ML20040B181

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Discusses 821020 Concerns Re Time & Effort Spent by ACRS & Ofc of Nuclear Regulatory Research on Program & Budget Reviews.Concurs W/Proposed Approach to Develop Plan to Conduct One Thorough Review Each Yr
ML20040B181
Person / Time
Issue date: 12/10/1981
From: Palladino N
NRC COMMISSION (OCM)
To: Mark J
Advisory Committee on Reactor Safeguards
References
NUDOCS 8201250245
Download: ML20040B181 (2)


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December 10, 1981 CHAIRMAN e

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Dear Dr. Mark:

Your letter of October 20 on the ACRS's several annual reviews of the RES l

program highlights a concern over the amount of time and effort that both the ACRS and the RES staff expend on the reviews.

RES has estimated that it expends on the order of 150 to 300 man weeks per year preparing for,

. participating in, and doing follow-up analysis for the ACRS reviews of its j

program and budget.

Your letter clearly expresses concern for the amount of ACRS time also spent in these reviews.

We share with you a desire to i

significantly reduce the time spent on these reviews, while at the same time not reducing the benefit that we and the Congress rcceive from the ACRS input and guidance to our research program.

We agree that ACRS should not have to perform three separate reviews each year. We concur with your proposed approach to develop a plan in which the Comittee would conduct only one thorough review each year, with i

possibly the need for some updating by RES to keep yca abreast of im-portM t changes. We agree with your recomendations regarding the report to the Commission on the RES budget request and the preparation of a com-prehensive report to the Congress in February of each year.

However, we believe that in view of the timing of the annual report to Congress on the Research program, it would also benefit the Comission, Congress and the RES staff if this review included consideration of the Long Range Research Plan (LRRP).

It is our intention that the annual development and refinement of the LRRP constitute the foundation for the planning of our research program.

Preparation of the LRRP permits us to lay out directions of the research program for the coming years and to obtain user office endorsement of these program directions. At this time, the research programs are in the fonnative stage and are more amenable to guidance and advice than at any 2

other stage. The planning effort can benefit from the perspective of a group of experts in nuclear safety problems who are in intimate contact

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with the current regulatory challenges. A thorough review by ACRS at this stage should provide all of the background and material needed to R

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2 December 10, 1981 allow the fulfillment of your obligations to the Congress and would be sufficient to provide my fellow Commissioners and me the benefit of your advice for our review of the RES budget in the summer.

Normally, the plan would be available for your review in December with sufficient time for you to hold subcommittee meetings in January.

The report for the Congress could also include an update of any changes (mostly deletions) to the program for the budget year being considered by the Congress that may have occurred as a result of the NRC-internal and OMB budget review process.

The LRRP for 1983-1987 (NUREG-0740) was the first attempt at preparing a plan under the current criteria.

(Five-year plans were prepared in 1976 and 1977.) RES has received constructive criticism on that plan; the next version, which is now being prepared, will have the benefit of that advice.

We expect that it will include more detailed program descriptions, discussion of need and expected use of results.

Thus, we concur with the ACRS recommendations contained in your letter of October 20, 1981 with the exception that an ACRS review of the LRRP 5e in-cluded in the comprehensive review of the research program which forms the basis for your annual report to Congress.

This would give us the benefit of your advice at the earliest and most productive stage and, we believe, result in the most efficient use of your and our RES staff time.

Commissioner Ahearne agrees to the ACRS reducing their level of budget re-view, but would have preferred to retain some level of ACRS review and comment on the more significant items.

The report to Congress is on the budget submitted to Congress.

This review does not duplicate the report to the Counission on the budget being considered for future submittal.

However, given the nature of the Long Range Research Plan, he agrees to relieving ACRS of their review of the Long Range Research Plan.

Please let us know if you have any additional thoughts on this matter.

Sincerely, i

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I Nunzio J. Palladino L

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g WASHINGTON, D. C. 20555 k '.. *,d October 20, 1981 Honorable Nunzio J. Palladino Chaiman U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

ACRS REVIEW AND REPORTS ON SAFETY RESEARCH PROGRAMS

Dear Dr. Palladino:

Since 1977, the ACRS has been required by the Congress to report to it an-nually on the NRC Safety Research Program. This report is prepared each year, after 0MB has transmitted the budget request to the Congress in November, and is submitted in February before the appropriate Congres-sional committees complete their recommendations on the authorization bill.

Since 1979, we have provided a report to the Commission on the research pro-gram and its budget, usually just before the EDO budget goes to the Commis-sion for final action in July. This report has been similar in scope to the Report to Congress, although the original request from the Commission was for comments on the budget rather than a complete review of the safety research program.

In 1981, we prepared a report to the Commission on the draft Long Range Re-search Plan (LRRP). This report was in the fom of a letter rather than the format of the other two reports noted above. This report, too, was re-quested by the Commission, and existing procedures call for similar reviews and reports on the yearly updates of the LRRP.

We believe that our reviews of the safety research program in general, and of individual areas and projects, have been useful to both us and the RES Staff. We believe that the Staff has been responsive in large part to our comments and recommendations.

However, we do not believe that the benefits from our reviews and reports justify the expenditure of resources by the ACRS, its Staff and consult-ants, and by the RES Staff, that has been required to make three Separate f

l reviews each year and prepare three separate reports. We understand that

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Mr. Minogue agrees with this evaluation.

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Honorable Nunzio J. Palladino October 20, 1981 We propose to ameliorate this situation, without reducing the extent or ef-fectiveness of our review of the program and our interaction with the RES Staff, by the following procedures:

Report to Congress.

We will continue to prepare this report, as before.

It will be relatively long and relatively comprehensive, and will provide comments on the nature, scope and effectiveness of the program as well as on needs and proposed funding levels.

This report will continue to be avail-able in February, and thus can be used by the RES Staff as a basis for its update of the LRRP and its preparation of the next budget cycle.

Report to the Commission.

If requested, we will, of course, provide comments or advice tc the Commission on the RES budget request or on specific portions of the safety research program or on funding levels in detail or in general.

However, we prefer not to provide evaluations and comments of the kind and scope already included in the Report to Congress. Such a report to the Commis-sion would be brief and in letter form.

Long Range Research Plan.

.1e first LRRP developed was little more than a five-year projection of current programs and current needs, and provided little to review in addition to the reviews we had already made of ongoing programs and those planned for the next one or two years.

We believe, there-fore, that reviewing the LRRP would not be an effective use of our time un-less a more meaningful plan is developed.

We would be pleased to have your comments on these proposed changes in pro-cedures, and we will be willing to discuss them with you and the Commissioners at your convenience.

Sincerely, J. Carson Mark Chainnan

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