UCS Blog - All Things Nuclear (text only)

North Korea’s Missile Test over Japan

Yesterday’s missile launch by North Korea is reported to have been launched from a site near the capitol city of Pyongyang (Sunan) and landed 2,700 kilometers (km) (1,700 miles) to the east after flying over part of the Japanese island of Hokkaido. The missile reportedly flew to a maximum altitude of about 550 km (340 miles), reaching Hokkaido after about eight minutes of flight and splashing down after 14 to 15 minutes.

Fig. 1 shows a possible trajectory for the flight, although it is possible the missile flew somewhat further north and passed over more of Hokkaido.

Fig. 1 (Source: Google Earth)

The launch appears to have been of a Hwasong-12 missile, since it is the only known missile able to reach this distance. The range of this test, however, was much shorter than that of the May 14 test of the Hwasong-12, which would have had a range on a standard trajectory of about 4,800 km (3,000 miles).

What accounts for the shorter range?

One possibility is that the missile was flown with a much larger payload on this flight than on the May 14 test. However, even assuming the May 14 test only carried a payload of 150 kg (corresponding to an empty RV), this launch would have required a payload of about 1,300 kg to give the reported trajectory. That seems unlikely.

A second possibility is that it was flown on a depressed trajectory to reduce the range from 4,800 to 2,700 km. However, that would require a severely depressed trajectory with a burnout angle below nine degrees and a maximum altitude of only 150 km (95 miles). That would also give flight times that were much shorter than those reported.

A more likely reason for a shorter range is a shorter burn time for the engines, either due to North Korea terminating the thrust early to reduce the range, or possibly due to a mechanical problem. In particular, I find if the burn time of the engine is reduced by about eight seconds from the time of about 151 second for the May 14 launch, the missile will fly on the reported trajectory (Fig. 2).

If flown on a standard trajectory (a “minimum-energy trajectory”), a missile with this range would reach a maximum altitude of about 630 km (390 miles) with a burnout angle of 38.1 degrees. The reported altitude of 550 km on yesterday’s launch would mean it was slightly depressed from normal, with a burnout angle of 33.6 degrees. This amount of depression does not seem particularly significant, and may not have been intended.

Fig. 2. The apparent trajectory of yesterday’s launch. Cape Erimo on Hokkaido is at a range of about 1525 km.

A missile on this trajectory would reach the closest part of Hokkaido after eight minutes, which seems to agree with reports. It would pass over Cape Erimo after 9 minutes, and would splash down at 15.5 minutes

Flying over Japan

Yesterday’s launch was the first time North Korea flew a ballistic missile over Japanese territory, although in 1998 and 2009 it launched rockets that overflew Japan on failed attempts to put satellites into orbit. It has gone to some lengths to avoid flying over Japan, by launching its missile tests on highly lofted trajectories so they will land in the Sea of Japan. In addition, it has directed its more recent satellite launches to the south, even though it is preferable to launch to the east—over Japan—since it allows the rocket to gain speed from the rotation of the earth.

After its threats of firing Hwasong-12 missiles near Guam, it is interesting that North Korea fired this missile to the east rather than in the direction of Guam, which might have been interpreted as an attack despite the short range. The missile also appears to have flown in a direction that did not pass over highly populated parts of Japan.

It is not clear what new North Korea would have learned from this launch that is relevant to a long-range missile. It would not have been useful in simulating the reentry forces and heating of a long range missile; in particular, the heating would have been only about half of that on a 10,000 km range missile.

The launch could be useful in getting information about reentry on a standard, non-lofted trajectory with a missile that could reach Guam, although that would require a missile with about 3,400 km range rather than the 2,700 km of this flight.

US Talks to China about North Korea, But Does Not Listen

The United States and China both want North Korea to abandon its nuclear weapons program. The North Korean leadership continues to defy them both. The United States says it is willing to risk a war to stop them. China is not.

Marine Corps Gen. Joseph F. Dunford Jr., chairman of the Joint Chiefs of Staff, signs the Joint Staff Dialogue Mechanism with his Chinese counterpart Gen. Fang Fenghui following a roundtable discussion in Beijing, Aug. 15, 2017. (DOD photo by U.S. Navy Petty Officer 1st Class Dominique A. Pineiro)

China’s top priority is preserving the peace, however uneasy that peace might be. A credible North Korean capability to launch a nuclear-armed ICBM may make US officials psychologically uncomfortable. But the Chinese leadership does not feel that increased US anxiety is a sufficient justification for starting a war that could conceivably kill hundreds of thousands of people and collapse Asia’s economy, even if no nuclear weapons were used.

China has made its priorities clear to both the United States and North Korea. An August 10 editorial published in China’s Global Times warned both sides against striking first. The editorial was not an official statement of Chinese government policy but it almost certainly was reviewed and approved at the highest level. It suggested to the leadership in Pyongyang that, “If North Korea launches missiles that threaten US soil first and the US retaliates, China will stay neutral”. It also suggested to Washington that, “If the US and South Korea carry out strikes and try to overthrow the North Korean regime and change the political pattern of the Korean Peninsula, China will prevent them from doing so.”

China has also made it clear that it will not agree to sanctions that strangle North Korea’s economy. China supports economic penalties that punish North Korea for defying the United Nations and continuing its testing programs. And China is willing to work with the United States and the international community to deny North Korea access to critical technologies. But on August 5th, in an official statement made at the time of the vote on the latest round of UN sanctions, China emphasized, as it has many times in the past, that China “did not intend to negatively impact such non-military goods as food and humanitarian aid.”

US Refusal to Listen

Though China’s position on North Korea is clear and consistent, US policy is based on the assumption that China’s position will change. On August 13th, US Secretary of Defense James Mattis and Secretary of State Rex Tillerson penned an editorial in which they repeated the claim, believed by most US policy makers and analysts,  that China has “decisive diplomatic and economic leverage over North Korea.” The implication is that China can force the North Korean leadership to abandon its nuclear weapons program. The joint editorial reiterated a US policy announced earlier this year by Secretary Tillerson, who said the Trump administration was engaged in an unprecedented effort to “lean hard into China” in order to pressure its leaders to change their policy.

Presumably this means trying to compel China to take steps to strangle the North Korean economy. The United States reportedly attempted to include a crude oil embargo in the latest round of UN sanctions. But China refused, as it has in the past, to agree to sanctions that would have the kind of suffocating economic impact the United States believes would force North Korea to surrender its nuclear ambitions. In their editorial Tillerson and Mattis told their Chinese counterparts they expect China to “do more” than enforce the current round of UN sanctions. They want China to cut off North Korea’s “economic lifelines.”

US policy experts imagine there are several factors that might prompt the Chinese leadership to bend to US demands. Henry Kissinger raised the specter of nuclear proliferation in Asia, including a nuclear-armed Japan. Others believe the Chinese are worried about increased US economic and diplomatic pressure, especially President Trump’s statements linking Chinese cooperation on North Korea to punitive US trade policies. US observers of Chinese domestic politics speculated that Chinese President Xi Jinping may need to alter China’s longstanding policies on North Korea to mollify domestic critics as he makes his case for a second five-year term at the upcoming Party Congress in November.

China Remains Calm

Despite these imagined pressures, there is no indication that President Xi is about change China’s position on North Korea. Throughout the month of July there was very little Chinese coverage or commentary on the North Korean missile tests. Official statements repeated past calls for calm, mutual restraint and a resumption of negotiations. It wasn’t until President Trump’s threat to unleash “fire and fury” on August 8th, followed by North Korea’s threat to fire missiles towards Guam on August 9th, that the Chinese leadership had the Global Times publish the August 10th editorial containing more emphatic and explicit language.

Not long afterwards, North Korea walked back its threat to fire missiles at Guam. The United States then made a series of high level statements intended to diffuse tensions.  In their editorial, Tillerson and Mattis questioned whether China was willing or able to “show the world how a great power should act.” History may well record that in this particular moment of high tension, China’s president acted with greater patience, skill and prudence than the president of the United States.

On August 14th, as tensions began to subside, an editorial in the overseas edition of China’s People’s Daily chastised both the United States and North Korea for “playing a game of chicken on the Korean peninsula.” That’s not the language of a country that lacks confidence in its current position or is overly concerned about upsetting the United States.

The Pyroprocessing Files

The article by Ralph Vartabedian in the Los Angeles Times highlights the failure of the Department of Energy’s decades-long effort to chemically process a stockpile of spent nuclear fuel at Idaho National Laboratory, ostensibly to convert the waste to forms that would be safer for disposal in a geologic repository. A secondary goal was to demonstrate the viability of a new type of processing spent fuel—so-called pyroprocessing. Instead, it has demonstrated the numerous shortcomings of this technology.

(Source: Idaho National Lab)

It is particularly important to disseminate accurate information about the failure of this DOE program to dispel some of the myths about pyroprocessing. The concept of the “Integral Fast Reactor”—a metal-fueled fast neutron reactor with co-located pyroprocessing and fuel fabrication facilities—has attracted numerous staunch advocates.

In addition to Argonne National Laboratory, which first developed the technology, the concept has been promoted in the popular media (most notably in the 2013 documentary Pandora’s Promise) and by GE-Hitachi, which seeks to commercialize a similar system. South Korea has long sought to be able to implement the technology, and countries such as China, Japan and Russia all have expressed interest in pursuing it. But this interest has been driven largely by idealized studies on paper and not by facts derived from actual experience.

DOE internal documents reveal problems

The LA Times article refers to a June 2017 Union of Concerned Scientists (UCS) report that draws on documents that UCS received in response to a Freedom of Information Act (FOIA) request. UCS initiated the request in 2015 to seek information that could shed light on DOE’s troubled program for pyroprocessing 26 metric tons of “sodium-bonded” metallic spent fuel from the shutdown Experimental Breeder Reactor-II (EBR-II).

Pyroprocessing is a form of spent fuel reprocessing that dissolves metal-based spent fuel in a molten salt bath (as distinguished from conventional reprocessing, which dissolves spent fuel in water-based acid solutions). Understandably, given all its problems, DOE has been reluctant to release public information on this program, which has largely operated under the radar since 2000.

The FOIA documents we obtained have revealed yet another DOE tale of vast sums of public money being wasted on an unproven technology that has fallen far short of the unrealistic projections that DOE used to sell the project to Congress, the state of Idaho and the public. However, it is not too late to pull the plug on this program, and potentially save taxpayers hundreds of millions of dollars.

History of the pyroprocessing program

DOE originally initiated the pyroprocessing program for EBR-II spent fuel in the mid-1990s as a consolation prize to Argonne-West National Laboratory (now part of present-day Idaho National Laboratory) after it cancelled the Integral Fast Reactor (IFR) program. The idea was that the metal-based spent fuel from the reactor could be pyroprocessed in a facility connected to the reactor, which would extract plutonium, uranium and other elements to be fabricated into new reactor fuel. In theory, this could be a system that could convert its nuclear waste into usable fuel on site and thus could be largely self-contained. Pyroprocessing was billed as a simpler, cheaper and more compact alternative to the conventional aqueous reprocessing plants that have been operated in France, the United Kingdom, Japan and other countries.

Although DOE shut down the EBR-II in 1994 (the reactor part of the IFR program), it allowed work at the pyroprocessing facility to proceed. It justified this by asserting that the leftover spent fuel from the EBR-II could not be directly disposed of in the planned Yucca Mountain repository because of the potential safety issues associated with presence of metallic sodium in the spent fuel elements, which was used to “bond” the fuel to the metallic cladding that encased it. (Metallic sodium reacts violently with water and air.)

Pyroprocessing would separate the sodium from other spent fuel constituents and neutralize it. DOE decided in 2000 to use pyroprocessing for the entire inventory of leftover EBR-II spent fuel – both “driver” and “blanket” fuel – even though it acknowledged that there were simpler methods to remove the sodium from the lightly irradiated blanket fuel, which constituted nearly 90% of the inventory.

Little progress, big cost overruns

However, as the FOIA documents reveal in detail, the pyroprocessing technology simply has not worked well and has fallen far short of initial predictions (Figure 1) (Refs. 1-3). Although DOE initially claimed that the entire inventory would be processed by 2007, as of the end of Fiscal Year 2016, only about 15% of the roughly 26 metric tons of spent fuel had been processed. Over $210 million has been spent, at an average cost of over $60,000 per kilogram of fuel treated. At this rate, it will take until the end of the century to complete pyroprocessing of the entire inventory, at an additional cost of over $1 billion.

But even that assumes, unrealistically, that the equipment will continue to be usable for this extended time period. Moreover, there is a significant fraction of spent fuel in storage that has degraded and may not be a candidate for pyroprocessing in any event (Ref. 4). The long time to completion is problematic because DOE has an agreement with the state of Idaho to remove all spent fuel from the state by the year 2035. The FOIA documents reveal that DOE is well aware that it is not on track to comply with this obligation (Ref 5). Yet DOE has not made any public statements to that effect and continues to insist that it can meet the deadline.

More waste, not less

An impure uranium waste product is deposited on a cathode in a  pyroprocessing cell (Source: Idaho National Lab)

What exactly is the pyroprocessing of this fuel accomplishing? Instead of making management and disposal of the spent fuel simpler and safer, it has created an even bigger mess. Pyroprocessing separates the spent fuel into three principal waste streams. The first is an enriched uranium metal material called the “spent fuel treatment product.” Because this material contains unacceptably high levels of plutonium and other contaminants, the uranium cannot be used to make new nuclear fuel unless it is further purified; thus it is a waste product. Meanwhile, the material is accumulating and taking up precious space at INL storage facilities, causing its own safety issues.

The second waste stream is the molten salt bath that is used to dissolve the spent fuel. Fission products and plutonium have accumulated in this salt for 20 years. Eventually it will have to be removed and safely disposed of. But for various reasons—including cost and a lack of available space for the necessary equipment—INL is reconsidering the original plan to convert this waste into a stable ceramic waste form. Instead, it may just allow it to cool until it hardens and then directly dispose of it in the Waste Isolation Pilot Plant (WIPP) in New Mexico (Ref. 6).

The third waste stream consists of the leftover metal cladding tubes that encased the nuclear fuel, and the metal plenums that extended above the fuel region, which are contaminated with fission products and sodium. The original plan was to convert these scraps into a stable, homogeneous waste form. But the FOIA documents reveal that DOE is also reconsidering this plan, and considering redefining this material as transuranic or low-level waste so it could be disposed of without further processing in WIPP or a low-level radioactive waste disposal facility. Storage of the accumulating metal scrap material is also becoming an increasing burden at INL (Ref. 7).

In other words, pyroprocessing has taken one potentially difficult form of nuclear waste and converted it into multiple challenging forms of nuclear waste. DOE has spent hundreds of millions of dollars only to magnify, rather than simplify, the waste problem. This is especially outrageous in light of other FOIA documents that indicate that DOE never definitively concluded that the sodium-bonded spent fuel was unsafe to directly dispose of in the first place. But it insisted on pursuing pyroprocessing rather than conducting studies that might have shown it was unnecessary.

Everyone with an interest in pyroprocessing should reassess their views given the real-world problems experienced in implementing the technology over the last 20 years at INL. They should also note that the variant of the process being used to treat the EBR-II spent fuel is less complex than the process that would be needed to extract plutonium and other actinides to produce fresh fuel for fast reactors. In other words, the technology is a long way from being demonstrated as a practical approach for electricity production. It makes much more sense to pursue improvements in once-through nuclear power systems than to waste any more time and money on reprocessing technologies that pose proliferation, security and safety risks. DOE continues to consider alternatives to pyroprocessing for the blanket fuel (Ref. 8). It should give serious thought to the possibility of direct disposal of the remaining inventory without processing.

Links to FOIA documents

Below are links to some of the documents that UCS obtained from its FOIA request. We will provide more documents and analyses of them soon.

  1. Argonne National Laboratory Spent Fuel Treatment Implementation Plan (2000)
  2. INL Preferred Disposition Plan for Sodium-Bonded Spent Nuclear Fuel (2007)
  3. History of Processing (through 2013)
  4. Technical Evaluation of Disposition of Non-Candidate Fuels (2014)
  5. 2014 INL Environmental Liabilities Spreadsheet
  6. Technical Evaluation of Alternatives for Salt Waste Disposition (2014)
  7. Disposal Solutions for Metal Scraps Derived from Treatment of Irradiated Sodium Bonded Fuel (2014)
  8. Technical Evaluation of EBR-II Blanket Disposition Alternatives (2014)

NRC’s Decision Making: 18 Reasons Why You Are Right, but Wrong

As described in a prior blog post, the Unit 3 reactor at the Palo Verde Generating Station had one of two emergency diesel generators (EDGs) explode during a test run. The license issued by the Nuclear Regulatory Commission (NRC) allowed the reactor to remain running for up to 10 days with one EDG unavailable. Fixing the heavily damaged EDG would require far longer than 10 days, so the plant’s owner submitted requests to the NRC for its permission to run the reactor for up to 21 days and then up to 62 days with only one EDG available.

As described in a followup blog post, NRC staffer(s) filed formal opposition to the agency’s approval of the owner’s requests by initiating Differing Professional Opinions (DPOs). Under the NRC’s DPO process, a DPO panel is formed to review the issue and to document its findings and conclusions in a report to the NRC senior manager who makes the final decisions. In this matter, that individual was the Director of the Office of Nuclear Reactor Regulation (NRR). The DPO originator(s) can nominate one individual to serve on the DPO panel. (The DPO process requires a minimum of three persons on the DPO panel, ensuring that the panel won’t have a majority of members sympathetic to the originator(s)’s concerns.)

The DPO panel issued its report on June 5, 2017, and the NRR Director issued his decision on June 28, 2017.  The NRC made the DPOs, the DPO panel report, and the NRR Director’s decision publicly available on July 21, 2017.

The DPO Originator

Troy Pruett originated both of the DPOs in the Palo Verde EDG case. Mr. Pruett is the Director of the Division of Reactor Projects in NRC Region IV. Among other things, Mr. Pruett oversees the NRC’s resident inspectors at all of the nuclear power plants operating in Region IV, including Palo Verde. Mr. Pruett has worked for the NRC for nearly a quarter century—long enough to know the agency’s regulations and procedures intended to protect nuclear plant workers and the American public inside and out (Fig. 1).

Fig. 1 (Source: Nuclear Regulatory Commission)

The DPO Originator’s Position

In his DPOs, Mr. Pruett contended that the owner’s requests to operate Palo Verde Unit 3 for up to 21 and later up to 62 days with one emergency diesel generator unavailable should not have been approved because they departed from the agency’s regulations, procedures, and practices.

The DPO Panel’s Conclusion

Quoting from their report: “The DPO Panel was not unanimous in concluding that Palo Verde License Amendments 199 and 200 should have been approved by the staff.”

One of Mr. Pruett’s candidates was appointed to the DPO Panel. NRC management selected three other members, assuring they’d have a majority. And sure enough, a majority of the NRC management-appointed panel sided with NRC management.

The DPO Panel’s 18 Observations

The DPO Panel’s report contained 18 Observations about the processes used (and not used) en route to the Palo Verde EDG approvals:

(1) The owner submitted two licensing requests to the NRC: one to operate for up to 21 days and the second to operate for up to 62 days with one EDG unavailable. The overwhelming majority of the hundreds of licensing requests submitted to the NRC each year are not bifurcated in this way and the agency’s procedures for reviewing licensing requests do not address such “split” requests. The DPO panel recommended that additional guidance be provided in LIC-101, the NRC’s procedure for handling such reviews, if the practice becomes more frequent.

(2) The DPO Panel noted that the staff’s reasoning for the two-step approach could have been made clearer in the first approval in the interest of transparently providing a complete record of the staff’s decision basis to the public.

(3) The DPO Panel observed that there may be opportunities to more effectively communicate with the public, including the use of less formal communications tools, during emergency requests, and suggests that guidance and training be considered in this area.

 (4) The second approval issued by the NRC staff contained an explicit requirement to shut down Unit 3 if workers found the cause of the EDG’s failure could also disable the surviving EDG. The DPO Panel noted that no formal regulatory commitment existed in the first approval. During interviews, the NRC staff was not able to provide a sufficient basis as to why a similar condition was not included.

(5) The DPO Panel observed that the Safety Evaluation issued by the NRC staff in support of the first approval lacked sufficient documentation to objectively identify the staff’s decision basis in several key areas, including how the potential for common cause failure of the surviving EDG was evaluated and the basis for a 21 day EDG outage time. In other words, the NRC staff failed to ask and answer all the relevant safety questions.

(6) The DPO Panel concluded that the use of a zero test and maintenance assumption (i.e., no other safety equipment would fail or be unavailable while the EDG was broken) in the owner’s probabilistic risk assessment (PRA) model was not consistent with Regulatory Guide 1.177 guidance and the regulatory commitment put in place for the second approval for the conduct of routine maintenance and surveillance was not consistent with PRA assumptions.

In other words, when the EDG was unbroken, the owner’s risk assessment assumed that there was a small, but non-zero, chance that the highly reliable emergency equipment would not perform needed safety functions during an accident. But when evaluating the risk during the 62 days the reactor would operate with a broken EDG, the owner’s risk assessment assumed that all emergency equipment would function perfectly. The DPO Panel found this assumption unrealistic, non-conservative, and contrary to longstanding NRC expectations.

(7) Additional guidance should be evaluated with respect to defense-in-depth, the adequacy of long duration equipment outage periods, and whether there should be a backstop (i.e., maximum outage period).

(8) The DPO Panel concluded that the Branch Technical Position 8-8 guidance was not strictly adhered to for the two approvals. The DPO Panel recommended that deviations from established guidance should be documented and justified. The Branch Technical Position explicitly stated that the NRC staff should not even review a request to operate for longer than 14 days with one EDG unavailable; in this case, the NRC staff not only reviewed such a request, they approved it without explaining why they dismissed the 14-day maximum duration.

(9) The DPO Panel confirmed that the NRC’s safety evaluation supporting the first approval did not include an independent verification of the owner’s risk evaluations.

(10) The DPO Panel identified that the second approval used the three risk-informed tiered review approach outlined in Regulatory Guide 1.177. The DPO Panel pointed out this approach was inconsistent with Standard Review Plan 16.1 guidance, which states that Regulatory Guide 1.177 only applied to permanent (as opposed to temporary or “one-time”) changes. In other words, the NRC staff used an approach not allowed by the agency’s procedures.

(11) The DPO Panel found no discernible differences between the DC Cook request for a 65-day EDG outage in June 2015 and the Palo Verde request. However, the staff appears to have arrived at entirely different conclusions, based upon different interpretations of the deterministic guidance of Branch Technical Position 8-8. Cook’s owner sought the NRC’s permission to operate Unit 1 for up to 65 days with one of two EDGs unavailable. The NRC said no to Cook’s owner and yes to Palo Verde’s owner, citing Branch Technical Position 8-8 for each of the entirely opposite decisions.

(12) In the DPO Panel’s opinion, the Palo Verde risk evaluation warranted closer scrutiny. However, interviews of the NRC staff identified that there is no guidance for when to use the agency’s SPAR models for independent verification and it appears to be at the discretion of the reviewer(s).

(13) Section 4.2 of the NRC’s procedure for reviewing licensing requests, LIC-101, states that, “Decisions to not apply specific precedents, especially precedents cited by a licensee, should be clearly explained in the SE [NRC’s Safety Evaluation] (to avoid the appearance of being arbitrary and/or inconsistent).” The DPO Panel observed that neither of the Safety Evaluations prepared by the NRC staff for the two approvals addressed the licensee’s referenced precedents. In other words, the NRC staff did not follow the procedure they purportedly used to make the approvals.

(14) The DPO Panel found that both of the Safety Evaluations prepared by the NRC staff for its approvals included Branch Technical Position 8.8 in the list of regulatory guidance documents reviewed. The Safety Evaluations stated that Branch Technical Position 8.8 required more defense-in-depth for station blackout scenarios than for loss of coolant accident scenarios because of a higher likelihood of occurrence. But the DPO Panel found no such statement or implication about design basis accident likelihoods in the Branch Technical Position. In other words, the NRC staff departed from the regulatory guidance document it purportedly used to justify the approvals.

(15) The DPO Panel determined that there is no established guidance for how NRC staff should judge the adequacy of risk evaluations provided by plant owners. The good news is that the NRC staff cannot depart from non-existent guidance; the bad news is that the NRC staff can, and has, wandered all over the map since it lacks proper directions.

(16) The DPO Panel identified a lack of clarity in the existing review guidance and related inconsistencies in the understanding between the NRC departments regarding who is responsible for reviewing what in licensing requests.

(17) The DPO Panel recommended additional guidance be developed for the NRC staff when reviewing requests for extended periods of safety equipment unavailability.

(18) The DPO Panel recommended that a lessons learned review be conducted after significant or first of a kind licensing actions to determine if the action should be used as future precedent and/or whether there should be specific attributes identified that future staff should evaluate before using the precedent.

Grading on a (Mobius) Curve

If you read these observations, and the more voluminous supporting text in the report, before reading the conclusion, you’d likely think that the entire panel agreed with Mr. Pruett.

After all, Mr. Pruett contended that the requests departed from regulations and the DPO Panel’s Observations 5, 6, and 14 confirm that contention and several others support it.

Mr. Pruett contended that the requests departed from the agency’s procedures. The DPO Panel’s Observations 1, 8, and 13 confirm that contention and several others support it.

Mr. Pruett contended that the requests departed from the agency’s practices. The DPO Panel’s Observations 9, 10, and 11 confirm that contention and several others support it.

But nooooo. The DPO Panel disagreed with Mr. Pruett.

You might ask why the DPO Panel could possibly have disagreed with Mr. Pruett.

If you do ask and someone gives you a straight answer, please forward it to me. I’ve monitored the NRC for nearly two decades and I cannot fathom how the DPO Panel could assemble so many reasons why Mr. Pruett was right, and yet conclude he was wrong.

It’s like a 19 chapter mystery novel with the first 18 chapters describing how the upstairs maid committed crime after crime only to have the butler—mentioned for the first time—arrested for the crimes.

Perhaps that explains it: the DPO Panel report is an intriguing work of fiction. Or maybe it only needed a non-fictional final chapter.

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