ML20137L640
| ML20137L640 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/1997 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Rogers K, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20137L491 | List: |
| References | |
| COMSECY-96-066, COMSECY-96-66, DSI-22, FACA, SECY-96-066-C, SECY-96-66-C, NUDOCS 9704070278 | |
| Download: ML20137L640 (3) | |
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4'#ge%'o UNITED STATES I
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o NUCLEAR REGULATORY COMMISSIO@ RELEASED TO THE PT' h
- l g W ASHIN GTON, D.C. 20555 . ,
k . . . . . ,o/ oate in d
- OFFICE OF THE COMMISSIONER February 5, 1997 ,
I MEMORANDUM T0: Chairman Jackson i Commissioner Rogers j Commissioner Dicus i Commissioner Diaz FROM: Edward McGaffigan, Jr. kJ jf
SUBJECT:
COMSECY-96-066 - DSI 22 - RESEARCH Having reviewed this paper and stakenolder comments. I would recommend several changes in the Commission's preliminary vjews (a combination of Options 4, 5.
6 and 7).
Let me start with two comments on the paper. It is striking that the bias in this paper is toward devoting fewer resources to the research program. Aside from the sizing option the Commission chose in its preliminary views (Option 4), all the other sizing options (Options 1-3) contemplated an even smaller research effort than the already sharply curtailed effort. Second. there are many issues left to be resolved in future Commission aapers that one might ;
have hoped to decide in the context of this Japer. Tlat these issues were not i mature enough to resolve probably reflects t1e degree to which the research i program has been destabilized as a result of being a budgetary bill-payer for i the agency in recent years. ]
I believe that it is important for the NRC as a knowledge-based agency to preserve a strong capability for independent analysis of safety issues in support of the agency's licensing and regu'3 tory processes. I support Option 4 (as compared to Options 1. 2, and 3) to the extent it is an Endorsement of budgetary stability for the research program at its current much reduced level. To the extent the Commission decides to devote additional resources to other needs as a result of other DSI papers, I would urge that research be put off-limit.s as the source for those resources. 4 I do not like the term " exploratory" research to describe the part of the research effort that addresses anticipated needs of the Program Offices. I would concur with the comments of the Advisory Committee on Nuclear Waste (ACNW) that we should term such research " anticipatory research". I would also agree with ACNW that the agency can not afford purely exploratory research, unconnected to a mission need. This is more than a minor name change. In my view, the users in the Program Offices need to be as involved in describing their mission needs for anticipatory research as they are for 9704070270 970403 PDR NRCSA I 22 PDR
O t . ,
j( 2 confirmatory research. User need has to drive both components of the program.
.If there is not a user sponsor for an anticipatory research effort in a a Program Office, there should be a real question as to whether. such a research
, effort is a luxury in tight budget times.
i j Several stakeholders commented that confirmatory research is s)onsored by both
- the Office of Research (RES) and Program Offices. I believe tlat the agency ,
would be better served if research were concentrated in RES, but with a Users" 2 Board representing the Program Offices (primarily NRR, NMSS and AE00) advising
- the Director of Research on research priorities, including defining core L research capabilities (Option 5), and evaluating the results of research projects from a users' perspective. Establishment of a Users' Board would i also facilitate a focus on programs with the highest safety and regulatory
- significance, as recommended Dy Commissioner Rogers and the Chairman. My
- assumption is that there will be far more uscr needs for confirnatory and
- anticipatory research than dollars to fund those needs. Therefore, it is vital that Program Office users have a major role in setting priorities. If they have that role. there may be less reluctance to concentrating research
. , rescurces in tSe Office of Research.
I I also believe. that it is time to move all rulemaking activities back to the Program Offices which have a clear stake and direct interest in enhancing our i regulations and direct experience with the problems and shortcomings in 4 existing regulations. Both this recommendation and the recommendation that research be concentrated in RES will involve the use of partnership processes.
I would recommend that staff be tasked to carry out such partnership activities and to report back with an implementation plan.
In my memorandum on DSI-2, I recommended that a high-level staff task force be
- set u) to identify issues and make recommendations to the Commission. I would
- note 1ere that the impact on NRC research needs of NRC oversight of Department j
of Energy (DOE) nuclear facilities may well have been overlooked by the DOE
._ Working Grou). So I would recommend that,the staff task force be directed to
! identify suc1 impacts and advise the Commission on the resource implications e of those impacts.
I do not support Option 6, to continue the Educational Grant Program. I agree entirely that universities can and should carry out a significant component of
- the overall research program, both anticipatory and confirmatory research.
Indeed, a strong case can be made to enhance the university role in areas such j- as thermal-hydraulics. But such research would normally be carried out
- through the use of contracts with specified deliverables rather than through
! grants. Grants lend themselves to truly exoloratory research, a luxury I i
believe we can not afford, It is telling that the paper says. "NRC may
- benefit from the results of such grants, but no more than any other public party."
If the Commission decides to maintain this program, I would recommend that J staff be given the flexibility to make awards of up to $250.000 per year
] (rather than the current $50,000 per two years) and that the grant i
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. . l announcement be targeted to very specific user needs for anticipatory research. This would result in a small number of grants aimed at agency needs to the extent the grant mechanism allows. ;
I support the Commission's preliminary views in support of Option 7. in particular the need for international research activities to be prioritized and integrated with the overall research program. The Users' Board should have as large a role in prioritizing and evaluating the international cooperative programs as they do on purely NRC efforts. i i
I'believe that we need to address the negative stakeholder comments on the i openness of our research program. I would recommend that staff be directed to
, come up with options to insure greater access to our research program, at all l phases from priority setting to evaluating research results. !
Finally. on the issue of cooperative research with other agencies and industry. I believe the staff should explore opportunities to gain greater insight into research supported by other U.S. entities and to participate in cooperative efforts where doing so would meet NRC needs consistent with the i limiting factors (legal requirements independence and public aerception) ;
mentioned by the Chairman. In the codes and standards area. NRC effectively i
leverages industry's and other agencies' resources while preserving its independence and right to impose additional requirements where public health ,
and safety so demand. That may be the model for research cooperation as well. ;
- In summary. I support Options 4. 5. and 7. subject to the numerous l l clarifications and additional comments provided above.
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