such work may be by its nature uncertain of success but has the potential for significant value. Still another example might be development of basic data needed to implement another research effort (for example, research on steam explosions to permit more precise risk assessments to be perfonned).

This type of research bears a relationship to the larger RES mission that is similar to the relationship of technical assistance projects to the missions of the other Offices. By its nature, most research of this type would be sponsored by RES.

IV. SOURCES OF RESEARCH G0ALS AND PROGRAM IDEAS NRC's research goals and program ideas are identified by a large number of sources. The most common source of new research goals and ideas is the recognition within one of the agency's licer.51ng, standards or inspection Offices of a need to perfnna research to improve that Office's ability to carry out its mission. Another common source is an agency-wide realization (often initiated or focussed by the Office of Nuclear Regulatory Research itself) of the importance of carrying out research to prepare the entire agency for some likely future need... research nn the safety of advanced reactors is a good example of this. Also, the RES Long Range Research Plan provides research goals which have been developed by RES with the input of the various Program Offices.

Other sources of research recomendations include the Comission, its staff, the ACRS, the Congress, public interest groups, the states, the nuclear engineering comunity, foreign nuclear experts, or the nuclear power industry. An extraordinary source of research goals and j

program ideas has come from the RES assessment and the Lessons Learned Task Force on the TMI-2 accident.

The methods by which such research ideas and goals are comunicated

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to the Office of Research are diverse, ranging from formal requests from NRC Offices to advice offered in scholarly publications, and also including Comission and ACRS coments, letters to NRC from outside the agency, Congressional legislation, and reports by special study groups and panels.

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.i V. FORMULATION AND IMPLEMENTATION OF THE RES RESEARCH PROGigdi Whatever the source of a suggested research topic, once it has been comunicated to RES its eventual incorporation into th RES research program requires a succession of five steps described as follows.

This series of steps is nearly the same no matter what the source of the original suggestion, or the manner in which its detailed fomulation is brought to the attention of RES:

1.

The idea must be formulated into a statement of need, or goal (research requirement), described well enough so that the usefulness or benefit to NRC's mission is delineated clearly, and in sufficient detail to permit RES to evaluate its priority relation to other needs and to develop a specific program or project plan. Usually, an Office oti;er than RES formulates the research requirement and transmits it to RES in the form of a user office research request (see Section VII).

If one i

of the bodies other than another NRC Office originates a research request, RES becomes the sponsoring office for that research.

2.

RES must convert the research request into a detailed plan for a program or project whose scope, level of effort, and timing is responsive to the research requirement and then seek agreement on the plan from the sponsoring office.

As a minimum, the program plan will contain a program overview, a detailed statement of work for each individual project of the proposed program, a cost estimate for the program by fiscal year, and a schedule of major milestones including all deliverables.

3.

RES must establish the priority of the proposed work in relation to other research either ongoing or planned. This priority assignment will generally follow the Decision Unit priorities established in the budget process and will be coordinated with other NRC Offices, with the EDO, and with the Commission, as appropriate.

l 4.

The RES budget allocation eicher must already encompass or must be modified to encompass sufficient financial resources (through the agency budgec or reprograming processes) to fund the proposed effort.

5.

Contracting action is initiated.

Endorsement is required before contracting action can be initiated.

As discussed above, endorsement should nomally be accomplished between steps 3 and 4 (that i.s, prior to the initial budget allocation for the fiscal year).

However, in some situations a budget allocation exists already, sometimes even before step 1 occurs.

In that case, endorsement still comes after step 3 but the budget allocation step (step 4) would occur earlier.

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. There are several important features of the five step process that require elaboration.

Perhaps the two most challenging steps to accomplish are the clear delineation of the research request so a; to demonstrate its importance to NRC; and the conversion of that request into a specific body of proposed work, with sufficient detailing of ultimate and intermediate objectives, milestones, experimental or analytical requirements, and so forth to render it manageable by MBG methods and suitable for contracting action.

Considering the first of these two tasks, it is often the case that the research requirement is delineated and justified by a sponsoring NRC Office. Usually RES provides assistance in that effort. Where several NRC Offices are identified as potential users, or where the proposed area of research is too broad or too long range in character to aller identification of a particular user, RES itself undertakes the delineation and justification of the research requirements.

The second key task, the conversion of the research request into a detailed plan with statements cf work is primarily the responsibility of the Office of Nuclear Regulatory Research.

RES interacts, as appropriate, with whatever relevant expertise exists elsewhere:

this usually includes staff in other NRC Offices, as well as sources of expertise outside of NRC (from laboratories, universities, the nuclear industry, private consultants, etc.).

It can also include advice from Research Review Groups.

Because of funding or time constraints, some new programs or projects may be delayed until the following fiscal year, or perhaps for two fiscal years, before they can be implemented.

In these situations the sponsoring Office will be kept informed on the status of the research request.

For more urgent work, reprogramming of RES or other funds may be considered as appropriate.

Any decision to reprogram will be made in consonance with procedures

• established by the Controller, based on results of a review of the relative priorities of ongoing and planned research and technical assistance projects.

In any case, the responsibility for the priority assignment and allocation of research funds between program areas lies primarily with RES, which obtains advice and concurrences from other Offices as appropriate.

• Memo, Controller to Distribution re " Procedures Within NRC to Reallocate Funds," dated April 29, 1976

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. VI. COORDINATION OF RESEARCH AND TECHNICAL ASSISTANCE NEEDS Coordinators are designated by each of the five NRC major Program Offices and the EDO.

They coordinate the identification of research requirements, ensure the absence of unnecessary duplication between i

research programs and technical assistance projects, expedite the response to research requests, and coordinate agreement on proposed research.

VII. THE FORMAL RESEARCH REQUEST PROLEDURt A.

Information Content of Research Requests As discussed above, much of the RES research program is carried out in direct support of r. present or anticipated NRC regulatory function. This resea'ch is usually initiated as a result of a specific request su'enitted to RES directly from one of the other four major Pragram Offices, or indirectly.

through the ED0 from one of '.he staff Offices.

These formal requests are called user research requests.

These formal requests will describe tha need in terms of how the research results will be used to benefit the regulatory functions of NRC. The request should include descriptions of the programmatic and technical requirements with enough information so that RES can formulate a detailed program plan, with statements of work in response. The request must also provide information concerning the timing and relative priority of the request.

A properly formulated research request should be so structured to enable RES to develop an adequate response; it should allow sufficient flexibility to RES and should only rarcly be so specific as essentially to predetermine RES' response in detail.

B.

Procest.ing of Requests for Research i

RES will take action promptly on each research request received.

This action will be in the form of a detailed program plan for the research or a recommendation that the research be deferred or not be initiated. Within 90 days after receiving a research request, RES will inform the sponsoring Office in writing of the action that RES recommends.

C.

The Endorsement Step After RES has fully developed its program plan with statements of work in response to a formal research request, RES will submit it to the requesting Program Office Director (or the ED0 for a staff Office) for his endorsement.

For research formulated by RES in response to needs identified other than l

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by a fomal research request, RES will attempt to obtain the endorsement of another Program Office Director, the EDO, or the Commission by approval of a staff paper.

The Director of RES also has the flexibility to endorse a fraction of the l

program without further endorsement (see below).

Endorsement through one of these mechanisms is required before contracting i

action can be initiated.

VIII. THE NATURE OF ENDORSEMENT Sponsor Office or EDO endorsement of proposed program plans will be obtained with respect to the technical content and timing of each proposed program or project so as to assure that the intent of the research request is being addressed.

Occasionally, an endorsement will cover a program that is made up of a number of individual projects taken together, some of which may not be fully defined, especially in multi-year efforts.

In those cases where individual projects are not well defined, an endorsement will be requested as the program develops. Usually, an endorsement will cover an individual project, but endorsement of larger programs that include several individual projects, will occasionally occur.

A decision on endorsement or non-endorsement of research should be based on whether the detailed program plan is responsive to a user Office need, with administrative and managerial matters given minor attention since these are the responsibility of RES.

Also, details at the task level should not fom the basis for an endorsement decision; task formulation is part of RES' responsibility, with appropriate input from other Offices.

Endorsement by another Office signifies the concurrence of the endorser that the RES detailed program plan and statement of work meets the defined need.

It does not imply responsibility for direction, monitoring, and performance of the contractors, which responsibility remains with RES. During the implementation phase, there will be continued coordination and information exchange, which will include sponsoring Office participation in source selection panels and for other mechanisms for coordination and information exchange such as Research Review Groups, the annual budget review process, the ACRS annual review of the research program routine staff interactions, site visits, contractor publications, and reports by contractors at periodic review meetings and technical conferences.

These mechanisms will be employed for review of both individual project! and programs involving multiple projects.

When a program or project developed by RES has a multi-year duration, this fact will be pointed out in the research plan.

Endorsemenn either by another major Office or by ED0 will remain in effect throughout the multi-year period covered, unless there is significant redirection, modification, or extension of the approved work.

In the event that the possibility is raised of withdrawal of endorsement, consideration should be given to the impact such withdrawal would have on the contractor, on the needs of the agency, and in some cases on international commitments.

I

e-o,

. Occcsionally, a program is undertaken without a firm termination time:

for example, RES might undertake a multi-year program of experiments on a major facility, such as LOFT, with the actual experimental program to be re-examined based on the results of the various tests as they occur.

In such cases, it is expected that endorsement will cover the entire program with review points indicated following completion of key program milestones. In those situations where major redirection of a program is deemed necessary, concurrence of the sponsoring Office Director will be requested.

IX. RESEARCH CARRIED OUT BY RES UNDER ITS OWN END0RSEMENT The Comission recognizes that occasionally the Office of Nuclear Regulatory Research will develop research ideas for which no endorse-ment is sought or for which no endorsement can be obtained from another Office.

For example, the Director of RES requires resources to aid in the long-range planning and management of work and rapid resolution of problems. Also, there may sometimes arise genuine technical disagreements between RES and other Offices as to the relevance, timeliness, probability of success, or usefulness of the proposed research. Alternatively, the RES Office Director may occasionally decide not to seek outside endorsement.

This could arise, for example, with highly speculative research, or with expenditures of minor amounts of funds.

Also, high levels of innovation are sometimes found in unsolicited proposals containing novel and meritorious ideas.

To realize the agency-wide benefits of giving flexibility of this kind to the Office of Nuclear Regulatory Research, the Commission permits the RES Office Director to endorse RES research himself, limited to a fixed percentage of the RES budget, subject to other budgetary and administrative constraints, and within Decision Unit allocations. This authority extends to endorsement of individual programs less than a million dollars each, and in aggregate total not to exceed 15 to 30 percent of the research budget.

The ED0 and the Directors of other relevant Offices will be informed of each program / project initiated under this arrangement prior to l

ontract initiation. These projects will be summarized in our annual report to the Comission.

X. IMPLEMENTATION OF THI'S POLICY i

This policy supersedes the policy adopted in Comission staff paper SECY-77-1308, and applies to all new contracts except risk assessment i

contracts initiated after its adoption.. Research programs and I

projects previously endorsed, either under the SECY-77-130B user request procedure or by adoption of a Comission staff paper, do not require re-endorsement.

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