ML22041A455
| ML22041A455 | |
| Person / Time | |
|---|---|
| Issue date: | 02/08/2022 |
| From: | NRC/SECY/CRS, NRC/SECY/OPS, NRC/SECY/RAS |
| To: | |
| References | |
| Download: ML22041A455 (55) | |
Text
1
UNITED STATES
NUCLEAR REGULATORY COMMISSION
+ + + + +
MEETING WITH THE ORGANIZATION OF AGREEMENT STATES (OAS)
AND THE CONFERENCE OF RADIATION CONTROL PROGRAM
DIRECTORS (CRCPD)
+ + + + +
TUESDAY,
FEBRUARY 8, 2022
+ + + + +
The Commission met via Videoconference, Christopher T.
Hanson, Chairman, presiding.
COMMISSION MEMBERS:
CHRISTOPHER T. HANSON, Chairman
JEFF BARAN, Commissioner
DAVID A. WRIGHT, Commissioner
ALSO PRESENT:
ANNETTE VIETTI-COOK, Secretary of the Commission
MARIAN ZOBLER, General Counsel
2
CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS
(CRCPD):
ANGELA LEEK, Chairperson (IA)
KIM STEVES, Past Chair (KS)
PATRICK MULLIGAN, Chair Elect (NJ)
ORGANIZATION OF AGREEMENT STATES (OAS):
AUGUSTINUS (AUGGIE) ONG, Chairperson (NH)
DAVID CROWLEY, Past Chair (NC)
STEVE SEEGER, Chair Elect (TN)
3
1 P-R-O-C-E-E-D-I-N-G-S
2 10:01 a.m.
3 CHAIRMAN HANSON: Good morning, everyone. I
4 convene the Commission's public meeting with the Organization o f Agreement
5 States, or OAS, and the Conference of Radiation Control Program Directors,
6 also known as CRCPD.
7 In this meeting we'll hear from these two organizations on
8 their views on the materials policy and regulatory issues that are of interest to
9 them and to the states.
10 We always welcome an opportunity to meet publicly with our
11 state partners. As my colleagues have noted again and again in recent
12 Commission meetings, nuclear safety is a team sport and certain ly our
13 partners in OAS and CRCPD are an integral part of the team part icularly when
14 it comes to the Nuclear Materials Program. We'll cover those a nd a lot of
15 other issues this morning.
16 And I'd like to just note what a pleasure it was to join my
17 colleague Commissioner Wright at the OAS meeting in Philadelphi a this past
18 August and I saw firsthand the important relationship that exis ts between the
19 NRC and the states. And even in these trying times coping with the pandemic
20 close coordination, collaboration, and communication among our regulatory
21 partners to assure safe and secure issues of radioactive materi als nationwide
22 as we'll hear about today has been exceedingly evident and I lo ok forward to
23 our discussion.
24 Before we start I'll ask my colleagues if they have any
25 remarks they'd like to make.
26 (No audible response.)
4
1 CHAIRMAN HANSON: No? Okay. With that we'll
2 proceed in the order that's listed on the public meeting announ cement, and
3 we'll begin with Ms. Angela Leek from the Iowa Department of Pu blic Health.
4 Ms. Leek?
5 MS. LEEK: Great. Thank you so much, Chairman
6 Hanson, and thank you, Commissioners, for inviting us today. O n behalf of
7 both the CRCPD and the OAS I just want to open our presentation here and
8 thank you for the opportunity to speak with you on behalf of al l of our interests
9 shared across the National Materials Program.
10 The states' partnership with the NRC and the National
11 Materials Program is a critical piece to the effectiveness of o ur shared
12 missions of protecting the public, workers, and the environment across the
13 many aspects of radioactive material in the nation.
14 Next slide, please? Oh, we are on the correct slide.
15 Please stay there.
16 The CRCPD and the OAS share common priorities in
17 radiation protection and we work collaboratively to promote coo rdinated
18 messages and we try to reflect each organization's perspective in a shared
19 platform. And you will see that today. Our coordinated discus sion of topics
20 is an example of these efforts, and so as they share the discus sions of these
21 topics from both the CRCPD and OAS it will be presented by boar d members
22 and board leadership from each organization, but as a combined presentation
23 style.
24 Today you're going to hear from the chair, the past chair,
25 and the chair-elect from each organization, and so as you intro duced, I am
26 Angela Leek, the chairperson for CRCPD. And I'm joined by Kim Steves, 5
1 who's our past chair from Kansas, and Pat Mulligan from New Jer sey, who is
2 our chair-elect. And from OAS we have Auggie Ong, who is their current
3 chairperson from New Hampshire; David Crowley, who is their pas t chair from
4 North Carolina; and Steve Seeger, who's the chair-elect from Te nnessee.
5 Each of us will introduce ourselves as we transition through th e slides as well.
6 Next slide, please? I'm going to start our first discussion
7 with the priority area that we have regarding our health physic s workforce.
8 Again I'm Angela Leek. I serve as the Radiation Control Progra m director for
9 the State of Iowa and I'm the current chairperson for CRCPD, and I want to
10 talk about our HP resources and the technical resources that ar e critical to our
11 ability to protect our public and to maintain our program in ea ch of our states
12 as well as across the National Materials Program.
13 Across the radiation protection community all of the
14 organizations in the federal entities as well as the health phy sics society and
15 other professional organizations are recognizing acutely that t here's going to
16 be a significant percentage of our technical personnel assets t hat are eligible
17 to retire, and this is currently outpacing the number of indivi duals that are
18 entering the profession. This is in part caused from a smaller number of
19 available nuclear engineering and health physics programs, but also coupled
20 with reduced student enrollment.
21 And this contributes to a trend toward a smaller and less
22 experienced cadré of radiation protection personnel that will b e available to fill
23 critical roles across the entire radiation protection community and undeniably
24 the work that the National Materials Program does to ensure pro tection of use
25 of the material is one of those critical areas that will be imp acted.
26 The NRC for many years has supported efforts to foster 6
1 educational opportunities and early career placement through th e University
2 Grant and Student Fellowship Program. More recently the NRC ha s worked
3 to expand eligibility in this program to include health physics in addition to
4 nuclear engineering and also allowing students to meet their se rvice
5 commitment either through state or NRC employment. We apprecia te the
6 efforts of the NRC to work on this and we are partnering with t he NRC to try
7 to manage some of the interim issues while we work to increase the HP
8 workforce through this important work.
9 Next slide, please? Recognizing the fact that we'll be
10 competing for and recruiting from the same and increasingly lim ited pool of
11 technical resources, the NRC and the CRCPD in conjunction with the OAS,
12 and hopefully the Health Physic Society as well, are collaborat ing through
13 organizing a work group under CRCPD's jurisdiction and this new ly
14 established work group will be called the Health Physics Workfo rce
15 Development and Coordination Committee.
16 This is going to be chaired by a CRCPD member, but also
17 co-chaired by an NRC staff person. And we hope to recruit memb ers to help
18 us work through these issues with two major priorities: We wan t to identify
19 opportunities for mentoring and training staff across the state s and the NRC
20 and try to document pathways to more easily integrate and utili ze resources
21 from other states, from the NRC, and across all of our jurisdic tional
22 boundaries, both to help grow the expertise of our staff, lever age specific
23 centers of expertise, and also to help us out if we find oursel ves in a position
24 where staffing of critical assets is reduced.
25 Next slide, please? These priorities are outlined in
26 charges, and so our work groups come together with charges. An d we've 7
1 started with these four to try to develop a process for sharing experienced staff
2 in a resource-deficient environment, try to work through some o f the legal
3 connectivity agreements, and set up some streamlined -- maybe k ind of in the
4 same vein as a reciprocity type of a condition.
5 We also want to facilitate growth opportunities for health
6 physics skills and identify educational opportunities where may be staff can go
7 and visit another radiological program or the NRC to learn some of the skills
8 that might be needed for some of the specialized type of licens ing and
9 inspections that we do.
10 We also want to identify any issues that might arise from
11 credentialing or reciprocity and try to identify mechanisms tha t might be used
12 to advertise for opportunities and really outline where those r esources can be
13 most effectively shared. And we want to maintain an awareness of these
14 resources across the state, local, and federal programs that ar e available to
15 leverage this.
16 For example, a group will work to identify ways to catalog
17 where there are centers of excellence, and that's one of the pr ograms that the
18 OAS is working on identifying across the National Materials Pro gram. And if
19 we can catalog and provide a road map for where these exist and how others
20 who might be outside of that jurisdiction can tap into those re sources we hope
21 that will help to foster a larger community of shared assets as well as provide
22 information for newer radiation control program directors or in dividuals
23 entering the workforce here in our National Materials Program w ho might not
24 be as connected with the existing resources or individuals who might know
25 how to tap into these resources.
26 It should be recognized though that the National Materials 8
1 Program is already really good at leveraging our assets and sha ring across
2 our partnership, but really it is important that as we bring ne w people in to the
3 positions that we're sharing this knowledge and making it easy for them to
4 integrate in with our existing community.
5 We are appreciative of the NRC's ongoing commitment to
6 support training in an inclusive national materials approach as has been done
7 for the decades and we appreciate that moving forward. And we also look
8 forward to exploring how these new initiatives and these work g roup activities
9 can help to proactively address the looming shift in the techni cal radiation
10 world.
11 As this workforce committee kicks of I look forward to
12 sharing some successes with you next time we meet and appreciat e the
13 ongoing commitment and support and coordination from the NRC.
14 Next slide? Next up is going to be Auggie Ong from the
15 OAS.
16 So I'll turn this over to you, Auggie.
17 MR. ONG: Thank you very much, Angela.
18 And good morning, Commissioners, and thank you for the
19 opportunity that you have provided our organization, and especi ally the
20 Organization of Agreement States, too, to have this opportunity to provide you
21 with the updates that -- the ongoing coordination between the N RC working
22 groups and our own organization, the OAS.
23 So that being said, just to remind everybody that the
24 progress report that I'm going to provide the update to the Com missioners and
25 to the attendees is that this is now Phase 3 of a multi-year pr oject. And we
26 already completed Phase 1 under Aaron McGraw and also partially Phase 2.
9
1 So at the completion of the Phase 2 we have moved onto more cri tical
2 changes under the Phase 3 project. That being said, this proje ct is now
3 headed by Leira Cuadrado, who is senior project manager from th e Materials
4 Safety and Tribal Liaison Branch within the NRC organization.
5 So the whole purpose of the Phase 3 is concentrating on
6 revising and taking a look at all the inspection reports, inspe ction protocols
7 that are used by both NRC inspectors and also by our own OAS materials
8 programs where we have commonality in terms of inspecting the v arious types
9 of license and license activities. So that being said, under P hase 3 then we
10 are now concentrating on what are those critical activities tha t would give rise
11 to a greater risk of use of radioactive material and the securi ty of those
12 radioactive materials and sources.
13 So that being said, then that's the whole purpose of revising
14 the inspection protocols and that is to really concentrate on t he riskiest
15 activities and take a look at how well the licensees are managi ng the use of
16 that -- the radioactive materials and how risky it is for both the users and the
17 general public and also the security of sources whereby it's mo re paramount
18 now than ever before. So that being said, all the IPs that we have now -- are
19 revising is concentrating on those riskiest elements, riskiest activities. And
20 any of these lesser risky activities would be delegated to the appendix which
21 I will describe a little bit more later.
22 So the purpose is really finding out whether in fact
23 inspections are doing what it's need to be done; that is, to en sure the safety
24 and the safe use of radioactive materials, safety for both user s and also the
25 general public, and also the security of the materials. And we are now using
26 our past experiences with the inspections that are being collat ed between the 10
1 NRC inspection groups and also the OAS materials inspection gro ups
2 whereby can we learn from what we have done in the past? Can w e do
3 anything better moving forward? And finally, then some of the issues dealing
4 with the safety will certainly be much more relevant now going forward under
5 the National Materials Program.
6 Next slide, please? So as I mentioned before, the whole
7 purpose of the inspection program, inspection protocols that ar e now being
8 revised is to identify those elements that are of risk, risky a ctivities, and making
9 sure that these risky activities would be correctly identified thereby to help
10 inspectors to concentrate on areas that are more important and spend less
11 time that are of activities that are somewhat insignificant, bu t not having any
12 greater impact in terms of protecting the users, protecting the general public,
13 and security of the materials.
14 So it is important then to have that -- of those activities are
15 correctly identified that are now be able to provide the necess ary inspection
16 protocols to both the NRC inspectors and to the Agreement State inspectors
17 so that then there will be a commonality in terms of -- regardl ess of various
18 states doing the inspections or NRC doing inspections. There w ill be a
19 commonality in terms of performance and expectations of the res ults of the
20 inspections and thereby having the same kind of ability to eval uate are we
21 working together effectively?
22 Are we able to have the commonality between both NRC
23 inspectors and the Agreement State inspectors thereby providing that
24 confidence that is needed to the NRC management and also to the Agreement
25 State management that in fact yes, we are able to capture the r iskiest
26 activities, we're able to identify those activities that would be the most critical 11
1 aspects of the inspection and those are covered so that then th at provides us
2 enough confidence that moving forward inspections are done corr ectly and
3 any of the issues are correctly identified thereby providing th e necessary
4 evaluation that yes, the National Materials Program does provid e enough of
5 the inspection protocols, the commonality between the NRC group s and the
6 agreement groups thereby everybody's working together as a team ?
7 Next slide, please? So as an example, on this slide some
8 of the inspection protocols that have now been revised. All ri ght. As you
9 can see they're dealing with the various types of uses of radio active materials
10 and sources. And of course this is only partial, but this is t he completion of
11 part of the Phase 3 whereby these inspection protocols have now been
12 revised and the riskiest activities have been correctly identif ied. The less
13 risky activity have been delegated to the appendix whereby that would help
14 the inspectors, both NRC inspectors and the Agreement State ins pectors, that
15 the activities that inspector ought to be able to spend more ti me in order to
16 make sure those riskiest activities are correctly identified an d correctly
17 inspected.
18 And any of the lesser activities would then still be visit if
19 there is -- somewhere there is a question as to whether in fact there are any
20 issues dealing with the management of the activities or somehow the failure
21 of one critical issue thereby leading to -- leading the inspect or to -- well, if
22 there's a safety issue involved, let's take a look at the other activities that may
23 then have some relevance or some significance to the overall in spection of
24 the entire licensee.
25 So that being said, these inspection program have been, like
26 I said, revised and now have been submitted to the Agreement St ate folks to 12
1 make comments, make any additional changes or recommendations w hereby
2 those comments and recommendation would be brought back to the working
3 group to revisit, to consider seriously, and to revisit if any change is necessary
4 to finalize the inspection program and the inspection procedure s.
5 Next slide, please? So the whole purpose of the updates
6 is to provide the NRC Commissioners and the management that we are
7 working together as a team, both NRC partners with OAS working groups.
8 We are working together. In fact, to demonstrate in fact there is coordination,
9 there's communication, there's back and forth that we -- that N RC is
10 considering the OAS comments seriously and the same thing with the OAS
11 whereby OAS is still relying on the NRC to provide the necessar y leadership
12 so that then we could work as partners together. So that is im portant.
13 And finally, of course then the -- we are under the discussion
14 how -- well, if the comments have been considered seriously and changes are
15 made to the draft of the inspection protocols, what would be th e time frame
16 whereby these IPs would now be finalized, then promulgated to both NRC
17 program and also to the OAS Materials Program whereby now the i nspectors,
18 both newer inspectors with less experience and the more seasone d
19 inspectors, both within the NRC and also the Agreement States, where they
20 will be able to find true value to the revisions that are made to the inspection
21 protocols. So that is under discussion right now. And there i s some time
22 frame that's already been considered.
23 Next slide, please? So under the National Materials
24 Program, as you know then we are now -- have completed the char ter -- not
25 completed -- finalized yet, but certainly the charter that to v isit the future of the
26 National Materials Program. Because obviously the NRC's sphere of control 13
1 is getting smaller, and that's obvious. And also the OAS still has the bulk of
2 the licenses that are various types, same as NRC, but now with the greater
3 control overseeing the activities of radioactive materials in t his country we are
4 now approaching something like more 40, if not more, in the nea r future
5 whereby the sphere of NRC is getting smaller and OAS is getting larger.
6 So that being said, then what the National Materials
7 Program would look like 5, 10, 20 years from now? So that bein g said, then
8 with the formation of this working group, both with the active participation of
9 NRC partners and also Agreement State representatives on the sa me working
10 group to visit this issue, what are we going to -- what do we w ant from the
11 National Materials Program? How are we going to visit the -- i n terms of
12 leadership, training, the various types of, how should I say, t he coordination
13 that's necessary in order to makes sure it's still a cohesive p rogram for the
14 next 5, 10, 20 years from now?
15 So that being said, again I'm glad very much that NRC has
16 reached out to OAS and OAS is very, very appreciative that in f act that kind
17 of coordination now exists whereby now we have a working team, a very
18 effective team under the leadership of Huda Akhavannik, if I ma y pronounce
19 your name correctly, have enact with the NRC intergovernmental liaison
20 person and also project manager under NMSS and NIST Programs.
21 So that being said, there are more than 20 folks that are now w orking on the
22 National Materials Program to visit what the future of NMP is g oing to look like.
23 So next slide, please? Well, thank you very much,
24 Commissioners, for your attention and for the other attendees a ttending this
25 portion of the presentation. And may I introduce Kim Steves, w ho is from
26 Kansas, and she will provide you with the latest updates and al so the 14
1 discussion on waste monitoring, source recovery, and disposal. Thank you
2 very much for your attention.
3 MS. STEVES: Okay. Thank you, Auggie. As he said,
4 my name is Kim Steves and I am the director of the Radiation Co ntrol Program
5 for the State of Kansas. Proud to say we have been an Agreemen t State
6 since 1965. And I'm also the past chair of the CRCPD board of directors.
7 I'm talking today about unwanted radioactive materials,
8 which is an ongoing challenge for our states. There are many v aried waste
9 issues with which our states are dealing on a routine basis. S ome examples
10 of this are unwanted and abandoned sources, medical waste where patients
11 go home after nuclear medicine treatments, naturally-occurring radioactive
12 material or technologically-enhanced naturally-occurring radioa ctive material,
13 NORM or TENORM, and foreign-origin radioactive material.
14 Our states deal with many varied issues associated with
15 disposal of unwanted radioactive material including these mater ials showing
16 up in landfills or at scrap yards and challenges finding places where it can be
17 disposed and money to pay for the disposal. Disposal of this r adioactive
18 material is sometimes addressed inconsistently across our state s.
19 So my purpose in discussing this topic is not anticipation
20 that we can solve the challenges today, but rather to raise awa reness as it an
21 issue that the state radiation control programs are dealing wit h on a daily basis
22 and to inform you of the activities being accomplished by the C RCPD in this
23 area.
24 Next slide? So one challenge is landfills and recycling
25 facilities. States find that NORM and TENORM, medical waste, a nd
26 sometimes licensed material, which could be lost or stolen, is showing up at 15
1 landfills and recycling facilities. With regards to NORM and T ENORM and
2 medical waste different states have different laws with regards to disposal of
3 radioactive material at waste -- in waste at landfills and stat es are often not
4 consistent in how waste issues are addressed or who the regulat ory authority
5 within the state is. For landfills it's typically not the Nati onal Materials
6 Program which has oversight. Landfills also have differing c apabilities
7 to detect and identify radioactive material. Some can detect, as in yes or no
8 there is radioactive material, and fewer can identify a specifi c radio isotope
9 such as iodine-131. Our states are regularly receiving phone c alls and
10 requests for assistance from landfills and recycling facilities about unwanted
11 radioactive material and what to do with it.
12 Naturally-occurring radioactive material and especially
13 TENORM are often the culprit found at landfills and recycling f acilities.
14 Transportation of NORM and TENORM waste occurs between states, but
15 states may handle it differently. Though we understand that TE NORM is not
16 a focus of concern for the NRC, it is an issue of significant i nterest across the
17 states and especially those with oil and gas industries.
18 Some of the issues our states are dealing with pertaining to
19 TENORM waste are the same that we address for other types of re gulated
20 radioactive materials: Harmonizing regulations to the extent po ssible,
21 communications with members of the public, ownership and financ ial
22 assurance, clean up of legacy sites, and disposal.
23 Next slide, please? The CRCPD has been working to
24 assist states with issues associated with the disposal of seale d sources that
25 can be disposed of as low-level radioactive waste. In the 2007 -2008 time
26 frame we did a pilot project in Florida which was very successf ul.
16
1 Approximately 2,500 sources were disposed.
2 One important lesson learned from that was that the state
3 financial services were very cumbersome and each state would do contracts
4 differently. That is why we contract disposal with licensed wa ste brokers
5 through the CRCPD specifically now.
6 And issue in 2008 was the closure of the Barnwell to out of
7 compact low-level radioactive waste. This shut down disposal p athways for
8 more than four years until the opening of the Waste Control Spe cialists low-
9 level radioactive waste facility in 2012. This opened up a new pathway for
10 disposal to all states and territories.
11 Another item which helps in our success on this issue is the
12 revision of NRC's Branch Technical Position on Concentration Av eraging and
13 Encapsulation from 2015. This allows the low-level radioactive waste sites
14 to be able to accept higher activity packages for disposal up t o the Class C
15 limits with acceptable justification, which helped us to manage the process.
16 All these activities evolved into the SCATR Program with
17 CRCPD, which I will discuss further in an upcoming slide.
18 Next slide? The disposal of higher levels of radioactive
19 material is an ongoing challenge because of the limited places that will accept
20 it and the high cost. In the next slides I'm going to briefly mention the two
21 programs in which the CRCPD participates to provide support to states:
22 SCATR and the Orphan State Recovery Project, OSRP.
23 In addition it's important to mention a white paper by the
24 CRCPD E-34 Committee for Unwanted Radioactive Material which wa s
25 recently published on our CRCPD website. This white paper cove rs
26 disposition of foreign-origin radioactive material. The purpos e of this paper 17
1 was to analyze the impact and possible solution for foreign-ori gin radioactive
2 material in the United States which require final disposition.
3 Sources manufactured in the U.S. are able to have final
4 disposition at the DOE Waste Isolation Pilot Plant, WIPP facili ty, however
5 those sources with foreign-origin material are not accepted for dis pos al at this
6 facility. It is challenging to estimate the size of the foreig n-origin rad material
7 problem in the U.S. because the majority of these sources which were brought
8 into the United States were below the NRC Category 2 limits and not tracked
9 in the National Source Tracking System. Reasonable estimates b ased on
10 the data which was collected by our committee show this to be a significant
11 issue.
12 The white paper provides possible solutions to secure this
13 at-risk radioactive material in the United States including con gressional action
14 which is needed to allow the use of WIPP to dispose of all tran suranic
15 materials containing foreign-origin material.
16 Next slide, please? As I mentioned previously, I do want to
17 discuss the Source Collection and Threat Reduction, or SCATR Pr ogram.
18 The Department of Energy National Nuclear Security Administrati on, NNSA,
19 and the CRCPD maintain a cooperative agreement to support seale d source
20 consolidation and commercial disposal at the state level. NNSA funds
21 disposal activities through a cost sharing which is 30 percent and possibly up
22 to 50 percent for higher activity sources. The licensee is sti ll responsible for
23 some of the cost of disposal of this material.
24 CRCPD administers this program through coordination and
25 contracting with waste brokers for packaging, transportation, a nd disposal.
26 The goal is to collect and commercially dispose of sealed sourc es no longer 18
1 in use which could individually or in aggregate be used malicio usly.
2 This program is very successful. To date under the SCATR
3 Program we have collected and disposed of more than 32,000 sour ces, almost
4 1,500 curies, plus an additional over 34,000 industrial radiogr aphy sources.
5 It's very successful over the years to ensure the safe disposal of these
6 materials, but we know there's a lot more out there. Currently one of our
7 areas of focus is working with Cesium Irradiator Disposal Group at DOE,
8 Department of Energy, on that project.
9 Next slide? With regards to the CRCPD Orphan Source
10 Recovery Project, as you know an orphan source generally refers to unwanted
11 or uncontrolled radioactive materials, often a sealed source of radioactive
12 material contained in a small volume. Some of the possible cha racteristics
13 of an orphan source are that it's in an uncontrolled situation or where the
14 responsible party cannot be identified, or where the licensee i s incapable of
15 providing for the safe disposal of this material, or in possess ion of a person
16 not licensed to possess the material, or possibly where the sta te radiation
17 control program took possession to mitigate a radiation threat.
18 An example of orphan sources are measuring and
19 controlling devices containing radioactive materials that were improperly
20 disposed of as scrap metal. Many of our states have had this o ccur, and I
21 can vouch that Kansas had this occur very recently.
22 The work the state radiation control programs have done
23 with their scrap recycling facilities to help them prepare to i dentify and deal
24 with radioactive materials, even though it's typically NORM or TENORM but
25 can also be these licensed lost or stolen sources, also benefit s this program
26 when the materials do fall under the Orphan Source Recovery Pro ject.
19
1 CRCPD has had an agreement and funding from the NRC for several years
2 to assist state programs in disposing of orphan sources, and we continue to
3 provide support for that program.
4 Next slide? So waste and the disposal of unwanted
5 radioactive materials is an ongoing issue for our states. As I stated in the
6 beginning of my presentation, my purpose by discussing this top ic is not
7 anticipation that we can solve the challenges today, but rather to raise
8 awareness as it is an issue that the state radiation control pr ograms are
9 dealing with on an almost daily basis and to inform you of the activities being
10 accomplished by CRCPD in this area.
11 Thank you for your time and I believe the next slide will turn
12 it over to David Crowley.
13 MR. CROWLEY: All right. Thank you, Kim.
14 Good morning, Chairman Hanson, Commissioner Baran,
15 and Commissioner Wright. Thank you for meeting with us today t o honor the
16 partnership that exists between our organizations and to ensure alignment on
17 the future of the National Materials Program, or NMP.
18 For those who do not know me, I am David Crowley, past
19 chair of the Organization of Agreement States, and interim chie f to the North
20 Carolina Radiation Protection Section. In my portion I will be reviewing
21 recent NMP activities.
22 Next slide, please? To start Agreement State programs
23 continue to grow. It seems like only yesterday that Vermont an d Wyoming
24 entered into agreements making 39 Agreement States. Now both
25 Connecticut and Indiana are working to become the 40 and 41st A greement
26 States. Currently Agreement State programs are responsible for nearly 90 20
1 percent of materials licensees nationwide. This will only beco me more
2 skewed toward the states.
3 Is the NMP prepared to support further shifts in regulatory
4 responsibilities? The idea of the NMP is not a new one. In fa ct, it has
5 existed for a couple of decades now. Challenges to the state s pace in early
6 the 2000s continue to be a challenge today, namely the dedicati on of state
7 resources to support national activities.
8 That said, the NMP has made small incremental progress
9 over the years. The NRC provides more opportunities for state members to
10 collaborate through working groups, rulemaking, establishing pr iorities, and
11 supporting frequent communications. The creation of the co-cha mpions has
12 really brought the NMP into focus for our members.
13 I want to extend a special thanks to Duncan White and Terry
14 Durston. These individuals have been critical to the ongoing e ngagement
15 and information sharing between co-regulators. They're evolvin g the NMP
16 from a mere whisper of old pilot projects into an identity that we can all relate
17 to. There was even a new emblem created this past year, pictu red on the
18 slide there, to symbolize the NMP.
19 We must continue to build on this progress to further
20 strengthen the National Materials Program and our co-regulatory
21 partnerships. Each of us brings unique expertise and lessons l earned that
22 can be shared for more effective regulation of our country's ra dioactive
23 materials.
24 Next slide, please? Every year NMP leadership meets to
25 review our goals and priorities. Members from the NRC, OAS, and CRCPD
26 discuss objectives, measure progress on past priorities, and en sure future 21
1 tasks align with our overall mission. This past year we settle d on five
2 categories. These include innovation and developing more risk-informed
3 approaches. For IMPEP this could be updating SA-100 program
4 implementation to better leverage technology and streamline our reviews.
5 Auggie has already discussed some of the changes and
6 ways that we're risk-informing our inspection programs. And we are looking
7 at using a similar approach to evaluate adoption of certain pro gram elements
8 such as regulatory or compatibility changes for states.
9 Next is risk, or rather minimizing it by addressing timely and
10 relevant topics. Steve will discuss some of our efforts to sha re lessons
11 learned throughout the COVID-19 public health emergency. Other topics we
12 continue to evaluate include fusion energy, extravasations, gen eral licensing,
13 and any other emerging issues.
14 Technology and using it maximize our regulatory
15 effectiveness. Enhancements to t echnology can impact the entir e NMP.
16 For instance, changes to the state communication portal. Web-b ased
17 licensing also continues to evolve for those that are utilizing it expanding the
18 NMP's licensing and inspection capabilities.
19 Next people. A little of what Angela has spoken to. But
20 we need to focus on recruiting, training, and retention of our NMP staff. The
21 NMP relies almost exclusively on the training provided by the N RC to grant
22 the foundational knowledge necessary to our members. Thank you for that
23 ongoing commitment to that critical mission.
24 Additionally, we can take advantage of our strengths across
25 the NMP by creating centers of excellence. So far the NMP has formalized
26 a center for emerging medical technology and is in the process of establishing 22
1 one for the Sealed Source and Device Program. We will create more of these
2 as we identify additional needs throughout the NMP.
3 Finally, we want to develop metrics on a broad scale that
4 can demonstrate the NMP's capability in meeting its mission.
5 Next slide? As I hinted at in the technology bullet above, I
6 would like to draw your attention to the NMP's website. Pictur ed here is the
7 current navigation page. NRC staff, contractors, and especiall y the co-
8 champions are working towards revising this page to deploy an i nteractive
9 platform for communication across the NMP. The page will be a resource for
10 historic information, guidance, upcoming events, records of pas t events, and
11 any other useful information for NMP members.
12 In the past there were forums hosted to allow discussion by
13 co-regulators, but those have not been available in many years. This NMP
14 website will include an area for state and NRC staff to log in and discuss time-
15 relevant issues in a safe and non-judgmental space. By includi ng the entire
16 community we can see who else out there may have pervious exper iences
17 and lessons learned leading to better future results when facin g similar
18 scenarios. For example, if a new technology is deployed in one jurisdiction,
19 sharing it through this platform might reveal that others are c urrently working
20 through the same technical challenges.
21 Together we can accomplish more and better meet our
22 safety missions, however this relies on reliable and trusted co mmunication
23 between partners. We hope that the enhanced website will provi de the
24 conduit to make that happen.
25 Next slide? As I began my presentation, the NMP is made
26 up of 40 different regulatory partners and we are still expandi ng. Though 23
1 each of our programs have unique strengths and weaknesses, thro ugh
2 collaboration we will improve in our roles as regulators. This slide provides a
3 few examples of how NMP members come together to support one an other.
4 First, communication sharing. This is necessary to discuss
5 industry trends, new technologies, incidents, or lessons learne d, and to
6 request assistance.
7 With regard to IMPEP we work together to improve the
8 NMP's overall performance. With NRC and state members serving on
9 IMPEP reviews we increase regulatory knowledge and consistency across our
10 programs.
11 Finally, by being contributors. The NMP is vast and diverse
12 and we thrive when every one can contribute. We achieve this i n ways
13 already mentioned, but specifically through working groups, cen ters of
14 excellence, commenting on regulation and guidance documents, an d by
15 participation in meetings.
16 Next slide? I'd like to end by highlighting a few of our past
17 and upcoming activities. For CRCP D they held their first virtual conference
18 this last May, 2021, and they will hosting an in-person meeting this coming
19 year in Tucson, Arizona. And that is May 16 to 19.
20 For OAS we met last August in Philadelphia, Pennsylvania.
21 For the first time we held a hybrid conference and as a result we almost
22 doubled our average attendance. We will be holding our next me eting in
23 Forth Worth, Texas August 15th through 18th. Your own Region I V staff are
24 helping to host this year and we very much look forward to it.
25 Our intention is to stick with the hybrid offering to retain th e increased
26 engagement that we saw this past year.
24
1 The co-champions have hosted a number of virtual
2 meetings for NMP members. These are called Champions' Chats an d the
3 participation levels have been great thus far. These covered t opics such as
4 IMPEP, the public health emergency, remote inspections, informa tion sharing
5 during incidents, communicating of enforcement actions, and mos t recently
6 misplaced sources during shipments.
7 The chats provide an opportunity to engage on topics of
8 interest between the NMP partners and to allow participation fr om staff at any
9 of our organizational levels.
10 The NMP also meets more formally through government to
11 government meetings usually to discuss a particular policy or r egulatory
12 matter. This has included new medical technologies, developing fusion
13 regulatory frameworks, and also more standard rulemaking activi ties. They
14 have proven an effective means to disseminate information and t o engage
15 with our NMP partners.
16 Finally to bring things full circle from the beginning, quite a
17 lot has changed in the last two decades for the NMP, thus we ha ve established
18 a working group to evaluate and make recommendations to the fut ure
19 structure of the NMP, and Auggie spoke a little bit this as wel l in his part. This
20 is just in the beginning stages, but we very much look forward to the group's
21 final report which should be available in a little over a year from now.
22 That is all for my part and I look forward to any questions.
23 Thank you again for this opportunity. Next up we have Patrick Mulligan,
24 CRCPD's chair-elect from New Jersey, and he will be speaking on rulemaking
25 and policy efforts.
26 Patrick?
25
1 MR. MULLIGAN: Thank you, David.
2 Good morning, Commissioners. I am Pat Mulligan and I
3 work for the State of New Jersey and serve CRCPD as chair-elect. I do want
4 to thank you for meeting with us today and am grateful for the time you set
5 aside out of your busy schedules to discuss radiation protectio n issues that
6 are so important to each of our organizations. I am going to d iscuss
7 rulemaking and policy efforts this morning.
8 The CRCPD and OAS recognize and appreciate the efforts
9 of the NRC over the past several years to improve the rulemakin g process,
10 especially the work it has done by the Rulemaking Center of Exp ertise. The
11 continued work on innovative approaches to rulemaking have prod uced
12 numerous enhancements that provide opportunities to streamline the process
13 while maintaining the quality and effectiveness of the rules. As the NRC
14 continues to work on enhancements to key areas of the rulemakin g process
15 we encourage the continued focus on the importance of stakehold er input and
16 involvement.
17 Both CRCPD and OAS recognize that there are many
18 opportunities for collaboration on rulemaking throughout the pr ocess and both
19 organizations strive to make the most out of those opportunitie s. We also
20 recognize and appreciate the efforts that the NRC has made to b e inclusive of
21 the state perspective and the many opportunities to provide fee dback through
22 participation on working groups, task forces, and other rulemak ing teams. As
23 the NRC continues to work toward rulemaking enhancement in the coming
24 years we encourage you to continue to look for opportunities to engage state
25 stakeholders in the process to ensure the development of the ti mely and
26 effective rules.
26
1 Next slide, please? The CRCPD is working to become
2 more agile and responsive to NRC rule changes through the work of the
3 Suggested State Regulation Council. The SSR Council develops d raft rule
4 language for states to use as templates for the implementation of radiation
5 protection rules and regulations. The process is collaborative and we strive
6 to ensure consistency across state programs. The Suggested
7 State Regulation Council created a Compatibility Tracking Worki ng Group to
8 create a more agile process for evaluating and addressing NRC regulatory
9 amendments. The goal is to ensure prompt evaluation of rule com patibility and
10 make suggested edits and recommendations for suggested state re gulation
11 updates within 60 days.
12 The NRC's interpretive rulemaking process can be an
13 effective and agile mechanism to provide a timely and effective response to
14 critical needs regarding applicability of a rule. There are a number of
15 variables that influence how state programs can operate in vari ous regions of
16 the country that can raise questions regarding the applicabilit y and
17 implementation of rules and regulations.
18 The NRC interpretive rulemaking process provides a
19 mechanism to clarify the language in a rule or offer advice on implementation
20 when these discrepancies arise. This process is a valuable way to provide
21 additional guidance to state stakeholders without the need to g o through the
22 cumbersome rulemaking process. The interpretive rule allows for clarification
23 of language and compatibility options for effective application of regulatory
24 requirements and can be quite effective.
25 Next slide, please? To illustrate the implementation and
26 outcomes of the interpretive rulemaking process I will briefly discuss two 27
1 examples. Last year the Nuclear Regulatory Commission withdrew a
2 proposed interpretation of its very low-level radioactive waste regulations that
3 would have permitted licensees to dispose of waste by transferr ing it to entities
4 who hold specific NRC exemptions.
5 The proposed interpretation was withdrawn based on the
6 NRC staff's assessment that the proposed changes may not benefi t the
7 regulatory framework. That assessment was certainly influenced by the
8 public comment including feedback from OAS. And this is a good example
9 of how the interpretive rulemaking process can work quite effic iently and
10 effectively and in the best interests of the stakeholders.
11 In the case of the two-person rule related to industrial
12 radiography we believe that there are opportunities for improve ment.
13 Because of the length of time between the initial petition for rulemaking and
14 the time the interpretive rule was issued the outcome was perha ps not ideal.
15 From the time the petition was filed to the day the public noti ce was issued
16 there were multiple changes in leadership, both at OAS and CRCPD, and the
17 original basis for the rulemaking petition may have been lost.
18 Over time, experience, and lessons learned regarding the
19 interpretation and applicability of the two-person rule changed of perspective
20 of state regulatory agencies. In the end by the time the petit ion was acted
21 upon the state regulatory perspective had evolved and the origi nal basis for
22 the rulemaking petition no longer existed.
23 Collectively I think we need to explore innovative ways to
24 reevaluate and reassess rulemaking petitions that do not get a high priority for
25 action and may be dormant for extended periods of time so that when
26 resources are applied for rulemaking that the need is still app licable.
28
1 And I'm going to go on and I'm going to briefly mention two
2 additional rulemaking topics that are actively receiving attent ion from the NRC.
3 First, the Commission recently issued their decision on the ree valuation of
4 Category 3 source security and accountability. The original pa per that served
5 as the genesis for this decision was the result of an NRC and O AS Working
6 Group established in 2016 to address general licensing topics. The paper
7 also served as the basis for continued work on a holistic revie w of a general
8 licensing program by NRC, OAS, and CRCPD.
9 Last year the OAS board asked CRCPD to create a working
10 group to look at the recommendations the General Licensing Work ing Group
11 pulled together since 2016. CRCPD was asked to identify best p ractices and
12 compile ideas that Agreement States could implement to address some of the
13 issues identified in the General Licensing Program structure. They also
14 tasked us with looking at important areas where regulatory chan ges may be
15 considered.
16 Now that the Commission has provided direction on the
17 issue to staff, both OAS and CRCPD encourage continued close co llaboration
18 to evaluate the impacts of the Commission decision on the recom mendations
19 developed by the General Licensing Working Group and whether to
20 reconsider regulatory changes. The CRCPD working group will wo rk in
21 conjunction with OAS and NRC on how to best proceed with the de cision
22 framework provided.
23 And finally, the Nuclear Regulatory Commission's proposed
24 rule on emergency preparedness for small modular reactors and o ther new
25 technologies originally published in the Federal Register in May of 2020.
26 Both OAS and CRCPD provided comments to the NRC on the proposed rule 29
1 during the public comment period. We understand that NRC staff
2 recommendations do not require the establishment of emergency p lanning
3 zones for these technologies, therefore no requirement for coor dination with
4 off-site response organizations.
5 We recognize that the level of risk for small modular reactors
6 and other new technologies will be less than that for current g eneration light
7 water reactors. We agree that a graded approach to off-site em ergency
8 preparedness is appropriate for these technologies and we do su pport the
9 concept that the EPZs sites may be determined based on the leve l of risk and
10 consequences of the range of postulated accidents. However, we do have
11 serious concerns for those approaches that result in EPZs that are limited to
12 the site boundary and have no off-site emergency response invol vement.
13 EPZs and emergency plans are provided to provide
14 defense-in-depth for low-probability, high-consequence events a nd are meant
15 to provide a well-defined methodology to reduce potential publi c exposures to
16 unnecessary radiation. While the probability for significant r eleases of
17 radiation for these technologies may be low, it's not zero. An d we believe
18 that the establishment of emergency plans that include off-site participation is
19 warranted.
20 The processes and knowledge required to assess fission
21 product releases are complex and we cannot overemphasize the cr itical need
22 for experienced off-site response agencies to be ready if there would ever be
23 a need for independent assessment of an accident at a nuclear p ower plant
24 regardless of whether it will exceed a PAG.
25 State and local agencies are responsible to communicate
26 impacts and risks of emergency events to their citizens and com munication is 30
1 the key to effective public messaging. There should be a requi rement for
2 these facilities to support maintenance of these key minimum as pects of
3 nuclear power plant response and we would be happy to discuss o ur position
4 in more detail with the Commission should you like to do that.
5 I would also like to thank you for your time. We welcome
6 any questions at the end. And I will now turn it over to Steve Seeger from
7 Tennessee. Thank you.
8 MR. SEEGER: Thank you, Pat.
9 Good morning, Commissioners and thank you for the
10 opportunity to share these important topics here today. My nam e is Steve
11 Seeger. I'm from Tennessee and I'm the OAS chair-elect. I wil l wrap up the
12 last of our topics here today and I will be discu ssing the COVI D-19 pandemic
13 and success through disruption.
14 Next slide, please? At the beginning of the COVID-19
15 pandemic the NRC used its existing authority to consider granti ng relief from
16 specific regulatory commitments through exemptions from regulat ory
17 requirements, amendments to license conditions or technical spe cifications,
18 and enforcement discretion under certain circumstances.
19 Next slide, please? The NRC issued the following
20 guidance documents outlining the regulatory options to seek reg ulatory relief
21 that might be necessary during the COVID-19 public health emerg ency.
22 On May 21st, 2020 guidance issued where a licensee could suspe nd
23 the use of licensed material and place material into safe stora ge.
24 On May 27th of 2020 guidance was issued pertaining to
25 radiological emergency response plans during COVID-19.
26 On July 1st, 2020 inspection guidance during transition from 31
1 COVID-19 mandatory telework for the Nuclear Materials and Waste Safety
2 Programs.
3 Next slide, please? OAS knew that many states had
4 questions and were wanting to make sure that they were handling inspections
5 correctly during the COVID-19 public health emergency, so OAS p rovided the
6 following guidance for consideration by state programs while fo rmulating their
7 policies, but also to aid licensees in identifying how things a re addressed in
8 the various state programs. The Champions' Chats have also bee n a big
9 help for states during the COVID-19 pandemic.
10 Next slide, please? So radioactive material inspections
11 have been impacted by the COVID pandemic is several ways: In m any cases
12 the licensee has imposed limitations on entering their facility.
13 Some health care facilities at times are so overwhelmed with C OVID
14 that they have requested inspections be postponed due to the pr evalence of
15 COVID in the facility and the lack of sufficient staff to handl e the patient load.
16 Some licensees are requiring everyone entering their facility
17 to show proof of vaccination prior to entry and the states don' t -- and some
18 states don't have the ability to require inspection staff to be vaccinated.
19 Some licensees require everyone to wear masks while
20 inside their facility and some inspectors claim to be unable to wear masks due
21 to certain health conditions.
22 It has been common to announce inspections since there
23 are so many possible limitations to entering these facilities d ue to COVID.
24 We have seen the emergence of both completely virtual radioacti ve material
25 inspections as well as what some are calling hybrid inspections, virtual being
26 entirely by remote means using whatever platform works; example s are Zoom, 32
1 FaceTime, GoTo Meeting, Teams, Webex, etcetera, and hybrid bein g a
2 combination of remote combined with an abbreviated on-site phys ical
3 inspection.
4 Hybrid inspections generally involve initiating the inspection
5 by phone and/or video-conference. Interviews can often be cond ucted by
6 phone or video-conference and many of the records can be provid ed and
7 reviewed remotely. This approach seems to be working in most c ases and
8 reduces the impact on the licensee. It can also reduce the ris k to the
9 inspector. The platforms being used still allow the inspectors to see the
10 facility and how they are doing their process and procedures.
11 Virtual inspections generally require more than one phone
12 call and more than one virtual meeting to complete the inspecti on. Although
13 hybrid inspections are sometimes awkward inspectors have provid ed a lot of
14 positive feedback now that they are getting used to the process. Licensees
15 have also expressed appreciation due to reduced time impacted.
16 Next slide, please? I'm sorry. I didn't mean to go to this
17 slide. Sorry.
18 And so some IMPEPs are also being affected by COVID-19
19 and some of them are being done virtually. This has helped IMP EPs to
20 continue in those states that might have high COVID cases and w here most
21 staff are working remotely. Virtual IMPEPs do lack the in-person aspect of
22 getting to know the team and the state program staff which migh t help a team
23 to get a better idea how everything is going and being in perso n does make it
24 easier to talk with each other.
25 In-person and virtual IMPEPs have been successful during COVID-19.
26 Next slide, please? Thank you to the NRC, CRCPD, and 33
1 OAS for the continued coordination across the National Material s Program.
2 This coordination has helped the National Materials Program to move forward
3 in a positive direction.
4 Next slide, please? So this completes our presentation of
5 topics and on behalf of the OAS and CRCPD we would like to thank the
6 Commission for the opportunity to have this discussion and we l ook forward
7 to addressing any of your questions.
8 CHAIRMAN HANSON: Thank you very much, Steve, as
9 well as Angela and Auggie, Pat, and David and Kim for all of yo ur
10 presentations. We'll begin questions this morning with Commiss ioner Wright.
11 COMMISSIONER WRIGHT: Thank you so much, Mr.
12 Chairman, and good morning to each of you. Thank you for your
13 presentations as well.
14 I really look forward to this meeting each year, maybe not
15 as much as I look forward to attending your meetings each year and I look
16 forward to seeing you again at those meetings this year as well.
17 When I joined the Commission back in 2018, much of the
18 discussion focused on the development of the Nuclear Materials Program and
19 the desire to form a more meaningful partnership as co-regulato rs, because it
20 hasn't always been in a great way.
21 I'm really excited to see how much progress that's been
22 made since 2018 when I started. And I really value the partners hip and I know
23 the NRC Staff has been working very hard and very closely with you and I just
24 think that's great.
25 So, Steven and Patrick, I want to congratulate you on your
26 selections as Chairs Elect and I look forward to working with y ou as you go 34
1 through your journey to obtain the most prized positions in you r organization,
2 which is that of past Chair.
3 So, we have a lot of work to do between now and then and
4 I look forward to walking besides you as you go down that road. Angela, good
5 morning to you, I'm going to start with you but I'm going to al low people to
6 chime in if they feel the need.
7 The shortage health physicists is an ongoing issue and just
8 so you know, we heard about the Staff's activities to address t his shortage at
9 the Nuclear Materials Users Business Line meeting last month he re at the
10 NRC.
11 We've also spoken about it several times at previous
12 meetings with OAS and CRCPD and I've heard the same feedback as well
13 from the Health Physics Society.
14 So, the NRC and states have put some programs in place
15 to maybe try to help address the shortage.
16 For example, the NRC has a grants program that offers
17 cross-training to the NRC's technical training center and we've started
18 discussions with you all on shared resources.
19 So, the question is have we started to see any relief based
20 on those programs and is there anything more we could be doing to address
21 this issue?
22 MS. LEEK: Thank you, Commissioner Wright, for that
23 question and I'm happy to take the lead on this to try to addre ss that question.
24 I think honestly we haven't even seen the bubble of the
25 impending change in our workforce availability yet.
26 I don't have the data in front of me but I know the Health 35
1 Physics Society is working on where are all the radiation profe ssionals, and
2 they have some data they've been compiling about projected time lines and
3 the track of the amount of health physicists and other technica l resources that
4 would be available at various times throughout our future.
5 So, I do really believe we're being proactive right now.
6 We're feeling some of the exodus at the moment, we're seeing a lot of
7 retirements coming but I honestly think we're going to see even more coming
8 through.
9 And even if we have the volume of bodies available, even if
10 we get the pipeline going and we're enticing people to join our very fun
11 profession, from my perspective, I think the level of expertise we'll have or the
12 experience that people have had will be different in our workfo rce.
13 And they're going to need more support, they're going to
14 need opportunities for experiences that don't exist as readily as they did back
15 in the 1950s, 1960s, 1970s, and we're going to need to figure o ut how to help
16 those individuals reach the level of excellence that many of ou r more
17 seasoned and retiring personnel will be taking with them.
18 So, I think we'll be seeing it coming.
19 I think the reason that our Workforce Development
20 Committee is being formed at CRCPD is to try to come up with some interim
21 solutions if we do find ourselves in the position where we have limited
22 resources or even limited expertise, that we make it easier to tap into and
23 share those resources as we work through maybe the dip that's c oming and
24 get ourselves back on track with the efforts that are happening with the grant
25 program and the university program.
26 COMMISSIONER WRIGHT: Does anybody else want to 36
1 comment?
2 MR. ONG: Yes, Commissioner Wright. This is Auggie
3 Ong representing the OES and I'm the current Chair.
4 In any case, OES has now reached out to the Health
5 Physics Society whereby any of the notification from CRCPD that the
6 vacancies are available in the various agencies and programs, I channel those
7 vacancies and the possibilities of those jobs to the HP Society, the Health
8 Physics Society, whereby those jobs would be made available for any of the
9 members at the HPS that are interested in working in the state programs in
10 their respective states.
11 Here are the jobs that are available, so that then I'm trying
12 to help as much as I can to channel the possible candidates tha t are certainly
13 well qualified, because they are HPs, to those state programs.
14 So, in addition, in the near future OES and I will certainly
15 reach out to the American Respiratory Radiological technologist s and again,
16 those professionals who already have the necessary training tha t some may
17 be interested in switching their careers to instead of simply o perating X-ray
18 equipment, they would be interested in doing field work and doi ng inspections,
19 doing any of the regulatory requirements that would be in their respective state
20 radiation control programs.
21 MR. CROWLEY: And if I may real quick, Commissioner,
22 just an example of how we're using our current resources, I spo ke to the
23 Centers of Excellence and the sealed source and device one hasn 't I believe
24 been completely formalized yet.
25 My own state has taken advantage of sharing other state
26 resources, NRC resources, and using our reviewers to help assis t other 37
1 programs and vice versa.
2 And so when we've had shortages of trained staff within our
3 own internal programs, we can lean on other states and partners in a way to
4 continue moving forward with the work that's at hand.
5 So, I think that's a really good way to highlight some of the
6 partnerships across the programs as well.
7 COMMISSIONER WRIGHT: Thank you for that, because
8 one of the things is there are existing people out there that m aybe we can
9 exchange, do trades and those kinds of things.
10 Because we have a lot of people leaving, they're still being
11 trained, I know that, which raises a lot of questions in my min d.
12 How do you get more people in the pipeline and is there
13 more outreach that we can do, or funding opportunities availabl e to get more
14 people interested to get into atract to school and other incent ives out there to
15 keep people in government positions really.
16 So, I look forward to working with you on this issue going
17 forward. Patrick, in the time I've got left I want to go quick ly to you. Pat,
18 thank you for sharing your views on the rulemaking process.
19 Some of the comments you m ade are on point, so thank you
20 for that. It sounds like we've made some progress in increasin g state
21 participation and we're doing some of the earlier stages in the rulemaking
22 process.
23 To me, obviously early engagement is the key on anything,
24 right, and consistent communication as well. So, I'm glad we b oth recognize
25 that as being key to success. One area I think we can do bette r is in the
26 notice of interpretation, or the NOI process.
38
1 This is relatively a new process for us. You mentioned two
2 NOIs related to the low-level waste and the two-person rule, bo th of which
3 would have impacted the agreement states.
4 And my understanding is the NRC was not aware of the
5 extent of the concerns from the agreement states before the pub lishing of the
6 NOIs.
7 What can we do at the NRC to improve communication and
8 coordination in the process there to ensure that agreement stat es' positions
9 and circumstances are considered before we issue interpretation s?
10 MR. MULLIGAN: I think we have a lot of the processes in
11 place right now. I believe there are a lot of Work Groups and compatibility
12 taskforces put together for various issues as they become relev ant or maybe
13 resources are applied.
14 So, I think there are some of those mechanisms in place and
15 there are rulemaking teams that collaborate between NRC, OES, a nd
16 CRCPD.
17 But I think that early on in the process, once the notice is
18 developed, before it's issued we need to touch base.
19 Is this relevant? Is this applicable? Is this something that
20 we need to do today?
21 I think particularly for the case of the two-man rule, what
22 happened was so much time had passed between the time that the petition
23 was picked up and the time that the notice went out.
24 And like I said, we have so much turnover in our
25 organizations I don't know there was anybody left that understo od what the
26 original basis was for that rulemaking.
39
1 And so I think went to go back when we pick these things
2 up and before we proceed to a notice, we need to make sure they 're relevant,
3 they're applicable and that we're essentially on the same page as far as where
4 we need to be for making the rules.
5 I'm not sure exactly when that happens, I know internally
6 there's processes in place that once you start the ball rolling they're hard to
7 stop. And you're kind of focused in your lane about what you n eed to
8 accomplish to get that notice out.
9 And sometimes you forget to look at who is in the other lane.
10 So, we don't want to make the process more difficult by stretch ing it out
11 because you need so much collaboration before you even get to s omething
12 that's put out there.
13 But I think there needs to be that sanity check, like is this
14 something we're ready to go with, are there big issues, do we h ave to have
15 discussions?
16 COMMISSIONER WRIGHT: One, I appreciate your
17 comments there and one of those things that we are striving fo r at the NRC,
18 and I know Staff is really trying to do this as well, constant improvement.
19 Anything that we can do to make it more effective, more
20 efficient, but that doesn't happen in a vacuum so we really nee d your input
21 and we need it to be timely input too.
22 If you see something going awry you've got to speak up and
23 let us know. So, thank you for that and, Mr. Chairman, with th at, I'll turn it
24 back over to you.
25 CHAIRMAN HANSON: Thank you, Commissioner Wright.
26 Pat Mulligan, I appreciated your opening the door on the 40
1 emergency planning zone rule, and if I could I'd like to walk t hrough it and dive
2 down not just with you but other members of the group this morn ing.
3 As you mentioned, the final rule is before the Commission
4 for consideration and I went back and looked at the comments in some detail
5 that CRCPD as well as individual state agencies provided on the rule.
6 And I found them really helpful. And as I was doing that, I
7 became really interested in teasing out the technical aspects as well, on the
8 one hand, and the policy aspects on the other.
9 And of course, in emergency planning this is really an area
10 where these two things kind of come together. I do want to foc us on one
11 thing. CRCPD as well as the State of Iowa provided comments an d in their
12 comments they mentioned of course the emergency planning zone i tself, but
13 also the ingestion pathway zone.
14 And of course, as you know, the rule suggests that when the
15 emergency planning zone is the site boundary, that is at zero, there wouldn't
16 be an IPZ either.
17 And I'm interested in getting feedback from a technical
18 standpoint, your thoughts about the determination of an ingesti on pathway
19 zone.
20 And that's open for anybody, that isn't necessarily...
21 MS. LEEK: Sure, I can jump in since you said Iowa, so I
22 will try to take the first stab at this and the perspective tha t we were coming
23 from that comment.
24 So, with the ingestion pathway zone, obviously that is a level
25 of contamination that would require us to assess the food produ cts and the
26 other things that could be ingested as a result of a radiation release.
41
1 And I think the basis of the comments that we're making
2 even with an emergency planning zone that is within the site bo undary, there
3 will be contamination offsite.
4 So, the basis that's being used for determining that is the
5 EPA PAG manual levels of where a PAG would be exceeded.
6 And so while that is the current standard for making
7 protected action recommendations and it would drive a lot of th e actions that
8 we would take, it doesn't mean there wouldn't be a lot of conta mination pretty
9 significantly offsite.
10 And our population and their perception of radiation are
11 going to be asking questions about this reading they can now ge t in their
12 neighborhood. Even though it's below PAGs, they're going to ha ve lots of
13 questions.
14 And we're afraid that without support to ensure the offsite
15 agencies, both in the emergency phase, even though it's not goi ng to need
16 protected actions, but on the converse, proving zeros or assuri ng our public
17 that it is a relatively manageable amount of radiation that doe sn't require an
18 action offsite is just as important as it is to say that a prot ected action is
19 necessary.
20 And so we may find ourselves with offsite response
21 agencies that have never had a nuclear power-plant in their jur isdiction, never
22 dealt with a fission release before, and not have those network s and those
23 coordinations for those assessments for other types of field mo nitoring in place
24 as effectively as we've built up and have seen very strong emer gency
25 preparedness communities around our existing nuclear power-plan t.
26 So, I think that's the basis. We recognize the risk is low but 42
1 that doesn't mean the public isn't going to be just as interest ed in the
2 contamination that's in their community.
3 CHAIRMAN HANSON: Thank you, Angela. Pat or Kim or
4 others?
5 MR. MULLIGAN: Yes, I can offer just a few additional
6 thoughts. Right now, and the thing that I've been struggling w ith the most
7 from a technical perspective is that number one, as far as I kn ow, there are no
8 approved reactor designs yet.
9 None of them are operable. The assessment for what is a
10 credible emergency or event at one of these plants has been lef t up to the
11 applicant to determine.
12 And so everything that we've looked at from this
13 perspective, where it's going to be below the PAG, is I'm not g oing to say a
14 whole part but it's somewhat theoretical and I think it's prem ature to decide
15 that there's no EPZ that's required prior to the technology act ually being
16 developed, implemented, tested, and the credible accidents look ed at.
17 So, beyond that, I do think that I agree with Angela, if you're
18 looking at a decision point and you're limiting it to the EPA P AGs, I think from
19 a state perspective it's a little short-sighted because there a re things we would
20 be concerned about and things we might be able to do at, say, h alf of the PAG,
21 at 500 millirem, or 100 millirem.
22 You can certainly still save dose to the public at those levels
23 by taking some action but you need to have the offsite response agencies with
24 the ability to assess that through modeling and through experie nce and
25 expertise that we have for those types of sites and reactors in place to make
26 that determination.
43
1 So, while I believe that, again, the risk is low, consequences
2 may be high and certainly public interest is going to be high a nd concern.
3 And I believe there are some things we should probably do
4 and we've proven to pipeline regardless of whether or not a PAG could be
5 exceeded offsite.
6 MR. CROWLEY: And I'll add real quick for you, Chairman,
7 my thoughts on this are it's a twofold problem. One is the tec hnical aspects
8 and I think we can all appreciate and understand that piece of it.
9 The second comes in a little bit to what Angela spoke about
10 to the communities and the communication and will they have tru st that what
11 we say is in fact the case?
12 Is it safe to have those reactors operating in their
13 communities?
14 So, I think the utilities, as we move forward and as we look
15 at this rule and approval of it, one way or another, are we set ting ourselves up
16 to succeed in actually building and operating one of these plan ts with the rule?
17 Will they grant us that social license where it's accepted by
18 the people and actually it can be brought into a community.
19 I think right now especially is a trying to time, a lot of peop le
20 are hesitant to trust facts and science and things. And even t hough we as
21 the technical experts know one thing, we will have that barrier to get over.
22 So, I think being very transparent too and communicating
23 these things and if that means following similar action to what we've done with
24 larger-scale fission plants, perhaps we carry that because that 's what's
25 worked and has been trusted.
26 So, just a few other thoughts.
44
1 CHAIRMAN HANSON: Thank you, Dave. I want to touch
2 on a couple of points here. All of your comments have been ver y, very
3 helpful.
4 To your point, Pat Mulligan, I think it's incumbent on
5 applicants to actually prove to us in their application that si te boundaries is
6 actually technically justified. It's not a default for advance d reactors.
7 So, to your point, the emergency planning zone is going to
8 be maybe different by each design and I do agree that, at least at this point,
9 the conversation is kind of hypothetical.
10 I guess my follow-up question then to each of you is
11 historically, licensees have paid for that offsite emergency re sponse planning.
12 And I certainly understand and I'm very sympathetic to the need for ongoing
13 state and local engagement in this.
14 But I guess my question is then are you as state agencies
15 open to other kinds of funding mechanisms that the Federal Gove rnment
16 might come up with?
17 So, if a licensee, again, hypothetically, has a reactor design
18 where it's technically justified that they have a site boundary then if that
19 funding doesn't necessarily come from the licensee but comes fr om some
20 other program through FEMA or the Department of Energy or some other
21 mechanism, would that be acceptable as long as it supported the offsite
22 response capability that we've been discussing?
23 MS. LEEK: Thank you, Chairman, I'll jump back in here
24 again with a comment on that. I think that fundamentally the s tates are
25 positioned to work within and accept any funding stream that wo uld help to
26 support this.
45
1 I think the focus of this and the desire of the community and
2 the Federal Government is to move and treat capabilities across all hazard
3 spectrums.
4 And so we've been looking at other funding resources and
5 opportunities.
6 Obviously we've had a form of funding that has come
7 through the utilities that states have become very used to. An d it's difficult to
8 make a shift and actually put the risk assessment into the curr ent THYRA
9 process.
10 Many times radiation incidents, because they are of such
11 low probability, they are not designated very high in certain j urisdictions so
12 they may not get designated to tap into those funds.
13 There are other restrictions as far as resources through
14 some of the Homeland Security Funds and have very specific dire ction as far
15 as securing the cities and designations of those entities.
16 So, we can end up with a disparate ability to utilize some of
17 those resources and funds in the current structure that's in pl ace.
18 So, I do think the states would be open to having access to
19 other funds, I just think we need to either look at the existin g funds and find
20 ways to maybe make a stronger checkmark in some of those fundin g streams.
21 Because if you have one of these reactors, you
22 automatically get higher on the list of prioritization of these assets or these
23 funds, if they're not directly funds that cover for this type o f reactor.
24 So, I do think there are options and there are many
25 possibilities we could look at but we definitely have to look a t them. We can't
26 assume they exist now because states have struggled with tappin g into those 46
1 right now.
2 CHAIRMAN HANSON: Thank you. If my colleagues will
3 just bear with me here, I just want to sneak in with one more q uestion. I'm
4 hoping both Commissioner Wright and Commissioner Baran will fin d it useful.
5 Right now under the framework, because we have for large
6 light-water reactors we have a ten-mile emergency planning zone, etcetera,
7 FEMA reviews the emergency plans for those plants and I guess I 'm interested
8 in your views on even, again hypothetically, to Pat Mulligan's point, for a site
9 boundary EPZ, whether FEMA --
10 Even in the site boundary, those reactors will have some
11 kind of emergency response plan presumably. Whether FEMA shoul d still be
12 in the role of reviewing that plan even when the EPZ is zero.
13 Anyone?
14 MR. CROWLEY: It's kind of like our position on the funding
15 as well. As long as it's being done or can be guarantee one wa y or the other,
16 I think we could end up being satisfied, at least our position as stated
17 regulators.
18 It doesn't need to be FEMA, it doesn't need to be NRC.
19 Everyone is comfortable if you continue with the same but I thi nk we would of
20 course be open to either way that would work.
21 We could look further into that if need be.
22 MR. ONG: If I could just make a side note, Commissioner
23 Hanson, and that is in terms of licensing of these reactors, be it more
24 advanced nuclear reactor or even the fusion reactor becoming al igned within
25 the next 20 years.
26 That being said, it's part of the licensing process whereby in 47
1 order for an applicant to get the license approved, the applica nt still has to
2 provide where are the boundary zones, where are the emergency p lanning
3 zones whereby that would then be able to reassure both the stat ed agencies
4 and the general population within the area whereby the plant wo uld be located.
5 In order to get everybody to have a buy-in in terms of
6 allowing the application to be approved. So, that being said, t he negotiation
7 will always be taken place.
8 What would the licensee be applicated in order to provide
9 that kind of assurance to cover any small, albeit low probabili ty of that failure,
10 to continue the material whereby it's now released beyond the s ite boundary.
11 So, that being said, there's still going to be ongoing issues
12 and the state certainly will be very reluctant, if I may add, i n this kind of
13 environment to tap into the state general fund in order to buy that assurance
14 to the communities that in fact there will be emergency plannin g zones, there
15 will be substantial personnel to be able to respond to the poss ibility of the
16 low-probability events.
17 That being said, then certainly if the Federal Government is
18 able to provide some funding source so to speak to help out the states, thereby
19 then everybody will have a stake in terms of getting the techno logy
20 implemented.
21 And for the state government this country's future.
22 So, everybody will have a stake in this eventuality. Thank
23 you.
24 CHAIRMAN HANSON: Thanks, Auggie, I really, really
25 appreciate it. I've run way, way over my time at this moment a nd I really want
26 to thank Commissioner Baran for his patience on this.
48
1 And I know we'll have an opportunity potentially to follow up
2 this afternoon with some more discussion on this point. And wi th that, again,
3 thank you Commissioner Baran and I'll hand it over to you.
4 COMMISSIONER BARAN: Thanks, Chairman, it's been a
5 great discussion. I don't mind waiting an extra few minutes, i t's been very
6 good.
7 I really appreciate all of the insights you all have shared and,
8 really, we value the partnership we have with all of you.
9 My sense is it's really as good as it's ever been, maybe
10 better, in recent times and I think we're all benefitting from that. Pat, thanks
11 for your comments on the two-person rule discussion there.
12 As I try to think through what can we do better next time, in
13 this case the reinterpretation was issued on June 1st and it to ok us back right
14 away. And NRC asked us to have the public comment period follo w the
15 notice of reinterpretation rather than precede it.
16 And this meant the Agency couldn't consider the comments
17 before making a final decision. I think that did not really wor k well. I think the
18 lesson I would draw is agreements made comment, the public comm ents
19 should be considered before the decision is made and not after.
20 I think that's really going to significantly reduce our risk of
21 doing something that ends up not making a lot of sense.
22 I don't know if you have thoughts about that or if your
23 colleagues have any thoughts about that but to me, that from a process point
24 of view is the thing that could be easily changed that would ha ve probably
25 made all the difference in this case.
26 MR. MULLIGAN: I certainly agree with you, 49
1 Commissioner.
2 Public comment prior to implementation is always the best
3 practice I believe and we've seen it work in other rulemaking, not just with
4 NRC but other organizations as well.
5 Everybody benefits from getting that input prior to taking an
6 action.
7 That's first, and I think second too, beyond that, when things
8 are put on hold for a while because the priority is low, I thin k when we pick
9 them back up again they should be filed on the back-burner with a little bit of
10 history so that when we pick them up again, we make sure we tak e the time
11 to ensure they are still relevant topics and that the condition still exists, that
12 whatever petition or rulemaking effort was based on.
13 So, I think that's first, make sure it's still relevant. Then we
14 get the public information and then we take an action to make a decision.
15 COMMISSIONER BARAN: That's a great point.
16 I'd like to ask about something that Kim touched on with her
17 discussion, which is financial assurance for the disposal of CA T1 and 2
18 byproduct material sealed sources.
19 Under NRC's current regulations, many CAT1 and 2 sealed
20 sources are not required to provide financial assurance for dec ommissioning.
21 That means no decommissioning funding plan and no
22 financial instrument in place to cover the eventual transportat ion and disposal
23 costs.
24 This is because the current regulatory threshold for the
25 financial assurance requirement is very high. For example, one of the most
26 commonly used radionuclides is large-sealed sources of Cesium-1 37 as we 50
1 all know.
2 27 curies of Caesium-137 qualifies as a Category 2 quantity,
3 which subjects the source to physical security and source track ing
4 requirements. But a licensee isn't required to meet financial a ssurance
5 requirements unless it's 100,000 curies of Cesium-137, which is quite a bit
6 more.
7 The Commission recently decided to proceed with the rule
8 to extend the current financial assurance requirements to all C AT1 and 2
9 byproduct materials sealed sources tracked in the national sour ce tracking
10 system.
11 I don't know, Kim, if you want to talk about it, or Auggie, can
12 you talk a little bit about the level of support among the agre ement states for
13 this rulemaking? I know that's been a long-time coming to get rolling on this.
14 Let's do that check-in now. How are you all feeling be this?
15 Is this something you think is a good idea?
16 MS. STEVES: I'll let someone from OES take that.
17 MS. LEEK: This is Angela Leek, I'm going to jump in here
18 real quickly.
19 From the CRCPD's suggested state regulations
20 perspective, we have a little bit of history in this topic and have been working
21 on this over the last few years.
22 There has been an interest across the states to figure out
23 ways to better support. Because as Kim did mention, often time s states are
24 left with those open sources or the disposal of a source that h asn't otherwise
25 been required to be financially assured by their licensee.
26 So, we have been working on suggested state regulations 51
1 and have had Committees working on this, very much in line with what has
2 been coming out of in the idea of the sealed sources and the hi gher-category
3 activity sources.
4 However, there was some interest by states to go a little bit
5 lower into almost a generally licensed device arena, not quite, and there's a
6 little bit of discrepancy there on the states.
7 So, I would say from the feedback we've gotten through that
8 process, which is not yet finalized, and now this new initiativ e is out we're
9 going to work to make sure we align our SSR efforts with what t he NRC is
10 working through in discussions, so they align and we're ready f or compatibility
11 at some point in the future.
12 However, I think from the comments we've received from all
13 of our states, there is a general support for doing some effort to require
14 financial assurance, whether that's a full decommissioning plan or not I think
15 can be varied on the level of actual risk from a sealed source versus lower
16 activity sources.
17 However, the higher activity sources I think you'll find a
18 consensus that we agree.
19 As you get down into lower activities or less risk, it gets
20 grayer so finding that level of where to draw the line might be the difficult part
21 but I do think you'll find some consensus across the states in agreement for
22 extending some of those financial assurance requirements.
23 COMMISSIONER BARAN: Auggie, do you want to add
24 anything?
25 MR. ONG: Definitely, thank you for the opportunity to do
26 so. I can only use New Hampshire as an example.
52
1 We do understand that the mom and pop businesses that
2 somehow are no longer able to have enough financial assurance s o to speak
3 for eventual disposal of those sources.
4 And that being said, what we have done in the past and still
5 are doing so is that for any of the material licensees who ship out low-level
6 radioactive waste, New Hampshire charges a certain percentage o f that
7 volume.
8 And the whole purpose of that is to provide a standard loan
9 fund thereby that could be used and tapped if necessary to prop erly dispose
10 of those abandoned sources.
11 So, what it means is that certain licensees will become, so
12 to speak, have a stake in ensuring that, eventually, the state does not get
13 stuck, sort of speak, funding the entire disposal cost of those abandoned
14 sources, where now the state will certainly contribute certain parts to that fund.
15 But the licensees that do ship out low-level waste will also
16 be partners in terms of helping the state to securely dispose o f those
17 abandoned sources.
18 So, that is one mechanism and I don't know of other states
19 doing similar things without having to tap into scattered progr ams or looking
20 for referral government to provide the necessary funding or to dispose of these
21 abandoned sources.
22 We're going to be at the start of this rulemaking and that's
23 going to give us a lot of time to interact with all of you and get your ideas and
24 feedback. We're really looking forward to making progress on t his with all of
25 your help.
26 Briefly, another topic on fusion that got brought up a little b it 53
1 today, we're seeing more interest in fusion technologies and th e development
2 of a regulatory framework for fusion.
3 I know that our partners from Wisconsin and California are
4 on the fusion Work Group with the NRC Staff. I realize we're still early in the
5 process of thinking through options for the regulatory framewor k.
6 Angela, at this point, does CRCPD have thoughts about the
7 appropriate role of states in regulating fusion reactor technol ogies?
8 MS. LEEK: Thank you for the question, Commissioner
9 Baran.
10 I think we have a Work Group, Jeff Samansick is the Chair
11 of the Work Group that's doing a lot of the efforts to stay on par with what
12 discussions are happening as this is evolving.
13 As far as the role of agreement states and the licensing, I
14 think I would defer to the agreement states and hopefully David will bail me
15 out on this to give a little bit of that feedback on what the O ES would believe
16 as far as the agreement states rule in this type of regulatory structure.
17 CRCPD is continuing to keep focus and make sure that we
18 are compiling all of the relevant information so that as this p roceeds we can
19 help to support comments as they come through.
20 MR. CROWLEY: I'll jump in there. Thank you, Angela, for
21 that point of view from CRCPD in their effort.
22 So, as far as fusion goes, we see a lot of different
23 stakeholders with respect to this and I think a lot of the thin gs that we hear
24 from the state perspective is to not lose sight that fusion cou ld mean more
25 than just power reactors, right?
26 So, we have potentially isotope production or different 54
1 industrial and research uses of fusion technology. And sometim es those get
2 attributed more closely to, say, an accelerator facility but it is in fact a fusion
3 process that's going under or taking place.
4 So, if the NRC passes either regulatory language or a
5 framework that goes forward in such a way, a lot of states migh t have issue
6 with all those other technologies being broadly swept up.
7 So, I think where we draw the line and how we delineate
8 between things is important. Additionally, I think the industr y and some
9 states make a case that fusion can be regulated.
10 It's not a fission process, it's not going to have necessarily
11 the same risks, it's not zero risk potential but it'll have dif ferent risks such that
12 the state could regulate those reactors, even if they were on t he power scale.
13 But the appetite from one state to the next to be able to take
14 that on is going to be much different. Some states have very r obust nuclear
15 programs and other ones much more limited.
16 So, my opinion way before we get down the road here, is
17 maybe we would see this as something that could be brought into our 274
18 type agreement. With the agreement state itself, does that sta te choose to
19 take on regulating fusion activities or not?
20 So, just early on but I do really appreciate the coordination.
21 We've had several meetings, both public and government to gover nment, that
22 have really helped bring some of these issues out for conversat ion.
23 COMMISSIONER BARAN: Thanks, Dave, I appreciate it.
24 I have one last question related to greater than Class C low-le vel waste.
25 There's a paper pending before the Commission about a potential GTCC
26 rulemaking.
55
1 Aside from the site in Texas that is potentially interested in
2 disposing of GTCC, has anyone heard interest from any other sit es or states
3 in accepting GTCC disposal?
4 I'm seeing a lot of shaking heads.
5 (Simultaneous Speaking.)
6 MR. ONG: Commissioner Baran, not that I'm aware of, so,
7 certainly, if that question is posed to agreement states then w e will certainly
8 send out a survey to determine the interest of that disposal.
9 COMMISSIONER BARAN: Thank you, I appreciate it, and
10 good to talk with you all, I think it's been a really good disc ussion, thank you.
11 Thanks, Chairman.
12 CHAIRMAN HANSON: Thank you, Commissioner Baran,
13 and thanks again to all the participants. As I said at the beg inning, nuclear
14 safety and security is a team sport and we're grateful for the incredible
15 collaborative relationship we have with both OAS and CRCPD.
16 So, thank you all for being here and your thoughtful
17 responses to all of our questions. Thanks to my colleagues. T he great thing
18 about having such good colleagues is a lot of their questions a re some of the
19 same questions I had.
20 We touched on I think really important topics today,
21 workforce development and program sustainability. Fusion is ce rtainly the
22 issue of the day. Sealed sources security among a lot of other issues.
23 So, I want to thank everyone again this morning and with
24 that, we're adjourned.
25 (Whereupon, the above-entitled matter went off the record
26 at 11:43 a.m.)