Monday, November 27, 2017

Recent Status of PRM-50-93 and PRM-50-95

Subject: Status of PRM-50-93 and PRM-50-95
Date: 11/22/2017 12:17:19 PM Mountain Standard Time

Mr. Leyse,

I am writing to provide an update on your letters dated November 17, 2009, and June 7, 2010, in which you submitted petitions to the U.S. Nuclear Regulatory Commission (NRC).  In your letter dated November 17, 2009, you requested that the NRC amend the regulations in Title 10 of the Code of Federal Regulations(10 CFR) Part 50 and Appendix K to Part 50 to require that the rates of energy release, hydrogen generation, and cladding oxidation from the metal-water reaction considered in emergency core cooling system evaluation calculations be based on data from multi-rod (assembly) severe fuel damage experiments.  In addition, you requested that the NRC create a new regulation to establish a minimum allowable core reflood rate in the event of a loss-of-coolant accident (LOCA).  In your letter dated June 7, 2010, you requested that the NRC order Vermont Yankee Nuclear Power Station (Vermont Yankee) to lower the licensing basis peak cladding temperature to 1,832 degrees F in order to provide a necessary margin of safety in the event of a LOCA.

The NRC docketed your November 17, 2009, letter as petition for rulemaking (PRM) 50-93.  A notice of receipt and request for public comment on PRM-50-93 was published in the Federal Register on January 25, 2010 (75 FR 3876).  Your letter dated June 7, 2010, was submitted as a petition for enforcement action under 10 CFR 2.206.  On August 6, 2010, the NRC denied your § 2.206 petition because it did not demonstrate that Vermont Yankee was in violation of any NRC regulations.  Because your § 2.206 petition asserted that there were generic inadequacies in NRC regulations, the NRC decided to review it under 10 CFR 2.802 as a petition for rulemaking and docketed it as PRM-50-95.  Because PRM-50-93 and PRM-50-95 address similar issues, the NRC consolidated these two petitions for review as a single petition for rulemaking activity.  AnotherFederal Register notice was published on October 27, 2010 (75 FR 66007), and the comment period was reopened.  The public comment period ended on November 26, 2010.  Thirty-three public comments have been received to date on the combined petitions.  These comments have been posted at (ID:  NRC-2009-0554).

The NRC staff is considering the merits of your PRM and the public comments received.  As described in the NRC’s letter to you dated August 25, 2011, the NRC has decided to increase the visibility to the public of the NRC’s review of these particular petitions.  The NRC will publicly release its draft interim reviews regarding each group or category of issues on a periodic basis as the review progresses.  These draft interim reviews will be posted on  So far, the NRC has publicly released four draft interim reviews:

The NRC staff will consider and respond to the comments you made regarding PRM-50-93 and PRM-50-95 at the Commission briefing on public participation in NRC regulatory decision-making on January 31, 2013, in the review of these petitions.

The NRC is considering the remaining issues and will notify you as the draft interim reviews are completed.  Once the petitions have been resolved, a notice will be published in the Federal Register explaining the Commission’s finding.  You will also receive a letter at that time notifying you of the action that the Commission has taken.

Please feel free to contact me at or 301-415-3748 if you have questions.


Dan Doyle

Project Manager
U.S. Nuclear Regulatory Commission
(301) 415-3748

Friday, November 24, 2017

FOIA at NSF - More tyranny at NSF

NSF routinely does not meet the 20 day statutory rule in responding to FOIA requests.  This current email exchange proves that.  Here is the key admission by NSF " As for the estimated response date, that date is automatically generated (20 days after your request is received and perfected) based on the statutory time limits of the FOIA.  However, we can rarely make that deadline because of the voluminous nature of most of our requests."

Sent: 11/22/2017 10:05:12 AM Mountain Standard Time
Subject: Fwd: RE: NSF FOIA Request: 2017-285F

Senator Risch,

The forwarded note discloses that NSF is routinely not meeting the requirement for a 20 day response time to a request under FOIA.  Nevertheless, NSF has plenty of resources to add ways of sending money to universities as is detailed in my most recent email to you. 

It is well past the the time that NSF needs to be shaken up.

Robert H. Leyse

Sent: 10/24/2017 10:50:25 AM Mountain Standard Time
Subject: RE: NSF FOIA Request: 2017-285F

Good afternoon Mr. Leyse

The National Science Foundation has "multitrack processing" of their FOIA requests -- which allows us to process requests on a first-in, first-out basis within each track, and also permits us to respond to relatively simple requests more quickly than requests involving complex and/or voluminous records.  As for the estimated response date, that date is automatically generated (20 days after your request is received and perfected) based on the statutory time limits of the FOIA.  However, we can rarely make that deadline because of the voluminous nature of most of our requests.  Technically, there are over 200 requests that should be processed before 2017-285F and our office move at the beginning of the month did no help either.  However, we hope to have a response to you early in November.


Justin Guz

Justin Guz
Government Information Specialist
Office of the General Counsel
National Science Foundation
2415 Eisenhower Avenue
Alexandria, Virginia  22314
Telephone:  703-292-2289

From: []
Sent: Tuesday, October 24, 2017 12:30 PM
To: Guz, Justin Joseph <>
Subject: Re: NSF FOIA Request: 2017-285F

Mr. Guz,

So far I have received nothing.

Robert H. Leyse

In a message dated 9/25/2017 4:28:35 PM Mountain Standard Time, writes:

The estimated response date to your request is October 20, 2017.

Wednesday, November 22, 2017

Tyranny at the National Science Foundation

Subject:                NSF discourages the real American Innovators

Date:     11/19/2017 1:23:56 PM Mountain Standard Time



Senator Risch, 

It is time for funding of our National Science Foundation (NSF) to be substantially reduced.  This past Saturday NSF issued the following spectacular announcement:

Innovation Corps - National Innovation Network Teams Program (I-CorpsTM Teams)

However, it is less spectacular hundreds of words later:

Who May Submit Proposals:

Proposals may only be submitted by the following:

·         Universities and Colleges - Universities and two- and four-year colleges (including community colleges) accredited in, and having a campus located in, the US acting on behalf of their faculty members. Such organizations also are referred to as academic institutions.

Briefly Senator, I know a lot about the NSF.  For example, I took my discoveries to UCLA and we jointly submitted a proposal to NSF.  It was rejected.  So, without my awareness, UCLA submitted an essentially identical proposal on its own  and it was accepted.  I then submitted my proposal and it was vehemently rejected.  The academicians resent significant discoveries that originated outside of their turf.  Following is one of the three reviews that is far more vindictive than objective; as well as being loaded with errors.  Furthermore, NSF will not disclose the identity of that reviewer and that is tyranny.

·         Proposal Number:

Proposal Title:

Proprietary Transformative Separations
Received by NSF:

Principal Investigator:

Robert Leyse

Review #3

Proposal Number:

NSF Program:

Principal Investigator:

Leyse, Robert H
Proposal Title:

Proprietary Transformative Separations


What is the intellectual merit of the proposed activity?

The most compelling portion of this proposal is that the PI has identified an anomalous boiling heat transfer regime from microscale wire surfaces. Unfortunately, the PI has not presented a convincing research plan that will lead to a fundamental understanding of the heat transfer process he has identified. Countless anomalous regimes have been identified in boiling heat transfer. While the PI believes that his discoveries are transformative, this Reviewer fails to see it. Truly transformative research will seek to explain the physical mechanisms driving the anomalous observations, and provide technologists with the understanding that may lead to technological advances. However, the PI fails to mention any of the various physical boiling phenomena at different length and time scale which may influence the process. For example, the PI claims his measurements are steady state. This completely ignores the time scales associated with ebullition. The PI claims the dispersive mechanism is turbulence without any evidence. It can just as easily be hypothesized that the dispersive mechanism is microbubble growth and collapse that has been observed in highly subcooled systems. It is unfortunate that the PI has expended so much effort to convince NSF to fund his proposed research. If the PI is convinced that his discoveries are transformative and can lead to revolutionary new technology, he should focus his efforts on developing that technology. For whatever it is worth, this Reviewer believes that the heat transfer behavior observed is confined to microscale wires, and attempts at scale-up would not be fruitful.

What are the broader impacts of the proposed activity?

It is difficult to identify broader impact associated with the proposal.

Summary Statement

Past Reviewers have been too gentle in pointing out the weaknesses of the proposed study. The PI should not be encouraged to resubmit a proposal covering the core topic.

Senator, this past Saturday’s Wall Street Journal has a significant discussion on page A11, Trump vs. the Deep Regulatory State.  It is time for an equivalent discussion of how the NSF has become dominated by assorted forces to the disadvantage of the real American innovators.

Robert H. Leyse

Friday, October 27, 2017

Remember, the vultures are circling

Yes, circling.  And, one has landed.  More will.

Wednesday, July 19, 2017

Thursday, July 13, 2017

Transformative Research

Here is an interesting link:

Transformative Research: Reflections on a NSF Workshop

April 6th, 2012 / in policy, research horizons, workshop reports / by Erwin Gianchandani
Michael E. Gorman, University of VirginiaThe following is a special contribution to this blog by Michael E. Gorman, a Professor in the department of science, technology, and society (STS) at the University of Virginia. Mike recently completed a rotation as a program director at the National Science Foundation, and co-funded a workshop on transformative research that took place in Washington, DC, last month.
During my two-year stint as a rotator at NSF, I looked for places where I could add value. There was a lot of discussion about transformative research and even some special funds that could be used for projects deemed transformative. In September 2007, the National Science Board (NSB) “unanimously approved a motion to enhance support of transformative research at the NSF.” The Board noted:
“The term ‘transformative research’ is being used to describe a range of endeavors which promise extraordinary outcomes, such as: revolutionizing entire disciplines; creating entirely new fields; or disrupting accepted theories and perspectives — in other words, those endeavors which have the potential to change the way we address challenges in science, engineering, and innovation. Supporting more transformative research is of critical importance in the fast-paced, science and technology-intensive world of the 21st Century.”
And it recommended the following addition to the NSF’s merit review criteria: “To what extent does the proposed activity suggest and explore creative, original, or potentially transformative concepts?”
In a January 4, 2007, talk, Transformative Research: The Artistry and Alchemy of the 21st Century, then-Director of NSF Ardent Bement, Jr., emphasized the way in which NSF works on the frontier where transformations are most likely to occur, but also recognized that we will:
“continue to quibble among ourselves about the meaning of ‘transformative research’, which as yet has no universally accepted definition. That is just as it should be. When concepts as complex as ‘transformative research’ are still emerging, we need to practice a kind of ‘constructive ambiguity’. Doing so will give us the flexibility to incorporate new knowledge and fresh perspectives as they arise; in other words, leave room for discovery. In that way, we can make course corrections along the way, adapt to changing circumstances, and remain open to diverse suggestions about the issues.”
I am a social psychologist of science and engineering who worked in NSF’s Science Technology & Society (STS) program and with the Science of Science and Information Policy (SciSIP) program. I knew these programs had expertise that could be brought to bear on this problem, so I catalyzed a workshop organized by Robert Frodeman and Britt Holbrook of the University of North Texas, co-funded by STS and SciSIP. [Many thanks to Julia Lane of NSF’s SciSIP program for her help vetting the proposal and co-funding the workshop (NSF award #SES-1129067). Any opinions, conclusions, and recommendations expressed here are mine, and do not necessarily reflect the views of NSF or any of its employees.]
Workshop participants included 25 invited practitioners and scholars from a wide range of disciplines: engineers, historians, philosophers, and science policy. Former and current NSF officials and representatives of other government agencies attended parts of the workshop.
The discussion was wide-ranging and deep; no simple summary will do it justice, nor was there a consensus. Alternative courses of actions included:
  • Convince the NSF drop the transformative criterion. As a basic science agency, the best way for the NSF to ensure transformations is to fund what Kuhn called normal science, and wait for anomalies to appear. Then perhaps the NSF could target research towards anomaly resolution, which might lead to the kind of revolution Kuhn talked about, creating a new paradigm.
  • Liberate the NSF from worrying too much about the definition of transformative. Keep it flexible and a bit vague while making the benefits of transformative research clear. The NSF could provide exemplars of previously funded work that turned out to be transformative.
The context of use should be included in transformation — a discovery can be transformative in terms of science but not use, and a discovery that is not transformative scientifically can be a catalyst for transformative innovations. Perhaps it would be better to substitute innovation for transformation.
Transformation occurs across an ecosystem — or parts of an ecosystem that many have broader or lesser impacts on other parts over time. Transformative research is part of a reframing of the scientific ecosystem, including research practices, research frontiers and potential applications.
Peer review may hinder transformation, because peers tend to reflect the existing paradigm. One indicator of a potentially transformative project may be a bi-modal distribution in peer reviews, where some see the transformative potential in the work and others regard it with horror — not on grounds of expertise, but because the new idea is incommensurable with existing thinking and practice.
One  alternative to peer review is a sandpit process which was used by the NSF and the U.K.’s Engineering and Physical Sciences Research Council (EPSRC) to catalyze and fund transformative ideas in synthetic biology. Participants from multiple disciplines evolved ideas for transformative research over several days. Program officers picked several ideas from among those that emerged and invited proposals on them, with the understanding that the proposals were likely to be funded.
In the peer process, reviewers that typically come from the same research community are critically reading and evaluating proposals. In the sandpit, researchers from multiple communities share ideas and look for possible collaborators — and are told that transformative ideas are a priority.  The sandpit process looks like a better bet for producing potentially transformative work.
The fact that the sandpit is deliberately interdisciplinary is one factor that increases its transformative potential. Combining two or more disciplinary communities on a new project is likely to produce a result that will appear transformative from the standpoint of any of the disciplines of origin. The further apart the disciplines, the more likely a sandpit discussion will produce work that is potentially transformative. Consider, for example, combining participants from social sciences, ethics, environmental science, computer science and civil engineering to develop new ideas on sustainability.
Interdisciplinary review panels are often formed at the NSF, but a proposal then has to satisfy all of the disciplinary reviewers — work that builds off all of the disciplines in the panel but transcends them — may fare worse. It would be good to do empirical work comparing sandpits and review panels and varying whether each was done within a single research community or across several. Which approach would be most likely to lead to transformative work?
The kinds of centers created by the NSF and other organizations could be catalysts for transformative research, especially if the right administrative infrastructure were put in place, one that encourages and supports radically interdisciplinary collaboration based on a solid foundation of disciplinary expertise. Again, empirical work could be done on the right sorts of structures.
The NSF has an important education mission as well, both in schools and universities and in informal settings like museums and social media. Given the emphasis on evaluation by disciplinary standards, it is harder to promote transformative thinking in formal education than informal. But there are lots of interesting options within formal education, e.g., interdisciplinary capstone projects and curricula.
The kinds of new scientific and engineering instruments placed in such centers and in national labs can also lead to transformative work by making it possible to explore and manipulate new aspects of the universe. Information technology has enabled many of these instruments and allowed them to be connected globally. IT has also enabled collaborations that have a global reach, and even virtual centers. Computer scientists not only do transformative research, but they also enable it in multiple fields of endeavor.

Thursday, July 6, 2017