ML20248E575
| ML20248E575 | |
| Person / Time | |
|---|---|
| Issue date: | 09/19/1989 |
| From: | Stephen Bell NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Colina SCIENCE & ENGINEERING ASSOCIATES, INC. |
| Shared Package | |
| ML20248E574 | List: |
| References | |
| CON-FIN-D-25129, CON-NRC-04-89-051, CON-NRC-4-89-51 NUDOCS 8910050306 | |
| Download: ML20248E575 (5) | |
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NUCLEAR REGULATORY COMMISSION g,
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.... Science & Engineering Associcates, Inc.
j 61CO Uptown Blvd. tE j
Albuquerque, thw Mexico 87110 l
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Dear Ms. Colina:
Subject:
Task Order tb. Col Entitled " Regulatory Analysis Support for the TEC tbclear Power Plant Access Authorization Prcgram" thder Contract tb. TEC-04-89-051 This confirms verbal authorization provided to you on May 2,1989, to connence work under tFe subject Task Order with a temporary ceiling of $20,0CO.CO.
This ceiling was verbally increased on tiay 11,1989 to $30,0:O.CO and on June 23, 1989 to 550,OCO.CO.
In accordance with tte task order pr ocedures of tre subject contract, this letter definiti:es Task Order tb. (G1.
This ef fort shall be perforned in accordance with the enc 1csed Statenent of Work, the Contractor's proposal for this Task Order tb. 001 dated May 18, 1989, incorporated terein by reference and tre follcuing telephanic changes as discussed with Mr. brad Ross cr>
Septemter 14 1939:
3 Reduce travel costs of $7,678.CO to $7,438.00 and m djust peopcced costs accordingly.
Tasl: Order ida. Col chall te in ef fect f rom May 2,1989 through June 30, 1989, with a total ccst ceiling of $78,064.00.
The ancunt of $72,469.CO represents tre total estimated reimbursable costs and the anount of $5,595.CO represcots tie fiwd fcc.
The total ceiling of $78,064.00 is inclusive of tFe 150,rOO.CO v1rbally eut torized as discusscd above.
fccconting Data for th.ts Task Order tb. Col are as follows:
B' R tb. :
CO-61-95-OO-40 FIN tb. :
D-2512-9 (PFN ib. :
31XO2CO.609 DBL 1 GATED /rCLtir:
$78,C64.03 The issuance of this Task Order does not anend any ternrs or conditions of the subjcct contract.
Ycor contacts during tt e course of this Task Order are:
Technical Matters:
Sidney Feld, Project Officer (201) 492-3748 Contr& tual Matters: Patricia Brennan, Contract administrator (301) 492-4733
@EIOO50306 890921 rDR CONTR NRC-04-sp 05)
FDC
_______--_-__-___________________________________________________-___________________________________a
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ifC-04-09-051
-Task Order No. 001 Please indicate ycur acceptance of this Task Order No. 001 by having an of ficial, auttorized to bind your organization, e>:ecute three copies of this document in the space provided and return two copies to the Contract Administrator. Your should retain the third copy for your rc<ords.
l Sincerely, I
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.jdGLf?L Ed Sharon Bell, Contracting Officer Contract Administration Branch Division of Contracts and Property Managenent Office of Administration
Enclosure:
As stated ACCETTED:
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Ilene R. Colina, Contract Administrator (Title) 21 September 1989 (Date)
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L STATEMENT OF WORK 4
SCIENCE & ENGINEERING ASSOCIATES, INC.-
CONTRACT TASK 01 REGutATORY ANALYSIS SUPPORT'FOR PROPOSED RULE CONCERNING NUCLEAR POWER PLANT. ACCESS AUTHORIZATION PROGRAM OBJECTIVE
.The Regulatory Analysis Section w ti hin the Regulation Development Rranch (ROB).
has been approached by the Operations Section, also within the RDB to develop a regulatory analysis for a nuclear power plant access authorization program.
To the extent possible, information should.also be developed that can serve as input to a Regulatory Flexibility Certification, a Paperwork Reduction Act Statement and a backfit analysis. This proposed task is to provide the necessary analysis and information.
BACKGROUND The Nuclear Regulatory Commission.is proposing to amend its regulations concerning nuclear power plant access authorization.
The Commission has approved licensees to have an access ' authorization program and would specify the major required attributes of the program. The NRC would also issue a regulatory guide which would endorse the Industry Guidelines, with appropriate The exceptions, as one acceptable means of complying with the rule.
regulatory guide should be finalized and ready for issuance at the same time that the Commission acts on the final rule.
The NRC has prepared a working draft of this proposed rule which includes the specific requirements to be imposed on effected licensees.
Further revisions to this draft document based on an internal NRC review are perceived as This and other relevant information will be forwarded to the minor.
contractor under separate cover prior to the initiation date of this task.
In addition Meetiteg'; will be held at NRC, Rockville, Maryland as needed, involving individuals from the NRC and industry most familiar with nuclear power plant access authorization program requirements and licensing issues.
It is expected the contractor will attend these meetings.
WORK TO BE PERFORMED AND EXPECTED RESULTS:
Subtask 1 The contractor shall prepare a regulatory impact analysis (RIA) for the subject action which conforms in format to the guidance available in NUREG/BR-0058, Revision 1, " Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission," May 1984. The RIA shall include the following Statement of the Problem; Objectives; Alternatives; distinct sections:
Consequences (costs and benefits of alternatives (value-impact analysis),
impacts on other requirements, constraints); Decision Rationale; and Implementation.
With respect to two of these specific elements, the following direction is provided.
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Alternatives:
The contractor shall adopt as alternative actions the requirements specified by the proposed action in NRC's draft rule and a no action scenario.
Consequences:
1.
Values and Impacts shall be assessed on an incremental basis.
It is the NRC's view that although a full spectrum of specific requirements are included in the proposed final rule, in many cases highly comparable requirements are already in-place as license specific amendments.
Consequently, for many of the. specific requirements, incremental impacts or values are not anticipated. With this in mind, a major thrust of the contractor's effort is perceived as being able to demonstrate the impacts on existing licensees.
2.
Tne contractor should recognize that not all incremental consequences are necessarily quantifiable (e.g. improvements.in health and safety).
In such instances, a qualitative discussion should be provided.
3.
Impacts'should be presented on an industry-wide lifetime cost basis. All future costs should be, expressed on a present worth basis assuming real discount rates of 5% and 10" 4.
The contractor should assess the impacts on future nuclear power reactor plants' as they relate to the proposed rulemaking action. Since it is not known how many plants will be in the pipeline for the future, costs should be developed on an average per plant basis.
5.
The analysis shall include impacts to industry, and the NRC.
Subtask 2:
As a result of the analyses performed for subtask 1, it is expected that the contractor will be able to provide the necessary supporting information for the Regulatory Flexibility Certification, Paperwork Reduction Act Statement, and Backfit Analysis. For example, the Regulatory Flexibility Act requires a determination on whether the proposed regulatior will have..."a significant economic impact on a substantial number of small entities". A determination on small entity is typically characterized on the basis of absolute size or the firm's size relative to the market it is servicing.
It is the staff's view
-that a supporting statement on this issue could be prepared based on the industry analysis performed under subtask 1.
Subtask 3:
In addition to the development of an RIA, the contractor shall prepare a backfit analysis on the subject proposed action in accordance with all of the requirements of 10 CFR 50.109. The contractor in developing the backfit analysis should consider the proposed action to be a final action.
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Deliverables:
The contractor shall deliver to the NRC a draft report and a final report.
The draft report will be due. June 1,1989, and will contain: a) regulatory impact. analysis suitable for inclusion in an NRC "ulemaking package; b) a separate appendix containing the backup and detailed support for the conclusions of the value-impact analysis; c) a separate appendfx.containing information useful ~ to the Regulatory Flexibility Certification, Paperwork Reduction Act Statement, and d) a Backfit Analysis. NRC will provide comments to the contractor two weeks after receipt of the draft. Upon receipt of comments from the NRC on this draft report, the contractor shall modify the draf t'as appropriate and deliver a final report to the NRC on June 30, 1989.
The contractor shall also provide a-brief monthly letter report summarizing the status of work in progress and any problems or delays encountered 'in the conduct of this task ~.
Period of Performance:
The contractor will complete this task by June 30, 1989.
Level of Effort:
It is estimated that this task will recuire approximately six staff-months of effort.
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