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 (Hyperlinks)
- Viruses
- Macros
- Copyrighted Information
- Copies
- Segmentation of Large Documents
- Sensitive Information
- Classified or Safeguards Information
- Who Should Follow this Guidance
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
| File Format | Version | Filename Extension | Recommended Use |
|---|---|---|---|
| Adobe® Acrobat PDF Formatted Text and Graphics (formerly known as PDF Normal). Options should be set according to the settings described in Section 2.9, Settings for Creating PDF Formatted Text and Graphic Files. | Current or 2 previous * | Textual documents converted from native applications only **, *** | |
| Adobe® Acrobat PDF Searchable Image (Exact) (formerly known as PDF Original Image with Hidden Text). Options should be set according to the settings described in Section 2.9, Settings for Creating PDF Formatted Text and Graphic Files. | Current or 2 previous * | Textual documents converted from scanned documents. | |
| Adobe® Acrobat PDF Image Only. Options should be set according to the settings described in Section 2.9, Settings for Creating PDF Formatted Text and Graphic Files. | Current or 2 previous * | Preferred format for graphic-, image-, and forms-oriented documents. |
| * | The acceptable versions of conversion software used to create PDF output files include the current market (non-beta) version distributed by the software vendor, the version distributed immediately prior to the current version, and the version distributed two versions prior to the current version. |
| Note: | Adobe has 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 lossy compression techniques that do not result in a true and accurate representation of the original document. |
| ** | Textual documents scanned from the original paper copies and converted into PDF Formatted Text and Graphics result in the capture of only a text file that contains Optical Character Recognition (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% accurate representation of the original document which 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 using word processing applications to cut and paste images of text instead of the text itself; from one document to another. This practice results in a picture (image) of the text being created that is not full text searchable. However, images of text that is intended as a graphical representation only and are not meant to convey the information contained in the text will be accepted. |
| Note: | PDF/A (ISO 19005) is an acceptable file format providing that it also meets the specifications contained in this guidance document. |
Images originally created in a Tagged Image File Format (TIFF) that are primarily graphic-oriented in nature (non-textual) may be converted to PDF for submission to NRC using the PDF Image Only format as described above. Moreover, images embedded in a document may be converted to PDF using lossless JPEG2000 compression techniques, which NARA will accept.
The NRC recommends that the results of spreadsheet applications be converted to one of the acceptable PDF file formats. The NRC staff may also need the native file spreadsheet data to perform additional calculations/analyses. Spreadsheet data may be submitted using the following acceptable native file formats:
Acceptable Spreadsheet File Format Table:
| Native File Format | Version | Filename Extension | Preferred Use |
|---|---|---|---|
| Microsoft® Excel | Current or 2 previous * | xls | Spreadsheet calculations |
| Corel® QuattroPro | Current or 2 previous * | wb3 | Spreadsheet calculations |
| Lotus® 1-2-3 | Current or 2 previous * | wk3/wk4 | Spreadsheet calculations |
* The acceptable versions of spreadsheets include the current market (non-beta) version distributed by the software vendor, the version distributed immediately prior to the current version, and the version distributed two versions prior to the current version.
Naming Convention
When electronically submitting documents to the NRC, the naming convention for each file should conform to ISO 9660 format, including the Joliet extension. Filenames are limited to a total of 49 characters, which includes the “.”, spaces and the three-character filename extension.
The 49-character limit is subject to the following criteria:
- 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).
- The filename should reflect, to the extent possible within the remaining characters, the chapter or section number (based on the logical breakpoint used for segmentation of the document as described in Section 2.18) and the title of the file/segment being submitted.
- When segmenting a >50 MB file for a multi-part (bundle) submission, each part must include the following: 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 should retain the default three-character file extension associated with the format.
Example: 001 Est of Long-Term Geochem Behavior Sec 1.pdf
(Example explanation: 001 belongs to the first document attached to the submittal; therefore, the next document attached would begin with 002. Est of Long-Term Geochem Behavior is the title of the document. Sec 1 is Section 1 of the document, therefore the next document attached would be Section 2. .pdf is the file extension of an Adobe® Acrobat document.)
File Naming Example Table:
| Document Title | File Name |
|---|---|
| Multiple-Part (Bundle) File Documents | |
| Chapter 1, Estimate of Long-Term Geo-chemical Behavior | 001 C1 Long-Term Geochem Behavior Part 1 of 3.pdf |
| Chapter 2, Estimate of Long-Term Geo-chemical Behavior | 002 C2 Long-Term Geochem Behavior Part 2 of 3.pdf |
| Appendix A Estimate of Long-Term Geo-chemical Behavior | 003 ApA Long-Term Geochem Behavior Part 3 of 3.pdf |
| Single File Documents | |
| Attachment II, CAL-EBS-NU-000017 Rev 003 Calculation, Radiolytic Specie Generation from Internal Waste Package Criticality | 001 Att 2 CAL-EBS-NU-000017 R003.pdf |
| List and Schedule for Model Validation Reports related to Criticality | 001 List-Schd for MVRs related to Criticality.pdf |
| Special Instructions for COLA only: See Section 8.3.1, Naming Conventions for COLA, DCD and ESP Submittal Exceptions for the specific naming convention for COL Applications. |
Security/Access Settings
Submissions should not contain any security settings, password protections, or any other attributes that would 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 pixels per inch (ppi).
- Color PDF resolution, not less than 300 ppi.
- Grayscale PDF resolution, not less than 300 ppi.
Submittals under 10 CFR Part 2, Subpart J, may use the minimum effective resolution for color and grayscale images specified in that subpart.
Resolution Flexibility Table for 10 CFR Part 2, Subpart J:
| Special Situation | Bi-tonal Resolution | Color Resolution | Grayscale Resolution |
|---|---|---|---|
| A document created after January 1, 2004 contains an image scanned before January 1, 2004 | 300 ppi | 150 ppi | 150 ppi |
| A document created before January 1, 2004 | 300 ppi | 150 ppi | 150 ppi |
In these cases, the submitter should maintain the integrity of the scanned image, the quality of the graphic presentation, and a readable representation of the original work capable of being duplicated and/or reproduced.
| Note: | A submitter can run a resolution test by using Preflight (included with Adobe® Acrobat 6/7/8/9 Professional). Preflight guidance can be found on the NRC’s “Reference Materials for Electronic Submissions” Web page. This information is available in PDF document form and in video clips. |
Settings for Creating PDF Formatted Text and Graphic Files
The NRC has established a custom optimization that strikes a balance between print and screen optimizations. 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 on all submittals to the NRC. The settings are specific to Adobe® Acrobat 9.0. However, when PDF creation software other than Adobe® Acrobat 9.0 is used, the PDF creation 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.
| Note: | PDF/A (ISO 19005) is an acceptable file format providing that it also meets the specifications contained in this guidance document. |
| Note: | If you are using an Adobe® product, to maintain documents compatibilities and ensure all security vulnerabilities are resolved, we recommend that you check Adobe's website  periodically to get the latest revision updates for your Adobe® version. |
| 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. This information is available in PDF document form and in video clips to assist users in preparing PDFs in compliance with NRC guidelines. Additionally available from the NRC’s “Reference Materials for Electronic Submissions” Web page are pre-configured PDF Adobe Distiller profiles for Adobe 5/6/7/8/9 (joboptions). |
PDF Settings Example Table:
| General Options | Recommend Optimal on Adobe® Acrobat 9.0.x |
|---|---|
| Compatibility | 1.5, 1.6, 1.7 or 1.8 |
| Object Level Compression | Tags only |
| Optimize for Fast Web View | selected |
| Embed Thumbnails | unselected |
| Auto-Rotate Pages | Off |
| Binding | Left |
| Resolution (ppi) | 300 |
| Images Options | Recommend Optimal on Adobe® Acrobat 9.0.x |
|---|---|
| Color Images: Downsample | Off |
| For images above | 300 ppi |
| Compression | Zip |
| Quality | 8-bit |
| Grayscale: Downsample | Off |
| For images above | 300 ppi |
| Compression | Zip |
| Quality | 8-bit |
| Monochrome: Downsample | Off |
| For images above | 450 ppi |
| Compression | CCITT – Group 4 |
| Anti-Alias to Gray | Off |
| Fonts Options | Recommend Optimal on Adobe® Acrobat 9.0.x |
|---|---|
| Embed All Fonts1 | selected |
| Embed OpenType Fonts | unselected |
| Subset embedded fonts when percent of characters used is less than 100% | selected |
| When Embedding Fails | Warn & Continue |
1You should 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 should be embedded to comply with NARA guidelines.
| Color Options | Recommend Optimal on Adobe® Acrobat 9.0.x |
|---|---|
| Setting File | None |
| Color Management Policy | Tag Everything for Color Management |
| Intent | Preserve |
| Gray | None |
| RGB | SRGB IEC61966-2.1 |
| CMYK | US Web Coated (SWOP)v2 |
| Preserve Overprint Settings | selected |
| Preserve Under Color Removal | selected |
| Transfer Function | Preserve |
| Preserve Halftone | unselected |
| Advanced Options | Recommend Optimal on Adobe® Acrobat 9.0.x |
|---|---|
| Use Prologue ps & Epilogue ps | unselected |
| Allow PS to Override Job Options | selected |
| Allow PostScript XObjects | unselected |
| Preserve Level 2 copypage semantics | selected |
| Save Job Ticket | selected |
| Illustrator Mode | selected |
| Gradients to Smooth Shades | selected |
| ASCII Format | unselected |
| Process DSC Comments | selected |
| Log DSC Warnings | unselected |
| Resize for EPS | selected |
| Preserve EPS Info | selected |
| OPI Comments | selected |
| Preserve Doc Info from DSC | selected |
Use of Color
The NRC discourages the use of color because it significantly increases file size. If the use of color adds no value to understanding the information presented, its use should be avoided. If color is required to make the document understandable, its limited use is acceptable. Examples of color documents that meet these criteria are graphs, bar-charts, and engineering drawings that depend exclusively on the differences in color to understand the information and data being presented. Additionally, logos (e.g., company letterhead, NRC emblem) are acceptable uses of color as they do not appreciably inflate a file’s overall size.
Files with Special Printing Requirements
Documents that contain electronic files with special printing requirements, such as oversize drawings or graphics that require a paper size larger than 11 inches by 17 inches, or documents that require the use of a plotter or other special equipment to print, or document that contain other enhancements such as 3D images, etc., should only be submitted electronically via OSM 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 OSM.
File Linkages (Hyperlinks)
Links within a single electronic PDF file are acceptable if those links are created using PDF authoring software. Multiple linked PDF files may be combined into a single PDF file using utilities often included in PDF authoring software. On the other hand, if a large PDF file (>50 MB) containing internal links is broken into segments and transmitted via multiple electronic transactions then the links between segments will become inoperable within ADAMS and cannot be recreated.
Files containing objects (e.g., pictures, tables, spreadsheets, and 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 to accept because the relationships among links in multiple file submissions are lost when captured in ADAMS or other agency electronic record keeping systems.
Electronic submissions to the docket for placement on the EHD cannot rely on the use of any hyperlinks to other electronic files or web sites in order to generate additional documentary material. If the submittal contains such hyperlinks, then it should include a disclaimer to the effect that the hyperlinks are either inoperable or are not essential to the use of the filing (see Sections 2.12.1 and 9).
If the submittal relies on Internet-based material, then the Internet-based material should be submitted as part of the filing. If the submittal contains hyperlinks to material in another electronic file, and such hyperlinks are necessary to access that material, then either a reference to the material should be provided or the material itself should be submitted.
| Special Instructions for COLA only: See Section 8.3.2 for the specific direction on File Linkages in regards to COL Applications. Also, see the diagram within Section 10.2 for acceptable use of links within COLA submittals. |
Viruses
Files received by the NRC will be checked for viruses prior to acceptance. Any submission identified as having a virus will be rejected and returned to the submitter with an explanation for the rejection.
Macros
Macros in files such as Microsoft® Excel are sometimes detected as viruses. Therefore, the use of macros should be limited.
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 the applicable requirements of copyright law.
Copies
Those submitting documents electronically should not send hard copies of the electronic documents. In instances where the NRC requires a paper copy for accessibility or other reasons, the NRC will make every effort to produce the copy using NRC resources. However, in those instances where the agency is unable to successfully generate an accurate paper copy from the electronic submittal, the NRC may require a paper copy from the submitter. This will be handled on a case-by-case basis.
| Note: | The DOE is required under 10 CFR Part 2 and 63.22 to submit hard copies of the Yucca Mountain License Application (LA) in addition to submitting the LA on OSM, consistent with these regulatory requirements. |
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 OSM. However, only a single copy of the OSM is required to be submitted to each location by the licensee or vender. Electronic submission via the EIE process available on the NRC's “Electronic Submittals” Web page does not require submission to multiple locations.
Segmentation of Large Documents
Large documents with file sizes >50 MB should be divided in file segments of <50 MB (and preferably segmented into files no greater than 15 MB (See Section 2.5)) at logical breakpoints such as:
- Chapters
- Sections
- Subsections
- Appendices
- Exhibits or attachments
- Charts, tables, or formulae
- For large transcripts, the end of a witness’ testimony or session recess
If the recommended file size cannot be achieved, consider moving the graphics (which are often large files) into an appendix or attachment. If, however, a graphic or other Binary Large Object (BLOB) that exceeds the 50 MB limit, but cannot logically be divided, it should not be segmented. In such a case, the graphic or BLOB should not be sent via the EIE process available on the NRC's “Electronic Submittals” Web page and should be provided on OSM in accordance with guidance in Section 4.
| Note: | Oversize drawings and other files with special printing requirements (see Section 2.11), regardless of the file size, should be provided on OSM. |
When OSMs are submitted, use electronic folders to organize the contents at the chapter level consistent with the file name guidance outlined in Section 2.4. The numeric portion of the file name should be sequential across all folders. This means the following:
- 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/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 a file name that reflects the folder where it resides, if practical, in conjunction with complying with the file name guidance.
| Special Instructions for COLA only: See Section 8.3.3 for guidance on segmenting large documents within a COL Application. |
Sensitive Information
This section does not apply to documents containing safeguards information, which are discussed in Section 2.20. If a document contains information that is deemed Sensitive Unclassified Non-Safeguards Information (SUNSI), it may be electronically submitted via the EIE process available on the NRC's “Electronic Submittals” Web page or on OSM. Transmittal documents used to transmit one or more documents containing SUNSI, must be marked to indicate the fact that SUNSI is contained in the documents being transmitted. A header marking must be placed on each page of the transmittal document indicating the type of SUNSI (i.e., “Security-Related Information – Withhold Under 10 CFR 2.390”, or “Proprietary Information – Withhold Under 10 CFR 2.390.”) Note that NRC’s internal procedure for these documents is to mark them as “Official Use Only – Security-Related Information,” or “Official Use Only – Proprietary Information.” Additionally, if the transmittal document does not contain SUNSI and only the enclosures contain SUNSI, the following marking must be placed at the bottom of the first page: "Enclosure(s) transmitted herewith contain(s) SUNSI. When separated from enclosure(s), this transmittal document is decontrolled." Other Federal agencies submitting documents should follow the above guidance regarding transmittal documents; however, they should use their markings for designating sensitive information.
If it is not practical to submit a large document containing SUNSI via the EIE process available on the NRC's “Electronic Submittals” Web page, submit the document via OSM. Submissions made on OSM should be accompanied by a transmittal letter that contains information regarding the sensitivity level of the transmitted documents (see Section 2.7). The transmittal letter should not have a SUNSI header unless SUNSI is contained in it.
When submitting documents via OSM that contain both publicly and non-publicly available files, all of the files should be included. In addition, separate OSM should be provided, containing only the publicly available files. Each OSM should be clearly labeled indicating its availability. Files contained on OSM labeled as “Publicly Available” will be released to the public.
If SUNSI, classified, or safeguards documents are appended to filings in the adjudicatory proceeding, the submitter shall seek an appropriate order from the presiding officer pursuant to 10 CFR Part 2, Subpart C, Part 13, or Part 110, or follow the procedures for Classified Information in 10 CFR Part 2, Subpart I.
For additional information on the procedures for marking and control of SUNSI, the following documents are available on the NRC Public Web site (www.nrc.gov):
- NRC Regulatory Issue Summary 2005-26, “Control of Sensitive Unclassified Non-Safeguards Information Related to Nuclear Power Reactors”, dated November 7, 2005
- NRC Regulatory Issue Summary 2005-31, “Control of Security-Related Sensitive Unclassified Non-Safeguards Information Handled by Individuals, Firms and Entities to NRC Regulation of the Use of Source, Byproduct and Special Nuclear Material”, dated December 22, 2005
- NRC Regulatory Issue Summary 2007-04, “Personally Identifiable Information Submitted to the U.S. Nuclear Regulatory Commission”, dated March 9, 2007
- In addition to the above guidance, other government agencies may designate, mark, and control information according to their procedures. Such information, if not safeguards information or classified information, will be handled by NRC as SUNSI when submitted to the NRC without requiring additional markings.
Classified or Safeguards Information
Documents containing Classified or Safeguards Information shall not be submitted via the EIE process available on the NRC's “Electronic Submittals” Web page.
OSM containing classified information shall be processed and produced on systems approved under the provisions of 10 CFR 95.49. Each OSM should be clearly labeled as containing classified information. The mailing package containing OSM with documents comprised of safeguards information should be processed, marked and transmitted in accordance with the requirements set forth in 10 CFR 73.21(e), 73.21(g), and 73.21(h), as appropriate. OSM containing classified information (e.g., National Security Information or Restricted Data), shall be packaged and submitted to the NRC in accordance with the requirements contained in 10 CFR 95.37, 95.39, and 95.41. If sensitive unclassified, classified, or safeguards documents are appended to filings in the adjudicatory proceeding, the submitter shall seek an appropriate order from the presiding officer pursuant to 10 CFR Part 2, Subpart C, Part 13, or Part 110, or follow the procedures for Classified Information in 10 CFR Part 2, Subpart I.
Who Should Follow This Guidance
This guidance is intended for licensees, applicants, external entities (including Federal, state, and local governments), vendors, and members of the public who submit documents to the NRC.
