POLICY ISSUE

INFORMATION

April 7, 2004 SECY-04-0056

FOR: The Commissioners

FROM: William D. Travers

Executive Director for Operations

SUBJECT: SEMI-ANNUAL 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 for the construction of a high-level waste (HLW)

repository in an electronic environment. 

SUMMARY:

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 of processing a

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

Previously, the Commission received semiannual reports from the Licensing Support Network

Administrator (LSNA), that covered the areas discussed in this report. Future semiannual 

CONTACT: John J. Linehan, NMSS/HBPI

 (301) 415-7780
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reports of the LSNA will be limited to activities related to Atomic Safety and Licensing Board

Panel (ASLBP) responsibilities. This report, which will also be issued semiannually, covers all

other HLW IT/IM and business process activities. The scope of this information paper includes

activities from July 1, 2003, through December 31, 2003. 

DISCUSSION:

A. Project Plan

Compliance with 10 CFR Part 2, Subpart J, which contains the requirements for the HLW

proceeding, 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 business processes and procedures. 

Collectively, these activities are called the HLW Licensing Support Program (HLW-LSP). The

following initiatives, which are the responsibility of several NRC organizations, make up the

HLW-LSP: Licensing Support Network (LSN); Digital Data Management System (DDMS); HLW

Electronic Hearing Docket (HLW-EHD); Electronic Information Exchange (EIE) forms and

process for HLW licensing activities; identification and electronic processing of NRC

documentary material that must be made available via the LSN; and upgrades to the Agency’s

IT infrastructure and IM processes. 

These are complex multi-year programs, most of which will extend until the end of the HLW

repository proceedings, with multiple components requiring significant advanced project

planning. Some of the systems have existing project plans. However, there was no integrated

plan that identified all key activities and all interfaces and dependencies of various systems and

activities. The HBPI is overseeing the development of an HLW-LSP Project Plan guiding the

execution of these activities. The Project Plan will develop and implement an appropriately

rigorous and disciplined project management approach to assist NRC in meeting the technical,

adjudicatory, and programmatic requirements of the HLW-LSP. The HLW-LSP Project Plan is

being developed with the support of Project Performance Corporation (PPC), using an

interactive process and ongoing communication with staff and management from all

organizations supporting the HLW-LSP.

The first draft of the HLW-LSP Project Plan was completed on December 1, 2003. The draft

focused on priority areas, including the work breakdown structure, integrated schedules, and

Risk Management Plan. Also under development for inclusion in the Project Plan are the

Communications Plan, Records Management Plan, and a Change Control Plan. The draft final

Project Plan was recently provided to the Commission.

B. HLW Meta-System Status

The HLW Meta-System is that collection of systems and processes 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 (Part 2, Subpart J). Significant

components of the Meta-System include EIE; Document Processing Center processing;

Agencywide Documents Access and Management Systems (ADAMS); Office of the Secretary

(SECY) processing; EHD; and DDMS. In addition, the HLW Collection (HLWC) Server, and the
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LSN system support the “discovery” phase of the proceedings by enabling NRC to share its

HLW documents with the participants. The status of the LSN, other than the staff’s certification

efforts, is covered under reporting by the LSNA, and will not be further discussed here.

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

HLW documents, additional significant, unbudgeted work is required to fully develop some of

the components of the Meta-System and associated processes and procedures in fiscal years

2004 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 ASLBP; Office of 

the General Counsel (OGC); Office of Commission Appellate Adjudication; and SECY, held 

a significant number of meetings to further define and initiate development of the Meta-System. 

This effort, which included developing a high-level concept of operations, identifying the

business need requirements of ASLBP, SECY, OGC, and Office of Nuclear Material Safety 

and Safeguards (NMSS), and identifying gaps and actions needed to fully develop the 

Meta-System, culminated in the issuance of an HLW Gap Analysis Phases and Action Plan

Report in late December. 

The individual systems and processes, as well as the entire Meta-System, must function to

support the expectations (business processes) of the involved organizations. To this end, it is

important that there be an in-depth understanding of the Service-Level Requirements (SLRs) 

imposed by the business requirements of the involved organizations and the requirements of

10 CFR Part 2, Subpart J. SLRs describe the product characteristics and/or services the

customer receives from the service provider. A separate Commission paper is being developed

to provide the Commission with concept of operations options available and their costs. 

HBPI and OCIO personnel facilitated a series of in-depth SLR meetings, starting in December

2003, to determine what service levels would be required by different organizations. The

specific requirements discussed included availability (planned downtime of systems and

processes); reliability (unplanned outage time of system and processes); capacity; and

continuity of operations. These SLRs become a very significant challenge that will place

significant demand not only on the Meta-System, but also on the Agency’s IT infrastructure. 

During the fall of 2003, Meta-System testing was conducted in NRC’s Consolidated Test

Facility. Five “end-to-end” test scenarios were chosen to fully exercise the existing portions of

the Meta-System. The results of this testing will be used as a guide to further develop the

Meta-System. The testing verified the capability of the systems and processes to process a

wide variety of documents. Timing studies provided insights into potential weaknesses of the

Meta-System that will be addressed via future system enhancements. As discussed above, all

activities needed to fully develop the Meta-System are being incorporated into the Project Plan. 

C. Regulatory Guidance - Regulatory Guide 3.69 

Regulatory Guide (RG) 3.69, “Topical Guidelines for the Licensing Support System,” dated

September 1996, is being revised, consistent with 10 CFR Part 63, and the “Yucca Mountain 

Review Plan” (NUREG-1804), dated July 2003. The RG defines the scope of documentary 
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material that should be included in the LSN. Proposed Revision 1 to the RG was issued as

Draft Regulatory Guide 3022 for public comment. Nine comment letters were received. While

there may be changes to the RG based on these comments, issuance of the final RG is on hold

until staff completes the response to public comments on the recent proposed amendments to

10 CFR Part 2, Subpart J. Amendments to Subpart J may require additional edits to the final

RG. Staff is working to expeditiously issue the final Subpart J rule and the final version of the

RG. At the last LSN Advisory Review Panel (LSNARP) meeting in December 2003, the staff

noted that the proposed Revision 1 to the RG is adequate for determining what documents

should be made available to the LSN. 

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 U.S. Department of Energy (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 DOE Information Classification and Control

Policy with participation from the DOE Office of Civilian Radioactive Waste Management

(OCRWM), the DOE OGC, the DOE Nevada Operations Office, and the NRC. The guide

provides guidance on what is sensitive unclassified information and classified information

associated with the DOE OCRWM’s 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 is being reviewed for approval 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 plans to certify LSN compliance in June 2004, and NRC

expects to certify compliance in July 2004. The NMSS Office Director is being designated as

the responsible official to certify to the Pre-License Application Presiding Officer that NRC

documentary material has been identified and made electronically available. 

The staff, with significant coordination and input from the LSNA and his staff, has 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. The activities to identify documentary material include scanning

legacy documents from the Legacy Library (pre-ADAMS); Center for Nuclear Waste Regulatory

Analyses; NRC staff offices (both organizational and individual); and former HLW files. After

these files are scanned, they are converted to Portable Document Format and added to 

ADAMS. Additionally, bibliographic headers only will be added to those documents that are not 
The Commissioners 5

suitable for image or searchable full text, or the documents subject to claims of privilege or

other bases for non-disclosure. Before the documents are made publicly available in ADAMS,

they are screened for sensitive homeland security information. After the screening is complete,

the documents are published from ADAMS to the LSN. At the end of calendar year 2003, over

15,000 out of approximately 35,000 documents from NRC’s collection have been published on

the LSN. The staff is on schedule to certify, in July 2004, that it has identified its documentary

material and made it electronically available via the LSN. 

F. Interactions with DOE and Other Potential Parties

The staff has actively participated in the two LSN Advisory Review Panel meetings with DOE, 

discussed in the LSNA’s semiannual report. There has been no identified need for further

technical exchanges with DOE during this period. 

G. Efforts to Identify Adjudicatory Employees for Commissioners

The staff developed a special Yucca Mountain module for the Strategic Work Place Skills and

Knowledge Survey, to better determine existing skills available for the Yucca Mountain review

and adjudicatory employee (AE) support to the Commission. The survey was announced on

October 31, 2003, and results were available in late December 2003. The results will be used

to identify staff to support the AE function and the NRC staff review of the DOE license

application. 

COORDINATION:

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

LSNA. 

/RA/

William D. Travers

Executive Director 

 for Operations
The Commissioners 5

suitable for image or searchable full text, or the documents subject to claims of privilege or

other bases for non-disclosure. Before the documents are made publicly available in ADAMS,

they are screened for sensitive homeland security information. After the screening is complete,

the documents are published from ADAMS to the LSN. At the end of calendar year 2003, over

15,000 out of approximately 35,000 documents from NRC’s collection have been published on

the LSN. The staff is on schedule to certify, in July 2004, that it has identified its documentary

material and made it electronically available via the LSN. 

F. Interactions with DOE and Other Potential Parties

The staff has actively participated in the two LSN Advisory Review Panel meetings with DOE, 

discussed in the LSNA’s semiannual report. There has been no identified need for further

technical exchanges with DOE during this period. 

G. Efforts to Identify Adjudicatory Employees for Commissioners

The staff developed a special Yucca Mountain module for the Strategic Work Place Skills and

Knowledge Survey, to better determine existing skills available for the Yucca Mountain review

and adjudicatory employee (AE) support to the Commission. The survey was announced on

October 31, 2003, and results were available in late December 2003. The results will be used

to identify staff to support the AE function and the NRC staff review of the DOE license

application. 

COORDINATION:

The OGC has reviewed this package and has no legal objection. This paper has also been

coordinated with SECY and the LSNA. 

/RA/

William D. Travers

Executive Director 

 for Operations

Distribution:

Luis Reyes, RII

ML040850055 

OFC NMSS* NMSS* NMSS* ASLBP* OCIO*

NAME J Linehan EKraus J Greeves P Bollwerk L Scattolini

DATE 03/08/04 03/04/04 03/08/04 03/15/04 03/11/04

OFC OCIO* OGC* NMSS/D DEDMRS OEDO

NAME E Merschoff K Cyr M Virgilio C Paperiello W Travers

DATE 03/12/04 03/18/04 03/3/104 04/06/04 04/07/04

OFFICIAL RECORD COPY