Steven Arndt

Bret Kugelmass
We are here today with Steven Arndt, who's a distinguished scientist at Oak Ridge National Labs and the President of the American Nuclear Society, the incoming President. Steven, welcome to Titans of Nuclear

Steve Arndt
I'm President Elect.

Bret Kugelmass
President Elect, okay, yes. Well, welcome to Titans of Nuclear.

Steve Arndt
Thank you.

Bret Kugelmass
Yeah, I'm super excited to hear about your career. I mean, I know you spent so much time at the NRC and I'd love to get into all of that, but before we get there, what interested you in the nuclear space earlier in life?

Steve Arndt
Well, it's kind of an interesting story. My father was an engineer, is an engineer, and he started out his career in the aerospace business. He went to Ohio State University, which is a good Midwest school, and when I was in high school, I was thinking about a number of different possible careers. I decided on engineering with the possibility of physics. I kind of wanted to be a physicist, theoretical physicist and my mom said, Well, you might want to hold your options open. They don't have that much call for theoretical physicists in the world.

Bret Kugelmass
Sounds like my mom.

Steve Arndt
So, I also went to Ohio State. I studied physics. After my first year, I entered a program called Engineering Physics, which is basically a physics degree with a bunch of engineering courses thrown into it that is taught actually out of the engineering college, something that I found out was a peculiar idiosyncrasy later in my college career. When I went to get my math minor, when I was doing my graduation paperwork, they told me, I couldn't have a math minor because I didn't have enough foreign language, because math was taught out of the arts and science college that had different requirements there than the engineering school. Anyways, I got my degree in Engineering Physics and while I was a senior, I started looking at the different options, because I knew I wanted to go to graduate school, and one was theoretical physics, but I had taken some courses in my engineering side when I was a junior and senior in undergraduate school, and those courses were in nuclear engineering. It was really fascinating. I had some really good professors. One in particular, Don Miller - very talented guy, who also went on to be President of American Nuclear Society - and he kind of convinced me that I should be a nuclear engineer. I think a lot of the decisions throughout my career have been very impacted by the really talented and very generous mentors I've had throughout my career. That was basically the first big one that got me interested in nuclear engineering in the first place. I went on and worked with Don and several other faculty members at Ohio State throughout my graduate career and went on to get a Master's and a PhD at Ohio State in nuclear engineering

Bret Kugelmass
And that's a great program, too. What did you focus your PhD on?

Steve Arndt
My Master's was actually on the theoretical instrumentation and control stuff and I started my PhD doing that, but I ran into some problems and some challenges along the line. I had done a lot of statistical methods in developing new instrumentation methods, so, I also took some courses in probabilistic safety assessment and in some of the policy issues associated with PRA and the Safety Goal Policy Statement that the NRC put out in the early 80s. And so I did my PhD on off-site consequences, basically Level Three PRA as well as the impact that has on how you assess the safety of nuclear systems.

Bret Kugelmass
Can we dive into that for a second? When I looked at the three levels of PRA, and I saw so much focus on PRA Level One, trying to prevent the accident from happening altogether, my first thought - and tell me if I'm crazy - was, why don't we just put more focus on PRA Level Two, let's say, by building a beefier containment, and PRA Level Three, let's say putting it in the middle of the desert and save all the money on PRA Level One, is that a crazy idea?

Steve Arndt
Not necessarily it's basically a design decision and it has a lot of impact on all the different other decisions you have to make. Obviously, if you put a reactor in the middle of nowhere, you have much lower potential off-site consequences, but at the same time, it's more expensive to build, it's more expensive to operate, because you don't have the infrastructure there, it is more expensive to move the electricity into the grid. So, there's some distinct downsides as well. Same thing for Level Two, there's a lot of expense and engineering that goes into a large containment. You look at a lot of the new modern, advanced designs, they really are going toward having a smaller containment or smaller parts of that, because of the cost of concrete and the cost of that kind of design. But the real trick to any of this is, you have to look at an integrated design philosophy, and not just for building the reactor, but the entire lifecycle of whatever kind of energy source you're looking at. That's actually one of the things, I think, is extremely important in a modern energy concept, is the look of the lifecycle of costs - not only on the dollars and cents of mining the fuel and transporting it and building the reactor or whatever other energy source you're looking at - but also things like, what's the cost of safety? What's the cost of transmission of electricity? What's the cost in terms of the social impact? And if you look at the NRC Safety Goal Policy Statement, one of the things that they don't emphasize as much as they do the safety aspect of it, is that it should be as safe as the next logical energy producing source that would be your alternative, so, hydro, or gas, or solar, or whatever. And that's something I think we need to do a better job of.

Bret Kugelmass
Okay, I was gonna ask you, because, throughout the many conversations I've had, it seems that a common theme is that the nuclear industry doesn't just go as safe as the next one, they go 10x more, either out of a feeling of, Hey, we need to do this, otherwise, we won't have a social license - which I don't believe - or maybe just built into the culture, built the engineering culture, the operations culture, where it's like, if we can add that one extra thing to get that extra 10 to the negative 6, 10s, and negative 7, 10 to negative 8, we should do it no matter how much it costs. That seems to be the culture that's in place now. What are your thoughts on that, on the difference in those goals?

Steve Arndt
Well, I think that certainly is part of the challenge that we have in nuclear. A lot of that that, I think, was built up when there was much higher uncertainty of the phenomena, back in the in the 40s, and 50s, and 60s. Something we don't talk about a lot is, if you don't know as much about a technology, or if you don't have as good understanding of its consequences, then you build in safety factors. That kind of engineering concept goes back hundreds of years. Early in our business, we did that. Unfortunately, that became very, very structurally embedded into how we do our work and as we've learned more, we've updated the engineering codes, we've looked at improving the way we do the analysis, and we know so much more about the phenomena now that we can do a very, very good job of understanding where those uncertainties are and how narrow or broad those uncertainty curves are, and in many cases do a much better job of not having to layer safety on top of safety on top of safety. There's actually a very good study a few years ago at MIT that looked at that overlap of, well, if you're doing this and you have a safety margin for the concrete, it's this much. And the safety margin for the steel that sits on the concrete is this much. And the instrument that hangs on the steel that sits on the concrete... And you don't need to do that. It doesn't make any sense. In some cases, it's actually counterproductive. We're working at that right now, it's one of the areas that has a lot of very positive research and analysis right now and a lot of the new advanced designs are looking at that and saying, Look, let's reassess. We don't have to have a super great this, and a super great this, and a super great this. We do need to have some diversity, but we don't have to have everything at this super high level. That's just overkill.

Bret Kugelmass
Did you see - from when you came into the NRC to the time that you left, I mean, quite a long distinguished career there - did you see a change in the culture and the attitude along these lines and like the progression of the ideology of how, from the regulator's perspective, not just from a designer's perspective, did you see that over your career?

Steve Arndt
Oh, yeah. I've been extremely fortunate. As you mentioned, I had a 31 year career at the Nuclear Regulatory Commission. Throughout that time period, I got to work on a lot of different interesting projects - and I'll talk to you a little bit about a couple of them as we go on - but one thing that we did do, and I was involved with certain aspects of it, was to look at a lot of the ways we evaluate designs. The NRC's mission, really, is to have that review process to regulate nuclear technology. What we really do is provide that reasonable assurance that the design and operation is safe. As we've moved forward, we've used more advanced tools like probabilistic safety assessment, to try and get that balance correct, but we've also improved our quality of analysis. We can look at something and say, You don't need a safety factor of five, you can do a safety factor of two, and it's perfectly good, and in many cases, just as safe, because we've reduced the uncertainty. One of the projects I was involved in, in the late 90s and early 2000s, was the measurement recapture of instrumentation upgrades. That really is an interesting story, because, back in the 60s, when we were starting to do the structure of the regulations, we basically said, Let's assume we know the actual power in the reactor to 2%. When you actually do the calculation to figure out how much actual megawatts you're producing, it's done with the steam flow, because that's what's actually going out to produce the energy. But then you have to back that calculation to calibrate the actual instruments that are reading the neutrons. When you do that analysis, you have to make certain assumptions on the accuracy of the instruments. At the time, we didn't really know how accurate some of those instruments were. They were things like flow meters and temperature gauges, RTDs usually. We basically sat down with a bunch of smart people and said, probably about 2%. So, you reduce the neutron power by about 2% so that you don't accidentally go over. Well, in the late 90s, people were saying, Well, there are more accurate ways of measuring - as it turns out, feedwater flow is the most critical of those parameters, there are others in there - and there's much, much more that we can gain by simply improving the accuracy, demonstrate the accuracy, you can get a percentage, a percentage and a half more power, simply because you have better accuracy. Now, that's an operational issue, but the same goes for a lot of the safety issues. You can look at the various analysis that we do, either operationally like the flow, or from a safety standpoint in the system codes, and you can improve things. You can make them safer and you can make it more economic. Through that 31 year time I was with the NRC, we did a lot of that. Some people don't really realize how good the engineers are at the NRC.

Bret Kugelmass
Yeah, I bet.

Steve Arndt
Many of them are some of the best in the world.

Bret Kugelmass
I bet. So, tell me, what was the arc of your career there? What were the various roles that you held, from beginning to end?

Steve Arndt
Well, I started out, I did a very short period where I was working on the staff of the Advisory Committee on Reactor Safeguards. I did that for about eight months, then I took a short hiatus while I was teaching at the United States Naval Academy. Then I came back and I spent a couple of years in our Emergency Operations Center organizational staff, working with them on training and how to do drills and things like that, and actually supporting the management there. Then I went down to our Chattanooga training office and I spent about six years there working on improving the training that the NRC does for its own staff. Most people are familiar with the training that engineers and operators get at utilities and a lot of that is extremely extensive. Well, the Nuclear Regulatory Commission has a similar kind of training program for all of our inspectors. The people actually go out into the plants, and either are resident at the facilities or go there for special inspections. Our training courses are similar to the operational training courses. They're not the same, because we don't operate plants, so, we don't have the level of detail of operations that operator we get, but we also need to understand what they're doing and how they're doing it, what decisions are being made. And also, we have to understand how the plants work. Some of our new people we get from industry, some we get from the Navy, the nuclear program there, some we get from engineering firms. So, we have a training course for all of those people in reactor operations. It's a very good course, we own our own simulators and it's a very good course. One of the things I was supposed to be doing while I was down there was improving the realism of some of that training, so, I did some of that work. It was also in the early 90s, and we were trying to improve our training on courses like probabilistic safety assessment, as well as things like the newer technologies and digital and fuels and things like that. I spent a lot of time working on that, as well as interfacing with the rest of the organization on what was really needed. Also, while I was down there, I got involved in a really fun and interesting project that most people don't remember anymore. Of course, early 90s was the breakup of the former Soviet Union and when they broke up, they had a number of different issues, and one was the strategic nuclear issues, the missiles and all that kind of stuff. But they also had a real challenge because, of course, post-Chernobyl, their regulatory structure for their civilian nuclear business was a mess. The regulator obviously had not done a particularly good job in Chernobyl.

Bret Kugelmass
To say the least.

Steve Arndt
To say the least. And now they had two new countries, Ukraine and Russia, that had always been part of the Soviet Union, but never functioned autonomously in terms of government structures. While Secretary of State Baker was doing all the non-proliferation negotiations, he also worked with Russia and Ukraine to sign this little agreement to say, If you want, we'll help you try and put a regulatory structure together and we'll try and help the plants as well to get their safety act together. The program was managed by the USAID and implemented by NRC and DOE. I was one of the leaders of the NRC program, so, I got to spend, oh, probably about four or five years, in the early to mid 90s going over to Russia and Ukraine.

Bret Kugelmass
Did you pick up the language during that time?

Steve Arndt
A little bit, not much. And it goes away very quickly.

Bret Kugelmass
Because they spoke English?

Steve Arndt
Many times they did. The State Department provided us with a translator. So, I did that. And sometimes it was all equations and math terms anyway, so, it was just as easy to point and say this and that. I worked with the Russian and Ukrainian regulators for about four and a half years, trying to improve their capabilities in certain areas. Sometimes I joke that I must have done too good a job because they're selling reactors a lot better than we are now. But it was a very interesting time and we learned a lot about their programs and their early VVERs and RVMKs. We taught them about how to structure a regulatory program, how to structure a training program, how to improve the safety processes. We did a lot of work with the plants on their simulator training and improving that. It was an interesting time. In the late 90s, I transferred back to Washington into our research group and I spent a fair amount of time there. I started out working in the human factors area.

Bret Kugelmass
When you say research group, is this internal research for the NRC to kind of understand technologies better, or is this research reactors versus power reactors?

Steve Arndt
The NRC has their own Office of Nuclear Reactor Research. Unfortunately, the acronym is Nuclear Reactor Research, NRR, but we don't call it NRR, because that's the other part of the agency. So, we just call it RES. But it's a medium sized group - it was a little bigger when I was there than it is now - but its purpose is to support the regulatory part of the agency in developing codes and standards, developing technical basis, in some cases, developing analytical tools like RELAP, TRACE and things like that.

Bret Kugelmass
RELAP which is like a thermal hydraulics code?

Steve Arndt
Yes, RELAP and TRACE are thermal hydraulic analysis codes. But they're also doing fuels research and human factors research, instrumentation and controls, a lot of PRA work, lots of analysis of how the engineering standards should be applied, and things like that. I spent a little bit of time working in the human factors area there, and then a while in the accident analysis area. I spent most of my time in the instrumentation and control area, because I had done that in my Master's work and it was an interesting area, and they needed somebody to work in that area. During that time period, we were really struggling with the introduction of digital systems into nuclear power plants.

Bret Kugelmass
Why is that? Why was it so hard, given that, digital systems weren't new to the rest of the world, and they weren't even new the power sector - every other power plant uses digital controls - why was it so difficult to certify them? And just to give some context, I think only one plant, maybe a Duke plant, only one plant in the whole country ever upgraded to digital controls. Is that right?

Steve Arndt
That's a bit of a misnomer. The Duke plant, it was Oconee, did do a very extensive upgrade of their reactor protection system and engineered safety function system. That was done a few years ago, but pretty much every plant has integrated digital systems. Most of them are not for the reactor protection system. When you say digital system, you have to be a little careful, too, because less sophisticated digital systems, TTL logic and things like that, have been in the plants for years. We're talking about the more sophisticated software driven type system

Bret Kugelmass
Like an operating system.

Steve Arndt
Yeah. They're obviously not exactly like operating systems, because they have to be real time and they have to have interrupt driven systems that will respond in very high reliabilities. The real challenge that we've had for quite a while, although I think we're pretty much past it now, is it's very hard to model software and how software performs or doesn't perform. Most engineering analysis is based on two things: one, you can model the system and how it works and doesn't work, and from that model, you can determine if you got a good safety margin edit, or alternatively, in a pure sense with the reliability of the system is. That's a lot harder to do with software than it is with hardware. And there's a number of reasons for that.

Bret Kugelmass
Why wasn't it as simple as just calling up like, Rockwell Automation or Honeywell and just saying, Hey, you've got systems in 1,000 coal plants, we just want to use the same one, we're going to use the same inputs and outputs, same sensors, same interrupts, just tell us, do these things freeze up, or do they not freeze up?

Steve Arndt
Well, that is one of the things we did. I think part of the problem - and this is not a I&C unique issue - is a lot of the nuclear systems were built as one-offs, they were not generic, they weren't commercial off-the-shelf type things. The principal reason was because of the quality assurance requirements. I think we are doing more of that now, one, for cost reasons, but two, for experience reasons. We have more experience with the systems that are high quality in other industries. At over the course of the last 15 or 20 years, we've gotten a lot better at qualifying commercial off-the-shelf systems. There's a couple of projects that are actually ongoing right now, many of them have just finished and some of them are just finishing up. There's actually going to be an article in nuclear news - I think it's the June issue - that talks about this whole thing. It's been a challenge because of that and we put a research plan in place in the late 90s to try and develop some of these ideas, both in terms of measuring the reliability of these systems, as well as understanding what really is important and what's not important, because that's really the biggest challenge the regulator has. You can't worry about everything at the same level of detail, because if you worry about the unimportant things, you're never going to get a license. And if you worry about the important things, then you can't move the process through relatively quickly. That was one of the biggest concerns in digital was that it was taking quite a while to work through the process. It wasn't that we were actually denying applications. Actually, we very, very seldom do that. It's that it was very difficult to demonstrate the safety and reliability of the systems.

Bret Kugelmass
I don't know what it's like, between an applicant and the regulator, but, just stepping into the applicant shoes, it seems to me that, dragging a review on forever, and with all the fees and everything and the time that it takes, is effectively the same as denying an application just from a business economics perspective. So, I feel like it would be very frustrating, from the position of the vendor to be just waiting around while the capabilities are developed or the assurance is built up, when it's like, Hey, this is like real dollars and cents on the lines. Why can't you guys just- like you said - and I believe it - some of the smartest engineers in the world work at the NRC, but can't you guys just take a common sense guess that it operates in 10,000 coal plants, but just put your stamp on it, it's fine.

Steve Arndt
That's always the challenge. Over the course of the last, say, 20 years, NRC has gotten to be better and better at doing that. To be fair, I wouldn't characterize it quite the way you did. They're really trying to get that reasonable assurance. And as we get more experienced with something new, as we know more about something new, we find out different ways of getting to that reasonable assurance, whether it's experience in other industries, or it's more experience in the nuclear industry, or it's better testing methods, or better analysis methods. As you do this more, you get better at it. And as you get better at it, you get quicker at it and more efficient and things like that. In the digital area, it was more challenging than most, but we've had challenges in other areas as well. One of the biggest challenges that I was ever involved with was the severe accident analysis area. And that was in the late 90s, as well. We were really, at that time, trying to decide how important designing for severe accidents really was, because again, we didn't have a lot of data - fortunately - we didn't have the best analysis tools. There was a lot of debate in the industry as to how important it really was. Some of our international colleagues were saying, You really have to over design in case of severe accidents. Of course, this was post-Chernobyl and there was a lot of concern in the industry, and particularly in Europe, about the need to over design in the area of severe accident mitigation. Similar to the first question you had about, where do you put the emphasis, is it in containment, is it in off-site consequence, is it in other areas? So, they were really beefing up the requirements in Level Two containment type stuff, that's where core catchers and things like that came from. So, we ended up, through some experimental work at Sandia, as well as analytical work that we did, saying, it's really not that necessary, particularly for the kinds of plants were licensing and the things we were looking at.

Bret Kugelmass
And it really wasn't that necessary for which reason? For the reason that the preventative work was so strong that it was unlikely to happen, or for the reason that the consequences are not as bad as we once thought they were?

Steve Arndt
It's both. At the time, we were really looking at the preventive methods were really driving down the likelihood. We learned later, through a research program that the NRC did looking at off-site consequences specifically, that those were really very, very small. And it turned out that the decision we made based on one reason proved out to be true based on that and other reasons.

Bret Kugelmass
Can I double click on that? The research that showed that the off-site consequences were small... when did that realization happen and how come that didn't lead to an overhaul of the entire theory of why nuclear is in this totally different classification in terms of risk and requirements than every other energy source? Because I came into nuclear industry post-Fukushima, and I looked at it in the way that the off-site consequences are not that bad, no one died from radiation. Why is nuclear subject to such extreme care at all?

Steve Arndt
There are a number of reasons for that. To answer the first part of your question, throughout the 2000s, there was a lot of work done, both from a policy statement, as well as a science standpoint, that looked at past accidents like Chernobyl, that looked at what really fails and what really gets out of the pressure boundary, into containment, out of containment, into the environment. There are a lot of mechanisms that you could look at, like the filtering that occurs in containment, the chemical interactions that occur in containment, that really knocks down the source term.

Bret Kugelmass
Yeah.

Steve Arndt
From a realistic standpoint, if you look at even really bad accidents, which are very, very unlikely to happen, the off-site release, let alone the consequences, are going to be very low. The real issue is that the people who make the decision - and when I say the people who make the decision, I phrased it that way, because it's a broad group of people who make decisions associated with radiation consequence, the NRC is certainly part of that, EPA is part of that. The Air and Water Group at EPA set the radiation standards. Look at the international community as well, look at the standards associated with that. The analysis methodology for off-site consequences, which is in large part based on the linear no-threshold model, which is an, admittedly, very conservative model, particularly for low dose. Then there's the public as a whole, because they are willing to accept the consequences of having very conservative regulation. Obviously, Joe Public doesn't make an active decision, but by not encouraging his representatives to change that, they're making a passive decision that it's okay to be over overly conservative in a lot of these areas.

Bret Kugelmass
Can I push back on that? I think you're right, that's how it structurally works, but I think that the nuclear industry takes that as a license to assume the worst. They say, Because nobody in the public is standing up and saying, We want nuclear, that the public is just so terrified of nuclear, that we have to go so far above and beyond what every other industry does. My research into the social science around energy systems and public acceptance actually shows the exact opposite. It shows that the more accidents that happen, like with natural gas, every day, people become numb to it. And people just don't care. It's when you make something, it's when the government steps up and says, No, we're going to go the extra mile to protect you, that that puts the thought into the public's head that Oh, it must be that much worse. Otherwise, they would do this with every other energy source.

Steve Arndt
Yeah, and there is a whole science of looking at that kind of concept. Professor Modarres at the University of Maryland has published extensively on that, and that's the whole concept of what makes something a more fearful type accident, be it a car accident, or an airplane accident, or an industrial accident, or whatever and the lack of familiarity, it doesn't happen very often kind of concept, adds to that. I think you touch on an important point, because, we as scientists have a certain responsibility, not only to do good science, but to let people know what that resolve is. You can go overboard on that, obviously, but it is the responsibility of scientists. Just like we had the responsibility during the recent pandemic, the continuing pandemic, to say what the real science really tells you. I think that's exactly the same case in terms of energy science. We as scientists have an obligation to speak up and say, Nuclear is not nearly as as potentially hazardous as most people think and in many cases, the structural requirements have dictated. Looking at that is extremely important.

Bret Kugelmass
I guess my question is, we've known now for over 20 years that the off-site consequences are just not as bad as we used to assume that they are. Fukushima really taught us that you can have the absolute worst, three gigawatt-scale core meltdowns of a light water reactor, the roof got blown off from a hydrogen explosion, and still, not enough radiation was spread into the public to hurt anybody. So, now we have empirical evidence, we have all of the studies that have been conducted for decades, we realize, after Chernobyl, that it wasn't a whole potluck of different radioisotopes that got through the biological pathways, it was just iodine-131. So, we have all of this evidence, was there ever a conversation at the NRC that, maybe we don't need to charge a new reactor developer $1 billion to approve their design? Maybe we can do it for $10 million?

Steve Arndt
Yeah. Part of the structural cost is dictated by Congress. So, I'm not going to get into Congress. But the concept that we don't need to be as intrusive as we once were, has been discussed a number of times, all up and down the layers of the Commission. And just for your audience that may not be super familiar, when you speak of the Commission, there's a large "C" commission and there's a small "c" commission. The Commission is the five presidentially appointed commissioners that have policy responsibilities, and then the commission staff is basically everybody else, the roughly 3,000 employees of the Commission. When you say, has there been a discussion at the commission, the answer is, yes, there have been discussions at the Commission, large "C", but there have also been discussions at the commission staff level, from junior staff all the way up to the senior staff of, What should we be doing as stewards of the public good in terms of interfacing with licensees and applicants for the development of licenses? One of those things is, can't we do this more efficiently? Because most of the cost is driven by the amount of time it takes us to actually process an application. Because we're required by congressional mandate to charge for our time. Something that most other regulatory bodies don't think about.

Bret Kugelmass
So, yeah, let's assume there's no way around that part. To me, it's just like, let's say, a company like NuScale comes to the NRC with an application, and this is post-Fukushima, and this is after we know all this stuff - tell me, I'm just so ignorant in saying this - but, what I would have done has been like, okay, we can calculate your decay heat with extreme accuracy. Because it doesn't need to be extremey accurate, we can do plus or minus 10% back of the napkin today, based on the fact that it's some 5% enrichment. Okay, we know your decay is going to be in the worst case, we know how much thermal mass you have from your big steel vessel, you're in a giant pool of water, we can calculate the roof, Alright, you with the NRC, you're the structural guy, give me this number, your decay heat guy, give me this number, you're the water boiler guy, give me this number. Tomorrow afternoon, we're going to come with our numbers and see if this, even in the worst case scenario, if anything's gonna get out of the building, and - tell me if I'm crazy - but I really think the whole application could have been done in a day based on those three calculations, which any good engineer - I don't care if your a nuclear engineer or you're not - any good engineer can open up the reference textbook and just do the math. I know it sounds crazy, but why wasn't it like a day approval process?

Steve Arndt
Well, I think we are moving toward that. If you look at, as an example, the rules we use for research and test reactors. As you know, research and test reactors are specifically designed to have incredible margins because they literally don't want to have to worry about the kinds of things that power reactors do. and they can't afford to anyway. They have thermal margins that are just crazy, they have a very small amount of fuel, basically some of the things you just mentioned. And because of that, we have a much lower regulatory footprint for those. In terms of power reactors, like NuScale, or others, they're still trying to optimize their amount of power versus the amount of concrete or power versus the amount of water. They're not as conservative as you might think, just a quick calculation.

Bret Kugelmass
Yeah, I get it.

Steve Arndt
But we are trying to look at how you structure the review of these systems, so you don't really worry about things that are never going to be a problem. We're trying to de-emphasize, and hence make shorter, the reviews of things that don't really matter.

Bret Kugelmass
And could one go to the research reactor group to license a power reactor and saying, Listen, we want to use your process, your standards. There shouldn't be any problem from a safety person, I mean, safety is safety at the end of the day, what do you care if I hook a steam turbine up to it or not, If I want you to just hold me to the same standards as the research group. Could someone literally say I want to license a commercial power reactor with your research team, with a research regulator team?

Steve Arndt
There actually have been people who have looked at that possibility and depending on the real hazard that exists, what the source term would be and what the off-site consequences would be and things like that. People have said, We're just like these guys. There have been some people who have looked at that concept. And the NRC is entertaining that, we're looking at-

Bret Kugelmass
Someone could ask to do that and they wouldn't be laughed out of the room?

Steve Arndt
No. And if you actually look at the rules in the Atomic Energy Act, there are some specific things that trip you into certain review standards and certain things that you can't do under certain other review standards. But within the law that has been established, the NRC is looking at the regulations, which sit on top of the law, to be as flexible as we can, which is the whole process that's going on right now to re-evaluate advanced reactor licensing, and maybe make it much more risk-informed, much more hazard-based, much more performance-based, and try and do that. One of the challenges is - and NuScale, for example, but some of the other small modular reactors are also going through this - is that, if we haven't done it that way before, we kind of have to write the procedures as we go and that, in some way, slows us down a little bit. But there's an active effort underway at the NRC to look at that.

Bret Kugelmass
And just structurally, how does it work? If someone is going to bring something a little less standard to the NRC, does it require the overarching commission to rule on it? Or can it can you essentially do it just with the day staff, the lifers, unless there's an issue of national security or national importance or something?

Steve Arndt
That's actually not a bad way of phrasing it, I wouldn't phrase it quite that way. Basically, when we change a regulation, the Commissioners have to approve that.

Bret Kugelmass
But what if you just file for an exception to a regulation?

Steve Arndt
So, there's a tier. If you want to change the law, you have to get Congress to do it. If you want to change the regulation, you have to get the Commissioners to do it. Below the regulation, you have exemptions and things like that. You also have regulatory guidance, which is basically, This is how we're going to interpret the regulation in these cases. Those can be obviously accepted by the staff. And then below that even, there's stuff that the licensee can do without bothering asking us.

Bret Kugelmass
Like what, what's an example?

Steve Arndt
Well, that's basically the 50.59 rule, which is basically a rule that we put in place when the regulations were first established that basically says, so long as you don't violate your licensing basis, you can make small changes to your plant without having to ask us. There's a set of criteria that would qualify it as within the scope of the rule or outside the scope of the rule. There are things like, is this going to significantly change the safety of the system? Is it going to present a new hazard that didn't exist before? Will it be something that the NRC would want to look at before you change it? It was put in place intentionally so that, you have a pump that breaks and you can't replace it because they don't make that pump anymore. But you can get a pump that's basically the same thing. Do you have to ask us? Well, the answer's no, you go through the test, there's no change in reliability, there's no new hazard, just go do it. But you have to record it and have the paperwork and things like that. There's a whole tier of things, depending on how small it is, how much of an implication it might have to your license, and whether or not it's been previously evaluated, that we can, with review, accept. One of the challenges with new and different things is, we either have to do it as an exception to what we already do, or we have to change the process as we go. The first movers are sometimes a little penalized, because they had that extra effort to change things as they go. Yeah. That's why everyone's joke in the business is everyone's racing to be second.

Bret Kugelmass
I lost my train of thought, I was gonna ask... Certain things that are not, let's say, safety related, how hard, for instance- I went around asking, how come these plants that are shutting down, maybe because they didn't get incentives from the state or this or that, there are all these incentives, let's say, to create green hydrogen now. Why can't we just take the facility, keep producing heat out of it, install a tap off the main steam line and build a hydrogen facility right next to it, and be like, this doesn't really affect the safety case, I still have my backup diesel generators, I still have everything, just installing a tap off the main safety line. And they were like, Oh, that's too hard to get through regulations. Is that one of those things that should be able to get under this 50.59 exemption?

Steve Arndt
It really depends a little bit on what part of license it may or may not affect. I haven't looked at that specifically, so I can't give you a definitive answer. I know a couple of plants are looking at doing pilots in the hydrogen generation and a lot of that stuff you can do under 50.59. A lot of it will require a very small change to license that can be done relatively quickly. For example, if you have to change the unavailability of an auxiliary steam system or something, then that might require a change in the license, but it would be a small thing that could be could be done relatively easily. I think one of the challenges that the NRC has had historically - and I think it's slowly getting better - is this concern that the licensees have, and it's a reasonable concern, that things would get tied up at the NRC, things will not move quickly, we won't be cognizant of their needs to have something done before refueling outage or something like that. Years ago that was more true than it is today. Today there's a very strong desire to not impede the industry. Obviously, the regulators are there to do the responsibility that they have to the public and, as long as you do that, as long as you're doing a reasonable job to ensure adequate protection, then you should be getting out of the way as much as possible. There's a desire on the NRC staff to do that much more so now than there has been. Most of the people who work at the NRC are engineers, and they want to see something built as much as anybody else.

Bret Kugelmass
One other topic to touch on that I know comes up as a point of frustration from a lot of utilities I speak to are the security requirements, having to maintain such a large security staff. Once again, when we kind of readjusted our potential top potential consequence, why wasn't that like a very easy petition for a utility to file to be like, Listen, if someone was gonna launch an armed attack on a facility, literally every other facility, more people would get hurt, compared to a school or an office building or something. Where there are real people inside the building. If there's an armed attack on a nuclear facility, worst comes to worst, there's no one inside the containment room, the systems are going to shut things down, so, why wasn't it a very easy request for utilities to say, Let's drop all this 9/11 extra security nonsense?

Steve Arndt
Security is always a challenging thing, because you don't have the same kind of reliability or frequency kind of calculations that you can do for an engineered system. It's all based on getting in the heads of the adversary and that's obviously not a trivial kind of thing.

Bret Kugelmass
Right, but I still don't understand even the idea. What are they going to go in with a team 1,000 engineers, like 1,000 outage engineers and unscrew the cap before the police caught wind of what's happening, I don't get it.

Steve Arndt
I can't get into that kind of thing in this kind of recording.

Bret Kugelmass
Yeah, that's fine.

Steve Arndt
But there is an active program looking at what is referred to as the design basis threat. That's something that is assessed both by the licensee and by the NRC and it's an active area of discussion, particularly for advanced reactors, where potentially they have even lower consequences.

Bret Kugelmass
Right. And I see a lot of the advanced reactor companies bringing this up and making a fuss about it. I guess my broader question before was like, Why don't the existing utilities do it? Let's say, I'm the CEO of a utility, I'm looking at my - forget security, because that might be too sensitive - but I'm looking at my budget for "x" personnel that I think don't need to be there. We're talking many, many millions of dollars a year. I could make a case to the NRC for less than many, many millions of dollars a year to have this rule relooked at, but I feel like it just doesn't happen that often. Is it just the utilities are just so set in their ways, they're like, if it ain't broke, don't fix it, let's just not fight back.

Steve Arndt
Many people understand that the rules exist for lots of different reasons. In the purest sense, they exist because there's good science that says, if you do it this way, it'll be safe. Rules exist for other reasons, both technical and policy. If you look at the waste management rules, for example, any good scientist would say some of those are not very scientifically based, but they got that way because of public opinion and Congress and policy reasons. The same, I think, is true of some of the other areas that we've discussed. The security is certainly one of them. The science is not as good and the politics are worse, shall we say? Can a utility or utility group or a set of scientists pushback on those? I think that's a viable option. But that becomes a business decision as to whether or not it makes sense for the utility to do that, what's the upside versus the downside. Some utilities, when you work with them, are have a different perspective. I won't name any names, but there are certain utilities that will always push back on the NRC and there are certain utilities that will never push back on the NRC. That's obviously an exaggeration, but if you work in the business, you know what those utilities are. That's a corporate decision that they've made, there are certain vendors that will push back more than others and that's a corporate decision that they've made. As a scientist, I think if you don't agree with NRC, you should say, Hey, that's not the best decision you can make. You should look at this data, you should look at this analysis and we can come to a better solution. But science is only one input to the corporate or governmental decision making and it should be an important one, but there are other things that influence how people choose to do their business.

Bret Kugelmass
Well put. I want to make sure we have time to kind of address what's coming next in your life. I feel like we could talk about this topic forever. Maybe we'll have to just have another conversation about this, because you obviously have a lot of experience and knowledge to share across many of these topics I've been very curious about, but I want to hear what's happening now for you with ANS and what's coming next in the next chapter of your life.

Steve Arndt
Well, it's a interesting time right now. As you probably know, I left the NRC about a month and a half ago, and I'm now working at Oak Ridge National Laboratory as a Distinguished Scientist with them. At least for the next few years, I'm going to be working with them looking at the advanced reactor technology, looking at some of the concepts associated with readiness to move to final design and construction, which has been a bit of a challenge for some advanced reactors, looking at some of the licensing issues from a science standpoint. That's going to be fun and exciting work. In terms of ANS, of course, I just was just elected President Elect of ANS, so I will take that role in June and then become President in June of 2022.

Bret Kugelmass
Yeah, that's right, it's a year staggered, three year staggered thing. Okay. Yeah.

Steve Arndt
Right. There are a number of things I want to do in the policy area, in both job descriptions, both hats, if you will. As we've discussed, there's going to be a lot of really good new technology coming into the industry in the next five years, be it advanced technology fuel, be it more digitalization of the plants, a lot of the potential for tighter integration with the grid and renewables. There's a lot of exciting new technologies that look at energy storage in combination with nuclear. All of these things, and lots of others, are things that we really need to make sure people are aware of. ANS has a great educational program at the elementary and high school area. I'd like to expand that into general public information and get people to be thinking about these kinds of things, so they can be better energy citizens, if you will, and interface with, not only their utilities, but also their public figures, the congressman and things like that, and be more active in the national decisions about energy.

Bret Kugelmass
Why is it so hard? I see the threat against the nuclear industry as existential at this point. I mean, never before has nuclear been more needed in society and we're just shutting down reactors like it's nobody's business. Given that we still have a workforce in the US of I don't know, what is it over 500,000? How many people are in the nuclear industry?

Steve Arndt
It depends on how you do the math a little bit, but and whether or not you count medical or not, but it's at least half a million.

Bret Kugelmass
I don't understand, why isn't it that we just don't call up every executive at every major nuclear company - there are only a few 1,000 of them - have them rally their troops, every one of their workers, and why don't we rank make 500,000 calls next month, telling every congressman 1,000 times over how important the nuclear industry is to clean energy, national security. I don't understand why it's not every single person in the nuclear industry raises their voice at the exact same time. Look at what the the coal industry is, like 80,000 people they took over an election. I don't understand how it's so hard to get 500,000 nuclear people to just raise their voice and actually show politicians how important this is.

Steve Arndt
Yeah, I think it's very important. It's obviously a little challenging to craft a message that you can get everyone to support, and you don't want to water it down too much to get too much inclusion at the expense of good science and good policy. But I agree with you. One of the biggest issues I have - and it goes back to some of my early research, but also, what's going on in the in the world - is, we should have everyone playing on the same level playing field. You look at whether it's regulation, and the cost of regulation, whether you look at incentives, however you want to phrase incentives, you look at pollution and waste, you look at all the different things associated with the energy industry. If you made everyone play on the same level playing field associated with all those things, then it would be a lot easier to say, Look, these are the attributes that are worth paying for. These are the attributes that are important to us. And a lot of times the message gets muddied, because we're saying, Compared to so and so, we're good. And we shouldn't be doing that. We shouldn't be saying, We've got a great technology, it can stand on its own, if everyone plays on a level playing field and these are all the great things we do. And if we do that, effectively, as you say, get everyone out there with a good message, then I think we'll have a more level playing field, and we'll have more support. There are a lot of people out there right now, sending that message or a similar message. I know I'm going to use my platform, as ANS president to send that message to the extent possible. I think it's a little challenging, because a lot of the people we want to bring into the fold, help us send the message, are a bit conflicted. Some professional societies, broader professional societies have previously jumped into the bandwagon with other technologies, so it's a little hard to pull them into the nuclear technology. Some of the utilities don't want to get too far out on a limb, because they don't want to say something negative about some other energy source. It's a complicated area.

Bret Kugelmass
It's complicated, but I think the way that you phrased it, it was just perfect. I mean, literally what you just said was perfect, like level playing field, here are all the things that are great about nuclear. That is not controversial. I'll say it again, I don't think we should have any less than 500,000 people call their senators, call their congressmen and just say the word the words exactly as you just said them. It wouldn't take too much time out of their day, and they should realize their livelihoods are at risk. Five plants just got shut down. This is a critical moment. Pick up the phone and say the exact words that you just said. Sorry, that was me on a rant. Sorry. You got me excited.

Steve Arndt
I'm trying to get people excited.

Bret Kugelmass
That's awesome. Okay, any final words for our audience before we wrap up?

Steve Arndt
I don't know if your other people this week have said this, but my personal friend and mentor and mentor to a lot of people in the industry passed away last week, Pete Lyons. If it wasn't for him, I would not be the man I am today. That's true of a lot of people in the business, but really, we talked about technology a lot, but we're really a business in an organization of people and many great people. Pete was certainly one of those. I just want to send my condolences to his family.

Bret Kugelmass
Yeah, I agree. Okay. Steve Arndt, thank you so much for taking the time today. Really appreciate it and hope to chat more soon.

Steve Arndt
Okay, you take care.