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 DEPARTMENT OF ENERGY

 OFFICE OF NONPROLIFERATION AND

 INTERNATIONAL SECURITY (NIS)

 PROPOSED CHANGES TO DOE PART 810

 ASSISTANCE TO FOREIGN NUCLEAR ACTIVITIES

 PUBLIC MEETING

 Grand Hyatt

 1000 H Street, N.W.

 Washington, D.C.

 Friday, November 15, 2013

 9:11 a.m.

 Reported by: Christine Allen,

 Capital Reporting Company
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1 A P P E A R A N C E S

2 Jeff Bedell, Los Alamos National Laboratory

Alisa Beyninson, Government Accountability Office

3 David Blee, USNIC

H. Brendan Burke, George Washington University Law School

4 Malcolm Burke, U.S. Department of Commerce

Ian Butterfield, Livingston Group

5 Jorge Canovas, University of Pennsylvania

Dwight Cates, Fluor Corporation

6 Preeti Chaudhari, U.S. Department of Energy

Steve Clagett, Department of Commerce

7 Joyce Connery, National Security Staff

Jean Cornell, ML Strategies

8 Jennifer Dahnke, DOE/NNSA

Colleen Deegan, Bechtel

9 Aubrey DeVilliez, American Nuclear Society

Vincent Esposito, House Committee on Energy and Commerce

10 Madeleine Foley, DOE/NNSA

Ted Garrish, Chem2Hill

11 Richard Goorevich, DOE/NNSA

Kelly Hochstetler, University of Virginia

12 Gisele Irola, DOE/NNSA

Ted Jones, Nuclear Energy Institute

13 Anna Jones, Morgan, Lewis & Bockius LLP

David Kincaid, U.S. Department of Commerce

14 Lenka Kollar, Argonne National Laboratory/Consultant

Jay Kraemer, Fried, Frank, Harris, Shriver & Jacobson LLP

15 Ajay Kuntamukkala, Hogan Lovells

Joshua Madrigal, AREVA

16 Melissa Mann, URENCO Inc

Stephen Markus, Pillsbury Winthrop Shaw Pittman LLP

17 LaReina Parker, DOE/NNSA

Craig Piercy, American Nuclear Society

18 Alex Polonsky, Morgan, Lewis & Bockius LLP

Millicent Ronnlund, Balch & Bingham LLP

19 George C. Rudy, Integrated Systems Technology

Linda Schenk, ERIN

20 Michele Scott, U.S. Department of Commerce

Matthew Shruhan, U.S.-India Business Council

21 Brooke Smith, Nuclear Regulatory Commission

Gretchen Smith, DOE/NNSA

22 Carlton Stoiber, Talisman International

4

1 A G E N D A

2 PAGE

Welcome

3 Katie Strangis 5

4

Part 810 Process improvement Project

5 NNSA: Project Plans and goals

 Richard Goorevich 6

6

State:

7 Understanding Foreign Assurances:

Why, Who, What, Where, When, How

8 Richard Stratford 26

9 NNSA: E-Licensing

 Jeff Wilkins 33

10

Q&A on Process 43

11

12 Break 77

13 NNSA: Part 810 Rulemaking Overview

Part 810: Purpose, History and Scope 77

14

What is changed

15

What's not changed

16

Next Steps in Rulemaking Process

17 Richard Goorevich 79

18 PNNL: Economic Impact of the Proposed Changes

 Tom Wood 89

19 Chris Toomey 95

20 Comments and questions from public to panel 101

21 Closing Remarks

 Joyce Connery 141

22

3

1 A P P E A R A N C E S [Continued]

2 Goran P. Stojkovich, Babcock & Wilcox

Katie Strangis, U.S. Department of Energy

3 Richard Stratford, Department of State

Chris Toomey, Pacific Northwest National Laboratory

4 Matthew Tynan, Hogan Lovells

Piet van der Heide, Enrichment Technology US, Inc.

5 Jeff Wilkins, U.S. Department of Energy

Tom Wood, Pacific Northwest national Laboratory

6 Bill Woodward, Holtec

Jennifer Young, Government Accountability Office

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1 P R O C E E D I N G S

2 MS. STRANGIS: Good morning, everyone.

3 Happy Friday and thank you all for coming. My name is

4 Katie Strangis. I currently work for Rich Goorevich

5 and NNSA. I think I know most, if not all, of you.

6 Welcome to our second public meeting on our 810 process

7 and rule making.

8 Just as a reminder, we are under ex parte

9 rules for the part of the conversation where we talk

10 about the rule making and for the entire presentation,

11 we are having it transcribed. So, just so you know,

12 anything you say I going to be recorded and will be

13 placed on our public website.

14 We've changed our agenda a little bit for

15 this meeting in that the first part of the presentation

16 is going to focus on Part 810 process improvement. And

17 we're just going to take you through some of the things

18 we're doing, a lot of it based on your feedback to

19 improve the 810 process.

20 Dick Stratford is going to take us through

21 understanding how foreign assurances work and how we

22 can maybe improve that process. And then we have Jeff
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1 Wilkins who's going to take us through our plan for our

2 new E-licensing system.

3 At the end of that we're going to do a

4 question and answer session and at that point you're

5 able to ask any questions about that section. We're

6 not under any sort of restrictions on what we can

7 answer.

8 We'll then take a break and get into the

9 rulemaking and more into our economic impact that we

10 submitted, as well. So, without further ado I will

11 turn it over to Rich.

12 MR. GOOREVICH: Okay. Well, thanks, everyone

13 and good morning. I know this meeting's happening a

14 little later. I guess when we first met in August we

15 had anticipated a meeting to take place in and around

16 the 1st of October. I think, as you all know, for

17 reasons out of our control, that we couldn't hold the

18 meeting then. As a result of those circumstances, what

19 we've done is we've scheduled the meeting now and we've

20 extended the date out for the comment period on the new

21 rule to take into account the fact that we couldn't

22 meet our commitment that we'd made in August.

8

1 airplane and they say, are you really sure you want to

2 go to San Diego? Well, this is the part where we say,

3 we're here to talk about Part 810, which implements

4 Section 57b of the Atomic Energy Act and it explains

5 what is--which I think is, we all know 57b prohibits

6 all assistance to foreign atomic energy activities

7 direct or indirect. This is the direct or indirect

8 assistance that you'll hear us talking about in the

9 production of, or the development of, special nuclear

10 material.

11 And then talking how the Secretary of Energy

12 must authorize these requirements and he makes these

13 decisions after coming to what we call a non14 inimicality finding and with the concurrence of the

15 State Department and in consultation with the other

16 parts of the agency, Commerce, NRC, DOD, and it covers

17 all SMN activities, whether for weapons or for

18 commercial purposes, so there's no distinction in the

19 law.

20 The scope, we can exempt some elements of

21 these activities and generally that's where it's found,

22 in the current 810.2, but it's a necessary regulation,

7

1 So we're happy to be here. It's a little bit

2 cozy in this room, but I think it's a very functional

3 room for what we're going to do. The idea here over

4 the next couple of hours is to take your through some

5 of the elements and areas that we really could not--

6 that we didn't have a chance to get into in the first

7 meeting and to really take the opportunity to solicit

8 your views on what you've seen so far in your study of

9 the SNOPR and how we're doing.

10 But as Katie said, what I'm going to do is

11 I'm going to take you through a little bit of the

12 process improvement ideas that we have, with the help

13 of Dick Stratford from State Department on the

14 assurance process and then Jeff Wilkins from our CIO's

15 office is building our E-licensing system.

16 So I think we've covered this. Katie talking

17 about that and then, as you can see from the bottom,

18 after the break we'll then get into the rulemaking

19 itself.

20 A couple of slides on background, just to

21 sort of insure that everyone knows why--this is sort of

22 the point where before they close the door on the

9

1 810, because of what the law requires the secretary to

2 do. We have the ability to generally authorize and I

3 think we've laid out, I think, in the SNOPR the reasons

4 for what we're going to be. How we're going to make

5 the determinations moving forward on what's generally

6 authorized and what's going to be in the requirements

7 for--if it's not generally authorized, what specific

8 authorization requires and, again, the inimicality

9 finding of the secretary. So essentially, what Part

10 810 does is it lays out the pathways for how to

11 implement 57b.

12 So, the rulemaking schedule, well, we started

13 the original rulemaking by issuing what we call the

14 NOPR--Notice of Proposed Rulemaking--in September

2011

15 and then in December of that year we received the

16 comments on the NOPR.

17 We then took some time and we went through

18 and really studied the comments, revised and reviewed

19 and because of the number of significant changes that

20 we felt were necessary to the NOPR, as a reflection of

21 our studying the comments that we received, we then

22 decided to issue a supplemental NOPR, rather than go to
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1 a final rule. We really did want to solicit more

2 feedback from the public.

3 August 2nd we went ahead and issued the

4 SNOPR, had the public meeting. We're now having the

5 second public meeting and then comments are due on

6 November 29th, and I know one of the questions that we

7 will probably be asked is, what's our intention with

8 the schedule further on regarding this? Well, our

9 intention is to really, again, study the comments that

10 we get and try and turn around as quickly as possible

11 then the next steps in going to, then, the final rule.

12 We don't expect it to take nearly a year and

13 a half, our hope is that we can do it in terms of

14 months, not years. And then try and get the rule out

15 and get it moving. But there's an element of this from

16 which we understood from the comments we got, which is

17 that it's good to change the rule, but the process

18 itself has to change.

19 I think one of the things that we've become

20 aware of internally over the past years is how industry

21 is being conducting is evolving. It's no longer being

22 conducted in the way the last time this rule was

12

1 where we sit, didn't have was a very good sense of

2 exactly how all the pieces were fitting together. And

3 through the public comment period and through the

4 creation of Team USA that Joyce is leading at the White

5 House, we now feel that we have a much, much better

6 view of how the 810 processes that we have should be

7 fixed and how to go forward.

8 Now, what I'm going to do is spend a few

9 minutes talking about what we're doing right now to

10 undertake those reviews and you'll see how some of the

11 public comments that we receive today fit into the

12 public process.

13 Most of you have probably seen this slide

14 before, which pretty much takes you through the three

15 stages of the authorization process, where the first

16 stage is essentially the initial review where we

17 receive the license application. We go through

18 internal reviews, both my staff--which also includes

19 the technical expertise at the National Labs. We talk

20 with our Office of Nuclear Energy and we talk with our

21 legal advisors to try and get a determination on that.

22 We then develop what we call the analysis. If

11

1 touched, which was the mid or early 1980s. Business is

2 evolving. How business is being done, how assistance

3 is being carried out, the importance of this trade and

4 this assistance, not only from a commercial standpoint,

5 but as part of a broader U.S. Government policy on

6 energy and on non-proliferation means that the pace of

7 activities is increasing and increasing in a way that

8 our current processes really do not support as well as

9 we would like to see them support.

10 So we recognize that the process needs to be

11 changed. But for us, sitting where we sit, we can only

12 see one part of all the activities that the public has

13 to go through in getting business, and marketing

14 business, and signing contracts, and implementing

15 contracts, to get that assistance out there.

16 What the public comments provided us was some

17 insight into the challenges that industry and the

18 public are facing with those elements of requirements.

19 We had anecdotal information and evidence based upon

20 our direct dealings with certain applicants that were

21 willing to explain that to us, but what we didn't get

22 was a very good- -what we don't have and because of

13

1 you look in the current regulation, there's 8 questions

2 we have to answer for the Secretary, so we can make the

3 non-inimicality finding and we answer those questions

4 at that point and then send the approval for

5 recommendation to the interagency for review and moving

6 forward.

7 We send approvals for recommendations. If we

8 think that the application will be denied for any

9 reason, we don't send it through the process until

10 we've talked to the company and the applicant, and we

11 make a determination as to working with the applicant

12 as to how we could change the application, change the

13 nature of the business, structure it in a way where we

14 feel confident that the interagency will come back with

15 an approval.

16 So the first stage is, we think, is very

17 important because it really helps and should set the

18 stage for approval in the stages moving forward.

19 Stage 2, agency review. Well, we've done our

20 analysis, we've sent it to the agency, State, Commerce,

21 Defense, and they take a look at it. At the same time

22 that we ask them for their comments and their views,
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1 and to concur with our recommendation, we also then ask

2 the State Department to request formal assurances from

3 the host government. And Dick will talk a little bit

4 about how we do that and why we do that.

5 When we get the clearances from the

6 interagency and we get the assurances from our partner

7 country's government, then we move to the approval

8 process which is essentially taking the package, taking

9 the assurances, taking the recommendations, drafting

10 the formal what we call authorization from the

11 secretary to the applicant. It then goes through the

12 entire DOE review process again, up to the secretary

13 and the authorization is granted and moving forward.

14 I know that one of the comments that we'll

15 get in questions is why the Secretary of Energy? It's

16 not on the slide, but something that I think will--if

17 the question is asked, we will point people to the

18 Atomic Energy Act.

19 The Atomic Energy Act. I think it's Section

20 161, there are certain things that are non- delegable

21 for the secretary to do. For example, one of the

22 things that is non-delegable for the secretary to do is

16

1 authorized country's technologies or transactions to

2 avoid the time consuming authorization process. There

3 are certain ways that we can look at countries, but in

4 the end it's going to come down to, again, the

5 secretary being able to make the non-inimicality

6 finding.

7 In our view, if folks feel that we need to

8 change a regulation to avoid the process, we probably

9 need to look at the process before we worry about

10 changing the regulation. And for us, understanding

11 that was certainly important for us. And, again,

12 pushing us to change and improve the process.

13 Commenters offered many process improvement

14 ideas and that process improvement is the key to better

15 regulation. If people feel this is slow, opaque, and

16 unpredictable--and I'm really mostly worried about the

17 opaque and unpredictable because any regulatory process

18 should be transparent and predictable and efficient--

19 then we need to make changes. And that's what we're

20 doing, we're going to fix the process overall with

21 limitation.

22 Now, what are the qualities of a good 810

15

1 determinations on restricted data. What's considered

2 classified and what isn't. The definition of what is to

3 be treated as special nuclear material, I believe, is

4 that.

5 There's a reference in 161 to 57b(2) and it

6 says that it's non-delegable. So it's not a decision

7 that, in our process, that we can at our level make

8 that determination to ask the secretary to delegate it

9 down. It would require a change in the law itself.

10 So, there's certain things we can do in the

11 process approval and there's certain things that we

12 can't do. And we're going to try and improve the

13 things that we can do, as best we can.

14 So what did we learn from the comments? Well,

15 we've learned that the authorization process is

16 considered slow, opaque, and unpredictable. These are

17 words and sentiments directly from the commenters. I'm

18 not going to quibble on whether I agree with all of

19 them or not, but this is certainly what we're hearing

20 and that's enough for us to understand that we need to

21 improve the process.

22 Commenters sought to exempt or generally

17

1 process? First and foremost, we have to meet the

2 intention of the law. We have to have effective threat

3 reduction. And, as I just said, we need to be open,

4 transparent, predictable and understandable. That is

5 also something that I think is going to be very

6 important to my office as we move forward;

7 understandable. One of the comments that we've heard

8 over and over again is that it's hard to understand the

9 810 regulation.

10 Lots of regulations are hard to understand

11 and we think we've gotten a lot of good suggestions on

12 how we can make it more understandable, and I'll talk

13 about that a little bit.

14 Efficiencies, we have to be more efficient.

15 As I said, the pace of business as you all know is

16 faster than we can respond to right now in our current

17 process and it's not going to slow down. It's just

18 going to get faster. And so we need to find a way to

19 make our processes efficient and flexible to be able to

20 meet the requirements that our applicants have.

21 And effective nuclear trade support--we're

22 competing in the global nuclear market and us having
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1 U.S. applicants, U.S. industry, U.S.

2 technology spread throughout the world is

3 important. It's important from an economic policy and

4 it's important from a non-proliferation policy, but we

5 have to be able to strike the balance between trade

6 promotion and the proliferation risk that's inherent

7 within the technology that we're dealing with.

8 So what are our objective? Well, our

9 objectives is very straight forward. To be

10 transparent, predictable, and understandable and to

11 reduce the time, okay? I think that it's not one over

12 the other and that we can reduce the time if we're

13 transparent, predictable, and understandable. And if

14 we're transparent, predictable, and understandable

15 we'll reduce the time. So I think those are the keys

16 to us.

17 We need to continue to meet our obligations

18 under the law and that we have to recognize that our

19 poor performance puts suppliers at risk and at a

20 competitive disadvantage. And so we understand that

21 we're in the service business and so we have to provide

22 the service, but, again, we have to strike the balance.

20

1 response times for foreign government assurances. Now,

2 this isn't solely a DOE activity. In fact, it's not

3 really a DOE activity, it's really a State Department

4 activity, but in partnership with State Department we

5 are looking at where we can find those efficiencies.

6 But again, there's only so much we can do. We have

7 some ideas we can implement, some Dick will talk about

8 here, some we can't because of the nature of those

9 activities.

10 But that's going to be key to this. That's

11 really the second stage of the slide that I showed, how

12 do we reduce the time for foreign government

13 assurances? And then reduce the internal DOE and

14 interagency reviews. We're looking for overlap. Where

15 are we looking at the same thing multiple times when we

16 don't have to, and we shouldn't be looking at the same

17 thing multiple times.

18 If we've made determinations and decisions

19 about essentially the same technology and the same

20 entities before, can we somehow borrow from those

21 determinations that have been made? We're going to

22 create fast track procedures for authorization of

19

1 So what are we going to do to help improve

2 the idea? Well, one of the ideas that we've heard and

3 that we continue to hear, and people have shown us

4 examples from others that have much deeper and much

5 more comprehensive and wider regulatory experiences

6 than we do, is to go ahead and put together a guide--a

7 sort of user's guide.

8 So while we'll have the regulation,

9 certainly--whatever that looks like--out there, one of

10 the things that we want to do is we want to create, as

11 part of our process improvement, a guide that includes

12 advisory opinions, frequently asked questions, and it

13 goes through and tries to explain in layman's terms

14 what the rule means. And how do you apply for an

15 authorization? What happens once you apply for that

16 authorization? And all the interpretations that we may

17 have taken, either from a legal or technical standpoint

18 that we have in the advisory opinions, to provide the

19 applicant with more resources to really understand the

20 rule and to be able to more efficiently and effectively

21 go through the application process.

22 We're going to be working on reducing the

21

1 activities that present the lowest risk. The idea

2 there is to try and build a rule that can be more

3 flexible--be flexible in a changing time. And be

4 flexible in a way that responds to the global industry

5 needs. And I think there are examples of that that are

6 in the SNOPR right now, such as how we're treating the

7 definitions of operational safety.

8 As we all know, post-Fukushima, this is going

9 to be an area that is going to continue to get a lot

10 more attention and a lot more expertise brought to it

11 to try and have the safest possible nuclear industry we

12 can. We want to create a rule, have the rule be in the

13 position, and to have our processes be in the position

14 to be able to respond to those changes that the global

15 industry that all the governments in the industry that

16 are associated with nuclear technology can be able to

17 take advantage of. So, developing a process that's

18 flexible--a fast track process or a flexible process--

19 is important to us.

20 And I think, finally, one of the things that

21 we heard loud and clear is, can we drag the 810 rule

22 into, at least, the late 20th century by creating a
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1 computer E-licensing system and our CIO is here and is

2 going to talk a little bit about what we're doing.

3 My fear had always been that our licensing

4 load probably wasn't to the point where we needed to

5 invest as the department millions of dollars to develop

6 an E-licensing system, but I think from what we've

7 heard, we do need to do this and we think we can find

8 efficiencies once the system's in place, to help move

9 the process along. And with Jeff's office, I think we

10 can find a way to do it in a cost effective manner, as

11 well, which is important, obviously, to the department

12 and to tax payers, as well.

13 So how are we going to implement all of this?

14 What are we going to do? Well, what we're doing is

15 we're going to use the Six Sigma analysis to help

16 select the best ideas.

17 So how are we going about--next slide-- what

18 are we going to do? Well, we acknowledge that the

19 process can and should be improved, we're committed to

20 process improvement, and the goal at the end of all of

21 this is to make the process, ISO 9001 compliant. My

22 department is moving through all of its business

24

1 way.

2 So, who's doing what to whom? My office is

3 the NIS and we're the lead Six Sigma project, so where

4 are we? Well, we're interviewing applicants, internal

5 administrators, and getting input from applicant groups

6 to determine the necessary and desirable features and

7 functions for the process.

8 We're determining necessary and desirable

9 licensing functions and features and we're providing

10 that to the CIO and we're identifying performance

11 issues and recommending improvements to what we're

12 getting back and forth. The CIO, Jeff, he's in charge

13 of essentially designing the architecture for the E14 licensing system and the software development and then

15 ultimate implementation. And then there's a whole

16 other group in NNSA, called the NA-QA, and they're

17 there to help us go through the ISO 9001 compliance and

18 certification process.

19 So, what is Six Sigma? Well, it's a quality

20 improvement tool and it's based on a rigorous fact21 driven approach, at least that's what C.J. keeps

22 telling me it's about. And up until now we have no

23

1 functions and its larger construction and program

2 efforts to become ISO 9001 compliant.

3 In the end, we want our process, the 810

4 process, to also be ISO 9001 compliant. And not only

5 compliant, my goal is to go and to seek the ISO 9001

6 certification, as well. That would then make us in the

7 U.S. Government the only export control process that

8 had gone through this kind of review, that would be ISO

9 9001 compliant, and would be ISO 9001 certified.

10 And so, the idea then is that through that,

11 in maintaining that certification, it forces us to look

12 at our process and to continue to improve and to

13 continue to find efficiencies. So that's the goal.

14 The goal is to force us to be better and to stay

15 better.

16 So, we have project plan and methods are set.

17 We have a team that's assembled and we're underway on

18 this project and it is--although it was informed by the

19 rulemaking, it is separate from the rulemaking. So,

20 regardless of what happens with the rulemaking, we

21 still have a separate track and we're on target to be

22 able to improve and go through this process all the

25

1 reason to doubt him. We have to determine the

2 critical--the quality characteristics. And this really

3 where C.J.

4 disappears for hours on end during the day to

5 go to what he says are interviews. They tend to be

6 done at Starbucks, as near as I can tell. And I'm not

7 really seeing him dip into his wallet too often at the

8 Starbucks, so whatever he's doing, I'm sure he's doing

9 it, you know, he's having a good time doing it.

10 So we've done interviewing the applicant and

11 the customers. We're interviewing the internal DUE and

12 interagency customers and I'll be honest with you, I've

13 not been part of this process at all. They firewalled

14 me and Katie off from this as the managers so that what

15 they're getting in the interview process isn't somehow

16 tainted by us, either having our own preconceived ideas

17 on what this should look like.

18 The next thing that the team's going to do is

19 measure quantified performance. To then analyze using

20 the metrics and then make essentially the

21 recommendations, and then for us to implement the

22 recommendations.
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1 So what I want to do now is really then get

2 into the E-licensing aspects, but before we get into

3 the E-licensing aspects I think it's important because,

4 as we're going through and before--because the E5 licensing is really where all the process improvements

6 come together, but us understanding and going through

7 the Six Sigma with regards to how we handle the

8 application and how we do our analysis and how we do

9 the paperwork is only part of it.

10 As we stated in Stage 2, there's another

11 part of it and that is the interaction with the foreign

12 governments and that's required for the secretary to

13 make the non-inimicality finding and that's where we

14 turn the process over to the State Department. So I

15 think before we go to Jeff and talk about what

16 ultimately the computer E-licensing system will look

17 like, let me pass it over to Dick, who's going to talk

18 a little bit about what State Department's role in the

19 810 process is and,

20 MR. STRATFORD: Thanks, Rich. I'm Dick

21 Stratford. I'm the director of what used to be called

22 Nuclear Energy Affairs, which means that we handle the

28

1 trade and commercial issue. More specifically, under

2 the Nuclear Suppliers Group guidelines we are committed

3 to insure that trigger list transfers and trigger list

4 technology transfers are subject to government to

5 government commitments of, number one, peaceful uses.

6 Number two, no retransfer of the technology without

7 consent and, number three, in some cases that there

8 will be no transfer of items produced through the use

9 of the technology or items produced that are

10 replicated.

11 So, how does it all work? DOE gets a Part

12 810 application. DOE analyzes the application and does

13 a write-up. If the write-up is negative, we'll

14 probably never hear about it because they will call the

15 company and say, you really don't want a "no" letter,

16 do you?

17 However, if the analysis is positive, then

18 they send it over to us and say, you're responsible for

19 government to government foreign affairs matters, so we

20 need the relevant assurances and we need your letter of

21 consent. Will you please go get the assurances? And

22 that's what we do. We send a cable out to the embassy

27

1 diplomatic aspects of virtually everything to do with

2 peaceful nuclear energy. These days it's called Nuclear

3 Energy Safety and Security because a couple of years

4 ago we inherited all the folks who had responsibility

5 for the nuclear safety issues.

6 There are two things I never learned to do in

7 roughly a 40 year career in mostly nuclear affairs--the

8 bad news is that I never learned to type and that's a

9 huge burden, believe it or not. The good news is I

10 never learned to do PowerPoint, so you are spared

11 slides this morning.

12 The State role in the Part 810 process is in

13 once sense limited and in another sense critical

14 because we are on the critical path. Under the law, in

15 order to issue an 810, DOE has to consult with various

16 agencies, Commerce, NRC, et cetera. But before the

17 Secretary of Energy can approve a Part 810 application,

18 he has to get the concurrence of the Secretary of

19 State.

20 Now, why are we on the critical path? Well, a

21 couple of reasons. Number one, exports are

22 fundamentally a foreign policy matter, as well as a

29

1 or the relevant whatever--embassy, consulate, whatever2 -and say, for this application we need assurances of.

3 Now those assurances don't have to come from the

4 foreign ministry. They only have to come from a both

5 an agency and a person who is authorized to commit that

6 government to those assurances.

7 Now, how long does it take to get those

8 assurances? In some cases it comes back very quickly.

9 They're so used to it that we go out with a cable and

10 we might, by the end of the week, get a cable back

11 saying, Mr. So-and-So says that you have the

12 assurances, et cetera, et cetera.

13 Does it always turn around quickly? No.

14 Sometimes it can take months before we get a reply.

15 Now, who is really slow in terms of getting back to us

16 on assurances? Well, we can't really mention any

17 names, but there are two nuclear weapon states who we

18 shall say are slower than some others.

19 Now, we get the assurances back, what happens

20 next? Well, usually the next day there's a letter that

21 goes back out to DOE saying that the Department of

22 State concurs in the relevant 810 and we have the
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1 assurances from So-and-so in the state. And I'm the

2 person who has been signing those letters for many

3 years.

4 The relevant time frame for the Executive

5 Branch to approve an 810 is 60 days, total. Do we

6 always make it in 60 days? Most of the time yes,

7 sometimes no; back to countries that don't reply very

8 quickly. What happens if we run out of the 60 days?

9 [In the case of NRC license applications,*]

Well, then, actually we have to notify Congress every

10 time and I'm the one who signs out the letters saying,

11 oh, by the way, we have a case, it's been 60 days, it

12 hasn't been approved and the reason it hasn't been

13 approved is because we have not gotten the relevant

14 assurances.

15 Now, that's the process in a nutshell. I

16 want to make clear that the government assurances

17 requirement is for all transfers of trigger list items

18 for nuclear fuel cycle use, except for de minimis

19 quantities of nuclear material. Now, I say for nuclear

20 fuel cycle use because if you have transfers of certain

21 materials for non-fuel cycle use, such as deuterium gas

22 for fiber-optic production, heavy water for deuterated

* Added by DOE/NNSA for clarification.

32

1 to go see those people, one by one, and to tell them

2 that they have two choices. They can come home within

3 a reasonable period of time--I forget what it was, six

4 weeks, two months--or if they don't, their name is

5 going to be placed on a watch list at the border and

6 when they do come home they're going to be picked up

7 and then they're going to be in trouble. Everybody came

8 home.

9 So that's just an incidence where 810

10 actually did apply to intangible technology, namely

11 somebody going abroad to assist a foreign nuclear

12 program. So, with that, that's our role in a nutshell.

13 As I said, it's a limited role, but it's a critical

14 one. Ultimately, we have to concur or the 810 can't go

15 forward. In most cases it's pro forma. All of the

16 analyses that we see are generally positive, so if you

17 get the assurances, the answer is it's easy to write

18 back very quickly and say, you have our concurrence, go

19 ahead.

20 Okay, I'm going to stop there. That's our

21 role, but I'll be happy to answer questions when we get

22 to the Q&A part.

31

1 compounds for pharmaceutical purposes, or depleted

2 uranium for non-nuclear industrial purposes, then we

3 don't need government to government assurances.

4 Now, what about intangible technology and

5 software? And the answer is, yes. We don't

6 distinguish between tangible and intangible. Tangible

7 would be a blueprint for building a reactor.

8 Intangible would be the scientist or engineer who knows

9 what the blueprint looks like and goes off to the other

10 country to consult and provide assistance. That's

11 intangible technology. And that person has to get a

12 Part 810 before he can do that.

13 Many years ago, in the late 1980s, there was

14 a case where somebody came to me and said, we

15 understand that there are roughly 25 Americans who are

16 consulting for utility in a country I won't mention,

17 but it would have required a Part 810 approval. What

18 are we going to do about it? This is illegal. These

19 people are committing a crime. So we thought about it

20 for not too long and said, I'll tell you what we're

21 going to do. We're going to send out a message to the

22 relevant embassy and the embassy is going to be asked

33

1 MR. GOOREVICH: Well, instead of me standing

2 up, I'm just going to introduce Jeff from sitting down.

3 So, as I said, we're moving ahead with

4 building an E-licensing system. An E-licensing system

5 is, as I said, is going to reflect the process

6 improvement aspects of this. And so we've turned

7 internally to our CIO's office to help us build the

8 system and that's why we've asked Jeff to come here

9 today to give us a little bit of a preview on what that

10 looks like.

11 MR. WILKINS: All right, thank you, Rich.

12 Good morning everybody. I'm glad to be here with you

13 to give you a little high level overview on the

14 approach we're taking to building an E810 E- licensing

15 system.

16 As Rich said, I'm Jeff Wilkins, I'm the

17 Associate Chief Information Officer for IT operations

18 with the NNSA CIO's office. We've been partnered up

19 with Rich and is team for about the past six months,

20 kind of getting my technical team and me up to speed a

21 little better on the existing process. The planned

22 process improvements and the way that we might sensibly
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1 and iteratively leverage technology to make things

2 better going forward.

3 So, a little bit about my talk this morning.

4 We'll go into a little bit of the background. I'm sure

5 you're all well aware, and Rich has really highlighted

6 it in terms of the existing process during his talk.

7 We'll talk about the process that we will use to design

8 a system iteratively going forward. We'll talk

9 specifically about the Phase 1 objectives for the

10 system and the benefits that we expect to deliver to

11 all of the stakeholders who are involved in this

12 process and talk a little bit about specifically how it

13 will affect you going forward as stakeholders in the

14 process.

15 So, a little bit more of the background. So

16 what we've found--again, knowing nothing about 810

17 licensing prior to six months ago--we found that it

18 generally works well in terms of producing the desired

19 end result, but it faces some challenges. Some of the

20 things that Rich talked about. It could be more open,

21 it could be more transparent, it could be more

22 predictable, it could be more understandable. So

36

1 other component of the system.

2 We're going to utilize a phased approach in

3 building out the system, as I said before. Phase 1 is

4 going to be focused on that public site and work on

5 really improving the transparency for the end users,

6 for the applicants. We're going to facilitate the

7 interagency review process during Phase 1. And, in

8 terms of a rough schedule, once we've finalized and

9 gotten NIS sign off on the Phase 1 requirements, we

10 expect that development process to take around 3

11 months, okay?

12 Phase 2 is going to be that internal piece to

13 streamline NNSA's processes, get everything in one

14 place, impose some standardization, and the electronic

15 repository. We expect to include the requirements

16 analysis and the build out of the initial operating

17 capability to take around six to nine months, okay?

18 And then Phase 3 is really kind of ongoing.

19 Building in additional features and functionality.

20 Enhancing and incorporating feedback from the initial

21 phases and generally improving the whole site and

22 supporting the process improvement efforts that NIS is

35

1 there's a lack of a visible feedback loop, so there's

2 the transparency piece. We could certainly stand to be

3 able to collaborate better among the different

4 stakeholders as any given application goes through the

5 process. And there is a lack of a consolidated

6 repository of information--some of the challenges that

7 Rich spoke of.

8 So what we're going to do is simply build a

9 centralized system to provide a cleaner solution to

10 manage the process. So the way that we're doing this,

11 as I've said, we've worked together to build a features

12 list and set out high level objectives. We've

13 determined the logical structure of the final solution

14 and what that's going to be. And I'll talk a little

15 bit more about this and follow on slides.

16 Essentially, there's a public piece, right,

17 that needs to be available to applicants, foreign

18 governments, other agencies, and then there's an

19 internal piece for NNSA processing. So, as you can

20 imagine, the public piece is inherently less secure and

21 would house less sensitive data. The things NNSA needs

22 to do behind the firewall will be contained in the

37

1 undergoing. That would be, as I said, ongoing with

2 perhaps quarterly revisions and updates--releases.

3 So, again, I've used the word iteratively

4 incrementally quite a few times. You know, there are

5 quite a few examples in the federal IT space and the

6 corporate IT space, most notably Healthcare.gov

7 recently. If you try to be all things to all people

8 all at once and make a big splash, you assume a very

9 high level of risk. So, what we want to do is apply

10 technology smartly and iteratively to the most pressing

11 pain points first and then work forward.

12 If you're dealing in small chunks, it gives

13 you the opportunity to course correct in small doses

14 going forward so that eventually, when you get to the

15 end state, you're hitting the mark, okay? So we really

16 take that seriously and that's how we try to do

17 everything within our CIO shop.

18 And also, the testing, we'll be doing phase

19 testing, right? So there will be internal testing

20 first, and then we'll put it out to the stakeholders

21 for alpha and beta testing prior to release, to make

22 sure that we have the opportunity to have all of the
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1 feedback that we need in order to make sure that the

2 actual releases are providing the functionality and the

3 end result that you all expect.

4 So, specifically, some of the objectives and

5 benefits, as we've said over and over again:

6 transparency, so applicants will be able to

7 see in real time the current status and history of

8 their submission. So if a company has multiple

9 submissions, they'll be able to see all of their

10 records when they log in. And, as Rich mentioned, he's

11 going to build out a guide and all of those documents

12 in the associated FAQs, glossaries and things like

13 that, will be accessible via the online system where

14 they can be updated, managed, and you can access them

15 any time.

16 As far as accountability, you can track your

17 application through the process. There will be

18 auditability to comply with the ISO 9001 initiatives.

19 And so, every action in the system will have a user

20 name and a date and time stamp associated with it, so

21 that we can understand what's going on within the

22 system.

40

1 possible for the applicant to insure that they're

2 providing all the right information in the right

3 structure. And then, again, we'll try to make it

4 intuitive so that you don't need to take a course in

5 order to understand how to use the system. We'll use

6 standard design elements that you see out on the

7 Internet and so if you're at least surfing the web, if

8 you know how to type-- sorry, Dick--if you're doing

9 that, then you should have a pretty easy time of

10 navigating through the site, doing what you need to do.

11 And then, in this arena security is very,

12 very important. That's the major driver for developing

13 two different components of the system, right? There

14 are things that necessarily need to remain behind the

15 firewall. All of the internal things, a lot of the

16 supporting documents will need to go in on the NNSA

17 side behind the firewall, so that will be the Phase 2

18 piece. The public facing stuff, we want to make it as

19 easy as possible for self-registration, for being able

20 to access the information that you need to determine

21 the status of your application.

22 And then there will be a secure transfer of

39

1 And, again, the milestone history: you'll

2 have easy access to be able to see how long your

3 request has been in a given stage of the approval

4 process. So, if it's at State, if it's with a foreign

5 government, you can see where it is right now and how

6 long it's been at that point in the process.

7 Efficiency. We understand that right now

8 there are often duplicate copies of application

9 packages or lengthy documents that float around so that

10 different parties can review and comment on them. The

11 system will facilitate one copy. It lives in the

12 system. Everybody goes to that, rather than having to

13 manage multiple copies, manage your versions of

14 documents and things like that. You'll know when an

15 action is required. You'll get a notification. You

16 don't have to go check the system every day to see if

17 an action is required on your part. So that will be an

18 improvement.

19 Uniformity. Again, as part of having it

20 electronic, having one instance--we'll work with NIS to

21 understand what data fields, what formats, are needed

22 for each submission type so that it's as easy as

41

1 information between the public and the private side

2 that we manage very closely, in terms of the security.

3 But again, both components will be secured at an

4 appropriate level. All data will be encrypted and then

5 you'll only have access to the information that you

6 should have access to. Everything will be controlled on

7 a role-based basis. So folks who shouldn't have access

8 to your information, won't, okay? So we take that

9 very, very seriously and that will be a major focus of

10 how we design the system.

11 All right, so I'm moving through pretty

12 quickly. How will it affect you? It's going to

13 compliment the improved process. NIS is doing this the

14 right way. IT is not a magic bullet that can fix

15 broken processes or suboptimize processes. They're

16 doing the tough work first to improve the current

17 process, make sure that it works well and then we'll

18 automate the stuff that we need to reduce time, right?

19 Improve transparency via electronic means.

20 This is the right way to do things. And we

21 fight that battle every day. We have a lot of people

22 who believe that IT is the magic solution to fix
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1 horribly broken business processes and so it's been a

2 joy to work with the team in that regard.

3 NIS has made it very clear to us that we need

4 to stress and enable the ability for the current

5 support team to still be engaged, right? We don't want

6 to facilitate the NIS team hiding behind the system,

7 right? And they've assured us that they won't do that.

8 The system won't replace that personal care that you

9 currently get, as you go through the process. It will

10 just augment the current process.

11 And again, to the iterative phase nature of

12 things, it'll be a phase transition. We're not going

13 to flip a light switch and go immediately from totally

14 paper-based to completely electronic and automated.

15 It's going to phase in over time, so that there's not

16 going to be anything too shocking or dramatic. And,

17 again, it will give us the opportunity to course

18 correct as needed.

19 And then, ultimately, presumably the desired

20 end state would minimize manual entry and minimize the

21 use of hard copy documents and work to be as secure and

22 automated as possible, okay?

44

1 Many of them are, so I'm asking some of these questions

2 on their behalf. We have an export controls taskforce

3 with about 45 individuals, representing more than two

4 dozen companies, many of them here. And they have been

5 guiding all of our work at NEI.

6 My first question regards the objective of

7 the process improvement. We understand that any

8 regulator wants to be efficient and to the extent

9 there's inefficiencies, there needs to be some

10 improvement, but since you mentioned in your initial

11 remarks that effective trade support is one of the

12 goals of this regulation. And since you've

13 acknowledged that it's an increasingly competitive

14 international market that we're dealing with, I'd just

15 like to start with an observation that reduction of

16 processing times can't just happen in a vacuum. We

17 actually need--it's critical that the reduction in

18 processing times close the gap in the processing times

19 of other countries equivalent approval processes.

20 And if you look at Japan, South Korea,

21 Russia, those times are 15 to 90 days for equivalent

22 processes, as a study prepared by Pillsbury for NEI

43

1 So I moved a little quickly, but I think

2 we'll have time for questions, so I look forward to

3 talking further with you. Again, thank you and we're

4 very glad to be a part of this process.

5 MS. STRANGIS: I just want to remind everyone

6 that all the presentations you see today will be

7 available on our website hopefully today, if not early

8 next week. So you'll be able to pull those up.

9 We're going to take questions now on the

10 first portion of it. We have two people with

11 microphones. If you have a question, please state your

12 name and affiliation and remember that everything's

13 being transcribed and will also be placed on our

14 website. So, right up here?

15 MR. JONES: Hi, my name is Ted Jones. I'm

16 with Nuclear Energy Institute. First, I'd like to

17 thank you for going out of your way for having this

18 second meeting today. I know it wasn't an easy thing

19 to do and the shutdown created the inconvenience of

20 extending the time period for public comment and our

21 members appreciate it.

22 Not all of them were able to be here today.

45

1 last year shows. So I know that we're not talking

2 right now about the SNOPR. These process improvements

3 are taking place outside of it, but I hope that they

4 can be undertaken with an eye towards closing the gap

5 and keeping our companies competitive with our

6 international rivals.

7 To that end I'd like to ask about the E8 licensing process. If there are any--acknowledging

9 that there's an iterative process of phases, you

10 mentioned that you have a features list, would DOE be

11 able to share the features list with the phases during

12 which these features have been scheduled to be

13 implemented? Because the NEI export controls taskforce

14 provided some recommendations, including some timing

15 features that I think could bring the Part 810 specific

16 authorization process a little closer into line with

17 these other countries, which have binding time limits

18 in their rules. So that's my question.

19 MR. GOOREVICH: Me then you?

20 MR. WILKINS: Yeah.

21 MR. GOOREVICH: So thanks, Ted, for the

22 question. Yeah, we're aware of the importance of
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1 making our process work so that our applicants can be

2 as competitive as possible. But again, one of the

3 things that I stated early on, we'll fix the things we

4 can fix. And that's our goal, to fix the things that

5 we can fix and to automate it as much as possible

6 because of the transparency and the efficiency and the

7 understandability that we want.

8 And so, what we have to do is we have to look

9 at our processes internally and our processes that are

10 required by the legal requirements that we as the

11 government and you as the applicants or you as the

12 public have because of what's based in law. So when

13 people come to us and say, well, my competitor or

14 somebody else can get something through somebody else's

15 system faster than ours, there's an element of our

16 processes that's involved in that. But there's also an

17 element of how that country's legal system and

18 regulatory system is set up. And if, for example, a

19 country allows for nuclear technology transfers to be

20 transferred under an existing bilateral framework, they

21 can probably move faster than we can.

22 But if they don't have a framework with that

48

1 that's your call.

2 But the thing I wanted to state is that the

3 thing that the IT system will bring is the milestone

4 reporting, right? What you have right now, as I

5 understand it, everything's anecdotal. It seems like it

6 takes country XYZ a long time to do this or it seems

7 like we're not very efficient in getting through this

8 part of the process, over which we don't have any

9 control.

10 Having an automated system with reporting and

11 tracking will provide the management information that

12 NIS needs in order to exert influence on other parties.

13 To get them to be more responsive and more timely in

14 executing their parts of the process, so that's the

15 value we want to add.

16 MR. GOOREVICH: So the answer is, Ted, yes.

17 As they make them available to us and we're in

18 agreement, then we will make it available for public

19 consumption.

20 MR. JONES: Thank you.

21 MS. STRANGIS: Over here.

22 MR. PIERCY: Thank you. Good morning,

47

1 country, they probably can't transfer it at all. Where

2 our system is slightly different. It allows us to

3 transfer things to countries that you don't have a 123

4 with.

5 So there are pros and cons to everyone's

6 system and what we are trying to do is fix our system

7 to be the best that it can be, based upon the legal

8 requirements that have been laid out for us to do. So,

9 for us it's about making our system work as best as it

10 can. We understand that there's a comparative factor

11 to it, but it's not driving us to competitive factor.

12 What's driving us is making our system work better for

13 you--for the public's needs.

14 When it comes to the actual can we share?

15 I'll leave that to Jeff as to what he needs to do with

16 the development and what kind of feedback that he feels

17 he needs to make the system work.

18 MR. WILKINS: Right. So in terms of sharing

19 the feature lists as they are grouped within the

20 phases, you know, we're working through that and

21 whenever Rich is comfortable that it's suitable for

22 public dissemination, we're happy to provide that. So

49

1 everyone. Craig Piercy, with the American Nuclear

2 Society. Let me echo Ted's comment in thanking you for

3 doing a second public briefing. The American Nuclear

4 Society, 12,000 members of the American nuclear

5 community--many of whom work both for U.S.

6 nuclear suppliers and also for the agencies

7 that actually regulate those suppliers through the 810

8 process.

9 My question today focuses on the issue of

10 foreign assurances. Dick, you said you've had the

11 benefit of not learning how to do PowerPoint, but you

12 did do a PowerPoint in August and in that PowerPoint

13 you talked about doing foreign assurances in accordance

14 with long-standing U.S.

15 policy and Nuclear Supplier Group guidelines.

16 I'm trying to understand a little bit more

17 about it because foreign assurances seem to be in many

18 ways the long pole in the tent here and that can really

19 contribute to the really long delays. So, I guess what

20 I'm getting at is the scope and nature of our foreign

21 assurances now, is that anywhere required in law or

22 regulation? Or is that something that's developed
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1 organically over time?

2 And so, along those lines, we hear that other

3 countries move faster on foreign assurances, are they

4 asking for the same things or are we asking more? And

5 if so, why are we asking for more and is that grounded

6 someplace?

7 And then the second question I have is, is

8 there a possibility or is there a case where the State

9 can provide its concurrence to an application without

10 getting assurances? Without getting a signed foreign

11 assurance document? Thank you in advance.

12 MR. STRATFORD: If we're going to send out

13 reactors, fuel, major components for reactors, Section

14 123 of the AEA applies. And you have to have, for a

15 non-nuclear weapons state, full scope safeguards--which

16 means peaceful uses.

17 Peaceful uses and no retransfer without

18 consent are required by the Nuclear Suppliers

19 guidelines. That's something everybody has to do.

20 Whether for technology that's based in law as

21 components are, I actually don't know the answer to the

22 question. But I'm sure Rich does, since they implement

52

1 company proposed to partner with a country; one of

2 those two states I mentioned that are sometimes a

3 little slow. And we did not get an answer for a long

4 time and DOE called up and said, what do you suppose

5 the problem is over there?

6 So, we sent out something and asked the

7 embassy to go in and say, so, what's the problem? And

8 the answer came back, well, there's actually two

9 problems. Number one, the company hasn't contacted us

10 and number two, we have no idea who the company is.

11 We've never heard of them. Now, for diplomatic reasons

12 I did not put in the cable, ask the next question,

13 which is, so why didn't you ask, instead of just

14 sitting there?

15 So what we did is call back the DOE and said,

16 call your applicant. Tell your applicant to call the

17 proposed partner and tell the proposed partner to go

18 into X-agency and see Y-person, so that Y-person will

19 know what's going on and be prepared to give the

20 assurances. And then we got the assurances.

21 Yes, it's a long pole. Yes, we have to do

22 it. And to the extent that we can find a way to

51

1 Part 810.

2 Assurances are the long pole in the tent. It

3 just does not take DOE that long to do the written

4 analysis and get it over to us, and if we have the

5 assurances in hand, it takes us about a day or two to

6 get the letter back to DOE.

7 Generic assurances can be done for a specific

8 list of items for specific purposes. Remember, most

9 countries are generally authorized. When a country is

10 not generally authorized it's usually because there's

11 something going on in the country that we would not

12 assist.

13 So, for example, you'll never see China or

14 Russia generally authorized for the simple reason that

15 they are nuclear weapon states. You can do anything

16 that you want with--pick a country-- Belgium, but you

17 can't do anything that you want with Russia or China

18 because there are certain places that you can't go and

19 certain places you can't assist.

20 Sometimes, when a case takes too long, we

21 will prod and say, what's the problem? And I had a

22 specific instance of that not too long ago where a U.S.

53

1 streamline the process via generic assurances, we'll do

2 it.

3 MR. GOOREVICH: Yeah, so specifically 57b

4 does not require foreign government assurances. It

5 requires that the secretary make the non- inimicality

6 finding. I've been doing this in DOE for 23 years.

7 I've been doing 810s or working closely in this area

8 for 21 of those some years. I'm hard pressed to think

9 of a Secretary of Energy who is willing to sign off on

10 an authorization for which the State Department cannot

11 guarantee that the technology would not be

12 retransferred to somebody else, or diverted.

13 So, while it's not required in the law, it's

14 kind of hard for the secretary to make the non15 inimicality finding because if the technology was

16 diverted because the other government wasn't aware that

17 it was there and wasn't keeping an eye on it, you know,

18 think about transfers within the weapons states. And

19 then the question comes back, how was the secretary

20 able to make the non- inimicality finding and allow

21 this to happen. So it's sort of a Catch-22.

22 The issue really crystallized with the
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1 Nuclear Suppliers Group guidelines. And when the

2 nuclear Suppliers Group guidelines changed in 1993, to

3 add technology explicitly on the control list. So now

4 our obligations to the Nuclear Suppliers Group

5 guidelines say that we can only make the transfer when

6 we're sure of the peaceful uses. No retransfer,

7 physical protection, but that doesn't really apply in

8 the technology, and full scope safeguards. And, again,

9 in weapons states it doesn't apply in that case.

10 So we do have a commitment through the NSG.

11 It's not required by law, but then again, when we send

12 a package up to the Secretary of Energy and he says,

13 well, are we sure that the other government's aware of

14 this and going to treat this as we expect them to treat

15 it? Without the assurances the answer is, no, Mr.

16 Secretary and, you know, your guess would be as good as

17 mine as to whether a Secretary of Energy would actually

18 sign that out without it.

19 Up until now I haven't been brave enough to

20 take that risk. And, you know, whether State

21 Department would ultimately give us the concurrence

22 without it is--because of the NSG commitment--is the

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1 you will be shortening the time it takes for Specific

2 Authorizations to get through the process.

3 The first quick questions, how many days do

4 you think you'll shorten it by, on average? What's the

5 metric goal here?

6 MR. GOOREVICH: I don't--because each one is

7 different, it's hard to say how much we'll shorten the

8 process by, but my goal is to get it from application

9 to signature within 90 days. That's published right now

10 in the Federal Register notice.

11 MR. CATES: Okay. And the second question

12 is, this is outside of the rulemaking process. It's

13 very exhaustive. You're clearly an interagency effort

14 here, but if each of you were to be replaced tomorrow,

15 how would the new administrators of this program know

16 what to follow or what the requirements are? Is there

17 going to be a DOE interagency memo? Or is there going

18 to be an order--a memorandum of understanding that kind

19 of sets this out and what your expectations are?

20 Because at the staff level you're clearly

21 trying to make this work, but it's your effort. It's

22 your office's effort, it is not a requirement, so how

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1 other issue.

2 MR. PIERCY: Can I, just quick, a follow- up

3 question? So, Dick, are you going to Six Sigma the

4 foreign assurances process?

5 MR. STRATFORD: You know, in all honesty, I

6 don't know what Six Sigma is, so the answer is probably

7 not.

8 [Laughter.]

9 MR. STRATFORD: But will we try to streamline

10 the process where possible? Yes. Does it generally

11 work fairly quickly? Yes. Does it not work quickly

12 all of the time? Unfortunately, yes. In which case,

13 the only thing you can do is prod them. Send out a

14 note and say, go see Mr. So- and-so or Ms. So-and-So

15 and say, so what's the problem here?

16 MS. STRANGIS: Over here.

17 MR. CATES: Hi, Dwight Cates with Fluor. This

18 presentation is impressive. I think it's clear that

19 you guys have pulled it together. And you've talked

20 about it in several presentations I've been at over the

21 past two years, but I think it's coming together at a

22 point where it appears that when this is implemented

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1 does this live over 10, 20, 30 years?

2 MR. GOOREVICH: Well, I think the first

3 question--back to you, Dwight--is what are you offering

4 Dick and I?

5 [Laughter.]

6 MR. STRATFORD: You said you were going to

7 replace us, so we want to know what the offer is?

8

9 MR. GOOREVICH: He's not cheap, by the way.

10 Well, the NNPA of '78 requires that the executive

11 branch publish its process on export applications. So

12 Commerce, NRC--Commerce for the Nuclear Referral List,

13 NRC--us--currently have a Federal Register notice, I

14 think it's dated, like, 1982, that lays out the process

15 and how it works. So, ultimately, since we're making so

16 many changes to our process, we feel that we'll have to

17 go back and certainly update how the DOE process will

18 work and incorporate now a lot of the changes that

19 we're going to make. So we'll come out as a Federal

20 Register notice.

21 Internally, though, yes, part of the ISO 9001

22 compliance and certification is that we develop our own
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1 internal processes, guidelines, guidance, et cetera.

2 Now whether that's going to be enshrined as a DOE order

3 or as an internal memo- -or how it's done and how to do

4 this internally, we have to take a look at. Quite

5 frankly, that's sort of at the end of the process

6 improvement plan.

7 We have the ability to do a DOE order if we

8 want to, but since it really only affects certain parts

9 of DOE and not all of DOE, the management tends to shy

10 away from doing actual orders. But we will have to as

11 part of the ISO 9001 compliance certification and then

12 to maintain and be in compliance and certification, we

13 will have to somehow innumerate all of these processes.

14 The interagency part will be done through the

15 Federal Register notice, so there will be actually two

16 elements that will have to be update or created to

17 enshrine that, okay?

18 MS. STRANGIS: Here and then behind you.

19 MS. MANN: Thank you. Melissa Mann with

20 URENCO. Let me just echo some of the comments we've

21 heard and really congratulate you all on the

22 professionalism of this process. This meeting, in

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1 just inherent within all of NNSA. So if there's

2 anything that reaches the UCNI level or anything like

3 that, it's not going to be on the public system, right?

4 So without getting into specifics, we still have to

5 work through all of those details. We will provide a

6 very high level of assurance and, as appropriate, we

7 would be willing to share our information security

8 documents with the appropriate parties. To make sure

9 that everyone's comfortable with putting the

10 information there.

11 MR. RUDY: George Rudy, Integrated Systems

12 Technology, an independent consultant. I've got three

13 questions and I can take them one at a time or I can

14 give all three of them to you here.

15 First, if we were to make an application

16 tomorrow, use the old rules? Or is there some magic

17 date we should wait until we apply to make sure we have

18 all of the--

19 MS. STRANGIS: That gets into the rulemaking

20 end of it?

21 MR. RUDY: Yeah.

22 MS. STRANGIS: Yeah. We're not doing that

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1 particular, I agree with Dwight, it is really

2 impressing. And we do appreciate the opportunities for

3 comment.

4 I want to get down a little nitty-grittier on

5 the E-licensing system, though, and maybe, Jeff, you

6 could comment.

7 One of the things that my company is very

8 careful about and that we spend a lot of time looking

9 at is loading sensitive information on a server and

10 then sending it off into the public. Can you talk a

11 little bit about the security features of the E12 licensing system?

13 MR. WILKINS: So essentially we're going to

14 design the front-end system, the public system, to only

15 call for the type of information which is appropriate

16 for that type of system. And then we will work with

17 Rich and his team to adapt the process, to allow for

18 the submission of more sensitive documents in a manner

19 so that they only live in the system that's behind the

20 firewall-- the component that's behind the firewall.

21 You know, we are subject to some very, very

22 strict information security requirements and that's

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1 part now. Just process improvement questions, please.

2 Just about the presentation.

3 MR. RUDY: Okay. Okay, then maybe the next

4 question will work? If there are several technical

5 service companies and at least two or three product

6 companies that will be applying 810s, and this gets

7 back to your internal communication and making the

8 process work better, what is your recommendation on

9 their submitting their applications so that they, I'm

10 going to say, co- identify, that we are all working on

11 the same project? Is that within the question?

12 MS. STRANGIS: Yep.

13 MR. GOOREVICH: So, yeah, under the current

14 rules--and I don't think at least the process won't

15 change, as we envision the process. If there's a group

16 of companies--

17 MR. RUDY: Synced to the same project.

18 MR. GOOREVICH: --a team is coming together

19 to need an application. There two ways. First of all,

20 we'd like to have a discussion with whoever's going to

21 be responsible for the team because there's essentially

22 two ways to do it.
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1 One way to do it is that somebody steps up as

2 the lead for that team and then makes the application

3 on behalf of the team. So, you know, in some larger

4 projects, like reactor builds, a team comes together

5 and they sort of identify themselves as a unique

6 person, using the legal vernacular of the term, but

7 they're different. It may be four companies and

8 they're not the companies, they are the team. They're

9 Team Maryland bidding on this project.

10 And so an application will come forward as

11 the team and then we take into account all of that. In

12 terms of the processing and how they communicate, you

13 know, the paperwork all comes in together as the team

14 paperwork and, when we implement the E-licensing

15 system, they will have a unique identifier as that

16 team.

17 The other way is, is that the companies

18 decide that for whatever reason nobody wants to step up

19 and take the licensing liability of doing that, and

20 they can all apply individually, but they ask them to

21 sort of link the project together in their applications

22 so that way, when we send it around to the interagency,

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1 agreements for commercial nuclear development, both

2 within China and then selling products and projects

3 elsewhere. How does that affect all of this? I mean,

4 what is that final agreement, which I have not seen,

5 but I know that something exists? And how would it

6 affect the 810 relationships as it relates to China?

7 MR. GOOREVICH: Well, in terms of the

8 process, I haven't seen an agreement, either. So if

9 there is one where there--

10 MR. RUDY: There was a meeting.

11 MR. GOOREVICH: A meeting, yes. An

12 agreement, I'm not aware of, but if there was a written

13 agreement between us and the Chinese that said, this is

14 how we're going to improve our processes and the

15 assurance process, that would then be factored in and

16 it would be a discussion with the State Department for

17 how we will make the process work. But again, if you

18 haven't seen it, I haven't seen it, either.

19 MR. RUDY: Something's afoot, but I don't

20 have it.

21 MR. GOOREVICH: This is Washington.

22 Everything's afoot.

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1 we're saying, well, here's the first, but there's going

2 to be four more coming. It's all for this project.

3 State Department, when you go off and get the

4 assurances, let's be aware and inform the other

5 government that we're expecting four more. And when we

6 do this we ask State Department--and State Department

7 does this--to get the assurances for everyone up front

8 for the project.

9 MR. RUDY: Sure.

10 MR. GOOREVICH: So then when the other ones

11 come in, we don't actually have to wait on the

12 assurances. We have them and we can just issue the

13 paperwork. But our preference is that the team comes

14 forward because we don't want to have to send four or

15 five packages to the Secretary of Energy for

16 essentially the same activity.

17 MR. RUDY: Okay.

18 MR. GOOREVICH: But that's completely up to

19 the companies. And we understand there are business

20 reasons why they may or may not choose that route.

21 MR. RUDY: My final question, at least for

22 now, the secretary recently visited China and made

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1

2 MS. STRANGIS: Over here, Jay?

3 MR. KRAEMER: Good morning, I'm Jay Kraemer.

4 I'm a retired lawyer.

5 MS. STRANGIS: Me, too.

6 [Laughter.]

7 MR. KRAEMER: Thank you for coming in and

8 making this presentation, which is very illuminating.

9 I have two questions and the first is for Dick. I

10 think you've put your finger exactly on it with the

11 need for additional generic assurances. I think it's

12 going to be particularly useful, in light of the

13 proposal in the SNOPR to expand the list of countries

14 requiring a specific authorizations by 77 countries.

15 But I wonder what specific plans you have at

16 this point to go forward with those generic assurances,

17 particularly in those countries-- certainly including

18 China--where the market of the next decade seems to be

19 focused, at least for new build. And in pursuing those

20 generic assurances in the principal market countries

21 abroad, what the industry can do to facilitate your

22 undertaking in that regard?
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1 MR. STRATFORD: Well, to be blunt, we don't

2 have any plans to go seek generic assurances from a

3 particular country. But keep in mind that where we are

4 going is that the generally authorized countries will

5 be everybody with whom we have a Section 123 agreement.

6 And the ones that require specific authorization are

7 the ones that don't.

8 Translated, for the most part, those are the

9 countries with whom we are not doing nuclear business.

10 Now, there are going to be occasions where Mr. X says,

11 I want to go off and talk to Ghana about specifics,

12 with regard to a reactor, et cetera. And I need to

13 show blueprints, et cetera, et cetera. That's going to

14 require a specific authorization and there's not much

15 generic that we're going to be doing with Ghana.

16 However, if a company were to come in and say

17 it would streamline the process for us if we could get

18 generic authorization for country X, we would certainly

19 be willing to look at it. I mean, if it's a country

20 with whom we have no concerns and they're prepared to

21 give us generic assurance to cover a long list of

22 specific activities, that would be okay. As long as we

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1 MR. WILKINS: It's certainly doable and that

2 should be expected. You know, reminders are certainly

3 a common approach to system design, so, yeah, that's

4 fine.

5 MR. KRAEMER: Thank you very much.

6 MR. WILKINS: Sure.

7 MS. STRANGIS: Right up here.

8 MR. BLEE: David Blee, U.S. Nuclear

9 Infrastructure Council. Again, echo. We appreciate

10 the response to this and the outreach. I think it

11 importantly portends well for the future, with respect

12 to these process reforms which we think are critical,

13 and work--certainly--in tandem with the rulemaking,

14 which we'll talk about in a little while.

15 And, of course, we endorse prompt, clear,

16 predictable as the goals. I'd say the only tweak I had

17 on your comments were to move the effective nuclear

18 trade currently ranking in the fourth position to, at

19 least, the number two slot behind effective threat

20 reduction.

21 And then the process of reforms follow

22 because obviously what we're interested in is effective

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1 know what the activities and where the activity is

2 going to take place.

3 So, if a company comes in and says, I want to

4 help country X, there are six locations that they want

5 me to do things at and these are the things they want

6 me to do at these locations, the answer is, yeah, I'd

7 give that serious consideration. And probably say,

8 yeah. Let's go out and ask for the assurances, but it

9 depends on the country.

10 MR. KRAEMER: Thank you. And Jeff, my second

11 question is for you. You indicated that the computer

12 arrangements that you have would provide notice to the

13 applicant if there were some action required of the

14 applicant. And I wonder if it's practicable to provide

15 notice whenever there's a change in status?

16 MR. WILKINS: Sure.

17 MR. KRAEMER: Because, I mean, it's the

18 absence of a change in status which requires the

19 applicant to check every day. So if the applicant

20 automatically got notice, then that would make the

21 system much more useful from the applicant's

22 standpoint.

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1 nuclear trade, representing a consortium of 50

2 businesses to that end. In terms of--as I think some

3 of you have heard from some of the folks here, the

4 enshrinement of this process is critical, to use a word

5 that's been used. And I can understand why you don't

6 want to enshrine it in the regulation, however I think

7 it's critical to provide some definitization of that

8 process through whatever mechanism you feel is a good

9 one, since you've been doing some good play calling

10 lately. So we look forward to more in that regard.

11 As far as the--I would suggest--you know,

12 Dick, I've read a few books on Six Sigma and I'm not

13 sure what it's all about, either, but I hope there are

14 typing lessons, by the way for him in this budget.

15 [Laughter.]

16 MR. BLEE: But in terms of the--a 360 review,

17 I think, again, of what exactly is being done on the

18 international regulatory front would seem to be able to

19 be embraced by a Six Sigma review, in some respects.

20 So, again, that's always a healthy thing to do.

21 So, again, thank you for your continued

22 responsiveness and your outreach today and we look
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1 forward to the coffee break and the next session.

2 MR. GOOREVICH: So, yeah, David, thanks for

3 the comments. My biggest fear coming out of this

4 meeting was exactly your comment there because now I

5 can envision C.J. saying he needs to go to Europe to

6 start interviewing people for the Six Sigma process.

7 He said next week, which now calls into

8 question C.J.'s analytical abilities because I would

9 have waited until the spring, C.J. Paris in the

10 springtime is a lot better than Paris in November.

11 You know, one of the things that I tried to

12 stress and that I think is important is, what we heard

13 from the comments. What we're now hearing as--we're

14 hearing from applicants about business is that how

15 business is being conducted is changing. It's evolving.

16 It's always evolving and that whatever process we put

17 in process today will have some flexibility in it, but

18 at some point that flexibility will end and applicants

19 will be looking for--because they're doing things

20 differently with their customers or they're doing

21 things differently with their teaming partners--will

22 say, your process is no good anymore, Rich. Fix it.

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1 ever write regulation, so how do we implement processes

2 to add some flexibility, don't lock it in, so that we

3 can then change and evolve with the industry?

4 Hopefully, a little bit ahead of the industry so that

5 there really isn't the lag time.

6 MR. BLEE: Yeah, I think you're trying to

7 actually, in retrospect, maybe to--maybe the better

8 word is just the definitization, but schedules,

9 metrics, those sorts of things. Enshrinement would

10 connote, certainly, installation, a one-time coronation

11 or entombment. So we'd prefer not to have that. Yeah,

12 so, living, breathing, all that other good stuff.

13 MR. GOOREVICH: Yeah, entombment's a good

14 word.

15 MS. STRANGIS: Ted?

16 MR. JONES: I just want follow up a question

17 I heard Craig Piercy ask earlier. Maybe I missed the

18 answer. He, I think, asked if we are asking in the way

19 of foreign government assurances something different

20 from what other supplier countries are asking? And if

21 so, then why?

22 MR. STRATFORD: The answer is if they're a

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1 If I'm still here, but Dwight may hire me away, so--

2 from what I heard today.

3 So when I say enshrined, it's about insuring

4 that we all know what we're doing, but I don't want it

5 to be so set in stone that we have to go through a

6 heavy lift to adjust to be able to meet the

7 requirements of the applicants.

8 And one of the things that we've learned here

9 is that these requirements are not stagnant. It won't

10 be stagnant and we shouldn't expect them to be

11 stagnant. We should expect them to change. And so for

12 us the challenge, you know, really, not just for my

13 group, DOE, but for all of us in the U.S. Government

14 is, how do you implement regulation in an ever changing

15 world? Because the nature of regulation is that, you

16 know, we expect processes and we expect things to

17 remain the same because to be transparent, to be fair,

18 to be all those things, regulation tends to have to

19 sort of just be stagnant. So that's really the

20 challenge and it's really a larger conceptual question

21 that we're grappling with, which is, the nuclear

22 industries, it's moving fast. It's faster than we can

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1 member of Nuclear Suppliers Group, no, because the same

2 applies to everybody. Now, I'll know better, exactly

3 what's going to happen probably within a few weeks

4 because one of the NSG governments is running a survey

5 on government to government assurances. And, as a

6 matter of fact, I've got our answers in front of me.

7 What are the forms of governmental assurances

8 required? Well, when the answer comes back to that

9 from all the members I'll know precisely what they're

10 asking.

11 Do you require assurances for all trigger

12 list items? Yes, we do. Do you require a governmental

13 assurance for intangible? Yes, we do.

14 Do you have cases where a governmental

15 assurance can be replaced by an end user statement from

16 the customer? In commerce cases, that's true and

17 sometimes an item that's on the list is being used for

18 a dual list purpose, in which case an end user

19 statement would work.

20 Do you have a target time set? Yes, we try

21 to get it done within 60 days, but assurances can take

22 longer. What's the average turn around? A few days to
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1 a week for most cases.

2 And do you have any suggestions for

3 streamlining the process, was the last question that

4 the country asked and the answer was that situation I

5 told you about where the country that you're asking it

6 from has no idea who you're talking about. In which

7 case there should be sort of a generic advice to all

8 companies who apply for 810s, which is tell your

9 customer to please be aware of the need for assurances

10 and tell the customer to get in contact with the

11 appropriate authorities, which I think would be good

12 advice up front, so you're not sitting there for five

13 or six weeks and we're sitting there waiting for

14 assurances that the other country doesn't want to give

15 because they don't know who you're talking about.

16 MS. STRANGIS: Let's take one more question

17 and then go to--

18 MR. JONES: Let me add something on.

19 MS. STRANGIS: Okay.

20 MR. JONES: Just by way of clarification,

21 Dick's the outgoing chair of the Nuclear Suppliers

22 Group and a member of the troika. I chair the

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1 we're doing?

2 MR. WILKINS: So, as I stated during my

3 presentation, sort of the expected roll-out timeline

4 for Phase 1, which is the public facing phase of it is

5 going to be T plus three months or so, if you will,

6 from the time that those requirements are codified and

7 approved by NIS.

8 At that time there will be an initial

9 operating capability of tracking. You'll have a

10 certain level of visibility into the status of your

11 application. Now, because the back end will be a

12 follow on phase, there'll be some degree of manual

13 updating on the part of NIS to put the statuses in the

14 system. That's kind of how we expect it to work, so

15 sort of T plus three months or so. You'll start to see

16 improvements in that regard. And that gets back to the

17 word I used 50,000 times during my briefing which was

18 iterative and/or incremental.

19 We want to do this in a way so that you start

20 basically immediately to see benefits, rather than

21 waiting two years for this huge project to complete

22 that, by the time two years has elapsed, will probably

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1 consultative group of the NSG. This was started

2 because there was a view within the group that

3 assurance processes aren't working very well for a

4 number of governments, okay?

5 So I understand certain individuals do

6 studies and kind of get some licensing data, but this

7 is because the NSG recognizes that we need more

8 information and we need to do better.

9 Now, your next question will be, well, can we

10 see the results of the survey? And the answer is no.

11 It's NSG confidential information, therefore U.S.

12 Government official use only. But certainly the

13 results of the survey is something that we're going to

14 be factoring into our process improvement as we go

15 forward.

16 Okay, I'm done now.

17 MS. STRANGIS: Okay.

18 MR. RUDY: Yes, George Rudy again. A

19 question for Mr. Wilkins. And this goes hand-in- glove

20 with the question I asked earlier regarding the

21 applications timeline. When would tracking, do you

22 think, be available so that we can be on top of what

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1 miss the mark, right? Does that answer your question

2 well enough?

3 MR. RUDY: Yes, sir.

4 MR. WILKINS: Okay.

5 MS. STRANGIS: So keep in mind there will be

6 time later for you to provide us with more feedback, so

7 let's take about a 15 minute break. We are the

8 government, so we have no refreshments, but there's a

9 Starbucks upstairs.

10 [Break.]

11 MS. STRANGIS: So we're going to get started

12 again. If everyone would take their seats, that would

13 be great. Okay, we're going to start with the second

14 part of our presentation today and that's the proposed

15 Rulemaking Overview. So with that I will turn it over

16 once again to Rich.

17 MR. GOOREVICH: Okay, so what did we learn

18 this morning? We learned that Dick can't type and he's

19 even worse at PowerPoint, which is fine. You know,

20 I've gone--many of you have seen me give these talks

21 before and at some point I've got to give a story, so--

22 Katie's a little nervous because we went a little long
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1 the last session, but I have to give this story.

2 My wife's a teacher in Montgomery County and,

3 you know, as part of being a teacher you have to go

4 through the summer license renewals, continuing

5 education. And right after we were married and I

6 started working at DOE--probably my second or third

7 year at DOE--she had to take one on science. You know,

8 one of these summer-long things on science and this was

9 really before PowerPoint was the rage.

10 She walked in one day and the session was on

11 nuclear and there was someone from the NRC there--

12 Brooke--and it was an engineer and he was going to talk

13 about nuclear technology and it's like a four hour

14 class in the mornings that she had to take. This guy

15 walked in with five inches of transparencies, with an

16 overhead projector, and just started.

17 He started with Transparency 1 and he went

18 four hours straight. Transparency after transparency

19 after--my wife, all she took from it was nuclear and

20 government. She came back home and then said, is that

21 what you do? And so, my wife's view for many years

22 was, that's all I did at work was just make

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1 authorized. There are other PSAs out there. We have a

2 PSA with Jamaica, I think we have one with Chile.

3 Under the U.S. IEA agreement for cooperation, we have

4 the ability to do PSAs, and so anything that's a PSA is

5 the equivalent of a 123 and would be under the general

6 authorization list.

7 Again, as I talked about in August, one of

8 the major reasons for this comes down to the non9 inimicality finding. The issue that we see that we

10 have is that, how does the secretary make the non11 inimicality finding when he's looking at classifying

12 countries?

13 Through the 123 process, through the Non14 Proliferation Assessment Statement, the NPAS, from when

15 we submit a 123 agreement to the Hill for

16 consideration, both the Secretary of State and the

17 Secretary of Energy are signing off and saying that

18 they've made the determination that that country, that

19 end user has made essentially the non- inimicality

20 finding through the paperwork, through the NPAS to the

21 Hill. It is the only place that I know of, and that we

22 can find, where there is a written non-inimicality

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1 transparencies and then I'd go off to Vienna with Dick

2 and just turn over the transparencies, one after

3 another for a period of time, which sort of got me off

4 of the idea of PowerPoint because, you know, it's my

5 wife. I've got to seem at least somewhat cool to my

6 wife--not too nerdy.

7 And so the difference between me having

8 PowerPoint slides and Dick not having PowerPoint slides

9 is really a function of the fact that my staff is

10 younger than Dick's staff and they know how to use

11 PowerPoint. So that's why I have PowerPoint slides.

12 You like that one, Zach? Yeah, okay, good.

13 All right, so you guys have all seen these

14 slides before. These are from August--some of the key

15 proposed changes to the SNOPR.

16 Destination classifications. From between

17 the NOPR and the SNOPR, as I talked about in August, we

18 did not make any changes to the GA assay way that we

19 worked it out, for the majority.

20 One of the changes that we did make was that

21 all IAEA project and supply activities, such as Mexico,

22 Laguna Verde project, would remain generally

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1 finding by both the Secretary of Energy and the

2 Secretary of State regarding nuclear exports.

3 It is a way--the law requires the secretary

4 to make that non-inimicality finding. How does the

5 secretary make that for other countries that are not

6 doing this? Well, if we wanted to make countries, the

7 other way we could do it is we could go through every

8 country in the world and start doing it. The issue is,

9 that would be an extremely long, lengthy process and

10 still then we'd still have the issue of assuring that

11 there was Congressional oversight on these activities,

12 as well.

13 So, as one of the major reasons that we're

14 doing this. Dick talked about some exemptions to that

15 earlier. That remains in effect, but the non16 inimicality finding and meeting the requiremental law

17 is obviously a big factor in driving our requirement.

18 We'll talk about the impact of this or

19 potential impact or lack of impact, depending upon how

20 you want to look at it, in a little bit when we talk a

21 little bit more about the economic study which we were

22 not able to get into during the August meeting and we
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1 wanted to make time available to do that here.

2 Other proposed key changes: deemed exports

3 would be generally authorized to foreign nationals

4 employed at the U.S. nuclear facilities if the employee

5 signs confidentiality agreements. Access is authorized

6 in accordance with NRC standards and the employer

7 reports it to access to DOE. It's just a reporting

8 requirement. And we talked about the NRC standards and

9 the NRC gave us a very comprehensive and detailed

10 briefing in August as to what that means and how to go

11 about doing that. But my assumption is that most of

12 you knew how that happened anyways, but we wanted to

13 make sure that everyone was clear on that.

14 It's a major change. What we're saying is,

15 if NRC has the regulatory responsibility, the

16 regulatory responsibility for access, and the ability

17 to perform work at that site remains with the NRC and

18 essentially all we're asking is that we are just

19 informed of it, just for our own records management

20 because right now we are not informed by NRC of

21 everyone who is there on that. So, a major change

22 dealing with the deemed exports.

84

1 programs. So these are what we heard loud and clear

2 from the proposed changes was activities where there's

3 peer reviews and benchmarking done by international

4 organizations to help with the operation of reactors

5 here in the U.S. and safeguarded reactors outside the

6 U.S. We're looking to make that easier and generally

7 authorizing those, as long as we just know about it in

8 advance.

9 And then extended DOE period. Since we're to

10 45 days, but in responses it's not 45 days for us to

11 respond, it's 45 days and if we don't respond, then

12 you're okay to go. The goal is for us to respond

13 positively within that time, but if it gets to be 45

14 days and you haven't heard from us, you'll be okay to

15 go. So it puts the onus on us, rather than the

16 applicant and helps hopefully with some predictability.

17 Other proposed changes: Commerce, NRC, and

18 State approved exports would be exempt from Part 810,

19 again to avoid duplication. Transfer of public

20 information would be generally authorized. We are

21 proposing the standardized definition to make transfers

22 exempt. Activities with remote connection to SNM would

83

1 Covered reactor technology. Scope is

2 changing as we've laid out. Narrow to reactor

3 technology related to SNM production, and this is

4 consistent with NRC and Commerce coverage and

5 consistent with our Nuclear Suppliers Group

6 obligations, and so those are some changes that we see,

7 moving forward.

8 Operational safety. Existing rule provides

9 for fast-track authorization for operational safety for

10 nuclear emergency assistance. The problem in the

11 current rule versus what we have in the SNOPR, based

12 upon the comments we heard is there's no definition of

13 operational safety and so we're adding a definition and

14 we're tying the definition to established safety

15 standards.

16 Before I talked about flexibility, as those

17 safety standards evolve, especially in all of the post18 Fukushima discussions, then the definition obviously

19 would evolve, as well. So, we're trying to add some

20 flexibility to keep up with where the global standard

21 is with regards to the operational safety.

22 Authorized safety exchange and benchmarking

85

1 be authorized or not covered--I'm sorry activities that

2 are too remote would essentially not be covered. So,

3 for example, mining and milling, not going to be

4 covered. Too indirect.

5 Medical isotope production. Although it uses

6 SNM, it is not essentially producing or developing SNM,

7 not going to be covered.

8 Fusion and a lot of--when I say back end, I

9 don't mean reprocessing, but I mean after reprocessing10 -sort of some of the disposition in transportation

11 aspects that were covered, essentially because of the

12 broad definition that we had in the NOPR, now in the

13 SNOPR, we've narrowed the definitions down on that.

14 Activities carried out by IAEA personnel

15 would be generally authorized, if they're working for

16 the IAEA, except employees working on an S&T

enrichment

17 and reprocessing. And that's because of Section 127

18 and 128 of the Atomic Energy Act that does not allow us

19 that authorization under 57b.

20 Commenters proposals that are not being

21 proposed in the SNOPR. We got into some ideas about

22 deregulating activities of foreign affiliates and then
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1 with the definition of a foreign affiliate that had a

2 certain percentage of ownership or not.

3 You know, when we looked at this and we

4 looked at our interpretations that we've made in the

5 past with the application of 57b, the law and the

6 Congressional Record does not provide us--when the law

7 was created--provide us any guidance on how much--

8 whether it's U.S. technology or foreign technology.

9 All it says is that a U.S. person providing that

10 assistance and, up until now, the rule and the law have

11 meant any technology regardless of the ownership.

12 It's the person doing the activity, it's not

13 the ownership of the technology and so we don't feel

14 that at this time that we can make that change to

15 incorporate a percentage of ownership on a technology

16 or on assistance because it's still the U.S. person

17 providing it. And so, it gets back to what 57b says

18 that caused us to have some pause on incorporating that

19 into the SNOPR.

20 Persons with dual citizenship, based on the

21 most recent or current residence: here, this was--and

22 I'll be honest with you, this is something that we've

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1 individuals, if the recipient is there.

2 Now, having said that, I think what's clear

3 though is that we have to define who the person is in

4 the recipient country. So, for example, if it's a

5 Canadian company and there happens to be a person who

6 works at that Canadian company who is not Canadian and

7 comes from a specific authorized country, the transfer

8 is to the Canadian company. The Canadian company is

9 the person, not every employee in that company.

10 I know there's been some discussion, in other

11 public meetings that 810 may be applied to mean the

12 citizenship of every employee in a particular company,

13 but if we can determine through the application that a

14 company in another country is the person who is

15 responsible for the receipt of the technology, we will

16 not and do not take into account the citizenship of

17 every employee at that company.

18 General authorization of the trial, sales,

19 marketing, and sourcing information, again, we don't

20 really have much ability because of the way 57b writing

21 to have considered it at this time. And then, sort of

22 the flip of the first point on the foreign owned, there

87

1 been going back and forth on for a long time, even

2 before the rulemaking, as we get into this. The issue

3 ultimately doesn't come down to the law, it comes down

4 to our NPT obligations. And, essentially, who takes

5 responsibility for this person. So, a person with dual

6 citizenship, really, who does he represent in what's

7 going on? And given our requirements and given UN

8 sanctions, you know, because quite frankly a lot of

9 these cases we get tend to be people who have been

10 sanctioned by the UN, or non-NPT parties having another

11 citizenship and residing in another country, but are

12 not a full citizen of that country. And there are

13 countries that give passports out that are not

14 citizens, or maintain citizenship of both countries.

15 So if we don't really understand who is

16 responsible, which government is taking responsibility

17 for the recipient, it makes it very hard for us to try

18 and implement the requirements of the law. And so, for

19 us, we feel that because of treaty obligations, because

20 of sanctions, obligations, and because of 57b at this

21 time we really could not include--or this time we had

22 to take into account all of the citizenships of

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1 was a proposal on generally authorizing something that

2 is Americanized. And, again, it's the same

3 considerations that we had to take into account.

4 So, with that--kind of that's the overview of

5 SNOPR changes. I didn't want to spend a lot of time

6 because the SNOPR's been out for a lot of comment. I

7 think we want to use as much time to get the feedback

8 from you guys on what you think about the SNOPR and I

9 wanted to make sure that we had time to talk about

10 something that was of interest to everyone at the

11 August meeting that we didn't have a chance to and that

12 was the economic impact analysis that was done as part

13 of our submission to ONB of the SNOPR. So, with that,

14 what I'd like to do is turn it over to Tom Wood and

15 Chris Toomey from PNNL, one of our laboratories who

16 work for the Department of Commerce on performing the

17 economic impact analysis. So, let me give it to Tom.

18 MR. WOOD: Thanks, Rich. I'm just getting it

19 out of the way to get out of the beam from the light.

20 I'm Tom Wood, my colleague Chris Toomey and I were the

21 principle analysts and authors of the economic impact

22 analysis that was incorporated in the SNOPR. It was
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1 done between the publication of the NOPR and the

SNOPR,

2 so we came a little late to the party, but I think we

3 had plenty of time to look hard at the problem.

4 As Rich said, PNNL is one of many labs that

5 support the NNSA export control and policy functions

6 routinely. What I'd like to do today and I hopefully

7 can do this briefly, so we have time for questions, is

8 just to frame the problem a little so you understand

9 the questions that we attempted to address in the

10 economic impact analysis and then let Chris talk about

11 the actual calculation of the direction and magnitude

12 of the impact.

13 And I think if you understand the question

14 that will help you make the appropriate input and

15 comments and we want to listen very carefully to your

16 comments.

17 So the scope of the study was generally

18 focused on predicting the measurable impacts of the

19 proposed regulatory change. The principle feature of

20 the regulatory change that we would expect to drive

21 these impacts is this reclassification of country

22 status for the 80 affected countries. Some countries

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1 there is some other projections we considered, as well.

2 The two very thin slices of the pie at the top

3 represent the trade in the countries that are affected

4 under the proposed regulation.

5 The green slice represents countries for whom

6 810 status is unchanged at SA. The orange slice is

7 unchanged GA countries. Much of the question that we

8 wrestled with in this economic impact analysis dealt

9 with the relative magnitudes of the two small slices,

10 that is the blue and yellow slice, in terms of whether

11 affected trade moving in the direction of SA to GA was

12 larger or smaller than the reverse. But as a starting

13 point, I think it's good to realize the scale of those

14 changes is much less than the global nuclear trade

15 considered as a whole.

16 Another point that I want to emphasize just

17 in starting is that, in a sense, we are analyzing

18 economic impact for an undefined end state. In the

19 sense that we are comparing competitiveness or the

20 integrity of our export process under SA and GA and

21 that we're dealing with historical statistics for the

22 existing SA process, rather than the process that will

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1 moving from SA to GA status and some countries moving

2 from GA to SA status.

3 We worked on this problem for several months

4 in this current fiscal year. We got a lot of support

5 and a lot of very insightful and critical coordination

6 collaboration with the Department of Commerce ITA

7 economic staff, led by Joe Flynn and we're very

8 grateful for that. We think it improved the product

9 quite a bit.

10 So, for today, I'm going to talk briefly

11 about conceptual foundations. Chris is going to talk

12 about the actual calculation and quantitative impact.

13 The first point I would like to make is that

14 the scale of the affected markets is actually pretty

15 small compared to the universe of global nuclear trade.

16 This is a pie chart that shows a hypothetical nuclear

17 trade scenario for the next roughly two decades that

18 counts trade basically by the volume or the number of

19 gigawatt electrical capacity in nuclear reactors that

20 is projected to be realized in the world.

21 Now, this particular projection underlying

22 this viewgraph was by UxC, but as you'll see later

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1 come out of the process improvement efforts. And so,

2 in that sense we had to be somewhat flexible and

3 parametric in doing the impact analysis.

4 So, really, the conceptual basis is pretty

5 simple and it's that this relatively lengthy, opaque,

6 uncertain and unclear process under SA is a competitive

7 disadvantage in some cases and we need to understand as

8 far as we can the extent to which that is so.

9 The statistics we had were from a database

10 called the Proprietary Export Database, which really

11 covered about three and a half years of individual

12 transactions in the SA process, in great detail. We

13 didn't have comparative statistics for GA transactions.

14 We had aggregate statistics for GA transactions.

15 I think the key insight in the study--and

16 there may be some discussion of this, but the

17 assumption we made is that whatever impact there is in

18 moving a given country from SA to GA, it would be

19 reversed if you moved the country back in the other

20 direction, so that the effect or the mechanism that

21 causes economic impact is symmetric and that's a key

22 assumption because what it tells you is that the
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1 direction of overall economic impact of the proposed

2 regulation is really just a function of the relative

3 trade volumes for those two sets of countries.

4 It's not a function of the extent to which a

5 particular transaction is disadvantaged under a given

6 set of SA rules. As I said earlier, the data that we

7 used is about three and half years of data on specific

8 transactions that were in and had moved through a

9 specific authorization queue. This database describe

10 the nature of each export in some detail. It described

11 the estimated or proposed by the vendor--or expected

12 dollar volume of that export transaction. It tracked

13 the status of approval and denial, if any dates.

14 There were 97 transactions. The average

15 annual dollar volume of this data was about $2 billion

16 a year.

17 So, when looking at this data--and we looked

18 at it in some detail, including familiarizing ourselves

19 with the nature of the transactions and how they had

20 faired in the process, it was very clear from reading

21 the documentation about individual transactions, that

22 there are three drivers for this trade.

96

1 trade and trying to identify what is the most relevant

2 time span to do this analysis. And, as we all know, we

3 can't predict the future and that, as Rich has

4 mentioned many times, the future is constantly evolving

5 and probably that evolution is accelerating, which

6 makes the prediction of trade patterns very difficult.

7 However, there's a lot of information out

8 there in the private sector about current market shares

9 and projections of nuclear growth over a defined set of

10 time. And most of those tend to coalesce around the

11 2013 to 2030 range and we were pretty comfortable with

12 that time span, given that it was consistent between

13 the projections and anything beyond that started to get

14 a little bit hazy.

15 Some key assumptions that we made is that the

16 U.S. industry remains as competitive in nuclear

17 technology markets as it has been in the period of

18 record in the database. And that the global trade

19 volumes will evolve consistent with the range of

20 nuclear energy forecasts.

21 When I say, a range, we looked at quite a few

22 and I'll show you the chart of the ones that we

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1 One is the extent to which countries are

2 planning nuclear power. A lot of this trade is

3 associated with plans for new plants and we were able

4 to identify a subset of the 97 transactions who fell in

5 that category. Similarly, the volume of construction

6 activity is a big driver and it was very clear which

7 transactions were associated with actual construction

8 of plants.

9 Finally, there is some technology that is

10 used in the operation of a plant. Fuel technology,

11 safety technology associated with the continuing

12 operation of plants. That was also easy to identify in

13 the database. So the basic starting point for the

14 quantitative analysis was to sort this set of

15 transactions into those three categories and then

16 conduct a statistical analysis.

17 So, at this point, I'm going to let Chris

18 take over and describe that analysis. We will both be

19 available for questions.

20 MR. TOOMEY: Thanks, Tom. So, building on

21 what Tom has mentioned and described qualitatively,

22 where we started was taking those three categories of

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1 considered. Taking the qualitative understanding of

2 the types of trade combined with the export dollar

3 volumes that had observed in the PED, we were able to

4 derive a series of base rates. And basically what this

5 means is that we could estimate the dollar value per

6 megawatt for each type of trade. So there's a dollar

7 per megawatt for existing power M&O capacity. There's

8 a dollar per megawatt for every megawatt under

9 construction, and there's a dollar per megawatt for

10 planned or future construction.

11 So we took that data and, as you can see

12 here, we derived these rates. What you'll notice is

13 that the future dollars are worth more than current

14 activities, so the value of trade for existing reactors

15 is fairly low. Construction megawatts are fairly

16 higher and even higher is the planned, projected

17 megawatts. So this does match up with what we were

18 seeing in the pie chart earlier, but this was the basis

19 for all of our estimates.

20 This was then combined with a series of

21 nuclear projections at the country level, which we were

22 able to match up with the SA to GA and GA to SA lists.
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1 Just as a reminder, looking at historical

2 nuclear power growth, you know it's been fairly

3 consistent over the last decade or so. Not large, but

4 consistent. We've noted the three famous nuclear

5 incidents, Three Mile Island, Chernobyl, and Fukushima.

6 Obviously, we don't have any information on nuclear

7 growth past Fukushima, but the previous history is

8 fairly instructive in that things are going to be

9 slightly steady. The won't be level, but they will be

10 steady.

11 Looking at the accepted industrial and

12 academic forecasts for the growth of nuclear power,

13 what you see on the left is where the IAEA has tracked

14 up to today and then on the right hand side, in the

15 different colors, are the different projections that we

16 were able to look at to bound our thinking. We have

17 data from WNAH, from UxC, from EIA, as well as NAC

and

18 ERI.

19 Some of these data were at aggregate levels,

20 some of these data were at country levels. We were able

21 to use WNA, UxC, NAC to match up our base rates with

22 the country level information so that we could create

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1 the time period we assessed is significantly larger

2 than the countries in the other category. Again, WNA

3 High reverses that trend, however that particular

4 projection incorporates again the upper bound of

5 perfect outcomes in the nuclear industry in countries

6 that are primarily in the GA to SA category. But

7 again, we feel that the numbers in the first three

8 categories are fairly convincing in that the SA to GA

9 trade, the benefits accrued from those particular sets

10 of countries far outweigh the relative trade disruption

11 going the other direction.

12 As Tom mentioned, there was a component of

13 this where we were dealing with an uncertain future and

14 what we tried to do is understand, or at least get our

15 hands around the potential impacts of those

16 uncertainties. So as these processes improve, as this

17 particular regulation gets implemented, the benefits

18 will begin to accrue and we didn't-- obviously, we

19 can't predict how much or how for how long, so we just

20 did a set of parametric analyses to look at the net

21 impact based on potential trade growth in the SA to GA

22 countries, again, amongst the different projections.

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1 the projections that are kind of the center piece of

2 the economic analysis.

3 As I mentioned, WNA, we used both the high

4 and low cases, but as you might have noticed before,

5 WNA High and WNA Low are quite divergent. We also

used

6 UxC and data from National Insurance Corporation. And

7 both statistically and within the eye test, WNA Low,

8 UxC, and NAC seem to all coalesce around a series of

9 likely futures. We did, again, look at WNA High and

10 there is an assessment of that projection in the

11 economic analysis you can find online. And we found it

12 to be unlikely sensitivity case, however, it is

13 presented here for sake of completeness.

14 Again, when we take the value at the base

15 rates for each of the countries within each forecast

16 and then aggregated it at the country category and then

17 averaged it both per year, as well as presenting the

18 aggregate number, you can see that trade going from

19 countries that are going from GA to SA is dominated by

20 trade going the other direction.

21 The three countries in the SA to GA category

22 both at an annual average level and in aggregate over

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1 And again, this does bear out that the SA to

2 GA benefit to nuclear industry far outweighs what you

3 would see going the other direction. Again, the details

4 of this calculation are found in the report, but again

5 we're trying to grapple with that question of

6 uncertainty. We use between 10 percent and 40 percent

7 just as a bounding case, but at the end of the day what

8 we found is that the way the rule was constructed and

9 the countries that are included in the recent generally

10 authorized update are where nuclear growth is going to

11 be happening, combined with the pie chart at the

12 beginning in that the majority of trade in high volume

13 countries is unaffected. We have found that the

14 economic benefits are potentially accruing to nuclear

15 industry are high and far outweigh what potential

16 disruption we may see in the 77 countries moving from

17 GA to SA.

18 As Tom mentioned, we'd be happy to take any

19 questions that you may have on process, on conclusions,

20 or otherwise. Thank you.

21 MS. STRANGIS: Okay, so we are going to open

22 it up now and then at the end we'll have a few closing
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1 remarks from the lovely Joyce Connery, who is here.

2 You'll notice the panel is a little cozy down here, so

3 Dick Stratford has moved up here, but if he needs to

4 address anything specifically, we'll just get a

5 microphone over to him.

6 So, right now we're really here to hear from

7 you. What do you think of the rule? What kind of

8 feedback can you give to us? What would you like us to

9 think about, in terms of the final rule? You know

10 there are certain things we can't answer, so that's why

11 we're really looking for your comments. So, anyone?

12 [No response.]

13 MS. STRANGIS: No way.

14 MR. JONES: Hi, Ted Jones with Nuclear Energy

15 Institute. I have a list of questions provided by some

16 of the members of our taskforce who couldn't be here

17 today, so if no one else asks them, I'll come back.

18 But I wanted to ask, just since the economic

19 impact assessment presentation was just done, something

20 about that. First, thank you for conducting the

21 assessment. We thought in 2011 an economic impact

22 assessment was appropriate and I think you've

104

1 ability of companies to employ qualified personnel from

2 all over the world who've got citizenship in these 77

3 countries. And, on the other hand, the ability to

4 access the whole global supply chain, which is

5 expanding. And to use shops and be competitive,

6 whether these countries are developing nuclear power or

7 not, they still have--

8 MR. WOOD: Let me respond first to the first

9 part of that comment and question, which I understand,

10 and then maybe clarify the second part, which I don't.

11 First, we did not estimate the impact of

12 moving from GA to SA or the impact from moving from

SA

13 in the reverse direction. And the reason for that is,

14 the database was only on SA transactions. And so that

15 was the base case.

16 What we observed and what I will insist is a

17 key feature of this whole problem is that there's no

18 reason to expect that effect not to be reversible or

19 not to be symmetric. And so if a given transaction

20 would have a 5 percent lower probability of being

21 successfully executed under SA rules than under GA

22 rules, then the reverse is true. It's going to have a

103

1 definitely cured that problem with the NOPR and getting

2 this done. However, we do disagree with some of the

3 conclusions based on an analysis that we had made of

4 your assessment by UxC, which is one of your sources,

5 of course.

6 I'm not going to get into that, you'll see it

7 with the industry comment letter that we submit next

8 week, I think. But it did find that there was

9 insufficient empirical data to support the conclusions.

10 The UxC said that the assessment underestimated the

11 commercial impact of shifting countries from general

12 authorization to specific authorization. And

13 overestimated the change in moving a country from

14 specific to general authorization. And then, finally,

15 it found that there was omission of some key additional

16 economic impacts and I wanted to ask a question just

17 about that last point. Did you consider in the study

18 the economic impact of workforce constraints and supply

19 chain constraints as a result of the SNOPR?

20 Such constraints would predictably result

21 from reclassifying 77 countries to require specific

22 authorization. I'm talking about on the one hand the

105

1 5 percent better chance if you had reclassified in the

2 opposite direction.

3 So we really did not estimate the strength of

4 that effect. All that we estimated was the underlying

5 trade volumes in the two categories of countries and if

6 you think about the situation with the SNOPR and the

7 process improvement, that's really all we could have

8 done because the end state that we're talking about is

9 not the existing SA process. The data that we had was

10 on the existing SA process and so the end state under

11 an improved SA process will presumably not be quite as

12 bleak as it would have been under the existing process,

13 but you do understand the distinction there. And I

14 will still, once again, insist that that effect,

15 whatever its magnitude, has got to be symmetric. If you

16 gain it going one way, you lose it going the other.

17 And since the countries are moving in both

18 directions, you have to account for both of those

19 possibilities.

20 The second part of your question relating to

21 workforce constraints in SA countries--I think they are

22 significant. I don't see how they are differentially
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1 relevant to SA trade or GA trade and since that's

2 really what we're trying to measure, I don't see

3 exactly how I could incorporate that into the

4 calculation. Do you want to elaborate on that a little

5 bit?

6 MR. JONES: What we've heard from companies

7 is that they may not be selling a nuclear power plant

8 to Singapore, but they have operations there, they have

9 shops that do work as sub- suppliers that they will

10 probably not be able to access. And that's the supply

11 chain side.

12 And then you have the human resources issue,

13 which is, you know, of all these countries-- many of

14 them not developing nuclear power, never even

15 considering it. Maybe not even having shops, there may

16 none the less be--

17 MS. STRANGIS: Can you hold it closer,

18 please? It's for the transcription.

19 MR. JONES: Yeah. There may be nonetheless

20 be foreign nationals of these countries that are

21 qualified personnel. And given that you're only moving

22 three countries from specific to general authorization,

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1 [No response.]

2 MS. STRANGIS: Ted, did you have more?

3 MR. BLEE: Sure, I think there is a lot of

4 logic and rationale to all of this. This is certainly

5 a vast improvement over both the process and also the

6 proposed rule. I think from the first one and it's

7 great to see the economic analysis behind this.

8 The one--and I understand the one thing that,

9 again, we don't necessarily have an answer for. We'll

10 probably include it in our comments is, you generally

11 follow the 1, 2, 3s in a general authorization. That's

12 all rational, except when it comes to weapon states--

13 and, of course, China and India.

14 So taking it up to 30,000 kilometers, there

15 are 150 reactors probably being built there by 2030,

16 half of what is projected. And we understand the Hyde

17 Act in India, and all of that. Is there any kind of

18 hybrid approach--and maybe you can't answer this today,

19 but--hybrid or intermediate approach that can be

20 considered there where you could do a triaging of--some

21 things will have to require specific authorization

22 because they're sort of in a bit of a hybrid zone, if

107

1 but a net of 77 in the other direction, it's probably

2 going to have--I mean, presumably, I think it would

3 have a much larger impact--negative impact.

4 MR. WOOD: Well, once again, you know, those

5 constraints are very real and very important to the

6 industry, but I don't see that they're differentially

7 relevant in a GA transaction, in a SA transaction.

8 They are constraints and they do limit your ability to

9 do effective business. They also limit the ability of

10 the competition to do effective business and they are

11 no different under a GA process than they are under an

12 SA process, so once again I'm not getting the

13 connection maybe that I need to understand for that.

14 The second observation is that the SA process

15 that we are moving to would hopefully be more

16 transparent, quicker, and more understandable. And

17 might allow you to cope with those constraints in a

18 more effective fashion than the existing process. But,

19 you're right, we did not include that as a quantitative

20 factor in the calculation.

21 MS. STRANGIS: Anyone else have any

22 questions, comments, feedback?

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1 you know what I mean?

2 Do you follow?

3 MR. GOOREVICH: So, yeah, I get it. I think

4 what I'm hearing you say is--or the question that

5 you're asking is really, I think, something that Dick

6 touched upon in the first part and it's really more a

7 process question than it is a SNOPR question. Which

8 is, if we see that there's a need to somehow address

9 transactions with an individual country and to be able

10 to try and fix our processes, are we willing to do

11 that?

12 And I think what I heard Dick say, and I

13 think what everyone heard Dick say is, yes. We are

14 willing to look at how to work with countries when

15 there isn't a demonstrated need to do that and that we

16 will attempt to try and find a way to insure that we're

17 not unduly burdening legitimate nuclear trade. So I

18 view that more as a process question than a question

19 about the rule. But the answer is, I think, yes.

20 MS. STRANGIS: Anyone else? Over here. And

21 please remember to state your name and affiliation.

22 MR. MARKUS: Yes, hi, Stephen Markus with
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1 Pillsbury. I wanted to ask a question with regard to

2 the reclassification and specifically, I guess, the

3 legal and non-proliferation basis for reclassifying the

4 GA to SA? We've heard from Rich that essentially

5 there's a basis in the Atomic Energy Act for--or a need

6 to incorporate a non- inimicality finding and that

7 essentially will stem from the non-proliferation

8 assessment statement that accompanies a 123 agreement

9 with a partner country.

10 I guess my question has two parts. One,

11 could you elaborate a little bit on the basis for

12 changing the status from GA to SA for the 77 countries,

13 on this new basis given that this process and legal

14 structure has been in place for some time now.

15 And secondly, are there some other mechanisms

16 that might be available other than 123 agreements that

17 might provide the basis for the non-inimicality finding

18 that would enable a country to reach general

19 authorization status?

20 MR. GOOREVICH: Okay. So what I think I

21 heard you say--see, I have to do this so that way

22 Preeti doesn't get upset with me. What I think I heard

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1 means besides just the NPAS and the 123. Exactly what

2 those are though, we haven't elaborated on and if it

3 presents itself in an opportunity, we'll certainly try

4 to identify those moving forward.

5 MS. STRANGIS: Other questions over here?

6 MR. MADRIGAL: Hi, Joshua Madrigal with

7 AREVA. So I have a couple of questions and they may

8 require some follow-up, so I apologize in advance.

9 But, you know, I wanted to say, as most commenters

10 have, thank you for holding this meeting. I think it's

11 really important because there's a lot of information

12 that we didn't have at the last meeting that we should

13 try to understand in this meeting.

14 So let me start with the economic analysis.

15 Now, we have some questions perhaps that are not as

16 clear and whoever wants to field this, please feel free

17 to, but I'm wondering, in the economic analysis itself

18 is there any value that's attached--what specific value

19 is attached to trade with, let's say, X-country that's

20 under specific authorization? How do you calculate the

21 value of trade with that country? Is it purely in

22 terms of revenue and that's it, or are you including

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1 you say was, where in the SNOPR have we talked about

2 this? And I think that in the SNOPR we've talked about

3 the justifications associated with why and how we're

4 laying this out.

5 I think what's clear and what we're trying to

6 say in the SNOPR that we're trying very hard to stick

7 to and to comply with 57b. Now the secretary has to

8 make a non-inimicality finding, that's clear in the

9 law. How he goes about doing that and whether there's

10 other ways than a 123 agreement and a NPAS, I believe

11 we've said in the SNOPR that, yes, we would consider

12 that--other ways to do that.

13 non-inimicality finding about the recipient

14 country and it has to be concurred upon by the

15 Department of State.

16 If that happens, then through the

17 Administrative Procedures Act we could move a country

18 from an SA list to a GA list. So, you know, I think

19 the SNOPR does a very good job of laying that out, but

20 I think you're asking the question, have we considered

21 that there are other ways and the answer I think we've

22 said in the SNOPR is, yes, we would consider other

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1 additional sources of income?

2 So what I'm thinking of specifically is all

3 of the attendant value of worth that may come with

4 starting that initial--let's say it's planning and

5 constructing a power plant. How much revenue is

6 included in your projections?

7 MR. WOOD: Yeah, good question. We perhaps

8 should have been more explicit about that, but the

9 metric we used was the prospective U.S.

10 technology export trade that would be

11 associated with each country and with each scenario.

12 And that was derived from the historical record of how

13 much trade had occurred in each of the three categories

14 we talked about.

15 Now, that's not to say that there won't be

16 other benefits attendant on those exports--that they

17 would generate yet more business, or yet more benefits

18 of some nature in the future. I think the implicit

19 assumption is that whatever those benefits might be,

20 they would be proportional to the dollar volume of the

21 trade itself. So that was our primary metric.

22 MR. MADRIGAL: Great. Okay, if I could ask a
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1 follow-on question to that? I think that's really

2 important because we're going back to the database.

3 Now, do I understand correctly the database covers a

4 four-year period?

5 MR. WOOD: It's about 3-1/2.

6 MR. MADRIGAL: Three and a half. And that 3-

7 1/2-year period roughly corresponds with a global

8 economic recession, am I to understand that correctly?

9 MR. WOOD: Yes, you're correct about that.

10 MR. MADRIGAL: Okay, if we could--what caveat

11 then would you place on the project impact, given that

12 the that data we're relying on, given that the

13 projections are coming effectively from a period of

14 soft economic growth and then also--I want to tie this

15 issue as well--the projections we have, a high

16 projection, we have a low projection. We talked about

17 how those roughly correspond, except for the high

18 projection in terms of output to 2030.

19 I wonder if you could go into those

20 particular assumptions though, in terms of whether you

21 think that projection needs to be relooked at, given

22 that--if I'm remembering correctly, a lot of studies

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1 If you look at published statistics on

2 nuclear trade it includes a much broader spectrum of

3 goods and services than is regulated under 810. So you

4 can't have it both ways. You can't have comprehensive

5 data and a focus on the regulated trade. And we opted

6 to take data strictly from the regulated trade.

7 MR. MADRIGAL: If I may, just one last

8 follow-on question on this? Why not include a

9 multiplier fact, then? Why rely solely on what we now

10 is a data set that reflects a soft period of soft

11 economic growth? Why not include what you said wasn't

12 included?

13 I mean, we could quibble about what the

14 multiplier fact is, but why not include that in the

15 study?

16 MR. WOOD: We could do that. It's not hard

17 to do that. It would not change the answer in terms of

18 the direction of economic impact, so it's relatively

19 straight forward sensitivity thing to examine that

20 question. And if Rich would like to do that, we'd be

21 happy to help him do that, but it's not going to change

22 your conclusion about the direction of the impact.

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1 you cite are from 2011, right? The WNA report is from

2 2011, should that--

3 MR. WOOD: Yeah, the vintage of all of these

4 forecasts was 2011 or 2012, in some cases. Your

5 question about the recession and its significance is a

6 good question. And what one would expect is that the

7 dollar volume base rates for each of these three

8 categories of trade might be depressed during that

9 period, relative to more normal economic times.

10 And you might even conjecture that they would

11 be depressed--that some of them would be more depressed

12 than others. You know, the spending on planned plants

13 is perhaps more discretionary than the spending on

14 construction once you've started construction. And so

15 there could be effects of the recession that would skew

16 those base rates.

17 I think the key thing for us is that the base

18 rates, I think, are a relatively good empirical

19 starting point. The comment was made that the data is

20 insufficient, well, that's about the only data that

21 really bares directly on the volume of nuclear

22 technology trade.

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1 MS. STRANGIS: So Joyce Connery has to get

2 back to the White House, so we're going to let her give

3 her comments now and then we have the room until 1:00

4 o'clock, so if people want to stay around after that

5 and provide more feedback, they're welcome to do that.

6 MS. CONNERY: Hi, sorry. I didn't mean to

7 interrupt the flow of the conversation on the economic

8 impact study, which sounds like a fascinating

9 conversation for the economists in the room.

10 Anyway, I'm Joyce Connery. I'm the director

11 of Nuclear Energy Policy at the White House. I'm sure

12 most of you know me. The last time we had this

13 meeting, I didn't have dispensation to speak, so Rich

14 spoke for me. When the White House heard that they

15 said, oh, we'll let you speak this time because we

16 don't want Rich speaking for you.

17 [Laughter.]

18 MS. CONNERY: Anyway, and then--

19 MR. GOOREVICH: It was the clearest you

20 sounded in years.

21 [Laughter.]

22 MS. CONNERY: Exactly, exactly. You couldn't
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1 even see my lips moving. Anyway, I do have to leave.

2 Not to go back to the White House. I'm actually running

3 a half marathon in Richmond tomorrow and my husband's

4 outside waiting to pick me up, so I apologize for

5 having to run.

6 But I do want to extend my congratulations

7 and thanks to the interagency team who have worked

8 tirelessly to put this together. And we've had a

9 number of bumps in the road, to include a government

10 shutdown which was not planned to forestall the last

11 meeting. It was coincidental and accidental.

12 But I think the main points that I'd like to

13 leave you with today, other than that we are very

14 focused on this at the White House and focused on

15 getting this right for the future of our non16 proliferation regimes, as well as for the future of

17 nuclear commerce. And I think the main points that I'd

18 like to leave you with--there's one, we heard you

19 between the last SNOPR and this one. I think you can

20 see a lot of your comments have been incorporated and

21 we've made a lot of efforts to not only fix the SNOPR

22 to address your comments, but also to address the

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1 we get to a point of a final rule, we also want to make

2 sure that we continue to do outreach to make sure that

3 the companies are comfortable with what the rule

4 changes are and that they can get through the

5 application processes without any problems.

6 So what I would ask of you, however, is also

7 that you are transparent with us. That if you have

8 comments or concerns that you come to us through the

9 process that we've set forward in the rulemaking and--

10 you don't have to go through another organization to

11 present us your comments. If you have comments, present

12 them to us so that we know who you are and that you

13 stand by them.

14 So, with that, I'm going to turn it back over

15 to the question and answer period and hope that you

16 have a productive afternoon. Thanks.

17 MS. STRANGIS: I think there's another

18 question over here.

19 MR. PIERCY: Craig Piercy, American Nuclear

20 Society. Not a question, but just more of an overall

21 comment. I think we want to echo the others in

22 congratulating you the interagency team in a much

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1 processes that were constraining our activities prior

2 to this.

3 So both the process and the content of the

4 rule, I think, are something that we've been focused

5 on, thanks to your comments.

6 I'd also like to point out that this is an

7 interagency effort. While Rich tends to be the face of

8 this operation, you'll see that the interagency is

9 sitting in front of you and that's because we work

10 together to make sure that we got this right. And

11 there were some heated arguments amongst ourselves, as

12 well, but I think we all stand by the product that

13 we've come to, so far.

14 And we've looked at all the aspects of this

15 to include competitiveness, as well as the non16 proliferation aspects to make sure that we got the

17 balance correct.

18 So, again, a great deal of work has gone into

19 this. We've been as transparent as possible, we've

20 answered as many questions as possible, we've made Rich

21 available, as well as the interagency, and I personally

22 feel committed to this process going forward. And once

121

1 improved product over where we were before. I think

2 this has been a very good process for give and take

3 between the various stakeholders and government.

4 The one thing I want to leave you with, we

5 will be submitting written comments and I'll leave our

6 particulars for that. But there's a larger issue here

7 that I think that we need to recognize. The SNOPR or

8 the rule is just one part of a system that includes

9 process. It also includes people and it includes

10 authorizing legislation. So it's hard to look at one

11 without looking at the entire system.

12 The one thing that we do see often is that

13 the notions of non-proliferation and notions of nuclear

14 trade are in tension with one another. And the point

15 that ANS really wants people to realize is that if you

16 get it right, the two are synergistic. That our

17 ability to export U.S. goods and services around the

18 world, actually, in the long-term promotes our non19 proliferation objectives by increasing our influence in

20 the world.

21 And so, to the extent that you finalize the

22 language, that thought process ought to be included as
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1 you look at specific provisions. So, with that I thank

2 you.

3 MS. STRANGIS: Thank you. Over here?

4 MR. KRAEMER: Jay Kraemer and I'm still

5 retired. I have a question about the economic work.

6 Is it possible to throw up on the board again the pie

7 chart that you had at the beginning?

8 MS. STRANGIS: Actually--

9 MR. KRAEMER: Okay, now I'm trying to read

10 this, but if I understand it correctly, some 55 or 56

11 percent of the market, as you projected it, was subject

12 to specific authorization before and continues, subject

13 to specific authorization now?

14 MR. WOOD: Correct.

15 MR. KRAEMER: Is that correct? And so the

16 difference made by the rule is, as compared to that 55

17 percent--about, say, 2.5 percent that's reduced18 -

19 MR. WOOD: Okay, let me state it my way and

20 see if this works for you. The size of the orange and

21 green slices of that pie chart are the countries

22 unaffected by the proposed reclassification. The real

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1 proposed, you would still have a majority--something in

2 excess of 55 percent of the projected market. That

3 requires a specific authorization, is that right?

4 MR. WOOD: that's true.

5 MR. KRAEMER: Okay, did you do a similar pie

6 chart--you probably didn't have any reason to-- with

7 respect to the rule that was put in place in 1986 to

8 determine, as to that rule, how much of the projected

9 market was affected?

10 MR. WOOD: No, we did not.

11 MR. KRAEMER: Well, then I guess I would have

12 the comment that I think Rich has said that when

13 there's a need to address a problem, we'll address it.

14 And, just from my own standpoint, if you have more than

15 a majority of the market which is subject to an SA

16 requirement, that seems to me a problem at least worth

17 attention.

18 MR. WOOD: Well, you know, my domain was the

19 economics and my understanding of the motivation of the

20 classifications both before and during this process is,

21 it's primarily based on proliferation risk. So I can't

22 really speak to that.

123

1 comparison in assessing the effect of the rule is

2 between the size of the small slices. Is the blue one

3 bigger than the yellow one? Is the yellow one bigger

4 than the blue one?

5 For all of the forecasts that we looked at,

6 except for the WNA High forecast, the blue one was

7 bigger than the yellow one. That is to say the

8 effected trade volume in the three countries moving in

9 the direction of SA to GA was larger than the effected

10 trade volume moving in the other direction, even though

11 it came from 77 countries.

12 MR. KRAEMER: But if I understand this

13 correctly, if you didn't move in either direction, 58.5

14 percent of the market would be subject to SA and the

15 rest would not. So the rule--

16 MR. WOOD: Ninety-five percent of the global

17 perspective trade volume is not affected by the

18 proposed reclassification.

19 MR. KRAEMER: Right, but I'm saying the rule

20 is being re-proposed in toto, right? So it's a whole

21 rule. So I'm asking just to understand the effect of

22 your pie chart that says if the rule goes forward, as

125

1 MR. KRAEMER: No, that was a comment. That

2 wasn't a question.

3 MS. STRANGIS: Okay, anyone else? Over here.

4 MR. JONES: Picking up where Jay left off

5 about that 55 percent and coming back to the question

6 that David, I think, was getting at earlier about the

7 big countries of, let's say, China and India which

8 together account for half of the planned new

9 infrastructure in the next few decades.

10 We made a proposal in 2011 and I think some

11 of the other commenters also made it that some

12 intermediate approaches be taken, between specific and

13 general authorization. And I think our top line

14 recommendation was that they be generally authorized

15 under on the basis of their non- proliferation

16 commitments and their Section 123 agreements, et

17 cetera.

18 But, you know what, I take the explanation

19 that you have concerns about transparency in China and

20 Russia and there's the Hyde Act that pertains to India,

21 so maybe that doesn't permit general authorization.

22 But in the SNOPR there's no comment on the intermediate
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1 measures that we suggested for authorizing transfers to

2 these countries.

3 Given that they're such a huge part of the

4 market--and I think if you did this pie chart for next

5 year, it would be much less than 55 percent. I mean,

6 they're expanding really fast.

7 Given the importance for us to remain

8 relevant, and I know you want to be able to control

9 transfers and if we're not in that market, then we're

10 not going really going to be controlling it or

11 advantaging our exports, either. What sorts of

12 intermediate measures have been considered? And if the

13 SNOPR is not going to entertain some of this

14 alternative suggestions that we made, then why not?

15 Could you elaborate on that?

16 MS. STRANGIS: So, if it wasn't discussed in

17 the SNOPR, we can't really discuss it here because of

18 the ex parte rules, but I assume that will be part of

19 your written comments and we would address it at that

20 point. If you can say something?

21 MR. GOOREVICH: I think I can say something.

22 I don't have all of the written comments in front of

128

1 said that, if there are ideas out there, we'd certainly

2 be happy to see them and to certainly consider them as

3 part of the public comment period because what you're

4 talking about is a significant change to a regulatory

5 concept. It's not just that the ideas we got were how

6 to treat certain classes of activities, but that's not

7 what I'm hearing in the question and what I think David

8 was trying to get at, okay?

9 MR. JONES: Right. Thank you.

10 MR. RUDY: George Rudy, just a point of

11 clarification. You said earlier, I believe, that the

12 slides would be available probably in a day or so and

13 did I also hear that the questions and the dialogue

14 that's going on here, there's a transcript that will

15 also be available?

16 MS. STRANGIS: Yes, we have a

17 transcriptionist recording everything. I'm not sure of

18 the timeframe for that, but it will absolutely be

19 publicly available.

20 MR. RUDY: Okay, thank you very much.

21 MR. MADRIGAL: Joshua Madrigal, with AREVA.

22 I have a question, if we can go back to process

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1 me. I think the challenge that we have is in the

2 comments asking the government--well, essentially what

3 you're saying is have we considered in the SNOPR this

4 sort of what you would call semi-general or semi5 specific authorization? Can we create a middle ground?

6 That's not covered in the SNOPR. We'd be

7 interested in any written comments on how we could

8 legally create something along those lines and we would

9 consider it. I think that's right.

10 The ideas that we received in the SNOPR were

11 about how to treat classes of transactions. Not about

12 how to create a whole new regulatory framework and so I

13 think--I can't comment directly on what we've

14 considered or not considered, but what I can say is,

15 that's something that if people have ideas on, then

16 certainly they should provide them in writing.

17 But I would also say, though, that it's

18 something that will have to be discussed about with my

19 interagency colleagues because if DOE accepts something

20 along those lines then there would be pressure on them

21 to consider that, as well. So it would be the

22 government, not just DOE, would consider. But having

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1 improvements? I didn't get to ask this in the previous

2 Q&A session, so I thought I'd ask this now. What I

3 wanted to ask is, what information you're entertaining

4 placing in the FAQ? And then, how you envision the

5 process for updating the FAQ?

6 I think this is something that when we're

7 talking about increasing transparency, it's perfectly

8 well to have a system that tracks where we are in terms

9 of applications and so forth, however, before we even

10 get to that stage there's a lot of person to person

11 contact where somebody from my company, for example,

12 may be contacting Rich and saying, you know, I have a

13 question. Before I even submit this, I want to know

14 where I may stand? And there's an associated delay, we

15 could say. I don't know what that is, but there's an

16 associated delay there. And what might lessen that

17 delay--what might improve the process, speed up the

18 process and, indeed, increase transparency is to have a

19 strong FAQ.

20 And one idea that I think might make sense is

21 to have a limited FAQ in a publicly available section,

22 but a more detailed FAQ available to users who have a
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1 particular credential, as defined by this new system

2 that's going to be implemented. If you could comment

3 on those?

4 MR. GOOREVICH: Yeah, sure. Our hope is--

5 and the goal is--that as Jeff talked about for the E

6 System, there will be a place where we will have FAQs

7 and a lot of that we expect will be based upon the sort

8 of questions that we get all the time from people, a

9 lot of phone calls we get. And we pretty much have a

10 good record of what those basic questions are. As well

11 as discussion on interpretations that we've made in the

12 past.

13 And they may be very detailed, such as, is

14 this kind of valve covered? Or it may be very general

15 as to how do you treat dual citizenship, and doing

16 that. But as I stated earlier, our hope is to have a

17 guide and, as I understand it, there are guides that

18 NRC has for how they do their regulations. Maybe

19 Brooke can talk about it. I think Commerce also has

20 guides on how they can do that and I think Steve can

21 talk to that--is to follow their examples. Their tools

22 to the exporters seem to work very well for their

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1 requirements. And those are generally developed by the

2 technical staff. They're put out for public comment.

3 There's usually public meetings associated with those

4 and then they're republished and they're publicly

5 available and you can access them on our website. And

6 they are updated periodically, as there's regulatory

7 changes and just implementation experience.

8 MS. CLAGETT: As well as with Commerce, we

9 have a number of things on our website. Some

10 frequently asked questions. Also questions as to how

11 to fill out the form, things like that. But also we

12 have a number of outreach seminars, which now--many of

13 them are put on the web, as well. So all of those

14 questions and answers are also available to the public.

15 But, again, it's just more of a general

16 openness. And I think with your frequently asked

17 questions, there's usually very few questions that we

18 answer that we don't want to share with the general

19 public, unless it's very much a company specific

20 commodity or technology specific.

21 If Boeing asked us a question or Westinghouse

22 asks us a question about the interpretation, we want

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1 processes and the hope is to do that.

2 But in us developing that, we really do want

3 to get some help from applicants and from industry as

4 to what type of questions and information should be in

5 there. So it's as much a product that is essentially

6 designed in concept and in detail from industry

7 involvement into what should be in the guide, what kind

8 of information, what kind of questions?

9 So we will be asking openly, you know, what

10 should we be putting in here? I don't expect it to be

11 as think as the IRS's guide for how to fill our a 1040

12 EZ form. And I don't expect it to be something that

13 you have to write to Pueblo, Colorado to get a copy of,

14 as other government things are. But maybe Brooke and

15 Steve can talk a little bit about what they do at their

16 agencies because I think ours is going to be very

17 similar to what they do.

18 MS. SMITH: So the NRC is part of--it's

19 domestic licensing program has what's called the New

20 Reg series. You're probably familiar with it. And it

21 provides guidance that, if you follow it, you'd be in

22 compliance with our regulatory and licensing

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1 them to get the same interpretation, so we generally

2 like to get as many of those questions out there as

3 possible, unless it divulges something that's truly

4 company specific or truly confidential.

5 MS. STRANGIS: Jeff?

6 MR. WILKINS: Sorry, this was the easiest mic

7 to get to. So I just wanted to say, in terms of the IT

8 system that we'll build out, yeah, we'll work with Rich

9 and his team to put tools in place to enable them to

10 solicit, collect and aggregate feedback from the

11 community to sort of inform and structure the Q&As and

12 future revisions of the guide, or initial versions of

13 the guide.

14 You know, we can do things like provide a

15 suggestion link that opens a form that allows you to

16 submit your suggestions directly through the site. We

17 can do things like discussion forums where stakeholder,

18 where companies can go in and just post discussion

19 topics and get feedback. And then Rich's team can mine

20 that data for suggestions for ideas to improve the

21 process, the guidelines, the IT system. Any of that.

22 So we'll do everything we can to enable that
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1 process for them and to make it as easy as possible to

2 publish updates to the information that they want to

3 share through the system.

4 MS. STRANGIS: We're losing critical mass

5 here, so a few more questions, but--right here.

6 MR. RUDY: George Rudy. I detected in some

7 activities that we've had with your department that

8 whether informal or formal--I'm not sure how it was--

9 that a real person point of contact was established.

10 Is that a standard procedure or is that something we

11 need to ask for as a program gets bigger?

12 In other words, instead of contacting you

13 directly--

14 MS. STRANGIS: That's a process question.

15 MR. RUDY: --with every question or do you

16 assign a project quote person to the--

17 MR. GOOREVICH: So, yeah, we have a staff and

18 as a question comes in, generally, depending upon the

19 question and the workload of the staff, most of the

20 time we will assign a staff member to make contact

21 directly with the company--

22 MR. RUDY: Okay.

136

1 work with them on designing the phased approach and

2 what features we all expect to be in the various

3 phases.

4 So, for that Phase 1, we're the farthest

5 along because that's the first activity that's going to

6 take place. We're, I would say, within a month--yes,

7 Darryann? Sorry, my technical lead's in the back. So

8 we're probably within a month of being at a position

9 where we can present the Phase 1 requirements,

10 features, and plan to Rich and his team for approval.

11 When we get that official approval that

12 that's--and they bless it--then that's the T in T- plus

13 three months or so, in building out the initial

14 operating capability for Phase 1.

15 MR. ESPOSITO: So you would expect in the

16 next two to three months?

17 MR. WILKINS: We would be able to start work

18 in about the next month or two and complete the work

19 about three months following. Okay?

20 MS. STRANGIS: Over here.

21 MR. MARKUS: Stephen Markus, with Pillsbury.

22 I just wanted to follow up on one aspect of my earlier

135

1 MR. GOOREVICH: --and then essentially any

2 follow-on activities, you work with that staff member.

3 MR. RUDY: Okay.

4 MR. GOOREVICH: So they take on your case. So

5 you essentially get a case officer. You develop a

6 rapport, they understand what's going on. So what we

7 don't want to do is have you work with one person, get

8 an answer and then have to file the application and

9 start new.

10 MR. RUDY: Right.

11 MR. GOOREVICH: We want someone who is

12 familiar with you, the specifics of your case, to be

13 able to help you get the application in and get our

14 analysis done and move forward.

15 MR. RUDY: Okay. All right.

16 MR. ESPOSITO: Vinnie Esposito, Energy and

17 Commerce. Jeff, you said a few times that Phase 1 gets

18 initiated at T-plus. Can you define T-plus a bit more?

19 MR. WILKINS: All right, so we've been

20 working with Rich and his team for pretty much the last

21 six months to understand the process, understand the

22 stakeholder feedback that's been received thus far and

137

1 question regarding the reclassification. You had

2 referred to the analysis and explanation in the SNOPR

3 on the basis for changing the approach from GA to SA--

4 well, SA to GA, essentially. And one of the statements

5 in the SNOPR referred back to the original NOPR in

6 saying that one aspect of the basis was to recognize

7 the fact that global markets for peaceful nuclear

8 energy and nuclear fuel cycle trading relationships

9 have become more dynamic in recent years. And I was

10 just wondering if you could clarify what is meant by

11 that and how that relates to the new approach to

12 classification?

13 MR. GOOREVICH: Are you asking me what the

14 word dynamic means?

15 MR. MARKUS: Well, in the context, yes. How

16 does the sort of dynamic--how is that word used in this

17 explanation?

18 MR. GOOREVICH: It's been a while since I've

19 actually read the SNOPR word for word, so let me try as

20 best I can to explain what we were attempting to say in

21 there, as much as I can.

22 What we heard and what we saw from comments
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1 and what we understood as we went into the NOPR was

2 that the market's changing. The market is evolving.

3 But we also understood that proliferation was changing

4 and proliferation was evolving. And so, therefore, as

5 you sort of have both ends of a spectrum.

6 You have proliferation concern and you have,

7 at the other end of the spectrum, the market concern.

8 And they're continually evolving and moving. In

9 between you have the regulation and the question that

10 we were grappling with and trying to identify was how

11 can the regulation, which tends to be very inflexible,

12 work while at both ends of the spectrum are sort of

13 pushing and pulling on the regulation to move forward.

14 So, places and markets that we had originally thought

15 were potentially okay and part of a supply chain, we

16 found out through concern, we're supplying the Kahn

17 network. So the question is, when we talk about

18 dynamic, it's dynamic both in terms of market

19 opportunities and supply chains, but it's also dynamic

20 in the fact of proliferation.

21 So the question becomes, then, how does the

22 secretary make a non-inimicality finding within this

140

1 MR. GOOREVICH: Well, I think that's exactly

2 why we're--well, first, are we getting close to the

3 bottom of the list, Ted?

4 MR. JONES: That's my last one.

5 MR. GOOREVICH: That's the last one? Okay,

6 good. The answer is blue.

7 [Laughter.]

8 MR. GOOREVICH: No, that's the point in all

9 of this, which is to try and be more transparent. You

10 made the statement that in the past when we've changed

11 from--when we've made changes to the list, we've

12 provided evidence. The list hasn't changed since 1984,

13 so I'm not aware of any time that we changed the list

14 where we've provided evidence or provided information.

15 In fact, if you look at the specific

16 authorization list today, it still says Yugoslavia

17 because the way the list was created, it required a

18 rule change. We have not changed the regulation. The

19 only time we changed a regulation was once and that was

20 to add accelerator driven sub-critical assemblies and

21 safety exemptions for former Soviet Union work. We've

22 not changed the rules since.

139

1 dynamic framework? Okay? And so that was the basis of

2 us looking at that.

3 It's not just dynamic from the market, it's

4 also dynamic from the non-proliferation, so I think we

5 have enough recent history to show that places that we

6 had expected to be and had hoped to be fairly safe

7 places to send our technology from the proliferation

8 standpoint turned out not to be the case.

9 So that's what we're grappling with. It

10 comes back to what Joyce said, the balance between

11 those two elements and the dynamic aspects of those two

12 elements, okay?

13 MS. STRANGIS: One more.

14 MR. JONES: Just to follow up on what Stephen

15 was asking, you mentioned that you have recent history

16 to show that places that were deemed to be safe, in

17 fact are not. In the past, when countries were moved

18 from general authorization to specific authorization,

19 that information was shared publicly to justify the

20 change. Would you be able to share this information to

21 justify the change for the 77? And does there exist

22 information for each of the 77?

141

1 MR. JONES: I'm talking about changing the

2 country list.

3 MR. GOOREVICH: It requires a rule change.

4 That's one of the--and we haven't changed the rule

5 except for that one time for technical reasons, so we

6 haven't changed the country list. Like I said, we

7 still have Yugoslavia listed on it.

8 So I'm not aware of when we've provided

9 evidence. By changing and moving into this direction

10 and saying that a country linked to a positive non11 inimicality finding by the Secretary of Energy and the

12 Secretary of State, we are providing the public through

13 the 123 process, or any other process that is

14 identified where we can do that, that, yes, there are

15 reasons why we are saying that these are countries that

16 are eligible for general authorization, okay?

17 So that's the answer I have based on my

18 experience with the current 810 rule.

19 MS. STRANGIS: With that I think we can say

20 thank you so much to our panel. And thank you all so

21 much for spending so much time with us today.

22 [Applause.]
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1 MS. STRANGIS: We really look forward to any

2 written comments that you have. I think the comment

3 period closes, I believe, the 29th.

4 (Whereupon, at 12:31 p.m. the MEETING was

5 adjourned.)

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

143

1 CERTIFICATE OF COURT REPORTER

2

3 I, CHRISTINE ALLEN, the Court Reporter before

whom

4 the foregoing proceeding was taken, do hereby certify

5 that the proceeding was recorded by me; that the

6 proceeding was thereafter reduced to typewriting under

7 my direction; that said transcript is a true and

8 accurate record of the proceeding; that I am neither

9 related to nor employed by any of the parties to this

10 proceeding; and, further, that I have no financial

11 interest in this proceeding.

12

13

14 ___________________________

 CHRISTINE ALLEN

15 Digital Court Reporter

16

17

18

19

20

21

22
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about--next 22:17

abroad 32:11

65:21

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beginning 101:12

122:7

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bigger 123:3,7

134:11

biggest 70:3

bilateral 46:20

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binding 45:17

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bottom 7:17 140:3

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100:4

bounding 101:7

branch 30:5 57:11

brave 54:19

break 4:12 6:8

7:18 70:1

77:7,10

breathing 72:12

Brendan 2:3

briefing 49:3

76:17 82:10

briefly 90:7 91:10

bring 45:15 48:3

broad 85:12

broader 11:5

116:2

broken 41:15 42:1

Brooke 2:21

130:19 131:14

Brooke--and

78:12

brought 21:10

budget 69:14

build 21:2 33:7

35:8,11 36:16

38:11 65:19

133:8

building 7:15 31:7

33:4,14 36:3,19

95:20 136:13

builds 62:4

built 108:15

bullet 41:14

bumps 118:9

burden 27:9

burdening 109:17

Burke 2:3,4

business 2:20

11:1,2,13,14

13:13 17:15

18:21 22:22

42:1 63:19 66:9

70:14,15

107:9,10 113:17

businesses 69:2

but--hybrid

108:19

but--right 134:5

Butterfield 2:4

C

C.J 24:21 25:3

70:5,9

C.J.'s 70:8

cable 28:22

29:9,10 52:12

calculate 112:20

calculation 90:11

91:12 101:4

106:4 107:20

Canadian

88:5,6,8

Canovas 2:5

capability 36:17

76:9 136:14

capacity 91:19

97:7

Capital 1:20

care 42:8

career 27:7

careful 59:8

carefully 90:15

Carlton 2:22

carried 11:3 85:14

case 30:11 31:14

50:8 51:20 54:9

55:12 73:18

74:7 99:12

101:7 104:15
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135:4,5,12

139:8

cases 28:7 29:8

32:15 73:14,16

74:1 87:9 93:7

99:4 115:4

Catch-22 53:21

categories

95:15,22 100:8

105:5 113:13

115:8

category 95:5

99:16,21

100:2,6

Cates 2:5 55:17

56:11

caused 86:18

causes 93:21

caveat 114:10

center 99:1

centralized 35:9

century 21:22

certain 11:20

14:20 15:10,11

16:3 30:20

51:18,19 58:8

75:5 76:10 86:2

102:10 128:6

certainly 15:19

16:11 35:2

57:17 65:17

66:18 68:1,2

72:10 75:12

108:4 112:3

127:16 128:1,2

certainly--

whatever 19:9

CERTIFICATE

143:1

certification

23:6,11 24:18

57:22 58:11,12

certified 23:9

certify 143:4

cetera 27:16 29:12

58:1 66:12,13

125:17

chain 103:19

104:4 106:11

138:15

chains 138:19

chair 74:21,22

challenge

71:12,20 127:1

challenges 11:17

34:19 35:6

chance 7:6 89:11

105:1

change 10:17,18

13:12 15:9

16:8,12 61:15

67:15,18 71:11

72:3 82:14,21

86:14 90:19,20

103:13

116:17,21 128:4

139:20,21

140:18 141:3

changed 4:14,15

5:14 11:11 54:2

140:10,12,13,18

,19,22 141:4,6

changes 1:6 4:18

9:19 16:19

21:14 57:16,18

79:15,18,20

82:2 83:6

84:2,17 89:5

92:14 120:4

132:7 140:11

changing 16:10

21:3 70:15

71:14 83:2

110:12 137:3

138:2,3 141:1,9

characteristics

25:2

charge 24:12

chart 91:16 96:22

97:18 101:11

122:7,21 123:22

126:4

chart--you 124:6

Chaudhari 2:6

cheap 57:9

check 39:16 67:19

Chem2Hill 2:10

Chernobyl 98:5

Chief 33:17

Chile 80:2

China 51:13,17

63:22 64:2,6

108:13 125:7,19

China--where

65:18

Chinese 64:13

choices 32:2

choose 63:20

Chris 3:3 4:19

89:15,20 90:10

91:11 95:17

Christine 1:19

143:3,14

chunks 37:12

CIO 22:1

24:10,12 37:17

CIO's 7:14

33:7,18

circumstances

6:18

cite 115:1

citizen 87:12

citizens 87:14

citizenship 86:20

87:6,11,14

88:12,16 104:2

130:15

citizenships 87:22

Clagett 2:6 132:8

clarification

74:20 128:11

clarify 104:10

137:10

class 78:14

classes 127:11

128:6

classification

137:12

classifications

79:16 124:20

classified 15:2

classifying 80:11

cleaner 35:9

clear 21:21 30:16

42:3 55:18

68:15 82:13

84:1 88:2 94:20

95:6 111:5,8

112:16

clearances 14:5

clearest 117:19

clearly 56:13,20

close 7:22 44:18
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140:2

closely 41:2 53:7

closer 45:16

106:17

closes 142:3

closing 4:21 45:4

101:22

co 61:10

coalesce 96:10

99:8

codified 76:6

coffee 70:1

coincidental

118:11

collaborate 35:3

collaboration

91:6

colleague 89:20

colleagues 127:19

collect 133:10

Colleen 2:8

Colorado 131:13

colors 98:15

combined 97:2,20

101:11

comes 29:8 47:14

53:19 62:4,13

63:13 67:3 73:8

80:8 87:3 88:7

108:12 134:18

139:10

comfortable

47:21 60:9

96:11 120:3

coming 5:3 8:13

55:21 61:18

63:2 65:7 70:3

114:13 125:5

comment 6:20

12:3 39:10

43:20 49:2

59:3,6 70:4 89:6

103:7 104:9

115:19 120:21

124:12 125:1,22

127:13 128:3

130:2 132:2

142:2

commenters

15:17,22 16:13

85:20 112:9

125:11

comments 4:20

9:16,18,21

10:5,9,16 11:16

12:11 13:22

14:14 15:14

17:7 58:20

68:17 70:3,13

83:12 90:15,16

102:11 107:22

108:10 117:3

118:20,22 119:5

120:8,11 121:5

126:19,22

127:2,7 137:22

142:2

commerce

2:4,6,9,13,20

8:16 13:20

27:16 57:12

73:16 83:4

84:17 89:16

91:6 118:17

130:19 132:8

135:17

commercial 8:18

11:4 28:1 64:1

103:11

Commission 2:21

commit 29:5

commitment 6:22

54:10

commitment--is

54:22

commitments

28:5 125:16

committed 22:19

28:2 119:22

Committee 2:9

committing 31:19

commodity

132:20

common 68:3

communicate

62:12

communication

61:7

community

133:11

community--

many 49:5

companies 44:4

45:5 61:5,6,16

62:7,8,17 63:19

74:8 104:1

106:6 120:3

133:18

company 1:20

13:10 28:15

38:8 52:1,9,10

59:7 66:16 67:3

88:5,6,8,9,12,14

,17 129:11

132:19 133:4

134:21

comparative

47:10 93:13

compared 91:15

122:16

comparing 92:19

comparison 123:1

competing 17:22

competition

107:10

competitive 18:20

44:13 45:5 46:2

47:11 93:6

96:16 104:5

competitiveness

92:19 119:15

competitor 46:13

complete 76:21

136:18

completely 42:14

63:18

completeness

99:13

compliance 24:17

57:22 58:11,12

131:22

compliant 22:21

23:2,4,5,9

compliment 41:13

comply 38:18

111:7

component 36:1

59:20 100:12

components 40:13

41:3 50:13,21

compounds 31:1

comprehensive

19:5 82:9 116:4

computer 22:1

26:16 67:11

concept 128:5
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131:6

conceptual 71:20

91:11 93:4

concern

138:6,7,16

concerns 66:20

120:8 125:19

conclusion 116:22

conclusions

101:19 103:3,9

concur 14:1 32:14

concurred 111:14

concurrence 8:14

27:18 32:18

50:9 54:21

concurs 29:22

conduct 95:16

conducted 10:22

70:15

conducting 10:21

102:20

confident 13:14

confidential 75:11

133:4

confidentiality

82:5

congratulate

58:21

congratulating

120:22

congratulations

118:6

Congress 30:9

Congressional

81:11 86:6

conjecture 115:10

connection 84:22

107:13

Connery 2:7 4:21

102:1

117:1,6,10,18,2

2

connote 72:10

cons 47:5

consent 28:7,21

50:18

consider 103:17

111:11,22

127:9,21,22

128:2

consideration

67:7 80:16

considerations

89:3

considered

15:1,16 88:21

92:1,15 97:1

108:20 111:20

126:12 127:3,14

considering

106:15

consistent 83:4,5

96:12,19 98:3,4

consolidated 35:5

consortium 69:1

constantly 96:4

constraining

119:1

constraints

103:18,19,20

105:21

107:5,8,17

constructed 101:8

constructing

113:5

construction 23:1

95:5,7

97:9,10,15

115:14

consulate 29:1

consult 27:15

31:10

consultant 60:12

consultation 8:15

consultative 75:1

consulting 31:16

consuming 16:2

consumption

48:19

contact 74:10

129:11 134:9,20

contacted 52:9

contacting 129:12

134:12

contained 35:22

content 119:3

context 137:15

continually 138:8

continue 18:17

19:3 21:9

23:12,13 120:2

continued 3:1

69:21

continues 122:12

continuing 78:4

95:11

contracts

11:14,15

contribute 49:19

control 6:17 23:7

48:9 54:3 90:5

126:8

controlled 41:6

controlling

126:10

controls 44:2

45:13

conversation 5:9

117:7,9

convincing 100:8

cool 79:5

cooperation 80:3

coordination 91:5

cope 107:17

copies 39:8,13

copy 39:11 42:21

131:13

Cornell 2:7

coronation 72:10

corporate 37:6

Corporation 2:5

99:6

correct 37:13

42:18 114:9

119:17

122:14,15

correctly

114:3,8,22

122:10 123:13

correspond

114:17

corresponds

114:7

cost 22:10

could--what

114:10

Council 2:20 68:9

countries 16:3

30:7 44:19
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45:17 47:3 50:3

51:9

65:13,14,17,20

66:4,9 72:20

80:12 81:5,6

87:13,14 90:22

91:1 92:3,5,7

94:3 95:1

99:15,19,21

100:2,5,10,22

101:9,13,16

103:11,21

104:3,6

105:5,17

106:13,20,22

109:14 110:12

122:21 123:8,11

125:7 126:2

139:17 141:15

countries--I

105:21

country 31:10,16

46:19 47:1 48:6

51:9,11,16 52:1

66:3,18,19

67:4,9 74:4,5,14

80:18 81:8

87:11,12

88:4,7,14 90:21

93:18,19 97:21

98:20,22 99:16

103:13 109:9

110:9,18

111:14,17

112:21 113:11

141:2,6,10

country's 14:7

16:1 46:17

counts 91:18

County 78:2

couple 7:4,20

27:3,21 112:7

course 37:13 40:4

42:17 68:15

103:5 108:13

Court 143:1,3,15

cover 66:21

coverage 83:4

covered 7:16 83:1

85:2,4,7,11

93:11 127:6

130:14

covered--I'm 85:1

covers 8:16 114:3

cozy 7:2 102:2

Craig 2:17 49:1

72:17 120:19

create 19:10 20:22

21:12 98:22

127:5,8,12

created 43:19

58:16 140:17

created--provide

86:7

creating 21:22

creation 12:4

credential 130:1

crime 31:19

critical

27:13,14,20

32:13 44:17

68:12 69:4,7

91:5 134:4

critical--the 25:2

crystallized 53:22

cured 103:1

current 8:22 11:8

13:1 17:16 38:7

41:16 42:4,10

61:13 83:11

86:21 91:4 96:8

97:13 141:18

currently 5:4 42:9

68:18

customer 73:16

74:9,10

customers

25:11,12 70:20

cycle 30:18,20,21

137:8

D

D.C 1:13

Dahnke 2:8

Darryann 136:7

data 15:1 35:21

39:21 41:4 75:6

94:6,7,15 97:11

98:17,19,20

99:6 103:9

105:9 114:12

115:19,20

116:5,6,10

133:20

data--and 94:17

database 93:9,10

94:9 95:13

96:18 104:14

114:2,3

date 6:20 38:20

60:17

dated 57:14

dates 94:13

David 2:3,13 68:8

70:2 125:6

128:7

day 25:4 29:20

39:16 41:21

51:5 67:19

78:10 101:7

128:12

days 27:2

30:5,6,8,11

44:21 56:3,9

73:21,22

84:10,11,14

de 30:18

deal 119:18

dealing 18:7

37:12 44:14

82:22 92:21

100:13

dealings 11:20

dealt 92:8

decade 65:18 98:3

decades 91:17

125:9

December 9:15

decide 62:18

decided 9:22

decision 15:6

decisions 8:13

20:18

Deegan 2:8

deemed 82:2,22

139:16

deeper 19:4

Defense 13:21

define 88:3

135:18

defined 96:9

130:1

definitely 103:1

definition 15:2

83:12,13,14,18

84:21 85:12
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86:1

definitions 21:7

85:13

definitization

69:7 72:8

degree 76:12

delay 129:14,16

delays 49:19

delay--what

129:17

delegable 14:20

delegate 15:8

deliver 34:10

demonstrated

109:15

denial 94:13

denied 13:8

department 1:1

2:4,6,13,20

3:2,3,5 7:13

8:15 14:2 20:3,4

22:5,11,22

26:14 29:21

53:10 54:21

63:3,6 64:16

89:16 91:6

111:15 134:7

Department--and

63:6

Department's

26:18

depending 81:19

134:18

depends 67:9

depleted 31:1

depressed

115:8,11

depressed--that

115:11

der 3:4

deregulating

85:22

derive 97:4

derived 97:12

113:12

describe 94:9

95:18

described 94:10

95:21

design 34:7 40:6

41:10 59:14

68:3

designed 131:6

designing 24:13

136:1

desirable 24:6,8

desired 34:18

42:19

Destination 79:16

detail 93:12

94:10,18 131:6

detailed 82:9

129:22 130:13

details 60:5 101:3

detected 134:6

determination

12:21 13:11

15:8 80:18

determinations

9:5 15:1

20:18,21

determine 24:6

25:1 40:20

88:13 124:8

determined 35:13

determining 24:8

deuterated 30:22

deuterium 30:21

develop 12:22

22:5 57:22

135:5

developed 49:22

132:1

developing 21:17

40:12 85:6

104:6 106:14

131:2

development 8:9

24:14 36:10

47:16 64:1

DeVilliez 2:9

dialogue 128:13

Dick 5:20 7:13

14:3 20:7

26:17,20 49:10

55:3 57:4 65:9

69:12 77:18

79:1,8 81:14

102:3

109:5,12,13

Dick--if 40:8

Dick's 74:21

79:10

Diego 8:2

difference 79:7

122:16

different 35:3

39:10 40:13

47:2 56:7 62:7

72:19 98:15

100:22 107:11

differentially

105:22 107:6

differently

70:20,21

difficult 96:6

Digital 143:15

dip 25:7

diplomatic 27:1

52:11

direct 8:7 11:20

direction 90:11

92:11 93:20

94:1 99:20

100:11 101:3

104:13 105:2

107:1 116:18,22

123:9,10,13

141:9 143:7

directions 105:18

directly 15:17

115:21 127:13

133:16

134:13,21

director 26:21

117:10

disadvantage

18:20 93:7

disadvantaged

94:5

disagree 103:2

disappears 25:4

discretionary

115:13

discuss 126:17

discussed 126:16

127:18

discussion 61:20

64:16 88:10

93:16 130:11

133:17,18

discussions 83:18
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dispensation

117:13

disposition 85:10

disruption 100:10

101:16

dissemination

47:22

distinction 8:18

105:13

distinguish 31:6

divergent 99:5

diverted 53:12,16

divulges 133:3

doable 68:1

document 50:11

documentation

94:21

documents 38:11

39:9,14 40:16

42:21 59:18

60:8

DOD 8:16

DOE 1:6 14:12

20:2,3,13 27:15

28:11,12 29:21

45:10 51:3,6

52:4,15 53:6

56:17 57:17

58:2,7,9 71:13

82:7 84:9

127:19,22

DOE/NNSA

2:8,10,11,12,17,

21

DOE--probably

78:6

DOE--she 78:7

dollar 94:12,15

97:2,5,6,8,9

113:20 115:7

dollars 22:5 97:13

domain 124:18

domestic 131:19

dominated 99:19

done 6:19 11:2

13:19 25:6,10

51:7 58:3,14

69:17 73:21

75:16 84:3

89:12 90:1

102:19 103:2

105:8 135:14

don't--because

56:6

door 7:22

doses 37:13

doubt 25:1

dozen 44:4

drafting 14:9

drag 21:21

dramatic 42:16

drive 90:20

driven 24:21

140:20

driver 40:12 95:6

drivers 94:22

driving 47:11,12

81:17

dual 73:18 86:20

87:5 130:15

due 10:5 25:11

duplicate 39:8

duplication 84:19

during 25:4 34:6

36:7 45:11

76:2,17 81:22

115:8 124:20

Dwight 2:5 55:17

59:1 71:1

Dwight--is 57:3

dynamic 137:9,14

138:18,19

139:1,3,4,11

dynamic--how

137:16

E

E810 33:14

earlier 72:17

75:20 81:15

94:6 97:18

125:6 128:11

130:16 136:22

early 11:1 43:7

46:3

easier 84:6

easiest 133:6

easy 32:17 39:2,22

40:9,19 43:18

95:12 134:1

echo 49:2 58:20

68:9 120:21

economic 4:18 6:9

18:3 81:21

89:12,17,21

90:10 91:7

92:8,18 93:21

94:1 99:2,11

101:14

102:18,21

103:16,18 108:7

112:14,17

114:8,14 115:9

116:11,18 117:7

122:5

economics 124:19

economists 117:9

education 78:5

effect 81:15 93:20

104:18 105:4,14

123:1,21

effected 123:8,9

effective 17:2,21

22:10 44:11

68:17,19,22

107:9,10,18

effectively 19:20

114:13

effects 115:15

efficiencies 17:14

20:5 22:8 23:13

efficiency 39:7

46:6

efficient 16:18

17:14,19 44:8

48:7

efficiently 19:20

effort 56:13,21,22

119:7

efforts 23:2 36:22

93:1 118:21

EIA 98:17

either 19:17 25:16

64:8,18 69:13

123:13 126:11

elaborate 106:4

110:11 126:15

elaborated 112:2

elapsed 76:22

electrical 91:19

electronic 36:14

39:20 41:19
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42:14

element 10:15

46:15,17

elements 7:5 8:20

11:18 40:6

58:16 139:11,12

e-licensing 4:9

E-licensing 6:2

7:15 22:1,6

26:2,3,16 33:4

59:5 62:14

eligible 141:16

else 46:14 53:12

102:17 107:21

109:20 125:3

else's 46:14

elsewhere 64:3

embassy 28:22

31:22 52:7

embraced 69:19

emergency 83:10

emphasize 92:16

empirical 103:9

115:18

employ 104:1

employed 82:4

143:9

employee 82:4

88:9,12,17

employees 85:16

employer 82:6

enable 42:4

110:18 133:9,22

encrypted 41:4

endorse 68:15

energy 1:1

2:6,9,12 3:2,5

8:4,6,11 11:6

12:20

14:15,18,19

26:22 27:2,3,17

43:16 53:9

54:12,17 63:15

80:17 81:1

85:18 96:20

102:14 110:5

117:11 135:16

137:8 141:11

engaged 42:5

engineer 31:8

78:12

Enhancing 36:20

enrichment 3:4

85:16

enshrine 58:17

69:6

enshrined 58:2

71:3

enshrinement

69:4 72:9

entertain 126:13

entertaining

129:3

entire 5:10 14:12

121:11

entities 20:20

entombment

72:11

entombment's

72:13

entry 42:20

envision 61:15

70:5 129:4

equivalent

44:19,21 80:5

ERI 98:18

ERIN 2:19

especially 83:17

Esposito 2:9

135:16 136:15

essentially 9:9

12:16 14:8

20:19 24:13

25:20 35:16

59:13 61:21

63:16 80:19

82:18 85:2,6,11

87:4 110:4,7

127:2 131:5

135:1,5 137:4

established 83:14

134:9

estimate 97:5

104:11 105:3

estimated 94:11

105:4

estimates 97:19

et 27:16 29:12

58:1 66:12,13

125:16

Europe 70:5

eventually 37:14

everybody 32:7

33:12 39:12

50:19 66:5 73:2

everyone 5:2 6:12

7:21 43:5 49:1

63:7 77:12

82:13,21 89:10

109:13

everyone's 47:5

60:9

everything 27:1

36:13 37:17

41:6 128:17

133:22

everything's

43:12 48:5

64:22

evidence 11:19

140:12,14 141:9

evolution 96:5

evolve 72:3

83:17,19 96:19

evolving 10:21

11:2 70:15,16

96:4 138:2,4,8

ex 5:8 126:18

exactly 12:2 65:10

69:17 70:4 73:2

106:3 112:1

117:22 140:1

examine 116:19

example 14:21

46:18 51:13

85:3 88:4

129:11

examples 19:4

21:5 37:5

130:21

except 30:18

85:16 108:12

114:17 123:6

141:5

excess 124:2

exchange 83:22

executed 104:21

executing 48:14

executive 30:4

57:10

exempt 8:20 15:22

84:18,22
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exemptions 81:14

140:21

exert 48:12

exhaustive 56:13

exist 139:21

existing 33:21

34:6 46:20 83:8

92:22 97:7,14

105:9,10,12

107:18

exists 64:5

expand 65:13

expanding 104:5

126:6

expect 10:12

34:10 36:10,15

38:3 54:14

71:10,11,16

76:14 90:20

104:18 115:6

130:7 131:10,12

136:2,15

expectations

56:19

expected 68:2

76:3 94:11

139:6

expecting 63:5

experience 132:7

141:18

experiences 19:5

expertise 12:19

21:10

explain 11:21

19:13 137:20

explains 8:4

explanation

125:18 137:2,17

explicit 113:8

explicitly 54:3

export 23:7 44:2

45:13 57:11

90:5 92:20

93:10 94:10,12

97:2 113:10

121:17

exporters 130:22

exports 27:21

81:2 82:2,22

84:18 126:11

exports--that

113:16

extend 118:6

extended 6:20

84:9

extending 43:20

extent 44:8 52:22

93:8 94:4 95:1

121:21

extremely 81:9

eye 45:4 53:17

99:7

EZ 131:12

F

face 119:7

faces 34:19

facilitate 36:6

39:11 42:6

65:21

facilities 82:4

facing 11:18

40:18 76:4

fact 6:21 20:2

24:20 73:6 79:9

116:9,14 137:7

138:20 139:17

140:15

factor 47:10,11

81:17 107:20

factored 64:15

factoring 75:14

fair 71:17

faired 94:20

fairly 55:11 97:15

98:2,8 100:8

139:6

familiar 131:20

135:12

familiarizing

94:18

famous 98:4

FAQ

129:4,5,19,21,2

2

FAQs 38:12 130:6

farthest 136:4

fascinating 117:8

fashion 107:18

fast 20:22 21:18

71:22 126:6

faster 17:16,18

46:15,21 50:3

71:22

fast-track 83:9

fear 22:3 70:3

feature 47:19

90:19 104:17

features 24:6,9

35:11 36:19

45:10,11,12,15

59:11 136:2,10

federal 37:5 56:10

57:13,19 58:15

feedback 5:18

10:2 35:1 36:20

38:1 47:16 77:6

89:7 102:8

107:22 117:5

133:10,19

135:22

feel 12:5 13:14

16:7,15 57:16

69:8 86:13

87:19 100:7

112:16 119:22

feels 47:16

fell 95:4

felt 9:20

fiber-optic 30:22

field 112:16

fields 39:21

fight 41:21

file 135:8

fill 131:11 132:11

final 10:1,11

35:13 63:21

64:4 102:9

120:1

finalize 121:21

finalized 36:8

finally 21:20 95:9

103:14

financial 143:10

finding 8:14 9:9

13:3 16:6 26:13

53:6,15,20

80:9,11,20

81:1,4,16

110:6,17

111:8,13 138:22
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fine 68:4 77:19

finger 65:10

firewall 35:22

40:15,17 59:20

firewalled 25:13

first 5:15 6:14 7:6

12:15 13:16

17:1 37:11,20

41:16 43:10,16

44:6 56:3 57:2

60:15 61:19

63:1 65:9 88:22

91:13 100:7

102:20 104:8,11

108:6 109:6

136:5 140:2

fiscal 91:4

fit 12:11

fitting 12:2

five 63:15 74:12

78:15

fix 16:20 41:14,22

46:3,4,5 47:6

70:22 109:10

118:21

fixed 12:7

flexibility

70:17,18 72:2

83:16,20

flexible 17:19

21:3,4,18 93:2

flexible--a 21:18

flexible--be 21:3

flip 42:13 88:22

float 39:9

flow 117:7

Fluor 2:5 55:17

Flynn 91:7

focus 5:16 41:9

116:5

focused 36:4

65:19 90:18

118:14 119:4

focuses 49:9

Foley 2:10

folks 16:7 27:4

41:7 69:3

follow-on 114:1

116:8 135:2

follow-up 112:8

for--because

70:19

force 23:14

forces 23:11

forecast 99:15

123:6

forecasts 96:20

98:12 115:4

123:5

foregoing 143:4

foreign 1:7 4:7

5:21 8:6 20:1,12

26:11 27:22

28:19 29:4

32:11 35:17

39:4

49:10,13,17,20

50:3,10 53:4

55:4 72:19 82:3

85:22 86:1,8

88:22 106:20

foremost 17:1

forestall 118:10

forget 32:3

for--if 9:7

form 131:12

132:11 133:15

forma 32:15

formal 14:2,10

formal--I'm 134:8

formats 39:21

former 140:21

forms 73:7

for--or 110:5

forth 24:12 87:1

129:9

forums 133:17

forward 9:5 12:7

13:6,18 14:13

17:6 18:9 32:15

34:2,8,13

37:11,14 43:2

62:10 63:14

65:16 69:10

70:1 75:15 83:7

112:4 116:19

119:22 120:9

123:22 135:14

138:13 142:1

found--again

34:16

foundations 91:11

fourth 68:18

four-year 114:4

frame 30:4 90:8

framework

46:20,22 127:12

139:1

Frank 2:14

frankly 58:5 87:8

free 112:16

frequently 19:12

132:10,16

Friday 1:16 5:3

Fried 2:14

from--when

140:11

front 63:7 69:18

73:6 74:12

119:9 126:22

front-end 59:14

fuel 30:18,20

50:13 95:10

137:8

Fukushima 83:18

98:5,7

full 50:15 54:8

87:12

function 79:9

94:2,4

functional 7:2

functionality

36:19 38:2

functions 23:1

24:7,9 90:5

fundamentally

27:22

Fusion 85:8

future 68:11

96:3,4 97:10,13

100:13 113:18

118:15,16

133:12

futures 99:9

G

GA 79:18 91:1,2

92:7,11,20

93:13,14,18

97:22 99:19,21

100:6,8,21
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104:12,21 106:1

107:7,11

110:4,12 111:18

123:9 137:3,4

gain 105:16

gap 44:18 45:4

Garrish 2:10

gas 30:21

general 80:5

88:18 103:11,14

106:22 108:11

110:18

125:13,21

130:14

132:15,18

139:18 141:16

generally 8:21

9:2,5,7 15:22

32:16 34:18

36:21

51:9,10,14

55:10 66:4

79:22 82:3

84:6,20 85:15

89:1 90:17

101:9 108:10

125:14 132:1

133:1 134:18

generate 113:17

generic 51:7 53:1

65:11,16,20

66:2,15,18,21

74:7

George 2:3,19

60:11 75:18

128:10 134:6

gets 28:11 60:19

61:6 76:16

84:13 86:17

100:17 134:11

135:17

getting 11:13

24:5,12 25:15

29:15 33:20

48:7 49:20

50:10 60:4

89:18 103:1

107:12 118:15

125:6 140:2

Ghana 66:11,15

gigawatt 91:19

Gisele 2:12

given 35:4 39:3

87:7 93:18 94:5

96:12 104:19

106:21 110:13

114:11,12,21

126:3,7

gives 37:12

glad 33:12 43:4

global 17:22

21:4,14 83:20

91:15 92:14

96:18 104:4

114:7 123:16

137:7

glossaries 38:12

glove 75:19

goal 22:20

23:5,13,14 46:4

56:5,8 84:12

130:5

goals 4:5 44:12

68:16

gone 23:8 119:18

gone--many 77:20

goods 116:3

121:17

Goorevich 2:11

4:5,17 5:4 6:12

33:1 45:19,21

48:16 53:3 56:6

57:2,9 61:13,18

63:10,18

64:7,11,21 70:2

72:13 77:17

109:3 110:20

117:19 126:21

130:4 134:17

135:1,4,11

137:13,18

140:1,5,8 141:3

Goran 3:2

gotten 17:11

30:13 36:9

government 2:2

3:6 11:5 14:3,7

20:1,12 23:7

28:4,5,19 29:6

30:16 31:3 39:5

46:11 53:4,16

63:5 71:13

72:19 73:5

75:12 77:8

78:20 87:16

118:9 121:3

127:22 131:14

governmental

73:7,12,14

governments

21:15 26:12

35:18 73:4 75:4

government's

54:13

government--well

127:2

Grand 1:11

granted 14:13

grapple 101:5

grappling 71:21

138:10 139:9

grateful 91:8

great 77:13 93:12

108:7 113:22

119:18

green 92:5 122:21

Gretchen 2:21

ground 127:5

grounded 50:5

group 2:4 24:16

28:2 49:15

54:1,2,4 61:15

71:13 73:1

74:22 75:1,2

83:5

grouped 47:19

groups 24:5

growth 96:9

98:2,7,12

100:21 101:10

114:14 116:11

guarantee 53:11

guess 6:14 49:19

54:16 110:2,10

124:11

guidance 58:1

86:7 131:21

guide 19:7,11

38:11 130:17

131:7,11

133:12,13

guide--a 19:6

guidelines 28:2

49:15 50:19

54:1,2,5 58:1

133:21

guides 130:17,20

guiding 44:5
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guy 78:14

guys 55:19 79:13

89:8

H

half 10:13 93:11

94:7 108:16

114:6 118:3

125:8

hand 51:5 98:14

103:22 104:3

hand-in 75:19

handle 26:7,22

hands 100:15

happen 44:16

53:21 73:3

happened 82:12

happens 19:15

23:20 29:19

30:8 88:5

111:16

happy 5:3 7:1

32:21 47:22

101:18 116:21

128:2

hard 17:8,10

42:21 53:8,14

56:7 87:17 90:3

111:6 116:16

121:10

Harris 2:14

have--I 107:2

haven't 54:19

64:8,18 84:14

112:2 141:4,6

having 5:11 10:4

17:22 25:9,16

39:12,19,20

43:17 48:10

79:7,8 87:10

88:2 106:15

118:5 127:22

hazy 96:14

Healthcare.gov

37:6

healthy 69:20

hear 8:8 19:3

28:14 50:2

102:6 128:13

heard 17:7 19:2

21:21 22:7

52:11 58:21

69:3 70:12 71:2

72:17 83:12

84:1,14 106:6

109:12,13

110:4,21,22

117:14 118:18

137:22

hearing 15:19

70:13,14 109:4

128:7

heated 119:11

heavy 30:22 71:6

Heide 3:4

help 7:12 19:1

22:8,15 24:17

33:7 67:4 84:4

90:14 116:21

131:3 135:13

helps 13:17 84:16

hereby 143:4

here's 63:1

he's 24:12 25:8,9

38:10 57:9

77:18 80:11

hi 43:15 55:17

102:14 109:22

112:6 117:6

hiding 42:6

high 33:13 35:12

37:9 60:6

99:3,5,9 100:3

101:12,15

114:15,17 123:6

higher 97:16

highlighted 34:5

Hill 80:15,21

hire 71:1

historical 92:21

98:1 113:12

history 4:13 38:7

39:1 98:7

139:5,15

hitting 37:15

Hochstetler 2:11

Hogan 2:15 3:4

hold 6:17 106:17

holding 112:10

Holtec 3:6

home 32:2,6,8

78:20

honest 25:12

86:22

honesty 55:5

hope 10:13 45:3

69:13 120:15

130:4,16 131:1

hoped 139:6

hopefully 43:7

72:4 84:16 90:6

107:15

horribly 42:1

host 14:3

hour 78:13

hours 7:4 25:4

78:18

house 2:9 12:5

35:21

117:2,11,14

118:2,14

huge 27:9 76:21

126:3

human 106:12

husband's 118:3

Hyatt 1:11

hybrid 108:18,22

Hyde 108:16

125:20

hypothetical

91:16

I

IAEA 79:21

85:14,16 98:13

Ian 2:4

I'd 43:16 44:14

45:7 67:6 68:16

79:1 89:14 90:6

118:12,17 119:6

129:2

idea 7:3 19:2 21:1

23:10 52:10

74:6 79:4

129:20

ideas 7:12 16:14

19:2 20:7 22:16

25:16 85:21

127:10,15

128:1,5 133:20

identified 141:14

identifier 62:15

identify 61:10
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96:1 112:4

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identifying 24:10

IEA 80:3

I'll 17:12 25:12

31:20 32:21

35:14 47:15

73:2,9 86:22

96:22 102:17

121:5

illegal 31:18

illuminating 65:8

I'm 7:10,11 12:8

15:17 16:16

25:6,8 26:20,21

30:1,10 32:20

33:2,12,16 34:4

41:11 43:15

44:1 49:16,20

50:22 53:8 61:9

64:12 65:3,4

69:12 71:1

75:16 89:18,20

91:10 95:17

103:6,22 107:12

109:4 112:17

113:2 114:22

117:10,11 118:2

120:14 122:4,9

123:19,21

128:7,17 140:13

141:1,8

imagine 35:20

immediately

42:13 76:20

impact 4:18 6:9

81:18,19

89:12,17,21

90:10,12 91:12

92:8,18

93:3,17,21 94:1

100:21

102:19,21

103:11,18

104:11,12 107:3

114:11

116:18,22 117:8

impact--negative

107:3

impacts 90:18,21

100:15 103:16

implement 9:11

20:7 22:13

25:21 50:22

62:14 71:14

72:1 87:18

implementation

24:15 132:7

implemented

45:13 55:22

100:17 130:2

implementing

11:14

implements 8:3

implicit 113:18

importance 11:3

45:22 126:7

important 13:17

16:11 17:6

18:3,4 21:19

22:11 26:3

40:12 70:12

107:5 112:11

114:2

importantly 68:11

impose 36:14

impressing 59:2

impressive 55:18

improve 5:19,22

15:12,21 16:12

19:1 23:12,22

41:16,19 64:14

100:16 129:17

133:20

improved 22:19

41:13 91:8

105:11 121:1

improvement 4:4

5:16 7:12

16:13,14 19:11

22:20 24:20

33:6 36:22

39:18 44:7,10

58:6 61:1 75:14

93:1 105:7

108:5

improvements

24:11 26:5

33:22 45:2

76:16 129:1

improving

36:5,21

Inc 2:16 3:4

inches 78:15

incidence 32:9

incidents 98:5

include 36:15

107:19 108:10

116:8,11,14

118:9 119:15

included 101:9

113:6 116:12

121:22

include--or 87:21

includes 12:18

19:11 116:2

121:8,9

including 45:14

65:17 94:18

112:22

income 113:1

inconvenience

43:19

incorporate 57:18

86:15 106:3

110:6

incorporated

89:22 118:20

incorporates

100:4

incorporating

36:20 86:18

increase 129:18

increasing 11:7

121:19 129:7

increasingly

44:13

incremental 76:18

incrementally

37:4

indeed 129:18

independent

60:12

India 108:13,17

125:7,20

indicated 67:11

indirect 8:7 85:4

individual 93:11

94:21 109:9

individually 62:20

individuals 44:3

75:5 88:1

industrial 31:2

98:11

industries 71:22

industry 10:20

11:17 18:1
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65:21 72:3,4

96:16 100:5

101:2,15 103:7

107:6 131:3,6

inefficiencies 44:9

inflexible 138:11

influence 48:12

121:19

inform 63:4

133:11

informal 134:8

information 11:19

33:17 40:2,20

41:1,5,8 48:11

59:9,15,22

60:7,10 75:8,11

84:20 88:19

96:7 98:6,22

112:11 129:3

131:4,8 134:2

139:19,20,22

140:14

information--

some 35:6

informed 23:18

82:19,20

infrastructure

68:9 125:9

inherent 18:6 60:1

inherently 35:20

inherited 27:4

inimicality 8:14

9:8 53:5,15,20

80:9,11,19

81:16 110:6

141:11

initial 12:16

36:16,20 44:10

76:8 133:12

136:13

initial--let's 113:4

initiated 135:18

initiatives 38:18

innumerate 58:13

input 24:5 90:14

insight 11:17

93:15

insightful 91:5

insist 104:16

105:14

installation 72:10

instance 51:22

instance--we'll

39:20

instead 33:1 52:13

134:12

Institute 2:12

43:16 102:15

instructive 98:8

insufficient 103:9

115:20

Insurance 99:6

insure 7:21 28:3

40:1 109:16

insuring 71:3

intangible

31:4,6,8,11

32:10 73:13

Integrated 2:19

60:11

integrity 92:20

intention 10:7,9

17:2

interaction 26:11

interagency

13:5,14 14:6

20:14 25:12

36:7 56:13,17

58:14 62:22

118:7

119:7,8,21

120:22 127:19

interest 89:10

143:11

interested 68:22

127:7

intermediate

108:19

125:12,22

126:12

internal 12:18

20:13 24:4

25:11 35:19

36:12 37:19

40:15 58:1,3

61:7

internally 10:20

33:7 46:9 57:21

58:4

international 1:3

2:22 44:14 45:6

69:18 84:3

Internet 40:7

interpretation

132:22 133:1

interpretations

19:16 86:4

130:11

interrupt 117:7

interview 25:15

interviewing 24:4

25:10,11 70:6

interviews 25:5

introduce 33:2

intuitive 40:4

invest 22:5

involved 34:11

46:16

involvement

131:7

Irola 2:12

IRS's 131:11

is--although 23:18

is--because 54:22

Island 98:5

isn't 15:2 20:2

25:15 72:5

109:15

ISO 22:21

23:2,4,5,8,9

24:17 38:18

57:21 58:11

is--or 109:4

isotope 85:5

issue 9:22 27:15

28:1 49:9 53:22

55:1 63:12 80:9

81:8,10 87:2

106:12 114:15

121:6

issued 10:3

issues 24:11 27:5

issuing 9:13

is--that 130:5

is--which 8:5

ITA 91:6

item 73:17

items 28:8,9 30:17

51:8 73:12

iterative 42:11

45:9 76:18
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37:3,10

it'll 42:12

it's 7:1,2 8:21,22

9:7 10:17,21

14:15,19 15:6

16:4 17:8,17

18:3,4,11 20:2,3

24:19,20,22

26:3 27:2 30:11

32:13,15,17

39:4,6,22 41:12

42:1,15 44:13

47:9,11,21

51:10 52:21

53:13,21 54:11

55:18,21

56:7,12,21

57:14 58:3 60:3

63:2 65:11

66:19 67:14,17

68:1 69:7,13

70:15,16

71:3,20,22

75:11 78:13

79:4 82:7,14

84:10,11

86:8,12,16 88:4

89:2 92:13 93:5

94:4 98:2

104:22 106:18

107:1 108:6

109:6 112:10

113:4 114:5

116:16,18,21

121:10 123:20

124:21 127:17

128:5 129:7

131:5 132:15,19

137:18

138:18,19 139:3

it--then 136:12

I've 25:12 35:11

37:3 53:6,7

55:20 60:12

69:12 73:6

77:20,21 79:5

137:18

J

Jacobson 2:14

Jamaica 80:2

Japan 44:20

Jay 2:14 65:2,3

122:4 125:4

Jean 2:7

Jeff 2:2 3:5 4:9

5:22 7:14 24:12

26:15 33:2,8,16

47:15 59:5

67:10 130:5

133:5 135:17

Jeff's 22:9

Jennifer 2:8 3:6

job 111:19

Joe 91:7

Jones 2:12,13

43:15 48:20

72:16 74:18,20

102:14 106:6,19

125:4 128:9

139:14 140:4

141:1

Jorge 2:5

Joshua 2:15 112:6

128:21

joy 42:2

Joyce 2:7 4:21

12:4 102:1

117:1,10 139:10

justifications

111:3

justify 139:19,21

K

Kahn 138:16

Katie 3:2 4:3 5:4

7:10,16 25:14

Katie's 77:22

Kelly 2:11

key 16:14 20:10

79:14 82:2

93:15,21 96:15

103:15 104:17

115:17

keys 18:15

kilometers 108:14

Kincaid 2:13

knew 82:12

Kollar 2:14

Korea 44:20

Kraemer 2:14

65:3,7 67:10,17

68:5 122:4,9,15

123:12,19

124:5,11 125:1

Kuntamukkala

2:15

L

laboratories

89:15

Laboratory 2:2

3:3,5

Laboratory/

Consultant

2:14

labs 12:19 90:4

lack 35:1,5 81:19

lag 72:5

Laguna 79:22

laid 9:3 47:8 83:2

language 121:22

LaReina 2:17

large 98:3

larger 23:1 62:3

71:20 92:12

100:1 107:3

121:6 123:9

last 10:22 45:1

74:3 78:1 98:3

103:17 112:12

116:7 117:12

118:10,19

135:20 140:4,5

late 21:22 31:13

90:2

lately 69:10

later 6:14 77:6

91:22

Laughter 55:8

57:5,8 65:1,6

69:15 117:17,21

140:7

law 2:3 8:19 9:1

15:9 17:2 18:18

27:14 46:12

49:21 50:20

53:13 54:11

81:3,16

86:5,6,10

87:3,18 111:9

lawyer 65:4

laying 111:4,19

layman's 19:13

lays 9:10 57:14

lead 24:3 62:2

leading 12:4
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learn 15:14 77:17

learned 15:15

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77:18

learning 49:11

least 21:22 24:21

40:7 61:5,14

63:21 65:19

68:19 79:5

100:14 124:16

leave 47:15

118:1,13,18

121:4,5

led 91:7

legal 12:21 19:17

46:10,17 47:7

62:6 110:3,13

legally 127:8

legislation 121:10

legitimate 109:17

lengthy 39:9 81:9

93:5

Lenka 2:14

less 35:20,21

92:14 106:16

126:5

lessen 129:16

lessons 69:14

let's 63:4 67:8

74:16 77:7

112:19 125:7

letter 28:15,20

29:20 51:6

103:7

letters 30:2,10

level 15:7 33:13

35:12 37:9 41:4

56:20 60:2,6

76:10 97:21

98:9,22 99:22

levels 98:19,20

leverage 34:1

Lewis 2:13,18

liability 62:19

license 12:17 78:4

licensing 22:3

24:9,14 26:5

33:14 34:17

45:8 59:12

62:19 75:6

131:19,22

lift 71:6

light 42:13 65:12

89:19

likely 99:9

like--out 19:9

limit 107:8,9

limitation 16:21

limited 27:13

32:13 129:21

limits 45:17

Linda 2:19

line 45:16 125:13

lines 50:2

127:8,20

link 62:21 133:15

linked 141:10

lips 118:1

list 28:3 30:17

32:5 35:12

45:10,11 51:8

54:3 57:12

65:13 66:21

73:12,17,18

80:6 102:15

111:18

140:3,11,12,13,

16,17 141:2,6

listed 141:7

listen 90:15

lists 47:19 97:22

little 5:14 6:14

7:1,11 14:3

17:13 22:2

26:18

33:9,13,21

34:3,4,12,15

35:14 43:1

45:16 49:16

52:3 59:4,11

68:14 72:4

77:22 81:20,21

90:2,8 96:14

102:2 106:4

110:11 131:15

live 57:1 59:19

lives 39:11

living 72:12

Livingston 2:4

LLP

2:13,14,16,18

load 22:4

loading 59:9

locations 67:4,6

lock 72:2

log 38:10

logic 108:4

logical 35:13

long 29:7 31:20

39:2,6 48:6

49:18,19

51:2,3,20,22

52:3,21

66:21,22 77:22

81:9 84:7 87:1

100:19

longer 10:21

73:22

long-standing

49:14

long-term 121:18

loop 35:1

Los 2:2

lose 105:16

losing 134:4

lot 5:18 17:11

21:9,10 40:15

41:21 57:18

59:8 70:10 85:8

87:8 89:5,6

91:4,5 95:2 96:7

108:3 112:11

114:22

118:20,21

129:10 130:7,9

Lots 17:10

loud 21:21 84:1

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lovely 102:1

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114:16

lower 104:20

lowest 21:1

M

M&O 97:7

Madeleine 2:10

Madrigal 2:15

112:6 113:22

114:6,10 116:7

128:21
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60:16

magnitude 90:11

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magnitudes 92:9

main 118:12,17

maintain 58:12

87:14

maintaining

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major 40:12 41:9

50:13 80:8

81:13 82:14,21

majority 79:19

101:12 124:15

majority--

something

124:1

Malcolm 2:4

manage 35:10

39:13 41:2

managed 38:14

management

48:11 58:9

82:19

managers 25:14

Mann 2:16 58:19

manner 22:10

59:18

manual 42:20

76:12

marathon 118:3

mark 37:15 77:1

market 17:22

44:14 65:18,20

96:8 122:11

123:14

124:2,9,15

126:9

138:2,7,18

139:3

market--and

126:4

marketing 11:13

88:19

markets 91:14

96:17 137:7

138:14

market's 138:2

Markus 2:16

109:22 136:21

137:15

married 78:5

Maryland 62:9

mass 134:4

match 97:17,22

98:21

material 8:10 15:3

30:19

materials 30:21

matter 27:22 73:6

matters 28:19

Matthew 2:20 3:4

may 19:16 62:7

63:20 71:1

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101:16,19

106:7,15,19

112:7 113:3

116:7 129:12,14

130:13,14

maybe 5:22 59:5

61:3 72:7,17

104:10 106:15

107:13 108:18

125:21 130:18

131:14

mean 64:3 66:19

67:17 85:9

88:11 107:2

109:1 116:13

117:6 126:5

means 11:6 19:14

26:22 41:19

50:16 82:10

97:5 112:1

137:14

meant 86:11

137:10

measurable 90:18

measure 25:19

106:2

measures

126:1,12

mechanism 69:8

93:20

mechanisms

110:15

Medical 85:5

meet 6:22 17:1,20

18:17 71:6

meeting 1:8

5:6,15

6:15,18,19 7:7

10:4,5 43:18

58:22 64:10,11

70:4 81:16,22

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112:10,12,13

117:13 118:11

142:4

meetings 88:11

132:3

meeting's 6:13

megawatt

97:6,7,8,9

megawatts

97:15,17

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58:19

member 73:1

74:22 134:20

135:2

members 43:21

49:4 73:9

102:16

memo 56:17 58:3

memorandum

56:18

mention 29:16

31:16

mentioned 38:10

44:10 45:10

52:2 95:21 96:4

99:3 100:12

101:18 139:15

message 31:21

met 6:14

methods 23:16

metric 56:5

113:9,21

metrics 25:20

72:9

Mexico 79:21

mic 133:6

Michele 2:20

microphone 102:5

microphones

43:11

mid 11:1

middle 127:5

Mile 98:5

milestone 39:1

48:3
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milling 85:3

millions 22:5

mind 66:3 77:5

mine 54:17 133:19

minimis 30:18

minimize 42:20

mining 85:3

ministry 29:4

minute 77:7

minutes 12:9

miss 77:1

missed 72:17

ML 2:7

Montgomery 78:2

month 136:8,18

months 10:14

29:14 33:19

34:17 36:11,17

76:5,15 91:3

135:21

136:13,16,19

months--or 32:4

month--yes 136:6

Morgan 2:13,18

morning 5:2 6:13

27:11 33:12

34:3 48:22 65:3

77:18

mornings 78:14

mostly 16:16 27:7

motivation 124:19

move 14:7 17:6

22:8 46:21 50:3

68:17 111:17

123:13 135:14

138:13

moved 43:1 93:19

94:8 102:3

139:17

moving 9:5 10:15

13:5,18 14:13

22:22 33:3

41:11 71:22

83:7 91:1 92:11

93:18 101:16

103:13 104:12

105:17 106:21

107:15 112:4

118:1 123:8,10

138:8 141:9

multiple 20:15,17

38:8 39:13

multiplier

116:9,14

N

N.W 1:12

NAC 98:17,21

99:8

namely 32:10

NA-QA 24:16

Narrow 83:2

narrowed 85:13

national 2:2,7,14

3:3,5 12:19 99:6

nationals 82:3

106:20

nature 13:13 20:8

42:11 49:20

71:15 94:10,19

113:18

navigating 40:10

nearly 10:12

necessarily 40:14

108:9

necessary 8:22

9:20 24:6,8

need--it's 44:17

negative 28:13

NEI 44:5,22 45:13

neither 143:8

nerdy 79:6

nervous 77:22

net 100:20 107:1

network 138:17

news 27:8,9

nine 36:17

Ninety-five

123:16

NIS 1:3 24:3

36:9,22 39:20

41:13 42:3,6

48:12 76:7,13

nitty-grittier 59:4

NNPA 57:10

NNSA 4:5,9,13

5:5 24:16 33:18

35:19,21 40:16

60:1 90:5

NNSA's 36:13

nobody 62:18

non 8:13 14:20

53:5,14,20

80:8,10,13,19

81:15 110:6

118:15 119:15

121:18 125:15

141:10

non-delegable

14:22 15:6

none 106:16

nonetheless

106:19

non-fuel 30:21

non-inimicality

13:3 16:5 26:13

80:22 81:4

110:17 111:8,13

138:22

non-NPT 87:10

non-nuclear 31:2

50:15

non-proliferation

11:6 18:4

110:3,7 121:13

139:4

NONPROLIFER

ATION 1:2

NOPR 9:16,20,22

79:17 85:12

90:1 103:1

137:5 138:1

NOPR--Notice

9:14

nor 143:9

normal 115:9

Northwest 3:3,5

notably 37:6

note 55:14

noted 98:4

nothing 34:16

notice 56:10

57:13,20 58:15

67:12,15,20

97:12 102:2

noticed 99:4

notification 39:15

notify 30:9
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November 1:16

10:6 70:10

now--many

132:12

NPAS 80:14,20

111:10 112:1

NPT 87:4

NRC 8:16 27:16

78:11

82:6,8,9,15,17,2

0 83:4 84:17

130:18 131:18

NRC--Commerce

57:12

NRC--us--

currently 57:13

NSG 54:10,22

73:4 75:1,7,11

nuclear 1:7

2:9,12,17,21 8:9

12:20 15:3

17:21,22

21:11,16 26:22

27:2,5,7 28:2

29:17 30:18,19

32:11 43:16

46:19

49:1,3,4,6,15

50:18 51:15

54:1,2,4 57:12

64:1 66:9

68:8,17 69:1

71:21 73:1

74:21

78:11,13,19

81:2 82:4

83:5,10

91:15,16,19

92:14 95:2

96:9,16,20

97:21

98:2,4,6,12

100:5

101:2,10,14

102:14 104:6

106:7,14 109:17

115:21 116:2

117:11 118:17

120:19 121:13

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32:12

O

objective 18:8

44:6

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34:9 35:12 38:4

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obligations 18:17

54:4 83:6

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observation 44:15

107:14

obviously 22:11

68:22 81:17

83:18 98:6

100:18

occasions 66:10

occurred 113:13

o'clock 117:4

October 6:16

of--as 69:2

offer 57:7

offered 16:13

offering 57:3

office 1:2 2:2 3:6

7:15 12:20 17:6

22:9 24:2

33:7,18

officer 33:17

135:5

office's 56:22

official 75:12

136:11

of--it's 131:18

of--some 108:20

of--when 85:8

oh 30:11 117:15

okay 6:12 18:11

32:20 36:11,17

37:15 41:8

42:22 56:11

58:17 61:3

63:17 66:22

74:19

75:4,16,17

77:4,13,17

79:12 84:12,14

101:21 110:20

113:22 114:10

122:9,19 124:5

125:3 128:8,20

134:22 135:3,15

136:19 138:15

139:1,12 140:5

141:16

old 60:16

omission 103:15

ONB 89:13

one--and 108:8

ones 63:10 66:6,7

96:22

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ongoing 36:18

37:1

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99:11

onus 84:15

opaque 15:16

16:15,17 93:5

open 17:3 34:20

101:21

openly 131:9

openness 132:16

opens 133:15

operating 36:16

76:9 136:14

operation 84:4

95:10,12 119:8

operational 21:7

83:8,9,13,21

operations 33:17

106:8

opinions 19:12,18

opportunities

59:2 138:19

opportunity 7:7

37:13,22 42:17

112:3

opposite 105:2

opted 116:5

orange 92:6

122:20

order 27:15 38:1

40:5 48:12

58:2,7

order--a 56:18

orders 58:10

organically 50:1

organization

120:10

organizations

84:4

original 9:13

137:5
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others 19:4 29:18

115:12 120:21

otherwise 101:20

ought 121:22

ours 46:15 131:16

ourselves 94:18

119:11

outcomes 100:5

outgoing 74:21

output 114:18

outreach 68:10

69:22 120:2

132:12

outside 45:3 56:12

84:5 118:4

outweigh 100:10

101:15

outweighs 101:2

overall 16:20 94:1

120:20

overestimated

103:13

overhead 78:16

overlap 20:14

oversight 81:11

overview 4:13

33:13 77:15

89:4

owned 88:22

ownership

86:2,11,13,15

P

p.m 142:4

pace 11:6 17:15

Pacific 3:3,5

package 14:8

54:12

packages 39:9

63:15

PAGE 4:2

pain 37:11

panel 4:20 102:2

141:20

paper-based

42:14

paperwork 26:9

62:13,14 63:13

80:20

parametric 93:3

100:20

Paris 70:9,10

Parker 2:17

parte 5:8 126:18

particular 59:1

66:3 88:12

91:21 94:5

100:3,9,17

114:20 130:1

particularly

65:12,17

particulars 121:6

parties 39:10

48:12 60:8

87:10 143:9

partner 14:6

52:1,17 110:9

partnered 33:18

partnership 20:4

partners--will

70:21

party 90:2

pass 26:17

passports 87:13

past 10:20 33:19

55:21 86:5 98:7

130:12 139:17

140:10

path 27:14,20

pathways 9:10

patterns 96:6

pause 86:18

payers 22:12

peaceful 27:2 28:5

50:16,17 54:6

137:7

PED 97:3

peer 84:3

Pennsylvania 2:5

people 14:17

16:15 19:3

31:19 32:1 37:7

41:21 43:10

46:13 70:6 87:9

117:4 121:9,15

127:15 130:8

per 97:5,7,8,9

99:17

percent 101:6

104:20 105:1

122:11,17

123:14,16 124:2

125:5 126:5

percent--about

122:17

percentage

86:2,15

perfect 100:5

perfectly 129:7

perform 82:17

performance

18:19 24:10

25:19

performing 89:16

perhaps 37:2

112:15 113:7

115:13

period 6:20 12:3

32:3 43:20 79:3

84:9 96:17

100:1

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115:9 116:10

120:15 128:3

142:3

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permit 125:21

person 29:5 30:2

31:11 62:6

86:9,12,16 87:5

88:3,5,9,14

129:10 134:9,16

135:7

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personally 119:21

personnel 85:14

104:1 106:21

Persons 86:20

perspective

123:17

pertains 125:20

pharmaceutical

31:1

phase 34:9

36:3,7,9,12,18

37:18 40:17

42:11,12,15

76:4,12 135:17

136:4,9,14
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phone 130:9

physical 54:7

pick 118:4

picked 32:6

Picking 125:4

pie 91:16 92:2

97:18 101:11

122:6,21 123:22

124:5 126:4

piece

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36:12 40:18

99:1

pieces 12:2

Piercy 2:17 48:22

49:1 55:2 72:17

120:19

Piet 3:4

Pillsbury 2:16

44:22 110:1

136:21

Pittman 2:16

placed 5:13 32:5

43:13

places 51:18,19

138:14

139:5,7,16

placing 129:4

plan 6:1 23:16

58:6 136:10

planned 33:21

97:10,16 115:12

118:10 125:8

planning 95:2

113:4

plans 4:5 65:15

66:2 95:3

plant 95:10 106:7

113:5

plants 95:3,8,12

115:12

play 69:9

please 28:21 43:11

61:1 74:9

106:18 109:21

112:16

plenty 90:3

plus 76:5,15

136:12

PNNL 4:18 89:15

90:4

point 6:4 7:22

13:4 14:17 22:4

39:6 55:22

65:16 70:18

77:21 88:22

91:13 92:13,16

95:13,17 103:17

115:19 119:6

120:1 121:14

126:20 128:10

134:9 140:8

points 37:11

118:12,17

pole 49:18 51:2

52:21

policy 11:5 18:3,4

27:22 49:15

90:5 117:11

Polonsky 2:18

poor 18:19

portends 68:11

portion 43:10

position 21:13

68:18 136:8

positive 28:17

32:16 141:10

positively 84:13

possibilities

105:19

possibility 50:8

possible 10:10

21:11 40:1,19

42:22 46:2,5

55:10 119:19,20

122:6 133:3

134:1

post 83:17 133:18

post-Fukushima

21:8

potential 81:19

100:15,21

101:15

potentially 101:14

138:15

power 95:2 97:7

98:2,12 104:6

106:7,14 113:5

PowerPoint 27:10

49:11,12 77:19

78:9 79:4,8,11

practicable 67:14

precisely 73:9

preconceived

25:16

predict 96:3

100:19

predictability

84:16

predictable 16:18

17:4

18:10,13,14

34:22 68:16

predictably

103:20

predicting 90:18

prediction 96:6

Preeti 2:6 110:22

prefer 72:11

preference 63:13

prepared 44:22

52:19 66:20

present 21:1

120:11 136:9

presentation

5:10,15 55:18

61:2 65:8 76:3

77:14 102:19

presentations

43:6 55:20

presented 99:13

presenting 99:17

presents 112:3

pressed 53:8

pressing 37:10

pressure 127:20

presumably 42:19

105:11 107:2

pretty 12:14 40:9

41:11 91:14

93:4 96:11

130:9 135:20

preview 33:9

previous 98:7

129:1

primarily 100:6

124:21

primary 113:21
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principle 89:21

90:19

prior 34:17 37:21

119:1

private 41:1 96:8

pro 32:15

probability

104:20

probably 10:7

12:13 16:8 22:4

28:14 46:21

47:1 55:6 67:7

73:3 76:22 96:5

106:10 107:1

108:10,15 124:6

128:12 131:20

136:8

problem 51:21

52:5,7 55:15

83:10 90:3,8

91:3 103:1

104:17

124:13,16

problems 52:9

120:5

procedure 134:10

procedures 20:22

111:17

proceeding

143:4,5,6,8,10,1

1

process 4:4,10,16

5:6,16,19,22

7:12,14 10:17

11:10 12:12,15

13:9 14:8,12

15:7,11,15,21

16:2,8,9,12,13,1

4,17,20 17:1,17

19:11,21

21:17,18

22:9,19,20,21

23:3,4,7,12,22

24:7,18

25:13,15

26:5,14,19

27:12 30:15

33:5,21,22

34:6,7,12,14

35:5,10

36:7,10,22

38:17 39:4,6

41:13,17

42:9,10 43:4

44:7 45:2,8,9,16

46:1 48:8,14

49:8 53:1

55:4,10

56:2,8,12

57:11,14,16,17

58:5,22 59:17

61:1,8,14,15

64:8,15,17

66:17 68:12,21

69:4,8

70:6,16,17,22

74:3 75:14

80:13 81:9

92:20,22

93:1,6,12 94:20

101:19

105:7,9,10,11,1

2

107:11,12,14,18

108:5 109:7,18

110:13 119:3,22

120:9

121:2,9,22

124:20 128:22

129:5,17,18

133:21 134:1,14

135:21 141:13

processes 11:8

12:6 17:19

21:13 36:13

41:15 42:1

44:19,22

46:9,16 58:1,13

64:14 71:16

72:1 75:3

100:16 109:10

119:1 120:5

131:1

processing 35:19

44:16,18 62:12

prod 51:21 55:13

produced 28:8,9

producing 34:18

85:6

product 61:5 91:8

119:12 121:1

131:5

production 8:9

30:22 83:3 85:5

productive 120:16

products 64:2

professionalism

58:22

program 23:1

32:12 56:15

131:19 134:11

programs 84:1

prohibits 8:5

project 4:4,5

23:16,18 24:3

61:11,17

62:9,21 63:2,8

76:21 79:21,22

114:11 134:16

projected 91:20

97:16 108:16

122:11 124:2,8

projection 91:21

99:10 100:4

114:16,18,21

projections 92:1

96:9,13 97:21

98:15 99:1

100:22 113:6

114:13,15

projector 78:16

projects 62:4 64:2

proliferation 18:6

80:14 118:16

119:16 121:19

124:21 125:15

138:3,4,6,20

139:7

promotes 121:18

promotion 18:6

prompt 68:15

proportional

113:20

proposal 65:13

89:1 125:10

proposals 85:20

proposed 1:6 4:18

9:14 52:1,17

77:14 79:15

82:2 84:2,17

85:21 90:19

92:4 94:1,11

108:6 122:22

123:18 124:1

proposing 84:21

Proprietary 93:10

pros 47:5

prospective 113:9

protection 54:7

provide 18:21

19:18 31:10
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48:11 50:9 60:5

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provided 11:16

45:14 102:15

140:12,14 141:8

provides 83:8

131:21

providing 24:9

38:2 40:2

86:9,17 141:12

provisions 122:1

PSA 80:2,4

PSAs 80:1,4

public 1:8 4:20

5:6,13 10:2,4,5

11:12,16,18

12:3,11,12

35:16,20 36:4

40:18 41:1

43:20 46:12

47:22 48:18

49:3 59:10,14

60:3 76:4 84:19

88:11 128:3

132:2,3,14,19

141:12

publication 90:1

publicly 128:19

129:21 132:4

139:19

public's 47:13

publish 57:11

134:2

published 56:9

116:1

Pueblo 131:13

pull 43:8

pulled 55:19

pulling 138:13

purely 112:21

purpose 4:13

73:18

purposes 8:18

31:1,2 51:8

pursuing 65:19

pushing 16:12

138:13

puts 18:19 84:15

putting 60:9

131:10

Q

Q&A 4:10 32:22

129:2

Q&As 133:11

qualified 104:1

106:21

qualitative 97:1

qualitatively

95:21

qualities 16:22

quality 24:19 25:2

quantified 25:19

quantitative

91:12 95:14

107:19

quantities 30:19

quarterly 37:2

question 6:4

14:17 43:11

44:6 45:18,22

49:9 50:7,22

52:12 53:19

55:3 56:11

61:4,11 63:21

67:11 70:8

71:20 72:16

74:3,16

75:9,19,20 77:1

90:13 92:7

101:5 103:16

104:9 105:20

109:4,7,18

110:1,10 111:20

113:7 114:1

115:5,6

116:8,20

120:15,18,20

122:5 125:2,5

128:7,22 129:13

132:21,22

134:14,15,18,19

137:1

138:9,17,21

question--back

57:3

questions 4:20 6:5

10:6 13:1,3

14:15 19:12

32:21 43:2,9

44:1 56:3 60:13

61:1 65:9 90:7,9

95:19 101:19

102:15 107:22

112:5,7,15

119:20 128:13

130:8,10

131:4,8

132:10,14,17

133:2 134:5

queue 94:9

quibble 15:18

116:13

quick 55:2 56:3

quicker 107:16

quickly 10:10

29:8,13 30:8

32:18 41:12

43:1 55:11

quite 37:4,5 58:4

87:8 91:9 96:21

99:5 105:11

quote 134:16

R

rage 78:9

range 96:11,19,21

ranking 68:18

rapport 135:6

rates 97:4,12

98:21 99:15

115:7,16,18

rather 9:22 39:12

76:20 84:15

92:22

rational 108:12

rationale 108:4

reach 110:18

reaches 60:2

reactor 31:7 62:4

66:12 83:1,2

reactors 50:13

84:4,5 91:19

97:14 108:15

reading 94:20

real 38:7 107:5

122:22 134:9

realize 92:13

121:15

realized 91:20

really 7:5,7 8:1

9:18 10:1,9 11:8

13:17 16:16
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25:2,7 26:1,5

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53:22 54:7

58:8,21 59:1

71:12,19,20

72:5 78:9 79:9

87:6,15,21

88:20 93:4,10

94:2 102:6,11

105:3,7 106:2

109:5,6 112:11

114:1 115:21

121:15 124:22

126:6,10,17

131:2 142:1

reason 13:9 25:1

30:12 51:14

62:18 104:13,18

124:6

reasonable 32:3

reasons 6:17 9:3

27:21 52:11

63:20 80:8

81:13 141:5,15

receipt 88:15

receive 12:11,17

received 9:15,21

127:10 135:22

recent 86:21

101:9 137:9

139:5,15

recently 37:7

63:22

recession 114:8

115:5,15

recipient 87:17

88:1,4 111:13

reclassification

90:21 110:2

122:22 123:18

137:1

reclassified 105:1

reclassifying

103:21 110:3

recognize 11:10

18:18 121:7

137:6

recognizes 75:7

recommendation

13:5 14:1 61:8

125:14

recommendations

13:7 14:9

25:21,22 45:14

recommending

24:11

record 86:6 96:18

113:12 130:10

143:8

recorded 5:12

143:5

recording 128:17

records 38:10

82:19

reduce

18:11,12,15

20:12,13 41:18

reduced 122:17

143:6

reducing 19:22

reduction 17:3

44:15,17 68:20

reference 15:5

Referral 57:12

referred 137:2,5

reflect 33:5

reflection 9:20

reflects 116:10

reforms 68:12,21

refreshments 77:8

Reg 131:20

regard 42:2 65:22

66:12 69:10

76:16 110:1

regarding 10:8

75:20 81:2

137:1

regardless 23:20

86:11

regards 26:7 44:6

83:21

regimes 118:16

Register 56:10

57:13,20 58:15

regulate 49:7

regulated

116:3,5,6

regulation 8:22

13:1 16:8,10,15

17:9 19:8 44:12

49:22 69:6

71:14,15,18

72:1 92:4 94:2

100:17

138:9,11,13

140:18,19

regulations 17:10

130:18

regulator 44:8

regulatory 2:21

16:17 19:5

46:18 69:18

82:15,16

90:19,20 127:12

128:4 131:22

132:6

related 83:3 143:9

relates 64:6

137:11

relating 105:20

relationships 64:6

137:8

relative 92:9 94:2

100:10 115:9

relatively 93:5

115:18 116:18

release 37:21

releases 38:2

relevant 28:20

29:1,22 30:4,13

31:22 96:1

106:1 107:7

126:8

relooked 114:21

rely 116:9

relying 114:12

remain 40:14

71:17 79:22

126:7

remains 81:15

82:17 96:16

remarks 4:21

44:11 102:1

remember 43:12

51:8 109:21

remembering

114:22

remind 43:5

reminder 5:8 98:1

reminders 68:2

remote 84:22 85:2

renewals 78:4
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replaced 56:14

73:15

replicated 28:10

reply 29:14 30:7

report 101:4

115:1

Reported 1:19

Reporter

143:1,3,15

reporting 1:20

48:4,10 82:7

reports 82:7

repository 35:6

36:15

represent 87:6

92:3

representing 44:3

69:1

represents 92:5

reprocessing

85:9,17

re-proposed

123:20

republished 132:4

request 14:2 39:3

require 15:9 53:4

66:6,14

73:11,12 103:21

108:21 112:8

required 26:12

31:17 39:15,17

46:10 49:21

50:18 53:13

54:11 67:13

73:8 140:17

requirement

30:17 56:22

81:17 82:8

124:16

requiremental

81:16

requirements

8:12 9:6 11:18

17:20 36:9,15

46:10 47:8

56:16 59:22

71:7,9 76:6

87:7,18 132:1

136:9

requires 9:1,8

53:5 57:10

67:18 81:3

124:3 141:3

requiring 65:14

residence 86:21

residing 87:11

resources 19:19

106:12

respect 68:11

124:7

respects 69:19

respond 17:16

21:14 84:11,12

104:8

responds 21:4

response 20:1

68:10 102:12

108:1

responses 84:10

responsibility

27:4 82:15,16

87:5,16

responsible 28:18

61:21 87:16

88:15

responsive 48:13

responsiveness

69:22

rest 123:15

restricted 15:1

restrictions 6:6

result 6:18 34:19

38:3 103:19,20

results 75:10,13

retired 65:4 122:5

retransfer 28:6

50:17 54:6

retransferred

53:12

retrospect 72:7

revenue 112:22

113:5

reverse 92:12

104:13,22

reversed 93:19

reverses 100:3

reversible 104:18

review 12:16

13:5,19 14:12

23:8 36:7 39:10

69:16,19

reviewed 9:18

reviews 12:10,18

20:14 84:3

revised 9:18

revisions 37:2

133:12

Rich 5:4 6:11

26:20

33:11,16,19

34:5,20 35:7

38:10 47:21

50:22 59:17

70:22 77:16

89:18 90:4 96:3

110:4 116:20

117:13,16

119:7,20 124:12

129:12 133:8

135:20 136:10

Richard 2:11 3:3

4:5,8,17

Richmond 118:3

Rich's 133:19

rigorous 24:20

risk 18:6,19 21:1

37:9 54:20

124:21

rivals 45:6

road 118:9

role 26:18 27:12

32:12,13,21

role-based 41:7

roll-out 76:3

Ronnlund 2:18

room 7:2,3

117:3,9

rough 36:8

roughly 27:7

31:15 91:17

114:7,17

route 63:20

routinely 90:6

Rudy 2:19

60:11,21

61:3,17

63:9,17,21

64:10,19 75:18

77:3 128:10,20

134:6,15,22

135:3,10,15

rule 5:7,10 6:21
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119:4 120:1,3

121:8 122:16

123:1,15,19,21,

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rulemaking

4:13,16 6:9 7:18

9:12,13

23:19,20 56:12

60:19 68:13

77:15 87:2

120:9

Rulemaking--in

9:14

rules 5:9 45:18

60:16 94:6

104:21,22

126:18 140:22

rules--and 61:14

run 30:8 118:5

running 73:4

118:2

Russia 44:21

51:14,17 125:20

S

S&T 85:16

SA 91:1,2

92:6,11,20,22

93:6,12,18 94:6

97:22 99:19,21

100:6,8,21

101:1,17

104:12,14,21

105:9,10,11,21

106:1

107:7,12,14

110:4,12 111:18

123:9,14 124:15

137:3,4

safe 139:6,16

safeguarded 84:5

safeguards 54:8

safeguards--

which 50:15

safest 21:11

safety 21:7 27:3,5

83:8,9,13,14,17,

21,22 95:11

140:21

sake 99:13

sales 88:18

San 8:2

sanctioned 87:10

sanctions 87:8,20

saw 137:22

say--see 110:21

scale 91:14 92:13

scenario 91:17

113:11

schedule 9:12

10:8 36:8

scheduled 6:19

45:12

schedules 72:8

Schenk 2:19

School 2:3

science 78:7,8

scientist 31:8

scope 4:13 8:20

49:20 50:15

54:8 83:1 90:17

Scott 2:20

seats 77:12

second 5:6 10:5

20:11 43:18

49:3 50:7 56:11

67:10 77:13

78:6 104:10

105:20 107:14

secondly 110:15

secretary 8:11

9:1,9 13:2

14:11,12,15,21,

22 15:8 16:5

26:12 27:17,18

53:5,9,14,19

54:12,16,17

63:15,22

80:10,16,17

81:1,2,3,5 111:7

138:22

141:11,12

section 6:5 8:4

14:19 50:13

66:5 85:17

125:16 129:21

sector 96:8

secure 35:20

40:22 42:21

secured 41:3

security 1:3 2:7

27:3 40:11 41:2

59:11,22 60:7

seeing 25:7 97:18

seek 23:5 66:2

seem 49:17 69:18

79:5 99:8

130:22

seems 48:5,6

65:18 124:16

seen 7:8 12:13

64:4,8,18 77:20

79:13

select 22:16

self-registration

40:19

selling 64:2 106:7

semi 127:4

semi-general

127:4

seminars 132:12

send 13:4,7,9

28:18,22 31:21

50:12 54:11

55:13 62:22

63:14 139:7

sending 59:10

sense 12:1 27:13

92:17,19 93:2

129:20

sensibly 33:22

sensitive 35:21

59:9,18

sensitivity 99:12

116:19

sent 13:20 52:6

sentiments 15:17

separate 23:19,21

September 9:14

series 97:4,20

99:8 131:20

serious 67:7

seriously 37:16

41:9

server 59:9

service 18:21,22
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services 116:3

121:17

session 6:4 70:1

78:1,10 129:2

sets 56:19 94:3

100:9

several 55:20 61:4

91:3

share 45:11 47:14

60:7 132:18

134:3 139:20

shared 139:19

shares 96:8

sharing 47:18

Shaw 2:16

shifting 103:11

shocking 42:16

shop 37:17

shops 104:5

106:9,15

shorten 56:4,7

shortening 56:1

showed 20:11

shown 19:3

shows 45:1 91:16

Shriver 2:14

Shruhan 2:20

shutdown 43:19

118:10

shy 58:9

Sigma 22:15

24:3,19 26:7

55:3,6 69:12,19

70:6

sign 36:9 53:9

54:18

signature 56:9

signed 50:10

significance 115:5

significant 9:19

105:22 128:4

significantly

100:1

signing 11:14 30:2

80:17

signs 30:10 82:5

similar 124:5

131:17

Similarly 95:5

simple 51:14 93:5

simply 35:8

Singapore 106:8

sir 77:3

sit 11:11 12:1

site 36:4,21 40:10

82:17 133:16

sitting 11:11 33:2

52:14 74:12,13

119:9

situation 74:4

105:6

six 22:15 24:3,19

26:7 32:3 33:19

34:17 36:17

55:3,6 67:4

69:12,19 70:6

74:13 135:21

size 122:20 123:2

skew 115:15

slice 92:5,6,10

slices 92:2,9

122:21 123:2

slide 12:13 14:16

20:11 22:17

slides 7:20 27:11

35:15

79:8,11,14

128:12

slightly 47:2 98:9

slot 68:19

slow 15:16 16:15

17:17 29:15

52:3

slower 29:18

small 37:12,13

91:15 92:9

123:2

smaller 92:12

smartly 37:10

Smith 2:21 131:18

SMN 8:17

SNM 83:3 84:22

85:6

SNOPR 7:9 9:3

10:4 21:6 45:2

65:13 79:15,17

83:11 85:13,21

86:19

89:5,8,13,22

90:1 103:19

105:6 109:7

111:1,2,6,11,19,

22 118:19,21

121:7 125:22

126:13,17

127:3,6,10

137:2,5,19

SNOPR's 89:6

so-and-so 29:11

55:14

So-and-so 30:1

Society 2:9,17

49:2,4 120:20

soft 114:14 116:10

software 24:14

31:5

solely 20:2 116:9

solicit 7:7 10:1

133:10

solution 35:9,13

41:22

somebody 31:14

32:11 46:14

53:12 62:1

129:11

somehow 20:20

25:15 58:13

109:8

someone 78:11

135:11

someplace 50:6

Something's

64:19

somewhat 79:5

93:2

sorry 40:8 85:1

117:6 133:6

136:7

sort 6:6 7:21 19:7

53:21 58:5

62:5,21 71:19

74:7 76:3,15

79:3 85:10

88:21 95:14

108:22 127:4

130:7 133:11

137:16 138:5,12

sorts 72:9 126:11

sought 15:22

sounded 117:20
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sources 103:4

113:1

sourcing 88:19

South 44:20

Soviet 140:21

space 37:5,6

span 96:2,12

spared 27:10

speak 117:13,15

124:22

speaking 117:16

special 8:9 15:3

specific 9:7 45:15

51:7,8,22 56:1

65:14,15

66:6,14,22 88:7

94:7,9

103:12,14,21

106:22 108:21

112:18,20

122:1,12,13

124:3 125:12

127:5 132:19,20

133:4 139:18

140:15

specifically 28:1

34:9,12 38:4

53:3 102:4

110:2 113:2

specifics 60:4

66:11 135:12

spectrum 116:2

138:5,7,12

speed 33:20

129:17

spend 12:8 59:8

89:5

spending

115:12,13

141:21

splash 37:8

spoke 35:7 117:14

spread 18:2

spring 70:9

springtime 70:10

staff 2:7 56:20

79:9,10 91:7

132:2

134:17,19,20

135:2

staff--which 12:18

stage 12:16

13:16,18,19

20:11 26:10

39:3 129:10

stages 12:15 13:18

stagnant

71:9,10,11,19

stakeholder

133:17 135:22

stakeholders

34:11,13 35:4

37:20 121:3

stamp 38:20

stand 35:2 119:12

120:13 129:14

standard 40:6

83:20 134:10

standardization

36:14

standardized

84:21

standards 82:6,8

83:15,17

standing 33:1

standpoint 11:4

19:17 67:22

124:14 139:8

Starbucks 25:6,8

77:9

start 44:15 70:6

76:15,19 77:13

81:8 112:14

135:9 136:17

started 9:12 75:1

77:11

78:6,16,17

95:22 96:13

115:14

starting 92:12,17

95:13 113:4

115:19

state 3:3 4:6 7:13

8:15 13:20 14:2

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strictly 116:6

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studies 75:6

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summer 78:4

summer-long 78:8

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technology 2:19

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total 30:5

totally 42:13

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track 20:22 21:18

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transaction

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Translated 66:8

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turned 33:6 139:8

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tying 83:14

Tynan 3:4

type 27:8 39:22

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vintage 115:3

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virtually 27:1
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visible 35:1

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