ML20149M693

an Analysis of Resource Requirements for High-Level Waste Licensing Support Sys

ML20149M693
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Issue date:	05/31/1989
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! AN ANALYSIS OF THE RESOURCE REQUTREMENTS j FOR THE HIGH-LEVEL WASTE LICENSING i

! SUPPORT SYSTEM i

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l Prepared by the Omce of the Controller Division of Budget and Analysis May 1989

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o 9 I. EXECUTIVE

SUMMARY

This study was conducted in response to the February 15, 1989 memorandum from Chairman Zech to the EDO, which requested that the EDO develop, in coordination with Commission staff offices, a

, special analysis of the resources needed by all offices (except the LSS Administrator's Office) to support the LSS. This study focuses on the additional resources needed to support the LSS beyond those

. budgeted for normal licensing document control and processing. The analysis was to lay out the planning assumptions, goals, and objectives that form the basis for requesting added resources.

Under the provisions of the Nuclear Waste Policy Act of 1982, as amended, the NRC is given a very stringent time frame in which to complete its review of the Department of Energy's application for licensing a high-level waste repository. To facilitate that licensing process, an electronic information management system, the Licensing Support System (LSS), is being developed.

The Final Rulemaking on the Licensing Support System for the High-Level Waste Licensing Proceeding (SECY-89-027) which was published April 14, 1989 established the procedures that govern the Commission's HLW licensing proceeding, including the use of the LSS for the submission and management of documents in the proceeding.

Under the provisions of the rule, the DOE is responsible for the design and development of the LSS, including the procurement of the computer system necessary to implement the LSS, and the NRC (the LSS Administrator) is responsible for the administration, management, and operation of the LSS.

This study recommends planning estimates to be included in the FY 1990-1994 Five-Year Plan (FYP) pending resolution of certain uncertainties associated with implementing the LSS. The study also provides recommendations concerning the goal, program planning assumptions, program objectives, program guidance, program elements, and activit'.as for the LSS to be included in the draft j FYP to be submitted to the Commission by the end of May 1989.

Finally, the study recommends that the NRC LSS Internal Steering ,

Committee be the vehicle for resolving the existing uncertainties. l II. BACKGROUND A. Taskina This study was conducted in response to the February 15, 1989 memorandum from Chairman Zech to the EDO, which provided revised planning guidance for developing the FY 1990-1994 Five-Year Plan (FYP) . That memorandum includes i

the following direction:

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i "The Commission requests that the EDO develop, in j coordination with Commission staff offices, a special

analysis of the resources needed by all offices (except j the LSS Administrator's Office) to support the LSS. The .

3 analysis should lay out the planning assumptions, goals,

• I and objectives that form the basis for requesting added i

resources. The Commission realizes there are still many unknowns in connection with the LSS, but believes that .

j . it is time that we incorporate our best estimates into l both the Plan and our next budget request to the OMB."

l B. DAckaround on LSS Under the provisions of the Nuclear Waste Policy Act of j 1982, as amencied, the NRC is given a very stringent time i frame in which to complete its review of the Department )

of Energy's application for licensing a high-level waste '

l repository. To facilitate that licensing process, an l electronic information management system, the Licensing j Support System (LSS), is being deve. loped.

{ The LSS is intended to provide for the entry of, and i accass to, potentially relevant licensing information as i early as practicable before DOE submits the license

} application for the repository to the-Commission. Thi l LSS will contain the documentary material, generated by j DOE, NRC, and other parties to the licensing proceeding,

nich is relevast to licensing of the repository. It is

planned for all anticipated major parties to have access i to this system well before the puceeding begins. Access j to these documents will be provided through an electronic j full-text search capability. This provides the i flexibility of searching on any word or word combinations l within a doc;unent, and thus facilitates the rapid l identification of relevant documents and issues. Because j the relevant information will be readily available through access to the LSS, the initial time-consuming l discovery process, including the physical production and  !

on-site review of documents by parties to the HLW licensing proceeding, will be substantially reduced.

The Final Rulemaking on the Licensing Support System for the High-Level Waste Licensing Proceeding (SECY-89-027) which was published April 14, 1989 establishes the procedures that govern the Commission's HLW licensing proceeding, including the use of the LSS for the submission and management of documents in the proceeding.

Under the provisions of the rule, the DOE is responsible '

ior the design and deve" 3pment of the LSS, including the pneurement of the compu r system necessary to implement the LSS, and the NRC (the LSS Administrator) is responsible for the administration, management, and operation cf the LSS.

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! C. Scone of Study I

) This study addresses the resource requirements necessary for all offices (excent the LSS Administrator's Office) to implement NRC responsibilities under 10 CFR Parts 2.1000-2.1013. In summary, these parts of the regulation i require the NRC to fulfill two different roles. First,

! as the LSS Administrator, the NRC must operate and 4 .

maintain the LSS once the system is developed by the DOE. -

l This entails a number of tasks specified in the rule. '

j Second, as an LSS participant, the NRC must provide

specified documentary material to the LSS Administrator  !

for entry into the LSS; dMignate an individual to administer its LSS responsibilities as an LSS i i participant, which are delineated in the rule. The full l text of these portions of the regulation is included in l

, Appendix D. The study excludes consideration of the resources required by the LSS Administrator's Office, i i consistent with Attachment 1 to the Chairman's February '

15, 1989 memorandum to the EDO. It is our understanding  ;

i that the Chairman's Office will develop an estimate for l the LSS Administrator's Office which will be reviewed by j the LSS Administrator, approved by the Commission, and '

incorporated into the FY 1990-1994 FYP. This study also ,

t excludes consideration of resources associated with j licensing the HLW Repository which are ngji required to r 3 support the LSS (i.e, resources required in connection  !

with the HTM repository licensing proceeding in the l l absence of ut LSS) . Such resource requirements will be

j. addressed as part of the normal FYP process.

i l D. Anoroach to Study As a prelude to this study, Staff from the Controller's Division of Budget and Analysis (OC/DBA) reviewed

{ appropriate backctround documentation, including those j documents listed in Appendix C. Following that review, the DBA staff met with members of the NRC LSS Internal i

Steering Committee to discuss the approach to be taken i in conducting this study, including defining the scope

! of the study, and determining the responsibilities of the i NRC as an LSS Participant. At subsequent meetings with ,

office representatives, DBA was provided with estimates of the additional resources required by each 7ffice to support the LSS and the specific activides to be accomplishe.1 with the requested resources. After reviewing that information, DBA developed a draft of this '

paper which was provided to members of the NRC LSS Internal Steering Committee for their review. The Committee concurs with the recommandations in this report.

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E. Assumntions Under1vina Study i

3 1. The NRC will fulfill all of its respor.sibilities I

under 10 CFR Part 2, with respect to its roles as j , both the LSS Administrator and an LSS Participant.

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. 2. Nominal support from the normal support offices (e.g., ADM and OC) will be available to those t

offices participating in the LSS development and 4 operation (including the LSS Administrator's Office) l without additional resources.

l 3. Responsibilities of the LSS Administrator's Office i will be as defined in the draft NRC Manual Chapter i attached to chairman Zech's March 6,1989 memorandum j (COMLZ-89-8).

! 4. The Licensing Support System (LSS) for the high-j level waste repository will be operational in the l FY 1992-1993 time frame.

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5. DOE shall be responsible for the design, development and procurement of computer hardware and software for the implementation of the Licensing Support j System.

III. OPEN ITEMS REQUIRING RESOLUTION i

i The following open items which are being addressed by the LSS

! Steering Committee must be resolved before detailed resource

' estimates can be made for each NRC office involved in the implementation of 10 CFR Part 2, Subpart J. (The following

! list is not necessarily exhaustive.)

1 l 1. 10 CFR 2.1003 requires the NRC, as an LSS Participant, l to submit specified documentary material to the LSS

! Administrator (LSSA) for entry into the LSS.

l l a. What volume of nag material by year and by office j . will be submitted?

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b. What volume of backloaaed material by year and by j office will be submitted?

l c. What are the protocols for submission of such data?

i For example, will all material funnel through one NRC office to the LSSA? Will all information be in electronic form (including bibliographic headers)?

Will such material be input via te2xinal at the point of creation?

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d. What ADP hardware and software is required for NRC

offices to interface as participants providing input

! to the LSS? Which office will budget for, procure, 1

and install such equipment?

I 2. 10 CFR 2.1004 requires NRC, as an LSS Participant, to 4 "make reasonable efforts to verify that the document has been entered correctly", to notify the LSSA of any errors l in entry.

a. Which office within the NRC will accomplish this

function (a single office or each office originating

j. material)?

b. What constitutes " reasonable efforts" (i.e., will j that require 100% verification or some sampling)?

! 3. 10 CFR 2.1007 requires the NRC to provide terminals for

access to the LSS at the headquarters PDR, at NRC LPDRs

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in the vicinity of the site, and at the NRC Regional offices.

a. What ADP hardware and software is required for this function and when will it be required?

b. Which office will budget for, procure, and install such equipment?

c. Which office will operate the equipment or assist the public in operating the 6quipment?

4. 10 CFR 2.1009 requires the NRC to designate an official who will be responsible for administration of its responsibilities as an LSS Participant, specifically: (1) establish procedures to implement the requirements in 10 CFR 2.1003, (2) provide training to the NRC staff on the procedures for implementation of LSS responsibilities, and (3) cooperate with the advisory review process established pursuant to 10 CFR 2.1011(a).

a. Which NRC office will serve that function?

b. What are the specific responsibilities of that cffice vis-a-vis the LSS Administrator and the other NRC offices?

5. 10 CFR 2.1011 requires the establishment of an LSS Advisory Review Panel on which the NRC will be represented.

a. The chairman of the LSS Steering Committee will be the NRC representative.

b. What is the workload associated with such representation?

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j 6. 10 CFR 2.1011 delineates certain responsibilities for the LSS Administrator (LSSA).

a. What assistance, if any, will the LSSA require from

, NRC offices in executing LSSA responsibilities?

I j 7. In execution of NRC's responsibilities as a participant i l in the HLW repository licensing process, the NRC staff will require access to the LSS data base.

a. What ADP hardware and software is required for j accessing the LSS data base.

b. Which office will budget for, procure, and install l, such equipment?

f 8. What are the total agency administrative resources needed -

to support licensing the HLW Repository including those which would be necessary even without the LSS?

IV. RECOMMENDATIONS FOR FY 1990-1994 FYP A. LSS Goal. Plannina Assuuntions. Procram Obiectives.

Procram Guidance. Proaram Elements, and Activities Appendix A delineates the recommended text to be included in the draft FY 1990-1994 FYP which is to be submitted to the commission at the end of May 1989. This information will be '

included in the Licensing Support System Program within the High-Level Nuclear Waste Regulation Mission Area. These .

recommendations will require revision after the Commission  !

reacts to tM separate submission by the LSS Administrator,  ;

and after ths open items noted in Section III are resolved. '

B. LSS Resources Until the open items are resolved as discussed in section III, the offices which identified requirements can not provide workload projections with any 3egree of certainty. Appendix B provides the resource requirements provided by each organization. This study therefore recommends planning estimates to be included in the FY 1990-1994 Five-Year Plan (FYP) pending resolution of the uncertainties associated with implementing the LSS. Once those uncertainties are resolved, it will be necessary to revise the resources shown in the table below, and to provide a resource allocation by office.

The resource estimates shown below are in addition to any resources currently shown in the FYP and at this time the planning numbers are not proposed as funding for any specific organization. It is intended as a planning baseline from which the revised resource allocation will be developed following the resolution of the open items.

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k RESOURCES REQUIRED TO SUPPORT TH3 LSS'

j. (Dollars are in thousands;-staff are in FTE)

j. FY 1990 FY 1991 FY 1992 FY 1993 FY 1994

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Program Support $ 1,000 $ 2,000 $ 2,000 $ 2,000 $ 2,000 l (Staff) (5) (5) (5) (5) (5) l '

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These estimates exclude resources required by the LSS Administrator's office. Such estimates will be provided I

separately by that office, after appointment of the LSS

! Administrator. These estimates also exclude any resources l associated with licensing the HLW Repository which are not i required to support the LSS (i.e., resources required in j

connection with the HLW repository licensing proceeding in the l

absence of an LSS) . Such resource estimates will be addressed as part of the normal FYP process. Based on their current understanding of 10 CFR Part 2 requirements, ASIAP, ASLBP, and GPA have indicated that they will not require additional resources (beyond those shown in other portions of the FYP) specifically to support the LSS. t 1

C. Resolution of Onen Itama l As noted in SECY-89-027, the NRC LSS Internal Steering l Committee (LSSISC) has begun to address the open items outlined in Section III as well as (1) the identification and prioritization of the LSS design and development issues that need to be addressed with the DGE; (2) the identification and prioritization of the issues that need to be addressed for implementation of the LSS within the NRC, including the delineation of the role of the LSS Administrator vis-a-vis the Steering Committee and the affected NRC Offices; (3) the preparation of a draft Memorandum of Understanding hatween the NRC and the DOE that would delineate the responsibilities of the respective agencies with regard to the LSS; (4) the preparation of a draft charter for the LSS Advisory Committee; and (5) proposed amendments to the topical guidelines contained in the Federal Reaister Notice for 10 CFR Part 2, Subpart J. The Chairman of the Steering committee will submit quarterly progress reports to the Chairman on the resolution of these issues. In addition, individual documents will be submitted to the Commission for approval as appropriate.

V. APPENDICES Appendix A - Recommended FYP Text Appendix B - Offica Developed Requirements Appendix C - Reference Documents List Appendix D - Extract of 10 CFR Part 2 LSS STUDY 7 5/25/89

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l Appendix A I

RECOMMENDED GOAL, PLANNING ASSUMPTIONS, PROGRAM OBJECTIVES, PROGRAM GUIDANCE, PROGRAM ELEMENTS, AND ACTIVITIES FOR THE HLW LICENSING SUPPORT SYSTEM PROGRAM LSS Procram Goal '

Facilitate the high-quality and efficient review of the Department of Energy high-level waste repository license application within the schedule mandated by the Nuclear Waste Policy Act of 1982, as amended, by:

eliminating the most burdensome and time-consuming aspect i of the current system of initial document discovery --

i.e., the physical production of documents after the license application has been filed by providing for the identification and submission of discoverable documents '

before the license application is submitted; minimizing the numerous FOIA requests for the same information that both the DOE and the NRC will surely i receive before and after the application is filed; enabling the comprehensive and early technical review of i the millions of pages of relevant licensing material by the DOE and the NRC staff, through the provision of electronic full text search capability which will allow the quick ident'ification of relevant documents and issues; enabling the comprehensive and early review of the millions of pages of relevant licensing material by the potential parties to the proceeding, so as to permit the earlier submission of better focused contentions resulting in a substantial saving of time during the proceeding; and providing for the electronic transmission of all filings during the hearing, thereby eliminating a significant i amount of delay. l

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O i-O Appendix A i-l LSS Procram Plannine Assumntions

1. The LSS Administrator will be appointed by the Chairman by June 30, 1989.

2. The Department of Energy's Licensing Support System (LSS) for the high-level waste repository will be operational in the FY

! 1992-1993 time frame. Documents will be prepared for entry l well before this date.

l LSS Procram Obiectives and Guidancg i

1. Ensure that the Licensing Support System (LSS) functions effectively to meet the requirements in 10 CFR Part 2, Subpart

}' J, related to the use of the LSS in the Commission's high-level waste licensing proceeding.

a. The LSS Administrator (LSSA) will advise the Department '

of Energy (DOE) on the design, development, testing, and any necessary redesign of the LSS.

b. The - LSSA will establish the LSS Advisory Review Panel within 60 days after designation of the LSS Administrator by the Commission, and will obtain advice from that group regarding the design, development, and operation cf the LSS.

c. The LSSA will consult with the NRC LSS Internal Steering Committee on the design, development, and operation of the LSS from the perspective of the LSS's effect on internal NRC activities.

d. The LSSA will manage and administer the LSS operation and maintenance to include: (1) providing for the entry of documentary material into the LSS; (2) maintaining the integrity and the security of the LSS data base; and (3) providing for LSS access by the LSS participants and by the public as appropriate.

e. The LSSA will evaluate the compliance of LSS participants with the applicable LSS rules.

2. Ensure that the NRC, as an LSS participant, fulfills the responsibilities of such participants as defined in 10 CFR Part 2, Subpart J.

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Appendix A i

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! a. The NRC will provide for early preparation of documents

!- for submittal and will submit appropriate documentary

. material to the LSSA as required by 10 CFR 2.1003.

l b. The NRC will verify that documentary material submitted j . by it has been entered correctly, and shall take l appropriate corrective action when required. i I c. The NRC will designate an official responsible for l administration of its LSS responsibilities (as an LSS

! participant), vill establish procedures to implement the

! requirements in 10 CFR 2.1003, will provide training to j its staff on the procedures for implementation of LSS responsibilities, will ensure that all documents carry the submitter's unique identification number, and will l cooperate with the advisory review process established

by the LSS Administrator pursuant to 10 CFR 2.1011(e).

i d. NRC offices involved as participants in the HLW F repository licensing process will designate members to

the NRC LSS Internal Steering Committee as a means of j consultation with the LSSA on the design, development, l and operation of the LSS.

I a. The NRC will provide public access to information as ,

j specified in 10 CFR 2.1007.

i j 3. The NRC will establish a Pre-License Application Licensing -

Board to rule on all petitions for access to the Licensing i support System. The Board will be designated six months before access to the Licensing Support System is scheduled to j be available.

I LSS Procram Elements and Activities

1. Licensina SuoDort System Administrator (LSSA) l

a. 'Ihe LSSA will monitor progress by the Department of l Energy (DOE) in designing and developing the LSS, and will advise the DOE regarding the design, testing, any necessary redesign of the LSS. (Program Guidance 1.a)

b. The LSSA will establish the LSS Advisory Review Panel by August 30, 1989, and will obtain advise from that group regarding the design, development, and operation of the LSS.- (Program Guidance 1.b) 3 m

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Appendix A i .

I c. The LSSA will consult with the NRC LSS Internal Steering l Committee on the design, development, and operation of l l .the LSS from the perspective of the LSS's effect on j internal NRC activities. (Program Guidance 1.c) i

d. The LSSA will budget for and manage the necessary

personnel, materials, and services required for proper l operation and maintenance of the LSS, including: (1) establishing the necessary protocols for entry of data j into the LSS and for access to data within the LSS; (2) l receiving and entering the documentary material specified ,

{ in 10 CFR 2.1003 into the LSS; (3) establishing and  !

l maintaining an effective quality assurance program prior  :

! to and during the operation of the LSS; (4) establishing and maintaining the necessary security requirements to protect the LOS data base; and (5) providing training, and other assistance to LSS users for accessing the LSS.

(Program Guidance 1.d.) i

e. The LSSA w H 1 continuously monitor the compliance of LSS Participants with the applicable LSS rules, and will provide advice to them on implementation of their LSS ,

responsibilities. The LSSA will evaluate the extent of the DOE's compliance with the provisions of 10 CFR 2.1003 at six month intervals with the first evaluation beginning December 31, 1989. (Program Guidance 1.e)

2. Other Offices' Licensina Suenort System Activities

a. The NRC will submit appropriate documentary material to the LSSA as required by 10 CFR 2.1003. (Program Guidance 2.a)

b. The NRC will verify that documentary material submitted by them has been entered correctly, and shall take appropriate corrective action when required. (Program Guidance 2.b)

c. The NRC will designate an official responsible for administration of its LSS responsibilities as an LSS participant, will establish procedures to implement the requirements in 10 CFR 2.1003, will provide training to its staff on the procedures for implementation of LSS responsibilities, will ensure that all documents carry the submitter's unique identification number, and will cooperate with the advisory review process established by the LSS Administrator pursuant to 10 CFR 2.1011(e) .

(Program Guidance 2.c) 4

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Appendix A 4

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. d. NRC offices involved as participants in the HLW I repository licensing process will designate members to the NRC LSS Internal Steering Committee as a means of

, consultation with the LSSA on the design, development, and operation of the LSS. (Program Guidance 2.d) j e. Six months before access to the Licensing Support System 1 is scheduled to be available, the NRC will establish a i Pre-License Application Licensing Board to rule on all

! petitions for access to the Licensing Support System.

(Program Guidance 3) l 1

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4 RESOURCES REQUIRED TO SUPPORT THE LSS AS IDENTIFIED BY ORGANIZATION (Dollars are in Thousands; Staff are in FTE)

J FY 1990 FY 1991 FY 1992 FY 1993 Fi 1994 i IBM Program Support $1,000 $2,000 $2,000 $2,000 $2,000 (Staff) (4) (5) (5) (5) (5)

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! Program Support $ 0 $ 0 $ 0 $ 0 $ 0 l (Staff) (1) (1) (1) (1) (1) l 1

} .QGC I

Program Support $ 3 $ 3 $ 3 $ 3 $ 3 i (Staff) (1) (1) (1) (1) (1)

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EEE Program Support $ 0 $ 0 $ 0 $ 0 $ 0 I (Staff) (.2) (.2) (.2) (.2) ( 2) )

I SECY $ 0 $ 0 $ 0 $ 0 $ 0 Program Support (0) (1) (2) (4) (4)

(Staff)

TOTAL (Excludes the LSSA)

Program Support $1,003 $2,003 $2,003 $2,003 $2,003 l (Staff) (6.2) (8.2) (9.2) (11.2) (11.2) i i

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l Appendix C i

REFERENCE DOCUMENTS FOR THIS STUDY 1

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1. February 15, 1989 Memorandum from Lando W. Zech, Jr. to Victor

Stallo, Jr.,

Subject:

Revised Planning Guidance

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2. SECY-89-027, dated January 30, 1989,

Subject:

Final Rulemaking on the Licensing Support System for the High-Level Waste

! Licensing Proceeding i

3. COMLZ-89-8, dated March 6, 1989,

Subject:

Office of the

Licensing Support System (LSS) Administrator l 4. March 14, 1989 Memorandum from F.X. Cameron to LSS Internal 4

Steering Committee,

Subject:

March 22, 1989 Committee Meeting j 5. April 7, 1989 SRM,

Subject:

Staff Requirements -

Affirmation / Discussion and Vote, 3

30 P.M., Thursday, March

30, 1989, Commissioners' Conference Room, One White Flint North, Rockville, Maryland I

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