ML20203E497
| ML20203E497 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/1997 |
| From: | Donnelly L NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Hagan T NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20203D144 | List:
|
| References | |
| FRN-63FR67726, RULE-PR-48C20 AF52-1-028, AF52-1-28, NUDOCS 9902170203 | |
| Download: ML20203E497 (3) | |
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NUCLEAR REGULATORY COMMISSION o, WASHINGTON. D.C. 20666 4001 l '% . . . . . p$
l September B. 1997 l MEMORANDUM TO: i of J.H g [irector. DCPM/ADM FROM: L oy Donnelfy, b ector. FMPAS/RES l
SUBJECT:
REQUESTFOROFFICEbOMMENTSANDCONCURRENCE-PROPOSEDRULl '
ENTITLED " NUCLEAR REGULATORY COMMISSION REGULATION (NRCAR)"
Attached are the Office of Nuclear Regulatory Research's comments 'on-the proposed NRCAR. If questions arise, please contact Marianne Riggs on 415-5822.
Attachment:
i As. stated !
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! 9902170203 990209 PDR PR 48C2063FR67726 PDR ,
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4 Att. 1 RES COMMENTS ON PROPOSED NRCAR General Comment: This document would have been easier to review if all added text had been highlighted. It was difficult to discern what was new and made reviewing the document more time consuming than it should have been.
- 1. Page 5. Part 2001.403. " Individual deviations".
REMARK: Use of words " individual cases" and "only one contracting action" is redundant and eliminates flexibility that might be needed in a particular situation. The fact that deviations are authorized on an individual case basis provides sufficient parameters.
- 2. Page 6. Part 2001.602-3 " Ratification of unauthorized commitments."
REMARK: The re-write of paragraph (a) has deleted the statement that the Government is not bound by agreements / commitments made by unauthorized parties. This idea should be reinserted due to the significant consequences to contractors and unauthorized parties entering into these agreements. Although the Government may have the ability to ratify an action, it may not choose to do so. This could result in substantial liability for the unauthorized party and for the contractor.
- 3. Page 18. last definition. " Subcontractor. .except subcontracts for i supplies and subcontracts in amounts in excess of $10.000." l REMARK: Shouldn't this state "less than $10.000."?
- 4. Page 35. Part 2015.604 (b). " Responsibilities" l
REMARKS: Paragraph (b) refers to the " Head of the Contracting Activity." It is unclear if this refers to the Designating Official or to the Contracting Officer. The reference needs clarification.
- 5. Page 38. (e) "The contractor officer's selection is made.
REMARK: Insert the word " source" between " officer's" and " selection" to clearly show that the paragraph concerns selecting the awardee of the contract.
- 6. Page 41. Subchapter D - Socioeconomic Programs. Part 2017.2 - Options.
2017.204 Contracts (a)
Is this paragraph only for socioeconomic programs or for all contracts in general? If it is for all contracts, shouldn't it be placed in a
~different subchapter?
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- 7. Page 45. Part 2025 - Foreign Acquisition REMARK: With the deletion of this part does this mean that there is no restriction on purchasing supplies or services from foreign entities?
If there is some restriction, where is it stated in NRCAR?
- 8. Page 99.~ Publication of Research Results- )
REMARK: For all contracts, net just university contracts. NRC reserves l the right to disapprove or delay the publication of research results. 1
'Further, if the NRC disagrees with the pro)osed publication for any reason, it reserves the right to require tlat any publication not identify the NRC's sponsorship of the work and that any associated publication costs shall be borne by the contractor. This statement should De made a part of the first (c) on the page just as it is in the second (c).
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