UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

OFFICE OF THE 

INSPECTOR GENERAL 

 January 22, 2010 

MEMORANDUM TO: R. William Borchardt 

 Executive Director for Operations 

FROM: Stephen D. Dingbaum /RA/ 

 Assistant Inspector General for Audits 

SUBJECT: MEMORANDUM REPORT: AUDIT OF THE NUCLEAR 

REGULATORY COMMISSION’S USE OF ELECTRONIC 

SUBMISSIONS FOR COMBINED LICENSE 

APPLICATIONS (OIG-10-A-08) 

The Office of the Inspector General (OIG) conducted this audit to evaluate the Nuclear 

Regulatory Commission’s (NRC) use of electronic submissions in the Office of New 

Reactors (NRO), with a specific focus on Combined License Applications (COLA), and 

its applicability to other NRC activities such as in the Office of Nuclear Reactor 

Regulation. OIG found that the electronic submissions process for COLA documents 

fulfills its intended purpose, and that NRC users and public stakeholders were generally 

satisfied with it. Although OIG makes no recommendations, auditors identified issues 

for consideration to enhance the electronic submissions process. 

BACKGROUND

NRC issues licenses for construction and operation of nuclear power plants. The 

agency last issued an operating license in 1996; however, there is growing interest 

among U.S. utilities in nuclear power. Since 2007, NRC has received 18 applications to 

construct 28 new reactors. 
Audit of the Nuclear Regulatory Commission’s Use of Electronic Submissions for Combined License Applications 

2 

Reactor license applications—generally referred to as COLAs—are large document 

packages that NRC must review to ensure that each applicant meets agency standards 

for building and operating nuclear power reactors. To reduce the logistical burden 

associated with paper document processing, applicants are to submit COLA documents 

using electronic media, such as compact discs (CD) or digital versatile discs (DVD). 1

NRC’s Office of Information Services (OIS) manages the processing of COLA 

documents submitted to NRC. After initial receipt of an applicant’s CD/DVD at the 

Document Control Desk, contractor personnel2

 at the Document Processing Center 

(DPC) review information contained on the CD/DVD to ensure that it is properly 

formatted. If the applicant’s submission passes this review, the documents can be 

uploaded to NRC’s Agencywide Documents Access and Management System 

(ADAMS), the agency’s main electronic recordkeeping system. If a submission does 

not pass this review, NRC staff notify the applicant so that the document(s) can be 

revised and resubmitted. Figure 1 illustrates this process. 

Figure 1: Processing of COLA documents submitted to NRC on electronic media. 

Electronic 

Application

Document 

Control 

Desk

Document 

Processing Center Application Review by 

NRC Staff

Document 

intake

Quality control

Document profiling

Official Agency 

Records in ADAMS

Notify NRC 

reviewers 

Applicant 

qualifications

Design

Safety

Operations

Environmental 

impact

CD 

or 

DVD

Source: OIG analysis. 

 

1

 CDs and DVDs enable applicants to submit files that are too large to transmit via the Internet. 2

 NRO document review and processing is a subtask within a broader ADAMS support contract. In the 

2008-2009 base year of this contract, the value for this subtask was approximately $71,500. An OIS 

project manager oversees the contract. 

 
Audit of the Nuclear Regulatory Commission’s Use of Electronic Submissions for Combined License Applications 

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PURPOSE

The audit objective was to evaluate NRC’s use of electronic submissions in NRC, with a 

specific focus on COLA documents, and its applicability to other NRC activities such as 

in the Office of Nuclear Reactor Regulation. 

RESULTS

Auditors evaluated NRC’s electronic submissions process for COLAs. This process 

meets its intended purpose of reducing the logistical burden associated with paper 

documentation. NRC and public stakeholders were generally satisfied with the 

electronic submissions process for facilitating COLAs. Furthermore, although some 

electronic submissions undergo delays in the ADAMS upload process, such delays 

reportedly do not prevent applicant personnel from proceeding with their work on 

applications. Further, as permitted by internal agency guidance,3 agency staff use their 

own working copies of COLA documents before they are uploaded to ADAMS. 

Although no recommendations are associated with this report, OIG identified several 

issues for the agency to consider. 

Issues for Consideration

 Offer more hands-on training. Several applicant personnel said that they had 

become more familiar with NRC’s standards and processes over time, and had 

learned much through early trial and error. However, one said NRC’s initial 

hands-on training was helpful and recommended that NRC offer it again. 

 

 Re-evaluate “pre-flight” criteria.4 Applicant personnel and one NRC staff 

questioned the value of “pre-flight” criteria that applicants are supposed to follow 

in preparing their submissions. One applicant employee mentioned instances in 

which documents apparently met the “pre-flight” standards, but were still returned 

to them by the DPC for revision. Another applicant employee noted an instance 

in which a document did not meet “pre-flight” criteria but was uploaded into 

ADAMS anyway. 

 Develop a means for formatting non-PDF documents. NRC guidance states 

that COLA documents should be formatted using Portable Document Format 

(PDF) software. However, some information is processed using non-PDF 

software unique to technical fields such as meteorology. Some historical 

information must be transferred from microfiche, which can present formatting 

 

3

 Management Directive 3.53, “NRC Records and Document Management Program,” revised March 15, 

2007. 

4

 The “pre-flight” check is a preliminary automated review of COLA submissions to ensure the documents 

meet NRC standards for file size and other formatting characteristics. Following “pre-flight,” DPC staff 

perform a more extensive manual quality control review of documents before uploading them to ADAMS. 
Audit of the Nuclear Regulatory Commission’s Use of Electronic Submissions for Combined License Applications 

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problems requiring the applicant to copy the microfiche onto paper and submit 

hard copies in lieu of CD/DVD. 

 

 Establish a single point of contact for applicants. NRO project managers and 

OIS staff are involved in processing COLA submissions, but there is no single 

point of contact to help applicants resolve problems with their submissions. 

Several applicant personnel said individual NRC staff were helpful; however, one 

reported experiencing poor communication among NRC organizations and 

difficulty in contacting OIS staff. One NRO project manager cited similar 

communication problems with OIS and recommended establishing a single point 

of contact as a solution. 

AGENY COMMENTS

NRC staff were given an opportunity to review a draft version of this report, and 

provided editorial suggestions. This final report incorporates revisions made, where 

appropriate, as a result of the agency’s suggestions. 

SCOPE AND METHODOLOGY

To understand NRC’s policies and procedures for processing documents submitted 

electronically by the public, auditors interviewed staff from OIS, the Office of the 

Secretary, the Office of the General Counsel, and the Atomic Safety and Licensing 

Board Panel. Auditors reviewed pertinent NRC guidance as well as the Government 

Paperwork Elimination Act. To understand processes unique to new reactor license 

submissions, auditors interviewed staff from NRC and the DPC, reviewed NRC’s 

electronic submissions guidance for end-users, and reviewed procedures used by DPC 

personnel to process new reactor license documents. In addition, auditors reviewed the 

contract for these processing services as well as data regarding document processing 

volume and contractor performance. To understand end-users’ perspectives on NRC’s 

policies and procedures, auditors interviewed personnel representing four electric power 

utilities, which, together, have submitted 6 of the 18 new reactor license applications 

received by NRC as of September 2009. Further, auditors interviewed a contractor who 

prepares applicants’ documents for submission to NRC and a representative from the 

Nuclear Energy Institute who had worked with NRC and the nuclear power industry on 

an electronic submissions task force. 

Internal controls related to the audit objective were reviewed and analyzed. Throughout 

the audit, auditors were aware of the possibility or existence of fraud, waste, or misuse 

in the program. 
Audit of the Nuclear Regulatory Commission’s Use of Electronic Submissions for Combined License Applications 

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The work was conducted from July 2009 to October 2009 in accordance with generally 

accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

The work was conducted by Beth Serepca, Team Leader; Paul Rades, Audit Manager; 

Levar Cole, Senior Analyst; and Michael Blair, Analyst. We performed the audit work at 

NRC headquarters in Rockville, Maryland.