ML21193A201
| ML21193A201 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/2021 |
| From: | Office of Nuclear Material Safety and Safeguards, Neal R. Gross & Co. |
| To: | |
| Carrera, Andrew | |
| Shared Package | |
| ML21142A003 | List: |
| References | |
| NRC-1526, NRC-2017-0214 NRC-2017-0214 | |
| Download: ML21193A201 (84) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Retrospective Review of Administrative Requirements Public Meeting Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, June 30, 2021 Work Order No.:
NRC-1526 Pages 1-84 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 RETROSPECTIVE REVIEW OF ADMINISTRATIVE REQUIREMENTS 4
PUBLIC MEETING 5
+ + + + +
6 WEDNESDAY, 7
JUNE 30, 2021 8
+ + + + +
9 The meeting convened via Videoconference, at 10:04 a.m.
10 EDT, Brett Klukan, Regional Counsel, presiding.
11 12 PANELISTS PRESENT:
13 ERIC BENNER 14 THERESA BUCHANAN 15 ANDREW CARRERA 16 KEVIN COYNE 17 NATHAN GAGEBY 18 JEREMY GROOM 19 SHAWN HARWELL 20 MABLE HENDERSON 21 BRETT KLUKAN 22 JOHN LUBINSKI 23 MIKE MAHONEY 24 25
2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 FRED MILLER 1
JILL SHEPHERD 5
MINH THUY NGUYEN 8
10 ATTENDEES PRESENT:
11 ADAM GOODMAN 12 ANDREW MAUER 13 ANDREW ZACH 14 ANGEL WANG 15 ANGELLA LOVE BLAIR 16 ANTHONY de JESUS 17 BEZA ALEMU, NRC 18 BRETT TITUS 19 BRIAN GREEN 20 CAMERON GOODWIN 21 CARLOS SISCO, WINSTON & STRAWN LLP 22 CATY NOLAN 23 CHRIS MARKLEY 24 CHRIS SPEER 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CHRISTEPHER McKENNEY, US NRC 1
CHRISTOPHER REGAN, US NRC 2
CINDY ROSALES COOPER, USNRC 4
CONNOR McCUNE 5
DAVID CROWLEY, NC DHHS DHSR RPS 7
DAVID GULLOTT, Exelon Nuclear 10 EANN RALEIGH 11 ERNEST BATES, Southern Nucle ar 12 HILARY LANE 13 ILKA BERRIOS 14 JAMES PAK, Dominion Energy 15 JAMES SLIDER, NEI 16 JAMES UHLEMEYER, KDHE 17 JANET SCHLUETER, SENIOR ADVISOR 18 JERE JENKINS 19 JOHN CONLY, CERTREC CORP 20 JONATHAN WALLICK, USGS 21 JUSTIN VAZQUEZ 22 JUSTIN WEARNE 23 LES FOYTO 24 MARLONE DAVIS 25
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 1
MARTIN PHALEN, NUCLEAR ENERGY INSTITUTE 2
NICOLE GOOD, STARS 4
PAM NOTO 5
PAUL HARRIS, NRC 6
PRIYA YADAV, NRC 7
SABRINA ATACK 10 SABRINA KAHLER, NRC 11 SHAKUR WALKER 12 SILAS KENNEDY 13 STEVE REESE 14 SUZANNE DENNIS 15 TANIA MARTINEZ 16 THERESA CLARK 17 THOMAS BASSO, Exelon 18 TIM RITI 19 TONY ZIMMERMAN 20 TRAVIS JONES 21 22 ALSO PRESENT:
23 LYNN RONEWICZ 24 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 C-O-N-T-E-N-T-S 1
Introduction and Opening Remarks 7
2 Objectives and Scope 9
3
Background
11 4
Retrospective Review of Administrative 5
Requirements (RROAR) strategy 13 6
Question and Answer 20 7
Part II Discussion 45 8
Question and Answer 55 9
Closing Remarks 82 10 Adjourn 84 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P R O C E E D I N G S 1
(10:04 a.m.)
2 OPERATOR: Welcome and thank you for 3
standing by for today's conference. Al l participants 4
will be in listen -only mode until the question and 5
answer session. At that time, to ask a question, press 6
star one. I would now like to turn the call over to 7
Brett Klukan. Thank you. You may begin.
8 MR. KLUKAN: Good morning, everyone. I 9
would like to welcome you today and thank you for 10 participating in this meeting to discuss the results 11 of the NRC's Retrospective Review of Administrative 12 Requirements and the path forward. Again, my name is 13 Brett Klukan. I am the Regional Counselor f or Region 14 1 of the U.S. Nuclear Regulatory Commission; however, 15 today, I will be serving as your meeting facilitator.
16 So this is an information meeting with two 17 question and comment sessions. The purpose of this 18 meeting is for the NRC staff to meet dire ctly with 19 individuals to discuss regulatory and technical issues.
20 And you will have an opportunity to ask questions of 21 the NRC staff and to make comments about the issues 22 we discuss during the meeting. However, to be clear, 23 the NRC is not actively solici ting comments towards 24 the development of any further regulatory decisions 25
7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 at this time.
1 In addition to speaking during the question 2
and comment session, you will also have the opportunity 3
to pose questions during Webex question and answer 4
feature. During those sessions, I will read the 5
questions out loud.
6 Again, the audio for today's me eting is 7
only through the telephone bridge. You must call into 8
that bridge in order to participate in the added 9
function. Granted, if you're hearing this, that means 10 you're already dialed into the audio function, but I 11 don't know how much help that is fo r those who (audio 12 interference). But, again, the information for the 13 audio bridge, if you know anyone who is having trouble 14 joining the audio bridge, it is included in the login 15 or when you enter into the Webex application. Okay, 16 next slide, please.
17 So,
- again, this meeting is being 18 transcribed. During, when it is your turn to speak, 19 I would ask that you please identify yourself, including 20 any organizational affiliation at the start of your 21 opportunity.
22 Slides are available for download from 23 ADAMS, s o those of you on the bridge, the Accession 24 Number is ML21164A007, and the Comment Evaluation 25
8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Summary is also available on ADAMS and the ML for those 1
of you just on the phone or the ADAMS Accession Number 2
is ML21012A439.
3 And now finishing my quick introd uction, 4
I would like to turn it over to John Lubinski, the 5
Director of the Office of Nuclear Material Safety and 6
Safeguards. Thank you.
7 MR. LUBINSKI: Thank you, Brett. And good 8
morning. And thank you, everyone, for attending this 9
morning. I apprecia te you attending the US NRC's 10 meeting and the Retrospective Review of Administrative 11 Requirements, and you'll hear us refer to that as RROAR 12 this morning.
13 As Brett already said, I'm John Lubinski, 14 and I'm the Director of NMSS within the NRC. As part 15 of the RROAR effort, we had asked stakeholders to help 16 us identify potentially outdated or duplicative 17 administrative requirements in 10 CFR, in Title 10 CFR 18 the code, of Title 10 of the Code of Federal Regulations, 19 I'm sorry.
20 Our goal was and is to examine regulations 21 for administrative requirements that could be either 22 eliminated or modified without having any adverse 23 effect on public health or safety, common defense or 24 security, protection of the environment, or regulatory 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 efficiency or effectiveness. Th is activity supports 1
and aligns with our agency focus on transforming our 2
processes to be both more effective and efficient.
3 While the review generally indicated that 4
the NRC's administrative regulations are reasonable 5
and adequate, there are a number of areas where we can 6
make our requirements probably more clear, current, 7
and overall, more efficient.
8 At today's meeting, the NRC staff will 9
present the results of our analysis of the comments 10 we received. In addition to examining the outcome of 11 our analysis and answering questions, the staff will 12 provide our plans on how we are implementing regulatory 13 changes to certain administrative requirements and how 14 that's going to move forward.
15 Also, we would like to hear from you today.
16 As Brett said, there ar e a number of opportunities 17 to ask questions. We would like to hear your questions 18 that you have on what our plans are, what the details 19 of our review. We would like to hear and understand 20 any recommendations you have about how we handled 21 certain questio ns that came in or certain 22 recommendations and understand from you your thoughts 23 on how that could be more effective or efficient as 24 we continue to move forward.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So, again, my thanks for everyone attending 1
today, and I would now like to turn the meeting over 2
to Kevin Coyne.
3 MR. COYNE: Thanks very much, John. As 4
John said, I'm Kevin Coyne, and I'm the Deputy Director 5
of the Division of Rulemaking, Environmental, and 6
Financial Support. And I want to provide a little more 7
detail on the RROAR effort to h elp tee up the discussion 8
today.
9 In early February of
- 2020, the NRC 10 requested public input on any potentially outdated or 11 duplicative administrative requirements that may be 12 modified or eliminated. At the close of the comment 13 period, the NRC had receive d 100 individual comments.
14 The staff applied the Commission -approved 15 evaluation criteria described in the February 2020 FRN, 16 it's programmatic experience and the "Be riskSMART" 17 decision-making framework to review the comments 18 received.
The staff finaliz ed the review of 19 stakeholder comments and recommended 44 comments to 20 be further evaluated in a new RROAR -related rulemaking 21 effort. Ten additional items will be addressed in 22 other ongoing rulemaking activities.
23 So the comments that need further 24 evaluation within the context of the new RROAR -related 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 rulemaking effort, we plan to submit one or more 1
coordinated rulemaking plans to the Commission for 2
review and approval.
3 The NRC documented the comment review 4
results of the RROAR effort in SECY 0056. There's 5
a link to that SECY on the public meeting announcement 6
and available on the NRC's public website.
7 Just a couple of quick, really quick 8
reminders. As Brett mentioned, there will be two Q&A 9
portions during this informational meeting; one to 10 discuss the staff comment disposition and another 11 focusing on the path forward. Also, in addition to 12 not accepting official comments during this meeting, 13 we will not be making any regulatory decisions today.
14 We look forward to an informative meeting 15 with you to day.
We very much appreciate your 16 participation in the meeting. And now I will hand the 17 meeting over to Andy Carrera, who is the project lead 18 for this effort.
19 MR. CARRERA: Thank you. Good morning, 20 everyone. Thank you, Kevin, and thank you, John and 21 Brett. So welcome, again, to the public meeting on 22 the NRC's Retrospective Review of Administrative 23 Requirements initiative. So I will also use the term 24 RROAR to denotes the initiative from now on. So we, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you know, as Kevin and John mentioned, we want t o thank 1
you for the comment, and input, and feedback that you 2
provided to us on this very unique initiative.
3 So in today's meeting we're providing 4
overview of the RROAR initiative and the comment 5
evaluation process, the result of our analysis of a 6
comment we receive, and the next steps for this effort.
7 So we break in between to take questions 8
related to the project's path forward as well and 9
adjourn the meeting by hopefully noon today. Oh, and, 10 I forgot to introduce myself. My name is Andy Carrera.
11 I'm one of the project leads for this initiative.
12 So, before we begin, I just want to 13 reiterate what Kevin had just mentioned. You know, 14 it's very important to note that we are not here today 15 to solicit for new input or feedback on administrative 16 requirements for consideration of RROAR initiative, 17 nor do we plan to issue any additional responses to 18 the inputs and feedbacks provided in the past other 19 than what was provided in SECY 0056.
20 We will use the term inputs, feedbacks, 21 and comments interchangea bly throughout the meeting 22 today, so and we also use the word we, and NRC staff, 23 and management interchangeably throughout the meeting 24 as well. Next slide, please.
25
13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 By way of background and overview of the 1
RROAR initiative in late 2017, the NRC issued a press 2
release to announce that the Agency would be initiating 3
a retrospective review of administrative regulations 4
to identify those rules that are outdated or 5
duplicative. Next slide, please.
6 And the goal of the review was to optimize 7
the management an d administration of the regulatory 8
activities and to ensure that Agency's regulations 9
remains current and effective. And review was intended 10 to identify regulatory changes that are administrative 11 in nature and that will make information submission, 12 recordkeeping, and recording processes more efficient 13 for the NRC, the applicant, and the regulated entities.
14 And once identified, the administrative regulations 15 will be evaluated to determine whether they may be 16 eliminated or modified without impacting the Age ncy's 17 mission.
18 So in this
- context, administrative 19 regulations means recordkeeping of reported 20 requirements of regulations that addresses areas of 21 the Agency's organization procedural practice.
22 So in late of 2019, the Commission issue 23 was set up by eval uation criteria to serve as factors 24 for consideration to guide the NRC staff's evaluation.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So the Commission also directed staff to request 1
stakeholders and NRC staff's input on any outdated or 2
duplicative administrative requirements in the 10 CFR 3
that ma y potentially be eliminated or modified to reduce 4
regulatory burdens to licensees and NRC as well.
5 Furthermore, and this is important, all 6
the criteria serve as useful guidelines in identifying 7
administrative requirements that should be considered 8
for modification or elimination.
9 The Commission also directed the staff to 10 consider its programmatic experience. The intent of 11 the requirement, and the effect of elimination or 12 modification of a requirement on NRC mission, and that 13 is, I mean, that is the, you know, the focus of our 14 effort is the NRC's not, you know, to do no harm to 15 the NRC's mission. So I need you to understand that 16 and the overall effect on resources when determining 17 whether to pursue a change in our regulations.
18 And in February of 2020, the NRC published 19 a Notice in the Federal Register. I believe it was 20 Volume 8, Page 6103, seeking public input on any 21 administrative requirements that may be outdated or 22 duplicative of nature. The five evaluation criteria 23 were also provided in the Federal Register Notice.
24 And, so the NRC conducted several public 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 meetings over the course of the RROAR initiative, and 1
the meeting in May of 2018 to discuss the RROAR 2
initiative and the draft evaluation criteria meeting 3
on March 5th and March 24th of 2020, to facilitate public 4
comments. Additionally, the NRC also conducted public 5
meeting on August 27 of 2020, to discuss the comments 6
received.
7 And at the end of the public comment period, 8
the NRC received a total of a hundred individual 9
comments. Where multiple comments provided with 10 similar precision or rationale, the NRC staff blend 11 them together and consider them as a group and count 12 them as one individual comment.
13 So the comment impacted five NRC offices 14 and 17 NRC divisions. The NRC staff established an 15 agency-wide working gro up of approximately 40 staff 16 to evaluate the comments and to ensure consistency in 17 evaluation of the comments, including those that have 18 implication to cross, you know, with cross -cutting 19 issues among different NRC programmatic areas, for 20 example, licensin g basis, tech specs, radiological 21 effluent
- reports, security clearance
- reports, 22 emergency preparedness, and so on and so forth.
23 The comments that we received span across 24 many of the Agency's programmatic areas and affect 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 regulations in 14 different parts of the 10 CFR. And 1
at the end of the comments evaluation process, the NRC 2
staff determined 54 comments fall within the scope of 3
RROAR.
4 And, as you know, in SECY 0056, we 5
recommend the following path forward for these 6
recommended comments, you know, either to be further 7
evaluated in a new RROAR - related rulemaking, or to be 8
incorporated in an annual administrative correction 9
rulemaking, or to be further evaluated in an ongoing 10 rulemaking activity outside of the RROAR -related 11 rulemaking. Now, next slid e, please.
12 So this slide shows various factors in 13 processes enhancement that inform the RROAR comment 14 evaluation process. We applied, as you know, we 15 applied five Commission-approved evaluation criteria 16 as described in the February 2020 FRN. And in ord er 17 to be considered for elimination, potential elimination 18 or modification through the rulemaking process, a 19 comment must meet at least one of the first four criteria 20 and not meet Criterion 5, with that being excluding 21 that criterion.
22 Also, per COMSECY 0027, the Commission 23 directed the staff to also rely on the NRC staff's 24 programmatic experience, look at the intent of the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 requirement, the effective elimination modification 1
requirement on the NRC's mission public health and 2
safety, and overall effect o n resources when applying 3
the criteria.
4 We also applied the "Be riskSMART" 5
decision-making framework to the comment evaluation 6
process by considering the intent of the requirements, 7
the risk of eliminating a modification requirement on 8
the NRC mission. For example, we started reporting 9
requirements that may look to be administrative in 10 nature; however, upon consideration of these comments 11 or requirements, we determined they are more than 12 administrative in nature. They are in place to provide 13 reasonable assurance of adequate protection, in place 14 to support programmatic needs. They're in place to 15 provide regulatory efficiency and transparency. And 16 by applying "Be riskSMART" decision -making framework, 17 we determined that modifying or eliminating the 18 requirements would impact the NRC's mission and the 19 benefit would not justify the risk. That is why we 20 screened these requirements out from the way we did.
21 The majority of these comments are found 22 in Section II of the Comment Evaluation Summary, which 23 is, I b elieve, Enclosure 1 to SECY 0056. So these 24 items are items Number 55 to 100 in Enclosure 1.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Now we also spotted requirements that are 1
borderline administrative in nature. By applying "Be 2
riskSMART" decision -making framework, we determined 3
that we st ill need the requirements to be submitted 4
to maintain the NRC's mission; however, there may be 5
regulatory burden reductions or efficiency gain 6
opportunities dependent upon how we modify the 7
requirements so that the risk would be minimal and the 8
benefit would outweigh the risk.
9 So for these requirements we determined 10 the benefit may outweigh the risk if we do it right.
11 And we like to explore them further in the rulemaking 12 process to allow ample opportunities for stakeholders 13 to be engaged and provide feed back. So the majority 14 of these comments are found in Section I of the Comment 15 Evaluation Summary.
16 Now we also spotted requirements that are 17 administrative in nature and modifying or eliminating 18 these report requirements would represent minimal risk 19 to t he NRC's mission. We also apply improvement 20 identified from the Process Simplification 21 Transformation Initiative such as we establish an 22 Agency side division office -level committees to 23 facilitate coordination and communication and to ensure 24 the consistenc y in the Comment Evaluation process, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 including those with cost -cutting issues among 1
different NRC programmatic areas.
2 We also make use of modern information 3
technology in the document development and concurrence 4
process for the SECY paper. Next slide, p lease.
5 So this slide shows the end result for the 6
100 comments received on the administrative 7
requirements.
According to our evaluation, 54 8
comments met at least one of the Commission -approved 9
criteria and did not meet Criterion 5 and should be 10 considered further consideration in the rulemaking 11 process for potential elimination or modification.
12 So these comments are divided into the following 13 categories.
14 Forty-four comments to be further 15 evaluated in a new RROAR -related rulemaking effort.
16 Five commen ts to be incorporated in an annual 17 administrative correction rulemaking.
And five 18 comments to be further evaluated as part of the ongoing 19 rulemaking activities outside of the RROAR -related 20 rulemaking.
21 Just a quick note here, on the five comments 22 to be i ncorporated in an annual administrative 23 correction rule, the NRC is in the process of publishing 24 a rule for those administrative correction, and I 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 believe we are expecting to see the rule sometime later 1
this fall.
2 So these comments I mentioned, we are in 3 to SECY 21-0056. And as mentioned before 4
the comments that need further evaluation within the 5
context of a new RROAR-related rulemaking effort, we 6
plan to submit one or more coordinated rulemaking plans 7
to the Commission for review and approv al. And we 8
discuss more on these rulemaking steps later in the 9
second of today's meeting.
10 Now we also identified 46 comments that 11 did not meet the Commission -approved Criteria of 1 12 through 4 or didn't meet Criterion 5. These comments 13 can be found in Se ction II of Enclosure 1
to 14 SECY-21-0056. These are items 5 to 100. And of those 15 46 comments, the NRC has taken no further action for 16 44 comments; however, in accordance with Commission 17 direction in SRM to SECY 17 -0119, we have also 18 identified two comments in this category. I believe 19 these are items on the table as Items Number 87 and 20 Items Number 94 Enclosure 1 that may be considered by 21 a process outside the RROAR initiative as appropriate.
22 And we have provided these comments to those conducting 23 the Age ncy's innovation and transformation efforts for 24 consideration. Next slide, please.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So we are going to stop here to take 1
questions from meeting participants. With that, I will 2
turn the floor over to, back to Brett to start this 3
up. Brett, I believe you will calling on NEI's 4
delegation to see if they would like to make a statement 5
at this time.
6 MR. KLUKAN: Yes, Andy. Thank you very 7
much. So I'm going to explain the process, and then 8
I will turn it over to NEI. So if you would like to 9
ask a question or to make a comment, please press star 10 one on your phone to enter into the queue, and then 11 the operator will take your information and then place 12 you in line to speak; however, as an alternative to 13 that, if it's a quick question or comment, please feel 14 free to add that to the question and answer function.
15 When you put the question into the question and answer 16 box, I will read it out loud, and then we will address 17 it verbally as, you know, time permits.
18 So, again, there are two options to 19 participate. You can verbally ask your question, as 20 well as your comment by pressing star one, or you can 21 directly enter your comment into the question and answer 22 function of the Webex, and then we'll go through them.
23 So with that, I'd like to get, if the NEI 24 delegation would please press star one on their phone 25
22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 at this time to be entered into the queue, we will go 1
from there. So once they are in line and ready to go, 2
Operator, if you could please unmute them.
3 OPERATOR: We will take questions at this 4
time. One mo ment, please. This question is from 5
Justin Wearne. Your line is open, sir.
6 MR. WEARNE: Thanks. I did have a couple 7
of questions on the slides, but Jim Slider from NEI 8
has some comments that we'd like to go through. Do 9
you want to go through Jim Slid er's questions or 10 comments first, and then questions on the slides, or 11 how would you guys like to do that?
12 MR. CARRERA: Good morning, Jim. So let's 13 go through your comment, your question on the slide, 14 and then we'll provide the time to Jim for his comm ent.
15 MR. WEARNE: Thanks, Andrew. This is 16 Justin Wearne, I'm from PSEG, and I've been helping 17 Jim Slider at NEI work through these, work through this 18 issue.
19 The first question I had was on Slide 4, 20 and I'm interested in how -- yeah, that slide right 21 there -- interested in how the regions were involved 22 looking at the five offices impacted and the 17 23 divisions involved. Can you talk through how the 24 regions were engaged on this process?
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CARRERA: Yes, thank you for that 1
question, Justin. So the regions were engaged through 2
the programmatic reviewing
- staff, the 40 staff 3
participated in the review. These staff would reach 4
out to the regions, the partner that they have and work 5
with them to provide a directional path forward or 6
recommendation on how to proceed forward with that 7
particular comment.
8 MR. WEARNE: Thanks, Andrew. On Slide 5, 9
the next slide, the, kind of the bottom bullet there, 10 talks about a process simplification. Ca n you explain 11 a little bit more on that? I didn't quite get 12 everything you said. Can you just kind of go through 13 that one more time?
14 MR.
CARRERA:
Yes.
So process 15 simplification that we use is really we request and 16 receive support from high -level NRC management, and 17 we have access to management to help us making decision 18 throughout the review process, provide input, provide 19 additional direction for us. So that is something that 20 we believe is a bulk of the arm or the typical project 21 case.
22 And also other process simplification in 23 terms of trying to, you know, gaining working product, 24 as you know, with the SECY paper and the Enclosure out 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in a timely manner, we do things like concurrence, or 1
parallel concurrence process to help facilitate, you 2
know, getting the process, the product out faster.
3 MR. WEARNE: And thanks. So this was 4
really, this is a process that you put together. Is 5
this just for the RROAR, or is it going to be part of 6
the rulemaking effort as well, and is it part of any 7
other Agency efforts?
8 MR. CARRERA: It is, yes. It is a process 9
that we are starting to use, starting to really lean 10 on and rely on to get, to be more efficient in terms 11 of, you know, getting management buying in as well as 12 getting documents through the process faste r. And that 13 is something that we have been using and are repurposing 14 that for the RROAR comment evaluation.
15 MR. WEARNE: Thanks. I have one more 16 question, and then I'll kick it over to Jim for our 17 comments. On Slide 9, if you can go there, Andrew.
18 MR. CARRERA: Slide 9.
19 MR. WEARNE: I guess we haven't gotten 20 there yet. I'll hold off for the next Q&A session then.
21 MR. CARRERA: Okay. Thank you, Justin.
22 MR. WEARNE: For the Operator, can I just 23 hold on. Can you give Jim Slider access, and then I 24 might have some back -up for Jim as he's going through 25
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 his comments?
1 OPERATOR: Thank you. Jim Slider, your 2
line is open as well, sir.
3 MR. SLIDER: Thank you. This is Jim 4
Slider from NEI. Andy, I appreciate the part of the 5
briefing you've gone thr ough this morning, and we 6
appreciate this opportunity to participate in this 7
public meeting. We think it's a vital effort to bring 8
the NRC's reporting requirements into the 21st century.
9 It's been a long process to get here, and part of our 10 frustration is over the pace.
11 The project is coming up on four years old 12 now, and we have yet to see true relief or improvement 13 in the regulations. And we would urge that as you go 14 forward with this that you do everything possible to 15 expedite, and we are quite willi ng and eager to work 16 with the staff to make sure that we do our part to support 17 efforts to streamline and prioritize the 18 recommendations and actions.
19 We're particularly frustrated at this 20 point that only now are you talking about a rulemaking 21 plan by the end of the year, and you've outlined some 22 steps that sound like they are promising this morning, 23 but again, we haven't seen any concrete results yet.
24 And we're eager to see that.
25
26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We think it's vital to streamline and 1
modernize these reporting requireme nts so that the 2
plants and facilities can continue to focus on what 3
matters most to safety. And streamlining these 4
reporting requirements, bringing them into the 21st 5
century through use of technology, through innovation, 6
through transformative thinking a nd so forth are vital.
7 And we don't see that in the SECY paper 8
that has been provided. The word transformation 9
doesn't appear. We don't see innovation in there.
10 No mention of the EMBARK Studio, and we're just eager 11 as we can be to see the staff embrac e innovation and 12 transformation throughout these reporting 13 requirements.
14 And I hope that as you go through this 15 presentation you'll be able to show us where you have 16 because this presentation today is the first time we've 17 seen mention of use of the "Be r iskSMART" framework 18 and simplifying your concurrence process and so forth.
19 So we're absolutely eager to see concrete results and 20 eager to see the RROAR project embrace transformation 21 and transformational thinking. We just don't see it 22 so far, and we're eager for the staff to get through 23 this and get through it as quickly as possible.
24 That's all I have to say right now, Andy.
25
27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And I'll have some other things to say later after 1
we talk about the path forward. But thank you, and 2
I look forward to your res ponse.
3 MR. CARRERA: Thank you, Jim. So I just 4
want to bring this back to why we're doing this in the 5
first place, right? We're, you know, people don't 6
understand that we are not in the rulemaking process 7
yet. We are in the exploratory stage where we are 8
trying to identify any potential requirements, 9
administrative requirements that may be eliminated or 10 modified.
11 Once we have those information, those 12 requirements together, it's something that we can pass 13 forward and make recommendations to the Commis sion and 14 the Commission approves. That's one we're going to 15 start doing, you know, getting to the rulemaking 16 process, which I will be talking a little bit later 17 on today.
18 You know, you mentioned EMBARK. We did, 19 you know, reach out to EMBARK, and we do share 20 information with EMBARK during the process. It's 21 unclear to me what your thoughts on EMBARK's role in 22 rulemaking is. Right now we're trying to identify 23 requirements that we can do rulemaking on. You know, 24 of course, we continue to engage EMBARK an d, you know, 25
28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 recently we did engage EMBARK.
1 Now we're going to be talking about what 2
we're considering revising or modifying, you know, 50.4 3
Communications section. We did reach out to EMBARK 4
regarding the portal, and we got some good information 5
on that.
6 But I, you know, and maybe you can elaborate 7
a little bit on what you're expecting EMBARK or the 8
transformational innovation effort in the rulemaking 9
process. So that's all I have, Jim. Thank you.
10 MR. KLUKAN: Thanks, Andy. Would you like 11 me to o pen it up to other, potential other speakers 12 at this time?
13 MR. CARRERA: Yes, please, Brett.
14 MR. KLUKAN: Okay, thank you. So, again, 15 if you would like to ask a question or post a comment 16 regarding the material that's already discussed, please 17 press s tar one on your phone. Again, that is star one 18 to be entered into the queue.
19 As an alternative to that, you can also 20 directly enter your question into the question and 21 answer function within the Webex portal. So I will 22 give individuals there a moment t o enter themselves 23 into the queue at this time. Operator, it looks like 24 we have one individual in the queue, if you could unmute 25
29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 them, please.
1 OPERATOR: Thank you, Justin. NEI, your 2
line is open.
3 MR. WEARNE: Yes, again, this is Justin 4
Wearne from PSEG, and I've been working with NEI on 5
this topic. Andrew, I just wanted to, kind of, address 6
your comment about the role that EMBARK and innovation 7
might play in this. So recently some of the power 8
reactor light reviews have received requests from the 9
region to establish SharePoint sites for posting the 10 UFSAR for common use by the regional staff and the 11 project manager and other NRC staff.
12 But what's confusing to us is that the 13 response in SECY 21-56 indicate that that's the, that's 14 the reason why these things need to be sent to the 15 Document Control Desk is so that that can get 16 distributed out to the NRC stakeholders that need copies 17 of a document.
18 And so now the practice that we're going 19 to have is sending the reports to the Document Control 20 Desk, and then updating this SharePoint site, as well 21 as providing inspectors that come on site with the 22 selective chapters of the UFSAR that they're interested 23 in. And in so much that not duplicative but a 24 triplicative practice here of reporting.
25
30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And I'd also like to note that Manual 1
Chapter 0620 indicates that the inspectors should not 2
be asking for duplicative or copies of information 3
that's already publicly available. And we really see 4
the EMBARK's NDOs as being able to, you know, create 5
a web portal or some sort of cloud, a system where this 6
free flow of information could take place. And that's 7
really the role that we see here of the EMBARK Studios.
8 Does that make sense to you, Andrew?
9 MR. CARRERA: It does. Thank you, Justin, 10 for clarifying it.
11 MR. KLUKAN: Okay. Again, I'm not seeing 12 anyone in the queue. If you'd like to ask a question 13 or further comment at this time, please press star one 14 on your phone. Again, that is star one, or, again, 15 enter your question into the question, question or 16 comment into the question and answer function, and I 17 will read that out loud. So I'll give individuals a 18 moment or two to see if they would like to pose any 19 questions and comments at this time.
20 And we act ually have one from Janet 21 Schlueter, S -C-H-L-U-E-T -E-R. To elaborate on Jim 22 Slider's remarks, industry does not see evidence that 23 the NRC relied on data (e.g., inspection results) to 24 identify low -risk items where the administrative 25
31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 requirement could be modified or deleted. To say the 1
NRC will address stakeholder input during the 2
rulemaking, it has already dismissed, it dismissed over 3
50 percent of comments.
4 Let me read that again because I had a 5
pop-up break up my comment, so, and also just to give 6
additional people any time to enter into the queue.
7 So, again, this is from Janet Schlueter. To elaborate 8
on Jim Slider's remarks, industry does not see evidence 9
that the NRC relied on data (e.g., inspection results) 10 to identify low -risk items where the admi nistrative 11 requirement could be modified or deleted. To say that 12 the NRC will address stakeholder input during the 13 rulemaking dismisses the fact that the NRC has already 14 dismissed over 50 percent of comments. Again, thank 15 you for that comment.
16 Again, g ive people here another minute or 17 two to ask any questions or comments. If not, we will 18 proceed forward. Okay, Andy, I'm not seeing any 19 additional individuals in the queue --
20 MR. LUBINSKI: Hey, Brett?
21 MR. KLUKAN: -- at this time, so -- yes?
22 MR. LUBINSKI: John Lubinski here, how are 23 you?
24 MR. KLUKAN: Good.
25
32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. LUBINSKI: Can I just, can I jump in 1
and ask a quick question here?
2 MR. KLUKAN: Absolutely, of course.
3 MR. LUBINSKI: Okay. Thanks. Hey, Jim, 4
I really appreciate your question an d the further, or 5
your comment about EMBARK. And Janet, thanks for your 6
further clarification, so I appreciate that.
7 Can I ask, I heard two things there, and 8
I just want to make sure I fully understand as we 9
continue to move forward because of your comm ent you 10 mentioned use of EMBARK a couple of times. And I think 11 what I heard was two things so far, and I just want 12 to make sure we fully capture them.
13 Number one is the use of something or the 14 idea of using something like a SharePoint site or a 15 web portal to capture the information that currently 16 is recorded under the regulations vice having it be 17 provided to us in writing under the current regulations.
18 And I heard you say, Jim, that that's one of the areas 19 where you felt EMBARK could provide further in sights.
20 And then, so I think I understand that and that's really 21 just putting something on a web portal vice setting 22 something in writing.
23 But then I heard Janet go a little further 24 in use of information in an inspection report. Maybe 25
33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 if I could under stand more on that because many of the 1
reporting requirements that we're talking about may 2
be how they were used on the front end to improve our 3
efficiency in preparing for inspections vice what 4
resulted in may be findings in an inspection report 5
or docume ntation of how we actually use that information 6
when we did our inspections.
7 So I'm trying to understand is that also 8
related to EMBARK, where you're questioning our use 9
of whether we have specific data that would support 10 the efficient and effective use of information that 11 was provided through reporting and how it came out on 12 the back end because I think a lot of our discussion 13 when Andy felt about "Be riskSMART" model was looking 14 at the benefits from a cost standpoint of having this 15 information and being able to review it electronically, 16 either in writing vice having to wait to go out to the 17 site and not be prepared and have to review it at a 18 later time even if it doesn't result in any type of 19 finding or issue, but it's still a verification that 20 we believ e was done more effectively and more 21 efficiently by having information beforehand.
22 So can either Jim or Janet maybe expand 23 on if there's more use that you saw at EMBARK that would 24 help in coming up with a disposition of comments?
25
34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. KLUKAN: Melinda, I think we have both 1
James and Janet on the line, so why don't we start with 2
James, or Janet first, and then, oh, it looks like Janet 3
is now the person in the queue, so why don't we open 4
up her line and go forward with that. So thank you 5
very much.
6 MS. SCHLUETER: Okay, can you hear me?
7 MR. KLUKAN: Yes, we can, thank you.
8 MR. LUBINSKI: Yes, Janet, thanks.
9 MS. SCHLUETER: Okay. All right. I'll 10 let Jim Slider talk about the EMBARK Studio because 11 that's not really my area of experience. John, so I 12 was coming at my comment more from the fuel cycle side 13 of the world, and one where, you know, NRC has 14 successfully, in the last couple of years, used 15 inspection results and their own experience in the 16 Oversight Program to risk-inform the Inspection Progr am 17 at the fuel facilities by relying on existing 18 inspections data findings violations. You know, to 19 be able to use less resources to focus on those low -risk 20 program areas that are stable, for example, that don't 21 change a lot, that aren't high -risk operati onal areas, 22 and then shift the resources more into those program 23 areas that are a higher risk area with regards to safety 24 and security.
25
35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So when I looked at the whole RROAR results 1
and the Enclosure to the SECY paper, which was very, 2
very useful, thank you for the attachments, I had to 3
kind of just stop and think. Well, how is NRC using 4
your own data, your availability of information that 5
you have from your licensing experts and inspectors 6
to risk-inform this effort.
7 And so I didn't really see any evide nce 8
to say, yes, we stopped, and we paused, and we've looked 9
out there. And we've said, hey, this is a really 10 low-risk, stable program, and we're not getting any 11 violations in this area, so what's the harm in modifying 12 a reporting requirement. Whether th at's a change in 13 frequencies? How, you know, the periodicities, 14 whether it comes into you at all or could be reviewed 15 on a site visit basis.
16 And I just don't see any of that. So my 17 comment is coming from the positive experience that 18 we've had with NRC in the fuel cycle industry through 19 the Smarter Program initiative.
20 And I think that's what, you know, I was 21 looking to see some data-based evidence of change here, 22 and I'm just not seeing that. That's all.
23 MR.
LUBINSKI:
- Thanks, Janet.
I 24 appreciate that for the clarification, thanks. And, 25
36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Jim, did you have some thoughts?
1 MR. SLIDER: I do, John. Can you hear me?
2 I don't know if my line is open or not.
3 MR. LUBINSKI: I can here you fine, thank 4
you.
5 MR. SLIDER: Great. Thank you. John, I 6
really appreciate your question. And Janet really hit 7
on one of the key points that struck us. The Enclosure, 8
which summarizes the stash rationale for accepting or 9
rejecting various comments is qualitative, and we don't 10 know the entire analysis that the staff put into its 11 examination of each of those comments.
12 So we don't know what consideration 13 might've been given to creative ways to meet those 14 reporting requirements that need to be retained or 15 which, as Janet said, which could be eliminated on a 16 risk-informed basis, or whatever. We just don't know 17 that rationale. We don't know the details of the 18 analysis. We don't know how much consideration was 19 given to really creatively thinking how could we use 20 technology and the innovative approaches being 21 pioneered by EMBARK right now. We don't know any of 22 that.
23 The communications on the project have been 24 fairly closed to our examination throughout this past 25
37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 year and over the life of the project. And so it's 1
been de eply frustrating. We have no idea how this 2
project has been plugged into the efforts of the 3
Commissioners to transform the NRC.
4 And these administrative reporting 5
requirements are just emblematic of legacy obligations 6
that we're all still adhering to, e ven to the point 7
of, as Justin said in his example, having to submit, 8
change pages to FSARs, and so forth, only so that we 9
then later upload an electronic copy to a SharePoint 10 site.
11 It's just maddening redundancy and inefficiency 12 and so forth. And that's what we were trying to get 13 at by using EMBARK as a symbol of the opportunity and 14 the resources within the Agency to use technology to 15 solve some of these administrative problems.
16 And to the earlier point about addressing 17 these things through rulemaking, this project has been, 18 in terms of public communications, the project has been 19 handled with the formality of rulemaking. And so there 20 hasn't been a lot of interaction that could help us 21 to see the progress, see what's coming, help have the 22 back and forth that we're used to in other areas where 23 regulatory requirements are being reconsidered or 24 considered for modification.
25
38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And so at this point, we don't know what 1
lies ahead. And as Janet said, if our only opportunity 2
to discuss these options occurs under the rigors of 3
rulemaking, it's going to be three, four, five years 4
before we get through all of that. And that would be 5
just a waste of public resources and a waste of industry 6
resources to take that long to address some of these 7
technology challenges, o r technology solutions that 8
we know are available in business today.
9 So that's my vent, John, and I appreciate 10 you being on the call today to hear us out.
11 MR. LUBINSKI: Hey, Jim, thanks for that.
12 Can I ask one more follow -up on that because I think 13 it was a good question you brought up, and it's a 14 question I had along related to some of the comments 15 I've heard from the industry.
16 All the requirements we're talking about 17 right now are requirements during the regulation. And, 18 therefore, the only way t o change those requirements 19 is either to go through rulemaking, issue an order, 20 use enforcement discretion, or some other vehicle that, 21 you know, specific exemptions.
22 So I would ask, when you're looking at 23 vehicles, if we were to agree, and I'm using the if 24 there, if we were to agree that some requirements should 25
39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 be modified earlier and maybe codified later through 1
rulemaking, what are you seeing as the vehicle, and 2
what are you seeing as the real cost benefits associated 3
with doing that through process t hat's outside of 4
rulemaking?
5 MR. SLIDER: John, I'm not sure I can 6
answer your question as you asked it. Let me try to 7
address it in the following way. We're not suggesting 8
at all that the Commission should bypass the rulemaking 9
process. We understand you're obligated by the 10 Administrative Procedures Act to go through that legal 11 process, fair and open public comment, and so forth.
12 We get that, and we're not suggesting at all doing 13 anything contrary to that.
14 But at this point, what we have available 15 to us is a set of recommendations for the disposition 16 of public comments and no idea, we've had no opportunity 17 to dialogue with the staff about brainstorming creative 18 solutions that we then could take into that rulemaking 19 process.
20 And the brainstorming o n creative 21 alternatives might even lead to a shared understanding 22 that some of these rules are outdated enough, simple 23 enough, or the options today because of technology are 24 straightforward enough that we can use within the 25
40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 rulemaking process. We can use accelerated means to 1
accomplish these changes.
2 At this point, we have no hope, no optimism 3
that that actually, that sort of prioritization, that 4
sort of let's work out the what looks like an improved 5
situation before we go into the formality of rulemakin g.
6 And we just don't see any of that forthcoming.
7 What we see is a product that says here's 8
where we are. A year from now we'll be starting 9
rulemaking, and we don't know when that's going to 10 happen. Does that answer your question, John?
11 MR. LUBINSKI : Thanks, Jim. I appreciate 12 that clarification, thank you.
13 MR. CARRERA: Hi, this is Andy. If I can 14 start for a minute. I heard EMBARK mentioned a lot, 15 so if I may, I'd like to call on Jeremy Groom, who is 16 the Director of EMBARK at the time, maybe to chime in 17 on his perspective on this.
18 MR. GROOM: Yes, great, great. Thanks, 19 Andrew. Can everybody hear me?
20 MR. CARRERA: Yes.
21 MR. GROOM: Great. So, Jim, appreciate 22 your comments and the rest of the comments from NEI.
23 I think you've got a good p erspective on EMBARK's role.
24 And I can tell you, we have reviewed, you know, the 25
41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 SECY and the various administrative requirements that 1
were captured in RROAR and the staff screening.
2 Just a little bit of clarity on how EMBARK 3
fits into this. My staff i s not experts in the various 4
administrative requirements and how they're used. And 5
so the respective screening Criterias 1 through 4, and 6
5, you know, we didn't, we weren't in a place to 7
necessarily challenge those and say to the staff you 8
did the right job in screening those. You know, the 9
individual members who use these various administrative 10 reports are the ones that have the expertise to do that.
11 And as you heard earlier in the presentation, the NRC 12 assembled a, you know, a skilled panel of subject matter 13 experts to perform that task.
14 (Audio interference.)
15 Jim, is exactly what you said. You know, 16 we're an innovation accelerator, and we're a group that 17 can help, you know, leverage technology, find better 18 ways to do things, and to that end, I think if you go 19 through the document it's probably not as overt as what 20 you're looking for.
21 But if you go through the SECY attachment, 22 there are various places where we talk about enabling, 23 you know, electronic submissions, looking at ways to 24 replace outdated processes. I'd call your attention 25
42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to items like 31, 32, 33, 34. Thirty -four, in 1
particular, talks about written communications, and 2
it talks about the staff considering alternatives, you 3
know, use of current technology and whatnot.
4 You know, it's a small line item in the 5
SECY attachment, but it's a big impact. It could be 6
one that, you know, really could have widespread 7
implications. I think Item Number 44 in the SECY 8
attachment also could have widespread implications.
9 It talks about submitting written documents into ADAMS, 10 and maybe there's a better way through a portal or 11 whatnot to perform that task.
12 So I can assure you that EMBARK is engaged 13 on this. Your perspective on our role is correct.
14 You know, we're not rulemaking experts. We're not 15 experts on administrative requirements. We're a group 16 that can help leverage technology and, you know, even 17 if there are certain specific line items that talk about 18 maybe enabling some electronic technology, so that's 19 really where we f it in. I just wanted to clarify 20 EMBARK's role in this process.
21 MR. CARRERA: Thank you so much, Jeremy.
22 And Greg, if I may just get back a little bit on the 23 Commission-approved, the five Commission -approved 24 evaluation criteria. So, as you remember, ea rly in 25
43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the RROAR initiative process, we did, a large portion 1
of those at that time was to, you know, commission the 2
regular staff to go ahead and develop these, you know, 3
develop these evaluation criteria. And the NRC staff 4
has did a significant outreach to the public at that 5
time to engage the public on developing and finalizing 6
that evaluation criteria.
7 So, you know, I just want to stress that 8
those criteria is not something that no one ever mind.
9 It's heavy. It has weight, and it has gravity because 10 of those, you know, action the staff engaged the public 11 and public comments on, and finally the Commission 12 reviewed the staff's propose based on public comment 13 and approve those criteria. So that's all I want to 14 bring up. Brett, back to you. Thank you.
15 MR. KLUKAN: Thank you, Andy. So it looks 16 like we have one additional speaker in the queue.
17 Again, if you'd like to ask a question or comment, please 18 press star one or enter it into the question and answer 19 box. So could you unmute in the queue, pleas e.
20 OPERATOR: Justin Wearne, your line is 21 open.
22 MR. WEARNE: Yes, thanks. Again, this is 23 Justin Wearne from PSEG. John, I just wanted to, I 24 wasn't fast enough on the unmute to get ahold of you 25
44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 during some of that discussion. But, you know, you're 1
kind of mentioning, you know, hey, we have to do 2
rulemaking or enforcement discretion or orders as the 3
vehicles to modify the regulations, right?
4 And I just wanted to point out that, oh, 5
boy, about 10 years ago, right, we did an enforcement 6
discretion to a lleviate the need to deal with porting 7
of emergency plan implementing procedures. And that 8
was a very quick win for us, right? That was a large 9
burden for the stations, and by doing it, kind of, in 10 that expedited process, you know, that was a big win.
11 So that might be something we want to keep on our radar 12 screen as something to kind of model going forward.
13 And then the other comment I had for you, 14 John, was we kind of talked about like the risk ranking 15 of these reports. And, so if you take the popula tion 16 of event follow -up reports, you know, there's an event 17 that happens at the station, and then you have to do 18 a written follow-up to the Agency. Those timeframes 19 very from 30 days up to 18 months, and it's not clear 20 to us why some of those are at 30 da ys and why some 21 of them are at 18 months. And I think we all know that 22 licensing event reports, you know, for the power 23 reactors, are at 60 days.
24 So that's kind of one of the things we were 25
45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 hoping to see was some sort of, kind of harmonization 1
or understanding of why these reporting frequencies, 2
and let's just take the event follow -up, why they are 3
at that different timeframes. So I just wanted to add 4
those two comments. Thanks, John.
5 MR. LUBINSKI: Yes, John Lubinski here.
6 Thanks for that additiona l clarification.
I 7
completely understand your second point about the event 8
reporting. On the first part, what else I'm not 9
familiar exactly what was accomplished under the, you 10 know, the enforcement discretion we used under for 11 emergency plans and how bi g an impact that was. And 12 so I can't really compare it since I was not involved 13 with that and don't have the awareness.
14 And in looking at what we saw today though, 15 I do believe folks looked at whether or not we saw 16 something significant enough in that a rea that would 17 really say that the costs to NRC and the industry, you 18 know, is such a burden that it would, you know, benefit 19 from as you said a minute ago, a big win, if you will, 20 of having something change much sooner through 21 enforcement discretion. If there was something like 22 that, we would certainly want to hear that, and I think 23 our initial look did not necessarily show that. Thanks 24 for that further information. I greatly appreciate 25
46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 it.
1 MR. KLUKAN: Okay, and this is Brett. If 2
you would like to a sk a question or comment, please 3
enter star one. Again, that is star one, or otherwise 4
type your comment into the question and answer feature 5
of the Webex portal. And I'll give individuals a minute 6
or two to do that if there are any additional questions 7
and comments at this time.
8 Okay. Andy and NRC staff, I'm not seeing 9
any additional questions or comments either in the 10 question and answer box or on the, or in the Verizon 11 queue. So if you'd like to, know, proceed forward, 12 please.
13 MR. CARRERA: Yes. Thank you, Brett, and 14 thank you, everyone for the discussions. And so let's 15 continue on, moving on. May I have next slide, please?
16 All right. So we resume this meeting. You know, we 17 discussed some of the past reviews and looked at the 18 administrative requirement looking in the rearview 19 mirror retrospectively, but I also want to discuss, 20 you know, look prospectively into the future towards 21 development of rulemaking plans for the requirement 22 based on, you know, based on your inputs as well to 23 recommend for consideration in the rulemaking process.
24 Now, in developing the rulemaking plans, 25
47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 moving forward we will leverage some of the new 1
rulemaking decision guidance and rulemaking approach 2
tools to identify effective and efficient options to 3
address the rulemaking needs.
4 Now we'll continue to apply the "Be 5
riskSMART" decision-making framework and other process 6
enhancements. We also consider your input and feedback 7
today that you provided, you know, in the previous Q&A 8
session, and as well as in the upcom ing Q&A session 9
to inform our, you know, decision -making process and 10 how we're going to move forward. Next slide, please.
11 So this slide shows some of the factors 12 that we really think about, need to think about in order 13 to identify and compose an effecti ve decision and 14 appropriate options and recommendations to address our 15 rulemaking needs. And I'm saying our rulemaking needs, 16 and then there'd be a, you know, we touch a little bit 17 on what things that we can do outside of rulemaking 18 that John Lubinski has touched a little bit on.
19 But I'm talking about, you know, looking 20 at the rulemaking portion of this now. So first and 21 foremost, the majority of requirement, as you know, 22 that we recommended, you provided, and we recommended 23 consideration of rulemaking process involve 24 information collection clearance changes and would 25
48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 require the Office of Management & Budget, OMB, to 1
review these associated changes to the information 2
collection clearance. And it's going to be for 3
multiple tangible parts and related inf ormation 4
collection.
5 Now this requirement would add additional 6
- time, complexity
- level, and uncertainty to the 7
rulemaking process when compared to the rulemaking 8
process that do not involve these type of information 9
collection clearance changes. So that' s one of the 10 factors that we need to consider how we're going to 11 slice and dice it, and, you know, do it in a way that 12 would be most efficient.
13 In addition, OMB process is also only 14 allowed a submission of one action per OMB control 15 number at a time. So the schedule for issuing the rule, 16 you know, we would have to be really think about it 17 and be careful about this and think it broadly in terms 18 of, you know, what rules that we have out there. So 19 the schedule of issuing the rule may be negatively 20 impacted if one or more of the rule related OMB control 21 numbers is blocked by prior submission.
22 So there is other slides are good examples 23 of where we can apply the "Be riskSMART" decision -making 24 framework as well as spot the risk, manage the risk 25
49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and act on that decision.
1 Another area that we need to look at as 2
well as agreement states involvement, right? RROAR 3
evaluation identified administrative regulation in 4
Parts 20, Parts 37, Parts 70, and that would be in the 5
scope of RROAR and also have compatible ag reement state 6
regulations. So we have to consider the impact on the 7
rulemaking process and determine what rulemaking 8
approach is appropriate and will be supported by our 9
agreement states partner. So we need to think about 10 that, you know.
11 So we'll also consider complexity of 12
- revision, right?
Whether the change is 13 straightforward and do not require compilation of, you 14 know, a regulatory basis, or something more complex 15 that, you know, when do it, you know, make a wrong 16 change, we don't think it really th rough, it may produce 17 unintended consequences that, you know.
18 And, so you know, those items would benefit 19 from additional stakeholders input, Jim, during the 20 rulemaking phase talking about regulatory basis.
21 That's where we would love to have additional, you know, 22 communication/dialogue with you just to really hammer 23 it out and get it right. You know, we don't want to 24 go back and change it later.
25
50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And also, could changes be addressed 1
through rulemaking process because if no, never mind 2
type of changes o r, you know, it could be it needs to 3
be addressed through conventional notice and comment 4
rulemaking process because we want your input. We want 5
your, you know, Commission input as well before we make 6
it final.
7 So also considering the priority of 8
rulemaking and our desire to make tangible progress 9
given that these changes will be very broad and would 10 impact resource from programs across Agency, you know, 11 what are we going to do if we have a large portion of 12 technical staff who are working on Part 53 rule making 13 right now who also are working rulemaking for RROAR?
14 Are we going to reassign them back to RROAR? It's 15 something that we really need to think about and, you 16 know, and discuss. So that's part of what I'm talking 17 on the slides about.
18 And lastly, you know, we really appreciate 19 your feedback, Jim, Justin, and Janet. And, you know, 20 further discussion on your recommendation is part of 21 this meeting. So we will use your feedback from our 22 discussions to inform the rulemaking plan development 23 for revisi ons of these administrative requirements.
24 Next slide, please.
25
51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Okay so some of you spotted that we're 1
missing an "R" in the ROAR Rulemaking Plan. So we would 2
drop the two R's as in retrospective review because 3
we've reached an important milestone in the project 4
where we stop looking to the past despite managed 5
questions relating to this administrative requirements 6
and regulatory burden reduction. We now look into the 7
future where we can act on our decision and we realize 8
the results through the rulemaki ng process.
9 Now the new R you see now in RROAR stands 10 for revisions of administrative requirements, which 11 is the title of future rulemaking.
12 So that aside, for comments that need 13 further evaluation within the context of the new 14 RROAR-related rulemaking effort, we plan to submit one 15 or more coordinated rulemaking plan to a SECY for review 16 and approval by, you know, late 2021 timeframe. And 17 if the Commission approved the rulemaking plans, we 18 will conduct further stakeholder engagement during the 19 rulemaking process that I mentioned earlier.
20 I just want to stress this again. It is 21 important to know that the RROAR initiative was part 22 of a, you know, dialogue and exploratory phase that 23 we have not yet reached or entered the rulemaking 24 process.
25
52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 On the right - hand side of the slide shows 1
the steps in the rulemaking process. And we are working 2
to develop one or more coordinated rulemaking plans 3
for those administrative requirement changes needing 4
Commission approval to pursue. And once the Commission 5
approves, the staff will be making plan the process 6
officially, the NRC rulemaking process officially 7
starts.
8 So the next step after the rulemaking plan 9
is to declare a separate regulatory basis document that 10 we identified as a clear need and benefit for those.
11 So the regulatory basis document, as you know, provide 12 NRC scope and objective rulemaking with the "Be 13 riskSMART" decision -making framework option including 14 rulemaking and non -rulemaking
- and, you
- know, 15 preliminary analysis, including cost and benefit 16 analysis, back fitting analysis, schedule and estimate 17 of resource. So with the regulatory basis, we have 18 an option of publishing it for comment and get your 19 feedback and input on the direction of the rule at that 20 time, although not required by the Administrative 21 Procedure Act of 1946 as amended. Public comments can 22 sometimes be, you know, in this phase, I believe, is 23 going to be beneficial in ge tting the rulemaking 24 approach, in particular rulemaking issue or a path 25
53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 forward for complex and regulatory changes. However, 1
if the staff believes the regulatory changes are 2
straightforward and may, may not need to prepare a 3
separate regulatory basis docu ment after we request 4
the Commission's approval to skip the step in the 5
rulemaking plan.
6 And the preparation of regulatory basis, 7
I have in a slide, it's in quotation in parenthesis 8
optional. It's optional insofar as the staff request 9
to skip step in th e rulemaking plan and the Commission 10 approved the rulemaking plan. And if the Commission 11 approves to skip the preparation of separate regulatory 12 basis for regulatory changes we believe to be 13 straightforward, we will draft the changes in the 14 preamble of the Notice in the Comment Report.
15 The after Commission approved the 16 rulemaking plan, we develop adequate regulatory basis 17 if one is needed. We can proceed forward with 18 development of proposed rule. The proposed rule 19 notifies the public that NRC is consi dering amending 20 its regulation and would include description of how 21 Agency proposes to amend its regulations. The preamble 22 would provide the Agency's rationale for proposal and 23 the proposal would then list regulatory text that if 24 adopted would be codified in the Code of Federal 25
54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Regulations.
1 And if the Commission approves the proposed 2
rule, the proposed rule is published in the proposal 3
section of Federal Register Notice and request public 4
comment on the proposal. Typically the public comment 5
period is 7 5 days. Also, typically, we would conduct 6
public meetings in comment period of the proposed rule 7
to facilitate information to inform stakeholders 8
comments on the proposed rule.
9 And at the end of public comment period 10 for the proposed rule, the NRC would consider the 11 comments we see in finalizing and issue the rule in 12 accordance with APA, final rule is the official Agency 13 statement of law or policy includes important dates 14 such as effective days and sometimes, you know, 15 implementation or compliance dates, and provides a 16 summary of public comment and NRC's response to each 17 of those comments.
18 So it is important to stress again that 19 the RROAR initiative was part of, you know, a phased 20 exploration, if you will, effort, and that we have not 21 yet entered the ru lemaking process that I just 22 mentioned.
23 I believe that's all I want to touch on 24 the rulemaking process. I believe there was much more 25
55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 than what anyone wanted to know. So may I have the 1
next slide, please?
2 So we, again, going to take a, you know, 3
stop here and take questions from the meeting 4
participants on the path forward for this initiative.
5 And to facilitate the Q&A session this time we have 6
three questions, some of which John has previously 7
touched on, but we're interested in hearing your 8
thoughts on; however, we are not requesting for or 9
requiring any of the comments to be submitted based 10 on these questions following this meeting, and that's 11 because of the Paperwork Reduction Act where we need 12 information clearance from OMB to receive submittal 13 of your comments.
14 So the first question is: What are your 15 thoughts on how the RROAR initiative has applied the 16 "Be riskSMART" decision -making framework to the 17 evaluation process? We touched a little bit on that.
18 The second question is: What does the 19 industry see as ways for more timely and efficient 20 regulatory burden relief? I think we touched a little 21 bit on that as well.
22 And the third question that we'd like to 23 get your thoughts on or pick your brains on: What are 24 the appropriate means to commun icate project status 25
56 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 with the industry?
1 So with that, Brett, I will kick this 2
meeting back to you and tee us off for the Q&A session.
3 Thank you.
4 MR. KLUKAN: Thank you very much, Andy.
5 So, again, if you would like to weigh in on any of these 6
questions, you see up here on the slide that Andy just 7
discussed, or if you have other questions (audio 8
interference), and it may be noted again, and I will 9
reiterate, we are not formally soliciting comments at 10 this time regarding these questions, or you can alw ays 11 write in the effort.
12 So with that said, the process is the same 13 as before. If you would like to speak, please press 14 star one at this time; again, that is star one. Or 15 feel free alternatively to enter your response or your 16 question or comment into t he question/answer function 17 in the Webex portal. So with that said, I will give 18 people a few moments to queue up, and then we'll get 19 started. So, thank you.
20 All right, Melinda, it looks like we have 21 one individual, two individuals in the queue, so why 22 don't we get started and unmute Jim first. Thank you.
23 OPERATOR: You're welcome. Jim, your 24 line is open at this time.
25
57 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. SLIDER: Thank you. Jim Slider from 1
NEI. Andy, I appreciate what you shared this morning.
2 I do want to respond to the example that Justin Wearne 3
mentioned about eQIP submittals. He found their 4
reference for that with, for John Lubinski's benefit 5
since John indicated he wasn't familiar with that 6
example, it involves risks 2015 -14 and EGM15 -003. So 7
those references can provide s ome useful background 8
on how the Agency handled the sort of opportunity to 9
provide prompt relief prior to getting through the 10 rulemaking process.
11 Andy, I understand and sympathize with all 12 of the constraints that you mentioned about the 13 rulemaking proce ss and all the effort that has gone 14 in to producing the SECY paper that we now have. There 15 are parts of, there are entries in the SECY attachment 16 that explain the staff's rationale for dispositioning 17 various comments that are not clear to us. And I'm 18 wondering what our opportunity is to go through all 19 of those line items with you.
20 I'm wondering is it an option for you to 21 schedule a separate public meeting where we can get 22 into those details, and so we can better understand 23 what the staff's thinking is o n each and every one of 24 the items in that attachment where I respect the fact 25
58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that you're not looking to change. You're not 1
soliciting comments today. You don't want to change 2
the staff's evaluation, but there are some that are 3
fairly obscure to us, and it would help us if we could 4
walk through them one at a time with you.
5 MR. CARRERA: Hi, Jim. This is Andy.
6 Thank you, thank you, again for that question. So at 7
this time, I hadn't planned to because the reason being 8
that these are recommendations tha t the Commission has 9
not seen yet, and the Commission will see it in the 10 rulemaking plan us moving forward.
11 And, I mean, we don't know what Commission 12 is going to approve or disapprove in the recommendations 13 that we're going to make. You know, in the En closure 14 I we provided, where we can, we can be specific on it.
15 Where we mention there are changes to periodicity or 16 frequency of document submittals, that's something that 17 we will intend to look at during the rulemaking phase, 18 you know, during the regulat ory basis and discuss that 19 with you to make sure that we, you know, what the 20 frequencies are, what the right, correct frequency 21 would be.
22 So at this time, I cannot answer or give 23 you a definite answer whether we, you know, I will have 24 to check back with my management on that whether, you 25
59 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 know, we're going to be open to a meeting, you know, 1
a sit down meeting or chat meeting on each of the items 2
that we are proposing to send in or recommend for 3
rulemaking.
4 MR. SLIDER: I hope you can persuade them, 5
Andy.
6 MR. KLUKAN: Okay. Thank you very much.
7 Next we are going to go to a question, well, I'm going 8
to read out loud a comment from Janet Schlueter in the 9
question and answer box. And Janet writes, assuming 10 the NRC decides to continue with this initiative,
11 establishing a RROAR dedicated webpage would be 12 helpful. DFM established one for the -- that is very 13 helpful. That is from Janet Schlueter. Andy, or 14 anyone from the NRC staff, any response or comments 15 with respect to that?
16 MR. CARRERA: Hi, Brett. I apologize.
17 Could you please repeat Janet's comment?
18 MR. KLUKAN: Sure, of course. So assuming 19 the NRC decides to continue with this initiative, 20 establishing a RROAR dedicated webpage would be 21 helpful. DFM established one for the Smarter Program 22 initiative that is very helpful.
23 So Janet is asking if th ere's any 24 consideration with respect to creating a dedicated 25
60 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 webpage for RROAR.
1 MR. CARRERA: Yes, I do not have any 2
comment on that. Maybe someone else, you know, would 3
like to chime in there.
4 MR. LUBINSKI: Hey, this is John Lubinski.
5 Yes, in respo nse to Janet's comment, and I'm going 6
to go back to Jim's as well, let me just say hey, Janet, 7
thanks for the comment. That is something we'll 8
definitely consider from a communication standpoint.
9 I was actually going to follow -up with it 10 on Jim's questi on is, you know, our question on the 11 slide right there is what are the appropriate means 12 to communicate project status with the industry?
13 And I assume, Janet, your response to that 14 is that the webpage similar to what we've done with 15 the one DFM would be appropriate. So thanks for that 16 recommendation, and we'll take that as a consideration 17 as we move forward. And, of course, respond publicly 18 to everyone letting them know we'll do that, if we do 19 that.
20 Hey, Jim, I think your comment was, or 21 question/recommendation to the same question was having 22 another public meeting where I'll say it's getting more 23 into detail of each of the recommendations and how they 24 reached this decision. So we'll, as Andy said, we'll 25
61 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 take that back as a request from to have anothe r public 1
meeting and get back on that as well. So, you know, 2
I'm going to ask our folks to take those as two takeaways 3
that we'll definitely be communicating back to the 4
industry.
5 And let me add to that. You know, Jim, 6
I'll ask maybe Jim specifically s ince you brought up 7
that meeting. Are there other topics that you would 8
see that we're not covering in today's meeting besides 9
just going down a list by list item of the items that 10 you would want to see more engagement of before we move 11 forward?
12 MR. SLI DER: John, I don't know. Can you, 13 is my line open? I don't know if you can hear me.
14 MR. LUBINSKI: I can hear you. You're 15 open.
16 MR. SLIDER: Okay, great. Thank you.
17 Well, we also, yes, we'd like to go through the items 18 one by one if we can. And we understand that's a tedious 19 process, but it would really help us to understand the 20 staff's thinking about their requirements that they 21 chose to retain. Some of the narratives that's 22 provided in the Enclosure to the SECY are very thorough 23 and complete. Some look like they're just cut and 24 paste, boilerplate language, which isn't so helpful 25
62 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 as some of the lengthier detailed ones. So we'd like 1
to go through what's there.
2 We did identify one of our comments on 3
5071-Echo, which doesn't seem to appear in t he staff's 4
response, and we wanted to discuss that as well, see 5
what happened to that comment.
6 And then just, the other issues, John, 7
nothing comes to mind other than helping us to 8
understand what the staff decided, the basis for the 9
decision, and then a ny opportunity to help that where 10 we can help to do anything at all to expedite the work 11 that we have to happen before you enter into the 12 formality of rulemaking.
13 Andy makes a pretty convincing case on the 14 rulemaking description slide that this effort, t he 15 results of this effort are heading into a bog and none 16 of us, neither you all nor us have any idea how we're 17 going to get through all of that in a reasonably timely 18 way. So anything that we can do in that subsequent 19 meeting to talk about options or pri orities or other 20 things, I think that would be helpful to us, John.
21 MR.
LUBINSKI:
Thank you for that 22 clarification, appreciate that.
23 MR. SLIDER: Thanks for the question.
24 MR. KLUKAN: Okay, Melinda, we'll go back 25
63 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to the phone. Could you please unmu te our next speaker?
1 OPERATOR: Andrew Mauer, your line is 2
open.
3 MR. MAUER: Hi, good morning. Can you 4
hear me?
5 MR. KLUKAN: Yes, we can hear you. Thank 6
you.
7 MR. MAUER: Oh, great. Thank you. This 8
is Andrew Mauer from NEI, and I really just wan ted to 9
reinforce some of the comments that Jim had and also 10 appreciate the staff for holding this meeting today 11 and for their efforts on this.
12 As you know, we've gotten nearly 300 13 reporting requirements that the industry is faced with 14 submitting and the NRC effort on this project is only 15 a fraction of the effort that the industry expends 16 submitting the hundreds of reports to the staff each 17 year. And, obviously, we believe that time and 18 attention would be better spent focused on what's most 19 important to safety.
20 So this last discussion on the industry 21 comments, you know, we're faced with a situation today 22 where over half of the industry comments have been 23 dispensed with or taken off the table without 24 explanation. And so there's not really an opportunity 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in the process, as we sit here today, to really have 1
the discussion that we think is warranted on those.
2 They simply have been dispensed and the rulemaking plan 3
is scheduled to follow in eight months with those taken 4
off the table. We don't know why thos e comments were 5
not addressed. We have a question on the slide in front 6
of us that asks about how the riskSMART decision -making 7
framework was applied and, hopefully, if we have a 8
follow-up meeting, as we hear the disposition of those 9
comments in a more wh olesome way, we can actually 10 understand, I would offer from the NRC staff how that 11 riskSMART framework was applied in dispositioning those 12 comments and continuing on the path that you're on right 13 now. So we look forward to any potential meeting on 14 that.
15 But as we sit here today, with most of those 16 comments taken off table, we see this really as a missed 17 opportunity. What we, I guess I'm not clear on whether 18 this effort is part of the transformation effort or 19 not. Jim pointed out that the word wasnt u sed in the 20 paper. What we see before, what we see before us is 21 sort of a compilation that's incremental change.
22 So I guess I would just sit here maybe 23 asking the question, you know, is this intended to be 24 transformation and modernization or is it being looked 25
65 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 at as a complex set of incremental changes?
1 And then, you know, finally, I would ask 2
a question also on sort of the overall schedule. Andy 3
had a slide up that goes to the different parts of the 4
rulemaking process. And as we've heard today, we've 5
spent four years on this already. I would ask for, 6
what is the schedule that goes along with that process?
7 So they list, you know, a set of incremental change 8
here, you know, we've already invested four years.
9 What is the schedule going forward to cont inue on this 10 effort? So just a few questions there and some 11 comments. Thank you.
12 MR. KLUKAN: Thank you for that. I just 13 want to see if the NRC had any response before I go 14 to the next question. If not, I'll move forward.
15 Okay. While they're thinki ng about it, I'm going to 16 reiterate that if you would like to ask a question, 17 please press star one or a question will come up, please 18 press star one on your phone or enter the question or 19 comment into the question/answer function into the 20 Webex portal.
21 MR. LUBINSKI: Hey, Brett, I think you're 22 looking for questions and comments. I'm going to go 23 back to Andy's comment. This is John Lubinski. Not 24 Andy, sorry, Andrew Mauer, jumped in there, and you 25
66 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 had a lot in there, Andrew. I think your big question 1
you had, most of them were comments, I think your 2
question was really how are we looking at this from 3
a transformation vice incremental changes is what you 4
referred to there.
5 And I think you're really hitting that in 6
a wide range of items. You know, tran sformation does 7
envelope many things we do. In looking at this, we 8
did step back and try to look at this across the board, 9
and that's why we had so many similar type comments 10 and it was based actually on recommendation from NEI 11 to look at similar type rep orting requirements and 12 handle them in a similar type -way, so we are doing that.
13 We are doing that as part of this process.
14 Are we looking at every one of our reporting 15 requirements that we have in regulations beyond those 16 that were provided in comments? And the answer to that 17 is no. We're looking at comments that we received, 18 and how we can address those. We are going to look 19 as we move forward from the standpoint of how can we 20 be more effective and efficient if we were to change 21 some of the requirements that were listed here, and 22 most of these being reported in recordkeeping as we 23 continue to move forward to determine are there more 24 effective ways, and can we be more innovative in 25
67 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 transformation in the way we do that?
1 I think just the fact that the word 2
transformation is missing from an information paper 3
that was sent to the Commission doesn't mean that we're 4
not continu ing to look in innovative ways of doing 5
things, and we'll continue to do that.
6 So I just wanted to address that. Many 7
of our activities may not be captured under a, you know, 8
specific "transformation" item at the Agency level, 9
but this is clearly someth ing we're continuing to look 10 at mindset to continue to be innovative, and we'll 11 continue to do that.
12 And I do appreciate your other comments 13 that you had as well, and many of those were reiterated 14 what was said earlier.
15 I would ask the NRC staff and ma ybe we might 16 have to get clarification back a minute ago from Jim's 17 comment on 5071-E being missing from the table. Can 18 I ask from the NRC folks, Andy Carrera, is that something 19 that was not included in there or was it included 20 somewhere else that was not easily identified? And 21 if there is a question about that specific one, we do 22 have time now, can we address it?
23 MR. MAUER: Hi, John. Yes, we do see the 24 5071-D, but we have not seen 5071 -B in the submittal.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Perhaps we can go back and check on the orig inal 1
submittal of that.
2 MR. LUBINSKI: Okay, so it sounds like the 3
response to the question is we'll have to follow -up 4
on that one. There was no intent to not include it 5
if it was part of the comments, correct?
6 MR. MAUER: That is correct, John.
7 MR. LUBINSKI: Okay, thank you.
8 MR. KLUKAN: Okay. Now I'm going to go 9
to, we have three questions or comments and questions 10 in the portal from Ernest Bates, B -A-T-E-S. I'm going 11 to go through them one by one. I'm not going to, so 12 I'm going to reach each one, wait for an NRC response, 13 and then move to the next one, and then we'll go back 14 to the people on the phone.
15 So the first comment and question by 16 Ernest: The nuclear industry participants prepared 17 a
list of burdensome and unnecessary reporting 18 regulations. But I do not see the list that the NRC 19 staff itself prepared. Did the NRC staff perform a 20 review at all or did they completely rely on the 21 industry? And I'll turn it over to the NRC staff for 22 the response.
23 MR. CARRERA: I guess, this is Andy.
24 Thank you for that comment and question. So the NRC 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 staff did their own review. We did solicit internal 1
reporting of staff input just as we did with external 2
stakeholders, and comments were provided. And if you 3
look at the Evaluation Summary that we published under 4
the submittal affiliation, you would see where it's 5
indicated that NRC, that would be the NRC staff, comment 6
and not NEI's.
7 MR. KLUKAN: Okay. Thank you, Andy. So 8
next from Ernest. As an example of Jim Slider's comment 9
on the need for input from the industry on the list:
10 Item 4 on the list, and that's Item 4 on the list 11 indicates that the NRC misconstrued the most common 12 comment made by the industry. The intent was not to 13 suggest a 60 -day reporting period for a summary of 14 emergency plan changes. The intent was a) to eliminate 15 the nonessential reports; and b) to align the remaining 16 essential reports around a common reporting period or 17 deadline, which would point more to a 24 -month period 18 applicable to FSARs and QA procedures.
19 Again, let me read that one more time just 20 for the sake of the staff. As an example of Jim Slider's 21 comment on the need for input from the industry on the 22 list: Item 4 on the list indicates that the NRC 23 misconstrued the most common comment made by the 24 industry. The intent was not to suggest a 60 -day 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 reporting period for a summary of emergency plan 1
changes. The intent was to a) eliminate nonessential 2
reports; and b) to align the remaining essential reports 3
around a common reporting period or deadline, which 4
would point more to a 24 -month period applicable to 5
6 Again, and I'll turn it over to the NRC 7
staff for a response or follow -up at this time.
8 MR. CARRERA: Hi, Brett. Thank you. So 9
I'm in communication with the organization who rev iew, 10 who was responsible for reviewing that 5054 -Q 11 requirement on Number 4 to see if they have any comment 12 or response on that.
13 MR. COYNE: Andrew, this is Kevin. So I 14 think while you're waiting for the Subject Matter Expert 15 to get queued up, I think on e general comment we can 16 make is the staff did consider the suggestion to 17 eliminate reports or go to a much longer reporting 18 frequency in general, and the way the table is 19 structured, you know, if we said hey, we would put it 20 into the process or accept it into the process, and 21 we look at 60 days, that really should be interpreted 22 as we didn't look at whether we could eliminate the 23 report or go to a much longer reporting frequency and 24 the piece of the comment that the staff was going to, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you know, put into t he process for consideration of 1
rulemaking was the specific item that we had mentioned.
2 So, you know, I don't know that it's correct 3
to say we misconstrued it. We did consider it in the 4
way that many of the NEI comments were structured.
5 You know, it wa s can you do A? If not, can you do B?
6 If not, can you do C? And so we went through that 7
process and evaluated them in general, and I think for 8
this specific one we had to get the Subject Matter 9
Experts to speak. But I think when you see that in 10 the tab le, that's how they would interpret what the 11 table is trying to convey.
12 MR. CARRERA: Thank you, Kevin. And I 13 think Bob Kahler, who is the Subject Matter Expert for 14 this particular requirement will be chiming in.
15 MR. KAHLER: Yes, with regards to the 16 comment about the reporting requirements for EP changes 17
-- can everybody hear me, I guess?
18 MR. CARRERA: Yes, Bob.
19 MR.
KAHLER:
Okay.
With that 20 requirement, that's 5054 - Q5, it was suggested by NEI, 21 or it was a comment received that we either eliminate 22 the reporting requirement all together as it is 23 something that the residents could look at, or to extend 24 it to a 24-month period.
25
72 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And it was, as we had discussed before, 1
it was something that we did look at quite extensively, 2
got our regions involved i n it as it is part of 3
inspection to an annual inspection process, I should 4
say. And the evaluation was assessed against the 5
significance of the changes that have typically been 6
submitted to us and where that reporting requirement 7
fit into the inspection p rocess.
8 And so we did evaluate it against other 9
type of change submittals, and it was decided that going 10 to 60 days could be something that could be done in 11 order to help reduce burden of submitting changes with, 12 rather than submitting changes in 30 days, and still 13 maintain our oversight capabilities and ensuring that 14 the emergency plan maintained effectiveness and being 15 able to be implemented.
16 But there was a lot of, I just wanted to 17 let everybody know that because the comment was 18 submitted with a reco mmendation as to what it could 19 go to, we looked at that first, and then we looked at 20 what could be, something we could recommend as far as 21 EP plan change. And that was the fallout on that one, 22 but we comment. Those are things that we look at going 23 into t he future, that we're making process goes along, 24 and we have it out there so we can always take that 25
73 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 feedback and ascertain again what our process was to 1
reach the conclusion of going from 30 to 60 days. Thank 2
you.
3 MR. KLUKAN: Thank you very much. And the 4
last comment from Ernest: Eliminating the duplication 5
of requiring routine reports through all these 10 CFR 6
regulations to NRR and requiring the same routine 7
reports be provided to the Region again prior to 8
inspection would result in a "Big Win" in t erms of 9
reducing regulatory burden, particularly when the same 10 records are already available to the NRC resident 11 inspectors in the plant recordkeeping system on an 12 ongoing basis every day.
13 And I'll read that one more time for the 14 sake of the staff, and t his is from Ernest Bates.
15 Eliminating the duplication of requiring routine 16 reports through all these 10 CFR regulations to NRR 17 and requiring the same routine reports be provided to 18 the Region again prior to inspection would result in 19 a "Big Win" in terms of reducing regulatory burden, 20 particularly when the same records are already 21 available to the NRC resident inspectors in the plant 22 recordkeeping system on an ongoing basis every day.
23 And I'll turn it over to the NRC staff for any response 24 or comment.
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CARRERA: Hi, Brett. This is Andy.
1 Thank you so much for that comment. And so that's 2
something that we also discussed during the comment 3
evaluation process and, you know, we discussed that 4
when we looked at what are the ways that we can further 5
make comment submittal more efficient under 50.4, and 6
that's something that we, you know, that's something 7
that we like to, we are considering that in terms of 8
providing a central portal or a central place where 9
licensee would be submitting records. And from t here, 10 NRC would take over and, you know, yes.
11 You know, the region would be able to come 12 to the central site and pull the information when they 13 need it without having to resubmit it to another place.
14 So that's something that we've been talking about amo ng 15 us as well.
16 MR. KLUKAN: Okay. Thank you very much, 17 Andy. And it looks like we have two speakers still 18 in the queue, so Melinda, could you unmute our next 19 speaker please?
20 OPERATOR: Next is from Justin Wearne.
21 Your line is open.
22 MR. WEARNE: Thanks. Andrew, I can 23 follow-up with you on the 5071 -Echo disconnect that 24 we saw. I can just give you call after this and walk 25
75 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you through that.
1 And then back to Ernest Bates' comments 2
on the inspectors requesting information that's alre ady 3
been provided to the Agency. In addition to it being 4
available in the public, or in our records management 5
system, it's also available in ADAMS, and again, Manual 6
Chapter 0620, so that the inspector shouldnt be asking 7
for information that's already p ublicly available.
8 But the reason I wanted to kind of jump 9
on here was, and it's a comment for John Lubinski, is 10 a little bit more detail on this kind of like a follow -up 11 discussion we would like to have is, you know, kind 12 of going through it line by li ne.
13 So kind of one item I've learned in the 14 review that we did of the SECY was that the drug and 15 alcohol reports that we give to the Agency are used 16 to help risk -inform the inspection process. And that 17 was a learning for me, and, kind of, a little bit o f 18 sidebar, like understand how that occurs.
19 But on one that we don't understand, if 20 I could just take a minute here to just kind of walk 21 you through our kind of what we don't understand of 22 what we really want to understand from the staff is 23 take the example of licensing event reports.
24 The staff comments back, provided three 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 rationales for why licensing event reports need to be 1
submitted, and one was for event response. And we 2
really think that 5072 of the Event Notification System 3
covers the event response. So, again, don't want to 4
talk about it now, but we don't understand how an LER 5
is used for event response.
6 The second thing the staff of the three 7
items that is used for inspection planning, and, again, 8
that doesn't kind of jive with what's actual ly occurring 9
in that the inspectors in the region will call us up 10 and ask us, again, for a copy of the Licensing Event 11 Report. So we don't understand how the submittal to 12 Document Control Desk is satisfying that need when the 13 inspectors are calling and as king for copies of it.
14 And then the third thing is what the staff 15 said was that the LERs are used to maintain a record 16 of conformance with the facilities licensing basis.
17 And we don't understand that. We'd like to point out 18 that the LERs, if you're rel ying on LERs to maintain 19 a record of conformance with the licensing basis, LERs 20 may be kind of a faulty input and in that, you know, 21 5069 gives you an exemption to 5073. NUREG 1022 allows 22 engineering judgment to not do an LER, and then more 23 fundamental that not all nonconformances with current 24 licensing basis are documented in LER. So that's like 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what we don't understand.
1 And then what we kind of expected to see 2
was something about how the LERs are used to support 3
research done by our national labs. An d so this is 4
the kind of follow-up discussion we want to have on, 5
and yes, we recognize it's going to be painful and 6
tedious, but we think we can learn things about like 7
why the staff thinks line items are important, and maybe 8
through this we co -understand, and we can help kind 9
of prioritize the subsequent rulemaking effort. Does 10 that make sense?
11 MR. LUBINSKI: This is John Lubinski.
12 Just for me, thanks for the clarification on what the 13 expectations would be if we have such a meeting, so 14 thank you.
15 MR. WEARNE: That's all I got. Thank you.
16 MR. KLUKAN: Thank you. Melinda, it looks 17 like there is one final speaker in the queue, so if 18 we could unmute them, please. Thank you.
19 OPERATOR: Next is from Andrew Zach. Your 20 line is open.
21 MR. ZACH: Good morning. This is Andrew 22 Zach from the Senate Environment and Public Works 23 Committee. I'm just making sure you guys can hear me.
24 MR. KLUKAN: Yes, we can hear you.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. ZACH: Okay. Thanks, just wanted to 1
make sure. And as this tends to happen at th e end of 2
a two -hour meeting, I think some of my observations 3
are probably reflected in comments that were previously 4
stated.
5 First off, I just want to thank the NRC 6
staff. You know, almost four years across the whole 7
organization, you know 40 NRC staff working on this 8
or more, you know, there's obviously a lot of effort 9
that's gone into this process, and I think that really 10 underscores the importance of getting a good end product 11 done, you know, getting some good return on investment 12 for all of the work that you guys have done, for all 13 the work that industry has put forward.
14 And so I really, you know, appreciate what 15 you've done so far, and I really urge you to kind of 16 have to take this opportunity to lean forward to make 17 sure that the end product is me aningful.
18 John, I appreciated what you said that, 19 you know, something doesn't have to say transformation 20 for it to still be transformational as part of, you 21 know, what the Agency is looking at. But I think that 22 that's really important to keep in mind, a nd to take 23 this opportunity that's in front of you to reduce some 24 of this regulatory burden.
25
79 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And when you look at other things that the 1
Commission has done before, for example, Project Aim.
2 You know, there was at least some cleaning up of low 3
priority i tems, and I really hope that this project 4
has a similar meaningful end.
5 I think that the question that I had, and 6
I kind of apologize because, again, some of the stuff 7
has been discussed already, it does feel as though 8
there's perhaps a little bit of lac k of transparency 9
in what comments were screened in and what comments 10 were screened out, but I think my question is for both 11 what was proposed in the paper and the EDO Memo, as 12 well as going forward, what's the actual use of data 13 analysis to go through and actually say these are the 14 things that are productive and that we need to keep.
15 These are the sorts of things. How are you using your 16 experience and data thrashing to form this process?
17 MR. LUBINSKI: Hi, Andy. This is John 18 Lubinski.
Thank you for p articipation today.
19 Appreciate your comments and on the question. With 20 the number of requirements that we have across the board 21 here that have been listed, as we said, there's over 22 a hundred different items listed in the table, some 23 of them have been qua litatively analyzed. Others, 24 where there is data on use of the reports where we tried 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to collect that as we've gone forward, if we go forward 1
in the rulemaking with the ones we have, of course, 2
we would make use of that data that we did have in putting 3
that together in a regulatory analysis. And even if 4
not, even if we don't do a Reg basis document up front, 5
there will be a regulatory analysis that would collect 6
that information going forward.
7 Where there were quantitative
- items, 8
again, they would be captured in the Reg analysis as 9
well. We have not captured the process to document 10 items that would be screened out necessarily to say 11 what kind of analysis, what data was used on those.
12 In some cases, there was data, but in most cases it 13 was qualitative analysis that was performed.
14 MR. ZACH: Thanks, John. I think just the 15 last thing I would close on is, you know, again, the 16 amount of work that's gone in in the nearly four years 17 to look at administrative requirements, you know, and 18 I understand that yo u guys are starting the process 19 of putting together a rulemaking plan to go to the 20 Commission. My understanding is you're allowing about 21 eight months to develop that for the rulemaking plan, 22 and then you have the plan, the Reg basis proposed rule, 23 the final rule, all of this requires public comment.
24 I really urge you to look for ways to, again, number 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 one, making sure that it's a meaningful end product 1
that has a tangible result that validates all the work 2
that you guys have put in and that the industry h as 3
put in, as well as ways to, you know perhaps accelerate 4
the process to get that sooner rather than later just 5
given the length of time and how much back and forth 6
has already gone on. So, thank you guys, and I look 7
forward to continuing to monitor this going forward.
8 MR. LUBINSKI: Thanks for that comment, 9
Andy. I appreciate it.
10 MR. KLUKAN: Thank you as well. Again, 11 at this point, I've read all the questions out loud 12 in the question and answer box, and I think we have 13 gone through our complete qu eue of speakers.
14 So with that, I'll turn it over to Andy, 15 but again, for me personally, thank you very much for 16 participating in the meeting today. So, with that, 17 I'll turn it over to Andy. Thank you.
18 MR. CARRERA: Thank you, Brett. And I 19 want to echo Brett. Thank you so much for our 20 discussion today. You know, we definitely take the 21 feedback and comments provided today to, you know, 22 consider that and inform our process moving forward.
23 And I think that's all I have. I would like to turn 24 this over to John to see if you have anything before 25
82 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 we turn over to Kevin to close it off, John?
1 MR. LUBINSKI: Andy, thank you. I, you 2
know, I thank all the participants today. I appreciate 3
it. I appreciate the different dialogue. We do have 4
a couple of takeaways that we will get back to everyone, 5
so thank you for that. And I want to thank, Andy, I 6
want to thank you. I want to thank Brett. I appreciate 7
you running the meeting today. And I appreciate Lynn 8
Ronewicz and everyone else who supported the meeting 9
today and putting this together. So my thanks, and 10 we will be back in touch. So we can turn to Kevin to 11 close the meeting.
12 MR. COYNE: Okie doke. Thanks, thanks so 13 much Andy and John and Brett. An d I want to thank 14 everyone for their participation and great discussion 15 today. And as John mentioned, we have a couple of 16 takeaways. You know, we look forward to getting the 17 details of the 5071-Echo issue, and we'll definitely 18 follow-up on that, and look at the request for a 19 subsequent meeting to provide a
more detailed 20 background on the information in the table. On that, 21 I can just say there was a thorough evaluation made 22 by the staff, and I can understand a desire to get more 23 of the details, and that's something that we can likely 24 provide.
25
83 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And just to wrap up, you know your feedback 1
is very important to us, and it will definitely inform 2
the development of one or more coordinated rulemaking 3
plan that the staff is going to be pulling together.
4 And I just want to close out with a reminder 5
to fill out the Public Meeting Feedback form. You can 6
find that on the Public Meeting Notification System 7
website, and we definitely use those to help improve 8
our future public meetings. So with that, thanks so 9
much for your participation, and I hope all have a great 10 day.
11 MR. CARRERA: Okay. Thank you, Kevin.
12 And I just one last one. Sorry I'm holding people up 13 here. But regarding 5071 -Echo, those are being 14 addressed in Comment Item Number 31 and 32. As it tu rns 15 out, NRC staff had also submitted it in comment and 16 that's how and we indicated under the NRC staff's 17 comments rather NEI's comment. So that's all. Thank 18 you.
19 OPERATOR: Thank you. That does conclude 20 today's conference. We do appreciate you atten ding.
21 You may disconnect at this time.
22 (Whereupon, the above -entitled matter went 23 off the record at 12:06 p.m.)
24 25