ML20045G560
Text
pu%
,0coh-9 g
4 UNITED STATES g
j('
g NUCLEAR REGULATORY COMMISSION
- y WASHING TON. D. C. 20555
},,
g
/
OCT 311990 gOROV ~2 g;;19 9, tuu..
'"M
' P l-jj MEMORANDUM FOR:
Mary Lynn Scott, Chief Policy Branch Division of Contracts and Property Management Office of Administration FROM:
Brenda Jo. Shelton, Chief Information and Records Ma~nagement Branch Division of Information Support Services Office of Information Resources Management
SUBJECT:
PAPERWORK {0NCERNS ON 48 CFR 20, ACQUISITION REGULATION (NRCAR), FINAL RULE We have reviewed the Statements of Consideration for the subject rule as they relate to concerns submitted by the Office of Federal Procurement Policy and by the University of California.
It appears that six paperwork concerns have not been addressed in the rule, and that four have not been adequately addressed.
These concerns must be addressed before OMB will approve the paperwork requirements. Enclosed is a list of these concerns with.our comments indicated.
Please submit an OMB clearance package that addresses all the paperwork re-quirements contained in the final rule. This is necessary because OMB did not approve the information collection requirements at the proposed rule stage.
Please ensure that all of the requirements are addressed. The clearance package submitted,for the proposed rule was incomplete, e.g), it did not include ll2009.570-3(b)(1-), 2009.570-5(b),- 2009.570-3(4){ii, and.2014> 201-670. The OMB clearance package must be submitted to 0MB before the NRCAR is published in the Federal Register.
If you have any questions or wish to meet and discuss our concerns further, please call Beth St. Mary on extension 28540.
Ab Y ie nda o.
Informa ion and Records Management Branch Divisi of Information Support Services i
Office of Information Resources Management i
Enclosure:
As stated l
i a]
g.
9307140122 930608 PDR PR v
48C2057FR61152 PDR 3
93aDRESSED PAPERWDRK CJMCE,RNS ComENT g
REFERENCE g
A s
$;t 9 p j (,1'/ Statutory citations should ref er to exact codif ed sec g?
' > ^ 0 PP possible, in order to reduce burden on user to find authorizing
..?lr provisions.
(There are numerous occurrences in the rule.)
J
- ,A OfPP /. ed>b09.570-3(b)(1)Moesnotclearlystatewhat information is to be reported, making b-J-
11 impossible to calculate the information burden os 3
' /,2ib9 57Q 3(c) /
Contains instructional language that should be excluded from
_g
/
d"0FPP.
' ' F, A NRCAR and issued through manual chapters, directives, etc.
~
f 4)s (Inclusion in NRCAR is duplicative.)
OfPP
[2009.570-3(c)(4) Contractor is required to report all proposed usages. This is P.' I
- (11) potentially very burdensome. It is sufficient to pr'>hibit usage c'
pawn
'f(.
of the information.
y j
< < N '. (W,;
0FPP 2009.576-5(b)
Recommend elimination of provision authorizing contracting
\\,
officer to recuest information in unfair competitive advantage situations.
/0F PP 2014 201-670 What is the reason and authority f or reoviring inf ormation on the responsibility of all prospective contractors when FAR 9.105-1 s
states it is normally limited to the Icw bidder or those in the y'e' range for award?
s' EalECCATELY ADDRESSED PAPERWORK CONCERNS EDW ENTOE REFERENCE COFtiENT 1RM CONCERNS U. of Ca.
2027 305-3 FAR as 27.305-3(a) reovires that No change was made. A (Addressed in subject inventories be identified negative declaration should rule. p 7) and diselosed NRC goes beyond be obvious if a positive t*at and reoutres a negative declaration is reautred.
declaration an addition No justificatice was
/.
p'evided as to why a negative declaration is neer: i i.,,
OFPP 2042 803(b)
It may be onerous to allow the Stated in rule no change (Addressed in gevernment to take six months to Reason fcr *no change" 15 rule, p 7.)
resolve a disputed item especially adequate. however, there is for small businesses Change to 30 a change
- 1. werding for the t
days worse Governrent was to resclve within six months Rule has tace :'anged to
/
- sin r.;o e t '. :. 11 possible,"
allowing the sc.ernment potentially e longer cerac: 4cr c w ?ot or UFPP x2052 2C9-77 "Centractor shall disclose all Nc char ge as race Ae> c'
/ (Addressed in p : Msec work of any tyce" is is inssi'acleat 0FPF rule, p 8) e n t r emefrly br0ad and burdenscee suggest1Lr was rot 0,'.
Should be " disclosure of new work addressed 0
that 15 the same as or substantially similar to."
(This should be sufficient for cetermination of conflict of irterest.
OFPP &
2052.212 70.
Why are monthly reports reovired?
No change was made. No U.
of Ca.
.71 and 72 This is very burdensome unless justification for need of __
(Addressed in justif ied by some specific need NRC deviation was rule, p 9-10) 15 11 c onsi s t ent with OMB Cir. A-1107 indicated, nor of report Report due date of 15 days after due date.
close of reporting period as unjustified.
M' $
- p.X C nk fu o f t'g '
c o m ~t t o S A -O L
(-
~ '
<* '~
j an.
as Lw'-
" ({s. V; m
- l c o.
e q,,,.,
l
-. a