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How to Prepare a Document or File for Submission

Electronic materials should be submitted in PDF or otherwise meet the specifications delineated here.

On this page:

• Preferred PDF Output File Format
• File Naming Conventions
• Security/Access Settings
• Resolution
• Settings for Creating PDF Formatted Text and Graphic Files
• Use of Color
• Files with Special Printing Requirements
• File Linkages
• Viruses
• Macros
• Copyrighted Information
• Copies
• Segmentation of Large Documents
• Sensitive or Non-Public Documents
• Who Can Participate

These instructions are updated from Chapter 2 of Guidance for Electronic Submissions to the Commission . Section references are to this document.

The following table defines the particular PDF output file formats and their use when submitting electronic documents to the NRC:

Preferred PDF Output File Format

* Textual documents scanned from original paper copies converted to PDF Formatted Text and Graphics result in capture of only a text file that contains OCR conversion errors. This inaccurate representation of the original document is not acceptable for capture by the NRC as an archival record. If the native format of a document is not available for creating a PDF file, the NRC recommends that Searchable Image (Exact) PDF be generated from a scanned image of the document. This will create a PDF file that contains a 100 percent accurate representation of the original document that will be acceptable for transfer to the National Archives.
** Adobe^® PDF Formatted Text and Graphics files that contain embedded images of text will not be accepted. These files are usually a result of cutting and pasting images of text, instead of the text itself, from one document to another while creating documents using word processing applications. This results in a picture of the text that is not full text searchable. However, images of text that are intended as a graphical representation only and are not meant to convey the information contained in the text will be accepted.

Note: Adobe has established a fourth PDF output file format (PDF Searchable Image (Compact)) that uses compression techniques to reduce file sizes of images. This is not an acceptable format for submission to the NRC because it uses techniques that do not result in a true and accurate representation of the original document.

Images originally created in a Tagged Image File Format (TIFF) that are primarily graphic-oriented in nature may be converted to PDF for submission to NRC using the PDF Image Only format described above.

The NRC recommends that the results of spreadsheet applications be converted to one of the acceptable PDF file formats. The NRC staff may also require spreadsheet data to perform additional calculations/analyses. Spreadsheet data may be submitted using the following acceptable formats.

When submitting an electronic file using one of the acceptable formats, do not change the default three-character extension of the file (e.g., a document prepared as "license_amendment.pdf"; have the ".pdf"; extension and a Microsoft Excel spreadsheet should have the ".xls"; file extension).

File Naming Conventions

Documents submitted to the NRC must

• Conform to ISO 9660 format, including following the Joliet extension.

• Have filenames that are limited to 49 characters (including the "."; and the three-character extension).

• Retain the default three-character file extension associated with the format in which the document was created. (Example: For files created to conform to Adobe’s Portable Document Format, ".pdf";; for files created using Microsoft Excel, ".xls";.)

• Include a three-digit numeric prefix (e.g., 001, 002, 003) in the filename that designates the correct order of the files contained in the submission, followed by the name of the file (example: "001filename of first document.pdf";).

• Filenames should be based on the logical breakpoint used for segmenting document (e.g., chapter, section) as described in Segmentation of Large Documents.

Large files create viewing and downloading challenges for the NRC staff and the public. The NRC requests that submitters make every effort to limit the size of each file to 50MB. If a document exceeds 50MB, it should be segmented using logical breaks (e.g., file broken up into individual chapters, see Segmentation of Large Documents).

Small files are problematic as well. Large volumes of files require significant resources to capture and profile in electronic document management systems. The NRC encourages submitters to combine components to create 50MB files that can be more economically and efficiently managed.

The maximum size of a document submitted to the NRC depends on the method of transmission. For example, e-submitters may use PDF files and/or accepted spreadsheet files (see Section 3.2) that do not exceed 50MB, including all attachments. Submitters should use CD-ROM in all other cases unless e-mail or fax is an appropriate option. (See Sections 5.2 and 6.2.) The use of compression techniques (zipped files, downsized files, etc.) is not allowed for electronic files submitted to the NRC because they do not result in a true and accurate representation of the original document. The table below summarizes the size limitations based on the method of file transmission:

⁺Total, combined size of message and attachments comprised of PDF file(s) and accepted spreadsheet format file(s). Note: Oversize drawings and other Files with Special Printing Requirements, regardless of the file size, should be provided on CD-ROM.
⁺⁺ The total CD capacity may be used, but submitters are urged to limit individual files to 50MB or less.
⁺⁺⁺ In some cases, a single page document or object (e.g., oversize color drawing) may exceed the 50MB file size limit. Submission of oversize files (in excess of the 50MB limit) are allowed in these instances.

Security/Access Settings

Submissions should not contain any security settings, password protections, or any other attributes that will preclude full NRC access to and use of the files. NRC’s internal security and archival processes will maintain the integrity of the materials that are submitted.

Resolution

To comply with NARA standards, PDF documents should be created using the following resolution guidelines:

• Bi-tonal (black and white) PDF resolution -- not less than 300 dots per inch (dpi)
• Color PDF resolution -- not less than 300 dpi
• Grayscale PDF resolution -- not less than 300 dpi

Adobe^® Acrobat "downsampling"; (an optimization option) may result in images with resolutions less than acceptable for submission to the NRC. Its use is not recommended.

Settings for Creating PDF Formatted Text and Graphic Files

Adobe^® Acrobat 5.0 provides four default optimizations when creating PDFs. These are eBook, Press, Print, and Screen. The NRC has reviewed these optimizations and has established a custom optimization that strikes a balance between Print and Screen optimizations. This custom optimization provides adequate retrieval response time for viewing online while providing sufficient clarity and resolution for printing. The settings established for this custom optimization are listed below and should be used on all submittals to the NRC. The settings are specific to Adobe^® Acrobat 5.0. When other PDF creation software is used, the software should be configured with values equivalent to those listed below. All fonts should be embedded in the PDF file to ensure compliance with NARA guidelines.

Settings

¹You must check the license(s) for any font(s) you intend to embed to verify that embedding is allowed. In some cases, the program will warn you if a font is not licensed for embedding, but this varies by vendor. Fonts must be embedded to comply with NARA guidelines.

Use of Color

The NRC discourages the use of color because it significantly increases file size. If color adds no value to the understanding of the information presented, it should be avoided. If color is required to make the document understandable, its limited use is acceptable. Examples of color documents that meet this criteria are graphs, bar charts, and engineering drawings that depend exclusively on color differences to understand the information and data being presented.

Files with Special Printing Requirements

Documents that contain electronic files with special printing requirements, such as requiring a plotter or other special equipment to print, oversize drawings or graphics that require paper larger than 11 inches by 17 inches, or other enhancements such as 3D images, etc., may only be submitted electronically via CD-ROM as separate files. If special software components (e.g., printer drivers) are necessary, include those components, their configuration parameters, and any hardware configuration requirements on the same CD-ROM.

File Linkages

Files containing objects (e.g., pictures, tables, spreadsheets, images of text) using link protocols such as Object Linking and Embedding (OLE), Dynamic Data Exchange (DDE), or any other object linking between electronic files are not practicable for the NRC because the relationships among the links are lost when captured in ADAMS or other agency electronic recordkeeping systems. Links within a single electronic PDF file are acceptable.

Viruses

Files received by the NRC will be checked for viruses before acceptance. Any submission identified as having a virus will be rejected and returned to the submitter with an explanation of the rejection.

Macros

Macros in files such as Microsoft^® Excel are sometimes detected as viruses. Therefore, the use of macros should be limited because a file identified as having a virus will be rejected and returned to the submitter with an explanation of the rejection.

Copyrighted Information

Submitting information electronically to the NRC shall be deemed to constitute authority for the NRC to place a copy of the information on its public document database and for the NRC to reproduce and distribute sufficient copies to carry out its official responsibilities. NRC use of the information specified herein does not constitute authority for others to use the information outside applicable requirements of copyright law.

Copies

Licensees and vendors using the Electronic Submittal system do not need to send confirming hard copies of their documents. In instances when the NRC requires a paper copy, it will make every effort to produce the copy using NRC resources. If the agency is unable to generate an accurate paper copy from an Electronic Submittal, the NRC may require 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). This practice continues for submissions that are made on CD-ROM. However, only a single copy of the CD-ROM is required to be submitted to each location. Electronic Submittals do not require submission to multiple locations.

Segmentation of Large Documents

Submitters should use CD-ROM (Section 4.0) for documents greater than 50MB. Divide the document into file segments of 50MB or less at logical breakpoints:

a. Chapters
b. Sections
c. Subsections
d. Appendices
e. Exhibits or attachments
f. Charts, tables, or formulae
g. For large transcripts, the end of a witness's testimony or session recess

If the recommended file size cannot be achieved, consider moving the graphics (which are often large files) to an appendix or attachment. Any graphic or other large object that exceeds 50MB and that cannot logically be divided should not be segmented. Note: Oversize drawings and other Files with Special Printing Requirements, regardless of the size, should be provided on CD-ROM.

Small files are problematic as well. Large volumes of files require significant resources to capture and profile in electronic document management systems. The NRC encourages submitters to combine components of larger documents to create larger files that can be more economically and efficiently managed.

When CD-ROMs are submitted, use electronic folders to organize the contents at the chapter level consistent with the File Naming Conventions. The numeric portion of the file name should be sequential across all folders. This means

• Each chapter must have its own folder that should then contain all files associated with that chapter, including sections, subsections, and graphics (either embedded in those sections/subsections or provided separately).

• The sections/subsections should be placed in logical sequential order within a folder.

• Separate folders may be created for appendices, exhibits, or attachments. Each item should have the file name reflect the folder where it resides, if practical, in conjunction with complying with the File Naming Conventions.

If multiple CD-ROMs are submitted, place the table of contents for the entire submission on each CD-ROM.

Sensitive or Non-Public Documents

Documents containing information that is deemed sensitive unclassified, specifically Proprietary Information (e.g., trade secrets, privileged, or confidential commercial or financial information), personal privacy information, or other Official Use Only information, may be submitted electronically or on CD-ROM. Documents containing Classified Information (i.e., National Security Information and Restricted Data) and Safeguards Information may be submitted electronically only on CD-ROM, but not via E-Submittal or e-mail. (See Sections 3.9 and 4.3.1.)

Who Can Participate

Applicants, licensees, external entities (including Federal, State, and local governments), vendors, and members of the public who submit documents to the NRC may do so electronically. Electronic Submittals (or EIE) ensures that documents are transmitted via the Internet in a secure and unalterable manner. Submittals that are required to be done under oath or affirmation may be safely transmitted this way. Applicants, licensees, vendors, etc., must designate individuals who will have the responsibility for originating, signing, or sending documents to the NRC in compliance with regulatory requirements.

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Tuesday, February 13, 2007