ML21167A213

From kanterella
Jump to navigation Jump to search
IMC 2602 Public Meeting Transcript from June 9, 2021 Meeting Titled - Modernization of the Fuel Cycle and Materials Decommissioning Inspection Program
ML21167A213
Person / Time
Issue date: 06/09/2021
From:
Office of Nuclear Material Safety and Safeguards
To:
Maurice Heath, 301-415-3137
References
NRC-1524
Download: ML21167A213 (51)


Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Modernizing the NRC Fuel Cycle and Materials Decommissioning Inspection Program Docket Number:

(n/a)

Location:

teleconference Date:

Wednesday, June 9, 2021 Work Order No.:

NRC-1524 Pages 1-50 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 UNITED STATES OF AMERICA 1

NUCLEAR REGULATORY COMMISSION 2

+ + + + +

3 MODERNIZING THE NRC FUEL CYCLE AND MATERIALS 4

DECOMMISSIONING INSPECTION PROGRAM 5

+ + + + +

6 PUBLIC MEETING 7

+ + + + +

8 WEDNESDAY, 9

JUNE 9, 2021 10

+ + + + +

11 The Public Meeting convened via Video 12 Teleconference, at 1:00 p.m.

EDT, Rob
Evans, 13 Moderator, presiding.

14 15 NRC STAFF PRESENT:

16 ROB EVANS, Region IV 17 JENNI DALZELL, Region III 18 MAURICE HEATH, NMSS 19 TRISH HOLAHAN, NMSS 20 MARY MUESSLE, Region IV 21 MARTI POSTON-BROWN, NMSS 22 23 COMMENTERS PRESENT:

24 NIMA ASHKEBOUSSI, Nuclear Energy Institute 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

2 LARRY CAMPER, Talisman International 1

SCOTT MURRAY, GE Hitachi 2

KATIE SWEENEY, National Mining Association 3

4 5

6 7

8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

3 TABLE OF CONTENTS 1

2 Page 3

Introduction 4

4 NRC Staff Presentation 6

5 Public Feedback and Q&A Session......... 30 6

Closing Remarks................. 48 7

8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

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

1:04 p.m.

2 MR. HEATH: Good afternoon, everyone, and 3

thank you for joining us. Today's public meeting will 4

discuss NRC's efforts to modernize the Fuel Cycle and 5

Materials Decommissioning Inspection Program.

6 My name is Maurice Heath. And I am an 7

engineer and project manager at the NRC Division of 8

Decommissioning, Uranium Recovery and Waste Programs.

9 I am going to quickly cover the logistics 10 for this meeting today. And as our operator, 11 Michelle, noted, everyone is in listening mode until 12 we get to the public comment portion of today's 13 meeting, which will occur after NRC's presentation.

14 If you are on the Webex, great. You 15 should be seeing our slides on your screen. If you 16 are not on the Webex and still would like to access 17 our slides or if you want to download a copy for your 18 use, you can find a link to them on the NRC public 19 meeting notice for today's meeting.

20 Today's meeting is an NRC information 21 public meeting, which means the staff will make a 22 brief presentation about modernizing the Fuel Cycle 23 and Materials Decommissioning Inspection Program and 24 then open the line to comments or feedback on this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

5 topic.

1 At the end of the presentation, if you 2

want to make a verbal comment, Michelle, the bridge 3

line operator, will give instructions on how to place 4

your call in the comment queue.

5 We would ask that anyone making comments 6

attempt to limit their statements to three minutes.

7 We will provide an opportunity for a second round of 8

comments as time allows. But we want to make sure 9

that everyone has the opportunity to speak.

10 In order to successfully capture verbal 11 comments, this meeting is being recorded so that the 12 statements made today can be transcribed. So please 13 make sure you clearly state your name and if you wish, 14 company or affiliation before starting your comment.

15 You can also provide written comments at 16 any time through the Webex interface using the Q&A 17 dialogue box or the chat function window.

18 The speaking bubble icon is at the bottom 19 of your Webex screen. Simply type in your comment to 20 either window, which you should be able to locate in 21 the menu at the bottom of your screen. In there, the 22 NRC staff are capturing the comments and questions.

23 Should there be any technical issues with 24 Webex, the bridge line will not be affected and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

6 meeting slides are available as an attachment to the 1

meeting notice on NRC's public meeting website. So we 2

should be able to continue the meeting in a new format 3

as needed. Hopefully, we will not need to go this 4

route but just in case, we are prepared.

5 Also a reminder to members of the NRC 6

staff that we are on an open line as speakers. So 7

please be mindful of the mute and unmute function on 8

your phone as neither I nor the operator have control 9

over the portion of the bridge line.

10 Finally, I would ask that we all be 11 patient and a little flexible given the virtual nature 12 of today's meeting. Please forgive any delays in 13 changing the slides or pauses between speakers as the 14 NRC staff is trying to confer from several individual 15 locations. Also forgive any dogs barking, babies 16 crying or house phones ringing as this is part of our 17 new normal.

18 Thank you. And I would like to turn the 19 presentation over to Mr. Rob Evans, who is the team 20 lead for the Fuel Cycle and Materials Decommissioning 21 Inspection Working Group. Rob?

22 MR. EVANS: Thank you, Maurice. My name 23 is Rob Evans. I am a senior health physicist in the 24 NRC's Region IV office and an inspector.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

7 What I'd like to do is introduce the 1

presentation meeting presenters. Then I will request 2

opening remarks from Mary Muessle. I will provide 3

some background information about the working group.

4 And then we will shift into a discussion of the plan 5

changes to the inspection procedures themselves 6

followed by the current schedule for implementation of 7

the new procedure program. And then after we're done, 8

as Maurice indicated, with the formal presentation, 9

the NRC staff will accept questions and comments from 10 the public and industry.

11 Next slide. I wanted to -- just in a 12 moment I'll introduce Mary. But opening remarks will 13 be provided by Mary Muessle, the director, Division of 14 Nuclear Materials Safety in the Region IV office.

15 There will be three presenters, technical 16 information presenters, during this particular 17 meeting, myself, who is the chair of the working 18 group, Jenni Dalzell, an inspector in the Region III 19 office and Marti Poston, a health physicist in the 20 Office of Nuclear Material Safety and Safeguards.

21 And the facilitators, the NRC facilitators 22 for today's meeting, include Maurice, the program 23 manager who has introduced himself already and Kellee 24 Jamerson, a physical scientist, both with the Office 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

8 of Nuclear Material Safety and Safeguards.

1 Next slide. I am so sorry. I need to 2

introduce Mary, Mary Muessle, who will provide a few 3

openings remarks.

4 MS. MUESSLE: Okay. So thanks, Rob, 5

thanks, Maurice, and thanks, Michelle, for getting us 6

started. Can everybody hear me okay? Could I get a 7

signal there that I have successfully unmuted? Okay.

8 Thank you very much.

9 Before I even introduce myself, I do want 10 to not just thank the openers to the meeting, but to 11 the working group who you're going to hear from today.

12 They have really started a good ball rolling in 13 looking at this project and not just in looking at the 14 procedures themselves but how we can engage you all 15 more as people interested stakeholders and how we can 16 look at advancing NRC's aspirations, I would say, to 17 do more with technology and to be more clear in how we 18 use risk in our oversight function.

19 So my name is Mary Muessle. I am the 20 director of Nuclear Materials Safety in Region IV.

21 For those of you that are not familiar with our 22 region, Region IV provides oversight functions and 23 some licensing functions for sites and licensees, 24 really to the west of the Mississippi.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

9 So that is my current role. But today I 1

am here as a representative of the National Materials 2

Program. And I am here as a sponsor for the working 3

group that's looking to modernize the fuel facility 4

and materials decommissioning guidance.

5 I am one of three executive sponsors in 6

that. Dr. Trish Holahan from our Office of Nuclear 7

Materials Safety and Safeguards is also a sponsor as 8

is Bill Irwin from the State of Vermont.

9 So the three of us are helping NMSS. That 10 office will be issuing the final guidance. But we are 11 here helping the working group as they look to do the 12 revision.

13 The NRC does strive to be a modern risk 14 informed reliable regulator and openness and 15 consistency in our guidance is integral to that.

16 We have an important mission in having 17 reasonable assurance of adequate protection in public 18 health and safety and in protecting the environment.

19 It's critical that we get this right and get the best 20 information out there.

21 And a large part of that is openness in 22 finding different views, understanding perspectives 23 and understanding the current environment. So we put 24 together a great diverse working group of NRC staff 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

10 members as well as Agreement State staff. And they 1

are looking at the guidance primarily in Inspection 2

Manual Chapter 2602, which has not been updated since 3

2008.

4 And while we do have this robust materials 5

program in fuel cycle decommissioning, we believe that 6

putting this group together will bring a clearer 7

perspective, will help bring more definition to things 8

and to use risk in the most appropriate way.

9 I mentioned that we have Agreement States 10 involved in this. They are our co-regulators in these 11 programs. And the perspectives that the Agreement 12 States bring are extremely important, and we value 13 their participation in the working group and in all 14 the forms that you may bring forward ideas in the 15 future.

16 We are also interested in other state 17 feedback. If you're not an Agreement State, from 18 tribes, from industry, from interest groups for 19 members of the public. And I think the working group 20 has done a good job of trying to figure out how to 21 creatively inform and engage you, including this 22 public meeting that we're having today.

23 So I look forward to the meeting. And I 24 will ask if Dr. Trish Holahan has anything she would 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

11 like to add before we get started?

1 DR. HOLAHAN: Thank you, Mary. Can you 2

all hear me now? I'm Trish Holahan. I'm the director 3

of the Division of Decommissioning, Uranium Recovery 4

and Waste Programs in the Office of Nuclear Material 5

Safety and Safeguards.

6 And I just want to reiterate everything 7

Mary said and thank the working group so much, both 8

the Agreement States and the NRC staff who has worked 9

hard to -- well, they're going to risk inform the 10 manual chapter and all the inspection procedures 11 accordingly for decommissioning material sites as well 12 as fuel cycle and uranium recovery sites.

13 And so with that, I'll turn it back over 14 to Rob and let him carry on.

15 MR. EVANS: Thank you, Trish. Thank you.

16 Next slide. Earlier this year, the NRC collectively 17 decided to form a working group that consists of joint 18 NRC and Agreement State staff to update Manual Chapter 19 2602, Decommissioning Oversight and Inspection Program 20 for Fuel Cycle Facilities and Materials Licensees.

21 The goal of the working group was to 22 update the inspection program to be more risk-23 informed, performance-based. And just kind of as an 24 aside for a moment, the program in the past leaned a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

12 little towards what's called a compliance-based 1

inspection, which was a verification of the procedures 2

and programs and implementation of the programs.

3 As we go into the future, we're more 4

interested in connecting risk-informed, performance-5 based inspections, which is an approach that considers 6

risk insights, analysis and judgment and performance 7

history to focus attention on the most important 8

activities and focus results over a cross-tested 9

method.

10 Next slide.

So this particular 11 implementing procedure, Inspection Manual Chapter 12 2602, will apply to 10 CFR Parts 30, 40 and 70 13 licensed sites, which, of course, includes source 14 material licenses, special nuclear material licenses 15 and fuel cycle facility licenses.

16 It will include uranium recovery 17 decommissioning, which is currently addressed in two 18 different manual chapters. For those of you who are 19 in the uranium recovery industry, you may recall that 20 2801 applies to conventional mills and 2641 applies to 21 in situ recovery sites. So what we plan to do is to 22 take the decommissioning portions out of those two 23 manual chapters and put them into 2602 as part of the 24 fuel cycle program.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

13 This particular Manual Chapter 2602 does 1

not include reactor decommissioning and that includes 2

power and non-power decommissioning or basically the 3

Part 50 licenses. It does not include independent 4

spent fuel storage installations, a/k/a ISFSIs. And 5

it does not include licensees basically that are not 6

in decommissioning. So an operating material skill 7

cycle in the uranium recovery sites will not be 8

captured under this inspection program.

9 So next slide, please. So the objectives 10 of the working group is to develop, as I mentioned, a 11 risk-informed, performance-based decommissioning 12 inspection program.

13 So what we decided to do is rather than 14 take the existing procedure and do word changes on it, 15 we decided to basically revise the program from the 16 ground up. So we redesigned a Fuel Cycle and 17 Materials Decommissioning Inspection Program in some 18 ways just by starting with an outline of what we 19 wanted in that program and then we created a procedure 20 off of that outline. So it's kind of a ground-up 21 rebuild of the inspection program.

22 We didn't want problems from the past for, 23 like, compliance-based inspections to carry over into 24 the future.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

14 So in addition to this, the second bullet 1

is we're going to be developing standalone inspection 2

procedures for the Uranium Recovery Decommissioning 3

Program.

4 And finally the third bullet is at some 5

future date we will develop a training program and 6

provide training and support for rollout of the 7

revised inspection program.

8 And I should point out that a charter for 9

the working group was issued in March 2021. And it's 10 listed on the reference slide at the very end of the 11 presentation if you have an interest in taking a look 12 at the working group charter.

13 Oh, next slide, please. The working group 14 itself consists of eight subject matter experts from 15 the NRC's headquarters' office.

We have a

16 representative from each of the four regional offices.

17 And we have a representative from the Agreement 18 States.

19 In addition, there's a steering committee 20 that provides management level oversight to the 21 working group, which includes Trish and Mary, who 22 introduced themselves a few moments ago but as well as 23 Bill Von Till. Not listed is Steven Koenick and Bill 24 Irwin, State of Vermont.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

15 And the last bullet, a guiding coalition, 1

as it's called, of supervisory level staff provides 2

guidance, support and change management to the working 3

group. And we have monthly meetings.

4 So if the working group has a problem or 5

an obstacle, for example, it's presented to the 6

guiding coalition for discussion. We get their 7

information, their feedback, their suggestions and 8

then we will change course accordingly.

9 An example of where the guiding coalition 10 comes in handy is we were struggling with terminology.

11 We have to keep terminology straight across the 12 various NRC programs. And so we got into a situation 13 where we were concerned about terminology, for 14

example, the difference between complex 15 decommissioning and non-complex decommissioning. So 16 we brought that to the guiding coalition for 17 discussion.

18 Next slide, please, so the plan changes to 19 the Manual Chapter 2602. We're identifying the risks 20 by program area, uranium recovery, fuel cycle, complex 21 and non-complex material sites.

22 I should point out that each of these 23 program areas have different risks. We plan to 24 describe the process for conducting risk-informed, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

16 performance-based inspections, and it will include 1

requirements for the inspectors as well as guidance 2

for the inspectors.

3 And the last bullet is the program will be 4

written as such to allow the inspector to use a risk-5 informed process to make decisions for each inspection 6

based on actual site conditions.

7 Every site will be different. So 8

therefore how you approach the inspection will be 9

different. And one of the ways we plan to do this is 10 by using a concept called Be riskSMART, the Be 11 riskSMART process.

12 So what I'd like to do now is turn it over 13 to Jenni, if you can introduce yourself and then 14 continue the discussion on risk. Thank you.

15 MS. DALZELL: Thank you, Rob. As he said, 16 my name is Jenni Dalzell. I am an inspector out of 17 the NRC Region III office in Lisle, Illinois.

18 As previously mentioned, the working group 19 is revising the inspection guidance to include more 20 risk insights into both the Fuel Cycle and Materials 21 Decommissioning Programs.

22 The Be riskSMART framework is a tool that 23 allows the NRC to consider risk insights together with 24 other factors in the decision-making process.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

17 The working group will be including the 1

concept from the Be riskSMART framework in the 2

revisions to the Inspection Manual Chapter 2602 along 3

with the associated inspection procedures.

4 Next slide, please. Using the Be 5

riskSMART concept, the working group will address the 6

radiological risk. The radiological risk of a 7

specific decommissioning facility will greatly depend 8

on what radioactive materials are present, in what 9

forms, and in what quantities are they being used and 10 stored at a facility?

11 Each of these factors will have to be 12 considered when planning inspections, using the 13 revised guidance. And there will need to be maybe 14 adjustments made to the inspection plan to address 15 those risks.

16 Next

slide, please.

To help the 17 inspectors, the working group is planning to include 18 risk modules in the Inspection Manual chapter along 19 with the core inspection procedures.

20 This will be to help the inspectors 21 address the risks associated with decommissioning 22 inspection activities. These risk modules will be 23 used to help inspectors determine what elements are 24 most important to cover during an inspection.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

18 There's another working

group, the 1

Inspection Manual Chapter 2800 group, which is the 2

Materials Inspection Program, that is also in the 3

process of risk informing their inspection guidance as 4

well, and they will be using risk modules in their 5

guidance.

6 Next slide, please. The working group is 7

proposing seven risk modules for the Fuel Cycle and 8

Materials Decommissioning Inspection program.

9 These risk modules were chosen to ensure 10 the most important aspects of a licensee's program are 11 covered by the inspection program.

12 The seven proposed risk modules are 13 security and control of licensed materials, 14 observation of decommissioning activities, 15 occupational radiation protection, waste generation, 16 storage and transportation, public dose, effluent 17 releases and environmental monitoring, management 18 organization and controls and finally final status and 19 confirmatory surveys.

20 The inspectors will use the Be riskSMART 21 framework to determine which of these risk modules 22 will need to be completed during an inspection and 23 also taking into consideration the status of the 24 facility and the work that is being conducted.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

19 Up next, we have Marti Poston-Brown, who 1

will be discussing the inspection procedures.

2 MS. MUESSLE: You're on mute, Marti.

3 MS. POSTON-BROWN: Thanks, Jennifer. I'm 4

sorry. Good afternoon. I apologize for not 5

remembering to turn my mute off.

6 I'm Marti Poston. I'm currently a staff 7

health physicist with the Uranium Recovery and 8

Materials Decommissioning Branch. I joined them in 9

August. Before that I was a uranium recovery and 10 decommissioning inspector out of Region IV in Texas.

11 So how are we going to focus on risk?

12 Well, as you've heard previously, we are going to 13 revise Inspection Manual Chapter 2600 to include 14 requirements and guidance that we feel should be 15 considered during decommissioning of facilities that 16 fall under the four disciplines, fuel cycle, uranium 17 recovery, complex materials and non-complex materials.

18

Remember, as Rob
said, reactor 19 decommissioning in ISFSI facilities are not going to 20 be covered under this manual chapter.

21 Requirements and guidance will be defined, 22 referenced or summarized in the manual chapter to 23 direct the inspector for additional information.

24 The document will also include some 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

20 requirements and guidance -- well, the document will 1

include, excuse me, some requirements and guidance 2

that are not applicable to all the modalities. We're 3

going to address this by having attachments to the 4

manual chapter for each modality that specifies which 5

documents and guidance information is applicable to 6

that modality.

7 We're also going to include information 8

associated with core and discretionary procedures for 9

each modality.

10 Next slide, please. The core procedures 11 will be developed for five modalities as you can see 12 here, uranium recovery, fuel cycle facilities, complex 13 material sites, non-complex material sites and final 14 status and confirmatory surveys.

15 The core IPs are going to have the minimum 16 inspection requirements that are necessary to meet the 17 objective of that IP and the risk modules, as Jennifer 18 and Rob have both indicated, will be applied for each 19 particular program area.

20 The design is to focus the inspector's 21 attention on the most risk significant issues 22 associated with that modality so that the inspector is 23 putting the emphasis on the right syllable, if you'll 24 excuse the expression, and we believe that the core IP 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

21 should be reviewed at each inspection.

1 Next

slide, please.

The guidance 2

requirement for risk modules will also be applicable 3

to discretionary procedures. And those will also be 4

addressed within IMC 2602.

5 These procedures are not required to be 6

reviewed at every inspection. Rather the inspector 7

bases the use of the discretionary IPs on site 8

activities and conditions at the sites.

9 I'd like to point out, I mean, that there 10 are some things listed here that should be, like, 11 don't they want to look at radiation protection every 12 year, or excuse me, every inspection? Yes.

13 But the reason we put some of these like 14 radiation inspection in discretionary IPs is because 15 it's not going to be an inspection procedure that is 16 specific to decommissioning. It's a more generic IP 17 that goes across multiple programs so that if we're in 18 a situation where you're doing an inspection at a site 19 that part of it is operational and part of it is under 20 decommissioning, you can still use the radiation 21 protection procedure to look at both of those 22 programs.

23 Use of the more generic IPs helps the 24 inspector use discretion -- sorry. I just said that.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

22 I apologize.

1 Next slide. One of the things that we're 2

also proposing is an inspection frequency be added to 3

2602. In the previous versions of 2602, the 4

inspection frequency was not specified. It was pretty 5

much left up to a negotiation between the project 6

manager and the regional inspection staff as to how 7

frequently a site would be inspected.

8 That was based on the fact that there are 9

situations where there is nothing going on at the site 10 because the site has got a decommissioning plan that 11 they're waiting for the NRC to approve or they're in 12 the process of preparing their decommissioning plan.

13 So they're basically on stand by and there's no 14 activities to be inspected.

15 So we decided to address that by 16 establishing a minimum frequency of plus or minus 17 three months. But, as I've said, there are situations 18 where there's no need to inspect because there's not 19 anything going on. So we're allowing the regional 20 staff with the concurrence of the project manager to 21 document the reason for not performing inspections to 22 the docket file so that 5 years down the road, 10 23 years down the road, it's clearly understood why an 24 inspection was not done at the minimum frequency.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

23 Now this doesn't mean that we can't go 1

more frequently. We can. That's going to be allowed 2

based on the NRC resources, based on site activities 3

like key performance and enforcement history.

4 So we're just trying to establish some 5

kind of minimum, make sure we document and it still 6

allows the inspectors the flexibility to determine the 7

frequency of inspection along with the concurrence of 8

the project manager for that particular site.

9 So I think I'm done talking about the 10 inspection portion, and I'm ready to turn it back over 11 to Rob. Thank you.

12 MR. EVANS: Thank you, Marti. I wanted to 13 briefly mention some various NRC initiatives that will 14 be reviewed and included in the revised inspection 15 program as needed. And I would like to point out that 16 we have developed a project plan that's being used to 17 keep track of all of these various ideas.

18 So if there's some sort of idea or concept 19 that we need to consider or incorporate then it goes 20 into the project plan to help keep track of all of 21 these various moving parts so to speak.

22 So the first one is managing changes in 23 inspection frequencies. So we have to make sure that 24 the guidance that we provide within the manual chapter 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

24 is consistent with NRC guidance across the different 1

program areas.

2 Benchmarking with other working groups, 3

again, to maintain consistency across these working 4

groups as we revise the procedures. And a good 5

example is the Manual Chapter 2800 Working Group. As 6

we mentioned earlier, we're in close contact with that 7

working group so we can maintain consistency between 8

the groups.

9 So the idea is when a material site is in 10 operation and it goes into decommissioning, there's 11 kind of a seamless transfer because the terminology 12 and concepts are the same when you go across from one 13 manual chapter to another manual chapter.

14 A third bullet is managing issues of low 15 safety significance. This is an emerging issue that 16 we're still taking a look at. But in simple terms, if 17 the issue is likely outside the licensing basis and is 18 of very low safety significance, then the inspector 19 may have the ability to stop pursuing the issue and 20 refocus their resources elsewhere.

21 The next bullet, maintaining consistent 22 terminology across the NRC. This one has come up a 23 couple of times with our working group. So if we come 24 up with a definition or something that kind of needs 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

25 to be defined, we need to make sure that it is 1

absolutely consistent across the NRC. And as I had 2

mentioned earlier, one example is differentiating 3

between complex and non-complex decommissioning.

4 And then the last bullet is managing 5

changes in technologies over time. And how we plan to 6

address that is still under consideration. An obvious 7

example for some of you who have experienced it is 8

remote inspections using electronic technologies as 9

well as there's been some NRC attempts to consider, 10 like, handheld devices during inspections.

11 So obviously, life changes, the world 12 changes, technology changes. So how are we going to 13 address that in the manual chapter? There's more to 14 come on that.

15 Next slide. I just wanted to reiterate our 16 communications strategy and outreach. So the working 17 group is supported by the Agreement States. Any 18 changes that we make to the program will have to go 19 through the internal and external stakeholder reviews, 20 and external being Agreement States.

21 Both, I'd like to mention, they're 22 representative of oversight groups, and both will 23 provide comments on the draft documents. These 24 procedures will ultimately be used by NRC as well as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

26 Agreement State staff, either directly or in some 1

similar form. So we felt that it was important to get 2

the Agreement State support as we develop and revise 3

the Decommissioning Inspection Program.

4 And we also at the very beginning elected 5

to conduct outreach to non-Agreement Streets, Tribes, 6

other federal agencies. We did issue what's called a 7

State and Tribal Communication Notification Letter.

8 It went out May 13. I've got a reference for that in 9

just a moment.

10 This meeting is an attempt to kind of like 11 inform the public and industry of what we're doing.

12 And we've also agreed that we're going to host a 13 second public meeting about the time of rollout of the 14 procedures to let everyone know these are the 15 procedures. This is what they look like. These are 16 the changes that we implemented. You'll be aware, you 17 as the public and industry, are aware of what the 18 procedures look like.

19 Next slide, please. So at this point in 20 time, we plan to have the draft procedures complete 21 for internal and external stakeholder review by August 22 or September. There has been some discussion about we 23 may dry-run test some of the procedures at a few 24 currently licensed sites. That's to be determined.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

27 We plan to incorporate all NRC and 1

Agreement State comments by the end of the year, and 2

issue the documents by the end of 2021 or early 2022.

3 And as I just mentioned, we plan to host a public 4

meeting and introduce the new program.

5 And the last bullet is with NRC Technical 6

Training Center support, we plan to provide training 7

to inspectors on the new program. Now what we haven't 8

fully decided is whether or not we will provide the 9

training to Agreement States or just simply give them 10 the NRC's training program and let them train 11 themselves. So the training is still to be 12 determined.

13 Next slide, please. I just wanted to give 14 you a quick update of the status of the other working 15 groups and the other inspection programs if you were 16 wondering.

17 So there's a Manual Chapter 2561 Working 18 Group for the Decommissioning Power Reactor Inspection 19 Program. They completed their work, and they re-20 issued their procedures in January.

21 The Research and Test Reactor Inspection 22 Program, which includes decommissioning of RTRs, 23 research and test reactors, was revised and reissued 24 in May of 2020.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

28 The uranium recovery and 112.(2) byproduct 1

material facility inspection program, 2801, has been 2

revised. It has not been issued. It's currently 3

undergoing final internal reviews. And it should be 4

issued within the next couple of weeks.

5 And for any of you who happen to be on the 6

line that are in the uranium recovery industry, there 7

is a National Mining Association meeting scheduled for 8

late July. And I have proposed to give a presentation 9

at that meeting to describe 2801 and 2602 as it 10 applies to uranium recovery. So more information is 11 forthcoming on that topic.

12 The next bullet is 2800, the Materials 13 Inspection Program. It was revised in 2020. But the 14 implementing procedures, the inspection procedures, 15 IPs as we call them, are currently being updated. And 16 I would expect that at some later date in the 2022 17 time frame, we may go back and update 2800 based on 18 the revised procedures, implementing procedures.

19 And finally 2600, fuel cycle facility, 20 operational safety and safeguards inspection program 21 was also reissued in January 2021.

22 So long story short is Manual Chapter 2800 23 procedures and 2602 are currently in the revision 24 process. And some of the other sister related 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

29 programs have just recently been reissued.

1 So the next slide is references. I kind 2

of briefly earlier talked about the charter, the State 3

and Tribal Communications Letter, Be riskSMART and 4

issues of low safety significance. If you have any 5

interest in more information, in learning about these, 6

we provide the ADAMS ML numbers for download for the 7

public.

8 So this is actually the end of the formal 9

presentation. So what I'll do is I'll turn it over to 10 Maurice, who will make a few comments before we open 11 it up for questions and comments. Thank you.

12 MR. HEATH: Thank you, Rob. And thank you 13 for everyone who put on the presentation today. This 14 is the point on the agenda where we're going to open 15 it up to anyone who has comments or questions.

16 I see one comment in the chat. But before 17 I get to that, I just want to mention that today if 18 there is a question that you have or maybe comes to 19 you after the meeting, I'm going to put my email into 20 the chat so all attendees can have a copy of my email 21 and then you can send a comment or question to me.

22 We will have a meeting summary that we 23 will issue in 30 days and if there are questions that 24 come that we can address that will be the place that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

30 we can address some of those in our meeting summary.

1 With that, before we go to the line, I'm 2

going to read our first question that has come into 3

the chat. It says, is there a need for financial 4

assurance for decommissioning sites and do the 5

inspectors look at that? And I will turn that over to 6

Rob for response.

7 MR. EVANS: Yes. This is Rob. Let me 8

start and then I may pass it on to one of the other 9

individuals. But the answer is for financial 10 assurance for decommissioning, there are regulatory 11 requirements and license conditions for financial 12 assurance. The actual financial instrument itself is 13 managed more by license reviewers or program managers 14 than the inspectors.

15 But during inspections there will be 16 situations where we may try to verify certain 17 activities. Like for example if the licensee says 18 they need a certain amount of money to do a certain 19 amount of decommissioning, what we would do during 20 inspections is to -- is this correct? For example, 21 have they properly considered subsurface contamination 22 and the cost of excavating and remediating a 23 subsurface activity or maybe an area below the 24 building?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

31 This financial assurance is required by 1

regulations in the license. It's usually a license 2

reviewer type of activity, but there are inspection 3

functions that we will review financial assurance on 4

a case-by-case basis.

5 MR. HEATH: All right. Thank you, Rob.

6 Does anyone else on the team have anything else to add 7

to it?

8 MS. DALZELL: Yes. This is Jenni Dalzell.

9 Just to add to that, the requirements for financial 10 assurance are based on the license. And so that does 11 continue throughout the whole decommissioning process.

12 It's not something that just goes away once the 13 licensee is no longer operating. It's maintained 14 until the facility has been decommissioned.

15 MR. HEATH: All right. Thank you, 16 Jennifer. At this time, I think we're going to start 17 to see -- Michelle, are there any questions or anyone 18 in the queue that would like to ask a question?

19 OPERATOR: Thank you. At this time if you 20 have any questions or comments, you may press star 1.

21 Please unmute your phone and state your first and last 22 name when prompted. If you would like to withdraw 23 your question, you may press star 2.

24 Again, that is star 1 if you do have any 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

32 questions. One moment, please. Once again, that is 1

star 1 if you do have any questions.

2 We do have a few questions. Nima, is it 3

Ashkeboussi? You may go ahead.

4 MR. ASHKEBOUSSI: Hi. Can you hear me?

5 Can you guys hear me?

6 MR. HEATH: Yes. We can hear you.

7 MR. ASHKEBOUSSI: I've got a couple 8

questions. But first I just want to say, you know, 9

kudos to this group for undertaking the effort to risk 10 inform the Inspection Program. I think it's really 11 critical at this time where we focus resources on the 12 activities that matter most to safety. And by the 13 way, I'm with the Nuclear Energy Institute.

14 And my first question, and I think, Rob, 15 you had a slide on benchmarking other activities. So 16 I just want to just check that, you know, NMSS has 17 done some great work in this area with Inspection 18 Manual Chapter 2600 and the associated IPs through the 19 Smarter Fuel Cycle Inspection Program.

20 So I just wanted to check to see if the 21 group had been engaged with that effort or reviewed 22 the insight from that update.

23 MR. EVANS: This is Rob. I can provide 24 you with sort of a broad answer. At the very 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

33 beginning of the working group, we did take a look at 1

that particular working group's activities and 2

results.

3 And it was kind of a starting point. And 4

it's not just that one. There was, like, four or five 5

other working groups that the information was kind of 6

fed into our project plan and something to get started 7

with.

8 But for that working group, it is -- some 9

of the information is going into our program. But 10 with regards to risk is we're adopting the Be 11 riskSMART approach as kind of an overarching primary 12 mechanism for making decisions, putting the procedures 13 together as well as the inspector making decisions 14 with regards to each individual inspection.

15 So long story short is we did take a look 16 at it. We took what we thought was useful for that 17 working group, but we're going in a slightly different 18 direction. But if you have specific examples or 19 suggestions, I would be more than happy to have you 20 email them to us by way of Maurice, and we will take 21 a look at them in detail.

22 MR. ASHKEBOUSSI: Okay. Great. Thanks.

23 I might do that. So my second question, and I think 24 it was on your next steps forward. There was, I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

34 guess, a bullet on seeking external stakeholder 1

comments. I'm assuming that was directed toward 2

Agreement States or state and Tribal entities not the 3

public? Is that correct?

4 MR. EVANS: Rob Evans here. We actually 5

discussed this very concept early in the working 6

group. And we made the decision that we were going to 7

go with Agreement State comments, Agreement State 8

support but notifications to the public.

9 So, again we're always willing to accept 10 comments if you have any. But we decided against 11 having the public and the industry and licensees 12 involved in the procedure revision process.

13 We just kind of felt for various reasons 14 not to do that. And that's fairly consistent with 15 some of the other working groups, not all. Some of 16 the working groups did get the public involved but not 17 all of them did that. So we're kind of in the middle 18 of the groups. So long story short is we considered 19 it, but we chose not to go that route.

20 MR. ASHKEBOUSSI: Okay. So I guess 21 external non-state stakeholders will see the document 22 when it's final then. Is that right?

23 MR. EVANS: They will have an opportunity 24 to -- again, the second -- we will have another public 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

35 meeting to announce the program and to describe the 1

program. But we decided not to include them in the 2

development of the program since there are NRC 3

procedures that will be used by internal NRC 4

stakeholders as well as Agreement State people.

5 Now some of the other groups may have an 6

interest in how the program is put together, but they 7

would not necessarily be implementing the procedures.

8 MR. ASHKEBOUSSI: Okay. Thank you.

9 OPERATOR: Our next question comes from 10 Scott Murray. You may go ahead, sir.

11 MR. MURRAY: Hi, Rob. This is Scott 12 Murray, GE Hitachi. I guess I have a question for 13 Marti, maybe. I noticed, Marti, on Slide 17 you 14 described core inspection procedures developed for 15 each of four program areas. And one of those areas is 16 a fuel cycle facility.

17 I'm just curious because I thought there 18 already was an inspection procedure. I think it's 19 88104. It's been around for a couple of decades. But 20 I noticed it was not listed in the Inspection Manual 21 Chapter 2602.

22 Has that inspection procedure been idled 23 or is it going to be revised or are you generating a 24 new one for fuel cycle facilities? Can you help me 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

36 with that?

1 MS. POSTON-BROWN: Hi. This is Marti.

2 MR. EVANS: This is Rob.

3 MS. POSTON-BROWN: Oh, you want to take 4

it, Rob? That's fine.

5 MR. EVANS: No, no. Let me start and then 6

you can jump in. But the bottom line is we plan to 7

take 88104 and basically gut it and rebuild it. So 8

88104, we're going to keep the number. We're going to 9

keep the name. But it will be an all new procedure.

10 But we're not there yet.

11 MR. MURRAY: Yes, Marti, anything else to 12 add about 88104? I was just curious why it wasn't 13 listed on the list for the Inspection Manual Chapter 14 2602. Is that just an oversight do you think?

15 MS. POSTON-BROWN: At the time that we 16 made that list, we were undecided as to whether we 17 were going to re-do that one or just start with a 18 brand new one and a brand new number.

19 So we just kind of left it off semi-20 deliberately shall we say? But we decided that we're 21 going to take it all the way down to the ground and 22 reuse the number.

23 MR. MURRAY: Okay. That helps. All 24 right. Thank you very much.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

37 OPERATOR: Thank you. And once again, if 1

you would like to ask a question, you may press star 2

1. Our next caller is Katie Sweeney. You may go 3

ahead.

4 MS. SWEENEY: Hi. This is Katie Sweeney 5

from National Mining Association. I just wanted to 6

say thank you for doing this presentation today. I 7

found it very interesting. I think risk-informed 8

inspections are just as important as risk-informed 9

regulations.

10 And, Rob, I just wanted to say yes, we 11 will accept your offer to present at the NMA Uranium 12 Recovery Workshop on both of inspection documents. So 13 I appreciate that offer, and we're going to take you 14 upon it. Thank you.

15 MR. EVANS: Oh, thank you, thank you.

16 Personally, I kind of wish it was in person so I could 17 take a nice fun trip up to Denver, but I'll still do 18 it virtually.

19 MS. SWEENEY: Well, next year, I promise, 20 we'll be back in person.

21 OPERATOR: Thank you. And once again, 22 that is star 1 if you do have any questions or 23 comments.

24 MR. HEATH: Michelle, this is Maurice. I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

38 would like to take one of the written comments that we 1

have in the chat before we go back to the line if 2

that's okay.

3 OPERATOR: Thank you.

4 MR. HEATH: All right. The next question 5

we received in the chat is what defines complex or 6

non-complex materials or is this in the context of the 7

materials and site conditions based on a risk analysis 8

tool?

9 MR. EVANS: Yes. This is Rob. I'll start 10 on that one. And if anyone else wants to chime in, 11 that's great.

12 But this is a topic that we spent a lot of 13 time discussing. And the first thought was the 14 different between complex and non-complex was presence 15 or absence of groundwater contamination.

16 But we kind of felt that that one really 17 didn't meet our needs. So the current definition or 18 difference between complex and non-complex is based on 19 decommissioning plans and classifications, NUREG 1757 20 classification.

21 So if a site has a decommissioning plan, 22 then it's considered a complex decommissioning 23 project. If it doesn't have a decommissioning plan, 24 then it's considered what we call a Group 2 project.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

39 And that would considered non-complex. So there's 1

different ways of looking at it.

2 There will be some minor exceptions but 3

public interest or congressional interest or something 4

like that.

But in general if there's a

5 decommissioning plan, it's complex, which would 6

include sites with groundwater contamination.

7 MR. HEATH: Thank you, Rob. I want to go 8

to one more question in the chat before we go back to 9

the phone lines.

10 The next question is when or how will the 11 changes in the various IMCs be addressed as part of 12 the IMPEP process? I'll turn that over to Rob.

13 MR. EVANS: That was from Larry Camper.

14 And, Larry, greetings. Nice talking to you again.

15 And I'm afraid I'm honestly a little stumped by the 16 question. And I don't think I have a good solid 17 answer.

18 So we can either -- I can turn it over to 19 my panel if they think they can answer this one. Or 20 what we will do is take this question and then think 21 about it and then come back with an answer eventually.

22 MS. MUESSLE: Rob, I also am happy to jump 23 in here, at least conceptually, and if we need to --

24 if it doesn't answer, then we can look to get more.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

40 But in terms of part of -- IMPEP process 1

for those on the phone is the way that we work to do 2

a review of the State Program Materials Program or the 3

NRC's Materials Program. We're actually in the middle 4

of an impact review this week here with NRC's Material 5

Program.

6 We look at the date of the changes and so 7

if a new procedure goes into effect, then that would 8

be the timeline that we would be looking at the time 9

it would be in effect. But in my experience with 10 other things, like with IMC 2800, it was clear when we 11 should be following that Inspection Manual Chapter.

12 So during that review period is when, you know, that 13 it would seem reasonable that we would be following 14 it. But I'm not sure if that fully addresses what you 15 were asking.

16 MR. HEATH: All right. Thank you for the 17 response, Mary. And if that did not answer the 18 question fully, I would ask Mr. Camper to just put a 19 follow-up question in the chat. If we have time, we 20 can get back to it.

21 I'm going to read one more question from 22 the chat and then we'll go back to the phone lines.

23 The question is have there been or are 24 there any planned changes in the inspection process 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

41 for the low level waste disposal facilities?

1 (Simultaneous speaking.)

2 MR. HEATH: I'll turn that one over to Rob.

3 MR. EVANS: Yes. I can partially answer 4

the question. But I don't think I can completely 5

answer it. The Manual Chapter 2801, which is in the 6

final draft about to be issued within a couple of 7

weeks, it does address an 11e.(2) disposal facilities.

8 But if you're talking about, like, low 9

level waste facilities that are managed by the states, 10 like, let's say like the one in Texas and other 11 locations, that's not within our scope of activities.

12 But you're asking are there inspection procedures for 13 low level waste disposal facilities?

14 And I would have to get back to you on 15 that one. That's another one that I would have to do 16 more research on.

17 MS. HOLAHAN: And, Rob, if I can add to 18 that. This is Trish Holahan. I would say we do have 19 inspection procedures for low level waste disposal 20 facilities. But as Rob indicated, most of the --

21 well, all of the disposal facilities are currently in 22 Agreement States. So we would have to look carefully 23 at the Agreement States, whether they feel a need to 24 revise them.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

42 MR. HEATH: This is Maurice. Just to 1

follow on with what Trish said that there are 2

inspection procedures. But we also talked earlier in 3

one of the slides about some of the discretionary IP 4

looking at radioactive waste management.

5 And there are some other discretionary IPs 6

that may come into effect. And we haven't gotten to 7

the point where we have identified some areas that may 8

be needed to revise in that area. So it's a little 9

early for us to make a definitive answer if there is 10 something that may touch on some of the low level 11 waste disposal facilities.

12 With that, Michelle, do we have anybody on 13 the line that would like to ask a question or have a 14 comment?

15 OPERATOR: So once again, if there are an 16 comments or questions, you may press star 1. Sir, at 17 this time, I'm showing no further questions.

18 MR. HEATH: All right. We do have two 19 more questions in the chat so I'll start with the 20 first one.

21 A Financial Assurance Working Group 22 provided a number of recommendations in a report last 23 April. Have they or when will they be ultimately 24 addressed within the IMC updates?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

43 MS. HOLAHAN: I'll take this question, 1

Rob. The Financial Assurance Working Group Report was 2

specific to power reactors. And we have incorporated 3

the changes that we recommended in IMC 2561 as well as 4

other guidance changes. We're still working on those, 5

but it was specific to financial assurance to power 6

reactors.

7 MR. HEATH: All right. Thank you, Trish.

8 We have one more question in the chat I'd like to go 9

through. And isn't there some advantage for vendors 10 to comment on the procedure for new technologies that 11 can be or are being used for decommissioning 12 activities? And I'll turn that one over to Rob.

13 MR. EVANS: Thank you. Thank you. And 14 I'm afraid I'm sort of stumbling with an answer. My 15 earlier response is that part of the problem with the 16 working group is we don't know what some of these new 17

-- we know what is currently available, like with say, 18 ISOCS, in situ gamma measuring systems. So we can 19 incorporate that into our inspection program.

20 But newer technologies that are coming 21 down the road, we have ideas, but we don't really know 22 how to address them in the procedure. So we're not at 23 the point where those words have been formulated.

24 An example would be is there's some 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

44 indications that future outdoor surveys may be 1

conducted by drones. So how would we inspect 2

something like that? Well, we haven't really sat down 3

and talked about it or discussed it. So this is kind 4

of a tricky one.

5 My crystal ball is a little fuzzy on what 6

the future is going to hold. But if you have any 7

suggestions of possible technologies, new 8

technologies, being used in decommissioning, please 9

let us know about them to make sure they're on our 10 radar screen. But actual vendors commenting on the 11 procedure is -- again, we had chosen not to do that.

12 But we are quite interested in the information. But 13 I do appreciate the comment.

14 MS. POSTON-BROWN: If I can chime in, Rob, 15 this is Marti. I think that it's hard to address 16 emerging technologies in an inspection procedure. So 17 there are going to be some situations where we're just 18 going to have to leave it up to the discretion of the 19 inspector on how they want to evaluate that emerging 20 technology or new technology to make sure that it 21 appropriately identifies the risk and tries to 22 mitigate the hazards.

23 We can incorporate some language 24 associated with emerging technologies. But I don't 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

45 personally feel like there's a real advantage to 1

finding out what all the things are coming down the 2

pike because then we might have to do that every two 3

or three years to see what new survey technique or 4

sampling technique is coming down the road.

5 And I'd really like to leave it up to the 6

discretion of the inspectors in the future to address 7

those as those technologies develop. That's just my 8

personal opinion.

9 MS. MUESSLE: So, Rob, I'd like to add on 10 a little here. We've had a couple of questions about 11 going out to stakeholders outside of the Agreement 12 States for actual procedure or guidance comments, 13 which is really contrary to the way that we ran our 14 oversight program here.

15 We do want perspectives.

We get 16 perspectives and then we try to put together the 17 correct oversight for those. So I think as Rob had 18 said, if there are specific perspectives that could 19 inform us as we draft and review those with our co-20 regulators in the agreement states, we are looking to 21 gather that input.

22 So the procedures that we write 23 specifically to oversee those we hold as an in-house 24 function.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

46 MR. HEATH: Thank you, Mary. I just want 1

to also give an update. If there are, and we just 2

talked about individuals, and if they wanted to 3

provide any additional information, I put my email in 4

the chat, maurice.heath@nrc.gov. That's M-A-U-R-I-C-E 5

dot H-E-A-T-H @nrc.gov. Please feel free to send me 6

if you have additional information or as we discussed 7

earlier if you have a question that we may not get to, 8

please feel free to send me an email.

9 With that, I would like to turn to 10 Michelle to see if there's anybody else on the phone 11 lines that would like to make a comment or have a 12 question.

13 OPERATOR: Thank you. We do. And as a 14 reminder, that is star 1 if you would like to ask a 15 question. Larry Camper, you may go ahead, sir.

16 MR. CAMPER: Can you hear me?

17 MR. HEATH: Yes, we can.

18 MR. CAMPER: Okay, good. Well, thanks for 19 your presentations and thanks for answering my 20 questions.

21 I found the last discussion a bit 22 intriguing in terms of what to do about emerging 23 technologies. And you made some very good points 24 because it's changing so fast. But probably one of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

47 the things that I've found most interesting of late is 1

the increasing use of drones mounted with Geiger-2 Muller detectors for detecting radiation fields and 3

being planned in the use of decommissioning for 4

example.

5 And so I think that's an area where as 6

time marches on you will want to take a look at the 7

calibration processors, how drones moving about are 8

able to measure radiation fields at various distances 9

and changing distances and how that all winds up in 10 with the validity and the accuracy of the resulting 11 inspection performed by drones.

12 It's a very interesting technology, very 13 useful technology. It's happening right now. And 14 it's being used very constructively. But I do think 15 from a regulatory standpoint if I look at Geiger-16 Muller's changing detection distances, you know, basic 17 physics kinds of things, it is an area that you're 18 probably going to want to take a look at as time 19 marches on down the road. Thank you.

20 MR. HEATH: Thank you, Larry, for your 21 comments. Do we have anybody else on the phone line, 22 Michelle?

23 OPERATOR: At this time, I'm showing no 24 further questions, sir.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

48 MR. HEATH: Well, just to reiterate, I 1

just put my email in the chat for everybody in case 2

you do have a question or any follow-up information 3

you'd like to provide to our working group. I'll just 4

wait to see if anybody else has a question or anybody 5

else on the panel had anything that they would like to 6

address.

7 OPERATOR: And once again, if you do have 8

any questions or comments, you may press star 1. I am 9

showing no further questions on my end, sir.

10 (Simultaneous speaking.)

11 MR. EVANS: This is Rob. I just wanted to 12 provide a couple of summarizing comments. I 13 appreciate everyone's time and participation today, 14 both the panel as well as those that called in or came 15 into the Webex. I greatly appreciate everything.

16 We're still putting the procedures 17 together. If you have information, we'll take that 18 information and add it to the project plan and 19 consider it as part of the inspection procedures 20 themselves.

21 As I had mentioned earlier our plan is to 22 have the draft procedures that are ready to go to 23 review by the end of August or September time frame.

24 Now we were mulling around the idea of how we're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

49 actually going to sort of dry run and test the 1

procedures either through tabletop exercises or maybe 2

even going out to a couple of sites.

3 And I have a few in mind where we can take 4

the procedures and then just sort of use them and kind 5

of debug them during an actual inspection.

6 And then the next step in the whole 7

process is to actually implement all comments and get 8

them out by the end of this year or early next year.

9 And as I had mentioned again is that I do 10 plan to host -- we plan to host another public meeting 11 about that time and then we'll give you all the so-12 called gory details of what the procedures look like 13 and how they will impact licensees going forward into 14 the future. So long story short, there's more to 15 come.

16 So any other final comments from anyone on 17 the panel?

18 MR. HEATH: I guess, Michelle, is there 19 anybody on the phone lines before we close out the 20 meeting?

21 OPERATOR: At this time --

22 MS. HOLAHAN: I'd just like to reiterate 23 our thanks to the working group who is doing a 24 yeoman's job of risk informing these procedures as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

50 well as the members of the public that ask good 1

questions. And I appreciate all the input we've 2

gotten.

3 OPERATOR: And at this time, I'm showing 4

no further questions, sir.

5 MR. HEATH: Okay. Thank you, Michelle.

6 With that, again, thank you for everyone who is 7

participating via Webex or on the phone line. We 8

appreciate your input. And as we go about this 9

process, bear with us.

10 As Rob laid out our timetable, I realized 11 some dates could change. But we will keep you 12 informed.

13 And also, if you have any follow-up or you 14 didn't get your questions or you need answered maybe 15 or you thought of a question later on this afternoon, 16 please feel free. My email is in the chat. And I'd 17 like to thank you for participating today. And with 18 that, we will close the meeting for today. Thank you.

19 OPERATOR: And thank you. This concludes 20 today's conference call. You may go ahead and 21 disconnect at this time.

22 (Whereupon, the above-entitled matter went 23 off the record at 2:16 p.m.)

24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433