ML20247L789
| ML20247L789 | |
| Person / Time | |
|---|---|
| Issue date: | 02/25/1998 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| DSI-22, SECY-97-220-C, SECY-98-030, SECY-98-030-01, SECY-98-030-R, SECY-98-30, SECY-98-30-1, SECY-98-30-R, NUDOCS 9805260074 | |
| Download: ML20247L789 (62) | |
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POLICY ISSUE (Notation Vote)
FebmaN 25.1998 SECY-98-030 ER8:
The Commissioners FROM L. Joseph Callan Executive Director for Operations
SUBJECT:
IMPLEMENTATION OF DSI 22 RESEARCH PURPOSE:.
To respond to the Commission's direction on DSI 22 activities contained in the SRM on SECY 97-220, dated December 5,1997 (Attachment 1).
BACKGRO_U@
Following Commission review of the direction setting issue (DSI) paper for research, DSI 22, and consideration of stakeholder comments, COMSECY-96-066 was issued on March 28,1997.
This SRM contained the Commissions decision on actions to be initiated related to DSI 22. The staffs response to this SRM was conthed in SECY-97-167 which discussed the staffs proposed plan to implement the Comrr.;ssion decision. The SRM on SECY-97-167 was issued on September 16,1997, which contained direction to the staff related to DSI 22 implementation issues. The staffs response to issues contained in the earlier SRMs was contained in SECY-97-220, dated September 30,1997 (Attachment 2). That SECY contained the staffs proposed plan to transfer rulemaking resources and responsibilities to the program offices and discussed responses to questions related to the staffs plans for activities to implement DSI 22.
The Commission in SRM dated December 5,1997, approved the proposed plan discussed in SECY-97-220 subject to six specific comments.
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Contact:
NOTE: TO BE MADE PUBLICLY AVAILABLE Malcolm Knapp, RES WHEN THE FINAL SRM IS MADE AVAILABLE 301-415-6641 h-qf
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l DISCUSSION:
l The staff's responses to the six comments contained in the December 5,1997, SRM are l
discussed below:
- 1. "The staff should clearly define the scope of activities meeting the definition of confirmatory research as defined in SECY-97-167. Technical activities meeting this definition, but not being transferred to RES, should be identified and the reasons for not transferring the activities should be provided."
Offices used the definition in SECY-97-167 as the basis to determine what is and is not confirmatory research. The definition is:
" Activities which (1) develop new methods or new data, (2) develop new computer programs, (3) modify / existing methods by adopting new rnodels or approaches or scientific data, (4) evaluate / validate existing methods or (5) extend the frontiers of understanding of a given area, are research" In applying item 4 of this definition the staff has not considered the evaluation of a licensee's methods as research work, but rather as a program office function. Accordingly, no work of this type has been identified as confirmatory research.
A number of activities in the program offices, meeting the definition of confirmatory research, were identified as candidates and were evaluated for transfer to RES. These activities, their evaluation and their recommended disposition are listed in Attachment 3. Those that are recommended for transfer to RES would result in 1.4 FTE and 487K of FY 1998 appropriated contract funds being transferred to RES (corresponding FY1999 resources to be transferred will be identified as part of the FY2000 Program-Based Budget Review (PB9R) due to the Commission in July 1998). In adddon, some funding from DOE to support the Russian regulatory authority (GAN) review of the core conversion of three Russian production reactors would be allocated to RES once received from DOE, and the lead for this activity would be transferred from NRR to RES.
- 2. "The staff should provide recommendations on the Generic Safety issues Program and the consolidation of highly specialized expertise to the Com:nission. As with the Rulemaking Activity Plan in the rulemaking area, there should be a mechanit,m in place to set priorities and scheduling for generic safety issues and to past that information to the Commission for review."
Generic Safety issue (GSI) Proaram The GSI Program involves responsibilities and activities for NRR, NMSS, and RES. SECY 001, dated January 2,1998, described recent actions that were initiated to ensure that the respective roles of each office are understood and that close coordination is practiced to eliminate duplication of effort and to have one agency-wide tracking system for GSis.
j
3 The GSI program includes six steps. The first step is identification of the GSI. The second step is prioritization, an evaluation of the safety significance and cost / benefit associated with the issue. The third step is resolution. During this step, the evaluat!on of the issue continues and a solution is identified. In the final stage of the resolution step, the generic evaluation of the options, including appropriate cost-benefit considerations, is completed. At this point in the process. the lead office shifts from RES to NRR. The fourth step is imposition. This step is j
taken by the program office since it involves regulatory actions such as rulemaking or issuance l
of a generic communication. The fifth step is implementation by the licensees who implement the solution to the issue. The sixth step is verification. During this step, the staff verifies that the solution has been implemented by licensees. This step may include a number of different activities including inspections. Attachment 4 provides an additional discussion of the GSI Program.
The staff's recommendation for the GSI Program is that the current responsibilities and process be maintained. RES would continue to prioritize reactor related GSis and evaluate, through the conduct of research, reactor and materials GSIs, as necessary, except those involving high level waste issues. NRR would continue to impose and verify implementation of the resolution of reactor related GSis. NMSS would continue to prioritize, resolve, impose, and verify implementation of non-reactor related GSis.
A related issue involves the Generic issue Management Control System (GIMCS). Currently, RES coordinates inputs from the program offices and updates this tracking system each quarter.
The current GSI Program includes a mechanism to prioritize GSis. Based on the prioritization step, GSis are categorized as "high," medium," low," or " drop." Resources are expended on GSis in accorda 1ce with this categorization. This process is described in detail in NUREG 0933.
Additionally, schedules, activities and milestones for GSis are included in GIMCS. The GIMCS update process focuses attention on the status of GSIs. Updates are provided to the EDO.
RES will revise the update process to include sending a summary of activities related to open GSis to the Commission on an annual schedule. Responsibility for this system could be transferred to the Office of Administration, as was the case for the Rulemaking Action Plan, or the responsibility could remain with RES. The staff recommends that responsibility for updating GIMCS based upon input from the program offices remain with RES as discussed in SECY,
001.
i Consolidation of Exoertise Regarding the consolidation of highly specialized expertise in one office, the staff notes the initial statement of the issue in DSI 22:
"Should the overlap in some technical disciplines (e.g. thermal-hydraulic and severe I
accident analysis, mechanical engineering, PRA, and human factors) continue to exist between RES and the program offices to provide " office-dedica.ted" expertise or should these be partially or completely merged to maintain a critical mass as a result of decreased resources?"
In the September 16,1997 SRM, the Commission directed the staff to provide a discussion of the advantages and disadvantages of their recommendation to the Commission for consideration. In SECY-97-220, the staff proposed to provide the
- 1..
4 Commission with a general discussion of the advantages and disadvantages of consolidation.
The staff found the primary advantages associated with consolidation are as follows:
Having a group of individuals with similar expertise as compared with one or two experts. When working in a group, individuals could specialize further, increasing the breadth and depth of the group's competence. A group with a number of similarly skilled staff can be more robust against loss of skill or corporate memory than one or two individuals. A group of experts can also l
be more able to respond to simultaneous short-term demands than one or l
two individuals. The group's supervisor may have the opportunity to improve quality by having products peer-reviewed intemally. Depending on the size of the group, it may constitute an entire section or branch. It might, therefore, have a supervisor or manager who can fully support the group's technical needs, and may be trained in the group's area of expertise.
Consolidating work could improve the efficiency and quality of the agency's i
efforts by bringing developers and users closer together and maintaining agency expertise by keeping a nucleus of staff interacting and sharing ideas.
Consolidating work could also result in consolidating contractor support by reducing the number of separate contracts and/or bringing more work in-house.
The staff also identified a number of disadvantages associated with consolidation of specialized expertise in a single office. The primary disadvantages associated with consolidation are as follows:
Decrease in the efficiency of the organization beyond the consolidated group.
For example, the office giving up its expertise to the consolidated group would need to arrange to obtain the group's technical assistance across office lines, which could be less efficient than managing the technical work directly. The office managing the consolidated group also faces additional challenges, such as planning and budgeting to support the needs of another office.
Consolidation would generally result in the receiving office performing work that is currently the formal responsibility of the contributing office.
Technical expertise is needed as an integral part of many activities within an individual office. For example, technical expertise is required in NRR to support timely decisions needed for operating plants, to resolve plant restart issues, to assess allegations and 2.206 petitions, and to respond to inquiries from Congress. Similarly, RES needs technical expertise to perform and manage research and technical contract management on a day-to-day basis.
The results of consolidation could impact these needed staff capabilities in the individual offices,
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e 5
The different functions and responsibilities of the offices could cause conflicts in the priority and attention assigned by the receiving office to the work being performed for another office. For example, extra effort to ensure key office milestones are achieved could temporarily divert resources away from activities that are not mainstream office functions. This has the potential to impact work being done for another office.
The staff identified and evaluated six technical areas as possible candidates for consolidation within a single office. These areas are:
Thermal-Hydraulic,' Fuels, and Severe Accident Analysis Review of Vendor Thermal-Hydraulic and Fuels Codes
)
Performance of High-Bumup Fuels l
Earth Sciences Human Factors Participation in High Level Committees within ASME and Other Standards Developing Organizations The staff found that each of these candidate areas was subject to one or more of the advantages and disadvantages documented above. On balance, the staff could not conclude that the advantages of consolidation outweigh the disadvantages, and thus no consolidation is recommended to be undertaken at this time.
- 3. "With regard to the lack of resources to carry out all the rulemakings currently underway, the staff should identify in the Rulemaking Activity Plan (RAP) which rulemakings will be delayed or eliminated to permit the Commission to concur with or amend the proposals as necessary. The RAP should become an effective mechanism for setting priorities for application of limited resources in the program offices. High priority rulemaking activities (such as the Part 35 revision and the regulatory guide for the license termination rule) should not be adversely impacted by the transition."
The program offices will identify rulemakings which will be delayed or eliminated during the next update to the Rulemaking Activity Plan to permit the Commission to concur with or amend the proposed changes.
- 4. "While the Office of Administration (ADM) will be designated the responsible organization for rulemaking infrastructure, the function of preparing OMB clearances for specific rulemakings should be retained by the program offices. In addition,
6 updating the Rulemaking Activity Plan will be a compiling function for ADM. the responsibility for proposing priorities remains with the Directors of the program onices."
The staff discussions related to implementation of OSI 22 will implement this direction. Each o# ice will work with ADM to ensure that the information necessary to update the Rulemaking Activity Plan is accurate and timely. The EDO will monitor this item to ensure a smooth transition of this function.
- 5. "The staff should forward the information on the staff core capabilities in response to the SRM on SECY-97-075 by the end of January,1998."
RES is working to provide information on core capabilities. This SECY will be provided by the end of March 1998.
l
- 6. "The transfer of rulemaking functions, staff and funding to the program offices should be complete by the end of February,1998."
The staff has and will continue to make the transfer of rulemaking functions, staff and funding, in order to initiate this transfer, some staff involved in rulemaking have been detailed to the appropriate program o# ices and other actions to address j
administrative aspects of the transfer of rulemaking functions are underway.
COORDINATION.
l The ONice of the General Counsel has reviewed this paper and has no legal objections. The ONice of the Chief Financial Officer has reviewed this paper for resource implications and has no objections. The ONice of the Chief Information Officer has reviewed this paper for information technology and information management implications and concurs in it. The Office of Human Resources and the Office of Administration concurin the recommendations of this paper.
RECOMMENDATIONS j
The Commission approve:
(1)
The transfer of confirmatory research work from the Program Offices to RES (Attachment 3),
(2)
There be no consolidation of expertise, I
l (3)
The current GSI Program and process be maintained without reassignment of responsibilities, and i
(4)
Annual reports summarizing the status and ongoing activities related to open i
GSis be forwarded to the Commission beginning with the first report in June 1998.
l 7
Note that the transfers of confirmatory research will be discursed with the Agency i
l LMPC and will be completed one month after completion of these discussions.
L. Jysehh Callan ExectMe Director for Operations Attachments:
- 1. SRM on SECY 97-220 dated December 5,1997 l
- 2. SECY-97-220, dated September 30,1997
- 3. Transfer of Confirmatory Research Activities
- 4. GSI Program Commissioners' completed vote sheets / comments should be provided directly l
to the Office of the Secretary by COB Friday, March 13, 1998.
Commission Staff Office comments, if any, should be submitted to the l
Commissioners NLT March 6, 1998, with an information copy to the Office of the Secretary.
If the paper is of such c nature that it requires additional l
review and comment, the Commissioners and the Secretariat should be apprised I
of when comments may be expected.
DISTRIBUTION:
Commissioners OGC OCAA DIG OPA OCA l
L
O ATTACHMENT 1 STAFF REQUIREMENTS COMSECY-96-066 - RESEARCH (DSI 22)
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MARCH 28,1997 l
ATTACHMENT 1
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WASHINGTON D C 20556
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December 5. 1997 04'C E 05 TwE SECAfTaav MEMORANDUM TO:
L. Joseph Callan Exe ti;/e Director f or Operations FROM:
Jo C.
o e
Secretary
SUBJECT:
STAFF REQUIREMENTS - SECY-97-220 -
IMPLEMENTATION OF DSI 22 RESEARCH l
i The Commission has approved the staff's plans to transfer the j
rulemaking resources and responsibilities to the program offices l
as described in SECY-97-220 and subject to the following I
comments.
1.
The staff should clearly define the scope of activities meeting the definition of confirmatory research as definedh-f in SECY-97-167.
Technical activities meeting this L
definition, but not being transferred to RES should be identified and the reasons for not transferring the i
activities should be provided.
1 (ED0r) (RES)
(SECY Suspense:
12fM/9-74 970025 12/24/97 2.
The staff should provide recommendations on the Generic Safety Issues Program and the. consolidation of highly specialized expertise to the Commission.
As with the Rulemaking Activity Plan in the rulemaking area, there i
should be a mechanism in place to set priorities and scheduling for generic safety issues and to pass that information to the Commission for review.
(SECY Suspense:
12 /-34 / 9-7-)
970024 12/24/97 3.
With regard to the lack of resources to carry out all the rulemakings currently underway, the staff should identify in the Rulemaking Activity Plan (RAP) which rulemakings will be delayed or eliminated to permit the Commission to concur with or amend the proposals as necessary.
The RAP should become an effective mechanism for setting priorities for application of limited resources in the program offices.
High priority rulemaking activities (such as the Part 35 revision and the regulatory guide for the license termination rule) should not be adversely impacted by the SECY NOTE:
THIS SRM, SECY-97-220, AND THE COMMISSION VOTING RECORD CONTAINING THE VOTE SHEETS OF ALL COMMISSIONERS NILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS SRM.
e transition.
ISGG)
(RES)
(SECY Suspense:
Next update of RAF) 95000Il While the Office of Administration (ADM) will be designated 4.
the responsible organization for rulemaking infrastructure, the function of preparing OMB clearances for specific In rulemakings should be retained by the program offices.
addition, updating the Rulemaking Activity Plan will be a compiling function for ADM.
The responsibility for proposing priorities remains with the Directors of the program offices.
The staff should forward the information on staff core 5.
capabilities in response to the SRM on SECY-97-075 by the end of January, 1998.
(BDG) (RES)
(SECY Suspense:
1-/-M/S&)
960007 1/23/98 The transfer of rulemaking functions, staff and funding to 6,
the program offices should be complete by the end of February, 1998.
(see)
(RES)
(SECY Suspense:
2/27/98) 970033 cc:
Chairman Jackson Commissioner Dicus' Commissioner Diaz Commissioner McGaffigan OGC CIO CFO OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
ATTACHMENT 2 y-.y 4
5 o,,
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POLICY ISSUE SECY-97-220 September 30, 1997 (Notation Vote)
FOR:
The Commissioners FROM:
L. Joseph Callan Executive Director for Operations
SUBJECT:
IMPLEMENTATION OF DSI 22 RESEARCH PURPOSE:
To respond to the Commission's direction on DSI 22 contained in SRMs dated March 28, 1997 (Attachment 1) and September 16,1997 (Attachment 2), regarding implementation of the Commission's decision on DSI 22, and to request Commission approval of the staffs proposed implementation plan.
1 BACKGROUND:
The staff responded to the Commission's March SRM on DSI 22, *Research," in SECY 167, "DSI 22 Implementation", in which it advised the Commission of its plan and schedule for implementing that DSI. In turn, the Commission provided further guidance to the staff in an SRM dated September 16,1997. In the two SRMs the Commission provided the staff wrth direction on a number of matters including the following (in the order in which they appear in the SRMs):
The staff should develop an integrated set of recommendations for Commission consideration addressing the key questions raised in the DSI 22 paper. (March SRM) 1 l
CONTACT:
F. A. Costanzi, RES Phone: (301) 4154 250 SECY NOTE:
TO BE MADE PUBLICLY AVAILABLE WHEN THE FINAL SRM IS MADE AVAILABLE.
l l
l 1
l l
The Commissioners
- The preparation and coordination of rulemaking should be expeditiously transferred
+
from RES to the program offices. Where RES develops the technical bases for a particular rule, whether by confirmatory research or technical review, RES should provide technical guidance to the program office which has the lead and primary responsibility for the rulemaking (including associated Re0ulatory Guides). (March l
and September SRMs)
Most confirmatory research activities now in the program office' should move to RES.
s (March and September SRMs)
The program office (s) should determine the need for RES concurrence on rulemaking matters based on the degree of technical guidance provided by RES in each case.
(September SRM)
The Commission disagreed with the proposal that RES include provision for short term technical assistance in its research contracts to assist the program offices in the performance of " technical studies," in that it should be the responsibility of the program offices to adequately plan for such situations. (September SRM)
The staff should propose a responsible organization such as the Office of the General Counsel or the Office of Administration to be responsible for the rulemaking infrastructure. (September SRM)
The staff proposed the consolidation of certain highly specialized technical expertise l
into one office to assure maintenance of a "cntical mass" of knowledge. The Commission questioned this approach. Tt.e staff should provide a discussion of the advantages and disadvantages of their recommendation to the Commission for consideration. (September SRM)
With regard to the Generic Safety Issue program, the staff should follow an approach
(
such that when the research and analyses on an issue have been completed and a l
resolution approach has been developed, implementation of the action to resolve the l
issue, wheth;r i+ involves rulemaking, issuing a generic letter, or other regu.. tory action, will be performed a y the program office. (September SRM) 1 The staff's proposed plans to respond to the above and the implementation plan follow.
l DISCUSSION:
Recommendations on the ouestions referenced in the March 28.1997 SRM.
l contains responses to the questions referenced in the March SRM. Ten of the l
fourteen questions are answered directly. The remaining four will be answered as a part of i
the staff's response to the Commission's SRM on SECY-97-075 on core capabilities, which is scheduled to go to the Commission on January 30,1998.
i l
The Commissioners -
Transfer of rulemakina responsibilities to the procram offices.
The Commission directed that the staff expeditiously transfer all rulemaking functions and l
responsibilities to the program offices. The Commission further directed in the September l
SRM that in those instances where RES develops the technical bases for a particular rule.
that it provide technical guidance to the responsible program office.
The staff will transfer all rulemaking responsibility from RES to the program offices and will revise the Rulemaking Activity Plan accordingly. A list of rulemakings contained in the Rulemaking Activity Plan marked to indicate the program office that will conduct the l
rulemakings is presented in Attachment 4. Attachment 4 also contains a list of regulatory guides that accompany or are planned to accompany the rulemakings. Responsibility and resources for developing the technical bases for these regulatory guides will remain in RES.
The RES resources shown in Attachment 4 are those budgeted for these efforts in FY 98 and FY 99, including both FTE and program support funds. The budgeted resources were not established to complete all of the listed rulemakings. Rather, they constituted a " level of effort" for rulemaking activity that foresaw completion of approximately one rule for every two staff years-of effort. Staff notes that RES resources budgeted for certain rulemakings were eliminated as a part of recent budget cuts. Program offices will evaluate the resources and workload associated with the transfer of rulemaking. The Commission will be advised of the impacts on the rulemaking schedules.
Resources will be transferred to the program offices as follows. Program support funds will be transferred consistent with the footnotes to the table in the Resources" section. RES staff will be provided to the program offices consistent with the FTE budgeted in RES.
Recognizing that more FTE are budgeted in FY 98 than in FY 99, permanent staff transfers will correspond to the FY 99 FTE budget. The additional FTE budgeted in FY 98 will be provided to the program offices using details that and at the end of FY 98.
Transfer of confirmatory research from the oroaram offices to RES.
In the March and September SRMR the Commission directed that most confirmatory research activities that had been ongoing and planned within NRR, NMSS, and AEOD ' e conducted by RES.
The program offices have examined t!.e technical activities conducted in their respective offices, and have identified activities that are potential candidates for transfer to RES. These candidate activities are listed in Attachment 5 along with the program office's recommendation for disposition. The. program offices will continue to evaluate their ongoing programs and provide final recommendations for transfer to RES in conjunction with recommendations addressing the questions of consolidation of technical expertise and the program for dealing with generic safety issues. The staff proposes to return to the Commission in November with its recommendations on what activities should be transferred to RES in the context of these three issues; transfer of most confirmatory research, consolidation of highly specialized expertise, and the Generic Safety issues program.
l
The Commissioners -
Procram Office determination of the need for RES concurrence in the September SRM, the Commission directed that the program office (s) should determine the need for RES concurrence on rulemaking matters based on the degree of technical guidance provided by RES in each case. This direction will be implemented immediately.
Short term technical assistance.
In the September SRM, the Commission disagreed with the proposal that RES include provisions for short term technical assistance in its research contracts to assist the program offices in the performance of technical studies"in that it should be the responsibility of the program offices to adequately plan for such situations.
The staff underst ads the Commission's concem. Staff will not make provisions in the RES contracts tnat could have the effect of providing RES resources to supplement the " technical studies" performed by the program offices.
Transfer of the rulemakina infrastructure
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in the September SRM the Commission directed the staff to propose an organization to be respotisible for the rulemaking infrastructure, and suggested the Offne of the General Counsel (OGC) or the Office of Administration (ADM). This function consists largely of maintaining the NRC's rulemaking INTERNET web site, updating the Rulemaking Activity Plan twice yedy, and through contract support, periodically updating the agency guidance on performing regulatory analyses and cost benefit analyses. The staff believes that these functions are rpore administrative than technical or legal, and notes that ADM is already responsible for the publication of agency rulemakings. After discussions with both OGC and ADM, staff recommends that the responsibility for this function be transferred to ADM.
The resources that have been expended by RES for rulemaking infrastructure and oversight and that will be transferred to ADM are identified in Attachment 4.
Consolidation of 5ichly specialized expertise.
One of the key questions in the JSI 22 paper' referenced in the March and September SRMs raised the issue of office-dedicated expertise vs. the synergy that could result from consolidation of staff to maintain a entical mass in light of decreased resources. In the September SRM, the Commission directed the staff to provide a discussion of the advantages and disadvantages of their recommendation to the Commission for consideration, by October 17,1997. In response to this direction, the staff proposes to retum to the l
Commission by that date with a general discussion of the advantages and disadvantages of consolidation.
'See Attachment 3, Question 4
I~~
The Commissioners Staff proposes to retum to the Commission with its recommendations conceming l
consolidation of specific areas of technical expertise in November. As discussed earlier, these recommendation would be made in the context of three issues; transfer of most confirmatory research, consolidation of highly specialized expertise, and the Generic Safety issues program.
Generic Safety issue oroaram With regard to the Generic Safety Issue program, the September SRM directed the staff to follow an approach such that when the research and analysis on an issue have been completed and a resolution approach has been developed, implementation of the action to resolve the issue, whether it involves rulemaking, issuance of a generic letter, or other regulatory action will be performed by the program office.
The approach for resolution of generic safety issues will be revised to more clearly define office responsibilities. RES will be responsible for prioritization and resolution of generic safety issues including research and analyses. The responsibility for implementing the resolution will be the responsibility of the program offices. As discussed earlier (transfer of confirmatory research from the program offices to RES), the staff proposes to retum to the
~
Commission in November with an approach to implement the direction in the September SRM that ensures that, as such issues continue to arise, sufficient resources are allocated within RES to enable it to conduct necessary research and analyses and to develop a l
suitable approach to resolution of the issues.
j l
implementation olans and imoscts.
Implementation plans will be discussed with representatives of the National Treasury Employees Union (NTEU) as appropriate following the Commission's decision. The staff will move as expeditiously as possible to effect the transfer of rulemaking functions and has l
targeted the transfer (including the transfer of dollars and reassignment of staff resources) to be effective within 120 days of the Commission decision. The physical relocation of the staff will likely take longer. Steps to be taken in this process appear in Attachment 6.
Staff also notes that for RES and the program offices to continue to operate efficiently following the transfer of rulemaking, the need for new organizational structures wit 6n RES l
and the program offices must be considered. Also, sevetal RES staff who may be proposed l
to be transferred to the program offices have multiple rule naking and research activities.
l Therefore, as responsibilities and staff are transferred, sons rulemakings and research j
activities will be reassigned. The reassignments will likely adversely affect several rulemaking schedules, as transferred staff leam new responsibilities. The Commission will be l
l kept informed of changes to the RES and program offices' organizational structure and where the staff reassignments have a scheduler impact on significant rulemakings.
RESOURCES:
There is no budget impact from the actions discussed in this paper, merely a realignment of resources among offices consistent with the realignment of responsibilities among the offices. The following table summarizes the realignment of resources, the details of which
The Commissioners
- are provided in Attachments 4 and 5. The resources shown in this table reflect direct FTE, secretarial support and management supervision, but exclude office wide support. Resource changes associated with office wide support will be addressed as a part of the staffs recommendations on transfer of confirmatory research, consolidation of expertise and the Generic Safety issues program to be provided in November as discussed above.
BUDGETED RESOURCES TO BE TRANSFERRED FY 1998 FY 1999 sK' FTE**
$K*
FTE**
NRR treceipt of rulemaking1
+ 370
+ 9.0
+300
+ 7.0 NRR'"
ltransfer of research) 220
-0.4
-120
-0.1 NRR inet transfer to NRR1
+ 150
+ 8.6 '
+180
+ 6.9 NMss leeceipt of rulemaking)
+ 1395
+ 17.5
+1570
+ 16.5 NMss*** ltransfer of researchl 0
-0.1 0
0 NMss inet transfer to NMssi
+ 1395
+ 17.4
+1570
+ 16.5 ADM treceipt of rulemakingl
+255
+ 3.0
+500
+ 3.0 ADM ltransfer of researchl n/a n/a n/a n/a ADM Inst transfer to ADMI
+ 255
+ 3.0
+500
+ 3.0 AEOD treceipt of rulemaking) n/a n/a n/a n/a AEOD'** ltransfer of researchl 0
0 0
0 AEOD inet transfer to AEOD) 0 0
0 0
REs
[ transfer of rulemaking)
-2020
-29.5 2370 26.5 REs Ireceipt of research)
+ 220
+ 0.5
+186
+ 0.1 REs inet transfer from REsl
-1800
-29.0
-2184 96.4 Does not include utanes and enersts; a taciudes overhead. Note: The W 1995 resources slown stove consuture the total budgeted resources for W 1993 to perform the desagnated activities. The actual resources to be transferred among the omces wSI depend upon the tamung of the transfers of the activities as dermed in the me; pian (s). *** Currem Program Omce Emanates COORDINATION:
The Office of the General Counsel has reviewed this paper and has no legal objection. The Office of the Chief Financial Officer has reviewed this paper for resource implications and has no objections. The Office of the Chief Information Officer has reviewed this paper for information technology and information management implications and concurs in it. The Office of Human Resources and the Office of Administration concur in the recommendations of this paper.
l
The Commissioners
- RECOMMENDATIONS:
That the Commission approve the staffs proposals to:
- 1. Proceed to arrange the transfer of rulemaking resources and responsibilities to the program offices as described above and documented in Attachments 4 and 5.
- 2. Proceed with the transfer of staff and program funds according to the steps shown in.
- 3. Retum to the Commission with recommendations on the transfer of research activities currently in the program officea as discussed above and described in Attachment 5, the advantages and disadvantages of consolidating highly specialized expertise, and the Generic Safety issues program in November.
l
- 4. Retum to the Commission with the staffs views on the key questions in DSl 22 conceming core capabilities as a part of the staff's response to the SRM associated with SECY-97-075, scheduled for January 30,1998.
O h.
L oseph Callan Executive Direct for Operations Attachments:'
- 1. Staff Requirements - COMSECY-96-066 - Research (DSI 22), March 28,1997
- 2. Staff Requirements - SECY-97-167 - DSI 22 Implementation (Role of Research),
September 16,1997
- 3. Questions from DSI 22
- 4. List of Rulemakings and Associated Regulatory Guides
- 5. Candidate Activities for Transfer to RES
- 6. Implementation Str.ps for Transfer of Rulemaking and Research Responsibilities snd Resources
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Commissioners comments or consent should be provided directly to the Office of the Secretary by c.o.b. Thursday. October 16.1997.
Commission staff office comments,if any, should be submitted to the Commissioners NLT October 9.1997. with an information copy to the Office of the Secretary. If the paper is of such a nature that it requires additional review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
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March 28, 1997 M CRETARY MEMORANDiF TO-1..
Joseph Callar.
execi:r :ve ;.: ve cr ' r Op="+-
w k
FROM:
John C. Hoyle, Secretary
SUBJECT:
STAFF REQUIREMENTS - COMSECY-96-066.-
RESEARCH (DSI 22) which should hauestaffshouldcontinuewiththeresearchprogram, include elements of both confirmatory and explorecory research (option 4), balanced in such a way that both current as well as potentially emerging issues are being addressed.
The research program should focus on progrcms with the highest safety an:'
regulatory significance, coupled with the maintenance of the uesca...ty technical capability.
This option permits response to The programmatic needs, as well as anticipation of future needs.
term " exploratory research" which is used to describe that part of the research effort that addresses anticipated needs of the Program offices should be changed to " anticipatory research."
In order to develop the scope of tnese technical capabilities the
@OfficeofResearchshoulddevelopcriteriafordeterminingcore research capabilities for Commission approval prior to going forward.
Therefore, the Commission also approves option 5 in conjunction with option 4.
RES she.*1d develop a set of core research capabilities for the "RC in consultation with the other program offices.
GDGF (RFS)
(SECY Suspense:
6/*/97) 9600073 it is essential hInadditiontothecoreresearchcapabilities, that the NRC, as a knowledge-based organization, monitor the overall technical capabilities of its staff to ensure that the necessary core capabilities are maintained.
The staff should recommend the appropriate office within the agency and provide the estimated resources to perform this function.
To ass ist top agency management, the selected office should create and maintain an agency-wide database that contains an inventory of the e
technical core capabilities of the NRC staff, i
GDG) (OP)
(SECY Suspense:
6/1/97) 9700076 hheCommissionsupportsincreasingthepercentageoftheresearch budget executed by universities, but wants to consider additional approaches to working with universities besides the current Educational Grant Program.
Such approaches might enhance i
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achievement of the goals of the NRC research program and provide l'
additional benefits useful to the NRC.
In keeping with the NRC designation as a Procurement Reinvention Laboratory, RES should coordinate with the Division of Contracts in exploring innovative ways to engage universities in NRC's research program (e.g.,
centracts and purchase through use cf cccperative agreements, orders, or through establishment of research consortia or l
institutes in areas such as FRA).
Grants would be, utilized wherc appropriate meenanism ror acnleving a purpose eney are tne most The staff would havc the flexibility to of the research program.
award grants of up to $100,000 per year.
The staff should develop this approach, including an appropriate higher goal for the percentage of research carried out directly by universities, and submit it for Commi'ssion consideration.
44E49 (RES/Amt)
(SECY Suspense:
6/1/97) 9700077 The staff should continue to support active participation in International Safety Programs (opt _cn 7).
The staff should ensure t. tat these international.activitics and the related programs _are prioritized and appropriately integrated with other NRC research efforts (option 4), and also are properly considered in the establishment and maintenance of core research capabilities (option 5).
All'resea.ch activities should be evaluated by the Office of Research for effectiveness, program of work, structure and budget, accomplishment of stated objectives and should include a sunset provision.
The programmatic review should be coordinated with the Research Effectiveness Review Board or Executive Council, as appropriate.
hThestaffshouldexploretheoptionofperformingcooperative research with both industry, and the DOE, so as to minimize duplicative work - where appropriate.
Legal ramifications, independence, and public perception should be considered when The staff should exploring any cooperative research program.
also examine the feasibility of improving access to research information during.he early phases of the work.
fs90/OGC)
(SECY Suspense:
10/t/97) 9700078 (RES There are many key questions raised in the research DSI paper -
note in particular pages 13, 14 and 18 of the DSI dated September 16, 1996 (pages attached and marked) -- that require much thought to resolve, but whose answers will nave a strong bearing on how the agency will operate in the future.
Implementation of Option 4 should include development of an integrated set of recommendations to be provided for Commission consideration.
-4EDQ4 (RES/NRR/MMSS/AE00)
(SECY Suspense:
8/1/97) 9700079 The Commission has decided that the preparation and coordination of rulemaking should move from RES to the Program Offices, and l
that most confirmatory research activities now in the Program Offices should move to RES.
The staff should develop and submit i
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' g to the Commission an implementation plan, with possible options for carrying out this decision, including the necessary par ~.nership activities.
G GN - (RES/NRR/NMSS/AE00)
(SECY Suspense:
8/1/97) 9700080 In con unction witr its development cf an implementation plan, the staff should consider tne creation of a Research Effectiveness Fev:=w Faerd.
This heard wculd be composed of representatives of tne Program Of: 1ces anc tne Researen Office.
Its purpose would be to advise the Director of Research and the Directors of the Program Offices on the effectiveness of the research programs in meeting the needs of the users and on the effectiveness of the program offices in supporting and in articulating their needs and priorities to the research offices.
The Board would periodically review the bases for initiating, cv...inuing, and terminating speci_^ic research programs giving particular attention to the effectiveness of broad haced long range programs and the capabilities of the staff to address core research needs.
The usefulness and advisability of its continuation should be examined by tae Commission every three years..
(PES /NRR/NMSS/AEOD)
(SECY Suspense:
8/1/97) 9700080
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(hFinally,'thehigh-levelstafftaskforce (set up under DSI-2) should also identify the impact on research needs of NRC oversight of Department of Energy (DOE) nuclear facilities, and advise the Commission on the resource implications of those impacts.
,(NMSS/RES/NRR/AE00/0E) 9700081
Attachment:
As stated cc:
Chairman Jackson Commissioner Rogers Commissioner Dic"s Commissioner Diaz Commissioner McGaffigan CIO CFO OCA 8
0.' G Office Directors, Regions, ACRS, ACNW, ASLBP E. Jordan (SARSC) l J. Silber (SARSC) i 1
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isESEAT.3 f
f DSI 22, In late 1993, Commissioner Rogers presented a paper that had as its central j
theme the importznce of NC's knowledge base to its succe:s as a regulatory In this paper he stated, 'The quality of NRC':, cecisionmaung is
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ultimately dependent epor. :ne agenc) *s a l11t} t&: id:ntify re1evant agency.
technica1' knowledge needed for its regulatory decisior.mai:ing; gain access to that knowledge; and, transfer that knowledge readily into its' regulatory This paper also suggested how the NRC might reorganize to be more l
practice.*
Although, reorganizations are effective in managing this knowledge base.
beyond this phase of the NRC strategic assessment initiative, two principles embedded in Commissioner Rogers' paper are relevant to the evaluation of the These principles are the following:
(1) the NRC l
options presented here. knowledge base requires continuing maintenance and ext l
These two princ.ples staff are the key to maintaining the NRC knowleoge base.
are addressed with the ceasequences under ea-b option.
Organ 12ational questions must ultimately be addressed, however, as the agency i
l looks at how the research program might be implemented more ef ficiently and l
A Comission decision on this DS' is a necessary first step to l
establish a framework within which effectiveness and ef ficiency initiatives ef fictively.
can be properly evaluated.
A key factor affecting effectiveness and efficiency is the role of the i
For example, research office compared with the role of the program offices.
l the Office of Nuclear Regulatory Research (RES) is often asked to assist the program offices in the review of issues to support specific regulatoryThe q l
decisions (technical assistance).
On the other hand, should efforts should be performed by the program oftices.
certain analyses performed by the program offices, such as thermal analysis, be performed only by RES?Should that continue, or should all rule even though all rulemakings de not involve usearch, or.should all rulemakings l
by RES.
l What RES functions, if any, could be be assigned to the program offices?
Sho"'d the perfomed m.re efficien+.ly anet effectively oy the program offices?
l overlap in some technical disciplines (e.g., thermal-hydrau exist between RES add the program offices to provide ' office-dedicated".
expertise, or should t}iese be partially or completely merged to maintain ailha l
critical mass as a result of decreased resoufces?
RES compared with that of program offices in staying i
Budget reductions have been so severe that all HLW research i
Even though activiti3s in RES are under consideration for transfer to 1 concepts?
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I will be explored in a more limited way because of licensing con I
Could the NRC attract and retain top piessures?
program if it were to be decentrall2ed.
D51 22
[
' RELEASE DATE: SEPTEMBER 16, 177C 13-t
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DSI 22 RESEARCH research talent, and would research of a broader / exploratory nature be pursued with the research procram components embedde: ir. iicensing organizations? If not, would that fundamentally impact the ability of the NRC to. fulfill its i
1 health and safety missicn given uncrc the regulatory crograms are today?
?
Would the researcn budget be smaller and more efficient if annaged by the licensing organizations 1 Nou16 the absence of an independent research office F~
result in lower cuality research,. absent a healthy technical debate between RES and licensing organizations over research applications and approaches?
All these questions and others will need to be carefully considered in the next phase of the strategic assessment.
C
'xternal Factors Several external factors significantly affect : 8.C's research program.
External organizations that have an impact on t..<C's research program are the nuclear industry, DOE, universities, international prc; rams, Congrass, and t;.e
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Nuclear Industry past research has provided an understanding and resolution of many of the important safety issues related to the design and operation of reactors.
Nevertheless, operational events, both domestically and internationally, including the possibility of a serious accident, are likely to continue to raise new issues.
In addition, the aging of plants and the introduction of new technologies (such as reactor instrumentation and control and the annealing of pressure v'essels to counter lgin'g effects) will raise new issues.
Financial pressures on industry are al:o likely +.o have a teamber of effects,-
including an increased desire to use risk-5 formed, performance-based approaches to meet safety requirements and the use of higher burn-up fuels.
These same p. assures will :.lso lead.to reductions in budgets for industry-sponsored research organ' ations such as the Electric Power Research Institute. The development of new reactor designs could increase the need for additional resear_ch,;although.'at this, time,. no new designs are expected in t
the foreseeable future. Finally, because NRC's budget is recovered by licensee fees; there is likely to bo increased pressure on the NRC to reduce its budget as a means of reducing licensing fees.
a 2.
Department of Energy, including the National Laboratories l
As D0E's budget is reduced, its support of advanced reactor concepts is being U
reduced, which will reduce the need for NRC research directed at understanding 1
these new designs. In addition, as a result of budget reductions Governraent g
wide, research activities at the national laboratories are being reduced.
This is resulting in a loss of capabilities and limiting the expertise 1
available to the NRC. Further, as non-NRC resea ch activities are reduced, t
RELEASE DATE: SEPTEMBER 16, 1996 14 DSI 22 i
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un 44 RESEARCH i
address some of the unique thermal-hydraulic issues associated with these 2
passive designs. However, work on the pas:iva dasi r i: no :::ing to an end, and the NP.C :Ust agirn Geterair.e the type ano scope of technical capability that need to be enintaiW te @=t: Mth :n;;ir; s; ci: n escrging salety 3
issues related to themal-hydr ::!ic ; ten::.ma. L,is is also;true in varying degrees for other areas of ongoing research (e.g., reactor component materials, severe accidents, earth sciences, PRA, health physics, human l
factors, Pnd instrumentation and control). Because of such factors as the aging of nuclear power plants and the introduction of new technologies, certain program elements should remain strong; in other program elements, major work is being completed in the next year or so. Therefore, the key' question that the NRC needs to address for aP af its rese:rch programs is in i
what specific areas and of what scope does the NRC need to maintain technical capability to address ongoing as well as er..ging issues.
Each area of technical cxpertise could be maintained:
G) in hwse (NRC staff)
(2) through the support of contractors at national laboratories, universities,
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or other appropriate organizations; or (3) by a combination of both in-house and contractor support.
i.
This subsumed issue can be considered a DSI itself, since it encompasses the
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scope 6f the research program and to a large extent its role. Among the questions to be addressed that bear on this issue are the following. Should core capabilities be maintained in some areas, with more robust programs in other areas? What is the right six of in-house staff and contractor capabilities for each core areat Which of the analytical activities currently performed in contractor organizations can and should be performed in house?
Which lower priority research programs should be discontinued, to be initiated again only if a specific need arises? Is this feasible? What types and depths of expertise would the HRC need to ensure the availability of a e
celtical six of skills not only to address ongoing issues, but also to respond to problems that may arise in the future? Exemples of criteria that can be,
used to develop a core progras are listed in Section IV under Option 5.
It.s anticipated that final criteria would be developed for approval by the Commission. After the Commission approved these criteria, RES would develop a arell-defined set of core capabilities.
I 2.
How could NRC's established leadership in safety research domestically g
and in such organizations as NEA and 1AEA be maintained?
This issue is subsumed because NRC's established leadership in safety research is interweven with and dependent on the role and scope of the overall research program. NRC's leadership position could be affected by the elimination, downsizing, er restructuring of its research program. As e
discussed previously, international interest in NRC's research results gives NRC the leverage to participate in many cooperative research programs overseas and to obtain international support for its o,#n research programs.
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,REl. EASE D?.TE: SEPTEMBER 16,106 IS DSI 22
ATTACHMENT 2 STAFF REQUIREMENTS SECY-97-167 - DSI 22 IMPLEMENTATION LROLE OF RESEARCH)
SEPTEMBER 16,1997 e
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- y'aneg,S UNITED STATES p
o,g NUCLEAR REGULATORY COMMISSION O
WASHINGTON, D C. 20555-0001 O
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September 16, 1997 l
l OFFict oF THE l
SECRETARY MEMORANDUM TO:
L. Joseph Callan Executive Director for Operations Karen
. Cyr Gene 1 Co e
l FROM:
Jo oyl,
ecretary
SUBJECT:
ST F REQUIREMENTS - SECY-97-167 - DSI 22 IMPLEMENTATION (ROLE OF THE OFFICE OF RESEARCH)
The Commission directs that the staff expeditiously transfer all rulemaking functions and responsibilities to the program offices.
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Likewise, most confirmatory research activities now in the i
program offices should move to the Office of Research (RES).
I The Commission has disapproved the proposed plan which would retain certain rulemakings i'n RYs.' _Where RES develops the technical bases for a particulaY rul, whether by confirmatory l
researen or technical, review, RES should provide technical guidance to the program office which has the lead and primary responsibility for the rulemaking (including associated i
regulatory guides).
Similarly, the Program Office (s) should determine the need for RES concurrence on rulemaking matters based on the degree of technical guidance provided by RES in each The Con..aission should be informed of progress in this case.
regard in the Septcmber 30, 199l update.
(20.) (RES)
(SECY Suspense:
sfM/M) 9700080 9/23/97 The Commission also disagreed with the proposal that RES inc' ie provisions for short term technical assistance in its research contracts to assist the program offices in the performance of
" technical studies," in that it should be the responsibility of the Program Offices to adequately plan for such situations.
The staff expressed a desire to retain some rulemaking infrastructure in one organization.
The staff should propose a responsible organization, such as the Office of the General l
Counsel or the office of Administration.
SECY NOTE:
THIS SRM AND SECY-97-167 WILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS SRM.
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! The staff also proposed the consolidation of certain highly specialized technical expertise into one office to assure The Commission maintenance of a " critical mass" of knowledge.
questioned this proposal.
The staff should provide a discussion of the advantages and disadvantages of their recommendation to the Commission for consideration.
(SECY Suspense:
10ft7f9'7 )
9700247 I
10/10/97 the staff should With regard to the generic safety issue program, follow an approach such that when the research and analysis on an issue have been completed and a resolutien-approach has been developed, implementation of the action to resolve the issue, whether it involves rulemaking, issuing a generic letter, or l
other regulatory action, will be performed by the program office.
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cc:
Chairman Jackson Commissioner Dieus j
Commiasicner Diaz Commissioner McGaffigan OGC l
t CIO l
CFO j
OCA 1
Office Directern, Regions, ACRS, ACNW, ASLBP (via E-Mai')
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ATTACHMENT 3 QUESTIONS FROM DSI 22 9
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1 A
s QUESTIONS FROM DSI 22 The CJice of Nuclear Regulatory Research (RES) is often asked to assist the program 1
offices in the review of issues to support specific regulatory decisions (technical assistance). (A) The question arises as to whether such efforts should be performed by the program offices. (B) On the other hand, should certain analyses performed by the program offices, such as thermal-hydraulic analysis be performed only by RES?
Answer A:
As stated in SECY 97-167, technical studies which apply existing methods to make regulatory decisions applicable to a specific licensee or group of licensees are not research, and should be performed by program offices.
Answer B:
The staff proposes to respond to this question in November as a part of its recommendations on what activities should be transferred to RES in the context of three issues; transfer of most confirmatory research, consolidation of highly specialized expertise, and the Generic Safety issues program.
2 At present, most rulemakings are managed by RES. Should that continue, or should all rulemakings be assignec to RES, even though all rulemakings do not involve research, or should all rulemakings be assigned to the program offices?
Answer.
The Commission has decided to transfer all RES rulemaking activities to the program offices.
3 What RES functions, if any, could be performed more efficiently and effectively by the program offices?
Answer.
The principal RES functions have been to (1) conduct confirmatory and anticipatory research, (2) manage the rulemaking activity, (3) develop and issue regulatory guides, and (4) manage the NRC generic issue reso!ution program. The Commission has decided that confirmatory and anticipatory research will be conducted in RES and that rulemaking and development of regulatory guides that accompany rulemaking will be done in the program offices. Wrth respect to development of other regulatory guides, because most have a significant research component, staff believes it would be more effective and efficient to retain them in RES. Wdh respect to the Generic Safety issues program, it does not appear to be more efficient or effective to assign them to 1
1 a program office for several reasons. First, because responsibilities for timely licensing actions and responses to events can frequently dominate the attention of a program office, longer term in-depth technical evaluations can suffer. Second, RES l
can consider generic safety issues independently, providing the basis for a healthy exchange of perspectives with the program offices. Third, RES involvement in generic safety issues provides an opportunity for RES staff to be involved in the mainstream of NRC's safety concems. Given this perspective, it appears there is little to be gained by transfemng responsibility for generic safety issues to the program offices.
Should the overlap in some technical disciplines (e.g., thermal-hydraulic and severe-4 accident analysis, mechanical engineering, PRA, and human factors) continue to exist between RES and the program offices to provide " office-dedicated" expertise, or should these be partially or completely merged to mairdh a critical mass as a result of decreased resources?
Answer in the September 16,1997 SRM the Commission directed the staff to provide for the Commission's consideration staffs recommendations for consolidation, and associated advantages and disadvantages, on October 17,1997. The staff proposes to retum to the Commission with a general discussion of the advantages and disadvantages of consolidation on that date. The remainder of this question would be addressed as a part of the staffs recommendations on what activities should be transferred to RES in the context of three issues; transfer of most confirmatory research, consolidation of highly specialized expertise, and the Generic Safety issues program, to be provided to the Commission in November.
What should be the role of RES compared with that of program offices in staying 5
abreast of national and intemational nuclear safety developments, emerging technologies, and design concepts?
Answer it #s essential that both RES and the program offices stay abreast of all of these areas, as their responsibilities apply. As demonstrated by past experience, there are significant efficiencies to be gained by conducting cooperative national and intemational resean... programs. Furthermore the quality of NRC research programs is enhanced by the information flowing from national and intemational activities and the peer review our programs receive through these interactions.
However, important perspective can also be gained from n:tional and intemational developments involving new regulatory and safety issues, e.g. standards being used by other countries in licensing decisions. The program offices need to keep abreast of such developments to be sure that NRC standards and regulatory approaches are benefitting from these perspectives.
2
Given the above, all offices will need to be cctiva in cll arers. How:vsr, it ma appropnate for the program offices to have lead res involving emerging technologies and design concepts. Such a division of responsibihty would appear to be consistent with the Commission's dir 16,1997 SRM on rulemaking and research.
September Budget reductions have been so severe that all H 6
economies, is it possible that research issues will be explored in a more lim because of licensing concems or pressures?
Answer.
Within the constraints of the reduced budgets, the high level waste prog refocused to address the most important technical issues for repository licen l
This ensures that resources are focused on the most significant activities t l
these issues whether they be experimental, analytical, or review of DOE wo Issues are reexamined and renrioritized on a regular basis to ensure that n l
activities are omitted. This approach ensures atte l
explored in a more limited way because of licensing concems or pressures.
Could the NRC attract and retain top research talent, and would research o broader / exploratory nature be pursued with the research program compone 7
l embedded in licensing organizations?
Answer:
Assuming that adequate compensation is provided, the ability to attrac research talent will be primarily affected by the confidence that these scientists will be participating in a stable long-term research program that h
technically challenging and professionally rewarding. Such stable long-term l
programs may be di*ficult to maintain in progra staff and managers. This focus of the program offices on near-term high licensing issues would also make it difficut for resolve significant long-term issues which the NRC will be facing.
1 3
8 if not, would that fundamentally impact the ability of the NRC to fulfillits health and safety mission given where the regulatory programs are today?
Answer:
Either the failure to attract and retain top taleni or to pursue anticipatory research could impact the technical knowledge base needed for effective regulation. In some instances the resulting uncertainties could be mitigated by operating with greater margins. However, given examples such as the aging population of nuclear power plants and the continuing need to understand implications of extended fuel bumup, and human perfonnance issues, information important to NRC safety programs could be reduced if significant erosion of research programs were to occur.
9 Would the research budget be smaller and more efficient if managed by licensing organizations?
Answer it4oes not appear to be generally beneficial in terms of size and efficiency to have the research budget managed by the program offices. There is a potential that a transfer of this function could result in increased efficiency through the more intimate knowledge of the program office activities. Likewise, there is a potential for inefficiency because the program offices focus primarily on their principal activities. It is, of course, important that RES management strive to make research effective and efficient and responsive to program office needs.
Staft notes that the Commission has decxied to transfer to RES most confirmatory research activities now in the program offices. In Attachment 5 the staff proposes which activities might be transferred and which might best remain with the program offices. Therefore, this question also is addressed, as appropriate, as a part of the staff's proposal on each activity.
10 Would the abserve of an independent research office result in lower quality research, absent a health echnical debate between RES and licensing organizations over research applications and approaches?
Answer The DSI 22 issue paper provided the Commission with the option of discontinuing NRC's research program. In the SRM on DSI 22, the Commission directed the staff to retain both confirmatory and anticipatory research, and to transfer most of the confirmatory research in the agency to RES. The staff believes these decisions moot this question.
4
11 Should core capabilities be maintained in some areas, with more robust programs in other areas?
Answer:
Yes. In some cases a core level of resources will be adequa'e. In other areas, workload demands may dictate a more robust program for a period of time. This question will be addressed in more detailin RES' response to the SRM associated l
with SECY-97-075 " Methodology and Criteria for Evaluating Core Research Capabilities." This response is scheduled for January 30,1998.
12 What is the right mix of in-house staff and contractor capabilities for each core area?
Which of the analytical activities currently performed in contractor organizations can and should be performed in house?
Answer.
These questions will also be addressed in RES' response to the SRM associated with SECY-97-075 " Methodology and Criteria for Evaluating Core Research Capabilities,"
referred to in the answer to Question 11 above.
13 (A) Which lower priority research programs should be discontinued, to be initiated again only if a specific need arises? (B) is this feasible?
Answer A:
Any lower priority research activities that should be discontinued will be identified in the RES response to SECY-97-075. Priorities will also be set during the budget process. For example, dunng the intemal review of the FY 1999 budget and in response to the House proposed cuts to tne FY 1998 budget, the severe accident research program was identified as an activity that would be discontinued at certain funding levels.
Answer B:
Reconstituting a research program once it has been discontinued is marginal at best.
The feasibility of restarting ind;.idual programs could vary greatly from program to program. In some cases, experienced staff and potential contractors could be readily available. Altematively, identifying new staff and contractors who are knowledgeable and free of conflict of interest may be difficult. Bringing them on board, training them, 5
l and giving them an opportunity to do enough work to become experts and, further, to Staff recommends that be recognized as experts, may well take five years or more' a decision to' terminate a program generally be considered to be permanent.
l What types and depths of expertise would the NRC need to ensure the availability of l
14 a critical mix of skills not only to address ongoing issues, but also to respond to problems that may arise in the future?
Answer This question will be addressed in RES' response to the SRM associated with SECY-97-075.
This estimate is based on the staff's experience in starting up the Center for 1
Nuclear Waste Regulatery Analyses.
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ATTACHMENT 4 LIST OF RULEMAKlNGS AND ASSOCIATED RESOURCES l
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RULEMAKINGS IN THE l
RULEMAKING ACTIVITY PLAN CATEGORY I ACTIVE RULES - RULES IN DEVELOPMENT' HIGHER PRIORITY:
NRR-C1 HP-11 Codes and Standards for NPP (Part 50.55a)--RM#318-AE26.........
l NRR-C1 HP-21 Reduction in Nuclear Power Reactor Security Requirements Associated With insider Threat (Part 73.55)-RM#405--AF11-W#950117...................
l NMSS-C1HP-22 Safeguards for Spent Nuclear Fuel or High-Level Radioactive Waste, (Parts 60, 72, 73, 75)-RM*346-AF32-W#930128..........................
NMSS-C1HP-24 Requirements for Shipping Packages Used to Transport Vitrified Wastes Containing Plutonium, Part 71 (PRM-71-11)-RM#491-AF59-W#960169...........
NRR-C1HP-26 Amending Initial Operator License Examination Requirements, Part 55--
l R M # 4 8 4-A F 6 2-W# 9 5 00 5 6...........................................
NMSS-C1HP 27 Removal of the 5-Year Term For Licenses For The Medical Use of l
Byproduct Material, Part 35.18-RM#493-AF77.............................
NRR-C1HP-28 Revision to Nuclear Power Reactor Decommissioning Financial Assurance implementation Requirements, Part 50.2 and Part 50.75-RM#424-AF41-W#950112..
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NRR-C1HP-29 Insurance Requirements For Power Reactor Facilities Under a Possession Only License, Part 50-RM#312-AF16--W#930116...........................
i NRR-C1HP-30 General Revisions to the Fitness-For-Duty Rule, Part 26-RM#397-AF12-W # 8 9 004 2......................................................
NMSS-C1 HP-31 Exempt Distribution and Use of a Radioactive Drug Containing Me Microcurie of Carbon 14 Urea, Part 30 and 32, (PRM-35-12) -Rm#432-W#970042 NRR-C1HP 32 Revision of Respiratory Protection Requirements, Part 20-RM#269 W#970194.......................................................
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'The office to which the rulemaking would be transferred appears at the beginning of each item.
The order of presentation is the ordei in which rulemakings entered the rulemaking 8
queue.
1
NRR C1HP-33 Safety Related Structures, Systems and Components (Direct Final Rulemaking), Part 50-RM# 500.........................................
NRR C1HP-34 Allow For Plant Specific Nuclear Power Reactor Decommissioning Costs Requirements, Part 50.75-RM#347-AF40-W#950111 NRR-C1HP-35 Performance-Oriented Requirernents for Fire Protection of Nuclear Power Facilities (Part 50)-RM#340-AF29-W#92019 7.............................
MEDIUM PRIORITY NRR-C1MP-10 Shutdown and Spent Fuel Pool Operations, Part 50-RM#398-AE9 7-VV # 9 20 2 23...............................
NMSS-C1MP-14 Deliberate Misconduct Rule, Parts 30,40,50, 60, 61,70,72,110)-
R M # 4 2 5-AF3 5-W # 9 6000 7...........................................
ADM-C1MP-15 Criteria sr.d Procedures For Determining Eligibility For Access to Restricted Data or National Security Information, Parts 10 -RM#431-AF48 NMSS-C1MP-17 Alternative Financial Criteria For Non-Profit Entities and Alternative Financial Criteria For Non-Bond issuing Licensees-RM#408-W#930212............
NRR C1MP-18 Audit Frequency For Emergency Planning and Security, Part 50, PRM 5 9, PR M-5 0- 6 0-R M # 413.............................................
NRR-C1MP-19' Addition of Radon-222 and Technetium 99 Values to Table S-3 and Revisions Resulting from Consideration of Higher-Burnup Fuel (Part 51)-RM#116-AA31-W # 9 1 0 1 4 6........................................................
NMSS C1MP 21 Revision of Prototype Testing Requirements for Watches Containing Tritium (PRM-32-04), Part 3 2.14-RM# 423.................................
NMS3-C)NP-22 Miscellaneous changes, Part 72-RM#446-W#960162 NRR-C1MP-23 Emergency Planning Requirements For Defueled Reactors and Exercise Requirements For Offsite E-gency Plans, Appendix E and Part 50.54(O), -RM#435 LOWER PRIORITY NMSS-C1LP-05 Revision to 10 CFR Parts 20,32,35,36, and 39 Regarding Minor Administrative Changes, Clarifications, and a Mirsor Policy Change-RM#402-AF46....
IRM-C1LP-17 Submittal procedures For Documents, Parts 19,20',30-36, 39,40, 51,52, 5 5, 60-6 2, 7 0-7 5, 140, 150-RM # 44 5....................................
ADM-C1LP-18 Nuclear Regulatory Commission Acquisition Regulation (48 CFR Chapter 2 0 )- R M # 4 7 5 - A F 5 2.................................................
NMSS-C1LP 19 Notice to Employees; Minor Amendment to Part 19-RM*495......
CATEGORYll RULES FOR WHICH THE TECHNICAL BASES ARE UNDER I
DEVELOPMENT l
l l
HIGHER PRIORITY l
l NMSS-C2HP-04 Criteria For Recycle / Reuse-RM#381.W#940059................
NMSS-C2HP-05 Disposal by Release into Sanitary Sewerage, Part 20-RM#288-AE90-W#940008......................................
NMSS-C2HP-07 Amend Certification of Compliance NO.72-1007 For The VSC-24 Dry Spent Fuel Storage Cask, Part 72.214--RM#390.............................
l l
MEDIUM PRIORITY l
NMSS-C2MP 05 Exemption from Licensing of Certain Products, Parts 30,32-RM*400-l l
W#900208.......................................................
LOWER PRIORITY NONE.........................................................
CATEGOR '111 RULEMAK NG PLAN BEING DEVELOPED l
l i
HIGHER PRIORITY NRR C3HP-07 Skin Dose Limits For Hot Particles-RM#164-W#900178........
NMSS-C3HP-09 Update of Decommissioning Funding Certification Amounts For Applicants and Licensees, Parts 30, 40, 70-RM # 24 3........................
NMSS-C3HP 10 Elimination of 30-Day Delay in Loading Spent Fuel After Preoperational Te sting, Part 7 2.8 2(E)--RM # 433........................................
3
NMSS-C3HP-12 Storage of Greater Than Class C Waste, Part 72-RM*436-W#960157 NMSS-C3HP-13 Energy Compensation Sources For Well Logging, Part 39-RM#440 l
NMSS-C3HP-14 Expand Applicabihty to include Additional Parties, Part 72-RM#439-W # 9 6 01 6 0.......................................................
l 1
NMSS-C3HP-20 Options For The Use of Radiography and Radiographic Equipment and A N SI N 4 3 2, Pa rt 34-R M # 4 77..........................................
NMSS-C3HP-22 Revision of Dose Limit for Members of the Public Exposed to Hospitalized Patients, Part 20 (PRM.20-24)-RM#490-W#960154 NMSS-C3HP-23 Specific Domestic Licenses of Broad Scope For Byproduct Material, Part I
3 3-R M # 44 8 -A F 5 4.................................................
NMSS-C3HP-24 Major Revision of 10 CFR Part 35-RM#497....................
NMSS-C3HP-25 Part 76 Certification Ammendment Process, Part 76.45-RM#499....
MEDIUM PRIORITY NRR-C3MP-01 Fitness for Duty (Scope)--RM#396-AF13 NMSS-C3MP-06 Special Nuclear Material Accountability, Parts 70,74-R M # 3 0 9 -W # 9 6000 7................................................
NMSS-C3MP-12 Clarifications and Addition of Flexibility to Part 72 -
R M
- 4 3 8 -W # 9 6 01 5 9................................................
NMSS-C3MP-13 Geological and Seismological Characteristics of Spent Fuel Storage Systems, Part 72-RM#441-W#960161 NMSS C3MP 14 Adopt.vn of Part 20 Dosimetry Methodology To Part 72-RM#437-W#960158...............................................
NMSS-C3MP-15 Financial Assurance Requirements For Waste Brokers and Sealed Source U se r s -- R M # 4 8 0....................................................
NRR-C3MP-16 Alternative Site Reviews, Part 50-RM#313.....................
NRR-C3MF-18 Staffing and Training Requirements For Defueled reactors, Pa rt 5 0, 5 5-R M # 444................................................
NRR-C3MP-19 Use of Alternate Cladding Material in Reactors, Part 50-RM#449......
4
NMSS-C3MP-21 Financial Assurance For Teletherapy and Krypton-85 LicCnsees Parts 30, 35-RM#482......................................................
NMSS-C3MP-22 Relief From The Use of Part 35 Requirements For Teletherapy Devices For Non-Human irradiation, Part 36-RM#479...............................
NRR-C3MP-23 Exemption From Criticality Monitor Requirements For Fresh Fuel, Part 70.24-RM#494...................................................
l NMSS-C3MP-26 Compatibility with the IAEA Transportation Standards, Part 71-RM#496 l
NRR-C3MP-28 Codes and Standards, Part 50.55a (h)-RM#498..................
I NMSS-C3MP-29 Spent Fuel Shipment Information Protection Requirements, I
Pa n 7 3 - R M # 5 01...................................................
LOWER PRIORITY NMSS-C3LP-01 Clarification of Criteria for Uranium Mills and Tailings, Part 40-RM#380--
VV # 9 4 0 0 7 8.......................................................
NRR-C3Lk05 Removal of Obsolete Appendices M, N,0, and O From Part 50-RM#483.
NRR-C3LP-06 ELIMINATE 10 CFR PART 2, APPENDlX A-RM#489 l
CATEGORY IVA PETITIONS UNDER CONSIDERATION NRR-C4A-02 Acceptability of Plant Performance for Severe Accidents; Scope of Consideration in Safety Regulations, Part 50-RM#268-AE38-W#900201 NMSS-C4A-07 PRM-20-21 Petitioner: Keith J. Schlager, Ph.D., et al.-RM#451......
NRR-C4A-14 PRM-50-62 Petitioner: Nucl ear Energy Institute-RM#459............
NRR C4A 15 PRM-50-63 Petitioner: Peter G. Crane-RM#460..........
NMSS C4A-18 PRM-3513 Petitio;.3r: National Registry of Radiation Protection Technologists (NRR PT)-RM #4 6 3........................................
NMSS-C4A-23 PRM-30 61 Petitioner: Nuclear Energy Institute-RM#468 j
NMSS-C4A-24 PRM 70-07 Petitioner: Nuclear Energy Institute-RM*469...........
5 i
l L_-________
CATEGORYIVB RULES ON HOLD NMSS-C48-01 Requirements for Possession of Industrial Devices Containing Byproduct Material (Parts 31, 32)-RM#81-AD34-W#890090 NMSS-C48-02 Requirements Concerning the Accessible Air Gap for Generally Licensed Devices (Parts 31, 32)-RM#264-AD82-W#900192..........................
NMSS-C4B-04 Revision to Parts 30 and 40, to Address RSO Duties-RM#386........
NRR-C48-09 Rulemaking on Probabilistic Risk Assessment, Part 52-RM#411 NMSS-C4B-10 Addition Of DOE Multi Purpose Canisters, Part 72.214-RM#412......
NMSS-C48-11 Domestic Licensing of Special Nuclear Material-Revision, Part 70 -
RM#351-AF22-W#94010...........................................
NMSS-C4B-13 Conforming 10 CFR Part 60 to EPA Standard and NAS Recommendations-
-RM#430.......................................................
NMSS C4Ei-19 Transfer of Unimportant Quantities of Source or Byproduct Material to Exempt Persons, Part 40.51 -RM#447....................................
NRR-C4B-21 Revise Part 50.34(f) To Apply To Unknown Future Designs-RM#485....
l NRR-C4B-22 Licensing Requirements for Senior Reactor Operators Limited to Fuel H a ndli n g -R M # 4 8 6..................................................
NMSS-C4B-23 General Domestic Licenses For Byproduct Material, Part 31-RM#487...
NRR-C4B-24 Reduction of Additional Reporting Requirements imposed on NRC
'i Licensees (10 CFR 50), RRGR ltem 59a-RM#387-W#940118...................
NMSS-C4B-25 Extremity Dosimetry-RM#146-W#870013.....................
1 6
REGULATORY GUIDES UNDER DEVELOPMENT ACCOMPANYING RULEMAKINGS' Regulatory Guide on license renewal for NPP, Scope of envoirnmental effects... License RenewalRule (completed) l Regulatory Guide on Financial Accounting Standards Board (FASB) standards for decommissioning cost accounting.....NRR-C1HP-28 Revision to Nuclear Power Reactor Decommissioning Financial Assurance implementation Requirements, Part 50.2 and Part l
- 50. 7S-RMN424-AF41-WN950112 l
RG 8.15 (rev) " Acceptable Programs for Respiratory Protection".....NRR-C1HP-32 Revision of Respiratory Protection Requirements, Part 20-RMN269 WN970194 Regulatory Guide on Demonstrating Compliance with the Radiological Criteria for Decommissioning... Decommissioning Rule (completed)
DG-0006 Guide for the Preparation of Applications for Commercial Nuclear Pharmacy Licenses... Radiopharmacy Rulemaking (completed)
DG-0007 Guide for the Preparation of Applications for Licenses to Authorize Distribution of Various items to Commercial Nuclear Pharmacies and Medical Use Licensees... Radiopharmacy Rulemaking (completed)
DG-0009 Proposed supplement to RG 10.8, Rev.2: " Guide for the Preparation of Applications for Medical Use Programs"... Radiopharmacy Rulemaking (completed)
Performance-Oriented Requirements for Fire Protection of Nuclear Power Facilities (10 CFR Part 50)....NRR-C3MP-04 Performance-Oriented Requirements for Fire Protection of Nuclear Power Facilities (Part 50)-RMN340-AF29-WM920197 l
Associated rulemakings are indicated in italics.
8 7
BUDGETED RESOURCES TO BE TRANSFERRED l
I FY 1993 FY 1999 4K*
FTE**
4K' FTE**
NRR - Transferred rulemaking (includeg accompanying regulsary guides) and regulatory guide development resources Reactor rulemaking licensing (direct) 120 5.0 50 4.0 Reactor rulemaking red. prot. (direct)
SO 2.5 80 1.5 170 Reactor Technical Assistance 170 TOTAL DIRECT 370 7.5 300 5.5 1.5 1.5 Management and support TOTAL 370 9.0 300 7.0 NMSS Transferred rulemaking (includeg accompanying regulatory guNies) and regulatory guide development resources
- Materials rulemaking Econsing (direct)
ISO 6.5 80 5.5 Materials rulemaking red. prot. (direct) 75 3.0 350 3.0 370 Meterial Techrucal Assistance 370 Decommissioning rulemaking (direct) 100 5.0 100 5.0 670 Decommissioning technical assistance 670 TOTAL DIRECT 1395 14.5 1570 13.5 3.0 3.0 Management and sups. ort TOTAL 1395 17.5 1570 16.5 ADM - Transferred resources infrastructure and oversight Idirect) 255 3.0 500 3.0 Does se i-h solans and benenes; ** IncE everhed. Nese: The W 1998 reenres shows ebe,e 1
- -a the total budsesed resurcs for W 1998 se perform the damemated activisies. De aromal reemeces to be transiemd essang the offices wiB depend span the sindag of the tressfers of the activities es densed in the im/
pineW.
1 l
8
ATTACHMENT 5 l
CANDIDATE ACTIVITIES FOR
~
TRANSFER TO RES i
i
TECHNICAL ACTMTIES CONSIDERED BY PROGRAM OFFICES AS POTENTIAL CANDIDATES TO RES The program offices have examined the technical activities conducted in their respective offices, and have identified activities that are potential candidates for transfer to RES. These l
c andidate activities are listed in this attachment along with the program office's recommendation for disposition. The program offices will continue to evaluate their ongoing programs and provide final recommendations for transfer to RES in conjunction with recommendations addressing the questions of consolidation of technical expertise and the program for dealing with generic safety issues. The following table summarizes the realignment of resources, the details of which are provided in this Attachment and in l
l.
i BUDGETED RESOURCES TO BE TRANSFERRED FY 1998 FY 1999
$K' FTE"
$K' FTE" trece'pt of rulemaking!
+370
+ 9.0
+ 300
+ 7.0 NRR NRR* "
ltransfer of research)
-220
-0.4 120
-0.1 NRR Inst transfer to NRR)
+ 150
+ 8.6
+180
+ 6.9 NMss treceipt of rulemaking)
+ 1395
+ 17.5
+ 1570
+ 16.5 f
NMsS*" (transfer of research) 0
-0.1 0
0 NMSs (not transfer to NMSS)
+1395
+ 17.4
+ 1570
+16.5 l
ADM treceipt of rulemaking!
+ 255
+ 3.0
+ 500
+ 3.0 ADM ltransfer of research) n/a n/a n/a n/a ADM Inst transfer to ADMI
+ 255
+ 3.0
+ 500
+ 3.0 AEOD treceipt of rulemakingi n/a n/a n/a n/a AEOD*" (transfer of research) 0 0
0 o
- net transfer to AEODI O
O O
o REs
[ transfer of rulemaking!
2020
-29.5 2370 26.5 RES leeceipt of research)
+ 220
+ 0.5
+186
+ 0.1 RES Inst transfer from REsl
-1800 29.0
-2184
-26.4
- Dess met indude nelanes and benefks; " laciudas everhead. Note: The FY 1998 resources shown aheve cemetitute the total budgeted resourtes for FY 1998 to perform the d-g=== d activities The actual resources se h trameterred among the offices we depend upes the tindag of the treasters of the activttass as defined in the 4
-- - plas(s).
- Curruas Progreen Omce 5%===
1 l
l l
1
- E--
OFFICE OF NUCLEAR REACTOR REGULATION In Service Insnaction Relief Raouest Database The purpose of this database is to develop and maintain a comprehensive inventory of relief requests to assist the staff (1) to address ISI requon for relief and alternatives so as to provide more uniform terminology, (2) to maintain the traceability of all data to source reference documents and notes to discussions on each report, and (3) benefit is gained by ease of reference to same or similar requests for relief and/or alternatives.
The database is to be updated every six months based relief requests processed during last period.
Resources-FY98 - $2OK and 0.125 FTE FY99 - $10K and 0.125 FTE Disposition and Rationale Not to be transferred, because the development of this database only involves collection of data regarding licensing documents - and not research. NRR's future reviews and evaluations of reaulatory actions involving licensee's requests for relief and attematives to the ASME Code,Section XI requirements, requires that this information be readily available to NRR staff.
Steam Generator Database The NRC Steam Generator Database (SGD) provides the NRC with the capability of maintaining current information on steam generator materials, inspections, and operating experience in a comprehensive manner. The SGD include chronological informatiori for each plant and inspection report data for SGs since 1991, including licensee and NRC data. The SGD provide the staff with a tool to evaluate and monitor materials aspects for licensing and inspection reviews while minimizing the staff time involved with locating references and data.
Resources:
FY98 - $50K and 0.2 FTE FY99 - $3OK and 0.2 FTE Disposition and Rationale Not to be transferred, because the development of this database only involves collection of licensing documents and references in a database - and not research.
NRR's future reviews and evaluations of regulatory actions involving steam generator performance requires that this information be readily available to NRR staff.
Reactor Vessel Intearity Database The Reactor Vessel Integrity Database (RVID) was developed 'following the Nuclear Regulatory Commission (NRC) staff review of licensee responses to Generic Letter (GL) 2
92-01, Revision 1. The RVID2 summarizes the properties of the reactor vessel beltline l
materials for each operating commercial nuclear power plant. For plants that are not operating, existing data has been maintained;i.e., no existing data for non-operating plants has been deleted. The RVID2 program has references and notes that document the source (s) of data and provide supplementalinformation. Additionally, the RVID2 I
includes sort and data search capabilities. The user can select a desired grouping of plants and then specify information categories to search and list.
The RVID2 program was designed and developed to reflect the current status of l
l reactor pressure vesselintegrity, and the data is consolidated in a convenient and accessible manner. Some of the data categories are inputs of docketed information; other data categories are computed values, which are not necessarily docketed. The programming logic used for calculations in the. RVID2 program follows the methodology in NRC Regulatory Guide 1.99, revision 2.0. (RG1.99r2). The newest Access Version" of the database will be released on the World Wide Web (www) once the data have been updated.
l Resources:
FY98 $10K and 1.0 FTE FY99 - $20K and 0.5 FTE Disposition and Rationale Not to be transferred, because the development of this database only involves collection, evaluation and analysis of licensing data - and not research. NRR' future oviews and evaluations of reaulatory actions involving reactor vessel requires that this information be readily available to NRR staff.
Grid Reliability Technical Studv The subject study provides staff support to the following NRR Action Plan task l
elements from the Grid Reliability Action Plan: (1) Develop technicalinformation to assess and evaluate the risk significance of potential grid instability due to deregulation: (2) Monitor industry deregulation and its impact on the reliability of offsite power to nuclear power plants: develop and implement staff-level contacts with the Federal Energy Regulatory Commission (FERC) and the Department of Energy (DOE):
assist Regional perscr.nel in establishing contacts with power pools and reliabil:
i councils in their area: (3) Development of Gereric communication; and (4) Evaluate, based on Task 1 results, the need for regulatory actions; evaluate method (s) to identify grid-centered event precursors: valuate the impact on deregulation SBO risk reduction goals: assess any requirements and the effectiveness of such requirements and enforcement policies as imposed by the North American Electric Reliability Council.
Resources:
FY98 - $220K and 0.1 FTE (Tasks 1 and 4)
FY99 - $120K and 0.1 FTE Disposition and Rationale Task elements 1 and 4, as mentioned above and in the Grid Reliability Action Pian, may 3
1 l
\\
l
be transferred to RES. Task elements 2 and 3 should remain within NRR to assist EELB in the assessment of licensee compliance with the existing regulations associated with ensuring offsite power to nuclear power plants. Given that the subject technical study is an integral component of the staff's efforts to meet the intent of the Staff Requirements Memorandum (SRM) dated May 27,1997 those commitments associated with the subject SRM should also be transferred to RES with task elements 1 and 4.
i Assessment of Turbine Failure at Vandellos 1 Development of staff NUREG or other publication to document turbine building fire issues for U.S. plants in light of the Vandellos fire.
Resources:
FY98 - $ 0 and 0.3 FTE FY99 - 4 0 and OFTE Disposition and Rationale To be transferred to RES and should be combined with overall fire protection research activities.
Rebaselinino Analyses for implementation of Revised Accident Source Term at Operatino Reactors Using Surry and Grand Gulf as model plants, dose calculations are being run for the spectrum of Design Basis Accidents. The term "rebaselining" comes from the analyses of the plants as currently designed using both the current regime (TID source term, whole body / thyroid dose acceptance criteria, and associated calculational assumptions and methods) and the new regime (NUREG-1465 source term, TEDE dose acceptance criteria, and revised calculational methods). These analyses will allow us to understand the impact of the revised source term before any design changes are made based on the revised source term. DBA dose will then be performed applying the various possible design changes licensees have or may propose based on the revised source term. These analyses will allow the technical reviewers to make sure that all of the calculational methods are develooed that will be needed to review the pilot plant lice.1.4 ig 3 applications. Using se mtormation in NUREG-1150, the impact on riu f;om these potential design changes will also be assessed. Finally, the impact on other "non-dose" design basis safety and licensing analyses from these design changes will be examined.
Resources:
FY98 - $150K and 1.3 FTE FY99 - $0 and 0.7 FTE Disposition and Rationale:
Rebaselining will provide support for the rulemaking and for the pilot plant and follow-on plant licensing reviews. Because it appears that both these activities will be conducted by NRR, NRR should have the lead for this effort. However, RES developed 4
the rsvised courcs t:rm cnd has substtnti:1 expertise and t:chnicil assistence contract connections in this area. For these reasons, RES has always been part of the task l -
force led by NRR for the overall implementation effort. Because of RES's expertise RES needs to take a much more substantial role in the rebaselining effort. The details of that increased role are being discussed now by RES and NRR branch-level l
management.
l DBA Meteorological and Dose Assessment Calculational Ccde Devefooment NRR uses several computer codes to assess the meteorology and offsite and control room doses for DBAs associated with license applications: PAVAN, ARCON, HABIT, and RADTRAD. HABIT was developed by RES. RADTRAD was developed by NRR.
NRR staff still needs training on RADTRAD and help from Sandia will be needed as the NRR staff starts to use the code for actuallicensing cases. ARCON was also developed by NRR. ARCON is finished, and training and help in actuallicensing use will still be needed. PAVAN and other related codes already exist and are being I
updated to ru.. on PCs and use ARCON-like data handling methods.
Resources:
FY98 - $50K and 0.2 FTE FY99 - $O and OFTE Disposition and Rationale:
NRR believes all these activities should remain under NRR; however, RES could be given the lead for the PAVAN and other related meteorological code development since code development is an RES responsibility. (NRR to provide resource split)
NRR Identified cad Transferred Research Resources FY 1998 FY 1999 Identified Transferred identified Transferred
$ in K FTE
$ in K FTE
$ in K FTE
$in K
.TE 500 3.2 220 0.4 180 1.63 120 0.1 l
i 5
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Backaround As a result of severe budget reductions in FY 1996, the HLW Management Board, made up of managers from DWM, RES, and the CNWRA, made recommendations on the l
prioritization and consolidation of ongoing research and technical assistance activities being conducted and planned at the CNWRA in light of the refocused HLW repository program and reduced budget. The Directors of RES and NMSS agreed with the HLW Board's recommendations and noted that the best way to manage the HLW program was to consolidate these activities in NMSS. The decision to consolidate HLW activities in NMSS was approved by the EDO and the Commission was informed (Memoranda dated 2/28/96 and 4/9/96). In the EDO's memorandum to the Commission (dated 2/28/96) it was noted that NRC could no longer afford the costs of running the HLW program between the two offices and still maintain a minimum acceptable level of technical expertise within the Commission and the CNWRA.
As a result of the decision to consolidated HLW activities in NMSS, all activities were grouped by the 10 key technical issues (KTis) most important to repository performance at the Yuc :a Mountain site. Within ev:. KTI, the activities were prioritized and resource limits set consistent with the reduced budget. This resulted in a list of funded and unfunded research and technical assistance activities. Of the eleven research projects, selected tasks from four high priority projects could be supported - three at the CNWRA and one at the University of Arizona. This work was funded as technical assistance specific for the Yucca Mountain site and was managed under the existing KTl structure, that is: 1) igneous activity KTI-probability and consequence studies; 2) near-field environment KTI-effects of engineered components on near-field water chemistry; 3) container life KTI long-term corrosion testing; and 4) radionuclides transport KTI-altemative conceptual models of transport. Subsequently, in FY 1997, CNWRA support for work in two of the KTis, container life and radionuclides transport, was eliminated as a result of continued reduced funding for the repository program. Work at the University of Arizona has been phased out. However, the long-term corrosion testing was continued in order to build on the years of data already collected. The end result of these budget reductions on research activities at the CNWRA was a reduction of approximately 90-95%
in funds -"ocated for these activities and the refocusing of the remaining activities to site-specific applications. h-ther, project management of these activities has been subsumed into the regular duties c. program element managers and represents only a small fraction of their element responsibilities.
The activities identified on the accompanying pages represent a combination of the remnants of the pr3viously described research activities and other DWM/HLW activities that may be considered research. Other activities such as work on models related to developing an implementing rule and work on conceptual models for thermohydrologic processes at Yucca Mountain were considered, but not documented in the accompanying pages because no significant work is expected to occur in FY98. Site-specific activities that are potential candidates for startup in FY96 (e.g., review of DOE's basis for incorporating matrix diffusion into PA calculations) also are not included due to the uncertainty in the appropriations expected from the Nuclear Waste Fund in FY98.
6
Total System Performance Assessment Code Development Joint NRC/CNWRA code enhancement effort has focused on having the licensing tools necessary to perform pre-licensing consultations, develop staff independent review capabilities, and evaluate an eventual license application from the Department of Energy, in FY97, TPA code development has proceeded through the testing and f
/
verification of the TPA 3.1 code. The code was completed and placed into configuration control on or about September 5,1997, and is now being implemented in pre-licensing consultation activities related to confirming those issues related to a l
geologic repository that are most important to demonstrating compliance.
l In FY98, it is expected that TPA 3.1 code development would be largely limited to activities related to determining the contribution that individual components of the repository system make to the isolation of wastes.
N Resources:
FY98 Approx. $75K and 0.05 FTE -
FY99 Approx $75K and 0.05 FTE Disposition and Rationale 3'
Not to be transferred because development (including most testing and verification) is essentially complete and efforts are now largely focused on the analysis of site characterization data, resolving potential licensing issues, and further developing DWM staff's licensing review capability by manipulation of the code. The TPA 3.1 e is being used to develop the staff's independent understanding of the abstraction l b' l
c f site-specific processes in order to prepare a standard review plan and review DOE's test plans, data, and assessments. All efforts are focused on site-specific work for the i
proposed geologic repository at Yucca Mountain, Nevada. Consequently, this technical work provides the tools and understanding the staff will use in its licensing reviews of DOE's program and is not considered to be " confirmatory research." Finally, this disposition is consistent with the EDO's decision (EDO to Commission dated 2/28/96:
EDO to Commissioner Rogers dated 4/9/96) to consolidate HLW activities in NMSS.
Lona-Term Corrosien Stuc4ies Related to Waste Packaos Daaradation Corrosion behavior of waste packages used for disposal of spent nuclear fuel over long time frames (> 1000 yrs) is uncertain. Long-term corrosion experiments have been j
/
ongoing at the CNWRA for a numter of years. The goal of these experiments is to better define the behavior of vario"s metals and alloys (including galvanic coupling) when exposed to Yucca Mountain site related conditions (e.g., J-13 water) for long periods of time.
.s FY98 - $100K and 0.05 FTE j
Resources:
FY99 - $100K and 0.05 FTE Disposition and Rationg}g Not to be transferred because of EDO's decision (EDO to Commission dated j' 7
i 2/28/96: EDO to Commissioner Rogers dated 4/9/96) to consolidate all HLW activities in NMSS so as to maintain a minimum acceptable level of technical expertise within the Commission and the CNWRA. In addition, budget reductions the last two FYs have resulted in most CNWRA work being focused on resolving potential licensing issues and developing staff review capability for the Yucca Mountain site. Although the work could be transferred to research because of the potential for work of this nature to be applied to generic issues related to the evaluation of the long-term behavior of various metals and alloys, activities directed towards generic applications would necessarily have to be funded out of non' Nuclear Waste Fund monies.
Volcanic Analoaue Studies to Define Consequences of Volcanic Events Volcanic analogue studies are being conducted by the CNWRA to aid in determining the eruption dynamics of a volcano that potentially could disrupt the geologic repository at Yucca Mountain in order to provide the technical basis for defining the consequences that would result from such a disruption. Scientists at the CNWRA are examining analogue sites (e.g. active volcanos such as Cerro Negro, Nicaragua) to better define the characteristics of basaltic volcanic events including the energetics of the eruption and the distribution of ash after eruption. The results of these analyses are being factored into risk analyses and are being applied to ongoing HLW performance asses'sment activities. Further the results of these activities have been used in IAEA-funded activities and published in the peer-reviewed literature.
Resources:
FY98 - $40K and 0.05 FTE FY99 - $40K and 0.05 FTE Disposition and Rationale Not to be transferred because of EDO's decision (EDO to Commission dated 2/28/96; EDO to Commissioner Rogers dated 4/9/97) to consolidate all HLW activities in NMSS so as to maintain a minimum acceptable level of technical expertise within the Commission and the CNWRA. In addition, budget reductions the last two FYs have resulted in most CNWRA work being focused on resolving potential licensing issues and developing staff licensing review capability for the Yucca Mountain site. Although worir 5 focused on u-derstnd;ay, site-specific processes for Yucca Mountain, it couM be appised to other, unrelated, nuclear siting a:tivities. Therefore, the CNWRA wo-k is extending the frontiers of understanding in volcanic risk assessment as applied to nuclear facilities. However, any activities directed towards applications other than Yucca Mountain would s.acessarily have to be funded out of non-Nuclear Waste Fund monies.
Studies of Structural Deformation in the Yucca Mountain Area to Define Consequences of i
Faultina Events Studies of structural deformation (fauiting and paleo-seismicity) are being conducted by the CNWRA to develop an independent review capability to assist in risk analyses for seismic hazard and fault displacement hazard for the geologic repository at Yucca Mountain. These studies are designed to provide the technical basis for staff 8
comments on the adequacy of proclosure design of surface facilities at the repository and evaluations of the effects of faulting on repository performance during the postclosure. CNWRA efforts are focused on the evaluation of faulting and seismic events in the Yucca Mountain area. The results of these activities are published in peer-reviewed literature.
Resources:
FY98: Approx. $100K and 0.05 FTE ' 0 FY99: Approx. $100K and 0.05 FTE Disposition and Rationale Not to be transferred because of EDO's decision (EDO to Commission dated 2/28/96: EDO to Commissioner Rogers dated 4/9/96) to consolidate all HLW activities l
[ in NMSS so as to maintain a minimum acceptable level of technical expertise within the
.f Commission and the CNWRA. Further, although some innovative approaches are being applied, all methities are directed at the study of the Yucca Mountain area and. as a result, are site-specific and focused on developing an independent licensing review capability. CNWRA activities in this area are not extending the frontiers of understanding of deformat.on in the Yucca Mountain area, but applying known techniques to assist in understanding site-specific processes in order to prepare a l
standard review plan and to review DOE's test plans, data, and assessments. Finally, because of progress made in the analysis of this key technicalissue, FY98 I
expenditures for this task are being reevaluated as part of the FY98 reprioritization of HLW activities based on the results of planned sensitivity studies.
l Development of a Databama on the Effects of Low Damas of ionizina Radiation and its e
'/
ADolication for Ausssina Radiation Hormesis as a Bioloaical Hvoothesis 1
The Nuclear Regulatory Commission and other relevant Federal agencies are participating in the organization and conduct of workshops designed to assess hormesis as a biological hypothesis, and its potential societal and scientific l
significance. In addition to the Nuclear Regulatory Commission, these Federal agencies include the National Institute of Environmental Health Sciences (NIEHS), Department of Air Force - Office of Scientific Research, Environmental Protection Agency (EPA) -
Office of Research and Development, Food and Drug Administration (FDA) - National Center for Toxicologic Research, Agency for Toxic Substances and Disease Registry (ATSDR), Department of Ene.gy (DOE)- Office of Energy Research, and U.S. Consu.r.ar Product Safety Commission (CPSC). The workshops would be conducted as a Biological Effects of Low-Level Exposures (BELLE) - related activity, administered at the University of Massachusetts, Amherst, under the direction of Edward J. Calabrese, Professor of Toxicology.
l These workshops would be supported by the development and completion of a relational retrieval data base on chemical (University of Texas A&M) and radiation hormesis (Nuclear Regulatory Commission). A workshop advisory committee will be assembled from representatives of DOD, EPA, NIEHS, FDA, ATSDR, DOE and CPSC.
The r ommittee will provide the Principal investigator, Professor Calabrese, with direction on the seriss of workshops with respect to selection of topics and speakers 9
and on the integration of information into the workshops from a companion project dealing with the development of a radiation hormesis data base. Total costs of the q
workshops are:
Resources:
FY98 - $ 0 and 0.05 FTE FY99 - $66K and 0.05 FTE (Unbudgeted) 3 Note: Total NRC contribution $181K NRC (Radiation Hormesis Data Base), $334K by Other Agencies (Organization and Conduct of Workshops)
Disposition and Rationale
/
/
To be transferred, collection, evaluation, and analysis of the relational retrieval data base will be completed in FY99, and integrated into the workshops. FY99 funds have not been allocated; therefore, RES will evaluate the appropriateness of transferring funds from otner sources to provide the identified FY(( funding.
Technical Assistance for Reviewina License Submittats Concemina Decommissioning - l Task Order 04. Modelina of Leach Processes at Decommissioning Sites CNWRA will evaluate and compare the capabilities of fate and transport codes currently used in site decommissioning performance assessment with possible application to SDMP sites. With mineralogic characterization information supplied by RES and in cooperation with RES, CNWRA willidentify possible constraints on input parameter values and identify limitations on general applications. In conjunction with RES, CNWRA will use SDMP leaching information from RES studies to provide constraints on source term parameters for fate and transport calculations.
Geochemii:al modeling (E03/6) at CNWRA may be used to evaluate the effects of leaching the waste under conditions anticipated at the SDMP sites.
/
5 Resources:
FY98 - $0 and 0 FTE FY99 - $0 and 0 FTE Quipmition and Rat:onale Not to be transferrr Work is underway and fully funded. Transfer of worx would be disruptive and not cost effective.
Billet Droo Test This project is largely completed using FY 97 funds, which are largely spent. The draft final report is scheduled to be submitted to NRC on 10/15/97. No follow on work is plannea or budgeted.
/
Resources:
FY98 - $0 and O FTE Resources:
FY99 - $0 and O FTE 10
Disposition and Rationale t
Not to be transferred to RES because the work is largely complete.
Diffusivity of Zinc l
This is a scoping study to be performed at NIST to determine if further research is needed in this area by NRC. The scoping study is being funded using FY97 funds, but the work willlargely be done in FY98. If the results of the scoping study identify further technical studies that are needed, SFPO agrees that follow-on work should be
/ conducted by RES.
Resources:
FY 98 - $0 and 0.05 FTE <
FY 99 - $0 and 0 FTE Disposition and Rationale To be transferred since further technical studies if needed, should be conducted by RES.
NMSS Identified and Transferred Research Resources FY 1998 FY 1999 Identified Transferred Identified Transferred
$ in K FTE
$ in K FTE
$in K FTE
$ in K FTE 315 0.3 0
0.1 381 0.25 0
0 11
~
OFFICE OF ANALYSIS AND EVALUATION OF OPERATIONAL DATA Common Cause Failure (CCF) Database The CCF database consists of events from LERs and NPRDS that are evaluated for their common cause potential and listed in a retrievable format. It also includes the calculational tools to evaluate the operating experience data in order to quantify CCF parameters suitable for use in reliability and risk assessments. This project grew out of methods developed by RES to analyze data for estimating CCF parameters for reliability and risk assessments.
Resources:
FY98 - $300K and 1 FTE FY99: $300K and 1 FTE Disposition and Rationale Not to be transferred, because development is now complete and future work will involve only collection, evaluation and analysis of the data. The future effort is an integral part of the AEOD work to apply risk-based techniques to the analysis of operating experience.
Loss of Offsite Power Database The loss of offsite power database consists of events relating to losses of power along with plant information relating to the design of the offsite power system in a retrievable format suitable for analyzing the frequency and duration of LOSP events.
Resources!
FY98 & FY99 -included in CCF values above Disposition and Rationale Not to be transferred because this effort is an application of previously existing methods to analyze the operational experience relating to loss of offsite power events at nuclear power plants. The activity updates the data and estimates of the frequency and ivation of loss v.' offsite po.vi.. events in a manner suitable for reliability a.3 risk assessment quantification as well as providing insights into the engineering and operator performance aspects of the events.
Performance Trend Plots (SMM sunoort)
The performance trend plots and supporting analyses are to be used as inputs for the SMM screening meetings to aid in deciding which plants should be discussed at the SMM. The plots represent the integration of performance data readily available.from the PI program and other sources. They show the combined plant performance with respect to these inputs over time and with respect to the industry averages.
Development of performance trend plots to support the SMM sirocess is an expansion and enhancement of the methodology proposed by Arthur Andersen in their report on the SMM process.
12
Resources:
FY98 - $330K and 2 FTE FY99 - $330K and 2 FTE Disposition and Rationale Not to be transferred because this activity does not requir$ development of new methods or technology, instead it uses readily accessible data sources and statistical tools to analyze the operating performance of plants.
Risk-Based Performance Indicators This activity is intended to replace the current Pls with those that would have a more direct connection to public risk. Examples would include substituting risk important initiating event frequencies and their trends for scram rates and trends, and using system and component reliabilities and trends instead of counts of safety system failures, etc. TNs effort is based on evaluations of actual plant operating experience.
Resources:
FY98 - $450K and 1.25 FTE FY99 - $100K and 2.5 FTE Disposition and Pationate Not to be transferred because this activity will not involve new technology or new methods but will use existing analytical techniques such as those being applied in the analysis of system reliabilities and initiating events.
Human Performance Database Analysis This at.tivity includes data entry into a humar, performance database and analysis and evaluation of the database to feed back lessons of cperating experience. This activity extracts information from detailed event investigations into a database previously established by an interoffice task force.
Resources:
FY98 - $75K and 1 FTE FY99 - $ 0 and 0.5 FTE Disposition and Rationale Not to be transferred because this activity does not require new methods or technology development. Analysis and enluation of operating experience including human performance is an integral part of AEOD's efforts to extract the lessons of operating experience and feed back the findings.
13
I AEOD Identified and Transferred Research Resources FY 1998 FY 1999 Identified Transferred loentified Transferred
$ in K FTE
$ in K FTE 1155 5.25 0
0 730 6.0 0
0 14
p - - - - - - ____ - __
Summary of Identified and Transferred Research Resources i
FY 1999 FY 1998 identified Transferred Identified Transferred
$ in K FTE
$ in K FTE Office NRR 500 3.2 220 0.4 180 1.63 120 0.1 NMSS 315 0.3 0
0.1 381 0.25 0
0 AEOD 1155 5.25 0
0 730 6.0 0
0 I
15 l
l
ATTACHMENT 6 IMPLEMENTATION STEPS FOR TRANSFER OF RULEMAKING AND RESEARCH RESPONSIBILITIES AND RESOURCES e
i
IMPLEMENTATION STEPS Identify candidate staff associated with transferred functions (for example,
+
rulemaking and supporting regulatory guides). Refine FTE allocation to current office and other program offices.
Detennine specific staff to be transferred (an individual's activity may suppert more than one program office or be divided between transferred and mtained activities within an office) and develop new organizational structure (for example, a new branch or branches)
Undertake appropnate discussions with the National Treasury Employees Union (NTEU)
ADM performs functional transfer
+
Present proposed arrangements for relocation of staff to office LMPCs Reach agreement with LMPCs on arrangements for relocation Effectrelocation of staff l
l
Confirmatory Research Activities l
Summary Office FY1998 Resources to be Transferred to RES NRR 1.4FTE 172K*
NMSS 0
315K AEOD 0
0 Total 1.4FTE 487K*
Does not include Nunn-Lugar funding for support of core conversion of Russian Production reactors.
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GENERIC SAFETY ISSUES PROGRAM IMPLEMENTATION OF DSI 22 The Generic Safety issue (GSI) Program was one of the functions reviewed as part of the direction setting issue paper review of the activities conducted by the Office of Nuclear Regulatory Research. The GSI Program is described in NUREG 0933, "A Prioritization of Generic Safety Issues." The current program began in October 8,1976, when the Commission directed the staff to develop a program plan for resolution of generic issues and completion of technical projects. The staff developed a generic issues program to address potential safety enhancements. It is important to note that this program does not include issues of adequate protection or compliance with existing regulations. As discussed in NUREG 0933, issues of significance such as adequate protection issues or compliance issues are excluded from the GSI process since decisions must be made in a shorter time frame. Actions taken for adequate l
protection or compliance issues generally takes the form of a Bulletin or Order.
The program is comprised of six steps: identification, prioritization, resolution, imposition, implementation and verification. These steps are described in NUREG 0933. In summary, identification includes the identification of a generic concern by an individual or organization within the NRC staff or an advisory panel, a member of the public, or a member of industry.
Prioritization includes a review of the safety significance of the issue to assist in a determination of the allocation of staff resources.1%ees which have little safety significance and hold little promise of worthwhile safety enhancement are removed from consideration. Resolution includes the development of a plan of work, including milestones, to develop a technical solution to the GSI. The technical solution is the basis to develop a proposed resolution. This step may include consideration of several attematives and involve a regulatory analysis, including a detailed cost / benefit analysis for each attemative. imposition includes the regulatory action which requires affected licensees to prepare a schedule for implementing the resolution.
Implementation includes the affected licensees' activities to satisfy the requirements or commitments made during the imposition step. Verification includes staff actions to verify that affected licensees have implemented the necessary actions. Inspections may be performed on an audit basis.
l Two broad options were discussed: (1) continuing the current process in which RES is l
responsible for prioritizing reactor related issues, and conducting research to identify solutions; l-NRR is responsible for imposition, implementation and verification of the solution for reactor l
related GSis; NMSS is responsible for all aspects of GSis for its licensees; and (2) transferring responsibility for conducting research and identification of the solution for all GSis to RES; NRR and NMSS would be responsible for imposition, implementation and verification as appropriate.
A related issue involves the assignment of responsibility for updating the Generic issue Management Control System (GIMCS) and NUREG 0933. There are two options related to this issue: (1) RES would retain responsibility for updating GIMCS, and (2) the responsibility for updating GIMCS could be transferred to the Office of Administration.
I
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2 The staff recommends that the current assignment of responsibilities be mainteined as discussed in option (1) above, with the clarification that confirmatory research necessary to l
resolve GSis involving NMSS (except those which may be related to high level we.ste issues) be conducted by RES. Currently there are no open NMSS GSis that are the subject of confirmatory research.
1 1
l 1
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