Mr. President – Ike would recommend the nuclear option for energy policy

Dear President Obama:

I was heartened to hear that you have put fighting climate change near the top of your “to do” list during your second term. It is time for you to dig through your memory banks, your pile of correspondence and the lessons you are learning by studying Eisenhower’s presidency to realize that you already know the right answer to the question.

As a rising young politician in Illinois, a state that obtains 50% of its electricity from the largest concentration of nuclear power plants in any state in the United States, you obtained the support of seasoned nuclear energy professionals at Exelon and at the Argonne National Laboratory. They taught you the importance of clean energy, and showed you that nuclear energy has an impressive and improving safety record built on a culture that aggressively learns lessons from mistakes made anywhere in the world.

After your first election, you received an open letter from Dr. James Hansen, one of the most prominent and prescient voices in the battle against climate change. He told you about the importance of effective solutions and he mentioned the incredible opportunity provided by advanced reactors, like the Integral Fast Reactor that was developed at the Argonne National Lab, located just a few miles outside of Chicago.

That system can turn material from former nuclear weapons into a forever fuel source by using it to make depleted uranium a valuable fuel. He did not mention them specifically, but we also have developed similarly impressive systems like the molten salt reactors that run on thorium and the high temperature gas reactors that can produce industrial process heat as well as electricity.

As Dr. Hansen pointed out, nuclear fission reactors are reliable power sources that do not produce any greenhouse gases. In addition to advocating investments in nuclear energy research and development programs for advanced reactors, he also pointed out that we have refined, 3rd generation light water reactors that are ready for immediate building programs.

One 3rd generation design is now so ready that the shovels have been moving in earnest for several years in Georgia and South Carolina at Plant Vogtle and VC Summer. Those two sites are employing about 5,000 people at wages that can support a family; there are thousands more supporting the projects in numerous locations throughout the industrial heartland of the United States. A second advanced design from GE is nearly ready for approval, while at least two others are winding their way through the rather slow moving Nuclear Regulatory Commission process, which has not yet established enabling new nuclear reactors as a high priority activity.

Ike giving a speech

Ike giving a speech

There have been reports recently that you are studying one of the most effective presidents of the 20th century for guidance as you decide how to spend your next four years in office. As you well know, President Dwight D. Eisenhower – called Ike by almost everyone – knew a bit about the dangers of the military industrial complex. I hope you have also discovered that he knew a great deal about the incredible potential offered by effectively using nuclear materials and industrial capacity for peace, not for weapons. One of his most important speeches, in terms of its long term impact on the United States and the world, was made in December 1953 to the assembled body of the United Nations. That speech has long been remembered as Atoms for Peace. Here are some of the words from that speech that offered hope and change for the world.

The United States knows that peaceful power from atomic energy is no dream of the future. The capability,already proved, is here today. Who can doubt that, if the entire body of the world’s scientists and engineers had adequate amounts of fissionable material with which to test and develop their ideas, this capability would rapidly be transformed into universal, efficient and economic usage?

Ike’s vision delivered hope and change for many years. In the 20 years after that speech, the US started enough new nuclear power plants to supply 40% of the nation’s electricity. About three times that many were begun in other countries around the world. Our manufacturers prospered and created hundreds of thousands of good jobs for products used both here and abroad.

Unfortunately, about half of the nuclear projects that started were not completed or were shut down well before the end of their useful life. There were many factors that led to that unhappy result, but the good news is that the plants that were completed produce about 30% more electricity every year that all of the power plants in the US combined produced in 1960. Their 800 billion kilowatt hours of electricity each year help the US avoid producing more than 600 million tons of CO2 every year. That is almost as much CO2 prevention as the total amount released from all of the passenger cars on the road.

A move to enable nuclear energy to prosper does not require much from you. A few carefully chosen words from the bully pulpit would help the NRC to recognize that efforts to license new reactors should receive a high priority. A few more words might help the commissioners and the staff to more completely understand how you interpret the NRC’s current mission statement:

The mission of the NRC is to license and regulate the Nation’s civilian use of byproduct, source, and special nuclear materials in order to protect public health and safety, promote the common defense and security, and protect the environment.

A regulatory agency with that mission should recognize that new nuclear plants protect public health and safety, promote the common defense and security and protect the environment, especially in an era where there is a large stockpile of refined nuclear materials that should be put into protected locations – and what location in the world has more layers of protection than an operating nuclear reactor – and where there is legitimate concern that CO2 emitted from power plants might be putting our children and grandchildren’s future prosperity at risk.

This is not a call for short cuts on safety, but every bureaucrat who has been on the job more than a few days knows that high priority efforts can be done much more expeditiously and at lower cost than those where every step of the process involves waiting in line in someone’s in-box. Regulatory reviews take some time, but they can also be purposely stretched into career length tasks if prompt completion is not encouraged.

An emphasized nuclear option in your energy policy has wide ranging political benefits. It fits in with “all of the above” by ensuring that the best of the above is not put at a disadvantage by taking too long or having support that seems too uncertain for making long term investment decisions. It does not require much in the way of public money – reducing regulatory slowdowns during reviews should cost less, not more. It does not require unpleasant sacrifices because after they are completed, nuclear plants are some of the lowest cost, most reliable generators on the grid. It does not even require you to ask Republicans to swallow bitter pills; they already like nuclear energy and would probably jump at the chance to help you move forward in that direction.

Mr. President, you have an opportunity that you cannot pass up. Please take advantage of your unique time in history to make the world a better, safer, cleaner, more prosperous and more equally hopeful place.

About Rod Adams

37 Responses to “Mr. President – Ike would recommend the nuclear option for energy policy”

Read below or add a comment...

  1. Joris van Dorp says:

    Amen. One sentence I don’t understand is:

    “Regulatory reviews take time, but they can also be purposely stretched into career length tasks if not encouraged.”

    Another thing: I’m not clear on why “it would not require much” from the President. At least, IMHO, he needs to make a speech similar in scope and passion to Ike’s speech. And he needs to release funding for an effective, evidence-based and sustained nationwide nuclear education and public consultation campaign. And he needs to get the major anti-nuclear camps in Washington into line by pragmatically targetting each of their specific (hidden) agenda’s and working out compromises and deals with them (if necessary) that would enable them to stop their anti-nuclearism.

    And preferably, since he is still the “Leader Of The Free World” he needs to additionally make sure there is a stronger international effort on nuclear energy, encompassing the responsible and transparent handling of (reprocessed) nuclear fuels and waste, as well as the free proliferation of safe, well monitored civilian nuclear applications to all countries that would otherwise burn fossils, in a fair, effective and generally bona fide manner.

    Maybe you mean ‘not much’ because all of these things do not necessarily have to cost a lot of money to the taxpayers?

    • Rod Adams says:

      Making speeches should be easy. That is one of the President’s core competencies.

      • Daniel says:

        Rod,

        I would say delivering speeches is a presidential core competency. Making and writing speeches belongs to guys like Zel Miller and not necessarily within the presidential domain. (Zel can deliver them too, but he is clueless when being interviewed)

  2. Brian Mays says:

    P.S. Please appoint a qualified person to chair the NRC.

    • Engineer-Poet says:

      Would that he but could
      Owes too much to too many
      Ed Markey objects.

      • Rod Adams says:

        Politicians who are independently wealthy and not eligible to run again should be able to make independent decisions. Besides, the President has some favors to repay for people besides Markey and Reid. People who would benefit from my suggested path vastly outnumber those who who would object.

        • Brian Mays says:

          Politicians who are independently wealthy and not eligible to run again should be able to make independent decisions.

          Rod – Independent decisions, perhaps, but is that necessarily a good thing?

          What you have just described is Mayor Bloomberg. Sorry, but I don’t like aristocrats, particularly ones that are so petty in their authoritarianism that they feel it is their inherent duty to tell the “little people” what size sodas they can or cannot drink. Isn’t it wonderful to live in a country where we have such unalienable rights as Life, Liberty, and the pursuit of Happiness … as long as it comes in 16 ounces or less? Welcome to New York! ;-)

          Didn’t we fight a war to get away from that sort of thing?

          The good thing about a candidate who wants to run for reelection is that he or she is at least required (in theory) to be answerable to the electorate. Kings, princes, and dictators are given the luxury of independent decisions. Their record is not all that good. Independent decisions are not necessarily wise decisions.

  3. Atomikrabbit says:

    “A move to enable nuclear energy to prosper does not require much from you”

    As Brian has just pointed out, part of what will be required is appointments of NRC and DOE leaders who have demonstrated their understanding of energy-dense technologies and their value in preserving the environment, providing energy self-sufficiency, and promoting economic sustainability.

    And the courage to overrule powerful political leaders within his own party who have assigned themselves veto power over important nuclear initiatives.

  4. Frank Jablonski says:

    Excellent, Rod. Maybe we should do a petition to this effect. They seem to run petitions for everything from secession to deportation of individuals these days, but maybe this is one that, with the right signatures, could garner some attention.

  5. donb says:

    The NRC’s own mission statement says it all:
    The mission of the NRC is to license and regulate the Nation’s civilian use of byproduct, source, and special nuclear materials in order to protect public health and safety, promote the common defense and security, and protect the environment.

    The NRC has effectively added its own points so that the statement effectively reads something like this:
    …to protect public health and safety from nuclear threats…
    and
    …and protect the environment from degradation caused by nuclear energy activities.

    The mission statement needs to be changed so that the public health and safety effects of things like the NRC’s slow approval process are part of the assessment of overall public health and safety. Delaying a safe and clean nuclear power plant allows other dirty and dangerous power plants to continue in operation. The impact of “safety” rules needs to examined. More burdensome regulation will push power utilities away from the use of nuclear energy and towards more dangerous coal and gas powered generation.

    The NRC has been making the perfect the enemy of the very good, to the detriment of public health and safety, and the environment.

  6. Atomikrabbit says:

    This article points out how political appointments other than NRC and DOE may be even more important in influencing the direction of future energy policy: http://energy.aol.com/2013/01/23/it-s-not-doe-that-drives-energy-policy

  7. Jim Van Zandt says:

    Eisenhower’s comment about “adequate amounts of fissionable material” deserves a note that, since then, we have (1) discovered there is much more uranium around than we knew about then, (2) made great strides toward fast reactors that make much more efficient use of the uranium, and (3) also made progress toward reactors using thorium, which is even more abundant than uranium.

  8. Jeff Walther says:

    I like the letter, but how do you get Obama to read it? Do you have a contact who can get it in front of him?

    Two things, I’m no expert on this kind of high level persuasion, so this may be misguided, but it seems like you fail to explicitly come out and say that the NRC needs to recognize that nuclear electricity generation is the least harmful form of generation, and anything that delays new generation encourages the continuation or expansion of more harmful forms to the detriment of public health. Therefore indefinite delay in licensing or restarting nuclear reactors has continuing negative consequences to public health and safety. Perhaps modify this sentence:

    “A few carefully chosen words from the bully pulpit would help the NRC to recognize that efforts to license new reactors should receive a high priority. ”

    To something like this:

    “A few carefully chosen words from the bully pulpit would help the NRC to recognize that efforts to license new reactors should receive a high priority, because operating nuclear reactors displace coal and natural gas electricity generation and coal and natural gas are proven to be harmful to the public health and safety, even when operating normally. Therefore any delay in licensing or restarting nuclear reactors has ongoing negative consequences to public health and safety and the NRC should take that into account when creating their operational time frames.”

    You put all the evidence in your letter, but I felt like you never drew the conclusion for your audience, and I don’t think you can assume that the audience will reach the same conclusion as we would here.

    Finally, , you have ‘to’ instead of ‘too’ in the first sentence of the penultimate paragraph, just before the word ‘uncertain’, .

  9. Rich Lentz says:

    Your dream will never happen with a democratic administration. Never. This administration is convinced that the “unreliable” energy sources will “save the world!” They are told this by the very people that should be supporting nuclear power. Does Duke Energy come to mind? Do you think Duke was pushing Nuclear power at the democratic convention? Look at the rumblings on the Nuclear Townhall webpage and in the power trade magazines about the NPPs that are throwing in the towel or talking like they will, Kewaunee for sure and probably Fort Calhoun and/or Oyster Creek (that I am aware of.) They do not care how they get their energy – PUC controlled utilities will always make money. (If they don’t, the municipality will take over and you will still pay.) Do you realize that GPU Nuclear actually made enough money to pay dividends while TMI-I was shut down? After bad press, they stopped paying dividends, but not because they were not making any money. Do the recent 787 problems give you an idea of where we really are on the new savior of renewable energy – the lithium ion battery? I hope you have not invested your whole nest egg in Li-Ion stock. This administration, and the next if democratic, will dump trillions into this sink-hole. Where is the research on fuel-cell technology? What happened to home sized natural gas fuel cells making electricity and using the waste heat to make your hot water? Why isn’t every home required to have a geothermal HP – HVAC? (and NG powered at that?)

    As for cost benefit, the NRC has forgotten what they are. I have been (was) in the business long enough to perform a real cost/benefit analysis and sell it to the NRC (AEC) at the time and prevented the plant from making one of their requested changes (we did have to agree to perform a test to prove our analysis though). When I retired all of the NRC changes were couched in terms of orders and or directives or had a NRC “canned” cost benefit analysis done when needed. Another typical NRC tactic is to attach a cover letter stating that the requested actions were exempt from these rules because, in their estimation, it would take less than 30 man hours to perform this activity. We had more than 3000 man hours invested in one of these 30 hour projects, not counting the “overhead” man hours of the numerous reviews by management as their time was charged to management codes and not project codes. And for that matter, even a thank you letter to the NRC required investing 50 to 60 hours in the research, preparation, review, approval and final signature process.

    • Joris van Dorp says:

      Same situation here in the Netherlands. I’ve actually seen CEO’s of Dutch power companies blast people who expressed doubt about the ability of solar and wind to supply large fractions of our energy needs and do it in a cost effective way. I still don’t understand how this is possible. Perhaps attaining CEO position these days requires having little or no real knowledge of energy systems? Or perhaps the CEO knows that solar and wind will not be a big threat whether they support it or question, and it is therefore no risk to support solar and wind way beyond what they are actually capable of doing, while reaping the benefits of seeming to be ‘greener’ that the competition?

      • jmdesp says:

        There’s a lot of connexion between wind and gas. It’s likely anyone who has big stake in gas sees wind as the biggest guarantee nothing will ever displace it’s gas investment, as there’s hardly any other option that’s similarly efficient at following the variations with limited capital and maintenance costs, so smaller bad consequences of running at a low load factors.
        Even if it’s more theory than fact, as a brand new modern CCGT is not that cheap, and does need a high load factor at a good price to reimburse it’s capital cost in the early years. That’s why some of them are belly up currently, given the crisis, low demand, and a lot of new renewable capacity added.

        • Engineer-Poet says:

          It makes me wonder if there’s an opening for coal-fed IGCC in Europe, with carbon sequestration in the gas cleanup (people are talking about spreading olivine on fields, do it in the gas stream and skip the middleman).  It could meet carbon targets and the price of fuel is a fraction of Russian gas.

          Once the Russians no longer have a lock on wind’s backup energy supply, there would probably be less support for wind.

    • Rod Adams says:

      @Rich

      Your dream will never happen with a democratic administration. Never.

      I am reading a terrific first hand account of the destruction of the Atomic Energy Commission and the creation of the Nuclear Regulatory Commission as a regulatory agency with no responsibility for promoting nuclear energy. The story appears in The Atomic Energy Commission Under Nixon: Adjusting to Troubled Times by Glenn T. Seaborg with Benjamin S. Loeb.

      Seaborg served as the Chairman of the Atomic Energy Commission for about ten years. He was a diligent diarist and uses his copious notes as the primary information source. His accounts of how Nixon and his staff worked to reorganize the Executive Branch, which included destruction of the AEC and its legislative sponsor, the Joint Committee on Atomic Energy is pretty depressing reading.

      In other words, please do not place the blame for our current structure on the Democratic Party.

      I will agree with Brian Mays and others that the current chairman was not the best choice, but the other four commissioners, all of whom have been either nominated or renominated by President Obama are top notch regulators with deep knowledge of nuclear energy. (The “deep” adjective is especially appropriate for Bill Ostendorff.)

      • Joel Riddle says:

        Rod, I wonder if there might be any hope of somehow resurrecting the JCAE? That would have to be much, much more feasible than getting the NRC to shift back towards more of an original AEC-like model of balanced safety regulation.

  10. John Tucker says:

    Well put letter.

    I hate to even mention this as I was very pleased with selection of the inaugural poet, who he is and indeed he is a beautiful writer and speaker, but when he hit “planting windmills
    in deserts and hilltops that keep us warm” it grinded like metal on metal.

    Anyway I guess “planting windmills in deserts and hilltops that may keep us warm randomly and intermittently while pureeing eagles” doesn’t sound as good.

  11. Robert Hargraves says:

    Rod,
    This is a wonderful letter. Unfortunately I’m learning that influential people are surrounded by armies of minions whose duty is to keep distracting messages away from the chief. Their job is to promulgate their chief”s [uneducated?] messages, not to influence the chief’s decision-making. We are all trying, however.

  12. nuke roadie says:

    Eloquent and direct as usual. The question that begs an answer is how to move this forward ? What is needed to actually give this the power and recognition it deserves? A mass petetion with as many signatures as possible might get the attention of the necessary people. Don’t let your (our) vision for a clean energy future fall into the void of the internet. I personally am willing to devote my time and limited resources to any initiative that moves nuclear energy forward and so are numerous others. Take the helm and our voices will be heard. Start the petition.

  13. Bernd Felsche says:

    A lovely letter.

    Alas; Obama is a fountain. While fountains spew volmes wonderously they never draw from those upon who they spout.

    If invited to the VaticanWhite House; take an umbrella.

  14. EL says:

    Steven Chu “out” and Ashton Carter “in”? Hard to tell what to make of these rumors, but it appears to be a developing story.

    http://www.bloomberg.com/news/2013-01-22/defense-deputy-carter-said-to-be-leading-contender-for-energy.html

    Great letter and forceful defense.

    • EL says:

      Yep … It’s official.

      “Steven Chu Resigning: Energy Secretary To Step Down From Obama Administration Post”

      http://www.huffingtonpost.com/2013/02/01/steven-chu-resigning_n_2599194.html

      If Ashton Carter is next in line, nuclear proliferation and global security risks are about to move to the top of DOE’s agenda. Together with NRC top post (and dealing with issues of waste management and storage), looks like a good foundation to tackle many of the long standing and overdue issues in nuclear (particularly in defense spending and Cold War era weapons programs). I’m sure others will see this differently here (perhaps as issues that don’t need to be addressed), but I would see a Carter appointment as a clear signal from Obama Aministration in this direction. I imagine we’ll have a new nominee for the post soon enough (in a matter of days to weeks).

      • Brian Mays says:

        Eh … good riddance to Chu.

        He managed to take a 35-year-old bureaucracy that was merely incompetent at cleaning up old Cold-War weapons sites and ineffective at promoting real innovation in the energy sector to the dubious honor of being the world’s worst venture capitalist fund.

        That’s a first. Perhaps he should take some sort of perverse pride in this accomplishment. Personally, I speculate that he’s just happy to return to his academic cocoon and leave (non-academic) politics behind.

        Don’t think that I don’t feel sorry for the guy. I realize that the person who was actually responsible for these awful decisions still has his job.

        Elections have consequences, folks.

    • EL says:

      Maybe this will get the conversation started.

      http://www.reuters.com/article/2009/05/18/energy-security-idUSN1836475920090518

      Ashton Carter has been leading efforts in the Defense Department to cut back on energy consumption, and promote a switch away from fossil fuels (with rising costs adding $7 billion, or 53%, to Department fuel costs in 2008).

      As many know, the defense department has leading efforts in renewables and alternative energy deployment, SMRs, and also evaluating energy security risks and infrastructure needs in the US and foreign countries.

      Carter called energy a big driver of Pentagon policies and strategies, and said the department had already tripled spending on energy research and development programs to $1.2 billion over the past two years, plus $300 million from the federal stimulus bill …

      Carter lauded a new report released Monday by the center that was prepared by a high-level panel of retired admirals and generals, saying the issue would play a key role in several reviews of defense programs now under way at the Pentagon.

      The report concluded that heavy U.S. use of fossil fuels and the fragile U.S. electricity grid posed significant security risks to the country and the military.

      Warning of the destabilizing nature of increasingly scarce resources, the report called on the Pentagon to fully integrate energy security and climate change goals into national security and military planning.

      He sounds like an interesting choice to me. Wondering if anybody else knows more about him, and what he might have in mind for US energy goals, infrastructure and financing needs, R&D, and climate policy?

      • Rod Adams says:

        @EL

        I am cautiously optimistic. The nagging question I have is his involvement with some of the very poor energy decisions that I saw being made by DOD from my point of view as a resources and requirements officer in the office that supported fleet maintenance and operations. That tour was my last active duty job; the decisions I saw being made with the way money was being put into dead end energy technology contributed to my decision to retire about 4 years before I would have had to retire by hitting the statutory end of service limit.

        The US Navy already has the answer to a vast reduction in DOD fossil fuel consumption. We’ve had nuclear fission technology since 1953 and have built the world’s most experienced cadre of nuclear technologists. I saw SOME support for continued use of nuclear energy and SOME support for new development, but I also saw a very large amount of money being taken out of the operating fleet’s fuel budget and then wasted on algae based biofuels, wind mills on military bases and huge solar arrays. From a military point of view, I cannot imagine anything less useful than large wind mills. The algae based biofuel cost 20-50 times as much as conventional fossil fuel and had an even more fragile delivery network.

        As long as Carter was NOT the behind the scenes decision maker for those silly expenditures, your description of his focus areas sounds like it is firmly grounded in utility, NOT fuzzy dreaming or blatant pandering to vested interests.

        • EL says:

          Thanks. The military seems to be invested in new energy developments across the board. Lots of debate over wind (“large spinning things” that jam radar signals according to [url=http://www.defense.gov/news/newsarticle.aspx?id=31070][color=#0000FF]one former air force base commander[/color][/url]). Searching the DOE site, 10 GW were cleared and approved for construction in 2011 after many delays. Here are the four at Guantanamo Bay (currently suppling 5 – 12% of the bases power).

          http://www.defense.gov/DODCMSShare/NewsStoryPhoto/2005-03/screen_20050329172352_windmills1.jpg

          Others will have to speak to the merits of his approach to nuclear power operations and systems.

        • EL says:

          Looks like Obama is ready to announce Ernest Moniz as Secretary of Energy (although it’s not official yet). Undersecretary of Department from 1997 – 2001 (where he directed research on Yucca Mountain), Panel Member on Blue Ribbon Commission, Director of MIT’s Energy Initiative and Professor of Physics and Engineering Systems, and more.

          He seems a major supporter of new reactor builds, SMRs, research on advanced fuel cycles, and nuclear waste management issues (which he calls dysfunctional and “limits the options for preventing other countries from using nuclear power infrastructure to produce nuclear weapons”).

          We’ll see … an interesting choice, and someone who might mend fences when it comes to Yucca. In recent writing, he makes a strong case for interim storage (where spent reactor fuels can be made available for future use), research on advanced fuel cycles (too soon for commercial development), long term plans for deep geological storage (especially for DOD wastes), and speaks out against prescriptive approach on Yucca Mountain (which he says contributed to so many decades of delay and mistrust).

          Once official, expect to hear much more. We’ll see how it all turns out.

  15. G.R.L. Cowan says:

    “the plants that were completed produce about 30% more electricity every year that all of the power plants in the US combined produced in 1960″ — you’ve got a “that” where you wanted a “than”.

  16. Jim Hopf says:

    Speaking of nuclear costs, NRC regulations, and perspective concerning risks, an article of mine concerning what’s driving nuclear construction costs has just been posted on the ANS Nuclear Cafe website. The article is meant to start a discussion, and I would like to hear any perspectives that any of you may have. (Forgive the plug.)

  17. Mikael Ros says:

    Rod,

    What is happening to the NRC review of the fee structure that you wrote about in 2010?

    The annual fee is now (2012) $4,766,000.

    Trade is pushing for changes The Commercial Outlook for U.S. Small Modular Nuclear Reactors

    In this document “NEI Position Paper: NRC Annual Fee Assessment for Small Reactors” the annual fee for reactors < 250 MWe is proposed to be approximately $115,000. Any news about this?

  18. Robert Bernal says:

    I posted to facebook…If only we all had a “million friends”.
    Every time I see a plea to stop an oil pipeline, etc, I always say something like:

    “If we don’t develop machines that can mass produce 100,000 square miles of solar and batteries for dirt cheap, then we MUST build advance nuclear such as LFTR or IFR… search them.”

    I see that a lot of other people are posting about nuclear too and hope this awareness thing works.

  19. Mikael Ros says:

    The new fee for operating nuclear reactor FY2013 is suggested to be increased from $4,766,000 to $4,780,000. Nothing about a reformed fee schedule for SMR. Can we hope for FY 2014?

    http://www.regulations.gov/contentStreamer?objectId=090000648121e059&disposition=attachment&contentType=pdf

Leave A Comment...

*

You may use these HTML tags and attributes: <a href="" title=""> <abbr title=""> <acronym title=""> <b> <blockquote cite=""> <cite> <code> <del datetime=""> <em> <i> <q cite=""> <strike> <strong>





Notify me of followup comments via e-mail. You can also subscribe without commenting.