ML021090572
ML021090572 | |
Person / Time | |
---|---|
Site: | Fort Calhoun |
Issue date: | 04/19/2002 |
From: | Clay Johnson NRC/RGN-IV/DRP |
To: | Ridenoure R Omaha Public Power District |
References | |
Download: ML021090572 (18) | |
Text
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- " REGION NUCLEAR REGULATORY IV COMMISSION 00 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-8064 APR 19 2O02 R. T. Ridenoure Division Manager - Nuclear Operations Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550 Fort Calhoun, Nebraska 68023-0550 ASSESSMENT
SUBJECT:
MEETING
SUMMARY
FOR END-OF-CYCLE PERFORMANCE
Dear Mr. Ridenoure:
at Dana Hall of This refers to the end-of-cycle performance assessment meeting conducted The meeting attendance list, a Science, Dana College, Blair, Nebraska, on March 26, 2002. Security in speech, "Nuclear copy of the slides presented, and Chairman Richard A. Meserve's the Post-September 11 Environment," are enclosed.
Part 2, Title 10, Code of In accordance with Section 2.790 of the NRC's "Rules of Practice,"
will be available electronically for Federal Regulations, a copy of this letter and its enclosure the Publicly Available public inspection in the NRC's Public Document Room or from ADAMS is accessible from Records (PARS) component of NRC's document system (ADAMS).
Public Electronic Reading the NRC Web site at http://www.nrc.gov/nrc/adams/index.html (the Room).
to discuss them with Should you have any questions concerning this matter, we will be pleased you.
Sincerely, CQWM6 &,1 Claude E. Johnson, Chief Project Branch C Division of Reactor Projects Docket: 50-285 License: DPR-40
Omaha Public Power District
Enclosures:
- 1. Attendance List
- 2. NRC Presentation
- 3. "Nuclear Security in the Post-September 11 Environment" speech by Dr. Richard A. Meserve, Chairman U.S. Nuclear Regulatory Commission cc w/enclosures:
Mark T. Frans, Manager Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550 Fort Calhoun, Nebraska 68023-0550 James W. Chase, Division Manager Nuclear Assessments Fort Calhoun Station P.O. Box 550 Fort Calhoun, Nebraska 68023-0550 David J. Bannister, Manager - Fort Calhoun Station Omaha Public Power District Fort Calhoun Station FC-1-1 Plant P.O. Box 550 Fort Calhoun, Nebraska 68023-0550 James R. Curtiss Winston & Strawn 1400 L. Street, N.W.
Washington, D.C. 20005-3502 Chairman Washington County Board of Supervisors Washington County Courthouse P.O. Box 466 Blair, Nebraska 68008 Sue Semerena, Section Administrator Nebraska Health and Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007
Omaha Public Power District Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street, Suite D Des Moines, Iowa 50309 Timothy F. Dunning, Sheriff Douglas County Hall of Justice 17th and Farnam Omaha, Nebraska 68102 Kathleen McAllistar, Chairman Douglas County Board of Commissioners Civic Center 1819 Farnam Omaha, Nebraska 68183 Steve Lee, Director Douglas County E M Civic Center EOC, Room 114 Omaha, Nebraska 68183 Todd Babor Civil Defense Director Harrison County 111 South 1st Avenue Logan, Iowa 51546-1305 Terry Baxter, Sheriff Harrison County Sheriff's Department Logan, Iowa 51546 Bob Smith, Chairman Harrison County Board of Supervsiors Court House Logan, Iowa 51546 James Long, Mayor City of Missouri Valley City Hall 223 E. Erie Missouri Valley, Iowa 51555
Omaha Public Power District Terry Hummel Emergency Management Coordinator Pottawattamie County 227 S. 6th Street, Court House Council Bluffs, Iowa 51501 Delbert King, Chairman Pottawattamie County Board of Supervisors 227 South 6th Street Council Bluffs, Iowa 51501 Bill Pook, Civil Defense Director Region 5/6 Washington County Courthouse P.O. Box 466 Blair, Nebraska 68008 Mike Robinson, Sheriff Washington County Courthouse 1535 Culfax Blair, Nebraska 68008 Jim Realph, President Blair City Council 218 S. 16th Street Blair, Nebraska 68008 Michael Mines, Mayor City of Blair 218 South 16th Street Blair, Nebraska 68008 Larry Halford, Mayor City of Fort Calhoun P.O. Box 448 Fort Calhoun, Nebraska 68023 Paul Oestmann, President Fort Calhoun City Council P.O. Box 448 Fort Calhoun, Nebraska 68023 Bill Pook Civil Defense Director Region 5/6 435 N. Park Avenue, Room B101 Fremont, Nebraska 68025
Omaha Public Power District Dick Hainje, Regional Director Federal Emergency Management Agency Region VII 2323 Grand Blvd., Suite 900 Kansas City, Missouri 64108-2670 Dianne Manns, Chairman Departement of Commerce Utilities Division Iowa Utilities Board 350 Maples Street Des Moines, Iowa 50319 Donald A. Flater, Chief Bureau of Environmental Health, 5th floor Iowa Department of Public Health 401 SW 7th, Suite D Des Moines, Iowa 50309 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources 205 Jefferson Street Jefferson City, Missouri 65102 Gary McNutt, Deputy Director Section for Environmental Public Health P.O. Box 570 Jefferson City, Missouri 65102 Jerry Uhlmann, Director State Emergency Management Agency P.O. Box 116 Jefferson City, Missouri 65102 Cecil L. Wright, Executive Director Missouri Public Service Commission 301 W. High P.O. Box 360 Jefferson City, Missouri 65102 Robert Leopold, State Liaison Officer Nebraska Health and Human Services Department of Regulation and Licensure Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007
ENCLOSURE 1 END-OF-CYCLE MEETING ATTENDANCE LICENSEE/FACILITY Omaha Public Power District - OPPD DATE/TIME March 26, 2002; 7:00 p.m.
LOCATION Dana College, Hall of Science, 2848 College Dr., Blair NAME (PLEASE PRINT) _ ORGANIZATION fc/c A'~h~ ~r4-Ptlblic hyr d?-~~
Page of
I END-OF-CYCLE MEETING ATTENDANCE LICENSEEIFACILITY Omaha Public Power District - OPPD 02 7:00 6 2002; Mac 26, :00 p.m.
P.M.
DATE/TIME March DATE/TIME Dana College, Hall of Science, 2848 College Dr., Blair LOCATION ORGANIZATION NAMEPLEASE PRINT)
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ENCLOSURE 2 NRC PERFORMANCE GOALS ANNUAL ASSESSMENT MEETING "* Maintain public safety and protect the environment
- Enhance public confidence
- Improve:
- Effectiveness
- Efficiency
- Realism of processes and decision making Nuclear Regulatory Commission
- Reduce unnecessary regulatory burden Region IV NRC Meeting Guidelines NRC Meeting Guidelines
"*Registration Table
"* Meeting with NRC and Licensee with Public observation
"* Questions and Answers
"* Inform Public of Plant Performance
"* Handouts
"* Feedback Forms Nuclear Regulatory Commission Region IV I
Meeting Agenda
"*REGULATORY OVERSIGHT
"*FINDINGS AND ASSESSMENTS
"* ADDITIONAL FOCUS AREAS
"* QUESTIONS AND ANSWERS Resident Inspectors Regional Inspectors
- Stationed at the plant
- 1679 hours0.0194 days <br />0.466 hours <br />0.00278 weeks <br />6.388595e-4 months <br /> of oversight
- Prompt response capability
- Specialized
- 1804 hours0.0209 days <br />0.501 hours <br />0.00298 weeks <br />6.86422e-4 months <br /> of oversight
- Inspection teams Comprehensive Oversight NRC Oversight Activities Program
"* Provide assurance plants are:
- Operating safely NRC'S IPUBC HEALTH ANDSAF' - Complying with regulations OverallI INUCLEAR REACTOR ASARESULT OF CIVILAN Safety Mission OPERATION "* Based on a logical and sound framework
"*Inspections focused on key safety areas Strategic Performance RADIATION Areas SAEY SAFETY SEURT "*Objective indicators of performance
"*Assessment program triggers regulatory actions IN 2
Baseline Inspection Program~ Baseline Inspection Program
- Gathers objective evidence of plant safety "* Inspection reports describe significant findings and non-compliance
- Conducted at all plants
- Focuses on safety-significant:
- systems "*Inspection reports are publicly accessible
- components
- activities
- events Event Follow-up and Reactor Oversight Process Supplemental Inspections SAFETY SIGNIFICANCE
"*Review events for significance S_ - very low
- low to moderate
"*Follow-up significant inspection findings
- substantial
"*Determine causes of performance declines
-- high
"*Provide for graduated response Key Aspects of the Assessment Program
"*Objective review of licensee performance
"*"Action Matrix" to determine agency response in three areas:
- Inspection
- Management Involvement
- Regulatory Actions
"*Plant specific assessment letters
"*Information on NRC public web site 3
Inspection Program Performance Indicators
- Inspection reports describe more than
- Performance indicator results and other minor findings and non-compliance assessment information available on the NRC's public web site:
- Inspection reports are publicly accessible www.NRC.gov/NRR/OVERSIGHT/ASSESSIFCSfcslHtm www.NRC.gov/reading-rm/adams.html IQ Inspection Results Performance Indicator Results NRC and Licensee identified inspection findings were of very low safety significance All performance indicators within the Licensee Control Band No special or supplemental inspections necessary Assessment Conclusion Licensee effectively managed:
- Reactor safety
- Radiation safety
- Plant security LICENSEE RESPONSE Ft Calhoun Station operated in a manner that protected the health and safety of the public 4
Nuclear Industry Issues Additional Focus Areas
"* Reactor Vessel Head Penetration Inspection
- NRC Responds As-Needed - NRC Bulletin 2001-01 "Circumferential Cracking of Reactor Pressure Vessel Head Penetration Nozzles"
- Mandate Licensee Actions "* Security at Nuclear Power Plants
- Substantial security measures in place prior to terrorist attacks
- Federal, State, Local and Licensee integrated response
- Implemented Emergency Preparedness to terrorist threat
- Small leaks were discovered
- Mandated Licensee Actions
- Identified larger problem Reaction to September 11 Reaction to September 11
- Coordinated with other agencies
- Ordered increase in minimum security requirements
- Updated advisories as terrorist threat changed
- Reviewing security regulations considering our changed environment
- Verified implementation 5
Conclusions Contacting the NRC
"*Report an Emergency:
- Assured Public Safety (301) 816-5100 (collect)
"*Report a Safety Concern:
- Flexible/Predictable Response (800) 695-7403 or Allegation@nrc.gov
"*General Information or questions:
- Risk-Informed Programs www.nrc.gov Select "What we do" for Public Affairs Reactor Oversicaht Process w
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http://www.nrc.gov/reading-ridoc-colle ...s/commission/speeches/2002/s02-00 l.html Speech - 001 - Nuclear Security in the Post-September I I Environment ENCLOSURE 3 Site Hel Site Index I Contact Us - S r Advanced Search 2002 > S-02-001 Home > Electronic Reading Room > Document Collections > Commission Speeches >
OFFICE OF PUBLIC AFFAIRS Office of Public Affairs Telephone: 301/415-8200 Washington, DC 20555-001 E-mail: opaanrc.gov Web Site: Public Affairs Web Site No. S-02-001 PDF Version (38 KB)".h Nuclear Security in the Post-September 11 Environment by Dr. Richard A. Meserve, Chairman U.S. Nuclear Regulatory Commission National Press Club Washington, DC January 17, 2002 Good afternoon. I am pleased to have this opportunity to address you.
you I suspect that you have a strong interest in security at nuclear power plants. I hope to provide Commission approaches security matters, with a with a summary of how the Nuclear Regulatory and with a description of some of the actions taken in the aftermath of the September 11th attacks, survey of some of the major challenges ahead.
Let me make a few general points at the outset.
credible First, and perhaps most important, since September 11th there have been no specific Of course, there is information that al Qaeda threats of a terrorist attack on nuclear power plants.
considers nuclear facilities as potential terrorist targets. In light of the high general threat environment, we and our licensees have maintained our highest security posture.
a Second, the physical protection at nuclear power plants is very strong. I know that there has been concerning the adequacy of security in light of the sensitivity of these facilities. But lot of discussion sabotage let me assure you that nuclear plants are not "soft" targets. For decades, security against activities and our licensees' responsibilities. The has been an important part of the NRC's regulatory formidable structures in existence and they are guarded by well trained plants are among the most more and well armed security forces. The security at nuclear plants is and has always been far since September 11.
substantial than that at other civilian facilities. And it has been augmented Third, I want to assure you that the NRC is responding to the terrorist threat in a comprehensive practices.
fashion. September 11 has served to alert America to the need for re-examination of past of our security program to ensure that As a result, the NRC is undertaking a top-to-bottom review we have the right protections in place for the long term.
I. The Existing Security System.
Let me start by providing you with a more detailed description of our security requirements.
Each licensee has a responsibility to defend its nuclear power plant, subject to regulatory scrutiny by the NRC. Under our existing regulatory system, we require that our licensees demonstrate a high assurance that they can defend their facilities against a so-called a
"design-basis threat." Although the details of that threat are classified, it basically involves commando attack by several skilled attackers, armed with automatic weapons, with 04/19/2002 8:24 AM I of 5
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200 2/s0 2 -O01.html hand-carried explosives and incapacitating agents, and with assistance by an insider, the use of a 4-wheel drive vehicle, and a vehicle bomb. Our licensees defend against such a threat by the establishment of a fenced perimeter (usually a double fence topped with concertina wire),
intrusion detection devices, layers of access barriers, heavily armed and carefully trained guard forces, armored defensive positions, and a comprehensive defensive strategy. The adequacy of the defenses is subject to detailed inspection by the NRC, including periodic force-on-force exercises designed to probe for weaknesses so that corrections can be made.
The design basis threat does not include an aircraft attack. In the aftermath of September 11, many have asked about the consequences if a large airliner, fully loaded with jet fuel, had crashed into a nuclear power plant. We had to say candidly that we were not sure. We know that reactor containments are extremely robust, typically being constructed with two to five feet of reinforced concrete with an interior steel lining. The plants benefit from redundant and diverse safety equipment so that if any active component were unavailable, there is another means to satisfy its function. The operators are trained to respond to unusual events. And carefully designed emergency plans are in place. Nuclear power plants are certainly far more capable to respond to an aircraft attack than other civilian facilities. But the NRC has never previously had reason to perform a detailed engineering analysis of the consequences of a deliberate attack by a large airliner. We are performing those analyses now.
I am sometimes asked whether a terrorist might be able to gain employment at a nuclear plant. Let me describe some of the regulatory requirements that bear on this issue. At the time of employment, every potential employee who will have access to safety equipment is required to pass various background checks, including examination of past employment, references, credit history, and an FBI criminal record check, as well as to undergo psychological testing. During the course of employment, each employee is also subject to fitness-for-duty requirements, which include random drug and alcohol testing. Behavioral monitoring of employees is also required so as to ensure that any aberrant actions receive appropriate attention. Of course, access to the plants is controlled and there are portal detectors for metals and explosives. We are examining whether these requirements should be supplemented in the course of our top-to-bottom review.
II. Response to the September 11 Events Let me turn now to the events on September 11 and the NRC's subsequent actions.
Shortly after the second crash into the World Trade Center, the NRC activated its Headquarters Emergency Operations Center and the parallel Incident Response Centers in each of NRC's four regional offices. We immediately called for our major licensees to go to the highest level of security, which we have maintained since that time and augmented as circumstances warranted. This heightened security stance generally includes, among other resources, increased patrols, augmented security forces and weapons, additional security posts, heightened coordination with law enforcement and military authorities, and additional limitations on access of personnel and vehicles to the site.
The NRC's safeguards analysts have worked continually with the intelligence and law enforcement agencies to assess the general threat environment, as well as information about specific targets. In order to assess whether terrorists may have been conducting surveillance of nuclear facilities, we, with assistance from Federal, State and local law enforcement, have carefully examined unusual incidents, such as fly-overs, threats, or the possible probing of defenses. NRC investigators have also examined incidents over the past two years that might have seemed innocent or odd at the time, but that in retrospect might suggest a pattern that should be referred to the FBI for follow-up.
As you might expect, there have been extensive interactions with other governmental agencies. We have worked closely with the new Office of Homeland Security, the FBI, the Federal Emergency Management Agency, the Federal Aviation Administration, the military, and the Department of Energy, among others. And I have communicated with the governors of 40 states so as to ensure that any state defensive assets (National Guard or state police) are used as needed to augment our licensees' defensive strategies.
III. Fundamental Challenges 2 of 5 04/19/2002 8:24 AM
2 http://www.nrc.gov/reading-rm/doc-colle...s/comnnission/speeches/200 /sO2-00I .html Speech - 001 - Nuclear Security in the Post-September II Environment not yet had the Let me turn now to some longer-term challenges. The Commission has of some of these issues, so these comments should opportunity to complete its consideration be seen as my own.
A. The Need for a Comprehensive Security Strategy I shall first discuss the context for examining the security of nuclear plants.
of As you know, there have been numerous discussions about the potential vulnerability terrorist attack. Some argue that the only acceptable response to nuclear power plants to with the risk is to shut down the Nation's reactors. Others contend we can continue as nuclear power - which provides about 20 percent of the Nation's electricity -- so long appropriate security measures are in place.
by the The crimes of September 11 were designed to shock the American people in part In the effort to ensure that very fact that they involved such large and imposing targets.
is a danger of drawing the wrong lesson from the no such horror ever occurs again, there attacks: of blaming the victim, so to speak. The destruction of a skyscraper does not suggest it was a mistake to build skyscrapers, any more than the dissemination of anthrax spores through the mails proves that it is an error to operate a postal service. If we allow the threats of terrorists to determine what we build and what we operate, we would be headed into the past -- back to an era without suspension bridges, harbor tunnels, stadiums, or hydroelectric dams, let alone skyscrapers, liquid natural gas terminals, chemical factories, or nuclear power plants.
The problem is not the terrorists' targets, but the terrorists themselves. It is they who need to be eliminated, not the creations of a modern industrial society. It is thus my view that a strategy of risk avoidance -- the elimination of the threat by the elimination of potential targets -- does not reflect a sound response. Rather, the evaluation of the terrorist threat to infrastructure, including nuclear plants, should include a careful and realistic examination of risks and benefits and the development of appropriate defenses in light of those risks and benefits.
September 11 has made clear that our society must increase the vigilance with which we defend ourselves from terrorist attack. But the reality is that, as a society, we do not have infinite funds to spend for this purpose. Accordingly, we must allocate our defensive resources in a fashion that serves to minimize the total risk. As a result, any policy regarding the defense of nuclear facilities should be integrated in the overall response to the threat to infrastructure of all kinds.
Clearly this is not a task that the NRC can undertake alone. We have sought, and will continue to seek, appropriate security at facilities subject to our jurisdiction. We look forward to working with the Office of Homeland Security and others to ensure that our strategy is coordinated with the Nation's overall defensive posture. I see this as a great challenge, however, because the task is large and the defense of infrastructure involves government at all levels.
B. Public and Private Roles.
The second policy issue that I would like to discuss relates to public and private roles in the defense against terrorism. This is an issue that the events of September 11 have brought clearly to the fore.
As I have explained, the NRC licensees must defend nuclear power plants against the "design-basis threat." September 11 obviously revealed a type of attack -- a suicidal assault using a large commercial aircraft -- that has not been part of the NRC's planning (or that of any other agency with similar responsibilities). Moreover, the event has demanded that the NRC and its licensees reevaluate the scope of potential assaults of all types.
There are limits, however, as to what should be expected from a private guard force, even as assisted by local law enforcement. For example, if it were determined that nuclear plants should be defended against aircraft attack, I cannot conceive that the NRC 04/1912002 8.24 AM 3 of 5
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/s0 2 -001 .html Speech - 001 - Nuclear Security in the Post-September I11Environment would expect licensees or local law enforcement to acquire and operate anti-aircraft weaponry. Rather, this obligation would be one for the military. Similarly, there might be other types of attacks which should properly involve governmental response because of the size of the assumed attacking force or the equipment that must be employed in defense. As a result, in its development of policy, the NRC must be prepared to differentiate the defensive obligation that is borne by licensees from that which must be undertaken by the government.
As part of the top-to-bottom review that I mentioned earlier, the NRC is examining the new threat environment in coordination with various other agencies of Government.
There may also have to be an additional discussion with the military, the States, and local law enforcement about the provision of governmental assets at appropriate times. I do not expect that defining the appropriate boundary between the public and private sector in the defense of nuclear facilities will be easy.
C. The Balance Between Security and Openness.
The third issue relates to the balance between security and openness. The NRC has sought to achieve public confidence through a variety of means, but perhaps the most effective tool has been a policy of transparency. We recognize that decisions made behind closed doors may be viewed with suspicion. We have therefore sought to assure open decision processes that would enable the public to be fully informed of the issues before us. We cannot aspire to a world in which all will be satisfied by our decisions, but we have hoped that all would see that our decisions were reached through fair processes.
September 11 has made clear that we need to rethink just how open we can and should be with respect to physical security issues. In this process we must give due regard to two vital but competing interests. The first is the public's right to know, a right that is grounded in law and that is one of the most cherished principles of our democracy. The other is the need to keep sensitive information away from those whose purpose is to destroy that democracy. We are striving to strike an appropriate balance between openness and security.
D. Achieving Progress In Other Agency Business.
The final challenge I would like to mention is the need to accomplish security reform at a time of major transition in the energy sector.
Over the past year or two, we have seen a quiet Renaissance in the nuclear business.
The nuclear generating companies have become "leaner and meaner": more efficiently run, with far fewer outages and greater reliability. In the past decade, the average capacity factor, which is a measure of plant utilization, has jumped from 70 percent to nearly 90 percent. Not surprisingly, as the electrical production of the average plant has increased, the cost of the electricity has declined. As a result, the production cost of electricity from nuclear plants is less than that from its principal competitors -- coal and natural gas. And nuclear is not burdened with the emissions constraints and concerns about global warming that attend fossil fuels.
Most importantly, by all objective measures, the safety performance of nuclear plants has improved in parallel with economic performance. The NRC tracks "significant events"
-- safety system failures, unanticipated plant responses, degradation of key systems or components, and operator errors. The number of significant events has declined 99 percent in 15 years. It is not an accident that safety performance and improved economic performance should be linked to each other: both are furthered by preventive maintenance, better training of operators, and the fostering of a safety culture.
Just a few years ago, some pundits claimed that restructuring in the electricity business would lead to the premature shutdown of nuclear plants. But, as a result of this strong economic and safety performance, we are instead seeing interest among our licensees in expanding their activities. Generating companies are seeking the renewal of the licenses of existing plants so as to allow operation beyond the initial 40-year license term. And some are even contemplating new plant construction.
4 of 5 04/19/2002 8:24 AM
http://www.nrc.gov/reading-rmdoc-colle...slcomrnssion/speeches/2OO2/s02-O01.html Speech - 001 - Nuclear Security in the Post-September 11 Environment oZf the plant that are License renewal involves a careful examination of the systems maintained over an extended are subject to aging so as to ensure that safety margins at four sites already, and for eight plants operating period. We have renewed the licenses literally the entirety of the remaining either have applications or expect applications from review of each application.
95 plants. We are committed to a thorough, expeditious in both safety and in economics.
New construction offers the promise of improvements many reasons, including that challenge for But new construction presents a significant different from existing new construction might involve designs that are completely are cooled by helium, rather that facilities. For example, there are discussions of reactors of new applications so as to than water. We have started to prepare for the possibility analytical tools in place.
ensure that we have the appropriate regulatory and September 11, the NRC was an I mention these developments because, even before we have used the past challenges. Fortunately, agency that was confronting significant processes and preparing to quarter century to good advantage, improving our If society decides to expand accommodate technological and economic developments. its role of protecting to perform reliance on the nuclear option, the NRC is prepared public health and safety.
Conclusion times and it is difficult at this Let me note in conclusion that we live in very uncertain I have mentioned will be finally juncture to predict how the security and other challenges that the NRC takes its resolved. I hope that I have left you with the awareness obligations very seriously.
to respond to questions.
Thank you for allowing me to join you. I would be happy 04/19/2002 8:24 AM 5 of 5