ML20052F496
| ML20052F496 | |
| Person / Time | |
|---|---|
| Issue date: | 04/06/1982 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML19291F085 | List: |
| References | |
| FOIA-82-144 NUDOCS 8205130094 | |
| Download: ML20052F496 (1) | |
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Akb f, A. PROPOSAL TO PROVIDE TECHNICAL ASSISTANCE'?
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SAI Proposal 1-246-71-820-07
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than to evaluate the propos'al;.provided thatlif 'a co'ntract is awarded ?to
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this offeror as a result ~ of or in' connection with the' submission of.this&*~'.2s Gr7~.ll the data to the extent provided in the contra'ctGTh'is' FiistrictioriToes.y $d@-
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may be released, disseminated, or otherwise disclosed by the NRC~ pursuant.f ff to a Freedom of Information Act request..
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_._-1, ADDENDUM A PROPOSAL TO PROVIDE TECHNICAL ASSISTANCE IN SUPPORT OF THE NRC REACTOR LICENSING PROGRAM Responses to NRC Questions Representatives of the NRC and SAI met on August 27, 1981 to discuss specific NRC questions related to SAI's proposal of August 6, 1981.
This addendum has been prepared in response to NRC's requsest for written confirmation of sal's responses to the questions discussed at this meeting.
As an aid to the reader, the addendum format presents each question posed by NRC followed by SAI's response.
Additional supporting or clarifying information has been incorporated to supplement the responses provided verbally during the August 27, 1981 meeting.
Technical understanding and the proposed SAI approach are not altered by the addendum.
It should be noted that in preparing this addendum, SAI has given particular attention to addressing those questions related to nuclear regulatory experience, project organization and staffing.
The following responses clearly demonstrate:
(1) the depth of staff knowledgable and experienced in the nuclear regulatory process; (2) the adaptability and flexibility of the proposed project organization and staff; and (3) SAI's corporate commitment to this important NRC program.
SAI proposes a staff possessing broad and varied experience related to
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technical licensing issues.
Related experience includes such projects as fuel cycle licensing support provided to NRC-NMSS.
Over the last eighteen months SAI has provided technical evaluations for NRC licensing dec is ions.
Fourteen separate actions have been assigned to SAI in such areas as low level waste storage for reactor sites, renewals of fuel cycle licenses, amendments for
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expansion, and seismic capabilities of spent fuel storage racks.
Other projects and individual staff experience are delineated in our response.
SAI has proposed a
project organization and manageme'nt system fully responsive to the particular circumstances associated with providing technical support for the Office of Nuclear Reactor Regulation.
l SAI will provide a dedicated technical and management team located in our McLean, Virginia f acilities.
It is SAI's intent to perform approximately 90%
l of the assigned tasks at this f ac ili t y.
This core technical staff can be q'
supplemented by additional SAI engineers working in energy related activities or by subcontractor personnel.
Depending on the nature and volume of licensing actions, McLeanstaff will be augmented through relocation of existing SAI staff or recruitment of new personnel.
Clos; proximity of the SAI team to the NRC 1
Bethesda offices will enhance communication and provide the quality support j
l necessary for successful performance of this project.
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Question 1:
Discuss further the relationship of past contracts at SAI to this contract.
SAI has successfully completed over a dozen projects, over its 12-year
- history, that involve and demonstrate our familiarity with the technical and regulatory issues that must be addressed for this contract.
These projects performed for the Nuclear Regulatory Comission (NRC), the Department of were Energy (DOE) and its predecessors, and the DOE National Laboratories.
Many of the projects for the National Laboratories were in support of their programs for the NRC and are directly related to licensing issues for reactors and fuelcycle facilities.
By way of example, SAI has performed numerous reviews of licensing submittals for fuel cycle facilities.
This work involves interaction with the licensees, working in conjunction with NRC licensing managers, and the development of requests for additional informatic.n.
The experience gained on l
these ongoing efforts is a direct demonstration of our familiarity with the l
licensing review process and the interactions that are required.
We have also performed a review of the licensing procedures used by the l
NRC staff for byproduct and radioactive material licensees. This effort made f
reconmendations for improvements and also resulted in the preparation of an I
environmental assessment of the impact of consumer products containing raJioactive material.
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SAI staff have participated with team members from NRC and National l
Labs to provide vital area analysis for several nuclear power plants.
These reviews require detailed knowledge of the operation, design, and engineering of i
the entire plant.
We have participated with NRC and other federal agencies in i
j the evaluation of emergency response plans for power reactors.
We have developed j
methodologies for use by NRC in the evaluation of specific licensing submittals I
involving low-level radioactive waste and are currently developing techniques for I
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.a the orderly construction of reactor system fault trees as a part of the Interim Reliability Estimation Program.
Our staff has not performed licensing reviews directly for NRR.
5 However, our familiarity with the issues and the technologies involved has been demonstrated by our participation in a variety of directly related projects.
Our staff is keenly i
aware that the reviews to be performed under this contract are not research projects, but rather are aimed directly at providing technical assistance to NRC to help reduce the licensing backlog.
Question 2: Discuss your recent turnover rate as it may affect this contract.
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Discuss the depth of your nuclear regulatory experience.
Many staff members proposed for this
- effort, including the Pro. ject l
Manager, have directly applicable licensing experience.
Some of this experience has been gained with previous employers and has continued at SAI.
Five of the f
proposed lead engineers have recent licensing experience, but have limited direct I
NRR involvement.
For example, SAI anticipates extensive review activity in the reactor systems area.
Problems associated with systems analysis, thermal hydraulics, i
containment response, and systems interactions fall under the ourview of
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P Many of the proposed staff members and lead engineers have contributed to the 14 separate licensing tasks performed as a part of our fuel cycle licensing support to NRC.
SAI staff, primarily located in our McLean f acility, have been conducting technical evaluations for NRC licensing decisions regarding low level waste storage at reactor sites, renewals of fuel cycle licenses, 5
m amendments for expansion, and seismic capabilities of spent fuel storage racks at West Valley.
Currently, we are interf acing with TVA and PP&L regarding LLW storage at Browns Ferry, Sequoyah and Susqueh anna.
In addition to preparing requests for additional information, participating in meetings with, licensees and conducting site visits, SAI staff have interfaced with State and local government i
officials.
We have performed several reviews of the physical security and material control and accounting procedures for licensee f acilities and have prepared technical reports of our findings.
We have carried out a multi-year program for the NRC which resulted in an environmental assessment of consumer products containing radioactive material.
This project involved many, if not all, of the elements that are necessary for the proposed efforts. With NRC support, we obtained information from licensees relating to the manuf acture and distribution of their products and thus provided SAI with an experience base of dealing with licensees and their licensing managers.
We performed a review of the licensing procedure used by the NRC for this activity and made recomendations for improvements.
We also prepared for the NRC relating to questions of radioactive materials in consumer responses products. In many cases, following NRC direction, SAI staff members responded directly to public and media questions.
SAI has performed several
- tasks, under contract with the National l
l Laboratories, which were directed toward licensing rela'ed activities.
These include participating with NRC and Laboratory personnel in performing vital area analysis and physical security reviews for several nuclear power plants.
This effort required familiarity with plant design and operation as well as the ability to effectively interact with licensee personnel. We participated, with NRC personnel, as a part of the " concurred in" review process of emergency plans at nuclear f acilities, and state / local government.
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In addition to the activities describi.d
- above, SAI has developed methods to be used by the NRC to provide site screening reviews for low-level waste sites.
Modeling techniques resulting from this effort are currently being used by SAI in performing licensing reviews for on-site storage of radioactive waste. We are also developing a procedure to allow the orderly construction of fault trees as a part of the Interim Reliability Estimation Program.
This methodology development activity requires detailed knowledge of the design and operation of the various systems in nuclear plants.
SAI staff have the necessary understanding of the role of the independent reviews that are required for the proposed program.
We have the demonstrated experience in providing such reviews for the NRC licensing staff.
Our experience as a corporation and the experience of our staff working together on these types of problems provides the NRC with a unique team to perform the work indicated in the proposed program.
SAI staff members have performed several programs which have addresse specific licensing concerns. These efforts have been performed for and some utilities.
Specific issues addressed involved the impact of turbine missiles and tornado hazards on the safe operation of the plants.
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We have also provided on-site quality assurance support for several utilities.
Question 4: With regard to the designated Project Manager, (a) How much of the proposal was prepared by him personally (with particular emphasis on technical understanding of the regulatory process and this contract, and the management plan) and (b) Discuss the effect his absence might have on the performance of this contract.
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i Contributions were made to the proposal by nine people.
It is estimated that Richard Starostecki personally prepared about 10 percent of the total proposal and about 20-25 percent of the technical understanding chapter and of the management plan, respectively, i
The Project Manager is one of eight key personnel on the SAI team.
t This team of personnel provides a responsive project organization possessing both an understanding of the NRC licensing process and extensive knowledge of the technical issues.
The work to be performed under this contract involves a variety of technical disciplines.
It is also deoendent upon inputs from licensees regulated by the NRC and may therefore place the NRC in an adversary relationship with the nuclear utilities relative to new requirements or additional inquiries. Although the ultimate responsibility for the safety of a licensed reactor facility is with the licensee, NRC has a mandate to verify the safety and adequacy of such plants.
Consequently, time spent by utilities in processing NRC forms or letters represents to the utility a drain on its resources. To minimize the adversary relationship, therefore, discussions with licensees must be well
- focused, understood and directed toward a well defined result. The regulatory process is complicated not only by the broad number of technical disciplines involved but also by a unique relationship between the regulator and the licensee.
l Introducing a third party, such as SAI, in the role of a technical support contractor to NRC could greatly assist in the communication effort.
SAI believes 1
that the proposed key personnel, who are senior engineers, will play a vital role i
in f acilitating effective communication and, thus, help ensure the success of the h
program.
The Project Manager must be an effective manager and provide an effective interface with NRC.
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Subsequent to the submission of SAI's proposal and, SAI's presentation a
on August 27, 1981, SAI management was informed that Rich Starostecki, the proposed Project Manager, was joining the NRC.
As discussed in the orals, SAI has a sufficient number of proven-effective managers with regulatory experience 8
to perform successfully on th is program.
Senior SAI management will take an active role in insuring that we are successful.
Dr. Bryce Johnson is proposed as the new Project Manager..
Dr. Johnson has worked for the AEC on reactor licensing issues and has, over the past seven years, worked with several utilities in the area of turbine missile analysis.
This experience, including testifying before the ACRS and in writing topical reports and responding to questions from NRC, is directly applicable to this project.
In addition, Dr. Johnson has demonstrated his project management capability in controlling costs and in meeting project schedules.
Dr. Johnson will be relocated to the McLean office to manage this project.
His resume is attached.
In addition to Dr. Johnson, other_SAI staff with experience and demonstrated bility to nianage the project are Resumes for these staff are also included.
s As part of our normal staffing activities, SAI continues to interview experienced staff in all technical disciplines.
The growth of SAI over the years demonstrates our ability to identify and attract key staff members.
Two potential employee's who have expressed an interest in. joining SAI have over five years of reactor licensing experience; one as a licensing project manager with
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NRC and one as a licensing engineer with a reactor vendor.
Due to the timing of NRC's recruiting of Mr. Starostecki, there have been no firm commitments to I
j senior potential employees who would participate in this project.
Although SAI's i
proposal is not dependent on hiring new staff, additional experienced staff have h
been identified, have expressed a strong interest, and are available.
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Question 5: Cl arif y the role of the Lead Engineer (LE).
Discuss the relationship of the LE's with technical line management as to review and direction of work.
SAI has proposed a matrix organization for this project.
The Lead Engineers (LE's) are senior SAI staff in their respective disciplines. These (LE's) in general do not have line responsibility within SAI for all work in their particular discipline since SAI is not organized by technical discipline.
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The LE is responsible for assuring the continuity and the quality of technical work in his technical areas. He is the equivalent of a Section Leader in NRC or a Group Leader in other organizations.
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The Lead Engineer, as a technical professional, will be an active i
participant in the review process of licensing actions. He may also servr as a Task Engineer for individual actions.
When a task is comprised of several similar licensing actions for a single generic topic, the Lead Engineer will have overall responsibility for the task. He will assign individual actions to Task Engineers.
The urgency and number of individual actions will determine the number of Task Engineers assigned.
Question 6: Are all the project people located in McLean? If not, which peoole are not? How do you plan to integrate and control their efforts?
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's SAI's intent to provide NRC with a dedicated technical and i
It management team centered in our McLean, Virginia f acility.
The management of the project team will be conducted by the Project Manager who will be located in our l
McLean office. The Project Manager will have administrative and contractual i
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suppo t provided at the same office. This assures maximum responsiveness to NRC's technical, administrative, and contractual needs.
Within the Energy Systems Group McLean office there currently exists a core group of technical staff who will be made available upon contract award.
This staff includes j'
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r nuclear engineers, chemical engineers, physicists and system engineers as well as human f actors staff.
Depending on the nature and volume of licensing actions,
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all can actively participate in performing technical evaluations.
The geographical distributiin of the staff members listed in the La proposal is as follows:
McLean, VA 25 percent La Jolla, CA 40 percent Oak Ridge, TN 25 percent Others, including subcontractors 10 percent SAI intends to perform 90 percent of the work with staff located in
- McLean, VA, As the tasks assigned by NRC become better defined, SAI will relocate staff to McLean to provide the close comunication that is required to insure that the project runs smoothly and that information is transmitted between In the first few months of the effort, work will NRC and SAI in a timely manner.
o be performed by the appropriate staff regardless of location.
geographic distribution of key project personnel is as Currently, the follows:
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i In other similar projects, such as the fuel cycle licensing support effort for NRC, the work on a task is performed in one geographic location; that of the task leader. No difficulties have been experienced in comvications between the task leaders and the Project Manager or between SAI and NRC. Concern
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of potential problems will be diminished as staff are transferred to McLean.
Question 7:
Provide a breakou t and composition of costs associated with projected subcontracting effort.
The potential subcontractors have provided details of their cost elements.
SAI plans to subcontract portions of the contract effort to the extent practicable, consistent with good business practices and NRC program requirements.
k Small, women owned, minority and economically disadvantaged firms have been solicited to submit qualification statements and cost schedules.
This will g
be a continuing process and will follow the procedures set forth in our subcontracting plan.
Upon award of a contract to SAI and issuance of task orders, SAI will solicit formal proposals from qualified firms including all t
necessary cost and contractual data.
Selection of subcontractor personnel will be based upon gradetermined technical and cost evaluation criteria.
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The dollar value of subcontractor efforts will depend strongly na ture and type of tasks assigned by NRC.
Prior to initiation of a request for I
work to be proposal for subcontractors, SAI will propose to NRC management the subcontracted and obtain tentative approval.
Prior to the issuance of any
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subcontract, NRC must approve the proposed action, including the cost, of work, and schedules.
A subcon tracting plan has been submitted for NRC I
approval.
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Question 8: Discuss the extent of negotiations, if
- any, with proposed subcontractors and how you will ensure that such costs are valid, reliable, and reasonable.
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All subcontractors have been told that the level of effort that they may expect will be dependent on the tasks assigned by NRC. No subcontractor has been told they will be awarded a contract on a sole source basis, and it is SAI's intent to obtain estimates from more than one subcontractor on a specific task.
To ensure that subcontractor costs are valid, reliable and reasonable, 7
SAI will utilize its standard purchasing and subcontracting procedures.
Cost or price analyses will be performed and cost comparisons with internal estimates and prior similar procurements will be made.
Rate verification with government customers and audit assistance by DCAA or SAI Internal Audit will be undertaken when required. All pertinent information will be forwarded to NRC with request for subcontractor approval.
Our experience in working with subcontractors on other projects (SERI, DOE, etc.) has helped us develop the procedures to issue request for proposals, audit cost and pricing data, and monitor both financial and technical d
performance.
It is our intent that subcontractor personnel will work as an L_
significant part of their time in SAI's extension of our staff and spend a
office. The potential subcnntractors are easily within commuting distance of SAI r*L offices and no communications problem or loss of efficiency due to lack of
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direction is expected. Quality control of the work will be performed by SAI p
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"* O Cost and Contractual Clarification SAI has reviewed the sample NRC Award Fee Determination P.lan and - finds it compatible with the SAI Plan submitted 6 August 1981.
The criteria established by NRC are in agreement with those proposed by SAI.
Direct labor rates proposed and the escalation factor applied to those base rates for this multi-year program are approved by DCAA.
These rates are
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