ML13031A056
ML13031A056
ML13031A056
Electronic
Submissions
to the NRC
August 6, 2021
Revision 9
Note : This document will not appear in the Code of Federal Regulations.
U U
U.S. Nuclear Regulatory Commission
Table of Contents
1. INTRODUCTION .................................................................................................................................. 3
1.1 SCOPE ........................................................................................................................................... 3
2. PARAMETERS FOR ELECTRONIC FILES SUBMITTED TO THE NRC............................................ 3
2.1 FILE FORMATS ................................................................................................................................ 3
2.2 FILE NAMING CONVENTION .............................................................................................................. 5
2.3 FILE SIZE LIMITATIONS FOR EIE SUBMISSIONS ................................................................................. 6
2.4 SECURITY AND ACCESS SETTINGS ................................................................................................... 6
2.5 USE OF COLOR ............................................................................................................................... 6
2.6 HYPERLINKS (FILE LINKS) ................................................................................................................ 7
2.6.1 Required Disclaimers ............................................................................................................. 7
2.7 VIRUSES ......................................................................................................................................... 8
2.8 MACROS ......................................................................................................................................... 8
2.9 SEGMENTATION OF LARGE DOCUMENTS........................................................................................... 8
2.10 TRANSMITTAL LETTERS (NON-ADJUDICATORY) ................................................................................. 9
3. SUBMISSION METHODS .................................................................................................................. 10
3.1 ELECTRONIC SUBMISSIONS THROUGH NRC’S EIE SYSTEM ............................................................. 10
3.1.1 Documents that may NOT be submitted via the EIE system ............................................... 11
3.1.2 Documents submitted under Oath and Affirmation .............................................................. 11
3.1.3 Electronic Submissions in Adjudicatory Proceedings .......................................................... 13
3.1.4 Criminal History Submissions .............................................................................................. 13
3.1.5 General Electronic Submissions .......................................................................................... 14
3.1.5.1 Fitness for Duty Submissions ................................................................................................... 14
3.1.6 Electronic Submissions for License Applications ................................................................. 14
3.1.7 Electronic Forms and Payments .......................................................................................... 14
3.2 EXTERNAL HARD DRIVE AND OPTICAL STORAGE MEDIA (OSM) SUBMISSIONS ................................. 14
3.2.1 Optical Storage Media Submission Criteria................................................................ 15
3.2.1.1 Adjudicatory Filings on OSM .................................................................................................... 15
3.2.1.2 General Submissions via OSM................................................................................................. 15
3.2.1.3 Information that may not be submitted on OSM ....................................................................... 16
3.2.1.4 Documents submitted on OSM under Oath or Affirmation........................................................ 16
3.2.2 How to Submit the OSM ....................................................................................................... 17
3.2.3 Files with Special Printing Requirements ............................................................................. 17
3.2.4 Packaging and Labeling ....................................................................................................... 18
3.2.5 Where to Submit the OSM in Adjudicatory Proceedings ..................................................... 18
3.2.6 Where to Submit OSM for General Submittals .................................................................... 19
3.3 E-MAIL .......................................................................................................................................... 19
3.3.1 What Can Be Submitted via E-mail ...................................................................................... 19
3.3.2 Where to Submit E-mail ....................................................................................................... 20
3.4 FACSIMILE SUBMITTALS ................................................................................................................. 20
3.4.1 What Can Be Submitted by Facsimile .................................................................................. 20
3.4.2 Where to Submit Facsimiles ................................................................................................ 20
4. OTHER SUBMISSION CONSIDERATIONS ...................................................................................... 21
4.1 OTHER 10 C.F.R. PART 2 SUBMISSIONS ........................................................................................ 21
4.2 CLASSIFIED INFORMATION ............................................................................................................. 21
4.3 SAFEGUARDS OR SENSITIVE INFORMATION ..................................................................................... 22
4.4 ACCESSIBILITY .............................................................................................................................. 23
4.5 COPYRIGHT INFORMATION ............................................................................................................. 23
4.6 COPIES......................................................................................................................................... 23
4.7 LIVING DOCUMENT UPDATES ......................................................................................................... 24
4.8 REJECTION OF SUBMISSIONS ......................................................................................................... 24
5. ADDITIONAL RESOURCES .............................................................................................................. 25
5.1 USER ASSISTANCE ........................................................................................................................ 25
5.2 FREEDOM OF INFORMATION ACT (FOIA) AND PRIVACY ACT REQUESTS ........................................... 26
5.3 REFERENCES ................................................................................................................................ 27
6. APPENDIX—NARA GUIDANCE ........................................................................................................ 27
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 2
U.S. Nuclear Regulatory Commission
1. INTRODUCTION
This guidance is intended for licensees, applicants, external entities (including Federal, State,
and local governments), vendors, participants in adjudicatory proceedings, and members of the
public who submit documents to the U.S. Nuclear Regulatory Commission (NRC).
The NRC updates this guidance biennially to reflect changes in technology and agency
experience. The next update to this guidance will be published in Fiscal Year 2019. The NRC
posts the latest version of this document on the NRC’s website at http://www.nrc.gov/site-
5TU
1.1 Scope
This guidance offers direction on how to submit documents electronically to the NRC. After a
successful submission, the documents will be imported into the Agencywide Documents Access
and Management System (ADAMS) and will be made publicly available at the Web Based
ADAMS Public Library, which can be accessed through the NRC’s public website at
http://www.nrc.gov/reading-rm/adams.html . Eventually, documents will be transferred to the
5T 5T
National Archives and Records Administration (NARA), in accordance with Title 36 of the Code
of Federal Regulations (36 C.F.R.) § 1228.270, “Electronic Records.”
Documents or other information submitted under oath or affirmation, or other documents where
secure transfer is either required or appropriate, should be submitted using the Electronic
Information Exchange (EIE) System or submitted on optical storage media (OSM). In
adjudicatory proceedings, participants in the proceeding are required to use the EIE system,
unless an exemption is granted by the presiding officer pursuant to 10 C.F.R. § 2.302(g)(2) or
the filing falls within the scope of 2.302(g)(1), which permits the use of OSM under certain
circumstances.
While E-mail and facsimiles are not appropriate for most submissions to the NRC, they may be
used for certain correspondence and communications with the NRC, such as:
• Rulemaking petitions and comments
• Communications from States, Tribes, and other Federal agencies
• Requests for enforcement action under 10 C.F.R. § 2.206
• Freedom of Information Act (FOIA) requests and appeals
Electronic files submitted to the NRC must be in the portable document format (.pdf or PDF) or
PDF/A format and should follow the guidelines below. The NRC accepts PDFs from electronic
documents converted directly to PDF or scanned images of physical documents.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 3
U.S. Nuclear Regulatory Commission
Several popular PDF creation solutions, such as the “Create PDF” feature in Microsoft Office
2013 or the “Save as PDF” feature in macOS, do not provide the level of customization that is
available in Adobe Acrobat. Nevertheless, these features embed fonts by default and thus
should meet the optimization guidelines in this guidance.
For PDFs created using Adobe Acrobat, the NRC has established a custom optimization that
balances between print and screen optimization. This custom optimization provides adequate
retrieval response time for online viewing, while providing sufficient clarity and resolution for
printing. The settings established for this custom optimization are listed below and should be
used for PDFs created with Adobe Acrobat. The settings are specific to Adobe ® Acrobat
P P
11.0.X. For electronic documents converted directly to PDF, fonts should be embedded in the
PDF to ensure compliance with NARA guidelines.
If a submission created using one of the methods described above is rejected, please contact
the Electronic Filing Help Desk at 1-866-672-7640 or MSHD.Resource@nrc.gov for assistance.
5T 5T
Note: PDF/A (ISO 19005) is an acceptable file format provided it also meets the
specifications contained in this guidance document.
Note: If you are using an Adobe ® Acrobat product we recommend that you check
P P
Note: Additional guidance on PDF settings, as well as PDF generation, can be found on
the NRC’s “Reference Materials for Electronic Submissions” Web page:
http://www.nrc.gov/site-help/electronic-sub-ref-mat.html . This information is
5T 5T
Required settings for PDFs generated from Native Applications using Adobe Acrobat*
Criteria
Optimized for Fast Web View
Embedded Fonts
Searchable Text
Security Method = “No Security”
File size ≤ 500MB (except for single image or data file)
*Adjudicatory documents will not be accepted in native format and must be converted to PDF
with the exception of MS Excel spreadsheets.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 4
U.S. Nuclear Regulatory Commission
Criteria
Optimized for Fast Web View
Resolution ≥300 ppi
Searchable Text by Optical Character Recognition (OCR) process
( http://www.nrc.gov/docs/ML1014/ML101440354.pdf , “PDF Document
5T 5T
Submittal Checklist”)
Lossless Compression
Security Method = “No Security”
File size ≤ 500MB (except for single image or data file)
Unless otherwise instructed (e.g., by the presiding officer in an adjudicatory proceeding), files
submitted to the NRC should be named using the following guidelines:
• File names (not to be confused with Document Titles) have specific requirements based
on the type of submission:
o General submissions cannot exceed 239 characters, including spaces and the
three-character file name extension; and
o EIE Adjudicatory submissions cannot exceed 85 characters, including spaces
and the three-character file name extension.
• The first three characters of the file name should always be used to identify the correct
sequential order of the submitted files (e.g., 001, 002, 003, etc.).
• The filename should reflect, to the extent possible, the chapter or section number (based
on the logical breakpoint used for segmentation of the document), and the title of the file
or segment being submitted.
• When segmenting a large file for a multi-part submission, each part must identify the part
number and the total number of parts. For example, if the file was segmented into three
parts, the name ending of the first part would be Part 1 of 3; the second, Part 2 of 3; and
so on (see File Naming Example Table below).
• The file name must retain the default three-character file extension associated with the
format.
Example explanation: 001 belongs to the first document attached to the submission;
therefore, the next document attached would begin with 002. Estimate of Long-Term
Geochemical Behavior is the title of the document. Section 1 is Section 1 of the
document; therefore, the next document attached would be Section 2. .pdf is the file
extension of portable document format file.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 5
U.S. Nuclear Regulatory Commission
Electronic submissions to the NRC, whether a single file or multiple files provided as one
submission, cannot exceed 500 MB. When submitting files to the NRC, the use of compression
techniques (zipped files, downsized files, etc.) is discouraged. Electronic submissions larger
than 500 MB must be submitted on OSM or through multiple electronic submissions. See
Section 3.2.1 for guidance on submissions on OSM.
5T 5T
Submissions must not contain any security settings, password protections, or any other
attributes that would preclude full NRC access to, and use of the files. The NRC’s internal
security and archival processes will maintain the integrity of the materials that are submitted.
Color should be used only in limited circumstances where, for example, the use of color
contributes to a reader’s understanding of the material being presented (e.g., maps, graphs,
charts, and engineering documents), or does not appreciably increase a file’s size (e.g.,
company logos). Excessive or unnecessary use of color can significantly increase file
size, which may result in files that exceed the 500 MB limit of the EIE system.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 6
U.S. Nuclear Regulatory Commission
Links within a single electronic document or file is acceptable. When dealing with multiple files
that contain links between each file, the files should be combined into a single file to ensure
links remain operable upon submission to the NRC. Links between multiple documents or any
other linking between electronic files are not allowed, as the links will become inoperable upon
submission to the NRC.
For adjudicatory documents (pleadings and exhibits), parties are discouraged from using
hyperlinks because of concerns about the integrity of the hearing record. If an adjudicatory
document does include hyperlinks nonetheless, parties must follow 10 CFR § 2.1013(c)(vi) and
include an appropriate disclaimer ( Section 2.6.1 ) to the effect that the hyperlinks are either
5T 5T
inoperable or are not essential to using the filing and that any referenced material that is
necessary to the completeness of the filing has been included as part of the submission, either
in its entirety or as an attachment to the filing.
For a submission in an adjudicatory proceeding, include the following in the body of the
submission if the document contains hyperlinks to other documents or websites:
For a non-adjudicatory submission (including License applications that consists of more than
one document (including License Applications*), include the following in the transmittal
memorandum if one or more documents contain hyperlinks to other files or to Internet websites:
This submission contains files, one or more of which contains hyperlinks to other
files or to Internet websites. These hyperlinks are either inoperable or are not
essential to the use of the filing. Any material referenced by hyperlinks to Internet
websites that was essential for use of this filing has been submitted as part of
the filing. Any material referenced by a hyperlink to another file that was
essential for the use of this filing has either been included by reference or
submitted as part of this filing.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 7
U.S. Nuclear Regulatory Commission
See the “Packing Slip Wizard User’s Guide”, which can be found on the NRC’s
Electronic Submittals Application Web page (http://www.nrc.gov/site-help/e-
submittals.html) for more information.
2.7 Viruses
Files received by the NRC will be checked for viruses before acceptance. Any submission
marked as having a virus will be rejected and returned to the submitter with an explanation for
the rejection.
2.8 Macros
Macros in Microsoft® Excel documents are sometimes detected as viruses. Although macros
are accepted, they should be limited.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 8
U.S. Nuclear Regulatory Commission
When submitting OSM, use folders to organize the contents at the chapter level, consistent with
the file name guidance. The numeric portion of the file name should be sequential across all
folders. Other guidance includes:
• Each chapter should have its own folder, which should then contain all files associated
with that chapter including sections, subsections, and graphics (either embedded within
those sections or subsections or provided separately).
• The sections and subsections should be placed in logical sequential order within a
folder.
• Separate folders may be created for appendices, exhibits, or attachments. Each item
should comply with the file name guidance in Section 2.2 and, if possible, have a file
5T 5T
For non-adjudicatory submissions, each submission of two or more files (regardless of size)
should include a transmittal letter that provides explanatory information that will enable the NRC
to ensure the completeness and integrity of the submission.
• The name, mailing and E-mail addresses, and phone number of a point of contact.
• A complete list of the submission’s components (electronic files and physical objects),
listed in the order in which they are submitted including:
o Filename (including file extension)
o Size of the file
o Sensitivity level (e.g., publicly available, proprietary, classified, etc.)
o An indication of whether the component is being submitted electronically, on
OSM, or by both
o A file that provides a non-sensitive description of all electronic components
characterized as binary large objects (BLOBs) or other physical objects
o Any special instructions or information necessary to view or use the information,
such as using the OSM*, computer operating system, or software requirements
for data files, computer models, etc.
* If OSM is used, the component listing should include the total number of OSM
submitted.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 9
U.S. Nuclear Regulatory Commission
• A detailed statement describing any deviation among the submitted files from approved
formatting.
• A disclaimer statement for any files that may have links to other files or to Internet
websites.
3. SUBMISSION METHODS
The following are acceptable methods for submitting documents to the NRC:
• EIE system (see Section 3.1 )
5T 5T
• External Hard Drives and OSM (e.g., CD, DVD, etc.) (see Section 3.2 ) 5T 5T
Note: Under NRC regulations, submission methods other than the EIE system or OSM
(as specified in 10 C.F.R. § 2.302(g)(1)) are not permitted in adjudicatory
proceedings unless an exemption is granted by the presiding officer.
The EIE system receives submitted documents and forwards them to the NRC’s Document
Processing Center (DPC) for processing. The EIE system uses a public key infrastructure and
digital signature technology to authenticate submissions.
Submissions that are required to be submitted under oath or affirmation (see Section 3.1.2 ) 5T 5T
Each individual who wishes to use the EIE system must obtain a digital ID certificate from the
NRC. The digital ID certificate allows the submitter to digitally sign and submit the form used to
transmit documents and, in the case of adjudicatory submissions, to retrieve documents. For
additional guidance, see the NRC’s “Getting Started” page: ( http://www.nrc.gov/site-help/e-
5T
submittals/getting-started.html ). 5T
More information on the types of submissions that can be made through the EIE system can be
found in the sections listed below:
• Adjudicatory submissions (see Section 3.1.3 ) 5T 5T
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 10
U.S. Nuclear Regulatory Commission
For additional information, please see the descriptions provided within the Electronic
Submission Systems section of the Electronic Submittals Application Web page:
( http://www.nrc.gov/site-help/e-submittals.html ).
5T 5T
3.1.1 Documents that may NOT be submitted via the EIE system
The EIE system may NOT be used for the following types of submissions:
• Documents containing classified information (i.e., national security information and
restricted data) or safeguards information, which may only be submitted electronically on
OSM.
• “Immediate” or “prompt” notifications required by NRC regulations (e.g., 10 C.F.R.
§§ 30.50(c)(1), 30.55(c), 50.36(c)(7), or 50.72).
• Notice of filing of bankruptcy petition, whether voluntary or involuntary (e.g., 10 C.F.R.
§ 30.34(h)(1)).
• Documents served on the NRC as a participant in Federal court proceedings or in non-
NRC administrative proceedings (such as administrative proceedings before the Merit
Systems Protection Board).
• NRC contractor proposals or invoices submitted in response to specific contractual
requirements. Given statutory and Federal Acquisition Regulation requirements to use
electronic commerce in Federal procurements whenever practicable or cost-effective (41
U.S.C. § 2301; 48 C.F.R. (FAR) Subpart 4.5), guidance for electronic submittal of
proposals and invoices will be addressed in individual procurements or through
standardized NRC contract clauses. Further agency guidance for uniform submission of
these documents will be issued at a later date.
• Financial assurance instruments to meet decommissioning cost requirements prescribed
by regulation at 10 C.F.R. § 30.35(e) and (f), 10 C.F.R. § 40.36(d) and (e), and 10
C.F.R. § 70.25(e) and (f) (including surety bonds, letters of credit, lines of credit, and
insurance).
• Documents with special printing requirements, which may only be submitted
electronically on OSM.
Some documents filed with the NRC must be submitted under oath and affirmation. Many of these
documents may be submitted through the EIE system, as discussed below.
• If the submitter is located in the United States, then to satisfy the provisions of 28 U.S.C.
§ 1746, they may submit through the EIE system:
o A single document under oath or affirmation by including in the body of the document
(normally at the end), the statement:
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 11
U.S. Nuclear Regulatory Commission
“I declare under penalty of perjury that the foregoing is true and correct.
Executed on (date) (Signature).”
When the document is ready to be submitted through the EIE system, the person
submitting the document must digitally sign the document by clicking on the
Signed by button and then transmit the document through the EIE system by
clicking on the Submit Document button.
Each document may be submitted separately using the process described above
for individual documents;
Each document may be electronically signed and provided in a single submission
provided the electronic signing process has been approved by the NRC; or
Each document may be created in hard copy and physically signed in ink.. The
original paper copies may then be scanned to create searchable image files of
the original signature pages (for additional guidance on creating a searchable
image file, see the “Reference Materials for Electronic Submissions” Web page:
http://www.nrc.gov/site-help/electronic-sub-ref-mat.html ). These documents may
5T 5T
o Affidavits filed in adjudicatory proceedings may also be signed with the statement:
Note: For a single document submission, when clicking the “Sign” button on the EIE
system submission form, the submitter is actually digitally signing the document.
In this case, signing the submission form meets the current requirements for
submission.
For a multiple document submission, when clicking the “Sign” button on the EIE
system submission form, the submitter is digitally signing the transmission only,
so all documents should be signed before submission. This likewise satisfies
requirements for submission.
• If the submitter is located outside the United States, then to satisfy the provisions of 28
U.S.C. § 1746 a single document that must be submitted under oath or affirmation may
be submitted through the EIE system by including the statement.
“I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct. Executed on (date)
(Signature).”
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 12
U.S. Nuclear Regulatory Commission
in the agency’s hearings , consistent with the requirements and specifications set forth in 10
0T 5T 5T
C.F.R. Part 2 . Persons wishing to submit adjudicatory documents using other methods (e.g.,
0T 0T
The NRC’s regulations in 10 C.F.R. Part 2 provide specific requirements governing the
submission of documents through the EIE system. For example, under 10 C.F.R. § 2.304(g),
each exhibit or piece of written testimony must be submitted as an individual electronic file.
Participants in the NRC’s adjudicatory proceedings are, among other things, expected to review
and comply with the E-Filing requirements in 10 C.F.R. Part 2.
See Section 2 for guidance on the parameters for electronic files submitted to the NRC.
5T 5T
Note: Most documents submitted in adjudicatory proceedings will appear in the NRC's
Electronic Hearing Docket ( https://adams.nrc.gov/ehd/ ), which is available to the
5T 5T
Further, several types of documents are (1) required to be withheld from public
disclosure or (2) may contain information that is exempt from disclosure and thus
the documents may be withheld in whole or in part under the procedures in 10
C.F.R. § 2.390.
As discussed in Section 4.2 and 4.3 , classified and SGI information may not be
5T 5T 5T 5T
The Criminal History form is used to transmit licensee personnel information to conduct criminal
history record checks to obtain unescorted access to nuclear power facilities, non-power reactor
facilities, category 1 or category 2 quantities of radioactive material, or access to SGI. It is used
for transmitting Criminal History applications to the NRC. This process supports enhanced
security requirements and improves information flow between licensees subject to criminal
background check requirements under 10 C.F.R. Part 37, “Physical Protection of Category 1
and Category 2 Quantities of Radioactive Material,” or 10 C.F.R. Part 73, “Physical Protection of
Plants and Materials,” and the NRC.
Note: Refer to the “Criminal History User’s Guide”, which can be found on the NRC’s
Electronic Submittals Application Web page:
http://www.nrc.gov/docs/ML1518/ML15182A294.pdf .
5T 5T
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 13
U.S. Nuclear Regulatory Commission
The general submission form is used for transmitting reports or other electronic filings to the
NRC.
Note: Submissions intended for a specific Region should have the Region listed in the
“Comment” field contained on the General submission form.
See Section 2 for guidance on the parameters for electronic files submitted to the NRC.
5T 5T
Licensees who wish to use electronic submissions to satisfy 10 C.F.R. Part 26, “Fitness for Duty
Programs” reporting requirements should use the general submissions form found at:
http://www.nrc.gov/site-help/e-submittals.html .
5T 5T
Note: Before submitting Fitness for Duty (FFD) reports, please read the FFD reporting
information at: http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-
5T
duty-programs/submit-ffd-reports.html . 5T
Note: Refer to the “Packing Slip Wizard User’s Guide”, which can be found on the NRC’s
Electronic Submittals Application Web page http://www.nrc.gov/site-help/e-
5T
submittals/packing-slip-wizard-user-guide-v1.1.pdf . 5T
Payments by credit card of civil penalties, Part 170 licensing and inspection fees, Part 171
annual fees, and other fees, may be done after completing NRC Form 629 (Authorization for
Payment by Credit Card) included with the invoice or civil penalty.
3.2 External Hard Drive and Optical Storage Media (OSM) Submissions
There are a number of external hard drives and OSM to choose from, including tapes, compact
discs read-only memory (CD-ROM), Digital Versatile Discs or Digital Video Discs (DVD), or
external hard drives.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 14
U.S. Nuclear Regulatory Commission
It is recommended that large documents made up of multiple files, folders, etc., be transmitted
on OSM. Oversize drawings and other files with special printing requirements, regardless of the
file size, should be provided on OSM.
Software used to produce the OSM should be configured to ensure that OSM submitted to the
NRC is “read only” before its delivery to the NRC. This requirement does not apply to external
hard drives submitted to the NRC.
Note: There are a number of external hard drives and OSM* to choose from. The NRC
will accept compact discs read-only memory (CD-ROM), or Digital Versatile Discs
or Digital Video Discs (DVD).
The NRC will also accept external hard drives* as long as they are USB 2.0-
compatible.
*External hard drives and OSM should NOT be encrypted or submitted with any
sort of security protection. If they are, the submitter must provide the password or
encryption key to the NRC or it will be rejected.
When an adjudicatory filing contains information or files that cannot be transmitted through the
EIE system, the filing must be submitted in accordance with the requirements in 10 C.F.R.
§ 2.302(g)(1). Under this section, any files that can be submitted through the system must be
sent using EIE. Then, separately, the participant must submit OSM containing the entire filing,
i.e., the material submitted via the EIE system, and any additional material that could not be
filed electronically. Service of the filing will be considered complete only after both the
transmission of documents using the EIE system and the OSM is deposited with the
delivery service provider. See 10 C.F.R. § 2.302.
There are also documents that should only be submitted using OSM, such as documents that
contain special printing requirements.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 15
U.S. Nuclear Regulatory Commission
Documents containing classified information (i.e., national security information and restricted
data) and safeguards information may only be submitted electronically on OSM.
The following type of information may not be submitted to the NRC on OSM:
• “Immediate” or “prompt” notifications required by NRC regulations (e.g., 10 C.F.R.
§ 30.50(c)(1), § 30.55(c), § 50.36(c)(7), or § 50.72).
• Notice of filing of bankruptcy petition, whether voluntary or involuntary (e.g., 10 C.F.R.
§ 30.34(h)(1)).
• NRC contractor proposals or invoices submitted in response to specific contractual
requirements. Given statutory and Federal Acquisition Regulation requirements to use
electronic commerce in Federal procurement whenever practicable or cost-effective (41
U.S.C. § 2301; 48 C.F.R. (FAR) Subpart 4.5), guidance for electronic submittal of
proposals and invoices will be addressed in individual procurements or through a
standardized NRC contract clauses. Further agency guidance for uniform submission of
these documents will be issued at a later date.
• Financial assurance instruments to meet decommissioning cost requirements and
prescribed by regulation at 10 C.F.R. §§ 30.35(e) and (f), 10 C.F.R. §§ 40.36(d) and (e),
and 10 C.F.R. §§ 70.25(e) and (f) (including surety bonds, letters of credit, lines of credit,
and insurance).
If executed within the United States, the OSM submitter’s signed original paper transmittal
letter should, to satisfy the provisions of 28 U.S.C. § 1746, contain the oath and the signature of
the person swearing to or affirming the accuracy of the information submitted. Specifically, the
letter should include the following statement:
“I declare under penalty of perjury that the foregoing is true and correct.
Executed on (date) (Signature).”
If executed outside of the United States, the OSM submitter’s signed original paper transmittal
letter should contain the oath and the signature of the person swearing to or affirming the
accuracy of the information submitted. Specifically, the letter should include the following
statement:
“I declare under penalty of perjury under the law of the United States of
America that the foregoing is true and correct. Executed on (date)
(Signature).”
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 16
U.S. Nuclear Regulatory Commission
OSM submitted to the NRC should be accompanied by a signed paper transmittal letter that
provides a detailed list of what is contained on the OSM. It is recommended that the letter and
OSM be sent to the NRC by expedited delivery service. Given the importance of submission
and document integrity and fidelity, expedited delivery of the OSM is strongly encouraged to
ensure coordinated processing if any companion documents are transmitted through the EIE
system.
For adjudicatory submissions, service of the submission is considered “complete” when the
participant has complied with the requirements in 10 C.F.R. § 2.302(d)—for documents
submitted by mail or expedited delivery service, service is complete when the document
is deposited with the delivery service provider. When a participant uses multiple
submission methods, service is considered complete when service by each method is
complete. See 10 C.F.R. § 2.302(d).
Note: Incoming mail addressed to the Federal government may be irradiated before
delivery. Irradiation of OSM may result in damage to the media and its contents.
Therefore, packages containing OSM submission should be clearly marked
“CONTENTS CONTAIN OPTICAL STORAGE MEDIA—DO NOT IRRADIATE!”
Note: Due to security measures, any mailed submissions will be delayed by at least one
week.
For electronic submissions on OSM that contain classified information (i.e., national security
information and restricted data), Sensitive Unclassified Non-Safeguards Information (SUNSI),
safeguards information, or non-public documents, additional requirements apply as described in
Sections 4.2 (Classified Information) and 4.3 (Safeguards or Sensitive Information).
5T 5T 5T 5T
If special software components (e.g., printer drivers) are necessary, include those components,
their configuration parameters, and any hardware configuration requirements on the same
OSM.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 17
U.S. Nuclear Regulatory Commission
The OSM should be labeled with the transfer media configuration (e.g., drive transfer rate) as
well as any numbering, exterior marking, or labeling used to reference the submission as it is
provided through the EIE system. If appropriate, the document’s version number should also be
included.
The mailing package containing the OSM with documents comprising proprietary, personal
privacy, or Official Use Only information should be an opaque envelope with no external
markings describing the presence of SUNSI, in accordance with the recommendations for
handling documents set forth in Attachment 1 of the NRC’s RIS-2005-31, “Control of Security-
Related Sensitive Unclassified Non-safeguards Information Handled by Individuals, Firms, and
Entities Subject to NRC Regulation of the Use of Source, Byproduct, and Special Nuclear
Material”: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-
5T
issues/2005/ri200531.pdf .5T
OSM containing classified information (i.e., national security information or restricted data) must
be packaged and submitted to the NRC in accordance with the requirements contained in
10 C.F.R. §§ 95.37, 95.39, and 95.41.
In accordance with 10 C.F.R. § 2.302, use either of the following two addresses for delivering
OSM (along with the signed paper copy transmittal letter) to the NRC via:
Participants making OSM filings should also serve copies of the OSM on the other Service List
parties in accordance with any protective order or other directions from the presiding officer
governing the submission.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 18
U.S. Nuclear Regulatory Commission
Use the following address for delivering OSM (along with the signed paper copy transmittal
letter) to the NRC by courier, express mail, and expedited delivery services:
3.3 E-mail
Files sent by E-mail should be sent as an attachment to the E-mail message to retain the
original formatting of the documents. Multiple document E-mail attachments are acceptable but
the E-mail cannot exceed 10MB. For non-adjudicatory E-mail submissions, the message
should include:
• Name of a contact person who can respond to questions about the submission.
• Contact person’s daytime phone number, physical mailing address, and E-mail address.
• A list describing each document attached to the E-mail message.
• A list describing the formats used to generate each of the attached file.
Documents submitted by E-mail, including the text of the E-mail, should contain only information
that could be made available to the public. E-mail submissions should not include personal
privacy information, such as social security numbers, home addresses, or home or personal
mobile phone number(s), unless an NRC regulation or other law requires submission of such
information. The following types of submittals may be made by E-mail:
• Rulemaking petitions and comments in rulemaking proceedings, which will be made
publicly available at https://regulations.gov as well as Public ADAMS, as stated in the
5T 5T
Note: NRC does not remove identifying or contact information from rulemaking
documents before public release.
• Requests for enforcement action under 10 C.F.R. § 2.206 may be sent to:
Petition.Resource@nrc.gov .
5T 5T
• All FOIA and Privacy Act requests and appeals may be submitted electronically by E-
mail.
• Responses to Federal Register notices or other agency communications where the NRC
has provided a specific E-mail address.
• Information from export and import license applicants and licensees.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 19
U.S. Nuclear Regulatory Commission
• The Office of the Executive Director for Operations for petitions under 10 C.F.R. § 2.206:
Petition.Resource@nrc.gov .
5T 5T
Facsimiles should include the name of a contact person who can respond to questions about
the submission, along with the contact person’s daytime phone number and physical mailing
address or E-mail address.
Documents submitted by facsimile should contain only information that could be made available
to the public and may be used for:
• Rulemaking petitions and comments in rulemaking proceedings.
• Requests for enforcement action under 10 § C.F.R. 2.206.
• FOIA and Privacy Act requests and appeals (requests submitted by facsimile may not
reveal personal privacy information).
• Responses to Federal Register notices or other agency communications where NRC
has provided for response by facsimile.
• Information from export or import license applicants and licensees.
The NRC has established centralized receipt points for official submissions transmitted by
facsimile to NRC headquarters and each of the regional offices. All official transmissions should
be sent to one of these official receipt points to ensure they are captured as official records of
the agency.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 20
U.S. Nuclear Regulatory Commission
Requests for enforcement action under 10 C.F.R. § 2.206 may be submitted by e-mail, FAX,
EIE system (as a General Submission or OSM), delivery service, or in person.
Documents containing classified information may not be submitted via the EIE process; OSM is
the only acceptable means for the electronic submission of classified information.
OSM containing classified information must be processed and produced on systems approved
under the provisions of 10 C.F.R. § 95.49, “Security of Automatic Data Processing Systems.”
Each OSM must be clearly labeled as containing classified information. OSM containing
classified information (i.e., national security information or restricted data) shall be packaged
and submitted to the NRC in accordance with the requirements contained in 10 C.F.R. § 95.37,
“Classification and Preparation of Documents”; § 95.39, “External Transmission of Documents
and Material”; and § 95.41, “External Receipt and Dispatch Records.”
Note: If OSM contains both classified and unclassified information, two separate OSM
submissions must be filed. One OSM filing should include both the unclassified
and classified/Safeguards Information (SGI). The second OSM filing should
include only the unclassified or publicly available information (the information in
this filing may be made publicly available in ADAMS).
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 21
U.S. Nuclear Regulatory Commission
Documents containing safeguards information may not be submitted via the EIE process.
Documents with Safeguards Information (SGI) may be transmitted on OSM. The mailing
package containing OSM with documents containing safeguards information must be
processed, marked and transmitted in accordance with the requirements set forth in 10 C.F.R. §
73.22(e), (g), (h), and (f), as appropriate.
If it is not practical to submit a large document containing SUNSI through the EIE system,
submit the document on OSM. Submissions made on OSM should be accompanied by a
transmittal letter that contains information regarding the sensitivity level of the transmitted
documents. The transmittal letter should not have a SUNSI header unless SUNSI is contained
in it.
When submitting documents on OSM that contain both publicly and non-publicly available files,
two copies of the OSM should be provided. One copy should contain both the non-public and
public files. The second copy, provided on separate OSM, should contain only the publicly
available files. Each OSM should be clearly labeled showing the information it contains
(“Publicly Available,” SGI, or SUNSI). Files contained on OSM labeled as “Publicly Available”
will be released to the public.
For more information on the procedures for marking and control of SUNSI, the following
documents are available on the NRC public website:
• 5T http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2005/ :
5T
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 22
U.S. Nuclear Regulatory Commission
In addition to the above guidance, other Government agencies may designate, mark, and
control information according to their own procedures. Such information, if not safeguards
information or classified information, will be handled by the NRC as SUNSI or per 10 C.F.R.
Part 1017, when submitted to the NRC without requiring additional markings.
4.4 Accessibility
Section 508 of the Rehabilitation Act and the accessibility standards in the implementing
regulations require Federal agencies to provide people with disabilities meaningful and equal
access to electronic and information technology. In support these standards, the NRC strives to
implement tools and plug-ins in its electronic and information technology systems. Authors of
documents submitted to the NRC should consider accessibility issues during document
authoring. To improve the NRC’s ability to make electronic submissions comply with Section
508, authors should use simple layouts, consistent styles, accessible table formats, alternate
text for images, and English (U.S.) language selection. For more information, please go to
https://www.access-board.gov/guidelines-and-standards/communications-and-it . The NRC will
5T 5T
Submitting information to the NRC constitutes authority for the NRC to reproduce and distribute
sufficient copies internally to carry out its official responsibilities. NRC use of the information
specified herein does not constitute authority for others to use the information outside the
applicable requirements of copyright law.
Submitters are expected to identify, as part of the submission process, copyright information.
Copyrighted information will not be placed on the NRC public access database without a
release from the copyright holder or a statement by the submitter that the information may be
publicly released under applicable requirements of copyright law. Even with a copyright release,
the NRC reserves the right to withhold information from public disclosure based on content if it
presents a security or safety risk, or until it can verify a submitter’s statement that such
information may be publicly released.
4.6 Copies
Paper copies of documents do not need to be provided when the documents are submitted
electronically. When the NRC requires a paper copy for accessibility or other reasons, the NRC
will make every effort to produce the copy using the electronic version of the document.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 23
U.S. Nuclear Regulatory Commission
However, in those instances where the agency is unable to generate an accurate paper copy
from the electronic submission, the NRC may request a paper copy from the submitter. This will
be handled on a case-by-case basis.
Many NRC regulations require submission of copies of documents to multiple NRC locations
(e.g., headquarters, regional offices). Electronic submission through the EIE system does NOT
require submission to multiple locations. However, OSM submissions require that the licensee
or vendor submit a single copy to each location that requires the information, as specified by
your NRC Point of Contact.
Historically, many large documents submitted to the NRC have been maintained as living
documents and have used a page-replacement approach when updated, such as an Updated
Final Safety Analysis Report (UFSAR), or Technical Specifications. Paper submissions can still
use this approach for providing updates to living documents.
However, revised sections of a document will not be accepted when the document is only
submitted electronically. If changes to the submitted document are necessary:
• The submission (including all of the electronic files and electronic objects that comprise
the submission) may be re-submitted through the EIE system if the total file size does
not exceed the 500MB limit; otherwise, the submission should be re-submitted on OSM.
• The transmittal letter accompanying the submission should describe the revised parts
(e.g., chapter, section, or graphic) as well as the general scope of the change.
• The document should be identified as a new version with conforming file identification
information.
• Each changed page should include the following:
o A change indicator (track changes) for the area changed (for example, a bold line
vertically drawn in the margin adjacent to the portion actually changed).
o A page change identification including either: (1) the date of change, (2) a change
number, or (3) both.
Per the guidance provided within Section 2—Parameters for Electronic Files Submitted to the
5T
NRC —when electronically submitting documents to the NRC via any method, failure to follow
5T
the guidance outlined in this document may result in rejection of the submission. Rejected
submissions must be resubmitted to the NRC.
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 24
U.S. Nuclear Regulatory Commission
• Portable document format (PDF) documents created using the PDF Portfolio feature.
• Virus-infected files.
• Compressed files.
• Encrypted files.
• Unknown file formats.
• Corrupt or unreadable files.
• Disabled fast Web view.
• Macros that are marked as potential viruses.
• File formats other than those listed in Section 2.1.
5T 5T
• OSMs that contain both publicly and non-publicly available files on a single OSM, unless
a second OSM with only publicly available information is also provided.
• OSMs containing object linking and embedding (OLE), dynamic data exchange (DDE),
or any other object linking.
• Fonts not embedded (originated by Native Applications such as Microsoft ® Word,
P P
The NRC may reject any submission if any inconsistencies are found and will inform the
submitter of the rejection.
5. ADDITIONAL RESOURCES
submittals.html 5T
started.html 5T
help/electronic-sub-ref-mat.html 5T
submittals/adjudicatory-sub.html 5T
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 25
U.S. Nuclear Regulatory Commission
http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/submit-
5T
ffd-reports.html5T
Telephone: 1-866-672-7640
E-mail: MSHD.Resource@nrc.gov
5T 5T
• Individual program offices may be contacted through the NRC website at www.nrc.gov 5T 5T
by selecting specific contact programs from the Contact Us link at the top of the home
5T 5T
page.
• For assistance with ADAMS, contact the Public Document Room (PDR):
Telephone: 1-800-397-4209 or 301-415-4737
TTY (hearing impaired): 1-800-635-4512
Facsimile: 301-415-3548
E-mail: PDR.Resource@nrc.gov
5T 5T
All FOIA and Privacy Act requests and appeals may be submitted, as follows:
• Facsimile: 301-415-5130.
• E-mail: FOIA.Resource@nrc.gov
5T 5T
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 26
U.S. Nuclear Regulatory Commission
5.3 References
• NRC, “Electronic Submittals Application” Web page: http://www.nrc.gov/site-help/e- 5T
submittals.html 5T
mgmt/ 5T
• Code of Federal Regulations, Title 10 (10 C.F.R.), Energy, which can be found at:
http://www.nrc.gov/reading-rm/doc-collections/cfr/
5T 5T
submittals/10cfr1.pdf 5T
for-duty.html 5T
and-policies 5T
6. APPENDIX—NARA GUIDANCE
mgmt/bulletins/2014/2014-04.html
Records – Tables of File Formats
5T
Storage
http://www.archives.gov/frc/flyers/erv-
5T
July 1994
11T
mgmt/initiatives/transfer-records-to-
is taken from NARA's regulations in the Code of
nara.html
Federal Regulations (36 C.F.R. §§
5T
Images
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 27
U.S. Nuclear Regulatory Commission
mgmt/initiatives/transfer-
[Rules and Regulations]
regulation.html
[Page 79517-79520]
5T
_________________________________________________________________________________________
Guidance for Electronic Submissions to the NRC Page 28