ML20056G491
| ML20056G491 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1993 |
| From: | Mattia M NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Cohen S S. COHEN & ASSOCIATES, INC. |
| References | |
| CON-FIN-L-1985, CON-NRC-04-93-058, CON-NRC-4-93-58 NUDOCS 9309030182 | |
| Download: ML20056G491 (7) | |
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UNITED STATES n
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E NUCLEAR REGULATORY COMMISSION
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RA M 0 4 1993 i
Sanford Cohen & Associates, Inc.
Attn: Sanford Cohen President 1355 Beverly Road, Suite 250 McLean, VA 22101
Dear Mr. Cohen:
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Subject:
Contract No. NRC-04-93-058, Task Order No. 3 Entitled, "Rulemaking Support For Decommissioning Nuclear Facilities"
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This confirms the May 21, 1993 verbal authorization provided to David Goldin
- of Sanford Cohen & Associates, Inc. to commence work effective May 24, 1993, L
under the subject task order with a temporary ceiling of $3,800.
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In accordance with Section G.4 entitled, " Task Order Procedures" of the l
subject contract, this letter definitiaes Task Order No. 3.
The effort shall l
be. performed in accordance with the enclosed Statement of Work.
l Task Order No. 3 shall be in effect from May 24,1993 through May 30, 1995, 1
l with a total-cost ceiling of $393,916.19 which is inclusive of the $3,800 i
temporary ceiling authorized on May 21, 1993. The amount of $361,391 l-represents the total estimated reimbursable costs and the amount of $32,525.19 represents the fixed fee.
The' obligated amount of this task order.is $317,725 which remains from what was obligated on the basic contract under FIN No. L1985 for the purpose of issuing task orders. This amount shall not be exceeded until notice is provided to you that additional funds are available.- It is estimated that this ~ obligated amount will cover performance of work through September 30, 1993.
Accounting Data for Task Order W. J is as follows:
APPN No.:
31X0200.360 B&R No.:-
36019401200 FIN No.:.
L1985 OBLIGAIED AMGUNT:
$317,725 B0C:
2542 L
RES IDENTIFIER:
RES-C93-364
'The following individuals are considered to be essential to the successful performance of work hereunder:
David Goldin and Steven A. Schaffer.
f The contractor agrees that such personnel shall not be removed from the effort under the task order without compliance 'with Contract Clause H.1, Key Personnel.
f 9309030182 930604
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NRC-04-93-058 Task Order No. 3 l
Page 2 l
Issuance of. this task order does not amend any terms or conditions of the I
subject contract.
Your contacts during the course of this task order are:
Technical Matters:
Clark Prichard Project Officer 1
(301) 492-3734 i
Contractual Matters:
Edna Knox-Davin Contract Administrator (301) 492-4731 Please indicate your acceptance of this Task Order No. 3 by having an official, authorized to bind your organization, execute three copies of this document in.the space provided and return two copies to the Contract Administrator. You should retain the third copy for your records.
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If 'you have any questions regarding this matter, please contact Edna Knox-l Davin, Contract Administrator, on (301) 492-4731.
Sincerely, g~
Mary Jo Mattia, Conthir.g Office-Contract Administration Branch No. 2 Division of Contracts and Property Management Office of Administration
Enclosure:
As stated l
ACCEPTED:
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Att. 1 STATEMENT OF WORK S. Cohen & Associates, Inc.
Contract NRC-93-058, Task 3 RULEMAKING SUPPORT FOR DECOM4ISS ONING OF NUCLEAR FACILITIES 3
BACKGROUND Decommissionir.g is defined in the Commission's regulations as removing a facility safely from service and reducing residual radioactivity to a level that permits release of the property for unrestricted use and termination of license. Currently, NRC uses an existing patchwork of guidance for decommissioning of facilities on a case-by-case basis. The NRC is preparing to initiate a rulemaking process to establish radiological criteria for the decommissioning of NRC-licensed facilities. The facilities that would be covered by such a rulemaking would include nuclear power plants, non-power reactors, fuel fabrication plants, uranium hexaflouride production plants, independent spent fuel installations, and materials facilities. According to the requirements of the NEPA and~ of the Commission's regulations in 10 CFR Part 51, this rmlemaking needs ;to be accompanied by an environmental impact statement.
In addition, this rulemaking must be accompanied by a regulatory analysis.
OBJECTIVE The objective of this work is to provide technical assistance to the Office of Nuclear Regulatory Research in preparation of a Draft and Final Generic Environmental Impact Statement and in preparation of a regulatory analysis to support the rulemaking on radiological criteria for decommissioning. To the extent possible, technical information should also be developed which can serve as input to a Regulatory Flexibility Certification, an OMB Clearance Package and a Paperwork Reduction Act Statement.
WORK REOUIREMENTS Task 1 c
The contractor shall provide technical assistance in preparation of a draft GEIS to support the rulemaking described above. The draft GEIS shall be prepared in a manner which adheres to the general and content requirements of 10 CFR 51.70 and 51.71, and to the format requirements of Appendix A to 10 CFR Part 51. The schedule of deliverables for the following tasks is listed below in the " Deliverables" section.
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4 Specifically the contractor shall:
1.
Identify and provide a preliminary assessmant of the rulemaking alternatives to be evaluated in the GEIS. Appendix A.5 of 10 CFR Part 51 indicates that all reasonable alternatives will be identified.
Alternatives to be considered shall be discussed with the Task Manager.
Based on-the identification and preliminary assessment of alternatives,
~ he contractor shall recommend rulemaking alternatives to be evaluated tfully in the GEIS; 2.
Provide assistance in the EIS scoping process required by 10 CFR 51.26 as follows:
. a) Provide, as necessary, technical input to the notice of intent for the scoping process as required by 10 CFR 51.27; b) Attend the scoping meetins indicated by 10 CFR 51.27(a)(4);
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c) Analyze:and provide a su%f of comments received on the scoping process as required by 10 CFR 51.29(b);
- 3. - Provide an outline of the GEIS confoming to the requirements of Appendix A of 10 CFR 51. indicating the infomation to be included in each EIS section, the generic facilities to be covered, and the infomation needs to be resolved;
- 4. - For the rulemaking alternatives identified in #1 above, perfom the following tasks:-
a) Evaluate the impacts, in individual and collective dose, associated with the rulemaking alternatives. Dose methodology to be used in the evaluations should be taken from NUREG/CR-5512, Volume 1 (October 1992). Dose conversion factors to be are scheduled to be supplied to the contractor by July 1993.
The overall approach for establishing criteria shall be discussed with the Task Manager; b)' Evaluate the costs associated with the rulemaking alternatives. This
--shal1~ include a summary analysis of the major procedures and associated costs of decommissioning, and a detailed evaluation and written analysis of the r;pecific procedures and costs which would be sensitive to the
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rulemaking alternatives. This. detailed evaluation shall include, for each of the-facilities' types indicated above in the Background section, (1) a generic analysis-(complete with technical basis and references l.
from the technical literature) of.the decommissioning procedures and associated costs necessary for achieving alternate radiological criteria for contaminated structures and land. Specific supporting technical l'
information will be supplied to the contractor for its use in the overall _ cost assessment.
%; and (2) an evaluation of the L
detection capability and costs associated with characterization surveys and with termination surveys to demonstrate that alternate radiological criteria _have been met; and (3) an evaluation of the uncertainties in this generic analysis and the range of possible contamination, and 2
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associated decommissioning and survey procedures and costs, at facilities covered by this rulemaking; c) Based on the results of Tasks 1.4.a and 1.4.b, provide a comparative analysis of the costs and impacts associated with the rulemaking alternatives. Based on that analysis provide a preliminary recommendation regarding the proposed action. This preliminary recommendation is required by 10 CFR 51.71(e);
I 5.
Using the information developed in Tasks 1.1 through 1.4 above, complete preparation of the draft GEIS by providing written and analytical material as necessary to conform to Appendix A of 10 CFR Part 51 regarding the format of an environmental impact statement.
l Task 2 The contractor shall provide technical assistance in preparation of a regulatory analysis to support the rulemaking described above. The regulatory analysis shall be prepared in a manner which conforms in format to the guidance available in NUREG/BR-0058, Revision 1, " Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, May 1984. The regulatory analysis shall include the following distinct sections: Statement of the Problem; Objective: Alternatives; Consequences (costs and benefits of rulemaking alternatives, impacts on other requirements, constraints); Decision l
Rationale; and Implementation. The discussion of alternatives, costs and benefits, and decision rationale can draw directly from the analysis and j
written material prepared as part of Task 1.
Task 3 Using the analyses performed for Task 2, the contractor shall provide the necessary supporting information for the Regulatory Flexibility Certification and Paperwork Reduction Act Statement.
Task 4 Based on development of the work in Tasks 1-3 and as directed by the Task Manager, provide technical expertise,by written comment or in discussion with NRC staff, either at NRC headquarters or by telephone conference call, related l
to the GEIS analyses to assist the staff of the Office of Nuclear Regulatory l
Research during review of the GEIS and regulatory analysis by other NRC staff, l
by NRC management, and by the EPA.
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Jask 5 Following the public comment period on the draft GEIS and as directed by the Task Manager,: the contractor shall prepare technical input for responses to public comments for inclusion in the Final GEIS. The contractor shall then L
provide technical input for preparation of a Final GEIS and final Regulatory j
Analysis to. support the decommissioning rulemaking.
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' REPORTING REOUIREMENTS l
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1he Contractor shall prepare tecimical progress reports and finamial status l
reports in accordance with subsections F.2, F.3, and F.4 of the basic l
contract and as stipulated below:
Submit senthly letter status reports in three copies, one each to the NRC l
Contracting Office, the Project Officer, and the technical monitor. The i
reports shall include a summary of work Imrfomed, problems encountered and how they are to be or were msolved; werc elements not perfomed as scheduled i
and the reasons, and a detailed' summary of costs incurred. The report shall be submitted by the 15th of each month.
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RE0UIRED EXPERTISE j
The pmject manager assigned to this project shall have extensive background
- and experience in health physjes, radiation protection, and be knowledgeable regarding the NRC licensing had environmental review process, the NEPA pmcess, and cost-benefit analyses.. Individuals assigned to this pmject to evaluate _ dose impacts shall have extensive background and experience in health physics and assessment of radiation exposums and health and safety 1spacts l
from radioactive materials.
Individuals assigned to this project to evaluate decommissioning costs shall have extensive background and experience in cost evaluations, decommissioning technology, and cost-benefit analyses.
l-DELIVERABLES i
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Deliverables include:
l 1.
The contractor shall deliver to the NRC written technical input to the
. notice of intent for the scoping process by May 15, 1993; the contractor i.
shall deliver to the NRC a written analysis and summary of comments received on the scoping process by August 15, 1993.
i 2.
The contractor shall deliver to the NRC a prelimina1*y, a draft, and a final DGEIS. The preliminary DGEIS shall be due September 30, 1993.
The Task Manager will provide comments.on the preliminary DGEIS to the contractor by October 15, 1993. Based on comments by the Task manager, the contractor shall provide fifteen (15) copies of a draft DGEIS by October 30, 1993; The contractor shall revise the draft DGLIS based on NRC-staff and EPA comments to be provided by the Task Manager by January 30,11994. The contractor shall deliver to the NRC a final DGEIS by February 28, 1994.
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The contractor shall deliver to the NRC a preliminary, a draft, and a j
final regulatory analysis (RA). The preliminary RA shall be due by i
September 30 1993, and shall contain: (a) regulatory impact analysis suitable for inclusion in an NRC rulemaking package; (b) a separate appendix containing the backup and detailed support for the conclusions of the.value-impact analysis (reference to analyses in the draft DGEIS l
may be made as appropriate); and (c) a separate appendix containing infonnation useful to the Regulatory Flexibility Certification and Paperwork Reduction Act Statement. The Task Manager will provide consents on the preliminary RA to the contractor by October 15, 1993.
The contractor shall modify the draft as appropriate and deliver a draft RA to the NRC on October 30, 1993. The contractor shall revise the draft RA based on comments to be provided by the Task Manager by January 30, 1994. The contractor shall deliver to the NRC a final RA by February 28, 1994.
4.
The contractor shall provide draft responses to public comments on the draft GEIS within 60 days of receipt of these comments from the Task
-Manager.
5.. The contractor shall deliver to the NRC fifteen (15) copies of a i
preliminary Final SEIS within 120 days of receipt of the public comments. The contract 6r shall revise the preliminary Final GEIS as directed by the Task Manager and shall deliver to the NRC a camera-ready copy of the Final GEIS with 45 days of receipt of direction from the l-Task Manager.,
i 6.
The contractor shall deliver to the NRC, at the same. time as the preliminary Final GEIS, a regulatory analysis for inclusion in the final f
rulemaking package.
EERHEL.QEJIRf_0.8tB!KE The contractor shall complete the task by May 30, 1995.
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