South Korea Consortium Steals UAE Nuclear Deal

UAE strengthens hand with nuclear deal/Sun Dec 27, 2009 10:28am GMT
DUBAI/SEOUL (Reuters) - South Korean firms Korea Electric Power Corp. (KEPCO), Hyundai Engineering and Construction, Samsung C&T Corp and Doosan Heavy Industries have won a deal worth around $40 billion to build and operate nuclear power plants in the United Arab Emirates, industry sources said today.
http://c.moreover.com/click/here.pl?t2427068707&f=10149

Were U.S. firms contenders? Probably not. Politics alone would have posed a barrier to GE. However, the broader issue is the dearth of U.S. commercial involvement. Although Westinghouse, owned by Toshiba, was one of the winning consortium, the plants are not AP-1000s. Most export income and profit from the project will go to Korea. The irony is that U.S. taxpayers, who footed the bill for commercial nuclear power development, will see no benefit accrue to U.S. companies, U.S. balance of payments, U.S. taxable income or other U.S. strategic concerns. Nor does the current crop of politicos in Washington on Capital Hill even care - they’re off chasing windmills.

The absence of a global U.S. nuclear strategy, as presented by President Dwight Eisenhower when he signed the Atomic Energy Act of 1954, has left the U.S. taxpayer's investments high and dry. Does the Obama administration care to change that picture?

Without a change of direction in Washington DC, the U.S. is headed towards third-rate status in world nuclear design, construction and operations. That should give all U.S. citizens pause for concern.

Will Westinghouse follow GE with its shield building design?

Via press release October 15, the Nuclear Regulatory Commission has said that Westinghouse’s new AP-1000 reactor design reactor shield building needs modification. Although Westinghouse said it would be no problem to comply with NRC’s request, this could slow down final AP-1000 design approval.

Insiders feel the NRC is frustrated with the Westinghouse shield building design, and that public release assures the NRC will slow the AP-1000 timetable. Some question whether utility loan guarantees that support the AP-1000 design should immediately stop, like DOE’s risk-ranking did when GE’s ESBWR design ran into similar licensing troubles.

Although rumors allege shield design problems, the details aren’t clear. Two stories relate them: (1) with modular construction of the Westinghouse shield structure design, and (2) NRC's design licensing approach. Both will affect new plant construction - the latter already has. With people who lack practical experience in design or construction, NRC is more into technical details than ever before. This story realizes everyone's worst fears, exactly. If the NRC won’t hold to a schedule, and dwells on technical details that may be beyond the technical skills of the staff, they can’t hold to a schedule. Furthermore, they‘ve never liked technical oversight of their work. Based on how the DOE evaluated the GE's ESBWR design for completion probability success, OMB should also hold up Congressional NP 2010 loan guarantees for the Westinghouse plants. That would put Areva's EPR design out front to construct, with multiple AP-1000 and lead plant Vogtle 3 owner Georgia Power (Southrern Nuclear) on hold. That would kill new nuclear construction momentum.

The bigger story is the NRC – and how they work. They aren't transparent like they claim, internally aligned, or objective. They don't follow schedules (how can safety be scheduled?) nor allow themselves to be held accountable for decisions. They worry eternally over technical details they can’t evaluate. Ironically, the loan guarantees were to protect against regulatory delay, but now they (loan guarantees) could exclude a "U.S." design from loan guarantees a second time. Loan guarantees are an essential prerequisite to funding. (GE’s case was the first.) Of course, now Toshiba owns most of Westinghouse. Although it’s a good time to get it out on the table, challenging the NRC and being delayed poses great risk.

Technical opinions on the validity of NRC claims against the AP-1000 speculate on this point; NRC experience is the best indicator. The AP-1000 containment approach is new. The US NRC does not do new well. They're still resolving digital IC controls, approved by the rest of the world 20 years ago. Since the NRC cannot work to a schedule, everyone must prepare for more cost. So much for Part 52's certified design risk-free development process. Converting a high-level design into construction is always complex. A tremendous amount remains ahead, for every design, constructing every plant even with a complete high-level design.

People have proposed more transparent methods to license new designs. So far, the NRC’s Commissioners, Executive Director for Operations and reactor venders have chosen to not raise the license process issue. Although we believe it would make the licensing more truly transparent and accountable, and speed it up, it would also take away power they currently hold.

If only based on what "others" said, Westinghouse has a problem. Going public NRC chooses an alternate path instead of resolving the technical issue directly. That's a bad sign - they're using their trump card. Prefabrication methods that accelerate construction in Japan are foreign to the US. The US NRC could delay licensing Westinghouse AP-1000 over them. Insistence on using modular construction techniques, including post-stressing systems, could be the focus of threats (under their owner, Toshiba that is) could delay approval of the Westinghouse AP-1000 recertification.

Scuttlebutt at a meeting in Washington DC asserted that in effect Westinghouse told the NRC, "Well, since the Japanese accepted the AP-1000 Shield Building design, it must be acceptable." The implication was that the Japanese regulator - with whom Toshiba presumably is in touch - was a tougher smarter or at least as qualified a regulator as the NRC. That’s hearsay, but if it happened, it would explain why the NRC would be upset. Of course, the Chinese are building four AP-1000’s today, with no specific concerns. (Remember, the US NRC already certified the early AP-1000 design in 2004.)

Should the NRC take Westinghouse to task - or visa versa? Calling press conferences for issues such as shield building modifications only foreshadows more problems. Many more are behind this one - digital controls, combustion turbine emergency backup power, Cyber Security, and others like them. Will this influence Westinghouse's marketing plans or stock price? It’s hard to tell now, but the worry is that it will. In the past, delays killed US nuclear programs. This threat realizes the banker’s worst fear, and emphasizes the role loan guarantees will have on retaining the US nuclear option - if it still exists.

Closing the RAP GAP for safety, cost and investment protection

September 25, 2009

Honorable Senator Thomas A. Carper
Chairman, Senate Environmental and Public Works
Subcommittee on Clean Air and Nuclear Safety
United States Senate 513 Hart BuildingWashington, DC 20510

Closing the RAP GAP for safety, cost and investment protection

Responding to Three Mile Island (TMI) learning twenty years ago, Part 52’s Combined License Quality Assurance Program (QAP) required certified designs provide a Reliability Assurance Program (RAP). Unfortunately, the nuclear industry failed to recognize that new plant RAPs are simply scheduled maintenance plans. Since introducing Boeing’s 747 in 1967, the FAA has only licensed new airplanes with certified scheduled maintenance plans. NRC should implement Part 52’s intent and letter by only licensing new designs with completed RAPs - the same way U.S. airframe suppliers have done the past 42 years.

Senator Carper:

Title 10 CFR Part 52[1] requires new nuclear plants to have reliability assurance programs (RAP) covering safety-related equipment. The difference between a new and operating plant reliability assurance programs - e.g., their scheduled maintenance plans - creates a RAP gap. Many nuclear plants started up under Part 50 with virtually no scheduled maintenance plans. Three Mile Island (TMI) was one. Few of those scheduled PMs. Surveillance test programs had major omissions, discovered only after industry-wide audits following TMI. New plant owners of that era assumed their operators could patch together various safety-related equipment maintenance and monitoring plans after startup once they completed the immediate startup goal to establish income flow. They did not.

TMI-2[2] demonstrated the huge risks that placed on the plant’s public, operators, and especially the nuclear industry and its financial backers. Those charged to develop plans were often woefully unprepared to do so, lacking formal training, qualification or effective tools. They deferred to operational needs. As a result, as late as 1995 many nuclear plants still ran with substantially incomplete reliability assurance plans.

Few financial lenders today would embrace placing their $8 billion dollar asset into operation without a scheduled maintenance program. Yet regardless of common sense, and rules that require RAP for nuclear safety-related equipment, we are poised to repeat that error again today - even on required, in-scope nuclear safety-related equipment. Although rules formally only cover a small fraction of overall plant equipment - the nuclear safety-related equipment - resistance developing programs before plants start up has emerged again. Regardless of what brokers or owners should expect to protect their huge investments[3] for purely economic reasons, addressing safety-related equipment’s planned monitoring and scheduled maintenance before startup remains unresolved.

Commitment today to implement Part 52’s NUREG-0800[4] and Regulatory Guide (RG) 1.206[5] RAP requirements remains unclear. Guidance remains suitably vague, confused by deterministic design considerations and engineering judgment. Completing the scoping of safety-related equipment classification is the only certain pre-startup requirement today. Thus, the same unprepared workers charged to develop Generation I plans, lacking in formal training, qualification and tools, are poised to do so again. Will they defer that task again to operational needs, and repeat the lessons of 1970’s and 80’s? Incomplete plans started up TMI, placing a huge risk on overall operations. The cumulative result of thirty years of nuclear operations indicates starting new plants with incomplete operating “software” causes confusion and introduces risk. Ignoring TMI, regulatory response the past thirty years has been many rules like as 50.49, Environmental Qualification of Class 1E Electrical Equipment for Nuclear Plants that specify nuclear maintenance programs. Guidance today now covers how to develop effective, comprehensive equipment scheduled maintenance and monitoring plans. For new nuclear construction, Part 52 specifies developing a reliability plan. Prospective licensees see providing the equipment scope covered by the rule, a safety-related MEL, meeting that requirement. Today, few anticipate providing scheduled maintenance plans required by the RAP at startup.

Industry should emulate the Federal Aviation Administration (FAA) and airline industry. FAA certifies new airframes with a preflight reliability assurance program as crew operational checks and scheduled maintenance[6] - before a licensed commercial plane ever leaves the ground! The advantages are many. Aside from having a complete startup plan from the onset, providing a systematic approach yields a structured plan. Plants can realize their design-based reliability, rather than let haphazard chance events determine outcomes. Reasons to develop embedded design-reliability programs include engineering completeness, along with forty-years operating experience. Financing requires realizing nuclear operations consistency from the start. Not only is it imperative not to repeat TMI, new nuclear generation economics require very high cost performance to repay construction loans. Cost-plus scenarios of Part 50 LWR licenses[7] are gone forever; they must meet public utility commission (PUC)-promised rate case projections. Predictable nuclear operating costs from reliability benefit safety directly as well as indirectly over a plants lifetime. Design-forward reliability benefits nuclear power consumers by not funding repetitive, haphazard design basis and scheduled maintenance reconstitution programs over and over, adding unnecessary or even detrimental requirements to maintenance processes. Everyone benefits from standardized operating plans licensed with plant designs.

Conclusion

Important strategic initiatives have hamstrung the nuclear industry in the past. While the industry should legitimately concern itself with the intrusion of regulation, existing safety statutes and rules are mandatory. Extending those sensibly to achieve common success on nonsafety related nuclear plant equipment should remain industry’s prerogative. However, the tools, methods and programmatic understanding to develop, implement and maintain effective, automated reliability programs have never been more available. If loan guarantees effectively make Congress the nuclear industry’s banker, it should require application of the very best methods and processes to protect its capital investment - not just nuclear safety-related equipment.

Given the substance, value and costs before us, as well as our safety interest, it is imperative that those who approve funds to develop safe American nuclear energy resources thoughtfully consider nuclear reliability and licensing. Congress should deliberate these matters as energy debates continue.

Sincerely,

J.K. August, PE
J.J. Hunter SRO
CORE, Inc.
303-425-7408/970-330-1411
[1] Licenses, certifications, and approvals for nuclear power plants
[2] The accident, a $2 billion loss.
[3] in nonsafety balance-of-plant equipment, constituting 80% of overall plant cost
[4] Review of Safety Analysis Reports for Nuclear Power Plants
[5] Regulatory Guide for Combined License Applications for Nuclear Power Plants
[6] See ATA MSG-3 (2001), Operator/Manufacturer Scheduled Maintenance Development, which provides an FAA-approved method for developing aircraft inspection/maintenance programs. Aircraft providers must certify airframes and power plants for commercial service applications.
[7] Under Part 50, most rate-based plants were allowed to recover “reasonable” ongoing construction costs.

Chairman Jaczko Remarks: Heritage Foundation

Gregory Jaczko, President Obama's new NRC head, outlined his priorities for the agency in a speech at the Heritage Foundation. He said little about new reactor applications, except that the agency would focus its limited application review resources on projects most likely to be built first. What does that mean?

What about DOE and the NP-2010 initiative, and Congress' Next Generation Nuclear Plant? What about new plant licensing? What about the high cost of new plants? What about operating plant performance improvements?

Chairman Jaczko needs to get the chance to firmly plant his feet. Then he should take off charging. If DOE's to have any impact on energy, NRC has to support their effort. They (the NRC) also need to support (coax, push, encourage and pressure) industry to get its act together. For thirty years there has been precious little new nuclear development of new U.S. nuclear application processes and thought. Yes, we have new LWR designs, but we're designing them like we did thirty years ago. And they really aren't new, they're evolutionary. Other than go to exhaustive extremes to prove the licensing cause under Part 52, precious little is new.

We need new thoughts, processes and challenges, and Chairman Jaczko must make that happen.

How we can boldly improve nuclear plant safety

June 26, 2009 rev June 14

Hon. Senator Thomas A. Carper, Chairman
Senate Environmental & Public Works Subcommittee on Clean Air & Nuclear Safety
United States Senate 513 Hart BuildingWashington, DC 20510

How we can boldly improve nuclear plant safety

Dear Senator Carper:

Removing nuclear plant safety concerns renews confidence in nuclear energy development. Improving nuclear plant safety requires reducing safety mistakes. Random safety errors like uncharged safety injection lines or reactor nozzle corrosion present near misses. Most nuclear safety errors randomly evolve from design process failures. Nuclear plant safety design anticipates all types of expected equipment degradation and provides the means to control their safety risks. Loss of safety design basis places errors deep into nuclear plant operational processes. Usually they only result in near misses. Rarely, something more happens than loss of defense-in-depth. Consequently, safety errors are unacceptable - particularly preventable ones. All non-random safety errors are preventable. Random factors should not determine nuclear safety when improved processes can entirely remove their threats. Most safety design losses come from failure to operationally integrate design. Aging equipment creates more safety design loss failure threats. Effective design basis integration preserves design-intended nuclear safety functions better - even with aging processes leading to equipment failure.

At Palo Verde, uncharged safety injection lines in both trains of the three units’ safety injection systems compromised capacity to supply emergency reactor cooling water. For a lengthy period, lost defense-in-depth substantially increased public safety risk. Though less risky (but more unnerving), Davis-Besse’s single reactor nozzle corrosion failure was another near miss. However, both presented the specter of direct nuclear fuel damage - a significant safety barrier loss. Direct fuel damage escalated into the calamity of an actual radiation release at Three Mile Island, creating the worst U.S commercial nuclear reactor accident. Persisting uncorrected for a lengthy period, in spite of multiple evident indications, uncharged safety injection was a “common-cause” failure - an especially insidious problem. Independently failing safety controls at Davis-Besse and Palo Verde reveal systemic industry problems - echoing Three Mile Island. Organizational behaviors powerfully influence common-cause failure risks. Training to improve nuclear safety awareness helps combat complacent cultures, but is not enough. Strengthening underlying safety processes provides additional needed assurance. Integrating safety design processes adds fundamental defense-in-depth. Integrating safety design with operations remains the most comprehensive way to improve error-prone nuclear safety.

Whether designing new plants or operating old ones, improving the design basis requires asking candidly how to correct the fundamental causes of design basis loss. Operating a three unit nuclear plant for many years with not just one but both safety trains inoperable in every unit does not generate public health and safety confidence. Flying in a commercial airliner with only one system to operate the plane controls, knowing all backup hydraulic controls were inoperable would also make the general public reluctant to fly - if in fact, they knew safety equipment was inoperable. People can personally assess flight risk from their own experience. After all, most of the general public flies today. However, few people today understand nuclear plants. They must trust others who do.

Commercial airline pilots cannot choose whether they do preflight instrument checks, leaving public flight safety to chance. Rules specify preflight system flight checks to assure safety performance. No plane leaves the ground with known, inoperable safety devices. However, commercial jet airliners integrate safety design into operations. Nuclear plants don’t. Discounting evident safety failures reveals safety weaknesses in the nuclear design process. While most of the time nuclear plants are safe, design basis integration would make them far safer. Ever so rarely, coincident multiple safety system failures randomly align, violating diversity, redundancy and principles of defense-in-depth. And once in a very great while, a nuclear accident happens. Overseas, in the military and at our National Labs nuclear accidents have killed people. Nuclear accidents can happen. Further reducing nuclear accident risk requires improving how we translate the underlying safety design basis into operational requirements. This requires integrating nuclear plant operations with plant nuclear safety design.

Nuclear safety performance improvement requires integrating the plant design basis. How can we justify not taking the next steps to further reduce nuclear safety risk? Three Mile Island, Chernobyl or the commercial airline industry have taught us nothing, if we have decided today that we are “safe enough.”

Sincerely,

J.K. August, PE / J.J. Hunter, SRO
CORE, Inc. 303-425-7408/970-330-1411

Terms: Design Basis (DB); Nuclear Safety Framework; Nuclear Safety Performance, Reliability Assurance Program (RAP); Systems Structures and Components (SSC), Component Part Aging; Next Generation Nuclear Plant NGNP; Failure; Failure Event; Failure Mechanism; Light-water Reactor (LWR); Actionable, Common-cause failure

Attachment: Strategic Nuclear Initiatives
Distribution:

US NRC
Gregory Jaczko (Chairman)
NRC Office of the Inspector General
Hubert Bell (Inspector General, US NRC)

Department of Energy
Steven Chu (Secretary, DOE)

House Committee on Energy and Commerce
Henry A. Waxman, CA, Chair
Subcommittee on Energy and Environment
Edward J. Markey, Chairman
Subcommittee on Energy and Air Quality
Rep. Perlmutter, CO Member

Senate Energy & Natural Resources CommitteeJeff Bingaman (Chairman)Lisa Murkowski (Ranking Member)

Senate Environment & Public Works Committee
Senator Barbara Boxer (Chair)
Senator George Inhofe (Ranking Member)
Matt Dempsey (Communications Director, Sen. James Inhofe Office)
Subcommittee on Clean Air and Nuclear Safety
Thomas R. Carper (Chairman)
Laura Haynes (Legislative Assistant, Senator Carper’s Office)
David Vitter (Ranking Member)
George V. Voinovich
Max Baucus
Benjamin L. Cardin
Bernard Sanders
Jeff Merkley
Christopher S. Bond
Annie Caputo, Senior Technical Staff

Government Accountability Office
Mark Gaffigan (Director, Natural Resources and Environment, GAO)

Nuclear Energy Institute
Marvin S. Fertel (President & Chief Nuclear Officer)

Institute of Nuclear Power Operations (INPO)
Jim Ellis (President & CEO)

Professional Engineering Societies & Consensus Standards Organizations
American Nuclear Society (ANS)
Jack Tuohy, Jr. (Executive Director, ANS)

American Society of Mechanical Engineers (ASME)
Kevin Ennis (Director Nuclear Codes and Standards, ASME)

Institute of Electrical and Electronic Engineers (IEEE)
John R. Vig (President and CEO, IEEE)



Industry
Westinghouse
Regis Matzie (Sr. Vice President/Chief Technical Officer)

General Electric (GE Hitachi Nuclear Energy)
Robert Brown (Senior Vice President, Regulatory Affairs GEH)

Areva NP
Tom Christopher (CEO & Vice-Chairman)

Mitsubishi Nuclear Energy Systems
Frank Gillespie (Senior Vice President, New Plant Technology, MHI)

Shaw
Steven Stamm (Vice President Business Development, Shaw)

Bechtel Power Corporation
Brian Reilly, Principal Vice President

Attachments sent to Senators/Representatives and others listed in red; letter only black.
For email or hardcopy copies of all materials, please send request via email with email address to:
jkaugust@msn.com
J.K. August
CORE, Inc.
P.O. Box 606
Arvada, CO 80001

Obama OK's Nuclear Power for Iran -- but rejects it in U. S.

Nuclear Power OK for Iran -- just keep it out of the U.S.

Obama said he "supported Iran's right to peaceful nuclear energy...." but worries about the same thing here in the U. S. (see previous post-- we promote wind and solar ) Perhaps the time has come to support nuclear power here in the U.S. too, if its so good for Iran (and Saudi Aradia, Egypt, the United Arab Emirates, Libya and Pakistan....) What gives, Mr. President?

Secretary Chu

Secretary Chu announced $2.4 billion in carbon capture research. Great, it'll keep the national labs going. When do we get down to actually doing something about energy? Apparently, when we get a new Energy Secretary. (The secretary appears to be unaware of Congressional direction under the 2010 plan of the amended EP Act of 2005, or chooses to ignore it.) The only way to make a dent in current carbon emissions is with current technology. That means nuclear.

Chairman Jaczko

Now that Obama’s confirmed Chairman Jaczko, we know that the NRC has a new titular head. Whether Chairman Jaczko leads, follows or continues to maintain that collegial body identified by the Kemeny Report will say more about future U.S. nuclear prospects than any press report. The U.S. nuclear industry is tired and stale, struggling to license passive safe designs. Meanwhile Japan, China, Korea, France, and even Taiwan race ahead, as we are left further behind. Mr. Jaczko could change that state of affairs, or merely sustain where we're at. In any event, stepping forward smartly to lead would take a new NRC hat. Is the U.S. NRC ready for the leadership that would put it on a new track? Standby folks, we’ll see, but don't hang onto your hat -- yet.

Nuclear Industry Leadership at the Crossroads

Nuclear Industry Leadership at the Crossroads
Thirty Years Avoiding Kemeny Report Three Mile Island Questions

After the Three Mile Island (TMI) at Unit 2 accident on March 28, 1979, President Carter launched an investigation. He chartered a commission to examine the accident’s causes and recommend changes. The Kemeny Commission delivered its report to the President October 30, 1979. Citing nuclear safety concerns with its recommendations, it created anger. The Kemeny Commission called for fundamental changes in the nuclear industry’s organization, procedures, and practices, and the even Nuclear Regulatory Commission (NRC):

“To prevent nuclear accidents… fundamental changes will be necessary.”

The Kemeny report questioned nuclear structure and staff accountability. It cited the need for technical qualifications, designing, building and operating nuclear power plants. While calling for changes, it said basic requirements must be unequivocal. It asked the nuclear industry to address the complexity, accountability and overconfidence in its approach to nuclear design and operations, and equipment obsolescence. It said that changes would threaten nuclear culture - forewarning their report would challenge the industry.

President Carter approved recommendations when he accepted the report. Some never acknowledged the critical content in the Kemeny report, so key recommendations remain. Others struggled with the findings, avoiding their call for change. Circumstances refocused guidance in the report; Ronald Reagan’s election in 1981 tabled recommendations. In 1982, two Kemeny associates accused the NRC of dragging its feet - ignoring critical elements that remained. Addressing the report was as threatening as the TMI accident. Burying it was easier than changing nuclear processes or culture. Thus, nuclear issues remain today. Since that time, the complexity cited in the report contributing to the accident has grown ever worse.

Problems remain in nuclear industry institutions and its framework. Complexity remains common. Regulations abound in non-actionable guidance. Nuclear costs remain high. Waiting for regulatory guidance and approval, the industry lacks technical innovations common in other industries, like digital controls and information automation. In the meantime, nuclear technology slipped into obsolescence. Obsolete controls developed decades ago remain in nuclear service. Industry awaits NRC direction to make changes, rather than initiate them on its own. Lack of initiative still demonstrates Kemeny Commission complacency documented in the report in 1979 - thirty years ago!

For forty years - virtually its entire existence - regulatory direction came from outside the industry. Most commissioners lack nuclear operating experience. Today government lab experience dominates commissioner backgrounds. Commissioners lack critical insights from within the industry. Lacking commercial operations perspective, their oversight is limited. Leadership lacks profound knowledge based on nuclear experience, insights by America’s foremost quality management expert, W. Edwards Deming, deemed critical.

New nuclear designs should not repeat the errors of the past - the same errors that caused TMI. Congress should help industry redefine unanswered questions. Then the nuclear industry, its trade organizations like the Nuclear Energy Institute or the Institute of Nuclear Power Operations - even the NRC - could finally resolve open nuclear problems. An ineffective framework won’t support new commercial nuclear plant designs effectively, much less new designs like the Next Generation Nuclear Plant (NGNP) - the new prototype plant Congress authorized. Intended to jump-start the hydrogen economy and help phase out carbon-based fuels, the NGNP will not be a success making the same evolutionary startup errors. We can’t afford the same cultural approach, chancing success by encouraging the same structural mindsets that gave us TMI.

The U.S. cannot prosper without nuclear power, so we must use all our experience to improve it. Rediscovering the Kemeny findings will not only continue to lower nuclear risks, but also benefit costs. Today - thirty years later - we should reevaluate the Kemeny Commission’s recommendations. We should finally address the structural nuclear issues that led Kemeny member Bruce Babbitt, Governor of Arizona, to conclude:

"There are still unresolved questions about what happened at Three Mile Island; … the institutional problems of the industry [must still be addressed]."

Congress should ask whether nuclear energy regulation can be more effective. “Is the framework today adequately safe and efficient?” “Can the NRC foster safer new nuclear technologies?” “Do regulatory bodies have a role restoring US nuclear energy leadership?” Or even, “Where does nuclear power technology need to be in the US today?” Congress should help resolve outstanding nuclear concerns. To fight complacency and allow safer, more effective nuclear energy growth, Congress must ask the nuclear industry’s leaders and regulators to address the issues. The industry must finally answer the Kemeny Commission. Only then can the highest-level safety, regulatory and cost-effectiveness concerns finally be laid to rest - along with the rest of TMI.

Thirty-years after Three Mile Island: Why the Kemeny Report is Still Important

Why the Kemeny Report is Still Important
Thirty-years after Three Mile Island, we still don’t understand it!

For the past thirty-years, there has been no nuclear construction in the U.S. Today we stand on the threshold of a nuclear renaissance. Before we resume where we paused thirty years ago, we should reexamine why construction halted – what were the problems? Why did the U.S. go into a commercial nuclear hiatus? Let’s look again at what happened.

In the early morning hours of March 28, 1979, in Middletown, Pennsylvania, a condensate pump tripped at a nuclear plant – a minor event. Moments later, other alarms began ringing, signifying the event’s escalation. An accident was starting to happen. Within several hours, the unthinkable had occurred – Three Mile Island’s (TMI) highly-radioactive nuclear reactor core had partially melted. Radioactive fission products were loose inside plant primary circuits, and no one knew what caused it. Within several hours, the operators declared a general plant emergency, putting the whole state on alert. Engineers, managers and regulators alike swarmed to the site’s control room to try to understand what happened. Frantically they sought to fix whatever was wrong, only no one knew what was wrong – only that fuel was failing. Critical core cooling was inadequate, releasing fission products into the primary coolant.

Several hours after the initial event, operators finally restored primary cooling, mitigating further core damage – the accident was over. However, by that time half of the core had melted! For the next several days, confusion, alarm and panic ebbed and flowed from the control room. The press sought to report what experts wouldn’t admit or didn’t understand. Once it was over, nuclear power had lost credibility and along with it, public support. TMI did not take a single life, despite its financial cost and mental stress. However, the public distrust left in its wake helped cancel or abandon sixty nuclear projects across dozens of states. By costing investors and the public billions of dollars, financial lenders imposed a virtual moratorium on nuclear power development.

Following the accident, President Jimmy Carter asked Dartmouth President John Kemeny to chair a commission to independently investigate TMI, its causes, participants, their effectiveness, and make recommendations. Twelve highly educated people neither for nor against nuclear power comprised the Kemeny Commission. They represented different interests assessing the industry from the outside. The Commission delivered its findings October 30, 1979 in the Kemeny Commission Report – an assessment of the events, causes and recommendations. The following week Time Magazine called the Commission’s report a “Scathing Look at Nuclear Safety.”

To prevent nuclear accidents as serious as Three Mile Island, fundamental changes will be necessary in the organization, procedures, and practices – and above all – in the attitudes of the NRC … and the nuclear industry.

Predictably, the report caused public controversy. The Kemeny Commission called for changes at the NRC, and in the nuclear industry itself. No utility would order new nuclear units in the U.S., and they would cancel 60 of the 165 units ordered.

So too, the Nuclear Regulatory Commission (NRC) initiated investigations. The NRC appointed a TMI Task Force, which developed specific recommendations “Lessons Learned”. It also hired an independent investigator, Rogovin, Stern & Huge, who reported their findings in the Rogovin Report. While NRC’s task force focused on events and their causes – equipment or process failures, it didn’t address organizations, institutional beliefs or structural problems. However, the Kemeny Report did.

For thirty years, the Kemeny Report has been silently on the shelf. We still don’t understand its basic issues, lessons, and recommended changes. Without understanding them, we can’t move forward confidently in a nuclear renaissance. Without confidence, people will question nuclear power and those who use it.

What did the Kemeny Report say, then? What were its conclusions and recommendations? Well, Kemeny found problems centered around fundamental principles, so the irony was problems were so common. Kemeny found weaknesses that were anything but new – many large organizations have them. However, nuclear energy’s higher risks gave its recommendations a greater urgency. Although the NRC and industry have addressed many recommendations, some remain. Of the forty-four basic recommendations cited by the President, five broad categories emerge:

• Technology arrogance
• Organizational culture
• Making requirements “actionable”
• Focus on the “Big Picture”
• Ability to learn

Let’s look at a few of these more deeply, relating them with the past.

Technology Arrogance

Complex processes and jargon that obfuscate are fundamental nuclear technology weaknesses. At TMI, engineering overconfidence ultimately led to lapses in design accountability. Preoccupation with complexity was common, lacking internal controls. Isolation lets nuclear experts think their understanding is complete, though it is not. Where ignorance leads to complacency, unquestioning mindsets undercut nuclear safety. The industry still lacks common standards and certifications for processes. Anyone can call himself a nuclear engineer, even those without credentials. Nuclear organizations give engineers without degrees or licenses titles. Unrestrained complexity continues to control nuclear processes today, as it did thirty years ago.

Organizational Culture

Not all organizations can apply nuclear power technology successfully. Some lack attributes necessary for nuclear safety, like objectivity or accountability. Kemeny cited NRC oversight for tolerating ineffective industry practices. People, skills, ability to examine technology objectively, sustain open-minded perspective and challenge assumptions all remain nuclear issues. The nuclear industry isolates people. The industry has been slow to accept superior technology like digital controls, rotary air compressors or computer-based design basis integration. These have been available for decades now, yet U.S nuclear power still doesn’t use them. U.S. nuclear power plants today are virtual museums of obsolete 1970’s processes and technology.


Making Requirements “Actionable”

Failure to recognize that a stuck-open power-operated relief valve would create a small line break “loss of coolant” accident epitomized failure to translate design basis accurately into operations. While any number of things -- inadequate reviews, operating requirements translation, inadequate testing – could have caused the TMI problems, the NRC cites similar near-miss close calls regularly. Events that recur over and over repeatedly have a systematic basis. However, NRC regulation eschews modern quality processes that identify, examine and correct systematic process weaknesses. Oversight bodies that reject the use of quality processes to get better practically block those it regulates from applying similar ideas. Converting nuclear plant designs into “actionable” operations tasks eclipses NRC experience – after all, it’s not an operating organization, unlike utilities or architect-engineers. By not understanding operating practices like how to develop and improve processes, NRC compromises the nuclear industry safety basis.

Focus on the Big Picture

Operating excellence takes follow-up on problems. Understanding overall requirements and how individual tasks contribute to overall requirements allows follow through. TMI allowed mindsets like, “Let someone else take care of it – it’ll be okay,” or “It couldn’t possibly happen to us – it never has before,” or “It’s too hard to change, with all the rules and procedures,” or “We meet NRC requirements already, that’s good enough.” Many other rationalizations met formal requirements in rules without understanding their basis. Kemeny said that’s what led to TMI’s operating weaknesses. Absence of effective measures to maintain defense-in-depth and the “people safety system” stemmed from failure to understand and focus on the big picture – overall requirements, on multiple levels. Accepting things as they are, excluding questioning attitudes exudes the very complacency TMI represents. Similar mindsets prevail in the nuclear industry today.


Ability to learn

Nuclear industry professionals and organizations couldn’t see ineffective processes, obsolete equipment or problems people had understanding nuclear technology. On the other hand, Kemeny members outside the system could. TMI lapses in understanding were evident to those who looked, but it took outsiders and a near-disaster to question practices that had long been taken for granted.

The nuclear industry today remains focused inward, just as Kemeny left it. It still can’t grasp lessons from the past or others, including its non-nuclear counterparts. It will not introduce new technology into its nuclear environment. Furthermore, intrinsic learning limits imposed by regulatory mindsets – avoiding new, different, or untested or untried methods from outside the industry – has left an industry replete with obsolete controls, equipment and – worst of all – mindsets. It struggles simply to replace obsolete equipment as time passes.

The Kemeny Report cites oversight for imposing barriers to finding and fixing problems. Focus on meeting the letter of the law, not its safety intent, led to weaknesses that eventually compromised the “safety system.” At TMI, people stopped actively thinking when they came to work. Nuclear mindsets today have hardly changed.

While the industry has addressed some Kemeny findings, others still remain. Alternatives can address a concern without using the recommended solution. For example, while the Kemeny Report suggested one NRC commissioner, President Carter left five, opting instead to strengthen the Chairman’s role. Otherwise, the President accepted all forty-four (44) Kemeny Commission recommendations. More urgently, we should ask: How did nuclear regulations get where they are today? Is the framework today adequate and effective? Can the NRC be effective fostering improved nuclear technologies? Can the NRC sustain the U.S. through the next nuclear design generation in its current form?

Kemeny wasn’t the first to question NRC effectiveness, and hearing concerns voiced in the Senate won’t be the last. Did the tradition of regulating the nuclear industry from the outside evolve just by accident? How can those unfamiliar with nuclear power operations ultimately serve the public’s health and safety interest?

Kemeny member Governor Bruce Babbitt's concluding remark echoes across three decades:

"While this [Kemeny] Commission has clearly addressed the institutional shortcomings of the NRC in its recommendations, it has not addressed the institutional problems of the industry."

Kemeny could identify critical problems, but others would need to address them. Critical questions remain, today. NRC’s added many complex new rules and requirements since TMI. Yet the complexity Kemeny found that contributed remains pervasive within the regulatory framework. Non-actionable guidance abounds. The Institute of Nuclear Power Operations (INPO) and Nuclear Energy Institute (NEI) have foregone their development roles to improve the framework, training or design basis methods, waiting for NRC guidance. Industry ignores technical developments from other industries, believing it can advance no further without NRC direction. Industry tolerates technical obsolescence – like forty-year old analog controls. Most disconcerting, industry awaits for NRC to direct changes, rather than initiate necessary changes on its own. Ironically, this lack of initiative was the very essence of complacency identified in the Kemeny Report.

An ineffective framework won’t support light water reactors effectively, much less new reactor designs using different technologies. Without changes, we can resign ourselves to repeating the same evolutionary learning mistakes in new designs as we made in the past – the very errors that created TMI. We can continue to tolerate near missies like Davis- Besse and Palo Verde, berating licensees all the while for their operational lapses. Meanwhile, design reliability assurance programs from nuclear suppliers are on hold. To sponsor ever-more complex technical requirements like PRA applications , we must balance that with implementation. We must carry requirements through rather than ignore them, hoping they happen like we did at TMI. Thirty years ago, the Kemeny Commission said the nuclear industry needed to address institutional problems. Isn’t it time we did? Either we use the Kemeny findings, abandon nuclear power – or place ourselves at risk for another accident like TMI.

Irony: Looking Back on Thirty Years: Senate Hearing on Nuclear Safety Complacency and Lessons Learned

April 3, 2009


Honorable Senator Thomas A. Carper
Chairman, Senate Environmental and Public Works Subcommittee on Clean Air and Nuclear Safety
United States Senate 513 Hart Building
Washington, DC 20510

Three Mile Island Looking Back on Thirty Years: Senate Hearing on Nuclear Safety Complacency and Lessons Learned
(Hearing March 24, 2009)
Senate Webcast: rtsp://video.webcastcenter.com/srs_g2/epw032409.rm?start=17:20

Dear Senator Carper:

March 28, 1979, undercooling damaged Three Mile Island Unit 2’s reactor. Events came to be known as “Three Mile Island,” or simply “TMI.” While the hearing’s general review of lessons learned and safety improvements since TMI was ad hoc, Senators asked several substantive new questions: “What do we still need to do to avoid nuclear safety complacency?” and, “Can we improve nuclear license process duration, maintaining safety? Must design reviews licensing new Light Water Reactors (LWR) plants take five years or longer to safely complete?”

The nuclear industry has been lethargic deploying current technology. Digital controls remain unapproved for nuclear use today. Slow progress approving digital controls demonstrates performance failure. When nonperformance becomes the norm, Senate oversight should challenge agencies to find better ways to get the job done.

In its commemorative hearing March 24, NRC failed to answer several substantial Senate’s Subcommittee questions. For example, whether new plant license reviews could be shortened while maintaining safety was not answered.

Interviewees failed to answer Senators’ questions completely. Some failed to address some questions at all. To avoid complacency, restore candor in nuclear dialogue and regain public confidence, we must demand, like Admiral Rickover -- “Answer the question, please!”[1]

As follow-up, the Senate EPW Clean Air & Nuclear Safety Subcommittee should ask the NRC's commissioners to:

• Defend current safety improvement processes.
• Review safety performance with continuous process improvement methods[2]
• Review the new licensing process implementation method for overall effectiveness
• Engage those able to independently assess nuclear performance using continuous improvement methods
• Establish a safety review licensing timeline based on substantial content milestones
• Pilot an NRC continuous improvement process like the US Department of Commerce Baldrige application, proven in use by other federal agencies .

Sincerely,

J.K. August, PE
J.J. Hunter SRO
CORE, Inc.
303-425-7408/970-330-1411
Attachment: Senate Response to Hearing Review
Re: EPW CA& NS Hearing Three Mile Island: Thirty years looking back

[1] Actually, it was -“Answer the question, dammit!” Evasive, incomplete or specious responses inflamed the Admiral, causing him to ask, “Do you really want this [nuclear] program?” He followed that shortly by shouting his legendary dismissal, “Get the h…out of my office, you horse’s ass…”
[2] The Armament Research, Development and Engineering Center, US Army Picatinny, NJ. (ARDEC) The “home of American firepower” won the US Department of Commerce Baldrige Award in 2007. "Lean 6-Sigma” is another process improvement approach approved by DOD. All have common elements.

When Incompetence Thundered

see By Michael Gerson Friday, March 20, 2009; Page A19 Washington Post:

AIG's November SEC filing set out its intention to provide more than $469 million in "retention payments" to employees, eliciting a smattering of congressional protest. Concerns on the broader compensation issue were serious enough to ensure unanimous Senate passage of an amendment to the stimulus bill sponsored by Sens. Olympia Snowe and Ron Wyden that penalized bailout bonuses in excess of $100,000.

But the Snowe-Wyden amendment disappeared into the misty bog of a House-Senate conference committee, only to be trumped by grandfathered language in AIG's retention bonuses. At first, this example of immaculate legislation -- miraculously fatherless seemed virtually spontaneous. Only after explicitly denying responsibility did Senate Banking Committee Chairman Christopher Dodd eventually admit to including the exception under administration pressure. But it doesn't sound like there was much of a fight. Administration input came from unnamed Treasury Department staffers, not high-level officials. Dodd said he viewed these as "innocent modifications."

The lack of focus, judgment and competence on the part of Congress and the administration has its explanations. But for those dealing in trillions, millions are like dirty pennies on the street. Hollow outrage and blame-shifting from Congress and the administration to the people is inexcusable, however.

"This is an example," thunders Rep. Barney Frank, "of people at the commanding heights of the economy misbehaving, abusing the system" -- which is completely true . . . of the conference committee that reshaped the stimulus bill in secret. Sen. Charles Grassley urged AIG executives to contemplate suicide. This combination of viciousness, shamelessness and cluelessness has consequences. It drains what little political will remains to confront the credit crisis -- an effort that may eventually require spending a trillion dollars or more to help purchase toxic debt. Thanks to AIG, Congress and the administration, Treasury Secretary Timothy Geithner may find his next round of necessary bailouts greeted by a revolt of left and right.

http://www.washingtonpost.com/wp-dyn/content/article/2009/03/19/AR2009031903039.html?wpisrc=newsletter&wpisrc=newsletter

So what else should we expect from Washington? Keep up the pressure, and force them to perform. Each and every one! The same lack of accountability can be seen in other places, where staffers make decisions and then decide to duck. Want me to start my list? I would start with some Commissioners and their managers at an agency, who avoid looking into problems that are readily corrected now, but fester as they go on....and on and on.

Ironic Twist: Obama Supports Irans Nuclear Programs while shutting down those in the U.S.!

re: PRI.ORG Britain supports civil nuclear program for Iran
UK Prime Minister Gordon Brown says all countries, even Iran, have the right to nuclear power, and his country would help Iran achieve it.
PRI - http://www.pri.org/

While the Obama Administration does all that it can to end commericial U.S. nuclear programs, it supports the commercial development of nuclear power in Iran. Is there something here I don't get? If it's good for Iran -- one of the world's leading oil suppliers, why isn't it even better for the U.S.?

Obviously there's a lot here I don't get. (Or maybe I do!)

Is GE the next AIG?

Will the NRC license new nuclear plants quickly, or let them go down tomorrow? Questioned whether the NRC would consider using statistical methods and the latest software to decrease new plant licensing time from four to one years, at the Regulatory Information Conference March 9-11 the NRC responded they would not. They considered using tools like Statistical Process Controls. They decided statistical methods did not help speed up new plant licensing processes.

Thus, timelines to license GE's new passive-safe nuclear plant design – the ESBWR, will not turn around soon enough to benefit GE's short-term financial condition, given the problems at GE Capital (finance). Had there been more prospects for improving GE, value licensing with nuclear plant ESBWR prospects would have increased for GE.

Losing $400 Billion in capital in the past two years, could a GE meltdown be next? Would Congress bail out GE if that happened? Their heavy metals group, (Energy) GE Nuclear, Aviation, Transportation, Oil & Gas, Water & Process Technologies, have significant value showing, yet even now. That value drops so long as their financial group continues to drag them down. Lengthy licensing processes at NRC don’t help.

Is GE the next AIG? Will Congress let GE spin off its remaining viable businesses -- heavy metals, or let them go down with the rest? If so, what happens to GE Nuclear, and it's twenty-year long effort to license passive safe nuclear designs.

Regulatory Information Conference (the "RIC")

We had a great time at the RIC, largely thanks to entertainment provided by Don Hofmann and a great speeches from Commissioner Svenicki, as well as her peers. Aside from the Commisssioners, who previewed the new order, Nuclear Energy outlook was surprisingly upbeat. Even if we got "nada" (nothing) from the new administration in stimulus funding, this it turns out, was our own making; we forgot to ask for money or show we had shovel-ready projects, even though we did.

Aside from the honorable commissioners, Jason Grumet, of the Bipartisan Policy Center, suggested we push Carbon issues and global warming to help build a new consensus for nuclear energy use. He believed this was critical to help overcome opposition to nuclear energy use from those who oppose it on environmental grounds -- like waste. Environmental awareness developed in the early 1970's, followed by the Three Mile Island, helped cement opposition to new nuclear power consideration in the US for forty years.

Congress, help the Country - Enlist Nuclear Energy!

Congress, help the Country - Enlist Nuclear Energy!

In its 2009 stimulus package, Congress ignored nuclear power. While possibly by oversight, or a gaff, or erroneous miscalculation, the conclusion is unmistakable. While other Congresses approved nuclear energy initiatives, the 2011th Congress overlooked nuclear potential - an unfortunate occurrence. To enlist other appealing technologies to fight carbon emissions, ignoring clean, nuclear contributions would be a tragedy. For energy success, Congress must recognize the energy champion before them, and place it on their agenda.

Reasons why Congress barred nuclear power from stimulus…

While Congress provided $5 billion directly for energy stimulus and with another $15 billion for new technology development each year, they failed to enlist the country’s proven non-carbon energy resource to combat carbon emissions. Could the nuclear energy solution be too simple to accept? While we could speculate forever, nuclear opponents shared reasons to bar nuclear energy stimulus participation. While we hear their concerns, we can’t accept their positions entirely. The common ones listed below deserve careful consideration.

1. Yucca Mountain: An unnecessary struggle fraught with difficulty, we should abandon and forget Yucca Mountain. Other methods available manage nuclear waste far better.
2. Nuclear Waste: Presented as an intractable problem for forty years, now we see every energy form has a footprint. Shouldn’t we ask, which is most economic, environmentally friendly and politically acceptable? Can’t we be creative?
3. Nuclear Plant Safety: In November 2007, Vermont constituents made nuclear safety their primary concern - after all, no one wants nuclear plants “that might blow up.” We need safer nuclear plant designs, or at least someone who can explain how they work - why nuclear plants can’t blow up - just like that!
4. Lengthy reviews: As critics point out, the track record licensing nuclear plants is very slow (8 years, average). Yucca Mountain (31-years) only expanded that fear.
5. High, unpredictable costs: Dissenters point out that nuclear construction, unlike solar or wind, takes forever. Never complete, it creates high, unpredictable costs. For anyone on a budget - as energy projects must be - that is not reasonable.
6. Consistency: The U.S. licenses many designs, of multiple vintages and types. U.S. regulatory interpretation varies for plants of the exact same type licensed historically in the U.S. Someone should ask who figured out this mess? “My three-year old daughter’s drawings make more sense,” said one critic. Critics seek regulatory and plant design consistency, unlike they remember in the past.
7. Trust: Although nuclear performance has been fair lately, only thirty years ago, industry spit up a problem - Three Mile Island. Local pundits said, “You promised us you wouldn’t do that. Gee, thanks, pal (tongue in cheek).”
8. Footprint: Okay, so nuclear energy has a no carbon footprint - big deal! Who cares if you still have to deal with radiation? After all, an event like Chernobyl could still kill you. You cannot trust nuclear operators or regulators to not act stupid - anywhere on earth. You hear that in the news, day in and out.
9. Endorsement: Nuclear engineers disclaim all that they do - how can you trust them to do anything right? Otherwise, wouldn’t they stand behind their design products? Instead, they act like weenies. Why can’t they just promise safe economic power?

Solutions for Congress

1. Abandon Yucca Mountain - it’s become a symbolic struggle. As candidate, Obama ruled out Yucca Mountain “because it was built on a fault line, shoved down the throats of the people of Nevada, [and] it was impossible to get done.” Otherwise, superior methods are available. Shutting down Yucca definitively tomorrow frees up billions of dollars to spend on a permanent solution - not waste in Nevada.
2. Nuclear waste has a simple solution. France has a reprocessing plant in LeHarve. They will take our high-level waste, reprocess it, and sell it (the fuel) back to us, vitrifying waste residue ending our nightmares. That solves our problem, once and for all. We get encapsulated residue, rendered harmless for eternity, new nuclear fuel to reuse in our reactors, or even theirs. All save millions of tons CO2 added to the environment year-by-year, pound-for-pound. (Ninety percent of France’s electricity comes from 59 reactors, initially designed here in the U.S. - surprise!!!) We only need the money to pay them, which shutting down Yucca Mountain makes available.
3. Improve Nuclear Safety Design. “There’s nothing we don’t like about nuclear power... just that it might blow up, kill us and radiate us - that’s the problem.” (Vermont, October 27, 2007 to Guy MacMillan) We must continue to improve nuclear plant safety designs to alleviate our President’s fears. We must also persuade hypochondriacs that nuclear plants won’t blow up, kill or radiate them, because they can’t. Because we designed and built them that way, just as Congress asked and regulated. They are not like the bombs the President described. Then more safe nuclear energy could help address global warming, economically.
4. Streamline Reviews. “The NRC is a moribund agency that has become a captive of the industry that it regulates and needs to be revamped… More broadly, the NRC is similar to the EPA, FCC, and FDA …. We’ve got a whole bunch of federal agencies … filled with cronies who lost their mission.” (October, 2007) We can improve slow nuclear plant licensing, compared with France, Japan or Taiwan. Sadly, our Finnish cousins suffer the same nuclear disease we had: interminable delays; ponderous design changes; unaccountable project management…and an open national pocketbook, regardless of safety benefits or the cost. Yep, even the U.S., which invented the infinite loop nuclear plant review cycle, saw analysis-paralysis alive and well in Finland at TVO’s Olkiluoto Plant. Yucca Mountain, déjà vu! “I want to make government ‘cool again’ - which I say partly tongue in cheek. I want to make them lean mean, make them work… [I want to] weed our bureaucracies that are bloated … not performing a useful function. Let’s restore the sense that government can get things done.” If Congress asks nuclear agencies to improve their processes they will - but not until then. Let’s show the President what we can do! Let’s meet his challenge - after all, didn’t we go to the moon? Could this be as hard as that?
5. Lower nuclear costs. Not constructed right, nuclear plants create unpredictable costs. Nuclear plants can’t be thrown up (or torn down) overnight. While we offer no excuse for past performance, we think we’ve put that behind us. We’ve learned many lessons for first of a kind plants, custom installations, design-build-license fast-track construction (versus turnkey design-license-build) from forty-years of nuclear experience under our belts. While an ungainly framework supports new plant construction, we can still make Part 52 overlapping rules work. We need political, financial and energy consensus before we start. We should not suffer blockers for approved safe, certified-design projects using the highest quality people and materials building the best available technologies. We will apply the best available new technology, even distributed controls, databases and other technology that apply.
6. Assure consistent processes. Multiple designs created a U.S. nuclear quagmire. Furthermore, each plant started from an independent license source. Regulations and interpretations for the same vintage and type of plant reflect historical U.S practice. Although Technical Specifications remain exceptions standardized in the 1980’s, most other plant aspects - operating procedures, scheduled maintenance plans, monitoring, safety significant equipment lists, probabilistic risk assessments, training… - remain custom. Systematic process simplification for consistency would require mapping the entire regulatory framework logically - something those familiar with existing regulations are loath to do. Like English measures, users familiar with English units never want to accept Metric alternatives. Although more consistent regulations would benefit new plants, those familiar with the current framework say it works acceptably - regardless how well. They seek to retain traditional methods.
7. Build trust. Thirty years ago saying, “Trust us,” industry spewed forth Three Mile Island. After that came Chernobyl. Then nuclear experts equivocated. Engineers said these improbable events were inevitable, just like a global tsunami. To regain trust engineers need standard, durable designs. They also need better processes, and people who operate designs inside well-defined intended limits. Trust requires simple transparent terms and processes. Engineers must share their work clearly to gain trust, not talk down obfuscating safety issues. They must clarify abstract ideas until the public grasps them. Finally, they must appreciate that trust isn’t bought or traded - it’s earned. Only consistently getting better earns public respect. We must also learn that trust includes cutting waste to lower costs.
8. Clarify footprint. “I [am] agnostic on nuclear power. I’m not saying it’s off the table - there is no perfect source. If we can make it safe, store it safely, it’s not vulnerable to terrorist attack, and we can control proliferation, nuclear power should be in the mix. [There are] a whole set of questions, but if they’re not solvable - I just don t want it. There’s nothing (inevitably) that we don’t like about nuclear power... just the fact that it might blow up, kill us and radiate us - that’s the problem.” Reactors inevitably will have limits, though new passive-safe LWR designs are safer than ever before. New helium-cooled reactors are even safer still; they can’t melt down, even externally dismembered. That the worst scenario, Chernobyl, could still kill you - is even far more remote. The greenest reactors leave little fission residue, not creating but retaining wastes better than ever before. Even in extreme accidents, they hold fission products unlike Navy reactors ever could. Failure testing demonstrates these reactors outperform their predecessors in crises, better than ever before. Like other technology, with experience and time, engineers refine designs to remove safety problems and risk. We seek to develop reactors that owners, their operators or regulatory authorities don’t need fret over. They do what’s right, naturally. These avoid the stupidest errors, because they’re simple by design - everywhere. We can make new reactors “passively safe,” as never before - more resilient to human conditions, operator errors and even terrorists like never before. While we cannot promise perfection, performance will be much better than ever. We provide better clean, low-risk power today than virtually any conventional power plant, 10,000 reactor-operating years of experience later.
9. Seek public endorsement. Nuclear designers and operators seek perfection in everything. The sophisticated codes they write project nuclear performance very well. Compared to other predictions, theirs are far more accurate. People in professional organizations like the ANS, IEEE, ASME, and ACHE wrote the standards, developed these codes and advanced nuclear technology to the position it holds today. Steady advances in countries like France, Japan or Korea provide a high fraction of energy from nuclear sources, securing its global position. Increasingly, environmental advocates praise it. Even former Greenpeace leader and founder Patrick Moore remade his commitment to the environment based upon nuclear energy. Responsibly factoring people’s need to grow food, make products or help their economy into account shares the best of both worlds - clean, reliable energy, and the freedom to use it, without the burden worrying that we’re damaging our planet. Though nuclear is not perfect, its problems are far easier (and less costly) to manage than other solutions people propose.

America’s Energy Policy Challenge
Evaluate energy from a common framework foundation

Congress must consider all energy options for value contributing to energy needs. We must evaluate sources as varied as those harkening back to sources powered by the wind to current cutting-edge options, including nuclear and clean coal. The fickle nature of wind or cloud cover incurs costs for availability like those faced by sailing ships of yore. Recovering investment for infrastructure is just that much larger, depending on multiplier. However, we must spend our funds diligently so Americans get the best deal possible for their precious tax funds.

1. Set electric infrastructure availability goals of 5% GDP growth/year (90%). Rank public energy for financial tax aid support by cost measures, based on contributions.
2. Increase public awareness of practical generation limits and costs. Amortize generation costs projections uniformly, based on availability, connection, utilization and cost. Gain acceptance for fact-based energy investments, driven by investment recovery on state of the art systems.
3. Decrease regulatory burden using non-carbon energy forms by 80%. Set national goal to increase non-carbon energy use 80% by 2060 to reduce CO2 emissions
4. Drop construction costs to $5 billion for a 1000 MWe reference light water reactor (LWR)
5. Guarantee non-carbon energy loans while other goals are achieved ($1600/kw -- $7500/kw, based on wind/solar – up to $5 billion/unit)
6. Overhaul regulatory framework to make nuclear safety more cost-effective. Authorize nuclear regulation’s cost-effectiveness role in Atomic Energy Acts of 1954 and 1974, creating commercial nuclear power and the NRC.
7. Construct new nuclear plants in 5 years or less under with current licensing methods - just as constructors do in China and Japan. Have100 new nuclear units operating by 2025, reducing oil dependence 25% from current levels.
8. Assess process improvements for nuclear design and regulation using the Commerce Department’s Baldrige Award Process. Establish customers and performance targets for energy development and regulatory control at agencies, like DOE, NRC, and EPA. Return design preeminence to the U.S. energy industry, like it was in 1954. Establish new nuclear MHR, LMBR designs that can support the hydrogen economy. Reduce solar and wind energy system costs to 50% of current levels for construction.
9. Make private financial support viable by reducing regulatory uncertainty and delays. Provide nuclear equity subsidies equivalent to those of other forms alternative energy forms. Close energy cycles economically - solar, wind, water and nuclear.
10. Provide long-term nuclear waste solutions: sell it to France (for reprocessing), provide permanent onsite storage, place it in Yucca Mountain while developing a national nuclear reprocessing facility. (France has one already.) Have a viable fuel reprocessing solution approved no later than 2015 as a national goal.


Nations with strong active nuclear programs include:

Japan
Korea
Taiwan
France
Spain
Finland
Russia

Many nations are reconsidering nuclear energy in their national energy portfolios, returning to the nuclear option based on low carbon emissions, “passive-safe” low-risk design and energy independence. These include:

Sweden
Italy
UK
Canada
India
China
U.S.
Czech Republic
Slovakia
Hungary
Romania
Bulgaria

Years without construction inflated US nuclear power generation costs with obsolete equipment and designs. Compared with state of the art equipment in China, France, or Japan US nuclear plant designs offer no digital controls. Regulatory approval is pending with completion projected for new nuclear construction, about 2015.

If stimulus options for renewable non-carbon energy don’t consider nuclear energy, who excluded its authorization, and what were their goals? Why doesn’t nuclear get factored into America’s future energy mixture with the same considerations as other stimulus? America’s best option for energy independence is nuclear technology developed right here at home? Nuclear power remains a viable option to reduce carbon emissions significantly, at low overall cost.

Total ownership costs of various generation forms and their energy. Spreadsheet cost/utility factors comparison.

Strategic Plan Input Strategic or Not?

Upon invitation by the US NRC to comment on their stratgic plan last year, we submitted a thoughtful input. Much to our chagrin, the NRC discounted it. It was not strategic, so they left it out. All of it. Readers, please decide for yourself:



Draft 2007-12 Strategic Plan: Public Comment

Re: The NRC encourages all interested parties to comment on the draft Strategic Plan. The comment period ends September 7, 2007. Comments on the draft plan are to be submitted in electronic format (Microsoft Word) using e-mail to: StratPlan@nrc.gov or mailed to Chief, Rules and Directives Branch, mail Stop T6-D59, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; or faxed to: Chief, Rules and Directives Branch at (301) 415-5144

Ref: Submittal Comments August 14, 2007



Summary:

Nuclear regulation should take advantage of new technologies – including information management – to improve productively, safety and realize other benefits. The strategic plan should boldly capture the highest aspirations of the nuclear industry to better realize its intrinsic strengths – safety, technology and people. Advancing a risk-informed, performance-based regulatory framework should support the nuclear industry with new initiatives that develop actionable, risk-informed, performance based operations. The industry should address historical weaknesses – undue dependence on traditional hardcopy paper, complexity, slowness to embrace proven technologies, and licensees who seek NRC direction before attempting low risk innovations or other beneficial improvements. The nuclear industry should strive to find a legitimate home for cost consideration in the risk-informed framework, so that end-users – the public – realize maximum benefits from new nuclear technology and regulation.


Dear reviewer:

Please consider the following summarized strategic plan recommendations. Their intent is to increase NRC’s strategic plan clarity, and directly improve the safety and economic viability of the next generation of new nuclear plants. Blue italics identify source document reference excerpts.

In the next five years, the Nation is likely to see the following changes occur:

Data management capabilities and relational data model understanding will improve as relational database technology and paper documentation systems migrate into data-centric formats, modes and software methods to replace paper. Practically, it will become more difficult to maintain large plant design bases without comprehensive, relational electronic media like computer-networked file server databases.
Basis: Advances in relational database technology and design, combined with file server networks have made traditional paper-based systems obsolete. Continued paper-based systems use as a primary source of data will lead to data errors with potentially serious safety consequences.

Changes in the regulatory environment also require that the agency's human capital planning includes provisions for knowledge management (capture, documentation and transfer),…

With the same labor market pool, labor productivity will be critical. There will be less available labor to waste on inefficient processes or design models.
Safety Goal Strategies

1. Develop, maintain, and implement licensing and regulatory programs for reactors, fuel facilities, materials users, spent fuel management, uranium recovery, decommissioning and waste-related activities to ensure the protection of public health, safety, and the environment.
Reactors regulatory programs will require more efficient use of resources to improve programs with fewer available personnel. Reactor regulatory program development should strive to simplify, clarify and streamline complex programs like those for Appendix B deterministic licensing SSC treatment requirements.
2. Prepare for and manage the review of applications for new power reactors while continuing to ensure the safe operation of existing plants.
New power reactor licensing needs to become more comprehensive and faster at the same time. Methods like standardization and repetitive work use will need to do more with less. Lessons learned from new interest areas like new reactor licensing should be used to improve existing fleet programs.
5. Use sound science and state-of-the-art methods to establish risk-informed and, where appropriate, performance-based regulations.
Assist licensees develop simple actionable methods that implement risk-informed, performance based regulations.
Using other similar consensus process standards, like the FAA-endorsed Air Transport Associations (ATA)’s MSG-3, Operator/Manufacturer Scheduled Maintenance Development, and industry experience, NRC should attempt to extend and simplify current regulations. The MSG-3 significance is providing FAA-endorsed consensus, actionable guidance to implement risk-based maintenance plan development for the airline industry.
8. Oversee licensee safety performance through inspections, investigations, enforcement, and performance assessment activities.

Use oversight operations to assist licensees develop better, more actionable risk-informed methods.
Basis: Current guidance is very confusing and complex for licensees. Ideally, risk-informed methods should translate into transparent actionable methods that licensee personnel can use to implement risk-informed regulations.

Means to Support Safety Strategies
Use sound science and state-of-the-art methods to establish risk-informed and, where appropriate, performance-based regulations.
NRC policy should investigate and apply similar programs in other high-risk, regulated industries and the most advanced technologies available, where they have already been developed and are shown to be effective.
Developing better regulatory risk structures to access and compare risk-informed equipment classifications, and relate those back to design would more-openly identify concerns that could pose safety risk. Portraying these in objective risk formats (“will cause xxx.yyy% increase…”) versus speculative format (“might cause”, or “could cause” …) should become a licensee communications operational goal.
Risk-informed regulatory approaches lack the simple safety-related/non safety related dichotomy of traditional deterministic licensing. To complete SSC classification, other organizations (NEI, INPO, ASME…).have attempted to fill gaps left when rules like 50.69, 50.65, or even traditional Part 50 Appendix A & B exclude the discussion of balance of plant equipment in risk considerations. INPO created critical equipment attempting to fill that gap. The Maintenance Rule applies risk to equipment lacking direct single failure safety threat in recognition of multiple failure event possibility. The upshot is SSC classification schemes that elevate much equipment into safety-related (or safety-significant) SSC classification on the basis of multiple failures. For traditionally non-safety related equipment, this places more equipment under the Maintenance Rule coverage, on the basis it could change the Power Output schedule planned for the facility in multiple failures. For procurements, this increases the number of SSC that must meet full 10CFR50 A&B requirements under old licensing. While the availability of a full-scope PRA corrects this situation, it only applies for new construction (which must have full PRA). Even new plant, full-scope PRAs rarely go below the SSC level into subassembly part internal failure events. Without part level PRA, all-encompassing, pervasive new plant SSC procurements prospects under Part 50 Appendix A & B (now Part 52) are very real. New plant procurements could become prohibitively expensive like the operating fleet’s. NRC should look at other risk management frameworks, like those developed by the ATA[1] and endorsed by FAA[2] (MSG-3(4), “Scheduled Maintenance Development”) to see what lessons learned could transfer to simplify nuclear risk management SSC categorization and treatments. Highly-redundant safety-critical applications need simple actionable guidance to categorize SSC and select special treatments. NRC should identify a framework whereby the new plant license holder can develop SSC internal event failure-mode identification to select special treatments, and confirm that this reduces simply to dedication practice – like that called for by 50.69, the IDP (Independent Decisions Panels). Finally, NRC should create a comprehensive list of SSC special treatments by type, placed in one location, for reference by designers and operator-maintainers so that they may readily assess SSC special treatment requirements available quickly based on safety classification.
At least three equipment risk categorizaton schemes compete with each other. Through consensus groups, NRC should encourage industry identifying a common schema that could be used simply, in conjunction with single point failure, to uniformly classify SSC safety risk. NRC should encourage the use of simple data structures that incorporate standardization into readily retrievable, consolidated formats. They should reduce SSC safety categorization (re)interpretation, while assessing safety function consequences to the lowest part subassembly level. Currently, Part 50 “dedication” process requires these steps. To improve consistency, operationalizing methods should be a practical implementation goal. Completed analysis should be retained in retrievable format for consistent reference.
Review licensing requests (e.g., new applications, amendments, renewals, decommissioning, termination) to confirm that they provide an adequate margin of safety and are consistent with regulatory requirements, and conduct environmental reviews, as appropriate, to ensure actions comply with the National Environmental Policy Act of 1970. [Supports Strategies 1 and 2]
Implement, review, and refine the Reactor Oversight Process,...
Maintain an environment in which safety issues and differing views can be openly identified without fear of retaliation. [Supports Strategies 1, 3, and 5]
NRC should encourage third party perspectives sharing licensee performance information. Contractors offer many insights into standard industry practices and specific licensee performance and practices. Soliciting candid opinions from contract organizations about license performance would also improve balance in licensee-subcontractor relationships, thereby encouraging more openness from contractors who may have performance concerns.

Timeliness: NRC decision making process is well reasoned, justified, and decisions are made in a timely fashion to ensure safety and security.
Making information that supports decision-making more centrally available and accessible should improve access to critical information improving time to develop derivative information. NRC may want to consider closing the regulatory loop for those submitting recommendations or changes to rules, policies and procedures. Currently suggestions generally receive no feedback response to submitters’.
Operational Excellence Strategies

4. Conduct the NRC's information technology and information management activities to improve the productivity, effectiveness and efficiency of agency programs and operations, and enhance the utility and accessibility of information for all users inside and outside the agency.

Advanced technologies that offer tested improvement to nuclear generation should be evaluated for transfer to stem obsolescence caused by regulatory inertia. Specifically, licensees are reluctant to try any new technology until they’ve been give NRC’s green light. Thus many effective technologies like distributed control systems, or centrifugal or rotary air compressors that offer substantial improvements over their nuclear equivalents, remain to see widespread application in nuclear industry. For data management, licensees remain committed to text document systems for critical attribute data management at a time when other industries and agencies have started migration to more advanced relational structures. NRC should encourage licensees to take measured risks in non-safety areas to develop technologies that promise to improve long term nuclear safety. Information access today is largely through document titles and PDF files. Critical attributes should be mapped to a common data structure to speed and integrate the access and logical organization of design data by plant type.
Methods that implement risk-informed guidance such as 50.69 SSC, Risk-informed Categorization and Treatment of SSC, should be made more actionable by relating new risk-informed methods with historical deterministic guidelines ones. Some practices will remain essentially deterministic at their final implementation. In some cases, risk-informed implementation method (e.g., actionable method) remains yet to develop. Others have deterministic final steps. For example, the dedication procurement of subassembly parts under 10CFR50 A&B, “dedication,” historically used a deterministic interpretation of the FSAR DBA safety events to identify (“dedicate”) parts requirements subject to 10CFR50 A&B rules. This process will still to apply under 10CFR50.69; new plant designs will have to dedicate all parts below the SSC level of the most detailed PRA – or procure entire SSC generally to the same all encompassing 10CFR50 requirements across the board. The latter choice leaves the dedication decision process for the successful supplier bidder who accepts the procurement requisition specification, and gets a Purchase Order. In each case, detailed PRA can develop parts safety requirements to the component subassembly level, removing this need and specification development requirement. NRC processes should identify actionable methods that identify how licensees and/or their suppliers should comply with complex requirements – simply. In every case, both should take full advantage of the efficiencies offered by retaining completed analysis retrievably for future access and reuse on later work.
Standardization of designs should be considered for processes and information used in the nuclear industry. Operating experience remains highly dependent on source submitters, and is not available to the general public since the Institute of Nuclear Power Operations maintains the information. Industry failure data should be as available as NRC generic communications reports.

5. Use innovative strategies to recruit, develop, and retain diverse employees, and increase the diversity of employees in senior and managerial positions to achieve a high quality, diverse work force.
So called Generation-X employees will expect more hot-linked and relationally tied information management tools that are more like advanced server applications on the web. The lack of new data management structures and continued dependence on documentation in PDF or other hardcopy files will place more workers in obsolete information management environments. This will place NRC at a disadvantage from an employee retention perspective. Furthermore, the nuclear industry follows NRC lead in information management practices. Industry organizations like NIRMA (Nuclear Information Records Management Association) remain firmly implanted in the use of microfiche and other obsolete technology in large part because of the continued nuclear operation organizations dependence on hard copy documentation. NRC should lead the way to develop better information structures because of its position in nuclear technology management.
NRC should encourage industry along the same path by creating innovative method to accomplish the same ends as formerly done by rote “nuking it out” methods. NRC should encourage more industry innovation to maintain a diverse, creative workforce. NRC might want to consider exchange programs with other highly-technical, high risk regulatory agencies like DOE, DOD FAA, and FDA to share experiences and perspectives managing public risk.

7. Sustain a learning environment that provides continuing improvement in performance through knowledge management, performance feedback, training, coaching and mentoring.

Knowledge management will be the most pressing developmental area the NRC faces with resumption of reactor design, licensing and construction and the absence of substantial changes in the processes used to accomplish these activities since the last generation of power plants was constructed. Although Engineering CAD (Computer Aided Design) systems have gained tremendous power in the past two decades, their use ends at the development of designs. They don’t allow only limited integration with the other structures on which they depend, like safety rules (10CFR50 A & B, for example). They neither allow operating entities economies of scale nor improved safety by integrating derivative systems like procurement specifications (which are based on high level design requirements’ SSC components), scheduled maintenance and operations monitoring treatments, and tag out configuration controls. The lack of design basis integration is the single most critical nuclear plant design challenge today. Since TMI there has been a continued, regular occurrence of nuclear plants unintentionally operating outside their design basis (in ignorance) that can only be attributed to the complexities and finer nuances of nuclear plant configuration management. Data duplication and complexity tracing back to the design basis should be simplified to avoid loss of critical operating information.

9. Provide accurate, timely, and useful financial information to agency managers for effective decision-making.

While licensee financial controls are outside the direct purview of the NRC, continuing on a deregulation path, even if limited, operating nuclear plant’s financial health needs to be assured. Under-funding nuclear plants could affect safety. To assure cost effectiveness and safety, NRC should encourage licensees to measure plant SSC level expenses, performance-basing all their financial cost-benefit metrics. This would assure plant expenses (or lack thereof) are measurable at system, train and even SSC level in meaningful ways to benchmark with comparable units and others. In short, in a competitive market NRC should encourage licensees to maintain the financial cost-benefit metrics that justify – and compare – all performance expenses.

Selected Activities to Support Operational Excellence
Information Technology/Information Management

· Improve information management processes, such as information dissemination and knowledge management. [Supports Strategies 3 and 4]

Standard plant designs selection should be complemented with the development of a standard licensing framework structured around networked, server-based relational data. The licensing of the design under the Combined Operating License could then be measured for degree of compliance to a standard, be it a Westinghouse AP-1000, GE ESBWR or other standard design approved under Part 52 with a Design Control Document. This would facilitate the simplification and standardization of reporting under 50.65, the maintenance rule, which is a significant nuclear plant/NRC staff manual personnel burden. A standard design and format would facilitate automated data input of maintenance preventable function failures and system availability to assess performance.

· Improve internal and external electronic information access and delivery systems. [Supports Strategies 3 and 4]

The integration of the critical attributes from fundamental licensing documents into a relationally linked form would provide the framework under which all information could be more readily accessed and used without the extensive experience requirements that new younger employees will lack. This will improve regulation and safety, while allowing more effective use of resources.

· Systematically evaluate, improve, integrate, and automate selected regulatory and support processes from beginning to end, considering the needs of all process participants and using the most effective redesign approaches and technologies. [Supports Strategies 3 and 4]

New plant licensing should attempt to provide an integral framework on a per unit design basis that allows integration of all regulatory processes from beginning to end. This should anticipate aligning all design basis maintenance activities from beginning to end, from the initiation of design under the top level regulatory criteria to the final release of the site for unrestricted use after decommissioning, many years later. In between, it should cover all design updates, revisions to rules, codes and standards, equipment replacements, operating experience, and other requirements needed to both maintain the design basis and automatically generate all operating treatments – operating procedures, tag-outs, procurement specifications, scheduled maintenance requirements, SSC risk classification, and other critical operating information based upon critical design attributes that are relationally linked.

· Apply information technology/information management (IT/IM) to meet high-priority business needs (e.g., new reactors, fuel cycle facilities, the high-level waste repository proceeding, homeland security). [Supports Strategies 3 and 4]

Automating the design cycle will improve not only licensee, but NRC regulatory and business needs for those programs deemed priorities by Congress and the President.

· Seek common solutions, reduce duplication, and promote sharing of data, systems, and service components across the agency. [Supports Strategies 3 and 4]

By developing a common information management regulatory framework, NRC would achieve significant synergies of licensing while allowing separate unique designs to go forward where economics dictated. For example, a common framework would support PWR, BWR and MHRs (or any other new design, for that matter) within a common set of metrics that allow cross-comparisons of performance based on the fundamental design control document. This would allow NRC to quickly identify performance outliers by quickly screening irrelevant site specific design features to get to fundamental performance. Enhanced data tools will make the oversight process more transparent, and facilitate the movement into a more design data centric framework that is more flexible by tying performance information more directly into networked performance monitoring systems

· Influence Federal initiatives that are applicable to the NRC and expeditiously adopt such IT solutions where they provide sufficient return on investment. [Supports Strategies 3 and 4]

Because many federal and state agencies, indeed whole industries grapple with similar information technology issues, yet lack the fundamental commitment framework of the nuclear industry, they can’t be effective integrating uniform server-based critical attribute data systems. For example, both DOD and VA need methods to move medical records for critical injured defense personnel from forward areas to treatment facilities. Lacking critical attribute-based personnel injury records, treatment suffers. Agencies can’t move hardcopy records with injured personal with certainty. Similar issues abound across the federal agencies like FDA, DOD (hardware), FBI, and NSA. Better data structure models elude network information designers for a variety of reasons, such as larger and more complex frameworks. Nuclear industry records have commensurate complexity but intense public interest in their accuracy, quality and safety based upon the regulatory framework in which they reside.

· Build shared services into the IT infrastructure to reduce costs of applications that require these services. [Supports Strategy 4]

Integration should begin at the design level with a common architecture and a goal to link in a common framework as experience is gained. Because efforts to link the entire design basis across all designs is so large, the first step should be at the individual design level within a common framework relational structure.

· Expand and strengthen information security capabilities to ensure that effective information protection is in place, and develop and communicate policies regarding security. [Supports Strategy 4]

Developing a common framework, each Part 52 plant design could eventually move to an NRC –controlled server. At that point, access controls could allow the same data security structures to provide information access based upon need, but restricted for safeguards based upon the logon authority of the user. This could eventually to place most information where it is most accessible, useful but still controlled.


In closing, the NRC public or industry input forum should also provide a means to notify applicants that their messages have been received, and are in the agency’s docket. At present, there is no way for the submitter of a complaint or suggestion to know their communication has been received (that we’re aware of). NRC should consider closing the loop to track inputs to their source to final disposition. This could be entirely by web.

For clarifications or questions, please contact me at the location below, or by fax or email.



Sincerely,

J.K. August
President, CORE, Inc.
jkaugust@msn.com
http://www.pmoptimization.com/
303-425-7408
303-507-5272 cell
303-425-0861 fax
[1] Air Transport Association
[2] Federal Aviation Administration