ML22074A052

Modification No. 014 to Task Order No. 31310018F0125 Under Contract No. 31310018D0001

ML22074A052
Person / Time
Issue date:	03/15/2022
From:	Jennifer Dudek Acquisition Management Division
To:	Maldonado P Southwest Research Institute
References
31310018D0001
Download: ML22074A052 (25)

Text

31310018D0001 31310018F0125 P00014 SECTION SF 30 BLOCK 14 CONTINUATION PAGES The purpose of this task order modification is to: (1) increase the exercised task order ceiling by $107,426.00, from $1,893,287.00 to $2,000,713.00; (2) provide incremental funding in the amount of $70,000.00, thereby increasing the obligated amount from $1,893,245.00 to $1,963,245.00; (3) revise the price schedule; (4) revise tasks 6 and 7 in the Statement of Work; and (5) extend the period of performance through March 29, 2023.

The task order is hereby modified as follows:

1) Clause SECTION B.2 CONSIDERATION AND OBLIGATION TASK ORDERS (AUG 2011) is deleted in its entirety and replaced with the following:

(a) The total exercised ceiling of this contract for the products/services under this contract is

$2,000,713.00 (Cost of and Fixed-Fee of ). The amount will increase as follows, upon exercise of additional Optional Subtasks.

Optional Subtasks 3A,B, & F: $ (unexercised)

Optional Subtasks 4A3, 4, & 5: $ (unexercised)

Total Task Order Ceiling: $ 2,095,514.00 (b) This order is subject to the minimum and maximum ordering requirements set forth in the contract.

(c) The amount presently obligated with respect to this order is $1,963,245.00 of which represents costs and represents fixed-fee. The obligated amount shall, at no time, exceed the order ceiling as specified in paragraph (a) above. When and if the amount(s) paid and payable to the Contractor hereunder shall equal the obligated amount, the Contractor shall not be obligated to continue performance of the work unless and until the Contracting Officer shall increase the amount obligated with respect to this order, in accordance with FAR Part 43 - Modifications. Any work undertaken by the Contractor in excess of the obligated amount specified above is done so at the Contractor's sole risk and may not be reimbursed by the Government.

(d) The Contractor shall comply with the provisions of FAR 52.232 Limitation of Funds, for incrementally-funded delivery orders or task orders.

(e) In accordance with FAR 52.216-8-Fixed Fee, it is the policy of the NRC to withhold payment of fee after payment of 85 percent of the fee has been paid in order to protect the Governments interest. The amount of fixed-fee withheld from the contractor will not exceed 15 percent of the total fee or

$100,000.00, whichever is less. Accordingly, the maximum amount of fixed-fee that may be held in reserve is

2) Clause B.3 PRICE/COST SCHEDULE is deleted in its entirety and replaced with the following:

Total Estimated Cost and Fixed-Fee breakdown by CLIN is presented below.

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31310018D0001 31310018F0125 P00014

3) SECTION C - DESCRIPTION/SPECIFICATIONS/STATEMENT OF WORK is deleted in its entirety and replaced with Attachment No. 1 to this modification.

4) SECTION F.1 TASK/DELIVERY ORDER PERIOD OF PERFORMANCE (SEP 2013) is deleted in its entirety and replaced with the following:

This task order shall commence on September 27,2018 and will expire on March 29, 2023.

(End of Clause)

All other terms and conditions of the task order remain unchanged.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 STATEMENT OF WORK FOR TECHNICAL ASSISTANCE FOR THE DEVELOPMENT OF AN ENVIRONMENTAL IMPACT STATEMENT FOR HOLTEC INTERNATIONALS LICENSE APPLICATION REQUEST FOR A CONSOLIDATED INTERIM STORAGE FACILITY FOR SPENT NUCLEAR FUEL AND HIGH LEVEL WASTE

1. OBJECTIVE The project described in this Statement of Work (SOW) is to provide Contractor technical assistance to the U.S. Nuclear Regulatory Commission (NRC) staff for the development of an Environmental Impact Statement (EIS) and to assist in National Historic Preservation Act of 1966 (NHPA) Section 106 consultation activities, in support of the staffs environmental review for the license application request from Holtec International (HOLTEC) to construct and operate a Consolidated Interim Storage Facility (CISF) for spent nuclear fuel and high level waste at HOLTECs proposed site near the border of Eddy and Lea Counties, New Mexico. The project also includes providing relevant Contractor expertise for a potential adjudicatory hearing on the licensing action.

2. BACKGROUND HOLTEC has submitted a license application on March 31, 2017 for a CISF to be constructed and operated on HOLTECs site in Lea County, New Mexico. Based on information provided by HOLTEC at public meetings with the NRC, the CISF would have the capacity to store up to 10,000 canisters of spent nuclear fuel (SNF) and high level waste (HLW). Other wastes may be included in the license application. HOLTEC estimates that 500 canisters of SNF and HLW would be shipped by rail from various nuclear power reactor sites in the U.S. to the HOLTEC proposed facility over a period of 20 years. An additional 20 years of storage would be addressed in the application and license.

The NRCs review of the HOLTECs license application request falls under the purview of the Office of Nuclear Material Safety and Safeguards (NMSS) for regulating activities which provide for the safe storage, transportation and disposal of high-level radioactive waste and spent nuclear fuel and the transportation of radioactive materials regulated under the Atomic Energy Act. The NRC staff finds that the proposed action is a major Federal action significantly affecting the quality of the human environment, which pursuant to 10 CFR § 51.20(a)(9), requires the NRC to prepare an EIS to meet the requirements of the National Environmental Policy Act of 1969, as amended (NEPA) and pursuant to the NHPA, is also federal undertaking pursuant to 36 CFR 800. In addition, the NRC typically coordinates reviews required by other statutes, such as the National Historic Preservation Act (NHPA) and Endangered Species Act (ESA), with its NEPA reviews. Furthermore, the NRC staff expects that HOLTECs CISF license application request will receive a high level of interest from potential interveners who live near the site and the licensing action could potentially be adjudicated (i.e., a contested hearing to be conducted by the NRCs Atomic Safety and Licensing Board (ASLB)). Consequently, the NRC staff requires Contractor technical assistance for the development of a Draft EIS and for consultation under Section 106 of the NHPA in support of the staffs review for the HOLTECs license application request to construct and operate a CISF, as well as relevant Contractor expertise for a potential adjudicatory hearing before the ASLB on environmental issues.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 This task order is a continuation of work performed under Contract NRC-HQ-12-C-02-00089, Task Order NRC-HQ-50-17-T-0001, awarded June 23, 2017. Under this task order the contractor provided support with developing the draft EIS to include development of the initial chapters of the draft report (Chapters 1 through 3).

3. SCOPE OF WORK The Contractor shall complete assistance with the development of a Draft EIS and provide assistance with preparing a Final EIS that the NRC will use to document its environmental review of HOLTECs license application request to construct and operate an CISF in Lea County, New Mexico, pursuant to 10 CFR Part 51. The resource/impact areas to be examined in the EIS in terms of the affected human environment and the potential impacts to that environment - shall include: land use; transportation; geology, seismology and soils; water resources (ground water and surface water); ecological resources (including threatened and endangered species); climatology; meteorology and air quality; climate change; noise; historic and cultural resources; visual and scenic resources; socioeconomics; public and occupational health (non-radiological and radiological); environmental consequences from accidents; waste management; and environmental justice. Of these, preliminary analysis by the NRC staff indicates that the most significant issues may relate to transportation, public and occupational radiological health, socioeconomics, and environmental justice. Cumulative impacts would also be of importance given the activities currently and/or potentially occurring at the proposed site as well as another potential CISF that is being proposed in the same geographic area.

The EIS will provide a comparative analysis of the potential environmental impacts from the applicants proposed action and from reasonable alternatives to that action, including, but not necessarily limited to, the no-action alternative. The EIS will also need to document the purpose and need for the applicants proposed action, the applicable statutory and regulatory requirements (including and in addition to those of the NRC), mitigation measures to avoid or minimize environmental impacts, environmental measurement and monitoring programs, an analysis of cumulative impacts, and a cost-benefit analysis.

As discussed above, the proposed action is likely to generate significant external stakeholder interest. Development of the EIS, therefore, will require a comprehensive and robust public outreach and facilitation program.

Preparation of the EIS will involve other federal agencies in the role of cooperating agencies, with the NRC as the lead federal agency. The NRC will coordinate the role of the cooperating agencies, if any, in the schedule for EIS preparation. These cooperating agencies will provide input to and comments on working copies of the draft EIS.

The Contractor shall prepare the EIS in accordance with the NRCs applicable NEPA-implementing regulations in 10 CFR Part 51 and associated NRC staff guidance in NUREG-1748. Also, the NRC typically coordinates reviews required by other statutes such as the NHPA and ESA with its NEPA reviews. Therefore, the Contractor is expected to be cognizant of other statutes that the NRC will need to comply with during its licensing review of the proposed action. In addition, the Contractor shall provide the NRC staff with relevant expertise for a potential adjudicatory hearing on environmental issues.

In addition, the Contractor shall provide support of the NHPA consultation process, potentially including research, facilitation, survey assistance, development of recommendations, survey and form reports, assessment of effects, and support in developing mitigation plans.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 The Contractor shall obtain and leverage any information from other consolidated storage facility applications for this review.

Due to several factors, the publication of the final EIS for the Holtec CISF application will be delayed and will require additional effort and time from the Contractor. The incomplete responses from Holtec on Requests for Additional Information (RAIs) have delayed and complicated inputs and finalization to EIS for the land use, geology, and water resources sections of the EIS (and associated comment responses). The extension in the schedule will also allow for updating final documentation and revising final reports.

4. SPECIFIC TASKS The specific tasks and deliverables required for the Contractor to complete the EIS, assist the NHPA consultation process, and provide support for a potential adjudicatory hearing on environmental issues are described in detail below. See also Section 6 of this SOW for a list of required deliverables and the deliverable/milestone schedule and Section 12.1 for travel requirements for the task order.

In preparing the EIS, the Contractor shall use the information provided by the NRC and additional information obtained by the Contractor, as described in the tasks/subtasks below.

The contractor will use information and analysis developed during the scoping process and early development activities for draft EIS from the contract NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002.

In addition, the Contractor shall incorporate in the EIS other information and conclusions developed during the NRC staffs safety review of HOLTECs license application request, as will be documented in the NRCs Safety Evaluation Report (SER), such as potential public and occupational health impacts, and environmental consequences from accidents. Furthermore, the Contractor shall also use any additional information as provided by the NRC, which either supplements or replaces HOLTECs original license application request. For example, the additions to the application may come in the form of an application supplement(s), and/or HOLTECs responses to NRC requests for additional information. The Contractor shall leverage information and experiences from the ISP interim consolidated storage facility nearby for this review is possible.

Task 1 - Project Management (ONGOING)

This task shall last for the entire duration of the EIS development, the NHPA consultation process, and, if needed, the adjudicatory hearing. It may involve travel for the Contractor Project Manager to meet with the NRC Contracting Officers Representative (COR), if needed. Following task order authorization, in consultation with the NRC COR, the Contractors Project Manager shall develop and maintain a detailed project schedule electronically in MS Project. This schedule shall be updated as necessary and provided to the NRC COR periodically upon request.

Communication The NRC anticipates a weekly status call or face-to-face meeting with the NRC COR and Contractor Project Manager will be held to discuss the status of the project (e.g., technical issues, contract monitoring, file management). However, communication may be more or less often depending on the need. NRC anticipates that quarterly progress meetings with the NRC COR may be necessary.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 File Management The Contractor shall use the Pacific Northwest National Laboratorys EARRTH website for file management. EARRTH shall be accessible by all Contractor project team members and contain project-related documents, correspondence, and all working and final files.

The NRC COR will facilitate access to EARRTH for all Contractor staff. See Section 9 -

Government Furnished Property for more detail on EARRTH.

Quality Assurance Program The Contractor Project Manager shall have overall responsibility for ensuring that a robust and comprehensive quality assurance program is adequately implemented for all aspects of the contract including, but not limited to, the quality of technical input as well as the editing of technical documents. The Contractor Project Manager shall ensure that all deliverables have been prepared in accordance with quality assurance standards and shall review all deliverables for adequacy, accuracy, and consistency in technical content. The Contract Project Manager shall assure that all NRC publishing requirements for documents are met.

Task 2 - Collect and Review Information The Contractor shall keep the NRC COR informed (via email, phone, or other correspondence) on at least a weekly basis, describing the information collected, reviewed, and analyzed under this task including, but not limited to, deficiencies found in HOLTEC-submitted information (i.e., the license application, including the safety analysis report (SAR) and environmental report (ER), and any other supplemental information provided in support of the application); other information deficiencies; and any portions of other NEPA documents and other environmental reviews for activities at the proposed CISF site and in the vicinity of the proposed project that can be either adopted, tiered, and/or incorporated by reference into the NRCs EIS.

The contractor will collect and analyze information to support the final documentations of the EIS. The Contractors independent data collection shall include, among other available data and information sources, references cited in the applicants license application, SAR, and ER, and relevant documents found through a comprehensive search and utilization of the NRCs publicly available Agency-Wide Documents Access and Management System (ADAMS), at http://www.nrc.gov/reading-rm/adams.html. Relevant documents in ADAMS may be found by the Contractor by searching, for example, under Docket Number 72-1051.

In addition to information collection, the contractor shall use information developed and collected during the tasks associated with NRC-HQ-12-C-02-0089, Task Order NRC-HQ 17-T-0002.

As part of this information collection and review task, the NRC COR, with the assistance of the NRC safety/licensing project manager, will facilitate the Contractors coordination with the members of the NRCs safety review team for the project who are preparing the SER.

The NRC safety review team members and their contact information will be identified by the NRC COR following task order authorization. The purpose of this coordination is for Contractor and NRC safety review staff counterparts to familiarize themselves with each other, establish an understanding for initial and ongoing coordination and discussions as needed, and identify and exchange information as needed for the ongoing environmental and safety reviews. Contacts may be by phone, email, or other correspondence, as necessary and appropriate. Contacts between Contractor staff and NRC safety review staff shall be made with the knowledge of the NRC COR and the NRC safety/licensing project manager, and may be arranged by the NRC COR when necessary.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 Further, with the knowledge and approval of the NRC COR, the Contractor shall update as necessary its EIS development process any additional coordination necessary to cover laws and regulations other than NEPA. In addition, as requested by the NRC COR, the Contractor shall provide support for NRC consultations, i.e., Section 106 consultation of the NHPA and Section 7 consultation under the ESA, as well as support for NRC coordination with other Federal, State, and local agencies. This support may include identification of agencies to contact, providing supporting information/documentation for consultations/coordination, input to and review of NRC letters/emails to agencies, etc. To these ends, the Contractor shall compile a list of federal, tribal, state, and local statutes, laws, and permits that are applicable to the project, with an accompanying short description of each statue, law, or permit. Information resulting from NRCs consultations/coordination with other agencies will be provided to the Contractor for use in the EIS analyses, as well as for summary, referencing, and reproduction, as necessary, in the EIS documents. These activities and contacts may have to be updated as necessary based on the development of the EIS.

Although the Contractor has conducted the bulk of the required information collection and review at the outset of the project and during tasks associated with NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002, the Contractor shall continue to collect and review information throughout the duration of the project, as necessary and as additional information may be identified or otherwise become available, to support the development and completion of the EIS and to provide support for a potential adjudicatory hearing on environmental issues. Coordination and discussions between Contractor, the NRC COR, and the NRC safety review staff are also expected to be ongoing, as necessary, throughout the duration of the task order.

The Contractor shall develop and maintain a bibliographic listing of all documents collected (reports, maps, papers, data files, etc.), including ADAMS Accession Numbers or web links where applicable, and shall also maintain on file electronic copies of all collected documents. The Contractor shall include in the listing a short description of each document and an accompanying brief discussion of how the document will be used in the EIS.

The bibliographic document list shall be in a format suitable for use in the EIS reference lists; and all references ultimately cited in both the EIS (cited references and maps, drawings, tables, etc.) must be already publicly available in ADAMS or elsewhere in the public record or can be made publicly available in ADAMS. The Contactor shall make the document list and electronic copies of documents, including periodic updates, available to the NRC COR upon request. The Contractor shall be responsible for obtaining and providing the NRC COR with appropriate permissions for use of any copyrighted materials and reference documents in the EIS.

Task 3 - Plan, Draft, and Complete Draft EIS The Contractor shall continue to plan, draft, and complete a Draft EIS that will document the NRC staffs evaluation of the potential environmental impacts of the construction and operation of the CISF as proposed by HOLTEC. The EIS shall be completed in accordance with the requirements specified in following subtasks. The Contractor shall format the EIS to meet NRC standards in NUREG-0650, Preparing NUREG-Series Publications, current revision, and NUREG-1379, NRC Editorial Style Guide. Graphics for the EIS shall be prepared by the Contractor in consideration that the NRCs published hardcopy versions of the EIS documents will be printed in black and white.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 Prior to submission to the NRC, the Contractor shall review all versions of the EIS for adequacy, accuracy, and consistency in technical content. In addition, reviews of the EIS shall be conducted by the Contractors technical editor. To the maximum extent possible, the EIS shall read as if written by a single author, rather than seeming to be a compilation of individual articles written by multiple authors in differing styles. Additionally, the EIS shall be written in plain language, meeting the intent of NRCs plain writing philosophy, techniques, and guidance (see http://www.nrc.gov/public-involve/open/plain-writing/nrc-philosophy.html#guidance).

Using information collected under the early tasks and form activities associated with the contract NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002, the Contractor shall provide a Preliminary Draft EIS that is consistent with 10 CFR Part 51 (see 10 CFR 51.70, 51.71, and 51.80) and the guidance provided in NUREG-1748. Subtasks involved in the preparation of the Preliminary Draft EIS by the Contractor include (1) a site visit and additional information gathering meetings/discussions with other federal, state, local, and tribal agencies] and information from activities associated with contract NRC-HQ-12-C 0089, Task Order NRC-HQ-50-17-T-0002, (2) development of requests for additional information (RAIs), (3) preparation of a revised annotated EIS outline, a revised purpose and need, and a revised description of the proposed action and alternatives from act ivies associated with NRC-HW-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002, and (4) preparation of all other preliminary draft chapters/sections of the EIS.

Note that the preparation of the RAIs shall be conducted concurrently with preparation of the Preliminary Draft EIS chapters/sections, and the RAIs shall be developed in consideration of the additional information needed from the applicant to complete the EIS. However, the RAI responses from HOLTEC are not expected to be available in time for inclusion in the Preliminary Draft EIS. Nevertheless, all of the Preliminary Draft EIS chapters/sections shall be as near complete and thorough as possible based on all other available data and information sources from Task 2, , and the site visit and information gathering meetings/discussions in Subtask 3A3.of contract NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002 OPTIONAL Subtask 3A - Second and Additional Rounds of Requests for Additional Information (RAIs)

If the Contractor determines that the information provided by HOLTEC (i.e., in the license application, SAR, and ER) and the information collected and reviewed during Subtasks associated with the contract NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002 is not sufficient to allow the Contractor to complete the EIS, the Contractor shall inform the NRC COR and subsequently, as directed by the NRC COR, prepare and provide the NRC COR with draft RAIs in a letter report. The NRC COR will provide the required RAI format and guidance on drafting the RAIs to the Contractor. The draft RAIs shall cover all topical areas needed to complete the EIS.

The draft RAIs shall be documented in a letter report to the NRC COR, stating by topical area what information is missing, the basis for requesting the information (e.g., to support the analysis of potential environmental impacts), and the expected use of the requested information in the EIS analysis. The RAIs shall be both clear and concise to elicit the necessary information from the applicant. It is noted that should HOLTEC be unable to provide certain information, the Contractor shall be able to define (separate from the draft 6

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 RAIs) what information could be developed by the Contractor versus information that must come from the applicant.

The NRC will review the draft RAIs and provide any comments to the Contractor, either in writing or through an electronic writing session (e.g., via webinar). The Contractor shall revise the draft RAIs to incorporate comments from the NRCs review and submit the final RAIs to the NRC COR. The NRC will transmit final RAIs to HOLTEC for response.

Following the applicants receipt of the RAIs, discussions regarding the RAIs with HOLTEC by the NRC and the Contractor shall be conducted as necessary to respond to the applicants questions and to provide clarification. Additionally, following the NRCs receipt and subsequent acceptance review of the applicants RAI responses, discussions by the NRC and the Contractor with HOLTEC regarding the RAI responses shall be conducted as necessary to obtain clarification of the responses, and identify any missing information.

Following the applicants response to the RAIs and any subsequent discussions with HOLTEC, the Contractor (in coordination with the NRC) shall determine if there is still insufficient information in any areas to complete the EIS. If it is determined that additional RAIs are required after the second round, then the Contractor (in coordination with the NRC) shall assess the specific information needed in the additional RAIs, and shall provide the additional draft RAIs to the NRC COR in a letter report. Preparation of the final additional RAIs, transmittal to the applicant, and subsequent discussions with the applicant as necessary will be conducted as for the initial round of RAIs.

OPTIONAL Subtask 3B - Second Revised Annotated EIS Outline The Contractor shall provide a Second Revised Annotated EIS Outline to the NRC COR to use as the basis for preparing the Preliminary Draft EIS. The Second Revised Annotated EIS Outline shall update the Revised Annotated EIS Outline submitted under Subtask 3B4 of Contract NRC-HQ-12-C-02-0089, Task Order NRC-HQ-12-C-02-0089, to reflect (1) NRC review of the preliminary outline, (2) comments and other information from the EIS scoping process, and (3) new information from the site visit and other sources, as appropriate.

The NRC COR will provide comments and approval of the revised outline.

Subtask 3C1Final Scoping Summary Report The Contractor shall finalize processing the scoping comments and developing the scoping summary report prepared under Task Order No. NRC-HQ-50-17-T-0002 under Contract No.

NRC-HQ-12-C-02-0089. The Final Scoping Summary Report shall satisfy the requirements of 10 CFR § 51.29(b). Specifically, the report shall summarize the public comments received by topical area and shall present a concise summary of the determinations and conclusions reached from the EIS scoping process, including the significant issues identified. The Final Scoping Summary Report shall disposition all public comments and include all NRC staff comments (including comments from legal review) provided by the NRC COR.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 Subtask 3C2 - Preliminary Draft Description of Environmental Impacts The Contractor shall complete preparing a Preliminary Draft Description of the Environmental Impacts of the Proposed Action and Alternatives that was started under Contract NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002. For the proposed action and each of the reasonable alternatives described in the Revised Description of the Proposed Action and Alternatives, the Contractor shall assess the potential environmental impacts of normal operating conditions, including direct, indirect and cumulative impacts, as well as climate change and accident scenarios (as appropriate). Mitigation measures committed to and proposed by the applicant to avoid or minimize environmental impacts shall be identified and taken into consideration in the impact evaluation. The assessment of the impacts shall be based on the guidance provided in NUREG-1748, and shall be conducted for the following resource/impact areas, as appropriate: land use, transportation, geology, minerals and soils, water resources (groundwater and surface water - water use and water quality), ecological resources, air quality, climate change, noise, historic and cultural resources, visual and scenic resources, socioeconomics, public and occupational health (non-radiological and radiological), accidents, waste management, and environmental justice.

In consultation with the NRC COR, the Contractor shall limit impact descriptions to those resource areas that are reasonably impacted by the proposed action or alternatives.

Additionally, the length and level of detail of the description of the impacts for each resource area shall be informed by the significance of the impacts to that resource area. For the impact discussion for resource areas other than environmental justice, historic and cultural resources, and threatened and endangered species, the Contractor shall make use of the impact significance levels (SMALL / MODERATE / LARGE) in Section 4.2.5.3 of NUREG-1748. The focus of the impact evaluation for those resource areas is to be on the important attributes of the resource and whether the environmental effects alter and separately destabilize those attributes. For environmental justice, historic and cultural resources, and threatened and endangered species, the Contractor shall use the impact wording specific to those resources (e.g., disproportionately high and adverse impact, adversely effect, adversely affect).

The Contractor shall coordinate development of impacts from any accident scenarios with the NRC COR. If accident scenarios and their impacts, if any, are developed by NRC safety staff in preparation of the NRCs SER for the license application, they will be provided, as necessary, to the Contractor for inclusion (and modification as necessary) in the EIS. Note, however, that if the accident scenarios and impacts (if any) are not yet available for inclusion in the Preliminary Draft EIS, they will be provided by the NRC COR for inclusion by the Contractor in a subsequent version of the Draft EIS. The accident scenario and impact information included in the Draft EIS (and later in the Final EIS) must be presented in a form that can be made publicly available.

Subtask 3D - Preliminary Draft EIS The Contractor shall prepare and provide the NRC COR with a Preliminary Draft EIS in accordance with the NRC's Notice of Intent to Prepare an EIS and the NRC-approved Revised Annotated EIS Outline from Subtask 3B4 of NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002 or Subtask3B of this task order if option is exercised. A copy of the Preliminary Draft EIS also shall be placed on EARRTH.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 The material developed in Subtasks 3B5, 3B6, and 3B7 of NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002 shall be incorporated into the Preliminary Draft EIS. The Contractor shall also develop and provide all additional materials necessary for a complete Preliminary Draft EIS including, but not necessarily limited to: EIS introductory information; a description of the purpose and need for the proposed action; a description of the scope of the analysis in the EIS; information on applicable statutory and regulatory requirements, permits and consultations; identification of the applicants proposed mitigation strategies, if any, and identification of any additional NRC recommended mitigation measures that may be necessary to avoid or minimize the impacts, as appropriate; a description of HOLTECs environmental measurement and monitoring programs; a cost-benefit analysis of the proposed action and alternatives; and a summary of environmental consequences.

Subtask 3E - Writing Session for the Preliminary Draft EIS The NRC will conduct a writing session of up to five (5) days in length with the Contractor on the Preliminary Draft EIS. This writing session shall take place either at the NRC Headquarters offices in Rockville, MD or at the Contractors office in Rockville, MD.

The purpose of the writing session shall be for the NRC to present its comments on the Preliminary Draft EIS and to provide clarification of the comments, as needed. The Contractor shall make available staff involved in the preparation of the Preliminary Draft EIS to take part in the writing session, either in person (if the staff is local) or by telephone or other appropriate medium (if the staff is not local). The writing session agenda and schedule shall be determined in consultation with the NRC COR in advance of the meeting.

Subtask 3F - Prepare Draft EIS Subtask 3F1 - Working Copy of the Draft EIS The Contractor shall revise the Preliminary Draft EIS consistent with (1) NRC comments received at the Preliminary Draft EIS writing session, (2) NRC resolution of any cooperating agency comments (if there are one or more agencies cooperating with the NRC in the preparation of the EIS), and (3) the applicants RAI responses. This Working Copy of the Draft EIS shall be placed on EARRTH.

Subtask 3F2 - Writing Session for the Working Copy of the Draft EIS A Working Copy Draft EIS writing session of up to five (5) days in length shall be held with NRC staff and cooperating agency staff (if any). This writing session shall take place either at the NRC Headquarters offices in Rockville, MD or at the Contractors office in Rockville, MD. At the meeting, staff from the NRC, the Contractor, and cooperating agencies (if any) shall conduct a line-by-line review of the Working Copy, as necessary. The Contractor shall make available staff involved in the preparation of the Preliminary and Working Draft EIS to take part in the writing session, either in person (if the staff is local) or by telephone or other appropriate medium (if the staff is not local). The writing session agenda and schedule shall be determined in consultation with the NRC COR in advance of the meeting.

Subtask 3F3 - Draft EIS The Contractor shall incorporate comments from the Working Copy Draft EIS writing session to produce the final Draft EIS. The Contractor shall submit this final Draft EIS to the NRC COR and place a copy on EARRTH.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 As directed by the NRC COR, the Contractor shall incorporate any comments generated during the NRC and cooperating agency (if any) internal and legal review of the Draft EIS.

During this time, to facilitate the review process and expedite subsequent revision of the Draft EIS, the Contractor shall assist in promptly addressing and responding to NRC and cooperating agency management, legal, and technical reviewer comments, as requested by the NRC COR. Within two (2) business days of the NRC CORs direction (or longer at the NRC CORs discretion), the Contractor shall post a revised final Draft EIS on EARRTH that addresses the comments received and notify the NRC COR. Subsequently, there may be up to two (2) additional versions of the revised final Draft EIS requested from the Contractor by the NRC COR, with each of these two versions incorporating additional revisions that are presently anticipated to be relatively minor and editorial in nature. Each of these additional versions shall be posted on EARRTH by the Contractor within one (1) business day of receiving direction from the NRC COR (or longer at the NRC CORs discretion).

Following the resolution of comments received during the pre-Draft EIS issuance document review and concurrence periods, the Contractor shall submit a camera-ready version of the Draft EIS to the NRC COR consistent with the schedule in Table 1 of this SOW.

OPTIONAL Subtask 3F4 - Additional Support for EIS Development The Contractor, in coordination with the NRC COR, shall provide additional support to address (1) a larger than expected number of public scoping comments (greater than 600 unique comments) and/or to address comments requiring additional analysis; (2) a larger than anticipated numbers of internal review comments or significant changes to draft documents resulting from review comments (such as from concurrence reviews or legal reviews); and/or (3) significant changes or updates to draft documents resulting from external comments, such as from the EPA and tribal interactions.

Task 4 - NHPA SECTION 106 REVIEW The Contractor shall continue to conduct the activities related to the NHPA Section 106 review and consultation that were initiated with act ivies associated with NRC-HW-12-C 0089, Task Order NRC-HQ-50-17-T-0002. As needed, the Contractor shall continue to coordinate meetings, site visits, and communication between all parties (Tribes, Tribal Historic Preservation Offices [THPOs], Texas and New Mexico State Historic Preservation Offices [SHPOs], NRC, the Advisory Council on Historic Preservation [ACHP], etc).

Subtask 4A1 - Assistance with Section 106 Activities The Contractor shall plan, coordinate, and conduct activities relating to the NHPA Section 106 review, as needed and in consultation with the NRC COR. The schedule and timing of the consultation activities, review, and required findings shall be coordinated with the schedule of the NEPA review so that the Section 106 process, to the extent possible, is completed along with the NEPA review. That is, the NEPA and Section 106 reviews shall be coordinated together to leverage site visits, information gathering meetings, public involvement, among other opportunities, as appropriate.

Activities to be completed by the Contractor may include:

Conducting research, sharing expertise, and providing technical assistance to the NRC COR; 10

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 Assisting with development, delineation and graphical representation for the Areas of Potential Effect; Participating in discussions with NRC experts as well as with the ACHP and the Licensees consultants to resolve conflicts and to help move the Section 106 process along; and Review of application and other documents that support the licensing action and provide feedback to COR.

The Contractor shall:

Develop reports and recommendations complying with SHPO guidelines for cultural reports; Participate in discussions with NRC and stakeholders to facilitate the Section 106 consultation process; and Interact with all Tribes involved, as established by the NRC, and ensure adequate communication is maintained between all parties.

The Contractor will rely on information and activities completed during for contract NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002. If necessary and as directed by the NRC COR, the Contractor shall prepare a summary report(s) documenting the Section 106 consultation activities performed including details such as personnel involved and decisions made. Prior to initiation of this Task, the NRC COR will provide more direction on the details of the Section 106 Review Summary Report.

Subtask 4A2 - Tribal Meetings For at least one and up to three meetings, and at the direction of the NRC COR, the Contractor hall prepare for and attend in-person, multi-Tribe meetings in locations to be determined. Tasks may include:

Arrange and facilitate meeting o Contact Tribes (including confirmation and response to questions);

o Coordinate approval for meeting materials; Provide logistics for meeting (select meeting location, provide necessary maps and other materials, instrumentation, and any other support including on site transportation, as needed);

o Support COR in all activities for the meeting; o Prepare summary of tribal meeting for NRC and stakeholder review; and o Follow-up with any action items.

Prepare for, attend and follow-up for teleconferences (at least 2 calls), including:

o Arranging teleconferences and providing for all logistics; o Contacting Tribes, including confirmation and response to questions; and o Preparing summary of teleconference for NRC review and approval.

OPTIONAL Subtask 4A3 - Ethnographic Study The Contractor shall conduct an ethnographic study. The scope of the study may include assembly and review of existing cultural resource records and other primary and secondary sources and require a site visit.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 Sources may include:

General environmental data sources (e.g., plant, animal, water, mineral) that may provide information regarding traditional cultural uses of the landscape; Existing historic, ethnohistoric, and ethnographic studies for the landscape available from regional studies and academic libraries; Tribal historical resources, local libraries, historical societies, and other repositories; Archaeological site reports and records for the landscape and its environs; tribal representatives (e.g., THPOs) as well as Tribal elder interviews (interview questions shall also be part of the record keeping); and Any other resources that would contain useful historical context regarding historical properties that might have cultural and religious significance to interested Tribes near the proposed project.

OPTIONAL Subtask 4A4 - Traditional Cultural Property Survey and Report The Contractor shall provide Traditional Cultural Property (TCP) survey assistance to tribes, if requested. Assistance may include:

Work with NRC COR and tribes to coordinate site survey and logistics (up to three weeks; dates TBD);

Provide Tribes with record keeping (if requested);

Work with Tribes with TCP identification and documentation efforts (this might require the Contractor to be onsite with affected Tribes for the duration of the study);

Provide materials for use in site surveys including maps; Provide logistics and support to tribes including site transport, if requested; Assist Tribes in developing the TCP study summary report; and Provide overall management of the TCP survey and report development. If the Contractor becomes aware of any issues (e.g., communication, technical, schedule),

the Contractor shall inform the COR within one business day by email.

OPTIONAL Subtask 4A5 - Additional Support to Conduct Required Analyses At the direction of the NRC COR, the Contractor shall provide resources for additional support for Section 106 Consultation activities listed in Subtasks 4A1 - 4A4. Prepare documentation and/or report to SHPO based on interaction, independent analysis, and tribal site survey information. All documentation shall be consistent with SHPO guidelines.

TASK 5 - DRAFT EIS COMMENT RESPONSE TO FEDERAL, STATE AND PUBLIC COMMENTS The contractor shall revise the preliminary final EIS to incorporate comments from the NRC review to produce the final EIS. The contractor shall submit the final EIS to the NRC as indicated in Section 6. Specific subtasks include:

Subtask 5A - Compilation of Comments (Comment Binning)

The contractor shall compile Federal, State, and Local agencies, and Public comments (estimated at less than or equal to 600) according to the guidelines provided to the NRC COR. The NRC COR will review and approve the binning of the comments prior to the 12

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 contractor developing the comment responses. The Contractor may have to revise the binning of the comments based on NRCs feedback. Some comments may be submitted to the NRC prior to the end of the public comment period. Therefore, the contractor shall begin this subtask upon receipt of the first set of comments, which will be forwarded to the contractor by the NRC COR. The contractor shall submit the binned comments to the NRC as indicated in Appendix A to the Final EIS.

Subtask 5B - Support for Draft EIS public meeting The Contractor is required to attend and support the Draft EIS public meeting(s) for the project.

The Draft EIS public meeting(s) shall be attended by the Contractors Project Manager and up to six (6) Contractor technical staff members (subject matter experts). The Contractors meeting attendees shall be determined in consultation with the NRC COR in advance of the scoping meeting(s). Up to six (6) public meetings will be held by the NRC after publishing the draft EIS and before the final EIS during two trips to the project site area and from NRC headquarters.

In addition, the Contractor may be requested by the NRC COR to provide information for and to review and provide comments on the PowerPoint (or similar format) presentation prepared by the NRC staff for the meeting(s), and to assist the NRC staff in the preparation of anticipated questions and responses to those questions as well as other materials for the meeting(s). The NRC staff presently anticipates that of the six potential meetings, the meetings may be held during two separate weeks in the vicinity of the project site or within the State.

Subtask 5C - Comment Response Report The contractor shall prepare a draft comment response report that provides responses to the Federal, state, and local agencies, and/or public comments on the Draft EIS. One comment response shall be developed for each bin of comments. The contractor shall work with the NRC COR to determine whether comments are unique or complex.

Incorporating NRCs comments, the contractor shall revise the draft comment response report to produce the final comment response report.

Subtask 5D - Significant Comments Received on Draft EIS If needed and authorized via Technical Direction from the NRC COR, in the event that significantly larger numbers of comments are received (>600 comments and the level of effort is exceeded for responding to these comments, the contractor shall provide the same level of detailed response for Subtask 5A and shall update the report in Subtask 5C to include additional comments. If comments require additional analysis and/or significant revision to the draft EIS, the contractor shall update the EIS accordingly.

Additional effort is required to address over six times the number of comments originally anticipated (an estimated 3,700 comments).

TASK 6 - FINAL EIS The contractor shall finalize the EIS based on information to respond to comments from the NRC staff, public and federal agencies.

Subtask 6A -Preliminary Final EIS 13

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 Based on input and comments from NRC staff, the contractor shall updated the final draft EIS incorporating necessary documentation regarding consultations over Section 7 of Endangered Species Act (ESA) and Section 106 of NHPA, and public comments based on developed responses under Task 5. The revised final draft EIS (Preliminary Final EIS) shall be reviewed by a technical editor formatted to NRC standards and reviewed for technical content. This will be delivered to NRC 30 days after receipt of all federal, state and public comments from the NRC COR. A writing session may be required after NRC staff have reviewed the draft final EIS deliverable.

Subtask 6B -Final EIS The contractor shall revise the preliminary final EIS based on NRC review comments received from the NRC COR. The deliverable shall be transmitted to NRC within 10 calendar days.

Additional effort will be required to address revision of the comment bins in response to NRC staff comments.

The completion of the Final EIS has been delayed due to delays receiving completed RAI responses. This delay will result in a delay of approximately 10 months. During this time there will be additional level of effort to address the following:

a. Evaluate new information in all resource areas and determine if new information is significant to the FEIS evaluation

b. Update and finalized the FEIS with new information and corresponding impact analysis

c. Update and finalized any issues from safety review RAI responses including land use impacts

d. Provide additional cross-checks for comment responses

e. Update comment response Appendix as necessary Task 7 - Pre-Hearing Support It is presently anticipated that petitioners may submit written contentions on the applicants license application and/or NRCs proposed licensing action for consideration by the ASLB. If any of these contentions are admitted by the ASLB, there will be a contested hearing held on the project. If needed and as requested by the NRC COR, the Contractor shall support the NRC staff by reviewing the submitted contentions on environmental issues and providing written responses (including copies of reference materials, as necessary) to these contentions, as well as other written materials in response to interrogatories from the ASLB on the contentions and related matters, as required. If needed and as requested by the NRC COR, the Contractor shall also review and provide written comments on any written materials submitted by the applicant and other parties relevant to the submitted contentions. It shall be assumed that up to ten (10) contentions on environmental issues will be submitted by petitioners.

Greater than 10 contentions have been submitted and petitioners continue to submit requests to reopen the record and appeal the Boards decision. The contractor shall respond and evaluate responses to appeals and newly requested contentions.

Under the direction of the NRC COR, the contractor will comply with any documentation requirements for on-going litigation. The NRC is currently involved in litigation both in federal district court and the United States courts of appeals concerning the licensure for two 14

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 consolidated interim storage facilities. The contractor must retain and hold all documents related to the license applications reviews and activities. The COR will direct the contractor in any additional effort to make those files available or transmit them to specific parties. This task may require extensive file searches and support for maintaining a litigation record.

5. APPLICABLE DOCUMENTS AND STANDARDS The documents listed below are relevant to the requirement and shall be used by the Contractor in the performance of the task order. The documents are publicly available and may be obtained by the Contractor from ADAMS or will be provided by the NRC COR. The NRC COR will continue to identify and provide necessary documents to the Contractor as they become available throughout the period of performance of this task order.

The Contractor shall be familiar with and shall rely upon the following documents in the performance of this effort:

HOLTECs license application, SAR, and ER HOLTECs responses to RAIs and any other supplemental information provided by HOLTEC NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs Deliverables and information developed for NRC-HQ-12-C-02-0089, Task Order NRC-HQ-50-17-T-0002

6. DELIVERABLES AND DELIVERY SCHEDULE The presently anticipated schedule for deliverables/milestones required under this task order is outlined in Table 1 below. All deliverables shall be provided electronically to the NRC COR in MS Word format. The MS Word documents shall be saved such that they are compatible with previous MS Word versions. In addition, certain deliverables (primarily the final and revised final versions of the Draft EIS, but others if requested) shall also be provided electronically in PDF format, upon request from the NRC COR. Except where otherwise noted, all deliverables/milestones are the responsibility of the Contractor.

Table 1. Deliverable/Milestone Schedule Task Subtask Deliverable/Milestone Anticipated Schedule Project Manager Detailed Project Schedule 1 -- Provided to NRC COR upon request in MS Project Bibliographic listing of all documents collected and file of electronic copies. Provided to NRC COR as needed 2

Permissions for use of copyrighted materials and reference documents Update List of federal, tribal, state, and local statues, laws, and permits as needed based 2 As directed by NRC COR on the review and development of the draft EIS.

3A 3 Second Round RAIs As directed by NRC COR (Optional) 3B 3 Second Revised Annotated Outline AS directed by NRC COR (Optional) 15

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 Task Subtask Deliverable/Milestone Anticipated Schedule Within 10 business days from receipt of the last 3 3C1 Final Scoping Summary Report comments from the NRC COR on the draft scooping summary report 60 business days after conclusion of site Preliminary Draft Description of visit trip from activities associated with NRC-3 3C2 Environmental Impacts of the Proposed HQ-12-C-02-0089, Task Order NRC-HQ-Action and Alternatives 50-17-T-0002 or at direction of the NRC COR 80 business days after conclusion of site visit trip NRC-HQ-12-C-02-0089, Task 3 3D Preliminary Draft EIS Order NRC-HQ-50-17-T-0002 or at direction of the NRC COR 20 business days from either (1) the receipt of NRCs final comments and resolution of comments from cooperating agencies (if 3 3F1 Working Copy of the Draft EIS applicable) on Preliminary Draft EIS, or (2) receipt of applicants responses to NRCs 1st round of safety RAIs, whichever is later.

20 business days after conclusion of the 3 3F2 Draft EIS Working Copy Draft EIS writing session (Subtask 3F2)

As directed by NRC COR during NRC and cooperating agency internal and legal 3 3F3 Revised final versions of Draft EIS review of Draft EIS (see discussion in Subtask 3F3)

Within 5 business days of final revision to Draft EIS in response to NRC and 3 3F3 Camera ready Draft EIS cooperating agency (if any) internal and legal reviews Summary Reports of Section 106 As needed, with schedule to be agreed to 4 4A1 Consultation Activities between NRC COR and Contractor Comments and review of cultural resource Within 10 business days from initiation of 4 4A1 report for NHPA Section 106 consultation Section 106 consultation 4 4A2 Site visit report and/or meeting summary Within 10 business days of site visit/meeting 4 4A2 Teleconference Summary Within 10 business days of teleconference 4 Schedule to be agreed to between NRC 4A3 Ethnographic Report (Optional) COR and Contractor 4 Within 10 days of tribal input and after last 4A4 TCP site survey report(s)

(Optional) survey 4 Schedule to be agreed to between NRC 4A5 Documentation/Reports (Optional) COR and Contractor Schedule to be agreed to between NRC 5 5A Draft EIS comment binning COR and Contractor Materials in support of Draft EIS public At least 10 days in advance of scheduled 5 5B meetings meetings Draft comment Response Report Schedule to be agreed to between NRC 5 5C COR and Contractor Schedule to be agreed to between NRC 5 5C Final Comment Response report COR and Contractor 16

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 Task Subtask Deliverable/Milestone Anticipated Schedule 6 6A Preliminary Final EIS Within 30 days of end of comment period Deliverables and schedule to be agreed to 6 6B Final IES (camera ready) between NRC COR and Contractor As directed by NRC COR (based on 7 Pre-Hearing Support (Reponses and/or

-- direction from ASLBP) or the NRC Office of Comments General Council and Solicitor General Monthly Letter Status Report per Section NLT 20th calendar day of the following All F.2 of the base contract Month Note: All days are calendar days unless otherwise specified.

7. REPORTING REQUIREMENTS Monthly Letter Status Report (MLSR)

The contractor shall provide a Monthly Letter Status Report in accordance with the base contract which consists of a technical progress report and financial status report by the 20th day of the following month. This report will be used by the Government to assess the adequacy of the resources proposed by the contractor to accomplish the work contained in this SOW and provide status of contractor progress in achieving activities and producing deliverables. The report shall include order summary information, work completed during the specified period, milestone schedule information, problem resolution, travel plans, and staff hour summary. If no work was performed during the prior month, the contractor shall not prepare and submit an MLSR.

8. REQUIRED LABOR CATEGORIES/STAFFING The Contractor shall ensure that the technical staff performing under this task order possess the necessary experience and expertise in the technical areas assigned to them.

The Contractors Project Manager shall have in-depth expertise in at least one of the significant issues for the EIS preliminarily identified by the NRC staff (i.e., transportation, public and occupational radiological health, socioeconomics, and environmental justice) and a general understanding of the range of issues covered by an EIS. In addition, the Contractors Project Manager shall have extensive experience in the technical and regulatory aspects necessary for evaluating the environmental impacts of the construction and operation of industrial facilities, including nuclear facilities that require reviews under NEPA, and shall have expertise in methods used to mitigate impacts on the environment.

The Contractors senior technical staff assigned to this task order shall have specialized experience to include a Bachelors Degree and at least 5 years of technical experience in conducting environmental reviews in the specific technical areas assigned or an advanced degree and experience reflecting continued achievement in their chosen profession, and shall have an appropriate combination of education, training, and experience in the areas required to complete the EIS, including land use, transportation, geology, minerals and soils, water resources (groundwater and surface water), ecological resources, climatology, meteorology and air quality, climate change, noise, historic and cultural resources, visual and scenic resources, socioeconomics, public and occupational health (non-radiological and radiological), accidents, waste management, environmental justice, cumulative impacts assessment, mitigation measures, environmental measurements and monitoring, and cost-benefit analysis, again with 17

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 the most important of these areas preliminarily identified by the NRC staff as transportation, public and occupational radiological health, socioeconomics, and environmental justice.

Additionally, the Contractors technical staff shall have a clear understanding of the depth of review generally required by the NRC for an EIS and specifically required by the type of activity proposed by the applicant for the disciplines they represent. Experience presenting technical information in written reports and providing written and oral testimony at adjudicatory hearings on the proposed license termination action also is required.

The NRC considers the following technical disciplines to be essential for this effort:

1. Project Manager

2. Environmental Specialist / Scientist / Engineer

3. Radiation Health Physicist

4. Hydrologist / Hydrogeologist

5. Geologist / Seismologist

6. Nuclear Physicist / Engineer / Criticality

7. General Engineer / Chemical Engineer

8. Historic and Cultural Resources Specialist

9. Ecology and Interrelated Earth Sciences Specialist

10. Environmental Justice Specialist

11. Socioeconomics Specialist

12. Transportation impact assessment Specialist

13. Cumulative impacts assessment Specialist

14. Facilitation/Public Outreach Specialist

15. Nuclear Fuel Facility and/or Spent Fuel Facility Specialist

16. Federal, Tribal, State, and/or other Local Agency Consultation and Coordination Specialist

17. Technical Editor

9. GOVERNMENT-FURNISHED PROPERTY The COR will facilitate the Contractors access to PNNLs EARRTH SharePoint site.

The Comment Response Database is also found on the EARRTH website.

10. PERIOD OF PERFORMANCE Refer to Section F.1 TASK/DELVIERY ORDER PERIOD OF PERFORMANCE (SEP 2013)

11. PLACE OF PERFORMANCE Except as otherwise indicated in Section 4 and Section 12.1 of this SOW, the work shall be performed at the Contractors facilities.

12. SPECIAL CONSIDERATIONS Include in this section, items such as the following as applicable:

12.1 MEETINGS/TRAVEL Throughout the task order period of performance, the Contractor shall maintain effective communication with the NRC COR and staff (and with cooperating agency staff, if any) to help coordinate and integrate EIS preparation with NRC and the cooperating agency (if any) 18

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 technical and decision making activities. Several meetings between the Contractor and NRC staff throughout the duration of this task order are presently anticipated. Meetings are presently anticipated to be held at the NRC offices in Rockville, Maryland, but may alternately be held at the Contractors offices. The meetings will be held to review progress, provide input into the project, and work on project deliverables. Travel to the HOLTEC site vicinity shall be required for the Draft EIS comment meeting(s). Travel to the NRC Offices in Rockville, Maryland, maybe required for the Draft and Final EIS Review Meetings (Writing Sessions). In addition, if necessary, the Contractor shall also attend meetings in Rockville, Maryland, to discuss RAIs with the NRC staff and HOLTEC and for coordination with cooperation agencies (if any) on the EIS. During Task 7, travel maybe required for pre-hearing support in Rockville, Maryland.

The contractor shall be authorized travel expenses consistent with the Federal Travel Regulation (FTR) and the limitation of funds for this task order. All travel requires prior written COR approval. Meetings and other activities that may require Contractor travel are summarized in Table 2 below. At the NRC CORs discretion, some of these meetings may be held in the form of teleconferences or webinars or at the contractors site.

Table 2. Meetings and Travel Contractor Number Days Staff Task Purpose Location of Trips per Members Trip per Trip 1 Quarterly Progress Meetings Rockville, MD 4 3 1 3A RAI Meetings Rockville, MD 1 3 2 (OPTIONAL)

HOLTEC site vicinity 4A2 Tribal Meetings 3 4 2 Hobbs, New Mexico 4A3 HOLTEC site vicinity Ethnographic Study 1 5 1 (OPTIONAL) Hobbs, New Mexico 4A4 HOLTEC site vicinity Tribal survey 2 5 2 (OPTIONAL) Hobbs, New Mexico Draft EIS comment public HOLTEC site vicinity 5 2 5 7 meetings Hobbs, New Mexico Preliminary Final EIS (Writing 6A Rockville, MD 1 5 1 Session) 7 Hearing Preparation Rockville, MD 1 4 4 12.2 SECURITY Work on this task order will involve the handling of documents that contain proprietary information. The contractor shall safeguard documents containing proprietary information against unauthorized disclosure. After completion of work, the contractor must either destroy the documents or return them to the NRC. If they are destroyed, please confirm this in an e-mail to the COR with a copy to the CO and include the date and manner in which the documents were destroyed.

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31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 12.3 KEY PERSONNEL Refer to Section H.2 2052.215-70 KEY PERSONNEL (JAN 1993) 12.4 LICENSE FEE RECOVERY The EIS preparation work and the NHPA Section 106 work are fee-recoverable.

The Hearing Support work is not fee-recoverable.

12.5 DATA RIGHTS The NRC shall have unlimited rights to and ownership of all deliverables provided under this contract/order, including reports, recommendations, briefings, work plans and all other deliverables. All documents and materials, to include the source codes of any software, produced under this contract/order are the property of the Government with all rights and privileges of ownership/copyright belonging exclusively to the Government. These documents and materials may not be used or sold by the contractor without written authorization from the CO. All materials supplied to the Government shall be the sole property of the Government and may not be used for any other purpose. This right does not abrogate any other Government rights. The definition of unlimited rights is contained in Federal Acquisition Regulation (FAR) 27.401, Definitions. FAR clause at FAR 52.227-14, Rights in Data-General, is hereby incorporated by reference and made a part of this contract/order.

12.6 QUALITY CONTROL PROGRAM The Contractors approach to quality control shall focus on project management and document production processes and tools that assure the quality of the deliverables and integrity of the environmental review process.

The Contractors project manager will serve as the focal point for coordinating the project activities and will be responsible for assuring the timely and high quality submittal of deliverables. All information shall be accurate and complete. The project management responsibilities include verifying quality requirements and deliverables specifications, responding satisfactorily and in a timely manner to feedback, and continuously improving products and services by communicating and applying lessons learned. The Contractors project manager shall also ensure that scientific and technical reports are developed in accordance with established practices for publishing scientific and technical information.

Project deliverables will be reviewed by someone other than the project manager to ensure that they are accurate and complete. Management approval is necessary for all final deliverables.

Document version control is critical to the document production process. The Contractor shall ensure that previous versions are kept so the Contractor will be able to return to any earlier version of a document and be able to track the changes and the basis for those changes.

Editorial review involves a complete review of the entire document by an editorial review team. The editorial review will help ensure that a coherent and complete story is being told 20

31310018D0001 31310018F0125 P00014 ATTACHMENT NO. 1 in accordance with writing and format guidelines. The quality of the graphics is also evaluated to understand if these are legible or need to be improved.

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