POLICY ISSUE 

INFORMATION 

July 31, 2012 SECY-12-0105

FOR: The Commissioners 

FROM: Brian W. Sheron, Director 

Office of Nuclear Regulatory Research 

SUBJECT: SUMMARY OF ACTIVITIES RELATED TO THE GENERIC ISSUES 

PROGRAM 

PURPOSE

The purpose of this paper is to inform the Commission on Generic Issues Program activities. 

This paper does not contain any new commitments. 

SUMMARY

The paper contains a summary of Generic Issues Program activities and discusses the results 

of changes in the Generic Issues Program, which were initiated by SECY-07-0022, “Status 

Report on Proposed Improvements to the Generic Issues Program,” dated January 30, 2007, 

and later implemented in Management Directive (MD) 6.4, “Generic Issues Program,” dated 

November 17, 2009. The U.S. Nuclear Regulatory Commission (NRC) staff used the improved 

Generic Issues Program to process a number of active Generic Issues (GIs) and proposed GIs 

since 2007. This paper explains the experience of NRC staff with the improved program and 

discusses successes and challenges in achieving the objectives of program improvements, 

such as timeliness, openness, and agencywide collaboration, outlined in the November 2009 

revision of MD 6.4 and SECY-07-0022. Furthermore, this paper provides the annual update on 

the status of continuing enhancements to the Generic Issues Program. In addition, this paper 

provides information on changes in the status of active GIs, estimated completion dates of their 

current major milestones, and the number of identified and dispositioned proposed GIs. 

CONTACT: Mehdi Reisi Fard, RES/DRA 

 301-251-7490 
The Commissioners - 2 - 

BACKGROUND

The NRC’s Generic Issues Program provides compliance with Section 210, “Unresolved Safety 

Issues (USIs)1

,” of the Energy Reorganization Act of 1974, as amended by the Congress 

through Public Law 95-209 on December 12, 1977. Section 210 required the NRC to “develop 

a plan providing for specification and analysis of unresolved safety issues relating to nuclear 

reactors.” In response to this requirement, NUREG-0410, “NRC Program for the Resolution of 

Generic Issues Related to Nuclear Power Plants,” was submitted to the Congress on 

January 1, 1978, describing the NRC Generic Issues Program that had been implemented 

earlier in 1977. The NUREG-0410 process for assignment of priorities and resolution of issues 

has evolved gradually since 1978 by taking a quantitative approach to place issues in four risk 

categories using risk assessment, introducing a more comprehensive quantitative system in 

early 1979, developing a quantitative prioritization method to assign a numerical priority score to 

each issue in 1981, refining the quantitative prioritization method in 1983, adjusting the 

numerical thresholds used for prioritization in 1993, and replacing the prioritization method with 

a screening process in 1999. 

In a staff requirements memorandum (SRM) issued in response to SECY-05-0126, “Staff 

Requirements–SECY-05-0126–Summary of Activities Related to Generic Safety Issues,” dated 

August 31, 2005 (Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML052430101), the Commission directed the NRC staff to develop a plan 

focusing renewed attention to resolve older GIs and to ensure that future GIs are resolved in a 

timely manner. In response to the SRM, the NRC staff provided a plan in a memorandum to the 

Commission, “Response to Staff Requirements Memorandum on SECY-05-0126, ‘Summary of 

Activities Related to Generic Safety Issues,’” dated March 29, 2006 (ADAMS Accession 

No. ML053570259), which, in part, described the staff’s intention to perform a more 

comprehensive and fundamental reevaluation of the Generic Issues Program to ensure timely 

and effective resolution of GIs. In addition, the NRC staff committed to continue providing the 

Commission with an annual status report on GIs. The NRC staff provided proposed improvements 

in the Generic Issues Program to the Commission in SECY-07-0022. Improvements proposed in 

SECY-07-0022 were intended to help ensure timely issue resolution, clarify roles and 

responsibilities, increase stakeholder participation, and establish clear interfaces between the 

Generic Issues Program and other program office processes and activities used to address GIs 

outside the program. Proposed improvements were implemented by issuance of the 

November 2009 revision of MD 6.4. This revision of MD 6.4 describes the agency’s policy for 

the Generic Issues Program, its legal basis and the programmatic changes in the program. 

DISCUSSION

Purpose and Benefits of Generic Issues Program

 

1

 A USI was defined as a matter affecting a number of nuclear power plants that poses important 

questions concerning the adequacy of existing safety requirements for which a final resolution has not yet 

been developed and that involves conditions not likely to be acceptable over the lifetime of the plants 

affected. Today, the term “Generic Issue” encompasses USIs and includes any generic question that 

meets specific criteria including a safety determination, and has been formally entered into the program. 
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The purpose of the Generic Issues Program is to enable the public and the NRC staff to raise 

issues with potentially significant generic safety or security implications to ensure that those 

issues are evaluated and dispositioned through an effective, collaborative, and open process; 

and to disseminate information about program activities. In accordance with the purpose of the 

program, improvements and process changes in the Generic Issues Program were 

implemented by the revised MD 6.4 to (1) enable and facilitate raising issues with potentially 

generic safety or security implications by providing an open process, (2) address issues with 

potentially generic safety or security implications by collaborating with other offices to determine 

an effective resolution, either by pursuing issues through the resolution stages of the process 

outlined in the revised MD 6.4 or directing them to appropriate regulatory programs or long-term 

studies, (3) ensure resolution of all accepted issues by effective and open tracking of all 

identified issues, whether pursued by the Generic Issues Program or by other programs, and 

(4) disseminate the status of active and proposed GIs to other offices and the public by issuing 

a number of status reports to provide an open and accountable resolution process. These 

status reports include current information on issues and their potential safety concerns, along 

with resolution timelines and results of the resolution process. 

The Generic Issues Program originally outlined in NUREG-0410 included plans for the 

resolution of generic environmental issues, development of improvements in the reactor 

licensing process, and consideration of less conservative design criteria or operating limitations 

in areas in which existing requirements might be unnecessarily restrictive or costly. As a main 

objective of Generic Issues Program improvements described in SECY-07-0022, the new 

program addresses only those issues that have significant generic implications related to safety 

or security that cannot be more effectively handled by other regulatory programs and processes. 

The Generic Issues Program continues to contribute to the agency’s mission of protecting 

people and the environment by identifying, elevating, and providing agencywide solutions to 

address issues with potential safety and security concerns. The most recent examples of these 

issues are GI-199, “Implications of Updated Probabilistic Seismic Hazard Estimates in Central 

and Eastern United States for Existing Plants,” and GI-204, “Flooding of Nuclear Power Plant 

Sites Following Upstream Dam Failure.” The effective and agencywide process for addressing 

issues along with the prominence provided to these safety issues by the Generic Issues 

Program, based on the mandate of Section 210 of the Energy Reorganization Act of 1974, has 

drawn significant attention to these GIs and resulted in implementation of regulatory actions 

toward resolution. 

Experience with Changes in the Generic Issues Program

The NRC staff has used the improved process to address all proposed GIs submitted to the 

program since issuance of SECY-07-0022 and a number of the active GIs initiated prior to 

issuance of SECY-07-0022. This section of the paper explains staff experience with 

implementation of changes in the Generic Issues Program and discusses successes and 

challenges in achieving the objectives of the revised MD 6.4. 

1. Address GIs in a timely and effective manner to support agency objectives. 

To timely and effectively address proposed and active GIs, the Generic Issues Program 

addresses only those issues that meet all seven screening criteria presented in SECY-07-0022. 

The NRC implemented these criteria to include only those issues in the Generic Issues Program 

that could be most effectively resolved by the program’s five-stage process. Issues that can be 
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more effectively handled by other regulatory programs or long-term studies are transferred to 

those appropriate programs, such as GI-204, which was transferred for implementation of 

resolution to the Order for NRC’s Japan Near-Term Task Force Recommendations 2.1 and 2.3. 

The screening criteria are continuously applied throughout the GI process to ensure that only a 

proposed GI or a GI that continues to meet all of these criteria is further processed. In addition 

to employing the screening criteria for timely and effective GI resolution, the program staff 

increased collaboration with other offices from the early stages of the program to build and 

ensure consensus on pursuing appropriate resolution processes available throughout the 

agency. Finally, program staff defined the roles and responsibilities of the offices and clarified 

accountability at all stages of GI assessment. As explained further below, program 

improvements mentioned above and recent process enhancements have affected effectiveness 

and timeliness of the resolution process for both proposed and active GIs. 

Since the issuance of SECY-07-0022 in 2007, 13 issues have been proposed to the program. 

Two issues, which were identified shortly before issuance of SECY-07-0022, were also 

processed in accordance with changes introduced by SECY-07-0022. As of July 2012, 4 of 

these issues are in the acceptance or screening stages of the program, 10 issues were not 

accepted into the program, and 1 issue, GI-204, was established as a formal GI. For issues that 

were not accepted into the program and warranted further considerations, the program staff 

collaborated with submitters of those issues to identify appropriate regulatory processes or 

long-term studies (e.g. further research) and directed issues to those programs. The Generic 

Issues Program continues to track proposed issues that are addressed as long-term studies 

until their final resolution. 

The program staff has observed notable improvements in effectiveness and timeliness of the 

review process for proposed GIs as a result of using the SECY-07-0022 screening criteria and 

collaborating with other offices to identify appropriate regulatory programs and processes 

available throughout the NRC. Using the screening criteria of SECY-07-0022, program staff 

dispositioned 10 issues in a timely manner at the early stages of the program without pursuing 

them through all stages of the program as formal GIs. In each of these cases, the staff 

determined that the proposed GIs were addressed by existing programs or processes, could be 

handled more effectively by other programs, or required long-term studies to establish their 

safety significance; therefore, did not warrant further action in the more intensive stages of the 

program. Applying the screening criteria has helped the staff focus on safety significant issues 

and direct issues to the most appropriate processes for them to be actively worked. On the 

other hand, as the Generic Issues Program seeks further collaboration with other regulatory 

offices and involved federal partner agencies to identify appropriate paths for resolution, the 

process for building consensus has, in some cases, required more time than originally 

envisioned. However, the attained value of intra and interagency collaboration in reaching 

effective resolution through consensus building and more effective communication planning has 

justified the additional time to address these issues. 

Figure 1 presents the timeline of issues proposed after or shortly before issuance of 

SECY-07-0022. For issues closed at the end of the acceptance or screening stages, the reason 

for disposition is also presented. 
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Figure 1. Timeline of proposed GIs 2

Fifteen formal GIs were active when SECY-07-0022 was issued. Nine active GIs were closed 

within a year of SECY-07-0022 issuance. Furthermore, the statuses of three more active GIs 

were updated to “regulatory office implementation.” The changes in the status of these issues 

were consistent with SECY-07-0022 and clarified accountability and responsibilities, as the 

assigned regulatory office is responsible for implementation and verification of regulatory 

solutions identified in prior stages of the program. Moreover, the flexibility of the improved 

Generic Issues Program, which allows GIs to be transferred to the appropriate resolution 

processes at any stage of the program, helped advance GI-204 toward resolution. Resolution 

of this GI is being pursued through the implementation of NRC’s Japan Near-Term Task Force 

Recommendations 2.1 and 2.3 following the March 2011, major earthquake in Japan. 

Although recent changes have improved the overall effectiveness and timeliness of the GI 

resolution process, the NRC staff acknowledges concerns on timeliness for resolution of some 

GIs. Figure 2 presents the timeline of GIs that have been active since SECY-07-0022 was 

issued. As indicated by this chart, a number of active GIs have undergone prolonged resolution 

processes. The safety and risk significance of GIs is, by definition, uncertain and, thus, needs 

to have the safety and risk significance quantified to determine if further regulatory action is 

 

2

 Pre-GI-001, “Multi-Unit Core Damage Events,” pertains to whether the NRC should develop multiunit 

Probabilistic Risk Assessments (PRAs). It has been determined that this issue is not a GI and is 

addressed by the site Level 3 PRA project. The program staff is updating documentation to reflect the 

transfer of this issue to the long-term Level 3 PRA project. 
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needed and, if so, what regulatory process is best suited to address the issue. Resolution of 

some complex issues identified prior to issuance of SECY-07-0022 involves a wide range of 

activities, which may include conducting research studies, issuing regulatory guidance and 

generic communications, building consensus among internal stakeholders, and implementing 

and verifying regulatory actions. Because the resolution process usually involves performing 

studies and analyses, these analyses can reveal aspects that need to be further explored, which 

can extend the time and level of effort required for resolution. Even though all actions for 

closure of some issues with extended resolution times are not complete, safety benefits are 

gained by licensee implementation of changes long before verifications are complete and issues 

are formally closed. 

Figure 2. Timeline of active GIs 

In addition to complexity of these issues, interactions with the industry to obtain generic or plantspecific information have contributed to additional time needed to resolve some issues. 

Although such interactions were meant to help timely and effective issue resolution, the process 

of obtaining information from the industry on a voluntarily basis proved to be less productive 

than anticipated in some cases. If an issue were to challenge reasonable assurance of 

adequate protection of public health and safety, the NRC staff would immediately propose 

Orders to licensees or other regulatory actions to the Commission as appropriate, rather than 

engaging industry and other stakeholders. Proposed GIs that pass the acceptance review of 

the program are referred to the responsible program office, which determines if prompt actions 

are necessary to provide assurance that facilities can continue to operate safely while GIs are 

being resolved. For example, if warranted for any emerging reactor safety issue, the Office of 

Nuclear Reactor Regulation (NRR) may implement NRR Office Instruction LIC-504, “Integrated 
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Risk-Informed Decision-Making Process for Emergent Issues,” to supplement the evaluation 

conducted by the Generic Issues Program. 

In addition to improvements in addressing proposed and active GIs, the NRC staff used the 

revised MD 6.4 improvements to provide a final disposition to legacy low-priority generic issues 

and to clarify the program role regarding further actions on legacy licensing and regulatory 

impact GIs. Disposition of these issues was described in SECY-11-0101, “Summary of 

Activities Related to Generic Issues Program,” dated July 26, 2011. As discussed below, the 

NRC is evaluating the program for more refinements to improve its effectiveness and timeliness. 

2. Coordination of the Generic Issues Program with other agency programs to avoid 

duplication, channel issues to be processed by appropriate agency programs, and build 

consensus and cooperation throughout the Generic Issues Program process. 

In accordance with the revised MD 6.4 process, the staff recognized the need to increase 

collaboration and coordination with other offices to identify the most effective process in the 

agency for handling each issue. The program staff collaborates with other offices by including 

their representatives on GI review panels and providing information on the program and the 

status of GIs through briefings, internal, and public meetings, and by issuing routine reports. 

As a few examples, development of an effective communication plan, coordination of the 

Generic Issues Program with other agency programs, and building consensus for channeling 

these issues to the appropriate agency program have helped the program staff in forming 

agencywide solutions for the safety and risk assessment of GI-199 and the screening analysis 

of GI-204. The program staff intends to further improve internal collaborations where areas for 

improvements have been observed. 

3. Effectively track, document, and report GI status to support Generic Issues Program 

process management and communication with stakeholders. 

The Generic Issues Program develops several reports and products, such as longstanding 

periodic reports to the Congress, to track, document, and disseminate information related to 

proposed and active GIs. To enhance the openness, improve accessibility, and provide more 

accountability, the program has been implementing several improvements to its reports and 

products in recent years. These improvements include the following: 

• Issuing periodic reports on the status of proposed GIs, beginning in August 2011. 

• Publishing and maintaining internal and public Web pages since 2007. 

• Initiating the process to produce a user-friendly, Web-based, accessible, and searchable 

version of NUREG-0933, “Resolution of Generic Safety Issues.” 

• Developing and posting a database on the data.gov Web site in December 2011, to 

enhance searchability and make the NUREG-0933 information more accessible. 
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• Changing the process for issuing quarterly generic issue management control system 

(GIMCS) reports on the status of active GIs by issuing reports to responsible Division 

Directors (vs. Branch Chiefs) since the fourth quarter of 2011. 

• Developing and disseminating statistics on timeliness and resolution of GIs. 

4. Provide a process that is open to the staff and public on proposed GIs. 

The program staff continues to provide an open process by promoting understanding and use of 

the Generic Issues Program and disseminating information about the program and its activities. 

As a few examples, the staff (1) has presented posters on the Generic Issues Program and 

active GIs during the NRC Regulatory Information Conferences three times since 2008, (2) 

published NUREG/BR-0478, “The Generic Issues Program,” issued July 2011, to provide key 

information about the program, (3) developed internal and public Web pages to provide 

information on the program and the process for proposing new issues, (4) developed a GI 

proposal form available on internal and public Web pages to facilitate proposing issues by the 

staff and public, (5) provided an effective communication plan and press releases for GI-204, 

and (6) made informational and technical presentations to NRC organizations such as the 

Advisory Committee on Reactor Safeguards. 

5. Coordinate with other offices to identify potential GIs from existing information 

sources. 

The program staff maintains awareness of potential issues through liaisons in other offices. In 

addition to coordination through program liaisons, the staff routinely participates in the Office of 

NRR’s operating experience clearinghouse to identify potential GIs with safety, physical security 

or cyber security implications. 

Improvement Efforts

Although significant changes to the program in SECY-07-0022 improved the timeliness of 

evaluation and determination of a regulatory resolution, GIs continue to face challenges in 

getting to closure when they move to regulatory office implementation. In light of that, Directors 

of the Office of Nuclear Regulatory Research (RES) and NRR directed that a team with 

representatives from different offices be organized and chartered to propose further refinements 

in the agency processes for GIs to efficiently resolve safety issues and more effectively 

communicate the progress. The team is evaluating improvements in areas such as internal 

collaboration and knowledge transfer, expectation of timely processing and management of 

issues exiting the program, and process changes that enhance external communication. 

Findings and assessments of this team will be reported to the Commission following the 

completion of this effort later in calendar year 2012. Any recommendations to alter the process 

discussed in SECY-07-0022 will be brought to the Commission for approval, as appropriate. 

Status of GIs

Since the previous annual report to the Commission (SECY-11-0101), the NRC staff completed 

actions supporting closure of GI-186, “Potential Risk and Consequences of Heavy Load Drops 

in Nuclear Power Plants,” in January 2012, and established GI-204, “Flooding of Nuclear Power 

Plant Sites Following Upstream Dam Failure,” in February 2012. 
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NRC opened GI-186 in 1999 to address a concern related to the measures to protect against 

heavy load drops. In the closure memorandum to the Executive Director for Operations, 

“Completion of Generic Issue 186, ‘Potential Risk and Consequences of Heavy Load Drops in 

Nuclear Power Plants’,” dated January 27, 2012 (ADAMS Accession No. ML113050589), the 

NRC staff concluded that the safety concerns associated with GI-186 have been adequately 

addressed and GI-186 is closed following staff activities supporting closure of this issue. These 

activities include the endorsement of an industry initiative that clarifies the licensing basis for 

control of heavy loads, development of supplemental inspection guidance, endorsement of an 

industry standard for the design of highly reliable overhead cranes, and reemphasis of existing 

regulations and guidance related to the control of heavy loads. Verification activities for this GI 

included the implementation of supplemental inspection guidance by region-based inspectors 

and the review of selected updated final safety analysis reports to establish that changes 

consistent with the industry initiative have been completed. 

The screening analysis for the proposed GI pertaining to the flooding of U.S. nuclear power 

plant sites following upstream dam failure was completed on February 29, 2012, and 

documented under ADAMS Accession No. ML111890588. With the endorsement of the RES 

Director, the proposed GI passed the screening stage of the program, and GI-204 was 

established. During the review of GI-204, staff identified an issue on failure of downstream 

dams, which is under review as a proposed GI. 

Following the completion of actions for GI-186 and establishment of GI-204 and transfer of the 

lead responsibility for this issue to NRR, one reactor GI remains open in the safety and risk 

assessment stage. Four reactor GIs are open in the regulatory office implementation stage. 

There are no open nonreactor GIs. 

Open GIs in the Generic Issues Program 

• GI-193, “Boiling-Water Reactor Emergency Core Cooling System Suction Concerns” 

(completion of safety and risk assessment estimated in November 2012). Staff has 

evaluated reports on simulated blowdown tests performed at Purdue University. The 

staff’s evaluations of the test findings and overall issue recommendations are in the 

process of being prepared and peer reviewed. RES is the lead office for GI-193. 

GIs in Regulatory Office Implementation 

The following reactor GIs are being processed by NRR for regulatory office implementation: 

• GI-189, “Susceptibility of Ice Condenser and Mark III Containments to Early Failure from 

Hydrogen Combustion during a Severe Accident” (completion of all agency actions 

estimated in January 2013). 

• GI-191, “Assessment of Debris Accumulation on PWR Sump Performance” (staff 

provided the Commission a notation vote paper in July 2012 with options for the path 

forward to resolve GI-191). 
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• GI-199, “Implications of Updated Probabilistic Seismic Hazard Estimates in Central and 

Eastern United States for Existing Plants.” Resolution is being pursued through the 

implementation of NRC’s Japan Near-Term Task Force Recommendations 2.1 and 2.3. 

• GI-204, “Flooding of Nuclear Power Plant Sites Following Upstream Dam Failure.” 

Resolution is being pursued through the implementation of NRC’s Japan Near-Term 

Task Force Recommendations 2.1 and 2.3. 

More information on active GIs can be found in the GIMCS report, which is updated once each 

quarter to track and report the status of active GIs. The GIMCS report is available at the NRC 

public Web site on the Generic Issues Program Web page (http://www.nrc.gov/aboutnrc/regulatory/gen-issues.html). 

In addition to active GIs, the Generic Issues Program has dispositioned 9 of 13 proposed GIs 

received since 2008. As of July 2012, one proposed GI is open in the acceptance review stage 

and three proposed GIs are open in the screening stage. As explained earlier, the program staff 

issued the first report on the status of proposed GIs in August 2011. Routine reports on 

proposed GIs are available at the NRC public Web site on the Generic Issues Program Web 

page. 

RESOURCES

For FY 2013, the staff estimated that the resources needed for Generic Issues Program 

activities would total $225,000 and 14.1 full-time equivalents (FTE). Resources for the Generic 

Issue Program were reduced to $175,000 and 13.1 FTE, as a result of budget adjustments, and 

are contained in the FY 2013 Current Estimate (CE) budget request. If the contracting needs 

change during the FY, additional funds will be requested through the agency’s shortfall process. 

Table of Budgeted Resources for FY 2013 and FY 2014 in Comparison to FY 2012 1 

 Business Line FY 2012 CE FY 2013 CE FY 2014 Request 

RES Operating Reactors $225k and 7.7 FTE $175k and 6.7 FTE $225k and 7.7 FTE

NRR Operating Reactors 6 FTE 6 FTE 6 FTE 

FSME Nuclear Materials 

Users 0.1 FTE 0.1 FTE 0.1 FTE 

NMSS Spent Fuel Storage 

and Transportation 0.2 FTE 0.1 FTE 0.1 FTE 

NRO New Reactors 0.1 FTE 0.1 FTE 0.1 FTE 

NSIR Operating Reactors 0 0.1 FTE 0.1 FTE 

1

 To facilitate comparison, FY 2012 amounts represent the FY 2012 CE from SECY-11-0101. 
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COORDINATION

The Office of the General Counsel reviewed this package and has no legal objection. The 

Chief Financial Officer reviewed this package and determined that it has no financial impact. 

/RA/ 

Brian W. Sheron, Director 

Office of Nuclear Regulatory Research 
The Commissioners -11- 

COORDINATION

The Office of the General Counsel reviewed this package and has no legal objection. The 

Chief Financial Officer reviewed this package and determined that it has no financial impact. 

/RA/ 

Brian W. Sheron, Director 

Office of Nuclear Regulatory Research 

ADAMS Accession No.: ML12170A098 EDATS:SECY-2012-0227/WITS 198300621 

OFFICE RES/DRA/OEGIB SUNSI Review Tech Editor RES/DRA/OEGIB RES/DRA 

NAME M. Reisi Fard M. Reisi Fard J. Dougherty

(via email) 

B. Beasley 

(J. Lane for)

R. Correia 

DATE 6/6/12 6/6/12 6/5/12 6/7/12 6/25/12

OFFICE RES/DE RES/DSA NMSS NRR NSIR 

NAME M. Case 

(S. Richards for via 

email) 

K. Gibson 

(M. Scott for via 

email) 

C. Haney 

(S. Smith for via 

email) 

E. Leeds 

(T. McGinty for via email) 

J. Wiggins 

(R. Caldwell for 

via email) 

DATE 7/16/12 7/17/12 7/18/12 7/3/12 7/16/12

OFFICE NRO FSME OCFO OGC/GCHEA RES 

NAME G. Tracy 

(C. Ader for via email) 

M. Satorius 

(A. McIntosh for via 

email) 

J. Dyer 

(V. Portillo for via 

email) 

M. Zobler 

(G. Mizuno for via email) 

B. Sheron 

DATE 7/13/12 7/9/12 7/18/12 7/16/12 7/31/12

OFFICIAL RECORD COPY