ML23258A181
| ML23258A181 | |
| Person / Time | |
|---|---|
| Issue date: | 11/09/2023 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| RIN 3150-AL00, NRC-2023-0071, NRC-006, NRC-2585 | |
| Download: ML23258A181 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
PROPOSED RULE: REGULATORY FRAMEWORK FOR FUSION SYSTEMS Docket Number: N/A Location: teleconference Date: 11-09-2023 Work Order No.: NRC-2585 Pages 1-83 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 1 U.S. NUCLEAR REGULATORY COMMISSION 2 + + + + +
3 PUBLIC MEETING 4 + + + + +
5 PROPOSED RULE: REGULATORY FRAMEWORK FOR 6 FUSION SYSTEMS 7 + + + + +
8 THURSDAY 9 NOVEMBER 9, 2023 10 + + + + +
11 12 The public meeting met via Video-13 Teleconference, at 1:00 p.m. EST, Dennis Andrukat, 14 Facilitator, presiding.
15 16 PRESENT 17 DENNIS ANDRUKAT, NMSS, Facilitator 18 ALLYCE BOLGER, NMSS 19 ADELAIDE GIANTELLI, NMSS 20 CHRISTIANNE RIDGE, NMSS 21 CINDY ROSALES-COOPER, NSIR 22 DIEGO SAENZ, State of Wisconsin 23 TODD SMITH, NSIR 24 DUANE WHITE, NMSS 25 DUNCAN WHITE, NMSS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 PUBLIC PARTICIPANTS 2 AUGGIE ONG 3 DON GREGOIRE 4 ANDREW HOLLAND 5 MATTHEW LIPKA 6 MIKE O'NEILL 7 ANDREW PROFFITT 8 PATRICK WHITE 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 1 CONTENTS 2
3 Call to order, welcome, logistics, and 4 opening remarks.. . . . . . . . . . . . . . . . . 3 5
6 Specific topics related to preliminary 7 proposed fusion system rule.. . . . . . . . . . . 9 8
9 Material Security.. . . . . . . . . . . . . . . 10 10 11 Emergency Preparedness. . . . . . . . . . . . . 20 12 13 Waste Management. . . . . . . . . . . . . . . . 25 14 15 Facilities and Equipment. . . . . . . . . . . . 36 16 17 Overall Occupational Dose Program.. . . . . . . 40 18 19 Question and Answer Session.. . . . . . . . . . . 45 20 21 Closing remarks.. . . . . . . . . . . . . . . . . 83 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 P-R-O-C-E-E-D-I-N-G-S 2 1:02 p.m.
3 MR. ANDRUKAT: So, good afternoon. I want 4 to welcome everyone and thank you for participating in 5 today's public meeting. This is the third public 6 meeting in a series of three to discuss the NRC's 7 rulemaking to develop a regulatory framework for 8 fusion systems.
9 Please note that this particular public 10 meeting, this third one, will have a transcript. We 11 ask that, for this meeting, that whenever you are 12 called upon to speak, please say your name and your 13 affiliation.
14 Please also note that the chat window is 15 not disabled. However, any questions/comments that 16 are placed into the comment window will be read aloud, 17 whether that's by myself or I will call on that 18 individual to read their question. That is for the 19 purpose of the transcript.
20 Okay. So my name is Dennis Andrukat. I'm 21 from the NRC's Office of Nuclear Material Safeguards 22 and Security. I am the rulemaking project manager for 23 this rulemaking, as well as serving as the facilitator 24 for today.
25 This is an information meeting with a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 1 question-and-answer feedback session which will occur 2 at the end of today's meeting. This type of meeting 3 is for the NRC staff to meet directly with individuals 4 to discuss regulatory and technical issues. Attendees 5 will have an opportunity to ask questions and provide 6 feedback to the staff about the topics discussed 7 today.
8 Please note, for today's public meeting, 9 the NRC is not actively soliciting comments towards 10 regulatory decisions or the subject rulemaking. No 11 formal responses from the NRC will be issued for any 12 questions, comments, or feedback received during 13 today's public meeting.
14 Again, the purpose of today's meeting is 15 to share with the public a more in-depth discussion of 16 certain specific topics regarding the staff's current 17 progress on the development of this proposed rule.
18 Specifically, the topics for today will include 19 security; more specifically, material security, as 20 well as emergency preparedness, waste management 21 facilities and equipment, and tritium bioassay. We 22 will also be using this meeting to hear feedback from 23 our various stakeholders.
24 Okay. Moving on to the agenda slide, as 25 such, you can see in the agenda it's broken into two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 1 main parts. The first part will be the presentation 2 from the staff, as well as a second portion for a 3 question-and-answer feedback session.
4 The agenda does show a break in between 5 these two sessions. However, the staff is open to 6 adjusting the timing of the break. So when we get to 7 that point, we will decide if we will take a break at 8 that time or if we shall continue on.
9 As noted on this slide, these times are 10 estimated, and depending on the participation level, 11 the meeting could adjourn earlier than scheduled. If 12 anyone has concerns with a potential early meeting 13 adjournment, please let me know.
14 Today, we'll have several presenters 15 covering several topics, as mentioned before. We will 16 have Duncan White from the NRC's Office of Nuclear 17 Material Safety and Safeguards, as well as Duane White 18 from the NRC's Office of Nuclear Security and Incident 19 Response; Cindy Rosales-Cooper from the NRC's Office 20 of Nuclear Security and Incident Response as well. We 21 have Dr. Christianne Ridge from the Office of Nuclear 22 Material Safety and Safeguards, and finally, we will 23 be having a representative from one of our Agreement 24 States coming from the State of Wisconsin, Diego 25 Saenz.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 1 We are using Microsoft Teams for this 2 public meeting. To minimize distractions during the 3 meeting, we ask everyone to please mute themselves 4 when they are not speaking and to do our best to not 5 speak over each other. And to help facilitate the 6 discussion session during the end of the meeting, we 7 request that you utilize the Raise Hand feature in 8 Teams, so that we can identify who would like to speak 9 next. The staff will, then, call on the individuals 10 when it is their turn to present their question or 11 comment. For those not familiar, the Raise Hand 12 button is the hand-shape at the top of the Teams 13 display area.
14 Now, let's see. For those individuals 15 that are joining via a bridge-line telephone line and 16 would like to ask a question or provide a comment, 17 please remember it is *6 to unmute and mute yourself.
18 So you would hit *6 to unmute yourself to ask or 19 present your question/comment. And when you are done, 20 we do ask that you mute yourself again by using *6.
21 And I will be reminding everyone later on 22 as well, but we are transcribing this particular 23 meeting. So it is very important that everyone 24 introduce themselves and their affiliation.
25 In the chat window here, I will be pasting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 1 in the information on the public meeting slides for 2 today, the presentation for today. And for those on 3 the phone, the ML number is ML23258A, as in alpha, 4 180. And pretty shortly here, I will be pasting that 5 information in the chat.
6 And before we begin with the presentation, 7 we would like to have Adelaide Giantelli offer up some 8 opening remarks. So Adelaide hails from the Division 9 of Materials Safety, Security, State, and Tribal 10 Programs that is in the Office of Nuclear Material.
11 MS. GIANTELLI: Thank you, Dennis. Hi, 12 everyone. As Dennis said, my name is Adelaide 13 Giantelli, and I am the Branch Chief for the State 14 Agreement and Liaison Programs Branch. And this is 15 the branch at NRC that's leading the regulatory effort 16 for fusion systems.
17 I'd like to welcome and thank you all for 18 your interest in fusion systems, in this fusions 19 systems rulemaking, and taking the time to participate 20 in this meeting.
21 It's a very exciting time to be able to 22 lay the groundwork for the country's up-and-coming 23 fusion system technology. And NRC is fully engaged to 24 working with our stakeholders and producing a quality, 25 usable rule for everyone.
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9 1 With that, NRC welcomes and encourages 2 stakeholder feedback, as staff works to develop this 3 rule and the associated guidance with it. We want to 4 hear from everyone, all stakeholders. Whether someone 5 is asking for clarifications; making suggestions to 6 what the rule should say or accomplish; providing 7 insights; pointing out potential issues and concerns, 8 we welcome it all. This is really an opportune time 9 for everybody to give us their thoughts on this.
10 Today's meeting is the third in a series 11 of three public meetings. We chose to break up the 12 meetings in order to have these focused discussions 13 and allow additional time for everyone to be involved 14 and to allow stakeholders to have a say here.
15 So as Dennis mentioned, today's meeting, 16 we're focusing on the topics of material security, 17 emergency preparedness, waste management, facilities 18 equipment, and tritium bioassay.
19 So thank you, everyone, and I'm looking 20 forward to hearing a great discussion on this topic.
21 And back to you, Dennis.
22 MR. ANDRUKAT: Okay. And it looks like, 23 apparently, I have two mute buttons that I have to 24 unmute. Okay.
25 So, many thanks, Adelaide. I appreciate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 1 that. Now, with that, we will now begin with today's 2 presentation.
3 For your convenience, we are using the 4 PowerPoint Live feature. This will allow you to 5 scroll up and down throughout the presentation 6 independent of the presenter.
7 And with that, I will turn it over to our 8 first presenter, Mr. Duncan White. Duncan?
9 MR. DUNCAN WHITE: Yes, thank you, Dennis.
10 Again, I'm Duncan White. I'm in the 11 Office of Nuclear Material Safety and Safeguards, the 12 technical lead for this rulemaking.
13 If we could go to the next slide? And as 14 Adelaide and Dennis just said, this is our third 15 meeting to talk about our development of the 16 regulatory language and the guidance. And if you 17 recall, back in October, we had a session to talk 18 about our proposed draft language for the rulemaking.
19 And last week, we talked about what was 20 going to be in the guidance. We talked somewhat about 21 how we do guidance in Part 30, and we also talked 22 about the outline and type of things that we'll be 23 covering in it. And we started to cover a little bit 24 of some of the particular areas.
25 And as just said, today we're going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 dive into five areas deeper and we're going to have 2 each subject matter expert to talk about that.
3 And if you go to the next slide, again, 4 you can see today's presentation, the ML number, how 5 to reach that, and for previous ones, if you want to 6 go back and look at what we previously talked about, 7 you're welcome to do that.
8 So with that, let's go to today's agenda.
9 And Dennis and Adelaide went through these topics 10 already. So why don't we just jump right into it.
11 The first topic is material security, and 12 Duane White from the Office of Nuclear Security and 13 Incident Response will be discussing this.
14 So, Duane, the floor is yours.
15 MR. DUANE WHITE: Okay. Thank you, 16 Duncan. Yes, as mentioned, my name is Duane White.
17 I am a Security Specialist in the Material Security 18 Branch of the Division of Physical and Cyber Security 19 under NRC's Office of Nuclear Security and Incident 20 Response.
21 Next slide, please. Based on the 22 information we have received regarding the near-term 23 fusion system designs, the NRC has determined at this 24 time that our current security requirements in 10 CFR 25 Part 20 and 10 CFR Part 37 are adequate for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 1 byproduct materials that may be produced, used, or 2 stored as part of the near-term fusion system 3 activities.
4 Under 10 CFR Part 20, we have security 5 requirements, and under 10 CFR 20.1801 and 6 10 CFR 20.1802, they require licensees to secure 7 radioactive materials from unauthorized removal or 8 access while in storage in controlled and unrestricted 9 areas, and to control and maintain constant 10 surveillance over licensed material that is in a 11 controlled or unrestricted area and not in storage.
12 Also, in accordance with our 10 CFR Part 13 37, licensees that possess aggregated quantities of 14 Category 1 and 2 radioactive material must establish, 15 implement, and maintain access -- or access 16 authorization programs.
17 Let me start over. Also, in accordance 18 with 10 CFR Part 37, licensees that possess aggregated 19 Category 1 and 2 quantities of radioactive material 20 must establish, implement, and maintain an access 21 authorization program and any security program to 22 ensure physical protection of the radioactive 23 material.
24 Table 1 of Appendix A of 10 CFR Part 37 25 lists the Category 1 and Category 2 threshold NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 1 quantities of radioactive material. The applicant 2 should refer to this table to determine whether its 3 proposed activities would be subject to the 4 10 CFR Part 37 requirements.
5 Next slide. The NRC will only grant a 6 license upon a determination that the application 7 meets the requirements of the Atomic Energy Act, which 8 includes protection of the public health and safety 9 and promotion of the common defense and security.
10 If the NRC receives an application for a 11 license that includes safety and security elements 12 that were not anticipated, such as the protection of 13 a new activated product that was not considered in our 14 requirements, the existing regulations under 10 CFR 15 Part 30 do provide the NRC adequate authority to 16 impose requirements to carry out that responsibility 17 on a case-by-case basis.
18 I would like to note that we encourage 19 applicants to engage in pre-application discussions 20 with the regulator -- and that's the NRC or Agreement 21 State -- if they expect their application will contain 22 new elements or activated products. And if additional 23 requirements are necessary, based on the new 24 information, we would issue, or we can issue on a 25 case-by-case basis, license conditions or orders.
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14 1 And that's all that I have for you. Now, 2 I'll turn it back over to Dennis.
3 MR. ANDRUKAT: Okay. Fantastic. Thanks, 4 Duane. Okay.
5 MR. DUNCAN WHITE: Dennis, I think you're 6 muted.
7 MR. ANDRUKAT: Oh, well, I'm glad the 8 system is acting appropriately today for us.
9 Okay. Let me start over. Since Duane has 10 to leave a little bit early for another event, I would 11 like to deviate from our agenda. I would like to open 12 a short question-and-answer session specific to 13 Duane's topic here, material security, while we still 14 have him here.
15 So if there's anyone that has any material 16 security questions related to this rulemaking, please 17 raise your hand and we will call on you and have a 18 short question-and-answer session here.
19 Okay. Let's see. The first one I see 20 here is Mr. Don. Go ahead and unmute yourself.
21 MR. GREGOIRE: Yes. Can you hear me okay?
22 MR. ANDRUKAT: Yes.
23 MR. GREGOIRE: Okay. I was just -- really 24 was trying to get to the question of (audio 25 interference) in Part 37, you know, there are certain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 1 materials that are considered in Part 37 that may have 2 a unique basis for being in there and regarding the 3 physical security requirements associated with them.
4 Is there some process for determining and (audio 5 interference) identifying materials that may be 6 irradiated?
7 That with following -- there are certain 8 thresholds (audio interference) is there some rule of 9 thumb that would help us maybe -- there may be, you 10 know, certain materials (audio interference)? I'm 11 just trying to get to the basis for the list of the 12 materials at present, instead of this Category 1 and 13 2 determination.
14 MR. DUANE WHITE: I think -- some of that 15 was a little bit difficult to understand, but I think 16 I understand your overall question.
17 In general, you know, we don't have -- I 18 guess I would say that in general we would look at the 19 characteristics of the radionuclide and see if -- kind 20 of going in alliance with what we already have 21 established, those isotopes that we have already 22 established in the Table A or the categorization.
23 Again, one thing that is different here 24 with fusion, though, as we are using different 25 products, we will have different items that come up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 1 that we haven't maybe had a chance to look at. So, 2 yes, there is a general process that we use looking at 3 the material, the characteristics of the material.
4 And from there, we would determine if anything else 5 would be required.
6 You know, it might be just that that 7 material would fall under the current requirements 8 under Part 37 because it has some of the 9 characteristics of some of the others. There could be 10 other things. It's hard to say right now, to give you 11 a general rule of thumb, but, as mentioned, we're 12 always looking at public health and safety, and is it 13 something that could be, for example, a concern or 14 other kind of potential hazard to the public?
15 MR. ANDRUKAT: All right. Fantastic.
16 And, Don, can you restate your name and your 17 affiliation for us, please?
18 MR. GREGOIRE: Don Gregoire, (audio 19 interference) Energy.
20 MR. ANDRUKAT: Yes, I think we're having 21 a little hard time understanding you. If you get a 22 minute, and if you're able to, would you mind typing 23 that into the chat window?
24 And in the meantime, I will -- looks like 25 Diego has his hand up. Go ahead, Diego.
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17 1 MR. SAENZ: Yes. Duane, if you could 2 elaborate a little bit? If I'm hearing you correctly, 3 right, you're saying that tritium was considered, but 4 we decided that it's not needed to be added to the 5 list for Part 37. I was just hoping you could 6 elaborate a little bit on that. I think that will 7 give people some good context. Thank you.
8 MR. DUANE WHITE: Yes. Based on the 9 characteristics of tritium, and tritium is not a new 10 isotope -- you know, we currently have others, you 11 know, other licensees that address tritium. We see 12 our current 10 CFR Part 20 requirements adequate 13 enough for the tritium. For the activation products, 14 that might be different where it could fall under our 15 Part 37. And so that's where maybe Part 37 might 16 apply if it meets one of those requirements.
17 Is that enough detail, Diego, you think?
18 MR. SAENZ: Yes, that's perfect. Thanks.
19 MR. DUANE WHITE: Okay.
20 MR. ANDRUKAT: Okay. Let's see. I see 21 another hand raised. I see Andrew. Go ahead, Andrew.
22 MR. PROFFITT: Yes, this is Andrew 23 Proffitt, Zap Energy. Duane, this is really helpful.
24 I wonder, just following on what Diego 25 mentioned and your answer there, you know, there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 1 many isotopes that have sort of already been evaluated 2 by the NRC, whether or not they needed to be 3 considered for the tables in Part 37. Is there any 4 list of that available at all? Just because, you 5 know, building the machines and understanding what the 6 activation products may be, it could be helpful to 7 sort of reference a list. And maybe the NRC has 8 already sort of thought about or evaluated it for 37, 9 but decided it wasn't necessary to be included.
10 MR. DUANE WHITE: Andrew, let me make sure 11 I understand your question. Are you saying a list of 12 isotopes that are under Part 37? Is that what you're 13 asking?
14 MR. PROFFITT: No, I'm sorry. Things that 15 aren't on the table, but have been looked at and the 16 NRC decided not to include them on the tables. Does 17 that make sense?
18 MR. DUANE WHITE: Yes. We don't have a 19 list that are not on the table. Yes, at this time, we 20 don't have a list. That's one thing that, as we move 21 further with the fusion energy system, we'll get a 22 better understanding of the isotopes that could be 23 produced to know if that would be something that we 24 would look at a little bit more.
25 That's why we indicated it would be very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 1 helpful if you come in early, you know, for a pre-2 application discussion, so that we can maybe talk 3 about that and have a good understanding. But we 4 don't have a list that would kind of say these are the 5 ones that maybe you could make it -- right now, at 6 this point, if it is not under Part 37, then we would 7 have to look at it.
8 And again, I'm not saying that it would 9 automatically mean that it would have some kind of 10 additional security code. It definitely will be a lot 11 of discussion before making any kind of decision with 12 the licensee.
13 MR. PROFFITT: Understood.
14 MR. ANDRUKAT: All right. Fantastic. And 15 let's see. We have another hand raised.
16 Thank you, Don. Don, our first attendee 17 with the first question, is with Zap Energy. He wrote 18 that in the chat. So, thanks, Don, for that.
19 Okay. Moving on, we have Patrick. Go 20 ahead and unmute and proceed.
21 MR. PATRICK WHITE: Great. Thank you very 22 much. Patrick White, Clean Air Task Force. So, 23 thanks so much for the presentation and the 24 information here.
25 When it comes to the threshold quantities NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 1 in Appendix A on Part 37, are these threshold 2 quantities that would apply across an entire license 3 or an entire facility, or could you start to, 4 essentially, do maybe subcategorization of maybe 5 looking at inventories across certain facilities or 6 activities?
7 I guess my question really comes down to, 8 would these security requirements apply across an 9 entire facility if a licensee met or exceeded those 10 thresholds?
11 MR. DUANE WHITE: So one thing I'll 12 mention is that it's based on the aggregated quantity.
13 So it does depend on how material is stored -- if you 14 did have separate storage areas, for example, for each 15 type of radionuclide. But, in general, it's for the 16 facility, but, you know, we do have some discussions 17 in our guidance, in NUREG-2155, about aggregation and 18 whether that material that might be in another room, 19 for example, would also be aggregated. The total 20 quantity might be what meets the Part 37 requirements 21 -- if that's clear to you.
22 MR. PATRICK WHITE: I believe it is. And 23 you said NUREG-2155?
24 MR. DUANE WHITE: Yes, NUREG-2155.
25 MR. PATRICK WHITE: Sounds good. Thank NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 1 you so much. I'll look there for additional 2 information.
3 MR. DUANE WHITE: Okay.
4 MR. ANDRUKAT: Okay. I don't see any 5 other hands raised at the moment. So with that, I'll 6 say thank you to Duane and for the attendees with 7 their security questions.
8 And we will now move on, and we're going 9 to turn the presentation over to Cindy Rosales-Cooper, 10 also of the Office of Nuclear Security and Incident 11 Response. And she will discuss the emergency 12 preparedness. So let me move the slide for you. Go 13 ahead, Cindy.
14 MS. ROSALES-COOPER: Thanks, Dennis. Good 15 afternoon, everyone. So I'll be covering our EP 16 portion of this, the emergency preparedness.
17 So the emergency response capabilities are 18 mandated to provide additional defense-in-depth 19 protection to both the onsite staff and the 20 surrounding population for any NRC licensed facility.
21 Consistent with the current regulatory 22 approach, the staff views the inclusion of emergency 23 preparedness for fusion system licensees as an 24 essential element in the NRC's defense-in-depth 25 philosophy. The defense-in-depth philosophy requires NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 1 four elements, three of which are barriers to reduce 2 the likelihood of malfunctions. These are high 3 quality in the design, construction, and operation of 4 the licensed facility.
5 Emergency preparedness is not in addition 6 to, but it is the fourth and last barrier, and is 7 expected to be the last line of defense when the three 8 previous barriers fail.
9 Even though complete EP requirements for 10 fusion systems cannot be confirmed until information 11 on the design, construction, and operation, and 12 likelihood of events, is known, we can state with 13 certainty that fusion facilities will be required to 14 have emergency response capability with offsite 15 response being commensurate to the radiological 16 hazard.
17 We believe the emergency preparedness and 18 response terminology in Part 30 may benefit from 19 consistent terminology used by NRC utilization 20 facility licensees, our federal counterparts, such as 21 the Federal Emergency Management Agency, or FEMA, and 22 the Department of Energy, as well as state and local 23 offsite response organizations.
24 The proposed limited scope rule under Part 25 30 will provide for a performance-based regulatory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 1 framework for fusion energy systems, including the 2 licensing basis for emergency preparedness of such 3 facilities.
4 The new limited scope rule requirements 5 will be consistent with the technology-inclusive 6 language already set forth in Part 30, and thus, will 7 provide the ability for emergency preparedness on a 8 scalable basis.
9 As a result, we're considering limited 10 changes to Part 30 for the EP requirements to address 11 the above and any potential unique risks with fusion 12 systems. And as a result, we would like to ask three 13 questions that I'll go over on the next three slides.
14 Next slide, please. So our first 15 question, we believe that fusion facilities may 16 benefit from an update to the emergency classification 17 definitions in Part 30, to include general emergency, 18 unusual event, and other changes consistent with a 19 performance-based, technology-neutral approach. As I 20 previously mentioned, this would allow consistency 21 with other federal partners, as well as state and 22 local offsite response organizations.
23 What are the benefits or consequences of 24 this approach to fusion system and materials licensees 25 under Part 30?
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24 1 Next slide, please. Our second question.
2 The staff recognizes that Part 30.32(i)(1) has 3 emergency preparedness requirements based on Schedule 4 C quantities for existing material facilities and 5 technologies.
6 What will be the benefits or consequences 7 of requiring all fusion system applicants to submit a 8 maximum dose evaluation and specific emergency 9 response plan for the expected quantities that will be 10 presented and generated at the facility, instead of 11 applying the quantities and Section 30.72 Schedule C 12 quantities of radioactive materials requiring 13 consideration of the need for an emergency plan for 14 responding to a release?
15 Next slide. And this is the last 16 question. As we previously discussed, fusion system 17 licensees will be required to have emergency response 18 capabilities scalable to their respective radiological 19 hazards.
20 What would be the benefit or consequences 21 of clearly requiring, so that we can be consistent 22 with decommissioned and small modular reactors and 23 other areas within our regulations? What would be the 24 benefits or consequences of clearly requiring all 25 fusion system applicants to include response NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 1 capabilities for protecting onsite personnel, as well 2 as coordination with fire, medical, and local law 3 enforcement agencies, as needed, during an emergency 4 in the draft proposal for Part 30.32(k)(2)?
5 And that will be the end of my 6 presentation.
7 MR. ANDRUKAT: All right. Thanks, Cindy.
8 So with that, I know we posed a couple of 9 questions or a few questions here. We will come back 10 to those during the open question-and-answer session.
11 Okay. Next, let's turn the presentation 12 over to Dr. Christianne Ridge of the Office of Nuclear 13 Material Safety and Safeguards to discuss waste 14 management. So let me get the slide over for you.
15 All right.
16 MS. RIDGE: Thank you.
17 MR. ANDRUKAT: Go ahead, Dr. Ridge.
18 MS. RIDGE: Thank you. Good afternoon, 19 everyone. I'm a Senior Risk Analyst in NMSS, as 20 Dennis pointed out, and I'm in the Division, 21 specifically, the Division of Decommissioning, Uranium 22 Recovery, and Waste Programs.
23 And I'm going to talk just for a few 24 moments today about waste management. And I'm going 25 to start with the issues that are on our radar.
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26 1 So if you could go to the next slide, 2 Dennis? So one of the first things that the staff 3 started in considering the waste management is, how 4 does the waste that we might get from fusion systems, 5 how does that fit into our current, existing waste 6 disposal framework?
7 And we've had stakeholders bring a number 8 of issues to our attention, and the staff has 9 identified other issues. And they fall into two main 10 categories.
11 And one is waste characteristics. So when 12 we talk about waste characteristics, we're talking 13 about both the waste forms, so the physical and 14 chemical properties of a waste, as well as the 15 specific radionuclides that are in the waste. And 16 fusion systems have the potential to generate waste 17 with different waste forms and radionuclide contents 18 that NRC considered extensively when we developed the 19 existing waste disposal framework, and specifically, 20 the low-level waste disposal framework.
21 Now, a safety assessment that's already 22 required for disposable low-level waste considers the 23 actual physical and chemical forms and the actual 24 radionuclide contents of waste for the safety 25 assessment for someone offsite. So who is that?
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27 1 That's, if there's a waste disposal site, that's 2 someone who lives just past the boundary of that. And 3 that's a requirement for all low-level waste disposal 4 facilities to do that type of analysis.
5 And so anything novel that was in a fusion 6 system waste would have to be considered by a disposal 7 facility accepting that waste in the context of 8 looking at, what could the dose to someone offsite be?
9 One of the things that stakeholders have 10 brought to our attention, and that staff has 11 identified, is the protections in the regulations for 12 someone who accidentally intrudes on the waste. So 13 that's someone -- say, after about 100 years we give 14 credit for institutional controls -- if someone were 15 to, if society at large were to lose knowledge that 16 there's a waste site there, and someone accidentally 17 intrudes into that waste. We call that person an 18 inadvertent intruder. They didn't mean to intrude in 19 the waste, but they inadvertently did.
20 Our waste disposal regulations protect 21 that person, but that protection relies, in part, on 22 the low-level waste classification tables. And one of 23 the things that staff has considered is that, when we 24 developed those waste classification tables, we looked 25 at the radionuclides we thought would be important at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 1 the time.
2 Now, this was the early 1980s. So we 3 looked at medical isotopes, what was in medical waste.
4 We looked at what was in industrial waste. And, of 5 course, we looked at, what are the characteristics of 6 the waste from a fission reactor?
7 And so we had certain radionuclides that 8 we thought, you know, these are the ones that are most 9 important for considering whether something is what we 10 would call a Class A low-level waste, which has 11 relatively less concentration, and therefore, less 12 protections than we would require for a Class B or 13 Class C low-level waste.
14 Now, many people listening are very 15 familiar with these tables. And I want to point out 16 that the radionuclides that we considered, actually, 17 that list is a little bit more extensive than what 18 actually made it into the tables.
19 So people have pointed out to us that, 20 hey, there are radionuclides that could be very 21 important for fusion system waste that are not in 22 those tables. Now, for an offsite member of the 23 public, that's okay. Whatever is in the waste will be 24 considered.
25 For protection for an intruder, there are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 1 radionuclides that maybe are very concentrated in the 2 waste, but that waste still wouldn't be Class C, 3 according to our tables, because that radionuclide is 4 not in the waste classification table as it stands.
5 So we want to address that safety issue.
6 And we believe that the safety goal of the 7 classification table can be accomplished in a very 8 risk-informed way if we require that, if the waste is 9 very different from what we considered when we 10 developed the low-level waste regulations, if waste 11 that's different from that, if disposal sites need to 12 do a site-specific intrusion analysis, that would put 13 it on equal footing with the safety analysis that's 14 done for an offsite member of the public, where the 15 actual waste characteristics, the actual radionuclides 16 in the waste, the actual physical and chemical form of 17 the waste need to be considered.
18 And so that is what we propose, just what 19 the staff is considering proposing to do right now.
20 It is that, if waste is significantly different from 21 what was considered in the development of the tables, 22 we would require this site-specific inadvertent 23 intrusion assessment. And I'm going to speak on the 24 next slide a little more specifically about what do we 25 mean by significantly different from what we've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 1 already considered.
2 But, before I do that, the second issue 3 that the staff has considered is waste volumes. And 4 there have been stakeholders who have brought to our 5 attention that the volumes of waste coming from fusion 6 systems might be greater than what we are accustomed 7 to from a fission reactor.
8 Now, that will depend in large part on the 9 designs and the materials that are used; how the 10 systems are operated. So we feel that there is some 11 uncertainty there, but the waste volumes that will be 12 generated are being considered in the environmental 13 review for this rulemaking. So I wanted to point out 14 where that waste volume issue comes into this process, 15 and it's in the environmental review for this 16 rulemaking.
17 Staff is also considering whether 18 applications need to include an assessment of disposal 19 pathway, and, you know, disposal pathway for whatever 20 volume of waste is anticipated to be part of the 21 licensed system, as part of the decommissioning 22 funding plan. So, essentially, as part of the 23 application, you would have to say this is how much 24 waste. This is where we think it can be disposed.
25 This is what it's going to cost. So that's where that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 piece of the volume would come in.
2 Next slide, please. So we plan to address 3 this issue of wastes that are different from what was 4 previously considered in a new part of Part 20.2008 in 5 a new paragraph (c).
6 And the text in green here is actually 7 text that we shared at the October 11th public 8 meeting, if you had an opportunity to participate in 9 that. And essentially, what this new paragraph does 10 is it allows waste from fusion systems to be disposed 11 of with low-level radioactive waste under the existing 12 framework.
13 Right now, accelerator waste is actually 14 specifically excluded from the definition of low-level 15 waste, but this part of -- so in general 20.2008 16 allows waste from fusion systems to be disposed of 17 with low-level waste.
18 The text in blue is new text that the 19 staff is considering since we last discussed this in 20 a public meeting, since that October 11th public 21 meeting. And that's the significantly different part.
22 And we are considering that because we 23 don't want to necessarily say any fusion system needs 24 to have the disposal site do a site-specific 25 inadvertent intrusion assessment because there very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 1 well may be fusion systems that have waste that falls 2 well within what we already considered when we 3 developed 10 CFR Part 61. That's the low-level waste 4 regulations. And there may very well be fusion 5 systems and the waste falls well within what we 6 considered.
7 But, if not, that's when we would want to 8 cover the safety goals of the waste classification 9 tables by having the disposal sites that accept waste 10 from a fusion system do this site-specific inadvertent 11 intrusion assessment.
12 So determining whether or not something is 13 significantly different, we're proposing that that 14 would be in guidance. So that would be in the new 15 proposed Volume 22 of NUREG-1556.
16 And it would address these, essentially, 17 are the physical forms of waste. You know, for 18 instance, activated metals, ion exchange resins, 19 contaminated soils, contaminated equipment -- a long 20 list that were considered when we developed the low-21 level waste regulations.
22 These are a list of what we considered.
23 Is this waste a novel physical form? Is it, for 24 instance, liquid metal? Large quantities of liquid 25 metal weren't necessarily considered. But many NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 1 different types of waste were. And so it would take 2 a look at that.
3 And then, it would also provide a list.
4 And many radionuclides on the list would be familiar 5 to people because, of course, they're what is in the 6 waste classification tables today.
7 But, actually, what was considered at the 8 time was a longer list. And some of those 9 radionuclides were excluded because they weren't very 10 common in waste at the time, but we do have those 11 calculations and we know, you know, on equal footing 12 with what is in the tables, we know what the 13 concentrations would be.
14 So we would put in guidance here's a list 15 of -- and, again, this is proposed. But the staff's 16 current thinking is that we are considering putting in 17 the guidance a list of these are the radionuclides 18 that were considered at the time, the concentrations 19 that were considered at the time. And is the waste 20 from this fusion system, is it within that envelope?
21 Or does it have different radionuclides, different 22 activation products than we considered at the time?
23 And so that part would be in guidance.
24 And then, the guidance for what would be 25 an inadvertent intrusion assessment is, actually, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 1 currently available and public because it would be the 2 same guidance for what is currently the direction of 3 -- there's a parallel ongoing rulemaking looking at 4 our low-level waste regulations. And they are 5 proposing to require an inadvertent intrusion 6 assessment. So there is existing guidance, and our 7 guidance would be exactly consistent with that.
8 So if you could go to the next slide? So 9 the proposed rule change that was on the previous 10 slide, as I mentioned, part of what that part of the 11 rule does is it allows fusion waste to be disposed of 12 within the existing low-level waste framework at low-13 level waste disposal sites.
14 And so this proposed change to that part 15 of Part 20 does not require any changes to Part 61.
16 It merely says, if a waste is being disposed of, if 17 fusion system waste is being disposed of with low-18 level waste, and it's significantly different than 19 what we considered when we were developing those 20 regulations, we would need to do this site-specific 21 intrusion assessment. And none of that requires a 22 change to Part 61, and we don't think it requires any 23 changes to other parts of Part 20, either.
24 And this last piece ties into the previous 25 slide, where I was saying the guidance for inadvertent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 1 intrusion assessment already exists. That's because 2 it's consistent with the direction that the staff is 3 proposing for the current low-level waste rulemaking 4 that's underway.
5 And then I think one more would be my last 6 slide. So I've talked a lot about this inadvertent 7 intrusion piece because it's the piece that's new.
8 But if we were just going to ask, well, what else 9 would be in this waste management guidance, it would 10 be a lot of things that are familiar from the guidance 11 for other materials licensees.
12 So the application should include 13 procedures for waste minimization, waste 14 characterization, waste handling, safe and secure 15 storage, and waste disposal. The first two bullets on 16 this slide really are similar to other materials 17 licensees.
18 I talked a lot about the first subbullet 19 here: potential waste disposal in terms of transfer 20 to a low-level waste disposal facility. But, of 21 course, other disposal methods that are available to 22 other materials licensees would also be available.
23 For very short half-life radionuclides, decay in 24 storage; certain effluent releases that are authorized 25 for other licensees already under Part 20. And then, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 1 there are other methods a little less commonly used 2 under other parts of Part 20, 20.2002 through 2005.
3 And then this third bullet just gets to 4 what I've been speaking to in the last few bullets.
5 For waste transferred to a low-level waste disposal 6 facility, the applicant would need to determine in 7 their application, as part of the contents of the 8 application, whether or not a site-specific 9 inadvertent intrusion assessment was necessary. And 10 again, we would provide guidance, trying to be as 11 specific as possible for what significantly different 12 means.
13 And so with that, I will turn it back to 14 Dennis, and I look forward to questions at the end of 15 today's presentations.
16 MR. ANDRUKAT: All right. Fantastic.
17 Thank you, Dr. Christianne. Next, let's turn the 18 presentation over to Diego Saenz of the State of 19 Wisconsin to discuss facilities and equipment.
20 Mr. Diego, sir.
21 MR. SAENZ: Great. Thank you so much, 22 Dennis. Again, my name is Diego Saenz with the State 23 of Wisconsin.
24 Oh, hold on a second. It looks like I 25 need to switch the camera. Okay. I don't know. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 1 guess the camera is just having issues. So that's 2 okay.
3 Okay. Great. If you could go to the next 4 slide, please? So here is a list of the pertinent 5 regulations. I won't speak to them all specifically 6 here, but it's important that we receive a description 7 of the facilities and equipment and a demonstration of 8 how that is adequate to protect health and minimize 9 danger to life and property; specifically, addressing 10 how exposure to workers and the public will be 11 minimized and kept as low as reasonably achievable, 12 and specifically, addressing those limits at the site 13 boundary or to members of the public.
14 So this is a combination of administrative 15 measures with the facilities and engineered controls 16 and barriers that would need to be described.
17 If you could go to the next slide? So 18 again, this is for those folks familiar with our other 19 NUREGs. These will be many familiar components. I'll 20 speak to a lot of these items for those that are less 21 familiar.
22 So generally we'll want to see facility 23 diagrams that have sufficient detail that show work 24 spaces for the staff. We would want to see shielding 25 and those components.
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38 1 One specific component that we've had a 2 lot of discussion within the group is the validation 3 piece. So with other sources of radiation, there's a 4 lot more experience in this area, and then, for 5 neutrons, that's one area that we're seeing this is a 6 more novel use, where we're seeing such neutron fluxes 7 without the large barriers and containment and other 8 components that you would see for fission facilities 9 that were providing a lot of shielding, and we're 10 there for a lot of other reasons. So here, that's an 11 area of focus that we're looking at.
12 The other thing that I would really want 13 to have some discussion about is -- so the requirement 14 is a dose limit from all sources of radiation. And 15 what's unique here relative to some other areas of 16 regulation is that this will be a partnership between 17 the x-ray side, which is regulated by the states, and 18 the radioactive material side, which is under the NRC 19 jurisdiction, which would be under the Agreement State 20 jurisdiction for states.
21 Again, for Wisconsin, we have a very 22 strong partnership between those two groups, but I 23 think it's important to keep that in mind for states 24 that it may be the NRC and a state regulating that.
25 Specifically here, I think what's really NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 1 important is those shielded calculations will be 2 really important because, not only are they going to 3 provide the exposure to the individuals, right? And 4 normally, we would think of that as a kind of device, 5 the electronic device, regulation under that 6 regulatory framework. However, there's also a strong 7 activation component, and those activated components 8 and the resulting radioactivity that would come from 9 those would be from the radioactive materials.
10 So here, I'm not going to read through all 11 these bullets, but you can see it speaks to these 12 different things. And it speaks to what is important 13 to a shielding calculation.
14 And if you go to the next slide, there's 15 more items. Great. And specifically here, we address 16 some of those ventilation systems. So there are some 17 unique components with how you monitor for tritium.
18 So that would be important to be addressed.
19 So those are the areas that we're focusing 20 here for the facility description of what we would be 21 looking for. And one specific item that we're having 22 a lot of discussion about would be the difference 23 between a first-of-a-kind facility, where we would be 24 looking for more monitoring than we would for a nth-25 of-a-kind facility.
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40 1 So more validation of those calculational 2 methods. So, of course, we're very used to relying on 3 shielding calculations. So that will continue to be 4 an important component, but then that validation piece 5 of having dosimetry throughout the building, and 6 perhaps at the site boundary, to demonstrate 7 compliance with the limits, that would be an important 8 component for verifying compliance.
9 So I would be hoping that we would have 10 more discussion on that specific boundary. What 11 should end up in this NUREG? And what should we be 12 looking for? Maybe more focused on a CRCPD guidance, 13 or something like that. So, thank you.
14 MR. ANDRUKAT: All right. Fantastic.
15 Thank you, Diego. And with that, we're going to turn 16 it over to our last topic, and we have a slight change 17 in presenter here. I know the slide says it's Duncan, 18 but we have Ms. Allyce Bolger who's going to actually 19 give the presentation on this particular topic. She 20 is with the same group. And with that, Allyce, I'll 21 turn it over to you.
22 MS. BOLGER: All right. Thanks, Dennis, 23 and you can go to the next slide.
24 All right. So as a part of the 25 application, the applicant, a future applicant, will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 1 be coming in and we will require that they provide us 2 information regarding their overall occupation dose 3 program and how they are going to evaluate how 4 workers, what their exposure will be and how they're 5 going to measure that.
6 And in particular, for fusion facilities, 7 we expect that the majority of them will be handling 8 and using tritium as that. So in particular we are 9 really interested in how that applicant will be 10 determining internal exposures in that case.
11 And under 10 CFR 20.1204, that describes 12 the compliance for occupational dose regarding 13 internal exposure and the means by which a licensee 14 may be in compliance with that. So they can measure 15 concentrations of radioactive materials in the air and 16 work spaces or they can look at the quantities of 17 radionuclides in the body or the quantities of 18 radionuclides that have been excreted from the body, 19 or some combination of those three measurements as 20 well.
21 So for this, bioassays would be the method 22 by which they would look at the kinds, quantities, or 23 concentrations; in some cases, even determine the 24 location of radioactive material in the human body.
25 A bioassay can be made by direct measurements or by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
42 1 analysis and evaluation of material excreted or 2 removed from the body.
3 If you'd go to the next slide? All right.
4 Thank you.
5 So the licensee or applicant will have 6 some flexibility in determining the frequency of their 7 bioassay measurements and program; whether they even 8 meet the requirement to need to perform a bioassay, 9 which would occur if an adult is likely to exceed 10 10 percent of the annual limit on intake, as described in 11 10 CFR Part 20.
12 For those licensees that maybe don't feel 13 they meet that requirement, it might just be that they 14 perform an evaluation demonstrating that they do not 15 hit that 10 percent limit.
16 Otherwise, the licensee or applicant will 17 need to establish a routine frequency for performing 18 these, and that routine frequency would include 19 performing baseline bioassays. So that would be the 20 initial start before an individual begins work 21 activities with the tritium or radionuclide of 22 concern.
23 And then establishing some sort of 24 periodic basis by which they will do that bioassay, 25 and then, finally, at the termination or the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 1 completion of that individual's activities.
2 And this will be used, obviously, to 3 assess the occupational dose. That's one component of 4 that, the internal component, and then also assure 5 that the licensee or confirming the licensee is using 6 appropriate engineering and administrative controls in 7 place and maintaining within their ALARA threshold or 8 limits that they've self-established as well.
9 The second type of bioassay would be a 10 special bioassay that you would perform in the event 11 of an abnormal or inadvertent intake. Examples of 12 this might be if there's some issues with respiratory 13 equipment or if there's an accidental intake of 14 material, a contamination of a wound, something like 15 that where it would absorb into the skin. The license 16 will need a program in place to also evaluate those 17 intakes.
18 Next slide. All right. So for the 19 bioassay program, written procedures would be 20 required. They would need to be developed, 21 implemented, and maintained in accordance with 22 10 CFR 20.1204.
23 And some of the considerations that the 24 applicant should include would be the type of bioassay 25 that they would be performing, whether that be direct NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 1 or indirect measurements; the number of samples or 2 data points that would be collected; the frequency; 3 sample size; the ease or difficulty of the sample 4 collection, and any instructions that they might need 5 to provide to the sample collector.
6 And that would be something that they 7 would either need to submit or at least have onsite, 8 and would be part of what we would review during an 9 inspection and confirming that the licensee is meeting 10 the occupational exposure limits established in Part 11 20. All right. Back to you, Dennis.
12 MR. ANDRUKAT: Okay. Fantastic. Well 13 done. Thank you to all of our presenters.
14 So that brings us to the end of our 15 presentation slides. If we look at the agenda, this 16 is when we predicted to have a break at this time.
17 And so I will throw out the suggestion, just like we 18 did last week, of foregoing the break, at least for 19 now, and continuing and jumping straight into the 20 question-and-answer session. But if anyone has any 21 objections to that, please feel free to let us know.
22 Okay. I'm not seeing any objections so 23 far. Okay. So let's do this. Let's go ahead and 24 start kind of the question-and-answer session. We'll 25 see how that goes. If we need to take a break, feel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 1 free to provide that feedback. We can always take a 2 break.
3 And I will add, for the material security, 4 if there are any additional questions for the material 5 security, I think what we can do is hold off on those 6 until the end of all the other questions. And what I 7 can do is see if I can pull Duane back into this 8 meeting if there's anything more for the security 9 topic.
10 Okay. So with that, a quick reminder to 11 use the raise hand function. A quick reminder to 12 remain on mute until we have called upon you, as well 13 as please state your name, your affiliation or 14 organization. And for those on the phone, muting and 15 unmuting is the *6.
16 Okay. So with that, let's go ahead and 17 open it up, and I will see -- I see no hands raised so 18 far. Let's give it a few minutes.
19 Okay. Patrick White, go ahead, sir.
20 MR. PATRICK WHITE: Great. Thank you.
21 Patrick White, CATF. So my question was for Cindy on 22 the emergency preparedness section, specifically on 23 question two.
24 I thought the discussion around submitting 25 a maximum dose evaluation was interesting, but I was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 1 curious if you could provide any more detail on maybe 2 what's maybe some of the initial thinking on what 3 would constitute a maximum dose evaluation. Or is 4 that something where some of the guidance around what 5 type of assumptions would be provided in regulatory 6 guidance?
7 MS. ROSALES-COOPER: So right now, because 8 the regulation is written as is for materials 9 licensees, and we know that fusion systems are going 10 to be different, we're just asking this question 11 because we want to make it as broad as possible to 12 make sure that we get the information that we would 13 need when we're looking at these new designs.
14 We don't know what's going to be coming 15 down the pike. So rather than going forward with the 16 regulation as is, which allows materials applicants 17 right now to make their own evaluation as to whether 18 or not they're going to need an emergency plan or not, 19 we would like to actually see all of those 20 evaluations.
21 And I hope I'm answering your question.
22 If not, I do have some of my other colleagues who are 23 on the line if we need to go further into that.
24 MR. PATRICK WHITE: No, that's really 25 helpful and it makes sense in terms of trying to get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 1 more information about kind of what's potentially 2 coming down the line.
3 I guess when I think about performing a 4 dose evaluation, there are a lot of things that you 5 consider in terms of, what is a source term; what is 6 a release fraction; what are the release conditions, 7 and a lot of things that potentially have an impact on 8 what the calculated doses would be, and just where 9 there might be potential guidance on what would be an 10 expectation from NRC staff on what types of 11 assumptions would be used when performing that dose 12 evaluation.
13 MS. ROSALES-COOPER: And we certainly 14 would want to address that when it comes down to what 15 the final rule looks like and would be able to address 16 those things in guidance further on.
17 MR. PATRICK WHITE: Okay. I got that.
18 MS. ROSALES-COOPER: At this point, I 19 wouldn't be able to answer that question for you at 20 this point, though.
21 MR. PATRICK WHITE: It's a pretty broad 22 question. So I appreciate the answer.
23 MR. ANDRUKAT: Fantastic. Okay. Let's 24 see. I see another hand raised. It looks like, 25 Diego, go ahead, sir.
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48 1 MR. SAENZ: Yes. So I guess I'll provide 2 some feedback on that question, too, as well for 3 emergency preparedness.
4 So from my perspective, I think that it's 5 appropriate for the threshold we have for when an 6 evaluation for an emergency plan would be required.
7 So there's some fusion systems -- so something as 8 broad as all fusion systems being required for this 9 may be too broad. There's some aneutronic systems 10 that would have a very low radioactive material 11 inventory, for which it may not be appropriate for 12 them to do that calculation, and that could become a 13 burden that's not adding regulatory value.
14 And again, this is very broad, all fusion 15 systems. There may be small R&D devices that would 16 get caught up in this as well. So I think it would be 17 very important to be very thoughtful about how we 18 frame some of these things. I think, right now, the 19 threshold of material provides a very reasonable 20 trigger point for that, I believe.
21 MS. ROSALES-COOPER: Thank you. That's 22 the type of feedback we're looking for. Thank you.
23 MR. ANDRUKAT: Okay. Let's see. Next, we 24 have Andrew Holland. Go ahead, Andrew.
25 MR. HOLLAND: Thank you all. Andrew NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 1 Holland, CEO of the Fusion Industry Association.
2 Am I coming through loud and clear?
3 MR. ANDRUKAT: Yes.
4 MR. HOLLAND: Okay. Great. On this same 5 question, you know, we do know that the NRC already 6 has a current method and reason that covers a broad 7 range of industries and topics, and it's already 8 within Part 30. And the question is, why should 9 fusion be treated any differently? If fusion is 10 defined as within Part 30 as an accelerator, why 11 should specific fusion be treated any differently?
12 And it seems like an extra burden, 13 especially on the broad variety of fusion technologies 14 out there, when there already is a -- NRC has already 15 determined what the scale and cutoff is. For those 16 that have low levels of tritium or other radioactive 17 material onsite, why is there a need for a specific --
18 for this for all licensees? Thanks.
19 MS. ROSALES-COOPER: So are you asking me 20 why we're asking this question to go broader? Or is 21 that your feedback?
22 MR. HOLLAND: That's the feedback.
23 MS. ROSALES-COOPER: Okay.
24 MR. HOLLAND: The feedback is it's not 25 clear why there would be a need for this beyond what's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 1 already in the regulation.
2 MS. ROSALES-COOPER: Okay. Thank you for 3 that.
4 MR. ANDRUKAT: Okay. Andrew, did we 5 answer your question?
6 MR. HOLLAND: Well, I'm not sure. I was 7 not sure if I was expecting an answer to the question.
8 MR. ANDRUKAT: Okay.
9 MR. HOLLAND: But, yes, the question is, 10 why would you consider something above and beyond what 11 is already in law or in regulation? Yes.
12 MR. ANDRUKAT: Okay.
13 MS. ROSALES-COOPER: So I was under the 14 assumption that was your feedback to this, as to why 15 make it broader. So what I was interpreting was that 16 you would prefer that we leave it as is.
17 Again, the purpose behind our question is, 18 because we don't know what the other future designs 19 could hold, we're just exploring and this is the type 20 of feedback that we are actually looking for. So, 21 thank you.
22 MR. HOLLAND: Yes.
23 MS. ROSALES-COOPER: Okay.
24 MR. HOLLAND: Yes, the feedback is that 25 there's a broad range of technologies and designs out NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 1 there, some of which would fall above the current 2 thresholds and some of which would certainly fall 3 below. And it would be an unnecessary addition, such 4 that we would think, you know, on first assessment.
5 MS. ROSALES-COOPER: Thank you.
6 MR. ANDRUKAT: Okay. Thank you very much.
7 Okay. It looks like we have another hand 8 raised. We have Don. Go ahead, Don.
9 MR. GREGOIRE: Yes, and Don Gregoire from 10 Zap Energy. And just another comment moving in the 11 definition section there. I think one of the concerns 12 that I have in slide 13, where you mention making use 13 of the terminology that's currently used in something 14 like NUREG-0654, which talks about general 15 emergencies, but it uses the terminology of a core 16 melt associated with that. And in fusion technology, 17 I assume that that's not going to happen.
18 The bottom line is, you know, there's 19 always a concern of mixing the terminology that the 20 other industries that might cast a meaning on a 21 certain event (audio interference) is not in 22 attendance. So I think we will -- things that we have 23 concerns making sure that (audio interference) will 24 work. And the social impact by characterizing these 25 too much doesn't seem right, as in the methods that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 1 have been used, especially in the fission industry.
2 And so that was just some feedback on that definition.
3 You've questioned (audio interference).
4 I do want to talk about, you know, this 5 management of the change, proposed change, to 20.2008.
6 And it just begs the question, there's already 7 guidance in the Part 61 and 61.402 which looks at 8 protections for individuals who inadvertently intrude.
9 And it's pretty generic. It's a -- in part of the 10 general requirements. It doesn't (audio interference) 11 express a specific dose (audio interference), which I 12 think these 5 millisieverts seems to be then something 13 that I couldn't find as being addressed anywhere else.
14 But what's the basis for it not articulating a 15 specific value and meaning on the existing 61.402 that 16 you (audio interference)?
17 MS. RIDGE: Absolutely, and that's an 18 excellent question, and I'm really glad you brought 19 that up. I'm happy to have a chance to address that 20 because the answer is twofold.
21 And one is that inadvertent intrusion, as 22 I mentioned, really does rely, in part, on the waste 23 classification tables. And that's because that's how 24 those waste classification tables were developed in 25 the original calculations to find those concentrations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 1 that are currently in Part 61.55. That's Waste Class 2 A, B, and C. That was based on an inadvertent 3 intruder assessment.
4 Now, that calculation was done so long 5 ago, it was done with ICRP-2. So those concentrations 6 were actually calculated with organ doses. But, 7 roughly speaking, we believe that is equivalent to a 8 5-millisievert total effective dose equivalent, the 9 TEDE, for those of you who are familiar with that 10 acronym, but the total effective dose equivalent.
11 So essentially this is an effort to put 12 this assessment on the same dose footing that those 13 original concentrations in the waste classification 14 tables were developed based on. So that's the first 15 answer. It's that 5 millisieverts comes from an 16 effort to make this intrusion assessment consistent 17 with the existing waste classification tables.
18 Now, the second part of the answer -- I 19 said it was twofold -- the second part of the answer 20 is this parallel rulemaking that's going on with Part 21 61. And part of the proposed published, publically-22 available language in that rulemaking is for certain 23 types of waste. And that rulemaking is focused on 24 very long-lived waste, such as depleted uranium. As 25 I said, this is a totally independent process that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 1 going on.
2 That rulemaking is moving towards 3 requiring a site-specific inadvertent intrusion 4 assessment for waste to certain long-lived 5 radionuclides. In that, they are also proposing this 6 5-millisievert-per-year limit for the site-specific 7 inadvertent intruder assessment -- for the same 8 reason. It's to put it on the same sort of dose 9 footing with the waste classification tables, as they 10 were originally developed.
11 But, you know, as we pointed out, if we 12 did go forward with this proposed language, it would 13 be consistent with what they're doing in that other 14 rulemaking.
15 MR. GREGOIRE: Thank you. That addressed 16 that question.
17 MS. RIDGE: Great.
18 MR. GREGOIRE: I have one last question, 19 and it has to do with the waste management application 20 where there is going to be an expectation to talk 21 about the waste disposal methods. And I don't know if 22 it was the last public meeting or at the first one, 23 but there was a discussion on what was going to be 24 considered acceptable as far as a decay in storage.
25 And there was some indication that may not be the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 1 threshold at which the NRC now considered itself to go 2 forward for disposal -- I'm sorry -- for waste 3 management and for extended periods of time.
4 Is that articulated anywhere? Is there 5 something that will come out on that that provides 6 more detail on the amount that's going to be 7 acceptable for a time period for decay in storage?
8 MS. RIDGE: Yes. That is actually 9 available already. Dennis, if you could go two more 10 slides, I think it's the slide after -- yes, the next 11 one.
12 So the decay in storage is one of the 13 existing possibilities for disposal of radioactive 14 waste. And we are not currently anticipating any rule 15 changes that would change decay-in-storage 16 requirements for fusion facilities any differently 17 from any other material, or any other material 18 licensees. Excuse me.
19 So right now, that is available for 20 radionuclides with a half-life under 120 days. And 21 we're not anticipating to treat fusion system 22 licensees any differently from how we would treat 23 other material licensees with respect to decay in 24 storage. Does that answer your question?
25 MR. GREGOIRE: Yes. And maybe I was just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 1 confused on the last slide, and I think Duncan (audio 2 interference) there was some comment being made about, 3 again, a threshold for a strategy where (audio 4 interference) to decay in the sites (audio 5 interference) something that wasn't going to be 6 accepted. So I think maybe there was more to it than 7 that. But I appreciate it being different. Thank 8 you.
9 MS. RIDGE: Okay. Thank you.
10 MR. ANDRUKAT: Okay. I'll give it a 11 couple more minutes. I don't see any hands raised at 12 the time. But let's just give it a couple more 13 minutes.
14 Okay. It looks like we had a hand raise.
15 Ah, Andrew. Go ahead, Andrew. Andrew Proffitt.
16 MR. PROFFITT: Yeah, this is Andrew 17 Proffitt, Helion Energy. Yes, a couple of comments, 18 and maybe I would like to spend a little bit more time 19 and maybe we can kind of walk through the questions 20 that were posed by the staff on EP.
21 But I definitely want to thank -- I think 22 the waste presentation today has been extremely 23 helpful to us here, here at Helion, and likely to much 24 of the industry, in helping understand a little bit 25 more the language and the purpose and the basis that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 1 goes around all that. So I really appreciate it. I 2 think there's still some for us to digest and think 3 about and understand the impacts, but I really 4 appreciate the explanation and the work here in that 5 thing.
6 I think the EP questions that are posed 7 are maybe a little bit concerning. I think to be sort 8 of coming from a spot of adding or treating fusion 9 differently than current byproduct (audio 10 interference) it seems like most of the other topic 11 areas have focused more on the novel issues that 12 fusion systems may provide or how fusion systems could 13 -- maybe just aspects that haven't been assessed, or 14 new materials or new ways of doing things.
15 Whereas, some of the EP can understand 16 that they're asked to give feedback in discussion, but 17 some of the concepts of sort of bringing in 18 utilization, the terminology and -- thing for a fusion 19 system that wouldn't be required for another byproduct 20 material license (audio interference) present a more 21 significant potential hazard to public health and 22 safety.
23 Sort of some of the themes and (audio 24 interference) started to think about them. So maybe 25 we can sort of go one-by-one through them, since we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 1 kind of went through them quickly in the presentation, 2 and maybe it would help folks enter a little bit more 3 discussion.
4 MS. ROSALES-COOPER: Sure. I'm fine going 5 back through the questions again. I just want to let 6 you know, though, I don't know if maybe for me, but 7 your volume was going in and out. So I didn't hear 8 everything you were saying.
9 MR. PROFFITT: Okay. I'm sorry. Can you 10 hear me now?
11 MS. ROSALES-COOPER: Yes. I mean, when I 12 was hearing you, I was hearing you fine.
13 MR. PROFFITT: Oh.
14 MS. ROSALES-COOPER: It was just there 15 were some times it was just completely silent.
16 Dennis, if you can go back up? Okay. So, 17 again, we pressed with EP, as I mentioned. And I 18 began my portion of the presentation talking about our 19 defense-in-depth philosophy at the NRC, for you to 20 understand exactly, or at least to tee it up, to make 21 folks aware where we're coming from with respect to 22 EP.
23 EP is, for us, the last line of defense, 24 but we kind of have to know what goes into those first 25 three lines, those first three barriers, before we can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 1 begin to state exactly what we, as the staff, believe 2 would be a requirement for us to make a determination 3 for reasonable assurance of public health and safety 4 for any license that we're looking at. So that's 5 where we're coming from.
6 And because we don't know the full scope, 7 we've sat in and my colleagues and I have sat in, and 8 there's a broad spectrum of different designs that can 9 come in under these fusion systems. So that's kind of 10 where we're coming from, and that's why we're asking 11 these questions.
12 We're not saying that this is what we're 13 going to do. No policy decisions have been made. We 14 haven't even offered any proposed rule language 15 changes as of yet. This is where we're at. We're 16 just asking these questions.
17 So question No. 1 really gets to parity 18 with the other licensees in the terminology, as I 19 mentioned, that's used not just within the NRC, but 20 it's used by our other federal agencies, and as well 21 as the state and local offsite response organizations.
22 And again, we're looking for feedback. Do 23 you think this would be problematic or do you think 24 this may be a good idea? That's why we posed this 25 question with respect to opening it up, bringing those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 1 definitions more current.
2 The definitions that are currently in Part 3 30 were written before 1987, and that hasn't changed 4 since 1987. Other parts of the NRC's regulatory 5 framework, especially for EP, has evolved and it's 6 changed, based on operating experience and more 7 familiarity with what can and might happen in that 8 area.
9 So that's the genesis of this question.
10 And I'll pause there to see if you have a reaction or 11 a thought on that.
12 MR. PROFFITT: Yes, I think that's a good 13 thought, and hopefully you guys can hear me now. But, 14 I mean, I think, you know, going to sort of the 15 general emergency, I think Don pointed out earlier 16 we're not talking about core damage.
17 And I think sort of those emergency 18 classification definitions sort of go to, like, a 19 progressing event. And I think part of the Commission 20 decision that was made in the SRM and to treat fusion 21 under Part 30 is there's not a sense that near-term 22 fusion (audio interference) would present the same 23 challenges of a reactor environment where there's a 24 progressing event that can continue, get worse, and 25 cause significant offsite consequences.
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61 1 And I think, you know, looking at the 2 definition for unusual event, it talks about offsite 3 actions or offsite consequences. And I think many 4 fusion systems, as Andrew Holland mentioned earlier, 5 many would not pose any potential risk offsite, based 6 on those designs.
7 So, I mean, I think it's just I think we 8 should be cautious in treating fusion differently than 9 other byproduct material licensees, I think is sort of 10 the overarching comment, I guess.
11 MS. ROSALES-COOPER: Okay. Thank you for 12 that feedback. Dennis, I don't know if you want to go 13 through the next questions, or do you want to pause, 14 since you have a number of other hands up? Let me 15 know.
16 MR. ANDRUKAT: Yes, let's go ahead, and I 17 figure the other people with their hands up may not be 18 these particular three questions.
19 So let's do this. If there's anyone that 20 has anything else for question one, let's go ahead and 21 you can just unmute real quick, and we'll wrap up 22 question one before going on to question two.
23 MR. GREGOIRE: This is Don, Don Gregoire, 24 and I've got my hand up, too, but it really is about 25 this question. And it is, in the first thought, it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 1 sounds like this is trying to address a broader issue.
2 Part 30 covers quite a broad scope of the industry.
3 Andrew Holland mentioned it earlier.
4 This change, you know, affects the entire 5 -- in every industry that's subject to the Part 30 6 licensing process. So it just seems like this is to 7 address an issue that maybe has some relationship with 8 the fusion industry, but it's going to be broadly 9 impacting. And it seems to me that this is something 10 that would be best suited separate from fusion 11 regulation and probably should be discussed by all the 12 entities that are going to be (audio interference) or 13 impacted by this. Because right now you are going to 14 probably get feedback just from fusion companies, but 15 it might not be that hard (audio interference) what 16 about the irradiators. What about the other companies 17 that might have some concern for the indications of 18 this definition (audio interference).
19 That's my (audio interference). Thank 20 you.
21 MS. ROSALES-COOPER: Well, thank you. We 22 appreciate that feedback. Thank you very much.
23 MR. PATRICK WHITE: Yeah, and I also just 24 -- this is Patrick White, CATF.
25 Yes, I also just wanted to echo that I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 1 think there are potential benefits from thinking about 2 updating the emergency classification definitions, but 3 a lot of that would also be tied to kind of what is 4 the specific performance-based criteria that we're 5 really interested in. Like when I take a look at the 6 general emergency kind of definition, it's coming down 7 to this idea of offsite releases can be reasonably 8 expected to exceed EPA protective action guideline 9 exposure levels beyond the plant site.
10 And so making sure that, if there are 11 updates, how are we tying them to something that is 12 really kind of broadly applicable and isn't 13 necessarily tied to something fission-specific like 14 core damage or substantial core damage?
15 So I think there are benefits, but this 16 larger approach of saying, okay, how are we tying it 17 to overall operations, I think could be helpful. So 18 just maybe something to consider as you're kind of 19 working through this.
20 MS. ROSALES-COOPER: Thank you.
21 MR. SMITH: Hi. Hey, Cindy, this is Todd 22 Smith. I'm the senior-level advisor for emergency 23 preparedness and incident response in the NRC.
24 And just to add to that last point, you 25 know, we're trying to look at a lot of different NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 1 perspectives here. So putting ourselves in the 2 viewpoint of an offsite emergency planner, many of 3 them are used to the definitions of what unusual event 4 and alert mean, or cite an emergency as being 5 contained to the site.
6 And so the idea here, too, isn't that, if 7 we had these definitions available, each one would 8 apply to each facility. You would still take a graded 9 approach. But the idea could be, is there a benefit 10 to be gained from a common understanding of these 11 terms, what they mean?
12 MR. SAENZ: And my feedback was actually 13 on question one as well. So from an Agreement State 14 point of view, many states that have nuclear power 15 plants within their state also have a role in 16 participating in radiological emergency preparedness 17 exercises with the plants.
18 So I think, with the caveats that, as long 19 as we do this in a technology-neutral, performance-20 based approach, which is what you're proposing, I 21 think having a common definitional framework makes a 22 lot of sense for us to be able to, you know, 23 especially those folks that kind of have a foot in 24 each area, I think it would be beneficial for the way 25 we talk about it to be the same. And again, as long NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
65 1 as those limits are appropriate, I think this makes a 2 lot of sense. Thanks.
3 MS. ROSALES-COOPER: Thank you for that 4 feedback. Dennis, do you want to go on to question 5 two again or?
6 MR. ANDRUKAT: Yes. Sorry, I was just 7 kind of scrolling just to make sure that I didn't miss 8 anybody here. Yes, so let's go ahead and go on to 9 question No. 2. There you go.
10 MS. ROSALES-COOPER: I forget which one of 11 the attendees earlier expanded on this a bit. This 12 would, again, just wanting to make it as broad as 13 possible to make sure we capture any of these designs 14 that we are not familiar with coming in. Do you see 15 any benefits or are there consequences? We're just 16 really asking the question to get the feedback. We're 17 not saying that this is what we plan to do. That's 18 the whole purpose of us bringing this in this 19 particular setting in this meeting.
20 MR. ANDRUKAT: And I think it was Patrick 21 White and Andrew Holland that previously talked about, 22 commented on this question.
23 MS. ROSALES-COOPER: Yes.
24 MR. ANDRUKAT: I see a hand raised. I see 25 Mike, Mike O'Neill. Is it on question two or did you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 1 have something outside of question two?
2 MR. O'NEILL: This is just a general 3 question for the process. Obviously, these questions 4 could involve quite in-depth responses, and we're kind 5 of coming at this on somewhat of a short timeline.
6 So I would suggest that, in addition to 7 the oral responses that we're making today, you know, 8 I suspect that it would be worthwhile for people who 9 feel strongly about this to respond in writing at a 10 later time to make sure that our views are well-11 thought-out and can be fulsomely explained.
12 MR. ANDRUKAT: So I think you bring up a 13 couple of good points. And I'll jump in here real 14 quick, Cindy. So from a process standpoint, two 15 things.
16 The first thing -- and this kind of goes 17 for everyone -- the way this particular meeting was 18 set up, we're not asking for any formal submissions, 19 any submissions of any kind from the attendees. If an 20 attendee happens to on their own accord want to submit 21 something in writing to the staff on their own accord, 22 that's outside of us. We're not requesting that.
23 But again, that would be your prerogative, 24 and that's fine. There's no guarantee that the staff 25 will make any considerations, and, of course, there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 1 no guarantee that there would be any kind of formal 2 response to anything submitted.
3 That kind of leads me to the second point.
4 And Cindy can correct me if I'm wrong. So there's a 5 possibility that, when the proposed rule goes out, 6 assuming the Commission approves the proposed rule, 7 goes out for public comment, we've been discussing 8 having some questions in there for the public to be 9 able to kind of digest and respond to, as part of the 10 formal public comment period. Now, whether we end up 11 having any, you know, whether they look exactly like 12 this, that is to be determined.
13 So, Cindy, hopefully, I'm not stepping on 14 your toes there.
15 MS. ROSALES-COOPER: Nope. Nope. You 16 covered everything exactly and the process is in your 17 court. So I appreciate that.
18 MR. ANDRUKAT: Yes. But, Mike, you're 19 absolutely right. You're coming at this a little bit 20 cold, or you are coming at this cold. This is the 21 first time everyone is seeing this, and the ability to 22 be able to digest and provide any written comments --
23 again, if it makes it into the proposed rule FRN, 24 Federal Register Notice, you'll have a formal chance 25 to respond at that time. Otherwise, we are not asking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 1 for any submissions, but at the same time we can't 2 prevent any submissions, if you will. You know, 3 that's totally up to you. So hopefully that helps.
4 MR. O'NEILL: Yes. Thank you for that 5 context, and I appreciate all the work that, clearly, 6 went into putting this presentation together and these 7 questions for feedback. So thanks very much.
8 MR. ANDRUKAT: Fantastic. So to reiterate 9 -- and I don't know if we did that during this 10 particular public meeting -- but, you know, we hosted 11 this series of three public meetings here at a 12 particular point in the development of this proposed 13 rule, in that we wanted to get to a point where the 14 staff thought they had a pretty solid preliminary 15 draft of something or thought, if you will, right?
16 But it's also at a point before the staff 17 has presented this to our management for the official 18 concurrence, and then, the follow-on approval process.
19 And the whole point would be to listen and try to hear 20 some additional feedback and see if we want to or need 21 to make any adjustments to what we're about to propose 22 to the management for concurrence, right?
23 And I apologize, it does contradict a 24 little bit what I was saying earlier because some of 25 these questions are coming at you cold, and the formal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 1 response to that won't be until after a proposed rule 2 is published, but any feedback that we do hear is 3 greatly appreciated.
4 Okay. Don, I think your hand is up next.
5 MR. GREGOIRE: Thank you. I think I want 6 to save this (audio interference), but the question 7 here is associated with going to -- certain with that 8 approach for -- specific to fusion industry, but I 9 think it really begs the question is the thresholds in 10 the Schedule C, is there something wrong with that?
11 At first blush, it makes me think that 12 maybe the existing guidance isn't sufficient for, you 13 know, it triggers the emergency response, the 14 emergency plan, and the evaluation of dose. But, you 15 know, initial thoughts are -- is that -- and I think 16 Andrew Holland (audio interference) is that there's a 17 number of fusion companies that are planning (audio 18 interference) or have very minimum quantities of this.
19 And to imply that all fusion systems need to submit, 20 you know, this dose evaluation over the emergency 21 response plans.
22 It just seems to beg the question, is 23 there something wrong with the existing thresholds and 24 their regulations? And that's just the initial, given 25 the short time that (audio interference) this is in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 1 question, as far as the risk. And so no question 2 there, but just commenting. Thank you.
3 MS. ROSALES-COOPER: Thank you for that.
4 And just for confirmation, from the EP 5 staff point of view, we were not seeing that there's 6 anything wrong with the thresholds in Schedule C.
7 We're looking at it specifically for what we've been 8 tasked, and that is to have a framework to license 9 fusion systems. That's where our point of view is 10 coming from. But thank you for that feedback.
11 MR. SAENZ: I know I spoke on this a 12 little bit earlier, but I just wanted to add a little 13 bit more context that I think would be really helpful.
14 So this was actually a very important 15 point back when we were working on the recommendation 16 to the Commission, and it was seen as a benefit when 17 we were trying to decide whether to go a Part 50 18 approach or a Part 30 approach. And it was seen as a 19 benefit that Part 30 did have this scaling approach 20 for some of these potentially very burdensome 21 requirements, when you consider the full scope of 22 facilities.
23 And then, I guess, when we think about the 24 consequences of something that would be as broad as 25 requiring this for all fusion system applicants, this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 1 would have significant consequences for the workload 2 required to review what could be a very simple fusion 3 device used for well logging, for example, or, you 4 know, a wide variety of applications where the hazard 5 would be well below, the quantities would be well 6 below the Schedule C quantities.
7 And requiring that would be burdensome on 8 the staff to review those additional things and would 9 be burdensome on the licensees or applicants, and 10 would also have impacts for the way that we already 11 have schedules for fees. You know, we may have to, 12 then, review those schedules for fees for the 13 additional review time.
14 So the consequences here are very real to 15 us, very significant. We think that this is something 16 that should be thought about extremely carefully, if 17 that's moved forward. And it was very intentional 18 that we didn't do something for all fusion systems.
19 So I think, you know, just for a little 20 bit more context, there was some discussion around 21 that. Then, it was backed off to, oh, do we say 22 fusion energy systems? And then it was also, well, 23 then, that's not technology-neutral; some fusion 24 systems may be used for thermal heat. And we kind of 25 went through that.
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72 1 And part of it, too, was, you know, what 2 somebody, pro -- typically thinks of as the more 3 hazardous fusion system where you would have an EP 4 plant consideration, it's already captured in that 5 Schedule C table.
6 So really the value would be very limited.
7 It's hard for me to imagine a fusion system where, you 8 know, we would get the benefit of having the emergency 9 plan, where we wouldn't have one otherwise, versus all 10 the things that would be caught up in this that 11 shouldn't be from a risk-informed point of view.
12 So I hope that extra color helps, but I 13 guess that is a scenario where I have strong feelings, 14 and I think we should seriously think about this.
15 Thank you.
16 MS. ROSALES-COOPER: Well, thank you very 17 much for that.
18 MR. ANDRUKAT: Okay. Let's see. I don't 19 see any other hands raised.
20 So, okay. So we move on to No. 3.
21 MS. ROSALES-COOPER: And, again, this gets 22 to making sure that our regulations are clear, and 23 especially with what the requirements are. There is 24 some who operate right now in a paradigm that thinks 25 that, if there is no need for an offsite EP plan, that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 1 there is no EP requirements, and that's not what's in 2 the NRC's regulatory framework.
3 So we just want to make sure that it's 4 clear, regardless of what it's called, whether it's 5 called an E-plan or whether it's called the emergency 6 procedures, you know, for onsite, protecting the 7 workers onsite, or anything that may go offsite, the 8 intent of this is we are considering whether or not to 9 clearly specify these requirements.
10 MR. ANDRUKAT: Diego, go ahead, sir.
11 MR. SAENZ: Okay. I wasn't hearing 12 anybody else, so I thought I would jump in here.
13 So I think from our point of view, I think 14 we've had a lot of success with the rule as written, 15 having licensees do the coordination with local law 16 enforcement agencies, or LLEAs, and fire and medical.
17 We feel like we've had the tools to require licensees 18 to do that.
19 So I guess I don't necessarily see that 20 there's a problem that needs fixing here. So that 21 would be the comment.
22 MS. ROSALES-COOPER: Thank you.
23 MR. LIPKA: Hello. Matthew Lipka from 24 TAE. And thanks so much for this presentation, and, 25 you know, echo all the comments on -- that we've had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
74 1 throughout this emergency preparedness question.
2 My comment is just that, as we think about 3 preparing our application, we're really looking at 4 these NUREG guidances. And so to the degree this is 5 already covered in the guidance with depth, that 6 should be sufficient for the preparation of the 7 application and the existing proposed regulatory text 8 or preliminary proposed regulatory text, but the 9 rulemaking is clear, at least from our reading of 10 what's available to date.
11 MS. ROSALES-COOPER: Thank you.
12 MR. ANDRUKAT: All right. Fantastic.
13 I'll give it another minute. So far, I do not see 14 another hand raised. Okay.
15 Okay. Let's go ahead and move on. Of 16 course, we can always come back to these, if we need 17 to. Let's go ahead, and speaking of topics, we have 18 Mr. Duane White back with us. He's the gentleman that 19 gave the materials security presentation. I know we 20 had some questions earlier on from the attendees on 21 security, but if we have any other security questions, 22 please feel free to ask.
23 Okay. So far, I'm not seeing any. Okay.
24 With that, is there anything else for the 25 topics today? Any other questions, feedback, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 1 suggestions?
2 And I will ask another question, but to 3 the attendees. This concludes our series of three 4 public meetings that we had planned for this stage of 5 the proposed rule development.
6 But I wanted to ask the attendees if any 7 additional public meetings should be held and if 8 there's any specific topics. Again, this would be, 9 for this time in the development, this would be before 10 the proposed rule goes to concurrence, before the 11 proposed rule is published, again assuming the 12 Commission approves the proposed rule.
13 So I welcome any feedback that we can kind 14 of take back and consider for additional public 15 meetings, as well as topics. And I see Andrew, Andrew 16 Holland, has his hand up.
17 MR. HOLLAND: Hi. Yes, thank you. We, as 18 the FIA members, we may have something to submit in 19 writing in the coming weeks, and you may see a letter 20 come through.
21 So we wouldn't close out the idea.
22 Perhaps not another one of these virtual meetings, but 23 we think there may be some value in more of a public 24 workshop format, where NRC staff and members of the 25 industry and the public can get together and discuss NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 1 some of these things in detail. Because it does seem 2 like there are some open questions that are more 3 technical in nature perhaps than previous regulatory 4 engagements over the last several years.
5 So we would consider suggesting perhaps in 6 the future a more kind of engaged workshop-type 7 format, where there could be give-and-take by 8 stakeholders, members of the industry, and NRC staff 9 in the future.
10 MR. ANDRUKAT: Fantastic. Andrew, did you 11 have any particular example, topic examples?
12 MR. HOLLAND: Well, we actually think some 13 of the topics here covered today are of particular 14 interest in important waste management, emergency 15 preparedness, tritium, security. These sorts of 16 things are more technical in nature and perhaps less 17 into the legal weeds and more into the topics on that.
18 We'll be able to say more specific and 19 coming soon, but we do think it would be important to 20 have an in-depth discussion on these technical topics.
21 MR. ANDRUKAT: Okay. Thank you. I 22 appreciate that. Okay. Oh, Patrick, go ahead, sir.
23 MR. PATRICK WHITE: Yes, Patrick White, 24 CATF. Yes, so I would just second. I think there are 25 opportunities for more of these collaborative NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
77 1 workshops, potentially on some of these technical 2 issues that might not be in the rule text, but might, 3 ultimately, become kind of key parts of guidance, just 4 to figure out kind of where is there potential 5 alignment and where are there questions that 6 discussions between stakeholders can help resolve.
7 I think on topics, specifically, like on 8 question two around emergency preparedness, this idea 9 of a maximum dose evaluation. Having feedback and 10 experience from NRC staff, from industry participants, 11 from external stakeholders, and other experts, could 12 be really helpful with trying to get kind of better 13 alignment on what the expectations are going to be and 14 what the scope of either topics where there are best 15 practices or topics where more work is needed could be 16 really helpful.
17 So I think it's kind of NRC staff working 18 through some of the guidance over the next year, 19 trying to identify some of those topics as 20 opportunities for public meetings or public workshops, 21 I think could be very helpful.
22 MR. ANDRUKAT: Okay. Fantastic. Auggie?
23 MR. ONG: Hi. Sorry.
24 MR. ANDRUKAT: There you go.
25 MR. ONG: I had a hard time of unmuting my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 1 mic. That being said, thank you very much for the 2 presentation. It has been very helpful.
3 My question to you --
4 MR. ANDRUKAT: Sorry, Auggie. Sorry.
5 MR. ONG: Yes?
6 MR. ANDRUKAT: Do you mind just restating 7 your name and your affiliation real quick?
8 MR. ONG: Yes. Hi. I'm sorry.
9 MR. ANDRUKAT: Sure.
10 MR. ONG: My name is Auggie Ong. I'm the 11 administrator for our program in New Hampshire.
12 So that being said, my question to you is, 13 will NRC provide refresher training for license 14 reviewers and for inspectors dealing with these new 15 fusion device industries?
16 MR. DUNCAN WHITE: I'll take this one, 17 Dennis. The short answer is an obvious yes. We have 18 actually hosted a seminar yesterday and on Tuesday --
19 MR. ONG: Yes.
20 MR. DUNCAN WHITE: -- with MIT. That's 21 part of it. That's been recorded and available.
22 They're available to Agreement State and state folks, 23 and NRC folks, of course.
24 And, yes, we are thinking about having to 25 plan, you know, training, once we have some guidance, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 1 you know, some draft guidance. And we will be rolling 2 that out as we get closer to implementation time. So, 3 yes, that is absolutely in the mix.
4 MR. ONG: Okay. Thank you, Duncan.
5 MR. ANDRUKAT: Okay. Let's see. Andrew, 6 Andrew Proffitt this time. Go ahead, sir.
7 MR. PROFFITT: Yes, Andrew Proffitt, 8 Helion Energy. Back to your future engagement 9 question, Dennis, I guess maybe sort of twofold.
10 I think it could be helpful to maybe do 11 one more near-term meeting, maybe in this format, 12 maybe in another, but where stakeholders could sort of 13 come in and present sort of on their views on this 14 suite of meetings, sort of all three of these 15 meetings, after we've had a little bit of time to 16 digest and go back and think about it, you know, the 17 language, the guidance development, and this specific 18 topic. So if we went into a little more detail here, 19 I mean, we would certainly be interested in providing 20 a bit more feedback, you know, coherently and as we've 21 had time to digest. We would certainly welcome that 22 opportunity sometime in the near-term.
23 And then I definitely want to echo Andrew 24 Holland's pitch and Patrick mentioned it, I think, as 25 well, on workshops and being able to work through some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 1 of these more technical topics, especially related to 2 the guidance and some of the topics covered today. I 3 mean, I think there's still a lot to be done in the 4 coming years on those topics, and I think we've 5 certainly built some good momentum of engagement here 6 through this series of public meetings. And we don't 7 want to sort of lose that, as we're working towards 8 the staff proposing, you know, not finalizing, but 9 getting to the preliminary ruling to provide to the 10 Commission next fall. So, I mean, we have almost a 11 year between now and then.
12 So I think it would be helpful to keep the 13 momentum going of engagement. As we saw today, we've 14 seen some differences even from just the October-to-15 November timeframe now of some differences in the 16 thinking and updates to the languages, and differences 17 in maybe what guidance would look like. So I think we 18 would certainly encourage engagement to continue over 19 the coming months. Thanks, Dennis.
20 MR. ANDRUKAT: Awesome. Thank you, 21 Andrew. Very good points.
22 So just kind of a reminder, or for those 23 that may or may not be familiar, Andrew kind of 24 pointed it out. So we have a due date to submit the 25 proposed rule package, which would include the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
81 1 preliminary draft guidance, to the Commission in 2 September of 2024.
3 Now, I think a lot of folks might be 4 familiar with our internal processes and kind of what 5 is involved in that. It's, more specifically, the 6 concurrence process here internally.
7 And so I just want to make the attendees 8 aware that, once it's in concurrence, which would be 9 several months before September of next year, that 10 really hinders the staff's ability to host a public 11 meeting. I don't want to automatically take that off 12 the table, but it really hinders.
13 So the timeframe, assuming we do have any 14 additional, say, whether it's a public meeting or 15 whether it's a workshop format, would, more than 16 likely, be sometime in probably the December, January, 17 February timeframe. And again, those are 18 guesstimates.
19 But I don't want folks thinking that, you 20 know, maybe it's June of next year; it's well before 21 September, maybe there's time for a public meeting, 22 and that may not necessarily be the case for the staff 23 here, just because of our process.
24 But very good points. Very good feedback.
25 I don't see any other hands raised. Let's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 1 see here. Okay. So I'll give it one more shot. Any 2 last takers for any of the topics discussed today?
3 Any other feedback, questions, suggestions for the 4 staff?
5 Okay. Okay. I'm not seeing any. I'll go 6 ahead and move on here. So like I said before, we 7 kind of just talked about these two topics here.
8 Upcoming public meetings or workshops is still to be 9 determined.
10 So we heard the feedback. We'll take that 11 back. We'll talk amongst each other and see what we 12 can do with setting up any additional public meetings.
13 And then, like I said before, the proposed 14 rule package, as well as the draft guidance, is due to 15 the Commission in, it's actually September of 2024.
16 And I think we're at the last slide. So 17 the last slide, thank you very much. I appreciate 18 everyone who attended.
19 Many thanks to the presenters and many 20 thanks to the discussions from the attendees, and as 21 well as to the other stakeholders for taking the time 22 to attend today.
23 In the chat window, probably towards the 24 beginning of the meeting, are some various ML numbers, 25 including for the presentation. You can see the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 1 presentation ML number on the slide here. There are 2 additional links with ADAMS accession numbers in the 3 chat for your convenience.
4 And as always for any of our public 5 meetings here at the NRC, we have the public meeting 6 feedback forms. And at 4:01 p.m. Eastern time, you 7 should be able to see a feedback form, if you go back 8 to the public meeting notice online. And we welcome 9 any feedback from you.
10 And again, this is feedback on the public 11 meeting process and how did the public meeting go.
12 It is not feedback for the content or topics. That's 13 separate.
14 All right. And let's do one last double-15 check. I don't see anything. So, with that, I will 16 conclude this meeting for today. Thank you, guys.
17 (Whereupon, the above-entitled matter went 18 off the record at 3:01 p.m.)
19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com