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Request for OMB Review Supporting Statements Re Info on Actual Decommissioning Costs for Nuclear Facilities from Current Previous NRC & Agreement State Licensees.Estimated Respondent Burdens Is 290 H
	ML20057B993
Person / Time
Issue date:	09/21/1993
From:	Cranford G; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:	;
References
	OMB-3150-0173, OMB-3150-173, NUDOCS 9309240256
	Download: ML20057B993 (18)
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" Financial Records, Evaluation Costs" NRC is soliciting information on actual decommissioning costs for nuclear facilities from current and previous NRC and Agreement State licensees. This information will be used to determine an accurate decommissioning funding certification.

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f Supporting Statement for Solicitation of Information on Decommissioning Activities (3150-0173)

Description of the Information Solicited Current or former material licensees covered under 10 CFR 30, 40, 70, and 72 (both NRC and Agreement State) who have actual decommissioning experience regarding termination of all or part of their license will be asked to provide information on the actual costs of their decommissioning activities.

Phone contracts for screening as well as contractor site visits will be used.

The initial group of current or former material licensees contacted by phone will be selected largely from the approximately 2300 NRC and Agreement State licensees who are required to provide certification of decommissioning funds for their facilities.

Based on these certifications, some 300 candidates will be selected for the initial phone contacts.

The purpose of the initial telephone contacts is to further screen out the best candidates that have the most useful decommissioning information for this study and minimize the burden to the remaining licensees contacted.

Because only limited information exists on decommissioning activities, only 30 licensees are expected to participate in this information collection.

For the some 30 licensees that are willing to participate in this information gathering program, the NRC contractor will perform a site visit to gather the necessary information in order to minimize the additional burden to these licensees.

NRC is requesting a one-year extension of this collection.

Because of internal delays in obtaining contacts for both NRC and Agreement State-licensees. NRC has been unable to complete the survey solicitations in the one-year clearance period that was originally requested. This extension i

submittal does not request any additional burden, but simply imposes the same information collection burden over a longer time period.

A.

JUSTIFICATION 1.

Need for the Collection of Information It is necessary to collect all available information about actual decommissioning costs for material licensees to resolve uncertainties with regard to the prescribed funding amounts in the current regulations.

For the majority of the licensees, the prescribed funding amounts in the current regulations were based on cost estimate models rather than actual cost data (such information was not available at the time).

Since the original cost estimate models have relatively large uncertainties due to the conservative assumptions used instead of actual data, the current decommissioning funding amounts in the regulations could overestimate the actual costs of decommissioning.

Concurrently, other licensees who may incur large decommissioning costs are excluded under the current requirements. Therefore, it is essential that a concerted attempt be made to more accurately define these costs based on i

actual cost information which should be available today.

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2.

Agency Use of Information The results of the data collected will be used to develop more realistic funding amounts in the decommissioning funding requirements and to provide the technical basis for NRC and Agreement State license reviewers to approve submitted decommissioning funding plans.

3.

Reduction of Burden Throuah Information Technoloov Although there is no legal obstacle to the use of information technology, the one-time nature of the survey may not lend itself to the use of automated information technology.

4.

Effort to Identify Duplication The Information Requirements Control Automated System (IRCAS) was searched to identify duplication.

None was found.

5.

Effort to Use Similar Information There is no similar information available to the NRC.

6.

Effort to Reduce Small Business Burden Less than 10% of licensees participating in this information collection will be small businesses.

Those licensees classified as small businesses are being asked to participate in this survey to ensure that each participant in the universe of respondents is given an equal opportunity to supply cost information.

7.

Consecuences of Less Freauent Collection This is a one-time solicitation.

Less frequent collection (i.e., none at all) could impose unnecessary financial burden on licensees who must provide funds, up front, for future decommissioning costs.

8.

Circumstances Which Justify Variations from OMB Guidelines There is no variation from OMB Guidelines.

9.

Consultations Outsioa NRC Discussions have been held with the Agreement States and with the NRC contractor regarding the need for collection of this information.

The responses from Agreement States have been supportive.

The NRC contractor has developed an information collection program to minimize the burden to licensees while maximizing the usefulness of the information collected.

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a et 10.

Confidentiality of Information All responses and comments will remain anonymous in that participating licensees would not be named in the compilation and use of material received.

The reports and information obtained may be released to the public.

11.

Justification for Sensitive Ouestions Sensitive questions are not used in this information solicitation.

12.

Estimated Annualized Cost to the Federal Government This one-time effort will be performed by an NRC contractor.

Time for the initial contact (telephone conversation) is estimated at 10 minutes per licensee times 300 licensees or 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months .

Approximately 30 licensees will be visited at their site by the contractor after being sent a notice on the type of information needed (Enclosure 1).

A written request for information will require about 1/2 hour of the contractor's time to prepare the information for a total of 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months for 30 licensees.

The purpose of the site visit is to minimize the burden to licensees by having the NRC contractor do the majority of the work associated with the information collection process.

The site visit followup is estimated to take 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of contractor time per licensee for a total of 480 hours0.00556 days 0.133 hours 7.936508e-4 weeks 1.8264e-4 months .

Adding total contractor hours gives 50 + 15 +

480 or 545 hours0.00631 days 0.151 hours 9.011243e-4 weeks 2.073725e-4 months .

Assuming approximately $132 per hour for the level of contractor personnel required for this task results in a total contractor cost of $71,940.

13.

Estimate of Industry Burden This one time effort will require a 10 minute phone conversation time for 300 licensees resulting in 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months .

Followup is assumed for about 30 licensees through contractor site visit and is estimated to take 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of licensee time resulting in 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months .

Thus total licensee time is estimated as 290 hours0.00336 days 0.0806 hours 4.794974e-4 weeks 1.10345e-4 months .

Assuming a $132 per hour licensee labor rate for the level of personnel required, results in a total cost of

$38,280.

14.

Reason for Burden Change This is a one-time information collection.

15.

Publication for Statistical Use This information is not being collected for statistical use.

B.

COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not used in this information collection.

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1 ENCLOSURE I I

OfCOMMISSIONING INFORMATION DESIRED FROM NUCLEAR FACILITY LICENSEES In order for the Nuclear Regulatory Comission (NRC) to develop realistica[ly amended regulations regarding financial assurances required for nuclear facility decomissioning, actual cata from licensee decomissioning activities i

are sought. The type of detailed information desired is given below (Note that this is not a questionnaire, but an identification of the kind of decommissioning information we are seeking based on your experience.)

We will be contacting you shortly to arrange a visit to your facility by one of our j

staff.

1.

Detailed decomissioning plan: status; staff-hours for each labor category of contributors and their respective burdened labor rates; j

other costs; total cost; calendar time requirements.

2.

Pre-decomissioning survey and post-decommissioning survey: status; staff-hours for,each labor category.of contributors and their respective burdened labor rates; other costs; total cost; radiation dose rates and doses to personnel; calendar time requirements.

3.

Decontamination and dismantling activities: status; forms and quantities of materials for decontamination and/or dismantling; decontamination and dismantling techniques; labor information as in I

prior items; materials and supplies needed and their costs and unit costs; services needed and their costs and unit costs; fuel materials and electricity and their costs; other costs; total cost; radiation dose rates and doses to personnel; calendar time requirements.

4.

Waste management activities:

status; quantities and characteristics of radioactive wastes and hazardous wastes generated from each major decontamination or dismantling or other activity; waste treatment i

processes used; quantities and characteristics of treated and/or conditioned wastes; labor information as in prior items; materials and supplies, services needed, fuel materials and electricity, radiation dose information, and calendar time information as in Item 3; transportation unit and total costs; waste disposal unit and total costs; other costs; total cost; salvageable materials, their disposition and value credits.

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Administrative activities:

status; staff-hours for each labor category of contributors and their respectives burdened labor rates; insurance costs and taxes during decomissioning; other costs; total cost; calendar time requirements.

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For further information, please contact:

Richard I. Smith Battelle, Pacific Northwest Laboratory

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P. O. Box 999 3320 Q Avenue ISB-II Building, MS-K7-90 Richland, WA 993552 Telephone:

(509) 375-6506; Fax:

(509) 375-6417 i

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k FIN No. L2025 NRC 189/Page 3 of 9

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Obiectives of Prooosed Work The objective of this project is to provide the U.S. Nuclear Regulatory Comission (NRC) with a well-coordinated program of activities that support the NRC's need for information and analyses related to decomissioning of i

fuel-cycle and non-fuel-cycle nuclear facilities.

The research under this project will update factors, formulae, and infonnation bases needed by the NRC l

staff for the regulations. These activities will include:

update to 1992 dollars the cost estimates developed in the earlier NUREG/CR reports on fuel-cycle and non-fuel-cycle facility decomissioning, excluding the mixed oxide fuel fabrication i

facility.

3 identify, gather and evaluate data on radiation dose, labor 2

requirements, waste characteristics, schedules and costs from ongoing fuel-cycle and non-fuel-cycle facility decomissioning activities in the U.S.

incorporate the above information into reevaluation of the reference fuel-cycle studies and reevaluation / expansion of the non-fuel-cycle facility decomissioning studies, reflecting current conditions relating to waste classifications, low-level radioactive waste and hazardous waste disposal, reductions in allowable occupational radiation dose to workers, and residual radioactivity limits for license termination.

identify and evaluate current technology for use in decontamination of site soil during decommissioning.

provide, as necessary, technical support for decommissioning rulemaking activities for material licensees.

It is expected that, based on the results of this work, an information base will be available to allow the NRC staff to consider initiation of rulemaking in this area in Fiscal Year 1994. The NRC is considering the possibility of rulemaking in two stages.

In the first and simplest stage, the regulation requiring funding amounts for decomissioning could be updated for inflation, and a formula similar to the approach taken in 10 CFR 50 for reactors could also be included, to allow for annual inflation adjustments.

In the more complex second rulemaking stage, an information base on actual costs for fuel-cycle and non-fuel-cycle facilities in the U.S. would be used to develop a classif hation scheme for categorizing decomissioning costs.

2.

Summary of Prior Year's Efforts This was a new project initiated late in Fiscal Year 1991.

Work accomplished in Fiscal Year 1991 consisted of initiating the planning for this study. Updated unit cost data were received from two low-level radioactive waste disposal facilities and from a truck transporter of low-level radioactive wastes, and other data collection was initiated.

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FIN No. L2025 NRC 189/Page 4 of 9 3.

Work to be Performed and Excetted Results This project is subdivided into three major tasks, with a total of seven subtasks. Each of these tasks and subtasks is described below.

Task 1.

Staae 1 Rule Develooment Basis PNL will develop a technical basis for modification of the present funding requirements in 10 CFR Parts 30, 40, and 70 for inflation. This work will be carried out in two subtasks.

Subtask 1.1 Vodate the cost estimates develooed in the earlier NUREG/CR reports on fuel-cycle and non-fuel-cycle facility decommissioninc to J192 dollars.

9 Decomissioning costs for the non-fuel-cycle facilities (NUREG/CR-1754, Addendum 1 - Table 2.4) will be updated to 1992 dollars.

Inflation formulae will be developed in terms of waste burial costs, labor costs, and other parameters that may be appropriate and necessary.

These formulae will be included in an addendum to the various NUREG/CR reports already developed.

The results of these activities will be documented in draft form by March 31, 1993.

Subtask 1.2 Develoo a NUREG/CR report on the decomissionino of sealed sources.

A new NUREG/CR report will be developed on the technology, safety and costs for decommissioning of sealed sources.

Except for the very large irradiators, no reference facility is required.

Also, for the decomissioning of a very large irradiator facility, sensitivity of the costs to contamination levels will be considered.

The spectrum of sealed source decomissioning costs should include alternatives where a) the tsanufacturer or the DOE will take the source back, b) where the licessee cannot dispose of the source and needs to maintain it in storage; c) and when the licensee can dispose of the sealed source in a comercial low-level waste burial facility.

Inflation formulae similar to those developed under Subtask 1.1 will be developed in terms of waste burial costs, labor costs, and other parameters that may be necessary (such as possession limits, etc.), and will be included in the NUREG/CR report on sealed sources.

This report will be completed in draft form by March 31, 1993.

I Task 2.

Staae 2 Rule Deveicoment Basis A case-specific decomissioning (or related) information database and a cost classification scheme will be developed to replace the certification approach currently used in 10 CFR Parts 30, 40, and 70.

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FIN No. L2025 NRC 189/Page 5 of 9 Subtask 2.1 Gather and evaluate data on radiation dose. labor reouirements, waste characteristics. schedules and costs from onooino fuel-cvCle and non-fuel-cvCle facility decommissionino activities in the L.l.

A case-specific examination of actual experience in the decommissioning of fuel-cycle and non-fuel-cycle facilities (or related activities) will be carried out. The information will be obtained by examining NRC licensee dockets and NRC and Agreement State licensee experience.

Other experiences such as those from DOE facilities, foreign countries, or unit cost data from reactor facilities will also be used to the extent possible.

Activity 2.1.a.

Plannino for Data Collection.

The first step in developing this work will be development of a proposed plan for obtaining information. The plan will include examining relevant NRC docket files to obtain NRC licensee information and to determine the potential for follow-up, screening contacts for preliminary inquiries into decommissioning experience from NRC and Agreement State licensees, and site visits to obtain specific information.

The proposed plan will be submitted to the NRC project manager for approval, and will provide the documentation and support for the necessary 0MB clearance requirements.

Activity 2.1.b.

Data Collection and Evaluation The data collection and examination will be carried out according to the approved plan developed under Activity 2.1.a.

The initial emphasis of this activity will be for non-fuel-cycle facilities.

Decommissioning cost information will be analyzed to include some departures from normal situations for sensitivity analysis considerations. Attempts will be made to obtain detailed labor, materials, and waste disposal costs associated with cleanup or decommissioning of facilities; to look for generic applicability; and to develop a set of appropriate unit cost factors (and dose factors) for these various activities.

This activ.ity and subtask will be completed at the end of Fiscal Year 1993, but additional data made available after that time will be utilized as much as practicable. The information will be utilized and documented J

in the reevaluations carried out in Subtask 2.2.

Subtask 2.2.

IncorDorate the above information into reevaluations of the reference fuel-cycle and non-fuel-cycle facility decommissionino studies.

reflectino all essential current conditions that affect decommissionino costs.

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FIN No. L2025 NRC 189/Page 6 of 9 The.information generated under Task 2.1 will be analyzed for consistency and subsequently utilized in reevaluation of the previous NUREG/CR reports on decomissioning of fuel-cycle and non-fuel-cycle facilities, and will result in preparation of new reports.

These reports will include sensitivity analyses on the effects of nonroutine contamination on decomissioning costs. When data are insufficient or inadequate, appropriate modeling will be developed and applied. The particular studies to be reanalyzed are:

NUREG/CR-1266 Low-Enriched Uranium Fuel Fabrication Plant NUREG/CR-1754 Non-Fuel-Cycle Nuclear Facilities.

NUREG/CR-1757 Uranium Hexafluoride Conversion Plant NUREG/CR-2210 Independent Spent Fuel Storage Installations.

I These reevaluations of the earlier NUREG/CR reports on fuel-cycle and non-fuel-cycle nuclear facility decomissioning and the development of the additional NUREG/CR reports, will be. carried out on a schedule to be established through consultations between the NRC Project Manager and other Offices of NRC.

The task for the reevaluation and/or additions to NUREG/CR-1754 will be initiated in mid-year of Fiscal Year 1993. A draft of the reevaluated NUREG/CR-1754 will be completed by mid-Fiscal Year 1994.

Other drafts will be submitted throughout Fiscal Years 1994 and 1995.

The following points will be included in conducting the Task 2 reevaluations:

The cost evaluations will utilize the unit cost factor approach to the extent possible, and will reflect current LLW burial site charges, labor rates, energy, and transportation rates.

Current waste classifications will be considered during the evaluations of packaging and transport costs.

Management of mixed wastes and/or toxic wastes resulting from decomissioning (e.g., asbestos), which cannot be. segregated from the decomissioning LLW, will be included in these reevaluations.

t Current and anticipated future limits (e.g., recent recomendations f

of the ICRP and NCRP) on cumulative occupational radiation doses will be incorporated into these analyses.

I Costs of onsite storage and/or storage at a waste broker will also be examined.

Formulae will be developed in all of these NUREG/CR reports to deal with inflation for rulemaking purposes in terms of labor costs, waste disposal costs, and any other relevant parameters similar to those under Subtask-1.1.

Each major group of nonreactor licensees (e.g., large irradiators, uranium processing facilities, etc.) will be considered using the.new

i FIN No. L2025 NRC 189/Page 7 of 9 cost database. Such considerations will be emphasized initially in the revised version of NUREG/CR-1754.

Draft addenda / reports will be prepared for the earlier fuel-cycle and non-fuel-cycle facility NUREG/CR reports. All of these draft reports will be reviewed and commented on by the NRC Project Manager and by other reviewers that the Project Manager might designate.

Coments will be resolved and a final camera-ready master of each of the reports will be delivered to the NRC Project Manager for publication and distribution.

Subtask 2.3 Develoo classification scheme for cateoorizino licensee decomissionino costs.

A classification scheme will be developed, recomended, and justified for rulemaking purposes, that will categorize particular licensee decomissioning costs and to facilitate assigning minimum funding requirements. The approach used will initially consider the scheme based upon the licensing fee system in 10 CFR 170. Alternative schemes that can be adequately quantified and that result in reasonable categorization will also be explored.

A draft of the classification scheme will be incorporated as an appendix to the reevaluated NUREG/CR-1754, and will be completed by March 31, 1994.

Task 3.

Other Related Efforts.

Other activities will be carried out that will support NRC's rulemaking regarding decomissioning of fuel-cycle and non-fuel-cycle facilities.

Subtask 3.1 Identify and evaluate technolooy used in current decontamination of site soil durino decommissionino, i

l The current state of technology for decontamination of soils will be described, and the various techniques will be evaluated for technical and cost effectiveness. Applicability of these technologies to sites being decomissioned will be examined. The results of these investigations, i

which will include the current costs for these techniques, will be documented in a letter report to the NRC Project Manager.

Subtask 3.2 Reculatory succort.

Technical and administrative support will be provided, as requested, for rulemaking activities for material facilities that arise with respect to j

decomissioning in areas related to the topics addressed in this project.

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FIN No. L2025 l

NRC 189/Page 8 of 9 Meetinos and Travel j

In order to carry out the program outlined for this project, it will be necessary, as a minimum, for PNL staff to brief the NRC staff annually at Rockville, Maryland.

PNL staff travel for data gathering and related activities will be necessary, and will be coordinated with the NRC Project Manager as the need for such travel is identified.

4.

Descriotion of Follow-on Efforts This project is expected to be a continuing effort that will require several years to complete, with similar activities being carried out during each year as each of the earlier NUREG/CR reports is reevaluated and addenda /new reports are prepared.

5.

Relationshio to Other Proiects This project is related to the previously completed projects that developed reports on technology, safety and costs of decomissioning licensed fuel-cycle and non-fuel-cycle nuclear facilities, to the development of the GEIS on decomissioning, and to the Final Decomissioning Rule.

It is also somewhat related to the decomissioning activities being carried out by the Department of Energy's Office of Environmental Restoration and Waste Management, including the DOE's International Technology Transfer activities.

6.

Reoortino Schedule Project activities and costs will be reported monthly.

Technical letter reports on specific topics will be issued as the work is completed.

Formal NUREG/CR addenda will be prepared on the cost updates prepared for each of the fuel-cycle and non-fuel-cycle facilities previously evaluated.

Separate NUREG/CR reports will be prepared on decomissioning sealed source facilities and on the reevaluations of the selected earlier NUREG/CR reports examined collectively in NUREG/CR-1754.

7.

Subcontractor Information No subcontracts are anticipated under this program. However, if special data or studies beyond the capabilities of PNL are required, subcontracts will be issued as necessary, subject to prior concurrence by the NRC Project Manager.

8.

New Capital Eauipment Recuirements No new capital equipment needs have been identified for this program, i

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FIN No. L2025 NRC 189/Page 9 of 9 9.

Soecial Facilities Recuirements No need for special facilities has been identified for this program.

10. Conflict of Interest This proposed project has been reviewed by Batte11e's Corporate Scope Coordinator, who indicates that it does not duplicate work being perforaied for others. Bettelle, Pacific Northwest Laboratory is aware of nothing that would prevent it from conducting the activities described in this proposal so as to avoid any bias in the performance of the work and to avoid any unfair competitive advantage as a result thereof.

11.

Excected Classification of Sensitivity This is an unclassified project. Safeguards, proprietary, or other sensitive information is not involved.

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18760 NRC FV92 Revision. RI SMITH ATTACHMENT A FY91 FY91 FY91 WANYD R FUNDINC 459098 SCI PROJECT COST DRUkD0tN COST 24f8 1.88 (Funding ratio included)

FUNDINC RATIO 187.5 OTHER S

NRC E1FWENTS FRONT PACE BRUNDOWN

-10E COST tatTIftlED BY 187.5 117 labor 3909 (-----

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3178,438 354 DOE ITC 3473 (-----

INDIR CUST ----)

1149,258 542 CIA 3642 (-----

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3183,875 542R CIA 312 (-----

CIA B32 SERVICE ASSE55WENT 3183 (-----

DIHER 826,438 847 NRC BUS OFFICE 138 (-----

OTHER 996 INST. StrP 3123 (-----

INDIR COST 958 l#JC ASSEssuENT 147 (-----

INDIR COST 981 CDUPOSIT EiU 3145 (-----

INDIR COST 981R ES&H 1830 Coup Bly 18 ( ---- INDIR COST TOTAL 32,399 3458,e86 (N0 00E ADDER FOR FY91)

HOURS FY WANWONTH WANYD R SCl[NTIFIC 19.8 8.13 8.81 DIHER 25 0 82 8 88 i

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Documents Containing Reporting or Recordkeeping Requirements; Office of Management and Budget (0MB) Review AGENCY:

Nuclear Regulatory Commission (NRC).

ACTION:

Notice of the OMB review of information collection.

s

SUMMARY

The Nuclear Regulatory Commission _ has recently ' submitted to 0MB f

for review the following proposal for collection of information

]

under the provisions of the Paperwork Reduction Act (44 U.S.C.

Chapter 35).

t 1

Type of submission, new, revised, or extension:

Extension 2.

The title of the information collection:

" Solicitation of Information on Actual Decommissioning Activities."

3.

The form number if applicable: Not applicable.

4.

How often is the collection required: This is a voluntary-one-time solicitation of information by the NRC.

1

d 5.

Who will be required or asked to report:

Previous and current material licensees - licensed under 10 CFR 30, 40, 70, and 72, as well as Agreement State licensees who are likely to have information based on a screening by the NRC of their licensee docket files.

6.

An estimate of the number of respondents:

300 for initial contact (phone conservation); 30 for follow-up through a site visit by the NRC contractor.

7.

An estimate of the number of hours annually needed to complete the requirament or request:

290 8.

An indication of whether Section 3504(h), Pub. L.96-511 applies:

Not applicable 9.

Abstract:

The Nuclear Regulatory Commission is soliciting information on the actual costs for decommissioning nuclear facilities covered under 10 CFR Parts 30, 40, 70, and 72 (material licensees) from previous and current NRC and Agreement State licensees.

This information is needed to make a more accurate, realistic, and potentially less conservative a

.sment of decommissioning costs than those presented in the current regulation for decommissioning funding cert !'; n ion.

This information also may be used as a basis fcr tw '

ing the current requirements and for 2

}

P t

i datermining if the current financial assurance burdens on t

the licensees can be reduced.

P Copies of the submittal may be inspected or obtained for a fee from the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC.

l Comments and questions can be directed by mail to the OMB reviewer:

Tim Hunt Office of Information and Regulatory Affairs (3150-0173)

NE0B-3019 Office of Management

..d Budget Washington, DC 20503 Comments may also be communicated by telephone at (202) 395-3084.

The NRC Clearance Officer is Brenda Jo. Shelton, (301) 492-8132.

$/

Dated a-sda, Maryland, this day ofbd W k, 1993.

W For the Nuclear Regulatory Commission.

2/

7

/

/ Gerald F. Crahford, Design &ted Senior N Official for Information Resources Management 3

ML20057B993

Text

SUMMARY

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