ML20003F311
| ML20003F311 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1981 |
| From: | Steele M NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | |
| Shared Package | |
| ML19284C410 | List: |
| References | |
| NUDOCS 8104200577 | |
| Download: ML20003F311 (79) | |
Text
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O Analysis and Comment on Redirection of the NRC Document Control System M. L Steele Division of Technical Information and Document Control Office of Administration March 1C81 I
'E 10 4 0 0 0 SM
CONTENTS
._Pa21 Introduction 111 Response to Briefing Charts and Evidence to Support Findings
-1 Briefing Chart 1 (p. 2 of Encl. Al) 1 Briefing Chart 2 (p. 3 of Encl. A1) 1
' Briefing Chart 4 (p. 4 of Encl. A1) 6 Briefing Chart 4 (p. 5 of Encl.A1) 7
. Evidence for Finding A.4 (from Encl. A2, p.-7) 14 Briefing Chart 5 (p.' 6 of Encl. A1) 16 Evidence for Finding B.2 of Briefing Chart 5 (trom.
18 (from Encl. A2, p. 11)
Briefing Chart 6 (p. 7 of Encl. A1)
~ 20 Evidence for Finding C.1 of Briefing Chart 6 21 (from Encl. A2, p. 18)
Evidence for Finding C.4 of Briefing Chart 6 26 (from Encl. A2, p. 23)-
Evidence for Finding C.5 of Briefing Chart 6 27 4
(from Encl. A2, p. 24)
Briefing Chart 7 (p. 8 of Encl. A1) 30 Evidence for Finding D of Briefing Chart 7 31 4
(from Encl. A2, p. 26)
Briefing Chart 8 (p. 9 of Encl. A1) 31 Evidence for Finding E.1 of Briefing Chart 8 31 (from Encl. A2, p. 27-28)
Related EDO-Directed Actions (Attach.1 of 35 November 18, 1980 memorandum)
Evidence for Finding E.2 of Briefing Chart 8 37 (from Encl. A2, p. 28)
Briefing Chart 9 (p.10 of Encl.' A1) 37 e
Evidence for Finding F.2 of Briefing Chart 9-39 (from Encl. A2, p. 34)
Evidence for Finding F.3 of Briefing Chart 9 42 (from Encl. A2, p. 35)
Evidence for Finding F.5 of Briefing Chart 9 44-3 (from Encl. A2, p. 37)
Briefing Chart 10 (p.11 of Encl. A1) 44 j
Evidence for Finding G.2 of Briefing Chart 10 45
-(from Encl. A2, p. 42)
Appendixes f
A.
Memorandum, Donoghue to Cornell, June 5,1980, " Document Control System"
'8.
Letter, R.F. Fraley, Executive Director, ACRS, to William J. Dircks. EDO, NRC, October 6,1980, "The TERA Corporation Retrieval System," and reply, November 24,1980, " Unrestricted Access for ACRS to all Indexes and Records of NRC Staff and program Offices."
C.
Memorandum, Conoghue to Triner, November 25, 1980, " Office of Administration's Request for Unobligated FY 80 Carryover Funds."
i D.
Memorandum, Commissioner Gilinsky to Chainnan Ahearne and Corsnissioners Hendrie and Bradford, October 6,1980, " Year Four of the Docurr.cnt Control System Contract."
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t ANALYSIS AND COP 9'ENT ON REDIRECTICN OF T}iE NRC DOCO*ENT CCNTROL SYSTEM by Myrna L. Steele Deputy Director, TIDC INTROOUCTION The EDO remorands of hovecter 18,1g83 (attached) purports to relate to the r.ajer findings of the CP'JA "... ccr:;rehensive review of the Document Centrol System (DCS)." The remorande states that "The study results are presented in the form of a briefing package..."; it then lists four so-called study results.
The re-crandu: also says tnat " Based en these findings, I have decided to rake substantial changes in the DCS.... A list of actions I have dire:ted, with descriptions of each, is provided in Attactrent 1..."
Sefore proceeding to the actual analysis of the content of the OP'PA study, the OFA triefing package, and the Actions directed by the EDO, it is ger=ane to ecte tnat the office res;cnsible for the centract (TIDC) was given, essentially, only six b:urs to look over the so-called triefing package and the so-called evidence. This tire constraint allowed cnly for pointing cut cajer errors.
(For c:nvenience, the briefing package and the evidence will be referred to with quotati n rarks in the rest of this pa;er because I cannot agree that the
" evidence" is, in fact, evidence.)
At no time during the OP'FA study was either a peer review or an outside review of the findings er the CRAFT report ever scught by Ct'JA.
The findings (1 throu;h 4 of Dircks' cecorandu J) are not direct functions of the briefing package or the evidence. Further, the a:tiens based en these ft:, dings cannet te correlated with the evidence or the corrents of users of the DCS.
The allegat~ in that the actions will irpr:ve the ranageeea.t of the DCS te;11es asismanagement without s;ecifically alleging any wrong:cing, misjudgrents, cr
- ccr ranagerent. New ere in either the briefin; ;a
- kage (Enclosure A1) cr the a
evidence (Enciesure A2) is there any infocation to sup;crt such innata.dc.
The establis* rent of a DCS Policy Advisory Greu: re;crting to the EDO and remval cf tre Centracting Officer Technical Ee:resentative res:cesibilites from the Division of Te:hnical Infer ati n and Docu ent Control withcut reas:n and witncut evidence for need to do so are incoecrenensible. Those a;;cinted to the DCS Policy Adviscry Group, which censists of Ce;uty Direcy;rs of all :cajcr user Offf:es, have been kept fully inferred at all tir4s and their advice has been solfeited and heeded. There is no evidence that they think there has been mis-P.anagement. The centinuing close cay-to-day operations interface between TIDC and t*e contra: tor's c;erations personnel are not facilitated by a CCTR who re;crts to the EDO.
Tne stated goal to *... reduce substantially the current 511 millicn annual cost" has a;;arently been used as the sole justificati:n for redirecting the DCS progran, since the eviden:e cces not provide a ecnerent argrant for such radirection.
Such could have been a:::cclisred witncut tiee-censeing " studies
- to justify trase actions, along with the innuendees and misstatenents of fact.
-111-
1
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1 l
2 RESPONSE TO BRIEFING CllARTS* AND EVIDENCE **
TO SUPPORT FINDINGS OMPA STUDY OF DCS
RESPONSE
BRIEFING CllART I (p. 2 of Encl. Al)
Purpose No reason is given why this evaluation is either necessary or desirable and the various elated topics that are of interest to NRC management To evaluate the current NRC Docimient Control System are not statcd.
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To identify and analyze options that will allow NRC to meet its document control needs at the lowest possible cost
- To respond to various related topics that are of interest to NRC management BRIEFING CilART 2 (p. 3 of Encl. A1)
General Background - DCS The chart titled " General Background" is interesting - not for what it says, BUT for what it leaves unsaid: Each point of the chart is discussed separately telow.
In November 1975, a Docimient Management _ Task For,ce found that at The statements of this paragraph are correct, NRC:
Information retrieval takes too much staf f tine No sure or systematic means exists for locating all documents on a technical problem or public inquiry Enclosure Al of Memorandum, Dircks to Ahearne, Nov. 18, 1980 Infonnation is not available to the public on a timely basis.
Encloture A2 of Memorandimi. Dircks to Ahearne. Nov. 18, 1980 Emphasis added
REspotiSE OMPA STUDY Of DCS SECY 76-431 requested Conunission approval to issue an Rf p and The second paragraph: "SECY 76-433 requested Consulssion approval to issue EtTmated that the DCS contract would cost $9 million (1976 $) over an RFP..."* It did not request permission to grant a contract. Eitfier two years to install and $5M (1982 $) par year af ter that. The
'tliis Tact was lost on OMPA, or they chose to ignore it. The statement accanpanying cost-benefit analysis assuned a high level of savings goes on to allude to an overse11 on the part of the program office: "...
and projected eventual net savings to NRC of over $20H annually The accompanying cost-benefit analysis assumed. a high level of savings (1982 $).
..."* Nowhere is it said that: (1) the cost-benefit analysis was, in fact, done by OMPA (the office doing. the evaluation) and that these were very, preliminary estimates; and (2) that the data were projections of best esti-mates. The preliminary nature of the data is made abundantly clear in SECY 76-433 in both the text of the paper, the Itst of Assumptions, and the Cost-Denefit Sensitivity Analysis which, incidentally, is missing from i
the OMPA study. It is included here as OMISSION 1 to show the types of information that were ignored by the OMP D UidF I OMISSION 1:
Assumptions (from SECY 76-433) 1.
Historical growth in workload 2.
Zero inflation 3.
Full-staff utilization of system 4.
Goal remains consistent: To proylde a systematic means of locating a.1,1_
available documents related to NHC activities; increased from present 300 documents per day to 2,000 documents per day.
5.
Present systems dist.ontinued as required 6.
first-year impact on operating costs is essentially zero.
Cost / Benefit Sensitivity Analysis (from SECY 76-433)
To continue present nianual approaches to the storage, retrieval and distribution of hard-copy docunents, with the above assumptions, and would:
.p.
Emphasis added
9
_0MPA STUDY Ot uCS
_ RESPONSE 1.
Require annual increases in staffing proportionate to the accumulated volume and increased paper flow 2.
'tequire an additional 44.5 man /yr. to meet add-on ef forts 3.
Require increased storage space on the order of 6,000 sq. f t.,
initially, and 1.500-2,000 sq. f t. per year to acconmiodate hard copies in multiple-user files 4.
Require continued reliance on an ERDA-TIC document management service to NRC (approximately 21 man-years and $483,000) 5.
Perpetuate the document control deficiencies outlined in the 1975 f.RC Document Management Task force Report, such as:
a.
Staf f and public inability to locate NRC information rapidly.
Manual crocessing and retrieval on occasion has required as much as a month before the infonnation is available to the user. Two weeks is the typical time required.
b.
Manual searches for infonnation b'y staff are the most expensive item for the regulatory and technical NRC ataff. Manual searches are 75% less efficient than the automated, indexed microfiche re-trieval. TN Task Force estimated that 20% of staff time is applied to some aspect of the infonnation retrieval problem -- making copies, distributing copies, locating doci.ments, searching for information, etc.
c.
Continued duplication of indexing, storage and distribution of NRC documents.
d.
Continued lack of integrity and reliability of NRC document files.
The Task Force observed that because of the lack of conmion, coordinated and automated approaches to records management there is minimal interof fice, interagency, or general user knowledge of what infonnation is available.
OMPA STllDY Of DCS
RESPONSE
1mplenw ntation of Automated Retrieval System would:
1.
Provide an automated microfiche storage and retrieval system for all NRC documents. The system will comprise off-the-shelf hardware and sof tware and will reduce staf f tine involved in retrieval of 751 by providing simultaneous access to indexes and documents by multiple users at renote cathode-ray tube (CRI) tenninals; acconendate biblio-graphic-citation listings and subject indexes specifically tailored to the needs of the NRC staf f, couplete with cross references; produce monthly issues of index and abstract journals, produce microfiche of NRC documents for public availability, as well as microfiche that are autonutically retrievable for high-resolution viewing at remote terminals by NRC staff.
2.
Replace present distribution of hard-copy docunents by multiple users and reduce hard-copy production by at Icast 151, 3.
Reduce the present system of nmitiple, duplicate files; e.g., docket 50 naterial is stored in hard-copy form in at least 5 locations. An estinated savings of 50% of storage space is expected.
4.
Eliminate the present system whereby distribution lists for NRC docu-ments are nulntained by every line organization -- the proper maintenance of one name requires one-nun-hour per year, if the name is nulntained by five organizations there is a lack of cost ef'ective-ness. There are an estimated 25,000 recipients of NRC information.
OMISSION 2:
further, the second paragraph treats the costs and benefits in overall terms, falling to dif ferentiate between aeninistrative, or document control, functions anel technical information benefits. This is important because of the later Ifnks in the OMPA study to " technical information benefits" that the OMPA study says were promised.
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V OMPA STUDY OF DCS
RESPONSE
OMISSION 4:
Af ter the paragraph on SECY 79-649, the next major action, i.e., addition of a second shif t, which is one-half of the site of the first shif t, is completely ignored by the OMPA study! The justification for adding the extra half shift was included in the FY 80 Supplemental budget request and approved by the Congress. The justification was provided by NRR and the reason for the extra half shift was made abundantly clear. Also, at the time of preparation of the supplemental budget request, the fact that this backfit effort would last at least four years was made known to the Budget Review Group and to the Commission. It was approved.
Contract provided that the term could be extended for a third and This paragraph is misleading to the extent of being erroneous! The items fourth year at NRC's option. The third year option (June 80 to that are referred to as contract " costs" are actually " ceilings." Through June 81) was exercised at a negotiated price of about $11M.
TIDC cost control efforts, brought about by budget limitations, the actual cost will be about $2 million less than the ceiling of $11M, or somewhat Total cogract price, is now $24M, including $10M original two-year 1 ss than $9M with all the scope of work being implemented.
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contract, $~3M docket backfit ef fort for year 2, and $11M for year 3.
BRIEFING CHART 3 (p. 4 of Encl. Al)
Areas of Findings - This briefing chart includes seven " major areas":
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HRf's needs; DCS use; DCS benefits and savings; component costs of DCS; changes to reduce cost; nunagement issues; and other issues.
These seven " areas" of findings do not, in any perceptible way, relate to the Dircks' memo. The seven findings bear no resemblance to the proposed "DCS Actions," Attachment I to the Dircks' nese. Further, the so called " evidence package" (to be discussed later) bears absolutely no
" evidence" to relate to either the " findings " the Dircks' memo, or the proposed DCS Actions.
For the reader's convertence I discuss these below in the order in which-they appear in the " briefing package" and OMPA study.
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-OMPA STUDY OF DCS
RESPONSE
BRIEFING CHART 4 (p. 5 of Encl. A1)
A. Is the DCS meeting NRC's needs?
General Conenent: Before discussing each " Finding" separately, some general infonnation on this question is necessary. It appears that this.
infonnation, although given to OMPA, was either ignored or not understood.
Perhaps, because of its volune and the tine necessary for understaading the nuclear Ifcensing process, the amount of infonnation was i p;ohibiting factor. At any rate, it was not included in the OMPA study. Si. ice this material is necessary it is included here as Omission S.
_0 MISSION 5:
The technical infonnation needs of the licensing / regulatory staff have a '
long histr*ry. The docunentation and studies on these needs start at least as early as 1967 and continue through 1980. The documentation and requirenents analyses take many fornn because they were done by many.
groups, including contractors, as well as internal technical and pro-fessional staff. These are listed in Table 1.
From these studies the generic model for the System as a whole was constructed and disseminated to prospective contractors. During the pro-posal conference all participants were apprised of at least five file cabinet drawers full of references and special studies that were germane to System design. To assure responsiveness of the System design, the Source Evaluation Board (SED) developed an approach tied to implementa-tion plans with their focal point being deliverables for each task.
This approach required the Contractor to take the models laid out in the many staff studies and confinn these models, making changes where neces-sary. This approach of confirmation of past studies and changes should be obvious for even a casual reader of both the RFP and the Contract.
Task 7 even defines the procedures by which interfaces are established.
One of the reasons why almost everyone outside the program office had had
. difficulty understanding the implementation plans is that they have not taken the time to sad the volumes of infonnation available on past studies and histories. The System, and all its component subsystems are -
products of.10 to 14 yeecs of study and Ek. No implementation plan or report from the Contractor is a stand-alone docunent' If that were the Table !
Chronological List of Studies of Technical Information Requirements of Licensing and Regulatory Staf f Comments l a,te, Descript,lorl j
1967 Computer llandling of Reactor Data for System was overly ambitious and complicated, it died Satety (CHORDS) from lack of management and funds 1967 FicheIndextoNuclearDockets(FIND)
This system was replaced by DCS 1967-1969 Indexing Studies four major efforts during the 12-year period were undertaken, but none were useful to staff. DCS system evolved from these efforts 1969 Reactor Opeiating Experience and Reactor The publications were terainated when person responsible for Construction Experience writing and managing wa', reassigned 1972 Automation of Licensing Activities Plan not carried Turward because no agreement on plan could be achieved 1972 National Archives and Record Services (NARS)
Cited need for automated information retrieval system.
5tudy of NRC 1972 Proposal for Collection of Dperatlog Illstory and This was the beginning of the current Systematic Evaluation failure Data on U.S. Nuclear Power Plants Program that is now being supported by DCS.
1973 Task force Report to the Director of Report recognized information problem Regulation 1973-present Nuclear Plant Reliability Data System (NPRDS)
This commercial venture supported by the nuclear industry and NRC depends on voluntary input from utilities and vendors.
It is therefore incomplete. Commission is considering future.
1974 LER Pilot Program Staff did not find this acceptable 1974 Dattelle-Pacific Northwest Laboratories Report on Study resulted in a very complicated, unmanageable system.
"A Review of Regulation's Management Information Systems and Requirements" 1975-1976 Document Management Task Force Report Basis for NRC information managepent program.
8
OMPA STUDY OF 0C5
RESPONSE
case, each of the documents would be multivolume and would take hundreds of manhours to write. Finally, tnere is adequate experience to convince the program office that even then, the documents could not stand alone.
Finally, this approach (i.e., implementation plan, technical staff approval where necessary, and program office approval) is the only way an jn_tegrated information system can be ef fectively installed. The management of the newly created NRC concluded not only that the staff could not be augmented (by 12 to 15 full-time staf f for systems analysis and desTgn) but NRC would probably not have need of these types of people on a sustained basis. Other manpower needs that could not be obtained by contract were overriding and insnediate.
A. 1.
NRC chose not to conduct a systematic assessment of its While this statraent is neither positive nor negative, it conveys a nega-specific user needs for information storage and retrieval tive tone, prier pally because of loaded words such as " systematic" and either prior to or subsequent to the development of the
" specific." This negative tone, or implication, could have been avoided DCS, because NRC intended the system to be flexible in by simply reversing the order of the sentence; for example, meeting user needs as they became apparent.
"Because NRC intended the system to '. flexible in meeting needs...." or "NRC chose not to conduct an assessment of specific user needs...."
It is curious that this statement wat even included because the so-called.
" evidence" does not support any typf.
- conclusion.
From the " evidence" it is clear that:
(a) The decision was made early by NRC to approach its information -
storage and retrieval probleins in a manner that OMPA apparently finds objectionable, and the decision was made for numerous reasons. The reasons and the actual design were never explored by ONPA, although an exhaustive quantity of information was given to them, and the complete five file cabinet collection was openeo to them. A total of
)
(MpA STUDY Of DCS RESP 0NM 537 hours0.00622 days <br />0.149 hours <br />8.878968e-4 weeks <br />2.043285e-4 months <br /> was spent over about four months by the program and contract offices explaining the approach and what was available to be reviewed and trying to explain the many phases and complexities of the project (i.e., contract, work scope, process, and nuny others).
(b) Numerous analyses and identifications of A[C/NRC probiens exist in reports given to OMpA. However, it taltes time and knowledge of the licensing approach that has been used historically to understand these reports. ALC and NRC had put hundreds of manyears and millions of dollars into studies from 1967 through 1975. Many of these reports were made availahic to the study group, but no indication is given that the reports were read or understood. The numbers of staf f man-
. years that went into 1EtWylews, sGf f evaluations, and descriptions of problems appear to have gone unnoticed, despite TIDC's tinphasis on these to each study member.
The " evidence" relatlwJ to the user needs is copious. It comprises a 10 to 15 year litany of information uses by the staff in the licensing and study evaluations of nuclear snaterials and applications. The confinning history of one failure af ter another is chronicled because the various information systnns were defined to address one problem by one group on one subject. Iurther, each of these systons contributed to (Ee pro-tEcting of the licensing process because they increased the isolation of one group frann another. In short, the existing doctanentation.is a history of numerous failures, seemingly endless studies and exhorbitant amounts of money put into band-ald solutions for a gaping wound. AEC Regulatory and NRC information needs for an integrated system of information that everyone could use were clearly laid out time and time again. The require-ments are overwhelming for an information system that can enhance ctmounications between groups and offices and provide, for the first time in the history of the licensing process, an ability to link documentation on changes in plants, examine similar problems in either similar or separ-ate plants, and to create a single data base from a very'o Fdata.large file (about 3 million records) which can provide a reproducible sel The validity of the licensing process requires that data and analyses be credible. The NRC technical and professional staf f must be able to access licenses and staff data and examine the flies for all plants of a similar design and, at a mininami, understand hnw the licensees' con-clusions were derived. Before this -Systnn was in p1 Ace and funClioning,'
RESPONSE
OpPA STUDf 0F DCS there was no chance that this could be done. For example, two years beforo preparations for this Sy; tem were begun AEC published three separ-ate reports on plant availability by three different vroups in Regulatory and arrived at three different res;1ts, within the sarac year. These data cane frun plant operating reports, but no two groups had the same collec-tion.
In order to create reproducible results, any agency, or group, nost have.
one central dc;a set. For an agency whose uses are as different and diTerse as the NRC's, that set of data must come from an integrated system. An integrated, on-line system ls~ expensive and large.
A. 2.
A number of general administrative and technical needs can somehow the study group seems to have confused the goals or objectives for be inferred frau initial system proposals and limited long-range orientation of the project and accomplishments and system experience with the system to date-implem?ntation,
a.
Establish a systematic means of locating all documents on While item 2 is not wrong, it is not particularly relevant to anything in a particular topic the " findings." The TEree pages of " evidence" devoted to supporting finding A.2 (pp. 3-5 of Es.cl. A2), are simply restatements of problems b.
Reduce professional staff searcn aad retrieval time which are summarized by the " finding." All that can be even inferred from the " findings" is that NRC had a number of documentation and informa-c.
Enable NRC to meet statutory requirements and ensure tion retrieval problems.
timely notification of licensees and public of avail-ability of NRC documents d.
Create a central file index and ensure file integrity e.
Eliminate duplication in storing and distributing docu-ments
RESPONSE
OMPA STUDY Of DCS A. 3.
Although the DCS was proposed and approved as a technical infor-Another curious point in this study arises here. This, coming inanedi-mation retrieval system, it is not yet fully developed to serve ately af ter item A.2, above, tends to suggest that: either the study this purpose.
group knew that with an information problem as large as the NRC's there was no cnnceivable way that technical infonnation needs could be serv' iced before administrative requirements for data base reliability (and, as a corollary, docunent control) were net; or this was intended by the OMPA staff as being positively supportive oT~the overall approach by the program of fice.
The System had been operational only five months when the TMI-2 accident occurred. Ilad the accident not required so many different functions of the System in such a short period of time, it would have had far more extensive tests performed on it in a more routine manner, liowever, the TMI-2 shock produced major perturbation within NRC, and every effort had to be expended to acconmodate informat. ion requirements of Congressional Consnittees, Presidential Conunissions, NRC's own investigations and public and FOIA requests, plus numerous letters and infonnation requests from private citizens.
It is significant to note that during and~ subsequent to the accident NRC received absolutely no complaints about either its.esponse to informa-tion requests or about the integrity of the file. It is also significant to note that a " normal" Docket 50 file comprises an average of about 6000 docunents, not including applicable issues. The THI-2 file, at the end of 1980, included some 20,000 docunents.
Throughout all this document processing and handling (in the time inter-val of about six months), baseline data were taken whenever tine could be found. Nonessential documentation and tasks originally specified in the Contract were postponed. TMI-2, in fact, cost NRC about eight months in tenns of System scnedules and implementation, although the Contractor met all his deliverables.
All of this is ignored - or simply not understood - in finding A.3 of the tilWA report.
One further point on finding A.3 is germane to thi discussion - that of the Subject Index implementation. The OMPA study greup apprently does
_ l
OMPA STUDY OF DCS RESP 0NSE not understand that installing a System such as this is a highly-complex, nultiphase process. for instance, implementing a subject-search capabi-lity requires that the users reach a sinultaneous agreement on terminology These are not inifes Efeid~f6nctions and are, in fact, s
and search process.
iEle easier or more dif ficult depending on the relative organizational cohesion in any agency or company, in NRC, agreement has been difficult to achieve.
Some terminology and search strategies were agreed to at the outset by the ma,lority of the staff. This agreement and utility was based on what the MC's Technical Information Center had done since 1968 for the AEC's Directorate of Regulation. Also, these descriptive cataloging processes are the subject of ANSI standards and are relatively well defined. These functions, then, could proceed rather quickly. This agreed-upon tennin-ology and the search strategies included things such as Docket Number. -
Author. Recipient. Corporate Source, etc.
The problem area is, and will continue to be for sone tine, the. Subject Tenns and Subject Search. The office in charge of the Contract was fully aware of TTie~ problem areas and, in fact, b_riefed all parties d ncluding the Connission, that this was a problem area. Concurance on termisology, alone " Eifff ficul t.
Subject search strategies will proceed even more slowly.
These are some (but not all) of the raasons that NRC originally'r basis.
laid out the philosophy that the System would be implemented oG silLla By November 1979. NRC and the responsible program of fice had negotiated adequate agreement among most of the technical / professional staf f to direct the Contractor to lay out in three logical steps the production of an interactive, on-line subject index. As the Contractor finished each of a series of documents (these are not, and were not intended to be.'
stand-alone documents), he has begun work on the corresponding software module.
RESPONSE
DMPA STUDY OF DCS Dnce reasonable agreement was obtained from a majority of staff as to what type of index they needed, work was begun on the first module for C.e Boolean capability. the design specification was delivered to NRC vecember 12, 1980, and targets the spring of 1981 for getting this operational on the processors.
The staf f has requested that this capability be available on-line, inter-actively at their tenninals. It was the intent of ilDC to perfonn additional cost analyses of this option and sutenit this to the i.sers and to the Office Directors. This systenatic process should be followed, and decisions as to whether to make this capability fully operational should be based on the collective responses.
A. 4.
The DCS satisfies sume, but not all, of NRC's administr tive This is anothar of those curious and phystenious findings. It is totally and technical document control needs, irrelevant.
The four pieces of " evidence" in the study are almost nonsequiturs. The lists of administrative services and technical services are correct.
Ividence for Isnding A.4 (from Encl. A2, p. 7)
Point 1 - the fulfowing is a Ilst of the nojar adninistrative services and prr. ducts provided t>y DCS:
- Daily Accession List of documents added to DCS data base
- Title List of Doctanents Made Publicly Available (NUREG-0540)
- FO!A Responses
- IPDR Accession List
- List of docunents sent to Central Files
- Congressional Correspondence Report
- Regulatory Infonnation Distribution System (RIDS)
- SECY Chnmological Docket List DCS Data Base Tapes for PDR "Public Dnly" tub of microfiche for POR
- NTIS Service (I copy of docket material to NTIS)
RESPONSE
,0MPA STUDY Of DCS Point 4 - The following is a list of major technical infernation What relation do Points 1 and 4 have on Point 3 (see following)7 This services and products provided by DCS:
third plete of " evidence" is nothing more than a reflection by a proposer of NRC's original objectives.
- lE Bulletins, Notices and Circulars Listings
- Incident Response Center Drawings Index
- IE Internal Illing Systems Subject Codes
- State Emergency Plans Microfiche Licensing Board Notifications and Generic Techntral issues printouts
- Antitrust Document Indexes
- ELD Subject Codes and Legal Sunenaries
- SD Codes and Standards Reports
- NMSS Internal file Codes
- Special Reports on IMI, Licensee Event Reports, inspection Reports, cumulative listings of certain classes of documents such as NUREGs, Consnission Papers, Research Infonnation Letters, and State Emergency Plans Point 3 - In the Technical Proposal to NRC TERA indicated that the Automated Records Management System (ARMS) would satisfy NRC's administrative document control needs [ identified in finding A.2, see page 3] in the folloving ways:
- enable rapid access to documents
- provide accurate retrieval
- ensure file integrity
- eliminate need for dupitcate flies among staff members
- reduce document handling time
- provide user-oriented document access
- enable compliance with statutory requiranents (TERA Technical Proposal, p. til-tv)
RESPONSE
,0MPA STUDY OF DCS Point 2 - Of the three administrative needs identified in finding Of " evidence" point 2, the Systemi was never designed nor intended to A.2 --
replace the filing systems used in NRC's of fice; it was designed to replace filing centers.
elimination of dupitcation in storage and distribution
- file integrity for documents in data base, and During the six hours that the program of fice had to review ("go over")
central file index the study that OMPA took four months to prepare before it was sent to Chairman Ahearne, the finding C.5 that is referenced here was found to DCS is completely satisfying only one -- file integrity.
be totally incorrect. As a result the finding ~C.5 to which this refers was deleted before the report was sent'EwTto thRhafrman, but
^
The inablltty of DCS to satisfy NRC's need to reduce the yeleting_this refer'thisinoTIf " s oveFT65kiF volume of hard-copy flies is discussed in finding C.5 It is not possible for DCS to prepare a cential file index because not all documents generated by NRC are routinely sent to T[RA for processing.
(Survey of File Center Supervisors)
BRIEFING CHART 5 (p. 6 of Encl. Al)
~~ ~ g~What usa e can This could have been one of the most useful products of this whole exer-B.
To what extent has the DCS been used to date?
lie ant EIjiitthif -
cise. Ik) wever, the approach, particularly with the surveys, really causes question of why the report, as a whole, was done.
For example, the use of two totally dif ferent surveys raises several questions: (1) Why wereTwo~siiWeis done? (2) )(hen where they done?
(3) Why are the,two not correlatable?
In fact, the two surveys are not cicarly identified. Consequently, very r
careful reading is required to find out that two studies exist. The
" findings" use the two almost interchangeably, although they are different. At best, considerable confusion is the result. For example, on the basis of the " briefing package," Ftr, ding B. I seems almost to contradict findings B. 4 and B. 5.
When the " evidence packas,e" is consulted, only one survey is footnoted, and the reader is referred to one_ survey, Upo'nT onsulting the Appendix (as the footnote says to do) the reader finds what appear _s, to be two explanations of a survey. Close
RESPONSE
OMPA STUDY OF DCS scrutiny of these two: (1) Methodolo3y for Survey of Identified DSC users, and (2) Metisiology for MFf'R'indESurvey of PotentiaTDCS Users, yields @yifferent surveyWlnterestang:
Despite the fact that no dates are shown as to when the surveys were conducted, a little scouting among NRC staff gives: Survey 1. "about" July 6,1980; Survey 2. "sometine in September 1980." This causes the reader to question: Why was the acond survey performed? No indica-tion is given that the first one was faulty. Did the second survey include the " identified users" from the first? How could they be sure that the second " survey" included potential users, as it says.
Survey No. I is well explained, analy:ed, and presented so that the reader can tell what was done and why. Survey No. 2 looks like a
" quick-and-dirty" piece of work.
And yet " Finding B.1," and half of " Finding B.2 " use Survey No. 2 as their only pieces of evidence.
B.
1.
About a fourbi of all potential users are currently using Who are OMPA's " potential" users? The " evidence package" has as its the system. Only about a third of these use the system sole piece of " evidence" the " Random Survey." Now - is that Survey 1
- daily, or 27 Af ter deciding that Survey 2 is the " Random Survey," the reader finds that 25 of the '5 people questioned who have taken the training f
are System users. Of these 25, eight use the System daily, five more use it several times each week, and four use it at least once weekly.
That means that 17 of the 25 trained people who were surveyed use the System once or more each waek. This neans that 68%, or more than two-thirds, of the people trained use the System nere than once each week.
OMISSION 6:
What the study does not say is even more significant. ~ By the end of July 1980 - about the tine these studies were done - only 487 people, out of a staff of nore than 2200 had been through the training; i.e.,
only 22% of the staff had had any formal training. That' training had been introductory in nature but was somewhat more advanced than instruc-tions on how to turn on the terminal.
RESPONSE
OMP,A STUDY Of prs OMISSION 7:
These surveh - BOTil - made no mention of "other services"; for example, hard-copy reports that the staff probably does not realize are products of the System or of expedited services from the central file areas tecause the user "used" the System indirectly. These surveys related only to direct use of terminals by the staff. ChTs Tai ~pTTR an on-1Trie.
Interactive system. No consTtTeTatton was given to anything else.
Thus, the OMPA study group appears to have chosen to overlook two crucial results from the data: (1) System usage is directly related to training and (2) System usage is not solely confined to an on-line use of terminals.
B.
2.
aystem use is about equally divided between administrative One sees immediately N0 connection between " Finding B.2" and the two and technical uses.
" evidence" points. Further, the assertion of "about equally" apparently comes from the parenthetical sentence in Point 1.
Apparently, OMPA also Evidence for finding B.2 of Briefing Chart 5 (from Encl. A.2, p.11) chose, this time, to ignore its " Random Survey" because this works out as closer to 701 than 50%. The " Random Survey" (Survey 2) findings do Point 1 - TtRA supplied MPA with document search statistics for the not support this. They say 68% of the use is technical. This " finding" period March-August 1980. The data indicate the number in the " evidence" package cites this, but one can only sunnise that of tenninals per of fice and the number of searches for these were ignored and the use statistics, reported monthly by the those tenninals. (MPA inferred technical or administra-Contractor, were the only reliable source of data, tive use from the location of the tenninals.) The MPA analysis of this data indicates that there are more But, if the " Random Survey" is ignored at this point, why then was it individual technical users and that these technical relied upon for the sole source of confirmation for " Findings B.1"? And users generally perfonn single searches; whereas, there why was the apparently unsupported " Finding B.1" put first - unless are fewer administrative users, but they generally that's all the majority are supposed to read?
conduct multiple searches. See Table B-2: " Document searches by Office for Period March-August 1980," for specific infonnation.
(Tenninal Use Statistics)
Point 2 - Responses to Question 6 in the MPA Random Survey of Potential Users, "For what work activities do you use the DCS? --- administrative? technical? or other professional?" indicate that 68% use the system for technical purposes.
(Random Survey) l
RESPONSE
OMPA STUDY Of DCS Current terminal locations were selected to assure that a preponderance B.
3.
NRR mid IE accourit for nearly all use of the DCS by the of users for at least the initial System were in NRR and IE.
In fact, maj*r program offices.
during the Document Management Task Force activities and the RFp writing and Source Evaluation Board (S[B) activities, fiRR and IE volunteered to be the first users of terminals. As a result, the first cost analysis n lating specifically to the System (sunenarized in Appen-dix H to SECY 79-649) was based on Docket 50 (and related nuclear plant information).
OMISSION 8:
1he ')MPA study fails to record that, in fact. 22 of the 44 user terminals are in the three-building complex that houses NRR and seven are in the file unit for that building. So, essentially, 29 of the 44 terininals are used in NRR. Further, eight of the other 19 are either in IE Head-quarters or Regional Offices. The study also falls to note that these two of fices account for about 63% of the available user teminals and Table B-2 (p.12 of Encl. A.2) represents an arbitrary breakout referred to by UMPA as " inferred," " tech'nical/ professional" searches and "administre?ive" searches.
B.
4.
There are a nianber of system limitations that inhibit use This is the only substantive " finding" in the whole of " Finding 8."
of the DCS. Prinmry limitations are lack of a subject This is also the first time the reader can infer a " User Survey," which search capability and an incomplete data base. Lesser he must surmise, by now, is Survey 1.
factors that may inhibit DCS use are data base accuracy, hours of operation, number and type of terminals and their locations, and user skills in operating the system.
OMISSION 9:
No mention is made of the subject indexing of documents alrea.iy being done or of the L.tiloring and design of sof tware to be implemented during the spring of 1981. This serious omission is all the more dif ficult to account for because all, the docunents pertaining to the i
OMPA SIUUY Of DC$
RISp0NSE subject indexing and search strategies were made available to the study group, and the scheduling charts we re explained in detail, the OMpA " evidence package" speaks for itself and the user speaks strengly.
D.
5.
Syston use would increase if these limitations (finding ihls " finding" along with findlay B.4. constitutes about the only H.4) were renmed; however, in the absence of a clear supported (by the " evidence") allegations in all of Section D.
understanding of user needs, it is difficult to prvject how great this use might be.
Ilowever, it should be 4.oted here that both findings B. 4 and B. 5 -
supported by the responses from the Offices - are directly opposite to the " Actions" ordered by Dircks' memnrandum of NovFinlFr lH.19fiODhese are directly countermandetifications (NRR) reported in each of the three scheduled Design Reviews. Copies of the Generic Technical Issues Report List (NRR) reports of each Design Review were given to the OMPA study group at the Dodet Data Qse (NHR) beginning (in June 1980) of their study. but the reports do not appear Meteorology / hydrology Data Base (NRR) as either references or " evidence."
systematic Evaluation program (SEp) Status Report (NRR)
LER Quarterly Munitoring Report (IE)
. periodic Listing of Bulletins. Notices, and Circulars (l[)
Incident Resimnse Center Drawing Liteary (l[)
LER and Bulletin Response Tracking (IE)
"... An average of two requests for special reports l
[one time onlyj are received and processed (by T[RA) each day."
(p. 151 (DCS Services Report)
C.
5.
The total cost of performing a number of related adminis.
NOTE: This is a relatively cautious way of stating an opinion in a trative functions using the DCS is probably less than the
% Tefing package." idhen the " evidence package" is consulted, it is cost of perfonning these functions under separate contracts clear why it could not be stated directly.
Evidence for Findini, C.5 of Briefing Chart 6 (from Encl. A2
- p. 24) point 1 "It is estimated that these tasks (iltle List, daily '
point I of the " evidence" is correct. However, points 2. 3. 4. and 5 accession list, distribution sheets) would have cost the.
Indicate that either fractional pieces of information were submitted by NRC about $5.3 million [$4.2 million. $1 million. $120.000..
the Office of Administration (ADM):in its " Office Director Ceauments" or respec*,1vely) in the first year of the (ES contract if they that OMPA either could not or did not complie the information. Further.
were continued to be done by outside contractors, whereas, the AUM " Office Director Comunents" raise questions as to who in ADM has 1
the total DCS contract for the first year was $4.5 million."
responsibility for this type of information.
i SECY79-649,p.1).
21..
=_
. _ ~.
l l
RESPONSE
OMPA STUDY OF DCS Point 2 - ADM estimated that the DCS replaced functions that they would have had to pay about $8 million for during the two years the contract has been operational (ADM did not provide a break-down). Examples that were provided by sane of the branches in ADM of functions which may cost more under separate contracts are:
- An additional $360K per year in timesharing costs for a locator system to locate sulmiittals and respond to staf f and 11Censee queries regarding their status.
- An additional $10-15K per month in timesharing costs to maintain the PDR Accession List.
s
- An additional $250K per year for production of Docket 50 microfonus.
- Record management function now perfonned by DCS would require 5-8 people if done in-house.
l (Office Director Conwents)
Point 3 - Historical growth in file storage has been in excess of 10%
Point 3 cites TIDC (ADM) as saying that 34,000 cubic feet of hardcopy annually. The DCS has allowed more than 34,000 cubic feet storage has been eliminated. Point 5 says "ADM... indicated a savings
+
of hardcopy storage to be eliminated and at least 12,000 of about 145 cubic feet... " and quotes IE as saying "We have begun to precluded, for a net reduction of 46,000.
This has been remove selected hardcopies of documents... for destruction..."
largely nonrecord material tecause of the lack of a National Question: Is all this additive? What is the real number? How does Archives approved record retention schedule for NRC. Once this relate to Poinc 2 above?
l NARS approves the NEC retention schedule (planned for complation in mid-1981), more than 75% of NRC record material will be approved for maintenance in microfonn.
(Meeting with TIDC 11/17/80) 4 i
b 1
(
1 J
OMPA STUDY OF DCS Resp 0NSE Point 4 - A significant portion of the task of distributing incoming documents has been taken over by the DCS. The cost of this service. If done separately. is estimated at $1.1 million.
(Heeting with TIDC 11/17/80) point 5 - None of the of fices indicated that they have discarded any liow is file space (and associated dollar value) related to the System?
of their hardcopy files. IE has begun to renove their files Is this reaj11_ part of the cost saved by the System? Firally, the reader 1
but has not yet discarded them. ADH. however, indicated a must question why this information was obtained so late, if in fact the savings of alanat 145 cubic feet of hardcopy storage space study was begun in June (dates appear in citations).
by converting Omanission papers and Vendors Topical Reports to microfiche.
Once again, the reader is lef t confused. This appears to be only tantalizing tidbits, and ainost extraneous.
A[M "A survey earlier this year indicated that approxi-mately one-half of the LpDRs will run out of space 1
in the next year and would havt to be moved if microfiche is not available."
(RIUS)
" Conversion to a nunned effort, assuming NRC requires the present turnaround time, would require an additional 10 or 11 persons and an additional 800 square feet or more of addi-tional space."
j "As of today, a total of 5.432 Commission Papers have been converted to microfiche to f ree approximetely 50 cubic feet of space. A total of 3.842 Vendors Topf-cal Reports have been converted to microfiche freeing up approximately 95 cubic feet of space."
IE "We have also begun to remove selected hardcopies of documents fawn the IE flies for destruction on the l
basis that the documents are available in DCS."
(Note:
IE plans to destroy these files when they receive formal authorization.)
(Of fice Director Conenents)
OMPA STUDY OF DCS RE SPON',E_
Point 6 - Slightly less than half of the users surveyed indicated that Point six contains the trolicit suggestion, especially wit'h the context they were using their hardcopy files less f requently than they of the previous point in lind, that the staff has always had to do safety had in the past. The remaining users said they used hardcopy analyses of nuclear plants with the assurance of only the files in their files with about the same frequency as they had before DCS, own offices. (... The remaining users (about 561) said they used their All users were reluctant to throw away their hardcopy files hard copy flies with about the same frequency as before DCS.)
in favor of the DCS.
(User Suney) is the apparent NRC staff habit of relying on information piled on the office floor the reason for the last sentence of " Finding C.2"? Since no supporting infonnation is included for this statement, one can only guess as to its intent.
BRIEFING CHART 7 (p. 8 of Encl. A1)
D.
What are the major components of the $10.9M cost of the DCS The table in D was included in the " briefing package" and represents a lor the third year reasonable breakout of costs. However, it contains no indications of s me pertinent facts that bear directly on it. such as impacts from the CONTRACTUAL COMPONENT THi-2 accident.
Equipment Reimbursable Costs Labor Lease
& Fixed Fee FUNCTION J$M
($M)
($M)
OMISSION 16:
The study group did not make it clear that these labor costs represent Coding 3.2 Data Entry &QC 0.7 0.1 1 1/2 full shif t negotiated for Year 3 as opposed to the single shif t
_ egotiated for Years I and 2. and that this extra half shif t was required Control & Distribution 0.3 n
Wcause of TMI-2 and followon activities.
Filming 0.3 0.3 0.2 Search & Retrieval System Oper. & Maint.
2.1 1.6 f.150 the cost of space and equipment for data base growth and storage System Management 0.8 increased because of the increased rate of input resulting from TMI-2 and Travel & Supplies 0.9 from the ongoing accelerated backfit.
Space 0.3 Fixed Fee 0.1 TOTAL $10.9M 7.4 2.2 1.3
..~ -.
RESPONSE
--OMPA STUDY OF DCS Lvidence for finding D of Briefing Chart 7 (from Encl. A2
- p. 26)
Total contract costs are covered in Modification 8 of the TERA contract (covering year 3). Functional cost infonnation is contained in TERA's " Critical Design Review" (pages 61-65).
i BRIErlNG CHART 8 (p. 9 of Encl. A1)
E.
What changes could be made now that would reduce DCS NOTE: This item appears to be nundated and it appears that this was what costs or increase systen bene (lis?
DMPX was given as an order. How is that conclusion reached? By the
~~
existence of a memorandum dated May 19. 1980 Cornell (DEDO) to Donoghue.
(OADM) which states
" Pursuant to our discussion on the NRC Document Control Systen, please provide options for limiting expenditures for FYs 1980 and 1981. It would be helpful if you could
~
provide at least three options by June 2. 1980 which would reduce expenditures by approximately one-third.
one-half, and two-thirds."
The reply is reproduced in Appendix A.
Evidence for finding E.1 of Driefing Chart n (from Encl. A2
- p. 21-28)
]
4
RESPONSE
OMPA STUDY OF DCS E.
1.
Changes that would reduce costs are:
Whatever the intent of this " Finding," the " Briefing Package" has no support from the " Evidence Package." Although on every other " Finding" Net Annual in the." Briefing Package" there is a one-to-one correlation between Saving
" Findings" and the so-called evidence.,in " Finding E" there is no such Maxinnan After off-correlation.
Annual Contract setting NRC Cost Reduction Cost increase The only place where there is agreement, or similarity, is between the
" Findings" and the ED0-directed " Actions" (see below). Ironically, these a.
Reduce the rate of backfit effort
$2k million
$2 million two packages are the only places that the " Actions" appear and the whole b.
Reduce labor billing rates
$1
$1 set of " Findings" do not support these " Actions."
c.
Limit system content to Docket 50 7
and PDR documents d.
Substantially reduce contractor
$3
$15 to 2 coding and abstracting e.
Eliminate subject index
$18.*
$k*
development f.
Eliminate video portion
$5
$5 of DCS g.
Reduce contractor planning
$S
$k to 5 1
and interface with NRC h.
Eliminate processing of duplicate
$4 0 to $5 documents by contractor
- i. Reduce equipment lease costs
$2
$2**
by purchasing equipment J. Eliminate contract "special handling" process k.
Provide Government-furnished 0
space to contractor Dne-time cost.
One-time purchase cost of about $2'aN not included.
Table E shows billing data for the 13 TERA occupational groups. The first column of numbers shows the " negotiated billing rates" for each of the occupational groups. These rates are the salaries, in dollars per hour, that NRC actually pays for the services of each person in a particular group (during the third contract' year). The negotiated billing rates include all nensalary factors such as overhead (51.1%),
fringe benefits ani othet silar factors called " labor additive" (57.9%), general and admre..trative expenses (14.36%), and profit (10%).
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RESPONSE
OMPA STUDY OF DCS t
The product of these four components (collectively called the " burden rate") is 3.0.
(The calculation is: 1.511 x 1.579 x 1.1436 x 1.10 = 3.0)
This means that NRC is billed by TERA at rates that are three tines what TERA salaries are supposed to be. The table shows, however, that the actual salaries paid to the TERA employees are different from the estinated rates that were the basis for the billing rates that NRC negotiated. In six of the thirteen labor categories (numbers 8 through 13), the negotiated billing rate is more than three tines the actual salaries paid to the 1 ERA employees. Significantly, several of these categories (Chief Tech Coder / Abstracter, Tech Coder / Abstracter, and Term Operator) are those in which the greatest total labor costs and labor hours are concentrated).
1 NRC is being billed for nearly $700,000 more than would' be the case if the buroen rate were 3.0 for all labor categories. Column 3 shows, for each of the labor categories, the extent to which the contract cost is influenced by burden rates varying fnmn the nnminal 3.0 level. Numbers in parentheses reflect contract savings that are attributable to burden rates less than 3.0; numbers without parentheses indicate " excess" costs attributable to burden rates greater than 3.0.
The Office of Aeninistration points out that the Defense Contract Audit Agency has performed an audit of and approved the components of TERA's burden rates. Moreover, ADM points out that it is difficult to compare the burden rates of TERA with other particular consulting firms because s
the nature of the work and other factors are significantly different.
The Division of Contracts has not provided examples of other firms against which we might compare or " benchmark" the TERA burden rates.
Nonetheless, our limited experience and intuition suggests
- that even The use of intuition as a basis for a conclusion is certainly peculiar,in a burden factor of 370 nay k high for the type of umrk Seing done by a technically oriented organization such as NRC.
TERA. Infonnal discussions with representatives of various consulting firms, albeit not a scler.tific or necessarily representative sample, suggests that burden rates of approximately 2.5 may be more typical for work inetuina large numbers of low-salaried employees. The last column on the table shows that NRC billings for year three are about 51.8 million more than they would be if NRC were billed at a rate of 2.5 times annual salary for each of the 13 labor categories.
Emphasis added *
(#1PA STUDY OF DCS I
lable 1: Year 3 Billing Data for llRA Occupational Groups Negotiated Ouupational Billing Rate Burden sotal Billings in Excess of:
_{}lfir L Rate
- 3.0 Burden Rate 2.5 Burden Rate
- Eroup, t
- 1. Programe Manageiment 113 2.04 (67,840)
(32,288)
- 2. Project Management 76 2.88 (17,280) 58,320
- 3. Principal Esegineer 68 2.88 (40,320) 120,960
- 4. Senior Engineer 65 3.01 0
85.248
- 5. Project Engineer 54 2.95 (5,760) 47,808
- 6. Engineer 44 2.94 (3,840) 25,056
- 7. Progransuer 40 2.64 (19,200) 8,160 H. Engineer Coder / Abstractor 39 3.22 34,560 100,224
- 9. Chief Tech Coder / Abstractor 33 3.77 199,680 318.064
- 10. lechnical Co.ler 31 4.00 460,800 669,600
- 11. Teiminal Ogierator 22 3.34 84,400 233,376
- 12. Technician 19 3.27 46,080 103.104
- 13. Clerical 21 3.22 9,600 44,880 680,960 Total 1,783,312 Total
- Durden rate is the factor by which the negotiated billiswJ rate is divided to obtain actual eng>loyee salary.
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RESPONSE
0_MPA STUDY OF DCS
- The greatest contributors to total cost are the coding and abstracting function (those for which the burden rates are greater than 3),
i
- The negotiated labor rates between years 2 and 3 have increased appreciably, typically by a third and by 50% for Senior Engineers.
Related ED0-Directed Actions (from Attacionent 1 of November 18, 1980 Memorandum)
The following list contains a brief description of actions being taken In this " Actions" package the items seem to concentrate on costs and " cost to redirect the Document Control Systen. The estimated annual con-savings"t in the "B-lefing Package" the same list is given with " costs."
tractual cost savings shown for some items represent the maximun llowever, in the so-called " Evidence Package." there is nothing that amounts that might be realized. Achieving savings in one area may addresses these costs nor the list. There is no discussion of either the licit the savings possible through others. For example, if lower costs or the proposed " changes" addressed by tee ~ " Finding." There is no labor billing rates are negotiated (Item 2), then the maximum indication of what these costs mean. Fran what or where were the costs savings associated htth other labor items w Id be less. Further, in the "Driefing Package" derived? What are the associated impacts? Wha t some of the actions that reduct contract costs may involve in-house is the total dollar value that the study group says could be saved overall costs.
(af ter NRC and other associated costs are.taken into account)? Are these numbers, as they appear to be, only someone's guess? Strangely, the first
- 1. Reduce the document backfit effort column (Maximum Annual Contract Cost Reduction) in the Table in E.1 totals to $12.25M. which is more than the contract ceiling of $10.971M: This, in (EstimatedSavings:
<$2 h million) fact, is the option that NRC should be urg!31 to take, since according to these figures, eten with keeping the contract alive. NRC could - even by
- 2. Examine options to lower contractor billin_2 rates absorbing)some costs - save a maximum of $9M (from the second column in Table [.1. In short, these numbers do not make sense.
d (Estimated Savings:
<$1 million)
- 3. Limit content of the DCS data base (Estimated Savings:
($' million)
- 4. Test, and where feasible, have NRC staff perform document coding (Estimated Savings: potentially up to $3 million)
- 5. Test the DCS subject search capability 1
)
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RESPONSE
OMPA STUDY OF DCS
- 6. Establish a DCS Policy Advisory Group
- 7. Exydite negotiations to pennit recompeting the contract
- 8. Conduct user needs study
- 9. Designate full-time contract nanager
- 10. Defer any expansion of video terminals
- 11. Reduce contractor planning and development staff (Estimated Savings: < $'s million)
- 12. Eliminate dupilcate document processing (Estimated Savings:
<$'a million) 2 13.!mprove quality control and user statistleg 14.!nvestigate techniques for user offices to share the cost of DCS E.
2.
Thanges that would increase the current system benefits are:
This table. like " Finding E.1." is taken directly from the " Briefing Package" and provides inf onnation for which no corroboration dental or Annual (Contract) bases exist in the " Evidence Package."
Cost increaso i
a.
Accelerate by a factor of two the
$2\\ million agglomerated into " Action 15."
backfit of doct;nnts b.
Backfit subject search capability
$1 to 2*
into existing data base c.
Increase hours of operation
$g d.
Lease 100 additional digital tenninals and assoCjated eonipment for llQ offices e.
Test and improve (if necWsary) data
$5 to \\
base quality f.
Expedite document processing
$k 4
- One-tine cost 36
RESPONSE
OMPA STUDY OF DCS Evidence for finding E.2 of Briefing Chart 8 (from Encl. A2, p. 28)
TIUC has planned to reconpete the contract in year 5.
Recompetition This point is correct.
could be expected to reduce contract costs.
Other costs shown for finding E in the briefing package are estimates I find basing cost estimates on " conversations" to be a strange way of based on conversations with NRC and contractor staffs.*
doin3 business.
BRIEFING CHART 9 (p.10 of Irc1 A1)
F.
What nanagement issues are selevant to future DCS operatians?
F.
1.
There are no systematic procedures for review, approval, or This is, once again, a rather peculiar allegation. Its peculiarity arises documentation of user requests for additional products and more from what is not said than from its con +. ant. This philosophy of servie.cs.
" systematic procedures" for everything from review to decisionmaking to.
" systematic assessment" of user needs pervades only the " Briefing package" and leaves the in:ression that if indeed one is not " systematic," he must certainly be unabie to perform. (NOTE: We assune that " systematic" is intended to correlate with " formal.")
The program office was aware of only one request for "... examples of analyses that you've done with respect to the special services" or "...
examples of procedures that you follow under normal conditions." We assuced that OMPA meant verbal explanation, since the program office had, four mor.ths earlier, provided detailed descriptions to other study members; on this occasion we assumed that the descriptions, procedures and informa-tion had teen conaunicated among the study group members. Regretably, the data and information were not consnunicated among the members - or at least it so appears.
The concepc of " systematic," as defined by OMpA, appears to be a point throughout the "Driefing Package" that runs counter to the design and implenientation philosophy of the.tRC's Automated Information Retrieval System. When the Counission approved the program office's request to issue tne RFP and, later, the contract, the design philosophy that the System now iipresents was presented to them. In effect, the majority of the Office Directors and the majority of the Cenmissioners, themselves, sanctioned this design philosophy. And yet.. OMPA appears to question this whole approach throughout. It appears to TIDC to be an intentional contention.
Emphasis added
RESPONSE
OMPA STUDY OF DCS Had the writers of the study group " Briefing Package" and " Evidence Package" mastered the many studies that were offered by the program office they could have discerned that perhaps this issue of " systematic
... " belonged to accounting problems and not to integrated information systems. The AEC/NRC has a long and unsuccessful history of nunerous projects and millions of dollars spent on " systematically" developed systems. When these systens were innlemented, they died of their own weight and ef fectively amou-+ed to applying band-aids to the gaping wound of information retrieval: Although the progran office made the results of these studies and "Systens" available to DMPA, either DMPA 1
did not understand them, or OMPA chose to ignore the several very expen-sive lessonCo7The last 10 years.
~
If MPA is to be involved in further activities with automated information retrieval, an understanding of the situations faced by all parties - users, managers, processing staf f, and review staff - is required. Based on
" Actions" resulting from the " Briefing Package," which are unsupported by most of the " Evidence Package,* one can only surmise that either (l) the OMPA staff cannot grasp the multifaceted aspects of an integrated informa-tion system or (2) that they cannot succes'sfully convey these meaningfully to the executive level.
F.
2.
Pressure for growth in systen products and costs occurs NOTE: The response to this " Finding" is on an " evidence point" basis because:
Isee below).
a.
User offices do not incur the costs of services provided j
to them, b.
Special custom products and services must be added to compensate for unrealized system capabilities, c.
TIDC lacks practical authority or incentive to deny uscr requests, and d.
The practice of direct interface between TERA and NRC staf f encourages increases in requests for services.
RESPONSE
OMPA STUDY OF DCS I
Evidence for Finding F.2 of 3riefing Chart 9 (from Encl. A2, p. 34)
Point 1
" Numerous requests have been generated by particular user This " evidence point" is lif ted out of context. This statement in the groups for specialized reports and these have been prepared SECY paper was a summary statement to indicate to the Commission that the and delivered by the contractor" Contractor had, in fact, more than complied with the contract statement (SECY 79-649) of work (50W). The contract 50W (p. 3-3) states that:
" Tasks to be performed by the Contractor fall into two basic cate-gories:
1.
Implementation and operation of systems which will generate the following hard-copy reports; a.
T!tle List.
b.
Tubject Index alone or cross referenced to the Title List serial numbers.
c.
Abstract /Index Journal.
d.
Other non-periodic reports (e.g., bibliographies, document groupings,etc.)
TheautomatedaspectsofTasks1thruIl that are associated with the production of these enrd-copy reports must be accomplished by the Contractor untti the hardware, which will be procured by NRC, can be installed and tested satisfactorily. The of feror should make provisions for whatever computer services he estimates will be needed.
2.
Implementation and operation of a Remote Access and Retrieval System for producing virtual images of documents from the NRC store of documents."
Point 2 - Most offices spacified general and off$ce-specific services OMPA Point 2 is apparently an OMPA " Summary of Office Director responses,"
they would like frun the DCS, but nene took cost into which is not totally correct. Although most offices are interested in the (Office Director Comments) prod *;ct or service they request, whether they get what they have specified account.
depends upon both the relative need of the specifying office and the
~
anount of systen perturbation induced into the overall System by the re-quest. When TIDC is not convinced of need and requests documentation, that request for documentation is objected to by some offices or groups.
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RESPONSE
GMPA STUDY OF DCS The latest such request for documentation by TIDC and the appeal to the EDO, with the ensuing response demanded by the EDO, is included in Appen-dix B.
Point 3 "One of the fundar. ental services of the DCS is the capabi-Point 3 is correct. Once the data are digitized, production of a special lity to produce written printouts imemdiately to serve the report generally takes minutes of computer tine. Large expensive reports, needs of individuals or groups within NRC. This particu-which are generally pro 3Uced periodically, were specified in both the lar service has been available since the start of the DCS original RFP and in the contract as deliverables. TIDC knew where the and has been taken advantage of by representatives from costly reports were required and called them out explicitly for obvious every najor NRC program and staff office. Currently, an reasons. The cost for most of the special reports is, on the average, average of two requests for special reports are received less than $100. The utility of this to the NRC staff is generally quite and processed each day."
la rge.
Point 4 - See evidence for Finding C.4 for list of ongoing services Point 4 is a reference.
provided by TERA.
Point 5 - Costs for additional services are added to the total cost Point 5 is either an DNPA summarization (it references TERA contract) or of the contract (increased manhours, sof tware modifica-it is contained in an obscure portion of the contract which we could not tion,etc.). All costs for DCS contract are paid through find.
Of fice of Aeninistration administrative support funds (B&R No. 48-20-25-302).
(TERA Contract)
Point 6 "Another management strategy of note resulted from a Point 6 raises some serious questions. The basic approach that Mr. Besaw decision of B111 Besaw that the relationship between the has pursued is one of minimizing the involvement of the TIDC staff in contractor and the NRC staff should avoid as much either operating the computer or in generating ONLY that class of reports bureaucratic red tape as possible. Therefnre, he decided for which data are already digitized. Any authority beyond this that the not to establish an agency staff to specifically inter-Contractor exercised would cause risk to the Contractor and to Mr. Besaw.
face TERA. Rather he pennits TERA client managers to The risk to the Contractor would be that he would not be paid for nan-work directly with the NRC staff. Therefore TtRA project power or products produced without contractual approval. The risk to managers work directly with the NRC staff to assess their Mr. Besaw would be that he might make himself liable to pay such demands needs, solve their problems, accept orders for reports as the contractor could provide and for which the NRC did not approve..
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RESPONSE
OMPA STUDY OF DCS and counsel them regarding their records penagement problems The overriding fact here is not what the " evidence" quotation suggests, without having to obtain forinal approval from the NRC but that the C.[TTR. duties are spelled out expitcitly in the SpecW
~
Contract Officer Technical Representative."
Provisions. Article IX Technical Direction and Surve'.11ance. Article IX is included here with pertinent emphasis added:
(Grimsley Case Study)
" ARTICLE IX - Technical Direction and Surveillance Performance of the work under this contract shall be subject to tre technical direction and surveillance of the C.O.T.R.
The tene "tec..ni-cal direction" is defined to include, without limitation, the following:
A.
Providing information to the Contractor's supervising representative which: assists in the interpretation of drawings, specifications or technical portions of the work description.
B.
Review, and where required by the contract, approval of: technical reports, drawings, specifications, and technical information to be t
Tellv_eged by the Contractor to the Government, under the contract.*
t Technical direction must be witnin the general scope of the work stated in the contract. Thg C.O.T.R. shall not exercise any supervision or control over the_ Contractor's employees; such employees shall be account-able only to the contractor's supervising representaI We.*
The C.O.T.R. soes not have the authority to issue and may not issue any" teclinTcaT3f rection which: (1)constituesan assignment of additlosal wore outside the general scope of the contract; [fi) constitutes a
~
change as defined in _the contract clausa entitled " Changes"; (iii) int any manner causes an increase or decrease in the ceiling price of the contract, or the time requFed for contract perfonnance; or (iv) changes any of the expressed terms, conditions, or specificallons of the contract.*
All technical directions shall be issued in writing by the C.O.T.R. or l
shall be confiried by him in writing within five working days after oral issuance.*
The Contractor shall proceed promptly with the implementation of all technical directions duly issued oy the C.0.T.R. in the manner prescribed Emphasis added
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RESPONSE
OMPA STUDY OF DCS by this article and within the authority of the provisions of this article.
If, in the opinion of the Contractor, any instruction or direction issued by the C.O.T.R. is withir, one of the categories defined in (1) through (iv) above, the Contractor shall rot proceed but shall notify the Contracting Officer in writing within five working days after the receipt of any such instruction or direction." (NOTE: This clause continues to give direction to the Contractor as to how'to notify the Contracting Of ficer. )
F.
- 3.. Certain provisions of the TERA contract -- the contractor's proprietary rights to system sof tware and the lease arrange-ments -- auke it difficult for NRC to recompete the contract.
Evidence for Finding F.3 of Driefing Chart 9 (from Encl. A2
- p. 35) i' Point 1 - Article XX of the original contract states that TERA Point I would have been better served without the MPA interpretations.
claims rightr to the original ARMS sof tware after the contract has expired. In order to continue system epera-The negotiations for both Points I crd 2 are being pursued by the tion. NRC nost buy or lease the ARMS software. (Informal Contracts and Legal staffs.
i discussions have been held between TERA and the Division of Contracts regarding the possible NRC purchase of DCS so f tware. ) Article XX is reprinted below.
" ARTICLE XX - NRC Use of the Contractor's Propriety foftware The Contractor alleges that its Automated 9ecords Manage-1 ment Systein (ARMS) is a proprietary computer system.
designed and developed by TERA. The Cc1 tractor shall l
provide to the Nuclear Regulatory Commission the utiliza-tion of the applicrhie sof tware portions of this system as determined by the educlear Regulatory Consulssion. Full rights and title to the existing ARMS software wili remain i
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RESPONSE
q
_0HPA STUDY OF DCS in TERA, except that the NCc only, will have the right to use, at no cost, the aforesaid applicable sof tware portions of the ARHS system in the manner and for the purposes set forth in Section 3 of this contract. Such rights shall survive the expiration of this contract. Improvements in the applicable software portion of the ARMS systen which are required to be originated or developed under this contract are subject to unlimited rights as defined in Clause 58.*
(TERAContract)
Point 2 - Discussio'ns with the Divistan of Cr~ tracts indicate that if potential bidders planned to use the existing DCS facility they woul j have to negotiate with TERA for sublease of the facility.
(Telephone conversation - C. Lebo, Division of Contracts) 4 1
F.
4.
The contract can be recompeted for year 4, beginning June 1981, This is a somewhat academic point. Based on previous experience with only with an expedited contract source selection proces3.
letting a contract, the program office estimates 12 to 18 months would be required to couplete a competitive procurement of this type. This means that the program of fice should have begun the rounds of 50W preparation and submitting to all the user offices for review, comment, suggestions, and subsequent approvals in August 1979 in order to make a June 1981 date.
But the OMPA study was ordered by the EDO and Consissioner Gilinsky in July 1980 and it was not completed until November 1980. Thus, all the time of the program office members who should have been drafting the 50W was occupied by " studies" to provide that it coulda't be done' Now that a full-time C.O.T.R. has been named, we can only assume that the task of drafting a new competitive 50W is his responsibility. Also, the 50W for Year 5 should have been started by August 1980 to make the June 1982 deadline.,
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RESPONSE
.OMPA SIPC..Y OF_DCS F.
5.
The cost of buying the DCS equipup*nt now (and maintaining it)
Routine notification of FY H0 unobilgated balance was transmitted to the is less than the cost of continuing to lease the equignent Offic.t Utrectors by the Centroller on November 14. 1980 and ADM for another two years, responded with the request for funds on November 25. 1980 (see Appendix C).
Evidence for Finding F.5 of Briefing Chart 9 (from Encl. A2. p. 37)
To date NRC has leased rather tr.an purchased ADP equipment. The T[RA This statemer.t is absolutely wrong' contract contains an equigaent purchase option that 110ws NRC to take a credit against the purchase price equal to a set percentage of lease payments made by NRC During the contract's third year (June OMIS$10N 17:
1980 to dsne 1981), a credit of 63% ot our cumulative lease payments is appitcable. If equipment is purchased in the contract's fourth The OMPA study group makes the same errors in its support for " Finding year or later, the credit is only 50% of lease payments. After 5-1/2 F.5" that are made over ar.d over. They assume that the equipment for the equipment congirTs~quipment and ignore all other.
Contract is ADP e in fact, the other years of paying lease. NRC vill own the equiguent and pay only mainte-es e mu'cl larger volume than ADP equipment. This alone nance costs of approximately $300-500.000 per year.
dem nstrates how little OMPA really understood its assignment.
(TERA Contract. Section 5.A.5(a))
Aside froh..ie failure to correctly identify the subject, the rest of the OMPA paraphrase of Contract NRC 10-78-580 appears to be accurate.
BRIEFING CllART 10 (p.11 of Encl. A1)
G.
What other issues are relevant to future DCS operations?
G.
1.
T[RA appears to have been resoonsive to the for1nal contract This section appears to have been added to placate the Contractor and as requirements and to the particular needs of various NRC a convenf ent place to address a Ceasnissioner request for inforination that was provided under SECY 78-67A. Appendix B.
(See Appendix D)
- users, Additionally, this section appears to highJght, items that are already addressed, either directly or impilcitly, or could have been addressed in other sections. We see no logical reason for this section. _
RESPONSE
OMPA STUDY OF DCS This is one of those " Findings" that, leads to the initial statement of this paper that the " Briefing Package" and " evidence" are filled with innuendo, but specifics remain either unsaid or unsupported.
G.
2.
An examination of the document control systems of 14 other agencies suggests the following:
a.
Compared to the t<S. the systens in other agencies are Having stated in Item a. that a comparison is of limited value, the study suf ficiently different in purpose and content that direct nonetheless goes on to make " general comparisons."'
comparisons of specific costs and benefits are of limited value.
The logic of making direct comparisons that are of " limited benefit," as stated by the above point causes the reader to wonder wd it was, never-h b.
General comparisons nf system attributes are:
theless, done' Also, the ambiguities and logical inconsistencies between the " Findings" create confusion for the reader trying to understar.d what
- NRC's system contains more document types (exception:
is being said. One can only suspect intentional obfuscation. For example.
CIA),
does " Dash 3" mean that to do a given job, more contractor personnel are
- NRC relies or contractors to a greater degree, required than having the same job done by government personnel? If one
- NRC has more people working on its system than all reads from " Dash 2" to " Dash 3" consecutively, then this is the logical but one agency.,
conclusion. The table of " comparisons' provided by OMPA only adds move
- The rates of documents entered into the DCS and confusion.
searches conducted on the DCS are not significantly dif ferent frun the averages for other systems.
The only conclusion that can be drawn fnma " Finding G" is that numerous
- The total costs of NRC's system (contractor and universes of information retrieval exist end that efforts must be in-house) are significantly greater than the total tailored to agency requirements, costs for the other agencies.
G.
3.
With respect to terminals:
What does this mean? Does it mean:
a.
The DCS was originally designed as an all video system.
(a) WJyt was the design changed to include digital?
b.
The cost of video terminals appears to be three to six (b) Ris (a) changed because of (b)?
times that of digital terminals.
(c) If (a) and (c) are correct, then why did these not override (b)?
c.
Primarily because of difficulties with ?:,e microfiche tub flies associated with digital terminals, the staff (d) Items (a) and (c) did not override (b) because (b) and (d) were of has expressed a preference for video terminals, stronger weight logically?
Emphasis added
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RESPONSE
DMPA STUDY OF DCS d The cost of transmitting video lauges among scattered (e) But since (e), if tuccessful, will add to (a) and (c) and these NRC locations sukes an all video system impracticable three will then logically outweigh (b) and (d) - therefore, we j
at the present time.
must wait...
s e.
Measures to improve video image quality have been initiated.
As with the whole of the study group report, the " Finding" is not j
supported by the " evidence." further, the whole OMPA study does not support the EDO " Actions" since the only correlation between the two i
" packages" (i.e.
Findings and Evidence) is " Finding E."
Logically.
the " evidence" does not support the " Actions" and, in fact, there is j
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90, connection between the " Actions" and the " evidence."
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t-APPECIX A Memorandam. Donoghue to Cornell, June 5, 1980 " Document Control System" k
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S4ga,3-):..d9 R LO d2_
1 9
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orais o si At ts t
s*s tCl F Ac cFr: et ainsw re"enceim v..u.n.:.un. Sa s n.
y
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EU..
ID*.ORRiOG1 FOR:
E. Kevin Cornell, Ce;uty Executive Director for Operations TROM:
Daniel J. Deno; hue. Director Office of Ac:::inistration SllBJECT:
00CG;ET.i 007.iRO:. 3707:M
Reference:
!!emo. Cornell to Donegnue. "00cu=ent Centrol System.* dated May 19.1980.
In your me.o of May 19. 1930. you asked for "... at least three eptions which would reduce expenditures by appr:xicately one third, one half, and two thirds."
We discuss six options below which would reduce services now provided by DCS.
In addition to the function but by arcunts different than these you suggested.
(option) and the amount of reduction of ex;enditures we have provided a ciscussion of impacts of each cut.
- 16. 1980, the System was designed and As we discussed during our reeting of May implemented to expedite and provide major assistance to the licensing and inspection / enforcement functions of the NRC staff. Accordingly, the reductions are discussed below in inverse order of potential impact on the licensing and enforcement programs.
1.
Backfit of E&'.' Plants a.
Entire Sackfit Effort The backfit efforts are two-fold: 'one part is to assure, with direct assistance from the technical staff, that flies are complete; the second part of this effort is to put all existing information in a standard format (done by c: ;utericing the infer".ation) so that the staff can find a dccu-ent by a nutter of different routes (e.g.. by Docket No. by date/ author, by subject, etc.).
Such cross cuts of informatius are not pessible without a cceputer because of the very large, very co= plex data base with which the technical staff works.
This thinking was the impetus for NRR and I&E requesting that all B&V-designed plants be backfit as soon as possible. This foresight has proven valuable in both the subsequent Crystal River and Arkansas Nuclear Cne incidents.
The funds fer the supplemental FY B0 budget request were justified by NRR. and
[
OACM cust get NRR and IaE concurrence before any cuts are made in this function.
If these c:ccurrences were cbtained, the extra shift at TERA. which now pr: cesses these d:curents would be discontinued. This would cean that:
APPENDIX A
..= _....
i f
E. i.evin Cornell, Leputy Executive Director for C;.raticns Pa;e 2
- the staff would be recuired to use files tnat are Lnown to be incomplete to make jucpements otractiy Learing un piulic naalth and safety on E&W designed and Systematic Evaluation Program (SEP) plants;
- the G5-14 and -15 technical staff and Project tunagers would, once again, be forced to revert to a role of " paper tracter" in order to ressenably perform theie technical functions; this in turn, reduces his efficiency measurably.
5 The net result of elimination of the extra shift, in ter=s of dollars, would be
$2.3 M in FY 81.
b.
Eliminate 24X Microfiche of Backfit Ocekets The backfit is being treated uniquely in the production of microfiche.
On an ongoing basis, the routine daily flows nave only 4SX microfiche made for staff use. Mcmever, when the backfit effort was begun the FDR and ACRS identified The PCR needed 24X for high-volume fast blewback a need for 24X microfiche.
to hard copy (nece;sitated fer response to public and because of unavailability i
of older recrods) and the ACRS needed 24X to send to its mesters.
If this function were eliminated, the dollar savings would be about 575K in FY 80 The effects of' eliminating this would be a very slow and about M27 K in FY 81.
response to be public for older, but active, flies because the hard copy reproduction would have to be done in-house (on a first-ccme, first-served basis with staff working overtime) until a contractor could be secured by the PCR to do blowback.of ASX fiche. The ACR5 would get only 48X microfiche to use in-house. We don't knew what they would provide to members.
1 2.
Document Handlino for Multicopy Packaces The fiRC currently has TERA expediting document flows, particularly to the PDR.
This means that TERA marks and packages documents after processing them and i
then delivers these packages to five different locations including the FOR at i
If this effort were H 5treet and LPDR and Central Flies staffs in Bethesda.
to be withdrawn from TERA, then TERA wculd receive only one document and would i
return that docu=ent after the data and information on it had been extrauted and the docueent had been filmed.
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Sirce this service cannot be eliminated and current NR staff is limited, a ccetract would have to be let for this function. The impacts would be:
- a contract could not be ccepleted before the beginning of FY 81;
- once the contract is let, work world be duplicated between the i
new centractor and TERA (e.g., keystroking titles, etc.).
This I
ceans that although seney can be extracted frca the TERA centract.
the overall TIDC budget requirements aculd increase.
- esti=atec cost to hire another company is eight man years, or i
about 5560,000.
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E. Levin Cornell, Deputy Executive Lirtc or for Ocerations p3ce 3 If this were to be withdrawn from TERA, it would yield about 3350E frma DOS f.ndt.
_ eculatory InforYation Distribution Service (RIDS)
R 3.
Another function which TERA performs for the hRC staff (GRR, I/E, AE00) is tne automation of all incoming documentation (principally, Docket 50 at present) relating to casework to allow TIDC to control it. CA31 is curr.ntly corsidering expancicg tne klDS activity because of staff requests anc activities (see attachedmemes).
In the last two years incoming documents that require control have increased from about 50 documents / day to about 150 docueents/ day. From the above referenced memos, we can only anticipate additional growtn. Inerefore, the function cannot be eliminated. It can only be shif ted to ancther contractor.
As with Item 2, above, the cost increases for putting it out on a separate contract. Her ever, in this case, the impacts are more dramatic than Item 2 above:
~
- a different contractor will require about 10 people to do this work. This estimate is based on past NRC and TERA efforts.
- the service purchased separately will cost the NRC $700K-5750K.
- unless the cycle is completely automated, a separate contractor will be slower. Currently, the whole RIDS processing cycle is automated so that the 150 documents are processed and ready for pick up in six hours or less. The duplication by TIDC staff requires another three hours on the average. The staff often finds this wait time unsatisfactory. Any longer delay would be unacceptable.
Because the RIDS cycle is completely automated only about $175K could be recouped by removing this from the DCS contract. The assumption inade te arrive at the estimated cost for a different contractor than TERA was that only a small portion of the processing of the documents would be automated.
This is the reason for the very great discrepancy between the dollar costs of doing it with DCS and having it done elsewhere.
4 Allew No RUSH Handling of Documents Currently an estimated 8t of the TERA manpower is spent on special projects (e.g. ovtesi:e drawings for the Incident Response Center; special processing of all State Emergency Plans). This special hand 11ag could be stopped, if absolutely necessary. However, it is not recommended because the impasts could be quite severe. For example, the ISE staff needs as-built drawings for all the operating nuclear plants to be available for use in the IRC. As a result, more than 2700 drawings were gathered by the Regional Offices a d ship;ed to the IRC/HQ staff in less than a month. Needless to say, a volume
E. Kevin Cornell. Deputy Executiva Director Pape 4 for Ocerations such as this is not manageable, ner are tne drawings use3tle withcut scme To handle this fer th-IF.:, TI"," i # ~T;*
d% wi sy st=~. tic ;,. c;as.,c as.
autcmateo drawing titles so that the infor-ation relating to the drawing can be retrieved by title, by drawing number (and revision), by plant, by docket numcer. or by date and the drawings were reduced to fit-into an ccening on a standard EC-column enmouter-type card so that they ce;1d be managed.
impair the To cut into this tyoe of service from the System would ssriously NRC staff's (technical and legal staff) ability to respond to emargar.cy anc heavy overicad situaticns.
5.
Cut Technical Sco; ort Functions The System provides, and was designed to provide, both technical infonr.ation and records management as requireo by the Administrative Procedures Act of However, the number of 1967, and the Atomic Energy Act of 1954, as amended.
documents processed can te cut frem the full daily flow of about 1000 documents / day to only those documents that are made publicly available (about 500 documents / day). The impacts of this action are:
- no services would be to the internal staff; only the documents cade publicly available would be handled;
- no document or data files would be computerized so that the offices would be able to see what each other is doing;
- no flie integrity could be assured because there would be no document centrol;
- staff members would have to return to keeping their own files and, essentially, two people working on the same plant would end up with two different sets of records (i.e., the Project Managers, Tech. Reviewers, etc., would have to return to the mode we operated in three years ago - being file clerks principally and technical pecple secondarily).
- the agency wculd return to putting out several reports en cenclusions (this actually has happened prior to 1976);
- no FOIA assistance can be provided.
The cost of providing this service for publicly available documents would be 510.971M). This about $6.8 millien (more ti.in half of the current cost of cost can be trirmed only by the folicwing actions:
NRC provide space for the 50-55 people required to ecde, 1.)
key, and handle the docu ents and to house the equipment.
This would allow NRC to trim about 51.05M; and
E. i.evin Cornell. Deputy Executive Director i s. e ;
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processing of the publicly available occu= ants (ct:st 1.25 c:1111on docu=ents/ year in FY 79). about 52.5-53.0M can be extracted from tne centract.
Tne ".RC has a basic operation cost of about 52.5-53.C" trt c::;ater er time-sharing casts to process the volume of docur.ents that it makes publicly availacle. Tnis cost cannot ce cut; tt is pare minimum. rurtner, tnis n=:er will prc: ably gr:w be:ause tr.e nu=:er of accurents c.ade liablicly avail-Setween 1974 end 1979 :ne nurnter of publicly available able grows yearly.
1.250.000 docu=ents increased from about 15.000 documents / year to ateut While the increase is not likely to be so dra=atic in the docu.ents/ year.
Furtner, if the poitey or maxing a_il next fivs wears, it will increase.
documents ;ublic is T2plemented (see SECY 79-301; it has alreacy been acepted by the Cornission), then the volume of documents will increase by at least 302.
We think this is responsive to your request. However, if you she'uld have questions, we will try to an:wer them.
Onfr n a situ G M t,2nis13.Ds==;has y Canfel J. Ocneghue. Director Office of Administration Enclosures Me=o 5/23/20-Theepsen to Eesaw Memo 6/3/80-Besaw to Thcepson bec: Mr. 0:n:ghue's chrono i
Mr. Sesaw i
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lI!".CTE'L'M FCP.: *11111am J. Eesaw. Director. Division of Technical Infor=ation and Document Control. ADM.
FROM.
Dudley ir.::psen. Executive Officer for Ooeratiens Support. IE
SUBJECT:
HANDLING OF CLASSIFIED INFCRMATION Cn April 16. 1980 we requested the regions to send a copy of the enclosed letter to all Fuel Cycle and 'aterials liccr. sees. This action v.2s a follewup to a request from AEOD to take several near-term steps to irprove the data collection and dissemination of reports. In this letter, a see:ific request is cade to send a copy of each report to DM3 for dissemination.
It has c::e to my attention that CMS is'not in a position to handle classified information. Obviously, prior to taking the above ' action we shculd have checked this point out, but we did not. In one case. Security has been conta:ted by a licensee and until such tice that CM3 can take classified information, the ifcen-see was advised not to send.any reports to CMS.
In a meeting on May 7.1980, attended by Steve Scott, Wilda !b111 nix, et al on a related matter, we obtained the impression that CMS is gearing up to be the 11e agency's central re:eiving point for operational reports fro: licensees.
have long been aware that a central systet for receipt and dissemination of these reports is the logical solution to many of the problems we encounter with We are in support of a centralized receiving point and we LER-type re;crts.
are giving preliminary thought to recoceending a rule change to facilitate such a system.
In view of the above it would appear highly desirable--if not mandatory--
for CMS to set up the facilities and procedure to handle classified infor=ation.
CO:; TACT:
G. C. Gower 49-272?6 i
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T 1d be interested in knowing your plans in this area rather promptly in c,rcer for us to resolve the problem ncted atsve with fuel cy:le and materials E's v.0.:
i ke..>ct rapsrts c.4 f:r :: further :09:f de-etiM regarding a centralized receiving point for licensee rs; orts.
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Dudley Th:: [on Eve:vthe officer inr 0;erations Support, JE Enc 1csure: Ltr. to alt Fuel Cycle and P.aterials licensees dtd 5-15-80 cc: - S. Scott, OBM L. R:terts0n, NMSS R. Paulcs, X005 W. Mallinix, X005 V. Miller NMSS J. Crooks, MPA C. Michelsen, AE00 t
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MD G /t'; D FOR: Dudley The pson, Executive Officer for C;eratices Support, IE TRui:
Willia.: J. Eesaw, Otrect:r Divisien of Technical Information anc Docu~ent Control, kDN S'.'I.'! CT :
PE:DLING OF CLASSIFIED INFORMATICE As ycu n:ted in your cercrandu of Hay 29, tne Division ci Tedniical Infor-atier.
and %:=ent Centrol is deveicping the Decu ent C:ntrol System as the central licensee systes for the receipt, centrol and internal disseminatien cf ine::inIs by Trasently, all pre;rietary and n:n-pr:prietary submitta inf r atien.
- .;er rea:t:r licensees are centrally ; recessed inreugh what is eslied the Re;ulat:ry Infer aticn Distribution System (RIDS).
We agree that expanding RIOS to include all ifcensee submittals is the ecstAs you noted, 1cgi:al, prudent and efficient a;; reach to document managem include nce-reactor licensee submittals.
IE, ;c'55, MPA and AECD to develop the prcper distributien patterns for each In addition, a recent study by OIA indicated that DCS type of submittal.
We have discussed sh uld aisc receive all LER's directly frcm licensees.
this with P.r. J rdan of IE.
As y:u suggest, a rule change is needed as soon as pcssible to assure that tJR has an efficient and effective means of centrolling de:umentation and disseminating it to those staff members who need the data.
We are prepared to begin the central centrol of d:cumentation i Such a: tion will cean better d:cu-ent management as well as reduce the c:pying, postage and handling burdens presently irpcsed en Regional dire:t:rs.
offices which rust new f rward multiple copies of the docu ents to Head;uarters.
H ever, we can not implement the centrol of classified d:cu ents at this ti e The cue to the staffE requirements that such an effort w uld it;cse.
se:urity control and accountability re:uire ents for classified d:cu ents To preclude any c: ;r::tse of classified inf rmation and assure that all d::u ents were c:ntrolled in ace:rdance with Manual Chapter 2101 are stringent.
would re:uire us to ic=ediately aug.ent cur staff by at least two l
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..f.- c1=ee434*d **+=eials f ron the R105 syste.. 1:nen staffine is availaole, we w:ule initially create only digital records on DL5. in tne future, we plan to electronically control access to vPJeo images also.
Steve Scott will continue to t;crk with your st6ff to integrate as many ty;es of re;vra., g.,, :,16 ir.tc the systa=.
original Signed By ElllD::1.J22:1 William J. Besaw, Director Division of Ta:nnical 1 fer:sti:n and Document Control, ADM cc:
D. Donoghue, AO:
C. Michelsen, AEOD R. Brady, Security G. Gower, IE J. Crooks, MPA E. Jo.-dan, IE 3
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APPENDIX B 1.etter, R.F. Fraley, Executive Director, ACRS to William J. Dircks EDO, NRC, October 6,1980, "The TERA Corporation Retrieval System," and reply, November 24,1980, " Unrestricted Access for ACRS to all Indexes and Records of NRC staff and Program Offices."
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NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS a,9.if ~ f wasmmarow. o. c. rosss g,
j October 6, 1980 Mr. William J. Dircks, Executive Of rector Office of the Executive Director for Operations U.S. Nuclear Regulatory Commission
Dear Dircks:
SUBJECT:
THE TERA CORPORATION RETRIEVAL SYSTEM The Advisory Comittee on Reactor Safeguards was given a TERA terminal last May and, in late June, was given a tuo file for material placed in the Public Document Room (PDR) after July 1,1980.
However, this office has been permitted access to only that information that has been released to the PDR. This precludes ready ACRS access to internal NRC documents generated by/for the staff which can contribute significantly to the activities of the Committee, even though these documents are frequently provided in full-size copy for Committee review or use. I understand that this limitation has to do with a concern about the ability of the ACRS/ACRS Office to withhold such material from publication in the conduct of Comittee business.
This memo is to confirm discussion with Kevin Cornell to request that this office be given access to the central files databank and to comparable tub files so that we may utilize the TERA system fully.
In this connection it shculd be noted that the ACRS Office and Committee membr7 will provide the same protection of these documents as members of tne regulatory staff in accordance with 10CFR Part 9 -
Public Records. Release of such records in accordance with FOIA requests, for example, are coordinated with the originator in accordance with procedures for control / release of such documents via the Division of Rules and Records.
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Sincerely yours, R. F. Fra1ey Executive Director cc: Kevin Cornell l
APPENDIX B i
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NUCLEAR MGULATCRY CCMMISSION r
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.use mcTcN. 2 c :0555 t '*~ &f f Novemoer 24, 1980
_ MEMORANDUM FOR: Directors of Offices and Divisions FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
UNRESTRICTED ACCESS FOR ACRS TO ALL INCEXE5 AND RECORDS OF NRC STAFF Arid PROGRAM OFFICES In response to a request from the Advisory Committee on Reactor Safeguards, it has been agreed that the ACRS will have unrestricted access to the digital data base and the 48X microfiche resulting from the DCS portion of the NRC's Automated Infor cation Retrieval System.
There are scene documents for which only digital records are made on the DCS and microfiche is not available. In these cases, the documents are retained in the originating office. In the event that ACRS requires copies of such documents, they have been advi, sed to contact the originating office for a copy.
Ab.. _,
William J. Dircks Executive Director for Operations t
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APPENDIX C Memorandum, Donoghue to Triner November 25,1980, " Office of Administration's Request for Unobligated FY S0 Carryover Funds."
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N0y 2 51550 MEMORANDLH FOR: Edwin Triner. Director Office of Budget FROM:
Daniel J. Donoghue. Director Office of Administration OFFICE OF ADMINISTRATION'S 2EQUEST FOR
SUBJECT:
UNC3 LIGATED FYSO CARRYCVER FUNDS In accordance to Len Barry's memo of November 14,1980 same subject, I am recuesting FY 1980 carryover funds for use on two high priority unfunded requirements.
The priority one recuest (Attach:.ent 1) is for the acceleration of For this accelerated program. I am requesting support to the LPCR's.
$290,000 in administrative support funds and $29,000 in travel funds.
The priority two request (Attac! cent 2) is to exercise the option to purchase the basic package of equipment for the Document Control Should the purchase option be exercised at this time, the System.
paytack period is 8-9 months, which is a very positive cost advantage for the long-tem operation cf the OCS.
g:3156 SIG-penopus DaIfeYby*Donoghue, Director Office of Administration
Enclosures:
As Stated i
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APPENDIX C l
C Office of Administration Division of Rules and Records Re;etst for L'nobligated FY 1980 Carryover Funds a.
Fund function: Accelerated LPDR Support b.
Amount: $290,000 for Administrative Support Funds
$29,000 for Travel Funds c.
Concise description of the unfunded requirement:
Funds are ecessary to (1) pay libraries for the actual coits of maintaining and servicing NRC's local public document collections in order to assure that tne collections ara maintained in good.
order and in an up-to-date manner and (2) pay travel costs te LPORs in connection with the installation of microfiche reader printers and to audit LPDRs to assure they are up-to-date.
6.
Explanation:
The Office of Administration has budgeted to provide funding and micrographic support to libraries maintaining NRC's local public document collections. It was the original intent that this progree would be phased in gradually over a three year period. In FY 1981, 584,700 was allocated for this program, and $248,000 is teing re;uested in FY 1982 budget.
In FY 1980, 30 microfiche reader printers and supporting equipment were purchased for the LPCRs. The FY 1981 funds are being used to purchase an additional 32 microfiche reader printers and supporting equipment. Funds are also being reprogramed by the Office of Administration in FY 1981 to provide microfiche reader printers and associated equipment to the remaining 26 libraries which house local public document collections for power reactors.
As a result of recent publicity and criticisms of the program by Nader and Pollock, the Commission has decided to accelerate the supp:rt program. The Office of Administratien is also making available in FY 1981 funds to provide financial assistance to 10 of the 98 libraries which house these collections. The requested funds of $290,000 for acninistrative sucport will provide support for the remaining 88 ocwer reactors collecticns ($3,C00 each),
22 limited service collections (mini-LP:Rs) ($1,C00 each), and three repearch and test reactor collecticns ($1,500 each).
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In addition. $29.0C0 of additional travel funds are recessary to implement, cocrdinate, and supervise the activities associated with this accelerated su;;crt program. The break denn of these addition funding requirenents are listed belew:
Recuite-ent Funding 1.
Install 62 microfiche reader printers
$15,500 new on crder; deliver microfiche c:vering period from January 1979; convert LPCR to TERA filing system, and instruct library staff in use of fiche and new filing system (Requires each LP:R to be visited, and assu=es f ur LFORs can be visited each trip at a cost of $1,000 per trip.)
2.
Mcve 10 LPORs which either (a) are 5.000 located in Courthcuses and do not have evening er wulend hcurs or (b) are unable or unwilling to pr:;erly maintain collectiens. (Requires cellection to be coved and set up in new locatien.
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and the library staff instructed in its use. Recuires a separate trip to enth of 5500 each.)ging L-) days at a cost location avera 3.
Install 36 microfiche reader printers 9.000 to be ordered in FY 1981. (Same requiremencs and assumptiens as in item 1 above.)
3.000 4.
Cicse 12 LPCRs W.ere the plants have announced cancellations or deferrals.
(Sa-a assum; tion of four LPORs per trip at a cost of $1.000. If LPDRs are not closed, it wculd still be necessary to visit them in FY 1981 to assure the docu ents were being
=aintained.)
5.
Audit =aintenance of 22 mini-LP Rs and 5.000 3 research and test reacter LP Rs (Vizits wuld be c :tir ed with other scheduled trips. Assur4s an additi:nal c:s cf $200 per LPOR.)
337'300 TOTAL FY 1931 TRAVEL COSTS SU :ET Ar. LOCATION FOR FY 1981 S11.500 I
C0"MITTED THRU 11/19/80 2,950 B.!!O 3"CGET S* LANCE 3E3.330 AOCITICNAL FY 1981 TRAVEL PEOUIREMENTS
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3 The im;act of not providing funding sucport in FY 1981 is severe.
flRC will not be able to assure tr.at the collections are being proce,iy mainttined and criticis s of the dccurent ectiections are likely to contir.ae. ltereover, the Division of Rules and Records will not be
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able to execute :ne Ccamission's decision to accelerate the su ; ort a
program for the LPORs.
As part of the Cennission's legislative package for the 97th Congress, the Office of Administration has submitted a proposal to recuire
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applicants and'licen' sees to establish, fund, and maintain a Iccal nuclear public document collection near the site of proposed or existina If.the legislative procesal is enacted, HEC fund}ng cf power plants.
local public document collections wcaid only be of a temporary nature, 4
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Pricrity: One D
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F.E00EST FOR FC 3:53 CF UNFUG0E0 RIQUIRE"ISTS 2.
(a) Function: Administrative Support (b) Amount: 5850.000 (c) Convert System (Automated Information Retrieval System) equipment from lease to purchase. (See Item (d) below.)-
(d) When the NRC's Automated Infor:ation Retrieval System was begun in June 1978, a purchase eptien for system equipment was included.
The contract provides that the equipment be leased cut b.t that "The NRC may, at its option, purchase the system... at any time after the basic period of performance..." The usage 411cwance shall be 6j!i of the cu=ulative mentnly-least payments if the system j
is curchasec after the third year of the cen ract*."
(TIDC calcula-tions of ccst are in Attacn=ent 1.)
In CA M budg't submittals fcr both FY 80 and FY 81, funds were e
requested to purchase the equipment since thc investment and useful-ness clearly make it beneficial fer the NRC, as a whole. Fewever, in botn FY 80 and FY 81. the requested funds were net allowed and funds were included for lease, only.
The reasons fcr the TIDC request for funds to ccnvert the equipment was that both our cost analysis and the cost analysis perfor ed by the Division of Centracts shewed that the most effective time fer equipment purenase was in Menth 25 (June 3 - July 3, 1980) cf the c:ntract.
Finally, the portion of the CM.FA study relating to the purchase of the current DCS configuration is given in Attachment 2.
Effectively' this shows, as TIDC had stated in budget subsittals, that the mest cest-effective time for purchase of the equipment was in June 1980.
However, it is still to the benefit of the Gcvernment to purchase the ecuip ent as seen as ; ssible.
(e) priority: Two Enc 1:sures:
As stated f
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. Cost to Pur:P*'e Equi r.ent
$1,413,202 Leis: Funds no longer recuired to lease the equipment just purchased 567,355 Additional funds required to Purchase Equi; rent
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COST ANALYS55 FOR PL'~.A55 GF ECUIPICT FRO' C0;!EA 7 140. NRC.10 78 553
$3,765,342 Furchase Price (from Contract)
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Usage allewance to NRC = 63: cf cumulative monthly. lease payments Monthly. ease Payment (during basic period of performance) = $143,332/mo.
Total nu= tar of months leased (during basic perice of performance) = 20.5 Total lease cost during
= (5143.332/mo.) (20.5 mos.)
basic period of performance
= $2,938,306 Kenthly lease payment (during )
extended period of performance
= Sil3,471 Nucter cf mcntns in extended period of perfor=ance prior
= 7 (from 6/3/80-1/3/81) to equipment purchase Lease cost during extended period of performance prior to
= (5113.471)(7)=5794,297 e;uipment purchase Tctal Collar Amount A; plied
= (S2,938,106 + $794,297)(0.63)
= (3,732,503)(C.63)
= 52,351,540 A.:unt NRC p st p.ay to
= S3.765.342 - 52,351,540
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ilke title.- o equip =ent
= $1,413,802 k_ cunt required to lease
= (5)(5113,471) equi; ent frem 1/3/81 6/3/81
= 5567,355 Attach. ent 1.
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. J.n.13 J.n. 34 h ~t$
- h. ts J.n. '37 J.n. 38
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.s., '. w To date TGC has lessed rather than purchased MP ecufp ent. The TFA contract c:ntains an e:ui;:ent pur:hase c; tion that ellcws ta: to take a c edit agains:
- e :gr:hase price e:ual to a set percentage of lease ;a-Sring the c:ntract's third year (June 19S3 to June 1331) rents race by ?GO.
a credit of 63 cf Our :u ulative lease ;ay ents is a:;11 cable.
- f ecui::ent is pur:hased in the c:ntra: 's fcurth year,cr later, the credit is cnly 50 cf lease ;a. cents.
After 5-1/2 years of paying lease. fa: will cwn the ecuf;:en: and ;ay :niv aintenance costs p f a;;r:xtertely 5300-500.0C0 per year.
(TE:.A C:r. tract !s:tien S.A.5(a))
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l The ':lle.ving :stles sh:w the s ;;crting c: :uta:f=ns for Figure F.6 and are t
baset :n purchasing e:ui;:en: by January 1381.
i Attach en: 2 i
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APPENDIX D Me-crandum, Comissioner Gilinsky to Chairman Ahcarne and Comissioners Hendrie and Bradford, Oct ber 6,1923. " Year Four of the Document Control System Contract."
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, ;%W,{[/. l NUCLEAR REGULATORY COMMISSION wasweescTom. o.c. ressa t 4.M e,
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crries os twe Ceteber 6, 1980 cow.ussionsa MF.MORANDUM FOR CHAIRMAN AHEARNE CO.v.9IS S IONER -HENDRIE CO.uMISSIONER BRADFORD SUBJECTS YEAR FOUR OF THE DOCUMENT CONTROL SYSTIM CONTRACT The attached memorandum from OIA of September 5. 1980 recemmeads that Year Four of the TERA Contract (which begins June 3, 1951) be awarded on a competitive basis. A previous memorandum of April 23, 1980, from the Division of Centracts made a similar suggestion, although their target date of September 15 for a Statement of Work (SCW) does not seem to have been acted upon.
I am concerned that if we do not act immediately on this very complex centract, it will be too late to obtain c==petitive bids for Year Four.
This is a very costly and problem-plagued contract. It wculd be difficult to justify before Congress our failure to act on these recccmendations from our own staff.
The staff should note Commission approval of the Year Three contract to TERA requested that future contracts be limited to essential NRC requirements and reflect all cost-saving modifications.
The chief preblem with this contract has been that the basic needs of the NRC were not clearly defined at the outset.
The pending MPA and OIA investigations should help to establish these.
The new SOW should be limited to these sasic, clearly-defined needs, and such eptions as the video system and special services should be ecsted separately.
f There have been repeated delays in producing the MFA and CIA t
l reports, due to the complexity of the contract. While awaiting these reports, however, the preliminary contract werk, such as appointing a Review Ecard, sheuld begin im.ediately.
Any further delay will autematically result in centinuation of the present unsa tisfactory contract.
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u Victor Gilinsky A'tachment rc:
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i APPENDIX 0 s
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