ML20214N672

Rev 3 to CRGR Charter

ML20214N672
Person / Time
Issue date:	09/30/1986
From:	Committee To Review Generic Requirements
To:
Shared Package
ML20214N676	List: ML20214N672 ML20214Q090
References
NUDOCS 8609160422
Download: ML20214N672 (17)

Text

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• Revision 3

' September 1986 e P

~ CHARTER COM ITTEE TO REVIEW GENERIC REQUIREMENTS Revision 3 September 1986 p * ,m ,

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' Revision 3

, September 1986 TABLE OF CONTENTS P.aie 1

I. Purpose............................................................

Membership......................................................... 2 II.

2 III. CRGR Scope...,......................................................

IV. CRGR Operating Procedures.......................................... 5 8

V. Reporting Requirements.............................................

Attachment 1: New Generic Requirement and Staff Position Review Process Attachment 2: Procedures to Control Communication of Generic Requirements and Staff Positions to Reactor Licensees APPROVED BY THE COMMISSION JUNE 16,1982(SECY-82-39A)

REVISION 1 APPROVED BY THE COMMISSION (SECY MEMO DTD JANUARY 6, 1984)

REVISION 2 APPROVED BY THE COMMISSION (COMSECY-86-5, JUNE 20, 1986)

REVISION 3 APPROVED BY THE COMMISSION (SECY MEMO DTD AUGUST 13,1986) 1 l

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Revision 3 September 1986

! I. PURPOSE i

l The Comittee to Review Generic Requirements (CRGR) has the. responsibility to review and recomend to the Executive Director for Operations (EDO) approval or ,

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' disapproval of requirements or staff positions to be imposed by the NRC staff .

L on one or more classes of power reactors. This review applies to staff propos-als of requirements or positions which reduce existing requirements or posi-i tions and proposals which increase or change requirements. The implementation of this responsibility shall be conducted in such a manner so as to assure that '

the provisions of 10 CFR 2.204, 10 CFR 50.109 and 10 CFR 50.54(f) as pertaining to generic requirements and staff positions are implemented by the staff. The objectives of the CRGR process are to eliminate or remove any unnecessary bur-

, dens placed on licensees, reduce the exposure of workers to radiation in imple-menting some of these requirements, and conserve NRC resources while at the '

same time assuring the adequate protection of the public health and safety and furthering the review of new, cost-effective requirements and staff positions.

The CRGR and the associated staff procedures will assure NRC staff implementa-tion of 10 CFR 50.54(f) and 50.109 for generic backfit matters. The overall process will assure that requirements and staff positions in place or to be issued (a) do in fact contribute effectively and significantly to the health and safety of the public, and (b) do lead to utilization of both NRC and licensee resources in as optimal a fashion as possible in the overall achieve-ment of protection of public health and safety. By having the Comittee submit recommendations directly to the EDO, a single agencywide point of control will be provided.

The CRGR will focus primarily on proposed new requirements and staff positions, but it will also review selected existing requirements and staff positions which may place unnecessary burdens on licensee or agency resources. In reach-1

ing its recomendation, the CRGR shall consult with the proposing office to ensure that the reasons for the proposed requirement or staff position are well understood and that the provisions of 10 CFR 50.109, 50.54(f), and 10 CFR 2.204, if applicable, are appropriately addressed by the staff proposal. The j CRGR shall submit to the EDO a statement of the reasons for its recomenda-tions. This statement shall provide a clear indication of the basis for the recomendation and, when appropriate, relate this basis to the provisions of 10 CFR 50.109, 50.54(f), and 10 CFR 2.204.

Tools used by the CRGR for scrutiny are expected to include cost-benefit analy-sis and probabilistic risk assessment where data for its proper use are ade-quate. Therefore, to the extent possible, written staff justifications should make use of these evaluation techniques. The use of cost-benefit analyses and other tools should help to make it possible to detennine which proposed re-quirements and staff positions have real safety significance, as distinguished from those proposed requirements and staff positions which should be given a lower priority or those which might be dropped entirely. When such techniques cannot be applied for lack of available, appropriate, or relevant data, other j methods will be used.

The EDO may authorize deviations from this Charter when the EDO, after consult-

) ing with the Chairman, finds that such action is in the public interest and the j deviation otherwise complies with applicable regulations including 10 CFR I

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September 1986 2.204, 50.54(f) and 50.109. Such authorization shall be written and shall become a part of the record of CRGR actions. The rulemaking proposal presented to and considered by the CRGR, and ultimately, if presented to the Commission, should~ include any necessary exemption request with supporting reasons for the proposed exemption.

II. MEMBERSHIP This Committee shall be chaired by the Deputy Executive Director for Regional i Operations and Generic Requirements (DEDROGR), and it shall consist of, in ad-dition to the DEDROGR, one individual each from NRR, IE, NMSS, RES and AEOD appointed by the Executive Director for Operations and one individual from OGC appointed by the ED0 with the concurrence of the General Counsel. The DEDROGR shall assure that process controls for overall agency management of the generic i backfit process are developed and maintained. These process controls shall include specific procedures, training, progress monitoring systems, and pro-visions for obtaining and. evaluating both staff and industry views on the con-duct of the backfit process. The DEDROGR is also responsible for assuring that each licensee is informed of the existence and structure of the NRC program described in this Charter. The DEDROGR shall assure that substantive changes in the Charter are comunicated to the licensees.

The Office of the DEDROGR will provide staff support. The Committee may use l

several non-NRC persons as consultants in special technical areas.

New members will be appointed as the need arises. If a member cannot attend a meeting of the CRGR, the applicable Office Director may propose an alternative for the appointing official's approval. It is the responsibility of the i

alternate member to be fully versed on the agenda items before the Comittee.

l III. CRGR SCOPE A. The CRGR shall consider all proposed new or amended generic requirements and staff positions to be imposed by the NRC staff on one or more class-es of power reactors. These include:

(1) All staff papers which propose the adoption of rules or policy statements affecting power reactors or modifying any other rule so as to affect requirements or staff positions applicable to reactor licensees, including information required of reactor licensees or applicants for reactor licenses or construction permits.

(ii) All staff papers proposing new or revised rules of the type de-scribed in paragraph (1), including Advanced Notices.

(iii)

All proposed new or revised regulatory guides; all proposed new or revised Standard Review Plan (SRP) sections; all proposed new or revised branch technical positions; all proposed generic letters; Revision 3 l

. September 1986 all multiplant orders, show cause orders, and 50.54(f) lettersI; i all bulletins and circulars; and USI NUREGs; and all new or re-vised Standard Technical Specifications.  ;

All staff proposed generic information requests will be examined

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! by the CRGR in accordance with 10 CFR 50.54(f). Except for infor- I mation sought to verify licensee compliance with the current li- '

censing basis for a facility, the staff must prepare the reason or reasons for each information request prior to issuance to ensure '

that the burden to be imposed on respondents is justified in view of the potential safety significance of the issue to be addressed in the requested information. CRGR examination of generic letters will include those letters proposed to be sent to construction pemit holders. For those plants for which an operating license is not yet issued, an exception to staff analysis may be granted ,

by the Office Director only if the staff seeks infomation of a i type routinely sought as part of the standard procedures applicable to the review of applications. If a request seeks to gather infomation pursuant to development of a new staff posi-tion, then the exception does not apply and the reasons for the request must be prepared and approved prior to issuance of the request. When staff evaluations of the necessity for a request are

required, the evaluation shall include at least the following elements

(a) A problem statement that describes the need for the infor-l mation in tems of potential safety benefit.

(b) The licensee actions required and the cost to develop a re- ,

sponse to the information request.

(c) An anticipated schedule for NRC use of the information.

B. The CRGR shall confider all licenses, license amendments, approvals of Preliminary Design Approvals (PDAs) and Final Design Approvals (FDAs),

minutes of conferences with owners groups, licensees or vendors, staff approvals of topical reports, information notices, and all other docu-ments, letters or comunications of a generic nature which are presented toreflectorinterpretNRCstaffpositjons,unlesssuchdocumentsrefer only to requirements or staff positions previously applicable to the affected licensees and approved by the appropriate officials. The 1 It is expected that the offices will develop internal procedures to ensure that information requests are developed in accordance with 50.54(f) 2 It is expected that the offices shall develop internal procedures to en-sure that the documents and comunications referenced above will contain only previously approved requirements or staff positions.

Revision 3

• September 1986 following are examples of approved staff positions not requiring CRGR review:

(1) positions or interpretations which are contained in regulations, policy statements, regulatory guides, the Standard Review Plan, branch technical positions, generic letters, orders, topical ap-provals, PDAs, FDAs, licenses and license amendments which have been promulgated prior to November 12, 1981. Any document or com-munication of this type shall cite and accurately state the position as reflected in a previously promulgated regulation, order, Regulatory Guide, SRP, etc.

(ii) positions after November 12, 1981 which have been approved through this established generic review process.

C. For those rare instances where it is judged that an imediately effec-tive action is needed to ensure that facilities pose no undue risk to the health and safety of the public (10 CFR 50.109(a)(4)(ii)), no prior review by the CRGR is necessary. However, the staff shall conduct a documented evaluation which includes a statement of the objectives of and reasons for the actions and the basis for invoking the exception.

Theanalysisreferencedin50.109(a)(2)maybeconductedeitherbefore or after the action is taken and shall be subject to CRGR review. This analysis shall document the safety significance and appropriateness of the action taken and consideration of how costs contribute to selecting the solution among various acceptable alternatives. The CRGR Chairman These should be notified by the Office Director originating the action.

imediately effective requirements will be reported to the Comittee for information and will be included in the report to the Comission.

D. For each proposed requirement or staff position not requiring imedi-ately effective action, the proposing office is to identify the require-ment as either Category I or 2.

Category I requirements and staff positions are those which the propos-ing office rates as urgent to overcome a safety problem requiring ime-diate resolution or to comply with a legal requirement for imediate or near-term compliance. Category 1 items are expected to be infrequent and few in number, and they are to be reviewed or otherwise dealt with within 2-working days of receipt by the CRGR. If the appropriateness of designation as Category 1 is questioned by the CRGR Chairman, and if the question is not resolved within the 2 working-day limit, the proposed requirementorstaffgositionistobeforwardedbytheCRGRChairmanto the EDO for decision.

3 The requirements of the backfit rule and the Commission guidance for re-laxation of requirements and staff positions shall continue to apply.

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' Revision 3 S ptember 1986 Category 2 requirements and staff positions are those which do not meet the criteria for designation as Category 1. These are to be scrutinized carefully by the CRGR on the basis of written justification, which must be submitted by the proposing office along with the proposed requirement or staff position.

Staff proposed generic modifications considered necessary to bring fa-cilities into compliance with licenses or the rules or orders of the Comission, or into confonnance with written commitments by licensees, will not require analyses of the type described in Section IV (B)(vii).

The proposed action shall be presented to the CRGR Chairman with a docu-mented evaluation including a statement of the objectives of and reasons for the proposed requirement or staff position and the basis for involv-ing the exception under 10 CFR 50.109(a)(4)(1).

E. The DEDROGR shall compile and maintain a list of projected generic re-quirements and staff positions based on input from the NRC offices. The CRGR may receive early briefings from the offices on the proposed new generic requirements or staff positions before the staff has developed the requirements or positions and held discussions with the ACRS.

F. The CRGR may be consulted on any issue deemed appropriate by the CRGR Chairman.

~IV. CRGR OPERATING PROCEDURES A. Meeting Notices Wetings will generally be held at regular intervals and will be sched-uled well in advance. Meeting notices will generally be issued by the CRGR Chairman 2 weeks in advance of each meeting, except for Category 1 items, with available background material on each item to be considered by the Committee.

B. Contents of Packages Submitted to CRGR

! The following requirements apply for proposals to reduce existing re-quirements or positions as well as proposals to increase requirements or positions. Each package submitted to the CRGR for review shall include fifteen (15) copies of the following information:

(1) The proposed generic requirement or staff position as it is pro-posed to be sent out to licensees.

(ii) Draft staff papers or other underlying staff documents supporting (A copy of all materials the requirements or staff positions.

referenced in the document shall be made available upon request to the DEDROGR staff. Any comittee member may request DEDROGR staff to obtain a copy of any referenced material for his or her use.)

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Revision 3

• September 1986 (iii) Each proposed requirement or staff position shall contain the sponsoring office's position as to whether the proposal would in-crease requirements or staff positions, implement existing re-quirements or staff positions, or would relax or reduce existing requirements or staff positions.

(iv) The proposed method of implementation along with the concurrence (and any coments) of OGC on the method proposed.

(v) Regulatory analyses generally confonning to the directives and guidance of NUREG/BR-0058 and NUREG/CR-3568.

(vi) Identification of the category of reactor plants to which the ge-neric requirement or staff position is to apply (that is, whether it is to apply to new plants only, new Ols only, OLs after a cer-tain date, OLs before a certain date, all Ols, all plants under construction, all plants, all water reactors, all PWRs only, some vendor types, some vintage types such as BWR 6 and 4, jet pump and nonjet pump plants, etc.).

(vii) For each such category of reactor plants, an evaluation which dem-onstrates how the action should be prioritized and scheduled in

' light of other ongoing regulatory activities. The evaluation shall document for consideration information available concerning any of the following factors as may be appropriate and any other information relevant and material to the proposed action:

(a) Statement of the specific objectives that the proposed action is designed to achieve; (b) General description of the activity that would be required by the licensee or applicant in order to complete the action; (c) Potential change in the risk to the public from the accidental offsite release of radioactive material; (d) Potential impact on radiological exposure of facility employ-ees and other onsite workers.

(e) Installation and continuing costs associated with the action, including the cost of facility downtime or the cost of con-struction delay; (f) The potential safety impact of changes in plant or operational complexity, including the relationship to proposed and exist-ing regulatory requirements and staff positions; (g) The estimated resource burden on the NRC associated with the proposed action and the availability of such resources; i  !

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_S:ptember 1986 (h) The potential impact of differences in facility type, design i or age on the relevancy and practicality of the proposed action; (1) Whether the proposed action is interim or final, and if inter-im, the justification for imposing the proposed action on an interim basis.

(viii) For each evaluation conducted pursuant to 10 CFR 50.109, the pro-posing office director's determination, together with the ration-ale for the determination based on the considerations of paragraphs (1) through (vii) above, that (a) there is a substantial increase in the overall protection of public health and safety or the comon defense and security to be derived from the proposal; and (b) the direct and indirect costs of implementation, for the fa-cilities affected, are justified in view of this increased protection.

(ix) For each evaluation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office director's determination, together with the rationale for the determination based on the considerations of paragraphs (i) through (vii) above, that (a) the public health and safety and the common defense and security would be adequately protected if the proposed reduction in requirements or positions were implemented, and (b) the cost savings attributed to the action would be substantial enough to justify taking the action.

C. DEDROGR Staff Review DEDROGR staff shall review each package for completeness. If the pack-age is not sufficient for CRGR consideration, it shall be returned by DEDROGR to the originating office with reasons for such action. Prior notice to the Comittee is not needed; however, CRGR members shall be informed of such actions.

- An accepted package shall be scheduled for CRGR consideration; however, scheduling priorities shall be at the discretion of the CRGR Chairman.

- All requests for particular scheduling shall be made to the CRGR Chairman.

- The DEDROGR staff may obtain additional information from industry and consultants on such proposals, particularly with respect to the cost of implementation, realistic schedule for implementation,

Revision 3 .

September 1986 and the ability of licensees to safely and efficiently carry out the full range of safety-related activities at each facility while implementing the proposed requirement or staff position. The DEDROGR staff normally shall provide a brief sumary analysis of each package to CRGR members prior to the meetings.

D. CRGR Meeting Minutes At each meeting, for each package scheduled for discussion, the sponsor-ing office shall present to the CRGR the proposed generic requirement or staff position and respond to comments and questions. A reasonable amount of time, within the discretion of the CRGR Chairman, shall be pemitted for discussion of each item by Committee members. At the con-clusion of the discussion, each Comittee member shall sumarize his position. The minutes of each meeting, including CRGR recommendations and the bases therefor shall be prepared. Minutes normally shall be circulated to all members within 5-working days after the the meeting, and each member shall have 5-working days to coment in writing on the minutes. It is the responsibility of each member to assure that the minutes accurately reflect his views. All comments received within that period shall be part of the minutes of the meeting.

The Committee shall recomend to the EDO, approval, disapproval, modifi-cation, or conditioning of generic proposals considered by the Committee, as well as the method of implementation of such requirements or staff positions and appropriate scheduling for such implementation, which shall give consideration to the ability.of licensees to safely and efficiently carry out the entire range of safety-related activities at each facility. The minutes shall give an accurate description of the basis for the recomendations and shall accurately reflect the consensus decision of the Comittee. Copies of the minutes shall be distributed to the Comission, Office Directors, Regional Administrators, CRGR Mem-bers, and the Public Document Room. The ED0's action taken in response to the Committee's recommendations shall be provided in writing to the Commission.

E. Recordkeeping System The DEDROGR staff will assure that there is ar archival system for keep-ing records of all packages submitted to DEDROGR, actions by the staff, sumary minutes of CRGR consideration of each package including correc-tions, recommendations by the Comittee, and decisions by the EDO.

V. REPORTING REQUIREMENTS The DEDROGR staff shall prepare a report to be submitted by the EDO to the Com-mission each month. The report will provide a brief sumary of CRGR activi-ties, including a list of all items that have been sent to the CRGR and their current status. The report shall be distributed to CRGR Members, Office Direc-tors, Regional Administrators and the Public Document Room.

. Attachment I to CRGR Charter September 1986 Revision 3 NEW GENERIC REQUIREMENT AND STAFF POSITION REVIEW PROCESS The attached chart is a schematic representation of how new generic require-ments and staff positions are developed, revised and implemented.

In the early stages of developing a proposed new requirement or staff position, it is contemplated that the staff may have discussions with the industry, ACRS and the public to obtain preliminary information of the costs and safety benefits of the proposed action. On the basis of this information,'the pro-posing office will prepare the package for CRGR review.

The CRGR may recommend approval, revision, or disapproval or that further public comment be sought. Af ter CRGR and EDO approval, there may be further review by the ACRS or the Commission. Decisions by the Commission are controlling.

Once final approval is received, the individual project managers will norwelly work with each licensee to develop a plant-specific implementation schedule taking into consideration all of the other requirements and staff positions that are being implemented at each plant.

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September 1986 SCHEMATIC REPRESENTATION OF NEW REQUIREMENTS REVIEW l

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USIs Generic Issues Prioritize and .

Discussions With l Develop Proposed Reg. Guides industry. ACRS, i i Requirement Sulletins & Orders Including Public Proposed Rules Etc. Regulatory Analysis Technical Management Review l

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Optional Discussions CRGR Review With Industry  :

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EDO Revise Proposal or Solicit Public Coment or

No Further Work Further Review i ACRS, Commission

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' = PMs Work With

< Licensees Input r Licensees l

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into I Composite Schedule Agreed Upon Plant Specific implementation Schedule i

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. Attachment 2 to

_CRGR Charter September 1986 Revision 3 PROCEDURES TO CONTROL i GENERIC REQUIREMENTS AND STAFF POSITIONS A. Background In a memorandum from the Chaiman to the Executive Director for Operations dat-ed October 8,1981, the Cossnission expressed concern over conflicting or incon-  ;

sistent directives and requests to reactor licensees from various components of j the NRC staff. By that memorandum, the Comission outlined c'ertain recommended

actions to establish control over the number and nature of requirements placed

! by NRC on reactor licensees. These included: establishing a Comittee to .

! Review Generic Requirements (CRGR); establishing a new position of Deputy Executive Director for Regional Operations and Generic Requirements (DEDROGR);

conducting a survey of formal and informal mechanisms to comunicate with reactor licensees; and developing and implementing procedures for controlling comunications involving significant requirements covering one or more classes of reactors. The following procedures have been established for controlling 1

generic requirements or staff positions and are designed to implement the

, provisions of 10 CFR 50.109, 50.54(f) and 2.204. ,

B. Comittee to Review Generic Requirements (CRGR) 4 Except for immediately effective actions, the CRGR sh'all review all proposed i new generic requirements and staff positions to be imposed on one or more

.i classes of power reactors in accordance with the Charter of the Comittee, i before such proposed requirements or staff positions are forwarded to the ED0

! and Comission and imposed on, or comunicated for use or guidance to, any re-actor licensee.

l C. Office Responsibility

! Each office shall develop internal procedures to assure that the following pol-

! icy requirements regarding reactor licensees are carried out:

! (1) All proposed generic requirements and staff positions (Table 1 attached)

shall be submitted for CRGR review. Such submittals shall conform to the ,

provisions of the CRGR Charter relating to the contents of such l submittals.

1 (2) All generic documents, letters and communications that establish, reflect or interpret NRC staff positions or requirements (Table II attached) shall .

be submitted for review by CRGR unless these documents refer only to re- l

quirements or staff positions approved prior to November 12, 1981. In the latter case, the previously approved requirement or staff position should be specifically cited and accurately stated. Offices should be careful to review new or specific interpretations to assure that they are only 1 case-specific applications of existing requirements rather than initial

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1 i applications having potential generic use. Case-specific applications are j governed by NRC Manual Chapter 0514.

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Attachment 2 to

• CRGR Charter September 1986 Revision 3 (3) For all other communications with licensees (Table III, attached), no statements shall be used that might suggest new or revised generic requirements, staff positions, guidance or recommendations unless such statements have been approved by the EDO or the Commission.

(4) In developing a proposed new generic requirement or staff position for CRGR review, an office may determine that it is in possession of important safety information that should be made available to licensees. It is the responsibility of that office to take immediate action to assure that such information is communicated to the licensees by the appropriate office.

Such actions may be taken before completion of any proposed or ongoing CRGR reviews.

D. Immediately Effective Action For those rare instances where it is judged that an inmediately effective ac-tion is needed to ensure that facilities p(ose no undue risk to the health an safety of the public (10 CFR 50.109(a)(4) ii)), no prior review by the CRGR is necessary. However, the staff shall conduct a documented evaluation which in-cludes a statement of the objectives of and reasons for the actions and the basis for invoking the exception. Theanalysisreferencedin50.109(a)(2)may be conducted either before or after the action is taken and shall be subject to CRGR review. This analysis shall document the safety significanc2 and appro-priatencss of the action taken and consideration of how costs contribute to selecting the solution among various acceptable alternatives. The CRGR Chairman should be notified by the Office Director originating the action.

These immediately effective requirements will be reported to the Committee for information and will be included in the report to the Commission.

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- Attachment 2 to

CRGR Charter

" September 1986 Revision 3 TABLE I PRINCIPAL MECHANISMS USED BY NRC STAFF TO ESTABLISH OR COMUNICATE GENERIC REQUIREMENTS AND STAFF POSITIONS Rulemaking I Advanced Notices

, Proposed Notices Final Rules Policy Statements Other Formal Requirements 2 Multiplant orders including show cause orders and confirmatory orders Staff Positions 3 Bulletins Circulars Multiplant letters (including 10 CFR 50.54f and TMI Action Planletters) ,

Regulatory Guides SRP (including Branch Technical Positions)

Standard Tech Specs USI NUREGs i

i 1 While Rulemaking is an action of the Commission rather than the staff, j

most rules are proposed or prepared by the staff.

t 2 The document itself imposes a legal requirement; e.g., regulatory orders license conditions.

3 Documents that reflect staff positions which, unless complied with or a satisfactory alternative offered, the staff would impose or seek to have imposed by formal requirement.

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Attachment 2 to ,

CRGR Charter September 1986 Revision 3 ,

TABLE II MECHANISMS OFTEN USED TO INTERPRET GENERIC REQUIREMENTS OR STAFF POSITIONS Action and Petitions for Rulemaking Action on 10 CFR-2.206 Requests Approval of Topicals Facility Licenses and Amendments SERs FDAs, PDAs I&E Manual I&E(HQ) Positions NUREGReports(otherthanUSIs)

Operator Licenses and Amendments Single Plant Orders Staff Positions on Code Committees Unresolved Issues Resulting from Inspections

Attachment 2 to CRGR Charter September 1986 Revision 3 TABLE III ,

ADDITIONAL MECHANISMS SOMETIMES USED TO COMMUNICATE GENERIC REQUIREMENTS OR STAFF POSITIONS DES & FES Entry, Exit and Management Meetings Information Notices Licensee Event Reports; Construction Deficiency Reports (Sent to Other Licensees) .

NRC Operator Licensing People Contact with Licensees Phone Calls or Site Visits by NRC Staff or Comission to Obtain Information (i.e., Corrective Actions, Schedules, Conduct Surveys, etc.)

Pleadings Preliminary Notifications Press Releases Proposed Findings Public Meetings, Workshops, Technical Discussions Resident Inspector Day-to-Day Contact SALP Reports SECY Papers (Some Utilities Apparently Sent Operators to College Based on Re-cent SECY Paper on Operator Qualifications)

Special Reports Speeches to Local Groups or Industry Associations Technical Specifications Telephone Calls and Meetings with Licensees, Vendors, Industry Representatives, j Owners Groups Testimony

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