ML20196K925
| ML20196K925 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/1999 |
| From: | Mace M NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Schossow F ICF, INC. |
| References | |
| CON-FIN-J-5236, CON-NRC-04-95-065, CON-NRC-4-95-65 NUDOCS 9907120197 | |
| Download: ML20196K925 (18) | |
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oc g b g 3 UNITED STATES g [ NUCLEAR REGULATORY COMMISSION 2 WASHINGTON, D.C. 20066 4001
\*****/ JUL Of Y ICF Incorporated ATTN: Ms. Frances Schossow Project Administrator 9300 Lee Highway Fairfax, Virginia 22031-1207
Dear Ms. Schossow:
Subject:
Task Order No. 21 entitled, " Technical Assistance for Rulemaking on Clearance of Materials and Equipment Having Residual Radioactivity,"
under Contract No. NRC-04-95-065 In accordance with Section G.5(c) of the subject contract, this letter definitizes the subject task order. This effort shall be performed in accordance with the enclosed Statement of Work and the contractor's technical proposal dated May 14,1999, and the revised technical proposal dated June 10,1999, which are hereby incorporated by reference and made a part of the subject task order.
Task Order No. 21 shall be in effect from the date both parties have signed this document through April 30,2001. The total estimated ceiling for this task order is
$438,878.00.-
The Accounting Data for this task order is as follows:
B & R N o.: 95015203115
, Job Code No.: {
J5236 A P P N N o.: 31X0200' BOC No.: 252A Obligated Amt.: $161,62si s .. .
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- . %,,s The following individuals are considered to be essential to the successful performance of the work hereunder: Paul Bailey, Steve Wyngarden, Gary Light, Alan Summerville, Daniel Shain, John Collier and Earl Harris.
The contractor agrees that such personnel shall not be removed from the effort under this task order without compliance with Contract Clause H.2, Key Personnel. [
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9907120197 990701 PDR CONTR NRC-04-95-065 PDR ,
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Contract No. NRC-04-95-065 l
Task Order No. 21 l Technical Matters: Carolyn Boyle Project Officer / Technical Monitor (301)415-7818 Contractual Matters: Amy Siller Contract Specialist (301)415-6747 The contractor shall not exceed the ceiling amount under this task order unless a formal modification is issued by the Contracting Officer.
The issuance of this task order does not amend any terms or conditions of the subject contract.
Please indicate your acceptance of this task order 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 U.S. Nuclear Regulatory Commission, ATTN: Ms. Amy Siller, Division of Contracts and Property Management, Contract Management Branch 1, M/S T-7-1-2, Washington, D.C. 20550. You should retain the third copy for your records.
Should you have any questions concerning the letter, please contact Ms. Siller on (301) 415-6747. ,
1 Sincerely,
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f lary H. Mace, Contracting Officer Contract Management Branch 1 Division of Contracts and Property Management Office of Administration
Enclosure:
As stated l
"fi":[w P L TITLE /f l '11l19 4 l DATE
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- 3. Prepare and publish, for comment, an issues paper on Clearance of Materials and Equipment Having Residual Radioactivity (henceforth, the NRC lssues Paper for Discussion).
B. A public EPR process, which will focus on the NRC issues Paper for Discussion, and primardy will consist of four pub.ic meetings.
C. Announcement in the Federal Register of the four meetings mentioned in item B above and of NRC's intent to conduct the NEPA scoping process to be conducted concurrently with the EPR rulemaking pwcess and meetings.
D. Holding public meetings and summarizing the results and recommendations of those meetings, as well as written (conventional or electronically submitted) comments received on the issues paper and scoping processes.
E. A draft Commission information package consisting of an attachment to a draft SECY paper addressing the deliberations and results of the EPR and the NEPA scoping process with any relevant supporting documentation, either by direct inclusion or by reference, relating to the alternatives for the proposed rule on clearance.
The Contractor shall assist in !! ems B-E above.
1.2 The Contractor shall attend, participate, and contribute to the public meetings. The NRC Technical Project Manager (TPM) shall provide the Contractor with written and electronic media copies of each transcript. At the conclusion of each meeting, the Contractor shall collect comments into a database in a format compatible with NRC's current word processing and spreadsheet software
- which will organize similar comments, grouped into categories, to be addressed during the EPR and NEPA scoping process. The Contractor shall coordinate responses and resolutions of the public comments in coordination with the NRC TPM in preparation for their inclusion into the Statement of <
Considerations (SOC) for the proposed rule on the clearance of materials and equipment
' having residual radioactivity and as input into the SECY paper mentioned in item E of this subtask as provided below. As part of the EPR process, the Contractor shall prepare an EPR process report, which will summarize the issues addressed and the attematives recommended in a format consistent with a NUREG/CR document.
1.3 Speedically, the Contractor shall, as directed by the NRC TPM, provide technical assistance in ennducting the EPR and NEPA scoping procenes in support of a rulemaking on tne need for regulations on the clearance of materials and equipment having resic.ual radioactivity. Conduct of this scoping process must comply with the provisions of 10 CFR Part 51; specifically with Sections 51.26-29. Moreover, the Contractor shall categoriza and address public commente made at the four public meetings tentatively scheduled from August-November 1999. These meetings will focus 8 Refer to $4, item 3 on reporting requirements.
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,o.d w STATEMENT OF WORK Technical Assistance for Rulemaking on Clearance of Materials and Equipment Having Residual Radioactivity Contract No. 04-95-065 Task Order No. 21 .
1.0 BACKGROUND
Clearance of radioactively contaminated solid materials by NRC licensees is currently carried out in accordance with NRC Regulatory Guide (RG) 1.86, " Termination of Operating Licenses for Nuclear Reactors." RG 1.8F 'ddresses only clearance of solid material having surface contamination. There is no NRC regulatory guidance for materials with volumetric contamination. Although the doses to protect public health and safety were considered in RG 1.86 and the levels were deemed protective, no quantitative dosa analysis by pathway was conducted as a basis for this guidance, and the dose levels are not uniform as calculated by current methods, The Commission, in a Staff Requirements Memorandum (SRM) dated June 30,1998, directed the NRC staff to proceed with rulemaking on clearance of materials and equipment having residual radioactivity. Specific directions regarding the content of a clearance rule contained in the SRM are that: 1) it will not be a detectability standard but will instead be a dose-based regulation focusing on codified clearance levels above background for unrestricted use that are adequately protective of public health and safety ; 2) it will base standards on realistic scenarios of health effects from low doses; and 3) it will be a comprehensive rule applicable to all metals, equipment, and materials, including soil, unless a narrower scope is justified based on probicms with applying the rule to certain categories of materials that could delay completing the rulemaking. The SRM also includes direction conceming the conduct of the rulemaking process,'specifically that it will include an enhanced participatory rulemaking process similar to the 10 CFR Part 35 revision process to solicit early public input on the major issues of the rulemaking, in response to the SRM, the NRC staff is developing a proposed approach which was forwarded to the Commission on January 27,1999.8 This strategy includes the use of the NRC Intemet home page to provide an open forum for the public on rulemaking issues and also includes development of an issues paper which will be used as the basis for discussions at a series of public meetings to be held from August through November 1999. Following this period of early public input, the NRC staff would anticipate preparing a proposed rule.
'Using input from an Intemational Atomic Energy Agency interim report, an analyses by the NRC's Technical Basis Contractor (TBC), and an ongoing practice with regard to NORM and NARM.
8 Commission direction in SRM dtd SE%30 for SECY-98-028, " Regulatory Options for Setting Standards on Clearance of Materials and Equipment Having Residual Radioactivity,"
January 27,1999.
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.2 Tim principal technical basis developed by the NRC to date for this rulemaking consists of a draft NUREG/CR on individual dose conversion factors through various clearance exposure pathways. The materials addressed in this technical basis include steel, copper, and aluminum bulk material and concrete rubble, as well as clearance of tools and equipment for reuse.
Following NRC staff review of this document, it will be issued as a NUREG/CR report. Other sources of technical information developed to date include those developed by the Environmental Protection Agency (EPA), the International Atomic Energy Agency (IAEA), and other affected organizations (see the list of references).
Additional technical basis to be developed includes analyses of collective doses based on exposures of populations to the pathways resulting from clearance of materials, and corWderations of costs and potential health impacts of attemate modes of material clearance or disposal. Also, additional analyses for individual and collective doses may be needed to cover other materials, including soil, beyond that currently analyzed. Other technical analyses may be 4 necessary in areas involved with implementing a rule (e.g., survey methods for volumetric contamination at very low radionuclide levels),
i This Task Order will provide supporting documents for a proposed rule, r/hich if approved by the Commission, will be published in the Federal Register for public comment.
2.0 OBJECTIVE
-To provide a proposea rule on clearance of materials and equipment having residual radioactivity, a draft Generic Environmental impact Statement (GEIS), a draft Regulatory Anwysis (RA), an information ccIlection burden report, and a summary and categorization of public comments received in response to the NRC web site, from public meetings, and from issuance of a proposed rule. The NRC has elected to pursue an enhanced participatory process in promulgating a rule on clearance.
. 3.0 WORKSCOPE There' are four major subtasks to be performed under this Task Order. The workscope for the four subtasks is as follows:
Subtask 1. Assistance with Enhanced Participatory Rulemaking Process and NEPA Scoping Process and Analysis of Public Comments 1.1. ; This rulemaking will have two parallel scoping processes: one will be an enhanced public a
p Micipatory rulemaking (EPR) process, which is being conducted by the NRC (as j uWlated in the 6/30!98 SRM), to encourage early input by the public in the rulemaking i process, and the other is the public scoping process required by the National .
Environmental Policy Act (NEPA). The NEPA scoping process provisions are codifici in the NRC's regulations in 10 CFR Part 51. Because the issues involved in both the EPR and NEPA scoping processes are closely related, they shall be conducted concurrently.
Specifically, the following shall occur:
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A. . Prepare and publish, for comment, an issues paper on Clearance of Materials and Equipment Having Residual Radioactivity (henceforth, the NRC issues Paper for Discussion).
B. A public EPR process, which will focus on the NRC lasues Paper for Discussion, and primarily will consist of four public meetings.
C. Announcement in the Federal Register of the four meetings mentioned in item B above 1 and of NRC's intent to conduct the NEPA scoping process to be conducted concurrently "
with the EPR rulemaking process and meetings.
D.' Holding public meetings and summarizing the results and recommendations of those meetings, as well as written (conventional or electronically submitted) comments received on the issues paper and senping processes.
E. A draft Commission information package consisting of an attachment to a draft SECY paper addressing the deliberations and results of the EPR and the NEPA scoping process with any relevant supporting documentation, either by direct inclusion or by 4 reference, relating to the altematives for the proposeo rule on clearance.
The Contractor shall assist in items B-E above.
1.2 - The Contractor shall attend, participate, and contribute to the public meetings. The NRC Technical Project Manager (TPM) shall provide the Contractor with written and electronic
. media copies of each kanscript.' At the conclusion of each meeting, the Contractor shall collect comments into a database in a format compatible with NRC's current word processing and spreadsheet software $ which will organize similar comments, grouped into categories, to be addressed during the EPR and NEPA scoping process. The Contractor shall coordinate responses and resolutions of the public comments in coordination with the NRC TPM in preparation for their inclusion into the Statement of .
Considerations (SOC) for the proposed rule on the clearance of materials and equipment
' ' having residual radioactivity and as input into the SECY paper mentioned in item E of '
. this subtask as provided below. As part of the EPR process, the Contractor shall i prepare an EPR process report, which will summarize the issues addressed and the .
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alternatives recommended in a format consistent with a NUREG/CR document.
1.3 -Speafically, the Contractor shall, as directed by the NRC TPM, provide technical
-assistance in conducting the EPR and NEPA scopirig pwesses in support of a rulemaking on the need for regulations on the clearant a of materials and equipment
. having residual radioactivity. Conduct of this scoping process must comply with the provisions of 10 CFR Part 51; specifically with Sections 51.26-29. Moreover, the Contractor shall categorize and address public comments made at the four public meetings tentatively scheduled from August-November 1999. These meetings will focus
- 8 Refer to $4, item 3 on reporting requirements.
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4 on issues identified in the NRC issues Paper for Discussion and on any additional issues raised during the course of these meetings.
1.4 As part of this process, the Contractor shall:
A. Assist the NRC staff in the preparation of a Federal Register Notice (FRN) of intent to hold public meetings and to conduct a scoping process, concurrently with these meetings, to discuss issues pertinent to a rule on clearance of materials and equipment having residual radioactivity. The FRN will provide an outline of possible alternatives for a clearance rulemaking, as addressed in the NRC issues Paper for Discussion, and will outline the scope of the GEIS, as stipulated in 10 CFR 51.26-27.
B. Prepare a database of public comments generated following the first public meeting and revised to include additional comments from the subsequent meetings, organized by categories based on issues identified in the NRC lssues Paper for Discussion, as well as on additionalissues raised during these meetings. The NRC TPM shall provide copies of the transcript of the meetings to the Contractor to assist in generating and revising the database. Moreover, this database should incorporate public comments on the FRN received by formal written submittal, from electronic submittal (Intemet), and by other appropriate means. The databus should be maintained in a format compatible with NRC's current word processing and spreadsheet software.8 C. Prepare a document that will summarize and categorize this database of public comments in a format compatible with that of a NUREG/CR report similar to NUREG/CR-6156 and NUREG/CR-6353. The total database of comments should be addressed in the preparation of the NUREG/CR report.
D. Prepare a draft Commission information package consisting of an attachment for a SECY paper addressing the deliberations and results of the EPP and NEPA scoping processes with any relevant supporting documentation, either by direct inclusion or by
, reference, relating to the alternatives for the proposed rule on clearance. I E. Prepare a draft and final EPR and NEPA scoping process summary report consisting of l
- sumg.arized public comments in preparation for transmittal to each participant in the i EPR and NEPA scoping process for the purpose of complying with 10 CFR 51.29(b).
This report should address the evolution of the scope of the rulemaking during the EPR and NEPA scoping process. Specifically, the final summary report shall include a concise summary of the determinations and conclusions reached, including the significant issues identified, and will be sent to each participant in the scoping process.
Any resolutions of comments will be incorporated, following review and approval by the NRC TPM, into the FRN issuing the proposed rule on clearance with discussion and rationale addressed in the attendant SOC. [ Refer to Subtasks 2 and 3].
1.5 The Contractor shall include this subtask progress in the monthly report to the NRC TPM.
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t-5 Su'btask 2: Preparation of a Draft GEIS -
2.1 The Contractor shall provide technical assistance to the NRC in preparation of regulatory products including assistan::e in preparing a draft GEIS and proposed rule with associated regulatory analysis (see Subtask 3) developed in support of rulemaking, as stipulatedin 10 CFR Part 51; specifically Sections 51.70-74,85-86, and Appendix A to Subpart A. The draft GEIS shall contain a NEPA analysis of the rulemaking attematives and the cost-benefit of the ' ~ natives leading to the recommendation to select one of l
)- the rulemaking attemative (as stipulated in 1'O CFR 51.71(e)). Additionally, the draft GEIS should address the affected environment, environmental consequences, including ]
both radiological and non-radiological risks, and socioeconomic factors such as environmentaljustice and expected land use. Therefore, assistance in preparation of the draft GEIS shall include input in these areas. The Contractor shall also assist in preparation of analysis and response to public comments in preparation of the draft GEIS.
2.2 Specifically, assistance in preparation of the draft GEIS shall be developed as stipulated below and shallinclude as a minimum the following draft GEIS sections:
General Cover Sheet
. Summary
- Purpose of and Need for Action Altematives including the Proposed Action Affected Environment Environmental Consequer ~.s and Mitigating Actions List of Preparers Appendices Specific supporiing technical information on individual and collective doses, materials and relevant costs shall be supplied by the NRC Technical Basis Contractor (TBC)
, through the NRC TPM to the Contractor for use in the overall assessment of 4 environmental impacts. This information, in conjunction with the subsequent analyses within this subtask as stipulated below, shall be used by the Contractor to generate the draft GEIS.
2.3 - In complying with general NEPA provisions, the Contractor shall:
A. Identify and provide a preliminary assessenent of the rulemaking attematives (PARA) to ;
be evaluated in the draft GEIS. Appendix A.5 of 10 CFR Part 51 indicates that all reasonable attematives shall be identified. Attematives to be considered shall be i discussed with the NRC TPM; i B. Recommend rulemaking attematives to be evaluated fully in the draft GEIS, based on the I identification and preliminary assessment of adematives- ,
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' C; Provide an annotated outline of the draft GEIS conforming to the requirements of Appendix A of 10 CFR Part 51 indicating the information to be included in each draft GEIS section, the activities and types of facilities to be covered, and the information that needs to be resolved; and D. Prepare a cost / benefit analysis. The Contractor shall perform a cost / benefit analysis for clearance attematives:
(1) The analysis shall address regulatory altematives corrMponding to 1) no regulatory change (i.e., basing clearance decisions on criteria as stipulated in RG 1.86 or other authorized limits stipulated by license); 2) a general prohibition on clearance with a requirement that all equipment and materials go to licensed LLW burial facilities; and
- 3) clearance of materials and equipment based on collective dose corresponding to individual dose-based alternatives including incremental values of 1,10, and 100 pSv/a (0.1,1 and 10 mrem /yr) above natural background to the average member of the critical group. Additional or different dose-based alternatives may be considered and should be determined with the NRC TPM.
(2) The scope of the analysis shall be the incremental benefits and costs that would result as a result of an NRC clearance regulation. The scope shall be defined by those attributes addressed in NUREG/BR-0184, Section 5.5, and the level of detail shall be commensurate with the level of uncertainty and the importance of the expected information to the decision on selection of an alternative clearance level.
(3) The TBC shall provide to the Contractor, through the NRC TPM, the technical data and information necessary to prepare a cost-benefit analysis of clearance rule l objectives cited in item O(1) above. The data shall address collective dose, exposure scenarios (including from multiple sources), material costs, estimates of quantities, and types of contaminated material inventories (by types of material, including soils, and type of radioactivity activity), and estimates of radioactivity build-
' up in materials released in general commerce. Specific information to be provided by the TBC shallinclude:
(a) Estimates cf the collective doses associated with attemate clearance levels under i various exposure scenarios; I (b) Estimates of the mass of materials and quantity of equipment qualifiable for clearance; (c) Estimates of the kinds and amounts of radioactivity associated with potentially cleared raaterials and equipment, including the potential for the build-up of radioactivity in ferrous 1etals, aluminum, copper, and concrete materials and equipment; (d) Estimates of the inventory, radioactivity, and extent of radioactively contaminated soil eligible for clearance under the attematives cited in item D(1) above; l
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7 (e) Estimated costs of dose-based clearance levels associated with radioactivity in materials entering general commerce, including cost impacts resulting from t5e removal of readily available, low-radioactivity reusable equipment and materials from general commerce; and (f) Treatment of uncertainties and sensitivity analyses used in calculation of collective doses and costs.
(4) The TBC shall collect, organize, qualify, develop, and address information related to the design objective attributes for the cost / benefit analysis, as stipulated in NUREG/BR-0184, Section 5.5, in the following subject areas:
I (a) Public Health Accidents and Costs
' (b) Routine Public Health (c) Occupational Health Accidents !
(d) Routine Occupational Health (e) General Public (f) Industrial operations not licensed by the NRC - Irnplementation (g) industrial operations not licensed by the NRC - Operations The preceding information in item (4)(a)-(g) shall be supplied by the NRC TPM to the Contractor for the purpose of cost-benefit and other analyses under this Task Order.
E. The remaining subject areas listed in NUREG/BR-0184, Section 5.5 shall be collected, organized, qualified, developed, and addressed by the Contractor. The Contractor shall
- identify needed cost-benefit related data that are not readily obtainable from the
! information provided by the TBC. The Contractor shall identify the critical roles of those j data in the analyses, an approach for obtaining the data, a rough estimate of the level of i effort required to obtain the data, and the impacts of obtaining the data on the schedule
! ' for completion in a written communication to the NRC TPM. The Contractor shall, after <
the written approval and direction of the NRC TPM, obtain the needed data.
l 2.4 Provide the following products: 1 A. An information package delineating the standard format and content for cost / benefit analysis required for the TBC and any other contractor to use in order to prepare l information to be submitted for the Contractor's cost / benefit analyses.
i B. A preliminary assessment of the rulemaking attematives to be evaluated in the draft !
GE!S.
1 C. An annotated outline for a draft GEIS assessing rulemaking attematives for clearance of ;
materials, including soils, and eqvpment having residual radioactivity with format and content accordirtg to the applicable requirements in 10 CFR Part 51.
D. Upon receipt of the NRC TPM's approval of the annotated outline in item C and/or nny subsequent revisions thereof, the Contractor shall prepare a preliminary draft GEIS
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8 assessing altematives in clearance, including thots identified under the EPR and NEPA
- scoping process under Subtask 1 and addressing the provisions listed in items A-D above in this subtask .
E. Following review and approval of the preliminary draft GEIS, and/or any subsequent revisions thereof, by the NRC TPM, the Contractor shall prepare a revised draft GEIS reflecting comments and direction from the NRC TPM, the analysis nf public comments on the draft proposed rule, the attendant SOC and supporting documentation. The draft GEIS shall be provided to the NRC TPM for review and approval. Upon receipt of NRC approval, the Contractor shall prepare the draft GEIS for publication in the format of a NUREG report in compliance with 10 CFR Part 51, specifically Sections 51.70-74,85-86, and Appendix A to Subpart A.
2.5 The Contractor shallinclude this subtask's progress in the monthly report to the NRC TPM.
Subtask 3: Preparation of a Proposed Clearance Rule, SOC, and Draft Regulatory Analysis (RA) 3.1 The Contractor shall provide assistance to the NRC during rulemaking on clearance of materials and equipment having residua! radioactivity, including clearance of soil, from nuclear. facilities. Under this subtask, the Contractor shall provide assistance to the NRC in the preparation of a proposed clearance rule and any attendant amendment of existing regulations and of a draft RA used in support of such a proposed rule. Assistance from the Contractor shall also be needed in preparing the supplementary information supporting the rule, such as the products from Subtasks 1 and 2. Specifically, assistance in preparation of the RA shall include as a minimum the following RA sections:
A. Discussion of rulemaking attematives; and B.' Benefits and costs of the rulemaking to NRC, the affected industry, the public, and the environment.
3.2 Specific assistance in preparation of the supplementary information shall include the following:
A. Technical input of the type developed for the draft GEIS as noted in Subtak 2 above; B. Criteria for residual radioactivity for clearance and enforceability of the criteria, including aurvey methodology, QA/QC, record keeping, and other administrative controls for protection of public health and safety; C. Preparation of tables of radionuclides with quantities and concentrations corresponding to the limiting dose criteria in the proposed rule to be imposed on licensees intending to release material or equipment for recycle or to dispose of such material; a
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~ D. Technical input to the regulatory flexibility analysis; and E. Assistance in drafting, reviewing, and revising the rule text.
3.2- Input to the RA and proposed rule shall be based on results from Subtacks 1 and 2 and from the information provided by the TBC through the NRC TPM. The Contractor shall assist in preparation of these . sections for the rule, in analysis and response to public comment on these sections, and in preparation of the final proposed rule.'
3.3 The Contractor shall prepare a preliminary draft RA which evaluates the costs and benefits from clearance of materials and equipment. This preliminary draft RA shall identify and describe opt:ons for potential amendments thnt NRC can use in the proposed rulemaking and shall be based on the number of potential NRC licensees releasing cleared material and equipment that will be affected by such a rulemaking.
The draft RA should also assess the volumes of cleared material and equipment associated with such clearance rule alternatives. Specific supporting technical information on collective doses and costs shall be supplied to the Contractor for inclusion and use in the overall assessment of environmental impacts. Based on this information, the Contractor shall estimate and compare the costs and benefits of regulatory alternatives to'the licensee and the NRC. The preliminary draft RA shall include a Paperwork Reduction Act Statement and a Regulatory Flexibility Act Statement. A recommended epproach for proceeding with rulemaking shall be included in the preliminary draft RA on the basis of the preceding analysis. The preliminary draft RA shall be prepared in accordance with NUREG/BR-0058, Revision 2, " Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission," and NUREGER-0184,
" Regulatory Analysis Technical Evaludion Handbook," (January 1997).
3.4 The Contractor's products in this subtask include:
A. A preliminary draft RA of the altematives identified in the EPR and NEPA scoping processes discussed in Subtask 1. The RA should comply with the format and content
' as stipulated in NUREG/BR-0058 and NUREG/BR-Ol84. This preliminary draft RA should reflect and be consistent with the analyses and findings of the preliminary draft GEIS prepared according to Subtask 2, item 2.4.D.
B. : Following review and comment of the draft preliminary RA by the NRC TPM and any
- additional applicable data and information, the Contractor, at the direction of the NRC TPM, shall prepare a revised draft RA. This draft RA shall be consistent with the analysis, rationale and findings of the draft CEIS produced under Subtask 2, item 2.4.E.
C.' Preparation of and contribution to a draft Comn'ission information package consisting of:
- (1) Assistance in preparation of an FRN proposing a rule, with a SOC, based on the cost- benefit analysis of attematives addressed in the preliminary draft GEIS in Subtask 2; (2) The draft GEIS prepared under Subtask 2, item 2.4.E; and
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,e 10 (3) Relevant supporting documentation, either by direct inclusion or by reference, relating to the alternatives for the proposed rule on clearance.
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l 3.5 The Contractor shall include this subtask's progress in the monthly report to the NRC j TPM. t
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Subtask 4: Information/ Collection Burden Report Use information collected in Subtasks 2 and 3 to calculate / estimate the information collection burden impact on potential or existing licensees and NRC which will result from the proposed amendments. NRC shall provide the Contractor with the NRC format that has been used in the past for submittal of the burden report to OMB. The Contractor shall provide the information to the NRC in draft and final form.
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4.0 REPORTING REQUIREMENTS I i
in addition to the deliverables discussed in Section 10 below, the Contractor shall comply with the following reporting requirements and schedule:
- 1. As part of the performance of this Task Order, the Contractor shall provide a monthly written progress report by the 15* of the following month summarizing the work performed during !
the previous calendar month. Monthly status reports shall be self-contained and shall include an executive summary that suinmarizes the results with regard to the project objectives as defined in the statement of work for this Task Order. The executive summary shall be structured to enhance the usefulness oireports to the licensing staff and the agency l as a whole. Monthly letter progress reports shall describe the monthly level of effort by various levels of pay, the technical work performed corresponding to the billing, technical and administrative issues, a log of the expenditures, and a projection of the spendbg plan by subtask. Vouchers billing work performed shall be preceded by or accompanied with a monthly letter status report corresponding to and accounting for the billing. The monthly letter progress report shall break down the number of hours billed and percent of effort by st6ff level corresponding to the billing. Project spending plans and billings shall be at the subtask level. The monthly letter progress report or billing shallinclude a tracking of the spending plan, a cumulative accounting of the spending, as well as the current billing. The monthly progress letter report shall include a section that cleady identifies issues, difficulties, needed decisions on the part of the NRC TPM, and financial concems.
- 2. Biweekly teleconferences with the NRC TPM, other NRC staff, and other NRC staff contractors to discuss progress of the Task Order, problems needing resolution, delays or advances in the schedule of activities and products, potential modification of subtasks, and other topics pertinent to the successful completion of the Task Order. In the case of unexpected complications or potential delay to the deliverables schedule, the Contractor shall notify the NRC TPM within two working days. Should the complication not be resolvable by telephone communication, the Contractor shall not!'y the NRC TPM, in writing and within 5 days of telephone notification, of the inability to resolve such problems.
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- 3. ' Analyses for inclusion in published reports shall be explicitly reported in NUREG or NUREG/CR format as appropriate. These reports shall be technically edited and l
publication-ready, complete with background information.' Letter reports and intermediate reports shall be submitted in both hard copy and electronically. Word processing j submissions shall be in Wordperfect *, version 7.0 or greater; spreadsheets in EXCEL *, i version 5.0 or greater with design specifications sufficient to enable implementation in different spreadsheet software or in later versions. Other electronic formats shall be agreed upon w?th the NRC TPM.
- 4. The final reports for publication shall be delivered in Wordperfect, version 7.0 or greater electronic fctmat, with one camera-ready, single-sided version, and three double-sided copies.
- 5. The contra:. tor shall plan on one complete draft for one round of review and comment prior to finalizing the report.
5.0 TRAVEL AND MEETINGS 1 i
in addition to the travel and meetings specified in Subtask 1 for the EPR and NEPA scoping process, the Contractor should plan on periodic meetings with the NRC TPM at NRC Headquarters in Washington, DC. Likewise, the NRC TPM and other appropriate NRC staff will meet with key Contractor staff at the Contractor's central work facility to perform 2 - 5 day program reviews. As necessary and approved by the NRC Project Officer, key Contractor staff may need to travel to industry and govemment facilities to collect information and data needed to complete the contracted activities. The following trips and meetings are envisioned:
4 Public Meetings for EPR and NEPA scoping - 2 principal Contractor staff /1 administrative staff person - 2 days each.
2 NRC Headquarter meetings project status briefings with NRC staff- 3 principal <
, Contractor staff persons - 2 days each.
2 NRC program review meetings - 1 Contractor staff person to travel to Contractor central work facility 2-5 days each. .
3 Data /information gathering trips - 1 Contractor staff person 5 days each.
Because the actual destinations and number of trips required for this Task Order are uncertain at this time, the Contractor shall use the proposed travel costs of $14,700.00.
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) Contractor shall provide, to the NRC TPM, completed draft sections of major reports, as they become available. This is intended to optimize the production schedule of deliverables by affording the NRC the opportunity to furnish early feedback to the Contractor as these reports are being prepared.
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6.0 PERIOD OF PERFORMANCE The overall period of performance for this Task Order is approximately 22 months. Subtasks 2 and 3 are not sequential, therefore, the Contractor can work on these subtaske simultaneously.
The Contractor can work on Subtask 4 once Subtask 3 results are available.
7.0 LEVEL OF EFFORT Totallevel of effort for this Task Order is estimated to be 31 staff months.
- 8.0 NRC-FURNISHED MATERIALE Copies of draft and final NUREG and NUREG/CR publications and other report generated for the NRC shall be provided to the Contractor as specified in this Task Order and/or on the l specific request of the Contractor.
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'9.0 TECHNICAL DIRECTION
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Technical direction shall be through a single point of contact, the NRC TPM, or his designee. l The NRC TPM for this Task Order is Giorgio N. Gnugnoli. Mr. Gnugnoli can be reached at 301-415-7135. {
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,, ..w 15 11'.0 ADDITIONAL INFORMATION AND REFERENCES
~ Radiation Protection Standards for Scrap Metal:' Preliminary Technical Support Document (TSD), EPA.7 Radiation Protection Standards for Scrap Metal: Preliminary Cost-Benefit Analysis, EPA.7 The New Orphaned Radioactive Sources Program in the United States, Intemational Conference on the Safety of Radiation Sources and the Security of Radioactive Materials, EPA, September 14-18,1998.7 lAEA TECDOC-855, Clearance Leveis for Radionuclides in Solid Materials, Interim Report for Comment, January 1996.
OECD/NEA, Recycling and Reuse of Scrap Materials,1996.
EC, Radiation Protection 89, Recommended Radiological Protection Criteria for the Recycling of
' Metals from the Dismantling of Nuclear installations,1998.
' NRC lasues Paper for Discussion, Clearance of Materials and Equipment Having Residual Radioactivity, March 1999.
' NUREG/CR 6156, Summary of Comments Received from Workshops on Radiological Criteria for Decommissioning, January 1994.
NUREG/CR-6353, Comments Received on Proposed Rule on Radiological Criteria for Decommissioning and Related Documents, March 1996.
Final Regulatory Analysis for Radiological Criteria for License Termination, NRC.
Draft NUREG-1640, Radiological Assessments for Clearance of Equipment and Mate.*ials from Nuclehr Facilities, December 1998.
SRM did 6/30/98 relating to SECY 98-028. ,
7These references are downloadable from the EPA home page with URL -
http:#www. epa. gov / radiation /cleanmetals/ publications.htm#cba
.