ML20199B767
| ML20199B767 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1998 |
| From: | Wiggins E NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Beckman D, Plunkett M, Wood D AFFILIATION NOT ASSIGNED |
| References | |
| CON-GENERAL NUDOCS 9801290014 | |
| Download: ML20199B767 (272) | |
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[- *, UNITED STATES c
'je NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2064 6 0001 ,
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_ ' OFFERORS: g E
SUBJECT:
REQUEST FOR PROPOSAL NO. RS-NRR-98-021 ENTITLED,
( " TECHNICAL ASSISTNCE IN SUPPORT OF NRC INSPECTIONS AT
- NUCLEAR POWER PLANTS AND ENGINEERING SERVICE ORGANIZATIONS" The U.S. Nuclear Regulatory Commission (NRC) is soliciting proposals for the project entitled above. The full scope of work anticipated is as set forth in Part I, Schedule. ,
This requirement is a 100% Small Business Set-Aside. The h.
r Standard Industrial Classification Code (SIC) for this acquisition is 8711. The small business size st.andard is no ,
more than $2.5 million average annual receipts for an offeror's -
preceding three fiscal years. A cost-plus-fixed-fee, .
indefinite quantity, type contract is anticipated with a base period of performance of three (3) years with two (2) one-year option periods.
nI The solicitation package is enclosed. If you desire to Q respond, your proposal should address the proposal vequirements .J set forth in Section L of the solicitation. All proposals will if l; be evaluated against the evaluation criteria shown in Part IV, -Q Section M. f
~-
Please be advised that all offerors shall make an ORAL --
Technical and Management Presentation. See Section L.14 of the ..
- solicitation for further information. In addition, the RFP closing date is February 13, 1998.
If you have any questions concerning the requirements of this solicitation, please contact Mona Selden, Contract Specialist, on (301) 415-7907 (collect calls will not be accepted). /
Sincerely, .
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~Elois J. Wiggins4 Contracting Officer 9801290014 98012a Division of Contracts and T Property Management R ,M I f' y Enclosure,y , yi pi pu\3[ h,gn': \wl.\\1\
._ CON - .As stated
. . . ,. . .- . . ~ , . .- -- ... . ... _. . . . . . . . . .
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'l Page 1 01/26/98 t
BIDDER'S MAILING LIST FOR
-- SOLICITATION NUMBER: RS-NRR-98-021
~
COMPANY- PHONE i /-FAX
, , - .4... ,o JLarg,e_Busine,ses are Identified with an Asterisk) , _, ,, , ,,, ,
Advent-Engineering Services, Inc. 313-930-7500 ,
Douglas =C. Wood .
Donino's Farms P.O.: Box'555- ,
Ann Arbor, MI.48106, ,
BECKMAN AND ASSOCIATES 412-872-9157 DON BECKMAN 1071 STATE ROUTE 136 BELLELVERNON, PA 15012 P.AS ENERGY: SERVICE NO PHONE MICHEL PLUNKETT 33 COLLEGE HILL ROAD BLDG 25F WARWICK, RI 02886 Excel' Services Corporation 301-984-4400 Donald Hoffman 11921 Rockville-Pike:
Suite-100
.Rockville, MD 20852-General Physics Corporation 410-290-2489-Donald Duquette 6700 Alexander Bell Dr.
n:wf : Columbia, MD 21406-J.M.'LEIVO ASSOCIATES 301-831-3003 JIM LEIVO 5615 CATOCTIN RIDGE DR
=MT.-' AIRY, MD 21771
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~~ N P T S ,>'L I n c ;:.
.' . 716-633-2775- ,
Hormoz'Mansouri 4455 Transit Road-
- suite 2CJ
'Williamsvillei NY 14222 b
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Page 2-
. 01/26/98 BIDDER'S MAILING LIST FOR- -I SOLICITATION NUMBER: RS-NRR-98 021 -
COMPANY PHONE / FAX 9- _
t, ]Large,Businose,s.are,, Identified with an Asterisk); , , , , , ,
E lNUENERGY INC 215-396-9123 l l
MICHAEL SH7YAMBERG ^
421 GLEM MEADOW ROAD l RICHBORO, pax 18954 PARAMETER, INC 414-786-7580 Richard A. Lofy 414-786-0419- L; 13380 Watertown Plank Rd.
Elm Grove, WI 53122-J POWERDYNE CORPORATION 610-398-9277 DON PREVATTE
-7924 WOODSBLUFF RUN FOGELSVILLE, PA-18051-t Proto-Power Corporation- 860-446-9725 Raymond Rugg
,- 15 Thames Street Groton, CT 06340 j-REGULATORY-AND TECH. AJVISORS 423-671-0833 KIRK' VAN DYNE '
10305 CASTLEBRIDGE COURT KNOZVILLE, TN 37922
! SYSTEMS RESRARCH'INTERNAITONAL 410-685-3833 OMAR MAZZONI 120-E..-BALTIMORE STREET SUITE 1910
' BALTIMORE;-MD 21202
- . -Stevenson and. Associates 216-587-3805 l
_ Timothy. Adams- ,
u '" 9217..MidwestoAvenue..
- - "' Cleveland, OH 44125 ~
The.Kevric Company, Inc. 301-588-6000 Managers. .
1 Silver. Spring Metro Plaza One 8401:Colesville-Rd. Ste.610 Arlington,_VA 20910- 7
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Page 3 01/26/96 BIDDER'S MAILING LIST FOR SOLICITATION NUMBER: RS-NRR-98-021 COMPANf . ' PHONE ~/ FAX (Large Busineses_are Identified with an Asterisk)- ,.
Vista Technologies 703-416-6878 Manager 1235 Jefferson Davis Highway Crystal Gatewayl, Ste.1100 Arlington, VA 22202 , , ,
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1.THrS CONTRACT #S A EATFp ORDga i S2WCITAT12N, CFFER AND AWARD Uuota DPA$ oS C a :So' k KATiNO N/A lPAGE l Osram, !
2 CONTRACY NO. 3 SOUCfTAYiON NO 4, TYPE OF SOuCIT ATON 5 DATEISSVED G MOVISITIONWRCHASE NO. '!
NRR 98 021 01/23/98 1
[X] NrOofiattD!Rm 7 ISSUED eV. s ADDRESS OFFER TO at eihe, then tiem Ti j CooE l U.S. Nuclear RRgulatDry COmm>$sion l DeViliOn of Contracts and Property Mgt. l Attro T 7+2 Washington DC 20565 NOTE eee s,e . owe,,ons ener onet. sere m.en e ence.aer .
SOLICITATION e Se.ed .nere in on as endF_oVRjd) so,,e to, su manmg r the supphe 9, serv.ces en the Scheduce wdl be ecce ved at the Piece noecit ed m item 8. or d henecerned m the gep05&v laceted m
_ item 7 % 3:30 P.M. ise ..e 02/13/98 (Howel Detel CAUTCN . LATE Su6messons. Mod hcotena. and withdreews See Sect A L. Prowson No $2 214 7 or $2 21810 As Otters are soberst to en terme end cor on.ons centened m seus schestaten.
- 10. FOR INF08edAflOef CALL: A NAVE 9 TELEPHONE tJO pactedt eres sodel (NO COLLECT CALLS)
Mona C. Selden (30H 416 7907 t t. T Asta OF CONTENTS See Attached Table Of Contents 8%)
l SEC. l DESC8vPTON l PAOf tS) fxl l SE C. l DESCRlPTION l PAOEIS) i 5
PART I
- THE SCHEDULE RT 11 CONTRACT CLAUStS A SOUCt1 AtcyCONTRACT PORM l 4 l CONTRACT CLAUSt$ l 8 SUPPLIES OR SERVICES AND PRICES / COSTS PART Hi LIST OF DOCUMENTS. (KH:0lTS AND OTHER ATTACH C DESCRIPTIOwseECS swCRs STATEMENT l J l LIST OF ATTACHMENTS l 0 PACK AGING AND MARKING PART IV MEPRtSENTAfsONS AND WSTRUCTIONS I WSPtCTION ANO ACCEPTANCE g REPRESENT ATIONS CERTIFICATONS AND OTHER F DELNE RIES OR PERFORM ANCE SA M N $ OF OWRORS O CONTRACT ADMINISTRATON DATA L INSTR . CONOS . AND NOTICtS TO OFFERORS H SP(CIAL CONTRACT REOUIRf MfNTS M EVALUAftON f ACTORS 704 An tD OFFEH (Must be fully completed by offeror)
NOTE. Item 12 does not oppsy d the schestaten includes the prowesons et $2.214-te, Mirumurn Ed Acceptence Pened.
= 12 in aesnessence with the above. tfie underwened egrees. If ttus etter as eccepted wittwn seiender Wevs 160 calender deve vasess e different pened es enserted av the otterett from tne date for escaset et etters specahed above. to tunwoh any or se items upon wtwch pnces ese guered et the pnce set oppoeste tech item. dehvered et the deggnated pointisl. within the time specatied m the
_ Schedule t3. OtSCOUNT FOR PROMPT PAYMENT to CAttNDAR DAYS 20 CALINDAR DAYS 30 CALENDAR DAv3 CALENDAR DAYS ISet Secten 1. Cteuse No.52-232 81 g 14 ACENOWLEOQEME 5 r OF AMINDMINTS AMENDMENT NO. DATE AMENDMENT NO DATE (The ottetor acknow6 edges rece pt of einendments to the SOttCIT AflON tee ef terare and esisted documents mumbered and dated
"*"I ! f AND COct FACILITY !. . _ to. NAME,AND TITLE OF PERSON AUTHORIZED TO SiON OFFER ne.e . -o ADDRESS OE OFFEROR
. ISS TELE' HONE NO enclude area codel ISC. CHECK IF REMITTANCE ADORESS IS DIFFERENT PROM 17. SIGNATUM 18. OFFER DATE ABOVE > ENTER SUCH ADDRESS IN SCHEDULE AWARD (To be completed by Government) 18 ACCEPTIO AS TO C'MS NUM6 FRED 20. AMOUNT 21, ACCOUNTING A*C APPROPRIATIC
- 22. AUTHORITY FOR U$aNG OTHER THAN FULL ANO OPfN COMPETITON: 23 SveMIT INVOICIS TO ADDttESS SHOWN IN ITEM to U.S C. 2304tel i ~l [ ' 41 U S C. 262td i i 14 cop *ee vedese otherwise specifiedt
- 2. .-,, Sum dv 2'Av= = =i -= a
,,e e~ ~, iten, n C.EI ca< i
- 24. NAME OF CONTRACitNG OFFICaR (Tvoe or pnno 27. UNITED STATES OF AMERICA 28. AWARD DATI (Sgnature of Centractmo Otticeet j IMeOftTANT = Amerd wel be #riede en ttes Perm. er en Stended Peren 26. er by other authensed Othesel wetten nonce.
STANDAfD FORM S3 1REW,4-$$1 i-
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TABLE OF CONTENTS . PAGE ,
PART I - THE SCHEDULE. . - - . . . . ... . . . .. .. . . . . . . . . . . . . -A-1 i
SECTION A - SOLICITATION / CONTRACT FORM . . . . . - . . . .. . . . . . . . . A-1 SF 33 SOLICITATION, OFFER AND AWARD. . . . . . . . . . . . . . . . . A-1 SECTION B'- SUPPLIES OR SERVICES AND PRICE / COSTS . . . . . . . . . . . . B-1 B.1 PROJECT TITLE , . . . . . . . . . . . . . . . . . . . . . . . B-1 B.2- BRIEF DESCRIPTION OF WORK (MAR 1997). . . . . . . . . . . . . . . B-1 ALTERNATE 1 (JUN 1988)
.B.3 CONSIDERATION AND OBLIGATION--TASK ORDERS (AUG 1989). . . . . . - B-1
-ALTERNATE 1 (JUN 1991)
B.4. MINIMUM AND MAXIMUM QUANTITIES. . . . . . . . . . . . . . . . . B-2 SE TION C - DESCRIPTION / SPECIFICATIONS / STATEMENT OF WORK . . . . . . . . C-1 C.1 BACKGROUND. . . . . . . . . . . . . . . . . . . . . . . . . . . C-1 C.2 . CONTRACT OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . C-2 C.3 WORK REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . C-2 C.4 ESTIMATED LEVEL OF EFFORT . . . . . . . . . . . . . . . . - . . . C-5 C.5: PERSONNEL QUALIFICATIONS. . . . . . . . . . . . . . . . . . . . C-5 C.6 MEETINGS AND TRAVEL , . . . . . . . . . . . . . . . . . . . . . C-5 SECTION D - PACKAGING AND MARKING. . . . . . . . . . . . . . . . . . . . D-1 >
D.1 PACKAGING AND MARKING (MAR 1987). . . . . . . . . . . . . . . . D-1 6dCTION E - INSPECTION AND ACCEPTANCE. . . . . . . . . . . . . . . . . . E-1 E.1 NOTICE LISTING CONTRACT CLAUSES INCORPORATED BY REFERENCE . . E-1 E.2 PLACE OF INSPECTION AND ACCEP"ANCE (MAR 1987) . . . . . . . . . E-1 SECTION P DELIVERIES OR PERFOPJ4ANCE. . . . . . . . . . . . . . . . . . F-1 F .1- NOTICE' LISTING CONTRACT CLAUSSS INCORPORATED BY REFERENCE . . . F-1 F.2 NRCAR 2052.212-72 FINANCIAL STATUS REPORT (DEC 1995) . . . . . F-1 F.3 PLACE OF DELIVERY--REPORTS (JUN-1988) . . . . . . . . . . . . . F-2 F.4 RESOLVING NRC CONTRACTOR DIFFERING PROFESSIONAL VIEWS . . . . . F-3 (DPVs)
F.5 DURATION OF CONTRACT PERIOD (MAR 1987). . . . . . . . . . . . . F-3 ALTERNATE 4 (JUN 1988)
F.6 TECHNICAL REPORTING REQUIREMENTS FOR EACH INSPECTION. . . . . . F-3 F.7 MONTHLY BUSINESS LETTER REPORTS . . . . . . . . . . . . . . . . F-4 F 7.1 I. -WORK PROGRESS STATUS. . . . . . . . . . . . . . . . . . F-4
. F.7.2 II. FINANCIAL STATUS SECTION. . . . . . . . . . . . . . . . F-6
-F.7.3 III. CONTRACTOR SPENDING PLAN. . . . . - . . . . . . . . . . F-6 F.7.4 IV. DELIVERABLES SUBMITTED DURING THE PE, )D. . . . . . . . F-6 SECTION G -' CONTRACT ADMINISTRATION DATA . . . . . . . . . . . . . . . . G-1
-G.1 2052.215 PROJECT OFFICER AUTHORITY. . . . . . . . . . . . . G-1 G.2 2052.215-82 TFAVEL REIMBURdEMENT-ALTERNATE 1 . . . . . . . . . G-2 LG.3- 2052.215-83 TRAVEL APPROVALS .. . . . . . . . . . . . . . . . .G-3 G.4 2052.216-71' INDIRECT COST RATES. . . . . . . . . . . . . . . . G-3 G . 5 -- -2052.216 TASK ORDER' PROCEDURES. . . . . . . . . . . . . . . G-4 G.6 :2052.216-75 ACCELERATED-TASK: ORDER PROCEDURES. . . . . . . . . G-5 G.7- ORDERING PROCEDURES (MAY:-1991). . . . . . . . . . . . . . . . . G-6 G' 8 -ELECTRONIC: PAYMENT. .. . . . . . . . . . . . . . . . . . . . . . G-6 1
SECTION~H -__SPECIAL CONTRACT REQUIREMENTS. . . . . . . . . . . . . . . . H-1 L H .1~ J2052.204-70 -SECURITY-.- -
.. ' . . . ... . .. . . . . . . . . H-1 v
(*Y
i TABLE OF CONTENTS PAGE
-H.2 2052.204-71 ' SITE ACCESS BADGE REQUIREMENT. . . . . . . . . . .-H-3 H.3 2052.209-73 CONTRACTOR' ORGANIZATIONAL CONFL' CTS. . . . = . . . . . H-3
'OF INTEREST
'H.4 2052.215-70 KEY PERSONNEL. . . . . . . .. . . . . . . . . . ._H-7 H.5 GOVERNMENT FURNISHED EQUIPMENT / PROPERTY - NONE PROVIDED . . . .-H-8' (JUN 1988)-
H.6 LICENSE FEE RECOVERY COSTS.(APR 1992) . . . . . . . . . . . . . H-8 H.7 -CONTRACT SECURITY REQUIREMENTS FOR UNESCORTED ACCESS. . . .. . H-8
.TO NUCLEAR POWER PLANTS (FEB.1995)
H.8 SEAT BELTS. . . . . . . . . . . . . . . .. . . . . . . .. . . H-10 H.9- -NRC FURNISHED MATERIAL. . . .- . . . . . . . .. . . . . . . . . H-10 H.10 'OTHER APPLICABLE INFORMATION. . . . . . . . . . . . . .. . . . H-10
-H.11 CONTRACTOR RESPONSIBILITY . . . . . . . . . . . . . . . . . . H-11 PART_II- - CONTRACT CLAUSES. . . . . . . . . . . . . . . . . . . .. . . I-l' SECTION I -
CONTRACT CLAUSES . . . . . . . . . .. . . . . . . . . . . I-1 I.1 NOTICE LISTING CONTRACT CLAUSES INCORPORATED BY REFERENCE . . . I-1 I.2 52.216-18 ORDERING (OCT 1995) . . . . . . . . . . . . . . . . I-2 I.3 52.216-19 ORDER LIMITATIONS (OCT 1995). . . . . . . . . .- . . I-3 I .'4 - 52.216-22 INDEFINITE QUANTI **? (OCT 1995). . . . . . . . . . .-I-3 I.5' '52.217 OPTION TO EXTEND L 'Emi OF THE CONTRACT . . . . .. . I-4 (MAR 1989)
I.6 52.232-25 ' PROMPT PAYMENT (JUN 1997) . . . . . . . . . . . . . I-4 PART III - LIST OF DOCUMENTS, EXHIBITS-AND OTHER ATTACHMENTS . . . . . . J-1
-SECTION J - LIST OF ATTACHMENTS. . . . . . . . . . . . . . . . . . . . . J-1 PlutT IV --
REPRESENTATIONS AND INSTRUCTIONS . . . . . . . . . . . . . . K-1
'SECTION K - REPRESENTATIONS, CERTIFICATIONS AND . . . . . . . . . . . . K-1 OTHER STATEMENTS OF OFFERORS K.1 NOTICE LISTING SOLICITATION PROVISIONS INCORPORATED . -, . . . . K-1 BY. REFERENCE K.2 52.203-8 CANCELLATION, RECISSION, AND RECOVERY OF FUNDS. . . . K-1 FOR ILLEGAL OR IMPROPER ACTIVITY (JAN 1997)
K.3 52.204-3 TAXPAYER IDENTIFICATION (JUN 1997) . . . . . . . . . K-2 K.4 52.209-5 CERTIFICATION REGARDING DEBARMENT,-SUSPENSION,. . . . K-3 PROPOSED DEBARMENT, AND OTHER RESPONSIBILITY MATTERS (Wut 1996)
K.5 52'.215-4 TYPE OF BUSINESS' ORGANIZATION (OCT 1997). . . . . .. K-4 K.6 52.213-6 PLACE OF PERFORMANCE (OCT 1997)_. . . . . . . . . . . K-5
- K.7' 52.219-1 SMALL BUSINESS PROGRAM REPRESENTATIONS. . . . , . . . K-5 (JAN.1997)
K. 8- 52.222-22 PREVIOUS CONTRACTS AND COMPLIANCE REPORTS. . . . . . K-7 (APR 1984)
.. -K.9 52.222-25 AFFIRMATIVE ACTION COMPLIANCE (APR-1984). . . . . . K-8 K.10 52.223-1 CLEAN AIR AND WATER CERTIFICATION- (APR 1984) . . . . K-8
- K.11 2052.209-70 QUALIFICATIONS-OF CONTRACT EMPLOYEES.. . . . . . . K-8 K.12 2052.209-71 CURRENT /FORMER AGENCY EMPLOYEE INVOLVEMENT . .. . K-8 K.13 2052.209-72 CONTRACTOR ORGANIZATIONAL CONFLICTS OF . . . . . . K-9 INTEREST REPRESENTATION SECTION L:- INSTRUCTIONS, CONDITIONS, AND NOTICES TO OFFERORS. . . . .. L-1
TABLE OF CONTENTS PAGE
-L.11 NOTICE-LISTING SOLICITATION PROVISIONS INCORPORATED . .. . . . . L-1
- BY REFERENCE L . 2 .. 52.204-6 CONTRACTOR' IDENTIFICATION NUMBER--DATA'. . . . '
~.
.-L UNIVERSAL NUMBERING SYSTEM (DUNS) NUMBER-(DEC 1996)
L.3 52.215-20 REQUIREMENTS FOR COST OR PRICING-DATA-OR .. . . . . L ;
INFORMATION OTHER.THAN COST OR PRICING DATA (OCT 1997).
- ALTERNATE IV (OCT 1997)
L.4 ~ 52.216_-1 TYPE OF CONTRACT. (APR 1984). . . . . .. . . . . . . . L-2
- L.5 52.216-27 SINGLE OR MULTIPLE AWARDS (OCT 1995) . . . . . . . . L-2 L.62 52,-233-2 SERVICE-OF PROTEST- (AUG 1996). . . . . . . . . . . . L-3 L. 7. 52.252-1 SOLICITATION PROVISIONS INCORPORATED BY . . . . , . . L-3 REFERENCE (JUN 1988)
L.8 2052.215-76 DISPOSITION OF PROPOSALS . . . . . . . . . . . . .. L-3 )
L9 - 2052.222-70 = NONDISCRIMINATION BECAUSE OF AGE . . . . . . . . . L-4 i L.10 ESTIMATED DURATIOd (JUN 1988) .. . . . . . . . . . . .. . . . L 3 L.11 - USE OF AUTOMATED CLEARING HOUSE (ACH) ELECTRONIC. . . . . . . . L-4 i PAYMENT / REMITTANCE ADDRESS L.12 TIMELY RECEIPT OF PROPOSALS . . . . . . . . . . . . . . . . . . . L-4 L .' 13 : AWARD NOTIFICATION AND COMMI"NENT OF PUBLIC FUNDS . . . . . . ..L-5
'L.14 PROPOSAL PRESENTATION AND FORMAT. . . . . . . . . . . . . . . . L-5 L.15 ESTIMATED LEVEL OF EFFOkT/ ASSUMPTIONS / ESTIMATES FOR PROPOSAL .-L-7 PREPARATION L.16 COST PROPOSAL REQUIREMENTS AND FORMAT . . . . . . . . . . . . . L-9 L.17 INSTRUCTIONS FOR OPAL TECHNICAL AND MANAGEMENT. . . . . . . . . L-10 L.17.1 TOPICS FOR ORAL TECHNICAL AND MANAGEMENT . . . . . . . . . . L-11 SECTION M - EVALUATION FACTORS FOR AWARD . . . . . . . . . . . . . . . . M-1 M.1 52.217-5 EVALUATION OF OPTIONS _ (JUL 1990) . . . . . . . . . . M-1 M.2 2052.215.84 CONTRACT AWARD AND EVALUATION OF PROPOSALS . . . . M-1 M.3 EVALUATION CRITERIA . . . . . . . . . . . . . . . . . . . . . . M-2 4
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'NRR-98-021' Soction?B PART I'- THE-SCHEDULE SECTION'B"-~ SUPPLIES OR SERVICES AND 7 PRICE / COSTS
-B.1- PROJECT TITLE The title of this project is as follows:
TECHNICAL ASSISTANCE-IN SUPPORT OF NRC INSPECTIONS AT NUCLEAR' POWER PLANTS AND ENGINEERING SERVICE ORGANIZATIONS B.2: BRIEF DESCRIPTION OF WORK (MAR 1987)
ALTERNATE 1 (JUN 1988) '
.~(a) Brief. description of work:
The Contractor shall provide expert technical assistance to assist NRC inspection teams in evaluating the design, installation and operation of electrical power systems, instrumentation and control systems, mechanical systems, mechanical components, and civil / structural system elements. The primary. objective is to support the review of design related activities. The secondan objective is' to support the non-design elements of the inspection, e.g.,-maintenance, surveillance, management effectiveness, testing, installation, and operation.
(b) Orders will be issued for work required by the NRC in
-accordance with 52.216 Orderino.. Only Contracting Officers of
'the NRC or other individuals specifically-authorized under this contract may authorize the initiation of work under this contract.
- The provisions-of this contract shall govern all orders issued hereunder.
Bi3' ._ CONSIDERATION AND OBLIGATION--TASK ORDERS (AUG 1989)
' ALTERNATE 1 (JUN 1991) l(a)LThe' Maximum Ordering Limitation (MOL) for products and services ordered, delivered and accepted under tnis contract is * (TO
-BE. COMPLETED IN.ANY RESULTANT-CONTRACT)'. The Contracting Officer may 3 place' orders'with the contractor during the. contract period provided the aggregate amount of'such' orders.does not exceed the MOL.
g..(b)-The'guaranteedLminimum obligated b'y the Government under this-contract 'is * (TO' BE COMPLETED . IN ANY - RESULTANT CONTRACT) .
B-1
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fNRR-_981 021 -Saction'B:
(c)LA.t'otal estimated cost as wellfas any fee, if any, will:be; 1
, _ negotiated.:for each task order and will be incorporated as. : ceiling.
in-theLresultantitask order. The Contractor shall! comply with the-
- orders provisions'of:- 52.232-20-;--
and:52.232-22c- -
Limitation:of Limitation-of Cost Funds forfor fully; funded:funded-incrementally task'-
, task orders,-issued hereunder.
~
B.4- MINIMIM AND MAXIMUM QUANTITIESc
'Itiis' anticipated that approximately124 task orders 1per: year will-be
- issued during the three-year base period of performance and that Sc? proximately-24 task orders will be-issued during each o? tion year.
Tae-minimum quantity that;the-Government;will order and the Contractor shall furnish will be at-least 5% of the. mutually agreed-i upon ceiling-amount.of-therresultant contract. The maximum quantityL ,
- tae Government will order and-the Contractor shall furnish shall not '
l cxceed'the-mutually agreed upon ceiling amount of the resultant-contract.: ,
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NRR-98-021 Section C SECTION C - DESCRIPTION / SPECIFICATIONS / STATEMENT OF WORK C.1 BACKGROUND The complexity and extent of design related errors that have been identified in recent years have caused the Nuclear Regulatory Commission (NRC) to increase its inspection efforts for operating plants. In addition,-problems related to non-design areas (maintenance, operations, management, surveillance testing) either separately or conjoined with design errors have reflected on the ability of plants to perform their safety functions.
As part of the program to assess the safety of nuclear power plants and to obtain additional assurance that nuclear power plants conform to Final Safety Analysis Report commitments and NRC regulations, the NRC performs various inapections and overviews licensee self-initiated assurance measures.
The NRC performs direct inspections of various types at operating plants and engineering service organizations. Some typical inspections are as follows:
Safety System Functional Inspections (SSFIs) and Safety System Engineering Inspections (SSEIs) assess selected safety-related systems of operating plants that may have been significantly modified since receipt of the operating license to verify that the systems are capable of performinT
- heir intended safety functions.
For example, Electrical Distribution System Functional Inspections (EDSFIs) are a type of SSFI that focuses on the electrical distribution sy, tem; the Service Water System Operational Performance Insgections (SWSOPI) are a type of SSFI that focuses on the mechanical components of the service water system. Operational Salety Team Inspections (OSTI) are in-depth reviews of plant operational programs, including maintenance, operations, surveillance, testing, corrective actions, management oversight, and engineering and technical support. Engineering Inspections evaluate the licensee's engineering activities, particularly the effectiveness of the engineering organization to perform routine and reactive site activities, including the identification and resolution of technical issues and problems. These inspections are performed in accordance with procedures in the NRC Inspection
- Manual, other inspections cover areas such as operational readiness for plants nearing restart, shutdown risk, service water systems, motor operated valves, and vendor design of components and equipment. In addition, NRC continually evaluates the need for new inspection concepts based on emerging problem areas. Inspection results are documented in inspection reports that are available in the NRC public Document Room.
C-1
NRR-98-021 Soction C C.2 CONTRACT-02JECTIVES The objective of this procurement is to obtain expert technical assistance to assist NRC inspection teams in evaluating the design, installation and operation of electrical power systems, instrumentation and control systems, mechanical systems, mechanical components, and civil / structural system elements. These inspections address both design and non-design elements. The primary objective of this contract will be to support the review of design related activities (design inspection). The secondary objective will be to support the non-design elements of the inspe'..-inns (e . g . ,
maintenance, surveillance, management effective #ss, testing, and installation and operation) and assess the integcsted operation of the plant.
Design inspections are part of the program to ensure that the design '
process used in constructing and modifying operational nuclear
. plants has complied fully with NRC regulatory requirements and licensee commitments, and results in a design where safety systems function as intended by the designer. These inspections are intended to provide a close examination of the design process and implementation for a limited sample of structures, systems or components fcr a specific facility.
For operating plants, design inspections address the design aspects of plant safety system functionality including review of incorporated or proposed plant modifications, as well as an casessment of the measures for ensuring proper design control.
The. design inspections typically include multi-discipline reviews that address areas such as mechanical systems, electrical power distribution systems, mechanical components, civil / structural features, and instrumentation and control systems.
Identification of lessons learned from these design inspections, including assistance in the preparation of generic communications, is an important part of this project.
C.3 WORK REQUIREMENTS This is a task order contract in which task orders will be issued by the NRC Contracting Officer at the sole option of the NRC. Refer to Section G regarding Task Ordering Procedures.
-The' scope of work involves furnishing any and all of the technical disciplines required for the annual performance of approximately 24 inspections. These inspections may include an overview of licensee engineering practices and. design / configuration control measures.
In response to task orders issued by'the NRC Contracting Officer,
.the Contractor shall provide, as requested, the necessary qualified personnel, facilities, test / inspection equipment, materials, and cervices required to. assist NRC staff in conducting inspections--at reactor sites, licensee offices, architect / engineering offices, and vendor facilities. Included'in this technical assistance is the C-2
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JNRR-98-021' l1
- follow-upioftinepactiontroletedEinouco end' findings.
In: examining a system, structure,Lcomponent'or operational program ,
at(operating plants, the. design--inspection or review will normally i
.focusion. topics suchLasi>
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Validity lofEdesign-inputs,-methods and-assumptions- :
Validity of-desi n specifications !
ValidityLof anal sis !
- Identification o -system interface requirements {'
Potential. synergistic effects of-changes Proper component classification-Revision-control Document control- ..
- Verification of as-built; condition against design ;
. output documents '
- Testing and functionality of des'ign products Past audit or inspection: findings .:
- Known and suspected deficiencies
-- Non-design elements of an inspection-may include operations, maintenance, testing and surveillance.- -These. elements focus on Ltopics such ast- .;
' Material condition'of1 the equipment Incorporation of design assumptions,. operational restrictions and vendor information into operating, maintenance,Ltest,-training, and surveillance procedures l ; Field verification ~of.as-built equipment relative to
- design documentation Verification that instrument calibration procedures are consistent with calculations 4
Verifying that adequate physical' separation / independence is maintained between channels / divisions verifying that test equipment accuracies are consistent.
- with calculational assumptions l
- Verifying that engineering and technical support and maintenance during operations are adequate and are supported by. operational control procedures -
- LAfdesign-inspection of a' Nuclear Steam System Supplier or-L
-Architect / Engineer consists-of a review of the-design: services
-provided.- The-purpose of,this inspection'is to determine whether
. the: design services; supplied'to the licensee ensure that the
--relevant-systems ~are: capable of performing.their intended functions and are11niaccordance'with. licensee commitments and regulatcry
- requirements.
- Thef. scope!ofnthe inspection'may beLmodified by NRC.to be responsive
!H :to. unique conditions att-a particular-facility.
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NRR-98-021 Ssction C As-will be detailed in the individual task' order statement of work, Contractor specialists will assist NRC staff in performing _
cetivities such as: ,
-(a) reviewing background information (b) recommending' specific areas and issues to be. reviewed during the inspection =
(c). reviewing detailed design analyses, calculations and' installation and operational attributes (d) performing independent calculations, where appropriate (e) examining plant hardware for.conformance with design (f) reviewing implementation and effectiveness of quality casurance and quality control programs
.(g) documenting the portion of the inspection conducted by the contractor specialist (h) reviewing reports of licensee self-initiated programs for occuracy, completeness, and acceptability
- (i)- reviewing licensee responses to inspection findings and concerns.and providing written evaluations of the responses (j)- reviewing any additional information to evaluate the design or design process of the facility and to close out inspection findings end concerns (k) nroviding expert testimony on problems, issues and allegations et pub'11c hearings that result from inspections and reviews, as necessary
-(l) documenting the results of inspections and reviews and other assignments frcm the Project Officer (m)- providing an internal quality assurance program to ensure Contractor tasks are conducted in an efficient and satisfactory manner.
-The issuance of a task older to obtain contractor technical casistance for each-of the various-inspections and reviews will be ot the-discretion of the NRC.
10 typical inspection team at a nuclear power plant may include an NRC team leader, other NRC inspectors and personnel, and Contractor cpecialists in one or more of the following technical disciplines:
olectrical. power systems, instrumentation and controls, mecaanical cyntems, mechanical components, and civil / structural.
Typical inspections include one to three Contractor specialists, but C-4
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NRRa98-0211 Sdction C j
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- 'moro:mny ba;necdad;for~largor inapections._ A-typical inspection !
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[. 1 jschedulelin~as followsi -
(a)e ' initial preparation:- 5 to-10 days 4(5Lda m offices >and/or;5 days at-NRC regional office).ystat? site / design)
Theltime'on site may< .
-includefeita: access-radiation; training. , y l
(b_) .* J ' first insp'ection at plantfsite/ design _ offices - 5 days a
(c)- : review of initial-inspection findings 5 days-at ;
Contractor's bome office or at NRC regionalLoffice y ;(d)* second inspection.atiplant site / design offices - 5 days- k 4 (e)L inspection documentation days at, Contractor's home-office-
.(f) follow up inspection-activities:'(if needed) 5 days k
- NOTE - site --inspection activities, as' noted in items- (b) and :-(d) !
above, will' typically require 10' hour workdays (50 hour5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> work weeks).
TC 4 ESTIMATED' LEVEL OF EFFORT ,
The estimated level of effort for'each-specialist for a-typical
-inspection consists of 100. hours for inspection preparation (item
-(a) - above) , 1501 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.711305e-4 months <br /> for on-site inspection activities and review of-initial findings (items- (b) , (c) and-(d) above), and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> for
~1nspection' documentation (item (e) above) and 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> for follow up,-if needed.
Each inspection will-typically require up to three specialists.:
C.5: PERSONNEL ~ QUALIFICATIONS.
~ All key personnel performing work under.this contract shall have a 1 Ldegree in:the field of engineering and/or equivalent pertinent technical-experience by discipline'with respect to theories, principles and practices of each of the technical areas as applied.
to NRC licensed- commercial- nuclear power: plants and, where a The key personnel should have l((pplicable,- managerial experience'.
a)1 performed = previous design inspections or peer-reviews of design,
- b) commercial nuclear power plant' design experience with U. S. -
- reactor: designs-such as would be obtained from having worked at :
architectural / engineering firms or NSSS suppliers, and (c) a "
thorough understanding of NRC regulatory and policy requirements.for
~ nuclear power = plant design and operation.
F C.6 = MEETINGS AND TRAVEL Each: task' order willispecify any require'd travel to nuclear power.
plant 4 sites throughout the United States; NRC offices,in Rockville, Jianland; NRC regional of fices; and, any other location required for cperformance"of:.the1 work detailed in1the task order statement-of :
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NRR-98-021 fcction C-(a). one-5-10 day trip to the site and/or regional' office for-inspection preparation and to review background information
-(b) _two-tri ps of 5 days for on-si te inspection (c) one 5 day trip to.the regional office for in-office review-Prior to any trip taken during_the-period of performance under'this contract, the contractor shall obtain verbal or written approval of the NRC Project Officer. No foreign travel is anticipated as part of this contract.
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NRR-98-021. Section D SECTION D: - PACKAGING AND MARKING D .1-- PACKAGING AND._ MARKING.-(MAR 1987)
The'Contractorishall package material for shipment to the NRCTin such a manner that will ensure acceptance by common > carrier and safe .
delivery At destination. Containers and closures-shall~ comply with -
the Interstate Commerce Commission Regulations, Uniform _ Freight _
Classification Rules, or regulations of other-carriers as< applicable to the: mode of transportation. On tl.e-front of-the package,-the-
'. Contractor.shall clearly identify the contract number under,which.
the. product-is.being provided,-
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'NRR-98-021 "Scction E- )
SECTION E : INSPECTION-AND ACCEPTANCE _ ;
L E .1- NOTICE' LISTING CONTRACT CLAUSES INCORPORATED BY REFERENCE i l
The following contract clauses pertinent to this section are 1 hereby incorporated by reference (by Citation -Number, Tit 3 e, and- l Date) in accordance with the clause at FAR "52.252-2 CLAUSES :
INCORPORATED BY REFERENCE (JUN 1988)" in Section I of this contract. 1 NUMBER TITLE DATE-FECZRAL ACQUISITION REGULATION (48 CFR Chapter 1) 52.246-5 INSPECTION OF- APR 1984 SERVICSS--COST-REIMBURSEMENT E.2 PLACE OF INSPEOTION AND ACCEPTANCE (NAR 1987)
In:pection and acceptance of the deliverable items to be furnished hereunder chall be made by the Project Officer at the destination.
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NRR-98-021 .Section F. !
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-SECTION F - DELIVERIES OR PERFORMANCE- i
~F.11 : NOTICE LISTING CONTRACT CLAUSES INCORPORATED BY REFERENCE The-following contract clauses pertinent-to.this section are-hereby incorporated by-reference (by Citation Number, Title, and )
Date) in accordance with the clause at FAR "52.252-2 CLAUSES :
. INCORPORATED BY REFERENCE (JUN 1988)" in Section I of this contract.
NUMBER TITLE DATE ,
-t FEDERAL ACQUISITION REGULATION (4 8 CFR Chapter 1)'
'52.242-15 STOP-WORK ORDER 'AUG 1989 ALTERNATE I (APR 1984)
F12 NRCAR 2052.212-72 FINANCIAL STATUS REPORT (DEC 1995)
'The contractor shall provide a monthly Financial Status Report to the project officer-and-the contracting officer- Also, whenever the report references the
-ccquisition of, or changes in status v., property valued at the time of purchase at-$50,000 or more, send a copy of-the report to the Chief,-Property Management Branch, Division of Facilities and Property Management, Office of Administration. The report'is due within 15 calendar days after the end of the report period and shall identify the title of the project, the contract number,
- job code, project wanager and/or principal investigator, the contract period of
.parformance, and the period covered by the report. Each report'must include the
'following for each discrete task:
(c) Total estimated contract amount.
(b) Total-funds obligated to date.
.(c)-Total costs incurred-this reporting period.
(d)" Total. costs incurred'to date.
(o) Detail of all direct and indirect costs incurred during the reporting .
-pariod for.the entire contract or each task,-if it is a task ordering centract.
-(f) Balance of obligations remaining.
(g) Balance.of funds required to complete contract / task order.
'(h) . Contractor Spending Plan- (CSP) status:
~(1) LProjected percentage of completion cumulative through the report period for the) project / task order-as reflected in the current CSP.
F-1
NRR-98-021 Section F I I
(2) Indicate if there has been a significant change in the original CSP projection in either dollars or percentage of completion. Identify the change, l tha reasons for the change, whether there is any projected overrun, and when l cdditional funds would be required. If there have been no changes to the original NRC- approved CSP projections, a written statement to that effect is cufficient in lieu of submitting a detailed response to item h.
- 13) A revised CSP is required with the Financial Status Report whenever-the l contractor or the contracting officer has reason to believe that the total cost ,
for performance of this contract will be either greater or substantially less i ths.n what had been previously estimated. !
I (i) Property status: j (1) List property acquired for the project during the month with an acquisition cost of $500 or more and less than $50,000. Give the item number for the specific piece of equipment. l (2) List property acquired for the proj3ct during the month with an '
ecquisition cost of $50,000 or more. Provide the following information for each line item of property: item description or nomenclature, manufacturer, model number, serial number, acquisition cost, _ and receipt date. If no property was ccquired during the month, include a statement to that effect. Note: The same peripheral equlpment which is part of a " system or system unit."
(3) For multi-year projects, in the September monthly financial status report provide a cumulative listing of property with an acquisition cost of
$50,000 or more ($5,000 or more if purchased prior to Octobar i, 1995) showing the above information.
.(4) In the final monthly status report provide a close-out property report containing the same elements described above for the monthly financial status reports, for all property purchased with NRC funds regardless of value unless title has been vested in the contractor. If no property was acwired under the contract. provide a statement to that effect. The report should note any proparty requiring special handling for security, health, safety, or other reasons as a part of the report.
(j )- Travel status:
List the starting and end dates for each trip, the starting point and dastination, and the traveler (s) for each trip.
If the data in this report indicates a need for additional funding beyond that clready obligated, this information may only be used as support to the official request for funding required in accordance with the Limitation of Cost (LOC)
Clause (FAR 52.232-20) or the Limitation of Funds (LOF) Clause FAR 52.232-22.
-F.3 PLACE OF DELIVERY--REPORTS (tTUN 1988)
Tha items to be furnished hereunder shall be deliveled, with all charges paid by the Contractor, to:
(c) Project Officer (2 copies)
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NRR-98-021- Section F (b') Contracting Officer (1 copy)~
l F.4 : RESOLVING NRC CONTRACTOR DIFFERING PROFESSIONAL VIEWS (DPVs).
The Nuclear Regulation Commission's (NRC) policy is to support the 4 contractor's expression of professional health and safety related concerns nacociated with the contractor's work fer NRC that (1) may differ from a '
prevailing NRC staff view, (2) disagree with an-NRC decision or nolicy position, or (3) take issue with proposed or established agency practices, An occasion may arise when an NRC contractor, contractor's personnel, or suocontractor personnel believes that a ccnscientious expression of a competent judgement is -
- required to document such concerns on matters directly associated with its performance of the contract. The procedure that will be used provides for the '
expression and resolution of differing professional views (DPVs) of health and safety related cencerns associated with the mission of the agency by KRC contractors, contractor personnel or subcontractor personnel on niatters directly '
anoociated with its performance of the contract, may be found in Section J.of the solicitation. Tae contractor shall provide a copy of the NRC DPV procedure to' oil of its employees performing under this contract and to all subcontractors who shall, in turn, provide a copy of the procedure-to its employees. NOTE:
The prime contractor or subcontractor shall submit all DPV's received but need not endorse them.
I F.5 DURATION OF CONTRACT PERIOD (MAR 1987)-
ALTERNATE 4 (JUN 1988)
The ordering period for this contract shall commence on the effective date of.
tha contract and will expire on *(TO BE COMPLETED IN ANY RESULTANT CONTRACT).
'Any orders issued during_this period shall be completed within the time apacified in the order, unless otherwise specified herein. (See 52.216 Ordaring.) The term of this contract may be extended at the option of the
' Government for an additional two (2) one-year option periods.
F.6 TECHNICAL REPORTING REQUIREMENTS FOR EACH INSPECTION For each inspection, the Contractor shall submit the following technical reports:
, (1) An initial inspection plan and daily reports to the NRC Team. Leader during the course of the on-site inspections.
These. reports shall be in a written format, e.g.,
finding sheets. All pertinent information shall be discussed with the Team Leader on a timely basis, i(2) -At the~ conclusion.of theLinspection-(prior to the exit-F-3
NRR-98-021 Saction F m:3 ting with tha liccnsoa), tha contrcctor's cpaciclict i shall provide the Team Leader with written material i suitable for exit presentation, e.g., summary-of findings and updated finding sheets, (3) A final inspection report that documents the ;
specialist's activities, efforrm and findings and ;
serves as input to the NRC inspa tion report. This ;
report shall be in accordance with a format and ,
schedule to be provided by the NRC Team Leader, l The specialist's input shall be prepared in accordance with the guidance in NRC Manual Chapter 610, unless otherwise directed by the NRC Team Leader.
(4) Unless stated otherwise in the individual task order, the final inspection report input shall be delivered no later than five working days after completion of the inspections.
(S) The final inspection report input shall be provided to the NRC Team Leader in both a paper copy and electronic version (computer diskette Wordperfect 5.1/6.1 or other IBM PC compatible software acceptable to the bRC Team Leader).
(6) One copy each of the specialist's final inspectior.
report input shall be delivered to the NRC Team Leader.
(7) When there is significant and important compilation of information in a technical report, and when the NRC Project Officer believes the report will be referenced frequently and/or wide distribution of the report as a stand-alone document is required, the NRC Contracting ,
Officer may negotiate a modification to the task order for the Contractor to submit a NUREG report to the NRC Project Officer. NUREG reports are.to be prepared in accordance with NRC Handbook 3.8.
F.7 MONTHLY BUSINESS LETTER REPORTS A Monthly Business Letter Report (MBLR) shall be submitted to the NRC Project Officer and the NRC Contracting Officer by the 15th day of the month. Each report shall include four sections as described below.
F.7.1 I. WORK PROGDESS STATUS For each Task Order, the Contractor shall provide the following work
. progress status information:
- 1. Task Order Identification Information and Cost Summary
-The JCN, task order number, and title F-4 I
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-NRR-98-021- Section FD q
-Thd:tock ordar pariod.of.parformnnco!
-The principal'invectigator(s)1and telephone: number (s)'
--ThetNRC Team Leader (s)- name:and telephone aumber(s)
-Cost; Ceiling-for the Task Order
- -Amount: Obligated- -
-Task Order Costsifor'the' Reporting / Period
-Task Order : Cumulative Cost to Date
-Percentrof Obligated Amount-Spert u 1
- 2. Schedule / Milestone Information-
'TheLinformation presented here is' intended to allow for an easy _ '
comparison'of' planned schedule and milestones 1versus actual completion datesifor each of the major activities in the task order. ~
-The-information-should be presented in:a four column format that provides'a brief' descriptive summary of-the activity; the day,' month ,
tand year scheduled for completion at time. task order is issued;'the revised completion date (the reason for the change must be provided i
'in the " Problem / Resolution" section below) r and the date when all work is actually completed. The following provides an example.
Planned Revised Actual Completion Completion Completion Task- 'Date Date Date 2
On-site 11/23/96 12/4/96 12/4/96 '
inspection inspection delayed at licensee request
- 3. Work Performed During the kariod This section should contain a clear, succinct discussion of the work.
performed during the reporting period. As a minimum, the discussion should support the costs reported for the period. Statements such as,." worked on all tasks," or " continued to work on task 1," are not
' particularly useful~and reduces the effectiveness of the monthly _
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.. report as a management. tool and for historical documentatica.
Travel'taken during.the, reporting period should be summarized in ,
-this section of the-report.1Each summary should identify the person
' traveling, the location and duration of the travel, the purpose of the travel, and work:and accomplishments _not reflected elsewhere.
4.- -Problem / Resolution ~ i
-Problems' encountered during the reporting period should be clearly landEsuccinctly identified. The potential impact of the problem should be evaluated'and the proposed or' actual solution should be
- describeda DIt should be' clear from a reading of this section, who <
Jis; responsible for resolving the problem and how it.-will be resolved 3should it?stilltexist at the time:the report is written.
'InforderJto1 maintain an: accurate historical document, all problems-should be? reported?in this section.of'the MBLR~ irrespective of the
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NRR-984021 Ssction F- ,
lctotui of the prob 1cm et the tims tha.toport 10 written. If tha. .
problem still exists in a subsequent month, it should be described es it then existshotherwise it should be deleted-from the report.
Problems or circumstances that require a change in the level-of offort/ cost,--scope, or travel requirements are to beireported in the- ,
MBLR-for documentation-purposes but:are to.be dealtLwito'inea timely- ,
mannernby11etter-addressed ano sentito the NRC Contracting Officer
- with=a copy to_the NRC Project: Officer.
- Si PlansLfor-Next Reporting Period Provide-a brief description of the work to be performed during the next-reporting period; including expected milestones.
- F.7.2 II . , FINANCIAL STATUS SECTION
- 1. - For each task order,.the-following information is to be.
_ provided. Financial information must include the-current month figures ~and cumulative costs for the task order.
3' -the-inclusive dates of the current billing period
-direct labor costs (hours and costs)
-indirect labor costs (hours and costs)
-subcontractor costs
-other direct costs ageneral and administrative costs
-fees- .
-total cost and fixed fee .
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For each JCN, provide the following cost summary information:
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-task order number
-task order ceiling amount
-total NRC obligations
-total costs to date
-obligation balance
- -percent costs to obligation
-total-contract. ceiling-amount
-total contract obligations
-percent total costs to total obligations F.7.3- III. CONTRACTOR SPENDING PLAN A contractor? spending plan is required for task-orders that are ,
expected to exceed $100,000 andsfor which the-period of perfo mance is: expected:to exceed six months.
' F.7.4' -IV. DELIVERABLES SUBMITTED-DURING,THE'PEkIOD
-Theireporting format for=the'above information shall.be provided to
- the ProjecttOfficer for approvalswithin 30 days from the effective
- dateiof the contract; F "
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SECTION G'-' CONTRACT ADMINISTRATION DATA
'f G.11 2052.215-71 PROJECT OFFICFR AUTHORITY-
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(a)1The1 contracting l officer's-cuthorized representative hereinafter- .
1 referred ^tocas=the project 1 officer for.this contract ist= 1 Hames_To be completed in any resultant contract.-
~Addreds: To-be completed in any resultant contract.
1 Telephone 5Numberilro be! completed-in any. resultant contract.- .
-(b) ' Performance of the work under..this contract is subject to the technical direction of the NRC project officer. The term technical direction is-deZined_to-include the following:
. (1)l:Technicalidirection to the contractor which shif ts work emphasis I between-areas of' work or tasks, fills.in details, or mtherwise
' serves to accomplish the. contractual: statement of' work.
(2k Provide advice'and guidance to the contractor.in the preparation of drawings, specifications, or technical. portions of the work description.
(3) Review and, where required by the contrace,. approval 1>f technical reports, drawings, specifications, and technical
- information to be delivered by the contracter to the Government
-t under?-the contract.
, ( ci) Technical direction.must be within the general statement of. work stated in-the contract. The project' officer does not have the yauthoritytto and may-not= issue any technical direction which:
.(1) Constitutes anLassignment'of work'outside.the general scope of.
the contract ~.
(2)LConstitutes a change as -defined .in the " Changes" clause of this -
contract.-
(3) Infany way;cause>an increase or decrease in the-total estimated -
Econtract-~ccat,.the fixed fee,~'if any, or-the. time required for
- contract performance.
I(4Ichanges3anyfof the ' expressed terms, conditions, or 1 specifications of thefcontract.
. (5): Terminates; the contract,Dsettles' any claim or dispute arising L
under.Dthe contractL or tissues? any; unilateral- directive: whatever. .
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NRR-98-021 Saction G (d) All tcchnical dir ctions must ba~ircued in writi.ng by tha project officer or must be confirmed by the project officer in writing within ten (10)- working days af ter verbal iosuance. A copy of the written direction must be furnished'to the contracting officer.-
(e) The contractor shall proceed promptly with the performance of technical directions duly issued by the project officer in the manner prescribid by this clause and within - the project of ficer's authority under the provisions of this clause.
(f) If, in th9 opinion of the contractor, any instruction or direction israed by the project officer is within one of the categories aJ defined in paragraph (c) of this section, che contractor ma) not proceed but shall notify the cortracting officer in writing within five (5) working days after the receipt of any instructior or direction and shall request the contracting officer to modify the contract accordingly. Upon receiving the notification from the contractor, the contracting officer shall issue an cppropriate contract modification or advise the contractor in writing that, in the contracting officer's opinion, the technical direction is within the scope of this article and does not constitute a change under the " Changes" clause.
(g) Any unauthorized commitment or direction issued by the project officer may result in an unnecessary delay in thL contractor's performance and may even result in the contractor expending funds for unallowable costs under the contract.
(h) A failure of the parties to agree upon the nature of the instruction or direction or upon the contract action to be taken with respect thereto is subject to 52.233-1-Disputes.
(1) In addition to providing technical direction as defined in paragraph (b) of the section, the project officer shall:
(1) Monitor the contractor's technical progress, including curveillance and-assesement of performance, and recommend to the contracting officer changes in requirements.
(2) Assist the contractor in the resolation of technical problems cncountered during performance.
(3) Review all costs requested for reimbursement by the contractor and submit to the contracting officer recommendations for approval, disapproval, or suspension of payment for supplies and services required under this contract.
O.2 2052.215-82 TRAVEL REIMBURSEMENT-ALTERNATE 1 (a) The contractor il encouraged to use Government contract Girlines,; AMTRAK rail services, and discount hotel / motel properties G-2
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- NRR-98-021 Saction G' d
~in ordar to reduce the-cost of travel 1under thic' contract. Tha -
Lcontractingofficershall,1ubonrequest, provide a-- letter: of identification w ich is arequired -ineach order traveler with' toLparticipate. ;
"in:this program. The: Federal Travel: Directory-(FTD)1 identifies carriers,- contract 1 fares, schedules',-payment conditions, and hotel / motel'propertiescwhich offer their servjces and rates to
' Government contractor personnel; traveling on' official businessiunderE this contract. The-FTD, which-is issued monthly,_may_be' purchased from the'U.S. Government Printing Office, Washington, DC 20402.
-(b) ~The contractor will 'be- reimbursed for reasonable travel costs incurred'directly and specifically in the performance of this .
contract'. The -cost limitations f or travel costs . are determined' in
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accordance-with-the specif'ic travel regulations cited in FARL ,
31.205-46, as are;in effect on' the date of: the trip. Travel costs -
for=research and-related activities performed.at Secte and nonprofit'
- institutions, in accordance-with section 12 of'Public Law 100-679, ,
shall be^ charged in accordance with the" contractor's institutional-
-policy:to tb- degree that.the 1Amitations'of Office of Management Land-Budget-(OMB) guidance'are not exceeded. Applicable guidanceL documents include OMB Circular A-87, Cost Principles for State and
~ Local Governments; OMB Circular A-122, Cost principles for Nonprofit Organizations; and OMB Circular A-21, Cost Principles for Educational Institutions.
- (c) Whenithe Government changes the Federal Travel Regulations, or ;
other_ applicable regulations, it is the responsibility of the -
contractor to notify _the contracting officer in accordance with the
' Limitations of. cost clause of this contract if the contractor will Ebe unable to make.all of-the approved trips and remain within the cost and fee ldmitations of this contract due to the changes.
G.3 2052.215-83 TRAVEL APPROVALS (a) All domestic travel requires the prior approval of the project officer.
-(b) All-foreign travel must be approved in advance by the NRC on NRC Form'445 and must be~in compliance with'FAR 52.247-63, Preference
!for U.S. Flag Air Carriers. Foreign travel approval must be communicated in writing through the contract ng officer.
G.4L 2052'.216-71 INDIRECT COST RATES-(a), Pending' the establishment- of final indirect: rates which must be.
. negotiated based _on-audit of actual costs, the' contractor shall be reimbursed for allowable indirect costs as follows: .
, * (TO BE: COMPLETED' IN ANY RESULTANT CONTRACT)
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NRR-98-021e St tion G
.(bkThecontractingofficermayadjustthekbove'ratesLas tppropriate=during the' term'of the contract upon acceptance of any revisions-proposed by?the contractor.---It is the contractor's- i Eresponsibility to notify the contracting officer-in accordance'with ,
TAR-52.232-20, Limitation of Cost, or FAR 52.232-22, Limication of.-
Funds,Jas applicable, if these changes affect performance of work within thecestablished coat-or' funding-limitations.
0.5; -2052.216-74 : TASK ORDER PROCEDURES (a)l . Task 1 order request for proposal. When a requirement within the ecope of work-for this contract is identified, the contracting
- officer shall transmit ~to the contractor a Task Order Request for 1 Proposal (TORP) which includes the following, as appropriate:
=(1) Scope of work / meetings / travel and deliverables; .
(2)? Reporting requirements; ,
(3) _ Period of performance-place of performance; ,
_4)1
( Applicable special provisions; ,
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(5) Technical skills required; and_ .
(6) Ectimated level of effort.
(b) Task' order proposal. By the date specified in the'TORP, the contractor shall deliver to the contacting officer a written
-proposal thac:provides the following technical and cost information, las appropriate:
(1) = Technical proposal content; (i) A discussion of the scope of work requirements to substantiate the contractor's understanding of the requirements of the task order end the contractor's proposed method of approach to meet the
- objective of the order.
-(11)' Resumes for p'rofessional personnel proposed to be utilized in
-the< performance-of any_resulting task order. Include educational.
, > background, specific pertinent work experience, and a list of any 1 pertinent publications authored by the-individual.
'(iii)1 Identification of ' administrative support personnel and/or facilities that:are~needed to assist the profecsional personnel in completing work'on theLtask order.
^
-(iv) Identificationfof::" Key Personnel" and the number of staff hours (that will be committed to completion of work on the task order.
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NRR-98-021 Section G (2) Coct proposcl. The contrcctor'c coct proposal for each task order must be prepared using Stanosrd Form 1411, Contract Pricing Proposal cover sheet. A copy of the form and instructions are attached to this contract. Each task order cost proposal must be fully supported by cost and pricing data adequate to establish the reasonableness of the proposed amounts. When the contractor's estimated cost for the proposed task order exceeds $100,000 and the period of performance exceeds six months, the contractor may be required to submit a Contractor Spending Plan (CSP) as part of its cost proposal. The TORP indicates if a CSP is required.
(c) Task order award. The contractor shall perform all work described in definitized task orders issued by the contracting officer. Definitized task orders include the following:
(1) Statement of work / meetings / travel and deliverables; (2) Reporting requirements; (3) Period of performance; (4) Key personnels (5) Applicable special provisions; and (6) Total task order amount including any fixed fee.
G.6 2052.216-75 ACCELERATED TASK ORDER PROCEDURES (a) The NRC may require the contractor to commence work before receipt of a definitized task order from the contracting officer.
Accordingly, when the contracting officer verbally authorizes the work, the contractor shall proceed with performance of the task order subject to the monetary limitation established for the task order by the contracting officer.
(b) When this accelerated procedure is employed by the NRC, the contractor agrees to begin promptly negotiating with the contracting of ficer the terms of the definitive task order and agrees to submit a cost proposal with supporting cost or pricing data. If agreement on a definitized task order is not reached by the target date mutually agreed upon by the contractor and contracting officer, the contracting officar may determi..e a reasonable price and/or fee in accordance with Subpart 15.8 and Part 31 of the FAR, subject to contractor appeal as provided in 52.233-1, Disputes. In any event, the contractor shall proceed with completion of the task order, subject only to the monetary limitation established by the contracting officer and the terms and conditions of the basic contract.
G-5 1
NRR-98-021 S0ction G C.7 CRDERING PROCEDURES (MAY 1991)
(a) In addition to the contracting officer, contract cdministrator, and project officer, the following individuals are cuthorized to issue delivery orders under this contracts (b) All delivery orders shall be prepared in accordance with FAR 16.506 and may be issued in writing, orally, or by written telecommunications.
G.8 ELECTRONIC PAYMENT The Debt Collection Improvement Act of 1996 requires that all cayments except IRS tax refunds be made by Electronic Funds transfer. It is the policy of the Nuclear Regulatory Commission to pay vendors by the Automated Clearing House (ACH) electronic funds transfer payment system. The electronic sybtem is known as Vendor Express. Payment shall be made in accordance with FAR 52.232-33, entitled " Mandatory Information for Electronic Funds Transfer Payment".
To receive payment, the contractor shall complete the " Company Information" portion of the Standard Form 3881, entitled "ACH Vendor / Miscellaneous Papent Enrollment Form" found in Section J.
The contractor shall take the form to the ACH Coordinator at the financial institution that maintains its company's bank account.
The contractor shall discuss with the ACH Coordinator how the payment identification information (addendum record) will be passed to them once the payment is received by the financial institution.
To ensure that adequate payment information will be available to the contractor, the contractor should inform the financial institution that the addendum record must not be stripped from the payment.
Further information concerning the addendum is provided at Attachment . The ACN Coordinator should fill out the " Financial Institution ~T3 formation" portion of the form and return it to the Office of the Controller at the following address: Nuclear Regulatory Commission, Division of Accounting and Finance, Financial Operations Section, Mail Stop T-9-H-4, Washir.gton, DC 20555, ATTN:
ACH/ Vendor Express. It is the responsibility of the contractor to ensure that the financial institution returas the completed form to the above cited NRC address. If the contractor can provide the financial information, signature of the financial institutions ACH Coordinator is not required. The NRC is under no obligation to send reminders. Only after the Office of the Controller has processed the contractor's sign-up form will the contractor be eligible to receive payments.
Once electronic funds transfer is establinhed for payments authorized by NRC,-the contractor needs to submit an additional SF 3881 only to report changes to the information supplied.
Questions concerning ACH/ Vendor Express should be directed to the G-6
NRR-98-021 Section G Fincncial Opbrctionc otoff ct (301) 415-7520." ,
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NRR-98-021 Section H SECTION H - SPECIAL CONTRACT REQUIREMENTS H.1 2052.204-70 SECURITY (a) Security / Classification Requirements Form. The attached NRC Form 107 (See Section J for List of Attachments) furnishes the basis for providing security and classification requirements to prime contractors, subcontractors, or others (e.g., bidders) who have or may have an NRC contractual relationship that requires access to classified information or matter, access on a continuing basis (in excess of 90 or mora days) to NRC Headquarters controlled buildings, or otherwise requires NRC photo identification or card-key badges.
(b) It is the contractor's duty to safeguard National Security Information, Restricted Data, and Formerly Restricted Data. The contractor shall, in accordance with the Commission's security regulations and requirements, be responsible for safeguarding National Security Information, Restricted Data, and Formerly Restricted Data, and for protecting against sabotage, espionage, loss, and theft, the classified documents and material in the contractor's possession in connection with the performance of work under this contract. Except as otherwise expressly provided in this contract, the contractor shall, upon completion or termination of this contract, transmit to the Commission any classified matter in the possession of the contractor or any person under the contractor's control in connection with performance of this contract. If retention by the contractor of any classified matter is required after the completion or termination of the contract and the retention is approved by the contracting officer, the contractor shall complete a certificate of poesession to be furnished to the Commission specifying the classified matter to be retained. The certification must identify the items and types or categories of matter retained, the conditions governing the retention of the matter and their period of retention, if known. If the retention is approved by the contracting officer, the security provisions of the contract continue to be applicable to the matter retained.
(c) In connection with the performance of the work under this contract, the contractor may be furnished, or may develop or acquire, proprietary data (trade secrets) or confidential or privileged technical, business, or financial information, including Commission plans, policies, reports, financial plans, internal data protected by the Privacy Act of 1974 (Pub. L.93-579), or other information which has not been released to the public or has been determined by the Commission to be otherwise exempt from disclosure to the public. The contractor agrees to held the information in confidence and not to directly or indirectly duplicate, disseminate, or disclose the info:rmation in whole or in part to any other person or organization except as may be necessary to perform the work under this contract. The contractor agrees to return the information-to H-1
NRR-98-021 Section H tha Commiccion or otharwico dicpoco of it at tho direction of tho '
contracting officer.. Failure to comply with this clause is grotnds for termination of this contract.
(d) Regulations. The contractor agrees to .onform to all securits regulations and requirements of the Commiasion which are subjen 'a change as directed b contracting Officer.y the NRC Division of Security and theThese changes will be under the the changes clause. !
(e) Definition of National Security Information. The term National Security Information, as used in this clause, means information that has been determined pursuant to Executive Order 12355 or any ,
predecessor order to require protection against unauthorized !
disclosure and that is so designated.
(f) Definition of Restricted Data. The term Restricted Data, as used in this clause, means all data concerning:
(1) design, manufacture, or utilization of atomic weapons;
- (2) the production of special nuclear material; or (3) the use of special nuclear material in the production of energy, but-does not include data declassified or removed from the Restricted Data category pursuant to section 142 of the Atomic Energy Act of 1954, as amended. ,
(g) Definition of Formerly Restricted Data. The term Formerly Restricted Data, as used in this clause, means all data removed from
' the Restricted Data category under section 142-d of the Atomic Energy Act of 1954, as amended.
(h)-Security clearance personnel. The contractor may not permit any individual to have access to Restricted Data, Formerly Restricted
- Data, or other classified information, except in accordance with the Atomic Energy Act of 1954, as amended, and the Commission's regulations or requirements applicable to the particular t we or category of classified information to which access is required. The contractor shall also execute a Standard Form 312, Classified Information Nondisclosure Agreement, when access to classified information is equired.
(i) Criminal liabilities. It is understood that disclosure of National Security Information, Restricted Data, and Formerly
- Restricted Data, relating to the work or services ordered hereunder to any person not entitled to receive it, or failure to safeguard-cny Restricted Data, Formerly Restricted Data, or any other .
classified matter that may come to the contractor or any person l under the contractor's control in connection with work under this
~ contract, may subject the contractor, its agents, employees, or
- cuocontractors.to criminal liability under the laws of the United States. (See the Atomic Energy Act of 1954, as amended, 42 U.S.C.
2011 et seq.; 18 U.S.C. 793 and 794; and Executive Order 12356.)
(j) Subcontracts-and purchasefoidersi Except as otherwise authorized H-2 1
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NRR-98-021 Soction H
', i in writing by tho_contrccting officor, the contractor chall incert i provisions similsr to.the foregoing in all subcontracts and purchase j orders under this contract. i (k) In performing the contract work, the contractor shall classify r all documents, material, and equipment originated or generated by l t:1e contractor in accordance with guidance issued by the commission. >
Every subcontract and purchase order issued hereunder involving the origination or generation of classified documents, material, and i equipment must provide that the subcontractor or supplier assign ,
classification to all documents, material, and equipment in ,
accordance with guidance furnished by the contractor. >
i H.2 2052.204-71 SITE ACCESS BADGE REQUIREMENT ;
- During the life of this contract, the rights of ingress and egress ,
for contractor personnel must be made available as required. In this ,
regard, all contractor personnel whose duties under this contract require their presence on-site shall be clearly identifiable by a distinctive badge furnished by the Government. The Project Officer 1 shall assist the contractor in obtaining the badges for the
- contractor personnel. It is the sole resoonsibility of the :
contractor to ensure that each employee .1as proper identification at !
all times. All prescribed identification must be immediately delivered to.the Security Office for cancellation or disposition upon-the termination of emaloyment of any contractor personnel.
Contractor personnel must aave this identification in their :
possession during on-site performance under this contract. It is the contractor's duty to assure that contractor personnel enter only those work areas necessary for performance of contract work, and to '
assure the safeguarding of any Government records or data that contractor personnel may come into contact with.
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M.3 2052.209-73 CONTRACTOR ORGANIEATIONAL CONFLICTS i OF INTEREST i
(a) Purpose. The primary purpose of this clause is to aid in ensuring that the contractor:
(1)_Is not placed in a conflictiL3 role because of current or planned interests (financial, contractual,--organizational, or 1
otherwise) which relate to the-work under this contract; and (2)JDoes'not obtain an unfair competitive advantage over other parties by virtue _of its; performance of this contract.
. .(b)' Scope -The-restrictions described; apply to performance or
. participation bylthe contractor, as defined in 48 CFR 2009.570- 2 in the activities covered by this clause.
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i NRR-98-021 Soction H j (c) Work for othora.
(1) Notwithstanding any other provision of this contract, during the '
term of this contract the contractor agrees to forgo entering into consulting or other contractual arrangements with any firm or organization, the result of which may give rise to a conflict of i interest with respect to the work being performed under this !
contract. The contractor shall ensure that all employees under this contract abide by the provision of this clause. If the contractor ,
has reason to believe-with respect to itself or any employee that :
cny proposed consultant or other contractual arrangement with any firm or organization may involve a potential confl.ct of interest, !
the contractor shall obtain the written approval of the contracting officer before the execution of such contractual arrangement. ;
(2) The contractor may not represent, assist, or otherwise support en NRC licensee or applicant undergoing an NRC audit, inspection, or review where the activities that are the subject of the audit, inspection or review are the same as or substantially similar to the cervices within the scope of this contract (or cask order as c?propriate), except where the NRC licensee or applicant requires tae contractor's support to explain or defend the contractor's prior work for the utility or other entity which NRC questions.
(3) When the contractor performs work for the NRC under this contract at any NRC licensee or applicant site, the contractor shall neither solicit nor perform work in the same or similar technical crea for that licensee or applicant organization for a period commencing the site (if not a task order contract)with the and award of the one ending task order or beginning of work on completion of all work under the associated task order, year or last aftertime et the site (if not a task order contract). ,
(4) When the contractor performs work for the NRC under this 1 contract at any NRC licensee or applicant site, (i) The contractor may not solicit work at that site for that licensee or applicant during the period of performance of the task order or the contract, as appropriate.
(ii) The contractor may not perform work at that site for that -
licensee or applicant during the period of performance of the task order or the contract, as appropriate, and for one year thereafter.
(iii)~Notwithstanding the foregoing, the contracting officer may cuthorize the contractor to solicit or perform this type of work (except work in the same or similar tecanical area) if the contracting officer determines that the situation will not pose a potential for technical bias or unfair competitive advantage.
_( d).
_ Disclosure after award <
(1) The contractor-warrants that to the best of its knowledge and belief, and except as otherwise set forth in this contract, it does not have any organizational conflicts of interest as defined in 49 -
'CFR 2009.570-2.
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l NRR-98-021 Section H L
(2) The contractor agrees that, if after award, it discovers organizational conflicts of interest with respect to this contract, !
it shall make an immediate and full disclosure in writing to the contracting officer. This statement must include a description of the action which the contractor has taken or proposes to take to avoid or mitigate such conflicts. The NRC may, however, terminate the contract if termination is in the best interest of the !
government. l (3) It is recognized that the scope of work of a task-order- type '
contract necessarily encompasses a broad spectrum of activities. -
l Consequently, if this is a task-order-type contract, the contractor agrees that it will disclose all proposed new work involving NRC licensees or applicants which comes within the scope of work of the i
l underlying contract. Further, if this contract involves work at a licensee or applicant site, the contractor agrees to exercise diligence to discover and disclose any new work at that licensee or applicant site. This disclosure must be made before the submission of a bid or proposal to the utility or other regulated entity and must be received by the NRC at least 15 days before the proposed ;
cward date in any event, unless a written justification demonstrating urgency and due diligence to discover and disclose is provided by the contractor and approved by the contracting officer.
The disclosure must include the statement of work, the dollar value of the proposed contract, and any other documents that are needed to fully describe the proposed work for the regulated utility or other regulated entity. NRC may deny approval of the disclosed work only when the NRC has issued a task order which includes the technical area and, if site-specific, the site, or has plans to issue a task order which includes the technical area and, if site-specific, the cite, or when the work violates paragraphs (c) (2) , (c) (3) .or (c) (4) of this section.
(e) Access to and use of information.
(1) If in the performance of this contract, the contractor obtains cccess to information, such as NRC plans, policies, reoorts, etudies, financial plans, internal data protected by t1e Privacy Act of 1974 (5 U.S.C. Section 552a (1988)), or the Freedom of Information Act (5 U.S.C. Section 552 (1986)), the contractor agrees not to (i) Use this information for any private purpose until the information has-been released to the public; (ii) Compete for work for the Commission based on the information for a period of six months after either the completion of this .
contract or the release of the information to the public, whichever is first; (iii) Submit an unsolicited proposal'to the Government based on the information'until:one year after the release of the information to the public;oor (iv)' Release the information without prior written approval by the H-5 P
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NRR-98-021 Soction H I
.contrccting officar unlose the inform: tion hoo previously bacn released to the,public by the NRC.
(2) In addition, the contractor agrees that, to the extent it receives or is given access to proprietary data, data protected by the privacy Act of 1974 (5 U.S.C. section 552a (1988)), or the Freedom of Information Act' (5 U.S.C. section 552 (1986)), or other confidential or privileged technical, business. or financial information under this contract, the contractor shall treat the information in accordance with restrictions placed on use of the information, j (3) Subject to patent and security provisions of this contract, the contractor shall have the right to use technical data it produces ;
under this contract for private purposes provided that all requirements of this contract have been met.
(f) Subcontracts. Except as provided in 48 CFR 2009.570-2, the contractor shall include this clause, including this paragraph, in :
cubcontracts of any tier. The terms contract, contractor, and contracting officer, must be appropriately modified to preserve the Government's rights.
L(g) Remedies. For breach of any of the above restrictions, or for intentional nondisclosure or misrepresentation of any relevant interest required to be disclosed concerning this contract or for cuch erroneous representations that necessarily imply bad faith, the Government may terminate the contract for default, disqualify the contractor from subsequent contractual efforts, and pursue other remedies permitted by law or this contract.
(h) Waiver. A request for waiver under this clause must be directed in writing to the contracting officer in accordance with the procedures outlined in 48 CFR 2009.570-9.
(i) Follow-on effort. The contractor shall be ineligible to subcontracts, or proposals therefor p(articipate in NRC solicited or contracts,which unsolicited), stem directly from the contractor's performance of work under this contract. Furthermore, unless so directed in writing by the contracting officer, the contractor may not perform any technical consulting or management cupport services work or evaluation activities under this contract on any of its products or services or the products or services of -
enother firm if the contractor has been substantially involved in the development or marketing of the products or services.
(1). If the contractor, under this contract, prepares a com
.ossentially complete statement of. work or specifications, the plete or contractor is not eligible to perform or participate in the initial contractual effort which is based on the statement of work or cpecifications. The contractor may not incorporate its products or cervices in the stacement of work or specifications unless so directed in' writing by the contracting officer, in which case the restrictions in this paragraph do not apply.
'(2) Nothing in this paragraph precludes the contractor from offering H-6
1 HRR-98-021 S3ction H or colling ito ctcndard commercici items to tho Governm3nt.
H.4 2052.215-70 KEY PERSONNEL (a) The following individuals are considered to be essential to the successful performance of the work hereunder:
to be filled in upon award The contractor agrees that personnel may not be removed from the contract work or replaced without compliance with paragraphs (b) and (c) of this section.
(b) If one or more of the key personnel, for whatever reason, becomes, or is expected to become, unavailable for work under this contract for a continuous period exceeding 30 work days, or is i expected to devote substantially less effort to the work than indicated in the proposal or initially anticipated, the contractor shall immediately notify the contracting officer and shall, subject to the concurrence of the contracting officer, promptly replace the personnel with personnel of at least substantially equal ability and qualifications.
(c) Each request for approval of substitutions must be in writing and contain a detailed explanation of the circumstances necessitating the proposed substitutions. The request murt also contain a complete resume for the proposed substitute and other information requested or needed by the contracting officer to evaluate the proposed substitution. The contracting officer or his/her authorized representative shall evaluate the request and promptly notify the contractor of his or her approval or disapproval in writing.
(d) If the contracting officer determines that suitable and timely replacement of key personnel who have been reassigned, terminated, or have otherwise become unavailable for the contract work is not reasonably forthcoming, or that the resultant reduction of productive effort would be so substantial as to impair the .
successful completion of the contract or the service order, the contract may be terminated by the contracting officer for default or for the convenience of the Government, as appropriate. If the contracting officer finds the contractor at fault for the condition, the contract price or fixed fee may be equitably adjusted downward to compensate the Government for any resultant delay, loss, or damage.
H-7
NRR-98-021 Section H .
N.5 GOVERNMENT FURNISHED EQUIPMENT /PR'jPERTY - NONE PROVIDED !
(JUN 1988) j The Government will not provide any equipment / property under this contract. 3 i
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H.6 LICENSE FEE RECOVERY COSTS (APR 1992) t Included as an attachment in Section J are billing instructions for license fee recovery costs. This information must be submitted by the contractor in conjunction with the monthly invoice.
M.7 CONTRACT SECURITY REQUIREMENTS FOR UNESCORTED ACCESS TO NUCLEAR PONER PLANTS (FEB 1995) .
Performance under this contract may involve unescorted access to -
protected and vital areas of nuclear power plants or access to unclassified Safeguards Information (SGI) . ;
Individual contractors requiring access to protected and vital creas of nuclear power plants or access to unclassified SGI will be
- cpproved for access in accordance with the following procedures:
A. Temporary Approval (a) The contractor shall submit the following information to the NRC Division of Security (SEC) through the NRC Project Officer
, - within thirty (30) calendar days following contract award, modification, or proposal of new personnel for contract tasks requiring unescorted access a completed Personnel Security Forms Packet, including an SF-86, " Questionnaire for Sensitive Positions (For National Security);" copies of the contractor's five-year amployment and education history checks, including verification of highest degree obtained; a reference from at least one additional person not provided by the individual; results of a psychological evaluation; and a certification that the contractor has found all checks acceptable. The results of a psychological examination, which usesla reliable written personality test or any other professionally accepted clinical evaluation procedure, shall be used to evaluate a subject's trustworthiness, reliability, and stability.
The contractor shall review all required information for accuracy, completeness, and legibility, except Part 2 of the SF-86 which is t required to be completed in private and submitted by the individual to the contractor in a sealed envelope.
Or, (b) The -individual. w1111 arrange to be fingerprinted by the subject utility,;and the contractor will submit to the utility's access-cuthorization program.
In Section A'above, SEC will conduct criminal history and credit H-8 l
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i NRR-98-021 Section H chocko cnd a cecurity cecurenco interview with tho individual.
Based on the result of these checks, SEC will determine the individual's eligibility for temporary access and provide an objection or no objection to the sponsoring Office pending completion of the required background investigation by OPM. )
i B. -Final-Approval (a) The required investigation on the individual has been completed, and is satisfactory, resulting in NRC's endorsement of l the individual's unescorted access at all nuclear facilities for the l life of the contract, or l (b) The contractor has obtained unescorted access authorization (other than temporary access) at the specific facility through that utility's access authorization program, or (c) The individual possesses a valid government issued clearance as verified by SEC. A valid government-issued clearance is defined as a U.S. Government-issued security clearance equivalent or higher than an NRC "L" clearance (e.g., Secret) based on a comparable investigation not more than five years old.
If an NRC contract is let to a foreign owned company employing foreign nationals, SEC will attempt to obtain a security assurence from the respective government that a comparable investigation has been conducted on the individual. If an acceptable assurance is obtained, SEC will provide a NO SECURITY OBJECTION without further investigative checks.
The investigation in Section B above may involve a National Agency Check with Inquiries and Credit (NACIC) or other investigation as deemed necessary by SEC in accordance with 10 CFR Part 10 and NRC Management Directive and Handbook 12.3. Any questions regarding the individual's eligibility for unescorted access to protected or vital areas of nuclear power facilities will be resolved in accordance with the provisions specified in 10 CFR Part 10, which is incorporated into the contract by reference as though fully set forth herein.
The contractor shall submit to SEC through the Project Officer for ,
each contractor individual submitted / approved for access under the provisions of Sections A and B above, a signed NRC form 570, "A cess Authorization Acknowledgment" from the individual that he or she
' understands'his or her responsibility to report to the NRC, Division of Security, Personnel Security Branch, any information bearing on his-or her continued eligibility for access authorization as specified in 10 CFR Part 10, Section 10.11 " Criteria".
Access .to unclassified power reactor Safeguards Information (SGI) ,
not also involving unescorted access to protected and vital areas of nuclear power plants will require the submission of a completed Personnel Security Forms Packet to SEC through the Project Officer and may require a National Agency Check- (NAC) or other investigation deemed necessary by the NRC in accordance with 10 CFR Part 10 and H-9
NRR-98-021 Saction H NRC M:ncg: ment Dircctivo cnd Hcndbook 12.3 which io incorporcted into this contract by refe ence as though set forth herein.
Any questions regarding the individual's eligibility for access to nuclear power reactor SGI will be resolved in accordance with the provisions set forth in Exhibit 11, Management Directive 12.3. Based on the review of the applicant's security forms by SEC and/or the receipt of adverse information by NRC, the individual may be denied cccess to nuclear power raactor SGI until a final determination of his or her eligibility for access is made under the provisions of 10 CFR Part 10. During the processing by SEC of new individuals for cccess to nuclear power reactor SGI, access may be granted under licensee programs.
C. Fitness for Duty Pursuant to NRC policy, all contract individuals proposed for performance of task orders requiring unescorted access to nuclear power plants will be subject to the requirements of the licensee's Fitness-for-Duty program.
D. Basic Exposure Control and Personnel Dosimetry Training Requirements The contractor shall certify that personnel utilized under the ccope of work herein have completed basic exposure control and personnel dosimetry training sufficient to meet the requirements of commercial nuclear power plants for unescorted access. Training will be provided on a one-time basis, upon issuance of the applicable task order (s), for those individual (s) for whom the contractor cannot certify as to having completed t'..e above training within the past year. Site specific training obtained at each site will still be required during the performanca of individual task orders in cddition to the basic training.
H.8 SEAT BELTS Contractors, subcontractors, and grantees, are encouraged to adopt cnd enforce on-the-job seat belt policies and programs for their employees when operating company-owned, rented, or personally owned vehicles.
C.9 NRC FURNISHED MATERIAL Documents required to prepare for the subject inspection will be provided by the NRC Team Leader.
H.10 OTHER APPLICABLE INFORMATION The-work specified in this sow is in most cases 100% licensee fee recoverable. The contractor shall provide fee recovery information H-10 i
NRR 98-021 Section H in tho monthly progroco reporto.
contractor's personnel assigned to this task ordar will hLve to be badged for unescorted access privilege at the plant site. The-contractor shall provide all-documentation required for badging (as identified by the NRC Team Leader) at the plant site.
H.11 CONTRACTOR RESPONSIBILITY It is the responsibility of the contractor to assign technical staff, employees, subcontractors, or consultants who have the required educational background, experience, or combination thereof to meet both the technical and regulatory objectives of the work ,
specified in this procurement. The NRC will rely on representations made by the offeror concerning the qualifications of any personnel to be assigned to any task order including assurance that all information contained in the technical and cost proposals, including tesumes, is accurate and truthful.
H-11 t
-NRR-98-021 Section I PART II - CONTRACT CLAUSES SECTION I - CONTRACT CLAUSES I.1 NOTICE LISTING CONTRACT CLAUSES INCORPORATED EY REFERENCE The following contract clauses pertinent to this section are hereb Date)yinincorporated-by accordance withreference the clause(byatCitation Number,CLAUSES FAR "52.252-2 Title, and INCORPORATED BY REFERENCE (JUN 1988)" in Section I of this contract.
NUMBER TITLE DATE FEDERAL ACQUISITION REGULATION (48 CFR Chapter 1) 52.202-1 DEFINITIONS SEP 1991 52.203-3 GRATUITIES .
APR 1984 52.203-5 COVENANT AGAINST CONTINGENT FEES APR 1984
~ 52.203-6 RESTRICTIONS ON SUBCONTRACTOR SALES TO JUL 1995 THE GOVERNMENT 52.203-7 ANTI-KICKBACK PROCEDURES JUL 1995 52.203-12 LIMITATION ON PAYMENTS TO INFLUENCE JUN 1997 CERTAIN FEDERAL TRANSACTIONS 52.204-2 SECURITY REQUIREMENTS AUG 1936 52.204-4 PRINTING / COPYING DOUBLE-SIDED ON MAY 1996 RECYCLED PAPER 52.209-6 PROTECTING THE GOVERNMENT *S INTEREST AUG 1995 WHEN SUBCONTRACTING WITH CONTRACTOR'S DEGARRED, SUSPENDED, OR PROPOSED FOR DEBARMENT .
52.215-2 AUDIT AND RECORDS--NEGOTIATION AUG 1996 52.215-8 ORDER OF PRECEDENCE--UNIFORM CONTRACT OCT 1997 FORMAT 52.215-15 TERMINATION OF DEFINED BENEFIT PENSION OCT 1997 PLANS-52.215-18 REVERSION OR ADJUSTMENT OF PLANS FOR OCT 1997 POSTRETIREMENT BENEFITS OTHER THAN PENSIONS (PRB) 52.215-19 NOTIFICATION OF OWNERSHIP CHANGES OCT 1997 52.216-7 ALLOWABLE COST AND PAYMENT MAR 1997 52.216-8 FIXED-FEE MAR 1997
- 52.219-6 NOTICE OF. TOTAL SMALL BUSINESS SET-ASIDE JUL 1996 52.219-8~ ' UTILIZATION OF SMALL,=SMALL JUN 1997-
. DISADVANTAGED BUSINESS AND WOMEN-OWNED SMALL BUSINESS CONCERNS-52.219-14 LIMITATIONS ON SUBCONTRACTING .DEC 1996 52,222 CONVICT LABOR AUG 1996 52.222-26 -EQUAL OPPORTUN7TY APR 1984
~
I-1 F
NRR-98-021 SGction 2 52.222-28 EQUAL OPPORTUNITY PREAWARD CLEARANCE OF APR 1984 SUBCONTRACTS 52.222-36 AFFIRMATIVE ACTION FOR HANDICAPPED APR 1984 WORKERS 52.222-37 EMPLOYMENT REPORTS ON SPECIAL DISABLED JAN 1988 VETERANS AND VETERANS OF THE VIETNAM ERA 52.223-2 CLEAN AIR AND WATER APR 1984 ,
52.223-6 DRUG-FREE WORKPLACE JAN 1997 52.225-11 RESTRICTIONS ON CERTAIN FOREIGN OCT 1996 PURCHASES 52.227-1 AUTHORIZATION AND CONSENT JUL 1995 52.227-2 NOTICE AND ASSISTANCE CONCERNING PATENT AUG 1996 AND COPYRIGHT INFRINGEMENT 52.228-7 INSURANCE--LIABILITY TO THIRD PERSONS MAR 1996 52.232-17 INTEREST JUN 1996 52.232-22 LIMITATION OF FUNDS APR 1984 52.232-23 ASSIGNMENT OF CLAIMS JAN 1986 52.233-1 DISPUTES MAR 1994 ALTERNATE I (DEC 1991) 52.233-3 PROTEST AFTER AWARD AUG 1996 ALTERNATE I (JUN 1985) 52.237-3 CONTINUITY OF SERVICES JAN 1997 52.242-1 NOTICE OF INTENT TO DISALLOW COSTS APR 1984 52.242-3 PENALTIES FOR UNALLOWABLE COSTS OCT 1995 52.242-13 BANKRUPTCY JUL 1995 52.243-2 CHANGES--COST REIMBURSEMENT AUG 1987 ALTERNATE I (APR 1984) 52.244-2 SUBCONTRACTS (COST-REIMBURSEMENT AND FEB 1997 LETTER CONTRACTS) 52.244-5 COMPETITION IN SUBCONTRACTING DEC 1996 52.244-6 SUBCONTRACTS FOR COMMERCIAL ITEMS AND OCT 1995 COMMERCIAL COMPONENTS 52.246-25 LIMITATION OF LIABILITY--SERVICES FEB 1997 52.249 6 TERMINATION (COST-REIMBURSEMENT) SEP 1996 52.249-14 EXCUSABLE DELAYS APR 1984 52.253-1 COMPUTER GENERATED FORMS JAN 1991 I.2 52.216-18 ORDERING (OCT 1995)
(a) Any supplies and services to be furnished under this contract shall be ordered by issuance of delivery orders or task orders by the individuals or activities designated in the Schedule. Such orders may be issued from the effective date of the contract through contract expiration.
(b) All delivery orders or task orders are subject to the terms and conditions of this contract. In the event of conflict between a delivery order or task order and this contract, the contract shall control.
(c) If mailed, a delivery order or task order is considered
" issued" when the Government deposits the order in the mail. Orders may be issued orally, by facsimile, or by electronic commerce methods only if authorized in the Schedule.
I-2
NRR-98-031 Section 8 l
I.3 52.216-19 ORDER LIMITATIONS (OCT 1995)
(a) Minimum order. When the Government requires supplies or services covered by this contract in an amount of less than $1.00, the Government is not obligated to purchase, nor is the contractor obligated to furnish, those supplies or services under the contract.
(b) Maximum order. The Contractor is not obligated to honor--
(1) Any order for a single item in excess of the ceiling amount of the contracts (2) Any order fcr a combination of items in excess of the ceiling amount of the contract; (3) A series of orders from the same ordering office within 60 calendar days that together call for quantities exceeding the limitation in subparagraph (1) or (2) above, (c) If this is a requirements contract (i.e., includes the Requirements clause at subsection 52.216-21 of the Federal Acquisition Regulation (FAR)), the Government is not required to order a part of any one requirement from the Contractor if that requirement exceeds the maximum-order limitations in paragraph (b) above.
(d) Notwithstanding paragraphs (b) and (c) above, the Contractor shall honor any order exceeding the maximum order limitations in paragraph (h), unless that order (or orders) is returned to the ordering office within 2 working days after issuance, with written notice stating the contractor's intent not to ship the item (or items) called for and the reasons. Upon receiving this notice, the Government may acquire the supplies or services from another source.
I.4 52.216-22 INDEFINITE QUANTITY (OCT 1995)
(a) This is an indefinite-quantity contract for the supplies or services specified, and effective for the period stated, in the Schedule. The quantities of supplies and services specified in the Schedule are estimates only and are not purchased by this contract.
(b) Delivery or performance shall be made only as authorized by orders issued in accordance with the ordering clause. The Contractor shall furnish to the Government, when and if ordered, the supplies or services specified in the Schedule up to and including the quantity designated'in the Schedule as the a raaximum. " The Government shall order at least the quantity of supplies or services designated in the Schedule as the a minimum."
(c) Except for any limitations on quantities in the Order I-3
NRR-98-021 Saction I l
. s
'imitotions
, c1cuco or in tho Schsdulo, thoro'io no limit on ths l iumber of orders that may-be issued. The Government may issue i siders requiring delivery to multiple destinations or performance at multiple locations. !
(d) Any order issued during the effective period of this contract cnd not completed within that period shall be completeu by the contractor within the time specified in the order. The contract chall govern the Contractor's and Government's rights and obligations with respect to that order to the same extent as if the order were completed during the contract's effective period; 1 provided, that the Contractor shall not be required to make any j deliveries under this contract after six months. l I.5 52'.217-9 OPTTON TO EXTEND THE TERN OF THE CONTRACT (MAR 1989)- ,
(a) The Government may extend the term of.this contract by written notice to.the Contractor within 60 days providad, that the .
Government shall give the Contractor a preliminary written. notice of its' intent to extend at least 60 days before the contract expires. !
+
-The; preliminary-notice does not commit the Government to an l oxtension.
(b) If!the Governmant exercises this option, the extended contract . .
chall be considered to include this option provision.
'(c) The total duration of this concract, including the exercise of any options under this clause, shall not-exceed S years. -
T I.6 52.232-25 PROMPT PAYMENT (JtfN 1997)
'Notwithstanding-any other. payment clause in this contract, the ,
Government will make invoice payments and contract financing l
. payments under the terms and conditions specified in this clause.
Payment shall be considered as being made on the day a check is dated or the date-of an electronic funds transfer. Definitions of pertinent terms'are set forth in section 32.902.of the Federal Acquisition Regulation. All days referred to in this clause are !
calendar days, unless otherwise specified. (However, see oubparagraph- (a) (4) of this clause concerning. payments due on ,
' Saturdays, Sundays,-and legal holidays.)
~ (a) T Invoice payments " (1) Due-Date. (i) Except as indicated in i cubparagraph - (a) (2) and: paragraph'(c) of this clause, the due date ifor making: invoice payments;by.the designated payment office shall '
1 be'the later of'the following1two' events:- ;
i X
.(A)L The Toth day af ter the designated billing of fice has 4 -I l i
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NRR-98-021 Soction I :
recoived a prepar invoico f rom the Contractor (except es provided in ,
subdivision (a) (1) (11) of this clause).
(B) The 30th day after Government acceptance of supplies delivered or services performed by the contractor, on a final invoice where the payment amount is subject to contract settlement actions, acceptance shall be deemed to have occurred on the effective date of the contract settlement.
(ii) If the desicnated billing office fails to annotate the invoice with the actuaI date of receipt at the time of receipt, the '
invoice payment due date shall be the 30th day after the date of the Contractor's invoice; provided a proper invoice is received and ;
there is no disagreement over quantity, quality, or Centractor ,
compliance with contract requirements. 1 (2) Certain food products and other payments. (i) Due dates on Contractor invoices for meat, meat food products, or fish; perishable agricultural commodities; and dairy products, edible fats or oils, and food products prepared from edible fats or oils are--
(A) For meat or meat food products, as defined in section 2 (a) (3) of the Packers and Stockyard Act of 1921 (7 U.S.C. 182 (3 ) ) ,
and as further defined in Pub. L.98-181, including any edible fresh ,
or frozen poultry meat, any perishable poultry meat food product, fresh-eggs, and any perishable egg product, as close as possible to, but not later than, the 7th day after product delivery.
(B) For fresh or frozen fish, as defined in section 204 (3) of the Fish and Seafood Promotion Act of 1986 (16 U.S.C. 4003(3)),
as close as possible to, but not later than, the 7th day after '
product delivery.
(C) For perishable agricultural commodities, as defined in section 1(4) of the Perishable Agricultural Commodities Act of 1930 (7 U.S.C. 499a(4)), as close as possible to, but not later than, the 10th day after product delivery, unless another date is specified in the contract.
(D) For dairy products, as defined in section 111(e) of the Dairy Production Stabilization Act of 1983 (7 U.S.C. 4 502 (e) ) ,
. edible fato or oils, and food products preparea from edible fats or oils, aus close as possible to, but not later than, the loth day after the date on which a proper invoice has been received. Liquid milk, cheese, certain processed cheese products, but er, yogurt, ice cream, mayonnaise, salad dressings, and other similar products, fall within this classification. Nothing in the Act limits this classification to refrigerated products. When questions arise regarding the proper classification of a specific product, prevailing industry practices will be followed in specifying a contract papent due date. The burden of proof that a classification of a s?ccific product is, in fact, prevailing industry practice _is upon tie Contractor making the representation.
(ii) If-the contract does not require submission of an invoice for payment (e.g., periodic lease payments), the due date will be as I-5 9 C T
. - . . .- - .. . . . . . . . - _ - ..- - - ~ -
NRR-98-021 Section I cpacified in the contreet.
(3's Contractor's invoice. The Contractor shall prepare and cubmit invoices to the designated billing office specified in the contract. A proper invoice must include tne items listed in paragraph (a)-(3) (1) through (a) (3) (viii) of this clause. If the :
invoice does not comply with these requirements, it shall be '
returned within 7 days after the date the designated billing office received the invoice (3 days for meat, meat food products, or fish; ,
5 days for perishable agricultural commodities, edible fats or oils, end food products prepared from edible fats or oils), with a otatement of the reasons whv it is not a proper invoice. Untimely notification will be taken into account in computing any interest penalty owed the contractor in the manner described in subparagraph !
(a) (5) of this clause. ,
(1) Name and address of the Contractor.
(ii) Invoice date. (The Contractor is encouraged to date it.solces as close as possible to the date of the mailing or transmission.)
- . (iii) Contract number or other authorization for supplies 46 Livered or services performed (including order number and contract
.line item number) ,
(iv) Description, quantity, unit of measure, unit price, and extended price of suppliep delivered or services performed.
(v) Shipping and payment terms (e.g., shipment number and date of shipment, prompt payment discount terms). Bill of lading number and weight of shipment will be shown for shipments on Government bills of lading.
(vi) Name and address of Contractor official to whom payment i
is to be sent (must be the same as that in the contract or in a proper notice of assignment).
(vil) Name (where practicable), title, phone number, and mailing address of person to be notified in the event of a defective invoice.
(viii) Any other information or documentation required by the :
contract (such as evidence of shipment).
(ix) While not required, the contractor is strongly encouraged to assign an identification number to each invoice. ;
<(4) Interest penalty. An interest penalty shall be paid cutomatically by the designated payment office, without request from the-contractor, if payment-is not made by the due date and the conditions listed in paragraphs (a) (4) (i) through (a)'(4) (iii) of this clause are met, if applicable. However, when the due date falls on a Saturday, Sunday, or legal holiday when-Federal Government offices-are closed,and Government business is not expected to be ,
-conducted,= payment may be made on the following business day without ,
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i NRR-98-021 Soction ! ;
incurring c leto paymant interent pennity.
(1) A proper invoice was received by the designated billing '
office (ii) A receiving' report or other Government documentation authorizing payment was processed, and there was no disagreement over term quantity, or condition. quality, or Contractor. compliance with any contract (iii) In the case of a final invoice for any balance of funds due the Contractor for supplies delivered or services performed, the amount was not subject to further contract settlement actions between the 09vernment and the Contractor.
(5) Computing penalty amount. The inte. rest penalty shall be at the rate established by the Secretary of the Treasury under section 12 of the Contract Disputes Act of 1978 (41 U. S .C. 611) that is in effect on the day after the due date, except where the interest penalty is prescribed by other governmental authority (e.g.,
tariffs). Tais rate is referred to as the " Renegotiation Board Interest Rate," and it is published in the Federal Register semiannually on or about January 1 and July 1. The interest penalty shall accrue daily on the invoice principal payment amount approved by the Government until the payment date of such approved principat amount; and will be compounded in 30-day increments inclusive from the first day after the due date through the payment date. That is, interest accrued at the end of any 30-day period will be added to the approved invoice principal payment amount and will be subject to interest penalties if not paid in the succeeding 30-day period. If the designated billing office failed to notify the contractor of a defective invoice within the periods prescribed in subparagraph (a) (3) of this clause, the due date on the corrected invoice will be adjusted by subtracting from such date the number of days taken beyond the prescribed notification of defects period. Any interest penalty owed the Contractor will be based on this adjusted due date.
Adjustments will be made by the designated payment office for errors in calculating interest penalties.
(i) For the sole purpose of computing an interest penalty that might be due the Contractor, Government acceptance shall be deemed to have occurred constructively on the 7th day (unless otherwise specified in this contract) after the Contractor delivered the supplieu or performed the services in accordance with the terms and conditions of the contract, unless there is a disagreement over quantity, provision. quality, or contractor In the event that actual compliance acceptance with a contract occurs within the constructive acceptance period, the determination of an interest penalty shall be based on the actual date of acceptance. The constructive acceptance requirement does not, however, compel Government officials to accept supplies or services, perform contract administration functions,.or make payment prior to fulfilling their responsibilities.
(ii) The following periods of time will not be included in the determination of an interest-penalty:
I-7 1'
l
NRR-98-021 S3ction I (A) The period taken to notify the Contractor of defects in .
invoices submitted to the Government, but this may not exceed 7 days :
(3 days for meat, meat food products, or fish; 5 days for perishable cgricultural commodities, dai n products, edible fats or oils, and l food products prepared from edible fats or oils).
(B) The period between the defects notice and resubmission -
of the corrected invoice by the Contractor.
(C) For incorrect electronic funds transfer (EFT) '
information, in accordance with the EFT clause of this contract.
(iii) Interest penalties will not continue to accrue after the filing of a claim for such penalties under the clause at 52.233-1, Disputes, or for more than 1 year. Interest penalties of less than
-$1 need not be paid.
(iv) Interest penalties are not required on payment delays due t to disagreement between the Government and the contractor over the ,
payment amount or other issues involving contract compliance or on !
cmounts temporarily withheld or retained in accordance with the 3 terms of the contract. Claims involving disputes, and any interest that may be payable, will be resolved in accordance with the clause at 52.233-1, Disputes.
(6) Prompt payment discounts. An interest penalt paid automatically by the designated payment office,ywithout also shall request be from the Contractor, if a discount for prompt payment is taken i improperly. The interest penalty will be calculated as described in oubparagraph (a) (5) of this clause on the amount of discount taken for the period-beginning with the first day after the end of the i discount period through the date when the contractor is paid.
(7) Additional interest ?enalty. (i) a enaltv l calculated in accordance wit s ?aragraph (a)p(7) (iil) amount, of this clause, ,
chall be paid in addition to t7e interest penalty amount if the :
contractor-- l (A) Is owed an interest penalty of $1 or more; (B) lts not paid the interest penalty within 10 days af ter the date the invoice amount is paid; and (C) Makes a written demand to the designated payment office e for. additional ?enalty payment, n accordance with paragraph (a) (7) (ii) of tais clause, postni iked not later than 40 days after the invoice amount is paid. '
(ii) ( A) Contractors shall support written demands for edditional ?enalty payments.with the following data. No additional i data shall ao required. Contractors shall--
(1) Specifically assert that lata payment interest is due under aJapecific-invoice, and request payment of all overdue late payment interest penalty and such additional penalty as may be I-8 i l
HRR-90-021 Stction I requirod; (2) Attach a co payment interest was due;py andof the invoice on which the unpaid late (3) State that payment of the principal has been received, t including the date of receipt. l i
(B) Derands must be postmarkec on or before the 40th day after payment was made, except that--
(1) If the postmark is illegible or nonexistent, the i demand must have been received and annotated with the date of receipt'by the designated payment office on or before the 40th day after payment was made; or (2) If the postmark is illegible or nonexistent and the designated payment office fails to make the required annotation, the demand's validity will be determined by the date the Contractor has placed on tne demand; provided such date is no later than the 40th ,
day after payment was made. !
(iii) (A) The additional penalty shall be equal to 100 percent of any original late payment interest penalty, except-- i (1) The additional penalty shall not exceed $5,000; (2) The additional penalty shall never be less than $25; and (3) No additional penalty is owed if the amount of the !
underlying interest penalty is less than $1.
(B) If the interest penalty ceases to accrue in accordance '
with the limits stated in paragraph (a) (5) (iii) of this clause, thb amount of the additional penalty shall be calculated on the amount of interest penalty that would have accrued in the absence of these limits, subject to the overall limits on the additional penalty specified in paragraph (a) (7) (iii) (A) of this clause.
(C) For determining the maximum and minimum additional penalties, the test shall be the interest penalty due on each separate pa pent made for each separate contract. The maximum.and minimum. additional penalty shall not be based upon individual ,
invoices unless the invrices are paid separately. Where payments are consolidated'for disbursing purposes, the maximum and minimum additional pena);y determination shall be made separately for each contract therein.
(D) The additional-penalty does not apply to payments regulated by other Government regulations (e.g., papents under utility contracts subject to tariffs and regulation).
(b) Contract financing payments--(1) Due dates for recurring financing payments. If this contract provides for contract financing, requests for payment shall be submitted to the designated billing office as specified in this contract or as directed by the 1-9
l NRR-98-021 Saction I Contrccting Officar. Controet financing paym:nto chcIl bo mada on the day after receipt of a proper contract financing request by the designated billing office. In the event that an audit or other review of a specific financing request is required to ensure compliance with the terms and conditions of the contract, the designattad payment office is not compelled to make payment by the due date specified.
I (2) Due dates for other contract financing. For advance .
-payments, loans, or other arrangements that do not involve recurring cubmissions of contract financing requests, payment shall be made in 3 cecordance with the corresponding contract terms or as directed by '
the Contracting Officer.
(3) Interest penalty not applicable. Contract financing pa chall not be assessed an interest penalty for payment delays. yments l the(c) claur' Fastpayment *. 52.213-1, procedure due dates.
Fast Payment If this contract contains Procedure, payments will-be
- made wiel 65 days after the date of receipt of the invoice.
r I
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NRR-98-021' Saction J f I
i PART III - LIST OF DOCUMENTS, EXNIBITS AND OTHER ATTACHNENTS SECTION J LIST OF ATTACNNENTS ATTACHMENT NUMBER TITLE 1 Billing Instructions 2 NRC Organizat4onal Conflicts of Interest 3 NRC Handbook 3.8 4 NRC Form 187 - Security / Classification Requirements
!5 ACH Vendor / Miscellaneous Payment Enrollment Form.
6-- NRC Hanual Chapter 610
'7. Format for Submission of Cost Proposal 2
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NRR-98-021 Soctio.. K PART IV - REPRESENTATIONS AND INSTRUCTIONS SECTION K - REPRESENTATIONS, CERTIFICATIONS AND OTHER STATENENTS OF OFFERORS K.1 NOTICE LISTING SOLICITATION PROVISIONS INCORPORATED BY REFERENCE The following solicitation provisions pertinent to this Section are hereby incorporated by reference (by Citation Number.
Title, and Date) in accordance with the FAR provision at FAR "52.252-1 SOLICITATION PROVISIONS INCORPORATED BY REFERENCE (JUN 1988)" in Section L of this solicitation.
NUMBER TITLE DATE FEDERAL ACQUISITION REGULATION (48 CFR Chapter 1)-
52.203-11 CERTIFICATION AND DISCLOSURE REGARDING APR 1991 PAYMENTS TO INFLUENCE CERTAIN FEDERAL TRANSACTIONS 52.222-21 CERTIFICATION OF NONSEGREGATED APR 1984 FACILITIES K.2 52.203-8 CANCELLATION, RECISSION, AND RECOVERY OF FUNDS FOR ILLEGAL OR IMPROPER ACTIVITY (JAN 1997)
(a) If the Government receives information that a contractor or a er p(a) son
, (b),hac engaged (c), or (d) in of conduct Section constituting a violation 27 of the Office of subsection of Federal Procurement Policy Ac* (41 U. S . C. 423) (the Act) , as amended by section 4304 of the . ;ional Defense Authorization Act for Fiscal Year 1996 (Pub. L. 104-106), the Government may--
(1) Cancel the solicitation, if the contract has not yet been awarded or issued; or (2) Rescind the contract with respect to which--
(i) The Contractor or someone acting for the Contractor has been convicted for an offense where the conduct constitutes a violation of subsection 27 (a) or (b) of the Act for the purpose of either--
(A) Exchanging the information covered by such subsections for anything of value; or (B) Obtaining ot givingLanyone a competitive advantage in the award of a Federal agency procurement contract; or K-1 L
NRR-98-021 Scction K (ii) The head of the contracting activity has determined, based upon a preponderance of the evidence, that the contractor or comeone acting for the Contractor has engaged in condact constituting an of fense punishable under subsection 27 (e) (1) of the Act.
(b) If the Government rescinds the contract under paragraph (a) of this clause, the Government is entitled to recover, in addition to cny penalty prescribed by law, the amount expended under the contract.
(c) The rights and remedies of the Government specified herein are not exclusive, and are in addition to any other rights and remedies provided by law, regulation, or under this contract.
K.3 52.204-3 TAXPAYER IDENTIFICATION (JUN 1997)
(a) Definitions.
" Common parent," as used in this solicitation provision, means that corporate entity that owns or controls an affiliated group of corporations that files its Federal income tax returns on a consolidated basis, and of which the offeror is a member.
" Corporate status," as used in this solicitation provision, means e de signation as to whetner the of feror is a corporate entity, an unir.corporated entity (e.g., sole proprietorship or partnership), or o corporation providing medical and health care services.
" Taxpayer Identification Number (TIN) , " as used in this colicitation provision, means the number required by the IRS to be used by the offeror in reporting income tax and other returns.
(b) All offerors are required to submit the information required in paragraphs (c) through (e) of this solicitation provision in order to comply wita reporting requirements of 26 U.S.C. 6041, 6041A, and 6050M and implementing regulations issued by the Internal Revenue Service (IRS). If the resulting contract is subject to the reporting requirements described in FAR 4.903, the failure or refusal by the offeror to furnish the information may result in a 31 percent reduction of payments otherwise due under the contract.
(c) Taxpayer Identification Number (T1N).
() TIN: .
() TIN has been applied for.
() TIN is not required because
() Offeror is a nonresident alien, foreign corporation, or foreign partnership that does not have income effectively connected with the conduct of a trade or, business in the U.S. and does not have an office or place of business or a fiscal paying agent in the U.S.;
K-2
NRR-98-021 Section K
() Offoror la on egency or instrumentality of a foreign ,
government; -
() Offeror is an agency or instrumentality of a Federal, '
state, or local government;
() Other. State basis.
(d) Corporate Status.
I
() Corporation providing medical and health care services, !
or engaged in the billing and collecting of payments for such services;
() Other corporate entity; -
() Not a corporate entity; i
() Sole proprietorship;
() Partnersaip;
() Hosp it (c)al or extended care facility described 501 (3) that is exempt from taxation under in 2626 CFR CFR '
501 (a) . 5 (e) Coumon Parent.
() Offeror is not owned or controlled by a common parent as defined in paragraph (a) of this provision.
() Name and TIN of common parent:
Name TIN l
K.4 52.209-5 -CERTIFICATION REGARDING DEBARMENT, SUSPENSION, PROPOSED DEBARMENT, AND OTHER RESPONSIBILITY MATTERS (MAR 1996)
(a) (1) The Offeror certifies, to the best of its knowledge and belief, that -
(1) The Offeror and/or any of-its Principals -
(A) Are () are not [] presently debarred, suspended, proessed for debarment, or declared ineligible for the award of l col. acts inr any Federal agency; (B) Have [] have not [ ), within a 3-year period preceding this offer, been convicted of or had a civil judgment rendered against-them for: commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or ~
( performing a public (Federal, state, or-local) contract or
~
suocontract; violation of Federal or state antitrust statutes
. relating to the submission of offers; or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, tax evasion or receiving stolen property; and
-(C) 'Are [ 3 are not [] presently indicted for, or-K-3 l'
+ . r - .-- , . - . - ,,
NRR-98-021 S;ction K othorwico criminally or civilly chnrgcd by a governmantel entity with, commission of any of the offenses enumerated in subdivision (a) (1) (i) (B) of this provision.
(ii) The of feror ias [] has not [], within a 3-year period preceding this offer, had one or more contracts terminated foi default by any Federal agency.
t (2) " Principals," fo. the purposes of this certification, means officers; directors; owners; partners; and, persons having primary managemeat or supervisory responsibilities within a business entity (e.g., general manager; plant manager; head of a subsidiary, division, or business segment, and similar posit ions).
THIS CERTIFICATION CONCERNS A MATTER WITHIN THE JURISDICTION OF AN l AGENCY OF THE UNITED STATES AND THE MAKING OF A FALSE, FICTITIOUS, OR FRAUDULENT CERTIFICATION MAY RENDER THE MAKER SUBJECT TO PROSECUTION UNDEP SECTION 1001, TITLE 18, UNITED STATES CODE.
(b) The Offeror shall provide immediate written notice to the Contracting Officer if, at any time prior to contract award, the Offeror learns that its certification was erroneous when submitted or has become erroneous by reason of changed circumstances.
(c) A certification that any of the items in paragraph (a) of this provision exists will not necessarily result in withholding of an award under this solicitation. However, the certification will be considered in' connection with a determination of the Offeror's responsibility. Failure of the offeror to furnish a certification the or provide such Contracting additional Officer information may render as requested the Offeror nonresponsi by' ole.
(d) Nothing contained in the foregoing shall be construed to require establishment of a system of records in crder to render, in good faith, the certification required by paragraph (a) of this provision. The knowledge and information of an Offeror is not required to exceed that which is normally possessed by a prudent person in the ordinary course of business dealings.
(e) The certification in paragraph (a) of this provision is a material repreeentation of fact upon which reliance was placed wnen making award. If it is later determined that the offeror knowingly rendered an erroneous certification, in addition to other remedies available to the Government, the Contracting Officer may terminate the contract resulting from this solicitation for default.
K.5 52.215-4 TYPE OF BUSINESS ORGANIZATION (OCT 1997)
The offeror or respondent, by checking the applicable box, represents that--
(a) It operates as [ ] an individual, ( ) a partnership, [ ]
a nonprofit organization, [ ] a joint venture, or [ ] a K-4
NRR-98-021 Section K corporation incorporated undse the laws of the State of
\
(b) If the offeror or respondent is a foreign entity, it operates as ( ) an individual, [ ]
a partnership), ( ) a nonprofit organization, [ ] a joint venture, or ( a corroration, registered for business in (country) _.
K.6 52.215-6 PLACE OF PERFORMANCE (OCT 1997)
(a) The offeror or respondent, in the performance of any contract resulting from this solicitation, [ ] intends, ( ) does not intend (check applicable block) to use one or more plants or facilities located at a different address from the address of the offeror or respondent as indicated in this proposal or response to request for information.
(b) If the offeror or respondent checks " intends" in paragraph (a) of this provision, it shall insert in the following spaces the required information:
Place of performance (street Name and address of owner and (street address, city, state, operator of the plant or facility county, code) if other than offeror or respondent X.7 52.219-1 SMALL BUSINESS PROGRAM REPRESENTATIONS (JAN 1997)
(a) (1) ~ The standard industrial classification (SIC) code for this acquisition is 8711.
(2) The small business size standard is $2.5 million (average annual receipts for 3 preceding fiscal yrs) .
(3) The small business aize standard for a concern which submits an offer in its own name, other than on a construction or service K-5
NRR-98-021 Saction K
) contrcet, but which proporos to furnich a product which it did not I itself manufacture, is 500 employees.
(b) Representations. (1) The offeror represents as part of its offer that it [] is, () is not a small business concern.
(2) (Complete only if offeror represented itself as a small business concern in block (b) (1) of this section.) The offeror represents as part of its offer that it [] is, [] is not a small disadvantaged business concern.
(3) (Complete only if offeror represented itself as a small business concern in block (b) (1) of this section.) The offeror represents as part of its offer that it [] is, ( ) is not a women-owned small business concern.
(c) Definitions.
" Joint venture", for purposes of a small disadvantaged business (SDB) set-aside or price evaluation preference (as prescribed at 13 CFR 124.321), is a concern that is owned and controlled by one or more socially and economically disadvantaged individuals entering
- into a joint venture agreement with one or more business concerns cnd is considered to be affiliated for size purposes with such other concern (s). The combined annual receipts or employees of the concerns entering into the joint venture must meet the applicable size standard corresponding to the SIC code designated for the contract. The majority of the venture's earnings must accrue directly to the socially and economically disadvantaged individuals in the SDB concern (s) in the joint venture. The percentage of the ownership involvement in a joint venture by disadvantaged individuals must be at least 51 percent.
"Small business concern", as used in this provision, means a concern, including its affiliates, that is independently owned and operated, not dominant in the field of operation in which it is bidding on Government contracts, and qualified as a small business under the criteria.in 13 CFR Part 121 and the size standard in paragraph (a) of this provision.
"Small disadvantaged business concern", as used in this provision, means a small business concern that (1) . is at least 51 percent unconditionally owned by one or more individuals whc are both socially and economically disadvantaged, or a publicly owned business having at least 51 percent of its stock unconditionally owned by one or more socially and economically disadvantaged individuals, and (2) has its management and daily business controlled by one or more such individuals This term also means a small business concern that is at least 51 percent unconditionally owned by an economically disadvantaged Indian tribe or Native Hawaiian Organization, or a publicly owned business having at least 51 percent of its stock unconditionally owned by one or more of these entities, which has its management and dcily business controlled by members of an economically disadvantaged Indian tribe or Native Hawaiian Organization, and which meets the requirements of 13 CFR Part 124.
K-6
NRR-98-021 Section K
" Women-owned small business concern", as used in this provision, j
means a small business concern--
(1) Which is at least 51 percent owned by one or more women or, in the case of any publicly ownad business, at least 51 percent of the stock of which is owned by one or more women; and (2) Whose management and daily business operations are controlled by one ca more women.
(d) Notice. (1) If this solicitation is for supplies and has been set aside, in whole or in part, for small business concerns, then the clause in this solicitation providing notice of the set-aside contains restrictions on the source of the end items to be furnished.
(2) Under 15 U.S.C. 64 5 (d) , any person who misrepresents a firm's status as a small or small disadvantaged business concern in order to obtain a contract to be awarded under the preference programs established pursuant to sections 8(a), 8(d), 9, or 15 of the Small Business Act or any other provision of Federal law that specifically references section 8(d) for a definition of program eligibility, shall--
(i) Re punished by imposition of fine, imprisonment, or both; (ii) Be subject to administrative remedies, including suspension and debarment; and (iii) Be ineligible for participation in programs conducted under the authority of the Act.
K.8 52.222-22 PREVIOUS CONTRACTS AND COMPLIANCE REPORTS (APR 1984)
The offeror represents that--
(a) It [] has, [] has not participated in a previous contract or subcontract subject either to the Equal Opportunity clause of this solicitation, the clause originally contained in Section 310 of Executive Order No. 10925, or the clause contained in Section 201 of Executive Order No. 11114; (b) It [] has, [] has not filed all required compliance reports; and (c) Representations indicating submission of required compliance reports, signed by proposed subcontractore, will be obtained before subcontract awards.
K-7 i
NRR-98-021 Section K i
K.9 52.222-25 AFFIRMATIVE ACTION COMPLIANCE (APR 1984)
The offeror represents that--
(a) It [] has developed and has on file, [ ] has not developed and does not have on file, at each establishment, affirmative action programs required by the rules and regulations of the Secretary of Labor (41 CFR 60-1 and 60-2) , or (b) It [] has not previously had contracts subject to the written affirmative action programs requirement of the rules and regulations of the Secretary of Labor.
K.10 52.223-1 CLEAN AIR AND WATER CERTIFICATION (APR 3 984)
The offeror certifies that--
(a) Any facility to be used in the performance of this proposed contract is [ ], is not [] listed on the Environmental Protection Agency (EPA) List of Violating Facilities; (b) The Offeror will immediately notify the Contracting Officer, before award, of the receipt of any communication from the Administrator, or a designee, of the EPA, indicating that any facility that the Offeror proposes to use for the performance of the contract is under consideration to be listad on the (EPA) List of Violating Facilities; and (c) The Offeror will include a certification substantially the same as this certification, including this paragraph (c), in every nonexempt subcontract.
K.11 2052.209-70 QUALIFICATIONS-OF CONTRACT EMPLOYEES The offeror hereby certifies by submission of this offer that all representations made regarding its employees, proposed subcontractor personnel, and consultants are accurate.
K.12 2052.209-71 CURRENT /FORMER AGENCY EMPLOYEE INVOLVEMENT (a) The following representation is required by the NRC Acquisition Regulation 2009.105-70(b). It is not NRC policy to encourage offerors and contractors to propose current /former agency employees to perform work under NRC contracts, and as set forth in the above cited provision, the use of such employees may, under certain conditions, adversely affect NRC's consideration of non-competitive proposals and task orders.
K-8
NRR-98-021 Section K (b) The offeror hereby certifies that there [ ] are [ ] are no current /former NRC employees (including special Government employees performing services as experts, advisors, consultants, or meters of advisory committees) who have been or will be involved, directly or indirectly, in developing the offer, or in negotiating on behalf of the offeror, or in managing, administering, or performing any contract, consultant agreement, or subcontract resulting from this offer. For each individual oo identified, the Technical and Management proposal must contain, as a separate attachment, the name of the individual, the individual's title while employed by the NRC, the date individual left NRC, and brief description of the individual's role under this proposal.
K.13 2052.209-72 CONTRACTOR ORGANIZATIONAL CONFLICTS OF INTEREST REPRESENTATION I represent to the best of my knowledge.and belief that:
The award to of a contract or the modification of an existing contract does [ ] does not [ ] involve situations or relationships of the type set forth in 48 CFR 2009.570-3(b).
(a) If the representation, as completed, indicates that situations or relationships of the twe set forth in 48 CFR 2009.570-3 (b) are involved, or the contracting officer otherwise determines that potential organizational conflicts of interest exist, the offeror shall provide a statement in writing which describes in a concise manner all relevant factors bearing on his representation to the contracting officer. If the contracting officer determines that organizational conflicts exist, the following actions may be taken:
(1) Impose appropriate conditions which avoid such conflicts, (2) Disqualify the offeror, or (3) Determine that it is otherwise in the best interest of the United States to seek award of the contract under the waiver provisions of 48 CFR 2009-570-9.
(b) The refusal to provide the representation required by 48 CFR 2009.570-4(b), or upon request of the contracting officer, the facts required by 48 CFR 2009.570-3(b), must result in disqualification of the offeror for award.
K-9
NRR-98-021- Section.L SECTION L - INSTRUCTIONS, CONDITIONS, AND NOTICES TO OFFERORS Y
r L .1 - NOTICE LISTING SOLICITATION PROVISIONS INCORPORATED BY REFERENCE The following solicitation provisions pertinent eo this ,
section are:hereby incorporated by reference =(by Citation Number, 4 Title, and Date) in accordance with the FAR provision at FAR ,
"52.252-1 SOLICITATION PROVISIONS INCORPORATED BY REFERENCE (JUN 1988)" in Section L of this solicitation, NUMBER. ~ TITLE DATE FEDERAL ACQUISITION-REGULATION (48 CFR Chapter 1) 52.215-1 INSTRUCTIONS TO OFFERORS--COMPETITIVE OCT 1997 ACQUISITION 52k215 FACILITIES CAPITAL COST OF MONEY OCT 1997
- 521222-24 PREAWARD ON-SITE EQUAL OPPORTUNITY APR 1984 COMPLIANCE REVIEW L.2: 52.204-6 CONTRACTOR IDENTIFICATION NUMBER--DATA UNIVERSAL NUMB 5 RING SYSTEM ~(DUNS) NUMBER (DEC 1996)
(a) Contractor Identification Number, as used in this provision, means " Data Universal Numbering System (DUNS) number," which is a nine-digit number assigned by Dun and Bradstreet Information Services.
(b) Contractor identification is essential'for complying with
. statutory-contract-reporting requirements. Therefore, the offeror is requested'to enter, in the block with-its name and address on the Standard Form 33 or similar document, the annotation " DUNS" followed by the DUNS number which identifies the offeror's name and address exactly as stated in the'. offer.
-(c) If the offeror does not have a' DUNS number, it should contact Dun and Bradstreet directly to obtain one. A DUNS number will be
~
provided immediately by telephone at no charge to the offeror. For information on obtaining -a DUNS number, the offeror should call' Dun and Bradstreet at 1-800-333-0505. The offeror should be prepared to provide the following information:
(1) . Companyfname.
(2 ) Company - address .
(3)M Company telephone number.
L -
1 r
NRR-98-021- Section L (4). Lina of 'buoinocs; (5) ChiefLexecutivo officer / key manager.
(6) DateLthe company was-started.
(7) Number of~ people' employed by the company.
(8) Compar;y af filiation. -
(d' Offerors located outside the United States may obtain the location and phone number of-the local-Dun and Bradstreet Information Services office from the Internet Home Page at http://www.dbisna.com/dbis/ customer /custlist.htm. If an offeror is unable to locate a local service center,.it may send an e-mail to Dun and Bradstreet at globalinfo@dbisma.com.
L.3 52.215-20 REQUIREMENTS FOR COST OR PRICING-DATA OR INFORMATION OTHER THAN COST OR PRICING DATA (OCT 1997)
ALTERNATE IV (OCT 1997)
(a)., Submission of cost-or pricing data-is not required.
(b) Provide information in the format found as Attachment 7.
L.4 52.216-1 TYPE OF CONTRACT (APR 1984)
The Government contemplates award of a cost plus fixed fee
-indefinite quantity contract resulting'from this solicitation.
L.5 52.216-27. SINGLE OR MULTIPLE AWARDS (OCT 1995)
The Government may elect to award a single delivery order contract or task' order contract or to award multiple delivery order contracts or-task order contracts for the same or similar supplies or services to two or more sources under this solicitation.
L-2
- iNRR-98-021 Section L- ,
L46- 524233-2__ SERVICE OF PROTEST .(AUG-1990) ,
'(a)JProtests;{as defined in section 33s101 of the Federal: >
Acquisition 1 Regulation, that;are filed directly:with an agency, and- ,
- copies of:any protests 4that are filed with the General-Accounting. 3 LOf fice 5(GAO) , shall-be-served on the Contracting Officer-(addressed -
as:follows)fby_ obtaining written and_ dated acknowledgment of receipt _ -
Iromi' THand-Carried Address: ;
U.S. Nuclear Regulatory Commission-Division of: Contracts and Property Mgt.
Attn: T-7-I 11545 Rockville Pike- i Rockville MD 20852
. Mailing Address:
- U.S. Nuclear = Regulatory Commission Division of Contracts and Property Mgt. ~
. Attn:-T-7-I-2 11545 Rockville Pike
. Washington'DC 20555
.(b)..The copy of-any protest shall-be received in the office designated above within one, day of filing a protest with the GAO.
'L.7 '52.252-1 SOLICITATION PROVISIONS INCORPORATED BY
' REFERENCE (JUN 1988)
. This-solicitation incorporates one or more solicitation provisions lby reference, with the same force-and effect as if they were given i
'in1fullatext. Upon request, the Contracting Officer-will make their -
fullLtext available, lb.8 ;2052.215-76 DISPOSITION OF PROPOSALS
- After award of1 the1 contract, one copy of-each unsuccessful proposal m is-retained by the-NRC's-Division of Contracts 1and Property ~
- Management ~in ' accordance_ with1the General Records . Schedule' 3 (5) (b) .
- Unless1 return of1the additional: copies of the proposals is requested by_.theLofferor:upon submission of' proposal, all other copies will be destroyed. This:requestLshould appear in a. cover letter-accompanying g the; proposal.-
L-3 t
7 k
}e--
y-- = . -
NRR-98-021 Saction L r
V L.9 2052.222-70 NONDISCRIMINATION BECAUSE OF AGE It is the policy of the Executive Branch of the Government that: ,
(a). Contractors and subcontractors engaged in the performance of
- Federal? contracts may not, in connection with the employment, cdvancement, or discharge of employees or in connection with the terms, conditions, or privileges of their employment, discriminate cgainst persons because of their age except upon the basis of a bona-fide occupational qualification, retirement plan, or statutory-requirements; and (b) That'contracters and subcontractors, or person acting on their behalf, may not specify, in_ solicitations or advertisements for employees to work on Government contracts, a maximum age limit for cmplopent unless the specified maximum age limit is based upon a bona fide occupational qualification, retirement plan, or statutory requirement.
L.10 ESTIMATED DURATION (JUN 1988)
The. duration of the contract is estimated to be three years. (See Section F for any option periods) -
'L.11 USE OF AUTOMATED CLEARING HOUSE (ACH) ELECTRONIC PAYMENT / REMITTANCE ADDRESS The Debt Collection Improvement Act of 1996 requires that all Federal-payments except IRS tax refunds be made by Electronic Funds Transfer, lt is the policy of the-Nuclear Regulatory Commission to pay government vendors by the Automated Clearing House (ACH) electronic funds transfer payment system. Item 15C of the Standard Form 33-may_be disregarded.
L.12 TIMELY RECEIPT OF PROPOSALS
-All" hand-carried offers including those made by private delivery services (e.g., Federal Express and Airborne Express) must be delivered to the NRC loading dock security station located at 11545 Rockville Pike, Rockville, Maryland 20852 and received in the located in Room T-7-I-2. All offerors shall allow extra
-depository:ternal1 time.for in mail distribution. NRC is a secure facility with
= perimeter access-control and NRC personnel are not available to receive hand-carried offers except during normal working houra, 7:30 L-4
NRR-98-021 Section L AM - 3:30 PM, Mondny through Friday, excluding federal holidays.
L.13 AWARD NOTIFICATION AND COMMITMENT OF PUBLIC FUNDS (a) All offerors will receive preaward and postaward notices in accordance with FAR 15.503.
(b) It is also brought to your attention that the contracting officer is the only individual who can legally commit the NRC to the expenditure of public funds in connection with this procurement.
This means that unless provided in a contract document or specifically authorized b/ the contracting officer, NRC technical personnel may not issue contract modifications, give informal contractual commitments, or otherwise bind, commit, or obligate the NRC contractually. Informal contractual commitments include:
(1) Encouraging a potential contractor to incur costs prior to receiving a contract; (2) Requesting or requiring a contractor to make changes under a contract without formal contract modifications; (3) Encouraging a contractor to incur costs under a cost-reimbursable contract in excess of those costs contractually allowable; and (4) Committing the Government to a course of action with regard to a potential contract, contract change, claim, or dispute.
L.14 PROPOSAL PRESENTATION AND FORMAT GENERAL INSTRUCTIONS
- a. Information submitted in response to this solicitation must be typed, printed, or reproduced on letter-size paper and each copy must be legible.
- b. The offeror must submit the following material, which will constitute its offer as defined by FAR 2.101, in two separate and distinct parts, at the date and time specified in Block 9 of the SF 33 for receipt of sealed offers.
- c. The offeror shall respond fully and completely to all sections of the solicitation package and to the elements that are described in the following Subparagraph entitled " TOPICS FOR ORAL TECHNICAL PRESENTATIONS AND WRITTEN TECHNICAL DOCUMENTATION"
- d. < Correctness of the proposal >>. Caution--Offerors are hereb_y notified that all information provided in its presentation L-5
NR'-98-021 R Saction L
- cnd cupporting docum2ntction, including all resumac, must ba cecurate, truthful, and complete to the best of the Offeror's knowledge and belief. The Commission will rely upon all representations made by the Offeror both in the evaluation process cnd for the performance of-the work by the offeror. The Commission ,
' may require.the offeror to substantiate the credentials, education, cnd. employment history of.its employees, subcontractor personnel, ,
cnd consultants, through submission of copies of transcripts,
-diplomas, licenses, etc.
PART 1 - SOLICITATION PACKAGE / OFFER.
- a. The Offeror shall complete and return two (2) original signed copies of this solicitation package. (The offeror does not have to return copies of the Attachments included in Section J). All cpplicable sections must be completed by the Offeror.
PART 2 - COST PROPOSAL.
- c. The Offeror shall submit one (1) original and four (4) copies of ,
the written Cost Proposal at the date and time specified in Block 9 on SF 33 for receipt of sealed offers. The format and content of this documentation is prescribed below.
PART 3 - ORAL TECHNICAL AND MANAGEMENT PRESENTATION
- n. The Offeror shall make an oral Technical and Management Presentation in accordance with the instructions contained herein.
Immediately after the oral presentation, the Offeror shall participate in an interview conducted by Government representatives.
The sole purpose of the oral presentation and the interview is to permit-the Government to test and evaluate the Offeror's knowledge end competence with regard to the Government's requirements and program objectives, the relevant technology, and program challenges and risks.
- b. Neither the oral presentation nor the interview will constitute discussions within the meaning of FAR 15.306 (d) and neither will
. obligate the Government to entertain revisions to the offer. During the presentation,-the-Government will not inform an Offeror of their atrengths, deficiencies, or weaknesses and will not engage in bargaining. The Government intends to award without discussions.
However, the Government may hold discussions and request revised proposals, if necessary.
- c. -The offeror shall submit one (1) original and four (4) copies of Written Technical Documentation on the date and time specified in
. Block 9 on SF 33 for receipt of sealed offers. The format and content of this documentation is prescribed below. Written
- Technical Documentation shall' include printed copies of the main points of each topic discussed during the Oral Technical
- Presentation. All Written Technical Documentation shall be printed, ,
Cnd reproduced on letter-size paper. Each copy must be legible, d., Oral Technical and Management Presentations will be held in a
- conference room _in NRC Headquarters located on Rockville Pike, in L-6 Ee
NRRi 98-021 'Saction L ;
- Rockville; Maryland. -Th's conference room will have a viewing screen. ..The NRC can provide an overhead projector for use at the request of the offeror. Contact-Mona-Selden, NRC Contract Specialist , lat- ~ (301) 415-7907 should you1 require;such equipment.
e..-The order in which'the Offerors will make their oral
. presentation will: be determined by the -Contracting Of ficer af ter >
-receipt _of offers. -Oral presenttions will-be scheduled to begin no earlier than 10 a.m..on tae third--business day after the.close of the solicitation, a f.- The Contracting Officer will notify all Offerors of their scheduled oral presentation date and time.- Once notified, Offerors-shall complete their' oral presentations as scheduled. Requests to reschedule will not be entertained. The-Government reserves the right-to reschedule oral presentations under extraordinary-circumstances'at the sole discretion of the NRC Contracting. Officer,
- g. Oral presentations:shall not exceed 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in duration and ,
shall be followed by a 30 minute recess. The subsequent interview session will commence immediately after the recess and shall not <
- exceed'one (1)-hour in duration.
L.15 ESTIMATED LEVEL OF EFFORT / ASSUMPTIONS / ESTIMATES FOR PROPOSAL PREPARATION (1) _ LABOR' CATEGORIES AND ESTIMATED-HOURS PER YEAR:
For. planning purposes, it'is assumed that the labor categories as listed below are applicable to the performance of work specified in
- Section C of this solicitation. For purposes of establishing technical capability and capability to respond to peak NRC demands, at least three > (3) qualified individuals in each technical discipline, having U.S. commercial nuclear reactor design experience at the design level and supervisory level,-shall be dedicated to this contract.
Estimated Hours
. Category Per Year Principal / Manager (or equivalent)* 960 Electrical' Power Systems Engineer cand Instrument-and Controls Engineer **
(or-equivalent) 10,000 Mechanical Systems-Engineer and Mechanical-Components (Piping / Pipe Supports) Engineer **
(or equivalent) 10,000
' Civil / Structural / Engineer **
(or equivalent) :4,480 Secretarial / Clerical 480 L-7 4
NRR-98-021' Section L
- Requires one (1) key individual (Individual shall be included as
" Key Personnel" in any resultant contract) ** Requires three (3) key individuals plus other supporting staff (Individuals shall be included as " Key Personnel" in any resultant contract)
The above' estimated hours are used:for cost evaluation purposes only. The NRC shall not be bound by these hours in any resultant contract. The contract will, however, contain an overall cost ceiling. In addition, each task order will be individually negotiated and will contain an overall cost ceiling.
(2) TYPICAL INSPECTION SCHEDULE:
The estimated level of effort for each specialist for a typical inspection consists of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> for inspection preparation (item (a) below), 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> for on-site inspection activities and review of initial findings (items (b), (c) and (d) below), and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> for inspection documentation (item (e) below). Each inspection will
' typically require one to three specialists. As stated in Section C, n . typical inspection schedule is as follows:
(a) initial preparation - 10 days (5 days at site / design offices and/or 5 days at NRC regional office). The time on site may include site access radiation training (b)* first inspection at plant site / design offices - 5 (c) review of initial inspection findings - 5 days at Contractor's home office or at NRC regional office (d)* second inspection at plant site / design offices - 5 days (e) inspection documentation - 5 days at Contractor's home (f) follow up inspection activities (if needed) - 5 days
- NOTE - site inspection activities, as noted in items (b) and
'd) above, will typically require 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> workdays (50 hour5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> work weeks).
(3) MEETINGS AND TRAVEL ESTIMATES Each task order will specify any required travel to nuclear power plant sites throughout the. United States; NRC offices in Rockville, Maryland; NRC regional offices; and any other location required for performance of the' work detailed in the task order statement of work. Generally, the following meetings and travel can be expected-for each inspection or review (assume 3 persons and 24 inspections per year) :
(a) one 5-day trip for 3 persons to the site and/or regional office for inspection preparation and to review background L-8
lNRR-98;021 Section LL
+ .information (b)' :two trips;for 3 persons.of 5 days for on-site- !
' inspection
^
(c)_ one.5 day trip to the regional office'forLin-office < review-
- NOTE: For purposes offpreparing a proposal, the contractor shall the country: listed below will be visited at the frequency stated per.
-Regions: Frequency:
Northeast U.'S. - Region I 6 inspections .
Southeast-U.S. --Region II-
~
6 inspections Midwestern U.S. - Region III 6 inspections Western U.S. -
Region IV 6 inspections Prior'to any trip taken during the period of performance under-this '
contract, the Contractor shall obtain verbal or written approval-r fromithe NRC Project Officer. No foreign travel is anticipated as -
part of this contract.
1 (d) Upon the NRC Project Officer's request, a minimum of two oral briefings per year by the contractor
~
(technical / manager) may be held at NRC .
Headquarters, Rockville, Maryland, office to review contractor progress and performance. In '
addition, up to four progress review meetings per year may-he held by the Project Officer in the contractor's home office.
(e) Any additional meetings and travel required will be specified in each Task Order.
L'.16 ' COST PROPOSAL REQUIREMENTS AND FORMAT
'a. The Offeror shall provide a= cost proposal based on the above estimated level of effort / assumptions / estimates. To provide a common base for evaluation of cost proposals, the level of effort data shall be-expressed in staff hours for each category and level--
l 'of management, technical and support staff personnel. Offerors should use 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> as. representing a staff year.
- b. LTheitotal-estimated cost: proposed by the offeror will be used
~
'forLevaluation purposes only.-Any. resultant contract must contain an .
.overall cost ceiling whereby individual Task Orders may-be--issued. '
s (Thefcost'and: fee,.if any,1for each Task Order will be-individually negotiated, and each Task Order will also contain a cost ceiling.
.c. The Offeror shalliprovide the cost proposal:in accordance with the formattincluded.as Attachment 17.
_ _L-9
.e g,.y -- $ g -
gy 9 u y9 y
NRR-98-021 Saction L i
- d. Tho coat propoanl ohn11 provida a workchcat which includs3 pertinent details sufficient to show the elements of cost upon which the total cost is predicated. The information furnished must be consistent with the offeror'a cost accounting system, coordinated with the Offeror's cognizant Audit Agency - adequately cross-referenced and suitable for detailed analysis. Any letters of cceeptance from the cognizant Audit Agency pertaining to the cost proposal should be submitted at this time. Absent a letter of cceeptance from the cognizant Audit Agency, the Offeror should provide a current point of contact (name and telephone number) within that Audit Agency who can verify the Offeror's proposed cost clements.
- o. When the Offeror's estimated cost for the proposed work exceeds
$100,000 and the duration of the contract period exceeds 6 months, the offeror shall submit a contractor Spending Plan (CSP) as part of its cost proposal. Guidance for completing the CSP is included in the attached Billing Ir/cructions.
- f. For any subcontract discussed through the technical and management presentation, provide supporting documentation on the selection process, i.e., competitive vs. non-competitive, and the cost evaluation.
- g. The offeror's cost proposal sha.1 include a description and estimated acquisition / fabrication cost of property required for performance that has a-proposed acquisition / fabrication cost in excess of $200 per item.
- h. The Offeror shall assume an award date of March 31, 1998 as the date upon which they should base their costs.
L.17 INSTRUCTIONS FOR ORAL TECHNICAL AND MANAGEMENT PRESENTATIONS AND WRITTEN TECHNICAL DOCUMENTATION
- a. The offeror shall present technical solutions to fulfill the NRC's requirement via an Oral Technical Presentation which is to be accompanied by Written Technical Documentation. The Written Technical Documentation shall document the main points of the Oral Technical Presentation. Both the Oral Presentation and the Written Technical Documentation shall present full and complete information to permit the Government to make a thorough evaluation and a sound
-determination that the proposed approach will have a reasonable likelihood of meeting the requirements and objectives of this procurement in accordance with the NRC's Statement of Work.
- b. The' Oral Technical Presentation shall not encompass price or cost and fee. However, resource information, such as data concerning labor hours and categories, subcontracts, travel, computer time, etc., shall be included in the presentation material so that the Offeror's understanding of the scope of work can be evaluated.
- c. The offeror is prohibited from taping or recording their own
-presentations. Should the NRC tape or record the nfferor's presentation, the NRC will NOT provide the Offeror with a copy of L-10 1
NRR-98-021 Section L i
tho tcpn or recording,
- d. The offeror must address the topics listed in the following subparagraph entitled, " TOPICS FOR ORAL TECHNICAL AND MANAGEMENT PRESENTATIONS AND WRITTEN TECHNICAL DOCUMENTATION".
Total presentation time shall be no longer than 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The presentation will be followed by a 30 minute intermission. The subsequent interview session wili eormence immediately after the recess and shall not exceed one (1) hour in duration.
In addition to the NRC Contracting Official, 2 members of the NRC's Office of Nuclear Reactor Regulation will attend the presentation.
L.17.1 TOPICS FOR ORAL TECHNICAL AND MANAGEMENT PRESENTATIONS AND WRITTEN TECHNICAL DOCUMENTATION The following topics must be addressed by the Offeror through the oral technical and management presentation. It is requested that those individuals proposed as key personnel for this effort perform the presentation.
- 1. CORPORATE EXPERIENCE /PAST PERFORKANCE The objective of this part of the oral presentation shall be to clearly demonstrate to the NRC the technical depth and competence of the organization beyond the personnel to be assigned to the contract and to demonstrate the organization's past performance in related efforts.
To this end, the Offeror shall discuss all corporate experience and qualifications over the past three years in roviding and performing EITHER a nuclear power plant inspection simi ar in s.ze and scope to an NRC inspection as described in Section C.3, OR a wide variety of multi-disciplined engineering design tasks including, e.g., design reviews, specialized inspections, other technical engineering services and regulatory projects encompassing the technical disciplines described in Section C 3, that are similar in size and scope to an NRC inspection as described in Section C.3., and the extent to which the necessary knowledge, experience and skills remain available within the organization. The offeror's description of current or past work shall include a description of the offeror's ability to meet schedules under the contract and control costs.
Finally, the offeror must discuss its successful performance on contracts similar in scope to this requirement. Letters of commendation should be included with the Written Technical Documentation.
- 2. ACCESS, AVAILABILITY, AND QUALIFICATIONS OF KEY PERSONNEL AND OTHER PROPOSED PERSONNEL The objective of this part of the oral presentation shall be to clearly demonstrate to NRC that the Offeror has on staff or access to qualified personnel.
l NRR-98-021 Saction L To thic cnd, tho offeror muct d:monstrcto thnt it hco cdaqucte resources to assure the *vailability of the workforce required. The offeror must discuss the methods, procedures, and criteria used in providing qualified personnel. (See Section C for Qualifications of Personnel) If subcontracts and/or consultants are proposed, the Offeror must provide a description of the extent to which the Offeror plans to place subcontracts for this work and the method of celection. Provide a list of the proposed subcontractors, if known, describe the work they will perform under the contract, and include resume (s) with related past experience.
The Offeror must discuss its means for coping with fluctuating workloads, including sources of personnel for tasks when they are casigned; a profile of the disciplines represented by each of these sources; and how the availability and access of key personnel can be ensured.
SUPPORTING DOCUMENTATION REQUIREMENTS (a) The Offeror shall provide four (4) copies of the following written documentation by the date and time specified in Block 9 of the SF 33 for receipt of sealed offers.
(1) Paper copy of the overheads or slides documenting the main points of each topic discussed through the oral presentation. All printed copies must be legible.
(2) List of all on-going contracts and contracts completed within the past three years in which you provided and performed either a nuclear power plant inspection similar in size and scope to an NRC inspection, as described in Section C.3 or a wide variety of multi-disciplined engineering design tasks including, e.g., design reviews, specialized inspections, other technical engineering services and regulatory projects encompassing the technical disciplines described in Section C.3, that are similar in size and scope to an NRC inspection as described in Section C.3. Section C, and similar in scope to this procurement. It is incumbent upon the Offeror to provide information which is accurate and current as the NRC may contact some or all references to verify the information provided. Each contract description shall not exceed 1 page in length and shall contain the following elements in identical order:
(i) Contract Number (ii) Name and Address of Government / Commercial Entity (iii) Contract office contact and telephone number (iv) Technical Representative and telephone number (v) Period of Performance including any extensions (Indicate whether or not the contract was successfully completed and include any known performance evaluations and whether or not the contract was renewed. If not renewed, explain why not)
(vi) Dollar value of Contract including modifications L-12 I
NRR-98-021 Section L (vii)- Type of Contract and brief technical des:ription (viii) Description of how the contracted effort was similar to the proposed effort. It is not sufficient to_just state that it is similar ,
in size and scope.
(3) Resumes for each individual-identified as a key person, or proposed subcontractor / consultant. Identify individuals who have been previously_ employed by NRC regulated utilities, and any organizational or employee vested interest in any NRC regulated activities. Resumes shall not exceed one page in length for each individual proposed and should be submitted in the following format:
(i) Name'and Title (ii) Name of Firm with which associated (iii). Years of Experience with this and other Firms (iv) Education - Degree (s) / Year / Specialization (v)- -Description of experience and qualifications relevant to the SOW.
(vi) A statement defining the percentage of time the Project Manager will commit to this requirement.
(vii) State if the key person proposed-is not presently employed by the Offeror. If the proposed person is under commitment, describe the terms of the commitment (s). Note
-specifically if the person will be employed
-at the time of contract award.
(End of Provision)
NRR-98-031 Section M SECTION M - EVALUATION FACTORS FOR AWARD
-w M.1 52.217-5 EVALUATION OF OPTIONS (JUL 1990)
Except when it is determined in decordance with FAR 17.206 (o) not
~
to be in the Government's bect interests, the Government will evaluate of fers for award purposes by adding the totol price for all options to the total-price for the bacic requirement. Evaluation of options will not obligate the Government to exe rcise the option (s)
M.2 2052.215.84 CONTRACT AWARD AND EVALUATION OF PROPOSALS (a) By use of numerical and narrative scoring techniques, proposals are evaluated against the evaluation factors specified in paragraph M.3 below. Award is made to the offeror:
(1) Whose proposal is technically acceptable; (2) Whose technical / cost relationship is most advantageous to the Government; and (3) Who is considered to be responsible within the meaning of Federal Acquisition Regulation Part 9.1.
(b) Although cost is a factor in the evaluation of proposals, technical merit in the evaluation criteria set forth below is a more significant factor in the selection of a contractor. Further, to be selected for an award, the proposed cost must be realistic and reasonable.
(c) The Government may:
(1) Reject any or all offers if the action is in the public interest; (2) Accept other than the lowest offer; and (3) Waive informalities and minor irregularities in offers received.
(d) The Government may award a contract on the basis of initial offers received, without discussions. Therefore, each initial offer should contain the offeror's best terms from a cost or price and technical standpoints.
(e) A separate cost analysis is performed on each cost proposal. To provide a common base for evaluation of cost proposals, the level of effort data must be expressed in staff hours. Where a contractor M-1 I
i
!Sic~'t ion M
~
NRR-98-021' L -
Spending : Plan 1.(CSP) Ein- requirsd -by othor 'provicions 'ofithic. _ . @
solicitation,Jconsideration-is givenLtoftheLPlan1foricompleteness,;
reasonableness, and as a measure of effective: management of<the-
- - offort.
- ~
(f) In making the above determination,.aneanalysisfis performedzby1 '
. theJGovernment.that takesEinto-consideration.the-results ofithet
- technical evaluation and cost analysis.
M.3 EVALUATION CRITERIA The. Offeror should ensure that its technical;andzmanagement
. discussion contains full and complete information as required by.
Section L,-Instructions:for Oral Technical and Managementtproposals.-
- 1. CORPORATELEXPERIENCE/PASTtPERFORMANCE (40 POINTS)
- a. . Extent of the offeror's corporate-experience in providing and performing EITHER a nuclear power plant inspection.simi.lar in size and scope to an NRC inspection as described in Seccion'C.3, OR a wide variety of multi-disciplined. engineering design tasks, s e.g., design reviews, specialized inspections, other technical services-and-regulatory projects encompassing the~ technical:
described in-Section C.3, that are similar in size and scope to an inspection as described in Section C.3. (20 points) 9
- b. Extent to which the offeror has' demonstrated. successful on contracts similar in. scope to this. procurement. (20' points)
- 2. AVAILABILITY, ACCESS, AND PERSONNEL QUALIFICATIONS (60 POINTS).
Availability of, access to, and qualifications.of Key personnel proposed personnel,_. including-related education, experience, and 4
4 i
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e.
, - - , . - - - ,...,,i- . , , . L.-i.. n ne rn,, - - - - - e-, , - n~ , , ,
. .t NRR-98-021 Soction M
' Spending Plcn.(CSP) icurcquired by_othar provisions ofsthis-
' colicitation,Leonsidoration:-is given-to the Plan for completeness,-_
reasonableness,:. and as ' a measure of; ef fective _ management of the
- Offort.~- -;
(f) In making the-above determination,.-an-analys'is is~ performed by 4 -
_the: Government:that takes'into consideration the results=of the' -
~ technical evaluationcand cost analysis.-
4 t
- M.3 EVALUATION CRITERIA.
The offeror should ensure that its technical.and management- _ .
discussion-contains-full and couplete information as required by. y
- Section L,-Instructions:-for Oral Technical and Management proposals. .
I In LCORPORATE EXPERIENCE /PAST PERFORMANCE (40 POINTS)-
- m. a .- Extent of the offeror's corporate experience in providing
-cnd1 performing EITHER a nuclear power plant inspection similar in size-and scope to.an NRC inspection as described-in Section C.3, OR:a wide variety =of-multi-disciplined-engineering design tasks, o.g.,- design reviews, specialized inspections,--other technical !
cervices'andl regulatory projects encompassing.the_ technical described'in Section C.3, that are similar in size and scope to an-t inspection as described in Section C.3. (20 points) b~ . - Extent to which the-offeror has demonstrated successful '
on contracts similar in scope to this procurement. (20 points)
~2. AVAILABILITY, ACCESS, AND_ PERSONNEL QUALIFICATIONS (60 POINTS)
Availability of, access to, and qualifications of Key personnel proposed personnel, including related education, experience, and e
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ATTADIO R 9 (MARCH 1996)
Page 1 of 10 BILLING INSTRUCTIONS FOR COST REIMBURSEMENT TYPE CONTRACTS general: The contractor shall prepare vouchers / invoices for reimbursement of costs in the manner and format described herein.
FAILURE TO SUBMIT VOUCHERS / INVOICES IN ACCORDANCE WITH THESE INSTRUCTIONS WILL RESULT IN REJECTION OF THE VOUCHER / INVOICE AS IMPROPER.
Number of Cocies: An original and three copies, including supporting documentation shall be submitted. A copy of all supporting documents must be attached to each copy of your voucher / invoice. Failure to submit all the required copies will result in rejection of the voucher / invoice as improper.
Desianated Acency Billina Office: Vouchers / invoices shall be submitted to the following address:
U.S. Nuclear Regulatory Commission Division of Contracts - T-7-I-2 Washington, DC 20555 HAND DELIVERY OF VOUCHERS / INVOICES IS DISCOURAGED AND WILL NOT EXPEDITE PROCESSING BY NRC. However, should you choose to deliver vouchers / invoices by hand, including delivery by any express mail services or special delivery services which use a courier or other person to deliver the voucher / invoice in person to the NRC, such vouchers / invoices must be addressed to the above Designated Agency Billing Office and will only be accepted at the following location:
U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike - Mail Room Rockville, MD 20852 HAND-CARRIED SUBMISSIONS WILL NOT BE ACCEPTED AT OTHER THAN THE ABOVE ADDRESS.
Note that the official receipt date for hand-delivered vouchers / invoices will be the date it is received by the official agency billing office in the Division of Contracts.
Acency Payment Office: Payment will continue to be made by the office designated in the contract in Block 12 of SF 26 or Block 25 of SF 33, whichever is applicable.
BILLING INSTRUCTIONS FOR COST REIMBURSEMENT TYPE CONTRACTS -
(Page 2 of 10)
Frecuency: The contractor shall submit claims for reimbursement once each month, unless otherwise authorized by the Contracting Officer.
Format: Claims should oc submitted in the format depicted on the attached sample form entitled " Voucher / Invoice for purchases and Services Other than Personal" (see Attachment 1). The sample format is provided for guidance only. The format is not required for submission of a voucher / invoice. Alternate formats are permissible provided all requirements of the billing instructions are addressed. The instructions for preparation and itemization of the voucher / invoice are included with the sample form.
Task Orderino contracts: If the contractor bills for more than one task order under a voucher / invoice, detailed cost information for each individual task order shall be submitted, together with a cumulative summary of all charges billed on the voucher / invoice. This includes all applicable cost elements discussed in paragraphs (a) through (n) of the attached instructions.
Fee Recovery Billinos: Pursuant to the provisions of 10 CFR Part 170 and 171 on license fees, the NRC must recover the cosc of work performed. Accordingly, the contractor must provide the total amount of funds billed during the period, fiscal year to date and the cumulative total for each task or task assignment by facility or report. The fee recovery billing reports shall be on a separate page, and shall be in the format provided in . The billing period for fee recovery costs should be from the first day of each calendar month to the last day of the same month Each separate fee billing report must be attached to the monthly invoice and cover the same period as the invoice.
Each report will contain a docket number or other unique identifier. The NRC will provide a unique identifier for all work performed. Costs should be reported as whole number to the nearest cent. For work that involves more than one facility at the same site, each facility should be listed separately and the costs should be split appropriately between the facilities.
Common costs, as defined below, shall be identified as a separate line item in the fee recovery billing report each month.
Common costs are those costs that are not licensee unique and associated with the performance of an overall program that benefit all similar licensees covered under that program or that are required to satisfactorily carry out the program. Coramon costs include costs associated with the following: preparatory or start-up efforts to interpret and reach agreement on methodology, approach, acceptance criteria, zegulatory position,
i I
-BILLING-INSTRUCTIONS FOR COST REIMBURSEMENT TYPE CONTRACTS -
(Page:3:of 10) 4 or_ technical reporting requirementsi-efforts-associated with the ,
-" lead planta concept-that might be involved ~during the.firstLone !
cnr two plant reviews; meetings and discussions involving the above efforts to provide orientation, background' knowledge _or guidance during the course of a program;.any technical effort applied-to a. docket or other unique identifier; and project management. Common costs must be reporting monthly for each-docket or unique identifier. Common costs must be-computed based '
on the proportion of direct costs incurred against each docket or -
unique identifier for the billing period.
Billina of-Cost After Exoiration of Contract: If costs are incurred during.the contract period and claimed after che contract has expired, the period during which chese costs were incurred must be cited..-To be considered a proper expiration tvoucher/ invoice, the contractor shall clearly mark it " EXPIRATION
-VOUCHER",or " EXPIRATION INVOICE". r Final vouchers / invoices shall be marked " FINAL VOUCHER" or " FINAL INVOICE".
Currenev: - Billings may be expressed in the currency normally used.by the contractor in maintaining-his accounting records; payments will be made in that currency. However, the U-.S. dollar equivalent for all vouchers / invoices paid under the contract may-not exceed the total U.S. dollars authorized in the contract.
Suoersessions- These instructions supersede any previous billing instructions.
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BILLING INSTRUCTIONS FOR COST REIMBURSEMENT TYPE CONTRACTS (Page 4 of 10) -
ATIACHMENT 1 INVOICE / VOUCHER FOR PURCHASES AND SERVICES OTHER THAN PERSONAL (SAMPLE FORMAT)
~~
Official Acency B' 11ino Office (a) Contract Number U.S. Nuclear Regu'atory Commission Division of Contracts MS: T7I2 Task Order No. (If Applicable)
Washington, DC 20555 0001 Pavee's Name and Address (b) Voucher / Invoice #
(c) Date of Voucher / Invoice Individual to Contact (d) Fixed Fee Regarding this Voucher Name:
Tel. No.:
(e) This voucher repre:;ents reimbursable costs for the billing period for the billing period from through .
Amount Billed Current Period Cumulative (f) Direct Costs (1) Di rect l abor * . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(2) Fringe benefits
( %. if computed as percentage)......
(3) Capitalized nonexpendable equioment ($50,000 or more -
see instructions)*......................
(4) Non capitalized equipment, materials, and supplies.................
(5) Premium pay (NRC approved overtime).......
(6) Consultants *..............................
(7) Travel *................................... .
(8) Subcontracts *.............................
(9) Other costs *..............................
Total Direct Costs (g) 10directCosts (A) Overhead % of (Indicate Base).........
(B) General & Administrative Expense
% of Cost Elements Nos. ....................
Total Direct & Indirect Costs (h) Fixed Fee (Cite Formula):
(1) Total Amount Billed.............................
(j) Adjustments.....................................
(k) Gi and Tot al s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- (Requires Supporting Information See Attached)
i BILLING INSTRUCTIONS FOR COST REIMBURSEMENT TYPE CONTRACTS (Page 5 of 10 (Cont.) ATTACHMENT 1--
SAMPLE SUPPORTING INFORMATION
- 1) Direct labor $2400 Labor Hours Cumulative Hrs. Billed Cateoory Billed Bite Total Senior Engineer I 100 $14,00 $1400 975 Engineer- 50 $10.00 $500 465 Computer Analyst 100 $5,00 ERQ 320
$2400
- 3) [gitalized Non Expendable Eauioment Prototype Spectrometer item number 1000 01 $60,000
- 4) Non capitalized Eauioment. Materials. and Sucolies
= $1100.00 10 Radon tubes 9 $110.00 6 Pairs Electrostatic gloves 9 $150.00 = $900.00
$2000,00
- 5) Premium Pay Walter Murphy 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 0 $10.00 Per Hour = $100 (This was approved by NRC in letter dated 3/6/95),
- 6) Consultants' Fee Dr. Carney 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B $100 = $100
- 7) Travel Start Date Destination Q21t1 3/1/89- Wash...DC $200 t
9 m
/
. . _ . _ _._ _ . _ . . _ _ _ _ _ _ . _ _ _ _ - . . . . _ _ _ . . ~ . _
P
- 1 BILLING INSTRUCTIONS FOR_-COST REIMBURSEMENT TYPE CONTRACTS (Page 6 of 10) -
' ATTACHMENT 1:(Cont.)
b_
h INSTRUCTIONS FOR PREPARING j
COST INFORMATION FOR NRC CONTRACT V0UCHERS/ INVOICES o
i Preparation-and Itemization of the Voucher / Invoice: In order to constitute a
) roper invoice, the contractor shall furnish all the information set forth
)elow.- These notes are keyed to the entries.'on the sample voucher / invoice.
Official Agency Billing Office: Address the original and 3 copies of the.
voucher / invoice, together with supporting documentation attached to each copy- ,
-to: U.S. Nuclear' Regulatory Commission, Division cf Contracts, MS: T7I2,
=
h Washington, DC 20555 0001.
Vouchers / invoices delivered by hand, including delivery by express mail or 1 special delivery services which use a courier or other person to deliver the Jyoucher/ invoice in person to the NRC, should be-addressed in accordance withL the foregoing and delivered to: - U. S. Nuclear Regulatory Commission. One White Flint North,11555 Rockville Pike Hail Room, Rockv1110, Maryland-
-20852. Hand delivered vouchers / invoices will not be accepted at other than the above address. Note, however, that the official receipt date for hand-delivered vouchers / invoices.will be the date it is received by the official
. . agency billing office in the Division of Contracts. .
Payee's Name and Address. Show the name of'the contractor as it ap) ears in
=the contract and its correct address. When an approved assignment 1as been ,
' made by the contractor, or a different payee or addressa has been designated.
insert the name and address of the payee. Indicate the name and telephone number of the individual responsible for answering any questions that the NRC may have regarding the invoice. The following guidance corresponds to the entries required on the sample form.
(a) Contract Number. Insert the NRC contract number.
Task Order Number, if applicable. Insert the task order number.
.(b); Voucher / invoice number. The appropriate sequential number of the
.- voucher / invoice, beginning with 001 should be designated. Contractors
, _ _ may also include an-individual . internal accounting number, if desired, m _in addition to the 3 digit-. sequential number.
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. +
J. '
._: - . . . . - . . .- - = - - - = - - - ..
BILLING INSTRUCTIONS FOR COST REIMBURSEHENT TYPE CONTRACTS (Page 7 of 10) -
ATTACHMENT 1 (Cont.)
(c) Date of Voucher / Invoice. Insert the date the voucher / invoice is prepared.
(d) Fixed Fee. Insert total fixed. fee. Include this information as it applies to individual task orders as well.
(e) Billing Period. Insert the beginning and ending dates (day, month, year) of the period during which costs were incurred and for which reimbursement is claimed.
(f) Direct Costs . Insert the amount billed for the following cost elements, adjustments, suspensions, and total amounts, for both the current billing period and for the cumulative period (from contract inception to end date of this billing period). -
(1) Direct Labor. This consists of salaries and wages paid (or accrued) for direct performance of the contract itemized as follows:
Labor Hrs. Cumulative Cateaor_v Billed Bits 121A1 lirs. Billed (2) Fringe Benefits. This represents fringe benefits applicable to direct labor and billed as a direct cost. Where a rate is used indicate the rate. Fringe benefits included in direct labor or in other indirect cost pools should not be identified here.
(3) Capitalized Non Expendable Equipment. List each item costing
$50,000 or more and having a life expectancy of more than one year. List only those items of equipment for which reimbursement is requested. For each s';ch item. list the following (as applicable): (a) thc item number for the specific piece of equbment liste l in ihe property schedule of the contract, or (b) the Contracting Officer's approval letter if the equipment is not covered by the property schedule, l
1
t BILLING INSTRUCTIONS FOR COST REIMBURSEMENT TYPE CONTRACTS (Page 8 of 10) -
ATTACHMENT 1 (Cont.)
(4) Non capitalized Equipment, Materials, and Su) plies. These are equipment other than that described in (3) a:ove, plus consumable materials, supplies. List by category. List items valued at $500 or more separately. Provide the item number for each piece of equipment valued at $500 or more.
(5) Premium Pay. This enumeration in excess of the basic hourly rate.
(Requires written approval of the Contracting Officer.)
(6) Consultants. The supporting information must include the name, hourly or daily rate of the consultant, and reference the NRC approval (if not specifically approved in the original contract).
(7) Travel. Total costs associated with each trip must be shown in the following format:
Start Date Destination (sitji From To From To $
(8) Subcontracts. Include separate detailed breakdown of all costs paid to apptoved subcontractors during the billing period.
(9) Other Costs. List all other direct costs by cost element and dollar amount separately.
(g) Indirect Costs (Overhead and General and Administrative Ex>ense). Cite the formula (rate and base) in effect in accordance with tie terms of the contract, during the time the costs were incurred a*.J for which reimbesement is claimed.
(h) Fixed Fee. If the contract provides for a fixed fee, it must be claimed as provided for by the contract. Cite the formula or method of computation. The contractor may bill for fixed fee only up to 85% of total fee.
(i) Total Amount Billed. Insert the total cmounts claimed for the current and cumulative periods.
-1 I
I BILLING INSTRUCTIONS FOR COST REIMBURSEMENT TYPE CONTRACTS (Page 9 of 10) .-
l ATTACHMENT 1 (Cont.) 1 (j) Adjustments. For cumulative amount, include outstanding suspensions. !
(k) Grand Totals. ;
Further. itemization of vouchers / invoices shall only be required for items having specific limitations set forth in the contract.
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BILLING INSTRUCTIONS FOR COST REIMBURSEHENT TYPE CONTRACTS (Page 10 of 10) .
ATTACHMENT 2 (Cont.)
FEE RECOVERY BILLING REPORT FIN:
Facility Name or Report
Title:
TXC or Inspection Report Number: ;
(or other unique identifier) :
Docket Number (if applicable): ,
Period Fiscal Year Total Cost Categories Period Amt. Cost Incurred To Date Costs Cumulative Costs ,
Labor ,
Materials Subcontractor /
Consultant Travel Other (specify)
Common Costs i Total Remarks: _;
'R:\ BILLING,396 t
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ATTA0f M 2 NUCLEAR REGULA10RY COMMIS$10N ACQUlbli!ON W LA110N l 2009.570 WRC organizational conflicts of interest.
52009.570-1 Scope of policy.
(a)
It is the policy of HRC to avoid, eliminate, or neutralize contractor organizational conflicts of interest. The NRC achieves this objective by requiring all prospective contractors to submit information describing relationships, if any, with organizations or persons (including those regulated by the NRC) which may give rise to actual or potential conflicts of interest in the eveht of contract award.
(b) Contractor conflict of interest determination ~s cannot be made automatically or routinely. The application of sound judgment on virtually a case-by-case basis is necessary if the policy is to be applied to satisfy the overall public Interest. It is not possible to prescribe in advance a -
arvr to identify and resolve
' specific method or set of criteria which would all of tha. contractor conflict of interest situations which might arise.
However, examples are provided in these regulationsHight to guide appitcation of the contractor, The ultimate test is as follows:
this policy guidance.if awarded the contract, be placed in a position where its judgment biased, or where it may have an unfair competitive advantage?
The conflict of interest rule contained in this subpart applies to (c) contractors and offerors only. Individuals or firms who have other
- relationships with the NRC (e.g., parties to a licensing proceeding) are not covered by this regulation. This rule does not apply to the acquisition of with other Government agencies, international organizati or foreign Governments. Separate procedures for avoiding conflicts of .
interest will be employed in these agreements, as appropriate.
I 12009.570-2 Definitions.
f As used in $2009.570:
Affiliates means business concerns which are affiliates of each oth when either directly or indirectly one concern or individual controls or has the power to control another, or when a third party controls or has the power
- to control both.
Contract means any contractual agreement or other arrangement with 'the NRC except as provided in (2009.570-1(c).
Contractor means any person, firm, unincorporated association, joint venture, co-sponsor, partnership, corporation, affiliates t,iereof, or their successors in interest, including their chief executives, directors, key personnel (identified in the contract), proposed consultants or subcontractors, which are a party to a contract with the NRC.
l Evaluation activities means any effort involving the appraisal of a technology, process, product, or policy.
association, joint venture, co-sponsor, partnership, co affiliates or successors in interest, including their chief executives, directors, Ley personnel, proposed consultants, or subcontractors, submitting a bid or proposal, solicited or unsolicited, to the NRC to obtain a contract.
Oraanizational conflicts of interest means that a relationship exists whereby a contractor or prospective contractor has pre (1)
May diminish its capacity to give impartial, technically sound, objective assistance and advice, or may otherwise result in a biased work product; or (2)
May result in its being given an unfair competitive advantage.
Potential conflict of int 1 tut means tW a factLal situation exists that suggests that an actual conflict of interest may arise fr proposed contraqt.
those situations that-Herit investigation before contract award to ascertain whether (1) award would give rise to an actual conflict; or Must be reported to the contracting officer for investigation if *
(2) they arise during contract performance.
Research means any scientific or technical work involving theoretical analysis, exploration, or experimentation. .
Subcontractor means any subcontractor of any tier who performs work under a contract with the NRC except subcontracts for supplies and subcontracts in amounts not exceeding the small purchase threshold.
Technical consultina and manauement sucoort services means i assistance to a componen* ol the NRC in the formulation or administralian of its programs, projects, or policies which normally require that the contractor be given access to proprietary information These or to information services typically that has include assistance in not bee made available to the public.
the preparation of program plans, preliminary designs, specifications, or statements of work.
52009,570-3 Criteria for recognizing contractor organizational conflicts of interest.
(a) General.
(1)
Two questions will be asked in determining whether actual or potential organizational conflicts of interest exist:
(i) Are there conflicting roles which might bias an offeror's or contractor's judgment in relation to its work for the NRC7
-,r-- - -,, - - . , - - ,,,vr
(11) Hay the offeror or contractur be given an unf air competitive advantage based on the performance of the untract?
NRC's ultimate determination that organizational conflicts (2) of interest exist will be made in Itght of common sense and good busine judgment based upon the relevant facts.
to prescribe in advance a specific method for avoiding all of the various situations or relationships that might involve potential organizational conflicts of interest, NRC personnel will pay particular attention to proposed contractual requirements that call for the rendering of advice, consultation or. evaluation activities, or similar activities that directly lay the groundwork for the NRC's decisions on regulatory activities, futureAny procurements, and research programs. licensee site will also be closely scrutini The following situations nr (b) Situations or relationshios.
relationships to, ,'ve rise to organizationa' conflicts of interest: t (1), The offeror or contractor shall disclose information, that may circumstances.
give rise to nrganizational conflicts of interest under the for the requirement, being performed, the period of performance, and the name and telephone number for a point of contact at the organization knowledgeab about the commercial contract.
Where the offeror or contractor provides advice and (f) recommendations to the NRC in the same technical area whe also providing consulting assistance to any organization regulated
(
' by the NRC.
Where the offeror or contractor provides advice to the (ii)
NRC on the same or similar matter on which it is also providing assistance to any organization regulated by the NRC.
(
(iii) Where the offeror or contractor evaluates its own products o,' s r.'ces, or has been substantially involved in the development or marketing of the products or services of another entity.
(iv) Where the award of a contract would result in placing the offeror or contractor in a conflicting role in which its judgment may be biased'in relation to its work for the NRC, or would result in an unfair competitive advantage for the offeror or contractor.
Where the offeror or contractor solicits or performs (v) work at an applicant or licensee site while performing work in the same technical area for the NRC at the same site.
The contracting officer may request specific information (2) from an offeror or contractor or may require special contract clauses such as provided in 52009.570-5(b) in the following circumstances:
l
[
t (i) Where the offeror ;r cte*tmtu ;.repares specifications that are to be used it, cug'.vtive procurements of products or services covered by Ine spM H mtions.
Where the offeror or contrattor prepares plans for specific (ii) approaches or methodologies that are to be incorporate ,
into competitive procurements using the aoproaches or methodologies.
(iii) Where the offeror or contractor is granted access to information not available to the public concerning NRC plans, ,
policies, or programs ti,at could form the basis for a later ;
procurement action, Where the offeror or contractor is grant-d access to (iv) proprietary information of its competitors.
Where the award of a contract might resulttin placing (v) the. offeror or contractor in a conflicting role in which its judgment may be biased in relation to its work for the NRC or ,
might result in an unfair competitive advantage for the offeror or >
contractor. '
The following examples are (c) Policy aoolication cuidance.
Illustrative only and are not intended to identify and resolve all contractor organizational conflict of interest situations.
Example. The ABC Corp., in response to a Request for (1) (i)
Proposal (RFP), proposes to undertake..certain analyses of aThe AB reactor component as called for in the RFP.
of several companies considered to be technically well qualified.
In response to the inquiry in the RFP, the ABC Corp. advises that it is currently performing siellar analyses for the reactor manufacturer.
CJidance. An NRC contract for that particular work (ii) nomally would not be awarded to the ABC Corp. because the company would be placed in a position in which its judgment could be biased in relationship to its work for the NRC. Because there are other well-qualified companies available, there would be no reason for considering a waiver of the policy.
Example. The ABC Corp., in response to an RFP, (2) (i) proposes to perform certain analyses of a reactor component tha is unique to one type of advanced reactor. As is the case with other technically qualified companies responding to the RFP, the ABC Corp. is performing various projects for several different utility clients.
None of the ABC Corp. projects have any relationship to the work called for in the RFP. Based on the NRC evaluation, the ABC Corp. is considered to be the best qualified company to perform the work outlined in the RFP.
An NRC contract normally could be awarded (11) Guidance.
to the ABC Corp. because no conflict of interest exists which e -e. -- w. ,. . - - ,-- - ,,9 .,.g--.- e.-- c.- ., m--.
l l could motivate bias with respect to the work. An appropriate i clause would be included in the contract to preclude the ABC Corp. i from subsequently contracting for work with the private sector j that could create a conflict during the performance of the NRC c contract. For example, ABC Corp. would be precluded from the l performance of similar work for the company developing the j advanced reactor mentioned in the example. !
i framole. The ABC Corp., in response to a competitive -
(3) (1)
RFP, submits a proposal to assist the NRC in revising NRC's 9uidance documents on the respiratory protection requirements of 10 CFR Part 20. A8C Corp. is the only fim determined to be technically acceptable. ABC Corp. has performed substantial work for regulated utilities in the past and is expccted to continue similar efforts in the future. The work has and will cover the writing, implementation, and administration of compliance
,' respiratory protection pr grams or nuclear power p1a s.
This situation would place the firm in a role. where (ii) Guidance.
its judgment could be biased in relationship to its work for the NRC. Because the nature of the required work is vitally important in terms of the NRC's responsibilities and no reasonable alternative exists, a waiver of the policy, in accordance with (2009.570-9 may be warranted. Any waiver must be fully documented in accordance with the waiver provisions of this policy with particular attention to the establishment of protective mechanisms to guard against bias. , ,
Example. The ABC Corp, submits a proposal for a new (4) (1) system to evaluate a specific reactor component's performance for a
the purpose of developing standards that are important to the NRC program. The ABC Corp has advised the NRC that it intends to seli the new system to industry once its practicability has been demonstrated. Other companies in this business are using older
-systems for evaluation of the specific reactor component.
(11) Guidance. A contract could be awarded to the ABC Corp. if the contract stipulates that no information produced under the contract will be used in the' contractor's private activities unless this information has-been reported to the NRC.
Data on how the reactor component performs, which is reported to the NRC-by contractors, will normally be disseminated by the NRC to others to preclude an unfair competitive advantage. When the NRC furnishes information about the reactor component to the con-tractor for the performance of contracted work, the-information may not be used in.the contractor's- private activities unless the information is generally available to others. - rurther, the contract will-stipulate that the contractor will inform the NRC contracting officer of- all situations- in which the information,-
. developed about the perfomance of the reactor component.under the-contract, is proposed to be'used. i
.(5) '(i)1 Examnle. The ABC Corp., in response to a RFP, proposes to assemble-a map showing cartain seismological features n.._.
1 of the Appalachian fold delt. It accoroante with the representation in the RTP and $2009.570-3(Mt1)(1 for several utilities in the eastern United States, but none of the sites are within the geographic area contemplated by the NRC study.
The contracting officer would normally conclude (ii C)Guidance. at award of a contract would not place ABC Corp in a Section conflicting role where its judgment sight be biased. ,
2052.209-73(c) Work for Others, would preclude ABC Corp. from accepting work which could create a conflict of interest during the term of the NRC contract.
(6) (1) Examole. AD Division of ABC Corp., in response to a RFP. submits a proposal to asti".t the NRC in the safety and environmentalreviewofapplicationsforlicensesforipe construction, operation, and decommissioning of fuel cycle
- facilities. ABC Corp.The is divided into two separate and distinct BC Division performs the same or divisions, AD and BC. The BC Division is currently pro-similar services for industry.
viding the same or similar services required under the NRC's contract for an applicant or licensee.
Guidance An NRC contract for that particular work (ii) would not be awarded to the ABC Corp. The AD Division could be
- placed in a position to pass judgment on work performed Further, the by the BC Division, which could bias its work for NRC.
Conflict of Interest provisions apply to ABC Corp. and not to If.no separate or distinct divisions within the company.
reasonable alternative exists, a waiver of the policy could be sought in accordance with (2009.570-9.
EKAMPLE The ABC Corp. completes an analysis for NRC of steam 7(1) Three generator tube leaks at one of a utility's six sites. months same analysis at another of its sites.
(ii) GUIDANCE 52052.290-73(c)(3) would prohibit the contractor from beginning this work for the utility until one year after completion of the NRC work at the first site.
EXAMPLE ABC Corp is assisting NRC in a major on-site 8(1) analysis of a utility's redesign of the common areas between its twin reactors. The contract -
is for two years with an estimated Near the completion of the NRC work, ABC value of $5 million.
Corp. requests authority to solicit for a $100K contract with ABC the same utility to transport spent fuel to a disposal site.
Corp. is performing-no other work for the utility.
(ii) GUIDANCE The Contracting Officer, would allow the contractor to proceed with the solicitation because A) it is not
.in the same technical area as the NRC work and B) the potential for technical bias by the contractor because of financial ties to
I the utility is slight due to the relative value of the two t contracts.
9(i) EXAMPLE The ABC Corp. is constructing a turbine building and installing new turbines at a reactor site. The contract with the utility is for five years and has a total value of $100 million.
ABC Corp. has responded to an NRC Request for Proposal requiring a the contractor to participate in a major team inspection unrelated to the turbine work at the same site. The estimated value of the '
contract is $75K.
(ii) GUIDANCE An NRC contract would not normally be awarded .
to ABC Corp. since these factors create the. potential for :
financial loyalty to the utility that may bias th: technical judgment of the contractor.
(d) Other considerations. ,
- (1)- The fact that the NRC can identify and later avoid, :
eliminate, or neutralize any potential organizational conflicts arising frorr.
the performance of a contract is not relevant to a determination of the existence of conflicts prior to the award of a contract.
(2) It is not relevant that the contractor has the professional reputation of being able to resist temptations which arise from organizational
! conflicts of interest, nr that a follow-on procurement is not involved, or that a contract is awarded on a competitive or a sole source basis. . -
~
l 92009.570-4 Representation.
(a) The following procedures are designed to assist the NRC i contracting officer in determining whether situations or relationships exist which may constitute organizational conflicts of interest with respect to a ,
particular offeror or contractor. The procedures apply to small purchases meeting the criteria d.ated in the following paragraph (b) of this sec+1on.
(b) The organizational conflicts of interest representation provision at $2052.209-72 must be included in solicitations and unsolicited proposals, (including those for task orderrand modifications for new work) for:
(1) Evaluation services or activities; (2) Technical consulting and management support services; (3) Research; and (4)-_ Other contractual situations wht-e special organizational conflicts of inttrest- provisions are noted in the solicitation and would be included in the resulting contract. This representation requirement also l
l applies to all modifications for additional effort under the contract except ,
L those issued under the " Changes" clause. Where, however, a statement of the type required-by the organizational conflicts of: interest representation provisions has previously been submitted with regard to the contract being modtfled,;only an updating of-the statoment is required. l H . -
(c) The offeror may. Decauw o! :c Mi sv.pattw al orgarizat tonal conflicts of interest, propose to en)ude sta:iin. im:x of work zontained in a RTP unless the RTP specifically prohibits ue uclusio9 Any such proposed exclusion by an offeror will be considered b) the NRC it, the evalustion of proposals. If the NRC considers the proposed enluded work to be an essential or integral part of the required work and its exclusion would be to the detrimer.t of the competitive posture of the other offerors, the NRC shall reject the proposal as unacceptable.
(d) The offeror's failure to execute the representation required by paragraph (b) of this section with respect to an invitation for bids is considered to be a minor informality. The offeror will be permitted to correct the omission. ,
(2009.570-5 Contract clauses.
(a) G T ral contract cl m q. All .ontracts and small purchases of the types set forth in $2009.570-4(b) must include the clause entitlecT,t "Contrar. tor Organizational Conflicts of Interest," set forth in 62052.209-73.
(b) Other special contract clauses, if it is determined from the nature of the proposed contract that an organizational conflict of interest exists, the contracting officer may determine that the conflict can be avoided, or, after obtaining a waiver in accordance with $2009.570-9, neutralized through the use of an appropriate special contract clause, if appropriate, the offeror may negotiate the terms and conditions of these clauses, including the extent and time period of tny restriction. These -
- clauses include but are not limited to:
(1) Hardware exclu:, ion clauses which ' prohibit the acceptance of production contracts following a related non-production contract previously performed by the contractor; (2) Software exclusion clauses; (3) Clauses 'Aich require the contractor (and certain of its key personnel) to avoid certain organizational conflicts of interest; and (4) Clauses which provide for protection of confidential data and guard against its unauthorized use.
52009.570-6 Evaluation, findings, and contract award.
The contracting officer shall evaluate all relevant facts submitted by an offeror and other relevant information. After evaluating this information against the criteria of $2009.570-3, the contracting officer shall make a finding of whether organizational conflicts of interest exist with respect to a particular offeror. If it has been determined that real or potential conflicts of interest exist, the contracting officer shall:
(a) Disqualify the offeror from award; (b) Avoid or eliminate'such conflicts by appropriate measures; or ,
i i
Award the contract under the waiver provision of $2009.570-9.
(c) l 92009.570-7 Conflicts identified after award.
if potential organizational conflicts of interest are identified af ter award with respect to a particular contractor, and the contracting officer .
determines that conflicts do exist and that it would not be in the best interest of the Government to terminate the contract, as provided in the l
clauses required by $2009.570-5, the contracting officer shall take every reasonable action to avoid, eliminate, or, after obtaining a waiver in accordance with 12009.570-9, neutralize the effects of the identified confilet. ,
62009.570-8 Subcontracts.
The contracting officer shall require offerors and contractors to submit a reptw enta;.,.1 statement from all subct 'racterr (other than a suDr'y i subcontractor) and consultants performing services in excess of $19,000 in accorda,nce with,62009.570-4(b). The contracting officer shall require the -
contractor to include contract clauses in accordance with 62009.570-5 in consultant agreements or subcontracts involving performance of work under a prime contract.
f2009.570-9 Waiver. '
The contracting officer determines the need to seek a waiver for (a) specific office director contract awards, and legal with the advice and concurrence of the prog counsel.
Executive, and after consultation with legal counsel, the Executive Director for Operations may waive the policy in specific cases if he determines that it ,
is in the best interest of the United States to do so.
(b)
Waiver action is strictly limited to those situations in which:
(1)
The work to be performed under contract is vital to the NRC program.
The work cannot be satisfactorily performed except by a (2) contractor whose interests give rise to a question of conflict of interest.
(3)- Contractual and/or technical review and surveillance method can be employed by the NRC to neutralize the conflict.
.(c) For any waivers, the justification and approval documents must be placed in the NRC Public Document Room, 2120 L Street, NW. (Lower Level),
Washington, DC.
(2009.570-10 Remedies.
In addition to other remedies permitted by law or contract for a breach
-of the restrictions in this subpart or for any intentional misrepresentation or intentional nondisclosure of any relevant interest required to be provided for this section, the NRC may debar-the contractor from subsequent NRC contracts.
~ __ _ _ . _ .
1 i ATTADIUiT 3
.i 4
d l Unclassified Contractor and :
Grantee Publications in the NUREG Series I
) '
A i: .;: ~; ~ :. :: .- u:: ~:~ , , 7 ;;.::' : ::: : : :;7 :2 ~ ~. . :ua==~; ,:nz:::=r;;;;;::= p:
l n
J G
l Directive
\
3.8 I
d
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l l
L e'-4 3 % ep. Y a e -h k p s-4' ,o ;, ; ,,
,&, 2
- f. ,
Volurne 3, Part 1 - Publications, Mail, Ed Information Disclosure Unclassified Contractor and Grantee Publications in the NUREG Series !
Directive 3.8 1
Contents Policy................................................................. 1 Obj ect i ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Organizational Responsibilities and Delegations of Authority . . . . . . . . . . . . 2 Executive Director for Operations (EDO) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 -
Deputy Executive Director for Nuclear Reactor Regulation. Regional !
Operations and Research (DEDR) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Support (DEDS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 O ffi ce Di r e ct o rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Director, Office of Adtninistration (ADM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Director, Division of Freedom of Information and Pu'olications Se ni ces. (D FIPS), ADM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Director, Division of Contracts (DC), ADM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Ap pli ca b ili ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Empl oye es . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 O th er Publi cations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 H a n d boo k . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Referen ces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
- Approved: June 17,1991 ,,,
- (Revised:_ July 9,1995) til
't U. S. Nucle:r Regul:tary Ccmmission
/~ '
i Volume: 3 Information hianagement S /j Part: 1 Publications, Mail, and Information
....+, Disclosure ADM Unclassified Contractor and Grantee Publications in the NUREG Series Directive 3.8 Folic (3.8-01 U.S. Nuclear Regulatory Commission policy requires that the following publications published by NRC adhere to the documentation and production requirements, standards, and practices specified in this directive and handbook: (1) unclassified NRC contractor, consultant, or grantee fonnal reports, books, and intemational agreement reports in the NUREG/CR (contractor reports), NU REG /G R (grant reports), and NURE G /lA (international agreement reports) series:(2) reports and books by contractors of the U.S. Department of EnerEy (DOE); and (3) publications prepared for NRC under memoranda of understanding and interagency agreements.
Objectives (3.8-02) l
. To ensure the production and dissemination of information and publications as required by the Energy Reorganization Act of 1974 and the Freedom ofInformation Act. (a)
. To ensure tecimical staff and management reviews of formal l reports and books before publication. (b)
- To ensure that national security, patent rights, copyrights, proprietary rights, and rights in other sensitive unclassified mformation, including those specified in interagency and i international agreements and memoranda of understanding, are not compromised by the release or publication of information by NRC.(c)
Approved: June 17,1991 (Revised: July 9,1995) 1
Volume 3, Part 1 - Publications, Mail, end Information Disclosure Unclassified Contractor cud Grantee Publications in the NUREG Series Directive 3.8 Objectives .-
(3.8-02) (continued) e To ensure that all unclassified NRC contractor or grantee publications in the NUREG series carry the registered Government identification NUREO/CR-0000, NUREG/
GR-0000, or NUREG/lA-0000, with the exception of some publications prepared by grantees, and indicate the availability of
, source material used in these publications. (d)
. To ensure that NRC-sponsored book manuscripts receive proper peer review from experts within and outside NRC. (c) e To provide uniform procedures for publishing formal reports and books prepared by NRC contractors or grantees. (f)
Organizational Responsibilities and Dele ations of Authority (3.8-03 Executive Director for Operations (EDO)
(031)
Delegates to the Deputy Executive Directors for Operation decisionmaking authority for the resolution of differences between NRC and contractors about the contents of publicatians, about granting contractors permission to publish NRC-sponsored information in the open literature, and about permitting contractors to issue press or other media releases concerning NRC-sponsored information.
Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research (DEDR)
(032)
As delegated from the EDO, makes final decisions in the following areas for the Office of Nuclear Reactor Regulation, the Office of Nuclear Regulatory Research, and regional offices:
e When an office director refuses to publish an NRC-sponsored document because of irreconcilable differences between himself or herself and the author about the contents of the document. (a)
Approved: June 17,1991 2 (Revised: July 9,1995)
Volume 3, Part 1 - Publications, Mail, and Information Disclosure Unclassified Contractor and Grantee Publications in the NUREG Series Directive 3.8 Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research (DEDR)
(032)(continued) e When an ofSce director refuses to permit a contractor's principal investigator to publish NRC-sponsored infonnation in the open literature. (b) e When an office director refuses to permit a contractor to issue a press or other media release about an NRC-sponsored publication. (c)
Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Support (DEDS)
(033)
As delegated from the EDO, makes final decisions in the following areas for the offices reporting to the DEDS:
e When an office director refuses to publish an NRC-sponsored -
document because of irreconcilable differences between himself or herself and the author about the contents of the document. (a) e When an office director refuses to permit a contractor's principal investigator to publish NRC-sponsored information in the open literature. (b) e When an office director refuses to permit a contractor to issue a press or other media release about an NRC-sponsored publication. (c)
Office Directors (034)
. Ensure that publications will be reviewed in draft for acceptability before final printing and distribution by determining that they are consistent with agency policy, management decisions, and that they raise no signiScant legal issues. (a)
. Ensure that statements of work on contracts
- include a requirement that contractors comply with this directive and handbook and with Government Printing and Binding -
Regulations. (b) geog in sh co.iesi enmeip== ne sandard order for oos work-(Nac rann 173), inter.seney and inier tional.gr.e.enii, 1
Approved: June 17,1991 (Revised: July 9,1995) 3
. ~ - . . _ - .- _._ _ . _ - . . . _ . . _ = = _ _. __ _ - .
Volume 3, Part 1 - Publications, hiall, and Inf;rmati:n Disclosure !
Unclassified Contractor and Gran'ee Publications in the NUREG S: ries .
Directive 3.8 ___
Office Directors (034)(continued)
- Sign, or delegate signature authoritv for, the NRC Form 426A,
" Release to Publish UnclassiGed NRC Contractor, Consultant, or Conference Proceedings Reports"(Exhibit 1 of Handbook 3.8),
and for memoranda requesting reprints of contractor publications. (c)
Director, Office of Administration (ADhi)
(035)
As delegated from the DEDS, administers NRC's programs and policies for publishing unclassiGed contractor and grantee reports and books in the NUREG series.
Director, Division of Freedom of Information and Publications Services,(DFIPS), ADh1 (036) e Develops and administers, as delegated from the Director, ADM, NRC's program and policies for publishing unclassi6ed contractor, consultant, and grantee formal reports, books, and international agreement reports in the NUREGICR, NUREG/GR, and NUREG/1A series. (a)
. Applies the policy, procedures, standards, and guides for the documentation, formatting, composition, printing, and dissemination of NRC-sponsored publications in the NUREG series consistent with the mission of the agency and in accordance with the requirements of the Government Printing and Binding Regulations issued by the Joint Committee on Printing, U.S.
Congress. (b) e Develops and administers the central agency publication numbering system for identifying, producing, and retrieving unclassi6ed NRC-sponsored publications in the NUREG series. (c)
Director, Division of Contracts (DC), ADh1 (037) linsures that those requests for proposals, imitations for bids, and grant proposals, and the ensuing contracts and grants that require Approved: June 17,1991 4 (Revised: July 9,1995)
Yolume 3, Part 1 - Publications, Mail, and Inf:rmation Discl:sure Unclassified Centractor cnd Grantee Publicati:ns in the NUREG S ri:s Directive 3.8 Director, Division of Contracts (DC), ADM (037)(continued) publications as deliverables include provisions requiring that contractors comply with this directive and handbook and'with Government Printing and Binding Regulations.
Applicability (3.8-04) ,
Employees (041)
All NRC employees shall follow the policy and guidance specified in this directive and handbook.
Other Publications (042)
The provisions of this directive and nandbook do not apply to NRC staff publications in the NUREG series. NRC docket material, or documents created by NRC boards, panels, advisory committees, or offices that report to the Commission.
Handbook (3.8-05)
Handbook 3.8 gives detailed guidelines for preparing unclassified
- contractor and grantee publications in the NUREG series.
1 References (3.8-06)
A Manualof Style, University of Chicago Press.
Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.),
" Copyrights," Title 17 United States Code.
i l " Cost Principles for State and 1.ocal Governments," OMB Circular A-87 Office of Management and Budget, January 1981.
I Energy Reorganization Act of 1974, as amended (42 U.S.C. 5801 l et seq.).
1 i
Approved: June 17,1991 (Revised: July 9,1995) 5
)
t Volume 3, Part 1 - Publications, Mail, and Information Disclosure Unclassified Contractor and Grantee Publications in the NUREG Series Directive 3.8 l l
l References .
l (3.8-06) (continued) l l
" Federal Grant and Cooperative Agreement Act," Pub. L 95-224, February 3,1978. ]
" Federal Regulation Requirements," Executive Order 12291, February 17,1981 (5 U.S.C. 5601 Note).
Freedom of Information Act (5 U.S.C. 552).
Government Printing and Binding Regulations, Pub. L 101-9, February 1990.
" Grants and Agreements With Institutions of Higher Education, Hospitals, and Other NonproSt Organizations," OMB Circular A-110, Office of Management and Budget, July 1976.
Memorandum of Understanding Between the Department of Energy '
and the U.S. Nuclear Regulatory Commission, February 24,1978.
Memorandum of Agreement Between the Institute of Nuclear Power Operations and the U.S. Nuclear Regulatory Commission, dated September 17,1993.
NRC Management Ditective 3.9, "NRC Staff and Contractor Speeches, Papers, and Journal Articles on Regulatory and Technical Subjects."
-- 3.11 " Conferences and Conference Proceedings."
- 12.2, NRC Classified Information Security Program."
12.6,"NRC Sensitim Unclassified hbrmation Security Program."
NUREG-0650, Revision 1, " Publishing Documents in the NUREG Series," November 1990.
NUREG/BR-0075, Revision 2, "NRC Field Policy Manual," Field Policy Manual No. 9, dated March 22,1993.
"Public Printing and Documents," Title 44. Chapter 3. Government Printing Office, United Stafa Code.
U.S. Govemment Printing Office Style Manual,1984.
Approved: June 17,1991 6
(Revised: July 9,1995)
l l
i
- I Unclassified Contractor and 1
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Volume 3, Part 1 - Publications, Mail, and Information Disclosure Unclassified Contractor and Grantee Publications in the NUREG Ser13s Handbook 3.8 Parts 1 - Vi Contents Part I I n t rod u ct i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I Part II Preparing Publication Requirements for Statements of Work for Co n t ra ct s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Specifying Publication Requirements (A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Publishing Formal Reports (B) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Publishing Unclassified Information in the Open Uterature and Presenting Pa p e r s ( C) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Reports Containing Sensitive Unclassified and Classified Information (D) . . . . . . . 6 Conference and Workshop Proceedings (E) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Distnbution of Reports to Contractors (F) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Coordmatmg Contractor Press or Other Media Releases of Information (G) . . . . 7 Part III Draft and Final NUREG Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Identification Information (A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 N U RE G Number (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
- Au th o rs' Nam es (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Organizational Identification (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Presious Reports in Series (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Report Dates (5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Repon Organization and Components (B) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Pre-Publication Reviews (C) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Pate nt Resiew (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Se curity Review (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Copyright Review (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Color Printing (D) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 M i crofi ch e (E) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Discl ai m e rs (F) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Approved
- June 17,1991.
-(Revised: July 9,1995) iii
Volume 3, Part 1 - Publications, Mail, and Information Disclosure Unclassified Contractor and Grantee Publications in the NUREG Series Handbook 3.8 Parts I - VI t
Contents (continued)
Part III (continued)
Availability Information (G) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Re ference Material (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Re p orts (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Forms (H).......................................................... 14 Bibliographic Data Sheet (NRC Form 335) (1) . . . . . . . . . . . . . . . . . . . . . . . . . 14 Release To Publish UnclassiBed NRC Contractor. Consultant, or Conference Proceedings Repons (NRC Form 426A) (2) . . . . . . . . . . . . . . 14 Printing and Reprinting (I) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Distri bu ti on (J) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Part IV International Agreement Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Backgroend and Rationale (A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Identification Information (B) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Cover and Title Page (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 NRC Report Number (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Previous Reports in Series (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Report Organization and Components (C) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Availability Information (D) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 References and Bibliographies (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Repons (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Discl aim e r (E) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Po nns (F) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Bibliographic Data Sheet (NRC Fonn 335) (1) . . . . . . . . . . . . . . . . . . . . . . . . . 19 Release to Publish Unclassified NRC Contractor, Consultant, or Conference Proceedings Repons (NRC Form 426A) (2) . . . . . . . . . . . . . . 19 Classified or Sensitive Unclassi6ed Information (G) . . . . . . . . . . . . . . . . . . . . . . . . . 19 Approved: June 17,1991-
- iv (Revised
- July 9,1995)
Volume 3, Part 1 - Pchlications, M:ll, and Infortnation Disclosure Unclassified Contractor cnd Grantee Pchlications in the NUREG Series !
Handbook 3.8 Parts 1 - VI Contents (continued)
Part V B oo ks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 G e n e ra l ( A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 D e fi ni ti o n (B) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Fo rm a t ( C) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 NRC Document Number (D) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Availability of Reference Materials (E) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Re vi ews ( F) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Pe e r ( 1 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Copyrigh t (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 S e curi ty (3 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Pa t e n t (4 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Publishing Authorization Form (G) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Discl ai m ers ( H ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 ,
Pri n ti ng (I) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Distribution and Sales (J) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Part VI G ra n t P ublica t ion s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Background and Rationale (A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Publication of Results (B) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Publication by NRC (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Publication by a Grantee (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Publication by a Grantee in the Open Literature (3) . . . . . . . . . . . . . . . . . . . . . 25 Reprints of Open Literature Publications (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Identi6 cation Information (C) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 L
Pr e-Publication Reviews (D) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 1
l:
L G l o s s a ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Approved: June 17.1991 (Revised: July 9,1995) v
Volume 3, Part 1 - Publications, Mail, and Information Disclosure Unclassified Contractor and Grantee Publications in the NUREG Series liandbook 3.8 Parts I - VI Contents (continued)
Exhibits
- 1. NRC Form 426A," Release to Publish Unclassified NRC Contractor, Consultant, or Conference Proceedings Reports" . . . . . . . . . . . . . . . . . . . . . . . . 32
- 2. NRC Fonn 335, " Bibliographic Data Sheet" . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
- 3. Microfiche Shee t Sample . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 i
Approved: June 17,1991 vt (Revised: July 9,1995)
V;lume 3, Part 1 - Pubilcations, Mail, and Inf:rmation Disclosure Unclassified Contractor and Grantee Publications in the NUREG Series Handbook 3.8 Part I Part I
, Introduction This handbook specifies the procedures that the Nuclear Regulatory Commission (NRC) contractors and grantees need to follow when preparing the following publications for the NRC: (A) e Final NUREG reports (1) e Interna:ional agreement reports (2) e Books (3) e Grant publications (4)
The handbook is divided into six major parts and includes a glossary and exhibits. Part II provides general information for staff consideration in preparing statements ofwork. Parts III,IV, V, and VI provide publishing guidelines specific to, respectively, contractor reports, intemational agreenient reports, books, and grantee publications. (B)
Contractor meam a private contractor, consultant, expert, another State or Federal a ;ency working under an interagency agreement. or a Department of I nergy (DOE) facility or subcontractor, such as a national laborato .y, working under the DOE /NRC Memorandum of Understanding o' February 24,1973, and any subcontractors of these organizations. (C)
This directive and handbook, as well as a copy of " Publishing Documents in the NUREG Series"(NUREG-0650, Revision 1), must be included or referenced in all contracts, interagency and international agreements, and grants for which the publications previously listed are contract deliverables or grant obligations. In addition to the guidelines specific to each type of publication that appear in subsequent parts of this handbook, all statements of work must contain the applicable guidelines outlined in Part II. (D) 4 Approved: June 17,1991 (Revised: July 9,1995) 1
Volume 3, Part 1 - Publications, Mail, and Inf rmati:n Disclosure Unclassified Contracto' and Grantee Publications in the NUREG Series Handbook 3.8 Part II _
Part II Prep'aring Publication Requirements for Statements of Work for Contracts Specifying Publication Requirements (A)
List and describe the type of technical repons required from uch project, task, or subtask, as applicable, State when, how many, and to whom the reports should be submitted and the scope of infonnation they should contain. These reports may be unclassified, sensitive unclassified, or classified. For guidelines and requirements covering sensitive unclassified and classified publications, refer to Management Directive (MD) 12.2, "NRC Classified Information Security Program," and MD 12.6, "NRC Sensitive Unclassified Information Security Program."(1)
This directive and handbook pertain to publications that *.vil' oe issued in the NUREG/CR, NUREG/IA, and NUREG/GR series. (2)
Publishing Formal Reports (s)
NUREG series repons will be printed and distributeo by NRC from camera-ready copy submitted by the contractor to the Publications Bran:h, Mailstop T-6 E7, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. The camera-ready copy is to be prepared in accordance with the provisions of this handbook.
Recommended guidelines for the organization and format of formal repons are speci5ed in " Publishing Documents in the NUREG Series" (NUREG-0650, Revision 1). (1)
When the repon contains sensitive unclassified or classified information, the contractor must comply with MD 12.2. (2)
Approved: June 17,1991 2 (Revised: July 9,1995)
V:lume 3, Part 1 - Publicatica.i, Mail, and Inf rmr.ti:n Discl::sure Unclassified Ccntract:r cnd Grcntee Publicati ns in the NUREG S: ries Handbook 3.8 Part U Publishing Formal Reports (s)(continued)
If a draft is desired before completing a final report, specify in the statement of work (SOD the due date for delivering the Enal camera-ready copy after eceiving comments from hPC staff or participants (if applicable) on the draft. State that all draft material be submitted to the cognizant NRC contact. (3)
When the contractor is to submit drrft material for comment before preparing the final repon, state that the contractor will be asked to make changes if there are comments from NRC staff or panicipants. If agreement on the changes is reached, the NRC contact will authorize the contractor to prepare the final copy and submit it to the NRC contact ifit is a letter repon or input to a Safety Evalwion Report or an Emironmental Statement, or to the Director, Division of Freedom of Information and Publications Services (DFIPS) if it is a camera-ready copy for printing and distribution. This procedure will ensure proper publication, handling, distribution and, among other things, preclude funher changes that might nullify the agreement. (4)
If special caveats were agreed to between the contractor and the NRC contact, the caveats should accompany the NRC Form 426A (Exhibit 1) for approval when it is sent to the NRC contact. A copy of special caveats should also accompany the camera-ready copy sent to DFIPS. (5)
If agreement on changes to a formal technical report to be issued in the l NUREG/CR series is not reached, the NRC contact may request the contractor to prepare the camera-ready copy with, in addition to the standard disclaimer required on all contractor formal repons (see Section (F), Part III of this handbook), any caveats deemed necessary to cover NRC objections. These caveats may range from 'The views expressed in this report are not necessarily those of the U.S. Nuclear Regulatory Commission" to the addition of a preface setting fonh the NRC opinion or footnotes at appropriate locations within the text. (6)
If NRC objections cannot be covered in this manner, NRC can refuse to publish the repon. In the case of DOE / national laboratory reports, the DOE Operations Office Manager responsible fo: the laboratory should be informed by the NRC office director or regional administrator cf the decision and the reasons therefor. A copy of the decision should be sent to the laboratory director. In the case of another Federal agency, a State, or a private contractor, the person who entered into the contract should similarly be informed by the Approved: June 17,1991 (Revised: July 9,1995) 3
V:lume 3, Pcrt 1 - Publications, htil, cnd Inf rmation Disclosure Unctissified 0:ntrcct:r cnd Grcntee Publications in the NUREG Seri:s Handbook 3.8 Part II Publishing Formal Reports (n)(continued)
NRC contracting off ar. The contractor is then free to publish the report without identifjing NRC as the funding sponsor of the report and without the NPC discicimer. Decisions by the office director or designee may bo appealed to the appropriate Deputy Executive Director for Oprrations. (7)
Publishing Unclassified Information in the Oper) Literature and Presenting Papers (C)
Specify whether the contractor's principal investigator is permitted to publish in the open literature instead of submitting a final report and/or to present papers at public or association meetings during the course of the work. If this arrangement is authorized, add the following statement to the SOW:(1) m-wevenm-m- wnwn - w ,nm rThepnne,spalutvestigatormaypublishtheitsultsufthisworkin!
the open literatniti'in'stEdd of submittingirmal reporti oEnisyj fp~resentipaperslit3publici oF associations mestingsist(inthrimi lst@_6fthshPBMGFMC
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t . _. 3 aTm %w -a,..
If the NRC contact wants to review the papel or journal article before presentation or submission for publication, so state in the SOW, as follows:(2)
-evemm-~wmwwmmwg r~mper investigatormaypublishtbt results ofthisworkin!
[Thepnneapal lthe opentliteintureinsteifefAnmittinkifinal[ rep (hidrhisy!fp
}stagesif ths worleifilkartisleee'iisipeihis tAsa reviewed by efiE iNRC costicEin dFift formiEndtagredmint lias seen'resichsd'oijn itis s ten k yi2 H h Nn M iE b M A W M G 4 d If agreement is not reached, NRC may also require that the paper include in addition to the standard statement "Wo'.k wpported by the U.S. Nuclear Regulatory Commission," any caveats deemed necessary to cover NRC objections. If NRC objections cannot be covered in this manner, NRC may refuse to authorize publication in the open literature and/or presentation of papers. (3)
In the latter case, NRC willinfonn the contractor of the decision, as previously stated. The contractor is then free to publish without identifying NRC as the 5.mding sponsor of the information. Decisions by office directors or designees may be appealed to the appropriate NRC Deputy Executive Director for Operations. (4)
I Approved: June 17,1991 4 (Revised: July 9,1995)
V:lume 3, Part 1 - Publications, Mail, and Inf:rmati:n Discl:sure l Unclassified C:ntract:r and Grantee Publicati:ns in the NUREG Seri:s t
Handbook 3.8 Part H Publishing Unclassified Information in '
the Open Literature awl Presenting Papers (C)(continued)
If the contrac*or proposes to publish in the open literature or present the information at meetings in addition to submitting the required technical reports, approval of the proposed article or presentation should be obtained from NRC. NRC shall approve the material as
, submitted, approve it subject to NRC-suggested revisions, or disapprove it. In any event, NRC may disapprove or delay presentation of papers on information that is subject to the Commission's approval that has not been ritled upon or that has been disapproved. (5)
If the contractor requests permission to publish in the open literature even though the contract does not explicitly provide for this type of publication, the contract can be modined to provide for such presentations. (6)
When the contractor submit:; journal articles for publication, each must be accompanied by the following statement: (7)
[theU.SfCE2iitsadeeC 5tisettNo.OQAecolidingly,'ths
[U.S.ichCEt&lusisind6MelusiMiroyaltilfriellisenkne Subush EnpiodaMis $sblistied fenn'6f this'iosiriliition, oE iaUiddoikeritse_Mfi.dU.s!Gover_nm_ent"p_urp_oies_Rh w -m - , a C_s All published papers and articles must include the following disclaimer:(8)
~Thisiri wnnwnnnemmmm-wwmm or
$~ p~ iwasprepared'astan WNMM account dNeittiesthsUnisd 1ofwontspes==M by IISi_AieRG_ov_enumenOnohamiy!
a . c- ~~ m ~w agency thereo_rd..n.
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eifakydtheih hcassumes em panydegaltliabilityn w r ~ ~s ordresponsibilithforsa tapparatus rodecthergprocess~t dasclosedv.jm -
thispreport, tor; drepresedis;#3mm12siEliBik trjssuch thisd partyfaildis ^
ilirinssisiiiisad'risinNviessexpressedin thisNperbehol pescessarily thesfer tlkUMNislese R@%Comenions alu m saleAM da n c m lA F ' %Ahlt - wmtae
'For DOE work orden, the appropriate job code number h appbcable.
Approved: June 17,1991 (Revised: July 9,1995) l' 5
Volume 3, Part 1 - Publications, Mail, and Inf:rmati:n Disclosure Unclassified C:ntractor and Grantee Publicati:ns in the NUREG S: ries Handbook 3.8 Part II Publishing Unclassified Information in the Open Literature and Presenting Papers (C)(continued)
If the contractor is requested by the journal or other publisher to transfer the copyright, the contract author will respond to the journal or other publisher in writing in accord with the sample letter shown as follows:(9)
, -- m.
RDear(Copyright w b. ::c ,~c l Holder's m w e mmpnge mwaName):ea&
mL m m Mi mut m% MitM
- WM + ~y a MYNiently!WeNed5M._g$5tIfdry s.igsisirej!assignIns.
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copinghtland repubh.eation rights {m.,the!sutimittedi article)
[(title)dsidentfas%ssanifericinopletingit@lthansfer?
thiid
[Q%MiglM%byyrpressly[tEnsfenind)j L
[assignieurirightslef (sandst downship}inithelatscit n
hmtW%j$iblidhaFMMdddd%/MN anadj%uh4GA3$mWV$8l:inMWibhWW ised,Igithist the
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+ public' anon errepublication sboveofue[above assignment and dtedweirkissubjecti jtoMM gg sv iai dg==gypwgwy%bre g==*eriptlias beers authored b Mesubp@tte$jGisinianesENgbO:l@[Md@P VeliiittiiCSeveniiiiiittiinddCEiracejNsMMNEMW Acisihiing
[roniii.
ioyali t'shis fem $MIEtilN,7Go6Wfiinsy s156EaskEMMisfiepiainceisti@mblisbliidh Gov _ennnen.
.~ h_tSutio6_;sessuaiot_he5?toMyMU1+1 ng dPTTdtM9d wM g6wcM m %
we tpurp0SeS8g yg.d fks% 93%gp%g eniis . 8gd?1 QQ us eAv-N m od %i . _. wg pamm-a a
Be$gt.@$$glp:%N
$ l l @ mggMi d M M i d d & F j F M. Lpg $ $yyp7q A M e g& aSinsid el'y/ # f YIMM g j
If NRC approves open literature publication and page charges and travel costs are required for the presentation of papers, see MD 3.9,-
"NRC Staff and Contractor Speeches, Papers, and Journal Articles on Regulatory and Technical Subjects." (10)
Reports Containing Sensitive Unclassified and Classified Information (D)
Examples of the proper marking of reports designated Official Use Only, Limited Official Use, Proprietary Information, Safeguards Information, and classified (CONFIDENTIAL, SECRET, and TOP SECRET) are specified in MD 12.2.
l L
Approved: June 17,1991 l 6 (Revised: July 9,1995) i
V:lume 3, Pcrt 1 - Publications, Mril, cnd Infcrmtti:n Disclosure i Unclassified Contrccter cnd Grcntee Publications in the NUREG S: ries IIandbook 3.8 Part II Conference and Workshop Proceedings (E)
If NRC approves publication of compilations of papers presented at NRC-sponsored or cosponsored meetings, conferences, and symposia, see MD 3.11, " Conferences and Conference Proceedings."
Distribution of Reports to Contractors (F)
Up to 50 copies of printed unclassified NUREG/CR, NUREG/GR, and NUREG/IA reports will be bulk shipped to the contractor by NRC. (The Joint Committee on Printing's Govemment Printing and Binding Regulations permit contractors to receive free of chage up to 50 copies of reports they have produced for NRC.) If fewer than 50 copies are needed, indicate the desired quantity on NRC Form 426A (Exhibit 1). Contractors requesting single copies for speci6c individuals in organizations other than the contractor's organization who are not inclrded in the distribution requested by the NRC contact may address su, a request, with written justification, to the hTC contact. lf the acaitional distribution is approved by the NRC contact, the contractor shall send address labels with the camera-ready copy to the Publications Branch, DFIPS, USNRC, Mshington, DC 20555-0001, and that distribution will be made along with the standard distribution.
Coordinating Contractor Press or Other Media Releases of Infortnation (o)
A contractor may request permission to issue a press or other media release on the work being done. That request must be made to the NRC office director or designee, who will consult with the staff of the Office of Public Affairs. The contractor must not issue a press release on nonroutine information without this prior approval. This approval may be obtained by a telephone call to the office director or designee to expedite the request. The contractor may appeal decisions not to authorize the release ofinformation or delays in handling the request to the appropriate Deputy Executive Director for Operations.
Approved: June 17,1991 )
(Revised: July 9,1995) 7 .
l
V:lume 3, Part 1 - Publicathns, Mail, and Informati:n Dischsure Unclassified Contractor and Grantee Publications in the NUREG Series Handbook 3.8 Part III Part III Draft and Final NUREG Reports Identification Information (A)
NUREG Number (1)
- Each contractor report published by NRC must be identified by a unique alphanumeric designation controlled and maintained by the Division of Freedom of Information and Publications Services (DFIPS). To obtain an NRC report number, call the Publications Branch, DFIPS, at (301) 415-7008. (a)
The NRC identification numbers will have one of the following forms:(b) e NUREG/CR-0000 e NUREG/GR-0000
. NUREG/IA-0000 CR indicates contractor report, GR indicates grant report, and IA indicates international agreement report. The contractor repon number, if any, will be placed below the NUREG number on the title page and cover. (c)
When a repon consists of more than one volume or binding, or is issued in more than one edition, an appropriate volume, number, supplement, pan, addendum, or revision designation must appear immediately below the NRC report number and the contractor's repon number,if any. (d)
Authors' Names (2)
Authors' names must appear on the report cover and title page, unless placing them there is impractical, as for an annual report having many contributors. Editors or compilers with subject-area expertise may also be identified as such on the cover and title page. The authors'
(
Approved: June 17,1991 8
(Revised: July 9,1995) l l
Volume 3, Pcrt 1 - Publicati:ns, Mail, cnd Inf:rrnati:n Discl:sure !
Uncl:ssified Ccntractor cod Grantee Publicati:ns in the NUREG S: ries Handbook 3.8 Part IH, ;
1 Identification Information (A)(continued)
Authors' Names (2) (continued) affiliation need not be listed unless it differs from the organization creating the repon.
Organizational Identification (3)
The Publications Branch, DFIPS, prepares the covers and title pages
. for all repons and will list information about the organization that created the repon as it is provided.
Previous Reports in Series (4)
If the repon being prepared is one in an ongoing series, list all previous repons in the series. Include repon numbers and issuance dates. Place this list on the back of the title page. If this list cannot be placed on a single page, place the pages at the end of the front matter rather than on the back of the title page.
Report Dates (5)
The repon dates are shown on the title page. These dates include the month and year the report is completed and the month and year it is published.
Report Organization and Components (B)
The organization and components of contractor repons vary, depending on their purpose and scope. Recommended format and organizational guidelines appear in " Publishing Documents in the NUREG Series"(NUREG-0650, Revision 1). (1)
Each draft and final report prepared for NRC must include an abstract of 200 words or less that appears on a separate page preceding the table of contents. The abstract also must appear on the " Bibliographic Data Sheet," NRC Form 335 (Exhibit 2). Instructions for completing NRC Form 335 appear on the back of the form. GuideEnes on the special writing requirements for preparing- abstracts appear in Section 5.5 of NUREG-0650, Revision 1. (2)
Pre-Publication Reviews (C)
Patent Review (1)
Patent implications must be considered before approval of reports for public release so that disclosure will not adversely affect the patent Approved: June 17,1991 (Revised: July 9,1995) 9
Wlume 3, Pcrt 1 - Publicati:ns, McII, and Informati::n Disclosure Uncl:ssified Centracter cnd Grantee Publicati:ns in the NUREG Series Handbook 3.8 Part III .
I Pre-Publication Reviews (C)(continued)
Patent Review (1)(continued) rights of NRC or the contractor. If the work being reported is contractually managed through another Government agency (e.g.,
DOE national laboratories), the contractor should request that Government agency to perform the patent review. The result of the review must be reported on NRC Form 420A under item 8 (see Exhibit 1). (a)
If N RC directly administers the contract, or the contractor is unable to obtain a patent clearance fro:.n the Government agency administering the contract, the responsiole NRC contracting officer must be consulted, and the responsible NRC technical contact shall consider the patent implications. If the report does not require a patent review because the report does not contain any description of novel technical developments that may be of an inventive nature, mark "N/A" on the NRC Form 426A in the space for the Patent Counsel's signature. If a possibility exists that developments of an inventive nature are disclosed, the contracting officer shall request assistance from the NRC Assistant General Counsel for Administration, Office of the General Counsel, on (301) 415-1553. (b)
Security Review (2)
If a report of sensitive unclassified or classified work is required, the NRC contact must work with the NRC Division of Security to establish the appropriate procedures and inform the contractor of these procedures through the contracting officer. The standards for marking and handling these reports are given in Management Directive (MD) 12.2, "NRC Classified Information Security Program."
Copyright Review (3)
Copyrighted material must not appear in NRC-sponsored publications without written permission from the copyright holder.
See Section 3.4 of NUREG-0650, Revision 1, for information about obtaining copyright permission.
Color Printing (D)
Regulations issued by the Joint Committee on Printing (JCP) restrict the use of color in printed materials to those uses that are of demonstrable value. JCP regulations specify that " demonstrably valuable multicolor printing" includes the following categories: (1)
Approved: June 17,1991 10 (Revised: July 9,1995)
V: luma 3, Itri 1 - Publicati:ns, Mail, cnd Inf:rmati:n Discl:sure Unclassified Ccntrcctor cnd Grcntee Publications in the NUREG Series Handbook 3.8 Part III S
Color Printing (n)(continued) e Maps and technical diagrams for which additional color is necessary for clarity. (a) e Object identification (medical specimens, diseases, plants, flags, uniforms, etc.), (b)
, 2 Safety programs, fire prevention, savings bonds programs, and competitive areas of personnel recruiting. (c)
. Areas wherein clearly identifiable savings in costs can be soundly predicated on multicolor use. (d) e Printing for programs required by law, whose relative success or failure is in direct ratio to the degree of public response, and for which that response can be logically attributable to the number of colors planned and the manner in which they are proposed to be used. (e) e Color for promotional or motivational purposes, such as programs concerning public health, safety, and consumer benefits, or to encourage utilization of Government facilities, such as programs for Social Security, Medicare, and certain areas of need for veterans. (f)
The regulationsindicate that the following categories do not meet the
" demonstrable value" criteria: (2) e Printed items wherein additional color is used primarily for decorative effect. (a) e Printed items for which additional color is used primarily in lieu of effective layout and design. (b) e Printed items for which additional color is used excessively, that is, four colors when two or three will fulfill the need, three colors when two are adequate, two colors when one is adequate. (c) e Printed items wherein the inclusion of multicolor does not reflect careful, competent advance planning that recognizes the contribution that the use of color is expected to make to the ultimate end-purpose. (d)
Approved: . June 17,1991 (Revised: July 9,1995) 11
l V:lume 3, Part 1 - Publications, Mdl, cnd Inf rmati:n Discl: sura l Unclassified C::ntract:r cnd Grcntee Publicati:ns in the NUREG S:rbs !
Handbook 3.8 Part III I l
Color Printing (D)(continued) .
If color printing is anticipated when the statement of work or standard order for DOE work is being prepared, contact the Publications Branch, DFIPS. Prior approval must be granted by the Director of DFIPS. If a requirement for color printing arises as the report is being prepared, submit a written justification for its use to the Director of DFIPS. (3)
Microfiche (E)
NRC contractors and DOE laboratories submitting microfiche with reports must submit a hard copy of each microfiche, include headers on each microfiche as shown in Exhibit 3, and conform to the following NRC specifications.*
- Microfiche must conform to either the 24/98 format for source documents with 14 columns and 7 rows (reduction ratio of 1 to 24) or the 48/270 format for computer output microfilm with 18 columns and 15 rows (reduction ratio of I to 48). (1)
. The micro 5che sheet must be standard 105 mm by 148 mm. (2) i e The microfiche must be either a silver-halide master or a black or blue-black diazo placed in acid-free envelopes. (3) e The microfiche must contain headers as shown in the sample in Exhibit 3. Specifically, the first block of the header must contain the NUREG number (include volume or revision, if applicable),
the contractor identification number, and the classi6 cation (e.g.,
unclassi6ed, proprietary). The second block must contain the description of the microfiche and may include the contractor.'s name. The third block must cc,ntain the publication date and the sheet identification. (4) e The header information must be eye readable on a clear background. (5)
. A foldout page must be microfilmed in sections if the page is too large to be microfilmed in a double frame. No less than 25-mm overlap of original material is acceptable. (6)
'With the excepoon of items (3), (4), and (8), these spectScanons are consistent with the American National stardards Insutute standard for Maographics-Microfiche. ANSI /AHM Ms5-1985." Copa of this standard are available from the Amencan Nanonal standards Institute, ATrN: sales Department.11 West 42nd street 13th Door. New York. NY 10036 (212) 642-4900, or from the Assocation for Inforination and Image Management.
ATTN: Publications section.1100 Wayne Avenue. silver spnng, MD 20910 (301) 557-8202.
Approved: June 17,1991 12 (Revised: July 9,1995)
Wlume 3, Pcrt 1 - Publicati:ns, Mall, cnd Infcrmation Discl:sure Unclnssified Ccntrcct r end Grantee Publications in the NUREG Series Handbook 3.8 Part III Microfiche (E)(continued).
- The first frame must be blank (on the first sheet only), and the second frame must contain the National Institute of Standards and Technology's (NIST's) Reference Material resolution target in Microcopy Test Charts (NBS SRM 1010A). (7) e Jacketed microfiche is unacceptable. (8)
Disclaimers (F)
The following notice will be added by the Publications Branch, DFIPS, before the printing process on the inside front cover: (1) m-wmv ~ ^ammmm~=mnem~m hThis7eport was. prepared jas sn;secount of work sponsored by Ran agencyof the United States GoGernmelit/Ndithieins United
$$thtesTGoYernmentM6rLainf hemplMaiskisisuswarr(agencyJtlissordnofany[ofitli anne 5ressedWimpliedh[Los o ifehfari thiid bassumiBanyllskalfliabilityN Ersp6hsibility$yYisf6rm@il kpahi'if uiissorithei resulisiefisch lLse,Wa kapphrathshhf6duc(Issplocesi@dishlsed dOlthi5?rihoirth of krppfesentith'ifiss$5 tspliscliitidnjds/wMdd A5t infrin'gd FprEsisly' Wii Old i M Y M ? Mids nww$d'iights!NM@@imilehAmi! -' "
Ruaa washweina The branch will print the additional statement, "The views expressed in this report are not necessarily those of the U.S. Nuclear Regulatory Commission," below the standard disclaimer, if appropriate. Other qualifying statements may be added, if needed. (2)
Availability Information (G)
Reference Material (1)
Reports or other documents referenced in text, reference sections, bibliographies, and appendixes of unclassified regulatory and technical reports in the NUREG series must be available to the public either in the public domain (as in a public library, at the Government Printing Office (GPO), at the National Technical Information Service (NTIS), or at other reference or sales outlets) or in the NRC Public Document Room (PDR). This means that references should not be made to personal communications and interviews, unpublished information and information with restricted distribution (e.g.,
prop;ietary, National Security, and Official Use Only). If the unretrievable information is important and unrestricted, quote it in Approved: June 17,1991 (Revised: July 9,1995) 13 1
1
Volume 3, Part 1 - Publicati:ns, htil, cnd Inf:rmati:n Disclosure Unclassified C:ntract:r cnd Grcntee Publications in the NUREG S ri;s Handbook 3.8 Part III Availability Information (G)(continued)
Reference Material (1)(continued) the ten or in footnotes. Provide any credit due to individu als in the text or in an acknowledgment section. Availability may be stated collectively for all entries. (a)
Although proprietary reports may not be included in a list of references, listing or identification of proprietary reports may be included in an appendix or in a separate listing following the reference section titled " Proprietary Sources ofInformation.(b)
In addition, reference to Institute of Nuclear Power Operations (INPO) documents may not be made without prior approval from INPO. Approval to reference INPO documents must be stated on the NRC Form 426A. (c)
Guidelines for developing and presenting reference material are provided in NUREG-0650, Revision 1. (d)
Reports (2)
Most final reports are sold by GPO and NTIS. A statement indicating this availability is added to each report, as appropriate, by the Publications Branch staff before the report is printed. (a)
Draft reports for which comments are requested are typically announced in the Federal Register as being available from the NRC.
These reports are not sold at GPO or at NTIS. (b)
Forms (n)
Bibliographic Data Sheet (NRC Form 335) (1)
All published NRC reports must include an NRC Form 335 as the final right-hand page of the manuscript. Instructions for completing the NRC Form 335 appear on the back of the form. A completed NRC Form 335 must be submitted to the Technical Publications Section, DFIPS, with the camera-ready copy of the report. Exhibit 2 shows a completed NRC Form 335.
Release To Publish Unclassified NRC Contractor, Consultant, or Conference Proceedings Reports (NRC Form 426A) (2)
The NRC contact must submit a completed NRC Form 426A (see Exhibit 1) with the camera-ready copy of the report to the Technical Publications Section, DFIPS. NRC Form 426A must be signed by the staff member designated by the appropriate office director.
Approved: June 17,1991 14 (Revised: July 9,1995)
V:lume 3, Pcrt 1 - Publications, htil, cnd Infctmati:n Discl:sure Ucclassified C:ntract:r cnd Grantee Publicati:ns in tha NUREG Series Handbook 3.8 Part IU Printing and Reprinting (I)
The Publications Branch, DFIPS, will review the camera-ready report submitted for printing for its adherence to the standards and requirements set forth in this directive and handbook, as well as any relevant guidelines from NUREG 0650, Revision 1. Unsatisfactory manuscripts will be retumed to the NRC contractor for appropriate action. (1)
Submit a memorandum requesting a reprint to the Director, DFIPS, or designee, for approval. Include with the request a written justification and the approval of the office director or designee for reprinting. Also provide address labels for recipients not on NRC standard distribution lists. (2)
Distribution (J)
The Publications Branch, DFIPS, will arrange distribution for all copies of unclassi5ed formal contractor reports in accordance with instructions on NRC Form 426A (Exhibit 1).The Publications Branch will also arrange automatic distribution of these reports to hTC NUDOCS, the NRC PDR, NTIS, GPO, and the GPO Federal Depository Library Program. (1)
Sensitive unclassified and classi5ed reports will be distributed by the NRC sponsoring office on a case-by-case basis. (2)
Approved: June 17,1991 (Revised: July 9,1995) 15 l
V;1ume 3, Part 1 - Publicati:ns, M:ll, and Inf:rmati:n Disclosure Unclassified Contractor and Grantee Publications in the NUREG Series Handbook 3.8 Part IV Part IV I,nternational Agreement Reports Background and Rationale (A)
NRC has cooperative nuclear safety research programs that involve either or both foreign governments and organizations and U.S.
industry. These programs include monetary contributions, information exchange, and comments on program plans and results as authorized in the Energy Reorganization Act of 1974. To this end, international and U.S. industry agreements have been signed that provide for transmitting unclassified technical information from l foreign participants to NRC. These procedures apply only to NRC-managed work. (1)
The interests of all NRC international nuclear safety research program panicipants are served best by formal dissemination ofinformation on these programs or codes developed for or in cooperation with l NRC. (2)
Identification Information (B)
Cmtr and 'Iitle Page (1)
The cover and title page will contain a title, a subtitle (if appropriate),
the names of the authors, the performing organization, and the NRC l office sponsoring the project. The cover and title page will be prepared l by the Publications Branch, Division of Freedom of Informacon and l Publications Services (DFIPS).
l NRC Report Number (2) l Each report must be identified by an NRC-controlled alphanumeric number as the prime number unique to that report. The ceritralized document control system for unique identi5 cation is maintained by DFIPS. Numbers may be obtained by calling the Publications Branch at (301) 415-7008. (a)
Approved: June 17,1991 16 (Revised: July 9,1995)
V:lume 3, Part 1 - Publications, Mall, cnd Inf:rmation Discl:sure Unclassified Contract:r and Grantee Publicati:ns in tha NUREG S: ries Handbook 3.8 Part IV _
Identification Information (s)(continued)
NRC Report Number (2)(continued)
The NRC identification number will have the form "NUREG/IA-000," where IA indicates "intemational agreement."
The foreign panicipant's repon number, if any, may be insened below the NUREG number on the cover, if desired. (b)
When a repon consists of more than one volume or binding or is issued in more than one edition, include an appropriate volume, number, supplement, part, addendum, or revision designation below the repon number and the foreign participant's repon number,if any. (c)
Previous Reports in Series (3)
If the repon being prepared is one in an ongoing series, list all presious reports in the reries. Include repon numbers and issuance dates. Place this list on the back of the title page. If this list cannot be placed on a single page, place the pages at the end of the front matter rather than on the back of the title page.
Report Organization and Components (C)
The organization and components of cooperative agreement repons vary somewhat, depending on their purpose and scope. Each of these repons must include an abstract of 200 words or less that appears on a separate page before the table of contents. The abstract must also l- appear on the " Bibliographic Data Sheet," NRC Form 335 (Exhibit 2).
Instructions for completing NRC Form 335 appear on the back of the form (Exhibit 2). Guidance on the special writing requirements for preparing abstracts appears in Section 5.5 of NUREG-0650, Revision 1.
Availability Information (D) l References and Bibliographies (1)
Reports or other documents referenced in text, reference sections, bibliographies, and appendixes of unclassified regulatory and technical reports in the NUREG series must be available to the public l either in the public domain (as in a public library, at the Government l Printing Office (GPO), at the National Technical Information Senice l (NTIS), or at other reference or sales outlets) or in the NRC Public Document Room. This means that references should not be made to personal communications, inteniews, and unpublished information with restricted distribution (e.g., proprietary, National Security, Official Use Only). If the unretrievable information is important and Approved: June 17,1991 (Revised: July 9,1995) 17
Volume 3, Part 1 <- Publicatiens, Mail, cnd Infortnation Disclosure Unclassified Contractor and Grantee Publicati:ns in th2 NUREG Seri:s
-Handbook 3.8 Part IV Availability Information (o)(continued)
References ind Bibliographies (1) (continued) unrestricted, it can be quoted in the text, in footnotes, or in appendixes. If the title of a document containing proprietary information is unclassified,it can also be quoted in the text or in a footnote. If credit is due to individuals, they can be mentioned in the text or in an acknowledgment section. Availability may be stated collectively for all entries. (a)
Although proprietary reports may not be included in a list of references, listing or identification of proprietary reports may be included in an appendix or in a separate listing following the reference section titled " Proprietary Sources ofInformation."(b)
In addition, reference to Institute of Nuclear Power Operations (INPO) documents may not be made without prior approval from INPO. Approval to reference INPO documents must be stated on the NRC Form 426A. (c)
Guidelines for developing and presenting reference material are provided in NUREG-0650, Revision 1, (d)
Reports (2)
These reports will be made available for sale by GPO and NTIS.
Disclairner (E)
Tne following notice will be added by the Publications Branch, DFIPS, on the inside front cover before printing.
M11afariGilssdNeithedtisil fAMiemust$c$$a*=%psisijpesiset;saisiiesit i~ualiaisilik bern-n- >
1iiii
' 3 y s lik, f* .quiie asvaess;ame C" HisteseR4ds %rmisiilssiE,aiiiisair,asase iirissiEnsamanMisr(ess dsiifesentshifts@w&qsu% it 115td issfddiddM4afHage@privatelyMVisistMWW wxusanans w w mmmm w,m my%. w Approved: June 17,1991 18 (Revised: July 9,1995)
Volum] 3, Part 1 - Publicati:ns, Mail, and Informati:n Discl sure Unclassified Contract:r cod Grantee Publications in the NUREG S ri:s Handbook 3.8 Part IV Forms (F)
Bibliographic Data Sheet (NRC Form 335) (1)
Submit a typed NRC Form 335 (Exhibit 2) with the camera-ready copy to the Technical Publications Section, DFIPS, as the final right-hand page.
Release to Publish Unclassified NRC Contractor, Consultant, or Confertnce Proceedings Reports (NRC Form 426A) (2)
An NRC Form 426A (Exhibit 1) must be completed and signed by the office director or designee and submitted with the camera-ready copy of the report to the Technical Publications Section, DFIPS.
Classified or Sensitive Unclassified Information (G)
The NRC contact should refer to Management Directive 12.2 or call the Division of Security for answers to questions about the status of classified or sensitive unclassified information in NUREG/IA reports.
4 Approved: June 17,1991 (Revised: July 9,1995). 19
V:lume 3, Pcrt 1 - Publicati:ns, htil, cnd Inf:rmatirn Discl:sure Unclassified Contractor and Grantee Publications in the NUREG Series Ilandboek 3.8 Part V Part V Books General (A)
These guidelines apply to books written by contractors and grantees that are printed by NRC. See Part VI of this handbook for guidance on publications, including books, by grantees.
Definition (B)
A book refers to a publication intended as a permanent reference or as a textbook or major critical review of a technical or regulatory topic.
Format (C)
Books are usually 6 by 9 inches in trim size, but size will be based on requirements such as ease of use and legibility for graphics, foldouts, and the like. The binding (casebound or paperback) will be chosen according to the need for durability. Additional guidance on manuscript preparations can be found in the U.S. Govemment Printing Office Style bfanual and the Chicago University's A Afanual of SO'le.
. Refer also to NRC's " Publishing Documents in the NUREG Series" (NUREG-0650, Revision 1) (1)
The contractor shall submit to the NRC project manager the typeset (photocomposed) manuscript suitable for printing. The NRC cc ntact shall submit the mamtscript to the Chief, Fublications Branch, Division of Freedom of Information and Publications Senices, (DFIPS), where it will be reviewed for adherence to the standards set forth and referenced in this directive and handbook. The manuscript will also be reviewed for printing acceptability by the Printing and Mail Services Branch, DFIPS. Unsatisfactory manuscripts will be reported to the NRC contact for appropriate contractual action by the NRC contracting officer or, in the case of Government agency or interagency agreement work, the publications manager of the performing organization. (2)
Approved: June 17,1991
,0
. (Revised: July 9,1995)
V;lume 3, Part 1 - Publicati:ns, Mail, and Inf:rrnati:n Discl:sure Unclassified Ccntract:r and Grcntee Publicati:ns in the NUkEG Seri:s Handbook 3.8 Part V Format- (c)(continued)
DFIPS will approve the design of the cover and title page contairdng appropriate information concerning-(3) e Authors' names (a) e Organizationalidentification (b)
. Public availability and sales (c)
All books must include a comprehensive subject index of the book's contents, unless the book is made up almost exclusively of graphical or tabular matter. See NUREG-0650, or The Chicago Manual Sole (13th ed.) for guidelines on creating an index. (4)
NRC Document Number (D) l Each book must be identified by an NRC-controlled alphanumeric l code unique to that book. The alphanumeric code will have the form NUREG/CR for books prepared by contractors and NUREG/GR for books prepared by grantees. (1)
When a book consists of more than one volume or binding, or is issued in more than one edition, include an appropriate volume, number, supplement, part, addendum, or revision designation directly below the document number. (2)
Numbers are assigned by the Publications Branch, DFIPS. The number may be obtained before the manuscript is submitted to DFIPS for printing by calling the Publications Branch at (301) 415-7166. The DFIPS staff will arrange to meet with the NRC contact for the project and, when appropriate, the author (s), to discuss the publication l
I production requirements and the schedule for the book. (3)
Availability of Reference Materials (E)
The guidelines for availability of reference material given in Section G of Part m of this handbook also apply to books prepared by contractors and grantees that are published by NRC.
Approved: June 17,1991 (Revised: July 9,1995) 21 Y
(Volume 3, Part 1 - Publications, Mail, cnd Inf:rniatirn Disclosure Unclassified Centract:r and Grcntee Publications in the NUREG Seri s' ,
Handbook 3.8' Part V Reviews (F) ,
Peer (1)
Books published by NRC must undergo peer review by experts within and outside NRC. Peer review refers to a critical evaluation'of the' ;
technical contents of a publication. These reviews may be conducted -
anonymously by reviewers from the author's own or a related field who are totally independent of the . work leading to the manuscript. (a) t Reviewers should be chosen by the NRC office sponsoring the book from the potential audience for the publication and should provide an -!
independent judgment abo _ut whether the publication successfully accomplishes the author's aims. Peer reviewers should be chosen for their expertise in the subject matter of the book. They may come from academia, the national laboratories, other Federal agencies, or from other research institutes or consulting 6nns. They may be identified ,
from the membership rolls of professional societies, American National Standards Institute (ANSI) subcommittees, and the like. Do not choose more than one reviewer from the same organization. (b)
When assessing potential peer reviewers, screen for demonstrated competence and achievement in a specific discipline or research specialty. Assess competence: based :on the quality of research accomplished, publications in refereed journals, and other signi6 cant technical activities, achievements, and honors. Consider the judgment, perspective, and objectivity of reviewers. Consider also the personal Luegrity of those selected to ensure the confidentiality of information reviewed.- Finally, avoid real or perceived conflicts of interest. Do not choose reviewers who are licensees or consultants to licensees, nor reviewers from intervenor groups. Likewise, do not choose reviewers who may pro 6t financially from influencing the-information reviewed. (c)-
The services of reviewers Dom ou: side the agency may be acquired through consultant services contracts. The decision as to whether to reimburse peer reviewers should be made on a case-by-case basis, however. Recognize that reimbursing peer reviewers may give the appearance of a conflict of interest, suggesting to some that because -
t NRC is paying for this service,' the agency will seek only reviewers thought to be favorably AS -d to the material reviewed. One way to offset this impression is to seek recommendations for peer reviewers
- from . independent organizations, such as the American' Physics -
I:
. :=
Approved: June 17,1991--
22 -- ; (Revised:: July 9,1995)
>W w
- re-u -n. p y.r+--i 4wfy'- e-,' w-
V;lume 3, Pcrt 1 - Publicati:ns, hial), and Inf:rmati:n Discl:sure Unclassified C:ntrcct:r and Grantee Publicati:ns in th2 NUREG Seri:s Handbook 3.8 Part V Reviews (F)(continued)
Peer (1)(continued)
Society, the American Nuclear Society, the American Society of Mechanical Engineers, or appropri?.te universities. Reimbursement could then be made to the organization. (d)
Copyright (2) ,
Copyrighted material must not be reproduced in NRC books without appropriate authority, usually written permission of the coppight holder. See Section 3.4 of NUREG-0650, Revision 1, for information about obtaining copyright permission.
Security (3)
On the basis of the know! edge of the information sources used, the author is responsible for ensuring that the manuscript does not contain classified or other access-controlled infonnation. If uncertainty exists with respect to the security classification of a reference document or manuscript, an authorized classifier or the NRC Disision of Security should be contacted for assistance. See also Management Directive 12.2, "NRC Classi5ed Information Security ProgrLn."
Patent (4)
The patent review guidelines for draft and final formal reports specified in Section (C)(1) of Part III of this handbook also apply to books prepared by contractors and grantees.
Publishing Authorization Form (c)
A completed NRC Form 426A (Exhibit 1), signed by the office director or designee or by a DOE national laboratory authorized official if the publication is prepared for the ' Office of Nuclear Regulatory Research, must be submitted to DFIPS with the book manuscript.
Disclaimers (a)
The following standard U.S. Government notice will be added before printing:(1)
Approved: June 17,1991 (Revised: July 9,1995) 23
V: luma 3, Pcrt 1 -. Publicati:ns, htil, cnd Inf:rmati:n Discl:sure Unclassified Centracter cnd Grantee Publicati:ns in the NUREG S:ri:s f
Handbook 3.8 Part V DISClaitnerS (H)(continued)
'%iiidssiGsesfWiprejiued iiis sissssuht'sfWrEspsasoiFed bssa sgenef4f the"UnitdStates Goverannend;Neitidthe f United States Governiment%Fanfaiincy thereof,[noFanyof 1 theifsEs16pisisaksinfiniininty, c'x' pressed erinipliedfor
[aWiisss "any?iessi'listidity!I6ETrtsponsibilip foniany(third
[ party's?uM2crithe nsults'oflsuch skfof$infornuttion)
!apsiaisiuspinduNors rbcess'diselssidEthisidocuanestfor u
f represen'ts ttiat its us byissh third
{ prinQegjdjigist$dj2$9)$;pdrty1wouldinst i d d d j [gs j infring The following additional statement may be printed below the standard disclaimer,if authorized by tne NRC office director or designee: (2)
[ThEdE5iieEtWiidiIa'rEdIin~deiUENiillEfeMist'67ff fC insissioirE NRC)5ConfrsEtTN6%* O ' MiTossinisiisd 1 IIksdingO:sisic(lesissdiid stes$lidendations expressidhilein FarelthosES tiis?suthudsfi6didd sofinecessariiphilesfthei p&
% g&.gg g q; 9 9 g ; 9. .y d etLast umgn, y 4. wid pg.gg , 97 Other qualifying statements may be added, if needed. (3)
Printing (1)
DFIPS will submit book manuscripts to GPO for printing. The printing cycle requires from 6 to 8 weeks.
Distribution and Sales (J)
The DFIPS staff will arrange distribution in accordance with distribution guidance provided by the NRC project manager on NRC Form 426A (Exhibit 1). (1)
Free distribution should be limited to those who contributed materially to the book or to those for whom the book's subject matter bears direcdy on their work at or for NRC. (2)
DFIPS will arrange to make the book available for sale through GPO.
DFIPS also will arrange to have it made available at the NRC PDR and for the GPO Federal Depository I.ibrary Program. (3)
Approved: June 17,1991 24 (Revised: July 9,1995)
V:lume 3, Part 1 - Publications, Mail, cnd Inf:rm: tion Discl:sure Unclassified Contractor and Grantee Publications in the NUREG Series Handbook 3.8 Part VI Part VI Grant Publications Background and Rationale (A)
The Nuclear Regulatory Commission funds grants for educational and nonprofit institutions, State and local governments, and professional societies for the expansion, exchange, and transfer of knowledge and ideas pursuant to the Atomic Energy Act of 1954, as amended, Sections 31.a and 141.b.
Publication of Results (a)
The grant will specify the publication requirements of the award.
Grant results may be published by NRC, by the grantee, or in the open literature.
Publication by NRC (1)
This publication option must be governed by the guidelines specified in Part III of this handbook for reports or in Part V of this handbook for books, as appropriate. See " Identification Information,"
Section (C) of this part.
Publication by a Grantee (2)
When the grant specifies that the grantee is to publish the results of his or her work, the grantee must grant to the Government a royalty-free,
- nonexclusive, irrevocable license to reproduce, translate, publish, use, and dispose of all copyrightable matedal Erst produced or composed in the grantee's performance under the grant.
Publication by a Grantee in the Open Literature (3)
When the grantee submits journal articles for publication, each article must be accompanied by the following statement: (a)
Approved: June 17,1991 (Revised: July 9,1995) 25
Volume 3, Pcrt 1 - Publications, Mnil, cud Inform: tion Disclosure Uncl ssified Centrccior cnd Gr ntee Publicatione. In the NUREG Series IIandbook 3.8 Part VI Publication of Results.(n)(continued)
Publication by a Grantee in the Open Literature (3) (continued) m._.-_,-----.--,__x-IThe submitted manuscript has been authored by a grantee ofi
!the.U.ShCovernment'under Grant'No.-
MAccoidingly,i jthe U.Sj Goknunent has a nonexclusive, royalty.-free license to ?
! publish or repredn, Ethe published form of this co, n,tfibution. g
~ . - ...
,;or allow others to do os for U.S!Gove.rnment purposes. w w ~ ~ .a.n - _/.--~.__.--.a All open literature publications prepared under this grant must contain the following statement: (b)
- m: w w w w e e % w m m e g:re w m ,
l This' paper was prepaoed with the suppori of the U.S. Nuclear;
! Regulatory Commission (NRC)'under Grant No.' ' < JThe?
[opinbasRfin; dings,yconclusions, sandy recommendations?
!expressedsherein?amithosetoff the; author (s)fandidoi:-nots
!necessarily:reflecithe views of theMC.o Mm-iszwedsweddLean%i ~ plPWt "w If the grantee is requested by the journal or other publisher to transfer the copyright, the grantee author will respond to the journal or other publisher in writing in accord v.ith the sample letter shown as follows:(c)
- " * " " * ""l?*
iDeW(Publishbr'sMmeF@"g"h vfum muwrgmam m@W"<""W~'.*"E*T*
M .a
!We recently;receivediaidocument forl signature;; assigning copyright l to (name 6f
[_and npublication rights 3n' theeumen s6bmitted irticle (title)f s
!tef;pub.
.l_ication)f'Ibi_slettelshfferi,dislickof completing
- m . . .
4 thea transfer! afrownershipf Acco tiie m
gly,;we do_fdm, hereby. m
~
expresslyjtransfedAndfasiigh9drWignWoffownershi%in?tliel (Nabove. cited 3seaftif snestpublisher)$p$$d' n x: n <
"J' lh wn a d You?sm rad + vised,1 a,+-.mp~ A wYthat1t.h(
n a M. mWinssignment6and.
c -
?.,any,;
- publicatio_n or npubli, cation of thssbove,-cited workis ,s,ubject to the.
tfollewing'GodehnmektiigMAs@d@@im?%
W savammm:; mun Ltc gw.* *.N.M P17 PN
. Enig 2n jThe submitted inanuscripthas been authored b;y a'grantec of the U.Sf
- Government'unddGrant
- ~+
NF '* " % Cfc AccontinglyftheU,.S3a 7
< G.novernmentash.a:nonesc --- lus.ive,; royalty-fne h. -eense:tofpublisti ors
%eedub'etlkpublishid fornfof this son 6itiniiion[odallow othursid do so; Tor:U.SJGdernmes/parposes. %# 3 Chddesd&M$Ainda$% [l'l3$elydEd l
Approved: June 17,1991 (
26 (Revised: July 9,1995)
V:lume 3, Part 1 - PublicatJ:ns, hell, cnd Inf:rmati:n Discl:sure Unclassified Ccntract:r cnd Grcntee Publicati:ns in the NUREG Series Handbook 3.8 Part VI Publication of Results (s)(cantinued)
Reprints of Open Literature Publications (4)
When any article resulting from work under the grant is published :n a scientific, technical, or professional joumal, two reprints of the publication must be sent to the cognizant NRC program officer, clearly labeled with the grant number and other appropriate identifying information.
Identification Information (C)
Each report or book published by NRC that results from a grant must be identified by an alphanumeric number, "NUREG/GR-000,"
where "GR" indicates " grant report." (1)
When the publication consists of more than one volume, number, supplement, part, c binding, or is issued in more than one edition, an appropriate volume, .7oplement, part, or revision designation must appear below the Nbt 3G/GR number. (2)
Numbers may be obtained from the Publications Branch at (301)415-7008.(3)
Pre-Publication Reviews (o)
The U.S. Congress characterizes the relationship between a Federal agency and a grant recipient as one in which "the iecipient can expect to run the project without agency collaboration, participation, or intervention hs long as it is run in accordance with the terms of the instrument."
Approved: June 17,1991 (Revised: July 9,1995) 27
V: lum: 3, Part 1 - Publicati:ns, htil, cnd Inf;rmation Disclosure Unclassified Contractor and Grantee Publications in the NUREG Series Handbook 3.8 Glossary Glossary
- Book. Apublication intended as a permanent reference or textbook or as a major critical review of a technical or regulatory topic. It may be casebound (hardback) or paperbound.
Camera-Ready Copy. Pages ready for printing by the offset printing process. This is a colloquial term used even though the printing process rnay not involve the so-called copy camera (see also reproducible masters).
Casebound. Term denoting a book with a hard cover.
Compose. To arrange letters, in type or film, for printing. Usually ,
synonymous with typesetting.
Composition. The p.ocess of setting type by hot-metal casting, phototypesetting, or electronic character generating devices (e.g.,
computers) for the purpose of producing camera-ready copy, negatives, a plate, or an image to be used in the production of printing or microform.
Contractor Report. Record of work done (a report) prepared in accordance with the provisions of a contract or under or pursuant to an interagency agreement.
Cupyright. A form of protection provided by the laws ef the United States (Title 17, U.S. Code), to the authors of " original works of authorship," including literary, dramatic, musical, artistic, and certain other intellectual works. This protection is available to both published and unpublished works. Generally, copyrighted material may not be reproduced without the permission of the author or the publisher.
Disseminate. To announce the publication of reports and make them available for free distribution, sale, or copying.
words in irhr in desninons are aho denned in the skxwy Approved: June 17,1991
,8
' (Revised: July 9,1995) -
Vclume 3, Part 1_- Publications, Mail, and Inf rrnation Disclo.sure Unclassified C:ntract:r cnd Grantee Publications in the NUREG Series Handbook 3.8 Glossan*
Glossary (continued)
Distribution. Reports dispensed to specific organizations and individuals to ensure their participation in the regulatory process and support of research and technological investigations. Such distribution may be accomplished by the use of standard distribution lists established and maintained by the Dhision of Freedom ofInformation and Publications Services at the request of the originating office or region.
Documentation. Classification and associated markings required for classified or sensitive unclassified documents, the NRC report number unique to the report, title (and subtitle, if any), author or correspondent (if any), organization identification and contract number (or job code number), date, and availability.
Edition. All copies of a book printed from the same type. Edition also refers to format, such as paperback, casebound, or to the text, as revised, expanded, and so on. If extensive revisions have been made to the text and the book is reprinted, the revised version is the new edition.
Grant. Alegalinstrument which de5nes the relationship between the Government and a recipient for the transfer of money, propeny, services, or anything of value to the recipient for the accomplishment of a public purpose of support or stimulation authorized by law. A grant presumes a limited amount of ,
involvement by the agency in the performance by the recipient.
Grant Report. A record of work done prepared in accordance with the provisions of thegrant.
Index. An alphabetical list of all major topics discussed in a book. It cites the page numbers where each topic can be found. The indexis the last section of a book.
International Agreement. Cooperative nuclear safety research programs that involve either or both foreign governments and organizations and U.S. industry. Such involvement, authorized under 42 U.S.C. 5801, includes monetary contributions, information exchanges, and comments on program plans and results.
International Agreement Report. A record of work done prepared in accordance with the provisions of an intemational agreement.
Approved: -June 17,1991
- (Revised: July 9,1995) 29
V:lume 3, Part 1 - Publications, Mail, and Inf:rmati:n Discl:sure Unclassified Contractor cnd Grantee Publications in the NUREG Seri:s Handbook 3.8 Glossary l 1
Glossary (continued)
Manuscript. A handwritten, typewritten, or composed vi sion of a document, as distinguished from a prin*ed copy.
NRC Prcject Manager. The NRC staff member responsible for the work performed by cortsultants or contractors and their subcontractors, or for work performed under or pursuant to an interagency agreement. -
Paperback. A book with a flexible paper cover.
Peer Review. A critical evaluation of the technical contents of a publication. These reviews are conducted by reviewert b.om the author's own er a related field who are totallyindependent of the work leading to the manuscript. Reviewers should be chosen from the potential audience for the publication and should provide an independent judgment about whether the publication successfully accomplishes the author's aims.
Photocomposition. Typesetting pedormed when photosensitive pape4 or film is exposed to light in the form of letters and characters.
Photocomposition is to be distinguished from hot-metal and typewriter composition.
Printing. As defined by the Joint Committee on Printing, includes and applies to the process of composition, platemaking, presswork, collating, and microform; the equipment used in such processes; or the end product produced by such processes and equipment.
Proprietary Information. Trade secrets; privileged or confidential research, development, commercial, or financial information exempt from mandatory disclosure under 10 CFR Part 2 (Sections 2.740 and 2.790) and under 10 CFR Part 9 (Section 9.17);
and other information submitted in confidence to the NRC by a foreign source and determined to be unclassified by the NRC.
Public Domain. Ma e-ials for which a copyright never cristed, such as U.S. Government publications, or for which a copyright has expired.
Publicly Available Documents. Information (reports and references) that is available in the NRC Public Document Roam (PDR) for public inspection and copying or available in thepublic domain.
Approved: June 17,1991 30 (Revised: July 9,1995)
Volume 3, P rt 1 - Publications, M:ll, cnd Inf:rmatino Discl:sure Uncl ssified Centract:r cnd Grantee Publications in thi % REG S:ri:s Handhaok 3.A Glossary Glossary (continued)
Reproducible Masters. Camera-ready copy that includes (1) originals of line drawings (or prints that can be copied); (2) glossy prints of black and white photographs; (3) original typeset or printed text, tables, cover, title page, contents, and abstract; or (4) other forms of the materials that a printer can reproduce.
Trim Sire. ~nie Unal size of the whole page, margins included.
Typesetting. The placer.:ent of type on a page (letters, numbers, and other characters) in conformance with specific style and layout instructions.
Unique Identification. NRC luentification (NUREG number) used on a report and its attachments, revisions, and supplements that is not used on any other publication.
l Approved: June 17,1991 (Revised: July 9,199S) - 31
Vclume 3, Itri 1 - Publications, htil, cnd Inform: tion Discl:sure Unclassified Contractor and Grantee Publications in t's.e NUREG Series Handbook '.8 Exhibits Exhibit 1 NRC Form 426A, " Release to Publish Unclassified NRC Contractor, Consultant, or Conference Proceedings Reports"
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Approved: June 17,1991 32 (Revised: July 9.1995)
Volume 3, Itri 1 - Publications, Mail, and Inf:rmation Disclosure Unclassified Contract:r and Grantee Publications in the NUREG S: ries Handbook 3.8 Exhibits 1
1 Exhibit 2 NRC Form 335, " Bibliographic Data Sheet"
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BituOGRt.PHIC DATA SHEET
- * ~ ~ . = ' ~ ~ fluRtG/CR 5603 e v.ise .,6e tGG.2607 Pressure-Dependent Frag 111 ties fer Piping Components 1 Gis*'.e.o.v . 6. ep Pilot Study on Davis.Beste Nuclear Power Station - . ..
Detober l 1990 BY9 c .. . . .. . . . .y D.A. Wesley. T.R. Kipp, D.K. Nakaki H. Hadidi-Tamjed chnicp A
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Idaho Falls. ID 8341
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. w= . .. . - . . n. ~ . -. e .y-Division of Safety Issue Resolution Dffice of Nuclear Regulatory Research U.S. Regulatory Comission Washinoten 0,C, ?O555 A e
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7\y4 The capacities of four. low. pres re id t to wi stand pressures and tempera.
tures above the design lev wer est lishe for e Da s.Beste Nuclear Power Stat.
ion. The results will use n e alu -
t ro ity of plant damage from Inter.
facing System Loss of olant Ac e is i, CA) part of the probabilistic risk as.
sessment of the Davis. sse leer r t ion u ertaken by EG&G Idaho. Inc. In.
cluded in this evaluatio are tank .- t e ogers, filters, pumps, valves, and flanged connections for w sys lhe p bab ities of failure, aF a function of in.
ternal pressu e ev.11ua d as 1 s the variabilities assocsated with them. Leak rates or les reas esti ed to t rolling modes of failure. The pressure capacities f th pi and ve als a evaluated using 11mit. state analyses for the various fallu no con ered. The pacities are dependent on several factors, in.
cluding the met ria pert . mo 1 assumptions, and the postulated failure cri.
- teria. The fail re d for y ete .f ange connections, valves. and pumps do not lend the to eva ati y conven onal structural mechanics techniques and evaluation rely rimaril on e from ongoing gasket research test programs and avail.
le v r informa on a test data.
T~sif -
" .eso.s ., .- ., a......u.m. e press -dependent a es Un11mited iDing com ts a m.au ces.C 1 erfact Sy . em La ss of Coolant Accidents (ISLDCA) u- w pro st isk a sessment Unclassified Da vi s-Bes ucle ower 5tation n- -~
Unclassified a .u.es. o. .*c.u
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Approved:= June 17,1991 (Revised:. July 9,1995) 33
Volume 3, Part 1 - Publicati:ns, M:ll, cnd Inf;rmation Disclosure Unclassified Contract:r and Grantee Publications in the NUREG S: ries Handbook 3.8 Exhibits Exhibit 2 (continued)
DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN THE NUREG REPORT 1865TfWCTl0NS NRC FORM 338. DISLIOGRAPHIC DATA $HtET. Il SA8tD ON CulDtuNtt POR PORMAT Aldo PRODUCTION OP SCIENilPIC ANO ftCHNICAL REPDAT8. ANas 239.18 1987 AVAILABLE PROM AMERICAN NATIONAL STANDARDS IN57tTUTE. ld30 DROADWAY, New YORK. NY 10018. t ACH StPARATE LY SOUNO REPORT.POR E KAMPLt. EACH VOLUW4 IN A WVLTIVOLUME SET.4 HALL HAVE 178 UNIOut $19UDGRAPHic DATA SHEEY.
- 1. R0 PORT IMasetfL Serh ladeutdiseley bound sooert must - 8. PERPORestle0 ORGA8dl1AT10et 46446f A080 MAILING eury e emealso eipheasaers eastywhen (NUMEO) onesgned ADORt95. Geve hone, estet, any, etage, and IIP emes.
by the Raouseiery Puhmesetese tronen, Davle6en of Fraseem Lbt no more t'en two town of an argonnemional hasserchy, of interweeten end PuMeestmas Servess. Wi : .. ernh Detoy the none of the ergeniasuen easetty en follows:
Amoresen 5dessenal Surutsed ANtl 13923 1983, beeneertl Otroen. Offme. Orgeseet6en er Goveronent esraey, and Teshneeel Resort femmber (ETRN), use useeressp isteers, eesposa.
AreMr moviereis, seashes, and hvemene only, se in the feltsw.
nne seemetsel NUR80 0100 NURtG/CP.0010. NUREG/ 9. SPON00 mite 0 ORGAasizATIOet if NRC. twee *$eme es CR4100. end NUROG/SR40llL 7er scourts en a serses odd aeove"J 4f eentratter, ersweser NRC On4 men.Offese er Repen.
Vol., Siossi., Ree and Assensium, essen poseenery. Add UA 88uelser Reguletory Conentesten, and seidsng seerens, sentrarier eromeeterense teradfinsitan omsmher til enyl heten NUMEGiertas emenduer e.4, PNL.XXXX, SANDXX. te. SuePLAMettTARY $00TES. $sese informeilen met inchMesd X KX X. &Al.XX XX. elsewsere tivt warful, essh een preeered in eessesetsen pietti ...
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- Volume 3, Part 1 - Publications, Mail, and Information Disclosure i Unclassified Contractor and Grantee Publications in the NUREG Series Handbook 3,8 Exhibits I
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ATTADf W 5 ACH VENDOR / MISCELLANEOUS PAYMENT ous N3 isio-oose ENROLLMENT FORM This form is used for Automated Clearing House (ACH) payments with an addendum record that contains payment-r: lated information processed through the Vendor Express ProDram. Recipients of these payments should bring this information to the attention of their financialinstitution when presenting this form for completion.
PRNACY ACT STATEMENT The following information is provided to comply with the Privacy Act of 1974 (P.L. 93 579). All information collected on this form is required under the provisions of 31 U.S.C. 3322 and 31 CFR 210.
This information will be used by the Treasury Department to transmit payment data, by electronic means, to vendor's financialinstitution. Failure to provide the requested information may delay or prevent the receipt of payments through the Automated Clearing House Payment System.
AGENCY INFORMATION r rDERAL PROGRW AGENCY U.S. NUCLEAR REGULATORY COMMISSION AGtHCY OENTFER AGDCY LOCATKW CODE (ALC) ACH FORMAT NRC 31000001 O CCcw 0 cTx 0 cTP 15oEis DMSION OF ACCOUNTING AND FINANCE, MAIL STOP T 9 H4 WASHINGTON, DC 20555-0001, 56if5C PERSONNAME TELEPHONE NUheER FINANCIAL OPERATIONS SECTION ( 301 ) 415 7520 PAYEE / COMPANY INFORMATION NAME san NO. OR T AK.* AY9R 10 h 3.
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Instructions for Completing SF 3881 Form 1 Agency information Section - Federal agency prints or types the name and address of the
- Federal Program agency originating the vendor / miscellaneous payment, agency identifier, agency location code, contact person name and telephone number of the agency. Also, the appropriate box for ACH format is checked.
- 2. Payee / Company Information Section - Payee prints or types the name of the payee / company and address that will receive ACH vendor / miscellaneous payments, social security or taxpayer ID number, and contact person name and telephone number of the payee / company. Payee also verifies depositor account number, account title, and type of account entered by your financial institution in the Financial Institution Information Section.
- 3. Financial Institution Information Section - Financial institution prints or types the name and address of the payee / company's financialinstitution who will receive the ACH payment, ACH coordinator name and telephone number, nine digit routing transit number, depositor (payee / company) account title and account number. Also, the box for type of account is checked, and the signature, title, and telephone number of the appropriate financial institution official are included.
Burden Estimate Statement The estimated average burden associated with this collection of Information is 15 minutes per respondent or record keeper, depending on individual circumstances. Comments concoming the accuracy of this burden estimate and suggestions for reducing this burden should be directed to the Financial Management Service, Facilities Management Division, Property and Supply Branch, Room B 101,3700 East West Highway, Hyattsville, MD 20782, and the Office of Management and Budget, Paperwork Reduction Project (1510-0056), Washington, DC 20503.
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NRC INSPECTION MANUAL PIPB MAUllAl CHAPTfP 0A10 INSPECTION REPORTS l i
l I
i l
Issue Date: 07/15/97 0610
i
_ INSPECTION REPORTS Table of Contents -
EE 0610-01 PURPOSE ....................... ..... 1 0610 02 OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . .. 1 !
0610-03 -DEFINITIONS ............................ 1 0610 04 RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . 3 04'.01 Genera'l Responsibilities--Reactor. Vendor, and Fuel Facility Inspections ................... 3 04.02 General Responsibilities--Materials . . . . . . . . . . . . 3 04.03 Report Writing .............. ....... 4 04.04 Report Review and Concurrence . . . . . . . . . . . . . . . 4 04.05 Report Issuance . . . . . . . . . . . . . . . . . . . . . . 5 04.06 Report Timeliness _. . . . . .... .. ....... 5 0610 05 Gul0ANCE - INSPECTION REPORT CONTENT . . . . . . . . . . . . . . . 5 05.01 Observations. Findings, and Conclusions . . . . . . . . . . 6
- a. Observations ..................... 6
- b. Findings .............. ........ 6
- c. Conclusions . . . . . . . . . . . . . . . . . . . . . . 8 05.02 Thresholds of Significance ...............12
- a. Thresholds ~of Significance for Noncompliance '
Issues ........ . . . . . . . . . . . . , 12
- b. Thresholds of Significance for Non Enforcement-Related Issues . . . . . . . . . . . . . . . . . . . 15
-05.03 Level-of Detail . . . .. . . , . -
- . . . . . . . . . . . . 16
- a. .Who is the Reader? ..........,,.....16.
b._ Importance of Overall Conciseness . . . , . . . . . 17
- c. Level'of Detail _on Inspection. Scope . . . . . . . . 17
- d. Level of Detail-on Observations and Findings . . . . 18
'05.04 -Documenting Noncompliances' . . . . . . . . . . . . . . . 19 ,
w 06101 - Issue Date:- 07/15/97-s
-f s' ,
. . . - - .- _ - - _ . . - - -. = .
- a. Types of Noncompliances . . . . . . . . . . . . . . 20
- b. Supporting Details and Discussions of Safety Significance ........ . . . . . . . . . . . 21 l
- c. Noncompliances Involving Willfulness .. . . . . 22 05.05 Documentation of Performance-Based Inspection . . . . . 22
- a. Documenting Performance-Based Issues vs.
Compliance Based Issues . . . . . . . . . . . . . 22 b ._ Documenting issues in Areas Not Covered by ;
Regulatory Requirements . . . . . . . . . . . . . . 24
[
- c. Document'ng Strengths and Weaknesses . . . . . . . . 26
- d. Documenting Management issues . . . . . . . . . . . 28 05.06 Treatment of Open items in Reactor Inspection Reports . . 29
- a. Initiating Open items . ..............29
- b. Follo+Up and Closure of Open items . . . . . . . . . 29
- c. Treatment of Licensee Event Reports . . . . . . . . . 30
- d. Avoiding " Implied" Inspection Fo',lo+Up Items . . . . 31 0610-06 GUIDANCE - INSPECTION REPORT FORMAT ........... . . 31 06.01 Cover Letter .................... . 31 06.02 Cover Page ....... ..............32 06.03 Executive Summary . . ........ ..... . . 33 06.04 Table of Contents . . . . . . . . . . . . . . . . . . . 33 06.05 Re? ort Details: Use of the Standardized Report Outline . 33 06.06 Report Details. Internal Organization of Specific Sections . . . . . . . . . . . . . . . . . . . . . . . 34 06.07 Exit Meeting Summary ..................35 06.08 Report Attachments .-,............ . . . . 36 0610 07 GUIDANCE - lNSPECTION REPORT STYLE . . . . . . . . . . . . . . . . 36 07.01 Peculiarities of Government Technical Writing _. . . . . . 3/
07.02 Clear Organization . . . . . . . . . . . . . . . . . . . 39 07.03 Effe.:tive Revision ..... ,. . . . . . . . . . . 41 !
07.04 Writing Style Guides and Useful NRC References . . . . . .-42 1ssue Date: l'7/15/97-0 - iii - 0610
0610 08 RELEASE AND OlSCLOSURE OF ]NSPECT]ON REPORTS AND ,
ASSOCIATED DOCUMENTS . . . ....... ........ . 43 i
Exhibit 1: Standard Reactor Inspection Report Outline ... . . . . El-1 Exhibit 2: Sample Reactor Inspection Report ........ ... . E2 1 Exhibit 3: Standard Materials inspection Report Outline ... . . . . E3-1 Exhibit 4: Standard Containment and Storage Inspection Report Outline . E4 1 ,
Exhibit 5: Standard Fuel Cycle Inspection Report Outline . . . . . . . E5 1 Appendix A: Noncompliance Information Checklist ........ .. A1 Managing the Writing Process . . . . . . . . . B1 Appendix B: ...... '
Appendix C: Inspection Report Review Checklist . . .......... C1 Appendix D: NMSS Inspection Report Supplement ... ....... . D1 i Appendix E: List of Acronyms Used in this inspection Manual Chapter .. E-1 0610 - iv - . Issue Date: 07/15/97
i INSPECTION REPORTS ,
0610-01 PURPOSE i To provide guidance on inspection report content. format, and style.
NOTE: Much of the guidance in this manual chapter applies to all NRC inspection reports, including reactor vendor, materials. fuel f acility.
Uranium recovery, and decommissioning facility inspections. In some areas. however (e.g. , format. report outline, and certain retters of report content), considerable variation exists. Where this i srue, the main body of this manual chapter provides guidance specifically applicable to reporting inspections at power reactor facilities.
Appendix 0 provides su)plemental guidance specifically applicable to reporting the results of inspections of NMSS licensees. ,
0610 02 OBJECTIVES ,
To ensure that inspection reports:
02.01 Clearly communicate significant inspection results to licensees. NRC staff, and the public.
02.02 Provide conclusions about the effectiveness of the programs or activities inspected. The depth and scope of the conclusions should be commensurate with the depth and scope of the inspection.
02.03 Provide a basis for enforcement action.
NOTE: NUREG-1600 is the NRC Enforcement Policy. The NRC Enforcement Manual (NUREG/BR-0195) gives specific guidance on addressing noncompliances in inspection reports.
02.04 Assess licensee performance in a periodic, short-tend context, and present information in a manner that will be useful to NRC management in developing longer term, broad assessments of licensee performance (e.g., Plant Performance Reviews (PPRs). Systematic Assessments of Licensee Performance (SALPs)).
0610-03 OEFINITIONS Anoarent violation. A potential noncompliance with a regulatory requirement that has not yet been formally cited as a violation in a Notice of Violation or order.
Certificate Holder. An entity res)onsible for meeting certain NRC requirements defined in an NRC issued Certifica:e of Compliance (e.g. 10 CFR Part 71 or Part 72)
Closed item. A matter previously reported as a noncompliance, an exercise weakness, a licensee event report an unresolved item, an inspection follow-up ,
item, or a Part 21 report that the inspector concludes has been satisfactorily resolved._ based on information obtained during the current inspection.
@nclusion. As used in this chapter, an assessment that relates one or more ndings to the broader context of a licensee program or a SALP functional area.
Issue Date: 07/15/97 0610
I Deviation. A licensee's failure to satisfy a regulatory commitment.
NOTE: For 10 CFR Part 21 and vendor inspections, the term " deviation" g' generally refers to the definition given in Part 21 (i.e.. "a departure '
from the technical requirements included in a procurement document").
Draft Insoection Cecort. Any version of the- inspection report before its official issuance, Escalated Enforcement Action. A Notice of Violation for any Severity Level 1.
II, or 11; violation (or problem). or a civil penalty or order based on a violation. '
Dercise Weakness. A finding that the licensee's demonstrated level of preparedness could have precluded effective implementation of the emergency plan .
in the event of an actual emergency (see 10 CFR 50, Appendix E.Section IV.F.2.g). !
findina. As used in this chapter, an observation that has been placed in context und assessed for significance.
-Insoection. The examination and assessment of any licensee activity to determine its offectiveness. to ensure safety, and/or to determine compliance. A single inspection report may encompass resident inspection in office document review, and/or one or more visits by regional or headquarters inspectors: however, a single report is normally limited to a specific period of inspection (e.g., a 6-week period).
I Insoection Document. Any material obtained or developed during an inspection that is considered to be an NRC record (see below).
Insnection Follow Un item. A matter that requires further inspection because of a potential problem, because specific licensee or NRC action is pending, or '
because additional information is needed that was not available at the time of the inspect 1on.
Intearated Inspection Renorts. A reactor or fuel facility inspection report that combines inputs f rom all inspections (resident. region 31. etc.) conducted within a specific period.
Licensee. The applicant for or the holder of an NRC license, construction ,
permit. or combined license.
NOTE: In general, the provisions listed as applicable to " licensees" in i this chapter are also applicable to vendors and certificate holders. ,
Non-Cited Violation (NCV). A violation for which the NRC staff chooses to exercise discretton and refrain from issuing a 10 CFR 2.201 Notice of Violation.
These include: - (1) ' documented minor violations; and (2) Severity Level IV violations that meet the criteria for discretion identified in Section Vll.B.1 of the NRC Enforcement Policy, ,
i Noncomoliance. A violation, non cited violation. deviation, or nonconformance, Nor mformance, A vendor's or certificate holder's failure to meet a contract requirement related to NRC activities (e.g.,10 CFR Part 50. Appendix B), where
-the NRC has not placed the requirement directly on the vendor cr certificate holder,
-0610 -2.
Issue Date: 07/15/91 ,
. ~ = .
Notice of Violation (NOVL A formal written citation in accordance with 10 CFR 2.201 that sets forth one or more violations of a -legally binding regulatory !
requirement. ;
NRC Record. Any written. electronic, or photographic record under legal NRC control that documents the policy or activities of the NRC or an NRC licensee :
(see also the definition in 10 CFR Part 9),
i Observation. A fact; any detail noted during an inspection. :
Opendtm. A matter that requires further inspection. The reason for requiring further 1nspection may be that the matter has been identified as a noncompliance. ,
unresolved item, inspector follow-up item. licensee event report, or Part 21 report.
Potentially Generic issue. An inspection finding that may have implications for otner licensees, certificate holders, and vendors whose facilities or activities are of the same or-similar manufacture or style.
Reaulatory Commitnent. An explicit statement to take a specific action, agreed to or volunteerec by a licensee, where the statement has been submitted in writing on the docket to the NRC.
Reauirement. A legally binding obligation such as a statute, regulation, license i condition, technical specification or order.
Unresolved itelD. A matter about which more information is required to determine -
whether the 1ssue in question is an acceptable item, a deviation, a nonconfor-mance, or a violation, i
Vendor. A supplier of products or services to be used in an NRC licensed flicensee acility or(e.g.
activity,
. . nuclear fuel fabricator, radioattive waste broker)in someorcases, the the vend vendor's product may be required to have an NRC Certificate of Compliance (e.g. .
certain transport packages such as waste casks or radiography devices)
Violation. The failure to comply with a legally binding regulatory requirement, such as a statute, regulation, order, license condition, or technical specifica-tion.
Willfulness. An attitude toward compliance with requirements that ranges from !
the careless disregard for requirements to a deliberate intent to violate or to falsify.
0610+04 RESPONSIBILITIES +
All NRC; inspectors are required to prepare inspection reports in accordance with the guidance provided in this Inspection Manual chapter. General and specific responsibilities are listed below..
04.01 General Resoonsibilities -Reactor. Vg urd Fuel Facility inspections:
Each inspection of a reactor, vendor, and rue @l facility should be documented in ,
a report consisting inspection (of a cover details vendor letter.
reports may7.not cover page, require an executive executive summary, and summaries).
04.02 General Responsibilities--Materials: See Appendix D, the NMSS Inspection
. Report Supplement.
Issue'Date: 07/15/97 0610 .
04.03 Rcoort Writina
- a. Inspectors have the primary responsibility for ensuring that observations and findings are accurately reported, that referenced material is l correctly characterized, and that the scope and depth of conclusions are ,
adequately supported by documented observations and findings. Advice and recommendations are ut to be included in inspection reports. l l
- b. Inspectors are responsible for ensuring that the content and tone of the i report, as issued is consistent with the content and tone of the exit meeting presentation. When the report differs significantly from the i exit meeting, the inspector (or the report reviewer) should discuss those differences with the licensee before the report is issued,
- c. Report writers and reviewers should ensure that inspection reports follow the general format given in this chapter and in the enclosed sample report (see Exhibits 1 5), t
- d. Fo" inspections conducted by regional and resident inspectors, the report ,
number is in the following form: ;
Docket No./ Year sequential number of the report in that year (e.g. 50 363/87 01) for inspections conducted by NRR. NMSS. AE00, etc. the report number is in the following form:
Docket No./ Year 2 followed by the sequential number of the report in that year (e.g.. 50 250/87 201)
NOTE: The report number format given here is for use in the
. inspection report itself, This format may be modified as needed for other applications (e.g. , for Inspection Follow-Up System (IFS) !
entries), due to electronic constraints and other considerations.
04.04 Report Review and Concurrence
- a. Before issuance. each inspection report should, as a minimum, be reviewed by a member of NRC management familiar with NRC requirements in the area inspected.
- b. The report reviewer (i.e., the member of management referred to above) should establish that conclusions are logically drawn and sufficiently supported by observations and findings, and that the observations..
findings, and conclusions are consistent with NRC policies and require- i ments,
- c. The report reviewer should ensure that assessments made in the inspection report represent the judgment of the issuing organization and estaalished NRC policy rather than solely the personal views of an individual inspector or group of inspectors.
- d. Regional administrators and office directors should establish internal ,
procedures to 3rovide a record of inspectors' and reviewers' concurrences. The procedures should address how to ensure continued inspector concurrence when substantive changes are made to the report as originally submitted, and how to treat disagreements that occur during the- review process . - As a minimum. Substantial changes should be
'0610? -4e issue Date: 07/15/97.
=- -__ --_ - _ . -- - ., . -- -- -
\
l discussed with the inspector or inspectors involved to ensure continued l concurrence, and disagreerrents that cannot be adequately resolved should ;
-be documented. I l
NOTE: The record of inspector and reviewer concurrence is ;
, maintained by the issuing office. This concurrence record is not I included in the generally distributed version of the re, cort. l 04.05 Report issuance l
- a. for regional inspection reports. the ap)licable division director or designated branch chief is responsible "or the report content, tone, conclusions and overall regulatory focus for integrated reports issued to reactor licensees, the Division of Reactor Projects (DRP) division ,
director or designated branch chief is responsible for issuing the report !
to the licensee,
- b. for NRR reactor reports or NMSS materials and fuel cycle inspection reports, the technical division director or designated branch chief is -
responsible for the report content, tone. conclusions, and overall regulatory focus, for NRR reports of vendor inspections, the Chief.
Special Inspections Branch holds this responsibility. Where applicable.
headquarters report distribution should ae consistent with that of the regions.
04.06 Report Timeliness
- a. General Timeliness Guidance. The goal for issuing inspection resorts is 21 calendar days af ter inspection completion (30 calendar cays for integrated reports and major team inspections). Although this goal may .
not be met in all cases, the report should be issued no later than 30 calendar days after inspection completion (45 calendar days for ;
integrated reports and major team inspections).
NOTE: Inspection completion is normally defined as the day of the exit meeting. For resident inspector and integrated inspection reports, ins)ection completion is normally defined as the last day covered by tle inspection report,
- b. Renorts Precedina Escalated Enforcement Actions. Timeliness goals should 3e accelerated for inspection reports covering potential escalated enforcement actions. For specific enforcement timeliness goals, see the NRC Enforcement Manual.
- c. Exnedited Reports for Sionificant Safety issues. Whenever an inspector identifies an issue involving significant or immediate public health and safety concerns the first priority is- facility and public safety: Issues of documentation or enforcement action are secondary. Based on the circumstances of the case, an expedited inspection report may be prepared that is' limited in scope to the issue, or expedited enforcement action may be taken before the inspection report is issued. The NRC Enforcement Manual provides additional guidance on matters of immediate public health
-and safety concern.
0610 05 GUIDANCE --INSPECTION REPORT CONTENT
.This section relates primarily to matters of content in the inspection report details. Some guidance on the content of-report cover letters and executive issue Date: 07/15/97 -5. 0610
summaries is given in Sections 06.01 and 06.03, respectively.
1 05.01 Observations. Find 1nns and Conclusions. As used in this chapter, the term " observation" refers to a fact- any detail noted during an inspection. The term " finding" designates an observation that has been placed in context and assessed for its significance. The term " conclusion" is used for an assessment that relates one or more findings to the broader context of a licensee program or a functional area.
Adherence to the use of these terms is less important than appreciating the underlying process. Achieving relative consistency in inspection report content first requires a common understanding of how inspection observations are assessed for significance, and how the resulting findings may be combined to reach a conclusion about the adequacy of the program or activity inspected.
- a. Observations. The most basic results of an inspection are the facts an inspector gathers -through watching work activit' es. examining equipment. <
interviewing licensee employees, reviewing records, and other ins)ection methods. As documented, these observations should be factual- tlat is, an inspector should not report hunches, unsubstantiated hearsay, or unverified opinions.
Consider an ins)ection in which a maintenance worker states that a particular pump las excessive shaft leakage, and the inspector wants to make this an inspection observation. If possible, the inspector should physically observe the pum) to verify the maintenance worker's statement. '
If the pump is inaccessib'e. or the leakage has already been corrected.
the inspector should attempt to verify the >eriod of excessive leakage through log review, maintenance records, ciscussions with additional plant personnel, or some other method.
When documenting an observation, use language that clearly identifies how the observation was discovered and verified (see also the discussion on active voice in Section 07.01.b.3):
BAD: "The chemical and volume control system (CVCS) make-up pump had excessive shaf t leakage " OR "It was noted that the CVCS make-up pump had excessive shaft leakage."
GOOD: "A maintenance worker informed the inspector that the CVCS make up pump had excessive shaft leakage. The inspector verified this information by observing the pump in operation." OR ". . . by '
reading the operator logs for June a 6."
NOTE: Neither of these statements explain the significance of the observation, nor the criterion used. -See the additional examples below, Other factual information may be relevant to an observation, such as the time of discovery, the length of time the problem existed, the type, size, or model of the equipment, and so forth. Section 05.03 discusses '
how to determine the appropriate level of detail.
- b. Findinas. Although inspectors are frequently told to " bring back the facts." NRC managers also expect those facts to be assessed for significance. Reports should be free of " dangling observations"--that is. items that leave-the reader unclear as to (1) how the observation relates to a requirement or standard. (2) whether the observation is 0610 Issue Date: 07/15/97
positive or negative. and (3) how significant the issue is. By answering these questions. inspection observations become inspection findings. .
- 1. Referentina ' Recuirements and Standards. Whenever possible, an observation should be related to a requirement or standard. Often this context is achieved by direct numerical comparison:
EXAMPLE: "The inspector observed, on control room Panel R442, that service water flow through residual heat removal (RHR) l Heat Exchanger B was indicating approximately 5900 gallons per ;
minute (gpm). The surveillance minimum service water flow, as given in TS 4.5.2.e. is 6500 gpm."
For some observations, the standard to be referenced will be cualitative. For example, in making an observation about the ;
licensee's replacement of in core detectors with a different design, the inspector may wish to reference 10 CFR 50 Appendix B. Criterton 111. Design Control." or may choose to reference, more specifically, an approved licensee procedure.
When the area of the observation is not covered by regulatory requirements, the ins)ector 'should still attempt to clearly state the expected standarc of performance. For example, suppose the inspector discovers that, as the result of a poor shift turnover, control room operators are not initially aware of an ongoing test elsewhere in the ,. ant. Depending on the significance of the test. '
the inspector may wish to document this observation. even in a case that is not covered by a specific requirement. In such a case, the inspector should use inspection procedures and discussions with NRC and licensee management to arrive at a clear statement of expected i performance. This statement should then be used in the report:
EXAMPLE: "In discussions with the control room operators. the ,
inspector determined that they were unaware. of a test in
)rogress on the make-up water storage tank level transmitter.
Further discussion and log review revealed that the level transmitter test had begun during the previous shift. but had -
not been discussed by the control room operators at shift turnover.
"The inspector discussed with the operations manager the licensee's expectations for conduct of shift turnovers. The operations manager stated that shift turnovers should include discussion of all evolutions in progress that could affect safe operation of the plant."
NGTE: For additional discussion of inspection in areas beyond regulatory requirements, see Section 05.05.b.
- 2. Clarifyino Positive /Neaative Status, The reader should usually be lef t with a clear sense of whether an observation is positive or negative. Often this is made obvious by the context, or by relating the observation to a requirement or standard. If the observation is
" neutral" and does nol relate to a requirement or standard, the inspector should question whether the item is significant enough to be documented at all. In some cases, a significant " neutral" observation can be- placed in context by its relation to past performance:
Issue Date: 07/15/97 -0610
EXAMPLE: " Total external exposure for Refueling Outage 2R6 eas 321 rem, which slightly exceeded the outage goal of 315 rem.
The total external exposure received was 15% higher than the total for the previous outage. According to the licensee's analysis, this difference was primarily due to the extensive steam generator tube sleeving and plugging performed during 2R6."
See also the discussion on documenting strengths and weaknesses in Section 05.05.c.
- 3. Providino Context for Sionificance. Fully assessing the significance of an observation requires consideration of many factors: Who was involved in the issue? What was the actual or potential safety significance?. What were the root causes? Has this occurred before? Is a trend or pattern developing? Who found the problem? Should it have been found by the licensee sooner? What was done to correct it? Were those corrective actions prompt and i thorough? How does the licensee characterize the significance of this matter?
The report need not always answer each of these questions, and need not ex1austively provide every supporting detail for every observa-tion. The inspector should weigh the circumstances impartially, and should include in the report those details that contribute to understanding the significance of the observation -regardless of whether they make the finding appear more severe or more benign.
NOTE: An inspector should always document certain supporting details for enforcement-related findings. On the other hand.
inspectors should be careful not to make direct statements, in the report details, regarding the safety significance of the noncompliance (see Section 05.04.b).
Since the process of assessing significance (or translating observations into findings) is subjective. it requires skill, experience, and judgment, and demands that the inspector carefully consider :11 viewpoints. The inspector should make every effort to understand and fairly characterize the licensee's perspective. In addition, the inspector's final assessment of a findir 's signifi- .
cance should be validated through discussion with other inspectors and with NRC management.
- c. Conclusions. Conclusions are general statements of assessment that relate one or more findings to the broader context of the licensee program or functional-area inspected. Conclusions can easily be made too narrow or too-broad: the report writer's task is to match the scope of the conclusions to what the inspection findings will support.
- 1. Conclusion Scoca.. The scope of a conclusion is usually dependent ,
upon _what amount of. inspection focus was directed toward a given area. For example: if a regional radiation cpecialist devotes an onsite week to inspecting the licensee's external exposure controls, the resulting report or report section should offer a conclusion about the status ~ of - the external exposure control Drocram. By contrast, suppose that the resident. notes two instances during a 6-week : period in which radiation signs were improperly placed (or ,
missing): the resident's findings are useful but are probably ng1 -
0610 8- Issue Date: 07/15/97
grounds. Independently. for making a broad conclusion about the relative health of the licensee's external exposure control program.
For a report writer to conclude that an overall program or ,
functional area is " declining." " marginal." " inadequate." or
" displaying significant weakness" (or, on the positive side.
" improving." " superior." or " considered a strength")--the inspection observations and findings must be sufficient to substantiate the ,
conclusion. A broad negative conclusion should be based on specific findings of unsafe practices. ineffective programs or activities.
operator or supervisory oversights, significant procedural inadequacies, etc. Conversely, a broad positive conclusion should be supported by findings of sustained safe performance. innovations to improve safety and rel.1 ability, efficient execution of complex tasks, programatic upgrades that improve safety or correct previous
- weaknesses, etc. ,
i Even in integrated reports, the inspector rarely has sufficient material to justify drawing broad conclusions on licensee performance in each overall functional area (e.g., " performance in the area of Engineering was excellent"). Depending on the focus of the individual inspection, however, the inspector may be able to draw meaningful conclusions about specific licensee programs (e.g..
fitness for duty program, outage work scheduling. in service inspection program) or nortions of a specific functional area (e.g..
motor operated valve maintenance, emergency drill performance, fuel handling operations).
NOTE: In reaching a conclusion, the inspector sometimes considers and integrates related information from a previous inspection report. In such a case, the inspector should briefly summarize the previous inspection information or .
reference the previous inspection report.
Frequently, the findings in a given program area will be mixed (positive and negative), or the limited scope of inspection in a particular area will only support a correspondingly limited conclusion, in such cases, the inspector should neither " force-fit" a broad conclusion nor restrict the conclusion scope to a simple restatement of the findings. Where applicable, the conclusion should account for both negative and pos1tive findings. '
EXAMPLE: Suppose that the resident inspector, during plant tours, makes a practice of verifying valves and circuit breakers to be in the position required- by technical specifications (TSs) and licensee procedures for the applicable plant mode. During a 6-week period in which such verifications are routinely performed, the inspector finds two instances of a particular breaker-being inappreariately closed to power a local receptacle. In each case' ;he inspector mentions the observation to the operatSns shift r" nager, who is unaware of the breaker closure, desp te- 1% / se policy that says the shift manager should be aware o (in conditions. After the second instance, the operations agvisor issues a control room directive to formally track any closures of this breaker.
An NOV is issued with the report.
In addition to the violation, what rmclusion can be drawn from Issue.Date: 07/15/97 0610
--v -
-e r ,- >
this information?
100 NARROW: "The inspector concluded that the operations shif t manager needed to be more aware of when MC 5B2 Breaker 13 was being used for welding."
T00 BROAD: "The inspector concluded that the operations control of plant configuration management needed improvement."
APPROPRIATE: "The inspector concluded that, while overall operations control of valve and breaker lineups was satisf actory during this period, the observed discrepancies and associated violation indicated a need for improved shift manager awareness of local breaker manipulations."
- 2. Conclusion focus. In general, conclusions should focus on the capab111ty of the program or activity to accomplish its design basis function, in assessin may take various forms,g this capability, the conclusion statementsbu supportable.
(a) For inspections of hardware components or systems, conclusions should seek to answer questions such as the following:
e is the component or system capable of performing the safety functions required by eit1er its design or licens-ing basis?
e is testing (and/or maintenance] adequate to demonstrate that the component or system would perform all of the safety functions required?
e is training adequate to ensure proper operation and maintenance of the component or system?
e Are control functions effective and reliable?
e Are human factors considerations relating to the component or system (e.g. , accessibility and labeling of components) adequate to ensure proper system operation?
e Are system procedures adequate to ensure proper system operation under normal and accident conditions?
Additional. similar questions may be developed based on the applicable ins)ection procedure. Answering these questions sloald 9sult 'n conclusions such as the following:
EXAMPLE: Based on aspects observed during the system walkdown, as described above, the emergency diesel generators were capable of performing the safety functions required by their design basis.
EXAMPLE: As described above, the surveillance testing observed during this inspection was thorough, consistent with industry standards, and suf ficient in scope to demon-strate that the reactor protection system would perform its required safety functions.
(b) Conclusions can also be helpful by assessing improving or declining performance in the particular area inspected:
EXAMPLE: As evidenced by the discrepancies discussed 0610 Issue Date: 07/15/97
above. plant material condition in the turbine building areas around the main feed and condensate systems had declined since the previous inspection.
Since the NRC inspection program only samples a portion of licensee activities, report writers should be careful in making statements about a perceived trend, to ensure: (1) that the focus of the statement is accurate in scope (i.e., not overly broad) and is based on an adequate sample of observations: (2) that a perceived improvement or decline does not simply reflect '
a lack of earlier observation in the area of focus; and (3) that the comparison of past and present performance involves the same specific licensee program area (e.g., the report should not assess an improving trend based on comparing the present excellent procedural adherence of the control room operators to a past problem involving the procedural adherence of auxiliary operators).
(c) for an inspection that has focused on an overall program, the conclusion should assess the basic capability of that program in meeting its safety objectives. In some cases, the safety objectives may be found in the applicable ins)ection procedure.
If the safety objectives have not been s>ec'fied elsewhere in .
the report, the conclusion should make tie objectives clear.
EXAMPLE: Solid radioactive waste controls are intended to minimize the volume of radioactive waste and ensure safe transportation of radioactive materials. Based on aspects observed during this inspection and discussed above, the inspector concluded that the licensee's solid radwaste program was effective in meeting these safety objectives.
(d) Finally, conclusion statements should note any noncompliances 7 described in that section of the report:
EXAMPLE: The overall conduct of outage maintenance observed during this inspection was controlled and thorough, and was appropriately focused on ensuring system and component safe;y and reliability. One violation was -
identified, as described above, concerning a failure to :'
properly tagout certain isolation valves before draining the "B" auxiliary feed header for maintenance. ?
Note that these conclusion statements are illustrative and are not intended to be used exactly as written. In addition, other types of conclusion statements may be appropriate in certain situations.
3, Insoection Reoort Conclusions vs. SALP or PPR Conclusions. NRC ,
assessment is an ongoing process, in which periodic, short-term evaluations (such as inspection reports and licensee self-assess-ments) are constantly integrated into longer-term, " big picture" '
evaluations (such as SALPs and PPRs), Just as a report section combines -findings to reach conclusions, so the SALP and PPR processes integrate the. findings and conclusions of multiple inspection reports to support broad conclusions.
Report conclusions should-be written in a manner to support this ,
overall assessment and integration process. As stated above. this issue Date:. 07/15/97 0610
,, .,y..w,_--_.. ,,_v.-.
l does not mean that each report should, for example, provide an overall assessment of the Maintenance SALP functional area.
However. if a succession of three or four reports each make well- l supported conclusions about a portion or portions of the maintenance ]
area (e.g., maintenance work control and scheduling, plant material condition, conduct of mechanical (or electrical or 1&C) maintenance, j adherence to maintenance procedures, maintenance personnel knowledge and performance, maintenance facilities, accuracy of maintenance )
records, etc.), the PPR covering that period should be able to integrate those assessments into a well-supported conclusion about i the overall maintenance program.
A thorough understanding of this concept adds perspective to the inspection process, Effective regulation requires the initiative to draw sound conclusions and demands a sense of the " big picture":
however, this does ng1 mean that, when an inspector makes an '
observation, he or she should immediately leap from that observation to a broad conclusion, Rather, each observation should be placed in context, findings should be related to other findings (and may provide the basis for further inspection), and reports and other NRC assessment processes should seek to incorporate those findings into ever broader conclusions.
05.02 Thresholds of Sinnificancs, At most licensed facilities, every day of operation involves hundreds of people, dozens of evolutions, and multiple plant systems. Problems are identified and resolved daily: most licensees process large numbers of " Corrective Action Requests" or similar problem tracking mechanisms. Within this scenario, the NRC inspector essentially performs an auditing role: he or she cannot hope to monitor all the activities in progress, ,
nor to document every minor discrepancy that occurs. As part of maintaining a focus on safety, inspectors continually use NRC requirements, inspection
)rocedures, risk assessment documents, industry standards, regional and leadquarters guidance, and their own training and insight to make judgments about which issues are worth pursuing and which are not.
To communicate effectively, inspection reports must give evidence of that judgment and prioritization, discussing significant safety issues in appropriate detail, treating less significant issues succinctly, and avoiding excess verbiage. To maintain some consistency in how minor issues are treated, report writers must recognize certain " thresholds of significance": that is, they must use similar criteria in deciding whether an issue is important enough to document, important enough to track or follow up, etc.
- a. Thresholds of Sinnificance for Noncomoliance Issues. The NRC Enforcement Policy acknowledges that some violations of minor safety, environmental, and regulatory concern are below the level of significance of Severity Level (SL) IV violations. Because of their minor nature, these violations (previously categorized at SL V) are not the subject of formal enforcement action and are not usually documented in inspection reports.
NOTE: For additional guidance in this area, see the NRC Enforcement Manual,
- 1. Minor ' Violations--Determininn Sinnificance, When an inspector recognizes that a violation has occurred, the determination of -
whether the violation is minor or "more-than minor" should be based on answering the following questions: ,
0610 Issue Date: 07/15/97
o Does the violation have any actuel impact (or any realistic potential for impact) on safety?
e Joes the violation suggest a programmatic problem that could have a safety or regulatory impact?
e Could the violation be viewed as the possible precursor to a significant event?
e 11 the violation inadvertently recurred. Would its recurrence be a more significant safety concern?
e if inadvertently lef t uncorrected. would the violation become a more significant safety concern?
e Are there associated circumstances that add regulatory concern to this violation (e.g., apparent willfulness. licensee refusal to comply. management involvement. etc. )?
If the answer to any one of these questions is "yes." the violation should be not be considered a minor violation. If the answer to all the questions is "no." the violation should be considered minor.
Note that. based on these questions, for cases in which a licensee does not take corrective action or repeatedly or willfully commits a violation that would otherwise be characterized as minor, the matter should be categorized as at least SL IV, and 6 formal re-sponse required.
EXAMPLE: Suppose that the control room night orders require that operators assess and log the status of a certain piece of equipment by 1:00 a.m. on every mid-shif t. The inspector reads 3 months of control room logs, and finds two instances in which this status was not assessed until 1:30 a.m. After reviewing plant conditions, the potential impact, and associated circumstances, the inspector answers each of the above questions with a "no." and determines that the matter was a minor procedural violation. Being minor, this violation need not be documented in the inspection report.
EXAMPLE: Suppose that an inspector is observing maintenance workers remove protective clothing when exiting a radiologically controlled area. In an isolated instance, one worker forgets to remove his protective hood until stepping over the boundary into the clean area. The radiation protection (RP) technician reminds the worker: the worker acknowledges the error, carefully removes the hood, and places it in the appropriate receptacle. The inspector notes that a violation of procedure has occurred, but finds no associated safety concern, and decides that the overall process was appropriately controlled. The inspector determines that the matter was a minor violation, and need not be documented.
EXAMPLE: As a variation on the previous example, suppose the maintenance workers as a group are incautious in removing their protective clothing, paying little attention to cross-contamination or posted signs, joking boisterously while frisking, ignoring the RP technician's directions and attempts to control the spread of contamination. As in the previous instance, the inspector notes the same violation of licensee procedures: based on the circumstances, however, the inspector determines that this is clearly more than a minor violation, and therefore merits both documentation and follow up.
Issue Date: 07/15/97 0610
I
- 2. Minor Violations Determinina Whether to DocyLnt. In general.
minor violations should agi be documented; bcwtver, certain
, exceptions apply. Documentation may be necessary as part of the ,
l resolution to an allegation. In other cases, while the /jolation '
itself is minor, the associated technical information may relate l directly to an issue of agency wide concern (e.g., the inspection was performed in response to an NRC Temporary Instruction (TI)).
i If, for these reasons or any other reason. the report writers and-reviewers wish to document a minor violation. then it should be documented as an NCV, with a reference to Section IV of the !LRC r Enforcement Policy. l
- 3. Violations identified as Part of Licensee Self-Assessments. Under certain circumstances, even a violation that could be classified as SL IV (*more than minor") need not be documented. This is generally justified when the violation has been identified and corrected as
) art of a licensee self-assessment effort. As a matter of policy.
1RC enforcement seeks to encourage licensee self-assessment efforts, and seeks to avoid the negative impact- that can result- from a ;
redundant NRC emphasis on problems wh'ch the licensee's responsible action has already identified and corrected. ,
For example. suppose that while evaluating the licensee's quality assurance efforts in the fire protection area, an inspector reviews relevant audits and surveillances conducted over the previous year.
The review reveals that the audits have been probing and thorough: '
the findings are well developed and technically sound, and include ,
six noncompliance issues, four of which might be classified at SL IV.
In such a case, the inspector should follow up on the noncompliances and other audit findings to ensure that root causes have been appropriately assessed, that appropriate and comprehensive corrective actions have been tak.en, and that no new examples of the violations exist. Provided, however, that no new problems are revealed by this follow-up the inspector is normally not expected to cite the four violations individually, nor to report the details of those violations in the inspection report. Instead, the NRC report findings and conclusions should assess the adequacy of the .
licensee's quality assurance efforts, including a clear reference to !
the name, dates, and general subject matter of the audit or self-assessment.
NOTE: This expectation only applies to SL IV violations. Even when identified through a licensee self assessment, violations that could be categorized at SL 111 or above mmt be documented in the inspection report and given appropriate follow-up, in some instances, reasons exist to document one or more of the violations found in a licensee - audit or self-assessment. .For example, if the report concludes that the licensee's self assessment was especially positive or negative, one or more examples should be given to support that conclusion. As another example, if the licensee's audit or. self-assessment findings reflect on overall '
licensee performance in a way that reveals a trend or would contribute meaningfully to the next PPR or SALP assessment, the particular-findings may be documented (and, if documented, should be
. appropriately dispositioned).
0610 14.- Issue Date: 07/15/97
In addition, the inspector may decide to document one or more of the violations found in a licensee self-assessment due to the technical significance or generic implications of the particular item.
Technical details surrounding the violation may provide useful insight on equipment or system reliability, or on some aspect of human performance. In some cases, the inspector may decide to pursue additional follow up of a oarticular licensee finding because of related licensee problems, previous NRC observations or violations involving the same or a related topic, or emerging agency or industry sensitivity in the given technical area.
If, for any of these reasons, the inspectcr decides to discuss in the inspection report a particular licensee self-assessment finding or audit finding, and that finding involves a violation, then the violation must be clearly dispositioned in the report. If the criteria of Section Vll.B.1 of the NRC Enforcement Policy have been met (including licensee corrective action, etc.) the violation should be documented as an NCV.
Note, finally, that the discussion in this subsection applies to violations identified through licensee audits and self assessments (i.e., cases in which the NRC's inspection is focused on the licensee's quality assurance efforts), and should n01 be applied to all licensee-identified violations. When the inspector pursues an issue as part of day to day licensee observation or other normal inspection activities, tre decision on whether to document the issue should be based on its significance (see discussions in 05.02.a.1 and 05.02.b). Unless the inspection is specifically focused on licensee auditing and self-assessment capability, violations of more-than-minor significance should be documented and dispositioned, regardless of whether they are NRC- or licensee-identified.
NOTE: The NRC Enforcement Manual provides additional guidance on documenting and dispos 1tioning violations.
- b. Thresholds of Sicnificance for Non Enforcement-Related issues.
Inspectors must also make Judgments about the relative significance of non-enforcement-related findings. As with enforcement issues. the judgment of individual inspectors will differ: cuestions on the relative significance of an issue should be discussed with other inspectors and with NRC managers.
- 1. Determinina the Sionificance of Neoative Findinas. The following questions should be used to determine whether or not a finding should be documented in the inspection report:
- Does this finding have any actual impact (or any significant potential for impact) on safety?
e Is this finding illustrative of a programmatic licensee problem that could have a safety or regulatory impact?
e Does this finding provide insights on an equipment, system. or human performance problem?
e Could this finding be viewed as the possible precursor to a significant event?
e If the licensee takes no action on this matter, will the condition worsen (i.e. . will the safety significance increase)?
e if this finding recurs, will its recurrence result in more significant or additional safety concerns?
Issue Date: 07/15/97 - 1E - 0610
l o Will this information be useful in assessing the long-term 3erformance of this licensee program or functional area?
e )oes this finding have generic significance?
If the answer to any one of these questions is "yes," the finding should be documented in the inspection report. If the answer to all
, questions is "no." the finding normally should not be documented.
- 2. Determinina the Sianificance of Neutral or Positive Findinas. For neutral or positive findings or for licensee improvements, similar thresholds of significance should apply. The inspector should ask questions similar to those below:
e Does this licensee improvement have an actual positive impact (or a significant e Will the licensee' potential for positive impar.t) on safety?s efforts to effect ch likely to result in programmatic improvements to safety or regulatory performance?
e Will this upgrade be likely to result in improved equipment or system reliability or improved human performance? Does this information provide useful equipment, system. or human 3erformance insights?
e )c,es this licensee action significantly reduce the probability of a particular event?
e Will this information be useful in assessing the long-term aerformance of this licensee program or functional area?
e loes this finding have generic significance?
If the answer to any one of these questions is "yes " the finding should be documented in the inspection report. If the answer to all questions is "no." the finding normally should not be documented.
NOTE: Ins)ectors should use care in giving credit or making strong positive statements for a proposed licensee action that has not yet been im)1emented, is in early stages of implemen-tation, or has not 3een verified by the NRC.
- 3. Findinas Previousiv Covered in Licensee Self-Assessments. This decision should be treated similarly to the corresponding decision for enforcement issues. In general, little benefit exists in NRC's re-emphasis of issues already covered in licensee self-assessments, unless there is some problem with the licensee's actions.
In some instances. however, the technical significance or generic implications of an issue merit ensuring that it is discussed on the docket and preserved is a matter of public record. If the licensee self-assessment that initially discussed the issue is already on the docket. the inspection report may simply refer to the discussion in the licensee self-assessment. If more detail is needed, or if the licensee self-assessment is not on the docket, the inspector may wish to discuss the issue in the inspection report narrative.
J5 03 lav.f of Oct61.1 Just as inspectors must use judgment in determining what
-ishes are worth including in the inspection report. so they must also determine the appropriate level of detail for issues that are included. Some issues should be discussed in more detail than others, based on safety or regulatory significance, technical complexity, and other f 7 mrs.
1 0610 Issue Date: 07/15/97
- a. Who is the Reader? In writing any technical or business document, the most basic step in ensuring the appropriate level of detail is to have a clear sense of the reader- his or her background, priorities, and level of expertise in the subject area. Inspection reports have multiple readers, with varying levels of technical expertise (including individuals at all levels of the NRC and licensee staffs, other licensees, vendors, industry groups, public interest groups and members of the general public). The principal reader, however, is the person to whom the report cover letter is addressed.
For reactor licensees. this is generm y the vice president, nuclear, or a similar high-ranking company off ( . The report should be written, therefore, with a corresponding hs af technitt detail, so that it will be understood by a knowledaeable mdiviual conversant with nuclear technoloav, but who may not be an expert in the specific area inspected.
Plant-specific design features, relevant procedures, event-specific details, and other factual information should be presented in sufficient detail to allow this " target audience" to understand the characteristics and significance of the inspection findings.
NOTE: Sea also the discussion on using technical, legal, and local jargon in Section 07.01.d.
Finally, the report writer should cc) sider that he or she is writing for the " record"--the docket file that chronicles official NRC interactions with the licensee. While the " record" is not a reader in the usual sense, the writer should be aware that later readers who use the docket file for research and historical perspective will frequently be dependent on the level of detail in an inspection reacrt. Certain types of detail can be especially helpful for these reacers: knowing the inspection procedure used, the exact component (or system or train) inspected, the component manufacturer (where relevant). the revision number of a referenced liensee procedure the date time, and duration of a plant event or transient, and similar details. This awarness--that one is writing for the record--should not be taken as an incentive to write long narrative descriptions, but it Lhoqld provide motivation for writing precisely.
- b. Imoortance of Overall Conciseness. For most writers, the second step in ensuring an appropriate level of detail lies in learning to differentiate between information that contributes to ur.derstanding the findings and information that detracts or merely adds verbiagc. The details used to describe any given finding should be scrutinized from this standpoint, and the non-essential details pared away. if properly performed, this 3rocess will result in a clearer presentation of the findings and a 3etter comm eicated message overall.
In learning to write concisely, many inspectors will need to overcome a widely held but naive assumption that a shorter (or less thick) inspection report is a report of less merit. The report is not intended to be a lengthy discourse of activities carried out so as to justify the time spent or k demonstrate knowledge of a particular technical area.
For any given report section, if no safety or noncompliance issues were identified, then all that is needed is a brief summary of the inspection me' hods, a succinct characterization of the activities observed, and any supportable conclusions on program adequacy.
- c. Level of Detail on insoection Scoce. The level of detail here should be Issue Date: 07/15/97 0610
minimal. Inspectors sometimes fall into the habit of inserting long "boilerplate" paragraphs at this point to establish that the inspection program is being implemented:
EXAMPLE: "The inspectors performed walkdowns of the accessible portions of various engineered safety feature (ESF) systems. In performing these walkdowns, the inspectors verified the proper installation of hangers and supports; the adequacy of housekeeping; correct valve position and conditions: the absence of ignition sources: proper labeling, lubrication, and cooling of major components; operational status of support systems, including instrumentation; consistency of significant process parameter values with expected values . "
Descriptions of this sort serve little purpose. They are usually copied from previous inspection reports or paraphrased from the inspection procedure, and they are rarely read. A simple reference to the inspection procedure used serves the same purpose, since inspection procedures are publicly available. Detailed descriptions of inspection methods or of "what was inspected" should only be 1.1cluded when they are needed to understand or add perspective to the inspection findings. A tabular format is frequently useful:
EXAMPLE: "Using Inspection Procedure 71707, the inspectors walked down accessible portions of the following ESF systems:
- Emergency Diesel Generator 2 e High Pressure Coolant Injection e Core Spray System. Train 1 "
This level of detail is normally appropriate when reporting a review of licensee procedures, observed work in progress, routine plant evolutions monitored, or similar inspection activities.
For certain types of inspection activities, more detail is appropriate, as follows:
- 1. When the inspector is present during a significant plcnt event or an unusual plant evolution, more detail may be appropriate concerning which portions of the event or evolution were actually observed.
- 2. For construction inspections or inspections of significant plant modi fications , strong emphasis is generally given to quality verification of newly installed or re-worked plant components or systems. In such cases. the description of inspection activities should be very detailed about what the inspector actually examined (e.g. , a listing of welds observed or radiographs reviewed). A tabular format may still be useful for presenting these details.
- d. Level of Detail on Observations and Findinas. Once the inspector has decided that a finding 1s important enough to be included in the report the same questions used in making that decision (see Section 05.02) can assist in determining the appropriate level of detail. The following guidance applies:
- 1. The degree of actual or potential safety consequence associated with a finding should be a primary consideration in determining the level 0610 - le - Issue cate: 07/15/97
_ of appropriate detail. Items-of higher significance generally merit
'more discussion.
- 2. If the inspector has concluded that a finding has programmatic aspects-(e.g., multiple examples of the problem a related series of failures, an underlying -training deficiency. or diverse effects ,
~
resulting from the same root cause), enough detail should be given to support this conclusion.
- 3. Findings of greater technical significance--that is, findings that give insights into equipment. system. or human performance issues.
or findings that could have generic significance--should be discussed in sufficient detail to communicate those insights.
- 4. When the inspector has identified that a particular finding has added significance based on= risk, that perspective should be explained. For exam)le. if the inspector finds that two components-with reliability pro 31 ems are related by a dominant event sequence.
that relationship should be explained.
S. As a general rule, " neutral" assessments should be described in less detail than Jositive or negative findings. For example, a report section shou'd not provide a detailed description of the licensee's conduct of various plant evolutions, only to conclude that "no problems were observed." In some cases, sufficient detail may be given simply by concluding that the licensee's program met certain expected criteria (e.g., "as of July 199 . the external dosimetry
)rogram had passed re-accreditation by the National Voluntary
_aboratory Accreditation Program").
Additional " neutral" details may be warranted when reporting certain performance indicators or similar information that will be useful in assessing long-term performance in a licensee program or functional area:(e.g., annual radiation exposures outage length, size of the mechanical maintenance backlog, number of radwaste shipments over a given period, etc.). These details can usually be given additional useful perspective by comparisons with previous performance or the performance of another facility of the same licensee.
- 6. Positive findings normally should be described with less supportive detail than negative findings (i.e., positive findings normally do not merit supportive detail on root cause, previous examples, related performance, etc.). If the inspector concludes that the licensee s performance in a particular area was superior or Joor, then the volume and nature of documented observations shou ~ d be sufficient to justify making that conclusion (see Section 05.05.c).
As noted above,- the- negative observations may warrant additional
' detail based on significance.
- 7. When initiating an unresolved item or inspection follow-up item, the issue description should provide enough background information that a different inspector, using that information, would be equipped to perform-the follow-up inspection.
05.04 Documentino Noncomoliances. The primary guidance for all matters related to enforcement, includ1ng documentation. is given in the NRC Enforcement Policy (NUREG-1600), and the NRC Enforcement Manual (N4 REG /BR-0195). The fol-lowing discussion, summarizes certain aspects of that guidance related to inspection -
Issue Date: 07/15/97 - 19.- 0610
reports.
The manner of documenting a noncompliance in
- a. Tvoes of Noncomnliances.
the inspection report de) ends on how that noncompliance will be dispositioned. A noncomp'1ance may be addressed' as a non escalated enforcement action (i.e., an SL IV violation, a-deviation, or a nonconformance): as an escalated enforcement action (i.e., an apparent SL
- 1. 11. or 111 violation): or as an NCV.
Note that a noncompliance may DD.t be documented simply as a " weakness."
" licensee failure." or a similar informal char 0cterization. If the report narrative describes a condition or event in a manner that suaaests to the reader that a violation may have occurred, then the finding must be clearly dispositioned as a violation, an apparent violation, or an NCV. If a violation does Dat exist' (e.g., no requirement exists in this area), it may be appropriate to clarify the finding by stating that "this condition [or event] does not constitute a violation of NRC _ require-ments."
L Non-Escalated Enforcemer,t ActLq0ji. Most violations of moderate significance (i.e., more than minor cuncerns) fall into the SL IV category, if at the time of issuing the inspection report a violation has been categorized at SL IV, then an NOV is generally sent out with the inspection report, as a "non-escalated" enforcement action. The cover letter for reports that include non-escalated enforcement actions should follow the appropriate NRC Enforcement Manual guidance.
. NOTE: A violation's severity level should not be discussed in the report details. Whether an NOV accompanies the report or is issued later, the designation of severity level is made in the NOV itself.
Deviations and nonconformances are also considered non-escalated enforcement actions. - When a licensee fails to meet a regulatory commitment or to conform to the provisions of an applicable code or industry standard, the failure may result in a Notice of Deviation.
When a vendor or certificate holder fails to meet a contract requirement related to NRC activities, the failure may result in a Notice of Nonconformance. While less frequently issued than SL IV NOVs. these non-escalated enforcement actions follow ; similar fermat and require a similar level of report detail.
- 2. Potential Escalated Enforcement Actions. When an issue is being considereu for escalated enforcem^nt action, the inspection report narrative should refer to the potential noncompliance as an
" apparent violation." The report details should not include any saeculation on the severity level of such violations nor on expected NRC ' enforcement sanctions. Potential escalated actions, by their nature, require further agency deliberation (and. usually, additional licensee input) _to determine the appropriate severity level and NRC action.
Similarly, report narratives that discuss apparent violations should be carefully constructed to avoid making explicit conclusions (i .e. .
final judgments) about the safety significance of the issue. The report should include any available details that give evidence of safety significance, or that would help in making such a decision:
0610 Issue Date: 07/15/97
however, since a potential escalated enforcement action automati-cally entails further evaluative steps, neither the inspection report details nor the accompanying cover letter should presenc a final judgment on the issue. See also the discussion below in Section 05.04.b.
- 3. Non-Cited Violations. Section Vll.B.1 of the NRC Enforcement Policy gives specific criteria under which an SL IV violation may be documented without an associated NOV or other action. When this enforcement discretion is applied, the report should briefly describe the circumstances of the violation, briefly describe the licensee's corrective actions, and conclude with the following boilerplate statement: "This non-repetitive licensee-identified l and corrected violation is being treated as a Non-Cited Violation.
consistent with Section VII.B.1 of the NRC Enforcement Policy."
In addition, the Enforcement Policy also provides that willful SL IV violations may be dispositioned as NCVs provided that they meet the four criteria outlined in the Policy. In these cases, the inspection report should include additional discussion to address this before providing the standard conclusive language. For example: "Although this violation is willful, it was brought to the NRC's attention by the licensee, it involved isolated acts of a low-level individual, and it was addressed by appropriate remedial action. Therefore, this non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll B.1 of the NRC Enforcement Policy."
Section IV of the NRC Enforcement Policy also authorizes the use of NCVs for minor violations--that 15. violations lesi significant than SL IV. As discussed in Section 05.02.a.2. these violations should rarely be documented. To the extent that such a violation js documented, the NRC Enforcement Policy mandates that it should be designated as an NCV. In such a case, the following boilerplate conclusion should be used: "This failure constitutes a violation of minor sigr.ificance and is being treated as a Non-Cited Violation.
consistent with Section IV of the NRC Enforcement Policy." A description of the licensee's corrective action may be included, but is not necessary.
- b. Suonortino Details und Discussions of Safety Sionificance. The discussion of noncompliance issues must be sufficiently detailed to substantiate any NRC safety and regulatory concernt and to support any enforcement sanction the NRC may choose to issue. The narrative should answer. as appropriate, the questions given in the Noncompliance Information Checklist (see Appendix A). At a minimum, for a violation.
the report should state:
e what requirement was violated; e how the violation occurred:
e when the violation occurred, and how long it existed:
- who identified it, and when; e any actual or potential safety consequence; e the root cause (if identified):
e whether the violation appears isolated or programmatic; and e what corrective actions ' lave been taken or planned.
The degree of detail necessary to support an enforcement action is a issue Date: 07/15/97 0610
. .~ . - - - _ - - _ - . -- _ _ _ . _- -_ .
function of the significance and complexity of the noncompliance.
Although supporting details clearly assist in determining the safety significance of- the noncompliance, inspectors must be careful to avoid making direct statements regarding safety significance in the inspection report details. Violation severity levels, as described in the MC Enforcement Policy, are based on the degree of safety significance involved. In addition, the NRC Enforcement Policy uses the term " safety significance" in a specific sense, which involves consideration of (1) actual safety consequence (2) potential safety consequence, and (3) regulatory significance (e.g., willfulness or management involvement in a noncompliance). As a result, if an inspection report refers to a noncompliance as being "of low safety significance" (meaning, in a general sense, that the noncompliance did not result in any actual adverse impact on plant equipment or personnel), the writer may have inadvertently made it difficult for the NRC to subsequently decide that the ootential for an adverse impact or the reaulatory significance of the noncompliance warrants issuance of a SL Ill violation,
- c. Noncomoliances Involvina Willfulness. Inspection reports should neither speculate nor reach conclusions about the intent behind a violation, such as whether it was deliberate, willful, or due to careless disregard. As with any observation, the report discussion should include relevant details on the circumstances of the violation without making a conclusion about the intent of the violator:
APPROPRIATE: "The radiographer failed to activate his alarr ;ag 4
dosimeter. although he had informed the inspectors earlier that he had been properly trained on the use of the device."
INAPPROPRIATE: "The radiographer deliberately failed to activate hu elarming dosimeter."
Conclusions about the willfulness of a violation are agency decisions, and are normally not made until after the Office of Investigation (01) has completed an investigation and a predecisional enforcement conference has been held. A premature or inaccurate discussion of the willfulness of an apparent violation in the inspection report could result in later conflicts based on additional input and review. Inspection reports that include potentially willful violations are to be coordinated with 01 and the Office of Enforcement (OE).
05.05 Documentation of Performance-Based insoection. " Performance-based inspection" 1s inspection that focuses on issues of safety and reliability, with an emphasis on field observation rather than in-office procedural or record reviews. The emphasis on safety and reliability frequently borrows from risk studies, incorporating probabilistic risk assessment (PRA) and individual plant examination (IPE) insights to structure inspections that focus on systems or components most important to plant safety. In addition, performance-based inspection tends to focus more on results (e.g.. does the pump work?) than on process and method (e.g., was the pumo maim enance procedure well-written?).
In moving toward " performance-based regulation " more recently developed NRC requirements (such as the maintenance rule,10 CFR 50.65) tend to be less prescriptive about process or method and more focused on results than earlier regulations, For most areas of inspection the range of relevant regulations.
license requirements, industry guidelines, and licensee regulatory commitments is a mixture of performance-based (results-oriented: less prescriptive) and
' 0610 Issue Date: 07/15/97
complianceibaseu (process-oriented:' more prescriptive) standards. - This mixture often makes it difficult' for. inspectors / report writers to present_ and document- :
inspection findings in a consistent manner.
- a. Documentino Performance Based Issues vs. Como11ance-Based Issues:. . ihe first step in documenting " performance based" findings is understanding .
.the underlying flow of logic, and differentiating this logic from that of .
a- finding based strictly on. compliance. For compliance issues. .the clearest manner of- presentation is usually comparison / contrast, similar to the format of an NOV.
EXAMPLE: Suppose the inspector finds that a certain surveillance is not being conducted at- the . required frequency. No - performance ,
- problems exist with the_ equipment, and follow-up of the observation determines it to be an isolated area of operator oversight, with no underlying training or proceduraln problem. The inspector _might 4 present such a finding in the following manner
TS states that the instrument channel shall be verified operaTTe by performing CHXRNEL CHECK and CALIBRATION operations at frequency. However, from April 7.19 until the inspector identified the issue on August 13,19 . De CHANNEL CHECK and CALIBRATION operations were only perforiiisd at a frequency of ,
thus failing to meet the above requirement ..." followed by a brief summary of - the inspector's follow-up actions. the licensee's response, and similar details, and concluding with statements that .
disposition the violation, By contrast. .a performance based fi'iding frequently begins with the field observation of a safety or reliability issue (e.g., an equipment problem, a deficient work practice, a questionable system response, etc.), which n results in efforts to place the observation in context, pinpoint the root causes, understand any associated problems with the underlying processes or methods--all of which may..or may -not lead to an issue of
, noncompliance. -When documenting such a finding, the clearest
- presentation-usually follows the same path of discovery--that is, the narrative (1) begins with a stattment of the observation. (2) Dlaces that
+
observation in the: context of related findings .or circumstances that contribute to understanding its significance . (3) exalains any known root causes or underlying process problems, and (4) leacs to a " bottom-line" assessment that a particular standard was or was not met (if the standard is a requirement, thi may be a finding of noncompliance).
l EThis performance-basu approach can be a factor in determining whether an observation is important enough to document, and if:ro, what level of detail is appropriate; For exampic, the organization and staffing of a 3 articular licensee group is seldom an-a]propriate topic from_ which to
)uild significant findings. Few NRC requ trements relate to organization and staffing: as a-stand-alone issue, lit rarely merits a detailed report-discussion.-
-A discussion of organization and staffing may be appropriate, however, if tit- results from the follow-up-of_ a performance issue:
EXAMPLE: Suppose" that - the- inspector, in routine tours of the -
Auxiliary Building. -begins noticing < rel_iability problems- with a ,
Eparticular type of pump. - A review of maintetlance requests shows a -
sharp increase beginning several months earlier in the backlog o_f LIssueDne: 07/15/97. 0610 9
p- - - - -
requests associated with these pumps. Discussion with the l mechanical maintenance supervisor reveals that the increased backlog stems from readjusted priorities, which in turn were occasioned by licensee cost-cutting measures that included reorganization and mechanical maintenance staffing reductions. The supervisor states that, based on available staffing, delayed responses to maintenance requests of this priority should be expected.
In this case, the organization and staffing issue may be a legitimate topic for the inspector to investigate and document. If no requirements exist for this licensee in this area the inspector should limit the discussion of staffing to factual observations, related performance issues, clearly demonstrated (not speculative) effects of the organization and staffing changes, and licensee assessments of the issue,
- b. Documentina Issues in Areas Not Covered by Reaulatory Reauirements.
Although the NRC always seeks to focus the requirements of its regulations and licenses on safety considerations, mere compliance with those requirements does not automatically ensure safety. The NRC's safety mandate entails inspection and evaluation of licensee performance in areas that may not be covered by written requirements.
Presumably, judgments made in this realm--in areas not covered by NRC requirements--must still use some standard as a reference point. Various inspection procedures give specific criteria for the inspector to use in evaluating a licensee's performance--including some criteria that are not directly related to an NRC requirement, and that might be more correctly charactertzed as matters of industry convention or standard nuclear safety practices. When inspection findings are made in these areas--that is, when safety issues are identified that do not relate directly to a regulatory requirement--the treatment of such findings can be extremely difficult. How are such findings to be dispositioned at an exit meeting.
or in an inspection report?
- 1. Avoidina Makina Recommendations or Creatina New Reauirements. As the first " rule of thumb" in this area, note that the " standards" discussed here are cenerally recoanized orincioles of safe coeration. and are not written or stated in a manner to resemble concrete eau 1rements. For example, while the generally recognized principle of keeping expcsures as low as is reasonably achievabb (ALARA) justifies writing the following statement.
ACCEPTABLE: " Licensee conduct of work in radiologically controlled areas should give evidence of in-process controls to minimize radiation exposure."
it would ngi be appropriate to prescribe soecific in-process controls that constitute recommendations or could be construed to be new requirements:
-UNACCEPTABLE: " Licensee conduct of work in radiologically controlled areas should include remote monitoring cameras and/or direct job-site supervision by a radiation protection technician."
Note also that, when seeking to establish a clear standard of expected performance in areas not covered by NRC requirements.
l inspectors must be careful never to imoose oersonal oreferences or 0610 Issue Date: 07/15/97 t
arbitrary oDinions on the licensee. Standards of expected perfor-mance should be discussed with both NRC and licensee management, and the inspector should promptly bring any licensee disagreements to the attention of NRC management.
NOTE: See also the discussion of backfits under Section 05.05.b.4.
- 2. Usina Standards in Areas Not Covered by NRC Recuirements. As discussed earlier in this chapter (see the second example in Section 05.01.b.1). the inspector should attempt. through review of inspection procedures and discussions with NRC and licensee management. to arrive at a clear statement of expected performance.
That statement should then be included in the report narrative.
EXAMPLE: Suppose that the licensee identifies the failure of the " A" equipment drain pump inside the containment. and decides to replace the pump during an "at power" entry. The inspector monitors this maintenance activity, and makes the following observations:
e the pre-job briefing places little emphasis on the actual work to be performed or the caution statements included in the work package:
e at the joo site initial communications with the control room are confusing and hard to hear due to in-plant noise:
e as the maintenance workers are about to begin dismantling tnepump,theinspectorobservesthattheyarereplacing the 'B" pump (rather than the failed "A" pump) and alerts the workers to this problem:
e due to these delays, errors, and the resulting additional time and effort, the radiation exposure received is nearly double that expected.
Each of these observations are valid and insightful. yet the inspector may in each case be unable to establish that any requirement has been violated (e.g. . since the workers stopped before actually re) lacing the wrong puma, an actual procedural violation may not lave occurred). On the other hand expected standards of performance clearly have not been met.
To clarify these standards, the inspector may choose to include in the report narrative a statement such as: "In later discussions with the inspector, the maintenance supervisor agreed that pre-job briefings for safety-related tasks are expected to ensure that workers understand the exact nature of the work to be performed. including means of identifying the proper components involved." Similar statements might be included regarding clear communications with the control room, job-site verification of correct components, etc.
Whenever possible. the inspector should seek to tie the finding to a documented program or expectation (e.g., a generic communication on wrong-component or wrong-train events, a licensee's previously established self-checking program, etc. ). In addition, once a clear standard is recognized, the inspector may be able to relate these findings tc other instances in which the licensee's performance has not met these expectations.
Issue Date: 07/15/97 0610
)When multiple problems have been:found, the-inspector mayidepending:
- on the circumstances'of the case; wish to use a more broad statement that applies to more than ohe of the observations. For- the example above such a statement might read as follows: " Licensee conduct of maintenance. on- safety related components or in: radiologically:
~
controlled areas should be characterized by adequate preparation.'
effective communication, and in-process controls-to avoid rework and minimize radiation exposure."
NOTE: Each of these example statiements are' focused on safety.
- performance, and characterize cenerally acceoted orincioles of' safe ooerdtion without creatina new reauiremente or imoosina oersonal co1nions, j
- 3. Addressina- the Need for Licensee Corrective Action. Since the standards discussed here may be in areas outside NRC requirements, they may not be used as the basis for reauestina licensee corrective i action either orally or in the: inspection report. When safety
-1ssues are involved, a responsible ~ licensee- will likely take -
corrective actions and these actions should be documented-in the inspection report as appropriate.
When _ questions exist about the adequacy of the licensee's taken or planned corrective actions,. -the inspector may choose to create an inspection - follow up item to ensure that the lionsee's later actions are. evaluated. in addition, if the licensee fails to take proper corrective action for a safety matter and the problem recurs or additional : safety issues result, the licensee may be in - ,
noncompliance with 10 CFR 50. Appendix 8. Criterion XVI.'"CorrectWa !
Action Finally, in extreme cases where the licensee refuses to take corrective action for a matter of immediate safety significance, the NRC may exercise .its authority co impose an order, even if the licensee has not violated an existing regulation or license-condition. Any such situation should result in prompt involvement by NRC management (including OE and the Office of General Counsel).
4 Avoidina Inadvertent Backfits. 10 CFR 50.109 establishes specific regulatory authority for thu NRC to impose new requirements on-reactor licensees involving the addition. elimination, or modifica-tion of structures, systems, or. components at operating facilities, in order to impose a backfit. the Commission must make a finding that the action will-result'in substantial additional protection of ;
_public health and safety or the common defense.and security.
As discussed in NRC Management Directive 8.4 an NRC staff recommen-dation. that the! Commissionc impose a backfit should only be made after- extensive deliberation and evaluation of u all associated 4
circumstances. ForL routine discussi_ons of safety issues in inspection reports. care must -be exercised to avoid making :an -
inadvertent recommendation that could be construed as an NRC backfit.
- NOTE: The:backf1t rule does not apply to vendors: -however,
.. vendor inspectors should Luse equal care to avoid imposing new-requirements on vendors.
30610- -- -26 s Issue Date: i07/15/97:
- c. Documentina Strenoths and Weaknesses. Consistent with maintaining a focus oi. safety. Inspectors often characterize their primary-responsinility as " finding problems." and inspection reports devote the most detail to discussions of licensee problem areas. Safety benefits can also: result.- however, from identifying and documenting positive findings. Licensee initiatives that have positive results should be encouraged and recognized. In particular, inspectors should be careful to recc]nize positive achievements related to licensee self-assessment efforts.
Section 05.02 discusses criteria to be used in determining whether to document negative and positive findings, and Section 05.03.d discusses the appropriate level of detail to be given these findings. In addition, report writers should be careful in using evaluative terms, and -in seeking to present a " balanced" report narrative.
- 1. Use of Evaluative Terms. Evaluative terms such as " strength" cnd
" weakness" are not always helpful in understanding the inspector's assessment of an observation. For example, the label of " strength" rapidly loses significance if it is applied e area in which no violations were observed. (qually to (1) a program
- 2) the completion of a maintenance procedure without incident, end (3) the introduction of a substantial, innovative licensee program that directly contributes to safety. The label of " weakness" becomes similarly unclear if used indiscriminately.
4 NOTE: The use of " exercise weakness." a specifically defined term, is di; cussed below in Section 05.05.c.3.
In general, report narratives and executive summaries can make a useful distinction in this area by using the labels of " positive finding" and " negative finding" for individual findings of mcderate or low significance. Use of the terms " strength" and " weakness" gain significance if they are reserved for (1) situations in which the overall assessment of a licensee program has found that program (or significant aspects of that program) to be particularly effective or ineffective, and the report nerative includes findings to support that broad conclusion, or (2) individual findings that have either high safety significance or programmatic implications.
Inspectors can communicate even more clearly if these and other evaluative terms are only used when- necessary. Instead, writers should search for descriptive terms that communicate more precisely the conditions observed. For example,
" Laboratory housekeeping was excellent."
conveys much less to the - aer than "The radiochemistry laboratory was brightly i:t clearly labeled. free of clutter. and exceptionally clean When summarizing a. report section, the proper characterization of the licensee's performance in that area typically includes terms like " adequate." " good." " declining " or " improving." However, writers may sometimes find it more descriptive (and equally accurate) to characterize the performance of radiation surveys as
" thorough" or " meticulous." the conduct of a difficult evolution as
- Issue-Date: 07/15/97 -
0610
" safety-conscious " or an overall program as " technically sound."
NOTE: See also.the discussion of " purple language" in Section 07.01.c.
- 2. Presentina a " Balanced" Reoort Narrative. The need for balance in presenting inspection findings is sometimes misunderstood.
Inspectors should not seek to-present a " balanced report" in the sense of offering an equal number of positive and negative findings.
Some inspection results are more negati"e than others: the report should accurately reflect the overall flivor of the inspection.
Balance should be sought, however, in the sense of placing findings in the context of the overall evaluation. When deficiencies are documented, the report should also note the " sample size"-
EXAMPLE: "The inspector reviewed +hr licensee's control, storage, and labeling practices for radicactive sources used in the calibration lab. Out of 56 sources, the inspector found three instances in which the labels were smudged and illegible."
Additional guidance is given in Section 05.01 on placing observations and findings in context.
- 3. Emeroency Precaredness Exercise Weaknesses. Each exercise weakness identified while monitoring a licensee's emergency preparedness exercise should be described in detail. 10 CFR 50. Appendix E.
Section IV.F.5 requires the licensee to take corrective actions for identified weaknesses or deficiencies. The report narrative should be sufficiently detailed for the licensee to determine what types of corrective actions are needed.
NOTE: " Exercise weakness" is a specifically defined term. The discussion on "Use of Evaluative Terms" in Section 05.05.c.1, abcve, relates to more general use of the term " weakness."
- d. Documentina Manacement Issues. Inspectors should exercise care in drawing conclusions on licensee management effectiveness. NRC requirements related to licensee management are limited, and few inspectors have professional training in evaluating administrative or managerial skills, the appropriate level of staffing for a given licensee task.or program, or similar issues. In general, broad-scope evaluations such as an Integrated Performance Assessment Process (IPAP). PPR or SALP are a more legitimate context in which to evaluate licensee management issues.
. Inspectors should seek, however, to identify and document findings that will assist NRC management in those broad-scope assessments. When discussing substantial improvements or declines in the performance of a particular licensee -program, the inspector may identi fy speci fic, concrete ways in which staffing changes or management involvement have
-contributed to that impact.
For example, suppose that a licensee with a record of outage scheduling and completion problems makes sweeping changes that result in successfully completing -a refueling outage under budget, ahead of schedule, and well within radiation exposure goals. In such a case, the 0610 Issue Date: 07/15/97
l inspector should be attentive to the effects of various changes.
including new approaches to outage organization. redistribution of staffing, specific efforts to generate more supervisory involvement, and similar measures.
When documenting these management issues, inspectors should avoid making vague, broad assertions. and should be careful not to report "cause-and-effect" relationships except where a direct correlation exists. In some cases, inspectors are too quick to conclude that a weak licensee program is " deserving of more management attention." or that a particular group 1s weak because of "a lack of management oversight." Since licensee management is ultimately responsible for all facility operations, these conclusions may be valid; however, a more effective approach is to be more specific. Consider the following statements:
NON-SPECIFIC: "The continued motor-operated-valve deficiencies showed a lack of management support in this area."
SPECIFIC: "The continued motor operated-valve deficiencies had several apparent causes, including (1) the failure to schedule outage repairs for the valves. (2) the lack of a system to track repetitive failures, and (3) the lack of follow-up to internal audit findings in this area."
The details given in tne second example are much more meaningful. In addition, these details add credibility and weight to later assessments such as PPR or SALP. when the findings and conclusions of individual inspection reports are integrated into conclusions of broader scope.
Finally, when referencing statements made or positions taken by " licensee management." the inspection report should be as specific as possible as to which licensee manager or management area is being referenced (e.g.,
"the Unit 2 operations manager." "the director of regulatory compliance "
or "the engineering manager for plant modifications").
05.06 Treatment of Ooen Items in Reactor Insoection Reoorts. Issues that merit additional inspection are ident1 fled by a unique tracking number and entered into the Inspection Follow-Up System (IFS) by the originating inspector or office.
Open items include inspection follow-up items (IFIs), unresolved items, violations, deviations, licensee event reports (LERs). and Part 21 reports.
- a. Initiatina Ooen Items. The action of initiating an open item is a commitment of future resources, and should therefore only be used when some specific licensee action is pending, or when needed information is not available at the time of the inspection In addition. IFIs should only be initiated for issues that, if substantiated, would clearly rise above the thresholds of significance discussed in Section 05.02. When the inspector believes that the additional information may reveal the issue to be a matter of noncompliance, an unresolved item should be initiated; otherwise, an IFI should be used. For an unresolved item, the report should identify the actions or additional research needed to resolve the issue.
Issues of noncompliance should always be assigned an IFS number for tracking purposes. When an inspection involves multiple violations (or multiple examples of a single violation), the inspector should be careful to ensure a one-to-one correspondence between the number of IFS entries and the number of " contrary to" statements in the accompanying Notice of Issue Date: 07/15/97 0610
Violation. The NRC Enforcement Manual provides additional guidance on tracking and following up 1ssues of noncompliance.
Upon receipt LERs should automatically be entered into the IFS system for tracking and follow-up,
- b. Follow-Vo and Closure of Ooen items. The level of detail devoted to closing open items depends on the nature and significance of the additional information identified. For example, the closure of an unresolved item or IFl should, at a minimum, summarize the topic, summarize the inspector's follow-up actions, evaluate the adequacy of the licensee's corrective actions, and include enough detail to justify the inspector's conclusion.
NOTE: An inspection followup item may be closed simply by adminis-trative action, when NRC management decides not to expend the effort originally envisioned when the IFI was opened.
In closing out a violation if the licensee's " Response to a Notice of Violation" already has given an accurate description of the root cause, corrective actions taken, and other aspects, and the inspector identifies no other instances of the violation, the close-out description should be correspondingly brief.
EXAMPLE: " Violation 50-999/93008-03 (Closed): failure to properly post a high radiation area. The inspector verified the corrective actions described in the licensee's response letter, dated March 28.
19 . to be reasonable and complete. No similar problems were ide5ti fied. "
- c. Treatment of Licensee Event Reoorts. All LERs should be followed up and given formal closure in an inspection report: however, the level of detail provided in the report will vary depending on the significance.of the LER and the results of the inspector's follow-up. LERs are somewhat different from other open items. because the event report itself has already provided, on the docket, the licensee's description of the event.
Wluding the surrounding circumstances. safety consequences corrective actions and other details.
For LERs involving minor issues, where no new equipment, system or human performance problems are identified, and where the inspector's follow-u) does not result in new information or additional perspectives, the LER closure should be correspondingly brief:
EXAMPLE: "(Closed) LER 50-999/96003: auxiliary building ventilation actuation. This LER was a minor issue and was closed."
NOTE: Sections 05.02.a and 05.02.b provide guidance on determining whether an issue is minor, and whether it should be documented in an inspection report.
Most LERs relate to some aspect of equipment, system, or human performance problems. If these aroblems have already been discussed and dispositioned separately in another section of this or a previous report, the LER closure may simply consist of a reference to that discussion:
EXAMPLE: "(Closed) LER 50-999/960,2: high pressure safety-injection isolation. This event was discussed in Inspection Report 0610 Issue Date: 07/15/97
50-999/96-01. No new issues were revealed by the LER."
When the LER involves more than a minor issue, and the issue has agl been -
discussed and dispositioned in another section of this or a previous report, the LER closure should provide. at a minimum, a basic description-of the event. This should include the licensee's immediate response and subsequent corrective actions. the root cause or causes, a summary of the inspector's follow-up actions, and a statement of how the finding was resolved. The discussion should be brief and concise, except in cases.
where the NRC's information and perspectives differ from the licensee's ,
information and perspectives described in the LER. If the inspector's follow-up does not result in new information or additional perspectives, the report should not uselessly reiterate the detailed event description from the LER.
Note that LERs frecuently involve violations of TSs or other require-ments. As with otler report findings. if the LER is discussed in a manner that implies a violation may have occurred (either as part of the event itself or in the underlying root cause), the noncompliance must be clearly dispositioned in the report as a violation, an apparent violation, or an NCV as approariate, or a statement included clarifying that "this event did not const' tute a violation of NRC requirements." If such a violation would normally be categorized at SL Ill, then the inspection report must provide a full description of the event and surrounding circumstances, and the matter should be treated like any other potential escalated enforcement issue.
For additional guidance on LER followup. refer to Inspection Procedures 90712. "Inoffice Review of Written Reports of Nonroutine Events at Power Reactor Facilities." and 92700. "Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities." Refer to the NRC Enforcement Manual and Section 05.04 of this Inspection Manual chapter for additional guidance on treatment of noncompliances.
- d. Avoidino "Imo'i ed" Insoection Follow-Un Items. For any issue that merits inspection follow-up, a formal IFS entry should-be made. Conversely if the NRC inspector or manager does not wish to open an IFI. then the report should not imply that follow-up will occur. In the absence of an IFI entry, the report should not . include statements such as the following:
"The NRC will continue- to monitor this matter during routine inspection activities."
In short. the inspection report should not commit to future NRC attention in a ) articular-area unless that commitment is tracked. In addition, an IFI s1ould only be opened by the NRC office responsible for the follow-up (i.e., one- office should not open an IFI that commits to action by another_ office).
0610 06 GUIDANCE - INSPECTION REPORT FORMAT Whenever possible, NRC inspe ion reports should conform to the standard formats
' described in this section and illustrated in the attached exhibits. This standardization in format significantly enhances readability and information u retrieval, which in turn increases efficiency and improves the ability to
-integrate inspection results. : Exceptions should - be made for major team Issue _Date: 07/15/97: _0610 L
inspection reports. augmented inspection. team (AIT) reports, and other cases where the specifically directed focus of the inspection coes not easily fit into the SALP functional area topics and sub-topics given in the standardized report outline.
'06.01 Cover Lettec. Inspection reports are transmitted using a cover letter from the applicable NRC official (branch chief, division director, or regional administrator) to the designated licensee executive. Cover letter content varies somewhat depending on whether or not the inspection identified noncompliances, in general, however, every cover letter uses the same besic structure.
NOTE: Management Directive (MD) 3.57. " Correspondence Management." Part 111 provides guidance for NRC letters, including inspection report cover letters. In addition, the NRC Enforcement Manual provides standard transmittal letter formats for inspections in which noncompliances are identified,
- a. Addresses. Date. and Salutation. At the top of the first 3 age, the cover letter begins with the NRC seal and address, followed )y the date on which the report cover letter is signed and the report issued.
NOTE: For cover letters transmitting reports that involve potential escalated action (EA), the EA number should be placed in the upper left-hand corner two lines above the principle addressee's name.
The name and title of the principle addressee are placed at least four lines below the letterhead, followed by the licensee's name and address (see Exhibit 2. the sample report). Note that the salutation is placed after the subject line.
b, Sub.iect Line. The subject line of the letter should state the type of insaection report (e.g,. "NRC INTEGRATED INSPECTION REPORT." "NRC RE0JALIFICAT10N TRAINING INSPECTION REPORT") followed by the report number. The words " NOTICE OF VIOLATION" (or " NOTICE OF DEVI ATION." etc.)
should be included if such a notice is accompanying the inspection report.
- c. Introductory Paracraoh.. The first paragraph of the letter should give a brief introduction, as follows:
EXAMPLE: "On July 24,19 the NRC completed a safety inspection at your facility. The enclosed report presents the results of
-that inspection."
- d. Body of the letter. The ensuing paragraphs should discuss the most important inspection results including noncompliances and significant findings or conclusions. Considerable flexibility is given to the NRC issuing official in terms of choosing the proper content and overall message of.the cover letter. In general, this portion of the cover letter _should focus on clearly communicating a few main points (or a single point) that are well-supported by the executive summary and report details, rather than attempting to deliver a large number of points or extensive detail.
If no noncompliances or significant issues were raised by the inspection, this section should briefly summarize the scope of specific; inspection activities performed, to give perspective to the conclusion that "no noncompliances or significant issues were identified."
0610 Issue Date: 07/15/97
- e. Closina. The final paragraph consists of legal boilerplate that varies based on whether or not enforcement action is involved, The signature of the appropriate NRC official is followed by the docket number (s) license number (s), and lists of enclosures and distribution.
06.02 Cover Paae. The report cover page provides a quick-glance stanary of information about the inspection (see Exhibit 2). It contains the dates of
. inspection, the report number. the names and titles of participating inspectors, and the name and title of the approving NRC manager.
NOTE: A record of inspector and reviewer concurrence in the report is separately recorded and maintained by the issuing office. This concurrence record is not included in the generally distributed. version of the report.
For vendor inspections, the cover page should list the name of the company, i" principal product (i.e. a description of the type of components. equipment. or services supplied), and a brief statement describing the vendor's nuclear industry activity.
06.03 Executive Summary. The summary should be informative but concise. An ideal inspection report summary will be useful as an overview tool for licensee management and for NRC staff when preparing PPRs. SALPs, or management briefings.
- a. Introduction. The summary should begin with a one- or two-sentence introduction that covers the type of inspection, the scope (i.e., the 11cersee programs or functional areas inspected), and any special details.
EXAMPLE: "This integrated inspection included aspects of licensee operations. engineering, maintenance. and plant support. The report covers a 6-week period of resident inspection. announced inspections by regional engineering and radiation specialist inspectors, and an unannounced visit by a regional safeguards inspector."
- b. Presentation of Sianificant Findinas and Conclusions. The list of issues that follows should be in the same order as the re) ort details (modeled after the standard inspection report outline incluced as Exhibit-1). In essence. the executive summary should be compiled by scanning each report section and writing a crisp. short summary sentence for each issue of note--noncompliances. significant findings, and conclusions. The threshold of significance for including an issue in the executive summary should be based on whether the issue would be included in an input to a PPR review or a SALP board evaluaticn. As a minimum, the executive summary should include a general conclusion on the adequacy of each program area in which significant inspection was performed.
NOTE: Unresolved items and inspection follow-up items should not be discussed in the executive summary (i.e. , where more information is needed to reach a finding or conclusion). If a finding or conclusion was reached in an area related to the open item, the executive summary may include that finding or conclusion. NCVs need not be discussed unless the technical significance or other aspects of the surrounding circumstances warrant-inclusion in the executive summary.
When negative findings are included in the executive summary, the usefulness of those findings will be increased by concisely stating the
. Issue Date: 07/15/97 0610
root cause (if the root cause has been determined). In addition, when broad conclusions are included indicating unusually positive or negative performance in a particular area of inspection focus, the conclusions will be made more useful by giving a brief but supportive example.
06.04 Table of Contents. For reports of significant length (i.e. . in which the report details section exceeds 10 pages), the writer should consider including a table of contents as an aid to clarity.
06.05 Reoort Details: Use of the Standardized Reoort Outline. Most reactor inspection reports should begin with a " Summary of Plant Status" that briefly describes any shutdowns or significant changes in power. For specialist inspections this summary may be shortened or eliminated as appropriate (e.g. ,
plant operating status may or may not be relevant to a safeguards or emergency preparedness inspection). The remaining report details should be to)ically arranged in accordance with the standardized report outline, included as Exnibit 1 This does not mean, of course, that each outline topic should be covered in each report: however, to the extent that inspection is performed in a particular area (e.g. , inspection of " general employee training in radiological protec-tion"), the resulting findings should be placed in the corresponding standard section of the report (e.g., in R5 of the standardized outline: see Exhibit 1).
NOTE: Conformity to the standardized outline should not result in artificially fragmenting an event description or separating report details that would logically be presented together. For example, if a proble: occurs while performing a maintenance procedure, it may have radiological, engineering, training, or other implications. Depending on the main thrust of the finding, it might legitimately be presented under M1, " Conduct of Maintenance"; MS. " Maintenance Staff Training.and Quali fication": or even R4 " Staff Knowledge and Performance in Radiological Protection and Chemistry."
Regardless of what section the writer finds most appropriate, the basic details need only be presented once. Cross-references should be made in l nther sections as appropriate. In the example above, the writer might choose to discuss )erformance of the maintenance procedure under M1 (because the most s'gnificant result related to how the maintenance was conducted), but include cross-references under M5 or R4 because of implications related to those areas. See the examples of cross-referencing given in the sample report, attached as Exhibit 2.
The sample report included as Exhibit 2 illustrates the effectiveness of this practice. While not all sections of the standardized report outline are covered, the report details are maintained in a coherent. predictable order that roughly corresponds to SALP categories, and corresponds to the placement of similar details in other reports.
06.06 Reoort Details: Internal Oraanization of Soecific Sections. Differences in the nature, significance, and complexity of individual findings results in considerable variety in how those findings are organized and presented. However, as shown in the attached sample report (Exhibit 2), the overall organization of each report section should follow the same basic progression of logic:
inspection scope observations and findings, and conclusions.
- a. Insoection Scope. As discussed earlier, this description should be complete and f actual but concise. A tabular format is frequently the most clear: the inspector can use this format to list systems and components inspected, specific work activities or plant evolutions that 0610 Issue Date: 07/15/97 i
were monitored. procedures and records reviewed etc.
- b. Observations and Findinas. This portion of each report section should be used to present. In a narrative format, the inspection results. At this stage in the report, the inspector may choose to simply number issues sequentially, with appropriate subheadings, or may use another method of organizing the findings (see Section 07.02 for additional guidance on organization methods).
- c. Conclusions. In general each report section should have a conclusion section. in which the findings are related to the broader context of the
) articular licensee program or that portion of a SALP functional area seing addressed. The relationship among findings will vary: in some cases. the conclusions to be drawn will be specific to the individual report section; in other instances, the findings of several report sections can be integrated into a broader conclusion. The sample report included as Exhibit 2 illustrates this variation.
NOTE: When a given section of the report only involves closure of one or more open items, a separate conclusion section may not be needed or appropriate.
06.C7 Exit Meetina Summary. The final section of each reactor inspection report should be a brief summary of the exit meeting. This summary normally should include the following elements:
- a. Characterization of Licensee Resoonse, in general, the report should not characterize a licensee's exit meeting response as one of wholehearted acceptance of the inspection findings. If the licensee generally agreed with the findings presented, the exit meeting characterization might read as follows:
EXAMPLE: "The inspectors presented the inspection results to members of licensee management at en exit meeting on June 12.19-.
The licensee acknowledged the findings presented."
On the other hand, when the licensee disaarees with the inspectors
- assessment of a particular finding, this position should be briefly and specifically characterized (e.g., "the plant manager stated that he believed the violation of TS 4.3.1.2 regarding a reactor trip system surveillance, to be of no safety signi ficance") . Specific items discussed elsewhere in the report should not be described in this section in detail. -
- b. Licensee Oral Statements and Reaulatory Commitments. If at the exit meeting or at any other time during the inspectior.. the licensee makes an oral statement that it will take a specific action, the report should attempt to accurately characterize that statement. As determined by the significance. complexity, subject area, and resource expenditure involved, the inspector should ensure that such oral statements are made or endorsed by the proper member of licensee management. Inspectors should be careful to differentiate bete.>een (1) licensee general descriptions of " voluntary enhancements" or general intent; and (2) oral statements of the licensee's intent to make a specific regulatory commitment (i .e. , to ciamit. on the docket, a written commitment to take a specific action)
Because regulatory commitments are a sensitive area, the inspector should Issue Date: 07/15/97 0610 l
also ensura that any reporting of such a licensee oral statement is accurately characterized. To ensure a clear mutual understanding of such issues, when the licensee makes an oral statement reflecting the intent to make a regulatory commitment, the report issuing office may wish to restate. in the report cover letter, the NRC's understanding of that proposed commitment, and ask the licensee to clarify any differences in understanding.
- c. Absence of Proorietary Information. At the exit meeting. the inspectors should verify whether or not the licensee considers any materials provided to or reviewed by the inspectors to be proprietary.
NOTE: When an inspection is likely to involve proprietary informa-ticn (i.e., based on the technical area or other considerations of inspection scope), the topic of how to handle such information should be discussed at the entrance meeting.
If the licensee does not identify any material as proprietary the exit meeting summary should include a sentence to that effect (see Inspection Manual Chapter (IMC) 0611 on actions to take if the report includes proprietary material).
EXAMPLE: "The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified."
- d. Subsecuent Contacts or Chanaes in NRC Position. The report writer should briefly discuss any significant contacts between the inspectors and licensee staff or management that occur after the exit 'aeting (e.g.. to discuss new information relevant to an inspection finding. In addition.
as discussed earlier if the NRC's position on an inspection finding changed significantly after the exit meeting. that change should be discussed with tne licensee before the report is issued.
06.08 Reoort Attachments. The attachments discussed below should be included at the end of the inspection report.
- a. Partial list of Persons Contacted. The report writer should list, by name and title, those individuals who furnished significant information or were key points of contact during the inspection (except in cases-where there is -a need to protect the identity of an individual). An exhaustive list is neither required nor desirable: 5 - 10 key individuals normally is sufficient. The list should include the most senior licensee manager present at the exit meeting. The list should also include other NRC technical personnel who had significant involvement, if they were not-listed as inspectors on the cover page.
- b. Liit. of Insoection _ Procedures Used. The report should list, by procedure number and title, the inspection procedures used. See the sample list included with Exhibit 2. In some cases the writer may wish to inr'ude other significant activities inspected (e.g., tis completed).
- c. List of Items Onened. Closed. and Discussed. The report should provide a quick-reference list of items opened and closed, including the item number, the IFS code for the item and a brief phrase (10 words or less)
-describing the item. Open items that were discussed (but not closed) should also be included in this list. See the sample list included with Exhibit 2.
0610 Issue Date: 07/15/97
- d. List of Acronyms. Reports of significant length (i .e. , in which the report details section exceeds 10 pages) should generally include a list of acronyms as an attachment. For reports in which a relatively small number of - acronyms have been used, such a list should be considered optional. In all cases, however, acronyms should be clearly defined when first used in text. regardless of whether a list of acronyms follows the report narrative.
0610-07 GUIDANCE - INSPECTION REPORT STYLE A package is frequently judged by its wrappings: similarly, an inspection is often evaluated based on the clarity of the inspection report. The best engineer, putting forth the most intensive inspection effort, may not succeed in delivering the desired safety messages if the inspection results are shoddily presented. On the other hand, a clear writing style that communicates the desired safety issues increases the professionalism of the product and can enhance the credibility of a good inspector (and of the agency).
07.01 Peculiarities of Government Technical Writina. Government technical writing as it appears in NRC ins)ection reports, combines aspects of scientific, legal and corporate communicat'on. Since few inspectors possess the combined skills of a scientist, attorney, and business executive certain aspects of NRC report writing have been standardized. Most new inspectors find these standardized aspects peculiar, and some writers adapt more easily than others.
Four specific writing style features will be discussed here: using " boiler-plate"; writing in standard grammatical tenses; avoiding " purple" language; and using technical. legal, or local jargon.
- a. Boilerolate. The first aspect is the use of standard paragraphs or phrases, called "boilerplate." for certain sections of the inspection report. Boilerplate is provided in various NRC references as a writer's guideline. (1) to achieve consistency throughout the agency among writers whose individual styles may v6ry, and (2) to provide precise wording for statements that may have leoal implications (such as the standard legal or enforcement wording that appears in cover letters and NOVs). Used properly, boilerplate can save time and effort.
Boilerplate should 001 be used as the substitute for report content, such as when discussing inspection methods, activities inspected, or inspection findings (see Section 05.03.c). On the other hand, once effort has been expended to develop clear standards in a given inspection area, the inspector may find it useful to save and repeat those statements in later inspections of the same or similar areas,
- b. Grammatical Person. Tense. and Voice Used in NRC InsDection Reoorts. The use of specific grammat .al conventions is another style peculiarity of NRC report writing that some -inspectors initially find awkward. The narrative sections of a report should be written in the third person, in the past or past perfect tense, in predominately active voice, as follows:
- 1. Always write in the third person.
RIGHT: "The inspector watched the mechanic remove the check valve."
WRONG: "I watched the mechanic remove the check valve."
1 Issue'Date: 07/15/97 0610 l
- 2. In general, use the past or past perfect tense.
RIGHT: "The plant manager stated that the review committee had been fully staffed as of April 19_." .
WRONG: "The plant manager states that the review committee was fully staffed as of April 19_,"
NOTE: As a rule of thumb. use the past tense (e.g. , "the pump cavitated .. " OR "the pump was cavitating . . .") when writing about events that occurred during the iispection. Use the past
)erfect tense (e.g. , "the pump had cavitated . . ." OR "the pump lad been cavitating ...") when writing about events that occurred before the inspection.
EXCEPTION: When quoting or paraphrasing existing literature, the" present tense may be used (e.g. , "10 CFR 50.71 states
... ). However, if using the present tense when quoting a-licensee procedure, be certain that the quotation is current at the time of issuing the inspection report (or give the date and revision number of the procedure from which the quote was taken).
- 3. Use predominately active voice (subject-verb-object). Passive voice tends to be more wordy and indirect, less interesting, and thus more difficult to read and comprehend.
ACTIVE: "The auxiliary operator reported that lW oil pressure was rising."
PASSIVE: "It was reported by the auxiliary operator that lube oil pressure was rising."
In addition, passive voice sometimes fails to identify the subject, ,
or the performer of the action.
PASSIVE: "It was reported that lube oil pressure was rising" OR " Lube oil pressure was reported to be rising."
In cases such as- the latter example.- the use of passive voice actually results in omitting information that could be important in evaluating the significance of the observation.
- c. .Avoidino Purole Lanauace. " Purple" _ language refers to words or phrases that have undesiralele connotations or hidoen implications, such that a reader might misconstrue the writer's meaning. Several examples follow:
EXAMPLE: "The inspectors concluded that the licensee - had a wonderful in-service inspection (ISI) program."
PROBLEM: - The term " wonderful" is imprecise and unsupported: a more concrete description, detailing those aspects of the ISI program that seemed superior, is more appropriate.
EXAMPLE: " Foreign material exclusion controls had been carelessly disregarded by the maintenance staff."
PROBLEM: - Because terms such as " careless disregard." " willful." and
" deliberate" represent agency conclusions with specific NRC enforcement connotations, they should not be used in a report 0610 - Issue Date: 07/15/97
narrative unless they represent a formal agency conclusion.
EXAMPLE: "By waiting until the last minute to return the charging i pump to service, the licensee narrowly missed getting an NRC violation."
PROBLEM: The inspection report is not a forum for the ins)ector's opinions or conjecture; observations should be factual ratler than speculative.
For further discussion on evaluative terms, see Section 05.05.c.1.
For further discussion on willfulness and related topics, refer to Section 05.04.c and the NRC Enforcement Manual.
d, Usina Technical . Leoal . and Local Jaroon, Because of the specialized technical and legal aspects of NRC regulation, inspectors must maintain sensitivity to the use of specialized vocabulary in inspection reports.
The use of technical and legal jargon is expected and necessary: however, inspectors should explain terms that are likely to be unfamiliar to the
" target reader" (see discussion in Section 05.03.a).
In addition, inspectors should avoid the use of " local jargon," terms or phrases that have specific meaning for a particular plant or region of the country but are not widely understood. Examples include terms and phrases such as " tailgate" (when used to refer to an informal meeting),
" work:around," and " command and control ." Because these labels are used routinely by a localized group, inspectors may become accustomed to their use and a.3sume that they have a consistent, widely understood meaning.
When used in inspection reports, however, readers from another facility or region may be given an unclear or unintended meaning. To avoid miscommunication, report writers should define such terms and phrases whenever used or, if possible, use an alternate word that has a clear, dictionary-defined meaning.
For example, consider the following usage of the term " work-around":
ACCEPTABLE: "The licensee's failure to resolve longstanding concerns has contributed to an excessive reliance on operator " work-arounds." The term " work-around," as used in this report, refers to non-routine actions performed by the operating crew to compensate i for equipment not functioning as designed."
In this case. the writer chose to use local jargon by including the term
" work-around." By defining the term immediately after its initial use in the report, however, the writer avoided the possibility of vagueness or an incorrect interpretation for a reader not familiar with the term.
NOTE: The example above would ng1 be acceptable if the writer had omitted the second sentence.
As an alternative, the writer may choose not to use the term at all:
ACCEPTABLE: "The licensee's failure to resolve longstanding concerns
-has contributed to'an excessive relicnce on the performance of non-routine actions by the operating crews, to bypass or compensate for eouipment not functioning as designed."
07.02- Clear Oraanization. .The attribute most likely to make a report appear
- unprofessional is a- lack of- organization. This writing style problem is Issue Dat : 07/15/97 0610
evidenced in reports that (1) leave the reader uncertain as to the main points or overall message: (2) blur the distinctions between observations, findings, and conclusions: (3) fail to present findings in terms. of relative significance (i.e., treat all findings with the same priority and level of detail): (4) present redundant information throughout the report (e.g.. Use the same observation to create findings and draw conclusions in multiple areas); and/or (5) draw unsubstantiated conclusions, or make contentions in the cover letter or executive summary that do not match the report findings.
Using a standardized report outline and a standardized format for report sections helps writers to achieve more coherent report organization, but is frequently not enough. For writers that struggle with organization, or for good writers that want to further improve their writing style, several specific actions can be of use.
- a. Manacina the Writina Proc.gn. Many writing. courses are designed to turn out an effect!ve business memo or convincing letter. These courses teach the mid-level executive how to break the writing process down into manageable steps. The same techniques, slightly modified, can be applied to an NRC inspection report.
Writing involves planning, brainstorming, organizing, drafting, and revising. Trying to perform all of these activities at once will produce
" writer s block.' incoherent presentation of findings, sloppy final draf ts, and extended cycles of report review and revision. A more effective writer breaks the writing process into stages to avoid frustration, save time, and produce a more professional product.
A3pendix B provides detailed guidance on managing the writing process in t11s manner.
- b. Standard Oraanizational Technioues. Within the " Observations and Findings" portion of each report section, the inspector must determine how to organize the findings relevant to that area. Wnen few findings exist. organization is simple. However, when extended evaluation of a licensee program has resulted in a large number of findings, the inspector must group the findings into logical categories, and arrange the findings in each category into some logical order. Several methods may be used:
e Order of lmoortance. Within each category, present the obserutions and findings beginning with the most significant.
- Chronological. This method is useful in presenting the essential details of a complicated event.
e Comoarison/ Contrast. This is the organizational method used for writing NOVs. in which the regulation is quoted or paraphrased and closely parallel language is used in the " Contrary to" statement.
This is also an effective method of presenting a negative finding in the report details.
- c. Use of Renetitive Formats. Most ins 3ection writing tasks are repetitive in organization. By 1dentifying t1e basic structure of each type of report section, the inspector can use this repetitiveness to make the organization of details much easier.
EXAMPLE: Consider the details usually present in closing an open 0610 Issue Date: 07/15/97
,a a > -ap. ..,m., ,-.u + 4 - +..a -t a n ~ - . w.a. ~~n. . . . - 2 -u- n..+a T
' item. List- the typesiof- information that may be included: a description of the issue: licensee corrective actions: an indication - ;
of:theiitem's open or closed status: the applicable regulatory :
criteria: the inspector's actions to verify resolution of the issue:_ !
the~ root cause-(when following up on an event or a violation): and-the IFS number of the open item. .
Now arrange these pieces of information into a logical . order, and-
- create a series- of steps for ' documenting the closure of an open- '
item:
- 1. Give the IFS number of the open item.
- 2. Indicate next to the number whether the item will remain open or closed.
i
- 3. ~ Briefly describe the issue, 4, In the. description, reference the regulatory criteria, if =
- applicable.
- 5. State the root cause if desired.
' 6. Describe the licensee's corrective actions. .
- 7. Describe the actions the inspector took to verify resolution'of -
the t sue.
Now examine the ' examples of follow-up items given in the sample ;
. report (Exhibit 2). In each case, the narrat1ve follows the same .
logical pattern described above. -Some types of information, such as ,
a statement of: root cause, will-not be included for less significant issues or_. - when the ~ follow-up. results are routine and
- straightforwed. The underlying organization, however, will remain-the.same. 4 This technique can be applied to most sections or subsections of the l inspection report. Once the structure has been established and repeated ,
several: times, the organization of similar details in later reports can become almost automatic, saving time and effort.
-07.03 Effective Revision. - Because of deadlines and other pressures many writers hand in their products for -review and _ approval immediately after drafting, without taking the time for effective revision; Whether reviewing one's own re3 ort or that of someone else. the following guidance will be helpful-in (1) ensur' ng that the report communicates clearly, (2) achieving professional-o ism in the writing style.-and (3) avoiding embarrassing mistakes. ,
-NOTE: The guidance below is summarized 1 in a report review cchecklist, included as-Appendix C to this chapter.
Levelst of revision should be prioritized . Some corrections are more'important' than others; if:the reviewer begins by hcusing on spelling and punctuation, he
~
- or~shimay beLtoo distracted to notice larger < organizational problems. The most effective-practice:is to revise in-severaT stages.
1The first: stage is a rapid read-through to check for overall coherent organiza-
- tion and Llevel of: detail Jin' each report section If no major revisions. are b neededt the second, stage l review isLthen performed, reading-to assess paragraph
~ structure. -sentence style.:and clarity _of syntax. The final stage is a careful 1 word-by-word proofread to check for spelling, punctuation, and accuracy. "
, Ja. -Hichliohtino the Messaae'. The first1 stage review ensures that the mosti Lsignificant findings and: conclusions will be evident to the reader.
- Issue- Date
- :. ; 07/15/97 .-=41 0610
. au - - - . - -, . . . . ..
o Are the main. topics of the cover letter supported by findings in the :
executive summary? o
- e; Are the' findings in the executive summary consi_ stent with the report tdetails?
e: ..Are the main-ideas _ inleach section clearly developed (observations -
translated ' toJ findings: . findings integrated - into - substantiated '
conclusions)?..
4 e Is the level of detail appropriate. for the significance of 'the- -
findin and in keeping with the technical expertise of the target
- reader ,
- b. Checkina the Style. Even a well-organized report can miscommunicate, Government technical writers sometimes lapse into a "bureaucratese" style ;
that can obscure meaning.
Long paragraahs and sentences, pompous language, and useless phrases are symptoms of an undesirable bureaucratic -
style, i
To illustrate: imagine sitting in a classroom, listening to the lecture r - of an eloquent instructor who knows the material well, who has an obvious enthusiasm for the task, who genuinely wants the students to learn, who-
. never loses the thread of -thought, who always has the a answers,- but whose fatal flaw is neglecting to give breaks, ppropriate and whose-effectiveness is therefore severely reduced by never giving the students )
i a chance to pause, to breathe -to digest the material. 'Long sentences
. (and long paragraphs) have a similar effect, (To understand this effect. *
, use a single breath to read aloud the first sentence of Ois-paragraph.)
By contrast, the_ second-stage revision can enhance re) ort clarity, in
- part, by noticing the amount of " white space" on t1e page, Where appropriate, add emphasis techniques, such as subheadings or lists, Make each paragraph coherent and concise. Ensure- the predominate use of active , voice. Eliminate wordy phrases, false subjects, and other symptoms of "bureaucratese" that weaken sentence clarity. A crisp, clear style will add far more credibility to a report than an inflated vocabulary,
- c. Proofreading. Unfortunately, there is no good substitute _for a final.
. word-by-word-proofread, Computer spell-check _-systems are. helpful, but:
will not-identify cases in waich the wrong word is used for the context >
10,g., " corrective actions- were directed by the cite maintenance-
- l manager"). This final revision should look for such errors as
-e Improper subject-verb agreement (and other gramar errors),
3 - e- ; Undefined acronyms, Lo- Typographical errors that result in the wron;; word for the ' context.
~
e: Missed or incorrectLpunctuation, and=
ei Metrication mistakes: errors--in converting SI to/from. English ^
Lunits.
- ~In addition, before ths finalJdraft is released, veri.fy the accuracy of y
all numbers (including page numbersh dates. distribution, and titles,
~. ' O 10f -- 42 + . Issue Date: 07/15/97-
=='-f,4-i.+eop .,ne ,y wr-r,- v er es+y.m** -=f7+-- -'7e- b -We & f g Du'M-"'9
-~ - .- _ . _ _ . _ _ _ _ _ _ . . . ~ _ _ _ _ _ . . _ - _.-
T 07.04- Writina-Style Guides and Useful-NRC References.
Few writers can recite all. the rules-of English grammar, and few inspectors can remember the-large assortment of NRC boilerplate and guidance. Most inspectors will" 'nd it useful to be familiar with the:following references: ,
a
- a, ?The NRC Enforcement Manual' pro'vides specific g'uidance and boilerplate for l writing associated with enforcement actions, ,
I bL The U S. Government Printina Office (GPO) Style Manual is a reference on -
- government writing style, covering a range of topics from capitalization- :
to compound words.
- c. NUREG-1379, the NRC Style Guide, establishes specific guidance for the agency on the use of abbreviations, ca)italization, punctuation, in'-text references, and so forth. The NRC Sty'e Guide is consistent with the ffQ '
Style Manual on most matters, -
Ld, -In addition, familiarity with a desktop writing guide adds efficiency and I confidence in achieving a clear communication style. Three-excellent 4r examples ' follow: (1) Handbook of Technical Writina (by Brusaw, _ Alred.
and Oliu, St. Martin's Press): (2) The Elements of Style (by Strunk and
-White, Macmillan): and (3) The Shioley Style Guide (published by Shipley Associates).
0610 RELEASE AND DISCLOSURE OF INSPECTION REPORTS -AND ASSOCIATED DOCUMENTS- ,
08.01; General Public Disclosure and Exemotions. Except for report enclosures-containing exempt information, all final inspection' reports will be routinely disclosed to the~ public. IMC 0611. " Review and. Distribution of Inspection
. Reports," describes the various types of exempt information. IMC 0620,
" Ins)ection Documents and Records," provides guidance on acquisition and control of NRC records, including inspection-related documents.
08.02 Release of Investiaation-Related Information
- a. When an inspector accompanies an itwestigator on an investigation, the inspector.shall not release either the investigation report nor his or her individual-input on the investigation report. This information is exempt from disclosure as provided _by 10 CFR 9.5, subject to determination by 01. OI reports of investigations.-while in preparation n -or. review, will not-be circulated outside NRC without specific approval p of'the Chairman (0I Policy Statement 23).
- b. Generally, NRC -technical and safety concerns can be communicated to a ,
licensee Without revealing- that an investigation is contemplated or
-underway, JHowever.1when information cannot be released without risk of
- compromising an investigation, the regional- administrator. (RA) will
~
l inform the - Director, l01, in advance that safety concerns require releasingDto the licensee information related to an open investigation.
The Director,: 01, will: review the information.to be released and. advise the RA of the anticipated effect on' theicourse of the investigation. '
The! RA will -release- the -information only. ~after determining that the
- . safety concernsi are significant. enough' to justify the ' risk: of- -
compnoiising the- any - potential sequent
+ ; regulatory action. pending . investigation--andConversely, when the RA decide with -01 to delay informing the licensee _ of- aniissue, the- RA =should _
LIssue)Date: LO7/i5/971 - - 0610-4 g i- , y, , , , , . , , , , . - ,.-_y((m ,s _
, i,.,,, 4 , , w
l document this decision, including the basis c determining that the delay is consistent with public hecith ar.d safety considerations. Any such
- d. cision should be rNxamined every three months to assure its continuing val'dity (see March 2. 1987 memorendum from the Executive Director for Operations (ED"-) to office directors 3nd regional administrators).
- c. When an emergency or significant safety Or security issue appears to require immediate action. NRC employees. at their discretion, may discuss with, show to, or provide the licensee any partinent material they believe the circumstances warrant. If time permits. regional trianagement
, should be consulted first.
An emergency situation meeting this criteria is one in which in the opinion of the senior NRC employee cognizant of the situation. a present danger to nublic health or safety or to the comon defense and security requ'res the release of investigative information to a licensee withnut the delay necessary to consult with appropriate 01 personnel (see March 2.1987 memorandum from EDO to office directors and regional administra-tors).
- d. If an issue d:sclosed during m inspection is to be referred to 01 for %
possible investigative action, the inspection report should not contain information that would lead a reader to conclude or infer that an investigation may be opened in this case, the report should contain only relevant factual information collected during the inspection. The referral to 01 should be made by separate correspondence, with any additional information needed to support the referral.
END Exhibits 1 - 5 Appendices A - E
-0610 -- Issue Date: 07/15/97
l STANDARD REACTOR INSPECTION REPORT OUTLINE b hibit 1 Cover Letter Cover Page Executive Susnary Table of Contents (<ptional)
Report Details:
Sunnary of Plant Status
- 1. Operations *
- 11. Maintenance
- 111. Engineering
- IV. Plant Support 'reas:
Radiological Protection and Chemistry
- Security and Safeguards
- Fire Protection
- V. Management Meetings
- Partial List of Persons Contacted List of Inspection Procedures Used List of items Opened Closed, and Discussed List of Acronyms (optional)
- Expanded outlines of these areas are provided below.
- 1. Doerations <
01 Conduct of Operations 02 Operational Status of Facilities and Equipment 03 Operations Procedures and Documentation 04- Operator Knowledge and Performance 05 Operator Training and Qualification 06 Operations Organization and Administration 07 Quality Assurance in Operations 08 Miscellaneous Operations Issues
-issue Date: 07/15/97- El 0610: Exhibit 1
--______._._...-__-.-_-____-______.-_m__ _ _ - _ _ _ _ _ _ _ . _ _ _ - . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ - - _ - . ___ dl
i II. Maintenance 1 M1 Conduct of Maintenance
.H2 Maintenance and Material Condition of Facilities and Equipment H3 Maintenance Procedures and Documentation l 3
M4 Maintenance Staff r.nowledge and Performance M5 Maintenance Staff Training and Qualification l M6 Maintenance Organization and Administration l M7 Quality Assurance in Maintenance Activities M8 Miscellaneous Maintenance Issues III. Encin " ing :
El Conduct of Engineering E2 Engineering Support of Facilities and Equipment E3 Engineering Procedures and Documentation E4 Engineering Staff Knowledge and Performance E5 Engineering Staff Training and Qualification E6 Engineering Organization and Administration ,
E7 Oe311ty Assurance in Engineering Activities ,
E8 Miscellaneous Engineering Issues IV. Plant Succort R1 R;Jiological Protection and Chemistry (RP&C) Controls R2 Status of RP&C Facilities and Equipment R3 RP&C. Procedures and Documentation R4 Staff Knowledge and "*nrmance in RP&C
- RS
- Staff Training and Qualification in RP&C
.R6_RP&C: Organization and Administration l Surveillance activities are included under " Maintenance." For example, a n% : section-involving surveillance observations might be included as a separate sub-
' topic'under M1, Conduct of Maintenance "
~ ~
?66}04.. Exhibit:1- El-2 -Issue Date: 07/15/97
R7 Ouality Assurance in RP&C Actitfities R8 Miscellaneous RP&C issues t P1 Conduct of EP Activities P2 Statut of EP Facilities. Equipment. and Resources P3 EP Procedures and Documentation P4 Staff Knowledge and Performance in EP P5. Staff Training and Qualification in EP P6 EP Organization and Administration P7 Quality Assurance in EP Activities P8 Miscellaneous EP 1ssues S1 Conduct of Security and Safeguards 'ctivities ,
S2 Status of Security Facilities and Equipment 53 Security and Safeguards Procedures and Documentation
$4 Security and Safeguards Staff Knowledge and Performance 55 Security and Satrguards Staff Training and Qualification 56 Security Organization and Administration P7 Quality Assurance in Security and Safeguards Activities PP Miscellaneous Security and Safeguards issues F1 Control of Fire Protection Activities F2 Status of Fire Protecticn Facilities and Equipment ,
F3 Fire Protection Procedures and Documentation F4 Fire Protection Staff Knowledge and Performance F5 Fire Protection Staff Training and Qualification F6 Fire Protection-Organization and Administration F7 Quality Assurance in Fire Protection Activities F8 Miscellaneous Fire Protection Issues .
.lsstie Date:: 07/15/97- .El 3 0610: Exhibit 1
J V. Manaaem nt Meetines X1 Exit Meeting Sumary Pre Decisional Enforcement Conference Sumary X3 Management Meeting Sumary
. 0610: Exhibit <1 El -
Issue Date: -07/15/97-m- - . . _ _ _ .;
SAMPLE REACTOR INSPECTION REPORT Exhibit 2 NOTE: the inspection report that follows is based- on a fictional reactor licensee and a fictional inspection. The report is intended to be realistic: however, any resemblance i to an existing facility or actual events is coincidental. l This inspection report may be used as a sample or model report for matters of format and style. It illustrates how to use the standardized inspection report outline, and adheres to the expected internal organization for each report section (as discussed in IMC 0610). In several ways, however, it departs from expected practice:
- 1. Although sample report sections have been included in each of the SALP functional areas (as would generally be realistic for an integrated repor' ,, no attemat has been made to match the overall size of this report to a normal integrated report.
- 2. Instead, this report illustrates various methods of report organization that would be appropriate to various types of inspection (e.g. , events, audit reviews, observations of work). Technical issues discussed are drawn from both BWR and PWR technology.
- 3. In terms of report content, the sample report illustrates the use of
" observations, findings, and conclusions," " thresholds of significance."
varying levels of detail, and other concepts described in IMC 0610.
However, the content included in this report should not h used as a
" standard" in the sense of how individual findings are treated (i.e.,
the fact that a particular event is described in a particular way in the >
sample report does not dictate that all similar events be given a similar level of detail in other reports). As discussed elsewhere, judgments about inspection report content must be made based on the circumstances of an individual inspection, and will therefore vary.
- 4. Pages are numbered continuously through this exhibit. Inspection reports should use separate page numbering for the c.ver letter, executive summary, and report details,
- 5. Although the report details refer to several violations and the cover letter refers to a Notice of Violation (NOV), no NOV has been included here. For sample NOVs, refer to the NRC Enforcement Manual.
Issue Date: 07/15/97- E2-1 0610: Exhibit 2 I -- - . -- --- .-
SAMPLE REACTOR INSPECTION REPORT August 14, 1996 Ms. Joan A Doe, Vice President, Nuclear Greckenshire Power & Light 721Y Brick Road Stone Towers, WF 44632
SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50 998/96 07, 50-999/96 07 .
NOTICE OF VIOLATION.
Dear Ms. Doe:
r i
On July 24, 1996, the NRC completed an inspection at your Dirojac 1 & 2 reactor facilities. The enclosed report presents the results of that inspec-tion.
During the 6 week period covered by this inspection )eriod, your conduct of activities at the Dirojac facilities was generally claracterized by safety-conscious operations, sound engineering and maintenance practices, and careful radiological work controls. We are concerned. however, about two violations of NRC requirements that were ident;fied. In the first instance, NRC inspec-tors identified that, due to an improper work package assess, int and the lack ,
of a questioning attitude, a Unit I control rod was returned to service ;
without a required retest for 5 days following maintenance, in the second in-stance, NRC inspectors identified a failure to review the qualifications of a non-destructive examination (NDE) inspector before beginning work.
These violations are cited in the enclosed Notice of Violation, and the circumstances surrounding the violations are described in detail in the enclosed report. Please note that you are required to respond to this letter and should follow the instractions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to deter-mine whether further enforcement action is necessary to ensure compliance with regulatory requiremants.
t-In accordance with 10 CFR 2,790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room (PDR). ,
Sincerely, Samuel A. Johnson, Director-Division of Reactor Projects Docket Nos,: 50 998, 50-999 License Nos: :XXX 77, XXX-79 EnclosuNs: Notice of Violation-Ins [ection Report' 50'998/96 07, 50-999/96-07 10610L Exhibit-2 7 E2-2 Issue Date: 07/i5/97
J. Doe, Greckenshire Power & Light 2-cc w/ enc 1: D. Alighieri. Compliance Manager G. Harquez. General Manager, technical Services J. Austen. Plant General Manager F. Buckfv11er. General Counsel j
t t
P i
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e
- 4 m
1ssue Date: ! 07/15/97.- E2-3'- -0610: Exhibit 2-i 4.'.
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U.S. NUCLEAR REGULATORY COMMISSION REGION X Docket Nos: 50 998. 50-999 -!
License Nos: XXX 77. XXX-79 Report No: 50-998/96 07. 50-999/96 07 Licensee: Greckenshire Power & Light (GP&L) .
I Facility: Dirojac Generating Station. Units 1 & 2 +
i Locationi 11555 Granite Blvd.
Stone Towers. WF 44632 Dates: June 11 - July 24. 1996 i Inspectors: A. Rand. Senior Resident Inspector M. Heidegger. Resident inspector i J. Locke. Senior Radiation Specialist :
P. Sappho. Reactor Projects Inspector Approved by: E. Tudor Chief Projects Branch 2 Division of Reactor Projects 1
f 0610: Ex.hibit 2 E2-4 Issue Date: 07/15/97
?
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EXECUTIVE
SUMMARY
Dirojac Generating Station. Units 1 & 2 NRC Inspection Report 50-998/96 u7. 50-999/96-07 This integrated inspection included aspects of licensee operations. engineer-ing, maintenance and plant support. The report covers a 6-week period of resident inspection: in addition it includes the results of announced inspec-tions by a regional radiation specialist and a regional projects inspector.
Doerations e in general the conduct of operations was professional and safety-con-scious, with marked improvements in the clarity and thoroughness of Unit 1 shift turnovers (Section 01). Self-assessment activities observed were effective (Section 07),
e Operators responded promptly and effectively to the inadvertent opening of a main steam system safety relief valve. and to the complications that arose during the subsequent Unusual Event (Section 01.2).
e Three out of four service water pumps remained inoperable for approxi-mately 2 weeks because operations, maintenance, and management personnel were not generally aware of the risk significance of the service water system and components (Section 02.2).
Maintenance e Maintenance activities were generally completed thoroughly and profes-sionally (Section M1.1).
e The inspectors identified a violation in which. due to an improper work package assessment and the lack of a questioning attitude, a Unit I control rod was returned to service without a required retest for 5 days following maintenance (Section M1.2).
- Maintenance identified a deficient valve gasket installation through post-maintenance testing, and used this insight judiciously to discover and correct another, similar deficiency (Section M1.3).
Epaineerino e The Non-Destructive Examination (NDE) program was technically sound, including procedures, records and calibration and testing practices.
The licensee completed a technically complex core shroud repair safely and without incident (Section E1).
e The inspectors identified a violation of several Dirojac procedures that required reviewing NDE inspector qualifications before beginning work (Section E5.1).
Plant Suonort e Implementation of radiological controls in the Unit 2 refueling outage was characterized by judicious RP controls and careful radiological work practices. Source term exposure efforts continued to be successful in reducing radiation exposure (Section R1.1).
Issue Date: 07/15/97 E2 5 0610: Exhibit 2
o A tour of Unit I radiologically protected areas showed generally good radiological housekeeping and worker RP awareness (Section RI.2).
e Fire protection personnel used a fire drill to provide effective control room and fire brigade training (Section F5).
s 0610: Exhibit 2 E2-6 Issue Date: 07/15/97
l l
8tagrt Details e
Summary of Plant Status ,
Unit 1 began this inspection period at 100 percent power. On June 21. the :
inadvertent opening-of: a main steam line relief valve occasioned a manual- l
- reactor. scram, with a continuation to cold shutdown on June 22.. Following ;
repairs, Unit I returned to full power on June 29 and remained at full power. j
- for the duration of the' inspection period. ;
Unit 2 remained in a refueling outage for the entire inspection period. Major .
work activities included a reactor water clean up modification, torus coating !
repairs, in service inspection, and reactor reassembly following fuel loading.
I. Ooerations !
01 Conduct of Operations i ;
~01.1 General' Comments (71707)
Using inspection Procedure 71707, the inspectors conducted frequent :
reviews of ongoing plant operations. In general, the conduct of opera- l tions was professional and safety-conscious: s)ecific events and notewor- '
thy observations are detailed in the sections )elow. In particular, the inspectors noticed marked improvements in the clarity and thoroughness of
- Unit 1 shift turnovers during this period.
01.2 Inadvertent Ooenina of Main Steam System Safety Relief Valve (Unit 1) a, Insoection Scooe (93702) :
At 12:14 p.m. on June 21, with Unit 1 operating at 100% of rated power, !
control room operators received alarms and instrument indications that main steam system safety relief valve (SRV) A2 was open. The inspectors responded to the control room and observed the operators' response to -
- this event, including operator monitoring of annunciators and parameter trends, supervisory: control, the declaration of Unusual Event (UE), and
- the use of the following procedures: ,
e Dirojac Operational Transient Procedure (DOTP) 211. " Inadvertent ,
Opening of a Main-Steam Relief Valve," Rev. 6 *
- e'= DirojacEmerg y Res)onse Procedure (DERP) 101 " Stuck Open Main
- Steam Relief ve." lev. 4 i L b. Observations and Findinas The operators immediately implemented 00TP 211. Attempts to close the-
- SRV were unsuccessful: within'2 minutes, the operators initiated-a manual ,
- reactor. scram as required by 00TP 211 and Technical S)ecification (TS) 1 p' 3.4.2. At 12:18 p.m.. the shift manager declared a UE in accordance.-with :
' 0ERP 101, due to the failure of the SRV to close.
The operators-closed the main steam isolation valves at 550 psig to
-i
_I To)ical headings such as 01 M8. etc..-- are used in accordance with' the NRC l standarcized reactor inspection report outline. Individual reports are not expected to address all outline topics ( .
11ssue Date: 07/15/97 : E2-7 ' 0610:' ~Ex.hibit 2 ;
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reduce the depressurization rate of the reactor vessel. At 12:34 p.m.
the SRV indicated clo.,ed, with reactor pressure decreased to 410 psig.
At this point. the cooldown rate was approximately 130 degrees F per hour exceeding the TS limit of 100 degrees F per hour.
Suppression pool tem)erature reached a maximum of 124 degrees F during the event. Before t1e event the A-loop residual heat removal (RHR) system was in service for routine suparession pool cooling. Immediately after the SRV opened, the B-loop of RAR was placed in service in accor-dance with DOTP 211. At about 30 minutes into the event. the operators observed indications of cavitation on the A-loop RHR pump, and removed it from service. The system manager promptly responded to the pump room to check the A loop pump; the pump was vented and returned to service by slowly increasing the discharge flowrate.
At 1:55 a.m. on June 22 with reactor pressure reduced to below 75 psig and one loop of shutdown cooling placed in service, the UE was terminat-ed. By 3:55 a.m. Unit I was in cold shutdown with a reactor coolant temperature of 194 degrees F.
As observed by the inspectors, the operators' response to this event was excellent. Imm Iate actions taken in response ;o the open SRV were prompt. deliber.se, and in accordance with procedure. T1e operators paia close attention to the excessive cooldown rate, and actions were taken to limit cooldown as much as possible. The shift supervisor was poised and alert in directing the event response. The operators quickly recognized the RHR pump cavitation, and expeditiously returned the pump to service with the assistance of the system manager.
The NRC performed a special team inspection to independently assess licensee management decision-making, root cause analysis, corrective actions, and Dirojac's overall event analysis. The results of the special inspection are documented in Inspection Report 50-998/96-08.
- c. Conclusions Operators responded promptly and effectively to the inadvertent opening of a main steam system safety relief valve. and to the complications that arose during the subsequent UE.
01.3 Startuo Observations (Unit 1) (71707)
The inspectors observed startup activities in the Unit 1 control room on June 29. The startup was characterized by clear operator communications.
attentive reactor engineering oversight. and effective control by shift supervision. Operators used appropriate procedures and control rod pull sheets. A shift turnover near the point of criticality was well-planned and controlled. The inspectors concluded that the overall startup was performed effectively.
02 Operational Status of Facilities and Equipment 02.1 Enoineered Safety Fealgre System Walkdowns (717011 The inspectors used Inspection Frocedure 71707 to walk down accessible portions of the following ESF systems:
- Emergency Diesel Generator 1 (Unit 1) 0610: Exhibit 2 E2-8 1ssue Date: 07/15/97
i t
o Reactor: Core isolation Cooling (Unit 2) e Standby Liquid Control (Unit 2) e High Pressure Coolant injection (Unit 1) ,
Equipmentoperabilitfe.materialcondition,andhousekeepingwereaccept-able in all cases, veral minor discrepancies were brought to the !
licensee's attention and were corrected. The inspectors identified no i substantive concerns as a result of these walkdowns. i t
02.2-Service Water Pumos (Unit 2) }
a.:Insoection Scoce (71707)- ;
On June 13. during a morning tour of the Unit I control room, the ins)ec- !
. tors learned that only one of the four service water pumps was availa)le. !
The inspectors reviewed the impact of pump inoperability in relation to the Dirojac; Individual Plant Evaluation (IPE), and discussed this review j
with appropriate maintenance, operations, and management personnel, b.' Observations and Findinas l Individual. status of the pumps was as follows: .
e -A - in service, supplying service water needs. ;
e1 B - valved out of service due to a leaking check valve j
- o. C --out of service due to high-vibration i e D - out of serv t e due to impeller failure and oil seal replacement !
Pumps B. C and D had each been out of service for approximately 2 weeks.
The inspectors noted that.-'at Dirojac, the service water system is common -!'
and is not safety-related. Pumps A. B. and C are motor driven; pump D is
-diesel driven. The system provides water for auxiliary cooling, drink-ing, sanitary use and building services. .
The inspectors' review of the Dirojac IPE found service water to be a .
risk-significant system, because it provides backup emergency cooling to the charging pumps. Thus, for a loss of off-site power concurrent with a -
common mode failure of component cooling water, the reactor coolant pump
of-coolant accident from RCP failure after about 90 minutes, The IPE concludes that this scenario represents 12% of the core damage frequency (CDF). contribution.
- The inspector discussed.this-information with the licensee's probabilis-
-tic safety assessment-(PSA) group. Based on the PSA group's June 13. :
analysis (DPC 2-96-042).-having the.D service water pump out~of service
.for--2 weeks-increased the CDF by about-15%. -The licensee concluded that the diesel driven service water pump (D) is a risk-significant component.
E Based on interviess with maintenance, operations, and management person- '
'nel. 3the inspectors found that the risk significance of the! service water '
b system was not widely known! Although.the licensee is currently conduct-
- ing1PSA trainingt not allsappro)riate-personnel have taken the course;
- The inspectors concluded that t,e licensee was not fully-sensitive to the :
~, (service water pump status'and its-effect-on overall CDF.
~
i k InLdiscussions with'.the inspectors, licensee management. agreed that: -
JIssueDate: l07/15/97f E2 9 - 0610:. Exhibit-2 !
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appropriate plant personnel should be aware of risk significant systems dnd Components, and aware of the scenarios under which these systems and components can contribute significantly to CDF. The licensee formulated an action plan to correct this situation, and discussed the plan at the June 17 morning staff meeting. Key actions planned included the follow-ing:
e Dirojac would expedite returning the inoperable service water pumps to a functional status:
e the PSA group would continue with PSA-related training, including training on the risk significance of service water:
e the PSA group would review the risk scenarios involving service water to identify additional operator actions that could reduce significance; and e the PSA group would provide plant management and contrni room opera-tors with a tool to monitor current CDF status (Dirojac outage management is already using such a tool).
The inspectors found these planned corrective actions to be appropriate.
C. Conclusions Three out of four service water pumps remained inoperable for approx 1-mately 2 weeks because operations, maintenance, and manacement personnel were not generally aware of the risk significance of the service water system and components.
07 Quality Assurance in Operations 07.1 Licensee Self-Assessment Activities (40500)
During the inspection period. the inspectors reviewed multiple licensee self-assessment activities, including:
e three Plant Nuclear Safety Committee (PNSC) meetings:
e the June 24 Company Nuclear Review Board (CNRB) meeting:
e various quality assurance (0A) and quality control (OC) reviews:
e a licensee-initiated review of the operating experience feedback program (0EFP): and The inspectors observed that Greckenshire corporate managenent was present and an active participant at the PNSC and CNRB meetings. The inspectors also found that the QA/0C reviews and the OEFP review were rigorous and self-critical in applying nuclear safety principles to Dirojac activities. The inspectors concluded that the self-assessment activities observed were effective.
08 Miscellaneous Operations Issues (92700) 08.1 (Closed) LER 50-999/95004: reactor trip while subcritical due to inadequate procedure. Following a shift change. oncoming control room operators did not initiate auxiliary feedwater soon enough during preparations for Unit 2 startup. A procedure interface problem was identified, involving Dirojac Operating Procedure (DOP) 143. " Unit Startup." and DOP 512. " Steam Generator Crevice Flushing." DOP 512 0610: Exhibit 2 E2-10 Issue Date: 07/15/97
referred the operators back to the wrong portion of DOP 143, thus omitting the step requiring initiation of auxillary feedwater.
The licensee promptly corrected this procedural inadequ5c). In addition.
the licensee's error reduction task force reviewed this event thoroughly, and identified specific problems with control room verbf conniunication and shift turnovers. By directly observing shift turnovers for three different crews, the inspectors verified that these problems had been corrected.
The inspectors determined that, at the time of the event. DOP 512 was not l appropriate to the circumstances. constituting a violation of 10 CFR 50. l Appendix B. Criterion V. " Procedures." This non-repetitive, licensee- l I identified and corrected violation is being treated as a Non-Cited l Violation, consistent with Section VII.B.] of the NRC Enforcement Policy.
II. Maintenance M1 Conduct of Maintenance M1.1 General Comments
- a. Inspection Scone (62703)
The inspectors observed all or portions of the following work activities:
e 1-96EW0198: modifications to circulating water screen controls to allow slow or fast speeds in both auto and manual e 1-96PM4083: RCP undervoltage/underfrequency testing e 2-96PM3541: overload testing of 480V breaker for 2EAC FN-120C e 2-95MW2666: replace casing flange gasket on RH-E-4 e 2-96R18112: calibration of letdown heat exchanger outlet tempera-ture monitor e 2-96SF1663: spent fuel cooling system valve and pump maintenano
- b. Dbservations and Findinas The inspectors found the work performed under these activities to be professional and thorough. All work observed was performed with the work 3ackage present and in active use. Technicians were experienced and (nowledgeable of their assigned tasks. The inspectors frequently observed supervisors and system engineers monitoring job ]rogress, and quality control personnel were present whenever required 3y procedure.
When applicable, appropriate radiation control measures were in place.
In addition, see the specific discussions of maintenance observed under M1.2 and M1.3. below.
M1.2 Untimely Retest Followina Scram Inlet Valve Packina Adiustment (Unit 1)
- a. Inspection Scone (62703)
The inspectors observed partial performance of Dirojac Maintenance Procedure (DMP) M51. " Adjustment of Scr m Inlet Valve Packing," Rev. O.
under Work Package 1-96MW3117. and later followed up on the completion of the work package. Discussions were held with maintenance workers, control room operators, and supervisors.
Issue Date: 07/15/97 E2-11 0610. Exhibit 2
- b. Observations and findinos On June 13 the inspector observed Unit 1 maintenance workers tighten the valve packing on scram inlet valve 2 SCV-134 for control rod J 10. The l
= maintenance workers stated that Operations had authorized the work. The I maintenance workers were professional and familiar with the procedure, and the packing adjustment was completed without incident.
On June 18. in reviewing packages awaiting testing. the inspector found that Work Package 1-96MW3117 was still filed as not completed, because the control rod had not yet been tested for scram time in accordance with the retest portion of the package, in a tour of +he control room. the inspector found that control cod J-10 was in service. A review of the June 13 operator logs revealed that the control rod had been returned to operational status following the scram inlet valve packing adjustment.
The inspector brought this matter to the attention of the shift engineer.
After reviewing the work package, with Unit 1 operating at full power, the shift engineer declared control rod J 10 inoperable. Operators fully inserted the rod. then successfully completed scram time testing. The work package was then filed as complete, and the control rod returned to service.
Later discussions confirmed that the control rod had been inserted and removed from service during the packing adjustment. At the completion of the adjustment, the shift engineer had asked the maintenance foreman for the retest requirements. Instead of reviewing the retest portion of the work package. the maintenance foreman had reviewed a vendor memorandum and incorrectly determined that a scram time test was not required. The shift engineer had not questioned the foreman's assessment, and had not independently verified the post-maintenance testing requirements.
10 CFR 50.55a and Section lWV-3200 of ASME Section XI (1986) require that after valve stem packing is adjusted. and before returning it to service, the valve shall be tested to demonstrate that performance parameters are within acceptable limits. Failure to perform a scram time test after tightening the packing and before returning control rod J 10 to service on June 13. 1996 is a violation of these requirements (50-998/96007-01).
The cause of this failure appeared to be an improper assessment by the maintenance foreman and the lack of inde)endent verification (and the lack of a quest.1oning attitude) by the s11ft engineer.
M1.3 Post-Maintenance Test of Hydraulic Control Unit (Unit 2)
- a. Insnection Stone (62703)
The inspectors reviewed a licensee finding of improperly performed maintenance on a hydraulic control unit (HCU) isolation valve. The inspection included a review of Dirojac Maintenance Procedure (DMP) M33.
" Hydraulic Control Unit Isolation Valve Overhaul and Inspection." Rev. 3.
and a review of the licensee's actions to correct the problem.
- b. Observations and findinas On July 6. during post-maintenance testing of Unit 2 hydraulic control 0610: Exhibit 2 E2-12 1ssue Date: 07/15/97
unit (HCU) A8 13. the licensee identified that the CDU-24 valve body to-bonnet joint leaked excessively. The licensee concluded that maintenance personnel had installed the bonnet in a cocked position. The licensee revised the installation procedure to require clecking the body to bonnet joint gap.
Maintenance checked the body.to-bonnet joints for all HCU valves worked during the outage. During the gap checks, the licensee identified one additional cocked body to-bonnet joint (associated with HCU B6-22). The licensee found an extra casket in the joint and determined that ti.e old gasket had been left in by mistake. Maintenance repaired this deficien- ;
cy, and performed a satisfactory gap check on the valve. )
Technical Specification (TS) 6.2.a requires that written procedures be established. implemented, and maintained covering activities recommended in Regulatory Guide 1.33. Rev. 2. Appendix A. TS 6.2.a applies to DMP-M33. The failure to remove the old gasket during maintenance was a violation of TS 6.2.a. in that DMP M33 required the old gasket to be removed and discarded. This non repetitive, licensee-identified and l corrected violation is being treated as a Non Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50 999/96007-02).
M1.4 Conclusions on Conduct of Maintenance Maintenance activities were generally completed thoroughly and profes sionally. The inspectors identified one violation in which an impro er work package assessment and the lack of a questioning attitude result d in a Jnit I control rod being returned to service without a required retest for 5 days following maintenance. in another instance, an NCV resulted when Maintenance identified a deficient valve gasket installa-tion through post-maintenance testing, and used this insight judiciously to discover and correct another, similar deficiency.
M8 Miscellaneous Maintenance Issues (92902)
M8.1 (Closed) Follow-Vo item 50-999/96002-03: adequacyofsafetyinjection system surveillance test. This item was ooened pending D1rojac s upcoming revision of Procedure DST-213. "S'fety a Injection System." to ensure a reliable check of the reactor trip resulting from safety injection signal logic interfacing relay contacts. The inspector verified that DST 213 had been revised, and provided instructions for fully testing the interfacing relay contacts for both trains. The surveillance test had been completed satisfactorily on April 23. 1996.
M8.2 (Closed) Violation 50-998/96003 03: failure to provide adequate proce-dural guidance for check-valve inspection retest. Dirojac Surveillanc0 Procedure (DSP) 740-2 "HPCI Torus Suction Check Valve Inspection " Rev.
I did not verify the disc would properly seat after the check valve internals were reassembled. The licensee had revised the procedure to incorporate a seat tightness test (using a feeler gauge) after valve internals were reassembled, in addition, for check valve disassembly, the licensee completed a data sheet to document the type of seat leakage check to be performed on each valve. The inspectors reviewed three subsequent work recuests involving check valve disassembly and inspec-tion, and confirmec that a seat leakage test had been properly documented in each case. The inspectors concluded that the licensee's corrective actions had been appropriate.
Issue Date: 07/15/97 E2-13 0610: Exhibit 2
. - . ~. . .-_ _ ..
I III. Enainee, ting )
El Conduct of Engineering l El.1 Non Destructive.Examinatkn Procram Review
- a. Insoection Scoce (73051) l The inspectors reviewed procedures and documents related to non-destruc- i tive examination (NDE) equipment, data, and evaluations. The review included 27 NDE test packages and 13 in service inspection (ISI) proce-dures.
In addition, the inspectors observed NDE personnel perform several calibrations of NDE equipment, review material certifications, perform inspections, and conduct ultrasonic testing associated with the Unit 2 core shroud repair (see Sections El.2 and E5.1).
- b. Observations and Findinas The inspectors found each of the applicable ISI procedures to be accept-able, approved by the ISI contractor, and in accordance with ASME Section
- V, 1989 edition. Examination data and documentation were also in accordance with the 151 procedures and ASME Code requirements.
The calibrations and material certification reviews observed by the inspectors met procedural and ASME Code requirements. NDE personnel ,
performing inspections properly identified and recorded indications, compared them to procedural acce)tance requirements, and where applica-ble, processed and re examined t1e indications.
El.2 Core Shroud Renair (Unit 2)
- a. Insnection Scono ./3051)
The inspectors observed various phases of the core shroud repair, including modification installation, NDE inspections of the completed arocesses, and cuality documentation. The repair was performed under Jirojac Design Fodification (DDM) 296 43.
b, Observations and Findinas DDM 296-43 was initiated to re) air cracked horizontal welds in the reactor vessel core shroud. T1e modification consisted of installing four vertical tie rod assemblies, designed to restrict vertical and horizontal shroud movement should the weld cracks propagate.
The inspectors observed that the contractor performing the installation took care in planning and briefing personnel before beginning work, adhered closely to the installation procedure, and was methodical and attentive during ultrasonic testing. The contractor experienced diffi-culty in aligning two of the tie-rod assemblies; however, considering the complexities of the processes involved and the new design overall work activities proceeded smoothly. Licensee oversight of contractor activi-ties was thorough and well-coordinated.
One roblem was noted with NDE inspector qualification (see Section E5.1 .
0610: Exhibit 2 E2-14 Issue Date: 07/15/97
El.3 Conclusion; on Conduct of Enoineerina The inspectors found the NDE program. including procedures. records. and calibration and testing practices, to be technically sound. The licensee completed a technically complex core shroud repair safely and without incident.
ES Engineering Staff Training and Qualification E5.1 Qualification of Level 11 NDE Inspectors (Unit 2)
- a. Inspection Stone (73753)
The licensee's inspection of the Unit 2 core shroud involved ultrasonic testing of core shroud vertical welds by contractor non destructive examination (NDE) personnel (see Section E1.2). The inspectors reviewed NDE personnel qualification records for consistency with ANSI N45.2.6-1978, the Dirojac Quality Assurance Manual (DOAM), and the following related licensee procedures:
e DOAP 320-3. "Non-Destructive Examination Personnel Certification Review." Rev. 2 o DTP 110 6. "In Service Inspection Plan." Rev. 10
- b. Observations and findinas t On July 14 the inspectors identified that the licensee did not have qualification documents for a contractor Level 11 NDE inspector perform-ing the core shroud inspections. In addition, the inspectors could find no evidence that the licensee had reviewed the UDE inspector's qualifica-tions.
The inspectors discussed several requirements with the engineering supervisor in charge of the NDF work. ANSI N45.2.6-1978 requires that records of personnel qualifications be maintained by the employer. The DOAM required the designated technical services engineer to obtain qualified contractors for in-service inspections and to review NDE personnel qualifications before beginning work. DOAP 320-3 required completing a certification checklist before beginning work. DTP 110-6 required employee. preparing a qualification review sheet for each contractor NDE The engineering supervisor was unaware of whether the necessary certifi-cation reviews had been performed. Additional licensee evaluation determined that the certification review, checklist, and qualification review sheet had not been completed for the NDE inspector in question.
The licensee stopped the core shroud inspection until the required qualification documents had been obtained and the certification reviews completed.
The inspectors did not find any similar deficiencies with the qualifica-tion and certification of other NDE inspectors. In addition, no safety problems were identified with the performance of the NDE inspector in question. However, the inspectors noted that previous problems had been identified with monitoring the qualifications of a security contractor (IR 50-999/96-04) and a contracted inspector for the torus re-coat work (IR 50-999/96 06).
Issue ite: 07/15/97 E2-15 0610: Exhibit 2
Technical Specification 6.2.a requires that written procedures be established implemented. and c.aintained covering activities recommended in Regulatory Guide 1.33. Rev. 2. Appendix A. Ta 6.2.a applies to D0AP 20 3. DTP 110 6. and the DOAM. Failure to perform the required qualifi-cation and certification reviews before beginning core shroud ultrasonic testing is a violation of TS 6.2.a (50-999/96007-03),
- c. Conclusions The inspectors identified a violation of several procedures that required reviewing NDE inspector qualifications before beginning work. At the completion of the inspection, the licensee had not determined the cause of this failure.
E8 Hiscellaneous Engineering Issues (92902)
E8.1 (Ocen) Unresolved Item 50-998(999)/95015 03: diesel generator cooling water (DGCW) 1ssues. Two issues had been identified: (1) the DGCW systems for both Units 1 and 2 were in unbalanced flow configurations, such that flow distribution to individual coolers could not be determined with precision; and (2) the licensee's system flow test did not demon-strate whether the 1/2 DGCW pump could meet the demands of the 1/2 diesel generator heat exchanger and the Unit 1 ECCS pump room coolers.
Regarding item (1). due to silt accumulation both DGCW systems remain in unbalanced flow mnfigurations. Using existing flow and temperature measurements. Engineering was able to demonstrate (using worst case assumptions) that sufficient flow existed in each system to maintain system operability. However, to improve flow characteristics and the accuracy of flow distribution measurements, the licensee intends to remove silt accumulation by hydrolazing the Unit 2 DGCW piping during the present Unit 2 outage. After hydrolazing, the licensee plans to retest the flows to the diesel generator and ECCS room coolers to verify.
sufficient flow. Flow balancing of individual coolers is not currently planned.
Regarding item (2). the licensee had added an additional test cot.iigura-tion to DST 640-8. " Quarterly DGCW to Unit 1 and Unit 2 ECCS Room Coolers flow Test," Rev. 2. to verify that the 1/2 DGCW pump could meet necessary flow demands. On May 23. 1996, the licensee's completion of the flow test using the revised procedure successfully demonstrated the capability of the 1/2 DGCW pump in meeting the flow demands specified above. This portion of the unresolved item is closed.
This item will remain open pending resolution of item (1).
IV. Plant Supoort R1 Radiological Protection and Chemistry Controls RI 1 Refuelina Outaae Radioloaical Controls (Unit 2) 0610: Exhibit 2- E2-16 1ssue Date: 07/16/97 v "' - ww+y
- a. J.soection Scone (8372H The inspectors reviewed radiological controls implemented in the Unit 2 refueling outage, including exposure records. ALARA goals and results.
and radiological problem reports (RPRs). The following high-dose jobs were observed in progress (either remotely or on location):
o residual heat removal (RHR) heat exchanger repair and pump motor refurbishment e high pressure core injection (HPCI) sparger modification e reactor water cleanup (RWCU) modification e torus coating repairs The ins)ectors also made frequent tours of the radiologically protected area (R>A), and discussed specific radiological controls with the ALARA supervisor and various radiation protection (RP) technicians,
- b. Observations and Findinos Outage dose to date was about 315 rem (3.15 SV) without about 70% of the work completed. Current exposures for the most significant jobs were as follows:
e RWCU modification 62 rem (0.62 Sv) e torus coating repairs. 51 rem (0.51 Sv) e in service inspection. 32 rem (0.32 Sv) e chemical decontamination of RWCU, RHR and reactor recirculation 31 ping 9 rem (90 mSv) e iPCI sparger modification 11 rem (0.11 Sv) e overhaul of main steam isolation valves (4 rem (40 mSv) e reactor assembly / disassembly (4 rem (40 mSv)
Both the torus and RWCU jobs were near complet' with no significant problems encountered. The remaining jobs were well below their respec-tive dose goals. due to good chemical decontamination results and efficient job management. However, the overall performance indicated that dose goals could have been more challenging.
The licensee identified several examples in which poor planning. communi-cation. and coordination resulted in unnecessary dose. For example. poor planning resulted in an RHR service water valve unnecessarily being taken out of service before performing the chemical decontamination. These unnecessary dose issues were identified by work groups other than RP.
Indicating some success in station efforts to improve overall RP aware-ness.
The inspectors reviewed three minor intakes associated with the torus work. The intakes were not caused by poor planning or inadequate job coverage, and resulted in minimal exposure.
Source term reduction efforts continued with hydrolazing, use of pipe vibrators to loosen crud. the chemical decontamination mentionei above.
installation of permanent shielding around the spent fuel pool neat exchangers, and decontamination cf the reactor building equi) ment drain l
tank. The licensee estimated that about 700 rem (7 Sv) had )een saved by
! these efforts to date.
During RPA tours, the inspectors noted good radiological housekeeping and Issue Date: 07/15/97 E2-17 0610: Exhibit 2
)
excellent worker awareness of radiological hazards. The inspectors also ,
noted sound RP controls and careful radiological work practices during '
thejobsobserved,
- c. Conclusions ,
Implementation of radiological controls in the Unit 2 refueling outage was generally characterized by judicious RP controls and careful radio-logical work practices. Source term reduction efforts continued to be successful in reducing radiatior. exposure.
RI.2 Tour of Unit 1 Radioloaically Protected Area (RPA) a.InsoectionScone(83750)
On July 2, one inspector accompanied an RP technician on a tour of the Unit 1 RPA and outside areas to observe and discuss radiological control practices. The inspector also reviewed the Unit I radiological event reports (RPRs) for May and June,
- b. Observations and Findinas Unit I radiological housekeeping and worker awareness of radiological hazards was generally good. The RP technician verified various Radiation Area and High Radiation Area boundary postings. using an R0-2 portable radiation detector. No discrepancies were observed.
During the tour of areas outside the RPA (but inside the restricted area). the RP technician discovered a yellow bag of contaminated material and several contaminated tools inside the motor-operated-valve trailer a recently released RPA. The bag was labeled as containing material with contamination levels of 3,000 - 115.000 disintegrations per minute (dpm).
The tools were painted purple, denoting fixed contamination. The RP technician took prompt action to secure the trailer, perform additional surveys, and post the area.
Subsequent licensee investigation found that the trailer had previously been posted as an RPA and Radioactive Materials Storage Area (RMSA), but had been released from RPA and RMSA status on June 30. The trailer had been surveyed and released by a contractor RP technician. The Unit 1 RP-manager informed the inspector that licensee policy did not normally allow contract technicians to release an area from RPA stat'..
The licensee performed additional surveys demonstrating that the radioac-tive material contained in the yellow bag was less than 10 times the quantity of licensed material specified in Appendix C to 10 CFR SS 20.1001 - 20.2401. The insoector concluded that the lack of radiological posting on tha motor-operated valve trailer did not constitute a viola-tion;-however, the inspector's review of RPRs disclosed two other recent instances-in which the release of temporary RPAs had not been well controlled. The-Unit 1 RP manager stated that the effectiveness of RPA
-release policies would be reviewed.
- c. Conclusions AtourofUnit1radiologicallycontrolledareasdemonstratedgenerally
- good radiological housekeeping and worker RF awareness, but raised a
-question about control of contaminated material and RPA release practic-0610: Exhibit 2 E2-18 Issue Date: 07/15/97
es. This matter will be reviewed during a future inspection (50-998/96- l 007-01).
R7 Quality Assurance in Radiological Protection and Chemistry Activities (83729)
The inspectors attended two meetings of the ALARA Review Comittee. The meetings were attended by representatives from mechanical and electrical maintenance system engineering. and outage management Participation was enthusiastic and well-coordinated: as a group, the committee was perceptive and innovative at devising methods for minimizing exposure.
F5 Fire Protection Staff Training and Qualification
- a. InsDection Stone (647Q41 The licensee conducted a fire drill on the afternoon of July 1. The inspectors monitored activities in the control room and fire brigade actions at the scene.
- b. Observations and Findinas Licensee fire protection personnel simulated a fire'in the Unit 2 AFW pump cage area. Control room operators referred ap3ropriately to emergency response and safe shutdown procedures. T1e fire brigade responded as directed by the control room announcement. Fire brigade members were prompt. ef ficient, and knowledgeable of applicable station practices.
In addition, the inspectors observed that fire protection personnel provided effective training by creating a challenging drill scenario and providing useful, perceptive comments in the post-drill critique.
c. Conclusion
Fire protection personnel used a fire drill to provide effective control room and fire brigade training.
V. Manaaeraent Meetjngs X1 Exit Hee ag Summary The inspectors ) resented the inspection results to members of licensee management at t le conclusion of the inspection on July 24, 1996. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identi fied.
X2 Pre Decisional Enforcement Conference Summary On July 24. a pre-decisional enforcement conference was held at the NRC Region I office to discuss potential enforcement issues identified in Inspection Report 50 998, 999/96 006. The issues related to radiological concerns over issue Date: 07/15/97 E2-19 0610: Exhibit 2
. - . -~. . _ _ . . . .
1 01rojac's control of access to high radiation areas. Slides used in the licensee's presentation at the conference have been included as Attachment A to this report i 1
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e 1
I 4
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4
'0610:. ExhibitL2_ _ E2 20 ' Issue Date: 07/15/97l t
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PARTIAL LIST OF PERSOf45 C0!4TACTED Licensee J. Alighiert. Manager, Compliance J. Austen. Plant General Manager W. Blake, Radiation Protection Manager. Unit 1 R. Hall. Operations Manager. Unit 2 L. Hsun, Radiation Protection Manager. Unit 2 G. Marquez. General Manager. Technical Services T. Morrisson, Supervisor, Mechanical Maintenance. Unit 1 Z. Thurston. Operations Manager. Unit I lE J. Dunne, Dirojac Project Manager Issue Date: 07/15/97 E2-21 0610: Exhibit 2
INSPECTION PROCEDURES USED IP 40500: Effectiveness of Licensee Controls in Identifying Resolving, and Preventing Problems IP 62703: Maintenance Observation IP 64704: Fire Protection Program IP 71707: Plant Operations IP 73051: Inservice Inspection - Review of Program '
IP 73753: Inservice Inspection IP 83729: Occupational Exposure During Extended Outages IP 83750: Occupational Exposure >
IP 92700: Onsite followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92902: Followup Engineering IP 92903: Followu] Maintenance IP 93702: Prompt Onsite Response to Events at Operating Power Reactors ITEMS OPENED, LOSED, AND DISCUSSED Onened 50 998/ % 007 01 V10 failure to retest control rod after maintenance 50 99.:'J6007-02 NCV failure to remove old gasket during maintenance 50-999/96007-03 VIO failure to review NDE inspector qualification ,
50 998/96007-04 IFI control of contaminated material and RPA release practices Closed 50-998/96003-03 V10 failure to provide adequate procedural guidance for .
check-valve inspection retest 50 999/95004 LER reactor trip while subcritical due to inadequate procedure
.50-999/96002-03 IFT adequacy of safety injection system surveillance test Discussed 50 998/95015 06 URI diesel generator cooling water issues
'0610: ; Exhibit'2 E2-22 -Issue Date: 07/15/97'
LIST OF ACRDNYMS USED AFW Auxiliary feedwater ALARA As low As Reasonably Achievable ASME American Society cf Mechanical Engineers CDF Core Damage frequency CFR Code of Federal Regulations CNRB Company Nuclear Review Board DDM Dirojac Design Modification 4 DERP Dirojac Emergency Response Procedure DGCW Diesel Generator Cooling Water DMP D1rojac Maintenance Procedure DDTP Dirojac Operatior 1 Transient Procedure dpm disintegrations pr d nute 00Ah Dirojac Quality A urance Manual 00AP Dirojac Quality As.urance Procedure DSP Dirojac Surveillance Procedure DTP Dirojac Test Procedure ECCS Emergency Core Cooling System
.ESF Engineered Safety Feature GP&L Greckenshire Power and Light HCU Hydraulic Control Unit HPCI High Pressure Coolant Injection IFl Inspection followup Item IPE Individual Plant i. valuation IR Inspection Report ,
ISI Inservice Inspection -
LER Licensee Event Report mSv milli-Sievert NCV Non Cited Violation NDE. Non-Destructive Examination <
NRC Nuclear Regulatory Commission Operational Experience Feedback Program OEFP PNSC Plant Nuclear Safety Committee PSA Probabilistic Safety Assessment GA Quality Assurance OC Ouality Control RHR Residual Heat Removal RMSA Radioactive Materials Storage Area RP Radiation Pro +ection RPA Radiologically Protected Area RPR Radiological Problem Report RWCU Reactor Water Clean-Up SRV Safety Relief Valve
! Sv Stevert TS Technical Specification UE Unusual Event VIO Violation l
l <
l l
Issue Date: 07/15/97 E2-23 0610: Exhibit.2
- y. , y.. ...y., .r , ,- - . . ,. ,. __,.,_ .y.w ...y..
T STANDARD MATERIALS INSPECTION REPORT GUTLINE Exhibit 3 This materials -inspection report outline need only include at eas inspected or applicable. In most cases, only a few of the areas below will have been inspected or applicable for a specific inspect.on. Conversely, the " Report Details" should include any other areas that were inspected but are not named in this outline. The outline t'iould serve only as a guide to draft inspection reports. It can and should oe revised as necessary, to fit each inspection.
Cover Letter Cover Page Executive Summary Persons Contacted Report Details - 2
- 1. Management Oversight
- a. Radiation Safety Committee
- b. Radiation Safety Officer
- c. Audits. Reviews or Inspections
- 2. Organization and Scope of the Licensee Program
- 3. Facilities
- 4. Equipment and Instrumentation
- 5. Materials Receipt. Use. Transfer, and Control
- 6. 1 raining. Retraining, and Instructions to Workers
- 7. Area Radiation Surveys and Contamination Control
- a. Area Surveys ,
- b. Handling and Use of Radioactive Materials c, Protection of Members of the Public
- d. Leak Tests and Inventories
- 8. Persont.el Radiation Protection
- 9. Radioactive Waste Management
- a. Disposal
- b. Effluents
- c. Waste Management
- d. T'acords
- 10. Recordkeeping for Decommissioning
- 11. Transportation
- 12. Posting and labeling
- 13. Generic Communication of Information
- 14. Notifications and Reports
- 15. Special License Conditions or Issues Exit Meeting Summary List of Acronyms 1
Observations, demonstrations. and measurements (both independent measure-ments and confirmatory measurements) made by the inspector during the course of the inspection should be described in the section of the " Report Details" that is mo:', applicable.
Issue Date: 07/15/97 E3-1 0610: Exhibit 3
STANDARD CONTAINMENT AND STORAGE INSPECTION REPORT OUTLINE Exhibit 4 f In addition to the major areas listed below. generic or routine areas inspected should be included in the inspection report. For containment and storage inspections, only some of the areas below will have been inspected or applicable for that i'. pection. As described below, the " Report Details" section should include any other areas that were inspected but are not named in this outline.
Cover Letter Cover Page Executive Summary Perons Contacted Report Details!-
- 1. [ Enter first major programmatic area inspected. If appropriate, each area could correspond to a different inspection procedure covered during the inspection. For instance. " Management Controls")
- a. [lf necessary, each major area may be divided and subdivided as necessary.]
- b. [Use as many divisions and subdivisions as necessary.]
- 2. [lf more than one programmatic area was inspected, enter the next major programmatic area inspected, such as " Design."]
- 3. [ Enter the next laajor programmatic area inspected, such as "Fabrica-tion."]
- 4. [ Enter the next major programmatic area inspected, such as "Mainte-nance."]
List of Documents Reviewed Notice of Violation or Nonconformance (if applicable) 2 Observations, demonstrations, and measurements (both independent measure-ments and confirmatory measurements) made by the inspector during the course of the inspection should be described in the section of the " Report Details" that is most applicable.
Issue Date: 07/15/97 E4-1 0610: Exhibit 4
STANDARD FUEL CYCLE INSPECT 10N REPORT O'JTLliE Exhibitj In addition to the major areas listed below, generic or routine areas inspected should be included in the inspection report. For most fuel cycle facility inspections, only a few of the areas below will have been inspected or applicable for that inspection. As described below, the " Report Details" section should .
include any other areas that were inspected but are not named in this outline.
Cover Letter Cover Page Executive Summary Persons Contacted Report Details':
- 1. Introduction (Optional - for team inspections and original program inspections.)
- a. Process Background
- b. Inspection Overview
- c. Summary of Inspection Observations 2, Programmatic Areas inspected (if appropriate, each area could correspond t- a different inspection procedure covered during the inspection),
- a. If necessary, each major area could be divided as necessary. For instance, " Radiation Protection" could be subdivided into Internal. External, Members of the Public, and Records.
- b. Usa as many divisions and subdivisions as ; w 3ary.
- 3. If more than one programmatic area was inspected, enter the next major programmatic area inspected, such as:
Plant Operations Chemical Safety Criticality Safety Radioactive Waste Material Control and Accountability Physical Protection Radiation Protection Effluents Transportation Environmental Monitoring Exit Meeting Summary list of Acronyms Observations, demonstrations, and measurements (both independent measure-ments and confirmatory measurements) made by the inspector during the course of the inspection should be described in the section of the " Report Details" that is most applicable.
Issue Date: 07/15/97 E5-1 0610: Exhibit 5
NONCOMPLIANCE INFCRMATION CHECKLIST ADoendix A NOTE: This checklist is presented as a guideline for gatnering and arranging enforcement-related information. However, it should not be considered prescriptive, nor in all cases will it-be all- .
encompassing.
REOUIREMENT o What requirement or commitment was violated? If the requirement was conditional, how were the conditions satisfied which made the requirement applicable?
STATEMENT OF VIOLATION o How was the requirement or commitment violated?
o_ By whom (individuals and titles)- was the requirement or commitment violated?
o When was the requirement or commitment violated and what was the duration of tkt violation?
CONTEXT a -What were the circumstances surrounding the violation (such as system configuration and o)erational ct,..ditions for reactor cases)?
o _- How, when, and by w1om (licensee or NRC) was the violation discovered?
o- When was the licensee aware or. put on notice of the problem requiring corrective action?
o Was the violation the result of a self-disclosing event?
ROOT CAUSE/ CORRECTIVE ACTIQN o What was the apparent root cause (and contributing causal factors) for the violation?
o -What-short-term corrective and remedial action was taken and when was it taken?
o Did NRC have to intervene to accomplish satisfactory short-term corrective and remedial action and, if so, to what degree?
o Were the licensee's corrective actions comprehensively or narrowly focused?-
ENFORCEMENT SIGNIFICANCE
.o- What was the actual. safety consequence of the violation (e.g., overex-posurer release of radiation. -loss of redundancy, inoperable safety system, degraded system, etc.)?
o What was the potential safety consequence _ of the violation?
o Are there other circumstances surrcunding the violation which increase or decrease its' significance (e.g., appearances of willfulness, careless
' disregard)?
NOTE: ; Inspection documentation should describe the circumstances of the-violation in a matiner to support later- discussions regarding enforcement
" action. However, inspect 1on reports should HQI offer conclusions regarding safety significance willfulness, or careless disregard, as these are agency conclusions, ilssue Date: 07/15/97 A-1 0610: Appendix A
a Was management aware or should it have been aware of the violation? .
o is there evidence that management was involved directly or indirectly in the violation and to what extent?
o Is the violation a repetitive violation or similar to past violations?
If- so, should the previous corrective actions have been -adequate to prevent recurrence?
o Are the inspection findings of programmatic problems?
ADDITIONAL FACTORS a If the violation was a result of a self-disclosing event. did the licensee demonstrate initiative in identifying the root cause?
a Were there prior opportunities for the licensee to identify the violation, such as through audits or NRC or industry notification that would have reasonably put the licensee on notice of the potential for a violation?
o Do the inspection findings represent another example of r ar performance or do they represent an isolated occurrence?
o Were there multiple examples of a particular violation?
o Did thi duration of the violation add particular significance to the issue?
REPORTABILITY a If the violation or the conditions leading to the violation were required to be recorded and the matter was not properly recorded, what was the applicable recording requirement?
o Was the violation required to be reported and, if so, what was the applicable reporting requirement?
o Was the violation reported and, if so, when and by whom was it reported?
o If the violation was reported, but the report was late, why was the report late?
a Was the report complete and accurate?
0610: Appendix A A-2 Issue Date: 07/15/97
1 MANAGING THE WRITING PROCESS Accendix B
- a.
Introduction:
Writina Efficient 1v and Clearly. Few inspectors place report writing high on their list of favorite activities. For many, the writing process is a frustrating, laborious experience involving many revisions. Contrary to popular belief, however, techniques can be ,
learned that will make the writing experience more manageable.
Learning to present facts in a clearly developed, logical order is a key ingredient in developing your communication skills. By consistent practice, you will recognize patterns of thought, repetitive arrangements of similar facts, that will increase both the speed and effectiveness with which you write. In addition these familiar, repetitive ways of thinking will help you ask key questions earlier in the inspection process, thus improving your field inspection skills as well as your writing.
- b. Seoaratina the Parts of the Writina Process. Writing involves planning, brainstorming, organizing, draf ting, and revising. Trying to perform all of these activities at once will produce " writer's block " incoherent presentation of findings, sloppy final drafts, and extended cycles of report review and revision. A more effective writer breaks the writing process into stages to avoid frustration. save time, and produce a more professional product.
- 1. Plannina, For the inspector, planning is the simplest stage of the report writing process: however, it asks two important questions that will help to maintain later focus-o What is the purpose and scope of this inspection report?
e Who are my readers, and what are their priorities?
Ideally, these questions will be answered before beginning w inspection. The purpose of the inspection report, will vary slightly with the nature of the inspection findings (e.g. , depending on whether or not significant weaknesses or enforcement matters were identi fied), The scope of the inspection report will be similar to the scope of the inspection itself, which in turn may be largely determined by the scope of a well-prepared inspection plan.
The report's principal reader, as stated earlier, will be the vice president. nuclear (for a reactor facility), or a similar official.
This reader's priorities will include understanding 'our findings (and perhaps defending a differing perspective), evaluating your conclusions, improving facility safety, protecting the environment, continuing unhampered operation, and maintaining good public relations. Being aware of these reader priorities will not change any of the inspection results (i.e., the report observations.
findings, and conclusions); however, it will help to make you a better communicator _ (e.g. , in setting the proper tone for the cover letter, or in emphasizing the need for written conclusions to be well supported by facts).
In addition, never expect to become a skilled report writer unless the inspection itself is well-planned. The importance of a detailed inspection plan cannot be overemphasized: it will not only influence the effectiveness of your inspection, but will also directly affect Issue Date: 07/15'97 B-1 0610: Appendix B l
I l the amount of time you spend in writing. A good inspection plan is your first report outline.
- 2. Brainstormina. Brainstorming involves the rapid, non-critical dumping of ideas onto paper (or into a com) uter). Like planning, brainstorming will first occur during tie construction of an effective inspection plan. In addition you will brainstorm during almost any inspection, as you speculate on the implications of your observations and inspect new areas, in writing reports, brainstorming is the single most effective wea>on against writer's block. When presenting a difficult tecinical issue, writer's block may resu't from the unrealistic ambition of trying, simultaneously. to remember all the necessary details, balance each one against the appropriate regulatory criteria, analyze the major areas of discrepancy, and blurt out the whole conglomeration as a coherent. well-organized report section.
Instead, brainstorm by listing all the related ideas rapidly on paper or computer, working from memory and your inspection notes.
Avoid worrying about organization or relative importance or what the report reviewer will think. Your brainstorming is complete only when you have ensured yourself that all details relevant to this report section have been written down. At that point, you are ready to consider the next step of the writing process.
- 3. Oraanizina. Organizing naturally follows brainstorming. Group your brainstormed ideas into topical categories, then arrange each the ideas in each category in a logiul order. If the scope of your inspection did not change significantly, these categories and their order may correspond naturally to the outline already provided by your original inspection plan. Standard methods of organizing 5
details include:
e Order of Imoortance. Within each category. present the observations and findings beginning with the most significant.
e Cnronoloaical. This method is useful in presenting the essential details of a complicated event.
e Comoarison/ Contrast. This is the organizational method used for writing Notices of Violation. in which the regulation is quoted or paraphrased and closely parallel language is used in the " Contrary to" statement. This is also an effective method of presenting a negative finding in the report details.
In addition, you may find it helpful to construct " repetitive formats" as organizational models for certain types of findings where the underlying structure is gererally the same from one report to another (such as when documenting events. follow-up of open items, noncompliances. review of audits. etc.). This technique is an extremely effective time-saver. Section 07.02.c of IMC 0610 gives additional guidance on how to create and use these " repetitive formats."
- 4. Dra f t ina. Now you are ready to draft the report. Most of the distaste inspectors feel for report writing is focused on this stage 0610: Appendix B B-2 Issue Date: 07/15/97
- . - - .-= , - . - - - - _
of the process. However, as stated earlier, frustration in writing is often the result of trying to do too many things at once. By .
breaking the writing task into separate, manageable steps, you make drafting itself a shorter. less complicated process, If you have planned._brainstormed, and' organized well, and if you resist the temptation to revise as you go, you can write your draft raaidly and effectively. This usually involves un-learning bad haaits, and requires practice. Follow these drafting steps:
(a) Work from your outline' of categories and brainstormed, organized notes.
(t) Begin with any section.
(c) Write quickly!
(d) Resist the temptation to edit!
Step (d) is, by far, the most difficult. Most writers have. learned to re-evaluate spelling, syntax, organization, and even the value of the written content while they are actually drafting. By resisting this acquired habit, the drafting process speeds up, revision becomes a natural part of the writing procass, and the result is both more polished and more quickly produced.
- 5. Revisina. Always let your draft " cool off" before beginning to revise. If you revise while you draft, or revise immediately after drafting, you will tend to see the inspection report in your mind's eye rather than the one on paper. As a result. you will be vulnerable to missing obvious mistakes.
In addition, never submit this first draft to your supervisor for review, Supervisors often take on the role of technical editor, making the review and concurrence process into a frustrating cycle of revised revisions. You can avoid this frustration by learning to responsibly edit your own work.
Levels of revision should be prioritized. Some corrections are more impcrtant than others: if you begin by focusing on spelling and punctuation, you may be too distracted to notice larger organiza-tional problems. The most effective practice is to revise in several stages.
The first stage is a rapid read-through to check for overall coherent organization and level of detail in-each report section.
If no major revisions are needed, the second stage review is then performed, reading to assess paragraph structure, sentence style, and clarity of syntax. The final stage is a careful word by-word proofread to check for spelling, punctuation, and accuracy. An
" Inspection _ Report Review Checklist" that explains each of these revision stages in detail is given in IMC-0610. Appendix C.
- c. Understandina the Supervisory Review Process The_ inspection' report review and concurrence process is frequently an area of inefficiency. For both supervisors and inspectors. it can become the' focus of considerable frustration. Much of this frustration-comes Issue Date: 07/15/97 B-3 0610: Appendix B
from miscommunication, unclear standards, and misunderstood roles. By understanding the review process and applying intelligent effort, you can l help to make these interactions positive and productive.
- 1. The imoortance of Suoervisory Review. The inspector and the supervisor are in some ways like liaisons to the rest of the world.
The inspector, as the NRC's " eyes and ears." interacts with the licensee or vendor with a responsibility to observe accurately, analyze logically, and report the results. The supervisor's responsibility is to ensure that when these results return to the "outside world" in their final written form, they reflect past enforcement practice, current industry knowledge, and approved agency emphasis.
In producing high-quality inspection reports. therefore, the supervisor serves a vital (but often misunderstood) role. The supeevisor is a shield between the inspector and certain " hazards."
such as unintentional backfits, inconsistent agency positions, and retracted violations. In the role of liaison, the supervisor anticipates the reactions of the report's readers (such as the licensee NRC headquarters and regional managemerit, the Office of Enforcement, and the public). The supervP,or also ensures that the report's message is clear and appropriate in terms of safety significance industry precedent, agency position, and general tone.
Conversely, the supervisor should not be viewed as a technical editor. The supervisor's function should not be to correct spelling errors, break up long paragraphs, and fix problems of report organization. In such cases, he or she can easily become so immersed in the report details that the more important supervisory functions described above ce lost.
When the supervisor's role becomes blurred in this manner, a cycle of inefficient review and concurrence begins. The draft report circles in a painful path from the sapervisor to the inspector to word processing and back again. By understanding the proper importance of supervisory review, and by ensuring that you make thorough, accurate revision your own responsibility, you can avoid this inefficiency and save yourself frustration.
- 2. Clarifvino the Suoervisor's Writina Excectations. Despite the best efforts of English instructors, writing remains a changii.g and subjective science. IMC 0610 and other references (the Fundamentals of Inspection Course, the NRC Enforcement Manual, etc.) establish a standard style and format for inspection reports: some aspects of the writing, however, remain a matter of personal preference. Your supervisor may have specific additional standards in these areas.
When the review and concurrence process has become the focus of frustration, it may be because of ill-defined supervisory expecta-tions. If the supervisor's writing standards differ from your own, you will both save a great deal of effort by taking the time to clarify those stc.ndards.
(a) Ask for a "model report" that meets your supervisor's stan-dards, if Jossible ask your su)er Mor to make clarifying remarks in t7e margins of the mode' report about what he or she expects.
0610: Appendix B B-4 Issue Date: 07/15/97 i;
(b) When changes are mace your writing. try to decipher the rule behind the change. 4 or clarification that will make your supervisor's comments m il for future reports (c.g. . "Do you prefer that I always ret to the regulatory criteria before discussing the related fu ings?"),
- 3. Coooerative Writer / Reviewer Relationshio. A cooperative inspec-tor / supervisor relationship must be learned. in many cases. Old bad habits don't just die hard- they also give birth to new bad habits.
For example, a non-cooperative writer / reviewer relationship may condition you to expect that your reports will always require significant revision: as a result you may become complacent about submitting a report that you know contains errors.
Clarifying the supervisor's writing standards, as discussed above, is one step in changing the "old habits." Three more are discussed below: early supervisory involvement, ef fective debriefings, and submitting final drafts.
(a) Early Supervisory Involvement. If you wait to involve your supervisor in the inspection findings until after the inspec-tion, you should expect to have your findings challenged at the debriefing. Worse still, if you first tell your supervisor about the findings by handing in a draft report, the review and concurrerce process may become lengthy simply in order to give the supervisor time to mull over your ideas.
" Supervisory review." ideally, should begin at the inspection planning stage. A short briefing, covering your intended inspection scope, will plant the areas of focus in your supervisor's mind, begin the cooperative effort, and build respect.
If your supervisor tends to respond to your findings by suggesting additional areas for inspection, you will profit by getting that input as early as possible. Telephone discussions with your supervisor several times during the inspection will continue the cooperative effort (brainstorming is even more effective with two people).
(b) Effective Debriefinas. As a matter of routine, hold a short telephone discussion with your supervisor before the exit meeting. By evaluating the inspection findings at this stage, you will avoid inconsistencies between the exit meeting and final report.
In any event, be sure to hold a thorough, organized debriefing with your supervisor before beginning the report. Two rules apply:
(1) Always try to resolve differences of opinion before writing about them. (Sometimes you will hear a statement like. "Well, why don't you try writing it up and we'll see how it looks on paper . . .
Using this approach to resolving technical or enforcement issues is a sure avenue to inefficiency Disagreements take much longer to resolve on paper than in oral discussion. Written products should become the arena for resolving dif ferences issue Date: 07/15/97 B-5 0610: Appendix B
only when unavoidable.)-
(2) Give the supervisor a mental picture of what the report will look like. By areparing and presenting your findings in a well organizec debriefing.- your expectations about the content and tone of the final report will become aligned with your supervisor's.
(c) Submittino Final Drafts. If possible, never give a reviewer anything other than a final draft (i.e.. don't hand in a draft before you have given it your own best revision efforts). The presence of errors--even minor spelling and punctuation errors-
-will predispose any reader to believe the document is also .
flawed in other ways.
0610: Appencix B- B-6 Issue Date: 07/15/97'
.c
INSPECTION REPORT REVIEW CHECKLIST Aooendix Q The checklist can be an effective aid both for writers and reviewers, It is not intended to be a prescriptive recipe: used consistently however, it will add considerable focus ar,d efficiency to the writing / reviewing process, and-it will improve the clarity )f the written product.
First Staae Review Co: Letter L Major idea is clearly presented a Message is supported by findings in the executive summary a Letter uses appropriate tone Executive Summary o Organization follows the order of the standardi:rd report outline o Each significant finding and conclusion is given a clear, concise description a Executive summary findings are support.d by report details Pfoort Details: Overall oraanization a Organization follows the order of the standardizec report outline o Each report section uses standard internal organization a " Areas Inspected" sub-sections are presented clearly and concisely Reoort Details: Presentation of Reoort Observations /Findinas/ Conclusions o Thresholds of significance (in determining what to document) are appropriate a Findings are clearly developed e Main ideas are clearly presented e Observations are placed in context e Assertions are supported by facts e Requiremer.t er standard is included, where a)propriate e Licensee response to findings is included, w1ere appropriate o level of detail is appropriate (based on significance, complexity, and reader awatcress) o' Conclusions are of appropriate scope e Conclusions are substantiated, and findings are incorporated e If substantial inspection has occurred, an assessment of program adequacy results i
Issue Date: 07/15/97 C-1 0610: Appendix C
2 Second Staae Review Clear cresentational style o Subheadings are used where appropriate o Emphasis techniques (bullets, underlining) are used where appropriate a Statistical data is presented in graphic or tabular format Paraaraohs o Each paragraph develops only one main idea o Main idea of the paragraph is clearly presented a Paragraphs are generally a maximum of 10-12 lines Sentences o Active voice predominates (Subject-verb-object) a Wordy phrases are avoided (e.g., "Due to the fact that . ." vs. "Because . ")
a False subjects are avoided (e.g., "It is clear that .. " vs . " Clearly . . . ")
a Weak verbs are avoided (e.g. , "The licensee gave authorization to " vs. "The licensee authorized . ")
a Word selection reflects a generally understood vocabulary (except where the use of technical jargon is necessary)
Third Staae Review
~
a Cover letter, cover page, executive summary, and report details are accurate and consistent on all dates, distribution, titles, etc.
o -Acronyms and initialisms are defined a Grammar and purictuation are correct a Spelling is correct 0610: Appendix C C-2 Issue Date: 07/15/97
NMSS INSPECTION REPORT SUPPLEMENT Annendix D 0610-D01 INTRODUCTION: PURPOSE OF THIS SUPPLEMENT Much of the guidance in IMC 0610 applies to all NRC inspection reports. including those documenting inspections of NMSS licensees. In some areas however (e.g. ,
format. report outline, and certain matters of report content). considerable variation exists. Where this is true, the main body of IMC 0610 focuses on t eporting inspections at power reactor facilities. This appendix provides supplemental guidance specifically applicable to reporting NMSS inspections.
For additional details on unique requirements and characteristics of materials inspection reports. see IMC 2800.
0610-D02 OBJECTIVES This supplement is consistent with the objectives in the main body of IMC 0610.
No additional objectives are added here.
0610-D03 DEFINITIONS In general, the NMSS use of inspectior-report-related terms is consistent with those definitions given in the " DEFINITIONS" section of IMC 0610. Note that IMC 2800 provides an expanded definition of " inspection." and provides detailed guidance on what constitutes an " inspection" for materials licensees.
0610-004 GENERAL RESPONSIBILITIES--MATERIALS Each inspection of a materials licensee should be documented with: (1) a cover Sage plus inspection report: (2) inspection field notes: or (3) a completed NRC orm 591. Formats for field ro ws can be found in Inspection Procedure 87100.
Field notes should be in ink. .ner than pencil: while they need not be typed.
they should be legible, and should contain:
e sufficient detail to describe the inspection:
e the compliance status in the areas examined:
e the status of follow-up items involving prior enforcement or reported licensee events:
e sufficient information to su) port any identified violations, including a description of completed anc anticipated corrective actions: and a sufficient detail for management to evaluate the licensee's overall safety program.
A different inspector should be able to use the field notes to prepare for a subsequent inspection. and to determine whether corrective actions have been taken.
A complete formal inspection re[ ort is required for some team inspections (see IMC 2800), and for apparent violations being considered for escalated enforcement action. These reports should be composed using format and writing techniques similar to those given in IMC 0610. with the exceptions noted elsewhere in this supplement. For materials reports transmitting potential escalated enforcement actions, the report details need address only the areas in which safety concerns and apparent violations are identified. In addition a formal report should be prepared for any special inspection coMucted in response to a significant licensee incident, event, or misadministration.
Issue Date: 07/15/97 D-1 0610: Appendix D
Because of the variety of'11censees. facilities, and conditions that come under NHSS cognizance, NMSS provides regional management the-flexibility to determine the appropriate -type of. report, format. and level -of detail . Inspections at decomissioning facilities (active).- low-level waste disposal facilities, and uranium ~ recovery facilities will often be in the formal ~ format de':ribed in IMC -
-0610- Section 04.01-(i.e., a cover. letter, cover page,Lexecutive summary, and -
inspection : details): however. less formal and comprehensive reports may be '
sufficient, especially for sites and facilities with minimal safety significance-or public interest. ,
Finally, note that NHSS does not use the 21-day goal for report timeliness as described in Section 04.05 of IMC 0610.
0610-005 GUIDANCE - INSPECTION REPORT CONTENT 05.01 Level of Detail in Reoorts Coverina NMSS Licensees. For inspectors of NMSS licensees, the process of developing observations, findings, and ';
conclusions is similar to that described in Sections 05.01, 05.02, and 05.03 of IMC 0610. Considerable variation exists, however, in the level of detail - provided . and the " thresholds of significance" -used in -
determining what to document. .
In general. -1ssues identified during a materials inspection should only '
result in a detailed report discussion when they involve significant problems or when escalated enforcement action is being considered. Many materials inspections are performed in as little as 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and cover many topics cuickly: NMSS does not expect thet reports of -such
-inspections will contain detailed coverage of all areas observed. In s addition, materials inspectors may find it difficult to assess "improv-ing" or " declining" performance trends- (as referred to in IMC 0610, Section 05.01.c.2(b)) for licensees that are inspected infrequently.
When describing a given issue, the inspector should provide a level of detail appropriate for-the principal reader--the report addressee. In other words, the report should be written so-that it will.be understood by a knowledaeable individual conversant with nuclear technoloav, but who
.may not be- an expert in the specific area inspected. For example. a ,
hospital president-or vice-president will know that the nuclear medicine
- and . teletherapy _ programs exist, but may not be familiar enough with program detatis to readily u: .drstand terminology with which. the radiation safety officer would be 'very familiar. Specific facility, product. or_ process features, relevant 3rocedures, event-specific details. and other factual information shoulc be presented in sufficient detail .to allow this " target audience"--the primary addressee -to understand the characteristics and significance of the inspection findings, 05.02 : Documentina Non-Comoliances by NM3S Licensees. . Documentation of non.
compliances by NMSS licensees varies somewhat from the guidance pre.>ided in .IMC- 0610. . In particular. , a minor- violation may be discussed in inspector; field notes (and noted as an NCV) without beingl documented in an NRC Form 591. However. -for- NCVs involving violations -of more than minor? iconcern '(e.g..- licensee-1dentified tand corrected SL IVs),_ -
documentation Eeither on . a: Form 591 or - in an inspection report is required- .For additional guidance on documenting violations. refer to
~
c i
_05;03 Documentina Licensee Manaaement Issues. -In Sections 05.05.a and 05.05.d.
0610: ! Appendix D . D Issue'Datei 07/15/97
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l IMC 0610 doeplays the relative importance of inspecting and documenting the licensee's organization and staffing. For mater ials (non-fuel cycle) licensees, however, this area n worth noting. " Big-picture" issues such as significant managemer.t or staffing changes should be looked for and evaluated. An inspector should note, for example, whether a licensee's reorganization has diminished the radiation safety of ficer's authority.
or if a corporate change has occurred that should have been reported to the NRC. The inspector should also describe what actions are being taken to address any concerns noted.
05.04 Qocumentino Doen Items. For additional guidance on use of IFS for materials inspections, see IMC 2800.
0610-D06 GUIDANCE - INSPECTION REPORT FORMAT As stated above in Section 0610-004. flexibility is provided in adapting the inspection report forfrat to the needs of the particular inspection. The guidance provided in IMC 0610. Sections 06.01 through 06.07 should only be used where applicable and helpful. Several specific differences are noted below:
- a. Use of a Standard Insoection Report Outline. Inspection report content and organization varies considerably for various types of NMSS licensens.
The following exhibits to IMC 0610 provide some guidance on report organization for inspections of NMSS licensees:
e Exhibit 3- ctandard materials inspection report outline e Exhibit . N ard containment and storage inspection report e Exhibit :andard fuel cycle inspection report
- b. Discussion of Proprietary Information. Materials (non-fuel cycle) inspectors do not traditionally take or use any proprietary information during tha course of an inspection. As a result, the mention of proprietary information in materials inspection exit meetings and materials inspection reports is generally unnecessary.
- c. List of Insoection Proceduresand/or IFS _I.t. ems. Materials (non fuel cycle) inspection reports generally do not include a list of inspection procedures used noi a lict of IFS items. A list of areas inspected should be included either as an attachment to the report (if the list is extensive) or on the report cover page.
0610-007 GUIDANCE - INSPECTION REPORT STYLE The guidance given in IMC 0610 is generally applicable to reports documenting inspections of NMSS licensees. No additional guidance is provided here.
0610-008 RELEASE AND DISCLOSURE OF INSPECTION REPORTS AND ASSOCIATED DOCU-MENTS The guidance given in IMC 0610 is generally applicable to reports documenting inspections of NMSS licensees. No additional guidance is provided here.
Issue Date: 07/15/97 D-3 0610: Appendix D
LIST OF ACRONYMS USED IN THIS INSPECTION HANUAL CHAPTER Anoendix E NOTE: a separate list of acronyms is given as an enclosure to Exhibit 2. l the sample inspection report.
AE00 Office for Analysis and Evaluation of Operational Data ALARA As low As is Reasonably Achievable CFR Code of Federal Regulations CVCS Chemical and Volume Control System EA Escalated Action-EF Emergency Preparedness ESF Engineered Safety Feature -
g]m gallons per _ nute G)0 Government Printing Office IFI Inspection Follow-Up Item IFS Inspection Follow-U) System IMC Inspection Manual Clapter IPAP Integrated Performance Assessment Process ISI In-Service Inspection LER Licensee Event Report MD Management Directive NCV Non-Cited Violation NMSS Office of Nuclear Material Safety and Safeguards NOV- Notice of Violation NRC Nuclear Regulatory Commission I!RR Office of Nuclear Reactor Regulation OE Office of Enforcement 01 Office of Investigations PIPd Inspection Program Branch FPR- Plant Performance Review RA Regional Administrator RHR Residual Heat Removal
- RP Radiation Protection RP&C- Radiological Protection and Chemistry SALP Systematic Assessment of Licensee Performance SI International System of Units
. TI Tem)orary Instruction TS Tec1nical Specification I
i 1ssuefDate: 07/15/97 _E-1 0610: Appendix E
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