EXHIBIT D 

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CORPORATE OPERATIONS MANUAL

Sponsored by

The Executive Committee

Holtec International

Document ID: CD-9

Category: Non-Safety Significant

Class: Generic

Revision 0

Issuance Date 01/18/2011

NOTICE OF PROPRIETARY INTELLECTUAL PROPERTY STATUS

This document contains valuable intellectual property of Holtec International. Holtec’s rights to the ideas, methods, 

models, and precepts described in this document are protected against unauthorized use, in whole or in part, under 

U.S. and international intellectual property laws. No part of this publication may be reproduced, stored in a retrieval 

system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or other, 

without the prior written permission of Holtec International.

The recipient of this document bears sole responsibility to honor Holtec's unabridged ownership rights of this 

document, to observe its confidentiality, and to limit use to the purpose for which it was delivered to the recipient.

© 2011 by Holtec International. All rights reserved.

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Table of Contents and Chapter Sponsors

Chapter Title Page Chapter Sponsor

1.0 Scope and Applicability Nick Abraczinskas

2.0 Organization Charts, Holtec Manuals, and Other Generic 

Corporate Documents

2.1 Organization Charts

2.2 Manuals

2.3 Agreements with External 

Organizations

Mark Soler and Nick 

Abraczinskas

3.0 Guidelines to Company Executives and Managers

3.1 Mandatory Guidelines

3.2 Management of Operations Centers and Interface 

with Corporate Acquisitions Department

3.3 Notion of “Apparent Authority”

3.4 Canons of Management Conduct

K.P. Singh

4.0 Project Management and Finance Management 

Tools

4.1 Project Management Forms

4.2 The Project Management Team

4.3 Meeting Minutes 

4.4 Finance Management Tools 

4.5 Recruitment, Retention and Termination of 

Personnel – HR Forms

Exhibit 4.A: Minutes-of-the-Meeting

Nick Abraczinskas

and

P.K. Chaudhary

5.0 Guidelines on Confidentiality and Proprietary 

Information

5.1 Confidentiality as a Corporate Creed

5.2 Holtec Proprietary and Confidential 

Information

5.3 Personnel Empowered to Execute Affidavits 

Pursuant to 10CFR 2.390(b) and 10CFR 

72.48

5.4 Control and Handling of Others’ Proprietary 

Information

5.5 Standard Tombstone Text for Front Page of 

Holtec-Produced Documents (Reports, 

Procedures, Specifications, etc.)

5.6 Footnote on All Communications Containing 

Commercial Information

Exhibit 5.A: Agreement to Protect Confidential 

Information

Marc Nocera

6.0 Management of Bank Accounts, Transfer of Funds, 

and Petty Cash for Remote Operations Centers

Frank Bongrazio

Nick Abraczinskas

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Table of Contents and Chapter Sponsors

Chapter Title Page Chapter Sponsor

7.0 Requests for Contract Price Adjustment (CPA) and 

Cost Forms for Pricing Projects

7.1 Contract Price Adjustment (CPA) Database

7.2.1 Applicable Cost Forms

7.2.2 Consistency and Transparency in Pricing 

Nuclear Projects

7.3 Notice of Commercial Claim

P.K. Chaudhary

8.0 Guidelines on Inter-Divisional Relationships

8.1 Financial Accountability for Errors by 

Business Units

8.2 Notice of Cost Impact and Schedule Impact 

to HMD

8.3 HMD Projects Corporate Allocations

Exhibit 8.A: Notice of Cost and Schedule Impact 

P.K. Chaudhary

9.0 Protocol for Processing Procurements and Payables

9.1 Guidelines

9.2 Operational Guidelines to Purchasing 

Personnel

9.3 Inter-Division Purchase Requisition (IPR)

9.4 Accounts Payable Process

P.K. Chaudhary

10.0 Travel and Entertainment Expense Policy

10.1 Purpose

10.2 Application

10.3 Responsibilities

10.4 General Travel Guidelines

10.5 Travel and Entertainment Guidelines

10.6 Air Travel

10.7 International Air Travel

10.8 Lodging

10.9 Rental Car

10.10 Other Transportation

10.11 Personal/Vacation Travel

10.12 Telephone Usage

10.13 Travel Insurance

10.14 Meals and Entertainment

10.15 Expense Reporting

10.16 Non-Reimbursable Expenses

Exhibit 10.A: Travel Authorization Form

Frank Bongrazio and 

Nick Abraczinskas

11.0 Vacations and Holidays Frank Bongrazio and 

Nick Abraczinskas

12.0 Duties and Responsibilities Associated with Holtec 

Managers

12.1 Nuclear Power Division

12.1.1 Duties and Responsibilities of NPD’s 

K.P. Singh

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Table of Contents and Chapter Sponsors

Chapter Title Page Chapter Sponsor

Program Manager

12.1.2 Duties and Responsibilities of Adjunct 

Project Manager

12.1.3 Duties and Responsibilities of the Technical 

Sponsor

12.1.4 Duties and Responsibilities of the Design 

Planning Manager

12.2 HMD Managers

12.2.1 General Manager – Nuclear Business Unit

12.2.2 Business Unit Manager – PPCD 

Manufacturing

12.2.3 Lead Product Line Manager – Nuclear

12.2.4 HMD QA Manager

12.2.5 Manager of Planning and Schedule

12.3 Discipline Managers (Holtec Technical 

Services)

12.4 Project Managers and Adjunct Project 

Managers

13.0 Corporate Governance and Code of Conduct

13.1 Recognizing Meritorious and Poor Conduct

13.2 Summary of Guidelines in External 

Interactions

13.3 Corporate Governance

13.4 Reporting of Complaint and 

Recommendations

Exhibit 13.A: Damage Report on Erroneous Work 

(DREW)

Exhibit 13.B: Citation for Meritorious Work

Exhibit 13.C: Demerit Notice

Exhibit 13.D: Notice of Reprehensible Conduct 

(NRC)

Frank Bongrazio and 

Nick Abraczinskas

14.0 Training and Human Performance

14.1 Holtec Personnel Training

14.2 Training Modules

14.3 E-Mail Training: Lessons Learned 

Database 

14.4 Training Tablets

Exhibit 14.A: List of Training Modules

Exhibit 14.B: Illustrative Training Tablets

Mark Soler

and 

P.K. Chaudhary

15.0 Performance Disseminations and Performance 

Reviews

15.1 Bi-Weekly Reports

15.2 Performance Review Forms

15.3 Confidential Review of Holtec Executive 

Personnel

Nick Abraczinskas

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Table of Contents and Chapter Sponsors

Chapter Title Page Chapter Sponsor

15.4 Improving our Work Environment

15.5 Internal Communications

Exhibit 15.A: Confidential Peer Review of Holtec 

Personnel

Exhibit 15.B: Confidential Review of Holtec 

Executive Personnel

16.0 Drug and Alcohol Policy

16.1 Introduction

16.2 Definitions

16.3 General Rules Regarding Drugs and Alcohol

16.4 Drug and Alcohol Testing and Searches

16.5 Employee Assistance

Exhibit 16.A: Condition of Reinstatement or Rehire

Exhibit 16.B: Testing Consent Form

Mark Soler

17.0 Safety and Quality Forms

17.1 Required Action Before Granting Access to 

a Visitor to a Holtec International 

Manufacturing Facility

17.2 Holtec Safety Bulletin

17.3 Vow of Safety

17.4 Quality Assurance Developments

Exhibit 17.A: Visitor Request Access Request & 

Authorization Form 

Exhibit 17.B: Holtec Safety Bulletin 

Exhibit 17.C: A Solemn Vow of Safety

Exhibit 17.D: Manufacturing Event Report

Kevin Dodge

18.0 Miscellaneous Items 

18.1 Questionnaire for Prospective Manufacturers 

as Holtec’s Team Partner

18.2 Process for Shipping Holtec Components

18.3 Position Papers: Formatting and Filing

18.3.1 How to Obtain a Position Paper Number

18.3.2 Organization and Formatting

18.3.3 Header and Footer

18.3.4 Filing of Position Papers

18.4 Memo to Clients to Secure Permission to 

Publish Holtec Highlights

18.5 Patents and Trademark Registrations 

Granted to Holtec International

K.P. Singh

P.K. Chaudhary

Nancy Moreland

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1.0 SCOPE AND APPLICABILITY

This document contains information on Holtec International’s policies and operational details to 

provide day-to-day guidance to the Company’s associates and managers at all domestic and 

overseas operations centers.

This document shall be revised from time to time to maintain it in current status. The latest issue 

of this document is saved on Holtec’s corporate network under G:\Generic\Holtec Corporate 

Manuals\CD-09\CD-09 Corporate Operations Manual, where all other “high level” manuals 

reside. 

Between updates of this manual, interim instructions on operational related items are issued 

through “Administrative Memos”. The Administrative Memos are issued via e-mail and stored in 

the main server at G:\Generic\Admin\Administrative Memos. 

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2.0 ORGANIZATION CHARTS, HOLTEC MANUALS, AND OTHER GENERIC 

CORPORATE DOCUMENTS 

2.1 Organization Charts

The Corporate and Division level organization charts can be found on the Company’s network 

under G:\Generic\Admin\Organizational Charts. The divisional organization charts are updated 

by the Company’s Corporate Administrative Department.

2.2 Manuals

All Company associates should be aware of the following manuals and be familiar with them, if 

required by their work.

Document Applicable 

Locations

Document I.D. Holtec 

Sponsor

1. Holtec Employee Manual All CD-1 Marc Nocera

2. Holtec Personnel Training 

Manual

All CD-2 Mark Soler

3. Holtec Quality Assurance 

Manual

Marlton, 

Pittsburgh, 

Lakeland, and 

Kiev

CD-3 Mark Soler

4. Holtec Quality Assurance 

Procedures Manual

Marlton, 

Pittsburgh, 

Lakeland, and 

Kiev

CD-4 Mark Soler

5. Holtec ASME Code Quality 

Manual 

CD-5 Mark Soler

6. ISO-9001 Manual CD-6 Mark Soler

7. Corporate Governance and 

Ethics Manual

All CD-7 Mark Soler

8. Not Used CD-8

9. Corporate Operations Manual All CD-9 Kris Singh

10. Not Used

11. Not Used

12. Not Used

13. Not Used

14. Not Used

15. Not Used

16. Rigging Manual Pittsburgh, 

Orrville, 

Lakeland, All 

Nuclear Sites

CD-16 Steve Soler

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17. Site Safety Plan All Nuclear Sites CD-17 Steve Soler

All Company manuals are maintained in the Company’s network under G:\Generic\Holtec 

Corporate Manuals.

In addition to the above generic manuals, Holtec International’s operating divisions also issue 

manuals for specific projects. O&M manuals and the manufacturing manual are examples of 

such manuals, which can be found in the database that contains all Holtec reports. 

2.3 Agreements with External Organizations

The following standard agreement forms shall be used, as applicable, in entering the Company 

into a legally binding relationship with another entity and may only be signed into use by the 

Chief Financial Officer or his designee:

Agreement Purpose Access

1) Representation Agreement For engaging sales representatives G:\Generic\Holtec Corporate 

Agreements\Representation 

Agreement

2) Non-Disclosure Agreement (also 

known as Confidentiality Agreement)

Used with any company to control 

use of mutually transmitted 

information

G:\Generic\Holtec Corporate 

Agreements\Non-Disclosure 

Agreement

3) Teaming Agreement Engage in collaborative business 

efforts with peer companies

G:\Generic\Holtec Corporate 

Agreements\Teaming Agreement

4) Declaration Pursuant to 10CFR2.390 For delineating proprietary 

information to the USNRC

G:\Generic\Holtec Corporate 

Agreements\Declaration Pursuant 

to 10CFR2.390

All of the above agreement documents are maintained in the network under: G:\Generic\Holtec 

Corporate Agreements. Please contact the Corporate Administration Department for any 

questions regarding the documents.

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3.0 GUIDELINES TO COMPANY EXECUTIVES AND MANAGERS

3.1 Mandatory Guidelines

1. No one person in the Company is authorized to autonomously commit the Company to an 

Agreement of any kind: This includes Teaming, Alliance, Non Disclosure, Non-Use, 

Employment, Confidentiality, Non-Circumvention and Representation Agreements. It also 

includes Job Offer Letters, Purchase Orders, etc. Any Agreement that binds the Company to 

any corporate obligation must be initialed by the Division head (Holtec Vice President) and 

formally signed by the Chief Financial Officer or his designee. 

2. Every Agreement must have a sunset clause. For example, a Representation Agreement 

must have provision to expire automatically (as an example, if the “rep” has been inactive 

for, say, six months).

3. Placement of purchase orders must follow the process set down in this manual: A Purchase 

Order placed in violation of the Company’s written process will be deemed invalid, and 

make the issuer personally liable for any resulting damages. 

4. Issuing e-mails or other forms of written communication obliging the Company to a direct 

or implicit liability is forbidden: This includes making a promise of future work to any 

vendor or a promise made to a client for work outside of the contract’s scope. 

5. We must process a valid vendor invoice punctually. If the invoice is deficient, it should be 

returned to the sender with a completed Form F-02 (Notice of Invoice Deficiency). 

6. The “Notice of Commercial Claim” (Form F-01) must be issued and tracked if a vendor 

costs Holtec time, money or resources because of a vendor error: No exception.

7. No work shall be ordered from any associate or contractor of Holtec without a Purchase 

Order prepared and authorized as stated in this manual  no freelancing.

3.2 Management of Operations Centers and Interface with Corporate Acquisitions 

Department

Management of Operations Center

Item

Comment

1. Purchasing Activities See Note 1 

2. Recruitment, Salaries, and Termination 

of Salaried Workers

(see Note 2)

Must be approved by the Corporate Sponsor and the Executive 

Committee

3. Budget and Expenditures See Note 3

4. Performance Assessment See Note 3

5. Making Bids VP in Charge or Designee

Note 1:

Holtec's Corporate Acquisitions Department (CAD) is led by the NPD Program Manager, who is supported by the 

Supply Chain Manager, and by the Purchasing Specialists.

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A Holtec Associate must enter his/her Purchase Requisition (PR) request as a task in the Task Tracking Database 

and provide the appropriate drawings and purchasing specifications to the Purchasing Specialist so that the 

purchase order can be issued. The Associate may prepare the Purchasing Requisition in the PR Database and 

submit to the CAD directly, provided that the due diligence to select the supplier has been done, in which case 

CAD will need to concur. The PR may be submitted to the CAD directly if the procurement is for services (i.e., 

not goods).

The above guidelines apply to all Holtec Operation Centers unless specific purchasing rights are given by CAD to 

a specific organization (viz., purchase of weld wire and gas to Pittsburgh).

 

Note 2:

Follow the guidelines of the Corporate Governance Manual (CD-7) scrupulously. Handling of all personnel 

matters shall be consistent with the Employee Handbook (CD-1). Specifically, any hint of nepotism in hiring or 

promotions is inconsistent with the Company’s corporate creed. 

Note 3:

Each Operations Center Chief will provide a budget for the four following quarters listing total projected expenses 

for the Center’s billings for work directly secured (sold) by the Center. The Executive Committee and the 

Corporate Sponsor will evaluate the performance of the Center at the end of the quarter. 

The Operations Center Chief is authorized to make purchases of routine items without the Corporate Sponsor’s 

authorization, using Express Purchase Orders. For special purchases, concurrence of the Corporate Sponsor is 

required. 

The Executive Committee will evaluate the performance of the Operations Center Chief in the preceding quarter 

using four criteria:

1. Profitability or control of unnecessary expenditures, as applicable.

2. Leadership achievements (status of associate morale).

3. Productivity of the work force.

4. Prognosis for the next quarter. 

Note 4:

Each Operations Center can bid on projects in its core areas of competence. However, for a bid over $500 

thousand dollars, the bid price must be approved by the designated Quotation Sponsor. In all cases, the Terms and 

Conditions for the sale must be approved by the Corporate Sponsor. 

3.3 Notion of “Apparent Authority”

Anyone who bears the title of Vice President or Director should be aware of a legal truism 

known as “Apparent Authority” under which any commitment made by a company official may 

hold up as a corporate commitment in a court of law. 

Don’t sign or make an oral promise to anyone unless authorized in writing to do so by a 

published policy statement by the Company’s executive leadership. 

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Any manager or executive who is unclear about his or her authority with respect to a certain 

matter should get a clarification by e-mail from the Company’s CEO or his designee. 

Specifically, a Holtec manager or executive shall not sign or make an oral promise to anyone 

unless he or she has been authorized in writing to do so by a Corporate Document or by e-mail

from the CEO or the CFO. At most one can promise to recommend, but must not commit. 

Failure to observe this rule shall be treated as a reprehensible conduct. 

3.4 Canons of Management Conduct

Please bear in mind that the emotional well being of the company associates who report to you is 

heavily influenced by your posture towards them. Language that may be construed as 

threatening, retaliatory, or otherwise likely to have a chilling effect must never be used. 

Language that reflects a bias with respect to gender, race, sexual orientation, or ethnicity 

likewise must be completely absent from your vocabulary (and your hearts, if possible).

Any Holtec associate who behaves belligerently and threatens you with legal action should be 

politely informed that the Company will have no objection to such action by him/her.

In short, be kind and gentle in all your interactions with your staff.

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4.0 PROJECT MANAGEMENT, FINANCE MANAGEMENT AND HUMAN 

RESOURCES TOOLS 

4.1 Project Management Forms

A number of forms labeled PM-01 through PM-07 are used by the Company’s project managers 

to communicate information to the client in an efficient and succinct manner. Please go to

G:\Generic\Admin\Administrative Memos\Project Management Forms to retrieve the Word file 

of the form that you need. The following forms are in use as of December 2010:

Form 

I.D.

Title

01 Document Comment Resolution Form

02 Summary of Project Enhancement Initiatives Based on Client Report Card Feedback

03 Request for Contract Price Adjustment (CPA) 

04 Visitor’s Code of Conduct 

05 Site Work Delay Notice

06 Request for Immediate Action to Protect Schedule 

07 Acceptance Criteria for a Valid Request for An Equitable Adjustment of Contract 

Price

Of the above forms, PM-03, Request for Contract Price Adjustment is explained in detail in 

Chapter 7. 

4.2 The Project Management Team

All projects categorized as large in the Company’s ISO 9001 program shall have a PM and an 

APM in the Project Team. The Program Manager shall appoint the PM and the APM from the 

cadre of project management staff. 

In all cases, at least one member of the Project Team shall be Marlton-based. The composition of 

the Project Team may be adjusted by the Program Manager during a project’s life cycle as the 

project moves from engineering to manufacturing to site services. To avoid ambiguity, the 

normal activities of the Project Team shall be clearly delineated by the Program Manager 

between the PM and the APM.

The routine activities consist of:

1. Ongoing interaction with the client such as to secure input data, establish 

performance schedules, make submittals, etc.

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2. Internal interactions with HTS staff, including the design sponsor, analysts, 

designers, etc.; shepherding the “software” work at Marlton.

3. Ensure that material procurement occurs on time.

4. Ensure that the manufacturing releases are made ASAP.

5. Maintain all databases (PSD, PHD, Milestone payment database, etc.), and the 

Project Punch List; make Project Progress Report submittals.

6. Maintain the project “INT” list and ensure that all incoming and outgoing project 

correspondences are filed in the project folder without fail.

7. Ensure that all project invoicing occurs timely and approve vendor invoices 

promptly.

8. Secure increase of work scope from the client, obtain price quotes from the Sales 

department, issue CPAs and make award announcements.

The duties between the PM and APM shall be divided to take advantage of each individual’s 

talents and expertise. Proper allocation of duties is critical to smooth project management. The 

Project Management members shall be identified by an “icon” on the Company’s monitors to 

provide quick access to this information to all Company personnel. 

4.3 Meeting Minutes

All meetings of potential contractual, commercial, or technical consequence shall be documented 

in the Minutes-of-the-Meeting template provided in Exhibit 4.A. 

4.4 Financial Management Tools

The following standard forms are used by the Company for internal and external 

communications on a project by the Company’s Accounting/Finance Department, project 

managers or contract managers, as applicable. These forms reside on the network under 

G:\Generic\Admin\Administrative Memos\Accounting Forms F Series.

Form I.D. Title

F-01 Notice of Commercial Claim (NOCC)

F-02 Notice of Invoice Deficiency (NOID)

Of the above forms, Form F-01, Notice of Commercial Claim (NOCC), is explained in detail in 

Chapter 7. 

The Notice of Invoice Deficiency (NOID) form is used to document if a Supplier invoice can not 

be approved for payment. In order to approve the Supplier Invoice for payment, the Procurement 

Department personnel need to determine the completeness of the Vendor invoices and to verify 

that requirements of the Holtec Purchase Orders have been met by the Vendor before the Invoice 

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can be approved. Among other things the Procurement Department personnel check the 

following checklist items listed on the NOID:

1. The Holtec Purchase Order (PO) for the deliverable does not exist in our system.

2. A Holtec PO has been issued but has not been acknowledged by the Supplier.

3. A valid Holtec PO has not been issued or the PO has expired.

4. The invoice is premature: the Supplier has not met the delivery milestone.

5. The invoice is unsubstantiated.

6. The Business Unit’s Receiving Department has rejected the delivered item (in whole or in 

part).

7. There is an outstanding Notice of Commercial Claim against the Supplier; the invoice needs to 

be adjusted accordingly and re-issued.

8. Holtec’s Client has rejected the work product (Please contact Holtec’s Project Manager).

9. Invoice cannot be processed because of lack of information (Purchase Order #).

10. The Holtec Travel Authorization Form is missing.

11. The Holtec Supervisor’s Authorization is missing from the Expense Reimbursement Request.

If the answer to any of the questions listed above is “Yes” then Invoice is rejected and NOID 

form is issued to inform the Supplier that an NOID has been issued against their invoice and 

payment cannot be processed.

4.5 Recruitment, Retention, and Termination of Personnel – HR Forms

No company personnel shall be terminated for reasons of discrimination of any kind. The forms 

used by the Company for recruiting and terminating personnel are maintained in the Company’s 

network under: G:\Generic\Admin\Employee Manual & HR Forms-Benefits\Human Resources 

Forms. Additional information on this matter may be found by contacting the Company’s Human 

Resources Department. Each Company manager should follow the latest applicable Company 

guidelines for evaluating an employee’s performance as well as handling any 

resignation/termination of an employee.

Please see the attached table below for the applicable Human Resources forms. Please note that 

the tables and forms are updated regularly. Please visit the network at 

G:\Generic\Admin\Employee Manual & HR Forms-Benefits\Human Resources Forms for the 

latest table and forms.

Form I.D. Title

HR-0 Holtec International New Hire Checklist

HR-01 Holtec International Application for Employment

HR-02 Background Check Disclosure and Authorization for Release 

HR-03 Background Check Applicant Information 

HR-04 Holtec International Offer Letter

HR-05 Holtec International Offer Form

HR-06 Required Information for New Employee IT Setup

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Form I.D. Title

HR-07 Holtec Employee Performance Review Form

HR-08 Application for Signing Bonus

HR-09 Application for Moving Expense Coverage-Bonus

HR-10 Form W-11: Hiring Incentives to Restore Employment (HIRE) Act, Employee 

Affidavit

HR-11 Holtec International Conditions of Employment

HR-12 Holtec Standard Procedure HSP-1001: Corporate Governance 

HR-13 Form I-9, Employment Eligibility Verification

HR-14 Form W-4

HR-15 IAA Member Enrollment Form

HR-16 Sun Life and Health Insurance Company Enrollment Request

HR-17 Mutual of Omaha Enrollment Form

HR-18 Orrvilon, Inc Standard Procedure OSP-1001

HR-19 Orrvilon, Inc. Conditions of Employment

HR-20 Visitor Access and Authorization Form

HR-21 Form for Requesting and Reporting Vacation Leave, Floating Holidays or Illness

HR-22 Holtec International Security Policy

HR-23 Rosenbluth Travel Profile Form

HR-24 Holtec International Application for Education Assistance

HR-25 Holtec International Application for ADVANCE Education Assistance

HR-26 Holtec International Profit Sharing Plan (401K Plan) 

Participant Enrollment and Change Form

HR-27 Holtec International Profit Sharing Plan Beneficiary Designation Form

HR-28 Travel Authorization Form 

HR-29 Expense Reimbursement Request 

HR-30 Holtec International Employee Information Form 

HR-31 FSA Enrollment Form 2011

HR-32 Form W-9 Request for Taxpayer Identification and Certification for 1099 

Contractors

HR-33 Holtec Direct Deposit Form

HR-34 Directors Questionnaire

HR-35 Holtec Compensation Schedule 2011

HR-40 Holtec Notice of Reprehensible Conduct (NRC) Form

HR-41 Holtec Damage Report on Erroneous Work (DREW) Form

HR-42 Holtec Demerit Notice Form

HR-43 Holtec Employee Warning Letter Form

HR-44 Holtec Citation for Meritorious Work Form

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4.6 Guidelines on Internal Communications on Projects

Please observe the following rules to ensure that our standard operating procedures for internal 

communications on our projects are followed:

 1. All technical developments in the project are shared within the project team in real time. No 

one in the project team shall be kept in the dark regarding any technical matter.

 2. Concise minutes-of-the-meeting shall be prepared documenting all commitments and 

developments whenever a substantive meeting with an external entity occurs. Such meetings 

should preferably be attended by two Holtec personnel. The minutes shall be documented in 

Holtec's template.

The above rules are essential for Configuration control, which is mandated by our QA program. 

They are also needed to make our project (like a crane) Single Failure Proof: Proverbially 

speaking; no road mishap occurs if any one person falls off the turnip truck.

In short, complete internal transparency and unfettered communications are a must in all Holtec 

projects. 

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5.0 GUIDELINES ON CONFIDENTIALITY AND PROPRIETARY 

INFORMATION

5.1 Confidentiality as a Company Creed

Confidentiality at Holtec is a corporate, personal, legal, and ethical obligation. Confidentiality is 

paramount to conducting business in a professional manner. It is the policy of the Company to 

ensure that the operations, activities, and business affairs of the Company, its customers, clients 

and suppliers are kept confidential. If, during the course of your employment, you acquire 

confidential and proprietary information, for example, information regarding product ideas, 

product development, and sales techniques as it relates to the Company, its clients, customers, 

and suppliers, such information is to be held in strict confidence and should not be disclosed with 

anyone outside the Company. Holtec employees are responsible for the internal security of such 

information.

Virtually all of the Company’s contracts have a Confidentiality section that obligates the 

Company and its personnel to maintain clients’ confidential information as "confidential". Our 

clients also reciprocate by maintaining confidentiality of our confidential information.

Company employees are requested to be aware of what information is confidential and exercise 

utmost diligence and care in protecting that information. To that extent, included in this manual 

is a sample of a confidentiality clause that delineates what is confidential in our contracts. Please 

see attached Exhibit A. If any employee is uncertain about any aspect of the Company’s policy 

on confidentiality, he or she should check with his or her supervisor and with the Corporate 

Administration Department. For the latest approved version of the Confidentiality Agreement for 

protection of the Company’s confidential and proprietary information, please go to 

G:\Generic\Holtec Corporate Agreements\Non-Disclosure Agreement on the Holtec network. 

5.2 Holtec Proprietary and Confidential Information

All Holtec employees are reminded that as part of the Conditions of Employment document 

“You agree[d] that you will not, during or after your employment with Holtec, (i) disclose, in 

whole or in part, any Holtec confidential information to any person, firm, corporation, 

association or other entity for any reason or purpose whatsoever unless authorized in writing to 

do so by Holtec...”

So there is no confusion regarding what an employee’s obligation is in regard to how any 

document at Holtec should be treated, associates are advised that all Holtec-generated 

documents/information are considered to be proprietary or confidential in nature, unless 

specifically identified to the contrary. Therefore, a Holtec associate is obligated by such 

language to ensure that all Holtec-generated Information which he or she has access to or which 

he or she handles as part of his daily employment duties remain confidential and not be disclosed 

to a third party. 

All Holtec-generated Confidential Information, no matter how simple or unimportant it may 

seem, may NOT be shared or forwarded to any person who is no longer employed by Holtec.

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5.3 Handling the Confidential Information of Others

1. Scope 

Holtec has many kinds of business relationships with many companies and individuals. 

Sometimes, they will volunteer confidential information about their products of business plans to 

induce the Company to enter into a business relationship. At other times, Holtec may request 

that a third party provide confidential information to permit the Company to evaluate a potential 

business relationship with that party. Whatever the situation, Holtec expects its employees to 

observe obligations of confidentiality and non-disclosure of confidential information and trade 

secrets of others with the same diligence used to protect Holtec’s own confidential information 

and trade secrets. The Company respects the legitimate intellectual property rights of others and 

will not reproduce or use software or other technology licensed from suppliers except as 

permitted by the applicable license agreement or by law.

2. Procedure 

From time to time, the Company enters into an agreement with another company 

(“Disclosing Party” or “Provider”) which places restrictions on Holtec with respect to use or 

dissemination of certain confidential information ("Confidential Information") received from the 

Disclosing Party. The procedures for handling such Confidential Information are as follows:

a. The originally executed Confidentiality Agreement or Non-Disclosure Agreement 

shall be kept in the Agreements online files and Binders (in the custody of

Holtec’s CFO). A scanned copy of the Agreement shall be placed in the 

engineering file by the Assistant Project Manager or Project Manager. The only 

Holtec personnel authorized to enter into the Agreement are the Holtec CFO or 

his designee. 

b. The Project Manager (of the project affected by this Agreement) and the Program 

Manager shall be orally advised of the signing of the Agreement by the Holtec 

representative who is the Signer of the Agreement.

c. The Project Manager will issue an e-mail notice to all project team members 

advising them of the Agreement.

d. The Information received pursuant to the Agreement shall not be copied or 

distributed. The following personnel are designated to serve as the custodian of 

Information:

Nuclear Projects: Program Manager – NPD

Power (non-nuclear) Projects: Program Manager - PPCD

e. Any project team member who needs access to the Information will receive same 

from the designated Custodian for use purposes only. Information will not be 

photocopied unless explicitly authorized by the Custodian (in writing). The 

authorization to copy will be given by the Custodian only after the Company's 

concurrence has been received.

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f. Notice of availability of all restricted Information will be announced through the 

Project Plan, a notation in the engineering file, e-mail to the project team 

members, and/or other means as deemed appropriate by the Project Manager.

g. The Information will constitute a valid design basis for the Project. Upon 

completion of the project it will be placed in the QA records in the storage vault 

along with other quality records on that project. The Corporate QA Manager, who 

is the custodian of the Quality Records, will bear the sole responsibility to ensure 

that the confidentiality of the Information is maintained. 

If the Information is not used or not needed as part of the Design Basis, then it 

shall be returned to the Disclosing Party (in original form, without copying). The 

Project Manager shall ensure that the agreed upon terms of the Agreement are 

followed. 

3. Application 

The above procedures apply to all Holtec projects (nuclear and non-nuclear).

5.4 Standard Tombstone Text for Front Page of Holtec-Produced Documents (Reports, 

Procedures, Specifications, etc.)

The following text shall be used by all Holtec Divisions for the proprietary notice on the front 

page footer of all Holtec-produced reports, procedures, specifications, etc.:

NOTICE OF PROPRIETARY INTELLECTUAL PROPERTY STATUS

This document contains valuable intellectual property of Holtec International. Holtec’s 

rights to the ideas, methods, models, and precepts described in this document are 

protected against unauthorized use, in whole or in part, by any other party under the U.S. 

and international intellectual property laws. Unauthorized dissemination of any part of 

this document by the recipient will be deemed to constitute a willful breach of contract 

governing this project. 

The recipient of this document bears sole responsibility to honor Holtec's unabridged 

ownership rights of this document, to observe its confidentiality, and to limit use to the 

purpose for which it was delivered to the recipient.

Portions of this document are subject to copyright protection under international and U.S. 

laws.”

5.5 Footnote on All Communications Containing Commercial Information

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The Company’s commercial data should not be released to third parties. To prevent release, 

please ensure that any Holtec letter or email containing commercial information has the 

following footnote:

This communication contains confidential business/commercial information whose 

dissemination to third parties will have an adverse impact on Holtec International’s 

business interests. Accordingly, the Company requests that the recipient prevent its 

release to any third party or to the general public. The recipient must not disclose or 

distribute this material outside his/her company without the express written permission of 

Holtec International.

5.6 Personnel Empowered to Execute Affidavits Pursuant to 10CFR 2.390(b) and 

10CFR 72.48

In accordance with the requirements of 10 CFR 2.390(b)(1)(ii), the following delegations are 

made:

On behalf of Holtec International, the personnel in the positions listed below are authorized to 

review information sought to be withheld from public disclosure by the Nuclear Regulatory 

Commission (NRC) and execute affidavits applicable to such information. Any individual 

performing these functions must be familiar with the content of the documents to the extent that 

they are able to identify Holtec-proprietary information, as defined in 10 CFR 2.390.

 Any Company Vice President

 Program Managers 

 Licensing Manager

 Site Services and Operations Manager

 A Discipline Technical Head (member of the TechHeads Group)

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6.0 MANAGEMENT OF BANK ACCOUNTS, TRANSFER OF FUNDS AND

PETTY CASH FOR REMOTE OPERATIONS CENTERS 

 All Company bank accounts are opened and managed by the CFO and the 

Accounting/Finance Department

o All Company Division bank statements should be scanned and emailed to the 

Accounting/Finance Department in Marlton, NJ immediately following their 

receipt from the local office 

 No one person in the Company has the authority to transfer funds without the written 

authority of the CEO or CFO

 Petty cash may be kept on hand at Company locations in an amount no greater than 

$500.00 at any time 

o All petty cash withdrawals must be documented and approved by the 

Accounting/Finance Department, which performs a monthly reconciliation of the 

petty cash account 

 All bi-weekly and other Payroll transactions for all Company Divisions must be preapproved by the Holtec CFO or his designee 

 All salary increase or bonus proposals for any Company employee must be approved by 

the CFO in writing

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7.0 REQUESTS FOR CONTRACT PRICE ADJUSTMENT (CPA) AND COST 

FORMS FOR PRICING PROJECTS 

7.1 Contract Price Adjustment (CPA)

All proposals for any additional work on existing projects that arise from conditions described in 

the table below MUST be entered into the Paradox CPA Log database, and the status of each 

entry MUST be updated as clients make decisions on those proposals. The database contains a 

link to the CPA form, created in MS Word, which shall be filled out and electronically submitted 

to the clients. In certain cases, when the CPA form is not sufficient, the preparer may use an 

attachment with the CPA form.

1. Existing option in the Project exercised by the client for which there is no price or 

schedule established in the contract. 

2. Expansion or reduction of work scope initiated by the client (e.g., Client would like to 

purchase a Mating Device).

3. Erroneous or incomplete specification provided by the client; (i.e., causes additional 

work by redoing design/analysis work).

4. Project schedule extended (escalation due to activity deferment).

5. Schedule of Performance compressed (premium labor rate).

6. Work disruption or delay by the Client (due to failure to provide input data on time; 

failure to provide timely release; underutilization of the Company’s resources, etc.).

7. Enhancement in the goods and services proposed by Holtec (e.g., upgrading of a 

commercial grade equipment to a NUREG-0612 compliant equipment). 

7.2 Cost Forms

Cost Forms are Holtec’s Company Confidential commercial information: They are saved in the 

directory: N:\Users\NMORELAN\COST FORMS PDF on the Company’s network. The Cost 

Forms are accessible to only a limited group of the Company associates.

This section is intended to provide directives to the Company personnel engaged in preparing 

cost estimates and proposals on dry and wet storage projects including EPC (Engineering, 

Procurement and Construction) projects. 

7.2.1 Applicable Cost Forms

Cost forms are Holtec’s principal tool for preparing cost estimates. The table below provides the 

list of the Holtec Cost Forms currently in use by the Company:

Listing of Cost Forms

Form I.D. Title

CF.1 Standard T&M Rates for Engineering Services on Major Company Projects

CF.2 Legal & Miscellaneous Consulting Fee Schedule

CF.3 Personnel Service Rates for Wet Storage Site Construction Services

CF.4 Computer Code Utilization Cost Schedule

CF.5 Equipment Lease Rates for Wet Storage Site Services

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Listing of Cost Forms

Form I.D. Title

CF.6 Unassigned

CF.7 Unassigned

CF.8 Personnel Service Rates for Dry Storage Site Construction Services

CF.9 Schedule of Storage Costs for Holtec’s Dry Storage System Components

CF.10 Standard T&M Rates for Non-Technical Positions

CF.11 Standard T&M Rates for Engineering Services on Major Company Projects –

Holtec Ukraine

CF.12 Unassigned

CF.13 Unassigned

CF.14 Unassigned

CF.15 Unassigned

CF.16 Unassigned

CF.17 Unassigned

CF.18 Unassigned

CF.19 Unassigned

CF.20 Project Cost Estimation Template for the Nuclear Power Division

CF.21 Project Cost Estimate Rates and Factors for Bids by the Holtec Manufacturing

Division

CF.22 Project Cost Estimation Template for the Power Plant Components Division

CF.23 Method to Compute the Cost of Involuntary Suspension of Work at HMD 

CF.24 Computation of Cost and Schedule Impact for Build-to-Print HMD Projects

CF.25 Request for Contract Price Adjustment (CPA)

7.2.2 Consistency and Transparency in Pricing Nuclear Projects

The Cost Forms provide a standard and transparent means to compute the selling price: They 

must remain the same for every Holtec client. Holtec is obliged to provide consistent pricing to 

all of its spent fuel (dry and wet) storage clients because of certain unique features of our dry and 

wet storage product lines. The notes below explain the special circumstances and the need for a 

faithful adherence to the Cost Forms by our estimating staff.

a. To successfully recover their outlays from the Waste Fund, the utilities must show that 

they have been prudent in their contract negotiations and have not overpaid in relation to 

their peers. This has led to the so-called “Most Favored Client” or “Most Favored 

Nations Pricing” clauses that are embedded in our contracts with many of them. We 

cannot violate these contract terms and the adherence to the Cost Forms will prevent 

inadvertent non-compliance with these contracts through standard pricing across the 

utility customer base. 

b. Because several of our patents give us exclusivity in certain areas, many of our contracts 

are established by sole source negotiation. To ensure that no client feels that Holtec is 

unfairly leveraging its intellectual property to secure unreasonable profits, it is necessary 

that the Cost Forms be applied uniformly in all project estimates, regardless of our 

competitive situation. In competitively bid projects, the division’s executive-in-charge 

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(Senior Vice President) has the freedom to raise the projected profit factor at his/her 

discretion.

c. The rates and factors in the Cost Forms are based on input from our accounting 

consultants and reflect our ongoing operating experience. Use of the cost factors ensures 

predictable operating margins, which are an essential component of our financial profile 

to our external auditors, banks and insurance companies who provide vital financial 

support to us (Letters of Credit, performance bonds, credit line, etc.).

We represent to our financial partners (banks and insurers) that our Cost Forms are not 

subject to opportunistic discounting by our sales personnel that may erode our future 

operating margins. Therefore, no Company personnel are allowed to lower any of the 

rates or factors without CEO or CFO approval.

d. The Cost Forms are intended to cover the whole gamut of circumstances that our 

estimators may encounter. However, if an estimator finds the guidance in a Cost Form on 

a particular item or scenario to be confusing or inadequate, then please contact the 

Accounting/Finance Department: a response will be provided immediately and the Cost 

Form in question will be appropriately clarified and, if necessary, the revision to the Cost 

Form will be issued without delay.

e. There will be no additional intra-company markup (overhead factors) applied to the sale 

price of any goods or service delivered by one Holtec division to another except for hard 

goods delivered to HMD. HMD will levy a 5% handling fee (procurement overhead) to 

such items.

7.3 Notice of Commercial Claim

The Notice of Commercial Claim (NOCC) is submitted to a vendor due to failure to meet the 

requirements of a purchase order of either Holtec International (Holtec) or a Company’s division 

such as Holtec Manufacturing Division (HMD). Any work that Holtec subcontracts to an outside 

vendor that is received back from the vendor with non-conforming conditions is costly to Holtec.

Issuance of Notice 

In order to capture all additional costs that are incurred by HMD and other divisions due to these 

vendor errors, a Notice of Commercial Claim against the vendor must be filled out for each 

vendor-created CR or NCR. The following process (using HMD as an example) MUST be 

followed for ALL vendors. Ultimately, the Product Line Manager (PLM) and Commercial 

Claims Manager are responsible to make sure this process is followed:

1. As soon as the item is received and receipt inspected, any discrepancies that are found must 

be documented by PLM on a CR/NCR form

2. The PLM sends a note with the form to the HMD Commercial Claims Manager, the HMD 

Supply Chain Manager for cost tracking purposes, and to HMD Administration to be placed 

on the HMD Weekly NCR report. HMD Administration will place the PLM’s name next to 

the NCR on the report in bold.

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 Note that the QC Department will also need to have a cumulative overview of repeat 

offenders, as they may want to schedule on-site visits or program development efforts 

to bring them up-to-standard.

3. As soon as a copy of the Vendor-caused CR/NCR is received by the Commercial Claims 

Manager, a formal Notice of Commercial Claim against the vendor MUST be filled out by 

the Commercial Claims Manager and issued to the Vendor.

4. A copy of the Notice of Commercial Claim shall be sent to all Holtec Accounts Payable 

departments, Purchasing departments at Corporate and HMD, and to the Holtec Corporate 

Financial Manager, so that any payment of the employed vendor invoice can be put on hold 

until the issue is resolved and future use of and relationship with the vendor may be 

determined.

5. Even if the full HMD costs are not known when the Notice of Commercial Claim is issued to 

the vendor, it can be issued with a clearly noted **Estimated Cost** using the cost forms 

until all of the final employee costs are gathered and cost forms are used.

6. The Commercial Claims Manager should use the cost forms to calculate the final employee

costs as follows: 

 Form CF.24 should be used for calculations.

 Form CF.1 should be referenced for Part A in CF.24.

 Form CF.21 should be used for Part B in CF.24.

 Form CF.1 should be referenced for Part C in CF.24.

 Note: If there is stoppage of work, then Part D of CF.24 should be used.

 Note: If there is suspension of another project because of the vendor error relating to 

this project, form CF.23 should also be used.

7. Once the Commercial Claims Manager calculates the final HMD costs to repair the deviation 

the final cost shall be added to the Notice of Commercial Claim and sent to the vendor with a 

copy to the Nuclear or Code Operations Manager, Corporate Financial Manager, and Supply 

Chain Manager.

8. The Supply Chain Manager in conjunction with the Commercial Claims Manager shall 

negotiate the final settlement with the vendor and submit to Corporate Financial Manager for 

approval 

9. Once a settlement with the vendor has been reached the Commercial Claims Manager and 

Supply Chain Manager shall notify the Holtec Accounts Payable Department and Purchasing 

Department of the settlement amount and release the vendor payment per the agreement 

Completion of the Notice of Commercial Claim Form 

Completion of the Notice of Commercial Claim Form requires insertion of information available 

to the PLM from the Purchase Order for the material in question. Any information not contained 

therein is easily obtained from document copies or computer records.

Please consult the Notice of Commercial Claim form below while reviewing the steps required in 

completing the form.

To prepare the NOCC, enter the following in the space provided.

A. Vendor Number

B. Vendor Name

C. Holtec or HMD P.O. Number

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D. Holtec or HMD PR# (when applicable)

E. Claim Number

F. Date Issued

G. Holtec or HMD P.O./PR Item #

H. Amount of Claim

I. Claim Category

J. Holtec or HMD NCR#

K. Summary of Claim

L. Settlement Option

M. Summary of Settlement

N. Issued By

O. E-Mail Address

Definitions

Item D. Holtec or HMD PR# (when applicable)

 Purchase Requisition Number from Purchase Requisition Form

Item E. Claim Number

 This is a combination of the Vendor Number and the NCR Number

Item G. Holtec or HMD P.O./PR Item #

Number of item from P.O./Purchase Requisition Form used if more than one item is 

purchased from a particular vendor

Item H. Amount of Claim

Total value of internal costs incurred as a result of the Vendor Non-Conformance. This 

amount can be waived if this is the first deficiency in a twelve month period and only if 

approved by all (Supply Chain Manager, Code or Nuclear Operations Manager and 

Corporate Financial Manager), as shown under SETTLEMENT OPTIONS Item A on 

the NOCC form.

Item K. Summary of Claim

 Brief explanation of the cause of the claim.

Item L. Settlement Option

If the Notice of Commercial Claim is the first in a twelve (12) month Period, Settlement 

Option “A” may be entered only if approved by all (Supply Chain Manager, Code or 

Nuclear Operations Manager and Corporate Financial Manager). If so, Item “H” on the 

NOCC should remain blank.

If the Notice of Commercial Claim is for a second or subsequent non-conformance or is 

not approved by all parties listed in Item L, enter Settlement Option “B”. An amount 

should be entered in Item “H” on the NOCC for the internal costs incurred due to the 

non-conformance.

Item M. Summary of Settlement

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Brief description of the agreement between Holtec/HMD and the vendor regarding how 

the vendor will correct the present non-conformance. The Vendor should be made aware 

if this is the first NOCC during a twelve (12) month period and claim is subsequently 

approved to be waived, a subsequent occurrence will result in a claim amount being 

assessed for the amount of the internal costs of Holtec/HMD.

Log of Notices 

A log of all NOCC’s will be kept and updated as they are received. At this time, the HMD 

Commercial Claims Manager will be responsible updating the log and making same available to 

the HMD Weekly Report. A copy of the log form is attached below. The file will be saved and 

available for review in:

DRIVE: Q:\Generic\NOCCs and NOCSI\NCR Reports

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8.0 GUIDELINES ON INTER-DIVISIONAL RELATIONSHIPS

8.1 Financial Accountability for Errors by Business Units

In the Company’s cost accounting system, Holtec Manufacturing Division (HMD) must receive

a credit for each Engineering Change Order (ECO) issued by the Nuclear Power Division (NPD) 

or PPCD to correct a drawing error; this credit must show up as an IPR to reflect the increase in 

the money paid to HMD for the affected component. All ECOs are not drawing errors; some are 

issued to help fabrication – no credit is given to any Division for ECOs issued to improve our 

operations. It is expected of NPD and PPCD to improve fabricability on an ongoing basis. In 

some cases, drawing errors can be corrected without requiring an ECO. In those cases also, IPRs 

must be revised to reflect increase in money paid to HMD for additional work created due to the 

drawing errors.

All HMD-caused NCRs are backcharged to HMD for each occurrence by deducting the money 

from HMD’s receivable.

Note that this internal accounting helps the Company to quantify the loss of revenue due to errors

by each division and thus help to identify financial rewards/penalties down to the individual 

level. 

Finally, all vendor-caused NCRs will immediately trigger a Notice of Commercial Claims 

(NOCC) backcharge to the vendor; the amount shall be established by HMD, PPCD, or NPD 

management, as applicable, based on the number of manhours of production and QA resources 

lost due to the NCR. The revenue loss/gain to HMD will appear in the weekly report next to the 

NCR. Please refer to Chapter 7 for details on NOCC process.

The Cost Forms issued by the Corporate Accounting/Finance Department contain the financial 

charges applied for the error by a business unit. 

8.2 Notice of Cost Impact and Schedule Impact to HMD

An HMD PLM is expected to issue the attached notice (Exhibit 8.A) to its client (NPD or PPCD) 

to inform them of the emerging risk to the manufacturing schedule (and hence, extra charges 

payable to HMD) because of the client’s action or inaction. 

If the client (NPD or PPCD) is unable to correct the cause of the schedule impact (and hence, 

avoid the extra charge), then HMD’s Controller will reissue the same form at a later date with 

compiled charges. 

NPD’s PMs and APMs are expected to take the necessary steps so the ultimate client is informed 

of the cost and schedule impact. If an impact occurs, NPD will owe monies to HMD and NPD is 

expected to collect the funds (with NPD’s markup) from the ultimate client, as applicable.

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8.3 HMD Projects Corporate Allocations

For HMD-based (manufacturing) projects, the following functions will be performed by Holtec 

Corporate: Purchasing, QA, Accounting, and Marketing and Sales support. Project Management, 

Estimating, Corporate, QC, and Manufacturing will be performed by HMD. Project Management 

for HMD projects will be consistent with all Holtec Divisions. 

HMD will issue IPRs to other Holtec Divisions for support such as design, engineering, 

component manufacturing, etc.

The Purchasing OH and Corporate G&A will be deducted by the accounting department from 

HMD’s receivables. The Project will stay with HMD.

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9.0 PROTOCOL FOR PROCESSING PROCUREMENTS AND PAYABLES

9.1 Guidelines 

1. No one individual in the Company is authorized to autonomously commit the Company to 

an Agreement of any kind: This includes Teaming, Alliance, Non Disclosure-Non-Use, 

Employment, Offer Letters, Non-Compete, Confidentiality, Non-Circumvention, Purchase 

Orders and Representation Agreements. Any Agreement that binds the Company to any 

corporate obligation must be initialed by the Division head (Holtec Vice President) and 

formally signed by the Chief Financial Officer (CFO).

2. Every Agreement must have a sunset clause. For example, a Representation Agreement 

must have provision to expire automatically (as an example, if the “rep” has been inactive 

for, say, six months).

3. Placement of purchase orders must follow the process set down in this section. A Purchase 

Order (P.O.) placed in violation of the Company’s written process will be deemed invalid.

4. Issuing e-mails or other forms of written communication obliging the Company to a direct 

or implicit liability is forbidden and will be deemed invalid by the Company: This includes 

making a promise of future work to any vendor or a promise to a client for work scope 

outside of a contract.

5. A valid vendor invoice must be processed punctually. If the invoice is deficient, return it to 

the sender with Form F-02 (Notice of Invoice Deficiency) filled out. 

6. The “Notice of Commercial Claim” (Form F-01) must be issued and tracked if a vendor 

costs the Company money because of his/her error: There are NO exceptions.

7. No work shall be ordered by any associate or contractor of Holtec without a purchase order 

authorized as stated in this section. Freelancing is not permitted. 

8. Placement of Purchase Orders must follow the approval process in this section. A Purchase 

Order placed in violation of the Company’s written process will be deemed invalid and the 

invoice will be returned to the vendor.

9. No work shall be ordered without a Holtec Purchase Order or Express Purchase Order form.

Issuing e-mails or other forms of written communication obliging the Company to a direct 

or implicit liability is forbidden: This includes making a promise of future work to any 

vendor.

10. For Purchase Orders or Express Purchase Orders under $2,500, the Holtec division or 

purchasing group shall create and process a Purchase Order that is signed, dated, and 

approved by the respective Business Unit Manager or Supply Chain Director.

11. For all Orrvilon, Nanotec, and PPCD-Air-Cooled purchases, if the Purchase Order is $2,500 

or greater, the Purchase Order shall be signed (endorsed) and dated by the Business Unit 

Manager and sent to the Holtec Chief Financial Officer for approval.

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12. For HMD manufacturing equipment purchases that are $5,000 or greater, Purchase Orders 

shall be signed (endorsed) and dated by the Business Unit Manager and Corporate Sponsor 

and then sent to the Holtec Chief Financial Officer for approval. 

13. For NPD, PPCD, HMD and HTS services and subcontracting procurement, if the Purchase 

Order is $2,500 or greater, the Purchase Order shall be signed (endorsed) and dated by the 

Business Unit Manager and sent to the Holtec Supply Chain Director for approval. On 

Purchase Orders that are $50,000 or greater, the Purchase Order shall also be approved 

(signed and dated) by the Holtec Chief Financial Officer.

14. For NPD, PPCD, HMD and HTS materials procurement, if the Purchase Order is $2,500 or 

greater, the Purchase Order shall be signed (endorsed) and dated by the Business Unit 

Manager and sent to the Holtec Supply Chain Director for approval. On Purchase Orders 

that are $250,000 or greater, the Purchase Order shall also be approved (signed and dated) 

by the Holtec Chief Financial Officer.

15. Each Purchase Order or Express Purchase Order must have the most recent version of the 

Holtec General Terms and Conditions attached to it.

16. All Purchase Orders must be acknowledged (signed) by the vendor or the unacknowledged 

Purchase Order will be deemed invalid and the invoice will be returned to the vendor.

9.2 Operational Guidelines to Purchasing Personnel

The following process must be followed in all procurements except for Express P.O.’s:

 At least three bids must be secured using a reviewed and approved purchasing 

specification.

 Accept a supplier-specific specification (Weldox, Hillman rollers, etc.) only if approved 

by the Director of Corporate Supply Chain.

 Attach the bidding data and your recommendation to the P.O. file for review by the PM 

and others. Include a comparison with past orders for identical items in the 

documentation. 

 On every P.O., the signature blocks shall contain Preparer, Reviewer, PM, and (if 

necessary) QA signatures.

 One person shall not sign in a dual capacity (such as Reviewer and PM) in the signature 

blocks under any circumstances.

 Every signatory to the P.O. document(s) is individually accountable for its correctness. 

 As specified in the Corporate Governance and Ethics Manual (CD-7), no Company 

employee or contractor shall socialize with or accept gratuities from vendors. 

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Purchasing is a serious activity that calls for attention to detail. Carelessness in procurement 

can lead to a severe loss to the Company. 

9.3 Inter-Division Purchase Requisition (IPR)

Purpose

A database called the Inter-Division Purchase Requisition (IPR) shall be used for all commercial 

transactions amongst Holtec divisions/operations centers. The IPR is used by a Holtec operating 

division to contract/authorize work to another Holtec operating division. 

IPR Database 

The IPR database assigns the IPR number sequentially under the project number. It contains 

information on the type of requisition, name of Holtec Division issuing the IPR, name of Holtec 

Division to which IPR is being issued to, Description of Work, Total Value of the authorized 

Work, Value ascribed to R&D, and Type of Manufacturing Authorization, if applicable, etc.

The IPR utilizes Manufacturing Authorization (MA) form as an attachment. In the IPR database, 

when the Type of Requisition is selected by the user as “Manufacturing Authorization” and the 

user clicks on the Pushbutton Labeled “Create MA file” the database generates a blank MA file 

in MS Word using the information provided in the “Type of Manufacturing Authorization” field. 

The database creates a link to the word file, which one can double click to access the MA file. 

Creating IPR

1. Go to the main Holtec Database Group Screen and click on the button labeled “IPR” 

located in the Purchasing/Manufacturing Group of databases.

2. The IPR form database will open. It has a pushbutton near the top of the screen labeled 

“Create IPR”. Click on it.

3. Enter the Project Number. The database will ask for your confirmation if you want to 

proceed. Click Yes.

4. Fill out all database fields except the field “Type of Manufacturing” as it is optional and 

applies only when you are issuing an IPR to authorize manufacturing. Also, you may 

leave the R&D Value field blank to be filled out later. 

5. Click on the MA file link, if applicable and fill out the word MA file. Save it in word.

6. Perform an electronic sign-off by the Author, Reviewer and the PM.

7. Print both the IPR form and the Word MA file (if applicable) into pdf and save the 

compiled file in the N:\0-PO-IPR-MA\ directory.

Revising IPR

1. Go to the main Holtec Database Group Screen and click on the button labeled “IPR” 

located in the Purchasing/Manufacturing Group of databases.

2. The IPR form database will open. Click on the pushbutton labeled “View Existing IPR”. 

Enter the Project number and IPR Number to pull up the IPR you are revising.

3. Click on the pushbutton labeled “Revise IPR”. The database will clear out the electronic 

signatures and increase the revision number by 1.

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4. Follow steps 4-7 described above.

9.4 Accounts Payable Process

1. The Accounting/Finance Department requires an original invoice from all vendors to 

make a payment. 

2. The original invoice is received by the Accounting/Finance Department, Payables 

Group.

3. The invoice is stamped and dated by the Payables Group.

4. The invoice is copied and the copy is kept by the Payables Group.

5. The original invoice is given to the Purchasing Department.

6. Invoices shall be entered into Vantage as received by the Purchasing Department.

7. All vendor invoices shall be matched to an Acknowledged PO by the Purchasing 

Department.

8. Invoices will be reviewed for completeness and fulfillment of the Purchase Order 

requirements by the Purchasing Department personnel using the Notice of Invoice 

Deficiency (NOID) process described in Chapter 4. 

9. If everything is in order then Invoice will be sent to Project Managers (PMs) for 

approval; otherwise an NOID will be issued providing reasons for rejection of the 

invoices.

10. Project Managers shall determine if invoice is correct and billable to a Holtec project.

11. After five (5) Business Days the invoice shall be approved or rejected by the PMs. 

a. If the invoice is approved it shall be returned to the Supply Chain Director for 

final approval and then to the Payables Group for processing payment. 

12. Purchasing and Accounting/Finance Departments shall sweep the vendor list on the 

Received but Not Invoiced report as part of the monthly accounting reconciliation 

process.

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10.0 TRAVEL AND ENTERTAINMENT EXPENSE POLICY

10.1 Purpose 

The Holtec International Travel and Entertainment Expense Policy establishes guidelines for 

associates incurring business travel and entertainment expenses on the Company’s behalf. 

The policy applies to all associates of Holtec and all divisions and subsidiaries thereof. 

The Travel Policy objectives are:

- To ensure that all associates have a clear and consistent understanding of policies for 

business travel and entertainment.

- To provide associates with a reasonable level of service and comfort at the lowest 

possible cost.

- To maximize Holtec’s ability to negotiate discounted rates with preferred suppliers and 

reduce travel expenses.

10.2 Application 

This Policy applies to all Holtec associates who travel, entertain, or incur expenses on behalf 

of Holtec in the conduct of approved Holtec business. Consultants, independent contractors,

and other non-company associates are not allowed to use Holtec credit accounts or insurance 

policies and are not covered under this travel policy. 

The specific policies and responsibilities set forth below shall apply to Holtec travel 

worldwide. Expatriates or Holtec associates temporarily or permanently residing in another 

country will be covered under other specific policies to their assignment. Associates should 

take advantage of conference calls and/or video conferencing facilities provided by the 

Holtec IT Department, and travel only when absolutely necessary.

This policy should be used in conjunction and conformance with the Holtec Governance 

Manual (CD-07) as well as any other applicable Holtec documents.

 

10.3 Responsibilities 

The associate is responsible for complying with all travel guidelines and procedures. Holtec 

will reimburse associates for all reasonable and necessary expenses while traveling on 

authorized Company business. Holtec assumes no obligation to reimburse associates for 

expenses that are not in compliance with this Policy. Associates are responsible for canceling 

any reservations through the authorized Travel Counselor as early as possible when 

cancellation is necessary. 

Holtec uses a Travel Counselor for the booking of travel for its associates. Holtec associates 

should utilize the Travel Counselor service for their airfare, rail, car rental and hotels. Sites 

such as orbitz.com, expedia.com or hotwire.com should be used to view the best fares as a 

comparison to the Travel Counselor rates. If the websites have lower rates, associates should 

first ask the Travel Counselor to match the pricing from any of these sites by providing the 

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information from the websites to the Travel Counselor. If the Travel Counselor is still not 

within a reasonable dollar amount of the websites’ rates, then the websites may be used by 

the associate for business travel. 

Management and Supervisors are also responsible for ensuring that associates who travel are 

aware of this Policy and comply with it; approving only necessary travel; managing travel 

and entertainment within a budget; and reviewing Expense Reimbursement Requests in detail 

for compliance.

The associate will be responsible for obtaining approval of a higher rate and providing an 

explanation of that rate on their Expense Reimbursement Request. When an associate does 

not book the lowest airfare, hotel, or car rental rate offered, the Travel Counselor will note 

the policy exception and it will be included in periodic exception reports provided to Holtec 

management. The Accounting Department may ask for further information from the associate 

after review of the Travel Counselor exception reports. 

The Accounting Department is responsible for reviewing and processing Expense 

Reimbursement Requests and questioning and seeking justification for expenses, especially 

those that do not comply with this Policy, and for withholding reimbursement for expenses 

that do not comply with Company policies.

The Chief Financial Officer (CFO) has overall responsibility for the development and 

maintenance of this Policy. Policy questions may be directed to the CFO. Reimbursement 

practice questions should be directed to the Accounting Department. 

10.4 General Travel Guidelines 

1. Travel should be consistent with the needs of Holtec and should be used to 

accomplish business objectives in a cost efficient manner. 

2. It is Holtec’s policy to reimburse associates for all necessary and reasonable 

expenses incurred while traveling on authorized Company business.

3. All travel expenses must be properly documented, approved, and submitted on an 

Expense Reimbursement Request in a timely fashion.

4. Managers/Supervisors have the responsibility to use good business judgment in 

approving expenses.

5. Holtec realizes that from time to time exceptions to these policies will arise. 

Approval for exceptions will be handled on a case-by-case basis. Any situations 

or exceptions outside of those explained in this section must have pre-approval by 

the CFO.

6. Advances for business travel will be handled on a case-by-case basis. Travel 

advances will NOT be issued to:

a. Associates with outstanding Expense Reimbursement Requests over 30 days.

b. Associates who are delinquent on their bi-weekly reports or timesheets.

c. Associates who have a Company credit card (cash advances of up to $500 

may be made for foreign currency conversions).

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d. Associates who choose to use their personal credit card for business travel 

(airfare, rail fare and car rental) expenses in lieu of a Company card on file at 

the Travel Counselor.

7. In general, personal expenses are not reimbursable, and are assumed to include 

any expenses which are not a necessary consequence of travel on behalf of the 

business purpose. If the Travel and Entertainment Expense Policy is not adhered 

to, expenses will not be reimbursed. 

10.5 Travel and Entertainment Guidelines 

1. Travel Authorization Form – Associates are to receive written authorization from 

both a direct supervisor and the Corporate Accountant by turning in the Travel 

Authorization Form (Appendix 1) for signature prior to making reservations for any 

(a) air/rail travel, (b) ground travel over 200 miles or (c) hotel stays. The Travel 

Authorization Form should have the associate’s proposed travel itinerary attached to 

it when it is routed to the direct supervisor and Corporate Accountant for signature. 

After approval, this form should be e-mailed or faxed to the Travel Counselor so that 

travel arrangements can be finalized.

2. Reservation Procedures – All associates’ air/rail travel reservations, hotels, and car 

rentals including en route changes, must be booked through the appropriate Travel 

Counselor. Holtec has arranged for the Travel Counselor to provide travel services to 

Holtec’s on regular work days. Reservations are not to be made directly through the 

airlines/rail providers or any other travel agencies. Lodging and car rentals should 

also be booked through the Travel Counselor. 

3. Advance Planning – Significant cost savings can be realized by making reservations 

at least two (2) weeks in advance of travel departure. Associates are requested to take 

advantage of these discounts by planning travel and making reservations as early as 

possible.

4. Group and Meeting Travel – Holtec may occasionally sponsor group meetings or 

special events that entail special travel arrangements and expense guidelines. All 

Holtec-sponsored group meetings or special events require prior written approval by 

the CFO. When this occurs, an associate will be designated to coordinate and 

disseminate travel guidelines that are to be pre-approved by the CFO. Associates are 

to comply with the guidelines for these occasions.

Additionally, Holtec may have several staff members traveling to a common 

destination for a common purpose. Often a group qualifies for significant cost savings 

for a portion of the activity or meeting. When an associate recognizes this situation, 

he or she should notify the Corporate Accountant and Travel Counselor so that cost 

savings opportunities can be considered, implemented, and universally applied.

5. Travel Profiles – When a new associate is hired or prior to their first companyrelated travel, the associate should fill out a Travel Profile for the Accounting Group 

and Travel Counselor so that hotel, rental car, and airline preferences will be readily 

available for subsequent trip planning. Also, any associate who expects to travel at 

least once per year should submit a completed Travel Profile form to the Travel 

Counselor to ensure that pertinent details and preferences are adhered to in the 

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reservation process. This will include the associate’s credit card number (if associate

is requesting his or her credit card be used), office address, office phone number, 

home address, home phone number, medical restrictions, special meal requirements, 

seat preferences and passport information. The associate is responsible for informing 

the Travel Counselor of all personal travel information changes.

6. Use of Video/Teleconferencing – Associates should first consider if a telephone 

conference call or video conference can satisfy the objectives of an off-site meeting 

prior to making travel arrangements. If more information is needed regarding Holtec 

video/teleconference services, please contact the Holtec IT Department.

7. Spouse/Companion – Associates who plan on taking a spouse or other companion 

along on a business trip should get written approval from the direct manager prior to 

making reservations. Holtec will not reimburse any travel and entertainment expenses 

incurred by a spouse or other individuals accompanying an associate on business 

unless there is a legitimate business purpose that is approved in writing by the direct 

supervisor and the Corporate Accountant prior to the travel.

Holtec’s Travel Counselor may be used for all reservations involving a travel 

companion. All spouse/companion airline tickets and hotel reservations should be 

charged on the associate’s credit card. If any personal charges from the 

spouse/companion are accidently invoiced directly to Holtec (such as airfare), the 

personal charges will be deducted from the associate’s next payroll check or Expense 

Reimbursement Request. Any expenses submitted by the associate related to the 

spouse/companion or charges on the Company credit card related to the 

spouse/companion must be shown as a “personal expense” on the Expense 

Reimbursement Request by the associate. If the charges are in excess of the 

associate’s payroll check, the associate is required to the pay the balance upon his or 

her return trip.

10.6 Air Travel 

Making Airline Reservations – All travel arrangements must be pre-approved by Holtec’s 

Corporate Accountant prior to scheduling any bookings. The Travel Counselor will not authorize 

or confirm airline flights without a signed travel authorization form. Accounting has been 

instructed to return all Expense Reimbursement Requests if a proper Travel Authorization form 

and travel itinerary are not approved and attached to any associate’s submitted Expense 

Reimbursement Request.

Associate should always book airfare as early as possible (minimum of two (2) weeks in 

advance) to obtain the best rate. The associate is asked to provide reason of travel on the Travel 

Authorization form as well as an explanation on why the travel is not booked two (2) weeks in 

advance. In the event that the associate has been made aware of necessary travel well in advance 

(in excess of two (2) weeks) and does not book the flight in excess of the seven (7) day window, 

the associate will be liable for the differential in price.

Holtec associates should utilize the Travel Counselor service for their airfare. Sites such as 

orbitz.com, expedia.com or hotwire.com should be used to view the best fares as a comparison to 

the Travel Counselor rates. If the websites have lower rates, associates should first ask the Travel 

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Counselor to match the pricing from any of these sites by providing the information from the 

websites to the Travel Counselor. If the Travel Counselor is still not within a reasonable dollar 

amount of the websites’ rates, then the websites may be used by the associate for business travel. 

1. Airline Class of Service 

a. All Domestic air travel must be in Coach Class. Associates are expected to use 

the lowest practical airfare available.

b. The standard class for International travel is Coach. Associates are expected to 

use the lowest practical airfare available. In exceptional situations, Holtec 

Executive Committee members may request Business Class travel in writing 

for legitimate business purposes (i.e., exceptionally tight business schedules 

with little or no time for rest; requirement to travel with executives from other 

companies; etc.). In these cases, the written request must be approved in 

writing by the CFO and attached to the Travel Authorization Form and later 

the Expense Reimbursement Request when submitted to Accounting.

c. If special circumstances necessitate that a higher class of travel be taken (i.e., 

associates with special disabilities; or when Coach is completely sold out and 

no alternate flights are available to meet the business purpose), associates 

must seek business unit VP and CFO approval in writing prior to make final 

reservations.

2. Upgrades for Airline Class of Service – Air travel class upgrades at the expense of 

Holtec are NOT permitted. Upgrades are allowed at the associate’s personal expense, 

including use of personal frequent flyer benefits. Upgrades may not be charged on the 

Holtec credit card. Higher classes of Coach airline seats that are chosen by associates

for the benefit of upgrades are not permitted per sections 1a and 1b listed above.

3. Lowest Airfare Definition – Holtec appreciates the value of convenience for its 

associates who travel. However, significant savings opportunities can sometimes be 

realized by taking advantage of alternative flights. Associates are expected to use the 

lowest practical airfare determined by the Travel Counselor based on the following 

parameters:

a. Routing results in a savings of $100 or more.

b. Routing requires no more than one additional interim stop each way.

c. Routing does NOT increase the one-way total elapsed trip time by 1.5 hours.

d. Arrival time will ensure accomplishment of specific business trip objectives.

Often, fares involving a Saturday-night stay can result in significant savings, even 

with the added cost of lodging and meals. Although associates are not required to take 

advantage of these types of low fares, they are encouraged to book these flights when 

an overall decrease in travel expenses will be realized and easily shown in backup 

documentation submitted for reimbursement.

4. Airline Frequent Flyer Programs – Traveling associates may retain frequent flyer 

program benefits as long as the associate pays for the cost of any program fees. 

However, participation in these programs must not influence flight selection that 

would result in incremental cost to Holtec beyond the lowest available airfare, as 

defined in this Policy.

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5. Associates Flying Together – The number of Company personnel traveling together 

on the same flight must not exceed ten (10). The following combination of officers, 

board of directors, and/or senior management, must not fly in the same aircraft:

a. The Chairman, the Chief Executive Officer (CEO) and any Vice Chairman; or

b. More than two (2) Executive Committee Members (Corporate Officers) and/or 

members of the Board of Directors; or

c. More than four (4) Vice Presidents and/or Managers.

6. Use of Private or Charter Aircraft: Associates may travel on private commercially 

operated aircraft licensed for the transportation of passengers, provided that the 

airline is CB certified or the equivalent in the country of origin. Planes are not to be 

flown by Company associates.

7. Ticket Changes/Cancellations – If an associate needs to change or cancel a ticket 

prior to or during a trip, the change should be made with Travel Counselor during 

normal business hours. When a trip is canceled after the ticket has been issued, the 

ticket can be reused for future travel less a penalty as long as the flight was canceled 

prior to departure. The new trip must be completed within one (1) year of the original 

date of issue. 

In many cases, a change in the ticket will result in the loss of a discount fare; 

especially when the change is routing, travel date, carrier, or advance purchase. It is 

therefore the policy that any associate changing his or her flight to suit their own 

personal convenience, or who elects to change plans for any reasons other than 

business purpose or those beyond their control, will be expected to personally pay for 

any additional fares or service charges incurred during the trip.

8. Unused/Voided/Lost or Stolen Tickets – Although rare, because most tickets are 

electronic, unused airline tickets or flight coupons must never be discarded or 

destroyed, as these documents have cash value. To expedite refunds, unused or 

partially used airline tickets must be returned immediately to the Travel Counselor. 

Unused tickets must NOT be sent to the airlines and must NOT be attached to 

Expense Reimbursement Requests. Under no circumstances is an associate permitted 

to utilize an airline ticket issued in another associate’s name unless it is approved 

prior to issue by the Corporate Accountant.

Immediately upon discovery of a loss or stolen ticket, the associate must report the 

loss to the Travel Counselor who will file the lost ticket application. The associate is 

responsible for the value of lost tickets.

9. Air Travel Payment Policies – Associate air travel costs booked through the 

authorized Travel Counselor will be charged to Holtec’s Company card. Air travel 

bills will be sent directly to Holtec for payment. Associates are still required to attach 

every flight itinerary to the Expense Reimbursement Request form after business 

travel. Consultants or Contractors MAY NOT charge to Holtec’s Company card.

10. Airport Parking – The maximum rates to be reimbursed by Holtec for airport 

parking are below:

24 hours $18.00

Over 24 hours $11.00 per day

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10.7 International Air Travel 

Most guidelines for International travel are consistent with other sections of this Policy. 

However, the following extra guidelines are provided for associates who travel 

internationally. For purposes of this policy, international travel covers all destinations 

outside the United States.

1. Advance Planning for International Travel – As referenced above, advance 

planning and reservations can result in significant cost savings. Associates 

anticipating travel to international destinations must notify the Travel Counselor at 

least two (2) weeks prior to departure date or at the earliest possible time thereafter.

2. Passports, Visas and Foreign Currency Exchange – For assistance or advice in 

obtaining visas or passports, associates should contact the Travel Counselor or Holtec 

Administration. Holtec will reimburse associates for reasonable expenses associated 

with the issuing of passports and short-term business visas. Reasonable expenses for 

foreign currency exchange fees are reimbursable. Please note the website used (such 

as x-rates.com) for foreign currency exchange on any Expense Reimbursement 

Request submission.

3. International Travel Advisories – The U.S. State Department may issue travel 

advisories naming countries that may not be safe for travel. The Travel Counselor 

will be aware of these situations. Holtec may restrict travel to certain countries if this 

occurs.

10.8 Lodging 

1. Hotel Reservations – Lodging should also be booked through the Travel Counselor. 

Sites such as orbitz.com, expedia.com or hotwire.com should be used to view the best 

fares as a comparison to the Travel Counselor rates. If the websites have lower rates, 

associates should first ask the Travel Counselor to match the pricing from any of 

these sites by providing the information from the websites to the Travel Counselor. If 

the Travel Counselor is still not within a reasonable dollar amount of the websites 

rates, then the websites may be used by the associate for business travel.

2. Hotel Selection Guidelines – It is Holtec’s policy to provide reasonable, 

comfortable, and safe lodging for associates while seeking to take advantage of 

opportunities for cost savings. Associates are entitled to stay in a single room with a 

private bath. The following guidelines have been established:

a. Associates must stay in moderate cost lodging that includes free breakfast, but are 

specifically not allowed to use properties in the luxury category.

b. Holtec reserves the right to guide associates to utilize properties where Holtec has 

special negotiated rates in properties near any Holtec Division. 

c. If a Company-negotiated or special hotel rate is not available, associates must use 

hotels in a similar cost and class category.

d. Holtec recognizes that there may be exceptions for both internal and external 

conferences, meetings, trade shows, seminars, etc., where it may be appropriate to 

stay at a higher cost hotel. The Corporate Accountant must approve these 

exceptions in writing.

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e. Prior to the travel, inquire of the Holtec client or business partner being visited 

about reduced rates available through their corporate agreements.

Associates will be reimbursed for actual and reasonable hotel room costs consistent 

with the room rate quoted at the time reservations were made. Associates will be 

responsible for expenses in excess of this rate unless there are circumstances beyond 

the control of the associate. These circumstances must be provided in writing when 

submitting the Expense Reimbursement Request; otherwise, excessive rates will not 

be reimbursed.

1. Hotel Upgrades – Associates may accept room upgrades if the upgrade is at no 

additional cost to Holtec.

2. Hotel Cancellation Policies – Associates are responsible for canceling hotel rooms 

within the cancellation rules and by the time indicated on the associate’s itinerary 

sheet in the time zone of where the hotel is located. The associate must always get a 

“cancellation number” and the name of the person processing the cancellation. This is 

important proof of the cancellation at a later time. If the associate neglects to cancel 

the reservations, he or she will be billed a “no show” charge. Holtec will NOT 

reimburse this charge if the associate has neglected to cancel a reservation.

3. Hotel Payment Policy – All business hotel reservations (holding the rooms for late 

arrival) should be made using the Holtec credit card on file at Travel Counselor. 

Actual hotel expenses per visit are placed on the associate’s personal credit card, 

unless there is a special exception. If the associate uses his or her own personal credit 

card, the charge should then be placed on an Expense Reimbursement Request. All 

associates must report their own hotel costs. Under no circumstances is one associate 

to pay for another associate’s hotel costs and report it on their Expense 

Reimbursement Request. Holtec requires original itemized hotel receipts. All 

itemized hotel receipts must be turned in with the associate’s Expense 

Reimbursement Request regardless of which credit card (Company or personal) was 

used. Only actual hotel expenses for business purposes will be reimbursed. 

4. Hotel Itemized Costs – The following will not be reimbursed by Holtec:

a. In-Room Movies

b. Telephone Calls: All associates have access to cell phones, pre-paid calling cards, 

Skype, etc. These should be used at all times. Only under extreme circumstances 

that are documented by the associate should the hotel telephone be used

c. Mini-Bar

d. Dry Cleaning Services. This service should be used only under extreme 

circumstances.

5. Hotel Frequent Guest Programs – Many hotels have frequent guest programs that 

reward associates with free accommodations in exchange for a given number of paid 

room nights at the hotel. Awards from such programs may be retained by associates 

for personal use. However, participation in these programs must not influence hotel 

selection, which would result in incremental cost beyond Holtec’s specifically 

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negotiated rate or preferred rate. Any membership fees associated with these 

programs are not reimbursable.

6. Gifts in Lieu of Lodging – On occasion, an associate may wish to stay at the home 

of friends or relatives while on a business trip. This is acceptable and if a gift is given, 

the reasonable costs of the gift may be included in the Expense Reimbursement 

Request under “Other Expenses” with the notation “Gift in Lieu of Lodging”. In all 

cases, the gift is not to exceed the cost of a local hotel room or $100.00, whichever is 

less. Receipts are required.

10.9 Rental Car 

1. Rental Car Guidelines – Associates should drive a rented car to their destination 

when (a) driving is more cost effective and timely than airline or rail travel, or (b) 

when transporting large or bulky material that is not conducive to air or rail travel.

Associates may rent a car at their destination when (a) it is less expensive than other 

modes of travel such as a taxi or airport shuttle or (b) entertaining customers.

2. Making Rental Car Reservations – Associate rental car reservations should be 

made through the Travel Counselor with Holtec’s preferred rental car partner 

(Budget) in which Holtec receives a corporate discount and direct billing. Sites such 

as orbitz.com, expedia.com or hotwire.com should be used to view the best fares as a 

comparison to the Travel Counselor rates. If the websites have lower rates, associates 

should first ask the Travel Counselor to match the pricing from any of these sites by 

providing the information from the websites to the Travel Counselor. If the Travel 

Counselor is still not within a reasonable dollar amount of the websites’ rates, then 

the websites may be used by the associate for business travel. Unless there is a 

moderate difference in fee, or Budget is not available, Budget should be used 

exclusively. 

3. Rental Car Categories – Associates should rent a compact/economy car whenever 

possible. An intermediate/standard car is acceptable if there are several passengers. 

Associates may book a class of service one level higher when cars in an authorized 

category are not available, when the customer can be upgraded at no extra costs, 

when transporting excess baggage such as booth displays, or for pre-approved 

medical reasons. Associates are also allowed to choose higher levels of car rental

service within reason if traveling through adverse weather conditions. It is 

recommended that no associate drive in adverse weather conditions.

4. Rental Car Insurance – Holtec carries rental car insurance through a special 

corporate policy that covers U.S. Associates for collision, fire, theft, vandalism and 

liability for automobiles rented and driven in the U.S. (Proof of insurance certificates 

are available from the accounting department.) Holtec associates should NOT 

purchase insurance (CDW, PAI, PEI, etc.) from rental car agencies in the U.S.; 

associates will NOT be reimbursed if insurance is purchased. Holtec associates using 

rental cars outside of the U.S. should purchase insurance from the rental car agency. 

Holtec will reimburse associates for rental car insurance outside of the U.S. NonHoltec associates, consultants, and contractors are NOT covered under Holtec 

insurance policies and should use their own insurance to cover car rentals when 

traveling. Non-Holtec associates, consultants and contractors will not be reimbursed 

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for insurance purchased from the rental car agency when traveling in the U.S. or 

outside the U.S.

5. Rental Car Cancellation Policies – Associates are responsible for canceling car 

reservations. If a cancellation is made directly through the rental agency, the associate 

should request and record the cancellation number is case of billing disputes.

6. Returning Rental Cars – All associates should return (a) to the original rental city 

unless approved for a one-way rental, and every reasonable effort should be made to 

return the rental (b) intact (no bumps, scratches or mechanical failures, and (c) on 

time, to avoid additional hourly charges. Do not purchase the fuel option with the 

agency. The rental car should be returned with a full tank of gas (rental re-fueling

from a gas station is reimbursable) to avoid excessive fuel charges from the rental 

agency.

7. Rental Car Payment Policies – When using Budget Rent-A-Car Holtec will be 

billed directly by Budget if the associate has a Budget card set up with direct billing. 

Associates should request a Budget car from the Accounting Department if they

travel frequently. If the associate does not use Budget, the rental charges should be 

placed on their personal credit card and placed on an Expense Reimbursement 

Request. All original receipts must be turned in with the associate’s Expense 

Reimbursement Request for the associate’s business car rental expense regardless of 

method of payment.

8. Rental Car Accidents/Traffic Violations – Should a rental car accident occur, 

associates should immediately contact the rental car company and local authorities, as 

required. If the police take a report, the associate should obtain a copy. As soon as 

practical, the Holtec HR Department should also be informed so as to follow-up on 

insurance issues. Fines for parking or any traffic violations are not reimbursable.

10.10 Other Transportation 

1. Personal Car Usage Guidelines – Associates may use their personal car for business 

purposes (a) if it is less expensive than renting a car, taking a taxi, or alternative 

transportation, (b) if it is timelier than taking public transportation, (c) when 

transporting Company goods for delivery or (d) when entertaining on official 

business. It is the personal responsibility of the associate to carry adequate insurance 

coverage for their protection and for the protection of any passengers.

2. Reimbursement for Personal Car Usage – Associates will be reimbursed for 

business use of personal cars at the current rate per mile as disseminated by the 

Accounting Department. Associates will NOT be reimbursed for any repairs to their 

personal car, even if these costs result from business travel. Associates will not be 

reimbursed for travel to and from their respective office location.

3. Company Vehicles – The usage of Company cars must be pre-approved in writing 

by the CEO or CFO. Maintenance and repairs must be pre-approved in writing by the 

CEO or CFO. No other expenses related to the Company car such as fuel or cleaning 

will be reimbursable without the written pre-authorization by the CEO or CFO. 

4. Ground Transportation To and From Airport Terminals – Associates traveling to 

the same location should share ground transportation to and from the airport 

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whenever possible. The most economical mode of transportation should be used to 

and from airports (i.e., bus and rail terminals). Associates should consider public 

transportation, hotel and airport shuttle services and personal car.

5. Rail Travel - Rail travel should be used when it is less expensive than air travel and 

when it is timelier than driving. Domestic and International rail travel will be in 

Coach Class. Rail reservations should be made through the Travel Counselor. Sites 

such as the specific rail service site, orbitz.com, expedia.com or hotwire.com should 

be used to view the best fares as a comparison to the Travel Counselor rates. If the 

websites have lower rates, associates should first ask the Travel Counselor to match 

the pricing from any of these sites by providing the information from the websites to 

the Travel Counselor. If the Travel Counselor is still not within a reasonable dollar 

amount of the websites’ rates, then the websites may be used by the associate for 

business travel.

10.11 Personal/Vacation Travel 

Personal/vacation travel may be combined with business travel provided there is no 

additional cost to Holtec and does not interfere with business objectives. In this situation, 

associates should get written approval from their manager prior to making reservations. 

Please see section 10.5.7 for spouse/companion procedures. No personal costs should be 

charged directly to Holtec.

10.12 Telephone Usage 

All associates are to use the cellular phones provided them during business trips for all 

business related calls. No business calls are to be charged to a hotel phone unless 

extensive circumstances prevail. If you do not have a Holtec cellular phone, one should 

be signed out from the Accounting/IT Department for the trip. Holtec will reimburse 

reasonable and necessary business telephones. As noted in the following guidelines, high 

cost calls should be avoided. When submitting an Expense Reimbursement Request, 

associates must provide an explanation and a copy of the bill must be attached.

1. Business Phone Calls – Associates with cellular phones should use that phone, prepaid calling cards, or Skype when out of the office for all business related telephone 

calls. If an associate does not have a cellular phone and must make a business related 

call after hours, they will be reimbursed by Holtec for calls made on their 

personal/home phones. Calls should be as brief as possible, direct dialed when 

practical, and made during the most economical calling times as possible. Callers 

should utilize toll-free 800 numbers whenever possible. If there is no other way to 

call the Holtec Marlton office other than from a hotel land line, the associate should 

use the Holtec toll-free 800 number when traveling.

2. Company Cellular Phones – All associates who travel extensively are eligible for a 

Holtec cellular phone. These charges are billed directly to Holtec and are closely 

reviewed. These phones should be used modestly. Each account has been designed 

to accommodate the associate’s business schedule and usage. If the associate exceeds 

the minutes/monthly allowance the associate will be charged directly for the excess 

usage unless the associate can show the charges are directly related to a project and/or 

business related travel. Associates are asked to utilize pre-paid calling cards, penny 

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talk, other lower cost local cell phones, or Skype rather than use International minutes 

and roaming on Company cellular phones. When traveling, the associate should 

contact the IT Department for a review of all options.

3. Personal Phone Calls While Traveling – A “safe arrival” call is allowed when an 

associate is traveling. For extended travel, occasional calls to home are reimbursable, 

provided they are not excessive. (Associates will not be reimbursed for personal calls 

made from air phones or rail phones.) Personal calls, other than safe arrival, should be 

identified as such on hotel bills (if the hotel phone is the only accessible means) and 

deducted on Expense Reimbursement Requests as a personal expense. 

10.13 Travel Insurance 

1. Travel Insurance Coverage – Regular, full-time associates traveling on Company

business are covered by regular Holtec group insurance benefits, such as life 

insurance, business travel insurance, and worker’s compensation.

2. Additional Travel Insurance Purchased by Associates – Holtec will NOT 

reimburse expenses for additional travel or specific trip insurance.

3. Rental Car Insurance – (Refer to Section H.4.)

10.14 Meals and Entertainment 

1. Personal Meal Expenses – Personal meals are defined as meal expenses incurred by 

the associate when dining alone or with Holtec colleagues on an out-of-town business 

trip. Associates will be reimbursed for personal meal expenses within the guidance of 

up to $45/day total ($10/breakfast, $15/lunch and $20/dinner) or less for meals while 

traveling. Expenses in excess of the guidance must be justified in writing on the 

Expense Reimbursement Request and approved by a direct supervisor and CFO for 

reimbursement. Fiscal prudence and common sense should be used. Expenses 

determined to be “lavish” will not be reimbursed.

2. Business Meal Expenses – Business meals are taken with clients, sales prospects, or 

other business associates during which a specific business discussion takes place. 

Note that Holtec contractors have separate agreements that specify meal 

expenses/reimbursements and are not eligible for Business Meal Expenses paid for by 

Holtec associates. Holtec associates will not be reimbursed for Business Meal 

Expenses for contractors. 

Associates will be reimbursed for business meal expenses with clients, sales prospects 

or other business associates according to actual and reasonable costs. Associates 

should use the guidance of $30 per person when business meals take place with 

clients, sales prospects, or other business associates. Written justification should be 

provided for any business meal expenses greater than $30 per person. Business 

purpose of the charges (related project information), names of all attendees, and name 

and location of the establishment is required on the Expense Reimbursement Request. 

In some cases, group meals and/or entertainment events are reimbursable by the 

client, possibly via project milestones. Any group meals and/or entertainment events 

require pre-approval of the specific divisional Senior Vice President. If the associate 

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is not aware of these events or possible project milestones, he or she should notify the 

project manager familiar with the client contract and/or direct supervisor after the 

group meal/event has taken place. The project manager should have a not-to-exceed 

budget to compare milestone billings to actual business meal and entertainment 

expenses with clients. The Accounting Department should be immediately notified by 

the project manager of any charges that are reimbursable by the client.

3. Business Meals Taken With Other Associates – Associates will be reimbursed for 

business related meals taken with other associates only in the following 

circumstances:

a. When a client is present.

b. When for testimonial, reward, recognition or other appropriate business purpose, 

with the approval of a direct supervisor and Corporate Accountant.

Business purpose of the charges (related project information), names of all attendees, 

and name and location of the establishment is required on the Expense 

Reimbursement Request. 

4. Entertainment Expenses – These expenses are reimbursable only to the extent they 

are considered ordinary and necessary to the operation of the business. There must be 

the expectation that the costs will benefit the business. Associates must receive 

written approval from their direct supervisor and Corporate Accountant in advance 

regarding planned expenses to determine what is “ordinary” and “necessary”.

A documented explanation of all entertainment expenses charged to Holtec and the 

business purpose of the charges (related project information), names of all attendees, 

and name and location of the establishment is required on the Expense 

Reimbursement Request. All original receipts for expenditures must also be attached.

5. Tips – Tips or gratuities for services rendered will be reimbursed as long as they are 

kept to a reasonable amount. The maximum meal tip is 15%. 

6. Reimbursement for Meals and Entertainment –These charges should be recorded 

on an Expense Reimbursement Request. Both a detailed receipt and the final receipt

showing tip amount should be included when the Expense Reimbursement Request is 

submitted by the associate. These charges are reimbursed in a timely manner 

provided the report/information is complete and contains all necessary receipts.

Written justification should be provided for any expenses greater than $20 per person. 

Business purpose of the charges (related project information), names of all attendees, 

and name and location of the establishment is required on the Expense 

Reimbursement Request.

10.15 Expense Reporting 

1. Expense Reimbursement Request Completion and Submission – All business 

travel and entertainment expenses must be itemized on an Expense Reimbursement 

Request and forwarded to Accounting with the necessary original receipts (detailed 

receipts and final receipts with tip amount), explanations, approvals, Travel 

Authorization form, and itinerary. Detailed instructions for the completion of this 

form can be obtained from Accounting. 

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Original itemized receipts (hotels, car rentals, meals, other) are required for any 

expense of $20 or greater for associates.

ASSOCIATES SHOULD COMPLETE AN EXPENSE REIMBURSEMENT 

REQUEST WITHIN 10 DAYS. ASSOCIATES WILL NOT BE REIMBURSED IF 

EXPENSE REIMBURSEMENT REQUESTS ARE SUBMITTED AFTER 30 DAYS 

OF COMPLETION OF TRAVEL.

2. Expense Reimbursement Request Approval/Authorization Process – Expense 

Reimbursement Requests should be filled out and signed by the associate, approved 

by the associate’s supervisor, and submitted to Accounting for approval/processing. 

After initial approval by the associate’s supervisor, Accounting approval/processing 

should take approximately 10 days from submittal and checks will be printed twice a 

month on the 15th and the 30th. Associates are reminded that meal and entertainment 

expenses require detailed information as allowed for on the form along with original 

receipts to satisfy IRS/Holtec Policy requirements. Furthermore, expenses in excess 

of the guidelines provided in this Policy must be justified in writing and 

reviewed/approved by a direct supervisor and CFO. Accounting has the authority to 

withhold reimbursement and return Expense Reimbursement Requests for expenses 

that are not within guidelines and/or do not have proper justification and approval.

It is not intended that an associate incur any financial loss while on Company

business for reasonable and necessary expenses. Nor is it intended for the associate to 

realize a financial gain. If an associate incurs expenses that do not appear to be 

covered under this Policy, but which are believed to be valid charges to Holtec, the 

associate should submit these charges on an Expense Reimbursement Request with a 

full explanation and supporting original receipts.

10.16 Non-Reimbursable Expenses 

The associate is responsible for complying with the Travel Policy. Associates will not be 

reimbursed for expenditures of a personal nature incurred on a business trip. The 

following list is not meant to be all-inclusive; rather, it represents commonly disallowed 

expenses. Holtec will reimburse associates for all reasonable and necessary expenses 

while traveling on authorized Company business. Questions regarding reimbursement 

should be resolved with the direct supervisor, Accounting Department, before the 

expense is incurred. Exceptions require written CFO approval. Holtec assumes no 

obligation to reimburse associates for expenses that are not in compliance with this 

policy.

a. First Class or Business Class Airline Travel

b. Rental Car categories higher than Policy guidelines

c. Limousine travel

d. Luxury class lodging

e. Personal auto repairs due to accidents or routine maintenance and tune-ups

f. Motor vehicle citations received while on Company business (parking or traffic)

g. “No Show” charges for hotel or car rentals

h. Travel, lodging, food and beverage expenses incurred outside of Policy guidelines

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i. Purchases of theater or sporting event tickets and other items or entertainment of a 

personal nature not necessary to the requirements of the business trip, except as 

allowed in Section M

j. Health club facilities, saunas, massages and spas

k. Golf fees (when not part of customer entertainment)

l. Mini-bar refreshments (in excess of daily meal allowance when integrated with other 

meals)

m. Movies (including in-flight and hotel in-house movies)

n. Newspapers, books and magazines

o. Haircuts, shoe shines, manicures

p. Clothing (i.e. socks, shoes, pants)

q. Car washes

r. Gum, candy, cigarettes and cigars

s. Toiletries such as soap, shaving cream

t. Theft, loss or damage to personal funds or items

u. Loss or damage to Company items such as cell phones, computers or other Company

equipment

v. Theft or loss of advances, unused airline tickets or Company credit cards

w. Medical expenses (refer to Holtec group insurance policy for coverage)

x. Luggage, briefcases, etc.

y. Personal property, travel or accident insurance

z. Household expenses while away from home

aa. Gifts, except to hosts in lieu of lodging as defined in Section G

ab. Childcare expenses, baby-sitting

ac. Kennel fees

ad. Excessive baggage charges

ae. Excessive personal, local/or long distance telephone charges

af. Excessive tips

ag. In-flight telephone charges

ah. Laundry (except reasonable expenses for business travel over 5 days)

ai. Valet Service

aj. Home entertainment is not reimbursable 

ak. Credit card fees, interest charges levied on overdue invoices or ATM fees 

al. Airline, Credit Card and/or other travel/miles club membership fees

am. Expenses related to vacation or personal days while on business trip

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an. Helicopter services for airport transfers

ao. Transportation to and from office

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11.0 VACATIONS AND HOLIDAYS

 The Holtec International Vacation Policy is located within the Holtec Employee Manual 

(CD-01)

 The Holtec International Vacation Policy shall be read and understood by each full-time 

or part-time employee that is eligible for vacation

 Each eligible employee shall use the Vacation Sick Day Request Form (HR-07), which 

must be signed by the employee’s supervisor and submitted to the Corporate 

Accounting/Finance Department prior to any Vacation 

 Each eligible employee has a Vacation Reconciliation spreadsheet that is kept in the 

Accounting/Finance Department in Marlton HQ

 The Holtec Company Holidays for the 2011 calendar year are as follows: 

 

 

December 31, 2010 (Friday) New Year’s Day

May 30 (Monday) Memorial Day

July 4 (Monday) Independence Day

September 5 (Monday) Labor Day

November 24 (Thursday) Thanksgiving Day

November 25 (Friday) Day after Thanksgiving Day

December 26 (Monday) Christmas Day

 Each eligible employee accrues his/her Vacation Days and a maximum of 2 Personal 

Holidays throughout the calendar year per the Vacation Policy within the Holtec 

International Employee Manual (CD-01)

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12.0 DUTIES AND RESPONSIBILITIES OF HOLTEC MANAGERS

12.1 Nuclear Power Division (NPD)

12.1.1 Duties and Responsibilities of NPD’s Program Manager

NPD’s Program Manager’s specific duties include:

a. Responsible for all project deliverables from NPD, which does not include licensing or 

Holtec Technical Services (HTS) deliverables.

b. Train PMs and APMs in the processes set down in the Company documents, including 

management of databases, good PM practices, etc. Ensure that all comply with the 

processes. 

c. Attend client meetings and provide management overview of the PMs in the contract 

management of their projects. 

d. Continue improvements in the information management infrastructure to eliminate 

human error and to improve communication.

12.1.2 Duties and Responsibilities of Adjunct Program Manager 

a. Plan the site services/construction components of all NPD projects to ensure that they are 

implemented seamlessly. Planning means ensuring all required procedures are prepared, 

establish staffing needs, coordinating the activities with other Holtec organizations such 

as Holtec Manufacturing Division (HMD), and interfacing with the client’s 

representatives. The planning shall be carried out with expertise and adroitness. 

b. Serve as the stand-in for the Program Manager, as needed. 

c. Participate in evaluating bids for site services along with the Program Manager and 

Project Manager.

d. Lead NPD’s efforts to expand the cadre of site engineers so that the Adjunct Program 

Manager does not become consumed in any one project. 

e. Initiate a plan to reduce reliance on contractors.

f. Lead the Company’s drive to expand field services in areas, such as MPC lid welding, 

with participation from HMD.

g. Establish a world-class site services package including Site Safety plan and Rigging 

manual. 

h. Coordinate the site services effort for all projects with the Field Service Manager.

i. Lead the Company’s emergency response team in the event of a setback at a site. 

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j. Work with the CFO and CNO to establish a sound structure to minimize overhead costs.

k. Provide support to the sales department in its efforts to sell turnkey projects.

The Adjunct Program Manager is solely responsible for proper planning and execution of all site 

services work in all NPD projects, for reducing our reliance on subcontractors, and for preparing 

NPD for a rapid growth inside services work. 

12.1.3 Duties and Responsibilities of the Technical Sponsor

The Technical Sponsor has the sole responsibility to guide the Designer through the design 

development process. Specifically, the Technical Sponsor (TS) is responsible to ensure that:

1. A complete Purchasing Specification for the SSC has been prepared and adopted.

2. The Designer is fully conversant with the technical nuances of the SSC, including all critical

dimensions.

3. The materials of construction have been carefully selected and welding requirements are 

appropriate.

4. The SSC is in full compliance with the applicable Codes and Standards and that the design is 

not wasteful of material or manufacturing labor.

5. The information is provided to the assigned Designers to prevent wastage of drafting 

resources. 

6. The HMD/Orrvilon personnel, as applicable, are brought into the design review process at 

the earliest possible date.

7. All requirements of HSP-191 (Product Development Design Control Process) are 

implemented. 

8. All required input data has been gathered in advance of the start of work.

The Technical Sponsor for a design task is named by the Corporate Design Manager.

12.1.4 Duties and Responsibilities of the Design Planning Manager

The Design Planning Manager reports to the NPD Program Manager and is matrixed to the 

Design Manager. 

1. Schedule and control the work load of designers. Assign target man-hours and 

completion date.

2. Maintain a performance metric for all Designers.

3. Ensure that the Technical Sponsor is fulfilling his (her) responsibilities in full measure.

4. Ensure that the Design/Checker are utilizing the relevant checklists to check for 

completeness and accuracy.

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5. Ensure that the work being assigned is within the authorized project scope under the 

terms of the Contract.

12.2 Holtec Manufacturing Division (HMD) Managers

12.2.1 General Manager –

The HMD General Manager (GM) is responsible to ensure that all structures, systems, and 

components (SSCs) contracted by HMD for nuclear plants (from NPD as well as external clients) 

and fossil-fuel plants (from PPCD as well as external clients) are delivered with high quality, on 

schedule, and at the lowest reasonable costs. 

The GM’s duties and responsibilities are summarized below.

a. Supervise the HMD PMs directly, train them, and improve their effectiveness and 

productivity.

b. Direct the scheduling of manufacturing of nuclear SSCs at HMD using the NPD-controlled 

PHD database as the guide. 

c. Implement the manufacturing on the shop floor and ensure that HMD’s interface with the 

Purchasing Department is robust, so the required material is available to support 

manufacturing at all times. 

d. Ensure that HMD continues to improve its fabrication processes and has minimal 

interruptions in manufacturing. 

e. Ensure that shop deviations will be handled at HMD: only those that require a detailed 

analysis or a §72.48 will be sent to NPD.

f. Ensure that the Vantage system is effectively deployed and operational at HMD. 

f. Procuring all materials and services for HMD. All purchasing personnel in Pittsburgh and 

Marlton report to the Corporate Supply Chain Manager. 

g. Inventory Control and Optimized Utilization of Materials.

h. Manufacturing of all standard nuclear components (NPD orders).

i. Human resources (recruitment of new personnel and right sizing of organization).

j. Maintenance of all equipment and machinery in the Nuclear and Code Business Unit areas.

k. Ensure that the welding program is well run (use of most appropriate weld procedures, 

welder training, and welding techniques).

l. Provide oversight for the Safety Program.

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m. Management of Material Processing Center.

n. Manage HMD’s transport (shipment) activities.

In summary, HMD will serve as a full-service manufacturer to NPD and PPCD, needing NPD’s 

or PPCD’s help only to amend the SAR or disposition a deviation that requires analysis. 

12.2.2 Operations Manager – Nuclear Business Unit

The Nuclear Business Unit General Manager (GM) is responsible to ensure that all structures, 

systems, and components (SSCs) contracted by HMD for nuclear plants (from NPD as well as 

external clients) are delivered with high quality, on schedule, and at the lowest reasonable costs. 

The Operations Manager’s duties and responsibilities are summarized below.

a. Direct the scheduling of manufacturing of nuclear SSCs at HMD using the NPDcontrolled PHD database as the guide. 

b. Implement the manufacturing on the shop floor and ensure that HMD’s interface with the 

Purchasing Department is robust, so the required material is available to support 

manufacturing at all times. 

c. Ensure that HMD continues to improve its fabrication processes and has minimal 

interruptions in manufacturing. 

d. Ensure that shop deviations will be handled at HMD: only those that require a detailed 

analysis or a §72.48 will be sent to NPD.

e. Inventory Control and Optimized Utilization of Materials.

f. Manufacturing of all standard nuclear components (NPD orders).

g. Maintenance of all equipment and machinery in the Nuclear Business Unit area.

h. Ensure that the welding program is well run (use of most appropriate weld procedures, 

welder training, and welding techniques).

i. Provide oversight for the Safety Program.

j. Single-point contact for union issues in the Nuclear Shop.

k. Leverage the Orrvilon facility to the maximum extent possible including light fabrication, 

trucks and trailers.

In summary, HMD will serve as a full-service manufacturer to NPD, needing NPD’s help only to 

amend the SAR or disposition a deviation that requires analysis. 

12.2.3 Operations Manager – PPCD Manufacturing

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Duties and responsibilities include the following:

a. Responsible for cost and schedule for manufacturing of all components for PPCD and work 

secured from HMD.

b. Single-point contact for union issues in the Code Shop.

c. Provide oversight for the Safety Program.

d. Maintenance of all equipment and machinery in the Code Business Unit area.

e. Leverage the Orrvilon facility to the maximum extent possible including light fabrication, 

trucks and trailers.

12.2.3 Lead Product Line Manager - Nuclear

Duties and responsibilities consist of the following:

a. Ensuring that all HMD procedures used in the shop (except welding procedures), including 

HSPs, HPPs, and QCPs, are in full compliance with the Company’s Quality Program and 

applicable Codes and Standards, and are production-friendly. 

b. Providing guidance and leadership to the PLMs. 

c. Training of Production Supervisors.

12.2.4 HMD QA Manager

Duties and responsibilities consist of the following:

a. Enforce all corporate QA procedures at HMD and its suppliers through a well coordinated 

plan of surveillance.

b. Maintain the Approved Vendors List (AVL) and ensure that the QC Department follows all 

required quality practices, including instrument calibration.

c. Surveil the shop to ensure that document control and material traceability are maintained.

d. Responsible for preparing the Documentation Packages, CCRs, and other client deliverables.

12.2.5 Manager of Planning and Schedule

Duties and responsibilities consist of the following:

 Responsible for planning and scheduling of all HMD work activities.

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12.3 Discipline Managers (Holtec Technical Services)

The following disciplines are established at HTS:

1. Applied Mechanics (HTS)

2. Nuclear Physics (HTS)

3. Design and Drafting (HTS)

4. Thermal-Hydraulics (HTS)

5. Site Services (NPD)

6. Licensing (HTS)

7. Head of Discipline Technical Heads (HTS):

8. Dry and Wet Storage Programs (NPD)

The principal responsibilities of the Discipline Managers are:

a. Assign personnel for each task in the Task Tracking Database.

b. Specify the expected completion date and target person-hours.

c. Provide a face-to-face report on status of active tasks to the executive 

management in scheduled weekly meetings.

d. Lead the effort to recruit additional staff, as necessary.

e. Provide annual (confidential) performance review on the discipline personnel.

12.4 Project Managers and Adjunct Project Managers 

a. The PMs and APMs are announced for each project. Consult the Project Database for 

the names of PM and APM on a specific project.

b. All PMs and APMs must take the self-study session being offered by the Company to 

be qualified for nuclear plant work. 

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13.0 CORPORATE GOVERNANCE AND CODE OF CONDUCT

13.1 Recognizing Meritorious and Poor Conduct

The procedure governing the conduct of all Holtec associates, regardless of rank, is set down in 

the Corporate Governance Manual (CD-7). Violation of any of the provisions of CD-7 will 

trigger the issuance of a Notice of Reprehensible Conduct (NRC)Form to the associate (please 

see Form HR-40). The NRC shall be issued only under circumstances in which an associate has 

been determined to have engaged in a reprehensible conduct that may damage the Company. 

Form HR-41 (DREW) shall be used to notify an associate of an error that has been detrimental to 

the Company’s reputation or finances. 

A “Demerit Notice”, also provided as a part of this section (Form HR-42), is a less severe 

citation. A Demerit Notice may be issued by an associate’s supervisor or any manager or 

executive up the associate’s chain of command.

An Employee Warning Letter (Form HR-43) may also be given to an employee for poor conduct, 

poor work product or a violation of Company policy or the Employee Manual.

A “Citation of Meritorious Work” (Form HR-44), shall be used to recognize an associate’s 

performance deemed to be creditable and exemplary.

13.2 Summary of Guidelines in External Interactions

1. No Holtec personnel will accept any gift from any corporate friend or acquaintance that 

exceeds $50.00 in value. All gifts accepted must be reported in writing to the appropriate 

person in the Human Resources Department with a copy to the CFO. The identity of the 

gift giver and the reason for the gift must be provided in your e-mail report. 

2. If a Holtec associate is approached by a client’s employee for a position at Holtec, the 

Holtec associate must inform the individual that prior to commencing any discussions, he 

must obtain authorization from Holtec’s upper management and Human Resources 

Department. Holtec’s executive management will have to clear this matter with the 

client’s upper management before making any overtures to hire a client’s employee. This 

prohibition does not apply to contractors who may be working for the client. 

3. Giving of any gifts in excess of $100.00 in value to a client’s representative must be 

approved by Holtec’s upper management and Human Resources Department in writing. 

Providing unauthorized gifts or gratuities to client’s representatives would expose the 

Holtec associate personally to the consequences of a wrongful act under U.S. law. The 

law extends to our activities in foreign countries also, under the so-called “Foreign 

Corrupt Practices Act”. 

4. Visits with client’s personnel to places of adult entertainment are disallowed as a 

permissible business expense. 

5. In addition to following the above guidelines, Holtec associates should familiarize 

themselves in this matter with the policy of Holtec’s client so that none of the client’s 

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rules are violated. CD-8 provides mandatory guidance on dealing with government 

employees. 

13.3 Corporate Governance

Please read CD-7 carefully. Violation due to ignorance of its provisions does not exculpate an 

associate from an inadvertent wrongdoing. 

13.4 Reporting of Complaints and Recommendations

Two email addresses, one for sending complaints and the other for sending suggestions, have 

been established for all Holtec associates. The “Complaints” mailbox is accessible to Dr. Alan 

Soler ONLY for reading. The “Suggestions” mailbox is accessible to the Executive Committee 

as well as Dr. Soler. If you wish to remain anonymous, please send your input from an outside 

computer, or simply state that in your email from any computer, internal, or external. If you wish 

to be identified, use any computer, and state that as well.

The company has established these mailboxes for anyone who finds his/her work environment to 

be: unsafe, unfriendly, oppressive, or otherwise disagreeable. Holtec has zero tolerance for 

sexual harassment, bigotry, unsafe work conditions, or an environment of retaliation or 

retribution. Suggestions for improvement are welcome and encouraged. Actions will be taken 

promptly regarding both complaints and suggestions.

The email addresses are:

complaints@holtec.com

suggestions@hotec.com

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14.0 TRAINING AND HUMAN PERFORMANCE

Holtec International views continuous training of personnel to be a critical component for 

improving human performance. As discussed below, a number of training vehicles are used by 

the Company.

14.1 Holtec Personnel Training

Manual (CD-02: This is the basic training document that provides generic guidance to Company 

personnel in different departments across the Company. CD-02 should be read by all personnel.

14.2 Training Modules

A number of PowerPoint-based training modules have been developed by the Company for 

indoctrination of personnel. These modules include QA related topics as well as discipline 

specific topics. The training modules are stored on the Company network under 

G:\Generic\Training-Holtec University for self-study by the Company’s personnel. Classroom 

training may also be given at periodic intervals.

Exhibit 14.A contains a list of training modules available as of December 31, 2010.

14.3 E-Mail Training: Lessons Learned Database

Holtec uses the email system to provide lessons learned to all applicable Holtec employees. 

Many of these lessons learned are generated as a result of corrective actions initiated by Holtec. 

The lessons learned files are maintained on the network under n:\public\qainfo\lessons learned. 

Lessons learned are also cataloged and maintained in an easily searchable database which is 

accessible to all employees from the Paradox Database Screen.

14.4 Training Tablets

The training tablets are in tombstone-form that appear on all company computers when the 

computer is powered on. The training tablets are single-topic, succinct messages that are 

intended to expose and reinforce the Company’s culture on an ongoing basis. 

Exhibit 14.B contains a few samples of illustrative “training tablets”. All Training Tablets are 

saved under N:\Paradox\Holtec directory.

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15.0 PERFORMANCE DISSEMINATION AND PERFORMANCE REVIEWS

15.1 Bi-Weekly Reports

All non-union Company personnel except secretarial staff from all Company divisions are 

required to complete a Bi-Weekly Report on their individual work accomplishments. Personnel 

are required to fill out the Bi-Weekly reports on the first and third Friday of each month. The 

completed reports are saved on the Corporate Computer Network directory and e-mailed to a 

staff member’s direct supervisor and the executive in charge of the Company Business Unit as 

described in the top section of the Bi-Weekly report. 

A Bi-Weekly Report template has been created for the following groups of personnel:

1. Sales and Marketing

2. Project Management

3. Design and Analysis

4. Quality Assurance

5. Site Services

6. Accounting

A copy of the latest templates are saved under G:\Generic\Bi Weekly Reports\2009 directory on 

the Corporate network located in Marlton, NJ. Please contact the Program Manager, NPD if you 

have any questions on the Bi-weekly reports.

15.2 Performance Review Forms

Form HR-7 is used to document an annual review of Holtec associates. 

Form HR-7 is also used to document the review of Holtec management by the Company’s 

associates. The annual Holtec Executive Survey is used by all associates to provide feedback of 

the executive management at Holtec.

15.3 Confidential Review of Holtec Executive Personnel

The annual Holtec Executive Survey is used by all associates to provide feedback of the 

executive management at Holtec. The Survey is sent to all company personnel in December of 

each year.

15.4 Improving our Work Environment

If you have a complaint or unaddressed grievance of any sort related to your work environment 

that remains unresolved, please do not suffer in silence.

Please read the Holtec Corporate Governance & Ethics Manual (CD-07 stored in 

G:\Generic\Holtec Corporate Manuals\CD-07 on the Holtec network) and follow the instructions 

therein to submit the complaint to complaints@Holtec.com.

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To allay your concerns of possible retaliation from anyone, the manual informs you on the means 

to maintain your privacy while filing your complaint. Holtec’s Corporate Governance Officer, 

Dr. Alan I. Soler is empowered by the Company’s Executive Committee and the Board of 

Directors to address the underlying issue and, if necessary, report it to the Company’s Board of 

Directors.

Starting on Jan 3, 2011, Holtec International will collate the complaint data on quarterly basis to 

monitor the health of our work environment at all Holtec Division locations.

15.5 Internal Communications

Holtec Internal Communications in person or via email, telephone or text shall be conducted in a 

professional manner. No derogatory language shall be used at any time. Please reference the 

Holtec Corporate Governance & Ethics Manual (CD-07 stored in G:\Generic\Holtec Corporate 

Manuals\CD-07 on the Holtec network) for guidance. All Company associates and contractors 

shall be aware that Holtec reserves the right to monitor all internal (as well as external 

communications) on Holtec Company property.

When communicating through email, Company associates shall use professional etiquette by 

addressing the email to the person(s) in the “Body” of the email appropriately to match the 

person(s) in the “To” line of the email. Those persons in the “CC” line of the email shall check to 

confirm that the email is not individually addressed to them in the “Body” of the email but 

should read and understand the email nonetheless. The “Subject” line should be used 

appropriately by the Sender of the email in order to provide a clear and concise subject of the 

email communication. 

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16.0 Drug and Alcohol Policy

16.1 Introduction 

The Company has a strong commitment to provide a safe workplace for all, to promote high 

standards of performance, to protect our employees, agents’ and contractors’ health and safety, 

and to promote and maintain customer confidence in our services. Holtec International (“The 

Company”) recognizes that involvement with drugs and alcohol, whether on or off the job, may 

affect job performance and endanger the health and well-being of both the involved individual, 

as well as those coming in contact with that individual.

The Company is confident that you must also be aware of the obvious and potentially serious 

risks to you, your co-workers, others in the workplace or at the worksite, and to the successful 

conduct of our business affairs, which could result from drug and alcohol use. Thus, we have 

adopted the Company Drug, Alcohol and Substance Abuse Policy (the “Policy”), which applies 

to all full-time and temporary employees, and to all agents and contractors of the Company at all 

Divisions of the Company.

This Policy shall be made available to all labor organizations whose members are utilized by the 

Company in the performance of its business; and the Company encourages those labor 

organizations to distribute copies of the Policy to its members or otherwise make its contents 

known to their respective memberships. 

ACCEPTANCE AND COMPLIANCE WITH THE TERMS OF THIS POLICY SHALL BE AN 

EXPRESS CONDITION OF EMPLOYMENT WITH THE COMPANY. THE VIOLATION OF 

ANY PROVISION OF THIS POLICY WILL BE CAUSE FOR DISCIPLINARY ACTION AS 

DETERMINED TO BE APPROPRIATE BY THE COMPANY UP TO AND INCLUDING 

TERMINATION OF EMPLOYMENT OR CONTRACT STATUS OR DENIAL OF 

EMPLOYMENT FOR A FIRST OFFENSE OR VIOLATION. 

The Company may perform work for public or private corporations, institutions, political 

subdivisions, or other business entities; or employ individuals who are members of various labor 

organizations, which have adopted their own form of drug, alcohol or substance abuse policy. In 

order to avoid any ambiguity as to which policy shall be applied to any given situation, the terms 

of this Policy shall supersede those of any other entity’s Drug, Alcohol or Substance Abuse 

Policy. This paragraph shall be applied in all cases involving any employment applicant, 

employee, agent or contractor of the Company; except that, should any other applicable entity’s 

policy provide for a more restrictive application or interpretation, in the interest of facilitating the 

highest possible level workplace safety, the policy establishing the strictest application or 

interpretation shall be applied.

As with all of its policies, the Company reserves the right to modify or supplement this policy at 

its sole discretion as may be necessary and appropriate, either to meet the objectives of achieving 

a workplace and a work force free from drug and alcohol abuse or to reflect changes required by 

law or regulation. Further, nothing in this policy is to be construed as a waiver of any of the 

Company’s inherent managerial and administrative rights to maintain discipline and to treat 

unacceptable work performance as a cause for termination of employment at any time.

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16.2 Definitions 

A. “Drug” means any potentially mind or ability-altering chemical of any kind, including 

specifically, but not limited too: depressants; stimulants; cocaine; narcotics; 

methadone; marijuana, and any other cannabinoid; hallucinogens or other controlled 

substances; any other legal or illegal drugs, and prescribed and over-the-counter 

medication.

B. “Individual” means any applicant for employment, employee, agent or contractor of 

the Company.

C. “Reasonable suspicion” means that an individual’s actions, appearance or conduct 

have caused the Company to suspect that the individual may be in violation of this 

Policy.

16.3 General Rules Regarding Drugs and Alcohol 

A. No individual shall manufacture, sell, dispense, distribute, use or have in his or her 

possession alcohol or drugs while on Company property, while using the Company 

vehicles or equipment, while performing work for or otherwise conducting any 

Company business, or while on meal breaks or rest periods.

B. No individual shall report to work, use the Company equipment or conduct the 

Company business while impaired or under the influence of a drug or alcohol. For the 

purpose of this Policy, an individual will be considered to be impaired or under the 

influence of a drug or alcohol if that individual, upon testing, tests at levels at or in 

excess of the cut-off levels set forth in Section IV.F.1 of this Policy.

C. Notwithstanding the above prohibition, individuals may take over-the-counter 

medication or prescribed dosages of medication under the direction of a physician 

while on the Company property, while using the Company equipment, while 

conducting Company business, or while on meal breaks or rest periods, so long as 

said medications do not adversely affect the individual’s ability to work in a safe and 

efficient manner. While doing so, however, they are responsible for being aware of 

any effect such medication may have on the performance of their job duties and must 

promptly report to their supervisor the use of any medication which might affect their 

ability to perform their job safely and efficiently. Individuals will not be disciplined 

for taking the prescribed dosage or medication, if it has been previously reported to 

their supervisor.

D. It is an individual’s duty to report the use of prescribed or over-the-counter 

medication which might affect job performance before job performance is actually 

impaired. Reporting or excuses made “after the fact” are not sufficient to limit or 

modify any disciplinary or remedial actions taken under this Policy. For the purposes 

of this Policy, individuals who report to work or perform work while impaired or 

under the influence of a prescribed or over-the-counter medication, the usage of 

which has not been reported to the supervisor previously, will be treated as having 

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reported to work impaired or under the influence of a drug, and thus in violation of 

this Policy.

E. When the Company determines, in its sole discretion, that the circumstances warrant 

removing an individual taking prescribed and/or over-the-counter medication from 

his or her current job, the Company may place such individual on a medial leave of 

absence or arrange for alternative work to be performed on a temporary basis, at its 

discretion.

F. Any individual who violates the terms of this Policy will be subject to disciplinary 

action up to and including termination of employment. Additionally, any employee 

who is found to have violated this Policy shall not be eligible for rehire for twelve 

(12) calendar months from the date of the violation; and thereafter must successfully 

demonstrate that he is drug and alcohol free to the satisfaction of the Company.

G. Nothing in this Policy shall be construed as a waiver of the Company’s right to take 

disciplinary action against an individual under other existing policies, procedures or 

job site work rules for unsatisfactory performance or misconduct. The use of or 

treatment for the use of abuse of drugs or alcohol will not be a valid excuse justifying 

poor work performance or misconduct.

H. The level of discipline to be imposed for violations of this Policy shall be governed 

by the Company, at its sole discretion.

16.4 Drug and Alcohol Testing and Searches 

A. General Overview

1. For the purposes of this Policy, if an individual tests positive for a drug or

alcohol, the individual will be presumed to be under the influence of a drug or 

alcohol, and thus in violation of this Policy. An individual will be considered 

to have tested positive if the drug or alcohol test results indicate the presence 

of a drug (or substance metabolite) or alcohol in the individuals system at or 

above the cut-off levels set forth in Section IV.C.1 below.

2. If an individual refuses to submit to a drug or alcohol test pursuant to this 

Policy, the individual will be the same as an individual who agrees to be 

tested and tests positive.

3. If the results of any test indicate that the specimen has been adulterated in any 

way, the Company shall consider the adulterated specimen to be a positive test 

result.

4. Prior to testing, all individuals being tested will be required to sign a 

consent/release form authorizing both the screening test and the release of the 

results to the Company. Refusal to sign such a consent/release will be

considered to be the equivalent of refusing to submit to the screening test and, 

thus, a violation of this Policy.

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5. All drug and/or alcohol screening tests will be conducted by a facility chosen 

by the Company.

6. Arrangements will be made by the Company to transport any individual who 

is believed to be under the influence of a drug and/or alcohol to the testing 

facility for a screening test.

B. Testing when Reasonable Suspicion Exists

1. Individuals whose performance or behavior indicates possible drug or alcohol 

use/abuse or impairment may be subject to a drug and/or alcohol-screening 

test based upon reasonable suspicion. Examples of behavior and performance 

which may provide such a reasonable suspicion are listed below; however, 

they have been listed for descriptive purposes only and are not to be 

considered all inclusive:

– Excessive absenteeism, which may include an excessive tardiness record, 

continuous unavailability or excessive frequency of occurrence.

– A poor work-related accident record when reviewed with regard to type of 

accident, frequency of accident, or severity of accident.

– Involvement in a work-related accident.

– Displaying abnormal behavior on the job as observed by a supervisor 

and/or co-workers.

– Odor of alcohol on the breath or clothes.

– Inability to perform usual/routine tasks

– Poor overall employment record including attendance reviews, 

disciplinary letters, performance reviews, and accident records.

– Involvement in the use of unauthorized delivery of a drug without 

authenticated medical explanation.

– Information made available to the Company from an outside source or from 

other than Company personnel which, upon review and investigation, is 

considered by the Company in its sole discretion to be a reasonable basis to 

require a drug or alcohol screening test.

– Involvement in the use, unauthorized possession, misappropriation or 

unauthorized delivery of a drug or alcohol while on duty or on the Company

property.

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– Arrest on criminal charges of possession, use or delivery of a drug, either on 

or off of the workplace.

– the Company has developed a Reasonable Suspicion Observation sheet to 

assist its supervisors in evaluating and documenting the existence of the 

circumstances giving rise to any reasonable suspicion test.

C. Test results

1. When screening tests are required under this Policy, the individual tested will be 

considered to have tested positive if any of the following levels are met or 

exceeded:

Drugs (all levels ng/ml)

Drug RIA Screen GCMS Confirmation

Marijuana metabolites 20 15

Cocaine metabolites 300 150

Opiate metabolites 300* 300

Phencyclidine 25 25

Amphetamines 1000 500

Barbiturates 200 200

Benzodiazepines 300 300

Methaqualone 300 100

Methadone 300 300

Propoxyphene 300 300

 25 ng/ml if immunoassay specific for free morphine. 

 Alcohol .05% (Blood Alcohol level).

These levels are designed to meet the cut-off levels established under 

the HHS guidelines dated April 11, 1988

2. If the results of an individual’s drug or alcohol screening tests are positive, a 

portion of the original sample will be retained and made available for further 

testing. If the tested individual requests that the sample be split at the collection 

site, medical personnel will split and retain a portion of the specimen. All 

necessary supplies (such as specimen container, label and mailer) will be provided 

by the testing facility at the time of the test. A portion of the specimen will be sent 

to a designated accredited laboratory, which has been certified by SAMHS/NIDA. 

All confirmation test results will be forwarded to the Ten (10) panel. The panel 

will notify the Company of the results of the confirmation test (pass or fail).

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D. Searches

The Company reserves the right to conduct random searches of equipment and 

personal property, including vehicles located in or on, or brought in or onto the 

Company property, work sites or equipment. The Company also reserves the right 

to use other investigative methods when reasonable suspicion exists to indicate 

possible drug and/or alcohol possession, abuse or impairment. All locks used on 

the Company property or equipment must be issued by the Company and are the 

property of the Company. Refusal to cooperate in the conducting of a search 

provided for in this provision will be considered a violation of this Policy.

16.5 Employee Assistance 

It is the responsibility of each employee to voluntarily seek assistance for a drug or alcohol

problem before a test is required, or the problem otherwise leads to disciplinary action. In order 

for an employee’s decision to seek assistance for a drug or alcohol problem to be considered 

voluntary, the employee must seek such assistance prior to being referred to a collection site for 

the purposes of obtaining a drug or alcohol test and prior to being identified as violating the 

Company rules. Once a violation of any of the Company rules has been identified, subsequent 

requests for assistance for a drug or alcohol problem will not lessen the disciplinary action for 

the rule violation.

Any employee who successfully completes an evaluation, treatment and/or rehabilitation 

program, whether the employee voluntarily sought assistance or not, shall, as a condition of 

returning to the workforce, be required to enter into a “Conditions for Reinstatement or Rehire”

Agreement (the “Agreement”). Pursuant to this Agreement, the employee will be required to 

consent to be tested for drug and/or alcohol, with or without cause, and without notice. An 

employee who voluntarily has sought assistance will be subject to such testing for nine (9) 

months following his or her return to work. An employee, who completes any treatment or 

rehabilitation program involuntarily, as defined above, shall not be eligible for hire or rehire for 

twelve (12) calendar months from the date of the violation, as set forth in Section III.F. above. 

The Agreement also will require, as a condition of continued employment, that the employee 

follow all prescribed after-care treatment.

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17.0 SAFETY AND QUALITY FORMS

Holtec International’s power plant operations include field services as well as manufacturing of 

parts, components, and structures. Holtec International holds safety of the company’s associates 

engaged in physical activity to be a central corporate focus. The sections in this chapter 

summarize some of the pro-active steps taken by the Company to raise safety awareness and to 

implement processes to improve safety performance of Company associates, contractors, and 

visitors to our plants.

17.1 Required Action Before Granting Access to a Visitor to a Holtec Manufacturing 

Facility

The attached Holtec Form HR-20 (Exhibit 17.A) is implemented across all Holtec manufacturing 

locations. This form requires the Plant’s Safety Manager and his or her superiors to evaluate the 

risk to the person of a visitor before granting access to the plant’s work areas – no exception.

Form HR-20 is intended to keep visitor’s from placing themselves in harm’s way. The Company 

will continue to treat the safety of people as the paramount consideration in all of our plants. As 

has been stated to our managers many times, those who place productivity before safety will end 

up with neither. All of our plant managers and executives are encouraged to keep the banner of 

safety flying high at all times at all of Holtec’s plants and construction sites where we are 

deployed.

17.2 Holtec Safety Bulletin

The Holtec Safety Bulletin is developed and distributed periodically by the Corporate Safety 

Manager to educate the Company’s workers in safe work practices by using lessons learned from 

ongoing operations. The template of the Safety Bulletin is provided in Exhibit 17.B.

17.3 Vow of Safety

The Vow of Safety is a declaration of every shop worker’s commitment to uphold safety as the 

paramount goal. A sample vow of safety is provided as Exhibit 17.C.

17.4 Safety Policy and Principles

The Holtec Safety Policy and Principles were developed by the Holtec State Certified Safety 

Committee to be utilized as the foundation of all safety and health related processes and 

employee actions. The Safety Policy and Principles is provided as Exhibit 17.D.

17.5 Safety and Health Programs

The Holtec Safety and Health Programs outline clearly stated work rules that are to be followed 

to protect workers and allow for safe operation of all Holtec facilities. All employees have the 

responsibility to know and follow safe work practices. Employee safety and health has been and 

will continue to be an integral part of everything we do at Holtec.

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18.0 MISCELLANEOUS ITEMS 

18.1 Questionnaire for Prospective Manufacturers as Holtec’s Team Partner

The questionnaire below is intended to obtain basic data on prospective manufacturing team 

partners to help determine the Company’s eligibility for further evaluation.

1. Date Company was founded.

2. Annual Sales (provide sale of the subsidiary or division if the Company operators through 

autonomous subsidiaries)

3. Number of salaried personnel at the plant

4. Number of shop production personnel

4a. Number of welders

4b. Number of mechanics

5. Number of QA/QC personnel

6. Shop fabrication area (square feet)

7. Maximum overhead crane capacity (tons)

8. Has any violation of national/local worker safety regulations over the past three years 

occurred in the plant? If so, please provide data

9. Is the shop unionized?

10. Is the candidate plant willing to enter into an exclusive relationship with Holtec 

International?

11. Please provide brief data on the experience and background of the business units' top 

management

12. Please describe prior (if any) experience in manufacturing products/systems that will be 

covered by the proposed teaming agreement

13. Does the plant have a nuclear QA program? If so, please provide a copy of the Quality 

Assurance Manual

14. Does the plant possess any national certifications (such as the ASME Code stamps)? If 

so, please provide copies of certificates

15. Please provide the number of components delivered in the past 12 months, and the 

percentage of that number that was delivered on time

16. Please provide the number of reportable injuries per 100,000 manhours worked in the 

plant

17. Please list the types of materials that the plant has worked with in the past three years 

(such as carbon steel, stainless steel)

18.2 Process for Shipping Holtec Components

Once the component has been fabricated, tested and inspected in accordance with the 

requirements of the appropriate IPR (Inter-Division Purchase Requisition), the process of 

shipping the component from a Holtec’s manufacturing facility involves the following steps:

1. As required by the IPR, a shipping release must be obtained from the client before 

arrangement for shipping can be made.

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2. Once the shipping release has been obtained from the Client then the shipping Logistics 

Manager at the Manufacturing Facility makes the arrangement for shipping the 

component to the Client’s Site.

3. The shipping and arrival dates are established by close coordination with the Client. 

When the offloading of the equipment at the site is part of Holtec’s work scope then 

Holtec’s Site Services personnel are also contacted by the Logistics Manger to coordinate 

the shipping and arrival dates. 

4. Once the shipping and arrival dates have been established then the PLM/Scheduler from 

the manufacturing facility will issue a Notice of Imminent Shipment form (see attached 

Exhibit 18.A) to Group1@holtec.com e-mail distribution group and to the Client 

notifying everyone of the impending shipment of the equipment. Group1 e-mail 

distribution group includes all NPD Project Managers, Site Services Personnel and

Accounts Payable personnel. This notice is sent to help alert our Clients for the upcoming 

equipment shipment to ensure that the site is prepared (i.e. security clearances) to receive 

the equipment. The PLM/Scheduler is advised to transmit this notice approximately two 

weeks before the scheduled ship date of heavy equipment such as HI-STORM and one 

week prior to the scheduled ship date of small packages such as ancillaries.

5. Finally, on the day of the equipment shipment from the manufacturing facility, the 

Shipping logistics Manager issues a Shipping Manifest (see Exhibit 18.B) notice to 

Group1 email group and the Client informing everyone that equipment has shipped and it 

is on its way to the Client site. The Shipping Manifest form contains information on the 

Truck Driver, type of equipment, quantity, weight, expected arrival date, etc.

18.3 Position Papers: Formatting and Filing

Filing of the position papers and the Table of Contents is by the Administration Department’s 

Administrative Assistant.

18.3.1 How to Obtain a Position Paper Number

A. Provide the author(s) name and paper title to the Administrative Assistant so a 

placeholder file can be placed in the Position Paper directory while the paper is being 

prepared, to avoid inadvertent duplication of numbers assigned. Alternatively, to obtain a 

sequential number for the paper, follow these steps: 

1. Obtain the next sequential number from the appropriate word file 

subdirectory:

 Dry Storage (DS) Position Papers

 Heat Exchange (HX) Position Papers

 Wet Storage (WS) Position Papers

2. Confirm that that next sequential number hasn’t been used by also checking the 

PDF directory and the Table of Contents for that category (DS, HX or WS). This 

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cross-reference is necessary in the event another individual pulled a number for 

use but didn’t make a placeholder in the PDF directory (i.e., made a placeholder 

file in word files, but not in the PDF files, or vice-versa).

Note: Some papers have their own subdirectory when there are many files relating to that 

paper. 

18.3.2 Organization and Formatting

Organization of the paper is by the author, but please note:

A. A list of figures and/or attachments can be added at the end of the text (and should be 

if some or all of the figures, attachments and/or appendices cannot be made 

physically part of the word file).

B. When a paper is in draft stage, consider putting a DRAFT watermark on all pages in 

addition to listing it as Draft in the header. 

C. Assign the paper Draft status when it’s under preparation and change it to Revision 0 

when it’s final. (For example, don’t assign a status of a “Revision 0 Draft”.)

18.3.3 Header and Footer

A. The verbiage exactly as given in (B) below is required for the header and footer.

B. The header must contain the following information:

Holtec International Position Paper DS-XXX

Title

Author(s)

Revision Number and Revision Date 

Note Regarding Header Information

Some authors have omitted the author and revision date in the header either because they have 

included a revision log at the end (if QA-validated) or inadvertently. 

Whether or not the paper contains a revision log and signatures at the end of the paper, the 

header should contain the author and revision number and date. 

C. The footer must contain the following information:

If the paper is not QA-validated the footer contains: 

Holtec International Proprietary Information

Unless otherwise explicitly stated, Position Papers are not QA-validated documents.

Page X of X

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If the paper is QA-validated the footer contains:

Holtec International Proprietary Information

This Position Paper is a QA-Validated Document.

Page X of X

Note Regarding the Footer Information and the PDF File 

If the PDF file contains pages (figures, attachments, or appendices) that can’t physically be made 

part of the word file, add the same footer to those pages of the PDF file that fall after the page 

where the actual footer ends, to ensure that the phrase Holtec International Proprietary 

Information is contained on all pages.

18.3.4 Filing of Position Papers

A. Send the word file or both the word file and the PDF file to the Administrative 

Assistant for filing electronically and filing a hardcopy (the current revisions of 

papers are kept in 3-ring notebooks for reference).

B. If you file the paper electronically, notify the Administrative Assistant so the 

Table of Contents can be updated and so that the most current revision can 

be filed in the 3-ring books. 

C. g:\generic\position papers\dry storage word files\current folder of DS Word files

g:\generic\position papers\dry storage PDF files\current folder of DS PDF files

Wet storage and heat exchange papers directories are named ...”WS Word files”, 

etc.

D. Name the file “DSxxx Rev Draft...” or DSxxx Rev 0” so it falls in sequence in 

the directory listing.

E. When the paper becomes officially Revision 0, the word “draft” should be 

dropped from the paper’s header and the file name.

F. Name files that contain only the figures and/or attachments with the same prefix. 

Example: DS264 Rev 0 Attachment A....

G. Filing of subsequent revisions beyond Revision Draft or Revision 0:

1. Each position paper directory contains a “Review File” subdirectory to store 

earlier revisions of the papers. 

2. So long as complete versions of the old revision (word file and PDF file) are 

archived in the Review folders, the hardcopy of the old revision will be 

discarded and replaced with the current revision.

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3. The overall directory for Position Papers (n:\generic\position papers) also 

contains a subdirectory:

g:\generic\position papers\Archives of Earlier Papers All Categories

18.4 Memo to Clients to Secure Permission to Publish Holtec Highlights

All requests to the client should go out with the following standard text:

" Dear xxxxx,

The attached issue of Holtec Highlights focuses on a product or service that bears a nexus to one 

or more contracts with your company being executed by Holtec International. While we have 

taken utmost care in crafting this publication, we request you review the attached text matter to 

ensure that its contents are fully in keeping with your (our client's) interests. As a matter of 

policy, the purpose of Holtec Highlights is to share significant technology or business 

developments with our stakeholders; as a matter of policy we don't disclose commercial or 

sensitive technical data in our press releases.

We would appreciate your no-objection email (or any proposed changes you may wish to make) 

by next [fill in day] to enable us to maintain the publication schedule.

Thank you."

18.5 Patents and Trademark Registrations Granted to Holtec International

The following is a near-current list of patents and trademark registrations that have been granted 

to Holtec International.

Patent Title Patent Number Date of Patent

Tube Bundle Support 4,579,304 April 1, 1986

Non-Segmental Baffles 4,595,161 June 17, 1986

Honeycomb Fuel Basket 5,898,747 April 27, 1999

Radiation Absorbing Refractory Composition 5,965,829 October 12, 1999

Extrusion Fabrication Process for Discontinuous 

Carbide Particulate Metal Matrix Composites and 

Super Hypereutectic A1/SI

6,042,779 March 28, 2000

HI-STORM Overpack 6,064,710 May 16, 2000

External Steam Dump 6,481,208B1 November 19, 2002

Duct Photon Attenuator 6,519,307B1 February 11, 2003

HI-TRAC Operation 6,587,536B1 July 1, 2003

Daearation of Makeup Water in a Steam Surface 

Condenser

6,619,042B2 September 16, 2003

Cask Mating Device

(Hermetically Sealable Transfer Cask)

6,625,246B1 September 23, 2003

Improved Ventilator Overpack 6,718,000B2 April 6, 2004

Below Grade Transfer Facility 6,793,450B2 September 21, 2004

HERMIT (Seismic Cask Stabilization Device) 6,848,223B2 February 1, 2005

Cask Mating Device (Divisional) 6,853,697 February 8, 2005

Davit Crane 6,957,942B2 October 25, 2005

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Patent Title Patent Number Date of Patent

Duct-Fed Underground HI-STORM 7,068,748B2 June 27, 2006

Forced Helium Dehydrator 7,096,600B2 August 29, 2006

Below Grade Cask Transfer Facility 7,139,358 B2 November 21, 2006

Forced Gas Flow Canister Dehydration 7,210,247 B2 May 1, 2007

Fin Tube Assembly for Heat Exchanger and 

Method

7,293,602 B2 November 13, 2007

HI-TRAC Operation (Maximizing Radiation 

Shielding During Cask Transfer Procedures)

7,330,525 February 12, 2008

HI-STORM 100U 7,330,526B2 February 12, 2008

Flood Resistant HI-STORM 7,590,213B1 September 15, 2009

HI-STORM 100M 7,676,016B2 March 9, 2010

Dew Point Temperature Based Canister 

Dehydration

7,707,741B2 May 4, 2010

Lateral Access Fuel Rack 7,715,517 B2 May 11, 2010

Trademark Name Registration 

Number

Date of Registration

HI-TRAC 2,564,194 April 23, 2002

HI-STORM 2,556,261 April 2, 2002

HI-STAR 2,961,795 June 14, 2005

Notes:

1. Because the Patent Titles assigned by the U.S. Patent and Trademark Office that are on 

the actual patent are generic descriptions (i.e., it’s difficult to distinguish one patent from 

another by its title alone), the Patent Title in the table above is the title that Holtec uses to 

refer to that patent to distinguish our various equipment patents. 

2. Use of Trademark (Paragraphs (a) and (b) below are extracted from correspondence from 

the Patent Attorney):

a. A trademark registrant should use “Registered in U.S. Patent and Trademark 

Office” or “Reg. U.S. Pat. & Tm Off.” or the letter R enclosed with a circle 

following the mark. The designation “®” should accompany the mark whenever it 

is used in conjunction with the goods listed in the registration. (Note: until a 

trademark is actually granted, the superscript mark  should be used.)

b. A trademark should always be used as an adjective (never as a noun) followed by 

the noun that describes the product. This usage will help maintain a trademark’s 

status as a source of a particular brand of product, rather than the common name 

for the product itself. Once a trademark becomes the common (or generic) name 

of a product, it can be used by anyone to designate that product. 

3. It isn’t necessary to use the ® symbol each time it’s used within one piece of writing (a 

single letter or a single document). The symbol can be used throughout or it can be used 

the first time the product is referred to in the document. But, if the document has multiple 

sections or chapters, it should be used at least once (first occurrence) in each. The ® 

symbol is superscript.

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4. The CEO’s Administrative Assistant maintains copies of the patents and the trademark 

registrations. Accounting maintains the originals. 

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Exhibit 4.A to Chapter 4

MINUTES-OF-THE-MEETING

Holtec International / 555 Lincoln Drive West / Marlton, New Jersey 08053

www.holtecinternational.com

Holtec 

Project No.

Date of 

Meeting

Place of Meeting

Participating 

Organizations

Subject 

of 

Meeting

Names of Participants (indicate 

those who attended part-time or by 

video conference). A signed 

attendance list may be attached in 

lieu of a typed list (indicate in next 

column if attached). 

Prepared by Verified 

by

Summary of Discussions

(Continue on a Second Page, et. seq. as necessary.)

Commitments Made

Task Due Date Responsible Party

This template must be used to document and memorialize the substantive discussions that occur in a 

meeting on a Holtec project. The contents of these minutes must be verified by a second participant in the 

meeting. The verifier should preferably be from the interfacing organization. The preparer must be a 

meeting participant from Holtec.

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Exhibit 5.A to Chapter 5 

AGREEMENT TO PROTECT CONFIDENTIAL INFORMATION 

(For Illustration Only)

1.1 Definition. 

The term “Confidential Information” shall mean all information or enhancements which relate to 

past, present, and future research, development, and business activities of Holtec or Client and its 

Affiliates, including inventions, discoveries, formulas, processes, devices, methods, 

compositions, compilations, system plans, flow charts, source codes, algorithms, procedures, 

data and other proprietary information of Holtec or Client.

1.2 Exclusions. 

Confidential Information shall not include:

1.3 Information lawfully known to Holtec prior to the performance of such Work other 

than through other work with or for Client; or

1.4 Information that is publicly disclosed through no act of Holtec, Subcontractors or any 

of their respective employees, either prior or subsequent to Client’s disclosures of such 

information to Holtec.

1.5 Holtec’s Obligations. 

During the term of this Agreement and thereafter, except as the Client may authorize in writing, 

Holtec shall and shall cause its associates and Subcontractors to:

1.6 Treat and cause to be treated as confidential all Confidential Information;

1.7 Use Confidential Information only in connection with the performance of Work pursuant 

to this Agreement or the Blanket Purchase Order and/or the Purchase Order Release for a 

Specific Project;

1.8 Make copies of any tangible embodiment of Confidential Information only as necessary 

for the performance of such Work;

1.9 Remove any tangible embodiment of Confidential Information from the premises of 

Client only with the express written permission of Client; and

1.10 Return any and all tangible embodiments of Confidential Information to Client

promptly following the request of Client, and in any event upon completion of Work 

pursuant to the Agreement or the Blanket Purchase Order and/or the Purchase Order 

Release for a Specific Project.

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Exhibit 5.A to Chapter 5 

AGREEMENT TO PROTECT CONFIDENTIAL INFORMATION 

(For Illustration Only)

(Continued)

1.11 Disclosure Pursuant to Court Order. 

Notwithstanding the foregoing, Holtec may disclose Confidential Information to the extent that 

disclosure is required by a court or other governmental agency of competent jurisdiction, 

provided that Holtec shall provide notice to Client of the request for such disclosure promptly 

upon receiving it.

1.12 Irreparable Harm. 

Holtec and Client acknowledge that the breach of any of the covenants contained in this Article 1

will result in irreparable harm and continuing damages to the other party and its business, and 

that the remedy at law for any such breach or threatened breach would be inadequate. 

Accordingly, in addition to such remedies as may be available to the parties at law or in equity in 

the event of any such breach, any court of competent jurisdiction may issue an injunction (both 

preliminary and permanent), without bond, enjoining and restricting the breach or threatened 

breach of any such covenant, including, but not limited to, an injunction restraining the violating 

party from disclosing, in whole or in part, any Confidential Information. The losing party shall 

pay all of the prevailing parties’ costs and expenses, including reasonable attorneys’ fees and 

accountants’ fees, incurred in enforcing such covenants. 

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Exhibit 8.A to Chapter 8

NOTICE OF COST and SCHEDULE IMPACT 

Issuer: Holtec Manufacturing Division / 200 Braddock Avenue, Turtle Creek, PA 15145

HMD uses this notice to request action by an internal or external Client to avert the risk of an impending cost 

and schedule impact and later to notify the Client if a cost event occurs.

NCI Number 

(Number sequentially in a year 

(viz., 2008-1)

Rev. No. Date of 

Issue

Issuer Purpose

Rev. 0

Project No. Rev. 1

Type of Notice (See Note 2) Rev. 2

Client (viz., NPD) Ultimate 

Client

HMD PLM’s Name PM (If 

Known)

Client PM Cost 

Category 

(R, M, or S)

(Note 1)

LIST OF ITEMS AFFECTED

Item Name

Item I.D. in 

Production 

Schedule

Last date for receiving 

release before rescheduling 

cost will accrue (for R or M

cost category)

Date when suspension cost 

becomes effective 

(for S Cost Category)

EXPLAIN THE BASIS FOR THIS NOTIFICATION BELOW

Continue on the next page, if required.

Process

First, this notice will be Issued by the HMD Scheduler or PLM in sufficient time to help NPD (or an external client, as the 

case may be) take remedial measures to avoid the cost of rescheduling of work. The PLM shall issue this notice on a 

suspended project as soon as a forced suspension occurs. Second, if the cost impact does occur, then the HMD 

controller will provide a final tally of the accrued charges at a suitable point in time to the client (viz., NPD, PPCD, or to 

an external HMD customer), such as, after the cause underlying the cost impact has been removed and work has 

resumed. 

The tally of charges from the Controller is attached: (Yes/No) 

(Use $AM-111 and/or $AM-112 to compute the extra charges.)

Distribution: This form shall be e-mailed to the Client’s Project Manager, EXCOM, FABMAN, MIDMAN, and Group1. 

The Corporate Finance Department will keep a log of NCIs. 

Note 1: Legend

R: HMD being forced to reschedule the work because of lack of timely manufacturing release.

M: HMD being forced to reschedule the work because of failure on the Client’s part to deliver the material under the

 provisions of the IPR. 

S: Work suspended by the Client, resulting in under-utilization of HMD’s facilities. 

Note 2: Legend

I: Notice of Impending Risk of Cost. II: Notice by Controller of Cost Incurred

Note 3: Purpose can be either “warning” of an impending cost (“warning”) or notification of accrued and/or 

accumulating cost (“notification”).

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Exhibit 8.A to Chapter 8

(continued

NOTICE OF COST and SCHEDULE IMPACT 

(continued)

EXPLAIN THE BASIS FOR THIS NOTIFICATION BELOW

Continue on this page, if required.

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Exhibit 10.A to Chapter 10

TRAVEL AUTHORIZATION FORM

(Form HR-28)

Name of Associate

Travel Dates

Destination

Purpose of Travel (if project related indicate

Project number) and name of client or Holtec 

Supervisor that is requesting the travel

Are the travel arrangements being made greater 

than two (2) weeks in advance?

Yes/No

If “No” please provide explanation

Total Estimated Cost

Name 2 Sources Used for Rates (Travel 

Counselor should be one of the sources)

Airfare Cost

Hotel Cost

Car Rental Cost

Associate’s Signature / Date

Supervisor’s Signature

Corporate Accountant Signature / Date

NOTE: FAILURE TO HAVE THIS FORM SIGNED PRIOR TO ANY TRAVEL 

ARRANGEMENTS WILL RESULT IN THE REJECTION OF YOUR EXPENSE 

REIMBURSEMENT REQUEST. 

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Exhibit 13.A TO Chapter 13

DAMAGE REPORT ON ERRONEOUS WORK (DREW)

DREW is a citation issued to any person identified to have committed an error that could endanger safety or quality or that has been 

costly in reputation or treasure to the Company. DREW is submitted to the Corporate Human Resources Department for 

recordkeeping along with advice for further action.

All Holtec personnel, including those in design, analysis, manufacturing, site services, sales, and project management are subject to 

DREW citation.

Name of Cited Personnel

Name of Cited Personnel’s Supervisor

Date of Citation

Reference Holtec Project No. (if applicable)

Reference QPV No. (if applicable)

Name of Holtec Division

Summary of Error

Consequence of Error

 Loss of funds to the Company; estimated amount $________________

 Damage to the Company’s image with the Client: Name the client ______________________

 Rework and Increased risk of scheduler non-performance

 Increased risk of causing an unsafe working environment

 Increased risk of error in manufacturing or site services

Cause of Error – Manager’s Input

 Inattention to detail

 Insufficient understanding of the task being worked on

 Inadequate background/training

 Cavalier attitude

Cause of Error – Associate’s Input (must be provided within 24 hours of receipt)

 Individual pressured to produce work without regard to quality

 Oppressive and stifling work environment

 Poor supervisory guidance 

 Other: Please explain

Executive Determination (by a Member of the Executive Committee)

Severity of Error:

1: Damage, d, is less than $1,000; no schedule impact (S = 0)

2: 1< d <$10,000; no schedule impact (S = 0)

3: 1K < d < 10K; at least one week schedule impact (1<S<4)

4. 10K < d < $50K (S > 4)

5. $50K < d <$100K; over 1 month schedule impact

Distribution: (1) Cited person, (2) His/her supervisor (3) Human Resources Department (4) Executive 

 Committee

Form No. HR-41 Rev. 0 June 2010

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Exhibit 13.B to Chapter 13

CITATION FOR MERITORIOUS WORK 

This citation may be issued to a Holtec associate for a distinguished work effort that is deemed 

by the associate’s superior(s) to be of high caliber and to have been instrumental in meeting a 

critical corporate commitment. The issuer may be a member of the Executive Committee 

(EXCOM), middle management (MIDMAN), or a department head (TECHEADS). No issuer 

may issue more than three citations in a calendar year (average one in a 4-month period). 

Associate’s Name

Associate’s Employer Number

Date of Citation

Issuer’s Name

Relationship with the Recipient 

Period of Work for which this 

citation is made

Area of Distinguished Performance

Check Box

1. Completed a project or task on an extremely tight schedule 

2. Developed an innovative solution to technical problem 

3. A long period of error-free work 

4. Other (Please explain below.) 

Basis for Citation

Notes

1. Internal dissemination: This citation may be shared only with the associate or with 

his/her peers at the discretion of the issuer.

2. Non-Disclosure Third Parties: Holtec HR forms are Company confidential documents. 

Forwarding them to a third party except by those Company personnel who are explicitly 

so authorized by a member of the Company’s Executive Committee is a violation of 

Company policy. All Company associates are expected to abide by this non-disclosure 

policy to maintain a good standing within the Company. 

3. Distribution: (a) Recipient (b) Executive Committee (c) Personnel File (d) Issuer

Form No. HR-44 Rev. 0, January 2010

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Exhibit 13.C to Chapter 13

DEMERIT NOTICE

The Demerit notice is issued to any associate who exhibits a sub-part activity or behavior. The 

Demerit Notice is issued by the individual’s immediate supervisor or any upstream 

Manager/Executive based on the ongoing assessment of the conduct of individuals. The 

Demerit Notice may also be issued by the Company’s QA Manager to a Company associate 

found to commit excessive quality infractions. The Demerit Notice will be issued only after an 

associate has been verbally advised by his supervisor to amend the deficiency but the associate 

has failed to do so. Any person who accumulates more than ten points in a year may be placed 

on probation or dismissed at the discretion of the Company’s Executive Committee. 

Associate’s Name Associate’s Number

Date Issued Location

Activity

Max. No. of 

Demerit Points 

that May be Given

Actual Number of 

Points Given

1. Often late to work. 5

2. Frequently fails to complete assigned 

tasks in assigned time.

5

3. Socializes excessively. 5

4. Frequently found surfing the Internet

(sites unrelated to Holtec’s business). 

5

5. Often speaks unfavorably of colleagues 

and/or the Company or spreads rumors (a 

“bad apple” behavior).

5

6. Excessive number of errors in the 

associate’s work product, QPVs, etc.

5

Provide to the affected associate and his supervisor. File a copy in the Associate’s Personnel 

File. 

Form HR-42 Adoption Date: March 1, 2010

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Exhibit 13.D to Chapter 13

Notice of Reprehensible Conduct (NRC)

Issued to Position

Associate’s 

Employee 

Documentation Number

Location of 

Employment

Sponsoring Holtec 

Executive 

Date

Concurred by Date

Reason for Issuance of NRC

Violation Category Check Box 

1. Willful violation of the Corporate Governance Procedure (HSP-1001) 

2. Unethical Conduct 

3. Activities disloyal to the Company 

4. Violation of the Terms of Employment 

5. Surreptitious use of the Company’s funds for personal benefit 

6. Insubordination 

7. Violation of the Holtec Employee Manual 

8. Rendering services to others in the associate’s area of expertise (moonlighting) 

Summary of Reprehensible Conduct

Both the executive who issued and the one who concurred must agree with the basis of citation provided 

below (be brief and specific).

Recommendation

This notice shall be held confidential within the Executive Committee: It shall be archived in the 

associate’s Personnel File. This notice may be hand delivered to the addressee/associate at the discretion 

of the HR Manager. 

________________________________

Sign Here

Form HR-40 Adoption Date: March 1, 2010

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Exhibit 14.A TO Chapter 14 

List of Training Modules

TRAINING FOLDER SUB CATEGORY DESCRIPTION

Contracts N/A Contracts: General Overview and Responsibilities)

Corporate Governance N/A Corporate Governance

Technical Licensing FSAR Writers Guide

Technical Licensing Certificate of Compliance (10CFR71 & 72)

Processes 72.48 72.48 Training Module- Overview

Processes CCR CCR Preparation

Processes Drawings/ECOs ECO Base Form

Processes SMDR SMDR Base Form

Project Management N/A How to be an Outstanding Project Manager

Processes Procurement Procurement Flow Chart

Processes Drawings/ECOs Drawings- Module 1: Drawings and ECOs

Processes Drawings/ECOs Drawings- Module 2: Drawing Reviews

Processes Drawings/ECOs Drawings- Module 3: Fabricability

Processes Drawings/ECOs Drawings- Module 4: Drawing Review Refresher

Processes Drawings/ECOs Drawings- Module 5: Standards

Technical Applied Mechanics

ASME Code- Module 1 (Stress Limits, Weld Cat., 

Serv. Cond.) 

Technical Applied Mechanics Seismic and Structural Basic Applications

Technical Nuclear Computer Review Guide

Processes Procurement Dedication and Quality Plans

Quality N/A Surveillance

Quality N/A Impact of a Discrepant Condition

Quality N/A ITS Classification

Project Management N/A Overview of Project and Program Management

Quality N/A Procedure Compliance, Self Checking and Review

Quality N/A Overview of QA Program

Site Services Rigging Rigging Manual

Site Services Rigging Rigging Handbook

Processes Reports Error Free Reports

Project Management N/A Client Communication

Quality N/A Root Cause

Quality N/A Auditing

Site Services HI-STORM HI-STORM Site Preparation- Module 1

Site Services HI-STORM HI-STORM: Concrete Overview- Module 2

Site Services HI-STORM HI-STORM: Site Work Activities- Module 3

Site Services HI-STORM HI-STORM: HSP-170- Module 4

Miscellaneous N/A ASME Code Overview

Miscellaneous N/A ASME Code- Section III- Article 2000

Miscellaneous N/A Dry Storage 101 (Note 5)

Miscellaneous N/A Wet Storage 101 (Note 5)

Miscellaneous N/A Criticality Overview (Note 5)

Miscellaneous N/A Radiation Overview (Note 5)

Quality N/A Human Performance

Note 1: New training programs may be added to this matrix. Position only needs to complete training in place at that time. 

Personnel’s individual training matrix identifies what training was completed at that time. Long time employees records 

may not include a matrix. 

Note 2: Read and sign of HSP-1001 is acceptable alternative.

Note 3: Must have specific training in this area prior to performing activity.

Note 4: Training as required based on work activities. 

Note 5: May be used as an option for indoctrination of new personnel when so identified on the individuals personnel training 

matrix.

Note 6: Only required for those stating wok in Part 71/72 projects. 

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Exhibit 14.B to Chapter 14

ILLUSTRATIVE TRAINING TABLETS

Shown on the Following 2 Pages

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Exhibit 15.A to Chapter 15

CONFIDENTIAL PEER REVIEW OF HOLTEC PERSONNEL

Please rate your colleagues under the five categories (only those you interact with sufficiently to have a well-formed opinion). 

Select five individuals whom you work with or of whom you have sufficient knowledge to provide input.

Give a rating between 1 to 5: 1 is poor, 2 is below average, 3 is average, 4 is good, 5 is excellent. This form should be filled out anonymously; management does not need to know the 

rater's identity. 

Name

Is most 

competent in 

the position he 

or she is in.

Is an excellent 

team w orker

Is very 

industrious, 

highly 

dedicated to 

his/her w ork.

Is a loyal 

corporate 

citizen

Assumes 

responsibility 

and attempts to 

meet deadlines

Show s self 

initiative and 

drive

Makes effort to 

improve ow n 

and others’ 

productivity

Remarks

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Exhibit 15.B to Chapter 15

Confidential Review of Holtec Executive Personnel

Please rate those management personnel with whom you are well enough familiar to provide constructive input, for the categories listed below and using the 

following numerical ratings: 1. Poor 2. Below Average 3. Average 4. Good 5. Excellent 6. N/A: Not Applicable

This form should be filled out anonymously; Holtec’s Executive Management does not need to know the rater's identity. Return the form by e-mail to the Human 

Resources Department within one week of the issuance of this form. When all forms have been returned, a summary of the results will be made available to each 

Company manager for self-improvement purposes. The object of your comments will not know your identity. 

IN YOUR VIEW, THE NAMED MANAGER:

Fosters an environment of merit-based reward.

Fosters a professional/cooperative working environment.

Fosters a “can do” environment.

Is an industrious Company manager.

Is intensely loyal to the Company’s growth and success.

Provides leadership to make project execution an 

efficient process.

Sets clear goals and objectives.

Is even-tempered and readily approachable.

Is genuinely interested in my career growth.

Emphasizes with my work-related problems and seeks 

to help me solve them.

Is competent in assisting me in my area of activity.

Does not suffer from indecisiveness.

Displays a high level of personal involvement in 

ensuring worker safety (personal commitment to safety)

Displays an appropriate regard for quality assurance 

(commitment to quality assurance) 

Displays a sense of urgency to meet schedule 

commitments. 

Is focused on improving worker productivity.

Acts to improve morale through words and actions.

Rewards subordinates based on merit (no favoritism).

Loyal to the main objectives of the Company 

(minimization of waste, increased productivity, increased 

revenues, worker safety, prevention of theft, QA).

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Exhibit 16.A to Chapter 16

Holtec International

CONDITION OF REINSTATEMENT OR REHIRE

I understand that my admitted use or abuse of drugs or alcohol as defined in the Company 

Drug, Alcohol and Substance Abuse Policy has raised a question about my ability to 

satisfactorily perform work for the Company consistent with its performance standards and 

applicable regulations. Accordingly, my reinstatement to employment or rehire by the Company 

is conditioned upon and subject to the following terms:

1. I will undertake treatment at ______________________________________.

2. I will participate in such program until successful completion thereof.

3. I will comply with all of the program’s requirements, both during treatment and 

following completion thereof.

4. My reinstatement will be expressly contingent upon and subject to the written 

final report issued by (______________________________), and I hereby 

authorize the release of that report and all related documents to the Company.

5. Following reinstatement, I hereby authorize the Company to require appropriate 

screening tests for drug and/or alcohol use on a random basis or whenever 

supervisory personnel have reasonable suspicion to believe that I may be under 

the influence of drugs and/or alcohol.

6. Should I refuse to take such tests, I understand that I shall be discharged 

immediately.

7. I understand that my previous job performance justifies close supervision for an 

extended period of time upon my return to work, and I will accept such 

extraordinary supervision as a condition of my employment.

8. I understand that upon my return to employment, I am required to meet all 

applicable regulations and all of the Company’s established standards of conduct 

and job performance, and that I will be subject to the Company’s established 

disciplinary and other applicable procedures for failure to meet such standards.

9. I will be subject to the terms of these conditions of reinstatement until I have 

completed nine (9) calendar months of work from the date of my reinstatement. 

Upon completion of that period, my job performance and recovery process will be 

reviewed to determine whether the terms of this agreement will be modified or 

sustained.

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Exhibit 16.A (continued)

Holtec International 

CONDITION OF REINSTATEMENT OR REHIRE

10. I understand that my failure to meet any or all of the above requirements will 

constitute “just cause” for the Company to terminate me.

11. Nothing contained herein shall be construed as a waiver of the Company’s rights 

to take normal disciplinary action against me under existing policies and 

procedures for unsatisfactory work performance or other misconduct. My use of 

or treatment for use of drugs or alcohol shall not constitute a mitigating 

circumstance.

Dated this ____ day of ______________, 20____.

Signed:

____________________________________

Employee, Agent or Contractor

__________________________________ By: _______________________________

Witness

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Exhibit 16.B to Chapter 16

Holtec International

TESTING CONSENT FORM

PLEASE READ AND SIGN BEFORE THE SAMPLE IS GIVEN

I , ________________________ hereby consent to provide urine, blood and/or breath sample for 

drug and/or alcohol testing and hereby authorize the release of the results of such tests to the 

Company for decisions relating to my employment, disciplinary action, and/or continued 

employment. I also hereby expressly release the Company from any and all liability of any 

arising from the taking of the sample(s), the testing procedure, or the release or use of this 

information.

I have taken or am taking the following drugs, prescription medications, or non-prescription 

medication within the past 30 days:

Name of Drug Condition Physician Dosage

__________________ __________________ _________________ __________

__________________ __________________ _________________ __________

_________________ __________________ _________________ __________

___________________________________ ______________________

Signature Date

___________________________________ ______________________

Print Name Social Security Number

Please read and sign AFTER THE SAMPLE IS PACKAGED ACCORDING TO THE CHAIN 

OF CUSTODY PROCEDURE:

I acknowledge that the urine and/or blood sample(s) I have provided is my own. Further I attest 

that my social security number was written on the sample container’s label, I initialed the label, 

the sample container was sealed with confidentiality tape, I initialed the tape, the sample was 

placed in a plastic bag with the request form and the bag was sealed with confidentiality tape.

________________________________________ ______________________

Signature Date

________________________________________ ______________________

Signature of person handling sample collection Date

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Exhibit 17.A to Chapter 17

Visitor Access Request & Authorization Form

Date of Request (mm/dd/yyyy) Visitor Number

(number sequentially)

Name of Facility Facility Safety 

Manager

Visitor Name Visitor Affiliation

Welcome to our Manufacturing Facility.

Please read the material below carefully. It is intended to familiarize you with the criteria that this manufacturing facility (herein referred to as 

Facility) uses to determine whether to permit access to the Facility by a visitor (non-Facility employee). Please realize that it is unlawful to provide a 

false or misleading response to this questionnaire. 

Please be informed that the Facility Plant Manager and Safety Manager have uncontestable authority (at his/her sole discretion) to deny access to you 

to protect your safety and the safety of others. 

Your responses to this questionnaire will not be shared with your employer or any other non-governmental entity unless so authorized by you or 

requested by a judicial authority. 

Questionnaire Yes No

Part A: Fitness Criteria

1. Have you ever used alcohol that resulted in on-duty impairment or tested positive for illegal drugs? 

2. Have you been subject to a plan for treating substance abuse?

3. Have you been removed from or made ineligible for activities in accordance with a fitness for duty policy: the 

ability to perform job duties in a safe, secure, productive and effective manner??

4. Have you been denied unescorted access to any nuclear power station, shop facility or denied employment in 

accordance with a fitness for duty policy: the ability to perform job duties in a safe, secure, productive and 

effective manner? 

5. Have you consumed alcohol or used recreational drugs within the past twelve hours?

6. Have you ever been convicted of a crime? If yes, please provide details on the reverse side of this form.

7. Has your authorized access to any nuclear power station or shop facility ever been revoked?

Part B: Safety Requirements

1. You will not enter any shop floor area without protective gear.

2. You will wear all protective gear provided to you by the Company for your use while in the shop.

3. You will not linger or socialize on the shop floor.

4. You will not walk outside of marked lanes unless escorted by a Facility Associate.

5. You will not take photographs (or engage in other activities that may distract you from a safety posture on the 

shop floor) without authorization from the plant’s Safety Manager.

6. You will remain alert and take all safety precautions known to you to protect your person from harm.

7. You will keep a watchful eye on the floor and all obstructions around you that may hurt you as you walk the 

shop.

8. You may be requested to submit to a drug/alcohol test.

As the manufacturing facility environment is inherently more challenging than an office, we ask the visitor to evaluate the risk to his/her safety in 

walking through the plant. The visitor agrees that he/she waives any claim or rights to a legal recourse against this Facility arising from physical harm 

to the individual while on the plant’s premises. Long-term visitors who have been given lengthy access privileges are subject to surveillance for 

fitness for continued access. The access rights of an individual may be terminated by the Facility’s Safety Manager.

By signing this form you are certifying that you have read and understand the Safety Requirements in Parts A and B above and that the information 

you have provided is true and accurate.

Signature of Visitor_____________________________ / ______________________________Date:____________

 (Print, Sign and Date)

Access Granted:  Access Denied 

Period for which Access is Granted: From __________________ to _________________

Signature of Approving Authority: ______________________ / ____________________________ Date: ____________

 (Print, Sign and Date) 

Note: The Plant’s Safety Manager is required to scan this completed form and transmit it to Holtec’s Corporate HR Department for record keeping.

 Holtec Form: HR-20

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95

Exhibit 17.B to Chapter 17

Holtec Safety Bulletin

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Exhibit 17.C to Chapter 17

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Exhibit 17 D. to Chapter 17

Keystone Commons, 200 Braddock Avenue, Turtle Creek, PA 15145

Telephone (412) 823-3773 / Fax (412) 823-6669

www.holtecinternational.com

MANUFACTURING 

DIVISION 

Safety Policy and Principles

1. Safety Policy

Safety is an integral part of everything we do at Holtec International; intertwined with 

quality; and woven into the production process so closely that there is no separation. 

2. Safety Principles

 The Safety Principles below are the foundation of all safety and health processes and 

subsequent employee actions. They shall be incorporated into all aspects of the business.

a. We believe that all occupational injuries/illnesses are preventable.

b. We are all accountable for our health and safety.

c. We must always work safely.

d. We are responsible for each other.

e. We will plan "Safety" into our work.

f. We will train employees to work safely.

g. We will measure safety performance.

h. We will resolve all occupational safety and health issues.

i. We will address incidents, not just react to occupational injuries and illnesses.

j. We will eliminate unsafe work practices and unsafe conditions.

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