ML20062E299

Mod 32,increasing Authorized Funding for LSS & Revising Spelling of Project Officer Name,To Operation of CNWRA - Ffrdc

ML20062E299
Person / Time
Issue date:	09/27/1990
From:	Hagan T, Priegel R NRC OFFICE OF ADMINISTRATION (ADM), SOUTHWEST RESEARCH INSTITUTE
To:
Shared Package
ML20062E291	List: ML20062E288 ML20062E299
References
CON-FIN-B-6666, CON-FIN-D-1035, CON-FIN-D-1070, CON-FIN-D-1590, CON-NRC-02-88-005, CON-NRC-2-88-5 NUDOCS 9011200057
Download: ML20062E299 (21)

Text

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4. CON T H AC T eo (Out -

PAGL OF PAGLS

~ ^?NDM,ENT OF SOLICITATION / MODIFICATION OF CONTRACT j

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,9/14/90 NMS-88-005 dtd 9/13/90 J...RE02:BS:.00s

i. Am.Nian nTo - esioehu sh.m eu "

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cooC uutu or cggtj U.S. Nuclear Regulatory Comission Division of Contracts 1. Property Management Washington, D.C.

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Southwest Research Institute

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6220 Culebra Rod San Antonio. Texas 78228

,,A. MOO,,C Ai,0N O, c oNi n Acifon ota NO.

NRC-02-88-005 t

X ion. oAno <sts iros e3, cOoe lr ActuTY CODE 10/15/90

11. T HIS ITEM ONLY APPLIES TO AMENOMENTS OF SOLICIT ATIONS is e a tenoM.

is not eo Tbe atsove numterM solic iation is amerced as set f or th In licm 14. The hout and date ssecified io receipt of Of fees sen+d d

wei. pt of tNs aniendenent twior to the bout and date srecilint in the Sohceta6an or as amerced, tsy one of the fra.was tnetho s:

Of tens must athtio tedge copies of the ener<1rew nt; It ) Dy ack no..si'esnj eeceiset of th.s arnendment cm och coor of the oHe r tal By compicurig licans 8 and l'a. and ecturn. rig suteetted; or (c) Dy scuate letser cw letegeam evhich includes a reference to the solichation and amarCrvnt numtwrs F AllUHE OF YOA MENT TO DE FtECEIVED AT THE PLACE DEstGNATED f OH THE HECElPT OF OFFEHS PHtOH TO TH IN 1sEJE CilON OF YOUH Or ri H #f tiv v.etute of th s amendment you desire to change an oller erre Jv sut>mittal, such change mar t+ awe by telegra'n letit's, prowedd each telegrJm of leiter ftiakes fefelerice to the solicitation and trois 3rvendment, and at ff ccoved (Wior to the o(ening) hout 34 d 7

12, ACCOUN IING Afeb APettQeste A l EON DA T A (l/ sygses,cdf N/A 13 THIS ITEM APPLIES ONLY TO MOOtFICATIONS OF CONTRACTS / ORDERS, IT MOOlflES THE CONTRACT / ORDER NO. AS DESCRIBED IN ITEM 14.

A, T Hl$ CHANGE C64d5 H t$ l$$U(O PUH$UANT T O: ($pecify ees,honty) T HL CHANGEb bli 6'Ost f H sN ilEM 14 Af48.YADE IN 1 HL con.

b,g T n AC T ORQ( H NO. IN 4 f E M 10A.

RED CONT R ACT/OftDE R 15 MOD 4FICO TO AE'FLECT THE ADMINIST R AT 8VC CHANGE & lsuch ea te.a*(as in pdysa, office,

@. THC ADOVE NUMBE,t.J SE T t' ORTH IN IT EM 14, PUR$UANT TO T HE AUTHORIT V OF F AQ 43.jo3(D).

erprortseHon date, e C. T Hth $UPPLt ut tei AL AG RCLMEN f 45 LN} ERE D INTO PUI45UAN T TO AU THonii Y 08 i X

Mutual agreement of the parties.

U. O v HI.it (Sprenty,s pe of modetece,*on end ou hontv)

Coniracto, O if eoi. O ii,cooi,eo io. ion ini, ooCo,oeni oea,,,,,, -

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E, IMPO RTANT:

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SEE ATTACHED 9011200057 900927 PDR C ONTR 1

NRC-OR-88-005 PNU '

Cic~t ts peov6ced heaven, ett terms and tongHeons of the coturnent etterenced in itern 9A ce loa, as heretotoee changeo, rema6ns uncnongeo and <n nuea tosce

<n049fecta 16A, N AML ANO flT L.E OF CONT H AcilNG Of FsCER (Type or pr.st)

[5A, NAME AND TIT LE OF StGNE84 (Type ot etsaff R. E. Priegel

~ Assistant Manager, contracts Timothy ~F. Hagan

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P8tCVIOUS COfTION UNU$ADLC Presce6Ded by C, SA F AH (4. CF R 53.243

4 The purpose of this modification is to:

1) increase authorized funding for the Licensing Support System Operations Plan by $81,000.00, 2) revise the.

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spelling of a Project Officer's name under Section G.3.1, 3) incorporate the revised Award fee Determination Plan, and 4) revise the Fin Number shown in Block No.12 of Modification No. 31.

Therefore, the following changes'are hereby made:

1.

Paragraph E under Section 0.2 is revised to read as follows:

i "E.

The amount currently authorized for each operations plan is as follows.

High-level Vaste FIN: 01035 AMOUNT: $17,344,000.00 1

Transportation FIN: D1070 o

AMOUNT: $

596,200.00 Research FIN:

B6666

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AMOUNT: $ 4,532,732.00 Licensing Support System FIN:

L15900 AMOUNT: ~$

166,000.00 Total Amount Authorized: -$22,638,932.00" 2.

The spelling f ar the Project Officer's name for Integrated Waste Package Experiments ut. der Section G.3.1, Paragraph C is revised from " Philip Reed" to ','Phillip Reed. "

3.

Under Section J, entitled " List of Attachments," Attachment 18 is hereby deleted in its entirety and replaced with the attached Award Fee Determination Plan dated September 1990.

4.

The Fin No. shown in Block No.12 of Standard Form 30 for Modification No. 31 is hereby revised from "D19500" to "L19500."

All other terms and conditions of this contract remain unchanged.

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. AWARD FEE bETERMINATION PLANLFOR?

%j CONTRACT NO. NRC-02-88-005 WITH SOUTHWEST RESEARCH INSTITUTE

FOR THE PERIOD OCTOBER.15,11990;THROUGH OCTOBER 14;-1991 T

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CPAF CONTRACT PERFORMANCE REPORTING REVIEW AND EVALUATION PROCEDURE Award Fee Determination Report.

FEE DETERMINATION.0FFICIAL (FDO)

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Award Fee Recommendation' Performance Evaluatlon Report CONTRACT REVIEW GROUP (CRG)

' Monthly Reports l

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Self-Assessment-Report i

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1 AWARD FEE' DETERMINATION PLAN FORC U

CONTRACT NO.?NRC-02-88-005 WITH SOUTHWEST RESEARCH= INSTITUTE S

f FOR THE PERIOD OCTOBER:15',1990 THROUGH.0CTOBER 14,:1991...,

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Introduction.

B.

Organization Structure for: Award Fee ' Administration '

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Evaluation Requirementr.

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D.

, Methods for Determining Award Fee -

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Change in' Plan Coverage

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, A.

Purpose 1.

The purpose of the Award Fee is to stimulate management actions which will motivate the Center for Nuclear Waste Regulatory Analyses (CNWRA or Center) staff as employees of Southwest Research Institute (SWRI or contractor) to str,1ve for excellence.in the overall performance of the Center, under the contractually,non-competitive environment of a Federally Funded Research and Dreelopment Center (FFRDC),

NRC interests'are best served when the Center?s performance is such that f

NRC can award the maximum. fee.

Therefore, any award of less than.

. maximum fee shall be accompanied by a list of specific problems that

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require successful corrective action by Center Management' in order to attain award of the maximum fee.

B.

Introduction-1.

This plan covers the administration of. the award fee provisions'of' Contract No. NRC-02-88-005 with SWRI for the evaluation period October 15, 1990 through October 14, 1991.

1 2.

The following matters, among others, are covered in.the contract.

a.

The contractor is required to maintain an FFRDC for the operation of the Center, b.

The award fee pool is $1,597,843.00 through October 14,-1990.

c.

The estimated cost and award. fee pool are subject to equitabic adjustments on account of changes or other contract

modifications.

d.

The award fee earned and payable-will be determined as specified elsewhere in this plan by the Fee. Determination-Official (F00) in accordance with this plan.

The F00.is Robert M. Bernero, or, his designee.

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Award fee determinations are not subject.to the Disputes clause of the contract.

3.

This award fee-is provided' for the establishment and maintenance of a high level of technical expertise for effective performance of functions for the NRC related to the NWPA waste management-1

-program. This award fee plan af fords. the contractor an opportunity to earn increased fee commensurate with the-achievement of optimum performance in pursuit.of contract objectives and goals. Optimum performa'nce is not'necessarily' equated with the highest level. of performance achievable in all; l

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incentive areas.

Rather, it represents the most favorable degree of performance obtainable considering the achievement of contract i

objectives in light of the compicxities of the tasks, the dif ficulties of the schedules agreed upon, and the contractor's most effective utilization of available resources. The i

<.onstraints beyond the Center's control shall be considered, j

i C.

Organization Structure for Award Fee Administration The following organizational structure is established for' administering l

the award fee provisions of the contract.

l 1.

Fee Determination Official (FDO).

a.

The F00 is Robert M. Bernero, or his designee.

b.

Primary FD0 responsibilities are:

(1) Determining the award fee earned and payable for each i

evaluation period as addressed-in Part D..

(2) Changing the matters covered in this plan as addressed in Part E, as appropriate.

f 2.

Center Rev_f ew Group (CRG)

I The Chairman of the CRG is Jesse L. Funches, or'his a.

designee. The'CRG consists of the following members:

Robert E. Browning Charles E. MacDonald Timothy.F. Hagan Hel Silberberg Advisors: Donald F. Hassell Sharon D. Hearse Evaluation Coordinator:

Barbara Stiltenpole b.

The Chairman may recommend the appointment of non-voting members to assist the Group in performing its! functions.

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The CRG will:

(1) Conduct ongoing evaluations and assessments of the.

Center's overall performance and submit a Performance Evaluation Report (PER) to the FD0 covering the Group's findings and recommendations for each evaluation period, as addressed in Part D.

(2) Considering-proposed changes in this plan and.

recommending those it determines appropriate for adoption by the FDO, as addressed in Part E.'

3.

Performance Monitors (PM)',

PMs areLall Program Element Managers and the Senior Contract a.

Specialist.

b.

Each PM.will.be. responsible for complying,with the General Instructions for Performance Monitors Attachment 0-1, and any specific instructions of the CRG Chairman as addressed'in Part D.

Primary PM responsibilitics. are:

(1) Monitoring, evaluating and assessing the Center's-performance in assigned areas.

(2) Periodically preparing a Performance Monitor-Report (PMR) for the CRG, as appropriate, (3) Recommending appropriate changes in this plan for consideration, as addressed in Part E, E

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Evaluation Requirements i

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The applicable evaluation requirements are attached as' indicated below:

i Requirement Attachment 1.

Evaluation Periods and Maximum C-1; Available Award Fee for Each; Evaluation Criteria for eahh ~

C-2"

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- Performance Period i

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3.

. Grading Tabic i

l TheweightsindicatedinAttachment,C2'andthegrabingtableundsr

' Attachment C-3 are quantifying. devices whose sole purpose:is to-provide guidancetoNRCinthe-formof.a'generalindication'of.theamountlofc award fee earned.

In no.way,wtil they be used to impute an-3 arithmetical precision to any) judgmental determination of the contractor's overall performance and the. amount of. award fee earned,-

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4.

Award Fee Schedule i

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-8' D.

Method for Determining Award Fee A determination _of the award fee earned for each evaluation period will be made promptly by ther FD0 after the end of the_ period. The method to be followed in monitoring, evaluating and assessing contractor performance during the period as well as for determining the award fee earned, is described below.

1.

Duties and responsibilities of'PMs will be in addition to, or an extension of, regular responsibilities.

2.

The CRG Chairman will require that each PM receives the following:

A copy of the contract and all modifications from'the o

Contracting Officer.

Appropriate orientation and guidance from the Contracting-o Officer.

t A copy of this plan along with any changes made in accordance o

with part E.

$pecific instructions applicable to PM assigned performance o

areas.

3.

PMs will monitor, evaluate and assess the Center's performance in accordance with the General-Instructions for Performance Monitors, Attachment D-1, and the specific instructions'and guidance furnished by the CRG Chairman.

4.

PMs will submit periodic Performance Monitor Reports'(PMRs) to the

'i Evaluation Coordinator and, if required, make. verbal presentations to the CRG.

5.

As appropriate, the CRG Chairman will. request and obtain performance information from other units or personnel normally

-involved in observing the Center's performance.

4 6.

Periodically, the CRG will. consider PMRs and other performance information it obtains and-discuss the reports and information with PMs or other personnel, as appropriate.-

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7.

Af ter the end of each evaluation period, -the Center shall submit f

to the Contracting Officer and the Evaluation Coordinator a written self-assessment identifying areas the Center has found.

needing corrective measures and the actions taken onLthose~

measures.- In addition, the assessment sha11' enumerate major-i accomplishments versus established milestones during the period.

Af ter receipt of the Center's self-assessment report', the Center may be required to meet with the CRG to discuss overall performance during the period. As requested by the CRG. Chairman, PMs and other personnel involved in performance evaluations will attend the meetings and participate in discussions.-

8.

Af ter any such meeting with the Center, the CRG will consider matters presented by the.Centen and estabitsh its ' findings and.

recommendations to be. included in the PER.

9.

The CRG Chairman will prepare the PER for the period an'd submit.it I

to the FD0 for use in determining the. award-fee earned. The report will include a recommended award fee with supporting documentation.

Prior to submitting the PER, the Chairman will discuss the CRG recommendation with the Center and shall afford i

i the Center the opportunity to' present any additional information:

for the FD0's consideration. When submitting the report, the Chairman will inform the FD0 whether or not the. Center desires to I

present any matters to the FD0 before the award fee determination is made.

10.

The FD0 will consider the PER and di'scuss it with the CRG Chairman or other personnel,_ as appropriate, if requested by.the Center,-

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or if the FD0 considers it appropriate; the FD0 will. meet with the Center for discussions.

If requested by the FDO,1the CRG Chairman and any other personnel involved in performance evaluation may be requiredclo attend the meeting with.the Center.

11.

The FD0 will determine-the amount of award; fee' earned during the l

period.

The amount determined will not result solely from.

J mathematical summing, averaging or the application'of' a-formula, L

-The FD0's determination of the, amount of award fee earned and the l

basis for this determination will be stated in he Award Fee Determination Report (AFDR)

The report.will;be signed by the FD0 1

and-given to the contractor for attachment to its voucher:-

requesting payment of the award fee.

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E.

Changes In Plan Coverage 1.

Right to Make Changes Any matters covered in this plan may be changed by mutual l

agreement of the parties 30 days. prior to the beginning of an evaluation period by timely notification to the' contractor and the-Center in writing.

Ilowever, when-the contractor and the NRC cannot agree on any proposed change the matter will be referred to' the F00 for a~ final decision. All; final-changes will=be made by formal modification to the contract'.

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2.

Method of Changing Plan Coverage i

The method to be fo,llowed for changing plan coverage -is described

below, a.

Personnel involved in the administration of the award fee provisions'of.the cont'ract are cncouraged to recommend i

i changes in plan coverage with a view toward changing, management emphasis, motivating higher performance levels, or i

improving the award feo determination process.

Recommended changes should be sent to the CRG for consideration and drafting.

b.

The CRG will coordinate proposed. changes with the Center.

c.

Prior to the~end of each evaluation period, the CRG will submit changes applicable to the next evaluation pe,riod for

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i approval by the F00 with appropriate comments and justification.

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ATTACHMENT C-1 TO AFDP I

CONTRACT NO. NRC-02-88-005 WITH SOUTHWEST RESEARCH INSTITUTE EVALVATION PERIOOS AND MAXIMUM AVAILABLE AWARD TEE FOR EACH Evaluation Period Maximum Available No.

Duration Ending__

. Award ree-1 6 months April 14. 1988

$102,009 2

6 months October 14, 1988

.$158,444 3

6 months April 14, 1989

$275,870 i

4 6 months October 14, 1989

$296,996 5

6 months

. April 14, 1990

$318,735 6

6 months October 14L 1990

$445,789a" 7

6 months April 14, 1991 TBD 8

6 months October 14, 1991 TBD

'The available award ice forLthe sixth evaluation period.contains fee for one-half of period 1 of the currently approved FY 199110perations/ Project-Plans which are antiquated due to changes in DOE's program.and OMB. budget.

t cuts. Consequently, the available award fee for the. sixth evaluation period is subject to adjustment upon receipt of the FY_1991-1992 Operations / Project Plans.

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ATTACHMENT C-2 TO AFDP.FOR I

CONTRACT NO NRC-02-88-005 WITil.SOUTilWEST RESEARCH INSTITUTE EVALUATION CRITERIA FOR YEAR THREE PERTORMANCE AREA WEIGHT 100 1.

Technical - 55 Points The extent to which the contractor provides sustained high quality technical assistance and research in. support of the NRC high-level waste program.

The functioning of the Center shall be consistent with the direction provided by the NRC Contracting Of ficer and the approved operations plans and the guidance provided by the NRC CNWRA Program

Manager, Evaluation factors shall include:

(A) Thoroughness and Accuracy of Work The extent to which the Center submits work products / deliverables which are thorough, accurate and meet contractual specifications.

l (B) Independence and Initiative The extent to which the Center's efforts exhibit independence and initiative in impicmenting the approved operations plans and recommending activities that need to be undertaken by the NRC to meet its responsibilities.

(C) Clarity and Conciseness The extent to which the Center consistently. submits work products that are clear and provide an adequate technical basis.

(D) Timeliness The extent to which the Center consistently submits work products on time. The degree to which delays are caused by circumstances beyond the Center's control shall be considered.

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(E) Complexity 1

Consideration will be given to the technical difficulty and schedule. requirement.

2.

Management and Staffing - 30 Points t

(A) Management The extent to which the contractor develops and maintains a Center capable of meeting NRC's'long and short-term needs and establishes appropriate priorities based on the direction' provided by the NRC -

Contracting Officer, approved Operations Plans and efficient utilization of available resources.

(1) Develop / Implement = Appropriate Procedures / Practices (a) The extent to which the Center develops.: implements and maintains administrative and-management policies, procedures and practices.needed.to.successfully operate an FFRDC, e.g., conflict of interest procedures.

(b) TheextenttowhichtheCentermaintainsandimhlements l

an effective QA program.

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(2) Independence and Initiative The extent to which the Center demonstrates -independence and initiative in developing, proposing and implementing plans and procedures for, eliminating existing and potential _

impediments to the work flow process.

The extent to which the Center acts independently to expedite the' flow of. work-

'i under the control of its organization and follows up to ensure information required from outside sources ts obtained-

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in a timely manner. The exten't to which the Center analyzes-problems and proposes measures to correct-them.

(3) Facilities q

The extent to' which the contractor establishes.and maintains

' facilities, equipment and computer capabilities.to meet NRC requirements in a timely and cost effective manner.

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(4) Effectiveness of Liaison Effort i

i The extent to which the Center provides effective liaison with the NRC; those contractors where technology transfer has been directed; 19d others to effectively manage the program and to facilitate the development of technical products..

i (5) Ability to Adjust to Changing Needs The extent to which the Center exhibits the ability to 6djust to the changing needs of the NRC. This shall take into account:. assignment of priorities of work; management of available time, personnel and fiscal resources; estab;f shment of long-term goals; and responsiveness to changirg.

priorities, program. direction, program focus 'and resultant impact including budgetary estimates.

(D) Staffing l

The extent to which the contractor recruits and maintains a qualified staff to meet proposed requirements, including i

provisions for the key personnel, in a timely manner, enabling the Center to function to fulfill its' mission.

The following. items will be considered:

(1) Effectiveness in' attracting a6d retaining high quality.

personnel in accordance.with-the Center's' staffing plan.

Consideration wille be given to. difficulty in acquiring a

personnel because of unique circumstances (for. example, an unexpected high demand for'certain disciplines)..

4 (2) Effectiveness in assigning qualified' personnel to accomplish work in approved opera ions plans and.long term program objectives which are the basis of the staffing plan.

3.

Cost Control and Contract Administration - 15 Points' The extent to which the contractor conducts 1the work in a cost-ef fective menner and has effected cost controls necessary to insure technical work products are completed within established limitations.

The following. items will be' considered under this criteria:

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. (A) Cost Estimation and Control (1) The extent to which the Center. develops detailed and-reasonable cost estimates for performance of. work.

Also, the-extent-to which the Center substantiates all cost estimates and/orLproposed revisions.

(2) The extent to which the Cent:-. performs work within the original cost-estimatee.. If revisions to work requirements are required, an evaluation will be performed based on agreed-upon revised estimates.-

(3) The accuracy and timeliness of information provided by the-Center's integrated. budgeting and cost reporting. system in compliance with contract requirements.

(B) Effectiveness of Contractor's Performance.in the Area of Contract Administration, including:

(1) The extent to which the Center provides dor.umentation which substantiates that:

subcontracts ~are negotiated, documented and administered in accordance with the Federal Acquisition 1

Regulations and subcontractor approval' requests are submitted in a timely manner including copies of all task directives issued and modifications to subcontracts.

(2) The quality and/or timeliness of:c required administrative, notifications such as limitation-of funds notification; reports such as periodic' progress reports.and subcontracting plan reports; and execution of contract modificati,ons.

(3) The effectiveness of liaison between the contractor, Center

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and the NRC Contracting Officer in all aspects'ofLcontract-

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administration.

(4) The extent to which the Center provides complete, accurate and timely information on conflict of interest issuest-i 1

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t ATTAtliMENT.C-3 GRADING TABLE PROPOSED EVALUATION GRADES Purpose The purpose of the Award Fee is to recognize Contractor performance andt stimulate management actions which will motivate Center staff to strive-for excellence in.the overall performance of the Center, under the contractually.

non-competitive environment ofLan FFROC.

NRC interests are best-served when the Center's performance is such that NRC can' award the maximum fee, 4

Therefore, any award of less than maximum fee shall be accompanied by a list' of specific problems'that' require successful corrective action by Center Management to order'to attain award of the maximum fee.

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PROPOSED EVALUATION GRADES Adjective Grade Numerical Grade-Definition Excellent 90-to 100 Overall performance of contract requirement is consistently outstanding and represents the-very best which.can be expected i

from the Center giving due-consideration.to complexity of l

the_ task and constraints (cost /

schedule) imposed by.NRC.

ThisL gradeLrepresents a practical goal, to be' awarded for a-degree of. performance which is.

-real and attainable, not

' theoretical.

Above Average 80 to'89 The Center's performance has met or exceeded most 1

expectations' set:forth in the contracta Areas'of-

. deficiencies are few-and r

overall are considered relatively insignificant.

The Center shows initiative in

' executing the' job and in making improvements. The: degree to which the CenterTmeets'or.

exceeds schedules, a'chieves-objectives; eliminates areas of deficiency identified in the evaluation' period, etc., will be considered.~

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Satisfactory-

- 70 to 79; The Center',s' performance-

-has met.mostlneeds / schedules,.

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iand expectationstset;forth*in:

the contract..; Areas-of_~

~ deficiencies are morelfrequenti, Lthan :in~ thelcriterialabove',1but'

are of fset by ~areasfof" excellent or; superior l

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performance lsuch that'; net Y H

1 affection overall program:was i

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'I Fair.

~ 60'to 69 The Center's_ perform'nce' a

'has not met-contractL

. requirements on numerous.

'. occasions.-' Areas;of deficiency" have had some; adverse. imp'act on" the. program (cost, schedule; m

and/or_ performance).

This,

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_ rating constitutes a: warning [to'

'the contractorEthatiits:,

performance =bordersLon'an!,

unsatisfactory rating. '

i unsatisf actory Below 60-

' Number"andsignif)canceofo

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deficiencies are such)that th~e Jcontra'c tor's loverall c

' performance;is unsatisfactory.

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l l C-4 AWARD FEE SCHEDULE CONTRACT NO. NRC-02-88-005 WITH SOUTHWEST RESEARCH INSTITUTE Award Fee Schedule The base fee for this contract shall be 0%.

Based on:the evaluation scale, the fee awarded shall be as follows:

Performance Rattna Fee Awarded Excellent 7% but not more-than 8%

Above Average

.-6% but less than 7%.

Satisfactory 3% but less than 6%

Fair 1% but less than 3%-

Unsatisfactory

'0%

_Use of Award Fee for Center Independent Research and Development (IR&D)-

Fee Awarded Maximum % of Fee Set Aside for Center IR&D 8%

35%

7%

30%-

6%

25%'

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5%

20%

4%

15%

3% or less 0%

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