POLICY ISSUE

INFORMATION

August 7, 2007 SECY-07-0130

FOR: The Commissioners

THRU: E. Roy Hawkens

Chief Administrative Judge

FROM: Daniel J. Graser

Licensing Support Network Administrator

SUBJECT: LICENSING SUPPORT NETWORK PROGRAM ADMINISTRATION -

SEMIANNUAL REPORT

PURPOSE:

This is to inform the Commission, in accordance with 10 C.F.R. § 2.1011(c)(5), 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, 2007.

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, 2007 through June 30, 2007.

DISCUSSION:

I. Activities

A. Licensing Support Network Administrator (LSNA) and Staff

LSN Quality Assurance Auditor Roy Hardin, who had been on detail to the Office of New

Reactors, Division of New Reactor Licensing (NRO/DNRL), accepted a lateral transfer to that

office late last year. This transfer, in conjunction with the vacancy created in June 2006 when 

CONTACT: Daniel J. Graser, LSNA/ASLBP

301-415-7401
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another LSN employee took a supervisory position in the Office of Information Services (OIS),

see SECY-06-165, at 2 (July 27, 2006), reduces the ASLBP technical team dedicated primarily

to the LSN from three individuals to one. Unfortunately, a hiring freeze at the end of last year 

resulted in a delay both in NRO being able to finalize Mr. Hardin’s transfer into that organization

and in ASLBP’s efforts to begin the process of obtaining a replacement. Mr. Hardin, at NRO’s

request, was detailed to NRO until his transfer became effective on March 4, 2007, but this

effectively left no federal staff backup for LSN project management and technical operations in

Rockville. 

While completing the process for hiring a new LSN employee, ASLBP prevented a coverage

gap for the LSN quality assurance and deputy project manager duties that were performed by

the individuals in the two now-vacant positions by appointing Joseph Deucher, the Las Vegas

Facility Manager and Deputy Project Manager for the Digital Data Management System

(DDMS), to act as the LSN Deputy Project Manager. ASLBP anticipates selecting a new

individual whose duties will be primarily LSN-related by early in the fourth quarter of Fiscal Year

(FY) 2007.

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

Dr. Andrew Bates of the Office of the Secretary (SECY) continues to serve as the LSN Advisory

Review Panel (LSNARP) Chair. 

C. LSN Advisory Review Panel (LSNARP) Activities

No LSNARP meetings occurred during the reporting period. ASLBP personnel did meet with

staff from the Office of Nuclear Materials Safety and Safeguards (NMSS) and SECY in April

2007 concerning a possible LSNARP meeting in conjunction with a planned June 2007 NRC

workshop for the Affected Units of Local Government (AULG). At that time, it was decided that

convening another LSNARP meeting in the near term was likely to be contingent on whether

system performance problems were encountered when the second Department of Energy

(DOE) LSN document collection was opened in May 2007. Ultimately, as is discussed in

section I.H.2 below, there were no problems when that DOE collection was made publicly

available, so no meeting was necessary. 

While there are no plans for an LSNARP meeting in the immediate future, if a meeting does

become necessary it likely will be held in conjunction with other NRC or DOE meetings to

conserve travel resources. 

D. LSN Administrator Guidelines

No LSNA Guidelines were revised, and no new Guidelines were promulgated, during the

reporting period. The technical bases for LSN operations, including participant organization

technologies, remain stable.
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E. Interactions with Other NRC Offices and Entities

1. The Commission

The previous LSNA semiannual report was submitted to the Commission in January 2007. 

2. Office of Information Services (OIS)

Interactions with the OIS staff on LSN matters dealt primarily with efforts to obtain a Federal

Information Security Management Act (FISMA) Authority to Operate (ATO) certification, which

is discussed below in section I.H.3 of this report. 

On June 25, 2007, the OIS network operations staff changed the Internet Protocol (IP) number

for the NRC LSN server. Because the NRC uses the IP number (rather than a domain name

such as “nrc.gov”) as part of the URL, with this change the approximately 26,000 documents in

the NRC staff’s LSN collection became unavailable via the LSN. The availability of other

participants’ collections was not affected. At the request of the LSNA, OIS staff promptly

restored access to the documents on their LSN server by restoring the original server IP

number on June 27, 2007. LSN staff will work with OIS staff to avoid this problem in the future,

and a followup “lessons learned” meeting with OIS has been scheduled.

3. Office of Nuclear Material Safety and Safeguards

Interactions with the NRC staff on LSN matters dealt primarily with routine document collection

maintenance issues. 

4. Office of the Inspector General

There were no interactions with the Office of the Inspector General.

5. Office of Administration/Division of Contracts

Routine contracting actions for acquiring annual software maintenance agreements for the

LSN’s AutonomyTM search engine software are discussed in section I.H.2 of this report.

F. Interactions with DOE’s Office of Civilian Radioactive Waste Management 

on Its Efforts and Readiness to Meet LSN Commitments

The LSNA testified at a March 5, 2007 conference held by the Pre-License Application

Presiding Officer (PAPO) Board regarding the status of loading activities by all participants over

the past year. At that conference, DOE advised it intended to open up its then-unavailable

DOE II collection of over 2.1 million documents within 60 days, i.e., before May 4, 2007. Public

access to this collection was actually provided on April 30, 2007. 

At that conference, DOE counsel also indicated the window for certifying the entire DOE LSN

document collection had been narrowed to between October 1, 2007, and December 21, 2007. 

Subsequently, in a June 29, 2007 monthly report to the PAPO, DOE counsel indicated that its

LSN certification could occur as early as September 21, 2007. 
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During the reporting period, LSN staff worked with DOE representatives and contractors on

DOE’s effort to correct erroneous or missing information from bibliographic information posted

on both the DOE I and DOE II document collections. This effort was ongoing throughout the

late spring and early summer and is eventually expected to result in 1.5 million DOE

bibliographic records being revised. Also during this period, the LSNA routinely coordinated

with and monitored DOE’s compliance with PAPO Board orders regarding the timely removal of

text and image materials (but not the associated bibliographic entries) for documents found to

contain privileged, Privacy Act, or other sensitive information. These transactions resulted from

DOE efforts during the reporting period to perform relevancy and privilege reviews of

documents previously loaded on either the DOE I or DOE II document collections.

G. Interactions with Other Participants in Conjunction with Their Efforts to be

Ready to Meet LSN Commitments

As of this date, the following organizations have submitted LSN certification/compliance

statements to the high-level waste (HLW) repository licensing proceeding Electronic Hearing

Docket (EHD): NRC Staff; the Nevada counties of Lincoln, Churchill, Lander, White Pine,

Eureka, and Mineral; and Inyo County, California. Additionally, DOE submitted a certification in

June 2004, the validity of which was challenged by the State of Nevada.

On May 23, 2007, LSN staff provided LSN training in the Panel’s Rockville hearing room to

State of Nevada representatives from the Washington, D.C. area. 

On June 18, 2007, the LSNA met with two individuals from the Clark County, Nevada

Comprehensive Planning Department, both of whom will be taking over responsibility for Clark

County’s LSN efforts, to provide them with background on the LSN program.

The LSNA participated in a June 19-20 workshop for the AULGs conducted in Las Vegas,

Nevada by representatives from NMSS and the Office of the General Counsel (OGC). The

LSNA presented an overview of the LSN and its role in the automation efforts associated with

NRC’s preparation for potential HLW repository licensing proceeding. As a result of the

session, the LSNA received requests for additional training from Clark County and the Cities of

Las Vegas and Henderson, Nevada. Additionally, the LSNA was notified by a Nye County,

Nevada representative that a substantial number of documents will be added to the LSN by Nye

County sometime after August 2007. 

H. LSN Project Plan Implementation

1. Ongoing Upgrades and Expansion to the LSN

There are no upgrades to or expansions of the LSN production system currently underway. In

February 2007 LSN staff completed a test system upgrade, which allows LSN staff to more

effectively install upgrades and fixes (e.g., Microsoft program and security patches).

2. Administration of the LSN

Project management performance by the LSN staff continues to achieve planned system

milestones for user access, participant support, and document loading timeliness. Project
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spending for FY 2007 continues to be slightly under budget, and all budgeted funds are on

schedule to be committed well in advance of the end of the fiscal year. 

AutonomyTM is the text search and retrieval software used in the LSN. During May 2007, a

request for proposals (RFP) for annual AutonomyTM software maintenance was issued, and

bids were received by the Division of Contracts and forwarded for LSN staff evaluation. 

Subsequently, the new software maintenance contract was competed, awarded, and put in

place without any interruption in software maintenance. 

DOE opened a second collection of materials comprised of 2,130,340 documents (roughly 20

million pages) on April 30, 2007. As previously requested by DOE, that collection had not been

available to potential parties or the public for searching to permit DOE staff to complete

document QA activities. This second DOE document collection was successfully opened for

search and retrieval without significant incident. On the first day this DOE II collection became

publicly available, one search feature was found to be inoperative. The AT&T contractor staff

providing LSN operations and maintenance (O&M) support were able to identify the problem

and test and deploy a solution onto the operating system within six hours after the problem was

reported. Throughout the process of opening the second DOE collection, usage statistics were

closely monitored to ensure that all user response times remained satisfactory, and no

adjustments to either the LSN hardware or software were required. 

The following table presents cumulative performance metrics for the LSN during the reporting

period:

Licensing Support Network System Performance Metrics for the Reporting Period

January February March April May June

Number of Participants 15 (2

hidden)

16 (2

hidden)

16 (2

hidden)

16 (1

hidden)

16 (1

hidden)

16 (1

hidden)

Number of Documents 3,465,685 3,448,999 3,430,593 3,430,995 3,467,815 3,491,813

System Availability (Against

Schedule) 100% 100% 100% 100% 100% 100%

Number of Days with Outage

More than Four Hours 000000

The following table presents the net document additions/deletions per month, by participant:

Licensing Support Network Documents Added by Participant

Added

January

Added

February

Added 

March

Added 

April

Added 

May

Added 

June

Total Added

1/07

Through

6/30/07

Churchill Co. 0 0 7 0 0 0 7

City of Las Vegas 0 0 0 0 0 0 0

Clark Co. 0 0 0 0 0 0 0
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Licensing Support Network Documents Added by Participant

Added

January

Added

February

Added 

March

Added 

April

Added 

May

Added 

June

Total Added

1/07

Through

6/30/07

DOE I (18,986) 0 (1,132) 0 (1) 2 (20,117)

DOE II* 8,469 (16,699) (17,356) (160) 36,981 23,996 35,231

Esmeralda Co. - - 13 0 0 0 0 13

Eureka Co. 0 0 18 0 0 0 18

Lander Co. 0 0 40 4 0 0 40

Lincoln Co. 0 0 0 0 0 0 0

Mineral Co. 0 0 0 0 0 0 0

State of Nevada 0 0 0 0 0 0 0

Nuclear Energy

Institute (NEI) 00 000 0 0

NRC 1 0 0 398 0 0 399

Nye Co.** 0 0 0 0 0 0 0

White Pine Co. 0 0 0 0 0 0 0

Inyo Co., CA 0 0 17 0 0 0 17

Total (10,516) (16,686) (18,406) 238 36,980 23,998 15,608

*DOE II - LSN collection not publically available January - April 2007.

** Nye Co. - LSN collection not publically available throughout reporting period.

3. Security Profile of the LSN

No system downtime was experienced during the reporting period because of hacker attacks

directed against the LSN. 

In January 2007, the LSN project team began the process of obtaining FISMA certification and

accreditation (C&A) for the LSN. ASLBP committed to working with OIS to try to complete the

C&A process for the LSN by March 2007 as part of the agency’s effort to demonstrate progress

in its overall information technology (IT) security program. On February 7, ASLBP was advised

by the OIS project manager that MAR, Inc., the contractor supporting the agency’s C&A efforts,

had submitted a proposal that would escalate the cost of LSN C&A by 25 percent (an increase

of approximately $37K from an initial estimate of $161.5K). Additionally, initial C&A efforts

revealed that the LSN O&M contract with AT&T required a task modification and contract ceiling

funding increase to add additional IT security specialist labor hours to obtain required

information from the AT&T web hosting facility in Ashburn, Virginia. On March 9, based on

Senior Information Technology Security Officer (SITSO)-identified C&A information

requirements, the LSN staff submitted a statement of work and independent government cost
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estimate for a $300k contract modification to allow the AT&T LSN contractors to assist in

completing and maintaining the system’s C&A. As a consequence, LSN C&A activities were

put on hold as of the end of March. To facilitate contractor availability to work on this effort, the

OIS Director and the SITSO recommended that the Office of Administration waive the

Management Directive 12.3 requirement that AT&T contractor staff have an approved IT-1 or

IT-2 security clearance before they can bill to this C&A contract. While contract arrangements

were being made to facilitate AT&T support, an additional $200k was provided to the OIS MAR,

Inc. contractors developing the LSN C&A products. 

Work on achieving an LSN ATO resumed on April 26. Because the LSNA and the LSN staff

take very seriously complying with IT security requirements so as to achieve a full ATO as part

of the LSN’s annual Office of Management and Budget (OMB) 300B submission, we are

working to obtain an LSN ATO by September 30, 2007. Nonetheless, the LSN, which is

currently operating under an Interim ATO (IATO) that is valid through October 31, 2007,

continues to be an extremely secure IT system, due in large part to its original design

architecture, the web hosting infrastructure provided by AT&T, and the robust third-party

security services included in the turnkey AT&T O&M contract. 

On March 27, during a routine weekly technical discussion with DOE contractors, a potential

safeguards information (SGI) spill was identified by the LSNA. The matter was referred to an

OIS IT security specialist, who determined that a DOE employee appeared to have mis-spoken

in the conference call by using the wrong term to describe sensitive files residing on the NRC

LSN server. Because the three documents at issue are not sensitive material and were part of

a batch of non-sensitive files that were removed from the LSN server for administrative

reasons, this incident was closed out.

During February 2007, badged LSN contractor staff successfully completed mandatory IT

security training via OIS-provided DVDs. 

I. LSN Communication Plan Implementation

LSN Communication Plan activities during the period were those associated with the participant

interactions noted in section I.G above.

II. Issues

A. LSN Impact of DOE Document Collection Certification Under a Continuing

Resolution

DOE has indicated it intends to certify its LSN document collection sometime between

September 21 and December 21, 2007. This certification will trigger a number of activities,

some planned and others that can be anticipated, that will result in an increased tempo of

sustained activity for the LSN project staff. The activities we will support during the next

reporting period include:
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• Submission of sensitive Protective Order File (POF) materials concurrent with

each participant’s certification. These will be delivered to the LSNA for

subsequent processing into the DDMS.

• Submission of Employee Concerns Program (ECP) materials. These will be

delivered to the LSNA for subsequent specialized handling as directed by the

PAPO Board.

• Certification of LSN document collections by other potential parties. We expect

significant last-minute pre-certification efforts by potential parties, in particular

Nye County and the State of Nevada, to load large numbers of additional

materials and must be prepared to support them in resolving any problems

encountered.

• Requests for additional LSN user training sessions for many of the potential

parties.

• Potential challenges to certifications and disputes over the release of POF and

ECP materials. We must be prepared to support the PAPO Board in any

hearings conducted to resolve certification or access issues.

The above noted activities could occur during a period when the agency is operating under a

continuing resolution (CR). In the past, the Office of the Chief Financial Officer (OCFO) has

required offices to submit estimates of monthly budget requirements covering the first quarter

of the fiscal year, and funds for contract activities such as the LSN O&M contract are typically

made available on a monthly or even bi-weekly basis. This funding management practice, if

applied to the LSN operations during this period of intense activity, potentially will seriously

interfere with our ability to provide focused support to the adjudicatory activities that will be

under way. 

In response to an LSNA recommendation, ASLBP management intends to engage OCFO to

explore the possibility that, in the event of a CR, the entire block (or a substantial portion) of

contractor support funding for ASLBP HLW-related IT systems -- both the LSN and the DDMS -

- for the first half of FY 2008 be made available so as to minimize the number and frequency of

financial activities needed to provide ongoing and uninterrupted contract funds.

III. Future LSN-Related Activities

LSN Project Manager Matt Schmit will aggressively seek full ATO status for the LSN in

accordance with FISMA C&A procedures.

Prepare and submit the LSN 300B report to OMB.

Exercise the first of two option years for the LSN O&M contract.

Provide LSN training to NRC on-site representatives in Las Vegas on August 2, 2007, per their

request.
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Provide LSN training to representatives of Clark County and the Cities of Las Vegas and

Henderson on August 3, 2007, per their request.

Provide LSN training to AULG representatives in Reno/Carson City, Nevada, in late September

2007.

Provide LSN training to Center for Nuclear Waste Regulatory Analysis (CNWRA) and NMSS

staff in multiple sessions currently being scheduled throughout October 2007.

Meet with Nye County technical representatives to coordinate the loading of a substantial

number of its documents sometime after mid-August 2007.

COORDINATION:

The Office of the General Counsel has no legal objection.

/RA/

 

Daniel J. Graser

Licensing Support Network Administrator

Atomic Safety and Licensing

 Board Panel
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Provide LSN training to representatives of Clark County and the Cities of Las Vegas and

Henderson on August 3, 2007, per their request.

Provide LSN training to AULG representatives in Reno/Carson City, Nevada, in late September

2007.

Provide LSN training to Center for Nuclear Waste Regulatory Analysis (CNWRA) and NMSS

staff in multiple sessions currently being scheduled throughout October 2007.

Meet with Nye County technical representatives to coordinate the loading of a substantial

number of its documents sometime after mid-August 2007.

COORDINATION:

The Office of the General Counsel has no legal objection.

/RA/

 

Daniel J. Graser

Licensing Support Network Administrator

Atomic Safety and Licensing

 Board Panel

Distribution:

Commissioners

OGC

ASLBP

CFO

EDO

SECY

OPA

OCA

ADAMS: ML071930440 *See Previous Concurrence

ASLBP ASLBP/Editor ASLBP/OD OGC SECY

*D. Graser:DG *P. Bollwerk:GPB *E. Hawkens:ERH *M. Zobler for

K. Cyr

A.Vietti-Cook

07/12/07 07/12/07 07/12/07 07/24/07 07/ /07

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