POLICY ISSUE

(Information)

August 11, 2004 SECY-04-0148

FOR: The Commissioners

FROM: Luis A. Reyes

Executive Director for Operations /RA/

SUBJECT: SEMIANNUAL REPORT ON STATUS OF STAFF INFORMATION

TECHNOLOGY/INFORMATION MANAGEMENT AND BUSINESS

PROCESS ACTIVITIES IN PREPARATION FOR THE HIGH-LEVEL

WASTE REPOSITORY PROCEEDINGS

PURPOSE:

To inform the Commission about the status of Information Technology/Information

Management (IT/IM) and business process activities related to preparation for the conduct of

the proceeding on a license application in an electronic environment for the construction of a

high-level waste (HLW) repository. 

BACKGROUND:

In March 2003, a HLW Business and Program Integration (HBPI) function was established to

integrate all Agency activities, to ensure the completeness of HLW business needs of the

Agency, and to ensure that systems exist, or will exist, to meet the needs both of processing a

license application for an HLW repository and of supporting the HLW adjudicatory process. 

This report is issued semiannually and covers HLW IT/IM and business process activities. The

first information paper, SECY-04-0056, covered July 1, 2003 through December 31, 2003. The

scope of the information paper includes activities from January 1, 2004, through June 30, 2004. 

DISCUSSION:

A. Project Plan

Compliance with 10 CFR Part 2, Subpart J, requires close communication, coordination, and

integration of activities and functions across several U.S. Nuclear Regulatory Commission

(NRC) organizations responsible for IT/IM, adjudication, technical support, and associated 

CONTACT: John J. Linehan, OCIO/HBPI

(301) 415-7780
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business processes and procedures. Collectively, these activities are called the HLW Licensing

Support Program (HLW-LSP). The HBPI has overseen the development of an HLW-LSP

Project Plan to guide the execution of these activities. 

The HLW-LSP Project Plan is being maintained with the support of Project Performance

Corporation, using an interactive process and ongoing communication with staff and

management from all organizations supporting the HLW-LSP. The latest version of the

HLW-LSP Project Plan was distributed on June 28, 2004. The Project Plan contains the work

breakdown structure, integrated schedules, Risk Management Plan, Communications Plan,

Records Management Plan, and a Change Control Plan. 

Although the framework provided by the Project Plan is relatively static, some components are

updated on a weekly basis. This includes the integrated schedule, management summary, and

schedule observations. Other components, such as the Risk Management database, are

updated on a monthly basis to reflect progress in risk mitigation and risk disposition. Newly

identified risks, however, may be added to the database and tracked at any time. Lastly, some

components, such as the Change Control Plan, trigger updates or meetings only when criteria

in the Project Plan are satisfied. 

Recently a major refinement of the project schedule was completed, which emphasized

collaborative and interdependent activities among the participating NRC organizations. During

this overhaul, a "template" approach was used in which common activities and tasks involving

NRC IT infrastructure and IT security were uniformly applied to each of the IT systems. 

Progress was made in use of “plain language” throughout the schedule. The advantage of the

refined schedule is that agency management may now schedule their resources more efficiently

and effectively. Furthermore, the resource impact of delays or accelerations in the schedule

may be accurately forecast.

Work is continuing on the generation of reports, for management, that more efficiently and

better communicate project data needed to manage, at all levels of the organization. A new

critical activities report is under development. On a weekly basis, reports are generated that

show the critical path, completed tasks, tasks that are overdue to start, and tasks that are

upcoming during the next 30 days, and next 31-90 days. Managers review and act on the data

to address risks and the impact of scheduling changes, taking appropriate actions to keep the

project on track. 

B. HLW Meta-System Status

The HLW Meta-System is that collection of software applications, technology, and data flows

that enables the processing of HLW documents in support of the HLW proceedings and in

support of the establishment of an HLW adjudicatory docket, as required by the regulations (10

CFR Part 2, Subpart J).

Although Meta-System components and processes are in place to process a low volume of

HLW documents, there still remains additional significant, unbudgeted work that will be required 

to fully develop the Meta-System and associated processes and procedures in fiscal years 2004
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and 2005. System enhancements are needed to increase capacity, reliability, and availability,

and significant testing will be required to verify and validate system performance.

HBPI and Office of the Chief Information Officer (OCIO) staffs along with the Atomic Safety and

Licensing Board Panel (ASLBP); Office of the General Counsel (OGC); the Office of Nuclear

Material Safety and Safeguards (NMSS) and Office of the Secretary (SECY), hold weekly

senior management meetings to monitor progress and discuss issues related to the HLW-LSP

and Meta-System. During this reporting period significant progress has been made in

developing a high-level concept of operations, identifying the business-need requirements of

ASLBP, SECY, OGC, and NMSS, and scheduling, in the Project Plan, the tasks and actions

needed to fully develop the Meta-System. We remain on track to have a fully functional and

tested Meta-System by April 2005, although there is virtually no slack in the project schedule. 

The greatest risk to the project is funding uncertainty.

Service-Level Requirements (SLRs) imposed by the business requirements of the involved

organizations and the requirements of 10 CFR Part 2, Subpart J describe the product

characteristics and/or services the customer receives from the service provider. A separate

Commission paper, SECY-04-0108, was provided to the Commission with options for SLRs and

their associated costs. 

During June 2004, a second round of Meta-System end-to-end testing was conducted in NRC’s

Consolidated Test Facility (the first round was completed during the Fall of 2003). An

interactive test scenario representing a postulated challenge to the U.S. Department of

Energy’s (DOE) certification was chosen to fully exercise the existing portions of the

Meta-System. NRC participants from NMSS, SECY, OGC, and OCIO were able to participate

from their desks, or at a nearby location of their choice, in a test script that was tailored to

exercise each organization’s role. Two NRC staff members also simulated the roles of external

parties. The testing verified the capability of the systems and processes to process a wide

variety of documents. Testing results provided insights into potential weaknesses of the

Meta-System that will be addressed via future system enhancements. Two additional rounds of

testing are scheduled for Fall 2004 and early Spring 2005.

C. Regulatory Guidance - Regulatory Guide 3.69 

Revision 1 to Regulatory Guide (RG) 3.69, “Topical Guidelines for the Licensing Support

System,” was made publicly available on June 25, 2004, on NRC’s website. The RG provides

guidance regarding the scope of documentary material that should be identified in, or made

available electronically. There are no substantial changes between the draft RG, which parties

have been using to prepare documentary material for LSN certification, and the final RG. 

Revision 1 modifies the topical guidelines to be consistent with the license application content

specified in 10 CFR Part 63; the structure of Revision 2 of the “Yucca Mountain Review Plan,”

NUREG-1804; environmental topics in DOE’s Environmental Impact Statement (EIS) and

NRC’s NUREG-1748, “Environmental Review Guidance for Licensing Actions Associated with
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NMSS Programs”; and the final 10 CFR Part 2, Subpart J, revision issued June 14, 2004, which

excludes correspondence between a party and Congress from the LSN. A Federal Register

notice was published on July 6, 2004, with a detailed response to public comments.

D. Sensitive Homeland Security Screening

All NRC documents that are being made available to LSN are being screened for sensitive

homeland security information. The criteria currently being used are consistent with the criteria

being developed by a joint DOE/NRC working group. The joint working group has prepared

CG-OCRWM-1, "Joint DOE and NRC Sensitive Unclassified Information and Classification

Guide for the Office of Civilian Radioactive Waste Management Program." The working group

was chaired by a DOE Information Classification and Control Policy representative with

participation from the DOE Office of Civilian Radioactive Waste Management (OCRWM), the

DOE OGC, the DOE Nevada Operations Office, and NRC. The guide provides guidance on the

definition and handling of sensitive unclassified information and classified information

associated with the DOE OCRWM program for constructing and operating a geologic repository

for the disposal of spent nuclear fuel and HLW at Yucca Mountain, Nye County, Nevada. The

guide has been approved by the Director, DOE Information Classification and Control Policy,

and by NRC’s Office of Nuclear Security and Incident Response. 

E. NRC Certification Activities

According to 10 CFR Part 2, Subpart J, NRC must certify it has identified and made

electronically available its documentary material to the LSN, no later than 30 days after the

DOE certification of compliance. DOE made its certification on June 30, 2004, and NRC

certified on July 30, 2004. The NMSS Office Director was designated as the responsible official

to certify, to the Pre-License Application Presiding Officer, that NRC documentary material was

identified and made electronically available. 

The staff established a Certification Program to manage the numerous activities necessary to

certify its documentary material collection. The certification program consists of activities and

processes that: (1) identify documentary material; (2) make documentary material electronically

available; and (3) establish procedures. All certification activities have been completed. 

Certain activities will continue on a periodic basis throughout the proceeding (i.e., after

certification), as required by the regulations, including: (1) identifying newly generated

documentary material; (2) identifying newly generated documentary material, if any, that is

privileged, requiring a bibliographic header; (3) conducting Homeland Security Screening of

documents; and (4) publishing documents to the LSN (over 24,500, to date). NRC staff not

involved in certification activities conducted a review of the staff’s readiness to certify and found

that the staff developed and followed procedures for identifying and making available

documents to the LSN that are consistent with Part 2 requirements.
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F. Electronic Hearing Docket

In an effort to assist the Atomic Safety and Licensing Board with current adjudicatory

proceedings and to flesh out implementation issues before an anticipated HLW proceeding, the

Electronic Hearing Docket was activated to display hearing files for existing proceedings. 

Issues that arose were addressed, and users have provided favorable feedback. 

Enhancements are being implemented before the anticipated HLW proceeding.

COORDINATION:

The OGC has no legal objection. This paper has also been coordinated with SECY and the

Licensing Support Network Administrator. 

/RA Martin J. Virgilio Acting for/

Luis A. Reyes

Executive Director 

 for Operations
The Commissioners 5

F. Electronic Hearing Docket

In an effort to assist the Atomic Safety and Licensing Board with current adjudicatory

proceedings and to flesh out implementation issues before an anticipated HLW proceeding, the

Electronic Hearing Docket was activated to display hearing files for existing proceedings. 

Issues that arose were addressed, and users have provided favorable feedback. 

Enhancements are being implemented before the anticipated HLW proceeding.

COORDINATION:

The OGC has no legal objection. This paper has also been coordinated with SECY and the

Licensing Support Network Administrator. 

/RA Martin J. Virgilio Acting for/

Luis A. Reyes

Executive Director 

 for Operations

WITS200400048

OCIO 04-219

ML042150294 *See previous concurrence

OFC OCIO/HBPI NMSS NMSS ASLBP OCIO

NAME JLinehan* EKraus WReamer* PBollwerk* JSilber*

DATE 08/02/04 07/30/04 08/03/04 08/04/04 08/02/04

OFC OGC NMSS/D DEDMRS OEDO

NAME KCyr (JMoore)* JStrosnider(RCP)* MVirgilio MJVirgilio for

LAReyes

DATE 08/05/04 08/06/04 08/11/04 08/11/04

OFFICIAL RECORD COPY