ML22140A220
| ML22140A220 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/2022 |
| From: | Office of Nuclear Reactor Regulation |
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| Download: ML22140A220 (68) | |
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UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
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34TH REGULATORY INFORMATION CONFERENCE (RIC)
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TECHNICAL SESSION - T3
PREAPPLICATION ENGAGEMENT FOR NEW AND ADVANCED
REACTORS
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TUESDAY,
MARCH 8, 2022
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The Technical Session met via Video-
Teleconference, at 1:00 p.m. EST, Christopher Hanson,
Chairman of the Nuclear Regulatory Commission,
presiding.
PRESENT:
THE HONORABLE CHRISTOPHER T. HANSON, Chairman,
Nuclear Regulatory Commission
PETER HASTINGS, Vice President, Regulatory Affairs
and Quality, Kairos Power, LLC
MICHELLE CATTS, Senior Vice President, Regulatory
Affairs, GE Hitachi Nuclear Energy
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TARA NEIDER, Senior Vice President and Project
Director, Natrium Demonstration Reactor,
TerraPower, LLC
MICHAEL DUDEK, Chief, New Reactor Licensing Branch,
Division of New and Renewed Licenses, NRR/NRC
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P R O C E E D I N G S
1:00 p.m.
CHAIRMAN HANSON: Good afternoon. It's
a great pleasure to be with everyone and to welcome
you all to Technical Session T-3, entitled
Preapplication Engagement for New Advanced Reactors.
I'm really excited to chair this session
because I personally believe that efficient and
effective licensing of new reactors begins with
successful preapplication interactions. Respective
applicants must understand what's expected from the
regulator, and the regulator must clearly articulate
its regulatory expectations while learning about the
applicant's design and safety approaches. Effective
communication between the NRC and applicants is
crucial.
With the anticipated volume of new
reactor applications in the coming years, effective
preapplication engagements are more important than
ever. The NRC needs to continue to improve our
effectiveness, and I hope our dialogue today can
contribute to that.
We have an excellent panel with a wealth
of knowledge and experience managing new reactor
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licensing projects.
Tara Neider is the Senior Vice President
and Project Director of Natrium at TerraPower. Peter
Hastings is Vice President of Regulatory Affairs and
Quality at Kairos Power. Michelle Catts is Senior
Vice President of Nuclear Programs at GE Hitachi.
And finally Michael Dudek is the Chief of the New
Reactor Licensing Branch at the NRC.
We structured this session in a panel
format to maximize need for dialogue on a variety of
topics related to the reapplication.
We have no prepared remarks or
presentations from the panelists, and we'll jump
right into discussions. But please note that we'll
be taking question from the audience later on in the
session so I encourage you to submit questions
through the platform.
Before we start with the discussion, I
want to highlight a few points on preapplication for
some context. The NRC encourages volunteer
engagement of reactor developers and prospective
applicants in preapplication activities in order to
support timely and effective licensing for new and
advanced reactors.
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Many members are currently in
preapplication engagement and more are announcing
their plans to start engaging on such activities.
Our experience so far has taught us the
importance of a comprehensive approach and a mutually
understood plan for the scope and outcome of these
interactions.
To that end, the NRC recently issued a
draft white paper proposing a robust preapplication
engagement could result in a more predictable,
efficient review due to early identification of
unique design issues and early engagement on
technical issues through topical reports, white
papers and public meetings.
So with that, let's get started. I want
to get your perspective on preapplication activities.
And to kick it off, Peter, Tara, Michelle, all of
your companies have been actively engaged in
preapplication activities with the NRC.
And my question is, quite simply, what's
in it for you? You know, preapplication is not
necessarily an inexpensive endeavor so why do it?
What do you see, as an applicant, has the value of
preapplication activities?
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MR. HASTINGS: I guess I'll start.
First of all, let me thank you, Mr. Chairman, for the
opportunity to be on this panel with this very
esteemed group.
At Kairos Power we've been described as
a good example of what preapplication engagement
should look like. While we've only been in business
for 5 years and only about 3-1/2 years of
preapplication engagement so far, we've had really
good success.
We've had 11 topical reports submitted.
Most of those have been approved or have draft
approvals, and the remaining handful are imminent.
We've had several ACRS engagements. We've got a
construction permit application under active review
with a committed 21 month review standing.
But you're right. It's not cheap. What
we benefit from most is the reduction in programmatic
risk by addressing the topics most likely to be novel
or potentially sticky. We try to group those topics
off of critical path for the actual application
review.
A productive preapplication engagement
also sends very positive signals to the prospective
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customers, to our investors and to the market in
general that we're moving forward in a regulatory
sense.
It also buys us at least some reduced
time one hopes in review of the application itself.
That points to a little bit of a downside, which is
the preapplication effort does not constitute a one
for one tradeoff. In other words, the area under the
regulatory review should in theory be constant. And
every hour we spend in preapplication engagement
ought to buy down an equivalent number of hours in
the actual application review itself. But that's not
likely. That's not been our experience. Making that
tradeoff more predictable -- predictability is what
it's all about actually. It's probably the best way
to encourage a more fulsome preapplication in the
future.
CHAIRMAN HANSON: Thanks, Peter. Tara?
MS. NEIDER: So, sorry, I had to turn off
mic. There was an ambulance going by. But I think
that the preapplication engagement has been very
helpful, and it provides a lot of value.
For us, as an advanced demonstration
reactor awardee, we really have no choice. We have
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to keep our licensing within a very short window. So
the more we can do upfront is going to help us through
the process.
In fact, what our real goal through the
preapplication process is to actually have all of the
issues resolved before you even see it in the safety
analysis report. That way things can go smoothly.
And so far we've had great results.
We've got a great project manager at the NRC. They
provide the right people in the room at the right
time. We've had, I think 13 or 14 meetings so far
with the NRC, and we've submitted a number of white
papers. It's been very, very valuable. And it
really -- I feel that we're very aligned on each of
the issues we discussed.
CHAIRMAN HANSON: Thanks. Michelle?
MS. CATTS: Yes. I want to thank you,
Chairman, and the NRC for the opportunity to take
part in this panel today on this very important topic.
You know, governments and people in the
world are focusing on reaching de-carbonization goals
including our own government to reach net zero
emissions by 2050. From recent events in Russia, it
is evident we need energy independence. Energy
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independence, it also meets our carbon neutrality
goals. Obviously, nuclear is going to be a key role
in that.
We're very excited at GE. We're working
obviously with TerraPower on a natrium reactor. And
we're also working on fulfilling our small modular
reactor, the BWRX-300, to help provide that carbon
free future.
So we're planning to license our reactor
in multiple countries. And in this day and age to
make financial sense, it really requires a change in
mindset for licensing and design.
You know, previously we would license a
reactor in one country. And then when we do a license
in another country, we would change our requirements
and change the design. It resulted in a lot of re-
work.
So instead we're designing our reactor
with international regulations in mind and
incorporating those into a standard design. So our
goal is to have an internationally adopted standard
BWRX-300 design, which provides predictability in
licensing and lower costs.
But if it is our purpose to be
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successful, preapplication is vital, really, to
reduce that regulatory uncertainty for each country's
preapplication processes. So for instance these
licensing topical reports in the U.S., vendor design
review processing Canada and then these
preapplication processes are going to help position
us to officially enter the licensing processes in the
near future in the U.S. and Canada.
And then finally, you know, from our
perspective we see so much value in preapplication
processes that we would really love to see other
countries adopt similar processes.
CHAIRMAN HANSON: Very good. Thank you,
Michelle. Michael, do you want to talk about this a
little bit from the NRC perspective?
MR. DUDEK: Absolutely. Thank you, Mr.
Chairman. So as you know, this is one of my favorite
topics, preapplication engagement. As the Chief of
New Reactor Licensing at the NRC, this is one topic
that always comes up with new applicants. And I
think I can summarize the importance and what it means
to the NRC in an essentially understanding, an
understanding, you know, really fostered in an
environment of setting and understanding common
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expectations between us and the applicants.
A lot of the applicants are new. They
are not familiar with our regulatory processes,
procedures and guidelines. So this gives them an
opportunity to start engaging with us and start
understanding and start setting those common
expectations.
It also helps the applicants understand
the NRC's process and procedures. As I said, some
of these new applicants aren't aware of -- aren't
seasoned, aren't aware of how we do things. There's
a certain way that we apply some of the GDC
requirements and so on and so forth. So it really
gives them a leg up and an understanding of an early
regulatory foothold, per se, of how we do things.
And really third, an understanding of the
design. What is paramount in all of these efforts
is for each applicant to, you know, highlight key
aspects of their design, whether they are new and
unique design features, first of a kind of evolutions
or something that is going to be entirely different.
When we get that application, we must understand how
it works. We ask the critical questions and that
gives us a clear and predictable path for licensing.
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Okay?
CHAIRMAN HANSON: Yes. Thank you very
much. So this is good. Because we kind of
established, I think, a little bit of philosophical
foundation of the discussion. And I want to drill
down just a little bit and Mike kind of stay with you
because, you know, the concept here of preapplication
discussions can be a little bit abstract, right?
And I think we want to -- but I guess,
you know, Michael staying with you, you know, what
are some of the tangible results of preapplication
from the NRC standpoint?
MR. DUDEK: Absolutely. And to easily
answer this question, I often use an analogy is that
us, the NRC, and the applicants are learning how to
dance. And truly while we might step on each other's
feet to begin with and it may be a little awkward,
the more you do it, practice makes perfect. The more
you do it, the better you get, the more understanding
you have and the more that each organization learns.
We learn from the applicant and the applicant learns
from us.
As I reflect on your comments earlier
today, Chairman Hanson, during your plenary remarks,
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as the NRC continues to learn and improve, I think
that's a key element in this aspect. And also, you
know, early identification of potential safety,
security and environmental issues. The earlier we
can get these issues on the table and get them
discussed and have early alignment on them, the
better.
CHAIRMAN HANSON: That's helpful. I
mean, there are a lot of different. I mean, Michael,
thank you for that. There's a lot of different
directions we can go with the whole dancing analogy.
And, you know, we might have a fox trot and a shag
and a waltz here among the panelists, cha-cha, I don't
know.
But let me, you know, I'm going to kind
of go back here in reverse order. And while
acknowledging, I think, you know, Peter, you know,
kind of alluded to some of the goals, I think, for
Kairos, but Michelle, what specifically is GE Hitachi
looking for in that preapplication process?
MS. CATTS: GE has been involved with
licensing reactors for many years. And we do see the
extreme value in preapplication engagement.
So like I said our goal is to create an
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internationally adopted standard design for
predictability in licensing and lower costs. Well,
how do we get there?
We identified the needed exemptions to
regulatory requirements and any alternate approaches
to regulatory guidance and addressed those during
preapplication engagement.
So, you know, what do we hope to achieve?
We hope to create open and transparent dialogue with
the regulators. We want to familiarize the staff
with the technical details of our design. You know,
they are highly beneficial from an issues perspective
for ensuring alignment and understanding of
regulatory expectations.
You know, it's one thing to read a
regulation and provide a submittal. It's another
thing to under expectations and what level of detail
is needed for the NRC to actually complete their
reviews. And we want to reduce regulatory
uncertainty associated with key technical topics
before an application is submitted.
And, finally, again, we want to position
our reactor design to officially enter the licensing
process.
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CHAIRMAN HANSON: Okay. Thanks,
Michelle. No, I really appreciate that. Tara?
MS. NEIDER: So as I mentioned, Natrium
is a demo winner, and actually we're working
collaboratively with GE-H on the design and licensing
of a Natrium reactor.
And I guess the most important thing for
me is that the regulations really have been set up
for light water reactors. And this will be the --
this time period now is when we're first -- the NRC
is first licensing the advanced reactors.
And that knowledge base has primarily
been with the Department of Energy as opposed to the
NRC. And I know the NRC has gone through a tremendous
amount of training on advanced reactors. But this
process is a new one. And when we go through a new
process, we know that the -- what the expectations
are tend to change over time as you see applications
from others and as you get more mature in the process.
So I had an experience early in my career
where we were licensing a spent fuel storage cask,
and it had already been licensed for use at an
existing power plant but then we were trying to get
a generic license. And after we had submitted the
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application, the standard review plan was issued for
our storage.
And I remember going into a meeting and
one of the NRC management people had said, I can't
believe you have gotten so far into the application
and you haven't followed the format of the standard
review plan.
And, you know, I was very upset because
in fact we had submitted our application before the
standard review plan even existed. So, yes, we
pulled it back and resubmitted it but that's really
unnecessary. And I think these preapplication
processes can help us avoid those things where we're
totally aligned when things do change we can adapt
easily and move forward.
It's really important for us that we
convey to the NRC what our design is all about and
what we're trying to achieve so that when they get
the application, it's going to be a lot simpler to
review. And once again, we just really need that
licensing process to be streamlined. So this is a
huge, huge help to us.
And we are following the draft guidance
for preapplication, but we have added quite a bit to
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that just because there are things that we
specifically want to focus in on and make sure we get
NRC input on.
CHAIRMAN HANSON: Thanks. You raise a
really good point, right, that NRC staff had been
getting up to speed on a lot of these technologies
and yet we've still got a Part 50 process. It's a
little bit of a square peg in a round hole kind of
issue where even our understanding, we have to
translate that for ourselves into, you know, the
requirements maybe in Part 50 and then work with you
all on what the exemptions are going to be from that.
So I think that's a really helpful insight. Peter?
MR. HASTINGS: So Michael has never seen
me dance or he wouldn't have used that analogy. I
did mention in my initial response some of the things
that we're looking for in preapp engagement,
familiarizing the reviewer with our technology,
buying down regulatory risk, hopefully reducing
critical path review time for the application. So
resolving the key issues upfront is really important.
In terms of the tangible benefit, we've
elected to do that via topical reports. And for
anybody in the audience that may not be familiar with
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that process, that actually results in a
preapplication NRC formal approval on a technical
topic, which can then be applied directly within the
application assuming that all of our conditions for
its use are met. So that's really important.
And as Michelle said, the key here is
regulatory stability. We understand that
preapplication engagement is an effective tool in
achieving a predictable outcome in the licensing
process. And while we, like many others, believe
that the reviews can and should be shorter, a
predictable and stable outcome is probably the most
important consideration, sending a signal to the
market that the regulatory path doesn't lead you to
a mine field is really important.
CHAIRMAN HANSON: Yes, no, I think that's
-- the external parties to this, you know, they're
not necessarily going to be front and center, but
they're still relevant to the overall discussion. I
think that's a great point.
You know, one of the great things about
the NRC, one of the things I'm most proud of, is kind
of the commitment on the part of the staff to be a
learning organization and to want to improve and do
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better in our processes.
So I wanted to have a little bit of a
conversation, particularly with our three vendors
here, about kind of what challenges you've run into.
And I think we'll get as we move along in the
conversation here some, hey, what are some things
that NRC can be doing better?
So if there are pot holes, speed bumps,
not to, you know, use another analogy, I don't know,
divots on the dance floor maybe in which a toe or a
heel could get stuck, what are some of those things
from your perspective? And I'm happy to start
anywhere. Tara, we can start with you.
MS. NEIDER: Sure. I guess the biggest
challenge I see in a preapplication engagement is
that we want to make sure that the right people are
in the room. And we believe so far that has happened.
And so we're very pleased with that.
But, you know, you really don't know
until you submit something in writing as to what, you
know, did we have one or two good people in the room
that really wanted to engage, but there's three back
in the office that have totally separate issues that
we haven't addressed? So that's probably the biggest
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thing.
Secondly, you know, those people that
we're engaging with now may not be here in the future.
So we might have to have, you know, a new training
and engagement process.
And then finally, you know, I'm really
pleased with the way that we're engaging with the
NRC. And it seems to be very beneficial for both
parties. But what I often hear from staff members
is that it's always good during that honeymoon
process where you're in that pre-engagement time.
But once you submit something in writing everything
changes. So we hope that that transition is going
to be nice and smooth and that we actually do get the
benefit out of these preapplication engagement
activities.
CHAIRMAN HANSON: Michelle or Peter?
MS. CATTS: Yes, I can go next. You
know, overall our preapplication engagements to the
NRC at all levels have been really fantastic. You
know, always there's, you know, some things that
could be done better on both sides, I'm sure.
One of the challenges that I see for
preapplication is the ability to predict the cost and
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schedule associated with some interactions to ensure
that the project stays on schedule and on budget.
I used to work for the NRC. I have a
family that lives near nuclear power plants. I
definitely understand the need for reasonable
assurance of adequate protection of public health and
safety. So I do realize some reviews take longer
than expected to ensure safety. That's not what I'm
talking about.
You know, sometimes it's difficult to
predict the cost of some of the preapplication
engagements. So, for example, the cost of
preapplication meetings because you don't know how
many NRC staff will be in the room.
Also licensing topical reports when
they're submitted, the NRC performs an acceptance
review. The acceptance review and the hours are not
included in the NRC's estimate on the LTR hours and
schedule. And that can actually be a significant
contributor to the cost.
And then finally, you know, some of the
LTRs have gone quite a bit over the NRC's estimated
hours. You know, from our perspective though, the
benefits do outweigh the costs. You know, we believe
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these preapplication engagements have many future
benefits for future applications. But for these
projects to succeed, you know, we really believe
there needs to be predictability in costs and
schedule.
CHAIRMAN HANSON: Thank you. Peter?
MR. HASTINGS: Yes, hi. I agree with
everything that Tara and Michelle said. One of the
things that falls into the sort of keep me awake at
night category is the notion that we get good
engagement and commitments to transformation, all of
which we've gotten but then, you know, others in the
agency don't "get the memo" and that has not
happened much.
Unfortunately though, we have
experienced that with one of our own topicals where
the one year review has turned into more than three
years and not really for a good reason other than one
particular office had to shuffle their resources and
weren't able to accommodate the schedule.
And, yes, that's going to happen on
occasion. We all understand, you know, those kinds
of bumps in the road are going to occur. And
generally we're still very encouraged but to keep on
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the theme that we've sort of talked about a couple of
times already, predictability is really important.
And if we lose that aspect, we start losing control
of other factors, like loss of credibility in the
market and amongst prospective customers.
Another challenge is the notion that the
preapplication engagement may not appear to represent
the best return on investment. We have a committed
21-month review schedule, which is really good for
our construction permit application.
Absent our robust pre-application
engagement, it might have, what, 24 months? I'm not
entirely sure but certainly not a dramatic buydown in
time. And so some might observe that four years of
focused preapplication engagement at a million
dollars a year buys down only a handful of months of
review and that may not be intuitively a good
investment.
So I think there may be more to be done
there to look for more opportunities to recognize the
value of the preapp engagement in terms of even more
tangible results once the application is submitted.
CHAIRMAN HANSON: Thank you for that,
yes, very much. We've got several themes here, and
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I want to give Michael an opportunity to kind of weigh
in on some of this stuff.
I mean, you know, budget and schedule
predictability, staff turnover, I think, you know,
some of these folks might -- Michael, I know -- you
and I know aren't the first ones to necessarily raise
this. But I also know that these are issues that
we're working on so I wanted to give you an
opportunity to kind of jump in here a little.
MR. DUDEK: Absolutely. And I'll
resonate with a couple of the common themes that we've
heard, you know, predictable and stable license. How
does the NRC do that?
And I would think that, you know, we do
that in a couple ways. You know, it starts with an
agency focus. And I think this group and everyone
else, that may be timing and can get to the theme
that the agency is focused on that. Both
Commissioners, Commissioner Wright and Commissioner
Baran mentioned, and you, Chairman Hanson, mentioned
advanced and new reactors in much of their speeches
in the plenary sessions this morning.
It is an agency focus. It is something
that we're focused on. It is something that we're
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trying to improve. It is something that we are
setting the appropriate infrastructure for. And it
is something that management is focused on and asking
those questions, asking those hard questions about
how can we do things differently? What have be we
done before? What lessons can we learn? And how can
we set, as Michelle said, that predictable budget and
timeliness for these products that are coming in?
And the only way to do that is provide
that infrastructure. That infrastructure is set at
the NRC within NRR. We joined the NRR a couple of
years ago. We have an amazing management team. It
starts with Andrea Veil all the way down to my
division management.
And hiring the new staff members, hiring
the next generation, getting them in and trained,
ultimately, very critical on handling the breadth and
volume of information and applications that we're
expecting over the next two or three years.
And then learning from our mistakes. You
know, we pride ourselves on being a learning
organization. What has been done during previous
reviews? What things went well and what things
didn't go well?
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Currently, we're evaluating the NuScale
DCA review. We're learning lessons. We've got
lessons from all over industry, all over
stakeholders. We formed an internal task group to
evaluate those lessons. We're making the changes.
We're taking a hard look at our guidance, our policies
and procedures. And we are currently doing
rulemaking, 50 and 52 rulemaking, which implements a
lot of those lessons learned.
So I think that summarizes, you know, how
the NRC can accommodate and the way that the NRC
anticipates changing in the future.
CHAIRMAN HANSON: One of the things that
I've become aware of is this core team concept, right,
that I think came out of that lessons learned to
address this issue of kind of staff turnover, you
know, where we've got this core group of people that
are really focused on a particular license
application.
They're going to really be the subject
matter experts. And then we're matrixing in people
who will deal with maybe specific issues but that the
kind of re-education or knowledge management
challenges we've had, we're starting to get our arms
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around that in those ways. So I think that's
important.
MR. DUDEK: Absolutely, Mr. Chairman.
And that goes back to the infrastructure. You know,
we have an infrastructure here in NRR where advanced
reactors has their piece and small modular reactors,
light water reactors, has our piece. And the DANU
advanced reactor piece is implementing that core team
strategy. And it's working very, very well.
We have lessons to learn in it, and we've
got a ways to go. But, you know, we are legitimately
trying to do things differently and providing that
predictable and stable licensing environment.
CHAIRMAN HANSON: Thank you. Let me ask
Peter and Tara and Michelle especially, we got this
in from the audience just now. And it's, can you
describe how you balance the need for preapplication
meeting between safety and environmental topics?
Does this kind of really come down to site specific
concerns?
I mean, for instance, Peter and Tara, now
you guys both have sites. I think certainly, you
know, Kairos had to have that as part of its
construction permit application. And, of course, you
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know, we know TerraPower is looking at the site in
Kemmerer, Wyoming. So, you know, how do you balance
that or are you finding most of the need to kind of
really be more on the reactor design side?
MS. NEIDER: I can start this one.
MR. HASTINGS: Go ahead, Tara.
MS. NEIDER: Sorry.
CHAIRMAN: Sorry. I should have called
one of you.
MS. NEIDER: So we've been covering both
aspects in our preapplication meetings. And I'd say
actually there's a lot of focus on the environmental
aspects right now. And the reason for that is, you
know, we have selected a site. We want to make sure
that we've done all of that correctly. We're
planning on -- one of our next meetings is one our
water resources in our met tower.
The environmental regulations are a lot
different than the safety evaluations. You know, the
safety evaluations there's kind of a pretty clear
path. But on the environmental, you have to, when
you select a site, it's how do you -- you know, what
about all these other places that it could have gone?
So there is a delicate balancing act there.
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And so we did spend a lot of time with
the NRC on the site selection as well. And it's a
part that I'm less familiar with so it has been very
good engagement in that area as well. And I don't
see any way not to go through that preapplication
engagement with the environmental sites.
MR. HASTINGS: Yes. We've similarly
had good engagement on both the environmental and the
safety side. The tools look a little bit different
because we've produced a number of topical reports
that feed into the safety side.
Topical reports for procedural reasons
and reasons associated with the topics that you're
addressing don't lend themselves quite as well to be
a good tool for the environmental side. But we've
had very active preapplication engagement on the
environmental side as well. It's a little less novel
on the environmental side than on the safety side
because there's not so much unique technology
involved on the environmental side.
We've also, outside of Kairos
specifically, as an industry we've had good
engagement with the staff on the notion of making the
environmental reviews more generic, to recognize that
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nuclear energy has a very long history of having an
overwhelmingly positive environmental impact and the
fact that, you know, the environmental review is
based on a procedural rule that's intended to inform
the federal action, in this case the issuance of a
license, as opposed to a compliance rule, like the
safety side lends itself to.
So anything we can do to help streamline
that process, make the environmental reviews simpler,
more straightforward and try to reduce the burden of
additional site specific evaluations that really in
many cases duplicate the safety analysis that's
already been approved at the last site will be a huge
step forward.
CHAIRMAN HANSON: Thank you. And,
Michelle, I wanted to recognize, of course, GE has a
site now in Tennessee as well as the site up in
Canada. So how are you all approaching this balance
in interactions between, you know, the safety and
environmental issues?
MS. CATTS: Yes, so, as a vendor, we
generally focus on the design and the safety of the
reactor design and usually the customer or the
licensee focuses on the environmental aspect,
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obviously with our input and our help.
So what we're doing for our safety and
for our design is basically capturing key
differences. So our BWRX-300 is the next generation
of BWRs, and it's based off of the NRC already
approved ESBWR design. So we're using preapplication
for mostly ways to capture the key differences
between the ESBWR and the BWRX-300 in these licensing
topical reports to basically have the NRC review and
approve these discrete topics ahead of time to
approve efficiency and transparency and reduce
uncertainty down the road. So that's really what
we're focusing on right now is these licensing
topical reports for these key or novel design
aspects.
CHAIRMAN HANSON: Yes, thank you. Tara,
I wanted to ask you a question and then I'm going to
kind of branch off and ask Peter a similar question
in a minute.
But, you know, TerraPower, you know,
oftentimes we think of preapplication engagements as
being focused mostly on topical reports. Which as
Peter said, you know, one of the advantages of this
topical report approach is some finality with regard
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to the issues being evaluated.
But TerraPower submitted a number of
white papers. And that's a little -- I don't want
to call it out as being different, but I think it's
different maybe from both Kairos and GE, and I wanted
you to talk a little bit about the white paper
approach that you're taking, how maybe that's
different and how you're deciding between a white
paper and a topical report, say, on a particular
issue.
MS. NEIDER: Sure. As you mentioned,
the topicals have a finality to them and the white
papers don't. They're basically opinion pieces.
The NRC is giving us what their thoughts are, but
they don't have to hold to those things that they
said in a white paper.
Natrium is driven by schedule. We have
a very tight timeline. And so the white paper was
very appealing to us because we got information back
sooner.
And, you know, so far we have submitted
a number of them. Two of them have been responded
to. And really what we saw in those white paper
responses is that, you know, we were aligned. The
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NRC was aligned with our approach.
They did provide us some valuable input
where we could, you know, strengthen some areas and
be more, you know, go into more detail in certain
areas than other areas. So it does drive our
licensing process, and I think it's been very
valuable so.
Topicals, we will still use topicals as
well, you know, for things we absolutely need a
certain decision now, but the white papers are great.
CHAIRMAN HANSON: Thank you, Tara. I've
got another question here from the audience that I
want to pitch to Mike and then offer an opportunity
for the vendors to weigh in.
You know I've talked a lot about data and
the importance of data for making regulatory
decisions. And, you know, data validation for new
technologies is going to be essential. And part of
that is going to be an evaluation or approval of
computational analytical methods, of course. And I
know that's the subject of some topical reports that
we've gotten, not just from the vendors here.
But the question for Michael is really
how is the NRC going to provide kind of regulatory
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predictability and certainty in the approval process
for essential analytical and computational methods?
I mean, I think about this a little bit,
right? In my RIC speech this morning, I said, show
your work. You've got to show the agency how you got
from Point A to Point B. So how are we kind of
validating or putting our stamp of approval on those
methodologies, some of which are pretty novel, that
are coming into the agency?
MR. DUDEK: Absolutely. And that's the
beauty of the preapplication engagement is that
through these processes, through these discussions,
through our actions, we gain alignment, and we gain
understanding about these methods and these computer
codes that the applicants are using.
Some of the new applicants aren't aware
of the typical and standard suite of computer codes
that the NRC uses in how we do business. And this
allows them to have the opportunity to compare their
numbers with our numbers.
There are several ways to do this in a
preapplication engagement. You can put those
methodologies and analyses in a topical report and
get that "finality" that Mr. Hastings was talking
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about. Or you can put a theology or a methodology
in the white paper and get a set number of hours and
get informal NRC feedback on that.
Also during preapplication engagements,
we can open up an audit in which you can have those
face-to-face discussions from the technical staff to
the technical staff. You run the same code. Are we
getting the same numbers? If you're on a different
code, are you getting similar numbers within a
bandwidth that makes sense? And that really fosters
that environment, like I said before, of
understanding.
We also have page turns. We also have
public meetings in which we can discuss openly in a
public forum or in a private forum. If it's
proprietary software or proprietary data, we can
discuss those items and gain alignment and
understanding on all of that data so we're talking
the same language, and we're using the same codes
moving forward. Very critical.
CHAIRMAN HANSON: Yes. Thank you.
Tara, Peter or Michelle, I wanted to -- just before
Michelle -- I wanted to give everybody an
opportunity, but I did want to note for the audience
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out there, for some reason, I think on that main
screen, Michelle's face is not appearing.
Michelle Catts from GE Hitachi is still
with us, still part of the conversation. We can see
her kind of behind the scenes here in Zoomland even
if the broader audience out there can't. So,
Michelle, I didn't want you to get lost out there.
There she is. See we got her feedback fixed.
MS. CATTS: My feed actually just
crashed. That's the fun thing about technology.
CHAIRMAN HANSON: So I wanted to -- I
don't know if others of you wanted to kind of weigh
in on this kind of analytical methods and approaches
as part of that preapplication engagement process.
MR. HASTINGS: So from Kairos'
perspective, what Michael described is exactly what
we've been doing. Half of our topicals are
essentially methodological in nature. And, yes,
there will be some sample calculations in those but
that is not what we're seeking approval on. We're
seeking approval of the methodology.
And then often as part of the staff's
safety evaluation, where qualification data are
needed to validate certain aspects of the
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methodology, those would be built into the conditions
under which that topical could be used as part of a
license application. So I think we're very closely
aligned.
MS. NEIDER: I think from TerraPower's
perspective, you know, Natrium is a big project, and
we have multiple companies that are doing designs.
So one of the challenges for us is limiting the number
of codes that we're using because everybody has got
their pet codes that they want. But this is an
enormous effort to get all the code V&V'd. So we are
trying to limit only those things in our application
which we actually need to support that application.
There are a number of programs that we
have that are optimization codes. And those
optimizations are -- they don't need to be V&V'd, you
know? We just have to show that what we finalized
and decided on for the design is in fact valid.
So we are trying to reduce our scope
somewhat to limit to what's necessary.
MS. CATTS: Yes, and for -- yes, I was
going to let Tara speak for Natrium. But for BWRX-
300, you know, a lot of our codes we already have
them approved for ESBWR. So it's just really
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updating those for BWRX-300.
And, you know, the licensing and topical
reports, really the purpose of them is to describe -
- you know, design criteria and methodology and
acceptance criteria to meet the key regulatory
requirements. And then when you actually go to
implement the LTR, you have to verify that you're
worked in the bounds of the LTR. So that's how we're
approaching it.
CHAIRMAN HANSON: Well, there are lots
of ways to kind of branch off of this discussion.
But we just got one in from the audience that I think
is really interesting and relevant. And I want to
go right to it before I double back and do some other
things.
You know, the level of detail in these
preapplications is kind of one of the themes that has
run through this. And, you know, and yet there's
kind of a -- there's a dynamic tension here that I'll
admit, I think, that's largely within the NRC, right,
where we need to kind of convey expectations about
the level of detail needed to vendors and yet we need
to kind of be careful for regulatory predictability,
uncertainty and other kinds of reasons, resource
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management reasons, et cetera, that we don't kind of
go on for lack of a better term -- you know, go down
rabbit holes or go on fishing expeditions or what
have you.
And a friend of mine described this to me
as, you know, we have an agency of really top notch
question askers. And not all of those questions all
the time are relevant to the task at hand.
And so, you know, Michael, I want to hear
from you a little bit about how the agency is kind of
preventing in a way the kind of unnecessary expansion
of the review in some cases and yet, you know, again,
maintaining that balance where we are getting the
level of detail that we need from vendors from COL
applicants and others.
MR. DUDEK: Very interesting question
and very tricky answer. I think that goes back to,
you know, the ability of the staff where they see
something brand new, they can ask questions, right?
And that's always going to be the case.
Where you draw the line is that -- we are
getting better in drawing that line. And that goes
to directly my feedback to applicants in that whether
it's a white paper or a topical report or whatever
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we're reviewing, make sure that you're drawing that
distinction. Make sure that it's a fulsome
application with all the information in there so
that we can fully evaluate it. And when we ask those
questions, it can be very pointed in any holes or any
areas that we see.
And that's critical because if we have a
fulsome application with all the information that we
need, that adds to that predictable and stable
environment of licensing. It adds to reducing the
time. It adds to reducing the cost. But if we don't
have that fulsome application, and we're having to go
and ask those critical questions, those questions
take time.
And then once you do get a question, one
question leads to two questions, leads to three
questions. And that is a testament to the technical
staff, but it's also a testament to the management
team of, hey, we're focused on the principles of good
regulation. We're focused on what is needed for
safety. We're focused on the key regulatory
differences of what we're seeing and what we've
experienced before.
So we are learning those lessons. We are
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trying to, as a management team, really trying to
guide our staff and evolve our procedure and evolve
our processes to a level of what do we really need to
know now? What do we need to know in the future?
What kind of level of finality can we provide for
these topical reports and these white papers? And
what do we need for the future for future applications
and how all of this integrates into one final
response, one final agency position on safety? So I
think that's how we'd like to proceed.
CHAIRMAN HANSON: Yes. I've heard it
said that management, you know, reviews every RAI,
request for additional information, that leaves the
agency.
MR. DUDEK: Well, that's one of the
lessons learned that we're evaluating as we speak.
CHAIRMAN HANSON: Mm-hmm.
MR. DUDEK: And one of the lessons that
we've learned. So while, you know, the staff comes
up with great questions, you know, even the mid-level
management, you know, asks the hard questions about
how this is involved in safety, why is this important
and really scrubs those.
They do go up in division management in
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a lot of cases. And division management has got that
high level umbrella picture where they can really
evaluate that on a larger scale and say, hey, this is
needed now or this is needed probably in the future.
CHAIRMAN HANSON: Thanks, Michael. Any
feedback? I want to give Peter and Tara and Michelle
an opportunity to weigh in here, too.
MR. HASTINGS: A couple of quick thoughts
from me. I think, you know, what Michael said is
true. I think we've seen improvement with regard to
the appropriateness of the scope of the questions
from the staff. We're never going to have a problem
of the staff not asking enough questions. That's not
going to be the problem.
An effective project manager or set-up
project manager is an appropriate sort of management
filter on the questions that come so that we can have
confidence that the questions do have an appropriate
regulatory basis. That is important. The
receptiveness of the project management team and the
management team, if we see that review going, you
know, sort of too far afield, receptiveness to that
feedback is really important.
It's also useful to note that if you have
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a good relationship with the staff, a good engaged,
you know, sort of collaborative relationship, there's
going to be a lot higher I'll say tolerance for lack
of a better term of questions that may not rise to
the level of this warrants an RAI, but, hey, this
staff member is curious about what's going on with
this widget. And if you can answer that question
over the phone and obviate it as a formal RAI and
maybe it helps inform his or her review when the
questions really are on point, that's useful as well.
So I have seen improvement. It is going
to be an area for, I think, continued focus. There
are always going to be, you know, incidents where we
don't think the question is appropriate, but
hopefully as we continue to progress, those are sort
of the outliers.
CHAIRMAN HANSON: Thank you.
MS. NEIDER: Yes, this is kind of a joint
effort here, as Peter mentioned, is that we do need
to push back when it's necessary to push back.
You know, a lot of negativity has been
about the NRC has made things too difficult, you know,
and it has driven the nuclear industry out of
business, those kind of things. And I think quite
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differently than that. I believe that we did it as
an industry. You know, the NRC was part of that but
so was the industry.
We have to watch for things where
engineers are just so proud so they want to tell all
about the things that they did versus what's actually
necessary for safety. And for each of the questions
and each of the things we submit, I think that's
important is you know, why are we doing this? Why
is this necessary to be part of the application?
Because if you put too much in there, it
always will have negative consequences, you know,
because there's going to be some reason that you want
to change something that's totally innocuous but now
you have to go through a rigorous process to change
those things.
So it's really incumbent on the staffers
to consider whether their questions need to be asked
but also with the applicants as to what information
that they should be providing and why they are
providing that information.
CHAIRMAN HANSON: Yes. Good points.
MS. CATTS: Yes. And, you know, my
perspective, the NRC they are really good question
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askers. For the most part, their questions are
really good. But it is important to have the NRC
management involved in the preapplication early on to
ensure that the review is fairly focused, you know,
what's being asked.
You know, also the goal of those
preapplication meetings is that the right level of
detail is provided so hopefully that will minimize
RAIs in the future.
You know from our perspective, like Mike
said, the NRC management should be thoroughly
involved in the review of the request for additional
information before they go out. And, you know,
really step back as a manager and look at the big
picture, you know, and ask yourself, does this
question that we may send out, does it provide
reasonable assurance of adequate protection or
absolute assurance? You know, what exactly are you
trying to get at? So just really kind of step back
and look at that big picture before those RAIs go
out.
CHAIRMAN HANSON: Thank you. Yes, very
helpful. Very helpful. And very interesting. I
think I want to kind of continue with this theme for
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a minute. We got another question in from the
audience, primarily for Mike about how are we kind of
allocating resources among applicants on, you know,
preapplication activities but just plain application
activities?
Is it kind of first come, first serve and
how are we -- you know, we've got an agency of already
busy people working on a lot of different issues and
how are we assigning resources to kind of the issues
that are coming in before us because we want to be
responsive to the people that are walking through the
door with whether it's white papers or topical
reports or, you know, construction permit
applications. How does that process go?
MR. DUDEK: I love this question. And
this is going to be my pitch in the fact that this
goes back to infrastructure and expectations.
So the NRC has set up the infrastructure
to be successful. We have two divisions very clearly
focused on two different areas, whether it's advanced
reactors or small module reactor licensing. When an
applicant comes in, we assign a senior project
manager and you meet. And that senior project
manager starts interfacing and develops a backup and
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a team to go along with him to ask those big
questions. And we start interfacing with the
appropriate technical staff. So that's the
infrastructure that we have set up to be successful
in this area.
And now my pitch to ensure that we're
successful is really incumbent upon the applicants to
let us know their timelines and schedules, whether
it's right before the engagement plan or information
to us on what is coming in and when. Because in some
respects it is first come, first serve.
If you let us know, if you adequately
communicate with us on what's coming in and when, we
can plan. We can adequately budget. We know what's
coming in. We have staff members set aside. We've
provided the training. We can hire. As long as we
know what's coming in, we can plan for it.
Now for those applicants that, you know,
don't involve the regulatory engagement process and
don't participate in preapplication as effectively as
others and we're not aware of what's coming in, we're
often surprised, and we can't budget.
We don't have the staff available to do
some of those reviews or if it's a specialized or a
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niche area, you know, we haven't done the outreach to
those technical parts of the organization, we use the
word matrix, the matrix organization to be able to
provide that expertise in a timely and effective
manner.
So, you know, it's just very, very
critical while voluntary for the preapplication
engagements to let us know what's coming and that's
my pitch.
CHAIRMAN HANSON: Well, if I can jump in
here, too, right, I mean, Mike we've talked about
this a little bit and, you know, this is where a lot
of things come together inside the agency, right,
where we're using some tools --I keep coming back to
-- in my mind I keep coming back to a point Michelle
made earlier about the predictability of budget and
schedule.
Well, part of that for us is actually
looking at what some of these efforts have taken in
the past so we can project in the future how long,
how many people, how much money, et cetera, right?
And then that allows us to better kind of allocate
resources among all the demands that we have.
And also, of course, then there's hiring,
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right? We want to make sure that, you know, we've
got attrition like every other organization in the
universe, and we want to make sure we're backfilling
those positions and that we're staffed up
appropriately to kind of meet the demands of the
agency.
So it's a real kind of multifaceted
effort, I think Mike, that you made a good point
about.
I did want to kind of ask, I want to get
down in the weeds just a little bit here and I also
want to take the pressure off of Mike a little bit
because I think a lot of the questions that are coming
in from the audience are coming into him.
So I wanted to ask Peter and Tara
primarily about this, you know, what kind of
preapplication interactions have you looked at or are
you having around kind of safeguards and to some
extent security kind of more broadly?
Particularly for your facilities, Peter,
I think we know that your proposing to use TRISO fuel,
which hasn't been widely used yet. But how are you
kind of approaching, you know, inventory and control
issues and have you approached the NRC with some of
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your -- or approach the staff?
MR. HASTINGS: That's a good question.
And the short answer is not yet, but it is definitely
on our list.
CHAIRMAN HANSON: Mm-hmm.
MR. HASTINGS: Not yet because it really
doesn't have as much bearing on the construction
permit as it will on the operating license.
A significant amount of the safeguards
and security aspects that we will be dividing into in
preapp space in advance of the operating license
application are more programmatic in nature.
Now that said, there are security by
design and safeguards by design aspects that we will
definitely be focusing on as we pivot to the detailed
design of the Hermes reactor.
And so where preapplication engagement
will help inform those design decisions that will be
made, you know, over the next several months, couple
years, then we'll definitely be engaging to make sure
that we factor that in as much as possible.
The more we can do by design, the less
burdensome those programmatic aspects will be. And
it's important for many of the people in the advanced
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reactor community to have these discussions because
there is no guidance out there today on Category 2
fuel, high-assay LEU many of us are using. Category
2 requirements are not particularly well understood
right now. And we would like to engage both at an
industry level and for individual applicants to make
sure that in the absence of guidance the staff doesn't
default to Category 1 guidance when it would be more
appropriate for facilities to look a lot more like
Category 2.
CHAIRMAN HANSON: Good points.
MS. NEIDER: And I would say we're kind
of in the same position that Peter mentioned for his
reactor. We did submit our safeguards program to the
NRC and were audited. And that went very well. We
expect to have approval for our safeguards shortly.
And I would say that we are following the safeguards
by design and security by design. However, we
haven't really engaged with the NRC on that yet.
CHAIRMAN HANSON: Yes, thank you, Tara.
I think that safeguard by design is something the NRC
is just starting to look at. It's something I have
an interest in but also I think Peter raised a number
of good issues, too, right, where we are encouraging
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the agency to -- a lot of the preapplication
activities that you're going to have aren't
necessarily going to be with the Office of Nuclear
Reactor Regulation. There's this other office, the
Office of Nuclear Material Safeguard Security, who
also are going to have some input here particularly
on the fuel side that's going to be important and not
necessarily fuel fabrication but, you know,
transportation and storage and other kinds of issues.
So very, very interesting.
This was a question that came in mostly
for Mike, but I'm kind of interested in the whole
group's perspective on this. And it's a genuine
question to kind of start from my perspective, which
is does the submission of topical reports end, or
white papers for that matter, kind of end when a
construction permit application or a COL for that
matter is submitted or are there kind of ongoing
things that you either want to or intend to interact
on?
And I guess, you know, the question
really came in about, you know, how was the NRC
looking at issues like constructability or ITAACs,
which is integrated testing accepting kind of reviews
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down the road, or inspection and oversight or
operations? Or is it the case where, you know, a CP
will come in and yet there might be still a desire
for further engagement on some of these issues that
may not be directly under review at any given time?
And I guess, Mike, I'll let you kick it
off. But I'm hoping our vendors can weigh in on this
issue as well.
MR. DUDEK: I think that's a testament
to the capabilities of our staff. You know, our
reactor assistance staff, for example, often has and
has had topical reports being reviewed at the same
time, multiple topical reports, being reviewed at
the same as the design certification. And it can be
a parallel activity.
It often is very challenging. You make
a finding in one area. You have to see how that's
integrated into the overall application. And we've
learned some lessons on that. And that's part of
what we're correcting now and some of the things that
we're looking at in the future.
I anticipate this to continue to occur
during several of our applications just because in my
opinion the finality that you gain for a very specific
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topic in a topical report and then parlaying that
into an overall application has dividends and has
that finality piece that does pay dividends down the
road. And for most topical reports, they can be
applied in multiple different areas.
CHAIRMAN HANSON: Thank you.
MS. CATTS: Yes. You know, from GE's
perspective, you know, we would continue with
licensing topical reports, you know, through
construction permits and EPRI licenses. But, you
know, again the goal is to be able to reference the
license and topical report in those, you know,
license processes, right?
So you've got to make sure you get it
reviewed and approved to be able to reference it in
your application. But, you know, some licensing
topical reports you might need prior to construction
permit. But some licensing topical reports you might
not need until prior to the operating license.
So for instance you might want to get the
severe accident source term figured out early on.
But, you know, you might be able to handle control
room type support center security requirements later
in the operating license.
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MS. NEIDER: Yes. And I would agree with
Michelle that we'll continue to have a lot of
engagement with the NRC on issues that are listed in
the question.
The one thing in the question that kind
of popped out at me that felt a little bit different
was ensuring that the reactors can be constructed,
you know, site constructability. And I don't think
that's an NRC -- or should not be an NRC concern.
That is our responsibility. We do have
constructability reviews throughout our design
process.
We are working with Bechtel, who is doing
those construction reviews for us. And it's a real
risk that, you know, you have construction
challenges. But that's ours. It's not a safety
issue. And I would push back on that. I think the
best thing with respect to constructability is that
we try to minimize the things that we commit to that
don't have an impact on safety.
MR. HASTINGS: Yes, that and the
component of how do we keep ITAAC from impacting the
construction schedule? A different way of phrasing
the question is a whole other discussion that could
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take quite a bit of time.
On the topic of does the topical stop at
the submittal of the application? As everyone else
has said, it doesn't. It's a continuum, and it
depends on how any particular report is going to be
used, what conditions there are for its use in a
subsequent license application.
We've got a construction permit under
active review, and we still have four topicals that
are still under review. So it absolutely doesn't
stop.
CHAIRMAN HANSON: Thank you. And, Tara,
good point about the constructability. You're right.
I was reading it off the question. Right.
Constructability is an issue for us only insofar as
we're able to inspect ongoing construction with
regard to safety parameters. I totally understand
that.
And that was kind of the context in which
I read it. It wasn't -- I didn't have in mind that
we were evaluating whether or not you could connect
Widget A to Widget B in a physical sense. So that's
a fair point from you and thank you for that.
How have -- there's a question here about
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kind of predictability of schedules. And it's a
question for the vendors. And I guess, you know,
there's a question I have about how are you -- you
know, we're looking at our data about how are things
going in terms of, look, we thought this review was
going to take X number of days or weeks, and it took
Y.
And we're looking at our own predictions
for that. But how are those predictions kind of
working on your end in terms of both the real data
you're getting? And some of those changes, some of
the deltas there are going to be entirely
understandable. Well, you know, it took us a little
long to respond to this question or, oh, we didn't
quite anticipate that question.
But how is that predictability kind of
shaping up in your own space and how is that kind of
informing your engagement posture, I guess, kind of
going forward?
MR. HASTINGS: I'll start from Kairos.
Our track record is pretty good, and it speaks to, I
think, the commitment of our company to do what we
said we were going to do.
That hasn't always been the case in some
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of my past lives to be honest. And that points to
maybe a call for a little bit of humility on the part
of developers to be willing to sort of raise our hands
and say we said we were going to do this and for good
reasons or bad reasons we didn't, and we're willing
to acknowledge our role in that in terms of what our
overall schedule looks like going forward.
MS. NEIDER: And I guess I could add to
that, we do have a very challenging schedule. And
we're committed to meeting our schedule. We have had
some struggles with hiring people. I think we've
hired really, really great people but our hiring ramp
is pretty fast. So we are people challenged.
And we will just, you know, commit to if
we do have delays we will provide those delays fairly
early so that people can respond to that. But we are
doing everything we can to meet the schedule dates.
And so far on the Natrium project we've met all of
our milestones. So we're doing fairly well, but it
is a big challenge because there are so many
developments going on right now in advanced reactors
and light water reactors for that matter. So there
is a limited staff in the industry.
MS. CATTS: For these projects to be
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successful, like I said, they really need to be on
track and on budget from both our side and from the
NRC's side. You know, from our perspective, early
engagement works best with the NRC. You have to
develop the regulatory engagement plans, stick to the
plan, you know, discuss the plan with the regulators,
stick to it, stick to the time frames that we say
we're going to submit something so that, you know,
the NRC has their time to review it and that NRC can
plan and budget their resources.
And one of the things I would really like
to see, you know, coming from the NRC to private
industry, I would really like, you know, to see the
NRC run these reviews like a full project management
process like you see in the industry with milestones,
budget reviews, action owners, due dates, for real
transparency and visibility so we can kind of see
it's on track and on budget the whole way through the
process.
CHAIRMAN HANSON: That's a great point,
Michelle. And I'll put Mike on the spot just a little
bit here, right? I mean, I've been around just
enough capital projects to be dangerous and have been
exposed just enough to tools like, you know, P3 -
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Primavera and other kinds of sophisticated scheduling
tools to be dangerous. I fully admit that.
But what about that, Mike? I mean, how
are we -- you know, to what extent are we kind of
leveraging some of these hard core project management
tools in our reviews?
MR. DUDEK: So good question. We are in
the -- we have come a long way over the last year in
being able to be predictable and on budget. And
we're getting better.
So I think that my applicants clearly see
that this is a priority that I make. And I have
daily, weekly and monthly briefings on my projects,
on my budget, and I operate, you know, within the
agency guidance, you know, clarity, openness,
reliability and efficiency, you know, those are the
core values that I tout, and I try to embody during
all of my reviews.
And it goes back to that predictability
piece. Are we setting realistic schedules? Are we
meeting those schedules and how do we do that? And
that's really incumbent on a management team to be
able to brief that out, to manage those processes to
be open.
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If we foresee that the RAI process isn't
going well, we need a second round of RAIs, I go out
to my applicants immediately and say, hey, we're not
meeting expectations. It's taking a little bit
longer and here's why and that could endanger the
review or that could lengthen the review. So that
goes back to that fulsome details, replying to RAIs
effectively and providing those detailed answers that
the staff needs to be able to fully meet those
schedules and those expectations.
As for the processes and procedures,
they're improving. We now have RPS, the Reactor
Project System, which we track and assign projects
through, which has been incredibly key, you know, and
we've only had that for the last two years.
So we are making progress. This is a
focus. And as Rob Taylor will tell you that we're
running this more as a business than anything else.
Are we on schedule? Are we providing good customer
service? Are we able to meet the demands and the
timelines needed to be successful in front of the
entire world for these new reactor applications? As
I said, we're making progress.
CHAIRMAN HANSON: It's really good to
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hear. And, you know, we can have -- this is another
one of those branches where we can kind of talk about
staff development in the NRC and building that
expertise, and we've done so much to get smart on I
think advanced reactors. Our Be RiskSMART framework
has been critical.
And I know, you know, for me going back to
my days as a consultant, I mean, some of the most
useful training I ever had was project management
professional training. I never did pull the trigger
and go get my PMP certification. But it's still a
framework and a kind of Heuristic that I use all the
time to look at issues. So there's lots of kind of
food for thought there.
I wanted to ask, you know, as an agency
who has kind of both the responsibility to applicants
and licensees to be transparent, to be predictable
where possible, to be open, and we also kind of have
this responsibility to the public, right, where we
want to be as clear as we possibly can with the public
about what we're doing and why we're doing it.
And to that extent and, you know, to that
end, we have a lot of these interactions. A lot of
preapplication interactions are public meetings.
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And some of them can't be, right, because of security
information or business proprietary information.
But I wanted to get some thoughts from vendors and
then Mike about the public facing aspect of our
interactions and your thoughts and kind of feedback
on that. Don't everybody jump in at once.
MS. CATTS: I'll start.
CHAIRMAN HANSON: Michelle will start.
MS. CATTS: I'll start. You know, from
our perspective, interactions with the public are
very important. We've been really trying to make our
presentations, for instance the ACRS meetings coming
up, things like that, try to make them as non-
proprietary as possible, the slides, so that we can
have more engagement with the public in these
discussions. Because the earlier you get the public
engaged, the more clarity you get early on to address
any issues, right? So this only helps you in the
long run to have, you know, early public engagement.
So I guess we've been really trying to
make our slides as public as possible so we can
minimize what's in the closed session and maximize
what's in the open sessions.
MS. NEIDER: And I think -- I'll add to
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that. For Natrium, I think we've been more public
than most. And we can see that because, you know,
we get targeted by anti-nuclears because we are
making almost everything public. But, you know, we
do have to keep some things separate because they're
propriety in nature or have security issues.
But we do think it's the right thing.
The public has a right to know. And we do try to be
as public as possible.
There was one NRC meeting we were in
where we were in the public part of the meeting and
we planned to discuss it in the closed meeting and a
question from the audience came out and they asked
that question.
But in the public meetings, the process
is the NRC responds to the questions not the
applicant. So we knew the answer to it and the NRC
answered incorrectly because we hadn't told them yet.
So there is a little bit of an issue there. So I
don't know if we should be speaking in the public
meetings or not but that's one thing to think about.
MR. HASTINGS: We found the public
meetings to be perfectly useful as well. It doesn't
inhibit our discussion with the staff in any way and
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wherever the information is public, we've been
perfectly open with it as well.
I want to acknowledge that the staff is
sort of the guardian, if you will, of what should and
shouldn't be withheld from the public. And in early
engagements with us on the topical report, we piloted
what came to be known as the "no RAI" approach to
reviewing the topicals.
And I was a little hesitant to use that
term because it makes it sound like we're, you know,
conducting discussions back behind the curtain
somewhere and that was far from the truth. All we
did was in collaboration with the staff short circuit
through some of the bureaucracy around generating the
questions and answering the questions.
So instead of an entire series of formal
letters back and forth, the staff would send us
questions. If we understood the question or with a
brief conversation clarify the question, we would
more often than not amend the report and submit it.
And all the questions and our responses and the
amended submittal all ended up on the docket just as
if they had been a formal sort of letter writing
campaign.
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So really good improvement in the process
without any, you know, obfuscation or anything
needing to be kept from the public, and it was
remarkably effective.
CHAIRMAN HANSON: Thank you. Mike?
MR. DUDEK: Well, as you know, Mr.
Chairman, you know, openness and transparency is the
bedrock of what we do at the NRC. So I can't tell
you how valuable it is to me at every turn whether
it's a public meeting or engagement on a document or
even during the rulemaking activities and the public
engagement we have on that, on the level of engagement
that we have and the insightful comments that we get
back.
I'll give you two examples. I mean, for
the NuScale rulemaking and for other rulemakings that
I've participated in, the level of insightfulness and
just the quality of comments that we get back from
some of those engagements really just make me step
back and think. Because you're laser focused on a
task and a lot of times you're not thinking about the
big picture, and you don't know what you don't know.
And a lot of these questions really make me step back
and think.
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And in some of the cases, our current
efforts have really made us go back and evaluate what
we're doing and how we're doing it. And so I truly
value the openness and transparency of the NRC and
that's what made me stay here for 20 plus years. I
love it.
CHAIRMAN HANSON: Well, I think that's
as good a note as any to kind of wrap-up here. I
really want to thank our panelists, Peter Hastings
from Kairos, Tara Neider from TerraPower, Michelle
Catts from GE Hitachi. Thank you all very much for
your willingness to engage and to give us, you know,
the NRC some constructive feedback here. It's been
enormously helpful.
I want to thank Mike Dudek for his good
humor. He spent a lot of time on the hot seat this
afternoon. And he handled it with a lot of grace.
And I appreciate everything you do, Mike, and so
forth.
I think we touched on a lot of really
good themes here, you know, having a good
conversation along that access of flexibility and
predictability in regulatory space but also kind of
in budget and schedule, the NRC's, I think,
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commitment to learn from other reviews, like NuScale,
and so forth and apply those lessons to the folks
that are currently in front of us now, many of which
we have with us today.
I think that, you know, we're looking and
the agency is really preparing for, you know, a
potential wave here of new applications and a
diversity, I think, of applications that's really
teeing up to be, I think, different.
And a lot of -- you know, even with kind
of existing light water reactor technology, the
technology has improved and the analytical tools have
improved. And we're, I think, adapting to that in
ways that I know will challenge the agency. And I've
been pleased with the preparations that the agency
has made so far even as I know we have more work to
do.
So thank you all again very, very much.
And thanks to the public for joining us. And with
that, we'll bring it to a close. Thank you again.
(Whereupon, the above-entitled matter
went off the record at 2:23 p.m.)
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