ML20003F310
| ML20003F310 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/1981 |
| From: | Steele M NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Besaw W NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML19284C410 | List: |
| References | |
| NUDOCS 8104200574 | |
| Download: ML20003F310 (2) | |
Text
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March 9,1981 MEMORANDUM FOR: William J. Besaw, Director Division of Technical Information and Document Control, ADM FROM:
Myrna L. Steele, Deputy Director Division of Technical Information and Document Control, ADM
SUBJECT:
ANALYSIS OF OMPA STUDY OF NRC'S AUTOMATED DOCUMENT RETRIEVAL SYSTEM (ADRS) AND THE ED0 MEMORANDUM OF NOV. 18, 1980 REDIRECTING THE DOCUMENT CONTROL SYSTEM PORTION OF ADRS In accordance with Manual Chapter NRC-4125, " Differing Professional Opinions,"
I am submitting the subject report. My paper is a point-by-point analysis of the four sections of the EDO memorandum:
(1) the sunmary ED0 memorandum; (2) the mandated DCS Actions; (3) the OMPA-prepared briefing package; and (4) the so-called evidence package 7~Those " evidence" points that are essentially correct are, in general, not included in my analysis. Where some " evidence"
' points are correct in part, I have noted the agreement, delineated where the information was omitted, and corrected information that is erroneous.
There are three things about the report that I find particularly interesting:
1.
The number of omissions of fact and omissions of substance are staggering.
These omissions are particularly important whan one considers that the redirection of the project was based on this Ltudy alone, ignoring 10 years of studies and collections of information needs and requiremenes for techni-cal information support.
The omissions are specifically noted and discussed in nty Response columns in the attached text. As an example, " Finding A" of the OMPA report purports to address the requirements and user needs. However, all of the infonnation we gave the seven different OMPA study group members over the five months of the study is not included; nor is it even referenced.
In fact in the " evidence" package for " Finding A," alone, there are six major omissions.
In the whole report there are at least 17 major omissions.
2.
The lack of logical progression from the ED0/DED0 memo to the DCS Actions mandated by the ED0/ DEDO, then to the briefing package, and finally to the so-called evidence package have made it extremely difficult to organize a logical presentation of cmissions and of errors o'f fact and of judgment.
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W1.lliam J. Besaw, Director Division of Technical Information and Document Control, ADM 2.
In fact, in attempting to deduce the mandated cctions based on the " evidence" package, I was convinced that a logical connection does not, exist.
3.
Finally, the ED0/ DEDO mandated "DCF Actions" seem to have been the answer from which all else was constructed.
The reason for this statement is that only in the briefing package
(" Finding E") do the actions mandated by ED0/ DEDO memo occur. The so-called evidence package never even addresses the mandated actions.
Obviously, I differ greatly with the ED0/DED0 memorandum of November 18, 1980.
I can only question its bases, logic, and the ultimate " Actions" because they do not make sense.
Since OMPA gave us only 1 1/2 hours to "look over" the briefing package, and Dr. Cornell chose to meet with.us only once for an hour or two shortly after the OMPA gave him the final report, it appeared to me that his audience was pro forma and not intended to hear either our objections or problems with the report. As a matter of fact, we had no opportunity to comment substantively on it.
As you know, this System (ADRS) was planned, until the November 18, 1980 Actions, to provide the basic technical infonnation tool to support the licensing and enforcement activities by assisting, first, with the retrieval of safety-related and licensing information and, later, with the actual analyses of safety and licensing aspects of the plants.
The value of the System for this has been recorded already by the Systematic Evaluation Program staff in NRR and by the IE l
staff.
In fact, the applicability of the System was ensured in our tailoring l
applications prior to ED0's actions.
For these reasons, I consider the ED0/ PEDO mandated actions to be a direct incursion into the NRC's activities to assure l
l public health and safety, and am, therefore requesting that serious considera-tion be given to the attached report. Further, I am requesting that actions mandated by the EDO be stayed until such time that a proper and fair considera-tion be given at the Commission level, and that this document be forwarded to the Commission so that I have a chance to present the Staff's side of the picture as well as the ED0/DED0/0MPA position.
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Myrha L. Steele, Deputy Director Division of Technical Information l
and Document Control, ADM l
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