ML22293B784
| ML22293B784 | |
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|---|---|
| Issue date: | 10/13/2022 |
| From: | NRC/OCM |
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| Download: ML22293B784 (100) | |
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION
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STRATEGIC PROGRAMMATIC OVERVIEW OF THE OPERATING REACTORS AND NEW REACTORS BUSINESS LINE
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THURSDAY, OCTOBER 13, 2022
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The Commission met in the Commissioners' Conference Room, First Floor, One White Flint North, Rockville, Maryland, at 9:00 a.m.,
Christopher T. Hanson, Chair, presiding.
COMMISSION MEMBERS:
CHRISTOPHER T. HANSON, Chair DAVID A. WRIGHT, Commissioner ANNIE CAPUTO, Commissioner BRADLEY R. CROWELL, Commissioner ALSO PRESENT:
BROOKE P. CLARK, Secretary of the Commission MARIAN ZOBLER, General Counsel
2 NRC STAFF:
DARRELL ROBERTS, Deputy Executive Director for Reactor and Preparedness Programs ANDREA VEIL, Director, Office of Nuclear Reactor Regulation (NRR)
ZACHARY HOLLCRAFT, Senior Reactor Operations Engineer, Reactor Inspection Branch, Divisions of Reactor Oversight, NRR JAMIE HEISSERER, Deputy Director, Division of Operating Reactor Licensing, NRR SHILP VASAVADA, Senior Reliability and Risk Analyst, PRA Licensing Branch C, Division of Risk Assessment, NRR BRIAN KEMKER, Senior Resident Inspector, Vogtle Units 3&4, Region II MICHELLE HAYES, Branch Chief, Technical Branch 1, Division of Advanced Reactors and Non-Power Production and Utilization Facilities, NRR HOSSEIN ESMAILI, Branch Chief, Fuel Cycle & Source Term Code Development, Division of Systems Analysis, Office of Nuclear Regulatory Research
3 1 PROCEEDINGS 2 (9:00 a.m.)
3 CHAIR HANSON: Good morning, everyone. Thank you for 4 joining. I convene the Commission's public meeting on the NRC's Strategic 5 Programmatic Overview of the Operating and New Reactor Business Lines.
6 The Commission is meeting today to get an update from 7 staff and discuss a range of important activities in the reactor business lines 8 supporting our critical safety and security mission. It's great to have this 9 important meeting, with the almost full complement of the Commission.
10 Of course, we have Commissioner Caputo and 11 Commissioner Crowell. Unfortunately, Commissioner Baran took a quick trip 12 to Canada yesterday and experienced a lot of this kind of post-COVID travel 13 problems. His flight was canceled last night. He's on his way back this 14 morning.
15 And we hope, fingers crossed -- I'm looking at Brooke -- that 16 he will be able to join us remotely for the second panel. So, we wish him safe 17 travels. I think he's in transit as we speak. And, hopefully, he can join us 18 shortly. So, we'll look forward to that.
19 We have two staff panels today. We'll begin with the 20 Operating Reactors Business Line panel first, followed by the New Reactor 21 Business Line.
22 Before we start I'll ask if my colleagues have any remarks 23 they'd like to make? No? Okay. So, with that, we'll begin with Darrell 24 Roberts, our Deputy Executive Director for Reactor and Preparedness
4 1 Programs. Darrell, the floor is yours.
2 MR. ROBERTS: Thank you. And good morning, Chair 3 Hanson and the Commissioners.
4 Staff in the Operating and New Reactor Business Lines are 5 doing incredible work, which we will be showcasing here today. Since the 6 Commission meeting last year, staff have continued to exhibit exemplary 7 dedication and focus to execute our important safety and security mission 8 through proactive actions to our changing environment, and consistent with 9 the principles of good regulation.
10 This includes continued improvement of our processes, 11 whether it's through insights from our own self-assessments, the COVID-19 12 pandemic, Commission direction, or other sources.
13 For example, we maintain a strong focus on addressing 14 current and future staffing challenges, including an evaluation of our hiring 15 policies to incorporate lessons learned from our experiences with a hybrid 16 work environment.
17 We are implementing the Commission's direction to 18 reassess how we conduct our subsequent license renewal environmental 19 reviews in accordance with the National Environmental Policy Act, NEPA.
20 The staff has embarked on a 24-month rulemaking, which is 21 currently on schedule, for these environmental reviews, and continues to seek 22 opportunities to work as efficiently as possible.
23 As a result of the Office of the Inspector General's event 24 inquiry at Diablo Canyon this year, the staff reviewed our baseline inspection
5 1 programs and determined that they continue to provide public health -- protect 2 public health and safety.
3 Later in the presentation we will highlight some additional 4 enhancements we've initiated as a result of the OIG's audit recommendations 5 in this area, as well as an event inquiry on the NRC's oversight of counterfeit, 6 fraudulent, and suspect items.
7 Lastly, the staff is proactive in taking steps to understand 8 and prepare for the future of operating new and advanced reactors in the 9 United States through extensive engagements with industry groups, non-10 governmental organizations, interested members of the public, and through 11 coordination with federal partners such as the Department of Energy.
12 In addition, the staff in these business lines are supporting 13 multiple international bilateral and multilateral exchanges related to advanced 14 reactors and small modular reactor licensing, inspection practices, digital 15 instrumentation and control, human factors, and probabilistic risk assessment, 16 among other topics.
17 The staff continues to support the United States 18 Government's response to developments at the Ukraine nuclear power plants 19 based on the changing environment in that area. The staff's expertise has 20 been instrumental in helping other governmental organizations have a better 21 risk assessment and understand possible scenarios there.
22 Next slide, please. Slide 3.
23 The first panel will be discussing the operating reactors 24 business line and its key role in NRC's mission. This includes work to ensure
6 1 several of our agencys enterprise and business line level risks are 2 appropriately managed.
3 During this panel, Andrea Veil, the Director of the Office of 4 Nuclear Reactor Regulation, or NRR, will talk about the operating reactors 5 business line, strategic priorities, and notable successes, including those that 6 enable our regulation of various technological advancements in the operating 7 reactor fleet.
8 After Andrea, Zack Hollcraft, a senior reactor operations 9 engineer in NRR's Division of Reactor Oversight, will be describing 10 innovations that have enabled our continuous improvements to the reactor 11 oversight process, or ROP.
12 Following Zack you will hear from Jamie Heisserer, to my 13 left, currently an NRR Deputy Division Director in the Division of Operating 14 Reactor Licensing, but previously Region III's Deputy Division Director for the 15 Division of Reactor Projects, who will share her experience regarding the 16 regions' resilience during the COVID-19 pandemic, and other inspection 17 program perspectives.
18 And, finally, to her left is Shilp Vasavada, the Acting Branch 19 Chief for PRA Licensing Branch C, and a senior reliability and risk analyst in 20 NRR's Division of Risk Assessment, will discuss how we are leveraging risk 21 insights to modernize our regulatory activities.
22 Next slide, please.
23 So, that concludes my opening remarks. And I will turn it 24 over to Andrea Veil.
7 1 MS. VEIL: Thank you, Darrell. And good morning Chair 2 and Commissioners.
3 We are focused on the safety and security of the operating 4 fleet of power reactors, as well as the safety and security of research and test 5 reactors and medical isotope facilities in the U.S. We are closely monitoring 6 the rapid changes in the U.S. energy market. And we will discuss our 7 preparations to provide safe licensing and oversight under various scenarios.
8 Next slide, please.
9 We demonstrated our dedication to the safe, efficient, and 10 reliable licensing and oversight of research and test reactors, and medical 11 isotope facilities. This past year we made significant process in the review of 12 SHINE operating license application. We are nearing completion of the 13 safety review, and closing a few outstanding technical issues in preparation 14 for December meetings with the Advisory Committee on Reactor Safeguards.
15 The staff is also in pre-application engagement with Atomic 16 Alchemy for a medical radioisotope production facility.
17 We continue to monitor the National Institute of Standards 18 and Technology's recovery efforts from the February 2021 fuel melt event.
19 We are continuing our inspection and oversight activities at 20 the site, as we observe evolutions, such as fuel loading and the important 21 assessment of safety culture enhancements and the licensee's corrective 22 action.
23 Inspection findings will inform our restart decision, which will 24 be based on our assessment of whether the facility will be operated in a safe
8 1 manner with its existing licensing basis.
2 Next slide, please.
3 We're also evaluating lessons learned from the pandemic in 4 order to identify long-term improvements for future emergencies and non-5 emergency conditions for our licensing and oversight programs.
6 Our initial ROP lessons learned report was issued in 7 January 2021. Given the additional experience that weve gained, the staff 8 conducted a follow-on lessons learned activity focused on exploring longer-9 term impacts from practices utilized during the COVID-19 pandemic. The 10 follow-on effort was broader in scope and included external stakeholder 11 engagement in the identification and development of conclusions and 12 recommendations.
13 This group recently finalized its work, and made 14 recommendations, and delineated potential next steps. They also prioritized 15 key actions and activities for each of the recommendations, if chosen to be 16 moved forward.
17 NRR, NSIR, and the Regions will evaluate the 18 recommendations, the prioritization, and the collaborative resources needed 19 to accomplish them, and future discussions, with the goal of increased 20 flexibility in our oversight program.
21 Our initial licensing COVID-19 lessons learned report was 22 issued in October 2021. We are implementing these lessons learned, 23 particularly in the area of coordination and communication to better prepare 24 for future events and incorporating them into current processes.
9 1 Next slide, please.
2 Although the ROP has been in place for more than 20 years 3 and is robust, it has continuously evolved. By design, the ROP has built-in 4 mechanisms to self-assess performance and consider stakeholder feedback 5 while continuously evaluating potential program enhancements.
6 Zack Hollcraft will discuss the staff activities to update and 7 reevaluate recommended ROP enhancements provided to the Commission in 8 2018 and 2019, which were subsequently withdrawn.
9 Four new papers were resubmitted for the items that require 10 Commission approval.
11 The staff continues to expand its use of risk insights in the 12 ROP. As an example, weve improved our use of processes to evaluate low 13 safety significant issues, often referred to as the very low safety significance 14 issue resolution process, or VLSSIR.
15 Specifically, we updated guidance to clarify that issues that 16 could potentially receive the lowest severity level of traditional enforcement, 17 and if the licensing basis is also unclear, those specific issues could be 18 documented using the VLSSIR process.
19 This change enables a more complete picture of a potential 20 importance of an issue being evaluated. In addition, we used risk insight in 21 the selection of two focus engineering inspections for implementation in 2023.
22 The staff is completing the plan actions in response to the 23 OIG's recommendations on the NRC's oversight of counterfeit, fraudulent, and 24 suspect items, or CFSI. The staff has concluded that there is no immediate
10 1 safety concern involved with CFSI at reactor or materials facilities.
2 But, we're continuing to enhance our awareness of CFSI 3 with development of formal agent -- formal agency definition for CFSI, 4 incorporation of this definition in relevant inspection guidance, and training 5 inspectors on the changes to guidance documents.
6 In addition, the staff recently issued a charter that details the 7 NRC's objectives, the overall approach, and the strategy associated with 8 regulatory activities related to CFSI.
9 The charter also defines roles and responsibilities 10 associated with the oversight activities related to CFSI at NRC-regulated 11 entities.
12 Next slide, please.
13 We're implementing the Commission's direction and 14 continuing subsequent license renewal reviews. Weve developed a plan for 15 environmental reviews in accordance with Commission's orders, including 16 how to efficiently complete each of the six affected applications, should they 17 choose to submit site-specific environmental reports.
18 We also delivered two rulemaking plans and are 19 implementing the Commission's direction on those plans as well.
20 As we move forward, the safety reviews continue in 21 accordance with the staff schedules, as they are unaffected by the 22 Commission orders, including issuance of safety evaluations, and meetings 23 with the Advisory Committee on Reactor Safeguards.
24 In parallel, we're engaged with licensees to help ensure
11 1 efficient, open, and reliable environmental reviews, and we held a public 2 meeting in August to discuss new processes for these reviews.
3 Next slide, please.
4 We are focused on the implementation of innovation 5 activities. The continued application of risk-informed decision-making and 6 use of integrated review team process has yielded significant enhancements 7 in both safety and efficiency in licensing reviews.
8 For example, a review of risk insights identified an 9 operational issue for an ongoing Wolf Creek license amendment request to 10 extend the completion time for an inoperable emergency diesel generator.
11 In addition, in partnership with the Office of Nuclear 12 Regulatory Research we recently completed an integrated risk-informed 13 decision-making process for emergent issues which examine the potential 14 change and the estimated fire risk associated with high energy arcing faults, 15 or HEAF.
16 This was a substantial accomplishment where the staff 17 determined that plants continued to operate safely.
18 This past year we've continued to use technology to 19 enhance access to data for decision-making. EMBARK Venture Studio, our 20 dedicated resource for promoting and shepherding innovation projects across 21 the agency, in partnership with the Office of the Chief Information Officer, is 22 continuing to implement process improvements through the mission analytics 23 portal, or MAP, and also MAP X, our external submission portal.
24 MAP has enabled the development of high-quality data
12 1 dashboards which allow staff and the public to readily access data with less 2 effort.
3 MAP X currently allows our licensees to submit some data 4 electronically.
5 The NRC is committed to keeping pace with technological 6 innovations to help ensure the safe and secure use of artificial intelligence, or 7 AI, in NRC-regulated activities. We're partnering with domestic and 8 international counterparts within the nuclear industry and other government 9 agencies to stay abreast of industry activities and plan to deploy AI in 10 identifying potential areas of collaboration.
11 Next slide, please.
12 For digital instrumentation and controls, we're successfully 13 exercising the enhanced digital I&C infrastructure, we're evaluating lessons 14 learned from implementation of the enhanced infrastructure for the Waterford 15 digital I&C upgrade, and we'll apply these lessons learned to the Turkey Point 16 and Limerick reviews.
17 In parallel, we recognize that we can continue to make 18 improvements to our infrastructure.
19 For example, we recently sent a paper to the Commission 20 to allow the consideration of risk-informed approaches to address digital I&C 21 common cause failure challenges.
22 For accident tolerant fuel, or ATF, we continue our 23 modernization efforts to ensure the agency is prepared to support the 24 industry's goal of batch loads in the late 2020s.
13 1 To encourage further engagement, we issued a memo to 2 industry stakeholders providing a generic schedule of review for topical 3 reports and licensing actions for the deployment of ATF concepts, high burn-4 up, and increased enrichment.
5 As an example of early engagement, the pre-application 6 meetings for Vogtle Units 1 and 2 were very useful, as we just accepted the 7 first amendment request for lead test assemblies with increased enrichment.
8 The NRC expects to complete the review within one year.
9 Next slide, please.
10 We are taking deliberate actions to meet the organizational 11 health objectives identified in the NRC's Strategic Plan. In light of a very 12 competitive and challenging job market, there is a robust effort underway to 13 fill critical vacancies.
14 Through collaboration efforts with the Office of the Chief 15 Information Officer, the hire -- the hashtag, has to be hashtag, sorry, #hirenrc 16 effort with in combination with OCHCO, we implemated -- we implemented 17 innovative methods to recruit more staff.
18 We are pleased to have successfully hired seven staff from 19 the Nuclear Regulatory Apprenticeship Network, or NRAN, Program in FY '22.
20 This was possible through strong partnerships between our hiring managers 21 and OCHCO.
22 As we onboard new staff, we recognize the need to engage 23 them in this new hybrid environment, and we developed innovative ways to 24 increase learning activities and leverage in-person interactions.
14 1 In addition, we dedicate -- we have dedicated teams working 2 on how to sustain knowledge management, innovation, and diversity and 3 inclusion efforts.
4 Next slide, please.
5 I'm now happy to turn the presentation over to Zack 6 Hollcraft.
7 MR. HOLLCRAFT: Thank you, Andrea.
8 Chair Hanson -- Oh, next slide, please.
9 Chair Hanson, Commissioners, the staff continues to 10 improve the reactor oversight process, now in its 23rd year of implementation.
11 The Commission approved the staff's recommendation to modify the 12 periodicity of engineering inspections, enabling the replacement of the 13 triennial design basis assurance inspection, with a quadrennial 14 comprehensive engineering team inspection, CETI, combined with focused 15 engineering inspections, FEIs.
16 The combined CETI and FEIs allow staff to examine an 17 additional engineering area based on risk significance, operating experience, 18 and regulatory framework, while still maintaining the necessary level of 19 oversight. These changes will improve effectiveness and efficiency by 20 providing more risk-significant samples while reducing the number of overall 21 resources needed.
22 The staff will implement this new inspection program 23 beginning January of 2023.
24 The staff has several other policy issues at or close to the
15 1 Commission for a vote.
2 First, based on a Be RiskSMART analysis, the staff has 3 recommended maintaining the team inspection portion of Inspection 4 Procedure 71152, problem identification and resolution, at a biennial 5 frequency as the staff incorporates other recommended enhancements 6 identified by the recently-completed comprehensive review of the PI&R 7 program. This provides a prudent approach to implement those 8 recommendations first, in order to assess any impacts to the effectiveness of 9 the PI&R inspection program before considering additional changes.
10 Next, the staff has recommended two changes in the ROP 11 assessment area.
12 The first is to delete the requirement that greater-than-green 13 inspection findings must wait at least four quarters before being removed as 14 ROP action matrix inputs upon successful completion of the appropriate 15 supplemental inspection.
16 The second is to revise the treatment of greater-than-green 17 performance indicators so that they remain action matrix inputs until the 18 appropriate supplemental inspection is successfully completed.
19 These recommendations are intended to encourage 20 licensees to prepare for supplemental inspections as quickly as possible, and 21 implement more timely corrective actions, while better reflecting real-time 22 licensee performance.
23 To improve clarity in the ROP and better communicate the 24 relative risks associated with inspection findings, the staff intends to change
16 1 the qualitative description of white and yellow significant -- safety significance.
2 There will be no changes to the description of green or red, 3 nor any of the risk-informed quantitative thresholds.
4 The NRC staff will include this proposal along with 5 associated changes in the currently planned revision to enforcement policy, 6 with the goal of sending it to the Commission by the end of calendar year 7 2022.
8 Lastly, Office of Nuclear Security and Incident Response, 9 NSIR, submitted a recommendation for risk-informed improvements to the 10 Emergency Preparedness Significance Determination Process, and will be 11 recommending to replace the alert and notification system performance 12 indicator with one that considers new technologies.
13 Also, following initial cybersecurity inspections to verify 14 implementation of new requirements, NSIR worked closely with the regions to 15 establish a biennial, one-week inspection to assess licensee maintenance of 16 their cybersecurity programs.
17 The implementation of these recommendations will 18 complete the current ROP enhancement efforts. The staff looks forward to 19 monitoring and assessing these changes and taking the next step in our 20 continuous improvement cycle.
21 Next slide, please.
22 Let's shift focus now from inspections to inspectors.
23 Recognizing the importance of our boots-on-the-ground 24 experts at each site across the country, we are continuing efforts to improve
17 1 our resident inspector recruitment and retention. We have implemented all 2 of the Commission's approved items to improve resident compensation and 3 reimbursement of relocation expenses and are improving our ability to monitor 4 and understand the health of our resident inspector program and the dynamic 5 issues resident inspectors face.
6 Recently, the internal resident inspector health dashboard 7 went live. This enables managers and staff to monitor the status of key 8 metrics and other information regarding the resident inspector program, 9 providing decision-makers with hard data on program health when 10 determining if action is warranted.
11 Examples include staffing and training levels, surveys on 12 inspector satisfaction, and promotion statistics.
13 To ensure that our efforts are persistent, NRR has created 14 a standing committee made up of current and former resident inspectors with 15 representatives from each of the regions.
16 This group is tasked with monitoring program health, 17 sharing best practices between the regions, and implementing the working 18 groups other recommendations for improvements, including hiring into the 19 Resident Inspector Development Program, getting residents out to sites, and 20 ensuring there are opportunities available after inspectors complete their 21 tours.
22 Next slide, please.
23 Another new dashboard that has yielded positive effects 24 was in response to an IdeaScale recommendation.
18 1 EMBARK Venture Studios worked with regional staff to 2 modernize and streamline end-of-cycle meetings, making it easier to gather 3 and prepare the necessary information to support these meetings through the 4 visualizations of a dashboard. This new process yielded a 30 percent 5 reduction in end-of-cycle preparation time and received substantial positive 6 feedback from both leadership and staff for its ease of use and the 7 visualization tools it provides.
8 Piloted this year, it has been unanimously endorsed by the 9 regions for full implementation.
10 Next slide, please.
11 NRR is partnering with Research and the Chief Information 12 Officer to enhance the ability of stakeholders to submit, search, and trend 13 operating experience documentation. We have updated the MAP X portal 14 with an event notification module. Fuel cycle facilities, nuclear materials 15 licensees, and non-power reactors can submit event notification information 16 to the NRC via MAP X.
17 We are following that up with a module for licensee event 18 reports.
19 These modules will improve the agency's ability to quickly 20 and easily analyze and process information.
21 Recently developed public search tools for event 22 notifications and Part 21 reports for defects and non-compliance will allow 23 internal and external users to perform a full text search of Part 21s. This 24 capability is not currently available to the public and was just recently rolled
19 1 out for use by internal stakeholders, including resident inspectors.
2 Additionally, we are upgrading the existing public licensee 3 event report search tool to add visualizations and enhance search capabilities.
4 For staff, we are improving our search capabilities for 5 operating experience documents to include the ability to perform a term 6 similarity search rather than simple keyword searches, and filtering by 7 inspection procedure, technical area, and plant system. This will provide 8 relevant advanced search capabilities not available on existing NRC systems.
9 The tools under development will greatly enhance searches 10 and trending for NRC staff and the public through new functionality, adding 11 more transparency and stakeholder confidence for these processes.
12 Next slide, please.
13 I will now turn the presentation over to Jamie Heisserer.
14 MS. HEISSERER: Good morning, Chair and 15 Commissioners.
16 We are two-and-a-half years into the public health 17 emergency and the resident and region-based inspectors continue to 18 demonstrate resilience day in and day out. And, as always, they do with the 19 utmost focus on safety.
20 This morning I'm going to highlight some areas of resilience 21 over the past year with respect to COVID, uncertainty with plant closures or 22 potential plant closures, and with staffing.
23 Next slide, please.
24 With respect to COVID, our inspectors continually show
20 1 remarkable flexibility in the implementation of the program, how we leverage 2 technology to complete our inspections more effectively, all while adapting to 3 rapidly-changing COVID policies and conditions and, of course, the personal 4 impacts of COVID.
5 As they have throughout the past two-and-a-half years, 6 resident inspectors have remained on site, and operator licensing exams and 7 all other operator licensing activities have continued. We did move some 8 inspections and exams, or grant exemptions for emergency preparedness 9 exercises, based on local COVID conditions.
10 Although challenges were experienced, the regions 11 successfully completed the Baseline Inspection Program in calendar year 12 2021 and are on track to do so in calendar year 2022.
13 Force on force and engineering team inspections continued 14 with flexibility based on COVID conditions from site to site. Our inspection 15 teams readily adapted and sought new techniques and approaches to meet 16 inspection objectives in the hybrid work environment.
17 In addition, the inspection staff has adjusted to rapidly 18 changing COVID policies both within the agency and from site to site. We 19 have also continued to be impacted by the virus, leading to last minute 20 adjustments to team composition, resident inspector support, and increased 21 teamwork if someone was out or unavailable. All regions were resilient in this 22 regard.
23 Next slide, please.
24 More so than ever, by leveraging technology, the regions
21 1 have been able to increase teamwork and efficiency, using software such as 2 OneNote, SharePoint, and Teams.
3 For example, even in-person teams are using a virtual 4 component with teammates being able to collaboratively edit and review 5 documents and team files in real time.
6 We've also employed these capabilities to conduct 7 inspections, including licensee interviews, when inspectors are unable to 8 access the site for various reasons that would have made them otherwise 9 unavailable for the inspections.
10 The resident inspectors continue to effectively leverage 11 licensee network remote access to access plant information real time from 12 home, allowing faster and more convenient assessment of plant status while 13 not on site or during off hours.
14 Examples of information that can be accessed include 15 control room logs, condition reports, plant parameters, and live camera feeds.
16 And this access varies from site to site.
17 The staff has also demonstrated exceptional resilience and 18 focus when faced with uncertainty and potential for, or actual plant closures.
19 For our Byron and Dresden teams, our inspection staff remained agile and 20 were prepared for either outcome throughout the summer of 2021.
21 When the decision was made for Byron and Dresden to 22 continue operation, the inspection teams maintained a laser focus on safety 23 and monitoring licensee re-staffing and safety culture throughout uncertain 24 times.
22 1 As Palisades neared closure, our teams monitored safety 2 and plant staff morale closely, and oversaw successful transition to 3 decommissioning.
4 The bottom line, despite challenges and uncertainty, the 5 regions met the mission and demonstrated extraordinarily -- extraordinary 6 resilience while doing so.
7 Next slide, please.
8 In Region III, we have externally hired nine highly-talented 9 new inspectors in the operating reactor business line in FY 2022. The 10 experience level of our new staff ranges from entry level to mid-career.
11 In Region III we supported five NRAN apprenticeships in 12 2022 and continue to support this important program. And all regions have 13 had success in the support of NRAN.
14 In Region III we are thrilled to have brought on three 15 apprentices permanently from the last cohort and look forward to hosting more 16 apprenticeships for the current one.
17 This increase in hiring is such exciting news for the future of 18 all of the regions. It also means increased effort on the part of existing staff 19 who are both conducting inspections and training and mentoring the new staff 20 and members of the team.
21 It's also critical that we continue to support rotational 22 opportunities to broaden staff and prepare them for future opportunities and 23 growth in the agency. Cross-organizational support has been important for 24 the success of the region and has enabled staff development throughout the
23 1 past year.
2 For example, Region III had support from Region IV for 3 acting senior resident inspector rotations at Byron and Palisades. We had 4 support from multiple offices for the Davis-Besse special inspection team.
5 Region III supported Region II with resident and senior 6 resident rotations.
7 Our inspection staff has had developmental and rotational 8 assignments as branch chiefs, technical assistants in program offices, and 9 senior resident inspectors, just to name a few.
10 Within Region III, we support each other across boundaries 11 as well. For example, our engineering inspectors often support our resident 12 or senior resident backfills or rotations. And our residents or senior residents 13 have participated in or led design basis assurance inspections, and so on.
14 We fully integrate new employees into the organization 15 through assigning them an ambassador who greets them weeks before 16 entering upon duty, and assigning each employee a coach who is the primary 17 point of contact for their training.
18 Region III has also established the inspector study group, 19 which both serves a knowledge management function, and establishes bonds 20 and friendships among the new inspector corps. This has led to increased 21 interconnectivity and teamwork throughout the region and inspector support 22 across organizational boundaries.
23 The challenges encountered over the past two to three 24 years, along with our focus on staffing, have presented opportunities to our
24 1 existing staff to support the organization in new ways, and to integrate new 2 talent into the organization, all while focusing on the mission.
3 Next slide, please.
4 Thank you. That concludes my presentation. I will now 5 turn the presentation over to Shilp Vasavada.
6 Thank you.
7 MS. VASAVADA: Thank you, Jamie.
8 Good morning, Chair and Commissioners.
9 NRR, in conjunction with our partner offices, is continuing its 10 journey to leverage risk insights, to modernize regulatory activities, under the 11 operating reactor business line.
12 It is a pleasure to present to you my insights on how the 13 business line is achieving this, consistent with the Be RiskSMART framework.
14 Next slide, please.
15 Use of risk insights in a manner that complements the 16 defense-in-depth philosophy has helped us achieve flexibility and efficiency, 17 while maintaining our unwavering focus on safety. This morning I will 18 highlight the investments in our people, improvements in our processes, and 19 enhancements of our risk tools.
20 These three areas enable us to identify and focus our 21 resources on safety-significant issues.
22 Next slide, please.
23 We continue to make dedicated investments in our people 24 to promote and facilitate a risk-informed mindset and the use of the Be
25 1 RiskSMART framework. These investments are aimed at empowering the 2 staff to make risk-informed decisions in their regulatory activities.
3 As an example, we promoted a common understanding of 4 how to leverage risk insights in regulatory activities by conducting targeted 5 workshops that reached more than 85 percent of NRR staff.
6 To ensure that the gains made using risk-informed decision-7 making are sustained, we are taking active steps to achieve positive change 8 management.
9 An example is the well-attended and interactive Regulatory 10 Information Conference session on leveraging risk insights in regulatory 11 activities for the operating reactor business line.
12 Another example is a Summer Risk Forum which was 13 organized in August and attended by more than 100 staff. The forum 14 provided case studies where the staff and the business line have successfully 15 leveraged risk insights to make their regulatory decisions.
16 Our positive change management efforts are aided by 17 formal and on-the-job training on the use of risk-informed decision-making for 18 all staff, including the NRAN cohorts and new hires.
19 Next slide, please.
20 We are leveraging technology to support operational 21 flexibility through major risk-informed programs. We have successfully 22 employed remote regulatory audits and are looking for opportunities to use 23 hybrid audits.
24 In part because of our effective use of technology, at the end
26 1 of fiscal year 2022, 47 percent of operating reactors will have an approved, 2 risk-informed technical specifications completion time program. 55 percent 3 will have an approved program for risk-informed categorization of structures, 4 systems, and components. And operating reactors will have an approved, 5 risk-informed surveillance frequency control program.
6 Our efforts to improve processes and procedures, support 7 the increased communication and use of risk insights in our regulatory 8 activities. An example is the staff's use of revised guidance on leveraging 9 risk insights within integral review teams to identify a cross-disciplinary safety 10 concern resulting from asymmetrical loading that led Indian Point 3 to revise 11 a fuel transfer plan design for improved safety and reliability.
12 As a learning organization, we maintain a feedback loop for 13 further refinement of processes to lessons learned and best practices from 14 their implementation. A recent example is the ongoing effort to capture 15 lessons learned from the first review conducted under the risk-informed 16 process for evaluations, or RIPE, and subsequently enhance the process as 17 necessary.
18 We continue to proactively expand the use of risk insights to 19 new areas that can benefit from them.
20 An example is the recent expansion of RIPE to allow its 21 application to license amendments involving a change to technical 22 specifications.
23 We also stay abreast of industry efforts to expand the use 24 of risk-informed decision-making. Last month the staff were invited to
27 1 participate in a workshop organized by the Pressured Water Reactor Owners 2 Group where industry stakeholders discussed their plans and roadmaps to 3 expand risk-informed decision-making to novel areas such as grading the 4 level of reviews for topical reports.
5 Next slide, please.
6 These tools play an increasingly important role supporting 7 the staff's ability to leverage risk insights. NRR, in collaboration with the 8 Office of Nuclear Regulatory Research, is taking deliberate steps to enhance 9 our level of risk tools.
10 One of the key reasons for the enhancements is to distill 11 qualitative and quantitative risk insights from these tools to facilitate their use 12 by staff who are not experts in the tools. An example includes the SPAR-13 DASH project, which was discussed at the June 1st Commission meeting on 14 Transformation at the NRC.
15 Along with the enhancements, we are increasing the 16 accessibility of available risk tools by the staff. Examples include the agency-17 wide availability of the Division of Risk Assessments' knowledge transfer 18 portal, and the agency-wide repository of risk insights containing the plant risk 19 information posts.
20 In addition, graded training options are available to the staff 21 on the risk teams.
22 I will end my prepared remarks by emphasizing that we are 23 seeing return on our investment in our people, processes, and risk tools 24 through the promotion, sustenance, and expansion of a culture that is open to
28 1 the use of risk insights in all our regulatory activities. Maintaining focus in 2 providing positive change management activities for the staff remains a 3 priority for the organization.
4 Next slide, please.
5 Thank you for your time. I will turn it over to Darrell for his 6 closing remarks.
7 MR. ROBERTS: Thank you, Shilp. And thanks to all the 8 panelists for showcasing some of the great work that the staff is doing to help 9 ensure the safety and security of our operating nuclear reactors.
10 As you've heard today, we continue to look for better ways 11 to do our work, using technology and data to improve our processes, and to 12 focus our efforts to those items of greatest importance to our mission.
13 Thank you, Chair Hanson and Commissioners for the 14 opportunity to present today. And we welcome your questions.
15 CHAIR HANSON: Thanks, Darrell.
16 We'll begin this morning with Commissioner Caputo.
17 COMMISSIONER CAPUTO: Good morning, everyone.
18 Thank you for being here today. Thank you all for preparing. It's wonderful 19 to be here for my first business line meeting after returning to the Commission.
20 So, thank you all for, for your efforts to prepare today.
21 I'm going to start with a question on problem identification 22 and resolution inspections. So, this will be to Andrea and possibly Zack. But 23 I think it's a high-level question for Andrea.
24 So, the recent paper the Commission proposed
29 1 backtracking on the recommendation to conduct these inspections every three 2 years or revert back to two years. The paper says there's new information 3 that supports the change, but I didn't see any new information in the paper 4 that would explain the change.
5 So, it sort of creates the impression that NRR changed its 6 mind.
7 My own recent conversations with resident inspectors 8 during my recent travels reminded me how they often in the course of their 9 duties will review whether or not licensees are adequately capturing items in 10 their corrective action programs, and whether they are resolving those issues 11 in a timely fashion.
12 So, let me just conclude with our principles of good 13 regulation state final decisions must be based on objective, unbiased 14 assessments of all information, and must be documented with reasons 15 explicitly stated.
16 So, what new information did NRR find that warranted a 17 reversal of the recommendation to conduct these inspections every three 18 years as opposed to every two?
19 MS. VEIL: I'll start. And then if you have anything to add, 20 Zack, feel free.
21 So, when the paper was written back in the 2018-19 time 22 frame, the comprehensive assessment was not done yet. And the 23 comprehensive assessment was kind of in its, maybe, middle phase.
24 So, because we looked at the new information that came
30 1 out of that assessment, it's clear in the paper that that assessment didn't refute 2 or support moving to triennial.
3 We also looked at the inspect -- resident inspector feedback 4 forms. There were about 28 of those forms. None of those forms had 5 anything to do with changing the frequency of inspections. There were things 6 like improving the assessment of corrective actions, looking at guidance, 7 being more explicit, but there was nothing about moving the frequency and 8 moving the frequency really wouldn't address the effectiveness of the PI&R 9 program.
10 There was very -- the first paper actually documented this 11 very well. There were lots of differing views on this topic. Some of the views 12 said that two years is not enough for the licensee to implement their corrective 13 actions or there's some overlap in inspection for inspectors if they go out 14 looking at the same areas. Well, that could occur in any periodicity, but that 15 doesn't necessarily mean move it out to, you know, a different frequency.
16 So, the ROP is always self-assessing. There wasn't 17 information there to say this is going to improve the efficiency, which was the 18 goal in the first place of looking at PI&R. Again, there wasn't anything that 19 refuted it.
20 So, I didn't see everybody else said kind of assess this, see 21 a strong basis for moving to triennial. But, of course, the ROP is always 22 evolving and assessing information. There wasn't hard and fast data saying 23 moving to triennial is going to get you the effectiveness and efficiency that 24 those 28 feedback forms requested.
31 1 COMMISSIONER CAPUTO: But it didn't refute it either.
2 MS. VEIL: That is correct.
3 MR. HOLLCRAFT: Yes. That's all correct.
4 I'll just add, Andrea, on to your point, Commissioner, 5 regarding the resident inspectors, we do receive assessment inputs via the 6 resident inspector daily review, the annual samples that are performed, and 7 the semi-annual samples that are performed all under the inspection 8 procedure.
9 However, one of the things that was revealed in the 10 comprehensive review and is discussed in our new paper is that -- and this 11 was actually discussed in the previous paper -- that those are all considered 12 mitigations if we went to a three-year frequency.
13 However, what we discovered is that that two-year 14 evaluation, the actual team inspection that provides, is the tool that provides 15 the meaningful assessment that can be used by regional decisions-makers.
16 And that's one of the reasons why we felt it was appropriate to keep it.
17 Thank you.
18 COMMISSIONER CAPUTO: Andrea, I'm going to stay with 19 you because I think this is an issue that affects more than just NRR. It also 20 affects the Rulemaking Center of Expertise in NMSS.
21 Rulemaking, our process for establishing and revising 22 safety and security requirements, should be an activity where we place a high 23 priority of using data analytics to support decision-making. This would or 24 should be documented in the regulatory analysis., but it seems over the last
32 1 few years that quality of regulatory analysis seems to be slipping. And seems 2 as though it's more or less becoming an after-the-fact rationalization of what's 3 being proposed in the rulemaking language rather than being used a tool that 4 shapes the decision.
5 Are there any efforts underway to improve our use of data 6 analytics in developing the regulatory analysis?
7 MS. VEIL: So, I'll start with just the beginning process of 8 rulemaking.
9 There's always a regulatory basis in a rulemaking plan, as 10 you know, that comes up and that may have cost information, cost benefit 11 information. So, that's the before-the-fact activity that starts.
12 When the proposed rule and final rule comes up, that's when 13 a regulatory analysis is sent up.
14 So, there's a working group that is formed and there's 15 actually improvements that are already on the table before the Commission.
16 I believe it's in NUREG/BR-0058, and also a 2020 SECY paper that has actual 17 recommendations for improvements to the process.
18 But there's in-house expertise for doing regulatory analysis.
19 There's data, there's data analytics for doing regulatory analysis.
20 But there's also a need for surge capacity. When workload 21 increases there may be some contracting help that's needed to do those 22 regulatory analyses.
23 But the Center of Expertise, along with the Program Office, 24 which is all part of the working group that works together, does use all the
33 1 information that they have to try to put together a regulatory analysis that has 2 the appropriate basis.
3 But the first steps at that point should have been done already in the 4 regulatory basis in the rulemaking plan. The reg analysis is really at the point 5 to put before the Commission for you all to make your decisions.
6 COMMISSIONER CAPUTO: Okay. Thank you.
7 Zack, back to you with another question on the ROP.
8 You mentioned a proposal to delay removing a greater than 9 green input for an objective performance indicator from the inspection -- the 10 action matrix once it has demonstrated a return to green performance, and to 11 delay that until after an inspection verifies that inspectors think a licensee has 12 really actually returned to green.
13 This appears to supplant objective performance criteria 14 which the agency has found reliable for the last 20 years, with inspection 15 results that can be subjective in nature. Now, I'll admit only having been back 16 for a couple months, I haven't focused on the details of this issue yet but this 17 is feeling like a step back in time for the agency.
18 The purpose of instituting the ROP was to replace its 19 predecessor, the subjective SOP process of the '90s, with one that was as 20 objective as reasonably possible.
21 Wouldn't what youve discussed this morning potentially 22 penalize licensees who return to green, green performance, as indicated by 23 their performance indicators?
24 MR. HOLLCRAFT: Very good question, Commissioner.
34 1 As you said, the PIs do, performance indicators do provide 2 objective indicators of safety in particular cornerstones, but they're not able to 3 assess the cause of the reduction in safety or if appropriate corrective actions 4 that are put in place to return the plant to its baseline levels.
5 Once a degradation is determined by the performance 6 integrator -- or performance indicator, and the licensee transitions from green 7 to white, the program requires an inspection to determine if the cause has 8 been corrected. The licensee is subject to supplemental inspection review of 9 its correction action to address the white PI, exactly the same as for a white 10 inspection finding. That's the way things currently work.
11 However, if a white PI returns to green once the data is 12 included, it no longer counts as an action matrix input and will no longer 13 aggregate with other greater than green inputs. Even if the licensee is taking 14 no corrective action to address the underlying reasons for that the PI 15 exceeded the green-white threshold.
16 The licensee remains in Column 2 of the action matrix until 17 they complete -- the completion of the supplemental inspection because 18 there's no white action matrix inputs for aggregation purposes, which can be 19 confusing to stakeholders.
20 This lack of aggregation makes it possible that the licensee 21 may not move to a higher column in the action matrix if other safety-significant 22 inputs are present. And several quarters may pass before the ROP identifies 23 this decline in performance.
24 The staff believes that this is a, this is actually contrary to
35 1 the principle of good regulation on reliability, and that appropriate regulatory 2 actions may not be promptly administered.
3 The staff believes that the current process is overly 4 complicated and is inconsistent with the principles of good regulation on clarity 5 and reliability, and does not give licensees a sufficient incentive to address 6 the underlying issues to prepare for a prompt NRC supplemental inspection 7 commensurate with the safety significance of the PI.
8 Basically, we're trying to align both the PIs and the greater 9 than green inspection findings and keep everything as simple as possible for 10 our stakeholders.
11 Thank you.
12 COMMISSIONER CAPUTO: One thing I firmly believe is we 13 need to remain as objective as possible in the ROP. And so, I'm going to be 14 looking at this issue in quite a bit of detail.
15 I want to understand how data is used to make that decision, 16 how many scenarios were considered, and how previous performance was 17 evaluated in reaching that decision. Because it's my understanding, given 18 the data that was provided, there are a significant number of data points 19 contrary to that recommendation.
20 So, I will be following up with that closely.
21 Thank you, Mr. Chairman.
22 CHAIR HANSON: Thank you, Commissioner Caputo.
23 Commissioner Crowell.
24 COMMISSIONER CROWELL: Thank you, Mr. Chair. And
36 1 thank you to all of the presenters today. This is an incredibly helpful and 2 informative briefing for me, and I've learned something new as I've read 3 through the materials prior to the meeting and in the discussions today. I'm 4 going to ask probably some more pedestrian questions, and I think that's 5 important for our stakeholders and the public who are following the actions of 6 the NRC probably more closely these days as we embark on a new era of 7 nuclear energy production and operations.
8 And I wanted to maybe address this first question to Jamie.
9 But whoever can take it, if they like, related to COVID and COVID measures 10 that were implemented.
11 What COVID adjustments were made that are going to be 12 carried into the future in a post-COVID environment and what's the rationale 13 for doing so?
14 MS. HEISSERER: Sure. Great question, thank you.
15 So, one of the major things we identified efficiencies with 16 and benefit from throughout COVID was using technology to streamline how 17 we communicate, to be able to, you know, access information from the 18 licensees in more -- in realtime, off hours, et cetera. We've identified a 19 number of efficiencies from that.
20 Communications efficiencies between the inspectors and 21 agency experts, and whether in the region or in headquarters, have been 22 enhanced through, you know, as issues are identified and come up. Just 23 being able to hop on a Teams call with the agency expert on a particular valve 24 issue has, has been priceless.
37 1 And those are the types of communications enhancements 2 that will absolutely be carried through.
3 And, yeah, and I would also add that the additional remote 4 capabilities for, for residents to be able to check in on events, you know, in off 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> when a call comes in, you know, that will certainly continue.
6 MR. ROBERTS: Let me just add some perspective, 7 Commissioner Crowell.
8 You know, the world we live in now compared to the one 9 that was around when I was an inspector is totally different, obviously. And 10 the technology affords our inspectors today to look at parameters far more 11 directly than what I had available to me.
12 Kind of wish I had some of the tools they have when I was 13 in their shoes, you know, a couple decades ago.
14 But, for example, laptop technology allows inspectors to 15 access plant data, you know, operating parameters, pump flow rates, 16 pressures, system pressures, all kinds of process information that, you know, 17 once you had to actually go into the plant to see, that you can now leverage 18 just by sitting at your desk and looking at a laptop and accessing the licensee's 19 plant data.
20 So, that's something that we're, you know, encouraging 21 inspectors to do. And they have that, that tool available to them now.
22 Likewise, it can also access, you know, documents remotely 23 as they prepare for inspections. You know, there's a number of cross-24 procedures, drawings, corrective action documents, things of that nature that
38 1 are of benefit to our inspectors as they're preparing for an inspection. So, 2 they can do that kind of work at home or work from an office looking at a 3 computer.
4 All that being said, it's still best that the inspectors have an 5 onsite presence so they can see activities in process or in progress. There's 6 still a huge benefit to having an onsite presence for our inspectors to ensure 7 that they're -- they being the licensee -- are conducting their activities safely 8 and securely and in accordance with their procedures and our regulations.
9 So, there's a little bit more of a, there's a little bit more of a 10 balance available that we're trying to seek with respect to the available new 11 technology and some of the more traditional means through which we do that 12 oversight function.
13 COMMISSIONER CROWELL: Thank you. Is it fair to say 14 then that any new or adjusted procedures related to COVID that will be carried 15 forward would represent an overall net safety benefit?
16 MR. ROBERTS: Yes, yes. The main goal will be to 17 ensure that we continue to provide adequate oversight to provide us with the 18 reasonable assurance of adequate protection and safety. And so any 19 changes that we make to our inspection and oversight programs and the 20 related inspection procedures will have that goal in mind, and there will be, 21 you know, net safety provided from that.
22 COMMISSIONER CROWELL: Okay. Thank you. I want 23 to touch on their organizational health objectives a little bit. And, Andrea, I 24 don't know if this is best for you, but, again, whoever wants to take it may do
39 1 so. Do you feel that the measures related to organizational health objectives 2 are sufficient to meet the near- and medium-term needs of NRR?
3 MS. VEIL: One of my goals when I came in to NRR is to 4 ensure that the people, I'm very people-centered, that we take care of our 5 people. Our folks are so incredibly dedicated that they're going to rise to the 6 occasion regardless of whats going on. COVID had a big impact. There's 7 a lot of, as Jamie said, there's a lot of personal impact that people have had 8 from COVID and various other things, just life. It comes at you fast, right?
9 So people will get the work done. But for me, it matters how you get there, 10 so we are very, very, very focused on hiring. We're focused on retention and 11 recruitment and also transparency. When I can share things with my people, 12 I do. When I can't, I tell them I can't and I tell them why. But we look at all 13 the things that we have going on, FEVS results, diversity and inclusion, town 14 halls, everything we can do to make the person whole because that's an 15 important part of organizational health. And then we have the productivity 16 that we need because we are embarking on a new generation of a lot more 17 work.
18 So I'm very focused on the people, making sure we have 19 what we need, both in-house and also what we bring in from new employees 20 and mid-level employees, as well.
21 COMMISSIONER CROWELL: I appreciate that. I mean, 22 as I get more familiar with the agency, it is clear to me that your portfolio is 23 heavy, so to speak, and I want to make sure you have the tools to do it well.
24 Along the lines that you just discussed, and I don't know if
40 1 this is NRR-specific or maybe NRC broadly specific, but are there efforts to 2 work with industry and academia to make sure that there's a robust talent 3 pipeline out there, and is there anything more that can be done in that regard?
4 MS. VEIL: Yes, definitely. Our Office of the Chief Human 5 Capital Officer has recruitment activities in place. Several of my folks are 6 ambassadors for universities. There's a grant program that Ray Furstenau 7 oversees that is both for individuals and for academic programs, and we focus 8 on that a lot. We understand that we need to bring people in.
9 There's a proposal on the table that's not really right for 10 prime time, but I'll kind of just mention it in general, of ways that we can partner 11 more across, of course within legal limitations, that we can partner across the 12 board, and this includes internationally. I was recently on a trip to Poland, 13 and they immediately said we want you to mentor long distance our women in 14 energy, so, of course, I need to talk to Marian about how to do that. But it is 15 a global issue that we're trying to get our hands around because it's a very 16 small community.
17 COMMISSIONER CROWELL: And, hopefully, Marian 18 helped you find a way to yes for those types of engagements because they're 19 incredibly valuable and important.
20 MS. VEIL: I haven't talked to her yet. This is her first time 21 hearing this.
22 COMMISSIONER CROWELL: We'll just talk to each other 23 while she sits between us. Just one more question, a little bit more wonky, 24 and it is probably to you, as well, but, in learning more about the subsequent
41 1 license renewal process and the GEIS associated with that, you know, I 2 understand, you know, the Category 1 considerations fall within that, but 3 what's in the Category 2 realm that we need to be, you know, like plant-specific 4 issues that may be addressed differently in subsequent renewals under 5 Category 2?
6 MS. VEIL: I'm very confident in what the staff has put in 7 place to kind of streamline, and I know streamline is sometimes not the best 8 word to use, but to be more efficient in plant-specific reviews. It could vary, 9 depending on sites. You could have siting considerations. You can have 10 emergency planning considerations. But the box that we put around those 11 Category 2 issues make it a little bit more standardized so that they can be 12 handled in a more efficient way. So we could certainly get you, like, kind of 13 deep dive into the specifics of that in future briefings, if you would like.
14 COMMISSIONER CROWELL: Yes, I think that would be 15 helpful, specifically on the emergency preparedness and planning efforts. I'll 16 probably ask a few more questions on that during the new reactor discussion.
17 So thank you. I appreciate everyone's help on this.
18 CHAIR HANSON: Thank you, Commissioner Crowell.
19 Andrea, I think I'll start with you. You know, a number of us noted with some 20 interest the passage of the Inflation Reduction Act and the inclusion in that of 21 the $15 per megawatt hour production tax credit for existing reactors. And 22 that tax credit, just based on my preliminary discussions with licensees during 23 drop-ins, it really has the potential for them to make significant additional plant 24 investments as they look to enhance the economics, continue to enhance the
42 1 economics of their operations. And these may include digital I&C upgrades, 2 use of higher enrichment, higher burn-up, and accident tolerant fuel designs.
3 Conversations on uprates, in fact, are also starting to emerge again, and there 4 may be a scenario where licensees propose all of these things in some 5 combination or all at once.
6 And for us, I think that means providing, you know, clear and 7 predictable regulatory pathways on issues, like 50.46(c), fuel fragmentation, 8 relocation, and dispersal, accident source term. And to do that, we need 9 adequate technical staff, you know, particularly in the reactor systems analyst 10 areas.
11 So I just wanted you to, I wanted to kind of get your thoughts 12 on, you know, what impediments do you see, if there are any, to us kind of 13 efficiently conducting those reviews and making kind of adequate protection 14 determinations as those amendment requests, I think, potentially, some pretty 15 complex license amendment requests, start to filter in.
16 MS. VEIL: Yes and yes, I've heard all of those things and 17 more about what could be coming based on the IRA, Inflation Reduction Act.
18 IRA can stand for a lot of different things.
19 So it goes to what I mentioned earlier: people are prepared 20 to do the work. They will do the work. They have the skills, the knowledge, 21 and ability to do the work, but we need more people. It's a small community.
22 We are competing with a lot of different organizations, some of which, you 23 know, have benefits that we're now allowed to have because of being a 24 government agency. So I am interested in making sure that we have a
43 1 pipeline, number one. Also, retain, and I say this every time I have a 2 discussion about recruitment, retain the people that we have, have knowledge 3 management to make sure people have what they need, and that we're 4 passing that information down.
5 We often get very busy. We're very heads-down in the 6 work that we do. But we make time in our arc to have what we call executive 7 technical, or ET, chats, executive team chats. And there's a specific topic.
8 It could be digital I&C, it could be FFRD, or fuel fragmentation, relocation, and 9 dispersal. It can be these kind of deep dives. And because of Teams, we 10 could have two - three hundred people out of the five-hundred in the office on 11 the line. We have SharePoint sites. We have a big focus on making sure 12 people are ready to do the work that's coming. There's a myriad of work 13 coming, and people are doing all this stuff at the same time.
14 So we're trying to pull in more people to give relief to some 15 of those folks that are working on some of these activities but also retain the 16 people who have all this knowledge that we don't want to walk out the door 17 and not, you know, share that knowledge with people that are here.
18 MR. ROBERTS: Can I add something, Chair?
19 CHAIR HANSON: Please.
20 MR. ROBERTS: Another impediment I would offer is, you 21 know, our budgeting process is a two-year forward-looking process, and our 22 strategic workforce planning efforts are a little bit broader than that, five years.
23 And often we hear from these utilities and other stakeholders that they've got, 24 you know, five- and ten-year and beyond projections for these things.
44 1 And so, you know, fortunately, we had a Project Aim, and 2 we had a transformation effort that gave us signposts and markers, which is a 3 tool that we can use to sort of better forecast the things that might be 4 happening in the industry to better prepare and budget for those things. But 5 I would offer that we're still constrained by our normal processes.
6 And so we have to make sure that we have the right 7 signposts and markers, for example, that we're looking at the right external 8 factors to better predict what is coming down the pike so that we can budget 9 those things that are in our requests.
10 CHAIR HANSON: Good, good. Thank you. Yes, that's 11 very helpful. I appreciate that.
12 Andrea, I'll come back to you again. I want to thank the 13 staff for submitting the recent paper on digital instrument and control common 14 cause failures where the staff recommends updating the 30-year-old policy to 15 expand the use of risk-informed approaches to evaluate digital I&Cs, and, yet, 16 I think the paper still relied pretty substantially on some deterministic and, you 17 know, technology-specific aspects of the current policy, and I guess I'd just 18 like to get some background about kind of what was the staff's thinking relative 19 to how these provisions might apply either, frankly, with the existing fleet or 20 kind of with advanced reactor designs, and, you know, what kind of influence 21 the staff in kind of going a little further on the risk, you know, down the risk-22 informed path with that paper.
23 MS. VEIL: Sure. At a high level, both of the 1993 paper 24 and the current paper that's before you has four points. The first three points
45 1 were risk informed. The fourth point is also risk-informed, but there's a 2 difference of opinion on how far that risk-informed provision went for point four.
3 So I can kind of clear it up here.
4 CHAIR HANSON: That's a good, I think that's a fair 5 characterization of the paper.
6 MS. VEIL: So I can clear it up here. Point four talks about 7 what manual and diverse controls are needed, for example, for control room, 8 right. And the difference of opinion is that the staff is saying that, regardless 9 of whatever risk-informed evaluation is done, that the staff is requiring diverse 10 manual controls, regardless of what the assessment is, so it's not performance 11 based or risk informed. But what the staff is actually saying, and this could 12 be semantics or it could be cleared up in guidance, what the staff is saying is 13 that, for critical safety functions, not just safety functions, critical safety 14 functions, like reactivity control, the reactor coolant inventory, containment 15 isolation, containment integrity, those are the defined -- and there's one more 16 I may be missing. Those are the defined critical safety functions.
17 So as a result of whatever analysis that a licensee does, for 18 those critical safety functions, then they could use non-safety related controls 19 to actually risk inform and control whatever, you know, manual and diverse.
20 And so I don't think anybody would argue that the critical safety -- they might, 21 but I'm not arguing that the critical safety functions that are just mentioned are 22 ones that are not worthy of diverse manual controls. But, again, it's the result 23 of the evaluation. We're not imposing evaluations on licensees. We're not 24 prescribing how they do it, but there needs to be controls for these critical
46 1 safety functions.
2 That's the source of argument for point four, I think. Most 3 people would tell you, one through three, hey, we're really happy staff has 4 gone further than before in, you know, updating this 1993 policy. Point four 5 is where most of the discussion continues, and it could be we clear it up in 6 guidance.
7 CHAIR HANSON: Thank you. Very helpful. I just want 8 to use the rest of my time, Shilp, I've got a question for you. I was really glad 9 to get the update on the risk-informed process for evaluations, or RIPE, and I 10 was glad to see, it had been a while since I tuned into the RIPE evolution, and 11 I was glad to see staff kind of continuing to pursue that in the change to tech 12 spec area. And, of course, I think it was in the spring now, it seems like it 13 was just yesterday, that we had the first one for Palo Verde, if I remember 14 correctly.
15 So what, in your view, has worked well so far with RIPE, and 16 what do you think are kind of the areas for improvement on that?
17 MR. VASAVADA: Thank you. I think RIPE was 18 successful in demonstrating the underlying purpose, the basis, and the 19 expected outcome of how we handle in a graded manner very low safety-20 significant issues. We can efficiently dispose them off in a manner that is 21 focused on safety and leave our resources and time for more safety-significant 22 issues.
23 Based on the review for Palo Verde, we have conducted and 24 are currently conducting a thorough lessons-learned evaluation. My
47 1 understanding is that, basically, the vast majority of the lessons learned talk 2 about improving the clarity of the guidance for performing reviews under RIPE.
3 An example is increasing the clarity of the expectations for technical staff in 4 the first step of the process, what's called a no technical objection review. But 5 I have not, to the best of my understanding, seen anything that challenges the 6 underlying basis and purpose of the RIPE process.
7 CHAIR HANSON: Good. Thank you, yeah, very much.
8 Really appreciate that. Oh, look at that. I'm right on time.
9 Commissioner Wright.
10 COMMISSIONER WRIGHT: Thank you, Mr. Chairman, 11 and good morning, everyone. Thank you for your presentations.
12 Personally, I really like the rain outside. It's due.
13 So there's been a lot covered here this morning, and there's 14 a couple of things that I think I need to address, and I'm going to follow-up a 15 little bit on Commissioner Caputo's questioning and go a little bit deeper and 16 maybe provide a little context, especially for Commissioner Crowell, as well, 17 and for Commissioner Caputo. And this goes to the ROP papers that are 18 before us. This goes back a couple of years, right? It transcends an EDO 19 change. It was really close to when, I think, Ho left the agency and you 20 entered the position here, Andrea. So, you know, that's something that we 21 have to consider when we think about how things have transpired, right?
22 But, originally, if you remember, the staff approached us and 23 polled the Commissioners about withdrawing the ROP papers. And when 24 asked specifically, I can speak for myself, when asked why that was
48 1 happening and what was the purpose, and this was also the explanation we 2 gave Congress when we were asked about it, as well, last year, I guess it was 3 the November - December time frame, but one of the things they asked, one 4 of the answers that we were given was that they wanted to implement things 5 that they already had the authority to do, in their opinion, that were in that 6 paper. So they wanted to remove that, and then there might be some 7 additional items that they wanted to add to the paper. But everything that 8 was in the papers would come back up to us as they were, and that was the 9 reason for me giving approval in my poll to withdraw that. Now, I can't speak 10 for any other commissioner who was polled for their reasoning, but that was 11 my reasoning for it.
12 And because the PI&R part of it was, it wasn't unanimous, 13 right? The recommendation that was given to us was triennial, I believe, and 14 it also had a differing view attached to it for our consideration. And I was 15 aware, as everyone else that was reading the papers, that it wasn't unanimous 16 among the regional administrators. I think it was three to one, you know, that 17 were favoring the biennial. So there was debate about it; I get that. But we 18 were being asked as a commission, make that policy call. We're throwing 19 that up to you to make that policy call. And so I said, okay, if that's coming 20 back to us, I'm good with it. I gave them my blessing to remove it.
21 Well, that ain't what's happened here. Okay. The ROP 22 has come back up differently, especially the PI&R. Plus, it's been split up, 23 which that's okay. But the PI&R thing, the reasoning for it, first off, the report 24 -- Zachary, Andrea, you all can, any of you can jump in on this one. The
49 1 report doesn't show, when you all refer to that, right, it doesn't give you basis 2 to do one way or the other.
3 And then based on what I've read so far, the new 4 information, I don't really know what it is. It doesn't really point to again. It's 5 more debate again. We're back in the debate space.
6 So for me, it's troubling that that change happened the way 7 it happened. Okay. Because we were being asked as a commission to 8 make a policy decision, and that was taken from us. Now, it's back up before 9 us. It's different, you know, which that's the troubling part to me because, 10 going forward, when I'm asked to withdraw papers, I'm going to be looking at 11 it with a little bit of a tainted view, right? So I'm trying to make sure that I 12 understand everything because I think there's more behind this than I'm aware 13 of right now, and, over time, it will come to light. But I didn't even say whether 14 I was for triennial or biennial. You know, nobody knows where I stand on 15 that. But the fact that that was taken from us and it was changed is troubling, 16 but we will make the decision.
17 Now, having said that, you know, to either Andrea or Zach, 18 can you discuss a little bit more about the types of potential impacts from the 19 PI&R procedure, the changes the staff are looking at, that could affect 20 evaluation of the PI&R team inspection frequency? And as a follow-up, can 21 you describe the staff's plans once the impacts are identified and evaluated?
22 MS. VEIL: I'll start, and then I'll turn it over to Zach. With 23 regard to withdrawal of the papers, the reason why it took almost a year, when 24 you think about it, for the four to come back up, and the SRM was very clear.
50 1 Assess any new information that you have. Inherently, so much time had 2 passed, we had new inspections, we had new samples. The comprehensive 3 assessment was completed in that time.
4 So we looked at all of that information, including the 28 5 inspector feedback forms that I mentioned earlier that were provided. And as 6 I said, before the information didn't support or refute moving to triennial.
7 Nothing in those assessments, nothing in the conversation said we will have 8 a more effective PI&R if we move it out to a triennial frequency. And when 9 the end-of-cycle meetings occur with the regions, with, you know, 10 headquarters' involvement, those touchpoints, as Zach mentioned earlier, are 11 important for making those decisions. So, inherently, by the fact that that 12 assessment was done, there are recommendations about procedure 13 improvements, recommendations about making sure that corrective actions 14 are done appropriately.
15 If we move the program out to triennial while we are 16 assessing all these other things, and you are correct that there are differing 17 views. Some people will say, well, those changes are around the fringes, 18 they're not going to really do anything. But then we are presupposing what 19 the outcomes are going to be instead of using data and information and 20 inspection results to see where we can go.
21 So if we moved out the frequency while all these other things 22 are going on, we don't have an anchor or a baseline to see what's really 23 happening in this program. And we don't get the touchpoints that we need.
24 The daily inspector touchpoints are not the comprehensive PI&R program.
51 1 They're aspects of it.
2 So, again, the ROP is robust. It's assessed. It's 3 continuously evolving. So we're trying to use that information to determine 4 how to move forward.
5 COMMISSIONER WRIGHT: So, again, it's troubling 6 because we were asked, we were given a paper to address a policy issue, 7 right? The way that you would respect that policy decision-making process 8 would have been to supplement the existing recommendation with the new 9 information that you have, which I don't really know if it's new information or 10 not. I'm still, you know, I'm going to give you the benefit of the doubt right 11 now; but what I've read so far, it doesn't provide, I don't see a basis for 12 recommendation of the change. That's what I see.
13 Now, having said that, I haven't made my decision, you 14 know, I don't really know whether I'd go with biennial or triennial. I don't know 15 yet. But that was taken from us, and, to me, as a commissioner in this space 16 up here, that is troubling. And so that would have been, in my opinion, how 17 you should have maybe approached this, but we are where we are and we 18 will make a decision on it, you know.
19 And I do appreciate you trying to give us the information that 20 we're looking for. So if there is more information, what's referred to as new 21 information that is different than what I'm reading right now, please 22 supplement it and get it up to us so we can use that in our decision-making 23 process.
24 MR. HOLLCRAFT: I'd only add, you had asked about our
52 1 plans going forward and our potential timeline. The goal would be to 2 implement any recommended changes from the comprehensive review in the 3 next year for a start, and the next biennial cycle, which would be January 2024, 4 ideally, we would have a two-year run on that in the next biennial cycle and be 5 able to perform an effectiveness review and then make any determinations for 6 future changes, which could possibly include frequency.
7 COMMISSIONER WRIGHT: Okay. Thank you. And I've 8 got about a minute. Darrell, do you have anything?
9 MR. ROBERTS: No, I --
10 COMMISSIONER WRIGHT: Okay. And we'll go to a 11 different topic here. And I guess in the minute that I've got, I wanted to go to, 12 I guess, Andrea, Darrell, Jamie, look at the resident inspector recruitment 13 retention thing. You had mentioned the health dashboard and the cross 14 region working group, and I think that's a great repository of information. So, 15 Jamie, I'd be interested to hear from you, if you've had an opportunity to use 16 the dashboard in your capacity in Region III and, if so, how did it help you 17 inform your decision-making? I'd also welcome Darrell and Andrea's 18 perspectives, and I'm interested to learn how the dashboard is updated, right, 19 to ensure it remains a good tool to gauge program health.
20 MS. HEISSERER: Great question. In the regions, we're 21 very excited about the dashboard tool that we have. It offers us data-driven 22 information, as Zach had pointed out, for all aspects of the resident inspector 23 health, from training and hiring to interest in sites.
24 So as one example in Region III that we used that data over
53 1 the summer, we had multiple concurrent senior resident inspector vacancies.
2 One of the pieces of that dashboard is a heat map which, based on survey 3 data from the existing pool of resident inspectors and senior resident 4 inspectors, my director and I were able to look at where was the interest in 5 these sites. We were able to forecast and target where we might have 6 challenges in filling a senior resident vacancy. And even while those vacancy 7 announcements were out and we were awaiting applicants, we were able to 8 strategize what was our plan for backfill, what was our plan for ROP 9 completion, what were our contingencies in case we did not get interest in one 10 particular site, which the data showed that had low interest. So that's one 11 example that we applied the dashboard.
12 So as far as updating the dashboard, it's critical that, you 13 know, what goes in is the best information we can get, so it's critical that that 14 is updated frequently. So that's based on inspector surveys, and one of the 15 methods that we're doing to make sure that that information is the best that 16 we can is the standing Resident Inspector Committee that will make sure that 17 the surveys are going out at a certain periodicity and that the regions are 18 updating with hiring data, et cetera, to make sure that those are updated 19 periodically.
20 MR. ROBERTS: Thanks. I'll just add, Commissioner, that 21 an important benefit of these dashboards is the visualization aspect of it. The 22 fact that this information, the information has pretty much been available to us 23 in various forms and fractions and other areas, and this brings them all 24 together and presents them in a way that all people can see it. It makes it
54 1 available to not just management but inspectors and others who might be 2 interested in going out to some of these sites. So it takes the guesswork out 3 of, you know, the whole resident inspector health program, not just for us 4 sitting at the table here but for the inspectors that are interested in pursuing 5 an inspection career at one of these sites. They get to see which sites have 6 the heat map impact, that have the, you know, levels of interest that might be 7 conducive to them wanting to take a chance and go out.
8 COMMISSIONER WRIGHT: Yes. Well, the dashboards 9 are helpful. There's a lot of them, right, and I just hope that we're using them 10 the way they were designed to be used. So I appreciate your answer.
11 Thank you.
12 CHAIR HANSON: All right. Thank you, everyone. I 13 appreciate all of your contributions to the first panel and the good discussion.
14 We're going to take a break. Let's just call it 10:30 we'll reconvene for the 15 new reactor business line. Thank you.
16 (Whereupon, the above-entitled matter went off the record 17 at 10:21 a.m. and then went back on the record at 10:30 a.m.)
18 CHAIR HANSON: All right. Thanks, everyone. We'll 19 now recommence with the second panel on the new reactor business line.
20 Once again, the discussion will be kicked off by our Deputy Executive Director 21 for Reactor and Preparedness Programs, Darrell Roberts.
22 Darrell.
23 MR. ROBERTS: All right. Thanks, Chair Hanson and 24 Commissioners.
55 1 During this panel, the staff is pleased to provide you with a 2 strategic overview of the new reactors business line. This work includes 3 licensing of new light water reactors and advanced reactors and oversight of 4 the construction of Vogtle Units 3 and 4. Staff recognizes the rapid evolution 5 and strong commercial interest in new and advanced reactors and continues 6 to enhance our programs to prepare for efficient and reliable licensing. We 7 are continuously monitoring indicators, such as the Department of Energy 8 funding, to support new technologies. This ensures we gain accurate 9 insights on the external environment to guide our planning and program 10 development.
11 Our panelists will describe how we are proactively planning 12 for these changes and using innovative methods to support our licensing 13 reviews and enhance our regulatory infrastructure. They will also discuss 14 how early coordination with other federal agencies, industry, and international 15 organizations is facilitating a more effective and predictable licensing review 16 process for new and advanced technologies.
17 The advancements we've made this past year have been 18 successful only through the great collaborations of the offices of Nuclear 19 Reactor Regulation, Nuclear Regulatory Research, Nuclear Material Safety 20 and Safeguards, Nuclear Security and Incident Response, the General 21 Counsel, and International Programs.
22 Now I'd like to introduce the panelists who will provide 23 additional details on staff's activities in this business line. First, you'll hear 24 again from our NRR director, Andrea Veil, who will provide a high-level
56 1 overview of the new reactors business line strategic priorities and success.
2 Next, you will hear from Brian Kemker to my immediate 3 right, senior resident inspector at Vogtle Units 3 and 4 in Region II. He will 4 be discussing how we are applying Vogtle 3 and 4 construction lessons 5 learned and how the staff is preparing for this transition of those units from 6 construction to operations.
7 Following Brian, Michelle Hayes, a branch chief in NRR's 8 Division of Advanced Reactors and Non-power Production and Utilization 9 Facilities, will provide an update on the staff's activities to strengthen the 10 agency's preparedness for licensing new and advanced reactor technologies.
11 And, finally, Hossein Esmaili, a branch chief in the Division 12 of Systems Analysis in the Office of Nuclear Regulatory Research, will discuss 13 his office's support for the near-term licensing of new and advanced reactors.
14 Next slide, please. And that concludes my opening 15 remarks, and I will now turn the presentation over to Andrea.
16 MS. VEIL: Thank you again for the introduction, Darrell.
17 We continue to prepare for future new and advanced reactor licensing actions 18 through pre-application engagement, developing risk-informed, technology 19 inclusive, and performance-based guidance in rulemaking, and coordination 20 with our federal and international partners. We're ensuring our workforce is 21 prepared for new and advanced reactors through knowledge management, 22 training, recruitment, and retention.
23 Next slide, please. During this year, we've continued 24 robust pre-application activities to support future licensing. Pre-application
57 1 reviews are underway with 15 prospective new and advanced reactor 2 applications, including those that support congressionally-mandated priorities, 3 such as the Advanced Reactor Demonstration Program.
4 The staff has completed the review of over 50 topical reports 5 and white papers on a variety of technical and licensing matters to support 6 applicants' submittal timelines. The NRC staff has 22 topical reports and over 7 20 white paper reviews ongoing and is projecting for an additional 70 to be 8 submitted for review over the next few years.
9 Pre-application activities position, as well, to review near-10 term small modular reactors and non-light water reactor applications, such as 11 Kairos Hermes test reactor. This is the first demonstration of NRC's 12 enhanced licensing approach for new and advanced reactors, which is 13 focused on more risk-informed safety determinations.
14 So far, we are seeing substantial success in implementing 15 this enhanced approach. The review is demonstrating our commitment to 16 timely review schedules and cost estimates and achieving those through 17 transformative review approaches all while keeping the focus on issues with 18 the greatest impact on safety.
19 During the Hermes review, the staff has identified, roughly, 20 400 questions for the applicant. Working closely with the applicant and 21 leveraging innovative and transparent approaches to address each question, 22 the staff resolved the issues in a timely manner and efficiently documented 23 their safety considerations.
24 Next slide, please. We are actively engaging stakeholders
58 1 to develop risk-informed, technology inclusive, and performance-based 2 guidance to support near-term applicants. To support future advanced 3 reactor applicants, the Technology Inclusive Content of Application Project 4 and the Advanced Reactor Content of Application Project aimed to streamline 5 the development of licensee applications for submission to the NRC are 6 focusing on issues with the greatest potential to impact safety and minimize 7 the documentation necessary for non-safety-significant information.
8 This will contribute to more reliable, clear, and efficient final 9 safety evaluation reports by the NRC staff. Furthermore, in anticipation of 10 light water reactor construction permit applications within the next few years, 11 the staff developed interim staff guidance to supplement the guidance in the 12 standard review plan. This is expected to be completed by the end of the 13 calendar year.
14 The staff continues to make significant progress on the Part 15 53 rulemaking to develop a risk-informed, technology inclusive, and 16 performance-based regulatory framework. Since the July 21st Commission 17 meeting, we continued stakeholder engagement in several public meetings 18 and released consolidated preliminary proposed rule language text to support 19 ACRS interactions this month.
20 The staff has benefitted greatly from stakeholder input on 21 the draft rule. Most notably, the staff expanded the scope of rulemaking to 22 address stakeholder requests for an alternative to the probabilistic risk 23 assessment-led framework. The alternative aligns with more of a traditional 24 framework and international standards.
59 1 This novel approach to rulemaking has also presented its 2 fair share of challenges. For example, stakeholder input has been diverse 3 and sometimes conflicting. The staff, however, continues to consider the 4 feedback and make modifications where appropriate.
5 Also, the size and complexity of the rule have presented 6 challenges to some stakeholders, including non-governmental organizations.
7 In February 2022, the staff held a public meeting that was specifically focused 8 on receiving feedback from several of those organizations.
9 Additionally, in June of this year the staff proposed to the 10 Commission a rulemaking often referred to as the Part 50-52 Rule. This 11 rulemaking would amend the regulations related to licensing new nuclear 12 power reactors to ensure consistency, promote a more effective and efficient 13 new reactor licensing process, and reduce the need for exemptions from 14 existing regulations and also licensing amendment requests.
15 Next slide, please. A large factor in our success to prepare 16 for the future of new and advanced reactor licensing is our coordination with 17 other state, local, federal, and international partners. For example, we're 18 coordinating with the Department of Energy and Department of Defense on 19 multiple national priorities, including the Project Pele Mobile Microreactor and 20 future microreactor at Eielson Air Force Base.
21 We're performing outreach to state and local governments 22 to consider their needs while developing new and advanced reactor policy and 23 rulemaking. We're also using our state and international partnerships and 24 networks to gain insights on fusion technologies, which will inform the paper
60 1 to the Commission to discuss options for regulation commercial fusion 2 facilities, and this paper is scheduled to be issued no later than November.
3 NRC management and staff members also lead and support 4 several multilateral efforts with the International Atomic Energy Agency 5 (IAEA), and the NRC has also led the SMR Regulators Forum since its 6 inspection and it continues to make invaluable contributions to new and 7 advanced reactor working groups on the Committee on Nuclear Regulatory 8 Activities. Most recently, the IAEA launched an initiative called the Nuclear 9 Harmonization and Standardization Initiative with a goal of establishing an 10 international framework that will enable increased cooperation of regulators 11 during SMR licensing reviews. The NRC will support this initiative and work 12 towards coordinating this with other ongoing efforts. In addition, in her 13 presentation, Michelle Hayes will discuss our cooperative work with the 14 Canadian Nuclear Safety Commission on advanced and small modular 15 technologies.
16 Next slide, please. The staff's completion of the first ever 17 10 CFR 52.103(g) finding for Vogtle marks a significant regulatory milestone 18 for the agency. Vogtle Unit 3 is the first Part 52 plant and the first new 19 construction of a commercial nuclear power plant in this country in over 30 20 years. This milestone is a significant achievement for the NRC, and they 21 should be proud of the accomplishments. It was a multi-agency effort, and it 22 was achieved only through those dedicated and committed actions and 23 activities from countless NRC staff from across the agency. We continue to 24 maintain our safety focus as Unit 3 prepares to load fuel for the first time.
61 1 Brian Kemker will share his firsthand on-site experiences as 2 a senior resident inspector at the Vogtle site. He will highlight our openness 3 to innovative methods and risk-informed approaches and our preparations 4 that led to the 10 CFR 52.103(g) finding. He will also discuss how we're 5 preparing for the future, including our ongoing lessons learned effort.
6 Next slide, please. This concludes my remarks, and I'll turn 7 the presentation over to Brian Kemker.
8 MR. KEMKER: Thank you, Andrea. And good morning, 9 Chairman and commissioners.
10 Next slide, please. On August 3rd, the NRC staff issued 11 the 10 CFR 52.103(g) finding for Vogtle Unit 3 based on our determination 12 that all of the inspections, tests, analyses, and acceptance criteria, or ITAAC, 13 in Appendix C of the Vogtle Unit 3 combined license were successfully 14 completed. The finding allows the licensee, Southern Nuclear Operating 15 Company, to load fuel and begin operation of the unit in accordance with the 16 conditions of the combined license. This historic accomplishment was over 17 ten years in the making since initial excavations began on site.
18 The staff worked diligently over the past several years to 19 ensure a successful transition from the construction reactor oversight process 20 to the operating reactor oversight process after the 103(g) finding. To do that, 21 we developed guidance for the transition and conducted tabletops to address 22 open issues that may have impacted the finding or the transition, including 23 possible hearing requests and late file allegations.
24 We had in place detailed procedures and conducted
62 1 extensive communications with key stakeholders. This facilitated timely 2 preparation of the Commission package that documented the basis for the 3 103(g) finding, which allowed us to efficiently update the final licensing and 4 inspection documents as ITAAC were complected and verified in our 5 inspection program. This enabled a very smooth and timely 103(g) finding.
6 A Vogtle 3 and 4 resident inspector office was intentionally 7 staffed with a diverse set of skills and levels of experience to cover the range 8 of construction inspections that needed to be completed and will ensure 9 continuity as Unit 3 and 4 become operation. The licensee will enter the 10 startup testing phase on Unit 3 when it commences initial fuel load. That is 11 expected very soon, possibly as early as this evening. The licensee plans to 12 begin the initial reactor startup later this year and enter commercial operation 13 early next year.
14 Unit 4 continues with plant construction concurrent with 15 component and pre-operational testing of safety systems. The licensee 16 plans to start high functional testing later this fall, begin initial fuel load next 17 spring, and enter commercial operation later in 2023. To support the Unit 4 18 103(g) finding, as of this month, we have verified approximately 37 percent of 19 the ITAAC closure notices.
20 Next slide, please. The Region II Division of Construction 21 Oversight, the NRR Vogtle project office, and the NSIR staff remain well 22 positioned and prepared as Unit 3 enters commercial operation and 23 construction and testing are completed on Unit 4. Maintaining the right 24 number of licensing, technical, and inspection staff, including bench strength
63 1 and expertise, is crucial to handle the current and upcoming workload for both 2 units.
3 We pull from experience with the Watts Bar Unit 2 4 reactivation in creating the Vogtle Readiness Group. This partnership 5 between the NRC offices, including the involvement of key managers, has 6 given us a highly effective way to communicate issues across the agency and 7 with a broad range of stakeholders to ensure early alignment and problem 8 solving for first-of-a-kind regulatory challenges.
9 We continue to use the Vogtle readiness group to 10 proactively identify potential inspection or licensing challenges and to 11 streamline issue resolution. To ensure regulatory engagement at all levels 12 and to facilitate a constant dialogue with the licensee and agency partners, 13 NRC executives and the Vogtle Readiness Group continue to meet routinely 14 on-site with licensee management and also meet internally during several 15 standing meetings. Open communications promoting understanding of 16 various technical issues during these meetings have been invaluable in our 17 successful oversight of the Vogtle 3 and 4 project.
18 As construction inspection work has concluded on Unit 3, 19 the inspection staff have been applying insights gained from Unit 3 20 construction, inspection, and testing to the remaining Unit 4 activities. For 21 example, from experience, we gained from the inspection of electrical 22 installation quality issues on Unit 3, we are informing our original inspection 23 planning and inspection techniques for electrical inspections on Unit 4. The 24 photos on this slide show three of our highly capable regional inspectors and
64 1 the Vogtle Readiness Group.
2 Next slide, please. The NRC staff is implementing several 3 strategies to ensure we maintain our construction oversight expertise. We 4 want to make sure we retain the talent. Over the last few years, Region II 5 has made it a priority to ensure our inspectors have meaningful assignments 6 at the NRC after the Vogtle construction project is complete. Using a select 7 now, place later approach and focusing on cross-qualification, that is 8 encouraging construction inspectors to qualify for other inspection areas, has 9 enabled us to maintain our experienced staff on the project while setting them 10 up for successful transitions to other important work in the agency later on.
11 Also, we actively look for opportunities to utilize our 12 construction inspectors on other agency projects that will leverage their 13 experience and expertise. For example, supporting inspection program 14 development for other construction projects, like new fuel facilities or reactors 15 or participating in limited work authorizations or early site permit inspections.
16 Region II is working closely with NSIR and NRR to stay 17 involved with the planning for future reactor and production facility 18 construction projects which will enable the staff to support the anticipated 19 oversight work related to new small modular reactors, non-light water and 20 advanced reactors, medical isotope production facilities, and fuel cycle 21 facilities.
22 Region II is also bringing in new talent, most recently 23 through the NRAN, and training some of them in construction oversight and 24 partnering them with experienced construction inspectors. This will promote
65 1 the development of new talent for the future. As part of knowledge transfer, 2 you see an example on the photo on this slide where I'm discussing some of 3 the features of the Unit 3 reactor vessel integrated head package during a tour 4 of the containment building with our technical assistant, Joylynn Quinones-5 Navarro.
6 Next slide, please. Last summer, we launched a lessons 7 learned initiative to conduct a holistic assessment of the Part 52 Licensing and 8 Construction Oversight Program for the purpose of improving the 9 effectiveness and efficiency of future programs. NRR has initiated efforts 10 which Region II is supporting to assess what construction and operational 11 oversight should look like for new and advanced reactors with potentially 12 enhanced safety profiles. Some of our lessons learned may also be applied 13 to our future oversight of the construction of new fuel cycle facilities.
14 The Nuclepedia symbol on this slide represents the internal 15 IT platform being used to capture the staff's extensive experiences and show 16 results of the lessons learned effort. This knowledge repository will also be 17 populated by stakeholder outreach and public meetings to gather feedback on 18 what worked well for Vogtle 3 and 4 and where we might be able to find 19 efficiencies.
20 These inputs will form the basis of a publicly-available 21 summary report that will include specific recommendations to improve the 22 effectiveness of the current construction inspection program, as well as to 23 inform the development of future construction oversight programs. Some 24 early lessons learned involve the success of the Vogtle readiness group that
66 1 I mentioned already.
2 When we were faced with unique challenges, such as 3 translating ITAAC language into safety, we were able to leverage the Vogtle 4 readiness group to build early consensus to make risk-informed decisions.
5 For example, when challenged with cable separation questions, we used a 6 revised technical assistance request process to gain alignment on a path 7 forward that was on solid regulatory ground.
8 Our lessons learned from construction oversight at Vogtle 9 continue the agency's learning culture and emphasize applying what we have 10 learned from construction over the past decade and informing the future 11 programs for small modular and advanced reactors.
12 Next slide, please. This concludes my remarks, and I will 13 now turn it over to Michelle Hayes to discuss new and advanced reactor 14 preparedness.
15 MS. HAYES: Good morning, Chair and Commissioners.
16 It's my pleasure to be here today. Thank you.
17 Next slide, please. As we transition to the execution phase 18 of the advanced reactor program, we're demonstrating, efficient, timely, and 19 risk-informed evaluations. We began reviewing the construction permit 20 application for Kairos Hermes test reactor last December and, as of today, the 21 safety evaluation is 60-percent complete with several chapters in the approval 22 phase. We are on schedule and budget to complete the final safety 23 evaluation report by next September.
24 Our ability to meet this aggressive milestone is the direct
67 1 result of extensive pre-application engagements with Kairos on 11 separate 2 topical reports and the project team's commitment to a safety-focused review 3 that is appropriately documented. The draft environmental impact statement 4 was streamlined to focus on the most important information needed to show 5 that the National Environmental Policy Act obligations were met and it was 6 issued ahead of schedule.
7 We received a construction permit application from Abilene 8 Christian University for their molten salt fuel research reactor in August and 9 expect to make an acceptance determination next month. We found 10 performing a pre-application audit of their draft preliminary safety evaluation 11 to be mutually beneficial. It helped the NRC become familiar with the design 12 and enabled Abilene Christian University to incorporate some of NRC's 13 feedback prior to submitting their application.
14 As Andrea mentioned, we have continued robust pre-15 application activities with many new and advanced reactor stakeholders. We 16 are excited that so many designers are taking advantage of these 17 engagements because early introduction to the various technology gives us 18 time to identify safety-significant aspects of the design, find the appropriate 19 core team members, and prepare relevant code and analysis tools. As 20 demonstrated with Hermes, addressing technical licensing and policy issues 21 early leads to a timely review.
22 Pre-application interactions cover a broad range of 23 activities, including the ongoing readiness assessment of the NuScale draft 24 standard design application, safety evaluations for topical reports, and less
68 1 formal feedback for white papers. To increase productivity, we are 2 continuously evolving our review strategies to incorporate best practices from 3 past projects. The NuScale design certification lessons learned report was 4 issued in March, and the recommendations have either already been adopted 5 or are in the process of being implemented.
6 We're also using our experience with Hermes to inform our 7 approach to Abilene Christian University, and we're improving efficiency 8 across all designs by standardizing how we review submittals on the same 9 subject matter.
10 We've developed and continued to enhance tools that 11 leverage data to optimize execution and communicate review status, such as 12 our internal and external dashboards. The dashboard on the right shows the 13 Kairos Hermes construction permit, the status of the Kairos Hermes 14 construction permit safety environmental reviews and is available to the public 15 through our public website.
16 We have also established internal design hubs that provide 17 one-stop access to news, schedule, application documents, and status.
18 These efforts enhanced the transparency of the way we do business and 19 promote stakeholder confidence.
20 Next slide, please. While some projects have been 21 delayed, overall, we've seen an increase in new and advanced reactor 22 licensing work this year and expect to continue in the future. As such, we're 23 continuing our focus to build an agile workforce that can respond to this 24 dynamic environment by taking advantage of various recruitment
69 1 opportunities to attract diverse staff, and we're investing in training and 2 knowledge transfer to build capacity.
3 For example, we've successfully involved staff from around 4 the agency in advanced reactor reviews so that we can introduce them to the 5 new technologies and our risk-informed approach. We were fortunate to 6 have a talented group of NRAN staff create a series of engaging Nuclepedia 7 articles on advanced reactor technologies. We created a knowledge 8 management corner around our internal SharePoint site with links to training 9 material, and we've dedicated resources to updating our external website, 10 recently adding pages on source term and fuel qualification.
11 Next slide, please. We've continued our efforts to build 12 modern risk-informed approaches to safety and efficiently regulate advanced 13 reactors in the future. Our efforts cover broad regulatory areas, and we've 14 demonstrated progress on key rulemakings, such as the Part 52 rulemaking, 15 emergency preparedness, physical security, and the advanced nuclear 16 reactor generic environmental impact statement.
17 We're providing the Commission with recommendations to 18 effectively address policy issues, such as fusion and annual fees for non-light 19 water reactors, including microreactors. This year, we've published fuel 20 qualification guidance and are finalizing our endorsement of three consensus 21 codes and standards. We're evolving guidance to support the 22 implementation of new rulemaking, such as Regulatory Guide 4.7, which 23 provides technology inclusive, risk-informed, and performance-based criteria 24 to assess population-related issues in the siting of advanced reactors.
70 1 Next slide, please. We are strengthening our readiness for 2 new and advanced reactor licensing through internal and external 3 collaborations. Our partnership with the Office of Nuclear Material Safety and 4 Safeguards ensures our ability to review transportation and storage of high-5 assay low-enriched uranium fuels and, as Hossein will explain in the next 6 presentation, we work closely with the Office of Nuclear Regulatory Research 7 on numerous activities.
8 We also regularly meet with our peers in the Department of 9 Energy to share information, data, and knowledge, creating a common 10 understanding of the technical issues impacting safety and allowing us to 11 collaboratively address areas of potential gaps in knowledge. We have 12 several contracts with DOE labs, including one with the Idaho National 13 Laboratory to pilot our fuel qualification guidance on metallic fuel. We are 14 also engaging with industry on their accelerated fuel qualification working 15 group.
16 We've continued our work with the Canadian Nuclear Safety 17 Commission to help ensure the safe development of new and advanced 18 reactor technologies. Incorporating lessons learned from past efforts, we 19 issued two joint reports this year and initialed a project that, when complete, 20 will establish common regulatory positions on the fuel qualification of 21 tristructural isotropic fuel.
22 We are strategically planning our next projects, including 23 five-party interactions with the Canadian regulators, GE-Hitachi, the 24 Tennessee Valley Authority, and Ontario Power Generation to support safe
71 1 and efficient deployment of the BWR X-300 in the U.S. and Canada.
2 In conclusion, the new and advanced reactor programs 3 have made great strides in the past year, and we're grateful for the dedicated 4 staff who are making the safe use of nuclear technology possible by 5 performing licensing reviews, creating the framework for the future, and 6 collaborating with internal and external stakeholders.
7 Next slide, please. I will now turn the presentation over to 8 Hossein Esmaili.
9 MR. ESMAILI: Thank you, Michelle. Chair Hanson and 10 Commissioners, thank you for giving me the opportunity to discuss the Office 11 of Nuclear Regulatory Research activities and safer readiness to support 12 licensing of new and advanced reactors.
13 The Office of Research is fully committed to supporting the 14 agency's efforts to license advanced nuclear technologies. Our staff include 15 many internationally-recognized experts who are engaged in research while 16 monitoring the progress made by the industry through periodic stakeholder 17 engagements.
18 Next slide, please. The mission of our office is to anticipate 19 and conduct research to provide the agency with analysis and information to 20 support resolving technical issues in an efficient and timely manner for risk-21 informed regulatory decision-making. We routinely engage with other offices 22 to understand their needs for efficient, clear, and reliable licensing reviews by 23 providing our expertise in validated methods and tools.
24 Our office has been developing detailed plans to build staff
72 1 expertise and analytical tools for non-LWRs and light water small modular 2 reactors. These plans take into consideration the need for novel technology-3 inclusive approaches given the variety of designs.
4 Our plans identify knowledge gaps, assess their safety and 5 significance, while leveraging and updating existing NRC tools with 6 appropriate investment in resources. We collaborate with stakeholders, 7 including Department of Energy, and international organizations to maintain 8 awareness of the latest advancements. We are leveraging the Nuclear 9 Energy Innovation and Capabilities Act of 2017 and associated memorandum 10 of understanding between NRC and DOE to support our development needs.
11 The Office of Research organizes cooperative international 12 research programs with participation from more than 25 member nations.
13 The objective is the exchange of data and analysis on experimental and 14 analytical research.
15 In the next two slides, I would like to give examples of how 16 the Office of Research successfully executes its strategy. I will highlight how 17 we develop a streamlined plan; how we put that plan into action; and, finally, 18 how we adopt it to conduct an efficient and timely review.
19 Next slide, please. The NRC's a modern risk-informed 20 regulatory using computational tools to identify risk-significant design aspects 21 and resolve potential safety issues. One of our main functions is ensuring 22 the agency is equipped with the necessary tools and up-to-date information 23 for licensing safe operation of new and advanced technologies.
24 I will showcase our state of practice core development
73 1 activities and demonstrate NRC's readiness and its capabilities.
2 To prepare for non-light water reactor licensing reviews, the 3 NRC documented development plans through a series of five reports, as you 4 can see on this slide. These reports identified key phenomena for various 5 designs and the plans for integrating them into our codes. We then followed 6 with developing reference plan models that would represent the main features 7 of the basic designs and the phenomena we expect.
8 We also shared the codes and models with our international 9 partners to leverage their expertise.
10 To show code readiness, we performed simulation with 11 SCALE Neutronics and MELCOR severe accident computer codes. These 12 simulations, the purpose of these simulations is threefold. First is to help 13 NRC staff understand how different systems response and provide insights 14 for regulatory guidance. Second, it's to use those insights to dialogue with 15 stakeholders on NRC's approach. And third is to test the newly-added 16 physics models to identify for safety analysis. These demonstrations also 17 explain how these codes are used to identify system characteristics and 18 uncertainties.
19 We have conducted five public workshops on advanced 20 reactor designs, including a heat pipe reactor and molten salt-cooled reactor, 21 and a gas-cooled reactor in 2021. In 2022, we conducted two additional 22 workshops for a molten salt-fueled reactor and a sodium fast reactor.
23 With regard to materials performance, chemistry, and 24 component integrity, staff has made significant progress in accelerating the
74 1 readiness to review advanced reactors, including collaborative efforts with 2 DOE, Electric Power Research Institute, and international regulators. Key 3 areas of focus include molten salt compatibility with high-temperature 4 materials, graphite performance and qualification, and endorsement of ASME 5 standard codes.
6 The Office of Research is also forward looking. Staff has 7 formed partnerships with research organizations and the international 8 community to continue to develop the expertise, tools, and capabilities to 9 enable future applications of artificial intelligence and digital for new and 10 advanced reactor designs.
11 Next slide, please. So here I want to focus on how NRC 12 can use our tools to support efficient licensing reviews and give examples of 13 our recent accomplishments. So when it comes to light water reactor SMRs, 14 the Office of Research recently completed an analysis of GE-Hitachi BWR X-15 300 containment performance using our tools that included TRACE 16 thermohydraulics and the MELCOR severe accident code. These tools have 17 been validated and used extensively in the licensing reviews of larger LWRs.
18 The extension to smaller design required relatively little effort and provided 19 NRR technical reviews with timely and useful information.
20 In some cases, our tools are also used by the industry. For 21 example, NuScale used the MELCOR code to estimate the source term for its 22 safety analysis report.
23 For advanced reactors, we recently adopted our modeling 24 approach for applications for the review of preliminary safety analysis report
75 1 for Kairos Power's Hermes non-power reactor. The modifications were 2 based on information in the construction permit application.
3 The code readiness strategy and the public workshops 4 facilitated timely performance of the work, and this provided NRR technical 5 reviewers with an understanding of how the reactor operated and informed 6 the development of safety-focused requests for additional information.
7 The NRC staff issued a trial use regulatory guidance in 8 March 2022 that supports applicants using the probabilistic risk assessment 9 standard for advanced non-LWR nuclear power plants. The agency 10 standardized plant risk or SPAR model for the new Vogtle Units 3 and 4 was 11 issued for use in licensing and oversight in early 2022. Work on the SPAR 12 model for NuScale will begin in FY 23 and will support development of the 13 oversight program for new reactors with lower risk profiles than current plants.
14 So NRC has been actively working on developing guidance 15 for a new approach to seismic design that is technology inclusive, risk 16 informed, and performance based. In this alternative approach, the safety 17 margins of individual systems' structures and components are designed 18 according to their contribution to the system level and plant level risk.
19 Enhanced review seemed to potentially unnecessarily conservatisms.
20 So as you can see, the Office of Research has been working 21 hard to anticipate the needs of the regulatory offices through development of 22 analytical tools, staff expertise, and regulatory guidance. When applicants 23 submit applications for a first-of-a-kind reactor design, the NRC will be able to 24 conduct licensing reviews to not only assure public health but to do so in the
76 1 most efficient way possible.
2 This concludes my remarks, and I will turn the presentation 3 over to Darrell Roberts. Thank you.
4 MR. ROBERTS: Thank you. And as you have heard, 5 commissioners, the staff in the new reactor business line are taking the 6 necessary steps to better regulate the nuclear technologies of both today and 7 of the future. We are also working with our domestic and international 8 partners to ensure our independence is not isolated. It's consistent with the 9 Commission's first principle of good regulation.
10 In closing, I would like to thank all the panelists today, staff 11 who supported preparations for this meeting, as well as the staff in both the 12 operating and new reactor business lines. Our success would not be 13 possible without the partnerships between the various offices, as I mentioned 14 before, and their continued efforts in the ever-evolving environment.
15 Thank you again, Chair Hanson and commissioners, for the 16 opportunity to present today, and I welcome your questions.
17 CHAIR HANSON: Thanks, Darrell. Commissioner 18 Caputo.
19 COMMISSIONER CAPUTO: Thank you. Once again, I 20 thank the panelists for coming and speaking today. Brian, Michelle, and 21 Hossein, it's wonderful to see you and thank you for the work that went into 22 your presentation.
23 I think my questions once again are probably largely going 24 to go to Andrea. I'm going to start by quoting the SRM to SECY-89-102,
77 1 Implementation of Safety Goals. The Commission stated, quote, it is 2 important to note that the Commission has made it clear in the Advanced Plant 3 and Severe Accident Policy Statements that it expects the advanced designs 4 will reflect the benefits of significant research and development work and 5 experience gained in operating the many power and development reactors 6 and that vendors will achieve higher standards of severe accident safety 7 performance than their prior designs. However, the NRC will not use the 8 industry's design objectives as a basis to establish new requirements.
9 Since then, the Commission has consistently rejected staff 10 proposals to apply tighter safety standards to advanced reactors than are 11 applied to the existing fleet. It's my understanding that the current version of 12 Part 53 proposes to evaluate severe accidents to a level of five times ten to 13 the minus seven while the existing fleet is evaluated to ten to the minus four.
14 The staff is proposing to require a tougher regulatory 15 standard for advanced reactors contrary to Commission policy. Isn't this the 16 opposite of risk informing?
17 MS. VEIL: I'll start with that's not the intent, and then I'll go 18 to explain why. So Framework A is a top-down approach, and it uses the 19 quantitative health objectives, QHOs, as a performance metric to determine 20 what the safety criteria is for various designs. So this is in lieu of the very 21 prescriptive requirements in Part 50 and 52, and the QHOs are just one 22 aspect. We have dose limits. We also have defense-in-depth, and all of that 23 together will help us make a reasonable assurance determination.
24 So we are using the same QHOs for operating and for new
78 1 reactors. The perceived difference is an artifact, and here's why. For 2 operating reactors, the surrogates are being used for QHOs, and that's the 3 five to the minus four. That's the five to the minus four core damage 4 frequency for individual latent cancer fatality risk. But for new reactors, we're 5 actually using the QHO number or proposing that in Part 53, and that's the five 6 to the minus seven individual prompt fatality risk.
7 So the artifact is because operating reactors are using light 8 water reactors centric surrogates. And, of course a light water reactor 9 surrogate is not going to be technology inclusive for all the various new 10 technologies that we expect to get with Part 53.
11 So it is confusing, and it does look like, you know, we're 12 using two different things, but we are using the same QHOs for both operating 13 reactors and for new reactors proposed in Part 53.
14 COMMISSIONER CAPUTO: I'm going to make an 15 observation here that five times ten to the minus seven is actually stricter, it's 16 actually a tighter risk than the jet propulsion laboratories have estimated for 17 an asteroid impact significant enough to consider, to create a global 18 catastrophe, so I think we need to sort of put that in context.
19 And as for the QHOs, obviously there's been significant 20 discussion about the QHOs, and they aren't currently included in regulation, 21 in regulatory language for the existing fleet. So we're looking at including 22 them in the Part 53 draft.
23 So for operating reactors with baseline risk, QHOs represent 24 an even lower risk where the difference between the two gives us what we call
79 1 the safety margin. But if you take the QHOs and put them into regulatory 2 language, you're now effectively replacing the current standard of what's 3 necessary for adequate protection with the QHOs, which is a tighter standard.
4 I'm kind of struggling with this because we use QHOs as the screening tool to 5 just decide whether or not cost benefit analysis is necessary in a backfit 6 evaluation, and now we're considering using it to redefine adequate 7 protection.
8 So regulating down to the QHOs without considering the 9 relative cost and benefits might be simpler for the staff, but we're redefining 10 adequate protection down to the level of QHOs. I have to say I feel like this 11 represents a failure to recognize or incentivize the leaps in safety that may be 12 presented in advanced reactor designs. I certainly feel like it runs the risk of 13 being counter to the guidance that Congress gave us in the Nuclear Energy 14 Innovation and Modernization Act to have a risk-informed rulemaking 15 framework.
16 So how do you reconcile putting QHOs into Part 53 with the 17 Commission's longstanding policy against tightening regulations for advanced 18 reactors?
19 MS. VEIL: There's a couple of important points here for the 20 QHOs. So as we know, the QHOs are part of the Commission Safety Policy 21 Goal Statement. So we've used QHOs to license Part 52 plants. We've 22 used it as technical basis for reg analysis, and we've used it as a technical 23 basis for Reg Guide 1.174, which is risk-informed decision-making.
24 So the reason why the QHOs are in Framework A, and I'll
80 1 get to Framework B in a minute, is because it is a understood and a robust 2 way to tie making safety determinations, safety categorizations. This was 3 responsive to what industry requested back five, six, seven years ago now.
4 COVID, you know. But this was a long time ago that the industry requested 5 the licensing modernization project. The staff put together Framework A and 6 put together the first iteration of Part 53 based on industry's request.
7 Fast forward to now with the request to, hey, you know, we 8 want options, there's a spectrum that the industry talked about, either PRA in 9 a lead role, PRA in a supporting role, or no PRA. And I would submit the staff 10 has done an incredible job covering that entire spectrum. Framework B has 11 PRA in that traditional support role where QHOs are not a part of the regulation 12 but are in a supporting role. And there's another part of Framework B called 13 ARE. I'm not going to go through with all that stands for, but there is no PRA 14 if an applicant can meet a certain threshold to not have PRA at all.
15 So there is a range. There are applicants, I know there's a 16 very steady sound bite that there are no applicants that are going to use Part 17 53. We hear that a lot, but there are actually indications that people that ask 18 for LMP and want it and then have the basis and have robust PRA are going 19 to use Part 53. Those that don't, there's a full spectrum of ways that an 20 applicant use Part 53 or they could choose to use Part 50 or Part 52.
21 So I really don't agree with the statements that we are not 22 reaching, you know, we're not implementing what Congress gave us. We 23 actually have a spectrum to do just that.
24 COMMISSIONER CAPUTO: Well, I guess I would raise a
81 1 concern about your statement that the industry asked for this because I think 2 there are a lot of contexts where the industry asks for a lot of things. And if 3 they are requesting something that's inconsistent with our priorities and our 4 policies and our practices, I don't think that that really forms a justification for 5 proceeding with it. I think we have to scrutinize that against what we believe 6 the right answer is.
7 So I have to disagree with that. And, you know, to the 8 extent that this is the nature of Part 53 when it comes to the Commission, you 9 know, I will obviously be looking very, very closely at this because, at some 10 point, this Commission will have to defend our decisions in rulemaking space 11 to a Congress that very much expects this to be a risk-informed rule, and there 12 will be a lot of scrutiny on that.
13 I want to have, I'm going to quickly ask one last question.
14 The current draft of Part 53 also incorporates several programs that the 15 existing industry employs but are not currently required or mandated in 16 regulation. By incorporating these programs into the rule, we are, in essence, 17 expecting advanced reactors to address operating lessons learned from the 18 existing industry when the technologies aren't comparable.
19 If these programs aren't mandated in regulation for the 20 existing fleet, why would we incorporate them into rulemaking and create a 21 mandate on advanced reactors?
22 MS. VEIL: So Part 53 is structured in a way to try to 23 balance design requirements and also programmatic controls, and the reason 24 we do that because there isn't operating experience with these new
82 1 technologies. So I'll give a quick example. Say there's a prediction that is 2 made or an assumption that is made for a reactor that's not built yet. There's 3 programmatic information that comes down the line, operational experience 4 that then can be used to go back and validate those predictions.
5 So having that balance of operational programs and design 6 controls can actually help address some of the uncertainties that we've heard 7 about in some of the stakeholder comments. These aren't built yet, what 8 about all the uncertainties involved with what you're assuming.
9 So we are trying to strike a balance, so there are programs 10 in Part 53 that are new, but there are also programs that are in Part 50 and 52 11 that aren't in Part 53. And there's also another sound bite about the length of 12 Part 53. It's actually 50 percent, if you take each framework on its own, it's 13 50 percent less than the existing regulations. So we are trying to strike that 14 balance, but we need to have information to then kind of deal with some of the 15 uncertainties that can come with not having operating experience.
16 COMMISSIONER CAPUTO: If the Chairman will indulge 17 me, I'd like to ask one quick follow-up. So why is it the programs belong in 18 rulemaking language and not in guidance, and don't you run the risk then that 19 every time a program is modified you're going to have to have some sort of 20 adjustment to the rulemaking?
21 MS. VEIL: Well, one of the things that we were mandated 22 was to have a predictable rule. If we had a rule that was so high level and 23 had a lot in guidance, in particular expensive and very impactful programs, 24 that wouldn't provide the predictability that, as you know, there's a variety of
83 1 applicants that are out there.
2 So we're trying to have that level of stability and reliability in 3 the regulations, and we're writing Part 53 in such a way that we're trying to 4 explain why we're putting it in there, but, of course, we're providing the 5 Commission with the information to make a policy decision.
6 COMMISSIONER CAPUTO: Thank you, Mr. Chairman.
7 CHAIR HANSON: Thank you, Commissioner Caputo.
8 Commissioner Crowell.
9 COMMISSIONER CROWELL: Thank you, Mr. Chairman.
10 Before I dive in on new reactors, Andrea, in the last round, I had asked you a 11 question about NEPA requirements related to subsequent license renewals, 12 and I just wanted to give you an opportunity to clarify on that, if needed.
13 MS. VEIL: Thank you. So the brain trust has alerted me 14 that I misspoke, and what I want to do is make sure I get the right information 15 on Category 2, the question you asked earlier for license renewal. So what I 16 will propose -- and Brooke doesn't know this yet either. I talked to Marian 17 about it on the break. I will propose that we get a briefing where the brain 18 trust can give the specific information and then also correct the transcript or 19 however we need. You'll figure it out, but I want to make sure I'm giving 20 accurate information. So we'll make all of the Commission offices have the 21 information about what Category 2 entails and what we're doing going forward.
22 Thank you.
23 COMMISSIONER CROWELL: Okay. I wanted to make 24 sure that everyone knows that we're going to clarify that going forward. I'm
84 1 going to take things back up to the 10,000-foot level here for my benefit and, 2 hopefully for others, as well. I don't know which one of you wants to take this 3 question, but what's the difference between an advanced reactor and a new 4 reactor and why is that distinction irrelevant from a regulatory perspective?
5 MS. VEIL: That's a very, very good question. So we 6 actually have two different divisions even dealing with it. So when I think new 7 reactors, I think of NuScale because it is not so dissimilar from current light 8 water reactors. There was a lot of inherent passive safety features, but it's 9 not so different that we're actually looking at whole new paradigms of how 10 we're going to review it.
11 When I think of advanced reactors, I think of some these like 12 single-digit megawatt type reactors that are completely different. It may not 13 even have water coolant. You know, molten salt reactors, some are 14 proposing mobile reactors. Some are, you know, things that could be 15 refueled in a factory.
16 So it's kind of two very different ways of looking at new 17 technologies that are entering into the framework.
18 COMMISSIONER CROWELL: And so how does that 19 change our regulatory approach to the two different new versus advanced?
20 MS. VEIL: It could. I'll give you an example. For some 21 of the proposals that are coming, for example, for mobile reactors. We 22 haven't done manufacturing license in, I think, maybe one or something in, 23 you know, I've been here a long time and I can say how long. But I think 24 there's only been one manufacturing license that I can think of.
85 1 So it brings in policy issues. There could actually be policy 2 issues surrounding criticality, when do you, you know, look at criticality? In a 3 factory? There could be, there are reactors that are talking about refueling 4 and then replacing. What does that mean for an inspection, tests, analysis, 5 and acceptance criteria? Do you do it for every single one?
6 So there are some different ways of approaching it and 7 some that will be policy issues that we will need to bring to the Commission 8 that may not be, you know, kind of consistent with the way we've regulated 9 before.
10 COMMISSIONER CROWELL: And so along those lines, 11 does the current process under Parts 50 and 52 help inform those issues, 12 particularly in the context of trying to put together a Part 53 rule?
13 MS. VEIL: We are actually trying to do that right now. So 14 there's some inconsistencies between Part 52 and Part 50. We learned 15 lessons from NuScale and other reviews that we've done. We have approved 16 other -- just because they haven't been built doesn't mean we haven't 17 approved them. We've approved other, you know, new and advanced 18 reactor designs. So we've learned from all of those activities, so we have 19 before the Commission the Part 50-52 rule to try to, you know, kind of 20 consistently address that.
21 So we've looked at issues, for example, when is the best 22 time to revise a design certification, what are implications to standardization?
23 What about TMI lessons learned? What about severe accident, kind of 24 handling of severe accidents.
86 1 So we're using all those lessons, so no matter what 2 framework is picked by a licensee, we can make a reasonable assurance of 3 adequate protection determination, regardless of it's Part 50, 52, or 53. So 4 we're trying to have that common thread throughout all the frameworks so that 5 we are set up for whatever an applicant would pick.
6 COMMISSIONER CROWELL: Yes, easier said then done, 7 and I applaud you and your staff's efforts to do this because it' s not easy. I 8 mean, regulating advanced reactors under Part 50 and 52, which is largely by 9 exemption, is far from ideal. But putting together the Holy Grail of Part 53 is 10 no easy task either, and, given limited resources and bandwidth to do all of 11 those things simultaneously, I just hope we're being, one process is informing 12 the other as much as possible and we're using our resources wisely. So I 13 appreciate that.
14 So on, I guess, advanced -- well, I don't know if this falls 15 under the advanced or new reactor category, but, for an advanced reactor, 16 whether it's using light water technology or not, if that reactor is paired with 17 energy storage capabilities, what regulatory challenges or hurdles does that 18 pose and how are we thinking about those types of designs?
19 MS. VEIL: So we focus on the safety determination, so we 20 would approach it the same way. Whatever business decisions are, you 21 know, taken by the applicant, whether they're using the reactor for process 22 heat. Whether they're using it as backup batteries, we approach it the same 23 way. We use the same safety criteria. There may be new technologies that 24 we need to learn about, and we've been very fortunate to get information early,
87 1 and there may be kind of new things we need to learn about. But we 2 approach it the same way, but the outcomes could be different. Whatever 3 the outcome is, and, again, processing or whatever, is down the line with a 4 business decision, but we're regulating the actual, you know, whatever the 5 entity is and the safety determination for that entity.
6 COMMISSIONER CROWELL: I know there's some 7 regulatory jurisdictional lines here, as well but, you know, there's been storage 8 projects paired with renewable energy projects in the past, particularly using 9 molten salt, that haven't performed well. And if we're going to use those 10 storage technologies in association with nuclear power, are you making sure 11 we're aware of those pitfalls, identifying them early, and that one is not going 12 to undermine the other when trying to do nuclear paired with storage. It's just 13 something to keep in mind as we move forward. And maybe that's a research 14 question as much as anything else, but I appreciate that and we'll talk more.
15 Thanks.
16 CHAIR HANSON: Thank you, Commissioner Crowell. A 17 couple of things here before we dive in. Brian, I just, you know, wanted to 18 give a shout out to you and the rest of the folks down in Region II and who 19 have been on the ground at Vogtle and the substantial work and expertise that 20 you all have brought to bear on that project, processing ITAACs, you know. I 21 think a lot folks thought that we would be the one pulling the tent on closing 22 ITAACs, and we weren't. And it's remarkable, and it's a significant 23 achievement. I think across the industry, certainly for the licensee, but also 24 here in -- I know we'll have some opportunities to celebrate that.
88 1 But I have to say, just from my standpoint, I had the 2 opportunity twice in the last six months to bring international visitors down to 3 Vogtle. It was a real point of pride to introduce them to you and the rest of 4 the team down there in Region II and kind of show off, you know, partly from 5 a Team USA standpoint but particularly from a team NRC standpoint, the way 6 we've approached this and the significant accomplishment it represents.
7 So I just wanted to thank you all again publicly for your work 8 in that area.
9 Michelle, I think I'll turn to you next. You know, I think it 10 may have been Andrea in her presentation who brought up the TICAP, the 11 Technology Inclusive Content of Application, and then the RCAP, the 12 Advanced Reactor Content of Application for, you know, advanced rector 13 applicants.
14 But given that we've got some light water reactor 15 technologies that are coming down the pipe, as well, on this, has there been 16 any given thought, and maybe this a question for Andrea too, but has there 17 been any thought given for kind of comparable guidance for light-water SMRs 18 that considers their safety significance or the significance of some of their 19 design features in developing license applications.
20 MS. HAYES: I have not been involved those 21 conversations. I could take a guess.
22 CHAIR HANSON: Okay. Okay, all right. Well, I'm sorry.
23 Let me pivot then and --
24 MS. VEIL: It makes sense. Just come on back over here.
89 1 There is lots of guidance that is either in place, in process, or in the near future, 2 and all of the above. So we are constantly trying to put guidance out, where 3 they were talking about SMRs, advanced rectors, Part 53.
4 So a lot of what we learn is from our international partners 5 with Brian Smith. He was here, but Brian Smith and before him, Anna 6 Bradford, the SMR regulators forum. So we get a lot of products out of that.
7 We have a lot of input to that. But, yes, there's no shortage of guidance on 8 all the aspects of new and advanced reactors that we're moving forward on.
9 CHAIR HANSON: Okay. Thank you. Hossein, I had a 10 question for you. You know, that I've got a strong interest in kind of, I don't 11 know, working all the angles, beating all the bushes, if you will, to kind of 12 develop data for both the operating fleet and the advanced reactors, new 13 reactors, to kind of fill, you know, kind of key technical information gaps. And 14 I think the Office of Research has really done an admirable job in a lot of ways.
15 I think, you know, FIDES and now FIDES2 are both really good examples of 16 kind of international cooperation where everybody is working together to utilize 17 facilities around the world to fill these gaps and to perform the confirmatory 18 analysis that we need to perform.
19 And I guess one of the questions I've been interested in 20 lately, and, you know, I had the opportunity, I went to Oak Ridge in June and 21 I was at Idaho National Lab in July, and I've had the opportunity to go to a few 22 universities this year so really feel like I've gotten exposed to how the labs 23 and universities are helping with codes and standards and other kinds of 24 efforts.
90 1 But I'm wondering what you might think or some feedback 2 on the idea of leveraging personnel exchanges with the national labs and 3 universities and/or international research organizations where, you know, we 4 send somebody there, they send somebody here, and, you know, we kind of 5 foster -- we have personnel exchanges oftentimes on the regulatory side.
6 We've done this on the ROP with places like Japan and so forth. But, you 7 know, what about it on the research side?
8 MR. ESMAILI: Thank you for the question. So the short 9 answer is yes. Personnel exchanges are very important for us. They're 10 extremely useful and beneficial for us. We have done in them in the past and 11 we continue to do more right now.
12 I know firsthand because, when I was the analyst, I worked 13 with some of the exchanges, you know, both international and domestic. And 14 so I know firsthand that it is very important. It's good for us, and it's good for 15 them, you know, because we do collaborate. Even after they leave, we start 16 collaborating with them, and so you get a lot of technical exchanges between.
17 So we have done exchanges with the national labs before.
18 We are in the process of actually doing two more from national labs to come 19 in and, you know, they're going to help us with some of these advanced 20 nuclear technologies, you know, fuel modeling, ATF, et cetera. And we also 21 had international foreign assignees. You know, the Office of Research, you 22 know, we had foreign assignees who would come for a year or so, you know, 23 like from Japanese, NRA. And right now I think we have a few of them right 24 in the Office of Research.
91 1 So, yes, it helps us a lot.
2 CHAIR HANSON: Okay. Good. Yeah, thank you. No, 3 that's very, very helpful. Thanks.
4 Andrea, just turning back to you here at the end, you 5 mentioned the significant interest in pre-application activities, right? You 6 said, you know, 22 topical reports and 20-plus white papers. You know, we 7 may have as many as 70 topical reports and white papers, and I guess my 8 question is kind of, I'm really glad. You know, I did a panel on the pre-9 application process and pre-application interactions at the RIC, so I really do 10 think these things are important for both us and for prospective licensees.
11 But I'm kind of wondering about staff capacity and how, if 12 necessary, one might go about kind of prioritizing those or, you know, 13 whatever. How do we decide what to work on first?
14 MS. VEIL: Yes. So we do prioritize them. And, of 15 course, this is all budgeted work that's come in and it's real, right? This is 16 not, you know, kind of theoretical type designs that are coming in.
17 So we definitely prioritize. We also have core teams, and 18 those core teams are the ones that are like head down, working on these 19 topical reports, these white papers, what have you. They're supplemented by 20 our wonderful technical SMEs, subject matter experts, our wonderful legal 21 experts that helps us. So we reach out when needed, but we're not trying to 22 tie down resources that we don't need.
23 So the core team, including the project managers, really run 24 these activities, and we give them that autonomy to do that, but it is a
92 1 challenge, obviously, which is why we're so focused on hiring and also 2 focused on -- we do have an add/shed process in this organization. It's very 3 tough for us, as you know, the NRC, to shed work. But we figure out those 4 things that can wait, either delay or shed, to make sure that we're focusing on 5 the most important, most impactful, most safety significant issues that we work 6 on. But we absolutely prioritize, and we have a wonderful workload 7 management tool. We meet, I think it's very month. I always have a conflict, 8 so I'm not there a lot. But my deputies are, and I look at all the information, 9 so we do prioritize.
10 CHAIR HANSON: I know. I appreciate that. But is that 11 part of the communication then with the folks who were sending in topical 12 reports or white papers?
13 MS. VEIL: Yes.
14 CHAIR HANSON: Did they kind of understand where they 15 are in the queue and --
16 MS. VEIL: Absolutely. Yes, no, it has to be, it has to be.
17 CHAIR HANSON: Okay, all right. I applaud the core team 18 approach. I know that was one of the big lessons learned from NuScale, you 19 know, core team with matrix support I think is important.
20 So with that, thank you very much. Commissioner Wright.
21 COMMISSIONER WRIGHT: Thank you, Mr. Chairman.
22 Well, again, to this panel, thank you for your presentations. I mean, it's 23 obvious that you spent a lot of time preparing and the information is very good, 24 well received.
93 1 Andrea, I'll just tell you, this is an ever-changing business 2 line and the things that are going on are of ridiculous importance to this 3 agency. I mean, I could compare it years ago to the telecommunication 4 agency because when you were trying to get things adopted and even, I 5 guess, in our business now, the hardware that we're trying to get it installed, 6 it changes before you get it installed, you know. Something new is already 7 down the pike.
8 So, I mean, this totally evolving thing is something that I 9 know it's hard to manage, Darrell. I know you all are trying to be on top of it 10 and doing the best that you can, and I recognize that, right?
11 Brian, I don't have a question for you, but I want to, I'm going 12 to pay you back and speak on top of what the Chairman said. I've been down 13 there two or three times here in the last year, and, you know, publicly, I want 14 to tell you and you can share with everybody back at Vogtle. From top to 15 bottom, the professionalism, the passion, and your attention to detail and to 16 safety is, you know, noticed and we're very thankful for what you do. And 17 that goes from Laura all the way down, so please pass that forward.
18 MR. KEMKER: Thank you, Commissioner and Chairman.
19 I will.
20 COMMISSIONER WRIGHT: Okay. Thank you. And I'm 21 going to piggyback on the Chairman's question that he just had, Andrea.
22 And, Michelle, this is probably, again, I was going to come to you, too, but 23 obviously you hadn't done that like maybe we thought.
24 So, you know, you spoke to -- and I guess I'm going to look,
94 1 focus, a little bit under 50-52, as well, right? You know, you highlighted the 2 importance of pre-application engagements, the 22 topical reports, the 20 3 white papers, maybe another 70 on the way. Michelle, you even mentioned, 4 I think, the example of a successful pre-application thing with Abilene 5 Christian, right?
6 So you've highlighted how effective engagement can be and 7 how it can result in successful technical, safety, and environmental reviews, 8 you know, as we've seen with Kairos, right? But I was wondering if you could 9 speak a bit to the spectrum of pre-application activities and strategies you've 10 observed that help maximize the usefulness of these important engagements.
11 For example, with early movers that are using Part 50 and 52, the importance 12 of establishing regulatory applicability up-front is likely a key aspect, I would 13 assume. And I was wondering if you could speak to any later-term process 14 innovation efforts, such as streamlining management, legal, or maybe even 15 ACRS reviews.
16 MS. VEIL: Yes. I'm just kidding. So we have a lot of 17 strategies that we use. One, and this is a down-the-line strategy, is virtual 18 audits. And, of course, I need to say, you know, pre-application activities are 19 voluntary. We highly encourage it. We can't mandate it, they're voluntary.
20 But we even have a subset of that called a readiness review, and some 21 applicants have taken advantage of that to see if there are any fatal flaws 22 before they even come in for pre-app. So that's been helpful.
23 But down the line, the virtual audits. For example, with 24 Kairos, getting our vendor inspectors kind of embedded in these virtual audits
95 1 and making sure before there is an in-person audit that these virtual ones have 2 occurred so you can resolve some issues that way. The core team, of 3 course, I can't say enough about having a core team.
4 And we have streamlined all across the board. If you look 5 at the Kairos schedule, I think Kairos might have requested 18 months, and 6 we have 21. Pretty close. That includes ACRS, that includes OGC, that 7 includes all our partners that we need, the village that it takes to get one of 8 these applications done.
9 We have a very agile staff. Even though it's matrixed for 10 subject matter experts, sometimes we have to reach out to more people than 11 we intended because, as you review, more issues come up. We are focused 12 on the most safety-significant aspects. This isn't bring me a rock or curiosity 13 questions. But this is tough, you know. It's new, so sometimes we have to 14 expand the team a bit. But all of those strategies have helped us, and we 15 continue to learn each one we do. So the first of a kind may be a little tougher 16 than the nth because we're learning as we're doing them.
17 COMMISSIONER WRIGHT: Yes. Thank you for that.
18 I'm going to stay with you for a minute. Michelle, do you have anything to add 19 to that at all?
20 MS. HAYES: I was just going to, like, back to the pre-21 application engagements, we've seen a wide range of engagements, and 22 we've made them all successful. Just that they want to come in, we do have 23 a white paper, you know, encouraging the topics. Regulatory analysis is a 24 big one, and, you know, we've issued a white paper on that, as well.
96 1 COMMISSIONER WRIGHT: Okay.
2 MS. HAYES: PDC is another big one that we've gotten 3 some of those in, and it's important to lay those out early because everything 4 that comes in after it is going to follow on that.
5 COMMISSIONER WRIGHT: Thank you. So, Andrea, the 6 staff's efforts to develop a new technology inclusive, risk-informed, and 7 performance-based regulatory framework has been mentioned several times, 8 right, during this panel. And while not the focus of today's meeting per se, I 9 wanted to raise a couple of questions on Part 53.
10 Since, as you noted, the staff recently issued a draft 11 preliminary proposed rule package to support the ACRS meetings and 12 received substantial stakeholder feedback following the recent public 13 comment period for the proposed rule language, some stakeholders are 14 concerned that the current approach of having two frameworks in Part 53 has 15 resulted in a rather cumbersome rule that may not be used by future 16 applicants, and being usable and used is one of the key things, right? And, 17 accordingly, some stakeholders have expressed that Part 53 is rather large 18 and should be streamlined.
19 So what's the staff's perspective on that, and could you 20 provide examples where the staff streamlined traditional requirements and 21 moved details into guidance? And then, additionally, how have you 22 addressed directly the feedback and shared these examples with those 23 concerned stakeholders?
24 MS. VEIL: Okay. So I'll start with the frameworks. So
97 1 Framework A, PRA is the central star. Framework B, it's not, it's supporting, 2 and then there's no PRA option.
3 In order to make that easier, I'm kind of going to flip around 4 what you said. They are self-contained. Instead of trying to do a crosswalk 5 across either current regulations or both frameworks, someone can take 6 Framework A and use it, someone can take Framework B and use it. That's 7 the length. To put them together and say that the rule is a lot bigger than 8 existing, it's not the right framework to think about it because, as I said earlier, 9 they're actually 50-percent less in and of themselves than current regulations.
10 So some examples of where we put things in guidance. In 11 Framework B, we put fire protection in guidance. We put principle design 12 criteria in guidance. We put codes and standard, in particular 50.55(a) in 13 guidance. We've taken comments that we've gotten about, hey, there's 14 quality assurance all over this rule. We streamlined that and put it all in one 15 place.
16 The whole Framework B was stakeholder comments.
17 When Part 53 started, it was just PRA centric. There was no Framework A, 18 it was just Part 53. Framework B and the other, you know, more deterministic 19 process, is all stakeholder feedback. And the way that we're -- this is like a 20 big five which, you know, I won't go over. But the way that we're developing 21 this rule to get to you all is here are the things that are really we've gotten the 22 most feedback on, here are some of the reasons why the staff supports this, 23 and it's also important to say that the preliminary rule language when it comes 24 to quantitative health objectives actually says or a surrogate proposed by the
98 1 applicant. It doesn't say that the QHO is it. It says this is what we are using 2 to adhere to the Commission Safety Policy Goal Statement because it's robust 3 and we've used it through the years.
4 So we're trying to make it as a transparent as possible. So 5 I understand, it's a large document. I've been through it a couple of times.
6 It's a large document. No argument there. But when you look at how it's 7 constructed, it is standalone frameworks and some of that language is 8 repeated to make it standalone, so that's where some of the criticism about 9 it's very large comes from.
10 COMMISSIONER WRIGHT: Indulge me one-half second.
11 So that really doesn't get to what I consider to be really something that's like 12 an elephant in the room here. You're getting comments from stakeholders 13 that it's too cumbersome it's too big, it's not going to be used. They continue 14 to say that, and I guess I'm trying to figure out why are they continuing to say 15 that and what are we doing in order to address that and to kind of understand 16 and remove that, right? So that's what I'm trying to get to, and I think that 17 was something that Commissioner Caputo was kind of referring to, as well.
18 MS. VEIL: So we have addressed some of those 19 comments. We have put some things in guidance. We have taken 20 comments and removed some items. We've tried to make it as streamlined 21 as possible. But just like you said earlier, there are policy decisions in Part 22 53. If we took stakeholder comments and took out everything that 23 stakeholders, some stakeholder comments said before we provided to you, 24 then we really are taking away your policy decisions.
99 1 So what we're trying to do is one stakeholder says we don't 2 like QHOs, ALARA, or defense-in-depth. Another stakeholder says, well, you 3 need to have those in there to have a robust rule, these are paper reactors 4 that aren't built yet. We are trying to have a balanced approach that we 5 provide to you with the reasons why we think this is the right approach to make 6 it as expeditious and as transparent as possible for you to make your policy 7 decisions.
8 COMMISSIONER WRIGHT: And I know you all have 9 stakeholder meetings, and I know that you all, there have been presentations 10 and stuff like that. But before it comes up to us, you know, I would hope that 11 you will do, because you cannot, again, this is something you cannot over-12 communicate with. So try to understand as much was you can before it 13 comes up to us. You know, that's what we would hope, so thank you for 14 listening.
15 CHAIR HANSON: Okay. Thank you all. Thank you to 16 both panels and to the staff and to your continued professionalism and 17 dedication to the mission. Obviously, the issues we have in front of us are 18 difficult ones. I think we look at a lot of things in this agency and, you know, 19 people will say to us, well, why haven't you done it already, and we'll say, well, 20 look, if it was easy, we would have. And so the substance and the tenor of 21 the discussion today I think reflects that, and I want to thank you all very much 22 for your service. Thanks to my colleagues for your questions and the 23 discussion today, as well. And with that, we are adjourned.
24 (Whereupon, the above-entitled matter went off the record
100 1 at 11:48 a.m.)