Allan Carson

CORDEL Project Manager

World Nuclear Association

August 16, 2021

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Ep 328: Allan Carson - CORDEL Project Manager, World Nuclear Association
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Bret Kugelmass
We are here today with Allan Carson on Titans of Nuclear. Allan is a Project Manager at the World Nuclear Association. Allan, welcome to the show.

Allan Carson
Thanks very much, Bret. Good to be here.

Bret Kugelmass
Yeah, so let's get started by just learning a little bit about you. First, tell us where you grew up?

Allan Carson
Oh, well, as you can probably tell from my accent, I grew up in in Ireland, specifically Northern Ireland, and I grew up on a in a farming community. My parents worked- well, my dad worked as a mechanic and my mother worked in health care all her life, so there's engineering or nuclear background there. And then I left Ireland, went to university in England to study process and chemical engineering-

Bret Kugelmass
And just because I- not to just pass over the Ireland thing too quick, did you grow up in North Northern Ireland? Or South Northern Ireland? Or where, exactly?

Allan Carson
West Northern Ireland, so I was pretty much 20 minutes from the border with the Republic of Ireland.

Bret Kugelmass
I was gonna ask, and when you were growing up was anything going on? What years was this?

Allan Carson
Yeah, this was going back from, I can't remember exactly - but going back maybe 30 years now? I would have been a child, but I still remember there being quite a lot of military presence around. There were no border checks at that time, but I still remember a lot of military presence and quite a lot of training happening in the area, etc, etc. And there was still quite a lot of angst in and around the local area or so.

Bret Kugelmass
Yeah, and probably a bunch of stories from your folks also, huh?

Allan Carson
Plenty of stories. I'm not going into any detail right now.

Bret Kugelmass
But I am curious how that, maybe if you've ever had a chance to kind of reflect on that and kind of piece it together with the rest of your life and kind of where you went? Did you think it had any influence?

Allan Carson
I think it made me quite strong-willed and I think it made me quite resilient to challenges in my life, and made me quite determined to sort of do something, to sort of move myself forward, not grown in sort of a cyclical, nonsensical argument. I think it probably did those things. I've not reflected on it too much, but if I was asked the question, I think those would be the key areas.

Bret Kugelmass
Okay, so tell us - it's always great to get some perspective on who the person is - but tell us, what did you want to make of yourself?

Allan Carson
Well, to be brutally honest, Bret, I didn't know. Still, I'm not entirely sure, if I'm being truly honest. I sort of take it one sort of day at a time, and I'm trying to deal with the challenges in front of me and I like fixing problems, so engineering came quite naturally to me, as in I was always good at this sort of the math, physics, chemistry side of school. To me, engineering became a sort of a natural transition from that, so I went and studied chemical process engineering for four years in Newcastle.

Bret Kugelmass
Where is that, exactly?

Allan Carson
Northeast England.

Bret Kugelmass
Okay.

Allan Carson
Cold in winter. I haven't. And then, that degree very much oriented me towards the oil and gas industry. It's very refining, distilling oriented. That's very much sort of where a lot of that training and coursework was going. Then, when I finished that, the natural progression was going to be into petrochemicals industry, but I ended up taking a job with what ultimately became Jacobs, an engineering consultancy company. Because I have a slightly different perspective, and I want the opportunity to work across different fields, not necessarily pigeonhole myself too much.

Bret Kugelmass
Yeah, give yourself options.

Allan Carson
Exactly, because you don't know what you're going to like or what you're not going to like in three years time, so it's about giving myself options. And then that's kind of really where I got introduced to nuclear power and the nuclear industry. And that I think, is most people of my generation in the UK will have started off working in some form of decommissioning at Sellafield, or all the projects that are associated with that and with waste management, etc.

Bret Kugelmass
Because that's where the money is. A lot of government money goes into it, that creates a lot of jobs and that creates a lot of training opportunities, especially for up-and-coming engineers.

Allan Carson
Well, yeah, exactly. And to be honest with you, when I was starting my career 15 years ago, the UK barely hard a new build program. It was only very fledgling at that point. There wasn't a lot of work in it and nobody was really sure where it was going. They hadn't built anything for 15, 20 years before that, so the decommissioning of nuclear was the only thing going in the UK at that point.

Bret Kugelmass
And what kind of decommissioning activities? Just kind of set the scene for us: what happens?

Allan Carson
What happens... some people would say nothing. But in truth, quite a lot happens. And a big part of it is a lot of the planning. It's about the de-risking of getting the fuel off the site, because once you can get the fuel off the site, then you can sort of put in the care and maintenance time, and you can start to strip things up with much more speed, basically. It's kind of thing of looking at how you take waste out of certain places where maybe that we shouldn't be, process that waste, and manage it and take it off site. When I'm talking about waste, so I'm not talking about spent fuel here. I'm talking about sort of the other tailings that have come out of legacy nuclear sites in the UK.

Bret Kugelmass
Yeah, I was just gonna ask you. I was gonna ask, what form is it even in?

Allan Carson
Some of it is just bits of steel, some of it is-

Bret Kugelmass
Just on the ground? Or it's already-

Allan Carson
No, no, they're normally put inside sealed vaults and then filled with water, etc. Sometimes it's in a resin form, sometimes it's in liquid form, sometimes it's in a slurry form. And so there are all the challenges to how you get it out of where it currently is, how you end up processing it, what the waste production is going to be, how they're going to manage it, how you're going to transport it to which final disposal site, etc. Those are the sorts of projects that you normally get involved in, or surely those were the early projects that I was involved in in the nuclear industry in the UK.

Bret Kugelmass
Got it. Okay, so what happened next?

Allan Carson
What happened next was Jacobs won a contract to provide the environmental case for the GDA for the AP-1000 in the UK. And I was very interested, because I, through the decommission work, you start doing a bit of research, you go down rabbit holes, and you think, okay, hang on, this industry is quite interesting. It would be good if we could build some new ones. When that opportunity came along, I jumped at it with two hands. Got myself involved as a relatively young engineer at that point, doing some of mass energy balances and looking at the waste volume, building up the environmental case, and then looking at the emissions, etc, etc. Supported reading the chapters of environmental case and supported the meetings with the environmental regulator in the UK at the evaluation. And then I got a bit of a crazy opportunity really, in that Westinghouse wanted somebody as sort of a UK liaison for the project to go over to the US, and so again, jumped at it with two hands.

Bret Kugelmass
And when I say you got that opportunity, how? Did somebody email you? What happened?

Allan Carson
No, I proposed it. Let's be clear, I suppose in fairness, I thought it was- because they were starting to struggle with sort of understanding what the UK regulators were actually asking, because there's a different- we all speak one language, but we don't really.

Bret Kugelmass
When you say we all speak one language, you mean we all speak English.

Allan Carson
We all speak English.

Bret Kugelmass
But we all mean different things when we say it.

Allan Carson
Correct. Yes, yes. Of course I've got some stories with that as well. But they needed- the UK regulator requires much more of a story. I got the impression at that stage that when you submit a response to a question to the NRC, it's pretty much just facts and figures, here's the answer, job done. The UK regulator requires much more of a, here's the background, here's why we've done it, and here's the decision process we've gone through. This is why we made these decisions, this is the outcome, and this will be the final design decision, etc. The environmental regulator and the safety regulator are one in the same to some extent, in that respect, because for the GDA, they actually form a joint office and they work hand in hand, so one submission goes to both essentially.

Bret Kugelmass
But let's not brush past this too quick. I think this is a great lesson learned that we can talk about to help others navigate the UK regulatory process in the future, the differences between the US regulatory culture and the UK regulatory culture. Are there any other examples maybe that you can dive into where the US way of doing it didn't work?

Allan Carson
There's nothing I can go into in too much detail. What I can say is there are a number of examples where- and I'm actually writing a report right now about different interpretations of regulatory requirements that delves into not just US to UK examples, but also France to Finland, France to UK, Russia to Hungary, etc. It delves into these- the regulatory mindset and framework sets up a set of interpretations that, while consistent with the IAEA safety guidance and standards lead to very different design decisions at the endpoint-

Bret Kugelmass
Like what?

Allan Carson
I&C systems, off the top of my head. If you pick the EPR, the I&C system in France is different to the one at Olkiluoto and it's different, again, to the one at Hinkley. Waste management systems between sort of how the waste gets managed and processed in the US or Japan to how the UK and or France would want it to be processed and managed and the time involved in that, and also what the envelope needs to look like. The famous one is the thickness of the pressure vessel between Russia and the US. I think it's 19 or 25 centimeters is the difference. Yes, both are considered safe in their own respective territories. These are the challenges that we've got when we move reactors from one territory to another territory. The requirements- and it's not just numbers and figures that are different, because in a lot of regulatory regimes, like the UK, you'll have set numbers and figures. What you have is an expectation to demonstrate it's as good as it can be and that can lead to some challenging conversations, because from the US perspective - and we'll get into sort of, I had some experience with the Japanese bringing the ABWR to the UK as well - they have a design that is safe and operating and why they're having to change that because the regulatory requirements or expectations are slightly different is a very challenging conversation to have with companies.

Bret Kugelmass
You said something that I want to dive into just in case I'm- it's one of those language things that we talked about before. You said as good as it can be. When you say that, what do you mean? Do you mean that it's as good as possible, or it's as good as it needs to be to fulfill-

Allan Carson
Well, they're two different things and it's kind of the essence of the conversation of radiation. It's all based around this concept of the ALARA or the ALARP principle, As Low As Reasonably Achievable, As Low As Reasonably Practical in the UK. Where I think we get ourselves into problems with this principle is we're always driving to a lower number. If we think about off-site emissions, for example, there comes a point where another three fifths of nothing makes no difference and so-

Bret Kugelmass
Who is missing that. Is it the regulator that's missing that or is it the applicant that's missing that point?

Allan Carson
It's the regulator in a lot of cases that is missing that point. And the regulator is driving more and more stringent requirements that- because it's this massive emphasis on more and more safety, more and more regulation as a good thing. But actually what that does is it stifles innovation, it stifles deployment times, it makes everything more expensive, etc.

Bret Kugelmass
And is this true of all regulators?

Allan Carson
I mean, it's true. I want to be clear, I don't want to upset the regulators, because let's be honest, we have an extraordinarily safe industry. And we have that industry because the regulators have learned lessons and have moved things forward and adapted.

Bret Kugelmass
And by the way, I actually don't think you'll be upsetting the regulators, even if you criticize them, because I've spoken to so many of them that want us to be critical of them, because they want- because they actually- many of the individuals want to change things, but they feel like the inertia of the organization doesn't allow them to. They actually welcome critical voices to give them more standing to have internal conversations that challenge the way of doing things. I would actually not hold back, if I were you, be as critical as you want and I think they'll appreciate it.

Allan Carson
No, I absolutely agree, but I did want to get the point across that I do think they do a fantastic job, and a very challenging job. And you're absolutely right, a lot of the individuals that I've spoken to as well are very keen to change things and very keen to be a bit more progressive and sort of collaborative between different regulatory bodies so that they can learn from each other. And you're absolutely right, the sort of the inertia and all the background within the associations, it's turning a tanker ship around, isn't it? It takes a really long time, or one of a better analogy. But yeah, it is the regulators. The regulators need to start having serious conversations about where this is going, because if we keep adding more and more layers, it will suffocate the industry.

Bret Kugelmass
Yeah. And I actually don't think it helps them achieve their goals either. If their ultimate goal is safety of people in the environment, I actually think there's a very strong argument to be made that adding additional layers adds complexity. Adding complexity, adds risk, risk that the layers are misunderstood, risk that the layers will interfere with each other in an unpredictable way, risk that there's just so much stuff going on that it actually becomes impossible to keep track of it all and then you miss something and you allow mistakes to happen. So I think we need to actually have that conversation as well, that more layers can be actually more dangerous, not more safe.

Allan Carson
You're absolutely right. The more things you have to engineer, the more things that can go wrong. The machine that doesn't break is the one with one moving part.

Bret Kugelmass
I love that. I haven't heard that one, but that's perfect. Okay, so tell me, let's just continue through your career a little bit so we don't lose track.

Allan Carson
Right, so we just got to the US with Westinghouse. I was there for a year living in Pittsburgh. Absolutely wonderful experience, met a very large number of very good friends and colleagues I still have to this day, both inside and outside of Westinghouse. That was absolutely brilliant. I really enjoyed that. And then I returned to the UK because Fukushima occurred and the whole industry went into sort of, it just collapsed in on itself a little bit and recoiled from the world scene a little bit. That was sort of the coming back to the UK and at that point, obviously a lot of the new build was just a little bit on hold, everybody was sort of locking up, like what are the next steps. That was the point I decided to sort of make a bit of a career jump and move to Rolls Royce Civil Nuclear Division as a lead engineer, and was part of their business development program to help them build their civil nuclear program, did business development work with various clients around the world and in the UK, looking to win contracts and bids and some of them they're delivering at Hinkley Point C today. I was there for about two years. Again, enjoyed it, but after about the two year period there, or two, three year period at Rolls Royce, the new build market was picking back up again in the UK and Hitachi had entered the fray and they were looking to build and develop a project of Wylfa, so I went and became part of the contract management team for the Horizon project and essentially managing parts of the contract to bring the ABWR to the UK and all the interfaces that that had with regulators, with design teams, with the licensing team that have been run in parallel to the to the project development team. I did that for about three years.

Bret Kugelmass
Now you're getting actually quite a bit of different experience seeing kind of fits and starts of outside international companies trying to play a role in the UK market, right?

Allan Carson
Yeah, exactly.

Bret Kugelmass
At this point, are there lessons learned or patterns emerging that you're seeing about what people are doing right and wrong?

Allan Carson
Yeah, I mean, I think the familiar pattern is the regulatory one. Everybody underestimates the regulatory challenge coming to the UK, particularly if you have a design that's already operating, because the cost of change is very high.

Bret Kugelmass
And why change it? If you- that's what I never actually understood. If you already have a design and it's working somewhere and someone- obviously, it's kind of gone through all of the, it's gone through the processes and the inspection and people looked at it, and it's really lived up to muster, why change the design at all? Why not just go to the regulator and say why the existing design meets their criteria, rather, and literally not allow for a single bolt to be changed. And just say, Listen, you can take it or leave it. Obviously, other people think this is safe. Obviously, we have a compelling case. Obviously, we have hundreds of engineers that can talk to you about why it's safe in its current form, but we are not changing this design. Period, end of story.

Allan Carson
They probably wouldn't let you build it.

Bret Kugelmass
And why?

Allan Carson
That's a really fascinating question. And it's kind of what I'm trying to solve in my job today. A big part of the objective of where I work today is that you can take a standardized design that has been approved by a competent authority and build it anywhere with next to zero change.

Bret Kugelmass
And why - I know we're gonna get into this - but why does that actually require any change in policy or procedure whatsoever? Why is that not just something that a few people have a conversation in a room, a few lawyers, a few engineers, a few heads of government, a few heads of state, and in one afternoon they all discuss it, people bring up their concerns, and then they come to the conclusion that, obviously, if another competent regulator approved it, it's good?

Allan Carson
Well, I think I'll tackle that in various stages. I think the first one is most of the regulators will tell you that they're independent. That would be first.

Bret Kugelmass
Yeah, but independent is supposed to be independent from undue influence from like an executive branch, where maybe a dictator takes control of a country and says, You build these plants with cheap parts or else, because my cousin runs the cheap part factory. And then they're supposed to be independent and be like, No, you don't control me, but not necessarily independent from each other.

Allan Carson
No, they're supposed to be independent from undue influence from heads of state and or other ways, right? The main reason I can work out - I don't have an answer as to why it doesn't happen, I'm still trying to look for that answer, by the way, I don't think anybody has that answer - but you're quite right. Just knocking heads together might be a good idea, but I think a lot of it has to do with history. I think a lot of it has, to some extent, from my personal perspective, I think a lot of it has to do with where did the nuclear power industry come from. It came from the desire to make weapons. And, as a result, a level of secrecy and security and control got built around it. That then manifested itself, when we started looking and each individual country start developing their own civil nuclear program for power purposes, that level of secrecy and security etc. came with it and as a result, it's sort of embedded into government and ministers' mindsets that this stuff needs to be protected. And it does need to be protected to a level, but maybe not to the level that we can't have a conversation with some friendly neighbors.

Bret Kugelmass
Yeah, and then also just making that distinction clear between weapons and civil. I mean, I just think the distinction is so obvious. You can use a proxy, like enrichment level, to just make a very clear distinction between the two. Like you can't make weapons with sub 5% enriched uranium, so why is anything that clearly is just using sub 5% enriched uranium not subject to the same levels of secrecy and concern.

Allan Carson
Exactly. But like I said, I think it's a historical mindset thing.

Bret Kugelmass
I see, it's cultural. It's beyond logic, it's cultural.

Allan Carson
Exactly, exactly. That's my personal perception, at least. I think the answer will only come out in the wash once you've actually solved the problem.

Bret Kugelmass
Okay. So I guess, how do you- actually how did you become part of the World Nuclear Association?

Allan Carson
Yeah, so that sort of came- after I came back from Japan - I lived in Japan for six months with Hitachi and then to come back and spend a little bit of time being a project management consultant for numerous projects, delivering a project into Hinkley Point C. And then I sort of had a bit of a decision to make really, in terms of I realized I could continue to ride the wave up and down of project development in the UK and come across all of the same challenges and same problems that every project I've worked on to-date has come across, or I could go and try and do something about it. I looked around and there was an opportunity with the World Nuclear Association and very specifically with their CORDEL Working Group, which is the Cooperation in Reactor Design Evaluation and Licensing working group.

Bret Kugelmass
Can you tell me a little bit more about that acronym? Is there a reason it spells out CORDEL?

Allan Carson
I's titled the Cooperation in Reactor Design Evaluation and Licensing and they just managed to pick the right letters in the starting two or three letters of each of those words to pick CORDEL. That's all I know about it.

Bret Kugelmass
It doesn't- I guess just thinking it sounds like cordial, because it's like people working together. Is there anything like that? Or is that just me making stuff up?

Allan Carson
If it is, it's before my time and then nobody's told me.

Bret Kugelmass
Okay, keep going. Sorry.

Allan Carson
No, you're fine. Very specifically, their standing mandate, as I've mentioned, is to have a situation where you have standardized reactors that you can build anywhere in the world. And so I thought this is a good fit. This worked quite well in terms of kind of where my mind is, in terms of what needs to change. I was lucky enough to get the opportunity to go and work there and then my focus there is on SMRs, on licensing and permitting, and on digital I&C. Those are the three areas that I'm responsible for.

Bret Kugelmass
Tell me about licensing of SMRs and does this change the story at all? Some of the things we were talking about before about how regulators do them. Are SMRs the opportunity to kind of press the reset button on our licensing cultural expectations?

Allan Carson
It might be. I'll probably answer that in three ways. The first one is sort of I wrote a- well, the association has written a report titled "Design maturity and regulatory expectations for SMRs" that looks across a number of countries trying to mesh together the design stages that you go through when you're deciding a reactor versus the design expectations of the licensing process in nine different countries. And it turns out that, as far as getting a construction license goes, everybody's relatively well-aligned. As far as the pre-licensing processes go, we're not all that well-aligned at all. Some of them start very early in the process, some of them start quite late in the process, and there's anything in between those two.

Bret Kugelmass
And what are these countries? I'm looking at a list right now, is it Belgium, Canada, China, France, Korea, Russia, UK, Ukraine, USA?

Allan Carson
That's the one.

Bret Kugelmass
Okay. And how did you choose these to look- because there are probably like 20 more. How are these chosen? They

Allan Carson
The way the association works, the way our industry cooperation groups work is we put out a request to our members that we're going to do, or we're proposing to do this report. Who wants to be involved, who wants to contribute? This is the information we're looking for and then we get back replies and responses. And thankfully, we have quite a lot of contributors to this report, quite well-detailed.

Bret Kugelmass
Yeah, it's amazing looking through it and I'm really glad that you guys put it together. I actually think certain reports are better than others in terms of clarity and I think this one hits the nail on the head, so to speak.

Allan Carson
That's good to hear. Thank you. A long time formatting and writing it.

Bret Kugelmass
I think that's important. And then so, I guess, I want to ask this question, but I know you can't answer, but I'll ask it anyway. Why doesn't everyone participate? I don't get it, why doesn't literally everybody jump at the opportunity? Because it's the World Nuclear Association. It's not like some gotcha organization. It's gonna be helpful to have- it'd be helpful to even see yourself in comparison to others. It's free education for yourself. Why wouldn't everyone participate?

Allan Carson
Absolutely. That's pretty much the premise of the way the working groups and task forces are set up is that it's freely publicly available information, and it's for everybody to contribute to and learn from. I can't answer as to why everybody doesn't necessarily get involved. I know it from the other side, as in having worked in organizations like that contribute to the World Nuclear Association is that there's always slightly different time pressures. You're always up against the clock on something, and then to take on something else that might be another two months of work might be a bit of a challenge. That's certainly a factor, but it's not the only factor. And so it's an interesting question, but not one I can definitively answer.

Bret Kugelmass
And do you think that now this report has come out that there's an opportunity you can send it back to everyone who didn't participate and say, Hey, we'd love to do an addendum. Now you can see everything that's going to be in it, will you now contribute? And then we'll come out with another one in six months, or something that has everyone?

Allan Carson
Well, to be honest, just to sort of get back to your original question about are SMRs the opportunity to reset the licensing button, for us, it's more about kind of the next step. It's kind of, we've sort of done this report. The level of detail about the content is really interesting and it's really useful, but for us, really, it's about how do we take those recommendations about international cooperation and bringing the regulators and industry and government closer together and make that work? That for us is the bigger thing. If the opportunity came along and other contributors wanted to add to it, we could absolutely do an addendum. That wouldn't be a problem, it would certainly add to the weight of the report and have other countries involved. Really, for us, it's about what do we do next? How do we move this to the next step, because the licensing challenge for SMRs is, to some extent, it's even worse than it is for PWRs, because we have the risk that things will diverge even further. If you separate SMRs, between light water reactors and the Gen IV concepts, the light water reactors will probably have similar challenges when moving between countries, as we've seen so far. The Gen IV concepts, if you pick, for example, a molten salt reactor, some of the countries listed in our report won't have any experience of it, so then they're gonna have to go and find something if they want to use it. Then there's a risk that that diverges even further from the other countries that are also reviewing molten salt reactors. It's ultimately urgent that we start to bring this together in an international forum, and get people thinking about how do we come up with an approach at an international level that can satisfy everybody from a regulatory safety standpoint and also can actually help A, both the mature nuclear countries deploy reactors faster, yet also help developing countries who don't really have the regulatory frameworks to pick up some of these technologies and utilize them.

Bret Kugelmass
And when you say - I want to be precise - when you say the developing countries, do you mean the developing countries that don't have nuclear or just don't have as many nuclear plants as the bigger countries do?

Allan Carson
Both.

Bret Kugelmass
Because one of the things that - I want to hear your thoughts on this - one of the things that I've been considering is actually, the nuclear countries - countries that have a nuclear reactor, but don't have a giant entrenched industry, don't have incredibly entrenched cultural values also in their regulatory scheme - might actually be the best pioneers to lead the way, which sounds a little counterintuitive. You think, okay, maybe you want the most resourced countries, the most ones with the most experience. But it's- let's take a small country like Czech Republic or something. They're extremely competent, they've got great nuclear engineers, they've got research reactors, they've got a couple commercial reactors. Is it possible that they're actually far better positioned to lead a new regulatory paradigm, than a country that has 1,000 stakeholders in their licensing organization?

Allan Carson
It's certainly possible, but in order for that to happen, though, it's very much- we sort of, I see the first step to that process being that we get ourselves comfortable - when I say we, I mean, this sort of international nuclear community - to get ourselves comfortable with the idea that the Czech Republic or another would take the design of an SMR that has been licensed in the US, Canada, the UK, France, Russia, wherever, and essentially, just does the site licensing activities required to sort of look at the seismic spectra, etc, etc, etc, to then build it on their site, without significant changes to core design, etc. and all this stuff that costs a lot of money.

Bret Kugelmass
Yeah, I mean, that's a no-brainer to me. That's just general reciprocity, right?

Allan Carson
Exactly. That's what makes a lot of sense. That, to me, I think, is the first step towards this new regulatory paradigm, because then, if you can get that done, you can then bring in other regulators to sort of look at that and say, Okay, there's a model here now, maybe this will be a way to go. And then you start to build and develop trust between how those activities are happening, and then all of a sudden we have a process, we might be able to harmonize.

Bret Kugelmass
Don't we have historical precedent for this? I mean, I went down to Mexico and met with the regulator down there and - I forgot how many people they have there, maybe like 100 or something - and they have a GE reactor. I think their basic premise was, Yeah, we're not going to ask GE to redo their reactor - like a BWR, this is like from the 70s, 80s, 90s, whatever it was - and they're like, Yeah, we're not gonna ask for any changes, we believe that the US did a good job and so we're here to make sure that the continued operations meet standards, but we're not gonna ask them to redesign their reactor.

Allan Carson
There is - I don't know this specific case in Mexico - but there's definitely precedence for it and there's also precedence in Europe where some countries will have their - particularly in Eastern Europe - will have accepted the Russian regulatory sort of findings and have moved on to construction on that basis. Others are less willing to do so. Again, that's sort of part of the mindset challenge that I believe we have to move past and get on to a point where we're a competent authority, deemed a competent authority, because they are just not.

Bret Kugelmass
Yeah, exactly. Okay, so what do you- let's get some- let's get action-oriented here. What do you think literally needs to happen to move forward on that?

Allan Carson
Right. And this is the other report I want to mention, CORDEL produced a what's called a lessons learned from transport report, because, believe it or not, the nuclear industry has actually managed to harmonize regulations previously in association with transport. It was one of the first activities the IEA really did.

Bret Kugelmass
When you say transport, what do you mean? Transport what?

Allan Carson
Transport of fuel, transport of new and spent fuel. We do it-

Bret Kugelmass
New and spent fuel. Okay, interesting. I would imagine those to be two wildly different cases. It's like new fuels and radioactive.

Allan Carson
Yeah, I mean, we have - what is it, I'll probably get this wrong - but the Type B package containers that are universally accepted for transport of spent fuel around the world. There are local challenges to it, but fundamentally, the regulations are harmonized at an international level. They're not defined by every country and there are no changes in requirements as you move from one territory to the next territory. We've been doing this for, well, since the 1960s, years ago. There's a large amount of precedence there in terms of something that we can do properly and we can harmonize.

Bret Kugelmass
And okay, you're using the word harmonize, which actually scares me a little bit. I like the world reciprocity better, because reciprocity means that you can actually have two different systems, but you trust the other system and you can go with either, and that makes it actually easier to get things done. With harmonizing - and maybe this is just the words and coming back to our English - I'm afraid whenever I hear harmonizing, because the first thing I think is, okay, everyone has to get in a room and agree on a common set of standards - and that's impossible - and then that common set of standards, there's no guarantee that's going to be the best final outcome. I mean, they're usually called common laws for a reason, and it might be overly conservative, and it might be maybe harder to get things done.

Allan Carson
No, you're absolutely right. And you raised a really good point. And harmony is- the word harmony scares a lot of people. I'm using CORDEL's language, because that's what they have traditionally used. What it really means is a harmonization of approaches or a streamlining of approaches in terms of, we're not talking about- what we definitely don't want to happen is everybody get in the room and agree with the most strict requirements are the ones we're going to follow, because that race to the top is just going to kill everybody.

Bret Kugelmass
Yeah, exactly. That's going to kill the whole industry, as if it's not already dying.

Allan Carson
That's the one thing we definitely don't want people to understand by harmonization. What we really mean is that there is an agreed approach and - I'll let you say that word.

Bret Kugelmass
Reciprocity.

Allan Carson
Reciprocity, that's the word, yes, thank you. That's quite a good way of thinking about it, because it means that one regulator can accept the output of another regulator's review, and/or they can do separate bits of a review and come together and share conclusions so that there is one whole part. That is kind of really what we're trying to drive at, but it's not everybody getting in a room and agreeing on a set of requirements, because that will never happen.

Bret Kugelmass
Yeah. Okay, so back to my other question. Literally, what do you do to move this forward? Do you host a conference? Do you get two people in a room and then add a third? What would you do to make us move forward?

Allan Carson
What we've proposed is the development of a - it's a long title - a multinational advisory panel, which essentially is constructed of competent regulators - and by competent regulators, I mean, the big regulators have been doing this for 40, 50 years - representatives from them, and they have a mandate from government to essentially dictate and control the activities associated with licensing of reactors around the world. It may start off quite small. It might start off with maybe two or three regulators coming together and working out how they're going to review designs of a number of SMRs. That may expand to get in, you may get a fourth and a fifth coming in for the second set of reviews, and then you have six and seven coming in for the next set of reviews. And ultimately, you build a repository of all these designs that have been reviewed and accepted by this panel and group of regulatory experts that have a mandate from the government and the mandate from the government is important, but really-

Bret Kugelmass
Does that mandate come with money, is that the idea?

Allan Carson
It has to come with money, because regulators have budgets for international collaboration, but they don't have budgets for this scale of international collaboration. This is- they're going to need more people, basically.

Bret Kugelmass
And when you say they come together and they approve designs, what exactly are they approving in these designs?

Allan Carson
That's sometimes the challenge, in terms of what are we actually going to lock up, because when we think about licensing, in the - I'll go back to the US and UK as two very different examples - in the US, you approve - if you think about the design certification process, or the design approval process - you approve a design, essentially the NSSS and supporting systems and then you can move that into your call application or your site license application. In the UK, you don't really approve the design. Your license application is for a site and activities on that site. Now, obviously, the design has a huge influence on that, but it's fundamentally slightly different criteria. Actually, one of the first things they have to get together and agree on is, what is it they're going to review and what does that mean? It's kind of part of that- part of what we're trying to develop now is, how do we take what they're going to review - and it's not about all of a sudden, this isn't about taking away regulators' national sovereignty, either. This is about them being part of an international pile of reviews and designs. There will then be, in theory, a process that takes that review and puts it back into their regulatory process. It just skips most of the front end and gets to the back end where you can apply for site license.

Bret Kugelmass
But how many, how much staff would this organization have? Because it's like, I've seen what NuScale had to go through, like 10 years - they say four, but it was like 10 - $500 million worth of- and this is for a very well-characterized technology and a giant bucket of water. Like what's- how could- if it took them all of that time, resources, effort to get, approval, how could this new organization possibly have the resources to license advanced - quote unquote advanced designs - that are not as well-characterized as just a small PWR?

Allan Carson
You're right, resources are probably- the initial intention is that you would reach back into existing organizations, you reach back into the ONR, reach back into the NRC-

Bret Kugelmass
Borrow people and borrow expertise.

Allan Carson
Borrow people and borrow expertise. And actually, a big part of the concept behind this is the working collaboratively and the development of trust. So if somebody from the NRC or from the ONR can work alongside somebody from the ASN in France and understand how they're doing the review process, such that they understand why they've done what they've done and understood what the output is, and they understand the implications of that, then that develop- that collaborative sort of working develops a level of trust, but then when a design comes out of the French regulator, it's a much smoother path through this process, because there are less checks and where you don't require as many checks and balances, because you get to a point where everybody in the room knows what everybody else is doing. And that's- that unfortunately takes time and effort and resources.

Bret Kugelmass
Yep. And then this might take a while to actually get spun up, also, right? Or do you think that there's a pathway to make this happen next year?

Allan Carson
There's not a pathway to make this happen- let me rephrase that. There is a pathway to make it happen relatively quickly. The challenge is the government funding. Just going back to, if you speak to regulators, regulators are generally quite keen to have more international collaboration. They are keen to work together, and they're keen to sort of learn from each other and take on board what they can do. It's how do we make it happen? How do we fund it? How do we get governments interested in making this happen? That's where some of the challenge is.

Bret Kugelmass
Can I ask a question - this might just sound insane, but you tell me - given how important moving nuclear forward is - and I think everyone in the nuclear industry internalizes that and they also kind of see what's been happening these last couple decades and know that things are not going in the right direction - so given that - also given, depending climate issues, and just like general clean energy and energy poverty issues that we know nuclear can solve - is it so crazy to ask people to volunteer 20 hours a week? I understand it's a lot of time. They're working 40 hours a week and I'm asking them to work 60 hours a week. But is it so crazy to ask for volunteers across the world to commit to 20 hours a week for two years stints or something and just say, I'm going to buckle down and I'm going to do this and form a corps, a volunteer corps of 2,000 people in the next few months that are just willing to do it, and then just say, this is too important. I want to leave, I've got kids, I want to leave a legacy of having moved the world forward. I know nuclear technology is going to be absolutely pivotal in doing that. And this is just my duty as a nuclear engineer to volunteer my time. Is that crazy? Is that insane?

Allan Carson
No, I don't think it's entirely insane. I don't think you'll get the numbers you need. I think you will get some extraordinarily dedicated individuals who would be willing to do it, but I don't think you'd get the numbers required. I think one possibility might be- and there's always been a question around what industry's role in this is, because this multi advisory panel sort of sits in the middle of industry, regulators, government, basically. We understand what the government's role is, we understand what the regulator's role is, there's always been a sort of a question around what can industry do to help move this forward? And maybe there's something not too far from your suggestion there, but where there are lots of extraordinarily competent safety engineers in industry. And it's not beyond the realms of imagination that maybe industry can provide some of those highly qualified safety engineers to this honor, sort of a rolling one, if you're based, a monthly basis, etc, as part of a common program, etc, etc. That, I think, is possibly a more realistic route of getting the numbers we need.

Bret Kugelmass
Industry. Yeah, I'm just trying to think of which companies, though, would actually do it. And the problem is the largest nuclear companies that have the people and can afford it are also generally the most conservative and also kind of, I feel like they're just like, they're dying for a reason. And I'm afraid- yeah, I don't know, maybe when you say industry, there are more medium-sized organizations that will be up for the challenge.

Allan Carson
I mean, straight off the top of my head, I was thinking more of some of your engineering consultancy organizations.

Bret Kugelmass
I see, like a Jacobs or one of those.

Allan Carson
Something along those lines. They have extremely competent people all over the world. And there might be- there's obviously something, there's a fair level of incentivization there for them as well to actually do it. Yeah, I understand you're saying, but it's a challenge. We have to find the people somewhere. I guess here's the thing, if we're serious about trying to solve climate change, and we're serious about doing that through the development of nuclear power - which I believe is the only way we're really going to do it in time - then we have to find a solution to that. And there are lots of roadblocks or other problems, and we have to find a way through those. And we have to do it far sooner rather than later, or I'm going to be sat here in 10 years talking to you just telling you that we haven't learnt the lessons from the deployment of the Gen III reactors, we made the same licensing mistakes as we did with the SMRs.

Bret Kugelmass
Yeah, I think at that point, we might as well just all give up and go home, because I think what nuclear has going for it right now, actually, is the climate message. I mean, it's always had the clean air and energy message, but I think that what's really kind of gotten more broad support outside the nuclear industry is the climate message. And in 10 years, we're either going to be at a tipping point where there's a clear solution in sight, or everyone just gives up because it's like literally too late. I mean, it won't be like the oceans are boiling then, like the math will show at that point that there's no going back. I think we have to move quickly, or just say we don't, just like admit we don't care.

Allan Carson
Yeah, yeah, we kind of have to do one or the other, don't we? We definitely have to get off the fence. Yeah.

Bret Kugelmass
Please. Yeah, just tell me more about- let's just switch gears for a second. Tell me more about just what you see happening in industry that makes you- not industry, but just like the nuclear sector in general that makes you optimistic.

Allan Carson
I think this is- I mean, I definitely think the advent of the amount of energy around SMRs at the moment and around the timescales of deployment and the ambition of all of the companies that they're bringing to the table and the enthusiasm and the energy they're putting into the sector at the moment is absolutely fantastic. I've never seen anything like it in the 13, 15 years I've been in the industry. That's really exciting. It's quite empowering. It's good to see that there are so many people engaged, and with so many people interested in it. And I actually think that's helping to drive a little bit of sort of cultural change and change the conversation a little bit around nuclear, because there are a lot more people who are periphery or are actively involved in the industry at this point, so that's quite positive. The other thing that's quite exciting is the amount of work that we are seeing regulatory enthusiasm about working together. We are- there's been signs with the MOC between the US NRC and the CNSC in Canada who are jointly working on some reviews of SMRs and CNSC have also signed in the MOC with the ONR. It looks like there might be some joint work there at some point in the future, hopefully, as well. That international sort of collaboration is starting to take some sort of shape. It feels a little bit like we're at a tipping point with it, where we need to kick it into the next gear, and then see where it takes us, or it will sort of settle itself back down again, and it won't go anywhere. That's kind of exciting that we're trying to drive that at the moment.

Bret Kugelmass
Allan Carson, everybody. Thank you so much for taking the time.

Allan Carson
Thank you.

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