ML22277A006
| ML22277A006 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/2022 |
| From: | NRC/OCM |
| To: | |
| Doyle, Daniel | |
| References | |
| NRC-1933, NRC-2015-0070, RIN 3150-AJ59 | |
| Download: ML22277A006 (66) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Public Meeting to Discuss the Proposed Rulemaking on "Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning" Docket Number: (n/a)
Location: Atlanta, Georgia Date: Tuesday, April 19, 2022 Work Order No.: NRC-1933 Pages 1-65 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 PUBLIC MEETING TO DISCUSS THE PROPOSED RULEMAKING 5 ON "REGULATORY IMPROVEMENTS FOR PRODUCTION AND 6 UTILIZATION FACILITIES TRANSITIONING TO 7 DECOMMISSIONING" 8 + + + + +
9 TUESDAY, 10 APRIL 19, 2022 11 + + + + +
12 The meeting convened at the NRC Region II 13 Office, Marquis One Tower, 245 Peachtree Center 14 Avenue, NE, Atlanta, Georgia, and by video 15 teleconference, at 6:00 p.m. EDT, Steven Smith, 16 Facilitator, presiding.
17 18 NRC STAFF PRESENT:
19 STEVEN SMITH, Facilitator, R-II 20 JAMES ANDERSON 21 KRISTINA BANOVAC 22 HOWARD BENOWITZ 23 JENNIFER DAVIS 24 MARLAYNA DOELL 25 DANIEL DOYLE NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 CHRISTINA ENGLAND 2 JULIE EZELL 3 DUANE HARDESTY 4 MAI HENDERSON 5 TARA INVERSO 6 BRETT KLUKAN 7 ERIC LEE 8 ANGELLA LOVE BLAIR 9 CARRIE McCANN 10 JOHN PELCHAT 11 LANCE RAKOVAN 12 AARON SANDERS 13 MAURIN SCHEETZ 14 DIANE SCRENCI 15 SOLY SOTO LUGO 16 TRENT WERTZ 17 LYNNEA WILKINS 18 BRIAN ZALESKI 19 20 ALSO PRESENT:
21 GEORGE ODOM 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 1 C-O-N-T-E-N-T-S 2 PAGE 3 Welcome and Logistics 4 4 Opening Remarks 6 5 Background and Status 9 6 Overview of the Proposed Rule 13 7 Tips for Preparing Comments 50 8 Public Feedback and Questions 55 9 Next Steps and Wrap-up 65 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 P-R-O-C-E-E-D-I-N-G-S 2 (6:00 p.m.)
3 MR. SMITH: Hello, everyone. My name is 4 Steve Smith. Im a Branch Chief at the U.S. Nuclear 5 Regulatory Commission, or NRC. And its my pleasure 6 to facilitate todays meeting, along with the NRC 7 staff who are here with me in Atlanta.
8 And with the staff on Teams joining us 9 virtually, this meeting will have a hybrid format, and 10 were going to do our best to help make this meeting a 11 work -- make this meeting work well for everyone.
12 Next slide, please.
13 So the purpose of this public meeting is 14 to provide information to inform you on the comment 15 process for the proposed decommissioning rule and 16 draft regulatory guidance. We will be going through 17 the various ways you can participate in this 18 commenting process as part of our presentation.
19 Next slide, please.
20 Here is our agenda for today. After I 21 finish with logistics, Ill have some opening remarks, 22 and then well provide our presentations, which will 23 include details on background and status, an overview 24 of the proposed rule, tips for preparing comments, and 25 the next steps. We will then open the floor for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 1 feedback and questions.
2 Next slide, please.
3 So logistics. Please note that todays 4 meeting is being recorded and transcribed. Wed ask 5 that you help us get a full, clear accounting of the 6 meeting by staying on mute if you are on the phone, on 7 Teams, and not speaking. Please keep your electronic 8 devices silent and side discussions to a minimum if 9 you are in the room.
10 Also, it would help us out greatly if all 11 speakers can identify themselves and any group they 12 are with when you first talk.
13 All meeting attendees have microphones 14 muted and cameras disabled during the presentation.
15 When we get to the Q&A portion of the meeting, those 16 of you on Teams can use the raise your hand feature to 17 signal that you have a question. Those on the phone 18 can use the -- star five.
19 Once our Teams facilitator enables your 20 microphone, you will have -- you will have to unmute 21 yourself before you ask your question. Please note 22 that the chat feature on Teams has been disabled.
23 If you are having trouble seeing the 24 slides, or if they cannot -- or if they are not 25 advancing for you, the slides that will be shown on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 1 Microsoft Teams can be found in the NRCs ADAMS 2 library at ML22108A142. You can also go to the 3 meeting notice page in the NRCs website, and there is 4 a link there to the slides.
5 Any phone attendees, please email 6 dan.doyle@nrc.gov for attendance. Thats D-A-N dot D-7 O-Y-L-E at nrc.gov.
8 One other item. Im hoping well fill out 9 -- Im hoping you will fill out -- this is our public 10 meeting feedback form. You can link to the public 11 meeting feedback form from the NRC public meeting 12 schedule page for this meeting. Your opinion on how 13 this meeting went will help us improve upon future 14 meetings. So please take a moment to let us know what 15 you think.
16 Those of you in the room today, please 17 note that the emergency exits are in the back of the 18 room. There is a restroom outside the meeting room to 19 the left.
20 Slide 5, please.
21 I would like to introduce Tara Inverso, 22 Deputy Director, Division of Rulemaking, 23 Environmental, and Financial Support, to give some 24 opening remarks.
25 MS. INVERSO: All right. Thank you, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 1 Steve. And good evening, everyone. I am Tara 2 Inverso, the Deputy Director of the NRCs Division of 3 Rulemaking, Environmental, and Financial Support.
4 I want to thank everyone for joining us 5 today to talk about the NRCs decommissioning proposed 6 rule. The NRCs goal for this rulemaking are to 7 maintain a safe, effective, and efficient 8 decommissioning process, incorporate lessons learned 9 from the decommissioning process, and support the 10 NRCs principles of good regulation, including 11 openness, clarity, and reliability.
12 The proposed rule would implement specific 13 regulatory requirements for different phases of the 14 decommissioning process consistent with the reduced 15 risk that occurs over time while continuing to 16 maintain safety and security.
17 The proposed rule would incorporate 18 lessons learned from plants that have recently 19 transitioned to decommissioning and that would improve 20 the effectiveness and efficiency of the regulatory 21 framework while protecting public health and safety.
22 Public comment has twice played an 23 important role in the development of this proposed 24 rule. We first published an advance notice of 25 proposed rulemaking and later a draft regulatory basis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 1 for comment.
2 We are seeing public input on the proposed 3 rule to implement regulations that will guide future 4 nuclear plant decommissioning. The rule addresses 5 several regulatory areas that you will hear about in 6 more detail during this public meeting.
7 We hope todays meeting will help you 8 better understand the proposed rule. We look forward 9 to your feedback and questions, but please note that 10 the NRC will not be responding in writing to verbal 11 comments from todays meeting. Comments must be 12 submitted in writing through the methods described in 13 the Federal Register Notice to receive formal 14 consideration in the rulemaking process.
15 This is our fourth public meeting on the 16 proposed rule. We will be having additional meetings 17 in other locations around the country with the option 18 of participating virtually. Please check the NRCs 19 public website for additional details about upcoming 20 public meetings and for other resources to help you as 21 you review the proposed rule.
22 Thank you.
23 MR. SMITH: Thank you, Tara.
24 Now Ill go ahead and turn it over to Dan.
25 MR. DOYLE: All right. Thank you. Ill NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 1 just turn on my camera here. Good evening. My name 2 is Dan Doyle. Im a Senior Project Manager at the 3 NRC. I will be giving -- providing an overview of the 4 rulemaking this evening.
5 If you attended any of our previous 6 meetings -- this is our fourth public meeting. We 7 have two more coming up. If you attended any of the 8 previous meetings, just please note that the first 9 half of this meeting will probably be about an hour.
10 But the NRC staff presentation is the same material as 11 the previous meetings, and then we will open it up for 12 Q&A. So that will be -- be different.
13 One final note before we move ahead is 14 about the meeting platform that were using. Were 15 streaming this meeting using Microsoft Teams. So you 16 should see the slides in the window, how youre 17 joined. Underneath that you should see arrows that 18 would allow you to move to a different slide.
19 Just be aware that that only affects your 20 view. That doesnt affect anyone else. So you can 21 feel free to move around and check out any of the 22 other slides if you want to. You should also be able 23 to click the links in the slides to access any of the 24 documents.
25 We have included several links that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 1 hope will be helpful to -- for your review of this 2 proposed rule. And if you have any trouble with that, 3 Ill have a link and show you a website where you can 4 get additional information or you can reach out to me 5 and I will be happy to help you.
6 Okay. Next slide, please. And next 7 slide.
8 All right. So Ill start off with just a 9 very brief background on why the NRC started this 10 rulemaking and the current status. There was an 11 increase in nuclear power plant shutdowns that focused 12 the NRCs attention on making some changes to the 13 regulations related to decommissioning for the NRC-14 initiated rulemaking in December 2015 to explore 15 changes related to that process.
16 We have already completed some extensive 17 public outreach. We solicited early comments on an 18 advance notice of proposed rulemaking, and we also 19 issued a regulatory basis document. We had public 20 comment periods on both of those and also public 21 meetings.
22 We do have information about both of those 23 early outreach efforts on our public website, which is 24 I believe highlighted later in our slides.
25 So the recent update with this project, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 and the reason were having this meeting today, is 2 because we published the proposed rule in the Federal 3 Register on March 3, 2022. The citation is 87 FR 4 12254.
5 So we are in the public comment period 6 right now. Its 75 days, so that will end in about a 7 month on May 17th, 2022.
8 Next slide, please.
9 For convenience, we have two slides that 10 list all of the key documents associated with this 11 proposed rule, with links to access them directly. So 12 this is the first slide. So, again, there is the 13 citation for the proposed rule with links to a web 14 version or the printed version.
15 We have supporting and related materials 16 listed here. First is a draft regulatory analysis, 17 which discusses the costs and benefits associated with 18 this action. We have a draft environmental assessment 19 for compliance with the National Environmental Policy 20 Act and draft supporting statements for information 21 collection.
22 So we do have some changes to information 23 collection requirements in this rulemaking. So those 24 are discussed in the supporting statements for 25 compliance with the Paperwork Reduction Act.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 1 There is an additional document listed at 2 the bottom. Thats the unofficial redline rule text.
3 So we have a slide later to show a little bit more 4 about that. So basically what that is, it shows how 5 the proposed rule would modify the current rule 6 language in a redline strikeout format. So showing 7 what words, language that would be inserted, what 8 would be deleted from the current regulation. So that 9 may be helpful, to see that in context.
10 Just wanted to emphasize -- hopefully the 11 title makes it clear that this is an unofficial 12 document, so please dont rely just on that for your 13 public comment. The official legal version is what is 14 published in the Federal Register.
15 Thank you.
16 Next slide.
17 We are also updating four guidance 18 documents as part of this rulemaking. So they are 19 available for public comment as well. They are listed 20 here on the slide. The first one would be a new 21 regulatory guide, and the other three are updates to 22 existing NRC regulatory guides.
23 The first one, Draft Guide 1346, is 24 related to emergency planning for decommissioning 25 nuclear power plants. The second one, Draft Guide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 1 1347, would be an update to Regulatory Guide 1.184, 2 decommissioning nuclear power plants.
3 Next one, Draft Guide 1348, is an update 4 to Reg Guide 1.159, availability of funds for 5 decommissioning production or utilization facilities.
6 And the last one on the list, Draft Guide 1349, would 7 be an update to Reg Guide 1.185, standard format and 8 content for post-shutdown decommissioning activities 9 report.
10 So these four documents are also out for 11 public comment now. If you have comments on the rule 12 and the guidance, please go ahead and submit it all 13 together in the same document. Its all going to the 14 same place.
15 Next slide, please.
16 So for this part of the meeting, we will 17 give an overview of the proposed rule. Ill start 18 with a general discussion of the graded approach 19 concept and how that has been applied to several 20 technical areas. The rest of the slides are going to 21 give an overview of each of the 16 technical areas or 22 topics in the proposed rule.
23 I would also like to point out that I am 24 the rulemaking project manager and serving as a 25 spokesperson for the rule today, but we have a great NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 1 team of NRC staff who are the subject matter experts 2 on these topics, and many of them are on the line here 3 today available for the question and answer session 4 later in the meeting.
5 Next slide, please.
6 The proposed rule takes a graded approach 7 to decommissioning where different levels of 8 requirements apply at different stages of the 9 decommissioning process. Across the top of this table 10 are the four levels used in the proposed rule as a 11 facility goes through the decommissioning process.
12 Level 1 begins after the facility dockets 13 the two required certifications. One is for permanent 14 cessation of operations, and the other is that the 15 fuel has been removed from the reactor vessel.
16 Level 2 is after a period of sufficient 17 decay of the spent fuel, which would generically be 10 18 months for a boiling water reactor or 16 months for a 19 pressurized water reactor if they meet the criteria in 20 the proposed rule.
21 Level 3 would then -- would be when all 22 fuel is in dry cask storage.
23 And Level 4 would be when all fuel is 24 offsite.
25 The rows in this table show the topic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 1 areas that have updated requirements linked at these 2 levels. Emergency preparedness would use all four 3 levels, starting with the post-shutdown emergency plan 4 in Level 1 through Level 4 where there is no longer a 5 need for an onsite radiological emergency response 6 plan because all fuel is offsite.
7 Other topic areas that use the graded 8 approach include physical security, cyber security, 9 and onsite/offsite insurance, which well discuss in 10 the upcoming slides.
11 Next slide, please.
12 This is the first of the topic slides. So 13 for each of these topic slides you will see a summary 14 of the proposed changes. There is a box in the upper 15 right corner that identifies the section in the 16 proposed rule with a more detailed discussion of the 17 topic as well as the page numbers. And we have also 18 listed all of the sections of the CFR, or Code of 19 Federal Regulations, that would be changed.
20 Where it says specific request for 21 comments on each slide, we will mention if there are 22 any questions related to this topic in Section V of 23 the proposed rule where the NRC included a number of 24 questions for the public to consider as it provides 25 comment.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 1 On the bottom of the slide, we have a 2 progress bar showing which topic were on, the ones 3 that we did recently, and the ones that are coming up 4 next. We also had additional information where we may 5 include some information wed like you to be aware of.
6 All right. So jumping into the first 7 topic here, emergency preparedness. Because the 8 current regulations do not provide a means to 9 distinguish between the EP requirements that apply to 10 an operating reactor and the EP requirements that 11 apply to a reactor that has permanently ceased 12 operations, decommissioning licensees have 13 historically requested exemptions from EP 14 requirements.
15 The proposed rule would provide common EP 16 requirements for reactors in decommissioning, 17 eliminating the need for specific exemptions or 18 license amendments. Because of the decreased risk of 19 offsite radiological release and the fewer types of 20 possible accidents that can occur at a decommissioning 21 reactor, the proposed EP requirements aligned with 22 that reduction in risk while maintaining safety.
23 So the changes that we are proposing.
24 Were proposing to add a new section, 10 CFR 50.200, 25 which would provide planning standards and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 1 requirements for post-shutdown and permanently 2 defueled emergency plans. The proposed standards and 3 requirements for emergency plans are consistent with 4 the level of planning the Commission has previously 5 approved for decommissioning facilities.
6 The proposed planning requirements also 7 ensure close coordination and training with offsite 8 response organizations is maintained throughout the 9 decommissioning process. The NRC is also proposing to 10 amend 10 CFR 50.54(q) to provide licensees with the 11 option to use the tiered requirements and standards at 12 the appropriate time in decommissioning and to add a 13 new process by which licensees can make changes to the 14 emergency plans to transition between levels.
15 There are two specific questions related 16 to this topic. So the first one, wed like to know 17 what you see as the advantages and disadvantages of 18 requiring dedicated radiological emergency planning, 19 including a 10-mile EPZ until all spent nuclear fuel 20 at a site is removed from the spent fuel pool and 21 placed in dry cask storage.
22 Is there additional information the NRC 23 should consider in evaluating whether all hazards 24 planning would be as effective as dedicated 25 radiological emergency planning?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 1 The NRC has determined that 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> would 2 be a sufficient amount of time for an emergency 3 response to the spent fuel pool accident based on an 4 all hazards plan. Is there additional information the 5 NRC should consider in evaluating this issue?
6 And then the second question is related to 7 emergency response data systems. Nuclear power 8 facilities that are shut down permanently or 9 indefinitely are currently not required to maintain 10 emergency response data systems. These systems 11 transmit near real-time electronic data between the 12 licensees onsite computer system and the NRC 13 operations center.
14 Licensees in Level 1 would maintain a 15 capability to provide meteorological, radiological, 16 and spent fuel pool data to the NRC within a 17 reasonable timeframe following an event. What are the 18 advantages and disadvantages of requiring nuclear 19 power plant licensees to maintain those aspects of the 20 emergency response data system until all spent fuel is 21 removed from the pool?
22 And then additional information, just 23 pointing out that we have developed guidance 24 corresponding to the proposed changes on this topic.
25 For EP, we have this new -- proposed new regulatory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 1 guide, emergency planning for decommissioning nuclear 2 power reactors, Draft Guide 1346. The NRC staff 3 believes that these changes will establish EP 4 requirements commensurate with the reduction in 5 radiological risk as licensees proceed through the 6 decommissioning process while continuing to provide 7 reasonable assurance that protective actions can and 8 will be taken, and maintaining EP as a final 9 independent layer of defense in depth.
10 Next slide, please.
11 All right. I will now turn it over to Mr.
12 Howard Benowitz from the Office of the General 13 Counsel.
14 MR. BENOWITZ: Thanks, Dan.
15 Hi, everyone. My name is Howard Benowitz.
16 Im in the NRCs Office of the General Counsel. And 17 on slide 14 we will be discussing the proposed changes 18 to the backfit rule.
19 The NRCs backfit rule is found in 10 CFR 20 Section 50.109. And in the proposed rule we would 21 provide a new backfitting provision for nuclear power 22 reactor licensees in decommissioning. The proposed 23 rule would renumber the paragraphs in Section 50.109, 24 so Section 50.109(a) would be the current backfit 25 rule, and a new Section 50.109(b), Bravo, would be the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 1 new rule text for decommissioning nuclear power 2 reactor licensees.
3 The NRC is also proposing edits to the 4 backfitting provision in Part 72, so that that 5 provision applies during the decommissioning of an 6 independent spent fuel storage installation, or an 7 ISFSI, or a monitored retrievable storage facility.
8 The proposed rule would also revise the 9 compliance exception to the requirement to perform a 10 backfit analysis, and the proposed rule would 11 specifically require the NRC to consider the costs of 12 imposing a backfit when the basis for backfitting is 13 use of that compliance exception.
14 This change is based on a 2019 update to 15 the Commissions backfitting policy that you can find 16 in Management Directive 8.4, and thats available on 17 our public website.
18 There is a specific request for comment in 19 the Federal Register Notice regarding these proposed 20 changes, and thats essentially, should we apply the 21 backfit rule to power reactor licensees in 22 decommissioning? So please give us your thoughts on 23 that.
24 Next slide, please.
25 MR. DOYLE: Okay. Back to me. So we are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 1 on environmental considerations. The proposed rule 2 clarifies various environmental reporting 3 requirements, including those related to the content 4 of the post-shutdown decommissioning activities 5 reports, or PSDARs.
6 In part, the proposed rule change would 7 clarify that licensees at the PSDAR stage are required 8 to evaluate the environmental impacts from 9 decommissioning and provide in the PSDAR the basis for 10 whether the proposed decommissioning activities are 11 bounded by previously issued site-specific or generic 12 environmental reviews.
13 The Commission provided additional 14 direction to the staff in its staff requirements 15 memorandum with respect to the consideration of any 16 unidentified -- Im sorry, of any identified unbounded 17 impacts. The rule changes would allow licensees to 18 use appropriate federally issued environmental review 19 documents prepared in compliance with the Endangered 20 Species Act, National Historic Preservation Act, or 21 other environmental statutes, rather than just 22 environmental impact statements.
23 The rule would also remove language 24 referencing amendments or authorizing decommissioning 25 activities in 10 CFR Part 51.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 1 In developing the original proposed rule, 2 the NRC staff considered but dismissed a proposal that 3 staff approve each licensees PSDAR before allowing 4 major decommissioning activities to begin. This was 5 done on the basis that requiring approval of a PSDAR 6 would have no additional benefit in terms of public 7 health and safety.
8 However, we have included a specific 9 request for comment about whether the NRC should 10 require approval of the PSDAR, a site-specific 11 environmental review, and a hearing opportunity before 12 undertaking any decommissioning activity.
13 Other than NRC review and approval of the 14 PSDAR, are there other activities that could help to 15 increase transparency and public trust in the NRC 16 regulatory framework for decommissioning, should the 17 rule provide a role for the states or local 18 governments in the process, and what should that role 19 be?
20 A few regulatory guides related to PSDARs 21 were revised to include clarifying language consistent 22 with the rule changes. And we would also like to note 23 that the decommissioning generic environmental impact 24 statement will be updated by the NRC, but that will be 25 a separate action apart from this rulemaking activity.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 1 So that will be updated in the future.
2 Next slide, please.
3 MR. BENOWITZ: Back to me for slide 16.
4 Were on license -- this one concerns license 5 termination plan requirements.
6 So in the proposed rule, the NRC would 7 clarify that 10 CFR 50.82 and 52.110 do not apply 8 before fuel has been loaded into the reactor 9 consistent with historical NRC practice. These 10 license termination provisions are written for 11 reactors that have commenced operation, and the NRC 12 has historically viewed operation as beginning with 13 the loading of fuel into the reactor, which is -- this 14 is discussed in the proposed rule Federal Register 15 Notice.
16 The NRC is proposing this change because 17 some confusion arose about whether 10 CFR 52.110 was 18 applicable when certain combined license holders 19 sought to terminate their licenses during construction 20 or before construction had begun. At that time, the 21 NRC informed the licensees that Section 52.110 did not 22 apply for the reasons that are also documented in the 23 proposed rule.
24 And there is not a specific request for 25 comment on this provision.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 1 Ill turn it back to Dan.
2 MR. DOYLE: Okay. Next topic, please.
3 Decommissioning funding assurance. So for 4 this topic we have two slides. So the first one 5 providing a summary of changes related to this topic.
6 The proposed rule modifies the Biennial 7 Decommissioning Trust Fund reporting frequency for 8 operating reactors in 10 CFR 50.75 to be consistent 9 with the three-year reporting frequency for 10 independent spent fuel storage installations, or 11 ISFSIs.
12 Were making two changes related to ISFSI 13 funding reports. One is that it would allow licensees 14 to combine the reports required by the regulations 15 listed on the slide, 50.82(a)(8)(v), 50.82(a)(8)(vii),
16 and 10 CFR 72.30.
17 The other related change is that the 18 proposed rule would remove the requirement for NRC 19 approval of the report filed under 10 CFR 72.30(c).
20 The proposed rule would clarify that when 21 a licensee identifies a shortfall in the report 22 required by 50.75(f)(1), the licensee must obtain 23 additional financial assurance to cover the shortfall 24 and discuss that information in the next report.
25 And then the final item to highlight, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 1 proposed rule would make administrative changes to 2 ensure consistency with 10 CFR 50.4, written 3 communications regarding the submission of 4 notifications and to eliminate 10 CFR 50.75(f)(2),
5 because 50.75(f)(1) fully encompasses paragraph 6 (f)(2).
7 Next slide, please.
8 We do have several specific questions on 9 this topic. So Im just going to briefly go through 10 each of those.
11 Related to financial assurance, what are 12 the advantages and the disadvantages -- what are the 13 advantages and disadvantages of updating the formula 14 to reflect recent data and to cover all estimated 15 radiological decommissioning costs rather than the 16 bulk of the costs?
17 For a site-specific cost analysis, what 18 are the advantages and disadvantages of requiring a 19 full site investigation and characterization at the 20 time of shutdown and of eliminating the formula and 21 requiring a site-specific cost estimate during 22 operations?
23 Decommissioning Trust Fund. Should the 24 NRCs regulations allow Decommissioning Trust Fund 25 assets to be used for spent fuel management if, one, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 1 there is a protected surplus in the fund based on a 2 comparison to the expected costs identified in a site 3 specific cost estimate; and, two, if the assets are 4 returned to the fund within an established period of 5 time.
6 What are the advantages and disadvantages 7 of allowing Decommissioning Trust Fund assets to be 8 used for those purposes? What are the advantages and 9 disadvantages of allowing Decommissioning Trust Fund 10 assets to be used for non-radiological site 11 restoration prior to the completion of radiological 12 decommissioning?
13 Timing of the decommissioning fund 14 assurance report -- reporting. What are the 15 advantages and disadvantages of extending the 16 reporting frequency from two years to three years?
17 Does this change affect the risk of insufficient 18 decommissioning funding?
19 And we also have a question about 20 identical requirements under 10 CFR 50.82 and 52.110.
21 Besides proposing conforming changes to 10 22 CFR Part 52, the NRC is asking whether the NRC should 23 continue to maintain identical requirements in 10 CFR 24 52.110 and 10 CFR 50.82.
25 We are also -- so, finally, on this slide, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 1 we are also proposing conforming changes to Regulatory 2 Guide 1.159, assuring the availability of funds for 3 decommissioning production or utilization facilities.
4 Next slide, please.
5 So for offsite and onsite financial 6 protection requirements, and indemnity agreements, 7 these changes would provide regulatory certainty by 8 minimizing the need for licensees of decommissioning 9 reactors to request regulatory exemptions for relief 10 from requirements that should apply only to operating 11 reactor licensees.
12 We do have two specific requests for 13 comment on this topic regarding insurance. What are 14 the advantages and disadvantages of requiring the 15 existing level of insurance to be maintained until all 16 spent fuel is in dry cask storage, which would be 17 Level 3?
18 And the other question related to 19 insurance for specific license ISFSIs. The NRC 20 recognizes that as a reactor site is decommissioned, 21 eventually all that remains of the 10 CFR Part 50 or 22 Part 52 license site is a general license ISFSI under 23 10 CFR Part 72, which is essentially the same as a 24 specific license ISFSI under 10 CFR Part 72.
25 Considering that 10 CFR Part 72 specific NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 1 license ISFSIs have no financial protection 2 requirements, should the NRC address the disparity 3 between specific license and general license ISFSIs as 4 part of this rulemaking? Please provide an 5 explanation for your response.
6 Next slide, please.
7 MR. BENOWITZ: Slide 20 concerns foreign 8 ownership, control, or domination. That really 9 focuses on -- this change focuses on, what is a 10 production or utilization facility during the 11 decommissioning process?
12 The Atomic Energy Act and the NRCs 13 regulations provide definitions for a utilization 14 facility and production facility. Additionally, 15 certain other provisions of the Atomic Energy Act and 16 the NRCs regulations, including the foreign 17 ownership, control, or domination prohibition, apply 18 only to a utilization or production facility.
19 During the decommissioning process, a 20 utilization facility or production facility will be 21 dismantled to the point at which it no longer meets 22 the definition of a utilization facility or production 23 facility.
24 The proposed rule adds language to the 25 regulations to establish the criteria for when exactly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 1 a production facility or utilization facility is no 2 longer a production facility or utilization facility.
3 The proposed rule also adds language to 4 affirm that despite the change, the NRC continues to 5 have statutory authority over the existing 10 CFR Part 6 50 or Part 52 license, and that the NRC regulations 7 applicable to utilization or production facilities 8 will continue to apply to the older of that Part 50 or 9 52 license, unless regulations explicitly state 10 otherwise.
11 And one of those regulations is the 12 foreign ownership, control, or domination provision, 13 and the proposed rule would amend that provision to 14 state that the prohibition on foreign ownership, 15 control, or domination no longer applies once the Part 16 50 or 52 facility is no longer a utilization or 17 production facility.
18 Therefore, the NRCs regulations would not 19 prohibit the transfer of a Part 50 or 52 license for a 20 facility that is no longer a utilization or production 21 facility to a foreign-owned, controlled, or dominated 22 entity.
23 There is no specific request for comment 24 on this -- on these proposed changes. You can see in 25 the top right corner that there are several provisions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 1 that would be affected or amended. So please take a 2 look at that and provide any comments that you might 3 have.
4 Thanks.
5 Next slide, please.
6 MR. DOYLE: So physical security. The 7 proposed rule would allow certain changes to eliminate 8 licensee requests for approvals via exemptions, 9 amendments, and for certain adjustments to their 10 physical security programs.
11 Current security requirements do not 12 reflect the reduced risk of a decommissioning facility 13 after fuel is removed from the reactor vessel. When 14 the fuel is transferred to a spent fuel pool, the 15 amount of plant equipment that is relied upon for the 16 safe operation of the facility is significantly 17 reduced, which allows for certain security measures to 18 be eliminated because their implementation is no 19 longer needed or the security measures can be adjusted 20 for the physical protection program during 21 decommissioning.
22 Because certain security measures can be 23 adjusted or no longer are necessary for 24 decommissioning, commonly requested exemptions and 25 amendments have been submitted by licensees to address NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 this new posture. For example, the control room is 2 specifically identified in current security 3 requirements as an area that must be protected as a 4 vital area.
5 The proposed rule would potentially 6 eliminate the need to identify the control room as a 7 vital area when all vital equipment is removed from 8 the control room and when the area does not act as a 9 vital area boundary for other vital areas.
10 Also, current security regulations for a 11 power reactor licensee require the use of licensed 12 senior operators for the suspension of security 13 measures during emergencies. For permanently shut 14 down and defueled reactors, licensed senior operators 15 are no longer required. The proposed rule would allow 16 certified fuel handlers to be used to suspend security 17 measures during emergencies at a decommissioned 18 facility.
19 And then, lastly, to eliminate the need 20 for the submission of license amendments and 21 exemptions for licensee transitions to ISFSIs, the NRC 22 is proposing that once all spent nuclear fuel has been 23 placed in dry cask storage, licensees may elect to 24 protect the general license ISFSI in accordance with 25 the physical security requirements that are consistent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 1 with Part 72 Subpart H and 10 CFR 73.51.
2 Licensees would continue to address the 3 applicable security-related orders associated with an 4 ISFSI that are conditions of the license.
5 Next slide, please.
6 Cybersecurity. Consistent with the graded 7 approach, the proposed rule would continue to apply 8 cybersecurity requirements to decommissioning plants 9 until the risk to public health and safety is 10 significantly reduced.
11 Specifically, the cybersecurity 12 requirement would be applicable until the fuel is 13 permanently removed from the reactor vessel to the 14 spent fuel pool and there has been a sufficient decay 15 such that there is a very low risk that the spent fuel 16 could heat up to clad ignition temperature within 10 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> if the spent fuel pool were drained.
18 Under the proposed rule, power reactor 19 licensees under Part 50 or Part 52 -- Part 50 and Part 20 52 -- would be subject to the same requirement. For 21 Part 50 reactor licensees, the proposed rule would 22 remove the license condition that requires the 23 licensee to maintain its cybersecurity plan. And for 24 Part 52 combined license holders, the proposed rule 25 would extend the requirement to maintain their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 1 cybersecurity plan during decommissioning, which would 2 be a new requirement.
3 For currently operating or recently 4 shutdown 10 CFR Part 50 reactor licensees, because the 5 licensees cybersecurity plan is included as a license 6 condition, this license condition to maintain the 7 cybersecurity program per their cybersecurity plans 8 remains in effect until the termination of the license 9 or the NRC removes the condition from the license; for 10 example, if the licensee submits a license amendment 11 request and the NRC approves it.
12 Therefore, the proposed rule would not 13 constitute backfitting because it would codify the 14 already imposed requirements of the cybersecurity plan 15 license conditions during Level 1 of decommissioning 16 or until the spent fuel in the spent fuel pool has 17 sufficiently cooled.
18 This is not the case for combined license 19 holders currently. The proposed revision would 20 constitute a new requirement because the operational 21 program, such as security programs that include a 22 cybersecurity program, are requirements in the 23 regulations and not separately identified as license 24 conditions like for Part 50 licensees.
25 Presently, combined license holders are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 1 required to maintain a cybersecurity program only as 2 long as 10 CFR 73.54 is applicable to them. This 3 means that combined license holders are not required 4 to maintain their cybersecurity programs during 5 decommissioning because a power reactor licensee is 6 not authorized to operate a nuclear power reactor 7 during decommissioning.
8 We do have a specific request for comment 9 on this topic. The proposed rule applies the 10 cybersecurity requirements to Level -- plants in Level 11 1. However, a licensee in Level 2 would not be 12 required to maintain a cybersecurity plan because the 13 NRC has determined that there is little chance that 14 the spent fuel in the spent fuel pool could heat up to 15 clad ignition temperature within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.
16 So we do have a question. Lets see here.
17 What are the advantages and disadvantages of 18 extending the cybersecurity requirements to shut down 19 nuclear power plants until all spent fuel is 20 transferred to dry cask storage. So thats what the 21 specific question is about.
22 The change to 10 CFR 73.54 is identified 23 in the proposed rule as a change affecting issue 24 finality for 10 CFR Part 52 combined license holders 25 as defined in 10 CFR 52.98. So, therefore, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 1 proposed rule includes a backfit analysis in Section 2 9(d).
3 Next slide, please.
4 The drug and alcohol testing topic. The 5 proposed rule would make several changes related to 6 requirements for drug and alcohol testing. There are 7 three items that Id like to highlight related to this 8 topic. The first one for 10 CFR Part 26, which is 9 related to fitness for duty, the proposed rule would 10 amend 10 CFR 26.3, scope, to correct an inconsistency 11 in the applicability of Part 26 to Part 50 and 52 12 license holders of nuclear power reactors.
13 Part 26 does not apply to a Part 50 14 license holder once the NRC dockets licensees 10 CFR 15 50.82(a)(1) certification that the power reactor has 16 permanently ceased operations, which formally begins 17 the decommissioning process.
18 However, Part 26 continues to apply to the 19 holder of a combined license issued under Part 52 20 throughout decommissioning. No technical basis exists 21 for this inconsistency, so Section 26.3 would be 22 revised to specify that Part 26 also no longer applies 23 to a Part 52 license holder once the NRC dockets the 24 licensees 52.110(a) certification that the power 25 reactor has permanently ceased operations.
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36 1 The second topic or second item related to 2 this topic is Part 26 criminal penalties. Section 3 26.3 includes a substantive requirement for certain 4 entities to comply with the requirements in 10 CFR 5 Part 26 by a specific deadline, and violations of this 6 regulation should be subject to criminal penalties.
7 The specific deadlines in 10 CFR 26.3(a) 8 were added in a 2008 Part 26 final rule, but 10 CFR 9 26.825(b) was not updated to reflect this change, 10 which was an oversight. Therefore, the proposed rule 11 would remove 10 CFR 26.3 from the list of provisions 12 that are not subject to criminal penalties if violated 13 in 10 CFR 26.825(b).
14 Last item. This relates to the insider 15 mitigation program. Section 73.55(b)(9)(ii)(B) 16 requires that a licensees insider mitigation program 17 contained elements of a fitness for duty program 18 described in Part 26, but does not identify which 19 fitness for duty program elements must be included in 20 the insider mitigation program.
21 The proposed rule would establish the 22 required elements of a fitness for duty program in the 23 insider mitigation program for operating and 24 decommissioning reactors under Parts 50 and 52.
25 Next slide, please.
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37 1 MR. BENOWITZ: Slide 24 concerns the 2 removal of license conditions and the withdrawal of an 3 order. The NRC would propose to withdraw an order and 4 remove license conditions that are substantively 5 redundant with existing provisions in the NRCs 6 regulations.
7 The order is Order EA-06-137, which 8 concerns mitigation strategies for large fires or 9 explosions at nuclear power plants. The license 10 conditions are the conditions associated with that 11 order and Order EA-02-026, which was an order issued 12 right after the events of 9/11.
13 There is also a license condition that Dan 14 just mentioned regarding the cybersecurity license --
15 the cybersecurity license condition that also would be 16 removed. Now, these license conditions are currently 17 parts of licenses, but under the proposed rule, these 18 license conditions would be deemed removed, and then 19 the NRC staff would actually remove them through 20 administrative license amendments after the effective 21 date of the final rule.
22 In this way, licensees would not need to 23 submit license amendment requests. The NRC can, on 24 its own initiative, do that, and essentially just --
25 it would mail or email, or however, the new pages --
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38 1 the marked up pages and new pages of the license to 2 reflect the removal of the license conditions.
3 We did include in the Federal Register 4 Notice a request for comment on this topic. We are 5 interested in if there are any potential redundant 6 requirements that we did not include in this proposed 7 rule that you think we should remove because, again, 8 they are substantively redundant. And, therefore, we 9 are not -- dont need to have more than one of the 10 same requirement.
11 Next slide, please.
12 MR. DOYLE: Slide 25, spent fuel 13 management planning. So brief background on this 14 topic. The NRC staff identified ambiguity in the 15 spent fuel management and decommissioning regulations 16 due to a lack of cross referencing between Part 72 and 17 Part 50. The rulemaking clarifies the information for 18 consistency.
19 Specifically, the regulation in 10 CFR 20 72.218 states that the 50.54(bb) spent fuel management 21 program, the irradiated fuel management plan, or IFMP, 22 must show how the spent fuel will be managed before 23 starting to decommission systems and components needed 24 for moving, unloading, and shipping the spent fuel.
25 Section 72.218 also requires that an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 1 application for termination of a reactor operating 2 license submitted under 10 CFR 50.82, or 52.110, must 3 also describe how the spent fuel stored under the Part 4 72 general license will be removed from the reactor 5 site.
6 Although 10 CFR 72.218 states what 7 information must be included in these Part 50 8 documents, the corresponding regulations in Part 50 do 9 not contain this information. Therefore, the NRC 10 proposes to clarify and align the regulations in 11 50.54(bb), 50.82, and 52.110, and 72.218, to ensure 12 appropriate documentation -- whew, I need some more 13 water here -- to ensure appropriate documentation of 14 spent fuel management plans and decommissioning plans.
15 I think Im going to have to come back to 16 this one. I cant really -- let me see if we have 17 another slide here.
18 Can we skip to slide 28? Sorry.
19 MR. BENOWITZ: No. No problem, Dan.
20 Slide 28. That concerns proposed changes to make our 21 regulations consistent in how we -- in how they apply 22 to Part 50 licensees and Part 52 licensees in 23 decommissioning.
24 Right now, we have regulations -- quite a 25 few. If you look in the top right corner of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 1 slide, you can see that we have many regulations that 2 reference -- for the most part they reference only the 3 Part 50 decommissioning regulation, 50 -- 10 CFR 4 50.82. They do not also reference Section 52.110, or 5 maybe -- or 110(a). Sometimes there are references to 6 52.110(a)(1) when it should be just 52.110(a).
7 And so there are several -- I wont call 8 them typos, but in some cases they are just to the 9 wrong paragraph within the section. Sometimes we 10 dont -- the section itself is not included in that 11 regulatory provision. Thats just the nature of, 12 unfortunately, doing rulemaking over the years, not 13 catching every one, but then this rule we hope that we 14 have done that, gone through all of the regulations, 15 Part 50 and 52, where one or the other provision is 16 referenced and without the other. And so our proposal 17 is to include both, to capture the 50 and 52 18 licensees.
19 If you find that we missed one, please let 20 us know. I think we -- I think we got them all.
21 Dan, thats all I have. I can keep 22 talking, but if youre okay to come back, that would 23 be great.
24 MR. DOYLE: I apologize for that.
25 Hopefully, Ill be able to -- Ill be able to keep it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 1 together here. Sorry. Allergies are -- Im having 2 some trouble with, having some trouble here.
3 Okay. So were back on slide 25, please.
4 Spent fuel management planing. So I was about to 5 explain the rule changes that we are proposing. I had 6 pointed out the inconsistency that the staff had 7 discussed.
8 We do have changes to 10 CFR 50.54(bb).
9 We propose moving the 72.218 provisions to 50.54(bb) 10 to clarify that the IFMP must be submitted and 11 approved before the licensee starts to decommission 12 systems, structures, and components needed for moving, 13 unloading, and shipping the spent fuel.
14 The NRC proposes to clarify the current 15 IFMP approval process and the 50.54(bb) provisions 16 regarding preliminary approval and final NRC review of 17 IFMP as part of any proceeding for continued licensing 18 under Part 50 or Part 72 as these proceedings no 19 longer exist as they did when 50.54(bb) was first 20 promulgated.
21 The NRC proposes to require submittal of 22 the initial IFMP and any subsequent changes to the 23 IFMP as a license amendment request.
24 Changes to 72.218. The NRC proposes 25 revising 72.218 to address requirements related to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
42 1 decommissioning and termination of the Part 72 general 2 license as the current title of 72.218, termination of 3 licenses, suggests.
4 MR. BENOWITZ: Dan, dont mean to 5 interrupt, but seriously, if you want me to continue 6 at any point, just let me know. Okay?
7 MR. DOYLE: Okay. I appreciate that.
8 So, specifically, the proposed 72.218 9 notes that the general license ISFSI must be 10 decommissioned, consistent with the requirements in 11 50.82 or 52.110, as the general license ISFSI is part 12 of the Part 50 or Part 52 license site.
13 Also, the proposed 72.218 notes that the 14 general license is terminated upon termination of the 15 Part 50 or Part 52 license. We do have a specific 16 request for comment on this topic. The proposed rule 17 clarifies that the current IFMP approval process, by 18 requiring submittal of the initial IFMP and any 19 changes to the IFMP, for review and approval by 20 license amendment, we would like to know if 21 stakeholders see any challenges with implementing this 22 part of the proposed rule.
23 We are also considering including a change 24 control provision to specify what changes a licensee 25 can make to the IFMP without NRC approval. Wed like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 1 to know what stakeholders -- wed like to know 2 stakeholders opinions on a change control process, 3 including the criteria for changes that licensees 4 could make without NRC approval, and any associated 5 recordkeeping or reporting for those changes.
6 The undeveloped guidance corresponding to 7 proposed rule changes for the IFMP, we added guidance 8 to Draft Guide 1346, Section (c)(3), to outline the 9 information to be included in the licensees IFMP.
10 And then for general license ISFSI 11 decommissioning, we added references to general 12 license ISFSIs in both Draft Guide 1347 and 1349 to 13 make it clear that the general license ISFSI must be 14 decommissioned, consistent with the requirements in 10 15 CFR 50.82 and 52.110.
16 The NRC staff believes that these changes 17 will provide regulatory clarity and enhance overall 18 regulatory transparency and openness regarding 19 decommissioning and spent fuel management planning.
20 Next slide, please.
21 Low-level waste transportation. When a 22 plant is actively being decommissioned, the plant 23 typically generates large volumes of bulk low-level 24 radioactive waste. To officially manage the 25 transportation of the waste to a licensed disposal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 1 site, most licensees ship waste by rail.
2 The railroads control the schedule for the 3 transportation of the railcars to the destination, and 4 the time to reach the disposal site destination is 5 generally more than the current 20-day notification 6 requirement.
7 So licensees -- under the proposed rule, 8 the licensees would continue to monitor and track the 9 location and progress of their low-level waste 10 shipments, but notifications to the NRC would no 11 longer be required unless the new proposed 45-day 12 limit is exceeded.
13 All right. Next slide here? So were on 14 slide 27.
15 Certified fuel handler definition and 16 elimination of the shift technical advisor. So its 17 kind of two topics combined under one heading.
18 Certified fuel handlers are non-licensed 19 operators who are commonly used at permanently 20 defueled nuclear facilities with irradiated fuel in 21 their spent fuel pools. A certified fuel handler is 22 intended to be the on-shift representative who is 23 responsible for safe fuel handling activities and is 24 always present on shift to ensure safety of the spent 25 fuel and any decommissioning-related activities at a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 1 facility.
2 Currently, a certified fuel handler is 3 qualified through a training program that must be 4 reviewed and approved by the NRC. The proposed rule 5 would modify the definition of a certified fuel 6 handler and add a provision that removes the need for 7 NRC approval of the training program if the training 8 program for certified fuel handlers is derived from a 9 systems approach to training and includes specific 10 topics which are outlined in the proposed rule 11 language.
12 Specifically, the training program must 13 address the safe conduct of decommissioning 14 activities, safe handling and storage of spent fuel, 15 and appropriate response to plant emergencies.
16 And then regarding the technical advisor, 17 the proposed rule would clarify that the shift 18 technical advisor is not required for decommissioning 19 nuclear power reactors.
20 Next slide, please.
21 Okay. This is the one that Howard 22 covered. Appreciate the pinch hit help there, Howard, 23 so we can move ahead to slide 29.
24 Record retention requirements. As noted, 25 when a plant is no longer operating in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 1 decommissioning, most plant components, such as pumps 2 and valves, are no longer in service and will 3 eventually be removed as part of the dismantlement 4 activities. Therefore, there is no longer a need to 5 retain certain records associated with these 6 components, and the rulemaking eliminates many 7 recordkeeping retention requirements.
8 This proposed change would not impact the 9 records that are required to be maintained in support 10 of decommissioning and license termination activities.
11 The proposed rule also includes a specific question 12 concerning the recordkeeping requirements for 13 facilities licensed under 10 CFR Part 52.
14 One of the rulemakings few proposed 15 changes to Part 52 would be in 10 CFR 52.63 regarding 16 the recordkeeping and retention requirements for 17 departures from the design of a facility. However, 18 these changes would not apply to a combined license 19 holder that references one of the certified designs in 20 the Part 52 appendices because those appendices have 21 their own recordkeeping provisions.
22 The NRC is asking in this proposed rule if 23 we should revise the Part 52 appendices to conform 24 those recordkeeping requirements with those proposed 25 in 10 CFR 52.63.
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47 1 Next slide, please.
2 Okay. So were on slide 30. So we have 3 completed all of the topic slides. There were 16 of 4 them. So this slide lists the specific requests for 5 comment. We have already highlighted most of these.
6 As I mentioned, in Section V of the proposed rule, we 7 do have these areas where were trying to highlight 8 for stakeholders information that would be 9 particularly helpful for the NRC.
10 Just to point out, there were three of 11 them that were not mentioned in the previous topic 12 slides, so Ill just briefly summarize them here.
13 The timeframe for decommissioning, the 14 second one of the left, the NRC is not proposing 15 changes to the decommissioning timeframe requirements, 16 but we are asking a question. What are the advantages 17 and disadvantages of requiring prompt decontamination 18 rather than allowing up to 60 years to decommission a 19 site?
20 As part of its review of a PSDAR, what are 21 the advantages and disadvantages of NRC evaluating and 22 making a decision about timeframe for decommissioning 23 on a site-specific basis?
24 Related to exemptions, which is the second 25 one on the right, as stated in the proposed rule, one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 1 of the goals of amending these regulations is to 2 reduce the need for regulatory exemptions. 10 CFR 3 50.12 -- 10 CFR 50.12 states that the Commission may 4 grant exemptions from the requirements of the 5 regulations in 10 CFR Part 50 if the request will not 6 present an undue risk to public health and safety and 7 is consistent with the common defense and security.
8 What are the advantages and disadvantages 9 of the current 10 CFR 50.12 approach to 10 decommissioning-related exemptions? What standard 11 should the NRC apply in determining whether to grant 12 exemptions from the new or amended regulations? What 13 are the advantages and disadvantages of providing an 14 opportunity for the public to weigh in on such 15 exemption requests?
16 Are there other process changes the NRC 17 should consider in determining whether to grant 18 exemptions from the new or amended regulation?
19 And then the final one to highlight is 20 applicability, the third one on the right.
21 Specifically, there is a discussion related to 22 applicability to NRC licensees during operations and 23 to ISFSI only and standalone ISFSI decommissioned 24 reactor sites. Permanently shut down nuclear power 25 plants will be at different stages of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 1 decommissioning process when the new decommissioning 2 regulations become effective and will have -- may have 3 previously received varying regulatory exemptions.
4 Can you foresee any implementation issues 5 with the proposed rule as its currently written 6 related to applicability for these licensees? For any 7 new or amended requirement included in the proposed 8 rule, how should the requirement apply to sites 9 currently in decommissioning -- the different stages 10 of decommission?
11 Next slide, please.
12 Okay. As I mentioned earlier, we do have 13 a regulatory analysis document for this rulemaking, as 14 we do for many other rulemaking activities, where we 15 discuss the cost and benefits associated with this 16 action. So this slide is just to provide an overview 17 and a summary of this -- of the conclusions from our 18 analysis.
19 So, overall, the proposed rule was 20 determined to be overall cost beneficial with the 21 estimated net averted cost, meaning costs that 22 otherwise would have taken place -- so savings -- of 23 approximately 17.9 million at a seven percent net 24 present value.
25 So the net present value, as mentioned on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 1 the slide a few times, thats just referring to, you 2 know, bringing dollars to present -- you know, future 3 dollars to present day, so you can compare apples to 4 apples, or 37 million at a three percent net present 5 value.
6 And then just highlighting several of the 7 areas that had the biggest influence on this 8 conclusion, the emergency preparedness alternative 9 would result in about a 7.74 million averted cost, 10 drug and alcohol testing would be about seven million, 11 and decommissioning funding assurance about 1.18 12 million.
13 Next slide, please.
14 Okay. So just a few tips. We thought 15 this might be helpful. Im sure many of the people 16 attending this meeting may have already reviewed and 17 commented on NRC regulations in the past. But if you 18 havent, then welcome. And even if you have, then 19 hopefully this will still be helpful.
20 So lets see. Next slide, please.
21 So Tip Number 1 as youre considering your 22 comments is to review the commenters checklist. This 23 is available on regulations.gov. Its actually right 24 there on the comment submission forms. This is not an 25 NRC document. This is something that is on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 1 regulations.gov, which is used by many federal 2 agencies for providing information and collecting 3 public comments on rulemaking activities.
4 So it has some helpful tips about how to 5 review the proposed rule and how to -- what kind of 6 information is helpful in general for agencies to 7 provide in your public comments.
8 Okay. Next slide, please.
9 So Tip Number 2 is to review the 10 unofficial redline rule language document. I 11 mentioned this earlier. This document shows how the 12 proposed rule would modify the current regulations in 13 this redline strikeout format, what would be inserted 14 and deleted, because sometimes that can be hard to 15 decipher from the required format in the Federal 16 Register.
17 But, again, this is an unofficial 18 document. Please do not rely on this for your -- for 19 your public comments.
20 Thank you.
21 Next slide.
22 Okay. Tip Number 3 is we have provided a 23 dedicated public website intended to be one-stop shop 24 for information about this proposed rule. So we have 25 a link to that. There is a short link on the slide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 1 there that should work if you wanted to click on that 2 or you could scan it with your -- scan the QR code 3 there with your phone.
4 If you have any trouble with that, please 5 dont hesitate to reach out to me and Ill make sure 6 that youre able to access it.
7 So the information -- some of the 8 information that we have on this website, we have a 9 link directly to the proposed rule, all of these 10 related documents that Ive mentioned. There is a 11 direct link to the comment form, to make it easier to 12 submit a comment. There is also information about our 13 past and upcoming public meetings, and there are some 14 additional background documents from the earlier 15 stages of rulemaking that we mentioned.
16 Next slide, please.
17 Okay. And then, just to summarize how to 18 actually submit a comment, the instructions are in the 19 proposed rule, Federal Register Notice. But just to 20 make it clear here, we do have three different 21 methods. Our preferred method would be for you to go 22 to regulations.gov and submit using that comment form.
23 You can either type in your comment or have it in a 24 separate document which you upload. So either would 25 be fine.
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53 1 Or you could send it to the NRC as an 2 email, and the address is there. Thats the same 3 email address for all rulemaking activities, so just 4 make sure you identify which rulemaking you are 5 commenting on. Or you can send it in the mail to the 6 address shown there.
7 Just a note, you know, please dont submit 8 the same comment multiple methods just to make sure 9 that we get it because that would create duplication.
10 We will get it. Just go ahead and submit it to --
11 using one of those methods.
12 Thank you.
13 Next slide, please.
14 Okay. Slide 37. Just wrapping up the 15 staff presentation portion of the meeting here, the 16 next steps after -- you know, moving forward, public 17 comment period, as I mentioned, ends in about a month, 18 May 17th.
19 Following that, the staff will collect and 20 review, address all the public comments, and develop a 21 final rule, which we will send up to our Commission.
22 We have Commissioners who set policy for the Nuclear 23 Regulatory Commission. So the staff would provide it 24 to them. Its scheduled in October of 2023.
25 And then the estimated publication date of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 1 the final rule when these rules would actually go into 2 effect -- well, the publication date would be May 3 2024, and then the rules would actually go into effect 4 30 days after that.
5 So those are estimated dates. Its 6 subject to change. There are a lot of things that 7 could happen, depending on the types of comments that 8 we get or other -- other factors or priorities.
9 Sometimes rulemaking schedules may change.
10 We do have a website, though, that -- that 11 lists these milestones for this rulemaking and for 12 every other rulemaking that we are working on. We 13 have these key milestones of when we would deliver it 14 to the signature authority and when we expect to 15 publish it. So if there are changes to our schedule 16 in the future, we will update it there, and you can --
17 you can find it on that website.
18 So that concludes the staff presentation.
19 Thanks for sticking with me, and I apologize again 20 for challenges with my allergies and voice here.
21 Thank you.
22 All right. So I will turn it back over to 23 Steven.
24 MR. SMITH: Thanks, Dan. Thanks.
25 So before we go into the Q&A session, wed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 1 like to take a quick break. The time is now 7:11.
2 Lets take 10 minutes, and well be back at 7:21. All 3 right?
4 (Whereupon, the above-entitled matter went off the 5 record at 7:11 p.m. and resumed at 7:21 p.m.)
6 MR. SMITH: So its 7:21. Lets go ahead 7 and transition to our public Q&A session. Please 8 remember that our goal today is to help you provide 9 informed written comments. So we ask that your 10 questions focus on any clarification you or others may 11 need in terms of the proposed decommissioning rule and 12 draft regulatory guidance.
13 Our intent is not to discuss specific 14 details about any particular facility. So we ask that 15 you keep your questions on the decommissioning rule 16 and related topics in general.
17 I will take questions from the Teams line 18 over the phone. Remember, those of you on Teams can 19 raise your hand with the hand feature, and I can see 20 that. Those on the phone can use star five. You can 21 call up and ask a question. If you are on Teams, you 22 can use your unmute button. And if youre on the 23 phone, use star six to unmute yourself.
24 I will take the hands in the order that I 25 see them, and I will alternate between Teams and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 1 phone.
2 To ensure each person who wants to speak 3 or ask a question gets a chance, please limit your 4 speaking time to three minutes. You will have the 5 option for one follow-up question. If you need more 6 time, please wait and I will take -- I will advise you 7 to take a second turn later. This will happen towards 8 the end of the meeting.
9 So, with that, lets go ahead and start.
10 Anyone on the phone or Teams have a question? I do 11 not see any hands. I dont see any indication from 12 anyone on the phone. So Ill give it a minute.
13 While were waiting, did you want to share 14 the website for comments?
15 MR. DOYLE: Sure. So were not -- were 16 not in a rush to get out of here. We did schedule 17 this meeting, and were available -- as I said, many 18 of the subject matter experts are available on the 19 line to answer if you do have a question. If youre 20 wondering if there may be other people out there with 21 the same question, please dont -- dont hesitate to 22 go ahead and raise your hand.
23 So let me -- let me share the website. So 24 this is a little different from the previous meeting.
25 What Im going to do is Im going to share my screen NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 1 here, and then share the screen.
2 So if someone could just kind of keep an 3 eye on the chat there, see if there are any questions, 4 but Im just going to -- Im just going to talk for a 5 little bit here.
6 And if anything I say, or if anything you 7 see, you know, prompts a question, feel free to just 8 go ahead and ask, or just go ahead and raise your 9 hand.
10 This is that -- the website that we put 11 out. This is the, you know, kind of one-stop shop for 12 this rulemaking activity. There is the -- the link 13 that was earlier in the slides. So what we have --
14 this right here, this link, you know, proposed rule, 15 read it in the Federal Register.
16 So if you click on that, this is the web 17 version of the proposed rule. And you can see this is 18 the link to submit a formal comment. Thats right up 19 here. This is the -- let me go ahead and click on it.
20 So theres a dropdown form. You can type in a 21 comment right there.
22 You can -- let me see here. Go back. You 23 can also see, you know, other -- other comments that 24 have already been submitted. It actually might be 25 easier to show you from here.
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58 1 If you wanted to see, say, what other 2 people have said about this proposed rule, you could 3 click that link right here, read comments received, 4 and that will bring you over to regulations.gov and 5 filter for the comments that have already been posted.
6 So you can see, as of today, we have 7 received and posted four public comment submissions 8 from other individuals. So as they come in, they will 9 be available there.
10 Many commenters tend to wait until right 11 towards the end of the comment period, so just be 12 aware of that. And also, if you submit something and 13 then dont see it immediately, it doesnt mean there 14 is a problem. There is kind of a holding -- holding 15 area basically where we -- where we -- the agency, you 16 know, sees what was submitted and then just confirms 17 that its okay to be posted publicly. So there may be 18 a few days between when you submit something and when 19 you see it posted.
20 We do have these -- the handy links to the 21 related documents. There is the four draft regulatory 22 guides, the EP, decommissioning, availability of 23 funds, post-shutdown decommissioning activities 24 reports. So those are all right here. Reg analysis, 25 the environmental assessment, the support statements.
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59 1 This is the redline rule text.
2 This -- so here is our introduction just 3 explaining, you know, what this document is showing, 4 that Ive already explained. Each of these headings 5 here in the table of contents are links. So you could 6 actually click to that, so, say, in 10 CFR 50.82, 7 termination of licensees, you could just click on 8 that. It will jump you right to the page that has 9 50.82.
10 So, again, this is showing, you know, the 11 current rule language. You dont see any red text 12 here. So what thats saying is that were not 13 proposing any changes to this paragraph right here.
14 So, but if you scroll down, so you can see, you know, 15 what it says and what it would continue to say, and 16 then how we would actually be -- how the NRC is 17 proposing to modify this regulation.
18 So this text would be inserted. Make this 19 a little bit bigger. So this text is there and would 20 continue to be there, but with these edits, we would 21 be adding this new paragraph 2.
22 Let see. Anything else here that would be 23 interesting to point out. We put in the -- the entire 24 section is there. So if were making at least one 25 change in a section, we included the entire section, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 1 just to kind of err on the safe side for context. So 2 it does make the document longer. Its a 260-page 3 document. But, you know, hopefully thats helpful, to 4 have that context. So these are all the sections in 5 eight different parts.
6 All right.
7 MR. SMITH: All right. Anyone on the 8 phone who has questions, please press star five to 9 indicate that youd like to talk, and star six to 10 unmute yourself.
11 For those using Teams, again, there is a 12 raise hand function that is at the top. I think its 13 under React. You click on that, and there should be a 14 little -- little handle that comes up just like that.
15 Again, well give it about 10 minutes to 16 give anyone an opportunity to talk. And if that -- if 17 we dont get anything, well wrap the meeting up.
18 Soly, can you pull the slides back up?
19 Well go ahead and go to slide 39, which is the 20 comments, opportunities for comments. Okay. Were 21 having some difficulties. Just bear with us. There 22 it is.
23 (Pause.)
24 MR. SMITH: I dont see any hands or any 25 indication of any questions so far.
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61 1 MR. DOYLE: Yeah. And thats totally 2 fine. I think, you know, probably, you know, some 3 folks who are joining are interested in the 4 rulemaking, maybe wanted to hear, you know, what other 5 people might have to say about it, and thats totally 6 fine.
7 So we can -- just in case someone joined 8 or in case something came to mind, again, we didnt 9 want to just rush out.
10 I dont think there was too much else. I 11 think the website is pretty self-explanatory. So 12 hopefully that was -- that was helpful.
13 We did have -- down in the bottom part of 14 that website, there is the additional background 15 documents. If -- you know, if people have been 16 following this rulemaking, its -- you know, as I 17 mentioned from the background, this has been going on 18 for a few years.
19 People may be aware that there was, you 20 know, a version that the staff had generated that was, 21 you know, submitted and publicly released in 2018. So 22 thats available in the additional background 23 documents, but thats -- thats historical. That is 24 not the current version.
25 But I do -- I do know that there were some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 1 people that were reaching out to me about that 2 document. Thats -- so that 2018 draft proposed rule 3 is listed under the additional background documents.
4 The Commission approved publication with several 5 changes in November, and that brought us to where we 6 are today, to the proposed rule that was published on 7 March 3rd.
8 So we have some previous Federal Register 9 Notices, the regulatory basis document, the ANPR, 10 previous public outreach, summaries of the public 11 meetings. So that is all there on the website.
12 MR. SMITH: Im not seeing any comments or 13 questions from the chat.
14 Excuse me. Soly, could you go ahead and 15 go to slide 39.
16 So while were waiting on -- you know, 17 well go ahead and pull this up. Again, you can just 18 scan the QR code or click on the link. Actually, I 19 dont think you have the option for that. But just 20 you can scan the QR code with your phone, and that 21 will take you to the meeting feedback form.
22 MR. DOYLE: Yes. And this -- this form is 23 just for the meeting itself, not about the rulemaking.
24 But if you have any suggestions for how we can make 25 meetings like this more effective, were very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 1 interested in that feedback.
2 We did just have one more slide after this 3 one, which is the acronyms. There are too many 4 acronyms here that we have used in some of the slides 5 as we were speaking.
6 (Pause.)
7 MR. DOYLE: All right. I think were 8 good.
9 MR. SMITH: Okay. So I want to thank 10 everyone for participating.
11 MR. DOYLE: Hold on.
12 MR. SMITH: Oh.
13 MR. DOYLE: We got somebody.
14 MR. SMITH: Got a question?
15 MR. DOYLE: Perfect.
16 MR. SMITH: Okay.
17 MR. DOYLE: Were not trying to rush out 18 of here.
19 MR. SMITH: Okay. Mr. Odom. Please turn 20 on your mic.
21 MR. DOYLE: You should be able to unmute 22 yourself now.
23 MR. ODOM: I didnt quite -- I really 24 enjoyed the presentation today, but I scanned your QR 25 code and its not -- its not really working.
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64 1 MR. DOYLE: I apologize for that. Let me 2 --
3 MR. ODOM: It says invalid meeting code, 4 and its asking for a meeting code.
5 MR. DOYLE: Hmm. You know what? I think 6 the system -- I think there might be a problem with 7 the system because I do know that this is the code for 8 the meeting, and it goes into the form. And youre 9 right, so you are completely right. I apologize.
10 So Im going to need to submit a ticket 11 for that. Sorry about that.
12 MR. SMITH: Thank you for pointing that 13 out, Mr. Odom.
14 MR. ODOM: No problem.
15 MR. SMITH: Any other questions? Any 16 comments?
17 MR. DOYLE: We did get a comment, by the 18 way, from one of the other staff that it -- just 19 confirmed that it is a problem with the system, 20 unfortunately, and that it has been submitted. But 21 Ill be following up on that also.
22 So if you could, if you wouldnt mind just 23 checking back in a day or two, hopefully well get 24 that resolved quickly.
25 MR. ODOM: Will do.
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65 1 MR. DOYLE: Thank you for confirming that 2 the raise the hand feature is working.
3 All right. And think we were just 4 wrapping up there. So, again, thank everybody for 5 your time, for your interest in this rulemaking. We 6 are looking forward to your -- any feedback that you 7 may have.
8 Again, as the PM, you can reach out to me.
9 My name and contact information is in the proposed 10 rule and this presentation here, if there is anything 11 that I can do to help you as you are reviewing this.
12 And, again, thank you. That concludes the 13 meeting today. Have a wonderful day. Thank you.
14 (Whereupon, the proceedings in the above-15 entitled matter went off the record at 7:36 p.m.)
16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com