POLICY ISSUE

INFORMATION

September 24, 2002 SECY-02-0171

FOR: The Commissioners

THROUGH: G. Paul Bollwerk, III

Chief Administrative Judge

FROM: Daniel J. Graser

Licensing Support Network Administrator

SUBJECT: LICENSING SUPPORT NETWORK PROGRAM ADMINISTRATION -

SEMIANNUAL REPORT

PURPOSE:

In accordance with 10 C.F.R. § 2.1011(c)(5), to inform the Commission of the status of the

Licensing Support Network (LSN) and the activities of the LSN Administrator (LSNA) for the

six-month period ending June 30, 2002.

BACKGROUND:

The Commission’s Staff Requirements Memorandum (SRM) dated January 31, 1992, directed

the submission of a semiannual report on the activities of the LSNA (formerly the Licensing

Support System (LSS) Administrator).

The scope of this semiannual report includes LSN program activities from January 1, 2002,

through June 30, 2002.

CONTACT: Daniel J. Graser, LSNA/ASLBP

415-7401
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DISCUSSION:

I. Activities

A. Licensing Support Network Administrator and Staff

No changes have been made to the staffing profile for LSN and Digital Data Management

System (DDMS) project activities since the last report.

B. Federal Advisory Committee Act (FACA)-Related Activities

No changes in LSN Advisory Review Panel (LSNARP) composition have occurred since the

previous report and there have been no changes in the charter. Dr. Andrew Bates of the Office

of the Secretary (SECY) continues to serve as the LSNARP Chair.

The LSNA, together with representatives from other affected offices, attended a meeting with

the Office of the General Counsel (OGC) and SECY representatives on May 15, 2002, to

discuss revisions to the Nuclear Regulatory Commission’s (NRC) implementation of new

guidance on Federal Advisory Committee Act (FACA) chartered advisory committees. OGC

and SECY provided clarification on how the changes might affect the operation of

subcommittees and working groups, such as are used by the LSNARP. No changes to the

LSNARP charter were identified as being necessary.

C. LSN Advisory Review Panel Activities

On January 29, 2002, LSNARP Chairman Dr. Andrew Bates issued a memorandum to

LSNARP members detailing progress to-date and providing preliminary responses to questions

raised at the August 2001 LSNARP meeting. Those responses were incorporated into the draft

version of LSN Guidelines that have been in place since June 2001 and the updated materials

were circulated to SECY, OGC, the Office of the Chief Information Officer (OCIO), the Office of

the Chief Financial Officer (OCFO), and the Office of Nuclear Material Safety and Safeguards

(NMSS) for comment. The LSN Guidelines, documenting technical decisions and describing

viable approaches to all aspects of the participants’ system implementation, were finalized on

April 25, 2002, and distributed via e-mail by Dr. Bates to LSNARP members and LSNARP

Technical Working Group (TWG) participants. The Final Guidelines are available on NRC’s

Agencywide Documents Access and Management System (ADAMS) (ML021160199), the

Publicly Available Records Systems (PARS), and on the LSN website.

An LSNARP meeting is scheduled for September 18-19, 2002, in Las Vegas. Potential agenda

items are detailed in section III.A of this report. 
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D. Interactions with Other NRC Offices and Entities

1. Commission

Briefings for individual Commissioners are provided upon request. Two informational briefings

were presented to members of the Commission and staff during February and April of 2002. 

The April 11, 2002 briefing on planning for the high-level waste (HLW) repository licensing

proceeding hearings, including the LSN, was made to the Commissioners’ assistants by Chief

Administrative Judge Bollwerk.

2. Office of the Chief Information Officer

Members of the LSN staff attended an OCIO demonstration of the web version of the Electronic

Hearing Docket (EHD), which is one of the HLW adjudicatory proceeding automation tools

required by 10 C.F.R. Part 2, Subpart J. The product developed by OCIO in response to SECY

management guidance seems to be of high quality and suggests that the final delivered

product, when accepted by SECY, will meet Subpart J expectations. 

On April 1, 2002, LSN staff provided OCIO with Government Information Security Reform Act

(GISRA) information needed to obtain system certification for the LSN as required by

Management Directive 12.5. A memorandum to the CIO was subsequently prepared

designating LSN Project Manager Matthew Schmit as the Information System Security Officer

(ISSO) for the LSN, completing the documentation needed by OCIO for certification. As of the

end of this reporting period, the LSN is awaiting system certification by the CIO. Certification is

expected before the end of the current fiscal year in order to report the system as compliant

with Government Information Security Reform Act (GISRA) reporting requirements. 

3. Information Technology Business Council (ITBC)

The LSNA participated in two working sessions conducted under ITBC auspices to consider

changes to agency guidance on development and operation of the agency’s Capital Planning

and Investment Control (CPIC) program. The LSNA was invited because of his involvement

with three major projects that have been subjected to a CPIC analysis: ADAMS, LSN, and the

DDMS. The LSNA offered insights on the expected outcomes, along with commentary on the

possible impacts on IT project managers’ effectiveness that could be anticipated from the

OCIO’s initial draft governing principles.

4. LSN Internal Working Group and the HLW Licensing Program

Executive Steering Committee (HLWESC)

Acting at the request of the HLWESC, the LSNA drafted a white paper on several issues, such

as technical standards applicable to documentary materials going into the EHD, that are

associated with utilizing electronic materials in the HLW repository licensing proceeding. The

draft was reviewed and revised by representatives from OCIO and SECY to include options for

formatting very large documents, such as the DOE electronic License Application (LA), that are

to be submitted through Electronic Information Exchange (EIE) and ADAMS intake. It was
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presented to the members of the HLWESC on May 15, 2002. As a result of HLWESC

discussions regarding the paper, OCIO proposed an OCIO/SECY-sponsored team to identify

gaps in NRC’s ability to accept and process electronic submissions for the high-level waste

proceeding. This team will focus on solutions to (1) allow EIE transmission of large documents;

(2) allow the agency’s official records repository (ADAMS) to intake such large documents

without fragmenting them into so many pieces as to make research, search and retrieval, and

usage difficult; and (3) facilitate large document availability in a publicly accessible EHD so as

to ensure they can be quickly and effectively downloaded by the public using the Internet. 

Since the ADAMS and EHD repositories define the technical file structures and document

organization approaches for materials that will be downloaded into the hearing room for use in

the proceedings, the decisions made to solve these problems have significant implications for

the successful use of large documents in the hearing room via the proposed DDMS. Timely

resolution of these issues will be important in demonstrating the effectiveness of NRC’s HLW

proceeding programmatic planning, managerial preparation and organization, and IT

competency. 

The team will report to and receive guidance from the full HLWESC, to develop an action plan

and schedule to identify and address issues with HLW documents. The action plan and

schedule are targeted for delivery by late July 2002 for discussion at an early August HLWESC

meeting.

5. NMSS Initiative for NRC/DOE Meeting on LA Electronic Submission

Representatives from ASLBP, OGC, NMSS, and OCIO met in January 2002 to discuss

electronic format and file organization approaches for the DOE LA. The meeting focused on

the relationship between the EIE guidance for the electronic filing rule (E-rule) currently being

developed and the already-promulgated Subpart J requirements for the EHD. File format

standards in these two areas are not fully consistent. Subsequent meetings between NMSS,

ASLBP, SECY, OCIO, and OGC were held to determine whether those standards should be

identical, or if the E-rule should indicate that HLW submissions are covered by other electronic

submission standards. The final consensus position was that DOE should be informed that,

notwithstanding prior guidance in 10 C.F.R. § 2.1011(b)(2)(iv), image density standards for

color and greyscale photos will have to be delivered to NRC using a minimum 200 dots per inch

(dpi) resolution standard to ensure that they can subsequently be converted or upgraded as

technology advances. This issue was identified for discussion with DOE at a June 2002

Technical Exchange meeting with DOE, which is discussed in section I.E below.

Another issue associated with DOE’s potential submission of an electronic LA includes the

E-rule’s provisions allowing for paper submissions and its potential for being erroneously

interpreted as applying to the DOE license application for a HLW repository. OGC has advised

that the E-rule is not applicable to adjudicatory proceedings, and even if it were, specific

requirements in Subpart J would override general E-Rule requirements when that rule is

eventually promulgated.

A third issue raised by OCIO concerned the feasibility of directing submission of the DOE LA on

CD-ROM and possibly not storing it in ADAMS because of its size. OGC has advised that
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“submission” on an “electronic medium” such as a CD-ROM does not comply with the 10 C.F.R.

§ 2.1013 (c)(1) requirement for “electronic transmission.” 

The above noted OCIO-led team will continue working to identify any outstanding technical

issues in regard to DOE electronic submissions and solutions for addressing those issues that

can be communicated to DOE.

NMSS conducted the first Technical Exchange on June 25-26, 2002, in Las Vegas, Nevada,

between the NRC and DOE concerning the electronic submission of documents associated with

a potential license application and associated proceedings for a Yucca Mountain HLW

repository. The NRC staff and DOE representatives discussed technical issues and potential

challenges that could affect electronic submission of documents.

Presentations by NRC included status reports on the key components to Subpart J automation

requirements, including the high-level waste information architecture at NRC, EIE process and

pilots, the use of the EHD for a potential HLW proceeding, electronic courtroom, and technical

issues with a potential electronic license application submission and other large documents. 

DOE provided a briefing on the status of its efforts to publish its HLW document collection and

make those materials available via the LSN, as did representatives from NMSS with respect to

the NRC collection. Staff will continue these interactions with DOE and future meetings on

electronic submissions are anticipated between NRC, DOE, and other potential parties.

NMSS is awaiting the recommendations of the OCIO-led team (expected Spring 2003) in order

to provide DOE with the technical specifications for the electronic LA that eventually will be

entered into ADAMS by OCIO and docketed by SECY in accordance with Subpart J. Resolving

the problems associated with the submission and handling of large documents is important to

the success of both the discovery and subsequent hearing processes.

6. Draft Regulatory Guide DG-3022: Topical Guidelines for the

Licensing Support Network

As noted in the agenda items found in section III.A of this report, the draft Regulatory Guide

that defines the scope of documentary material for inclusion in the LSN was released for public

comment on July 2, 2002, and will be discussed at the upcoming LSNARP meeting. The

purpose of the draft Regulatory Guide is to provide a list of the topics for which LSN participants

should submit documentary materials for entry into the LSN. It represents a proposed

Revision 1 to the existing Regulatory Guide 3.69. The draft revisions have been developed to

be consistent with requirements for DOE LA content as described in 10 C.F.R. 63.21 and

specified in the draft Yucca Mountain Review Plan, Revision 2. The comment period for the

draft Regulatory Guide extends through September 30, 2002. 

E. Interactions with DOE on Their Efforts and Readiness to Meet LSN

Commitments

The DOE HLW document collection server has been successfully integrated with the LSN portal

since last year. Subsequently, like NRC, DOE has formulated post-9/11 review criteria and is
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1

 A “crawler” or “spider” is a computer program that is directed to visit a designated

location and parse through all the data it finds. In the Internet environment, the program

subsequently fetches the information it finds, brings it back to its own server, and delivers it to

other software that builds an index to that information. The spider then “throws away” the

information it found, and continues the process with the next data or document that it finds until

the entire target collection has been indexed.

coordinating efforts for the release of documents, and the LSNA interactions with DOE have

focused on technical improvements to facilitate downloading image documents from the DOE

collection and improving the speed of the LSN “crawler” software in indexing the DOE

documents. To those ends, the LSN staff continued to coordinate with DOE representatives

from the LSNARP TWG on technical integration enhancements, efforts that have resulted in a

limited number of test documents being made available to evaluate the new, improved LSN

crawler. 1

At the June 25-26 Technical Exchange meeting reported above, DOE presented a schedule 

that calls for identification and processing of their holdings commencing in October 2002. Once

identified and prepared, they plan to have their documentary holdings available on their

production server commencing in August 2003, with loading completed in time for a planned

initial certification in June 2004 -- six months prior to the currently projected December 2004 LA

submittal. This plan included a time line that was not very specific and covered long time

spans, but still represents significant progress as it is the first concrete operational schedule

presented by DOE to the LSNA. Technical discussions with the DOE computer staff indicate

that they are sizing their system to hold 300,000 documents (projected to represent 5,100,000

pages). It is worth noting that the LSN design criteria used approximately 5 million pages as its

low-end design criteria and 15 million pages as its high-end criteria, so the LSN is well

positioned to accommodate these new planning numbers.

The LSNA continued to coordinate with the Chief Information Officer of DOE’s Civilian

Radioactive Waste Management Program to verify DOE’s commitment to make LSN access

available in DOE reading rooms, as required by Subpart J, in fifteen locations across the State

of Nevada.

F. NRC Compliance as Party to HLW Proceedings

NRC staff awaited the Commission’s screening criteria for sensitive homeland security

information during the reporting period and did not place any HLW documents on the LSN

collection server. NMSS is now working to publish its collection of HLW header and document

files.

In the meantime, LSN staff evaluated the structure and content of test data published for the

NRC HLW document collection and provided detailed feedback to the NRC staff on the quality

of NRC’s LSN data as a prelude to further integration testing. The OCIO contractor continued

to make progress in getting the NRC data in a format that can be used by the LSN portal per an
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action item closure meeting convened by OCIO on March 20, 2002. These efforts were

coordinated in a March 26, 2002 meeting under NMSS lead. 

When the sensitive homeland security information screening review process is implemented

and final technical details are resolved with the NRC web publishing process, the agency

expects to start making its HLW document collection available in December 2002.

Although the NRC Public Document Room provides a terminal with access to the NRC

homepage, access to “external” Internet locations is blocked for public users at this time.

However, OCIO has established a hyperlink from the NRC homepage to the LSN homepage,

complying with the “and/or” requirement at 10 C.F.R. § 2.1007(a)(2). 

G. Interactions with Other Participants on Their Efforts and Readiness to Meet

LSN Commitments

On January 10, 2002, in accordance with the Nuclear Waste Policy Act (NWPA), Secretary of

Energy Abraham notified the State of Nevada of his intention to recommend to President Bush

that the Yucca Mountain site is scientifically sound and suitable for development as the nation's

long-term HLW geological repository. There was an immediate and notable increase in the

tempo of technical interactions with potential parties.

• On January 14, 2002, the LSN staff was contacted by technical representatives

from the Nevada counties of Nye (Elaine Ezra), and Lincoln and White Pine

(Jason Pitts) to begin arrangements for connecting their HLW document

collections to the LSN. LSN staff provided both representatives with a copy of

the LSN header generator software. 

• The LSNA and NMSS representatives met on February 15, 2002, with Cheryl

Noriega, a county commissioner from White Pine County, Nevada, and Josie

Larson, the county’s technical coordinator for LSN efforts. They were

accompanied by John Gervers, a consultant to the county. LSN-related

discussions centered on how the county can comply with 10 C.F.R. Part 2,

Subpart J, requirements given the small volume of documents the county is likely

to generate. 

• On April 17, 2002, LSN staff provided web site set-up guidance and header

generator software to Lander County, Lincoln County, and White Pine County

representatives per their requests. 

• Similar technical exchanges occurred with representatives of Clark County on

April 23, 2002. 

• On May 10, 2002, the LSN staff received notification that the LSN sites for the

Nevada counties of White Pine and Lincoln were established and ready for

testing. 
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• During the week of May 13, 2002, NRC’s LSN contractor began assessing the

installed configuration. A single server has been established collaboratively by

Lincoln and White Pine Counties to house their individual collections. Some

minor configuration issues were identified and have been brought to the attention

of the counties’ automation vendor. The Lincoln and White Pine joint effort was

successful in using the header generator tool provided on the LSN web site to

create bibliographic headers, and initial connectivity testing was completed. LSN

staff expect to test document indexing in July and August 2002.

• Further technical exchanges with the Clark County staff took place on June 26,

2002. Clark is preparing to establish its LSN site and would like to begin testing

in September 2002.

• At the June 25-26 DOE/NRC electronic submissions Technical Exchange

meeting, Susan Lynch, Administrator of Technical Programs for the State of

Nevada, indicated that depending on the outcome in July 2002 of the

congressional process for overriding the Nevada Governor’s veto of the

President’s December 2001 site recommendation, the State of Nevada would be

interested in launching technical discussions with LSN staff and contractors this

coming September.

H. LSN Implementation Project

1. LSN Response to Delay in DOE LA Submission

Efforts during the reporting period were focused on performing security enhancements and

assessments of the LSN system while the DOE and NRC were developing post 9/11 guidelines

for making materials available via the Internet. 

Additionally, in the fall of 2001 a significant change in the target date for the DOE HLW

repository license application occurred. Although there had been suggestions that the DOE

application date was going to slip for some time, it was only at that time that it became evident

that DOE’s LA submission was not going to be received in March 2002. At the time of the initial

LSN Capital Planning and Investment Control (CPIC) Business Case Analysis (BCA)

submission, March 2002 was the agency planning date for the DOE HLW repository LA. 

However, since the fall of 2001 DOE has been stating publicly a license application date of

December 2004, consistent with the President’s FY 2003 budget request for DOE.

LSN staff analysis relative to this changed condition led to identification of long-term operational

risks and fiscal impacts associated with DOE’s two-and-a-half-year delay. DOE’s delay will

necessitate substantial maintenance activity to accomplish (1) a technology refreshment; (2) an

operational strategy shift to keep the LSN search engine at current release versions; (3) and

three years of additional operational support that will exceed the five-year term of the existing

LSN design/operations contract, thus requiring a new procurement action. The LSNA response

was to detail the delay-associated risks and impacts, submit an update/revision to the original

LSN CPIC BCA (ML 020840041) to OCIO, the ITBC Chairman, and OCFO. 
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2. Close Out of LSN Development Phase Contract and Start of

Operations & Maintenance

The basic LSN development contract with GRC International, Inc., (GRCI) ended January 15,

2002. The contract for the base period of performance was completed on budget. 

The LSN staff worked with the Office of Administration/Division of Contracts (ADM/DC) to

exercise an option for operations and maintenance (O&M) support covering the performance

period from January 16, 2002, through January 15, 2003. As requested by ADM/DC, the

statement of work for the option period was modified to incorporate performance-based

contracting principles. 

3. Hardware Reconfiguration

Partially in response to initial government test and acceptance findings on the delivered LSN,

and partially in response to the events of September 11, 2001, the LSN staff took several steps

to make the LSN architecture more secure and redundant. For instance, working in conjunction

with ADM/DC, LSN staff processed an engineering change proposal (ECP) from the LSN

contractor for a hardware reconfiguration that permits work to be distributed among the LSN

servers so as to allow for immediate response by the “clustered” servers to individual

component failures. The proposed configuration is intended to eliminate a single point of failure

problem and provide robust backup and recovery.

Additionally, the LSN staff received and processed an LSN contractor ECP for hardware for a

supplemental LSN reconfiguration intended to further improve system security, performance,

and stability. ADM/DC requested that the contractor resubmit the proposal using General

Services Administration (GSA) schedule items, which it did, resulting in ADM/DC approval to

the contractor on March 26, 2002, to procure the additional hardware from the GSA schedule. 

During a part of the reconfiguration process, the LSN was unavailable and displayed a banner

notifying users the system is being upgraded. LSN staff worked closely with the LSN contractor

to coordinate and minimize LSN unavailability.

Reconfiguring the LSN hardware to make the LSN more secure, along with release 2.0 of the

web site search engine and “spidering” software (i.e., the index building software) were

completed by April 30, 2002. The release 2.0 web site user interface has no new features, but

incorporates a new hardware design and leverages technology for faster page loading. 

Version 2.0 of the spider leverages multithreading, which will allow the LSN to spider large sites

(e.g., DOE) faster. During May 2002 LSN staff began version 2.0 integration testing with the

NRC and DOE, which DOE supported by posting 50 test documents. When version 2.0 is

tested and accepted, one of the side-benefits will be that LSN staff will have demonstrated one

aspect of technology refreshment - - the ability to make an upgrade to the underlying

commercial off-the-shelf (COTS) search engine software (Autonomy 4.0) - - with minimal effort. 

NRC’s LSN staff is currently processing a procurement action for the Division of Contracts (DC)

to purchase a two-processor copy of Microsoft SQL Server Enterprise Edition, a final piece of

software needed to ensure database redundancy. This software will let one database
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automatically pick-up if another should fail. A purchase order had been awarded for this

software, however, the awardee made an error in its price. As purchase orders are not binding

until the contractor initiates work and the contractor was not willing to provide the software at

the price quoted, the initial purchase order was cancelled.

4. Administration of the LSN

During this reporting period, the LSN contractor completed development of a new and more

secure module for administering the content of the LSN web pages by LSN staff. This

administrative module enhances the LSN security posture by replacing the current

web-accessible version with one installed directly on NRC desktops. During May 2002, LSN

staff commenced acceptance testing of the new administrative module developed concurrently

with the new release of LSN.

5. Disaster Recovery Exercise

On April 16, 2002, LSN staff observed a disaster recovery exercise at the AT&T Ashburn,

Virginia facility that hosts the LSN servers. This was a dry run demonstration of the disaster

recovery component of the business continuity plan currently in place for the LSN. Although the

Ashburn facility was never actually taken off-line, all the resources necessary to do so were

marshalled and that facility’s preparations and performance were then compared to

benchmarks for the AT&T hosting facilities’ recovery timelines. The results were within AT&T’s

target for fulfilling the conditions of its service level agreements. Observing dry run exercises

such as this by government project managers is an element of performing GISRA-required

security assessments. 

6. Security Profile of the LSN

In February 2002, the National Security Agency (NSA) was engaged to plan and conduct a

vulnerability assessment on the LSN. NSA’s support included an overview of its information

security (INFOSEC) assessment; a high-level review to determine appropriate system security;

network evaluations (cooperative penetration testing in which NSA searches for all

vulnerabilities and recommends improvements); a “red team” (an adversarial approach similar

to the network evaluations, but with no advance notice); and documentation of recommended

improvements in a final report. On February 28, 2002, LSNARP TWG members were invited to

participate in the NSA pre-assessment process, to include information identification and

definition. A meeting with NSA representatives on the pre-assessment phase of the NSA

security vulnerability assessment was held on March 26, 2002, with LSN staff and LSN data

owners. Participants included NMSS HLW staff, a representative from the State of Nevada,

and teleconference attendance by the Nuclear Energy Institute (NEI) and Mineral County,

Nevada. A summary of the pre-assessment activities performed by NSA was distributed to the

LSNARP via e-mail.

LSN staff coordinated information and interviews for the LSN vulnerability assessment

performed by NSA, including coordination with OGC to generate an NSA-required memo to

provide agency permission for NSA to use a software tool to identify Internet vulnerabilities on
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the LSN site. The assessment was performed during the week of June 10, 2002. NSA

interviewed staff at the LSN contractor’s facility and at the AT&T Ashburn, Virginia facility at

which the servers that host the LSN are located. The final, written NSA assessment report is

expected in late July or early August 2002 and will be reported in the next semiannual report

covering activities for the period July-December 2002.

I. Native Americans Communications Plan

On March 27, the LSNA and Chief Administrative Judge Bollwerk attended a meeting with the

Office of State and Tribal Programs (OSTP) and NMSS to discuss initiatives, current activities,

and information resources that could be used in an effort to develop a consistent

communications plan for informing Nevada Native American interests about the LSN. A draft

LSN communications plan outlining coordination between internal offices, messages, media

products, and potential target offices was developed by the LSNA and was forwarded for review

by ASLBP management. Follow-on meetings will be scheduled after the LSNA integrates

information provided at this meeting and additional contact lists are finalized. 

II. Issues

A. Sensitive Homeland Security Information Issues Associated with DOE and

NRC Collections

Availability of the DOE and NRC HLW document collections via the LSN was held in abeyance

pending guidance for withholding sensitive homeland security information. A staff requirements

memorandum (SRM) was signed on May 28, 2002, approving proposed criteria for withholding

certain sensitive homeland security information from the public. The NRC guidance and its

implementation was documented in a June 17, 2002 memorandum from the Executive Director

for Operations (EDO), entitled “Withholding Sensitive Homeland Security Information.” This

information was provided to DOE and the public to provide insight into the screening criteria

that will be applied by NRC for its own HLW document collection that will be populated to the

LSN. 

However, the guidance provided in the above-noted SRM and EDO memorandum does not

address potential situations where a third party in the proceeding submits a non-redacted

version of a sensitive homeland security document already in their possession. A hypothetical

example is a DOE or NRC legacy document that, following homeland security review, the

Federal agency authoring the document chooses to make available in redacted form only, but

which the State of Nevada or other potential party already has as an un-redacted document in

their collection and chooses to post it. This action potentially makes the Federal agency’s

redaction ineffectual and the un-redacted version available via an NRC system. This situation

has been brought to the attention of the EDO by ASLBP per the direction provided in the

June 17 EDO memorandum and will be discussed at the September 2002 meeting of the

LSNARP. 

Additionally, with respect to sensitive homeland security information, the extent to which either

agency places additional restrictions upon the public availability of HLW documents may have
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an impact upon the LSN, as well as the Pre-License Application Presiding Officer and the

Commission, by generating additional disputes regarding the availability of HLW documents

that will have to be resolved on a case-by-case basis. See 10 C.F.R. §§ 2.1010, 2.1015(b)(1). 

B. NRC User Desktop Compatibility with LSN

As previously reported, LSN technical staff identified an issue associated with the standard

NRC desktop configuration and its display of TIFF images on a user’s workstation inside NRC. 

DOE TIFF image files are single-page images. The LSN views TIFF image files within the

Netscape web browser using a plug-in and has additional code to allow the user to move

between pages. Conversely, NRC’s desktop uses a separate executable to view TIFF image

files. These different approaches -- an executable v. a plug-in -- were reconciled. LSN staff

received approval from OCIO to install TIFF viewer (ALTERNATIFF) on NRC user machines,

and this issue is now considered to be resolved.

C. Consistency with DOE’s Yucca Mountain Schedule

LSN staff completed efforts to rebaseline the LSN project plan, including revised forecasts for

budget, schedule, and FTEs based on the latest estimated DOE license application filing date

of December 2004. LSN staff completed an analysis of LSN impacts, identified a strategy for

managing technology refreshment, and identified the funding issues associated with the project

budget. As noted above, this analysis was incorporated into ASLBP planning for, and

information provided during, the current budget cycle. The funding issues for technology

refreshment have been addressed in ASLBP’s FY 2004 budget request and FY 2003

reprogramming request. The LSNA will continue to monitor developments in the DOE LA

schedule and assess potential impacts on the agency’s HLW automation initiatives.

D. Adequacy of NRC’s ADAMS and EHD Infrastructure

As noted above, the LSNA met in February 2002 with representatives of OGC, NMSS, and

OCIO to resolve issues associated with data format requirements being proposed for the E-rule

covering nonadjudicatory submissions. Some E-rule data format guidance differs slightly from

existing HLW adjudicatory submission standards already detailed in 10 C.F.R. Part 2,

Subpart J. 

A number of meetings were held to address the issue of NRC guidance to DOE on the

submission of large documents. Participants have included NMSS, OCIO, SECY, OGC, and

ASLBP. These meetings raised the issue of the efficacy of the NRC’s current technical

infrastructure to deliver large, complex technical documents usable to HLW proceeding

participants and the public via the ADAMS-based EHD. Also, as noted earlier, the LSNA

accompanied OCIO, SECY, OGC, and NMSS representatives to an NRC/DOE Technical

Exchange in Las Vegas, Nevada, on June 25-26, 2002. Representatives from OCIO covered

the HLW-related EIE and the EHD capabilities, with the objective of identifying technical issues

associated with DOE’s electronic submission of its LA that is anticipated to be a very large,

complex document that could tax NRC’s current technology infrastructure capabilities. The
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OCIO-sponsored team will identify gaps in and solutions to NRC’s ability to accept and process

electronic submissions for discovery and the high-level waste proceeding.

Challenges exist and are being addressed at many levels to resolving the technical issues

associated with using electronic materials in the HLW repository proceeding. Arriving at

appropriate technical solutions is key to developing a comprehensive operational plan for

making the most effective use of EIE, EHD, and the planned electronic courtroom (DDMS). If

there are no clear technical solutions that can encompass all the affected systems, changes to

the NRC’s HLW license submission rule to accommodate existing agency technology or to

develop agency information management strategies to respond to the existing regulatory

environment may be considered further. As the target date for the DOE LA approaches, time

constraints inherent in implementing projects to augment existing agency IT systems may limit

the alternatives that can be considered if a selected solution is to be in place before the LA is

received. 

III. Future LSN-Related Activities

A. LSN Advisory Review Panel Meeting

Planning for a September 2002 LSNARP meeting to be held in Las Vegas, Nevada, was

initiated. The LSNA has identified a number of potential agenda topics including:

• LSNA progress report on LSN

• Results of system security risk assessment performed by NSA

• Demonstration of LSN production version 2.0

• Identification of participant LSN training needs and user expectations; possible

training strategies and approaches; points of contact for training coordination

efforts

• Proposed Revision 1 to Topical Guidelines 3.69 (Draft Regulatory Guide DG3022, published in the Federal Register for comment on July 2, 2002, 67 Fed.

Reg. 44478)

• Review of relevancy (requested by Clark County, Nevada)

• Role of a rural county in the licensing (distinction between party with standing,

interested governmental party, etc.) (requested by White Pine County, Nevada)

• The importance of participation in the LSN as a prerequisite for being a

participant in the licensing process (requested by White Pine County, Nevada)

• LSN public availability/access via NRC and DOE reading rooms and Nevada

libraries

• LSN system upgrade prior to LA

• Summary of June 25-26, 2002 NRC/DOE Technical Exchange on Electronic

Submissions

• Overview of NRC plans for digital courtroom environment

• Overview of NRC and DOE efforts to implement sensitive homeland security

information screening and impact on document retrieval and display.
- 14 -

COORDINATION:

The Office of General Counsel 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 and has no objections.

\RA\

Daniel J. Graser

Licensing Support Network Administrator

Atomic Safety and Licensing

 Board Panel
- 14 -

COORDINATION:

The Office of General Counsel 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 and has no objections.

\RA\

Daniel J. Graser

Licensing Support Network Administrator

Atomic Safety and Licensing

 Board Panel

Distribution

ASLBP

OCIO

Electronic Concurrences* See previous concurrence**

ASLBP** ASLBP/OD** NMSS/OD ADM/DC OCIO OGC OCFO/DPB

A/PAB

OEDO

D.Graser G. Bollwerk M. Virgilio* T. Hagan* S. Reiter* K. Cyr* T. Pulliam* W. Travers

09/04/02 09/04/02 09/05/02 08/19/02 08/21/02 8/20/02 08/09/02 09/19/02

OFFICIAL RECORD COPY