POLICY ISSUE 

NOTATION VOTE 

October 5, 2012 SECY-12-0137

FOR: The Commissioners 

FROM: R. W. Borchardt 

 Executive Director for Operations 

SUBJECT: IMPLEMENTATION OF THE CUMULATIVE EFFECTS 

 OF REGULATION PROCESS CHANGES 

PURPOSE: 

To obtain Commission approval on the staff actions to implement the Commission direction 

related to the cumulative effects of regulation (CER) process. 

SUMMARY: 

In the Staff Requirements Memorandum (SRM) to SECY-11-0032, “Consideration of the 

Cumulative Effects of Regulation in the Rulemaking Process,” dated October 11, 2011 (NRC’s 

Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML112840466), the Commission provided direction to the staff on issues related to the 

implementation of the CER process enhancements. This paper builds upon the staff’s 

proposals in SECY-11-0032 and contains the staff’s response to the Commission direction. 

Specifically, the “Discussion” section describes interactions with stakeholders throughout all 

stages of the rulemaking process, guidance publication, the common prioritization of rulemaking 

(CPR), the staff’s consideration of applying risk insights to prioritize regulatory actions, the 

impact of CER implementation on other regulatory actions, and the staff’s consideration of the 

need to quantify cumulative impacts of regulation. In addition, this paper addresses feedback 

from external stakeholders received at the May 2012 public meeting on CER. 

BACKGROUND: 

In SRM M091208, “Briefing on the Proposed Rule: Enhancements to Emergency Preparedness 

Regulations,” dated January 13, 2010 (ADAMS Accession No. ML100130067), the Commission 

directed the staff to consider if the schedule for implementing the emergency preparedness 

rulemaking and future rulemakings should be influenced by the “aggregate impact” (now more 

commonly called “cumulative effects of regulation” or CER) of the new and recently issued 

regulations already scheduled for implementation. 

CONTACT: Tara Inverso, NRR/DPR 

 301-415-1024 
The Commissioners -2- 

In response to this direction, the staff prepared SECY-11-0032 (ADAMS Accession 

No. ML110190027), which included rulemaking process changes and several enhancements 

designed to: 1) encourage increased interaction with external stakeholders throughout the 

rulemaking process in order to resolve issues that can lead to implementation challenges and 

contribute to CER, 2) explicitly solicit feedback on CER concerns to increase stakeholder 

awareness and enable the NRC to make well-informed decisions on how to mitigate CER, and 

3) improve the process for establishing the time allowed for implementation by seeking 

additional information on CER. Specifically, SECY-11-0032 described the following rulemaking 

process enhancements: 

• Interaction (with stakeholders) throughout all phases of the rulemaking process; 

• Public meeting on implementation during the final rule; 

• Concurrent publication of draft guidance with the proposed rule and final guidance with 

the final rule; 

• Explicit request for stakeholder feedback on CER; and 

• Scheduler process changes. 

In its SRM to SECY-11-0032, the Commission approved the process enhancements and 

directed the staff to provide its final strategy to implement the changes. In addition, the 

Commission directed the staff to: 

• Revise office-specific rulemaking procedures to reflect the rulemaking process 

enhancements; 

• Consider application of risk insights to prioritize regulatory actions; 

• Consider other regulatory instruments when incorporating the CER process changes; 

and 

• Consider the need to quantify the cumulative impacts of regulation. 

On March 20, 2012, the Office of Management and Budget’s (OMB) Office of Information and 

Regulatory Affairs issued a memorandum to the heads of executive departments and agencies 

entitled “Cumulative Effects of Regulation.”1

 The memorandum stated that “agencies should 

take active steps to take account of the cumulative effects of new and existing rules and to 

identify opportunities to harmonize and streamline multiple rules.” While the memorandum is 

not binding on the NRC, the staff plans to implement, or has already implemented, the steps 

suggested in the memorandum through existing NRC processes, including the CER process, as 

described herein. 

On May 31, 2012, the staff held a Category 3 public meeting to obtain external stakeholder 

feedback on the CER process changes described in SECY-11-0032 and its corresponding 

SRM. Forty individuals participated in the meeting, including members of the industry (power 

reactors and materials), agreement states, and the NRC staff. That feedback is contained in the 

topic-specific portions of the “Discussion” section of this paper, and the meeting summary is 

available in ADAMS under Accession No. ML12165A720. In addition to the comments specific 

to the additional directives contained in the SRM to SECY-11-0032, external stakeholders 

provided the following concerns and recommendations regarding the generic application of the 

 

1 Available at http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/cumulative-effects-guidance.pdf
The Commissioners -3- 

CER process: 

• A CER template could be used early on in the rulemaking process to determine the 

viability and priority of a new rulemaking. 

• Rulemaking is just one part of the regulatory picture; relative prioritization of activities 

should include all regulatory actions, including inspections. 

• Implementation challenges vary at different levels; therefore, the CER process should 

consider the impact on individual plants, a fleet of plants, and industry as a whole. 

• A well-defined problem statement early in the process is a must. 

The attendees also suggested that there are three possible actions to address a CER issue: 

1) delay issuance of the rule, 2) consider site-specific implementation timelines, and 3) use 

enforcement discretion or exemptions. The staff does not consider the use of enforcement 

discretion to be the optimal regulatory vehicle to address a CER issue. Further, the staff notes 

that this decision process will be applied on a case-by-case basis, but, in all cases, safety and 

security concerns take priority over CER concerns. 

Following the public meeting, the Nuclear Energy Institute (NEI) sent a letter (ADAMS 

Accession No. ML12170A660) dated June 15, 2012, which reiterates key points made by 

industry representatives during the public meeting. 

DISCUSSION: 

In its SRM to SECY-11-0032, the Commission directed the staff to submit the results of its final 

strategy to implement the CER process changes for Commission review and approval. The 

following subsections build upon the staff’s initial proposal in SECY-11-0032, respond to the 

additional direction contained in the SRM, and address the public feedback from the 

May 31, 2012, public meeting. 

The staff has developed the following definition of CER: 

Cumulative Effects of Regulation describes the challenges that licensees, or 

other impacted entities (such as State partners) face while implementing new 

regulatory positions, programs, or requirements (e.g., rules, generic letters, 

backfits, inspections). Cumulative Effects of Regulation is an organizational 

effectiveness challenge that results from a licensee or impacted entity 

implementing a number of complex regulatory positions, programs or 

requirements within a limited implementation period and with available resources 

(which may include limited available expertise to address a specific issue). 

Cumulative Effects of Regulation can potentially distract licensee or entity staff 

from executing other primary duties that ensure safety or security.2

 

CER will not apply to administrative rules, direct final rules, interim final rules, design 

certification rules, consensus standards rules, and other similar types of rulemakings that will be 

identified in a pending revision to Management Directive (MD) 6.3, “The Rulemaking Process.” 

Accordingly, the described process enhancements will be applied to CER-applicable rules. 

 

2 The staff has revised the CER definition in SECY-11-0032 by making editorial changes.
The Commissioners -4- 

At the May 31, 2012, public meeting, the stakeholders requested staff revisit whether CER 

should be applied to rulemakings that incorporate voluntary consensus standards. Specifically, 

stakeholders believe CER should be applied to rulemaking amendments to Title 10 of the Code 

of Federal Regulations (10 CFR) 50.55a because industry does not always agree with the 

consensus standards, and because these rules can be burdensome to implement. 

The staff revisited this issue and determined that no change is necessary. The staff does not 

intend to apply the CER process changes to rulemakings that incorporate voluntary consensus 

standards because: 1) consensus standards already incorporate stakeholder input early on in 

development of the standards, and 2) industry stakeholders historically have advocated for 

expedited processing of these rulemakings to avoid relief requests and to reduce proposed 

alternative submissions (licensing actions) to the NRC. Furthermore, the staff does not interpret 

the concerns raised by external stakeholders during the public meeting to be CER concerns. 

These concerns, which are technical in nature and are not related to implementation, are more 

appropriately raised through the standard notice and comment rulemaking process. 

CER Template 

At the May 31, 2012, public meeting, industry stakeholders recommended that the staff use a 

“CER template” in the early stages of rulemaking to determine the viability and priority of a new 

rulemaking, as compared to ongoing regulatory actions. The CER template, as described by 

the industry, would suggest criteria (e.g., safety, risk, compliance, regulatory relief) that would 

be applied to a prospective rulemaking to facilitate obtaining stakeholder feedback to support 

the NRC’s decision on whether and when to proceed to rulemaking. The NEI volunteered to 

take the lead on developing the CER template and coordinating in a public forum with the NRC 

throughout its development. This concept was not envisioned in SECY-11-0032, nor directed 

by the Commission in the corresponding SRM. 

The staff will begin the dialogue with external stakeholders to gain a better understanding of the 

content of a CER template and how the template could be used. This dialogue, the 

development of a CER template, and, if adopted, the application of the CER template to an 

individual rulemaking, would take place in an open, transparent process (i.e., public meetings). 

The NRC retains the ultimate decisionmaking authority on whether and when to proceed with a 

rulemaking. 

The regulatory basis stage may be the optimal point in the rulemaking process to apply a CER 

template. During that stage staff develops the necessary details about the rulemaking, and 

evaluates whether issuing a proposed rule is the appropriate action. A CER template might 

support the goals of the CER process enhancements, in particular the goal to increase external 

stakeholder interaction, by providing a structured tool that the staff could use to obtain external 

feedback. 
The Commissioners -5- 

Interacting with Stakeholders during the Regulatory Basis Stage 

The NRC’s current regulatory process encourages stakeholder interaction during the early 

stages of the rulemaking process, which begins with the development of the regulatory basis 

and may include an advance notice of proposed rulemaking. The staff believes that early 

stakeholder interaction leads to a more informed regulatory basis, identifies issues earlier that 

could result in implementation problems, and reveals areas where guidance is needed. This 

early interaction also improves the quality and completeness of problem statements for the 

rulemaking. In the past, stakeholder interactions did not always occur at the regulatory basis 

stage. Going forward, stakeholder interactions will be conducted routinely at the regulatory 

basis stage of a rulemaking. 

In its SRM, the Commission directed the staff to keep the Commission informed of the outcome 

of the regulatory basis development interactions and to provide the Commission with general 

conclusions based on these interactions via a Commissioners’ Assistants (CA) note for each 

rulemaking as soon as practical. The staff intends to implement this direction by submitting a 

CA note following public interactions that convince the staff to substantively change the content, 

scope, or schedule of the rulemaking. If a CER template is adopted, a CA note would be 

developed when significant areas of disagreement exist during application of the CER template 

to a specific regulatory basis. 

Interacting with Stakeholders during the Proposed Rule Stage

The Commission directed the staff to seek and consider stakeholder feedback on the CER 

considerations related to a proposed rule. Each rulemaking program office revised its 

rulemaking procedures and templates to include a list of generic questions that apply to 

rulemakings. Optional rule-specific questions may be developed in some cases. Questions 

related to CER will be included in future proposed rules. 

In the May 2012 public meeting, the staff received positive feedback from external stakeholders 

on the CER-related questions. One attendee did note, however, that the NRC should request 

comment on the regulatory activities of other agencies that may impact an NRC rulemaking. 

The staff agreed and revised the CER-related questions accordingly. 

Interacting with Stakeholders during the Final Rule Stage 

The staff incorporated a public meeting into the final rule stage, and has held these meetings for 

three recent rules on generic environmental impact statement for nuclear power plant license 

renewal, research and test reactor employee fingerprinting, and emergency preparedness. The 

purpose of this type of meeting is to better understand and clarify any CER concerns and to 

provide an opportunity to properly structure the implementation dates of the final rule 

requirements. The May 2012 public meeting attendees indicated that the public meeting on 

implementation could aid in identifying implementation issues for specific licensees. The staff 

notes that, in order for these implementation meetings to be successful and effective, it is 

imperative that preliminary final rule language and draft final guidance documents are publicly 

available. This ensures that external stakeholders will be aware of the requirements and can 

make informed assessments on implementation challenges. 
The Commissioners -6- 

Although the staff plans to conduct public meetings on implementation during the final rule stage 

for most rules, there may be some rules for which a public meeting might not be held. For 

example, a public meeting would not be necessary for a rule that extensively considered the 

implementation date (external stakeholder interaction included) during the regulatory basis and 

proposed rule phases. A rule that includes a straightforward, noncontentious implementation 

date or a rule for which no CER input was received may not warrant a public meeting at the final 

rule stage. External stakeholders expressed general agreement with this approach during the 

May 2012 public meeting and agreed that in these cases, it was not worth delaying issuance of 

the final rule (nominally by about one month) to hold the public meeting. Stakeholders did note, 

however, that frequent (especially early) interaction is key. 

Guidance Associated with Rules 

The CER process requires that draft guidance be published for comment concurrently with 

proposed rules and that final guidance be published concurrently with final rules. The SRM to 

SECY-11-0032 directed the Executive Director for Operations to promptly inform the 

Commission of any instances (and the associated reasons) for which a proposed rule package 

will be provided to the Commission without having completed the draft guidance. In the event 

that guidance cannot be published in accordance with the current schedule for the rule, the staff 

will request a schedule extension to allow for the concurrent publication of the rule and 

associated guidance. For future rulemakings in which CER applies, the staff will develop project 

plans to issue rules and guidance concurrently, and it will budget additional time and resources 

accordingly. 

During the public meeting, external stakeholders noted that the concurrent publication of 

guidance and rules is working well, and they highlighted the recent 10 CFR Part 37, “Physical 

Protection of Category 1 and Category 2 Quantities of Radioactive Material,” rulemaking as an 

example. The meeting attendees expressed frustration when, despite stakeholder interactions 

throughout the process, final generic communications and rules are published with significant 

changes that have been made during concurrence. With the new CER process, stakeholders 

will see the preliminary final rule language during the public meeting on implementation at the 

final rule stage. 

Common Prioritization of Rulemaking 

The Commission directed the staff to use the common prioritization of rulemaking process for 

prioritizing its rulemaking activities and, where appropriate, project potential future rulemaking 

activities beyond the normal 2-year budget horizon. The Commission also noted that the staff 

should consider making this information public. 

The CPR process considers four factors and assigns a score to each factor. Those factors 

include support for the NRC’s Strategic Plan goals; support for the Strategic Plan organizational 

excellence objectives; a governmental factor representing interest to the NRC, Congress, or 

other governmental bodies; and an external factor representing interest to members of the 

public, non-governmental organizations, the nuclear industry, vendors, and suppliers. This 

process is used primarily for the development of rulemaking budget estimates, but the staff also 

can use the process as a means for deciding the relative priorities of rulemaking projects during 

budget execution. 
The Commissioners -7- 

In addition, the staff includes all planned and active rulemakings in the CPR regardless of their 

planned start dates. Many of the rulemakings in the CPR process are active or near-term 

activities, but the process allows staff to include rulemakings that may not begin for several 

years. 

The staff concluded that elements of the CPR should be made public, and that the Unified 

Agenda is the most efficient and effective vehicle to communicate rulemaking priorities. The 

Unified Agenda, which the NRC and all Federal agencies publish semiannually, provides an 

update on all active rulemaking activities. The fall edition of the Unified Agenda contains the 

NRC’s regulatory plan, which contains a statement of the major rules that the Commission 

expects to publish in the coming FY and a description of the other significant regulatory priorities 

from the CPR that the Commission expects to work on during the coming fiscal year (FY) and 

beyond. To further promote openness and transparency, the spring 2013 Unified Agenda, 

published in mid- 2013, will include a brief description of the NRC’s CPR process. 

The public meeting attendees were interested in the four factors used to prioritize rules in the 

CPR, and they suggested that the process include a weighting factor for rules that provide 

regulatory relief. The staff noted that regulatory relief is currently considered in the external 

factor of the CPR process. The attendees also suggested that the rulemaking priorities be 

reevaluated at several points in the rulemaking process. The staff notes that it currently 

updates the CPR on an annual basis, at which time rule priorities are re-considered. The 

attendees expressed interest in the NRC making the CPR process visible. As noted above, the 

staff will add additional information on the CPR process to the Unified Agenda. 

The SRM to SECY-11-0032 stated that CPR updates also should be provided via CA notes on a 

periodic basis at an appropriate interval determined by the staff. As described above, the staff 

updates the CPR annually during the budget formulation process, and includes these updates in 

the budget submittal to the Commission. Staff notes that the CPR informs the budget process 

and is striving to ensure future consistency between the CPR and the budget. Considering 

these factors, the staff intends to maintain the annual update process. 

Applying Risk Insights to Prioritize Regulatory Actions

 

In its SRM to SECY-11-0032, the Commission directed the staff to consider whether the revised 

process should apply risk insights to prioritize regulatory actions, whether such a prioritization is 

practical, and, if so, how it might be pursued.

 

The CPR process, as previously described, considers the extent to which a rulemaking could 

enhance safety or security. This is part of the staff’s consideration of how the rule would 

support the NRC's safety and security strategic goals and organizational excellence objective of 

effectiveness, all of which are factors in determining the rulemaking’s priority. The staff’s 

judgment that a rulemaking could considerably enhance safety or security could justify a higher 

priority. Risk information or insights are considered when available and as appropriate to 

prioritize rulemaking actions. The staff notes that this prioritization is used for budgeting 

purposes and informs the initial rulemaking schedule. In general, the timeline for completing the 

rulemaking is determined once the staff has begun work on the regulatory basis and is driven by 

scope, complexity, Advisory Committee on Reactor Safeguards interest, level of public 

engagement, number of guidance documents, OMB reviews, etc.

 
The Commissioners -8- 

Beyond CPR’s consideration, the staff does not recommend a different approach for applying 

risk insights to prioritize regulatory actions. For example, quantitative risk information is often 

very limited (if available) during the early stage when the staff is prioritizing rulemakings. 

Obtaining detailed risk information prior to the regulatory basis stage may require significant 

staff resources at a point in time when the staff has not yet determined whether rulemaking is 

the appropriate regulatory action. In addition, efforts to obtain this information could delay the 

rulemaking schedule.

 

However, the staff believes that risk insights, when available, can also be applied to a 

rulemaking in appropriate circumstances when determining implementation date(s) for 

competing regulatory requirements. The CER template described previously, if adopted, could 

identify qualitative risk information for rulemaking activities early in the rulemaking process, 

although the primary purpose of CER is focused on unintended consequences to licensees 

implementing regulatory programs and not on risk analysis of the regulatory program. Because 

CER template discussions would occur in a public setting, external stakeholder feedback on 

associated risk could be obtained and incorporated in the assessment. Further, the staff 

expects that the specific request for comment on CER in the proposed rule will gather feedback 

on other regulatory actions and their relative significance to the proposed regulatory action that 

may impact the implementation of the subject rule. Additionally, the public meeting on 

implementation held during the final rule stage could be used to assess the relative change in 

risk associated with the rulemaking compared to the other ongoing and near-term regulatory 

actions. At that stage of the rulemaking process, the draft final rule requirements would be 

known, and a better view of other ongoing and near-term regulatory actions would be available. 

For rulemakings and associated regulatory actions where no or limited risk information is 

available or is not otherwise considered, the rulemaking implementation date(s) would be 

determined based on a qualitative assessment of factors such as the relative benefits of the 

actions (e.g., if the rule provides regulatory relief), the number and complexity of the actions, the 

flexibility of implementation dates for other actions, etc. In contrast, for rules where risk 

information is available, it could be used as an additional factor in determining the rulemaking 

implementation date(s).

Schedule Process Changes 

The CER process enhancements may impact rulemaking schedules due to increased 

stakeholder interaction and the requirement to publish draft guidance with proposed rules and 

final guidance with final rules. The staff will discuss the schedule with external stakeholders at 

public meetings held during the rulemaking process as appropriate. As directed in the SRM to 

COMSECY-12-0007, “Impact of the Cumulative Effects of Regulation on Existing Rulemaking 

Due Dates,” the staff will use the existing rulemaking schedule change process to request 

schedule revisions, as necessary. 

Impact of CER Implementation on Other Regulatory Instruments

The Commission indicated that the implementation of CER should consider other regulatory 

instruments and that the staff’s procedures should be revised to include provisions accounting 

for other regulatory actions that may influence implementation dates for new rules. The staff 

intends to consider the impact that other ongoing regulatory actions (orders, generic 

communications, etc.) may have on implementation of the new rule requirements. In those 

specific cases, the Federal Register notice of the proposed rule will specifically request public 
The Commissioners -9- 

comment on how those other activities may impact the proposed rule. The impact other 

regulatory actions may have on a rulemaking will be discussed again during the public meeting 

on implementation held during the final rule stage. 

At this time, while the staff does not routinely apply the CER process to other regulatory actions 

such as orders, generic communications, and inspections, it does apply the overall concepts of 

CER (e.g. providing early communication of guidance, conducting meetings with stakeholders, 

and coordinating schedule implementation). After some experience with CER in the rulemaking 

process, the staff could reevaluate CER for applications other than the rulemaking process. 

The staff received the following feedback on the use of CER for other regulatory actions from 

external stakeholders during the May 2012 public meeting: 

• Preparing responses to 10 CFR 50.54(f) letters is often more resource-intensive than 

rulemakings. 

• Generic communications can change the licensing basis of plants. 

• The regulatory issue resolution protocol may be a useful tool to define the regulatory 

problem and associated success criteria (to ensure that such actions effectively address 

the defined problems with minimum burden). 

Quantifying the Cumulative Impacts of Regulation 

The Commission directed the staff to consider the need to quantify the cumulative impacts of 

regulation and provide the Commission with its views on how the agency might develop a 

measurement and evaluation approach that would inform both future and current regulatory 

activities. 

The staff discussed this question with members of the public during the May 2012 public 

meeting. One attendee noted during the public meeting that quantifying the cumulative impacts 

of regulation is challenging, and stated that qualitative assessments should not be overlooked. 

Though the CER template described earlier in this paper has not been developed, the staff 

expects any CER template to be a qualitative, rather than a quantitative, tool. Furthermore, if a 

CER template were to provide quantitative data, which could include industry-wide, fleet-wide, 

or site-specific schedule, cost, or staff-hour burdens, staff is uncertain how it would use that 

data to quantitatively evaluate CER. Also, considerations at “fleet level” and below could be 

complicated and resource-intensive. The NRC has an accepted method for performing a 

regulatory analysis where regulatory burdens are converted into cost. However, there is no 

current analytical method for converting, combining, and assessing CER data to compute CER 

burden and an appropriate implementation period for a rulemaking. Therefore, the staff does 

not recommend at this time using a quantitative approach for evaluating CER. Rather, the staff 

believes that the NRC should qualitatively evaluate CER by considering, in part, 

currently-identified, pending and planned regulatory actions and their implementation dates. 
The Commissioners -10- 

RECOMMENDATIONS: 

The staff recommends that the Commission: 

1. Approve the staff’s proposed actions to implement the CER process enhancements, as 

described in the “Discussion” section of this paper. 

2. Note that the staff is revising rulemaking schedules, as appropriate, to consider CER as 

described in this paper and it will plan future rulemakings accordingly. 

RESOURCES: 

The lead rulemaking offices (the Office of Nuclear Reactor Regulation, the Office of New 

Reactors, and the Office of Federal and State Materials and Environmental Management 

Programs) have revised their rulemaking resources in the FY 2013 President’s Budget and the 

FY 2014 Performance Budget to include those resources associated with the CER Process. 

COORDINATION: 

This paper has been coordinated with the NRC’s Rulemaking Coordinating Committee and all 

rulemaking lead and partner offices. The Office of General Counsel has reviewed this paper 

and has no legal objection. The Office of the Chief Financial Officer has reviewed this paper for 

resource implications and has no objections. 

 /RA/ 

 R. W. Borchardt 

 Executive Director 

 for Operations 
The Commissioners -10-

RECOMMENDATIONS: 

The staff recommends that the Commission: 

1. Approve the staff’s proposed actions to implement the CER process enhancements, as 

described in the “Discussion” section of this paper. 

2. Note that the staff is revising rulemaking schedules, as appropriate, to consider CER as 

described in this paper and it will plan future rulemakings accordingly. 

RESOURCES: 

The lead rulemaking offices (the Office of Nuclear Reactor Regulation, the Office of New 

Reactors, and the Office of Federal and State Materials and Environmental Management 

Programs) have revised their rulemaking resources in the FY 2013 President’s Budget and the 

FY 2014 Performance Budget to include those resources associated with the CER Process. 

COORDINATION: 

This paper has been coordinated with the NRC’s Rulemaking Coordinating Committee and all 

rulemaking lead and partner offices. The Office of General Counsel has reviewed this paper 

and has no legal objection. The Office of the Chief Financial Officer has reviewed this paper for 

resource implications and has no objections. 

 /RA/ 

 R. W. Borchardt 

 Executive Director 

 for Operations 

201200147/EDATS (Not in EDATS) 

201100272/EDATS: SECY-2011-0641 

201100276/EDATS: SECY-2011-0645 

ADAMS Accession No: ML12223A162 * via e-mail 

OFFICE NRR/DPR/PRMB NRR/DPR/PRMB* Tech Editor* NRR/DPR/PRMB:BC* NRR/DPR:D 

NAME TInverso CEngland JDougherty SHelton TMcGinty 

(SBahadur for) 

DATE 08/09/2012 08/09/2012 08/16/2012 08/15/2012 08/20/2012 

OFFICE RES:D* FSME:D* NMSS:D* ADM:D* NSIR:D* 

NAME BSheron 

(SRichards for) 

MSatorius 

(JPiccone for) 

CHaney CCarpenter 

(CBladey for) 

JWiggins 

(CLui for) 

DATE 09/06/2012 09/07/2012 09/06/2012 09/07/2012 09/07/2012 

OFFICE NRO:D OGC/GCLR/RMR* OCFO:D* NRR:D EDO 

NAME GTracy BJones 

(HBenowitz for) 

JDyer 

(JBiggins for) ELeeds RBorchardt 

DATE 09/07/2012 09/07/2012 09/06/2012 09/14/2012 10/5/2012 

OFFICIAL RECORD COPY