ML23328A016

M231116: Transcript - Briefing on Region I Activities and External Engagement

ML23328A016
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Issue date:	11/16/2023
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION

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BRIEFING ON REGION I ACTIVITIES AND EXTERNAL ENGAGEMENT

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THURSDAY, NOVEMBER 16, 2023

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The Commission met in the Market and Broad Conference Room, King of Prussia, Pennsylvania, at 9:00 a.m. EST, Christopher T.

Hanson, Chair, presiding.

COMMISSION MEMBERS:

CHRISTOPHER T. HANSON, Chair DAVID A. WRIGHT, Commissioner ANNIE CAPUTO, Commissioner BRADLEY R. CROWELL, Commissioner ALSO PRESENT:

BROOKE CLARK, General Counsel CARRIE SAFFORD, Secretary of the Commission

2 EXTERNAL PANELISTS:

SARAH ABRAMSON, Executive Director, C-10 Research and Education Foundation THOMAS CONGDON, Executive Deputy, New York State Department of Public Service, Chair, Indian Point Decommissioning Oversight Board MATTHEW HERR, Senior Vice President of Mid-Atlantic Operations, Constellation Energy JEFF SEMANCIK, Director, Radiation Division, Connecticut Department of Energy and Environmental Protection MARCO TORRES, Radiation Safety Officer, Baxter International Corporation NRC STAFF:

ELIZABETH ANDREWS, Technical Assistant DANIEL COLLINS, Deputy Regional Administrator DANIEL DORMAN, Executive Director of Operations FARRAH GASKINS, Regional State Agreements Officer MELVIN GRAY, Chief, Engineering Branch 1 JASON SCHUSSLER, Senior Resident Inspector

3 1 PROCEEDINGS 2 (9:00 a.m.)

3 CHAIR HANSON: Good morning, everyone. I convene 4 the Nuclear Regulatory Commissions public meeting for the purpose of 5 hearing an overview of Region I activities, as well as hearing views from 6 external stakeholders regarding communications and interactions with the 7 NRC. This is our second off site Commission meeting. We did one about 18 8 months ago in New Mexico, and previous to that it had been more than 40 9 years, so I think we're -- like a lot of things at the NRC, we're headed in the 10 right direction on some of these things.

11 I think it's good for the Commission as a group to get out of 12 headquarters, and see not only the regional space, but also hear about 13 some region-specific issues that may not come up in quite such a focused 14 way in other kinds of settings. So, I want to thank Dan, and Blake, and 15 Dave, and Mary, and everyone else, the entire team in Region I for hosting 16 us today, for making all of the systems work the way they're supposed to.

17 I want to thank SECY for all the advanced work on this as 18 well. I know there's a lot of effort in making sure these things run smoothly, 19 and we really appreciate it. So, we'll hear from two panels today, first a 20 panel of external stakeholders who will speak on a wide range of topics.

21 Then we'll take a short break, then we'll hear from the NRC staff about 22 various activities in Region I.

23 Before we start, I'll ask my colleagues if they have any 24 remarks they'd like to make. Okay, as a public service announcement I

4 1 learned I had a little bit of a dry run with the microphones, you'll see I'm 2 speaking directly into the microphone, it is very close, and there's a button of 3 course on there too, and I think you're looking for the green light.

4 So, just as a reminder, so that everybody can hear us both 5 online and in the back. See, there's Tony back there, if Tony can hear us 6 then we know we're in good shape, we'll get the thumbs up from him. So, 7 with that I'm going to hand it over. We're going to start with Jeff Semancik, 8 he's the director of the Radiation Division for the Connecticut Department of 9 Energy and Environmental Protection. So, Jeff, over to you.

10 MR. SEMANCIK: Thank you. Good morning, Chairman 11 Hanson, Commissioners Caputo, Crowell, and Wright. I thank you for the 12 opportunity to discuss Connecticut's perspective on becoming an agreement 13 state. Get the slides up please. Next slide. I usually get two main 14 questions, why, and why now?

15 So, with respect to why, Connecticut views becoming an 16 agreement state as a way to improve safety and ensure regulatory and 17 programmatic compatibility and consistency with both our federal and our 18 regional partners. This benefits the licensee community by eliminating dual 19 regulation, especially in the medical community where state inspectors have 20 performed inspections for machine-based radiation sources, as well as 21 audits for hospital licensure.

22 It also ensures that we are accountable for our 23 performance, not only to the National Materials Program through the periodic 24 IMPEPs, but also to the public and licensees through agency and state

5 1 leadership. Fiscal impacts are also an important driver as we project about 1 2 million dollars in direct budget impact after accounting for program costs.

3 As for why now, new leadership was an opportunity to 4 remake our case, as we were able to discuss the proposal with new agency 5 leadership and a new governor. Interestingly enough, the map that's 6 provided up there was kind of an important part of our communications, 7 because it kind of clearly showed where we were as an outlier, especially in 8 the region to our leadership.

9 Next slide please. Once the letter of intent was signed, we 10 embarked on an effort to educate our legislators, the regulated community, 11 and our other stakeholders on the benefits and process of becoming an 12 agreement state. We used a series of single page information sheets like 13 the one you see up here to ensure we communicated a consistent message.

14 Through this outreach we were able to identify and 15 address some concerns and misunderstandings. For example, some of our 16 Tribal partners were concerned that this could lead to a storage of spent 17 nuclear fuel on their lands and several of our legislatures were concerned 18 that we were going to regulate Millstone Nuclear Power Station.

19 From these interactions we modified our messaging to 20 clearly describe not only what an agreement state is, but just as importantly 21 what an agreement state is not. Early outreach to our power users, large 22 universities, hospital networks, and professional associations, as well as 23 large industrial customers also provided us input in program direction.

24 In many cases we met with the radiation safety

6 1 committees. Through these interactions we were able to make some key 2 decisions, for example the licensees were the ones that strongly encouraged 3 us to incorporate NRC regulations by reference, and we modified our 4 process plan accordingly. We also recognized the need to reach out to our 5 internal stakeholders in the agency.

6 Next slide please. The letter of intent, as you know, is a 7 milestone that kicks off support from the NRC staff, including assignment of 8 a project manager and participation in radioactive materials training. We are 9 fortunate to have Duncan White, and the NRC team from headquarters 10 supporting us including Monica Ford and Farrah Gaskins, and other staff 11 from Region I.

12 From the beginning, the NRC team reinforced the long 13 poles, which are legislation, regulation, and staff qualifications, and this 14 helped focus our efforts to achieving these milestones. From the 15 Connecticut side we did assign -- we added one new staff member, and he's 16 the lead for incorporating our agreement state process, Brandon Graber is a 17 CHP that we brought in.

18 Monthly project meetings have been helpful to ensure 19 progress and resolve issues. In addition, NRC has provided us in-process 20 reviews of procedures, regulations, and other program elements to ensure --

21 to help us with midcourse corrections. Finally, we have benchmarked recent 22 agreement state applications such as Vermont, and listened in on IMPEP 23 meetings to build this operating experience into our program and 24 preparations.

7 1 Next slide. I would not have embarked on this project 2 without an exceptionally experienced team. We have a diverse team with a 3 background maintaining our own NRC license, under which we conduct 4 training for first responders with radioactive sources, retrieve risk-significant 5 orphan sources, and remediate contaminated facilities.

6 My staff has not only participated in oversight of complex 7 decommissioning projects but has also performed remediation work under 8 our license. We have inspection experience with machine-based sources 9 and respond to about 150 radiation-related calls annually. Our diverse staff 10 of 12, we have qualified almost half in the materials program.

11 This includes a certified health physicist, an experienced 12 license reviewer inspector from another agreement state, and personnel with 13 industry experience in medical, industrial, and academic fields and 14 management. We made the decision to build this much bench strength in 15 after a discussion with other states noting that staffing has been an issue in 16 several other states.

17 This is only possible with excellent training and support 18 provided by the NRC through the National Materials Program, including over 19 1850 hours0.0214 days <br />0.514 hours <br />0.00306 weeks <br />7.03925e-4 months <br /> of inspector training, and over 460 hours0.00532 days <br />0.128 hours <br />7.60582e-4 weeks <br />1.7503e-4 months <br /> of experience 20 accompanying Region I inspectors. I'd also like to highlight a few benefits of 21 the process that we didn't really anticipate but did want to note.

22 First, in addition to the training benefit provided by 23 accompanying NRC inspectors, these have provided an excellent 24 opportunity for us to engage with licensee personnel and management, and

8 1 for us to demonstrate our readiness. The agreement state process has also 2 served as a driver for us to update our regulations, which are currently still 3 based on ICRP 2, and over 40 years old, and for us to fully vet and learn our 4 statutory authorities.

5 We're building processes that better integrate with those 6 already in the agency and ensuring our competencies in them. Next slide 7 please. Key to success includes management support of this effort, a solid 8 team and effective project management. While we are supported by the 9 National Materials Program, the only recommendation I would kind of have is 10 maybe for a person from another state that's recently gone through the 11 program would be nice to be assigned as part of the project team.

12 We've kind of reached out to Vermont on our own, but that 13 would be an improvement. Next slide. While we've been successful so far, 14 attracting and retaining health physics talent is something I'm always 15 working on. State regulatory processes, which involve additional reviews not 16 part of federal rule making will require attention to maintain compatibility.

17 Finally, in the ever more electronic world, I expect 18 increasing integration of IT into our processes, and across state programs as 19 stakeholders look for one-stop shopping. Likewise evolving IT security 20 requirements must be considered in any application, in any applications 21 compliance must be a priority for deployments.

22 Last slide please. So, I believe in the end, the end crowns 23 the work. And that becoming an agreement state actually gives us value to 24 the labor that produces it. Thank you.

9 1 CHAIR HANSON: Thank you very much for that 2 presentation. Next we'll hear from Tom Congdon, he's the executive deputy 3 for the Department of Public Service and chair for the state of New York on 4 the Indian Point Decommissioning Oversight Board.

5 MR. CONGDON: Thank you, Chair. I'm Tom Congdon, 6 the executive deputy of the New York State Department of Public Service, 7 and chair of the Indian Point Decommissioning Oversight Board. Thank you 8 for inviting me to talk about the state role in decommissioning, and NRC's 9 engagement with stakeholders.

10 Next slide please. We view the state's role in 11 decommissioning as applying to any area not already covered by the federal 12 government. This can include local emergency preparedness, work force 13 issues, oversight by a state utility regulator, et cetera. States also play a role 14 when the licensee agrees to subject itself to enhanced state standards.

15 Next slide please. The state also plays an important role in 16 providing a venue for information exchange between all relevant 17 stakeholders and enhancing public awareness and education. Next slide 18 please. In New York, these concepts for the state's role in decommissioning 19 informed our creation of the Indian Point Decommissioning Oversight Board, 20 or DOB in May 2021 shortly after Indian Point permanently ceased 21 operations and was transferred to Holtec.

22 The DOB includes state agencies, all of the state and 23 elected officials who represent the host community, labor leaders, an 24 environmental representative, and an independent technical expert. We

10 1 meet three to six times per year. Our goal is to ensure decommissioning is 2 safe, prompt, and thorough, and to have robust community engagement.

3 Next slide please. We believe that providing a venue for 4 community involvement can help ensure we meet our public interest goals 5 for decommissioning. We have a very active host community, and the state 6 makes a deliberate effort to not only provide information to members of the 7 public, but also to listen carefully, and pull information from the public to 8 identify areas in need of additional focus.

9 Next slide please. Here I'd like to provide some specific 10 examples of what the state's role has looked like in practice. First, as part of 11 the Department of Public Services review of the transfer of Indian Point, we 12 entered an agreement with Holtec and other parties to address several state 13 concerns.

14 For example, the agreement established a requirement for 15 Holtec to maintain minimum decommissioning trust fund balances 16 throughout decommissioning and established an accelerated schedule for 17 transferring spent fuel from the cooling pools to dry cask storage. As the 18 DOB began engaging with the host community we learned that NRC's 19 resident inspector would no longer work at the site full time given the 20 reduced risk profile after the plant ceased operations.

21 While we understand NRC's rationale and understand that 22 NRC continues to periodically perform inspections at the site, many 23 members of the public and their elected representatives, never the less 24 expressed a strong desire for a regulator to be on site on a daily basis. To

11 1 fill that gap, the state hired its own inspector, and Holtec agreed through an 2 MOU to cooperate with the state oversight function.

3 To address community concerns about the co-location of 4 high-pressure gas pipelines in the immediate vicinity of Indian Point, we 5 arranged for external experts to advise us, and we identified best practices 6 for risk mitigation. We facilitated an MOU between Holtec and the pipeline 7 owner to coordinate activities and establish a formal protocol to protect the 8 pipeline.

9 Residents near the plant also expressed concern about 10 dust migration they feared would occur during heavy demolition. The DOB 11 coordinated the local government, which issues building demolition permits, 12 and the state Department of Environmental Conservation, which has 13 regulations pertaining to dust control.

14 From these discussions, we were able to incorporate dust 15 control measures into the local demolition permits, and now we have a local 16 enforcement tool to stop any activity that causes dust migration from the site, 17 and our state inspector monitors compliance on a daily basis. For added 18 protection we also established plans for air monitoring at the fence line, and 19 in the community to identify any potential contamination that is leaving the 20 site during decommissioning.

21 Next slide please. NRC's engagement with the 22 Decommissioning Oversight Board has been excellent. NRC subject matter 23 experts have made numerous presentations to the DOB on a range of 24 issues. The presentations have been clear and have helped broaden an

12 1 understanding of NRC regulations and oversight, as well as the technical 2 aspects of decommissioning.

3 In July, NRC also sent a large group of expert staff to 4 participate in a public forum where there was a candid back and forth directly 5 with our public stakeholders. Next slide. New York greatly appreciates 6 NRC's responsiveness to our meeting invitations, and to our extensive 7 information requests, but there's always room for improvement.

8 Indeed, I have continuously made adjustments to our 9 Decommissioning Oversight Board processes based on the feedback from 10 our stakeholders, and I offer the following for your consideration. While NRC 11 has been terrific in providing timely written responses to our information 12 requests, in some instances the written answers to us have been too 13 general.

14 Some stakeholders then perceive generalized answers as 15 evasive. In my experience NRC staff will engage in follow up to provide us 16 with more detail, especially when attending our meetings. But in my opinion, 17 providing detailed and transparent responses to information requests in the 18 first instance will build more trust with stakeholders.

19 NRC's approach to decommissioning should also be 20 reconsidered. The proposed rule contemplates only relaxing existing 21 regulatory requirements, and that's consistent with NRC's reduced presence 22 at decommissioning sites while the rule making is underway. Rather we 23 believe it should strive to establish a tailored approach to address 24 decommissioning's unique challenges.

13 1 As NRC has seen, public interest in activities can actually 2 go up when plants transition to decommissioning, as was the case with 3 Indian Point. The public is demanding highly protective standards and a 4 strong oversight presence during decommissioning. We have submitted 5 comments in your decommissioning rulemaking that recommends an 6 escalated enforcement approach when there are trends of recurring non-7 compliance at decommissioning sites.

8 I believe it's important for NRC to consider the suggestions 9 made by state partners like New York and complete its rulemaking process 10 for decommissioning as soon as possible. And with that, I'll be looking 11 forward to your questions, thank you.

12 CHAIR HANSON: Thank you very much. Next we'll hear 13 from Sarah Abramson, she's the executive director of C-10 Research and 14 Education Foundation. Sarah?

15 MS. ABRAMSON: Thank you, Chair. Good morning. I am 16 Sarah Abramson, executive director of C-10, we are a nuclear safety 17 advocate near Seabrook Station, and I'm very grateful to the Commission for 18 including me on this panel today to share perspectives as a public 19 stakeholder. Next slide please. We've been delivering on our mission since 20 1991 and have experienced a lot with the NRC in those 32 years.

21 Today I'm going to focus on our current experiences, 22 hoping that the major takeaway is that although we have regulatory and 23 safety concerns, we are appreciative of the improvements that we have seen 24 in NRC communication, and we hope that it continues to evolve in a positive

14 1 way. Next slide please.

2 The 2019 ASR related license amendments were hard won 3 in a formal hearing where C-10 challenged the NRC's approval of NextEra's 4 comparatively weak original ASR mitigation plan. Since then, NextEra has 5 been issued numerous violations for non-compliance. Inspectors have 6 issued only minor and non-cited green violations related to ASR, which carry 7 no timeline requirement for corrective action or consequence.

8 And we understand that this is because of the regulatory 9 structure that dictates this. So, since those situations do not have an 10 operability or safety impact. So, what C-10 is observing is continued non-11 compliance, and long-term languishment of fixes. The Petition Review 12 Board acknowledged those ASR violations were repetitive in its denial of C-13 10's recent 2.206 petition, though the NRC perception was that the violations 14 were not willful.

15 In one example Seabrook failed to identify signs of ASR in 16 a reactor containment area when there were photos present years prior to 17 the inspector's finding of that area, yet those photos did not make it into NRC 18 facing reports. Also the NRC accepted a time line of up to three years from 19 NextEra for their full ASR mitigation plan.

20 Now it has been seven years, and recently NextEra 21 reported it won't be done until 2026, which is 11 years. How does the NRC 22 consider if an omission of photos, or the slow walking of expensive ASR 23 planning are willful acts? Next slide please. C-10 has at time been 24 perplexed by the designation of proprietary when C-10 asks for ASR data

15 1 that was used by an inspector to perform a basic calculation. We were 2 denied on two grounds.

3 One, the inspector's calculation would have been 4 destroyed per an NRC management directive, and two, that ASR cracking 5 index data could be considered proprietary or fodder for NextEra's 6 competitors. We are perplexed by this, thinking basic instrument readings 7 from off the shelf devices fail to fall under security or intellectual property.

8 Overall, this comes back to our perception of a need for 9 more collaboration between NextEra and the NRC, and the outside experts 10 that have careers dedicated to this niche topic of ASR. Sharing raw ASR 11 data can only result in more robust research and mitigation 12 recommendations without infringing on anyone's proprietary models or 13 engineering designs.

14 Furthermore, outside experts cannot offer the NRC 15 anything new to consider in a 2.206, or formal rulemaking petition without 16 such information sharing. Next slide please. C-10 applauds the accessibility 17 and transparency that we receive from NRC resident and reactor inspectors, 18 also some project managers and NRR members who have helped to grow 19 our understanding, which leads to more trust and fewer inane questions from 20 us.

21 Conversely, we felt dismissed in some other NRC 22 channels. In one example, an NRC project manager and I have been 23 engaged in a 13-month email chain related to questions we had following a 24 public ACRS meeting held last April. I have had to resend a written question

16 1 seven times because the PM keeps asking for them to be re-provided each 2 time I inquire for a status update.

3 This feels like subterfuge and gate keeping, compared to 4 the otherwise high accessibility and transparency we receive from 5 inspectors. Next slide please. Of all the stakeholders, it feels like the public 6 has the least access and influence but bears the most risk. The 7 Administrative Procedure Act prescribes a path for public input which C-10 8 did take advantage of in the ASR case.

9 But there is so much informal decision making that impacts 10 us coming from sources such as Management Directives, which certainly 11 don't make it to the Federal Register for public review or comment. If one 12 looked at public attendance rates across all NRC public meetings, the 13 numbers probably aren't high, and I think part of that is a knowledge gap 14 issue.

15 I can personally say that I am aware of two public meetings 16 in 2022 that I wish I had known were happening related to Seabrook Station 17 emergency planning. And having missed them, I could not use the publicly 18 available PowerPoint slides, or one page summary to fully understand in 19 substance what had been discussed. I may have been able to if there had 20 been a full recording or transcript provided. Next slide please.

21 When our community members ask us about safety at 22 Seabrook Station, the first thing I describe are the dedicated and 23 communicative NRC inspectors who live nearby with their families. While we 24 also feel it is the regulatory decisions made at the top that ultimately reflect

17 1 the NRC's priorities. With the old age of Seabrook, similar to most 2 commercial plants in the U.S., we do appreciate the NRC's close monitoring 3 of age-related degradation.

4 We feel strongly that preserving or even increasing 5 emergency plan resources is prudent for this aged and ASR impacted plant, 6 which makes NextEra's proposal to relocate and cut emergency plan 7 resources alarming. And you well know that a structural emergency is not 8 the only consideration. C-10 is concerned about Seabrook's fire safety 9 violations, which are three times more frequent than the average across 10 Region I.

11 Next slide please. The suggestions listed here reflect our 12 hope that we can continue to experience increased accessibility and 13 openness between the NRC and C-10 as a public stakeholder. In just the 14 last few years we have been privileged with one-on-one conversations with 15 both Chair Hanson and former Commissioner Baran related to the ASR 16 issue.

17 An ultimate testament that at the highest level of NRC 18 leadership you're willing to model that ideal. Next slide please. Here I'm 19 simply sharing some relevant NRC insider anecdotes to bring home our 20 belief that open communication with the public is the best path to increased 21 trust. Thank you.

22 CHAIR HANSON: Thank you, Ms. Abramson. Next we'll 23 hear from Matt Herr, he's the senior vice president for Mid-Atlantic 24 Operations at Constellation Energy. Matt?

18 1 MR. HERR: Thank you, Chair Hanson, and the 2 Commissioners, just for the opportunity to come talk to you today a little bit 3 about our interactions in Region I as a licensee. I am Matt Herr, senior vice 4 president at Mid-Atlantic, which means I'm responsible for Peach Bottom, 5 Limerick, and Calvert Cliffs, all in Region I.

6 First off, I'd just like to say overall we have very strong 7 communications in Region I, as well as with our state and local 8 governments. You can go ahead to the next slide. Constellation has three 9 dedicated positions that work closely with the state and local governments, 10 as well as Region I, on everything from awareness of day-to-day operations 11 to understanding of special inspections, giving tours, implementing work 12 force development initiatives, and hosting community information night.

13 You can see on the far right there, that's the Limerick 14 community information night, over 1500 individuals from the local 15 community, as well as government officials attended. And certainly, a great 16 opportunity with the NRC's senior resident in attendance as well to interact 17 with the public, we find those to be a very informative night, as well as you 18 can see with 1500 people being on site, just a tremendous outreach 19 opportunity.

20 This year alone we've given more than 50 tours to local 21 state and federal representatives at our Region I plants. And additionally, 22 our state level representatives in Region I continue to work closely on key 23 stakeholders on legislative as well as regulatory efforts while supporting the 24 community role.

19 1 You can go to the next slide. Just a couple of thoughts on 2 risk insights in the inspection program. From our perspective there is 3 multiple ways the NRC is using risk insights for the inspection program, 4 which has yielded positive benefits. First, from my perspective, the 5 inspection finding review board really provides a framework to obtain 6 regional staff and management agreement on proposed performance 7 deficiencies, and effectively manage actions needed to reach preliminary 8 decisions on the significance of findings that don't initially screen to green.

9 And we've seen very positive benefits from that since it's 10 been implemented. Second, really the NRC's use of risk insights to help 11 focus inspections. Right now, Constellation provides a packet of information 12 to inspectors prior to, which really includes risk insights for applicable 13 hazards, whether they're internal, fire, or et cetera.

14 And then significant structures, systems, components, 15 human actions as well as accident sequences and initiators, which really 16 allows the inspectors then to focus on risk significant areas, and make sure 17 that what's most important to public health and safety is getting the majority 18 of the effort and scrutiny.

19 I would be remiss if I didn't say the interactions with the 20 senior risk analysts during the SDP process has been very good for us in 21 Region I, which really in my perspective has led to increased realism both in 22 our internal models, as well as the NRC models.

23 I would say, I think probably one opportunity to continue to 24 further drive and modernize risk as it pertains to inspections, from my

20 1 perspective, if you think through I'm taking all the corrective action data, 2 performance data, as well as finding and using AI really to help generate 3 additional insights into risk, I think it could help drive even further use of risk 4 insights into the inspection process.

5 Next slide. Transitioning to digital instrumentation and 6 control, something that we're very excited about at Limerick with the pilot 7 program really converting all of our RPS, as well as N quad S systems to 8 digital is well underway at this point; we submitted the license amendment 9 request in September, and several supplements since that time.

10 I might say a couple of things from a learning perspective 11 as we're going through this project right now. The extensive pre-submittal 12 meetings were very effective, we've had about 12 to this point, which helps 13 build alignment, as well as understanding for us on key decision points for 14 the NRC and making sure that we're keeping folks very up to date.

15 Second, really the audit open items process has been 16 helpful to resolve issues efficiently. Really allows us to address questions as 17 part of the submittal, rather than relying on RAIs, and has significantly 18 reduced the number of RAIs as part of the process. And then ongoing 19 communications with the NRC project managers have been very strong to 20 this point, keeping very open lines of dialogue has been very important.

21 I think one thing we're learning that we're likely going to 22 have to make sure we're taking a closer look at as we move forward is clarity 23 on human factors evaluation as part of the digital projects. Right now, not 24 currently -- interim staff guidance isn't totally clear on this, so it leaves some

21 1 interpretation as to which NUREG is going to be used to do the evaluation.

2 And I guess in my perspective, or our perspective, neither 3 of the options is efficient or predictable. So, helping to develop a more 4 defined pathway for the human factors evaluation with the alternative review 5 framework will be helpful for us moving forward. We are going to be 6 providing Region I with a high-level milestone schedule to facilitate planning 7 and observations.

8 Just recognizing that this is going to be first of a kind and 9 may take several months as we work our way through it. That ends my 10 presentation, thanks.

11 CHAIR HANSON: Thank you, Mr. Herr, I really appreciate 12 that. Next, and last, but not least, we'll hear from Mr. Marco Torres. He's a 13 sterilization principal engineer and the radiation safety officer at Baxter 14 Healthcare Corporation. Mr. Torres?

15 MR. TORRES: Good morning, Chair. Thank you for all 16 the different Commission members, also I really thank you for the invitation 17 to the meeting. So, basically we'll be presenting the role of Baxter in the 18 island, and also how is the direction with the agency. Next slide please.

19 Baxter has different locations, and they basically provide different types of 20 products.

21 All of them are directly associated to the patient treatment 22 to sustain and save lives. So, we have different plants across the island that 23 have different substructures and different types of products for anesthesia, 24 IV solution bags. All different devices that are basically the first units that we

22 1 receive any time we reach a hospital.

2 So, for having these types of products into the market, also 3 at the end to the patient, we need to put them into a sterile way, so we use 4 the gamma radiation for those products. So, summarizing the operations, 5 we have different types of resins and materials in pellets, that we transform 6 those pellets and materials into finite products.

7 We have different sets of assembly, different processes to 8 allow us to produce those types of products based on the different 9 customers' needs. And then we also add in a new line of solutions for the 10 operation, and also provide an extra capacity for external customers to other 11 different companies in the island who also need that sterilization service as 12 well for providing their product to the market.

13 So, next slide please. Okay, so Aibonito started operation 14 back in 1976, but for the sterilization of the product they used ethylene oxide, 15 a chamber for that. Then we switched to gamma in 1983, so a gamma 16 irradiator was constructed, also built by the NRC back in 1983, and that 17 should basically summarize the type of station that we have there.

18 So, it's what we call the wet storage induced for gamma 19 category type. So, we receive most of our products, as mentioned before, 20 from all the different Baxter plants, and also from external customers in 21 boxes. We put in those bins, or containers, then in the conveyor system 22 they move across the system, and then get exposure by the cobalt-60 23 radiation source.

24 And based on that activity of the source, we calculate an

23 1 exposure time that assures that the product is completely sterile and is safe 2 for use to the patient. So, we have been also licensed into ISO 13485 and 3 11137 allowing us to produce a marketing dose and externalize our medical 4 devices and products.

5 Next slide please. And our interaction with the NRC has 6 been great since back in 1983. We have right now, our little gamma 7 irradiators in the Baxter network, we have one in Aibonito, and the other one 8 is in Singapore. So, the first thing that we need to have in place is the 9 license requirements to be in compliance all the time.

10 Also having that radiation safety program also in 11 compliance, numbered parts 36 and 37, parts that we need to comply as well 12 into the system, and also have that responsibility in terms of the community 13 and security aspect for having that largest irradiator in the Caribbean. So, in 14 the Caribbean and also in the community, it's to maintain that operation 15 safely so the different operations that we have, and also as well for the 16 community, and the environment.

17 So, that's our biggest responsibility within the company.

18 And also having this in compliance allows us to be having the products into 19 the market, and at the end, to the patients, our principal customers. So, the 20 integration is to have this compliance in terms of the interaction that we have 21 with the agency in terms of material transportation.

22 Our license allows us to have the sources in using that in 23 our facility. And also have the coordination with the supplier to do the 24 different types of removal, the decommission of materials, siting new

24 1 sources (audio interference) to recharge or reload the system. We also have 2 this open communication with the agency, knowing that Puerto Rico is in the 3 middle of the Caribbean, especially when we have different weather events, 4 different earthquakes or the hurricanes.

5 So, the agency is basically our first point of contact for all 6 the different protocols and systems that we have in place for ensuring safety 7 at all time. Also it's very, as we engrained in the recent years, when we 8 have to go into the equipment upgrades, or do improvements based on the 9 recommendations made by the supplier.

10 So, they are our first point of contact to discuss the types 11 of modification or improvement to the system that all the time we need to 12 make sure we are in compliance with the license and the operation. We have 13 been receiving the audits, inspections, as part of the routine process, and 14 also communicating with the agency any changes that are needed into the 15 process.

16 We also have been serving as a place of receiving visitors 17 and training related activities. So, we can have the facility as a benchmark 18 location for any inspector or any local agency or part of the community that 19 we have for safety related response. So, we can go to the facility and see, 20 and get a knowledge of what are the reasons, what we have been doing in 21 Aibonito, and that's a great experience with the different people.

22 And I also thank the NRC for supporting us in that activity.

23 So, that's basically my last slide, thank you.

24 CHAIR HANSON: Thank you very much, Mr. Torres.

25 1 We're going to start off questions this morning with Commissioner Wright.

2 COMMISSIONER WRIGHT: Thank you, Chair, and good 3 morning. Thank you for your presentations this morning. I'm really happy to 4 be here myself, back from Ghana, and that was a week ago today, right?

5 And I look forward to getting out from the office at headquarters and doing 6 meetings like this. We don't get to do a lot of these, I think we do basically 7 now one a year, we've done it, right?

8 So, it's a lot of fun just to come out and hear from you 9 here, to be in front of Region I is great, because it's fun to be in person, I just 10 love being here. And this, for me, comes on the heels of a couple of days in 11 Pennsylvania here where yesterday I had the pleasure of spending a full day 12 at Peach Bottom doing what I call my resident for a day program.

13 And I go, I started it this year, and literally I spend the 14 whole day shadowing and doing what the resident inspectors do from the 15 time they get to work in the early morning, and sometimes it's pretty dog 16 gone early, and spend the whole day with them. I do what they do each day, 17 and it gives you a really good, it puts things in a different context for you, 18 right?

19 You kind of get to really appreciate what they do, and how 20 they interact with the licensee, and how important that trust is, and how it's 21 built and maintained. So, they do a really, really good job. And so, for me it 22 kind of puts the plants behind the policy, and you kind of understand it. So, 23 a huge shout out to Scott Rutenkroger, and also Corey Dukehart, who were 24 there yesterday with me, and they were awesome.

26 1 And I appreciate everything that they do even more. So, 2 with that, I'll talk about that a little more in the next panel, but I want to shift 3 to some questions here now. So, Matt, good to see you. Since I just talked 4 about Peach Bottom, I thought I would touch with you on a couple of things 5 that you mentioned, and then take us in a different direction as well.

6 So, first you mentioned some of the benefits of risk 7 informed decision making, and I'd like to dive a little deeper here. I'm 8 interested in your perspectives regarding some of the risk informed 9 decisions, initiatives that Constellation is implementing. For instance, you 10 talked about categorization and treatment of SSCs, risk informed completion 11 times.

12 I'm interested to hear not only about how the LAR process 13 went, but also are y'all seeing the benefits of those initiatives now that you're 14 implementing them? And are they doing for you what you thought they 15 would?

16 MR. HERR: Yeah, great question. I'll hit it with two parts.

17 First, risk informed completion time, where essentially almost every one of 18 our sites in Constellation has implemented them. We've got three that are 19 still in the process at this point. So, from the LAR standpoint, no issues or 20 concerns, and most are through it already.

21 From the implementation of risk informed completion time, 22 I think we're seeing very good benefits to this point. One it allows, I think a 23 more thoughtful response to an issue, being able to extend certain LCOs 24 that have minimal risk impact on the power plan from planning parts, as well

27 1 as a thoughtful extended condition review I think allows some additional 2 response time.

3 And that is safer for the individual, safer for the power 4 plant, and allows operators confidence in where we're going. From the 5 50.69 I think we're seeing good benefits, but I'm not sure we've realized the 6 full potential yet. I think there's still a lot of learning on our part on how to 7 fully capitalize on some of the opportunities there.

8 So, I think that's something we're continuing to learn from 9 others in the industry, as well as our own fleet, continuing to share some 10 opportunities. So, good benefits, but I'm not sure we've maximized it the 11 same way we have in the risk informed completion time.

12 COMMISSIONER WRIGHT: Okay, you also mentioned 13 the digital modernization project that's underway at Limerick. And that area 14 of human factors presents an opportunity for improvement, right? I'm 15 interested in whether or not you think this, or any other area is a regulatory 16 gap per se, or if it's more of a question of needing more guidance to be 17 clarified or developed.

18 MR. HERR: Yeah, at this point I think it's clarification and 19 guidance as part of the digital modernization project, to make sure it's clear 20 on how to best implement the human factors evaluation with a digital project.

21 So, I don't think it's a gap per se, but I think if we don't change it, it's going to 22 complicate future implementation of digital projects that will make it more 23 challenging for folks coming after us.

24 COMMISSIONER WRIGHT: Okay. So, I'm going to stay

28 1 with you one more question. So, I'm going to go in a little bit of a different 2 direction here. Back in March at the RIC, I was fortunate to have you on a 3 technical session, well, I had your colleague Eliot Frick, and they gave a 4 presentation about the hydrogen project at Nine Mile Point.

5 And I believe that this is the first of its kind in the country. I 6 also know that also you were awarded some DOE money for this hydrogen 7 hub project. Can you give me a little bit of an update on how these projects 8 are going?

9 MR. HERR: Yeah, the Nine Mile project is implemented, 10 it's demonstrating its ability, on a scale of what we're talking about, it's very 11 small, we're talking one megawatt production of hydrogen, which is 12 demonstrated to be functional and no real challenges there. Obviously a lot 13 of learnings we'll capture going forward.

14 But then in the Midwest with the hydrogen hub award that 15 we were granted, a lot of work is already underway at our LaSalle Station, 16 building out that behind-the-meter production to be able to support the hub, 17 and there's going to be a lot of work over the next couple of years. It's so far 18 going well, but a tremendous amount of work in front of us to make sure that 19 we demonstrate that it's going to work on a much larger scale.

20 COMMISSIONER WRIGHT: Okay, thank you so much.

21 Jeff, good to see you. I first want to commend you for all the work you're 22 doing to facilitate Connecticut becoming an agreement state, and your work 23 in everything associated with that I really appreciate. I know it's not easy 24 work, it's not fast work, but it's a work of passion and love, and I know you

29 1 have that, and I appreciate you for it.

2 MR. SEMANCIK: Thank you.

3 COMMISSIONER WRIGHT: You noted that you're having 4 some issues with staffing, and I know this is an issue that agreement states 5 are all having across the country. Is there anything that the NRC can be 6 doing to better support the states with this endeavor. And do you feel like 7 you're supported in this effort?

8 MR. SEMANCIK: Yeah, I think I'm supported, and what I 9 think is important to recognize is with the staffing, a lot of it is going to be 10 training we provide, vice we hire. So, continued support for the materials 11 training program, and continued support to improve that pipeline just in the 12 bandwidth of the number of people we can get through it, because a lot of 13 the states are going through it.

14 So, for example, in Connecticut we have job classifications 15 for radiation control physicists, although the ones I hired are very good and 16 I'm very happy that we got them, I couldn't get the number I wanted. And so, 17 now we've moved over to a different job classification to try to bring people in 18 with an environmental analyst background, and then train them up to be 19 radiation folks.

20 And the training you provide is very critical for that, and so 21 anything we can do to continue that training, and then like I said, improve the 22 bandwidth of that. Just yesterday I was at a meeting with the New England 23 states, and all the directors kind of said the same thing, it's an 18 month kind 24 of process to get people qualified, and we're all losing people kind of in a

30 1 retirement wave.

2 So, anything we can do to expedite that, some courses 3 have moved online, that probably helps with getting them through, but 4 maybe not as much on some of the details, but I think that's probably the 5 biggest thing right now. And I know we're working in CRCPD with NRC, 6 recently even with CISA in the government coordinating council, we've had 7 some discussions about what we can do. So, I think that's the biggest thing.

8 COMMISSIONER WRIGHT: So, one of the things I've 9 noticed when I've traveled around, and I've been asked by certain states to 10 go in and talk to their governor's offices, or the oversight committee head 11 that that program falls under. One of the problems that I've seen, and that I 12 know you are aware of, is the employees being poached by other states. Is 13 that a big issue in the states and region?

14 MR. SEMANCIK: I would say it's less of a poach -- state to 15 state movement typically what I experience, like the inspector I had come to 16 the state came for family reasons. There's not a lot of variation in there. Our 17 bigger challenge, and I'm sure my Pennsylvania counterpart would say it, is 18 state going to federal, because your pay is higher.

19 So, if you're in Region I, and you're in Pennsylvania, and 20 you can get qualified for the state, but then I can boost my salary without 21 moving, that's a challenge. State to state tends to be more personal 22 decisions from what I see.

23 COMMISSIONER WRIGHT: Okay, so a little different up 24 here, all right. Thank you so much.

31 1 CHAIR HANSON: Thank you, Commissioner Wright.

2 Commissioner Caputo?

3 COMMISSIONER CAPUTO: Good morning, thank you all 4 for your presentations, it's always good to hear from our stakeholders and 5 their perspectives, so thank you for being here. It's also good to see that we 6 are all aligned in the goals of safe use of radioactive materials, and safe 7 operation of nuclear power plants. We may not agree on every aspect of 8 how to achieve them, but we do share common goals, so thank you all for 9 being here.

10 One area I'd like to discuss is the use of risk insights that 11 Mr. Herr brought up. On his third slide he refers to a report by the Nuclear 12 Energy Institute, The Nexus Between Safety and Operational Performance 13 in the U.S. Industry discusses the current trends of high performance and 14 impact on improving safety and reducing risk.

15 This matches well with a decades long trend in lowering 16 accident sequence precursors, and the agency's conclusion in its most 17 recent annual report that stated licensee risk management issues are 18 effective in maintaining a flat or decreasing risk profile for the industry.

19 One thing I would challenge Mr. Herr on is the statement 20 on that slide that implies the agency should quote use more recent industry 21 performance data to determine risk significance policy thresholds. The 22 commission has long had a policy against lowering the threshold on what we 23 consider safe enough in response to improved performance by the industry.

24 This was probably best articulated by the Commission in

32 1 1990 when it issued a staff requirements memorandum on the 2 implementation of safety goals and said that for advanced reactors the NRC 3 will not use the industry's design objectives as the basis for establishing new 4 requirements. The same concept applies to currently operating reactors; our 5 risk significance policy thresholds shouldn't change in reaction to industry 6 performance.

7 Instead, I believe what the agency should be doing is using 8 industry performance data from inspections, performance indicators, and 9 operating experience as an input to determining how much and what type of 10 oversight is appropriate. Can you comment on how the agency's efforts to 11 risk inform should reflect or align with recent industry performance data, Mr.

12 Herr?

13 MR. HERR: Yeah, first, I appreciate the clarification, 14 because I agree with you. The way it was worded on the slide, probably not 15 well articulated. And what I intend to mean by that portion is I do think the 16 risk informed portion of what we're doing is working well. And to further 17 gather data and use artificial intelligence or more current data in that realm I 18 think would help further risk informed inspections.

19 Not to change thresholds, but to help pinpoint areas within 20 inspections to further drive what we're seeing right now to help improve the 21 health and safety of the public really. So, I agree with your initial statement.

22 Not looking to change ROP thresholds, but really drive the risk insights into 23 the inspection process, to really make sure we're spending our time where 24 it's most effective in the safety and risk significance areas.

33 1 COMMISSIONER CAPUTO: Thank you. Since you 2 mentioned AI, I am going to ask a question on that topic. Last August I 3 attended an American Nuclear Society conference, there was a panel 4 discussion on AI, and how some plants are using AI. One, in terms of fuel 5 modeling and designing fuel reloads. But a question came from the 6 audience on reactor vessel aging and whether AI could be used to assist 7 with modeling the aging of reactor pressure vessels given that the number of 8 coupons in the vessel are going down over time with the use of testing and is 9 it possible to sort of supplement the analysis of those reactor vessel coupons 10 through the use of AI. Is that something that you're looking at, or have you 11 explored that, what can you tell us about that?

12 MR. HERR: Well, I think it's a great question. I would say 13 right now we're just really scratching the surface of where we think AI can be 14 used. Actively being used in a couple areas, you talked about core design 15 and modeling. Likely is an opportunity for what you talked about in vessel 16 aging, but I think there's a number of different potential opportunities.

17 I think we're approaching it with a sense of caution at this 18 point, making sure we fully understand the implications of implementing 19 those technologies in a number of areas, and we've got a group that's 20 actively working on it, and that is an area we're exploring. We haven't 21 implemented that yet though.

22 COMMISSIONER CAPUTO: Okay, thank you. On the 23 heels of that, I think I'll ask another slightly different question. The University 24 of Purdue, Purdue University has a research reactor. They also, as part of

34 1 their installation of digital instrumentation and control in that research reactor 2 have now proceeded into the digital twin space in terms of gathering real 3 time data from the reactor.

4 And that's giving a fair number of opportunities in terms of 5 analysis modeling, and so on. What opportunities do you see in terms of 6 those real learnings? I feel like this is the first situation I know of where 7 digital twin is no longer conceptual, but actually established and under use.

8 What opportunities do you see there?

9 MR. HERR: Again, I think as we see continued progress in 10 a number of areas, and the one you talked about at Purdue is an excellent 11 example. So, as we watch what folks are doing, I think we're looking at a 12 number of different opportunities. We haven't yet implemented digital twin, 13 certainly the digital modernization project will allow our ability to move 14 forward with something similar to that.

15 And we're going to have a lot more information at our 16 fingertips certainly as we move into that space. I think it's exciting, I think 17 there's an air of caution, but excitement all at the same time, and having 18 folks looking at that, and continuing to pay attention to what's going on in the 19 industry as well as research to make sure we're able to capitalize on that as 20 we implement a little further in the digital space.

21 COMMISSIONER CAPUTO: I think it has, it offers a lot of 22 opportunities to improve safety. One of which I think is just the wealth of 23 information and how you characterize human factors and look at issues like 24 that. So, I have great hopes for that. And as long we're talking about digital

35 1 instrumentation and control, as I noted in my recent vote on digital I&C and 2 common cause failure policy, the successful implementation of digital I&C is 3 growing more important with the passage of time and can yield significant 4 safety benefits for new and operating reactors. So I'm glad to hear that the 5 Limerick project is progressing, and I think your points on human factors in 6 response to Commissioner Wright's question are well taken. But one 7 additional question that I have is just the nature of the pre-application 8 discussions that you had.

9 You commented very positively on those. Can you give us 10 an idea of whether you see efficiency benefits to the pre-application 11 engagement? You said that it's fostering alignment, does it actually save 12 more time and effort than it costs, or does it simply help in the realm of 13 alignment and predictability?

14 MR. HERR: Well, I think it's a little bit of both. Alignment 15 and predictability certainly streamlines the amount of resource on something.

16 But I do think also the pre-submittal allows us to understand a number of the 17 questions and be able to proactively deal with those as part of our submittal, 18 and then save the need for RAIs as part of the process, which do tend to 19 take time, and can be a complicating factor in the LAR.

20 We can address information up front that's part of our 21 submittal, and make sure it's clear, and we understand the questions that we 22 would expect, it certainly helps. I think we'll do a full evaluation at the end, 23 but right now I would say more beneficial from that than what we're seeing 24 from a time investment.

36 1 COMMISSIONER CAPUTO: Okay, thank you. Mr.

2 Semancik, I'd like to piggyback on what Commissioner Wright was asking 3 about. He asked about staffing, I'm just wondering what other key 4 challenges do you see in bringing your pursuit of agreement state status to 5 completion. Are you seeing other challenges, or are there things that you've 6 observed in working with other states that have gone through recently?

7 Are there challenges in addition to staffing that you're 8 seeing? And are we giving you enough support on those challenges?

9 MR. SEMANCIK: Yeah, I think the other big challenge you 10 see is, at least for me, is regulation in the state. Most of our state processes, 11 after you go through public hearing notice and get it signed off, you've still 12 got to go back to the legislature or some form of the legislature to get it 13 formally approved.

14 And so we add, as complex as the federal rulemaking is, 15 we make it a little harder in every state, and so that gives us a challenge.

16 Probably an area, I'm going to go out a little bit because I haven't been 17 through an IMPEP on the receiving side, but risk informing compliance 18 probably makes a lot of sense.

19 I don't think all regulations are the same risk if they're not 20 done in the same time from a compatibility point of view, not a compliance, 21 compatibility. There would probably be some benefit to adding that, and 22 giving a little leeway to the states that are struggling through some regulatory 23 processes to make sure that they get the right regulations up to compatibility 24 in a timely fashion as opposed to something that may have less of a risk

37 1 significance.

2 COMMISSIONER CAPUTO: I'm not sure we can help 3 much with the legislative effort, but I'm glad to hear that our staff are being 4 helpful as you proceed through that effort, so thank you.

5 CHAIR HANSON: Thank you. Commissioner Crowell?

6 COMMISSIONER CROWELL: Thank you, Mr. Chair, and 7 thank you to all of our panelists today for being here, this has already, I think, 8 demonstrated its value in terms of holding a regional meeting in one of our 9 regional offices. Thank you to the NRC Region I staff for accommodating 10 today. What we're hearing today is a little bit more granular, and closer to 11 the ground level than information that we normally hear at NRC meetings, 12 and I think it's really valuable for the Commissioners to hear that.

13 As a former head of state regulatory agency, one of the 14 values of that experience was being closer to the people that you impact with 15 your decisions, and that have an interest in these topics. So, I hope this 16 becomes something that the NRC does on a regular basis so we can learn 17 more about how to engage effectively in what we're doing well, and what we 18 maybe can improve upon.

19 Mr. Semancik I'll start with you. Just with my former state 20 regulator hat on, and this will piggyback right on the last question you 21 answered. But becoming an agreement state is, it seems like an obvious 22 thing to do, but the behind the scenes that it takes is significant, and I was 23 trying to think about what I would have done in my home state of Nevada if 24 they weren't an agreement state already, how I would have gone about

38 1 trying to effectuate that.

2 And the thought of having to convince a governor's office, 3 convince the legislature, whom the governor and the legislature may not see 4 things the same way, knowing that a legislature in Nevada at least meets 5 every other year, so getting regulations done is a whole other soap opera.

6 Can you just tell a little bit more about how you went about the front end of 7 the process in terms of getting agreement from the state leaders, be that on 8 the executive branch side, or the legislative side to go forward down this 9 route?

10 MR. SEMANCIK: Yeah, certainly. So, we've been looking 11 at it in the program for a while to see why, does it make sense? So, the first 12 thing we do is kind of think through why would it make sense, what would it 13 make sense for folks for us to do this. Both in my department, in the 14 legislature, in the governor's office to do that. So, if you saw, when I had up 15 the slide, I had up some one pagers that we kind of went through and said 16 what are the real benefits we're going to see?

17 We're going to see an economic benefit, we're going to be, 18 as you said, closer to the license community, we're going to have 19 accountability, we're going to have a better trained staff, all those things are 20 factored in, and we looked at that. We had also the benefit that I think 21 Monica was able to provide a briefing for us at the state level, to make sure 22 we really understood the process.

23 Like what is the process, it kind of seems obvious and 24 easy, but you've got to kind of really lay out that it's going to be three to five

39 1 years, right? And this is going to require this kind of commitment, get you 2 some dedicated project staff to do it. So, we were able to kind of continue to 3 brief those things to people, and then just a lot of touches out there both in 4 legislative committees within the organization up and down, across the 5 organization.

6 The other departments that may be addressed and 7 working through that. And for us, a lot of it, because we had people kind of 8 put in new leadership all the way up, they were interested and receptive in 9 hearing ideas, and so that was kind of a good opportunity for us to see that 10 to go forward.

11 COMMISSIONER CROWELL: Yeah, that makes sense.

12 You pick your spot when you see the least obstacles in the road.

13 MR. SEMANCIK: Correct.

14 COMMISSIONER CROWELL: I appreciate that. And on 15 staffing issues, yeah, it's tough at the state level. It's often the feds who steal 16 from the state, and then the private sector that steals from the feds, with the 17 exception being during my time in Nevada, California could steal from 18 Nevada, they paid better but their cost of living was much higher too.

19 I'm going to move to Ms. Abramson (1:01:30), and Mr.

20 Congdon, whose presentations I really appreciated. It is a message that we 21 don't get to hear as directly as we should, what you provided today. And 22 being a new Commissioner, one of the things that I'm really focused on is 23 how do we interact with the public better and bridge the gap in terms of 24 perception and reality or speak in more plain terms so that average people

40 1 who live near these plants or are interested in this topic can understand 2 really what they should be concerned about, what maybe they don't need to 3 be as concerned about, how to engage the NRC process, which is very 4 complicated. And so, kudos to you and your entities for helping do that. Mr.

5 Congdon, I was hoping that you could maybe expand a little bit more on 6 what you had said.

7 That the NRC can fill some gaps in terms of the -- I don't 8 know if it's the amount, or type of information provided, or whatever gaps 9 those were. Can you just kind of illuminate a little bit more on those?

10 MR. CONGDON: Yeah, sure. So, at the 11 Decommissioning Oversight Board, we make a commitment to the public 12 during our public statement hearings, any question they put on the record we 13 will commit to answering. When NRC has participated in our meetings, they 14 have also agreed to that commitment, and it's been a terrific partnership, and 15 we've received a lot of written answers to our questions from the NRC that 16 we post on our website, and we're being very responsive to the public's 17 questions.

18 From time to time, we also as a state agency, the 19 Department of Public Service, or in my capacity at the DOB will write to the 20 NRC to express some concerns, ask some questions. Recently we wrote a 21 letter pertaining to the Inspector General report related to the Region II 22 inspections of ISFSI finding some issues with qualifications, inspection time, 23 et cetera.

24 And we requested detailed information about inspection

41 1 records pertaining to the New York plants to make sure that none of the 2 issues the IG found in Region II occurred in Region I. We did get a written 3 response back from the NRC that very generally said no issues but did not 4 answer by providing the records that we were seeking, which we believe we 5 could use to then show the public what occurred at the New York plants, and 6 to give us some assurance that the issues identified by the IG didn't exist in 7 Region I. We've asked the NRC to come to our December meeting to 8 address that further, and again, as I said in my remarks, in my experience 9 when there's a lot of follow up, we get the details that we are seeking.

10 But I think in that first response there tends to be, and it 11 may be because it's so voluminous, or it's so detailed that it could be 12 someone's judgment that jeez, this is too much, or it might be confusing. But 13 I think by not providing the level of detail that we are seeking, it creates 14 suspicion among my colleagues on the DOB that the NRC isn't being 15 completely transparent, and that erodes trust.

16 COMMISSIONER CROWELL: I appreciate you making 17 the point, because it's more than just the NRC being willing to participate 18 and being responsive, it's the quality of that participation and 19 responsiveness. And if we're not going to be able to respond in the level of 20 detail asked, it needs to be made very clear as to why certain information 21 can't be provided, or why it's going to take longer.

22 And if it's just a resource issue in terms of time, then we 23 need to be looking internally about how we make more resources available.

24 Because really, we're not going to be successful as an agency if we're not

42 1 being successful in engaging with the state regulators and stakeholder 2 groups. It's just you're not going to build and maintain that social license to 3 do what we do and regulate the commercial nuclear power industry the way 4 we do if we're not being truly responsive and clear in how we do things.

5 And so much to that point, Ms. Abramson, I'll turn to you.

6 You mentioned some very specific things that the NRC could do to be more 7 transparent or more responsive. They all seemed very reasonable to me, I 8 don't know the back story on all of them. Has anyone given you a rationale 9 as to why one or more of those things couldn't be accommodated?

10 MS. ABRAMSON: This is my first time requesting those 11 things.

12 COMMISSIONER CROWELL: Okay, noted.

13 MS. ABRAMSON: So, compiling that PowerPoint was 14 really good exercise for me to shift the perspective, my own perspective a bit 15 to starting to look for solutions, and what are really easy, I think maybe cost 16 effective, but I'll leave it to the IT expert things that can be done. And I've 17 also had a lot of interaction with the ADAMS database teams just over the 18 last year, becoming more fluent in how to navigate it with help from NRC 19 project managers.

20 There's a lot of nuance, and in doing that a lot of those 21 gaps were revealed to me recently.

22 COMMISSIONER CROWELL: Okay, well then in that 23 case, thank you for highlighting them, and consider this the beginning of that 24 conversation to see what can be done, and we'll probably explore it a little bit

43 1 more in the next panel, but certainly after today's meeting. Just in the little 2 bit of time I have left here, Mr. Torres, a straightforward question, I think, for 3 you.

4 Given where you do business in Puerto Rico, have 5 weather events and associated but not completely correlated power supply 6 and electric reliability issues incentivized Baxter to think about whether they 7 can continue to cost effectively do business in a place like Puerto Rico with 8 those impacts? How are those kind of natural and somewhat man-made 9 phenomenon impacting your business decisions?

10 MR. TORRES: Yes, that's one of our bigger challenges in 11 terms of still being competitive in terms of the manufacturing costs 12 associated first of all with the human labor, but also for having the power.

13 Just to give you a number, Baxter pays around a half million every month in 14 power, and also it's just not a very stable system that we can have it 15 available any time.

16 So, for any reason you can have that interruption in the 17 process that has that impact. And also increase when we have the 18 hurricane season, any other environmental event on the island. So, we 19 continue having this opportunity, and Baxter overall site has been putting the 20 emphasis on having this power continuity on the site. We have been 21 installing power generator backups, and now we recently assessed this 22 week, we opened a cogent power plant that is fueled by natural gas.

23 So, we want to have that operation completely separated 24 from the current power authority just to continue that operation in place, and

44 1 having this opportunity to continue operating without the limitation that we 2 currently have. So, it's continuing to improve, and we have different 3 challenges, but our first and hardest challenge right now is power.

4 So, that basically has been moving up just to assure that 5 we have different backup systems, and disconnect completely from the 6 current system, and be able to still operate continuously in the health safety 7 operation, as well as the rest of the -- not only for gamma, the gamma 8 operation, but as well for the manufacturing sites.

9 COMMISSIONER CROWELL: Understood, I appreciate 10 the answer, thank you.

11 MR. TORRES: Okay, thank you.

12 CHAIR HANSON: Thank you, Commissioner Crowell.

13 This is, again, as a number of us say, as we go along, this is the problem of 14 going last, is a lot of the good topics have been covered. But I guess I'll stick 15 with you, Mr. Torres, I don't want you to feel neglected as we go along here.

16 As you know, the radiation safety requirements that we have are rigorous 17 and kind of purposefully prescriptive.

18 Overexposures have occurred, although they are rare. But 19 I guess I wanted to get into then given how important those processes, 20 procedures and rules really are, how is Baxter, or the facility in Puerto Rico 21 approaching the issue of recruiting, retaining, developing talent for radiation 22 workers, and kind of other ancillary personnel at the facility?

23 MR. TORRES: And that's a very similar to the other 24 positions in the island. So, to keep the talent, and retention, similarly we

45 1 have a lot of workers that decide to move, you mentioned for personal 2 reasons, move to different departments looking in terms of better benefits or 3 better working shifts. So, that's something that we consider as part of the 4 continuous day to day operation.

5 So, we need to make sure that all the different employees 6 that come to the site are provided the proper training, the proper 7 understanding of the way that they are working, and the first thing that we 8 need to understand there is that they need to realize that they are not a 9 manufacturing department, or they are not running a manufacturing machine 10 at the other departments that are nearby to us.

11 So, they need to understand the responsibility of having 12 this type of operation. So, they will be handling different products, but at the 13 end they will be putting the different products into a system, that we need to 14 make sure they are completely trained and understand the reason of the 15 operation that they are doing.

16 So, first of all, that's our biggest challenge, just prior to 17 them coming to the department or to the site. The first thing that we talk to 18 them is to make them realize, and make sure that where they are moving to, 19 basically will be moving to an operation department, will be doing assemblies 20 or doing a different type of operation.

21 Now you'll be moving to a different department where you'll 22 have a role that safety is first priority to everything. So, once we've got the 23 type of culture implemented, so we have a very -- we know that the talent 24 goes, they move, sometimes they move between departments, so we keep

46 1 them to the sites.

2 Well, that's something that we make sure that every time 3 we get new hires, that's our goal, to make them understand where you're 4 moving, the first question is why are you moving to -- if you're willing to stay 5 in this type of production environment they have different regulatory 6 compliance requirements for the other side of the plant.

7 So, that's what we want to make sure, just to continue 8 having them train, and any doubt that they may have, any doubt that they 9 may have regarding the operation, just to be open to them, and free 10 communication to them, and also as we mentioned before, we have the NRC 11 available any time that we need to consult, and do any kind of a call just to 12 any kind of recommendation, consideration that we have, and that's our first 13 option, to have that first response from the agency.

14 CHAIR HANSON: Thank you. So, I understand you're a 15 graduate of the University of Puerto Rico Mayaguez?

16 MR. TORRES: That's correct.

17 CHAIR HANSON: Okay. As you may know, the NRC has 18 a long history and relationship there. So, I'm just kind of curious if Baxter 19 Healthcare is also kind of looking, in your case, I think it's west there to the 20 university, for graduates and skilled people coming in?

21 MR. TORRES: Correct. The university performs different 22 type of fairs during the year, so also Baxter is interested in having the 23 students to help us as we go, the co-ops, to have them experience a working 24 environment. So, we took advantage of those students that want to get

47 1 knowledge in the industry. Some of them want to continue to have another 2 post graduate experience.

3 But the other ones that want to go directly to the working 4 environment, so we take advantage of that. So, we provide them to the 5 plant, just to be a student. Also, we have this type of program that we get 6 those students and move to the different sites on the island, and also in the 7 U.S. So, they get different knowledge on the different technologies, and 8 different processes through Baxter.

9 And then once they graduate, those are the ones that we 10 select for the position based on those interests to be part of the Baxter 11 family, as well as in different aspects of the operation, so it's a very useful 12 program.

13 CHAIR HANSON: Very good. I guess the last question I 14 have, and this is just, I guess sort of a question about Baxter more generally.

15 I've had the opportunity to travel a little bit in the Caribbean, and heard from 16 both national regulatory bodies and others, healthcare establishments, et 17 cetera, about the appetite for radiation protection workers, but also just those 18 services in general.

19 And whether it's irradiation, or whether it's access to 20 medical isotopes and what have you, and then the capability on both the 21 regulatory side, and just on the handling side. So, I mean does Baxter have 22 a broader presence, or a broader strategy in the CARICOM for example?

23 MR. TORRES: Initially when we started operations the 24 main goal was to have only the Baxter product coming to the island for

48 1 sterilization and then moving to the market. But then other different sites 2 have been also introducing other types of radiation technologies to their site.

3 So, some of the volumes that we typically receive for handling has been 4 reduced.

5 And then we took that extra capacity to offer the services 6 to different sites also on the island, and also knowing that there are not too 7 much irradiation sites in the Caribbean, and also nearby. So, we take 8 advantage of that in terms of doing business, but as well allowing them to 9 continue the operation of different manufacturing companies.

10 At the end, they also need the irradiation services. So, 11 that way we have their business, as well as also have continued operation, 12 take the benefits from the invoicing and that's something that the company 13 has been doing for the last 15 years that we introduced getting external 14 customers.

15 And I think that basically will be continuing, assuring that 16 we maintain our capacity to run our products, as well as having this extra 17 capacity, we take advantage to help other companies on the island as well 18 too, to process products as well.

19 CHAIR HANSON: Great, thank you very much. I know 20 I've got just a little bit of time left. I want to just, Mr. Congdon, and Ms.

21 Abramson, I wanted to just come back to you for a minute here. I think Tom, 22 it was you that talked about public education. You mentioned both public 23 education and data visualization, that caught my attention. And public 24 education can mean a lot of different things.

49 1 Sometimes, as you mentioned in response to 2 Commissioner Crowell, it can mean answering questions in a particular way.

3 But I guess I was wondering if each of you could kind of give me an example 4 or two of maybe specific types of public education, about what the NRC 5 does, and how we do it, or how we make decisions, et cetera, that might be 6 helpful for communities around these facilities.

7 MR. CONGDON: So, would you like to go first?

8 MS. ABRAMSON: Sure. So, thank you for asking that 9 question, because I think it's the dream of any nuclear safety advocate to 10 have the Chair of the NRC Commission ask them this exact question. I 11 would echo kind of what we've heard before, which is responding to written 12 questions with more substantive answers. And I do understand that written 13 answers do go through legal channels.

14 And that sometimes that's where a lot of that 15 generalization happens. So, we have found that our personal increase in 16 education, which has happened a lot in the last year, has been because of 17 Zoom meetings and lengthy phone conversations, because unlike a written 18 response, a verbal conversation can evolve and be flexible in context.

19 So, we feel privileged, but with that privilege maybe there's 20 a bit of unfairness, because there are a lot of other groups that don't get the 21 same courtesy. We happen to have really responsive inspectors working at 22 Seabrook. I don't know that -- I do know -- that other groups like us in other 23 communities don't feel that way.

24 So, if there was some guidance from the top that what you

50 1 are hearing from me about my experience with Seabrook is something that 2 you would like modeled in other places, I think you might see that 3 improvement in stakeholder trust. I also might suggest if you could offer 4 some webinars that are even pre-recorded and available online, like how to 5 navigate the ADAMS database.

6 How a sign up to receive notifications from ADAMS that 7 documents have been posted related to your nuclear station, how to 8 navigate the Federal Register and put in a public comment. Like really basic 9 civic engagement stuff, which I know is probably the job of public schools, 10 but I think that if you could have it on your website, it would demonstrate an 11 effort on your part.

12 And I don't know what type of staff you have dedicated to 13 public stakeholder engagement aside from just your public relations staff, 14 because my perception of their role for the most part has been engaging with 15 media, and curating press content that is publishable, not necessarily people 16 who have a focus on reaching people on the ground.

17 CHAIR HANSON: Thank you.

18 MR. CONGDON: Thank you. I'll just add in my 19 experience at the DOB, let me first commend the staff that have been 20 attending our meetings, and making presentations, it's been really terrific.

21 And they've been able to condense a lot of information into very effective 22 slide decks. So, on the visualization piece, I think that that's where we see 23 great value.

24 And sometimes with the sort of letter exchanges we get

51 1 citations to ADAMS, and then you go in, and there's a data set that's a mile 2 long, right? So, those are the standard of what we're looking for, and where 3 there could be some improvement. But I will say that our DOB includes a 4 number of people who have been involved in NRC matters for many, many 5 year and they have been very, very complimentary of NRC's engagement 6 with our DOB, including things like our public forum. Where staff came and 7 answered questions directly from the public, and had a back and forth, 8 allowed the follow up questions.

9 So, no, it's been a terrific partnership, those in person 10 meetings, just showing up is so appreciated, so thank you.

11 CHAIR HANSON: Okay, good. Well, thank you both for 12 that answer. I think like a lot of technical organizations, the difference 13 between kind of data and information can be kind of a hard line to toe, 14 because both of those things can promote transparency, and yet the data 15 might be transparent, but it may not be entirely clear what it actually means 16 in terms of for the lay person.

17 So, I appreciate both of your insights on that. Well, I want 18 to thank our external panel very, very much for being here today. I 19 completely agree with Commissioner Wright, it's great to do these things in 20 person, and to get out here. We are going to take a ten-minute break, we're 21 going to reconvene at let's say 10:35. Thank you all again, and thanks to my 22 colleagues, and with that.

23 (Whereupon, the above-entitled matter went off the record 24 at 10:23 a.m. and resumed at 10:34 a.m.)

52 1 CHAIR HANSON: We're going to get started here with the 2 second panel. From Region I staff, our Executive Director for Operations 3 Dan Dorman will kick it off. Dan, the floor is yours.

4 MR. DORMAN: Thank you, Chair, and good morning, 5 Chair Hanson, and commissioners. On our second panel this morning the 6 staff is pleased to provide you with an overview of Region I activities and 7 external engagement. The panel will provide the Commission with an 8 overview of region activities with Region I specific insights on how we 9 continue to meet our mission. Next slide please. So, I'll introduce the 10 panelists. First, you'll hear from Dan Collins, the deputy regional 11 administrator here in Region I.

12 He'll provide an overview of Region I activities, including 13 ongoing hiring initiatives, training, office space, and outreach to external 14 stakeholders. Then we'll hear from Farrah Gaskins, one of Region I's 15 regional agreement state program officers in the Division of Radiological 16 Safety and Security.

17 Farrah will be discussing regional support to states 18 becoming agreement states. Mel Gray, the branch chief of Engineering 19 Branch 1 in the Division of Operating Reactor Safety will discuss the 20 engineering inspection program, key technical challenges, and stakeholder 21 outreach. Then Jason Schussler, the senior resident inspector at Ginna 22 Power Station in the Division of Operating Reactor Safety will discuss 23 resident inspector priorities and challenges.

24 And finally, we'll conclude with Elizabeth Andrews, the

53 1 technical assistant in the Division of Radiological Safety and Security, and 2 the Region I culture team lead, and she'll provide an overview of Region I 3 culture team activities. So, that concludes my opening remarks, and I'll turn 4 the presentation over to Dan Collins.

5 MR. COLLINS: Next slide please. Thank you, Dan. Good 6 morning, Chair, and Commissioners. Next slide please. The Region I 7 presenters today hope to leave you with the following key takeaways. First, 8 that the Region I staff is effectively implementing the NRC's mission despite 9 significant challenges with staff turnover and associated demands for 10 training and qualification of new staff.

11 We are actively working to support several states in their 12 efforts to become agreement states. Second, that we are mindful that the 13 coping strategies we have implemented in recent years to accomplish the 14 mission are not long-term solutions to the staffing challenges we face. And 15 third, that we understand that while our mission of protecting people and the 16 environment has not changed, we do need to adapt the ways in which we 17 accomplish the mission.

18 These adaptations must encompass technology, process 19 improvements, and how we engage staff, and our culture in the mission.

20 Next slide please. Region I staff continues to achieve our mission with a 21 high level of credibility and competence across a broad range of activities 22 and licensee types, including 20 operating power reactors, nearly 650 23 materials licensees, and more than 41 other facilities such as 24 decommissioning reactors or dry fuel storage facilities that represent the

54 1 back end of the nuclear fuel cycle.

2 We also support and collaborate with our regulatory 3 partners in 17 agreement states. Next slide please. In a typical year our 4 reactor inspectors conduct more than 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of operations, sorry, 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of inspection during all phases of reactor operations. They administer 6 approximately ten scheduled operator license exams and conduct 7 approximately 150 inspections to ensure safety of nuclear materials, and 8 they also conduct 60 to 70 inspections at decommissioning and dry fuel 9 storage facilities.

10 Additionally, our corporate mission support staff and 11 administrative staff work tirelessly to ensure that the staff and the managers 12 have the resources and the support they need to accomplish the mission.

13 The dedication of our staff is clearly reflected in the results that our staff 14 achieves.

15 In addition to the mission, we continue to focus on our 16 people and process improvements. With respect to people, Region I 17 managers continue to work to ensure that communication with our staff is 18 timely and clear, and that staff feedback is sought through multiple venues.

19 We are placing extra emphasis on ensuring that newer staff are welcomed, 20 and fully engaged in the mission, and can bring their whole selves to work.

21 You'll hear more on this from Ms. Andrews. Regarding 22 process improvements, we continue to work with our partners in 23 headquarters and other regional offices to modernize and streamline 24 processes. For example, supervisors and staff in our Division of Resource

55 1 Management have been collaborating with their peers in the other regions to 2 benchmark how corporate functions are performed, and share best 3 practices, improve efficiency, effectiveness, and consistency.

4 Region I branch chiefs and staff have also participated in 5 the development, piloting, and improvement of the competency based 6 qualification process to streamline inspector qualifications. Next slide 7 please. Region I has made significant efforts to attract and hire quality 8 candidates. This has included partnering with human resources specialists 9 in the Office of Chief Human Capital officer, and with other offices and 10 regions to attend recruiting events and university career fairs.

11 As you have heard in other presentations, finding, 12 onboarding, and retaining highly qualified people for the resident inspector 13 positions and health physicists, particularly those who have clinical 14 experience in nuclear medicine, continues to be a significant challenge. In 15 the last three years, Region I has hired 48 external applicants for full time 16 positions.

17 22 of those we onboarded in fiscal year '23. In 2023 we 18 also supported five summer hires, and seven NRAN rotations, and I'm happy 19 to report that four of the current NRAN class members have accepted post 20 NRAN positions here in Region I, two in the resident inspector development 21 program. This is reflective of the heavy emphasis that we have placed on 22 this priority.

23 However, we know that we need to do more, particularly 24 with regard to the resident inspector positions. It's not surprising that the

56 1 large number of new hires has contributed to a significant need for training 2 classes and has placed additional burdens on our senior staff who perform 3 on the job training.

4 We have made extensive efforts to get the newer and 5 qualifying staff out into the field with very experienced inspectors, and 6 involved in working groups and assignments that enhance their development 7 of knowledge and regulatory skills. We've also continued to support a large 8 volume of developmental assignments for our staff. In fiscal year 2023 we 9 supported 64 staff rotations.

10 However, one issue that cannot be overlooked is that in 11 the past few years the average experience of our inspection staff has 12 decreased. We have had to assign staff who are basic Appendix A qualified 13 to permanent resident inspector positions due to the heavy turnover within 14 the resident ranks, and this leads to the newly assigned staff having to 15 perform the duties of the job and complete further qualifications concurrently.

16 In addition to training the new hires, we have had very 17 experienced senior staff and supervisors heavily involved in the development 18 of training related to new aspects of the reactor oversight process. For 19 example, we have supported those activities with respect to training modules 20 for fire protection, commercial grade dedication, digital I&C, and cyber 21 security.

22 Among our accomplishments in the realm of training, in 23 fiscal year 2023, 22 Region I staff completed basic or full inspector 24 qualifications, and 4 staff completed materials license reviewer qualifications

57 1 to obtain or to expand their signature authority. Next slide please. Shifting 2 gears a little, I'd like to highlight that Region I successfully completed its 3 office relocation in fiscal year 2022.

4 This move reduced our office space square footage by 5 approximately 55 percent and reduced our annual rent by nearly 65 percent 6 for an annual savings of approximately 1.8 million dollars. This achievement 7 would not have been possible without the active engagement of our staff in 8 the planning of the new space, or the constructive support from the union 9 partnership who were open to dialogue and decisions regarding new work 10 space assignment and use protocols.

11 Next slide please. Turning briefly to our outreach with 12 stakeholders, in addition to the interactions with our licensees, Region I staff 13 continues to have important engagement with external stakeholders. These 14 include the organizations you heard from in the previous panel, as well as 15 others, such as the Organization of Agreement States, the Conference of 16 Radiation Control Program Directors, non-governmental organizations, and 17 other state and federal partners.

18 We coordinate with NMSS's tribal liaison staff for 19 interactions with Tribal nations in Region I, such as the Seneca Nation near 20 the West Valley Demonstration Project in New York, and the Mashpee 21 Wampanoag near the Pilgrim Decommissioning Site. In these interactions, 22 we strive to clearly explain the technical and regulatory issues that we 23 identify and are reviewing, along with the appropriate safety context 24 regarding our assessments of licensee performance and risk significance of

58 1 the issues.

2 Finally, we have provided significant support to the 3 agency's international activities. This includes significant involvement in the 4 creation and delivery of the IAEA School of Nuclear and Radiological 5 Leadership for Safety for regulators in more than eight different countries.

6 We have also had staff participate as instructors in the 7 IAEA root cause analysis course and participate in regulatory peer review 8 missions. I will now turn the presentation over to Farrah Gaskins for 9 discussion of the agreement state support. Next slide please. Farrah?

10 MS. GASKINS: Thank you, Dan. Next slide please. The 11 process to becoming an agreement state requires significant communication 12 and coordination between the NRC and that state. A state interested in 13 regulating radioactive materials within its borders submits a letter of intent 14 which is signed by the governor to the NRC.

15 After the letter of intent from the governor is received, a 16 project manager from the Office of Nuclear Material Safety and Safeguards, 17 or NMSS is assigned to manage the timeline for the process. A regional 18 state agreements officer, or RSAO is also assigned as the regional point of 19 contact to assist the state and NMSS during the process.

20 The NMSS project manager and the RSAO hold monthly 21 meetings to answer questions during the state's development of the draft 22 and the final application. The state will submit a draft application to the NRC 23 for review. The NRC reviews the draft application and will provide 24 comments to the state.

59 1 The final step is for the state to address the NRC's 2 comments and submit the formal request with the completed application.

3 The entire process can take from three to five years. Next slide please. I 4 would like to share some details about other states in Region I that have 5 become agreement states, as well as talk about my specific involvement with 6 those transitions.

7 Region I radioactive materials licensing and inspections 8 program covers 23 states, 17 of which are agreement states. And during my 9 19 years with the NRC, there have been four states that have transitioned to 10 agreement states in Region I, and those are Pennsylvania, New Jersey, 11 Virginia, and Vermont.

12 As a qualified materials inspector and license reviewer, I 13 participated in training of state staff during those transitions. State staff 14 accompanied me as I performed routine inspections in which they learn 15 basic inspection techniques and regulatory requirements specific to the 16 modality of inspection being performed.

17 I also trained staff in reviewing licensing actions, which 18 helped them to become qualified license reviewers. Additionally, I reviewed 19 portions of the draft and final applications that were submitted. Currently, 20 two Region I states have submitted letters of intent, and those are 21 Connecticut and West Virginia.

22 As mentioned, I support the Connecticut transition, while 23 the other RSAO in Region I supports the West Virginia transition. Next slide 24 please. As the point of contact for Connecticut I coordinate inspector

60 1 accompaniments for the state staff to accompany Region I inspectors. To 2 date, the state of Connecticut has accompanied Region I on over 60 3 inspections.

4 I also assist the state in understanding the current licensee 5 demographics within the state by providing details about specific licensees.

6 When the draft application is received, Region I staff will also have a role in 7 reviewing part of the application and providing comments to the state.

8 Region I will also participate in training the Connecticut staff in licensing and 9 the use of NRC's web-based licensing system.

10 Additionally, Region I staff will complete inspections six 11 months prior to their due date to give the new agreement state a little 12 breathing room when the agreement goes into effect. After the agreement is 13 in effect, Region I will of course remain a resource to the state to answer 14 licensing and inspection questions. Next slide please.

15 There are benefits to having regional support during the 16 entire process, developing a professional rapport with the state helps to 17 foster great communication. Another benefit is that the state has an 18 opportunity to learn hands on from qualified NRC license reviewers and 19 inspectors. Maintaining a healthy working relationship with the state during 20 this process also helps with early identification and resolution of any issues 21 during the development of the draft application.

22 Finally, it is an opportunity to strengthen the National 23 Materials Program by developing enhanced communication and 24 collaboration with the soon-to-be agreement state. Thank you for your time

61 1 this morning. I will now turn the next part of the presentation to Mel Gray, 2 who will discuss engineering inspection program. Next slide please.

3 MR. GRAY: Thank you, Farrah. Next slide please.

4 Engineering inspections are completed by region-based staff qualified and 5 trained for these activities. Most engineering inspections are accomplished 6 by teams with a comprehensive engineering team inspection being the 7 largest. Smaller teams complete the commercial grade dedication, age 8 related degradation, and fire protection inspections.

9 These activities shown on this slide make up the 10 quadrennial cycle recently approved by the Commission. These changes 11 improved efficiency and sharpened our safety focus. Thank you for your 12 support which allowed us to move forward. Engineering inspections not part 13 of the quadrennial cycle are also illustrated, such as the in service inspection 14 of reactor coolant systems, and containment during refueling outage.

15 Next slide please. Engineering inspections affirm plant 16 safety. They verify licensee performance to maintain structures, systems, 17 and components within their design basis. They help confirm that the plant 18 will perform as intended under conditions not demonstrated by operation or 19 testing, and that plant modifications meet requirements. Next slide please.

20 The technical challenges involve implementing the new 21 focused engineering inspection sufficiently, reliably, and with clarity.

22 Challenges also involve maintaining engineering staff capability and 23 adjusting inspections as plants age. Best practices from prior focused 24 engineering inspections include close regional and headquarters staff

62 1 coordination to draft new inspection procedures, develop examples, and 2 work through tabletop exercises.

3 Stakeholder input is also solicited. Additionally, cross 4 regional panels review inspection results to help drive consistency, clarity, 5 and reliability. These best practices will provide a sound foundation to 6 address technical challenges going forward. Additionally, we have other 7 inspections which have inter regional forums as well.

8 The age-related degradation inspections are challenging 9 because they encompass broad technical areas involving active and passive 10 component aging, and a regulatory framework that spans numerous 11 requirements. Furthermore, these inspections will involve review of 12 initiatives related to preventative maintenance and condition monitoring.

13 Proper adjudication of these results will be supported by cross regional 14 reviews.

15 The new commercial grade dedication inspection will also 16 benefit from these best practices to prepare regional inspectors for this new 17 inspection area. Maintaining engineering capability is a technical challenge.

18 Region I engineering inspectors bring to bear in depth expertise in 19 mechanical, materials, cyber security, fire protection, and electrical 20 disciplines.

21 Additionally, they provide technical assistance to resident 22 inspectors and backfill at sites. Region I engineering staff turnover has been 23 managed through internal transfers and promotions, strategic external hires, 24 and hiring from the current NRAN cohort. Our branches also draw from the

63 1 resident and senior resident inspector ranks. About half of engineering staff 2 are former resident inspectors.

3 These staff bring strong operational knowledge to our 4 branches and follow on service harnesses their capabilities while expanding 5 their technical expertise. A further technical challenge involves adjusting 6 engineering inspections as plants age. A decision before us is the focused 7 engineering inspections to begin in calendar year 2027.

8 A working group of engineering branch chiefs previously 9 developed candidate topics considering risk insights and operating 10 experience. Region I engineering branch chiefs consider this list to be a 11 good start, and would advocate for considering external hazards capability, 12 or station black out coping capability topics as leading candidates.

13 Next slide please. Stakeholders have high interest in our 14 oversight of Region I plants. Current topics of interest include the Seabrook 15 Station structures affected by alkali silica reaction. In my experience, 16 effective outreach begins with branch chiefs maintaining strong relationships 17 with our partners from the Office of Public Affairs, Office of Congressional 18 Affairs, and our own state liaison officers to identify early on technical issues 19 of stakeholder interest.

20 As topics are identified, branch chiefs lead regional staff to 21 develop and implement communication plans for intentional outreach 22 regarding issuance of an inspection report or planned public meeting.

23 Communications include offering briefings to congressional staff, outreach to 24 state and local officials, and preparing our public affairs staff for inquiries.

64 1 For topics of ongoing high interest, such as Seabrook 2 Station buildings affected by the alkali silica reaction, our resident 3 engineering inspectors regularly respond orally and in writing to questions 4 from individuals and groups. We also conduct focused outreach through our 5 annual assessment meetings, which for high interest sites such as the 6 Seabrook Station, are held in the vicinity of the plant.

7 We make brief presentations and provide for several hours 8 of question-and-answer activities. Our resident and engineering inspectors 9 most knowledgeable of the issues lead in responses. The photos on this 10 slide show these activities. Also shown on this slide is Region I staff 11 involvement in international stakeholder outreach last month.

12 When inspectors from the Japan Nuclear Regulation 13 Authority observed our engineering inspection at a Region I site. Thank you 14 for your time, I will turn the meeting over to Jason Schussler. Next slide 15 please.

16 MR. SCHUSSLER: Thank you, Mel. Next slide please. I 17 must say I really enjoy my position as a senior resident inspector. It has 18 provided me the opportunity to contribute to the agency's mission and 19 demonstrate its values. I do this as the eyes and ears in the field. I, as well 20 as my peers, embrace the importance of public health and safety.

21 As we respond to events, perform routine inspections, and 22 provide independent assessment of plant performance to regional and 23 agency leadership, our priority is to develop and field train inspectors.

24 Recently, I supported the mentorship and field training of two Nuclear

65 1 Regulator Apprenticeship Network, NRAN, employees, one from each of the 2 previous cohorts.

3 The picture on this slide is from a refueling outage this 4 spring. Jack, from an NRAN cohort, and I are wearing protective clothing to 5 perform inspections inside containment. I spent time with him walking down 6 safety systems and observing testing. I know he was excited to see and 7 inspect areas of the plant we infrequently visit.

8 I can't blame him. I was too. Overall, I feel this type of 9 training happens successfully when we are on site at the resident office and 10 in the field. In that environment I can personally provide insights of our risk 11 informed inspection activities, event response procedures, and interaction 12 with site personnel.

13 Albeit training and mentorship takes time and resources, it 14 is rewarding to see the pride of fellow inspectors as they successfully 15 complete their qualifications and become future residents carrying out the 16 agency's mission. Next slide please. Another priority is technical expertise 17 in the field, this is critical to carry out the agency's mission.

18 Through event response, inspection activities, and 19 allegation intake. I do this with high levels of integrity and an unbiased eye 20 for public health and safety. This fall, while mowing my lawn on a Saturday 21 afternoon, I got a call that the reactor had tripped. Being the only resident on 22 site at the time, I cleaned up, packed my dinner to go, and headed into work.

23 My knowledge of plant systems allowed me to provide the 24 details and independent assessment to regional management, ensuring the

66 1 agency's response verified safe plant operation. My priorities remain 2 consistent, sharing knowledge to develop and train new inspectors through 3 an independent on-site field presence.

4 Tactical expertise and event response inspection activities, 5 and stakeholder interaction ensure I continue to accomplish the agency's 6 mission of public health and safety. Next slide please. I feel I represent the 7 character traits of many who are aware of the challenges of this position. I 8 accept the possibility of phone calls and notifications on nights and 9 weekends.

10 Currently staffing, training new inspectors, relocation, and 11 tour length limits are some challenges. I appreciate the effort by the agency 12 and the recent trust huddle event which sought input from resident 13 inspectors regarding the current internal and external factors affecting them.

14 Resident inspector staffing is a current challenge; vacant positions create 15 additional stress. I am in an office of two inspectors, and when one position 16 is vacant, the workload shifts. Due to training and temporary promotion I 17 have been without an assigned resident for several months. I have had 18 support from the regional office inspectors and from nearby sites as needed.

19 A necessary pairing with position vacancies is a resulting 20 increase in workload to field train and develop new inspectors. Tour length 21 limits and uncertainty of post tour options present a challenge to the resident 22 inspector program. I started my position knowing a guaranteed move at year 23 seven.

24 So, as engineers do, I developed a plan. Well, of course

67 1 we all know even the best laid plans often change. And that's okay, as I 2 reach my seven-year mark I find myself pondering what options are available 3 to me post tour? I appreciate the option and the flexibility provided in the 4 end of tour telework memo.

5 This is a tremendous bridging strategy to ease the 6 transition to move from one resident office to another. Another area posing 7 challenges is relocation. After seven years I am preparing for the relocation 8 process, and I do so with a family that has established roots. I feel internal 9 and external factors affect this process.

10 I maintain an awareness of the financial obligations 11 resulting from recent relocation tax laws, and the adage time goes fast for 12 the 120-day window to start the process, and find, buy, sell, and pack. A 13 timeline which I can supplement with temporary quarters. External factors 14 are present too, dual income household consideration, geographic cost of 15 living areas, school enrollment, and national economic climates.

16 Regardless of these factors, I am extremely grateful for the 17 relocation compensation provided to me, and I appreciate the agency's effort 18 to alleviate that burden. As I look to the future, I leave behind what I feel is 19 one of the best positions in the agency. Going forward, communication of 20 strategies, decisions impacting the resident inspector program can build trust 21 and could mitigate the challenges in this position. This concludes my 22 remarks, I will now turnover to Elizabeth Andrews. Next slide please.

23 MS. ANDREWS: Thank you, Jason, next slide please.

24 The Region I culture team was established in April 2021 to monitor and

68 1 optimize Region I's organizational culture and suggest areas that may need 2 increased focus. This is a staff led team with representatives from each 3 division and an SES sponsor. The expected duration of team membership is 4 two to three years to balance a team while also providing renewed 5 perspectives.

6 The culture team meets monthly to analyze data, review 7 information presented during the agency wide culture meetings, and discuss 8 areas of staff interest to identify, understand, and address organizational 9 culture issues at the earliest stages possible. The team presents culture 10 related topics during all employee meetings throughout the year.

11 And a member of the culture team meets with each new 12 employee to ensure everyone is aware of the culture team, its activities, and 13 its purpose. The Region I culture team takes pride in providing valuable 14 insight to senior management and staff not only in Region I, but to other 15 program offices as well.

16 Members of the culture team spoke to NRR and NMSS 17 representatives on culture team best practices, and presented during an 18 agency wide change agent meeting on how we formulated the Region I 19 culture plan. Next slide please. The culture team collects and analyzes data 20 from a variety of sources, including surveys, focus groups, and informal 21 discussions, formulates key messages, and communicates these messages 22 to management and staff. The culture team also communicates results of 23 agency wide surveys and initiatives. The culture team reviews Region I's 24 FEVS results, and trends overall regional and divisional responses, which

69 1 the team is actively working on for the 2023 FEVS results.

2 Historically, Region I's FEVS results are well above the 3 agency average. But the culture team has noted a decrease over the last 4 several years, specifically in the FEVS global satisfaction and leaders lead 5 indices. We believe this can be attributed to a variety of factors including, 6 but not limited to, the COVID pandemic, the recent Region I office move, and 7 the current staff workload.

8 The culture team looks for ways to continually improve our 9 culture, but the culture team's work goes beyond evaluating FEVS scores.

10 We take extra measures to evaluate culture and gain insights on staff 11 perspectives to provide meaningful recommendations. Annually, the culture 12 team issues a pulse survey to Region I staff, and trends staff responses to 13 identify top themes.

14 During the last pulse survey, the top themes included 15 telework, the new office space, staffing, and workload. The culture team 16 also conducts annual focus group discussions based on topics identified in 17 the pulse survey and FEVS results. The focus groups are separated by 18 division without management present and are completely voluntary.

19 The areas of interest during the last focus groups included 20 management engagement, leading change, and decision making. The 21 culture team noted a lack of resources, communications, and staffing were 22 significant areas of interest to staff. Next slide please. The culture team 23 takes this information from the FEVS, pulse survey, and focus group 24 discussions to inform the Region I culture plan.

70 1 For the 2023 culture plan, the team identified three key 2 focus areas. Management communication, staffing retention and succession 3 planning, and staff workload and burnout. For each focus area the culture 4 team recommended actions and associated due dates to keep Region I 5 leadership accountable.

6 The goal is for the region to continually improve culture, 7 which is why we recommended actions that were realistic and achievable.

8 Examples include communicating the why behind decisions, analyzing 9 current staff workload to identify opportunities to potentially streamline work, 10 and periodically updating staff on the Region I hiring strategy.

11 The culture team will continue to monitor the effectiveness 12 of these actions through staff participation rates in division level team 13 building activities, survey and focus group responses, and informal 14 feedback. Next slide please. Beyond the culture plan, the team also 15 communicated learnings from the recent organizational culture inventory 16 results.

17 Region I was recognized as an office implementing high 18 levels of constructive behaviors during the survey, meaning our organization 19 promotes goal setting, learning, and collaboration. The culture team 20 challenged the region to continue to build upon this foundation. Overall, the 21 culture team continues to provide valuable insight into Region I's culture, and 22 we are proud of the work that we have accomplished.

23 At this point I am going to turn it over to Dan Dorman for 24 closing remarks. Next slide please.

71 1 MR. DORMAN: Thank you, Liz. The Region I staff has 2 touched on a wide variety of topics in this brief presentation, and as we 3 indicated at the beginning, our intent in this overview is to highlight that the 4 Region I staff is effectively implementing the NRC's safety and security 5 mission despite challenges with staff turnover, training new staff, and they 6 are effectively supporting states seeking to become agreement states.

7 We are mindful that the coping strategies implemented in 8 recent years to accomplish the mission are not long-term solutions to the 9 staffing challenges. And we understand while the fundamental mission of 10 protecting the people and the environment has not changed, we do need to 11 adapt in the ways that we accomplish the mission, and how we engage staff 12 in our culture.

13 So, this concludes the staff's presentation, and we look 14 forward to your questions.

15 CHAIR HANSON: Thanks, Dan. Thanks to the staff panel 16 from Region I, really appreciate it. Commissioner Wright, over to you.

17 COMMISSIONER WRIGHT: Thank you, Chair. So, good 18 morning to each of you, thank you for your presentations. As I mentioned, 19 I'm really happy to be here in Region I, I mean you have a great facility here, 20 and it's very flexible the way you set it up, it's impressive, this is really nice in 21 here. And I love being in your stomping grounds, and hearing about what's 22 on your plate.

23 If our residents are boots on the ground, then the regional 24 staff are truly the front lines of the work that we do. I think we would agree

72 1 with that. As I said earlier, I got to spend the day yesterday at Peach Bottom 2 with Scott and Corey, and I just learned earlier that Liz's husband was the 3 resident at Peach Bottom before Corey, isn't that right?

4 And I was very impressed with the professionalism, the 5 dedication, the expertise of both the senior resident and the resident there, 6 and they do that every day, that's just normal, that's just the way they do 7 business, they're that good, and the residents at every other plant that I've 8 been to exhibit the same qualities.

9 So, Jason, thank you for your service at Ginna, as senior 10 resident as well as for your presentation today, it was very well done. And 11 with that, I think I'm going to probably start with some questions on the 12 resident program, and some about the overall framework and stuff. So, Dan, 13 I guess I'll come to you first, this Dan, and then this Dan can answer too.

14 Y'all can each chime in. And Jason you can too as well, 15 right? So, I want to talk a little bit about workload coverage for resident 16 inspectors. This is clearly an extremely important role, and I'm also thinking 17 in terms of work life balance, which was mentioned, for our residents, and of 18 course we need to make sure the mission is accomplished, that's number 19 one.

20 But we also want to make our residents, let them take time 21 to maybe go on vacation, go to their kid's first birthday party, or go to a piano 22 recital, or a soccer game, or something like that to get some time to 23 decompress, to just step away from their roles for a bit. And knowing that 24 there's coverage to get the mission done, right? Also every site is different.

73 1 With varying distances from regional offices for example, 2 and the one that comes to mind most is Diablo Canyon in Region IV, it just 3 takes a long time to get there if you wanted to provide backup from the 4 region. So, with that in mind has there been any recent consideration given 5 to adjusting the number of residents per site, or for certain sites, like 6 specifically I mentioned Diablo Canyon for example.

7 That would enable the flexibility that is needed to help 8 these residents. So, I'm not saying it needs to be country wide, I'm just 9 saying are there specific areas, have you looked at that?

10 MR. COLLINS: Thank you, Commissioner. So, with 11 respect to assignment of an additional resident inspector, we haven't 12 necessarily discussed increasing that. Our experience has been that the 13 current resident staffing, when filled, is sufficient to accomplish the baseline 14 inspection program. We do have, however, recent experience with a former 15 senior resident who is currently on full time telework still in the location of his 16 former site providing supplemental coverage.

17 Both during times where current staff needed to take time 18 off for whatever reason, or even during event response. So, I guess the 19 short answer to your question is there is a discussion going on now about 20 having inspectors in the geographic proximity of plants, but not necessarily 21 as assigned resident inspectors, if that helps.

22 COMMISSIONER WRIGHT: Yeah, so I was at Diablo, for 23 example, and I did hear firsthand that they can't take off. You've got two 24 plants and you're down to one inspector, they can't take off, and they're

74 1 having difficulty getting the backup from the region, and they're very vocal 2 about it, and I appreciate the fact that they're very vocal about it.

3 So, I know it's an issue, and I just wondered, Dan, do you 4 have anything you wanted to add?

5 MR. DORMAN: Yeah, I was just going to offer, obviously 6 there's the day-to-day things that are challenges, I think things like vacation 7 you can plan for, and work with the branch, there are resources in the region 8 who can help provide coverage so that resident inspectors can take their 9 time off. Also from time to time resident inspectors are called on to support 10 supplemental or reactive inspections at other sites.

11 They do visits to other sites as part of their -- what's the 12 word I'm looking for there, not accountability, their --

13 COMMISSIONER WRIGHT: Objectivity?

14 MR. DORMAN: Objectivity, thank you, visits to other sites 15 to see how other residents are applying the program. And so, obviously the 16 region management needs to work with them to plan those activities, and 17 provide coverage from the regions, because as Mel indicated, half of the 18 engineering inspectors in Region I are former residents, and the project 19 engineers in the branches are typically qualified to go support them too.

20 So, the planned things you can manage too, I think the 21 bigger challenge is we've had the turnover in recent years that when you're 22 getting people out to the plant as resident inspectors who are just Appendix 23 A qualified, the basic qualification, and are still working on their full 24 qualification, it becomes more challenging. But for the planned things there

75 1 are things you can do.

2 And I think one of the concerns I would have with adding 3 another resident is, as Dan said, you can do the baseline with the existing 4 complement, so if you add another body out there, or they're assigned out 5 there, but we start using a third of three people's time elsewhere, it's a 6 different management challenge.

7 COMMISSIONER WRIGHT: Yeah. Well, we obviously 8 have an issue right now, because we even heard Jason talk about it too. So, 9 Jason, I'm going to come to you for a second, and the time I've got left, I 10 don't know how many minutes I've got left, four, but okay. So, Jason, there's 11 an ongoing conversation about recruitment challenges for resident inspector 12 positions.

13 And we also know that it's an incredibly important job, and 14 it's real hands-on experience stuff that you talked about, is so valuable not 15 just for the agency, but for individual staff development too, right? And so 16 one idea that I've heard, and it actually came from outside the agency, and 17 we've done a version of this before, is creating something like, I don't know, 18 maybe a semi-mandatory rotation for newer employees to spend a couple 19 weeks or more inside a plant.

20 Which we used to do, what was it called, the Nuclear 21 Safety Professional Development Program, right? So, they actually did do 22 that in order to kind of complete, round you out. What do you think about 23 resurrecting some kind of version of this program, or that program again?

24 Do you think it would help with the day to day?

76 1 And I'm really kind of looking at it as do you think it might 2 help create, pique some interest for people to get into the program?

3 Because we're looking for ways to encourage.

4 MR. SCHUSSLER: Yeah, the program you speak of, I 5 remember folks going through that qualification process and their extended 6 rotations at the site. So, yes, I think that it also increases the transparency 7 of the role, right? They get to see firsthand the fun and excitement that we 8 have during a refueling outage, and the challenges that go along with it.

9 So, it's a realistic -- I think that's a highlight of the current 10 NRAN provides an apprenticeship rotation at the site where the individual 11 gets to see and shadow the resident inspectors. So, I think that creates a 12 longevity of folks who enroll, and kind of starts that training process 13 throughout that.

14 COMMISSIONER WRIGHT: Thanks. In the tours that I've 15 done so far, I've experienced pretty much everything you can as a resident, 16 and I look forward to getting my qualifications. Thank you.

17 CHAIR HANSON: Thank you, Commissioner Wright.

18 Commissioner Caputo?

19 COMMISSIONER CAPUTO: Well, good morning, thank 20 you all for your presentations. It's great to be here in Region I, it's wonderful 21 to be able to see all of you in person, and hear all of the good things that are 22 going on in Region I. I want to particularly recognize Mr. Schussler for his 23 hospitality and wonderful support of my visit to Ginna last year.

24 I also want to commend you just on stressing the value of

77 1 the in-person training with up-and-coming NRC staff, and the window into 2 resident inspector work that Commissioner Wright has been talking about.

3 Just thank you for your dedication and commitment to providing all of that.

4 One area that's received a fair amount of attention from stakeholders these 5 days is the agency's progress and review of license renewal and subsequent 6 license renewal applications.

7 I'd like to highlight the fact that there really is an interface 8 between oversight of a licensee's existing aging management programs 9 during the period of extended operations, and the review of subsequent 10 license renewal applications. So, there's an intersection with the focused 11 engineering inspections that Mr. Gray had mentioned.

12 It makes sense to me that the agency would coordinate 13 these types of inspections to some extent with review of subsequent license 14 renewal applications, or even in advance of license applications that we 15 anticipate coming in. Mr. Gray, could you discuss how you and your staff 16 work with folks in NRR to sort of maximize the value and the lessons coming 17 out of these aging related inspections?

18 MR. GRAY: Sure, thank you for the question. First of all 19 we have a suite of license renewal related inspections we do, phase one 20 through four as a plant gets towards its period of extended operation. And 21 then when they're in the period of extended operation we have the baseline, 22 and also one phase four inspection five to ten years within the PEL.

23 We communicate -- Region I plants are further along than 24 some of the other regions. Our touch with headquarters is probably during

78 1 the quarterly license renewal counterpart call we have with the NRR's 2 projects in license renewal where we share information about what we're 3 finding, what inspection reports we have out, and we get insights on where 4 the interest -- highlight operating experience that should be ensured to be in 5 the GALL for subsequent license renewal or a rev. So, that's our touch, we 6 also have a touch with it's called a materials engineering counterpart call, 7 which is monthly, which touches all things materials related between NRR, 8 research, and all four regions where we share anything material related, it's 9 usually a containment, reactor coolant system.

10 But it does go into license renewal and aging issues in 11 general. So, those are our touches to make sure that we implement the 12 inspections when we see areas that we think would warrant further focus in 13 developing the supporting licensing action infrastructure, we communicate 14 those.

15 COMMISSIONER CAPUTO: Okay, thank you for that. Mr.

16 Collins, I'm going to pose this question to you, I think, unless Dan and Mel 17 want to dive in as well. But I was recently in Region II, I had a wonderful all 18 hands meeting with the staff, but also got a presentation from the 19 management team. One of the things that it sounds like they really focused 20 on has been accelerating qualifications.

21 Not streamlining or reducing the qualifications but looking 22 for ways in which to expedite getting people through those qualifications just 23 based on the number of staff that we're onboarding, the work that needs to 24 be done, and managing to meet those needs. So, is there something that

79 1 happens at the regional administrator level that translates these best 2 practices?

3 And are you looking, have you looked at the nature of the 4 successes in Region I, in expediting qualifications, and are you working on a 5 similar effort here?

6 MR. COLLINS: Yes, so we are working on a similar effort, 7 Commissioner. In terms of communication at my level, I have a biweekly 8 phone call with my peers in the other regions, and we talk about issues such 9 as this. We also have monthly meetings with each of our technical divisions, 10 and they share some of their successes that they're having.

11 So, we're aware of the success that Region II had. We 12 also had two of our current resident inspectors went through the pilot 13 program for the final qualification practical at TTC, and provided feedback to 14 help improve that process. And then we currently have one individual who is 15 nearly completed with the qualification through the CBQ process, and he'll 16 be finishing up in December.

17 COMMISSIONER CAPUTO: Thank you. I just was really 18 impressed with the effort there, because it was clearly data driven. I think it 19 really illustrated how useful a dashboard can be, and really documented the 20 results that they've achieved, so I look forward to having hopefully all of our 21 regions take sort of a data driven approach to such an important topic.

22 Ms. Gaskins, while Mr. Semancik was very 23 complimentary, said thank you for your dedication and your effort there, so I 24 have a couple of questions. You've been with us for 19 years, of those 19

80 1 how long have you been an RSAO?

2 MS. GASKINS: I've been an RSAO for three years, it'll be four 3 years actually in January 2024.

4 COMMISSIONER CAPUTO: Well, congratulations on your 5 upcoming anniversary, thank you for that. So, when you put up the map it 6 was pretty striking how Delaware and Puerto Rico are the only non-7 agreement state entities. So, as states proceed through the agreement state 8 process, obviously there is a fair amount of work for you and your colleagues 9 in supporting that transition to agreement state status.

10 Once that transition has happened, how does that affect 11 your workload, and your staffing?

12 MS. GASKINS: So, currently there are two regional state 13 agreements officers in Region I, and we divide the states as a primary point 14 of contact. And as the primary point of contact, we answer questions, we 15 support the Integrated Materials Performance Evaluation Program, or 16 IMPEP, with the state. And we will continue to do that once Connecticut and 17 West Virginia become an agreement state.

18 We will continue to support those efforts, as well as be a 19 point of contact and a resource. Because as they have questions, especially 20 with being a new agreement state, they may rely on us, or reach out to us to 21 ask those questions, and we'll be available, that's part of our normal duties, 22 to be available to answer those questions.

23 COMMISSIONER CAPUTO: Okay, good. For staff that 24 have been engaged in conducting these inspections within those states that

81 1 will no longer be conducting those inspections, what does the path forward 2 look like for them? Do they have opportunities to move into other spots, or 3 qualify for other roles? Are we finding opportunities for them?

4 Because clearly they are important contributors to the 5 agency, and just because their work may not be needed in those states any 6 longer, we clearly need to put the expertise and dedication to bring to bear 7 elsewhere. So, are you seeing opportunities for qualification and 8 reassignment to other positions?

9 MS. GASKINS: So, I'll start that question, but I'll also ask 10 Dan to talk about the staffing as well. Remembering that as a state goes 11 through agreement, there are a few NRC licenses that will remain, those are 12 federal jurisdiction licensees, as well as licensees that decide to split and 13 become NRC and have temporary job sites.

14 So, I believe that there will be still a need for inspectors 15 and license reviewers in those situations. And there have been 16 opportunities, or other places that they can look to, but I'll let Dan speak on 17 that a little more, I think he'll have a better.

18 MR. COLLINS: Thanks Farrah. So, Farrah's correct, there 19 are going to be continuing licenses in the states that will be NRC licenses 20 that we will continue to inspect, although we will have fewer, we know that.

21 The staff will have opportunities to perform both licensing and inspection 22 work as they do now.

23 And there will also be opportunities, for example in the dry 24 fuel storage, or the decommissioning for the HP related functions that we still

82 1 perform. And we know that there is going to be a draw down in our budget, 2 and any new staff that we would hire today takes 18 to 24 months for them 3 to qualify.

4 So, by the time they would finish a qualification if they 5 came in the door today, they'll be finishing their qualification right about the 6 time that Connecticut would become an agreement state. So, we're looking 7 very carefully at each and every hiring action in the materials world to make 8 sure that we don't get to the point where we have too many staff and not 9 enough work.

10 COMMISSIONER CAPUTO: Are you seeing any interest 11 in people who have been spending their time as materials inspectors shifting 12 into the resident program?

13 MR. COLLINS: Generally, well not a lot, there have been 14 one or two.

15 COMMISSIONER CAPUTO: All right. So, Dan Dorman, I 16 have one question following up from the resident trust huddle. Can you just 17 tell us what actions are underway to address the nature of what was 18 discussed in that trust huddle? Because I expect there was probably latitude 19 to address some things, maybe not room to address others.

20 But can you just tell us where things stand having had the 21 conversation what actions are going to actually flow through that to address 22 as many concerns as you can?

23 MR. DORMAN: Yeah, thanks for the question, 24 Commissioner. There are two specific actions that are currently being

83 1 worked through, and I hope to get one of them out here this month, and the 2 other one by the end of the calendar year, that relates to recruitment and 3 retention. One of them is tied to retention incentives, and the other is tied to 4 the end of tour telework that was mentioned in the briefing.

5 Particularly even going back to when I was here in Region 6 I, we used end of tour telework on an ad hoc basis. Several years ago, end 7 of tour telework was captured as a more systematic approach through a 8 memo from, I think the director of NRR to the EDO at the time, and one of 9 the recommendations out of the trust huddle was to kind of reverse that and 10 make that agency policy.

11 And they have a memo from me to NRR and NNSS, 12 because we do have two resident inspectors in the fuel facilities program, to 13 make it so for the people approaching the end of tour, they have a more 14 reasonable expectation of a consistent application of that resource to help 15 them with their next transition. So, those are two specific actions that are 16 currently actively being worked.

17 I'd have to get back to you on some of the other things that 18 came out of that that are also being worked with the resident program 19 manager in the Division of Regional Oversight in NRR.

20 COMMISSIONER CAPUTO: Okay, so one issue that's 21 come up before, and it's still coming up, is the nature of relocation, and the 22 tax treatment of relocation expenses. I have to admit I'm a little surprised 23 that this is still an issue. Is this an issue that requires Commission action, is 24 this an issue that requires a legislative fix? I for one would --

84 1 MR. DORMAN: Let me get back to you on that one, 2 because I know it was a legislative fix, because it was a legislative fix that 3 put us in this box, but I'd have to get back to you --

4 COMMISSIONER CAPUTO: But that was years ago.

5 MR. DORMAN: That was several years ago, and I know 6 that CFO worked prestigiously to identify where we could provide some 7 relief, and one of the difficulties that the residents have experienced in that is 8 even when we come back and compensate, that compensation becomes 9 taxable, and it comes several years after the fact with a lot of paperwork.

10 So, I think that I could definitely take that back, and get 11 back to you on where that currently stands, and where you could help, or 12 potentially we may need legislative.

13 COMMISSIONER CAPUTO: Because I would think that 14 there would probably be legislative interest in fixing this. And I for one would 15 certainly be very interested in reviewing whatever steps we might need to 16 ask of Congress to fix this for our residents. Because I think that's a fairness 17 question, and I would imagine there's probably a receptiveness to 18 addressing this, but it would take some time.

19 But there's no better time than the present certainly to 20 come up with a solution and come to the Commission with what's necessary 21 here. So, I certainly would like to see the staff recommend to the 22 Commission what options there are for addressing this, so that we can act 23 accordingly.

24 MR. DORMAN: Appreciate the support, I'll get on it,

85 1 thanks.

2 COMMISSIONER CAPUTO: Thank you.

3 CHAIR HANSON: Commissioner Crowell?

4 COMMISSIONER CROWELL: Thank you, Mr. Chair.

5 Thanks to everyone for their presentations today, I thought they were all 6 excellent. I wish I had ten minutes at least with each of you to go back and 7 forth on things that popped into my head in addition to what I prepared 8 previously. I'm going to pick up a little bit where Commissioner Caputo left 9 off on the agreement state topic, but from a different perspective.

10 So, Ms. Gaskins, I'll give this to you first, but either of the 11 Dans can jump in as well. But what happens from a resource perspective 12 when an agreement state like New York recently, gives back part of their 13 authority to the NRC? How do we manage that from a resource 14 perspective? Just any comments on how we should meet those challenges?

15 MS. GASKINS: So, when New York gave back a part of 16 their agreement, it went to the specialized group in headquarters. So, that 17 became a part of their resources. I unfortunately can't speak to how it 18 affected that group, but that part of the agreement that they returned went 19 back to -- I'm sorry, a specialized group in headquarters.

20 COMMISSIONER CROWELL: So, either Dan, but Dan 21 Dorman, if you know.

22 MR. COLLINS: So, that gets addressed through the 23 budgeting process to add back some resources, typically you're looking at a 24 fraction of an FTE.

86 1 COMMISSIONER CROWELL: Okay, I guess we have 2 new states on the cusp of becoming agreement states at the same time at 3 least one state is giving back part of its authority, does that present an 4 opportunity to shift staff resources from those that were previously working 5 with the non-agreement state to say, support New York, or another state 6 giving back part of their authority?

7 I mean is that, do we have to do it through a whole new 8 fresh budget process, or can't we just shift staff as one state becomes an 9 agreement state, and another gives partial authority back?

10 MR. DORMAN: So, I think the issue there is what they 11 gave back is typically done out of NMSS as a specialized thing. So, yes, the 12 resources come back to the agency, but not necessarily in the same place, 13 and that would be handled through NMSS' leadership in the business line 14 formulation.

15 COMMISSIONER CROWELL: What leads to a state 16 giving back their authority in any respect? Either in the New York example, 17 or another example, how and why does that happen?

18 MS. GASKINS: So, in this particular case, because I am 19 also the point of contact for New York, New York wasn't receiving enough 20 amendment requests, and enough opportunities to be able to train their staff 21 effectively in the areas that they were able to -- so that they could have an 22 effective program. They did have trained staff, but as staff began to come 23 on, they felt that it was a better position for them to return that portion of their 24 agreement.

87 1 While in other parts of their agreement they thought it was 2 best for them to return that agreement in that particular case.

3 COMMISSIONER CROWELL: Was it -- do you know if 4 New York was having a budget issue in terms of hiring and retaining staff to 5 do that, or it was just a turnover in experienced staff, and training new staff 6 issue 7 MS. GASKINS: I don't believe it was a budget, I believe it 8 was more of a turnover. So, as new staff began to come on, while they did, 9 like I said, have qualified staff available, as new staff, and they were trying to 10 train them, the new staff, there weren't enough types of actions to effectively 11 train them. So, they didn't have --

12 COMMISSIONER CROWELL: I see, got you. And if and 13 when they have more actions, or activities, if that transpires, how hard is it to 14 reverse course, and for them to reassume that authority if it were 15 appropriate?

16 MS. GASKINS: They would need to come in and ask for it 17 again --

18 COMMISSIONER CROWELL: And go through the whole 19 process, or would it be expedited, or less arduous given that they're already 20 partially an agreement state, or have been a full agreement state before?

21 MS. GASKINS: I'm going to allow Dan to answer that.

22 MR. DORMAN: I would think there would be efficiencies to 23 be gained, particularly when they've already regulated the area, if they 24 haven't gotten rid of their regulations in their state regulations, then we would

88 1 just need to make sure that, from any compatibility aspect, that they were up 2 to date as part of the transition back, and then make sure that they had the 3 trained and qualified reviewers and inspectors ready to pick it back up.

4 So, I think it would probably be a more efficient process, 5 because a lot of the things that you heard about today from Jeff and Farrah 6 would already be in place.

7 COMMISSIONER CROWELL: Yeah, depending on how 8 long it's been.

9 MR. DORMAN: Right.

10 COMMISSIONER CROWELL: Yeah. Switching topics 11 here. Mr. Gray, I'm going to turn to you for a second here. So, I'm very 12 interested to learn about that quadrennial engineering inspection program, 13 and the focused engineering inspections that began this year. Do you have 14 any insights you can share with us today, at this point in the program's 15 history, that can shed any light on licensee performance issues that have 16 been identified as a result of this program being put in place, with 17 inspections happening?

18 MR. GRAY: I think the strength of the program is we're 19 looking at areas where we think the risk might be most evident. So, the 20 strengths of these are that they're highly risk informed, the procedure has 21 you look in certain areas. You look at those, you focus on performance-22 based attributes, and you get insights from that.

23 Probably the comprehensive engineering team inspection, 24 that is a foundation, I think contributes to very mundane, boring fleet

89 1 operation. What it does is it finds problems that won't show themselves in 2 good operation when the balance of plant is working well. They'll find issues 3 where only under limiting conditions there could be, where equipment is 4 called upon to work, where there are some performance deficiencies.

5 One involves a modification was done at a plant, if a 6 balance of plant pipe broke, the water in that area was going to be four feet 7 higher, and it interfaced with emergency diesel doors, and data room doors, 8 and we didn't find -- the licensee did a good job on that to affirm those doors 9 were sufficiently leak tight.

10 So, we found that, they ensured they had that margin, but 11 that's something we documented. It's green, but it really gives confidence 12 that plants, their capability to perform under conditions that aren't 13 demonstrable by operation, and they give us insights on the risk models, that 14 the risk models are -- they have fidelity to the as maintained, as operated, as 15 built plants.

16 COMMISSIONER CROWELL: I appreciate that answer, 17 and I think it relates directly to another topic Commissioner Caputo brought 18 up about license renewal and subsequent license renewal. I think the 19 strength of the program that you just described would lend itself directly to a 20 more efficient, robust license renewal process, because you know those 21 things on a ongoing, or an advanced basis. Is that fair to say?

22 MR. GRAY: Those processes cross talk all the time. That 23 is the strength, I think, of the agency. And I would say that that strength has 24 really been enhanced by something as mundane as Microsoft Teams.

90 1 Where we used to be around the phone, and now our touch points are all by 2 Teams with sharing of documents, and it's just -- so in all those operation 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> back to the licensing actions and oversight, I think we have much 4 more touch points than we ever had in my experience of 25 years with the 5 agency.

6 COMMISSIONER CROWELL: Yeah, it's always ironic that 7 the mundane things usually add up to be the most significant, important 8 things in some. I find myself today thinking back a lot to my prior 9 professional experience, particularly as a state regulator, and how -- I think 10 there's the most similarities with how the regions do their work.

11 And having run a large state agency prior to joining the 12 NRC, I was thinking about our park rangers, they're qualified in 13 environmental resource issues, and often public safety, or enforcement 14 issues. Our firefighters are trained as foresters, and firefighters are 15 environmental inspectors, or engineers, and scientists, but they're not 16 trained to be necessarily communicators or interactors with the public, but 17 they are the tip of the spear when it comes to interacting with the public.

18 And so, maybe Mr. Schussler, to you, or whoever, if it 19 doesn't already happen, would it benefit for regional inspectors or other parts 20 of the regional office, or even headquarters office, that are first line 21 interactors with the public to get some training on how to engage 22 stakeholders? And not talking about licensees, I'm talking about the public, 23 and our more citizen stakeholder types.

24 MR. SCHUSSLER: Yeah, thank you for the question.

91 1 During our qualification process we have a communication, public media 2 course we take. And I think that just starts the conversation. I would offer 3 that you heard from the previous panel, the community night for the public 4 outreach, I participated in those several years in a row, each year I think I 5 got better at that conversation.

6 But it starts with reaching out to the experts in the regional 7 office to understand strengths and weaknesses and build upon those. So, to 8 answer your question, yes, I think there's opportunities for technical staff to 9 grow in that area beyond what we already do.

10 COMMISSIONER CROWELL: And do you think that 11 internally the resources are available for staff to grow in that area, or we 12 should avail ourselves of external options, or increase the quality of our 13 internal training opportunities in this regard?

14 MR. SCHUSSLER: I would offer there's a part there, a 15 little bit beyond my sphere of influence. But personally, myself, I have 16 resources available to me, and that's going to be different based on the 17 individual, so I would offer it to Dan to respond as well. Thanks.

18 MR. COLLINS: Sure. Thank you, Commissioner. I agree 19 with what Jason said, there's probably room for some additional training. I 20 think one of the things that the public affairs staff here point out to us time 21 and time again when we're getting ready for public interactions is that we 22 need to be mindful that we're talking technical language, and the public 23 stakeholders really are coming from a more emotional standpoint.

24 And we need to make sure that we're communicating in

92 1 plain language, and acknowledging their legitimate concerns, and not just 2 burying people with technical jargon.

3 COMMISSIONER CROWELL: And that's a skill that you 4 don't necessarily -- you will learn it in a trial by fire manner, but it's not the 5 best way to do it. Because if you start in a hole in terms of building and 6 maintaining that relationship with the public, and for resident inspectors, 7 these are your friends and neighbors, you live in these communities.

8 That's not a deficit you want to start, you want to start 9 feeling like you know how to communicate, and what level you should be 10 communicating on, and I'd say the federal government at large is not good at 11 that. And so, I'd love to find some, make sure we have the external 12 resources as well to bolster our competencies in that area. But thank you, 13 appreciate it. Thank you, Mr. Chair.

14 CHAIR HANSON: All right, thank you, Commissioner 15 Crowell. Dan, I guess I wanted to, I'll start with you, I've got a couple of 16 questions that I want to kind of pull the thread on. The very low safety 17 significance issue resolution process, colloquially known as VLSSIR was 18 started in 2020 as a way to review and assess and disposition issues of very 19 low safety significance.

20 So far, it's been used across the agency, I think to 21 disposition about 20 issues or so. Most of those in Region II. Region II is 9, 22 and Region III is 5, and Region IV is 4, and then Region I has 2 of those 23 issues. And I just wondered if you could kind of tell me about Region I's 24 implementation of VLSSIR, and from a change management perspective,

93 1 and do you think there's sufficient buy in from staff?

2 And can you just give me some insights on that data set, 3 particularly with regard to Region I's utilization of that?

4 MR. COLLINS: Yeah. So, in the first instance where we 5 used it, it was actually a staff recommendation to management to use the 6 VLSSIR process after extensive engagement with the licensee on the 7 particular issue it was being used. And the second issue, it was we got to 8 the decision to use VLSSIR after extensive dialogue with headquarters on 9 some issues related to insulation on piping that makes up a containment 10 barrier.

11 So, I would say to your question, Chair, about is there buy 12 in from the staff, I would say it's mixed, and it depends on the issue at hand.

13 But the staff have all been trained on it, and I know that the branch chiefs are 14 very good about having the risk discussion with their teams as they're going 15 through issues, and as they consider how to disposition the various issues.

16 CHAIR HANSON: So, is that a question then, if issues are 17 identified as part of that evaluation process? And maybe Mel, this is a 18 question for you too. Is that question, Is this appropriate for VLSSIR?, is 19 that a specific thing that gets asked, or is it more ad hoc, how is that getting 20 worked into that process?

21 MR. GRAY: Having been the one who did those twice in 22 Region I, I'll give you some insight.

23 CHAIR HANSON: That'd be great.

24 MR. GRAY: I think VLSSIR is most suitable for design

94 1 basis questions which at the end of the day will be very low safety 2 significance, and the effort needed to get to that answer just isn't there. I 3 think the differences across the regions, I don't know why the other regions 4 have more. But all I can say is in Region I, we work hard to understand the 5 design basis and licensing basis, retrieve it from ADAMS, and go from there.

6 And we haven't hesitated to use it where we think it's 7 appropriate in both cases. And so, it might be just the sampling to date that 8 we've used it less, I don't see a bias against using it. I think any inspector 9 would, if we have too many deviations from the enforcement process, or 10 other processes where we segue, that can affect inspectors.

11 We've got to be careful they don't feel like they're not -- the 12 process has too many off ramps, I'll use that, I don't like that term, but we 13 need to make sure we follow enforcement, and when it's appropriate and 14 flexible, that this process better fits, we do that. And I think we've done that 15 when VLSSIR is appropriate in Region I.

16 CHAIR HANSON: Yeah, that's helpful. And I 17 acknowledge, Mel, the other side of that coin, where when we first 18 implemented VLSSIR, that was one of my questions for residents and other 19 kinds of inspectors, was hey, have we created so many off ramps where 20 people don't feel like they can raise even what ultimately are low safety 21 significant issues, right? Because you want to take issues and run them 22 through that process in a systematic way.

23 And I was assured across the board, and across the 24 country as I traveled around that that was not the case, that inspectors still

95 1 felt like they could raise all the issues, and then move them through that 2 process. On the other hand, we kind of had this early uptick in use of 3 VLSSIR, kind of here's this new process, let's try this out.

4 And I think it's kind of come down over time, and I want to -

5 - I think it's worth exploring why that's the case, and what the reasons for use 6 or not are of that process as we kind of continue to risk inform our inspection 7 practices. So, Dan, I don't know if you want to comment there.

8 MR. DORMAN: If I could, just briefly to reinforce that 9 VLSSIR is appropriate in a case where the staff finds ambiguity in the 10 licensing basis and using risk insight to determine how much time we're 11 going to spend figuring out the disambiguation. And in fact, one of the 12 issues that drove us to creating VLSSIR was here in Region I, where we had 13 an issue that we sent to headquarters, and it bounced around for a really 14 long time.

15 And we all knew that it was going to be a green non-cited 16 violation if it bounced through as a compliance issue, and we just can't 17 spend our time on those kind of things. So, there's -- I would say that the 18 fact that there's been about 20 over several years tells you that there's some 19 ambiguity out there around the margins of the licensing basis, but not that 20 much.

21 Because I think if it's clearly a non-compliance issue, then 22 Mel and his team are going to take it into the appropriate enforcement 23 process and disposition.

24 CHAIR HANSON: That's helpful, thanks Dan, I appreciate

96 1 that context. This got touched on in a couple of different directions, and I 2 certainly want to associate myself with Commissioner Wright, and his getting 3 creative about how to address some of these staffing challenges. I guess I 4 would ask the question this way, is what can headquarters do to better 5 support the regions, particularly, certainly resident inspectors, and maybe 6 there's an opportunity there.

7 But also I'm just thinking about engineering inspections, or 8 specialized inspections, and how can we -- can we augment regional staff 9 with qualified headquarters technical staff? Maybe that's already happening 10 some, but maybe we could be doing it more. Dan, and Mel, I just kind of 11 want to get your thoughts on that.

12 MR. COLLINS: Okay, I'll let Mel go first on that since he's 13 closes to it.

14 MR. GRAY: A couple of discrete things, I think just 15 engineering inspections, we have an IOU back to the commission in two 16 years to see whether we got the bang for the buck from our changes, and I 17 would just -- that, and where we might go from there, probably attention to 18 that, ensuring it's driven by operating experience, and it's cross regional 19 input on that I think would benefit.

20 A discrete item that the Commission could help is from a 21 selfish point of view, engineering, I covet senior resident inspectors who 22 have done multiple tours in locations, and now I have the tools in the 23 toolbox, and I can use them for three years, and then we have to navigate 24 other processes. I think it's a great fit for former senior resident inspectors

97 1 staying in the area for personal reasons to serve in engineering branches.

2 They have more face-to-face contact because they're 3 always on teams, or at sites, than many people. So, the remote doesn't 4 really fit, that title doesn't fit to their situation. It would encourage long term 5 service in the resident inspector ranks, and it's a benefit to my branch to 6 have them. And finally, they're just a remote resource to help cover areas, 7 it's most germane to Region I, II, and III, not IV, maybe IV, but those are all 8 benefits. So, attention to that would be helpful.

9 CHAIR HANSON: Okay, thank you, that's very helpful.

10 So, I guess kind of flowing downhill of that in a way, Mel, this is maybe a 11 question for you, maybe a question for Jason. We heard this a little bit from 12 Matt Herr, it's kind of one thing to, and I think this is an important step, but 13 having licensees adopt things like 50.69 and TSTF-505.

14 And then there's the knowledge that's gained from the risk 15 informing the classifications of some of this, but then it's the okay, kind of 16 what difference does that make, how does that change, or focus our actual 17 inspection practices based on the results of those analyses, and those 18 approvals? So, maybe talk to me about how either engineering or resident 19 inspectors are kind of evolving those practices kind of based on those 20 evaluations.

21 MR. SCHUSSLER: Yeah, thanks, Chair. I actually 22 personally had an opportunity to perform an inspection on the uses of risk 23 informed completion time in the field, so that really, we have inspection 24 procedures that support that guidance for the resident inspectors. And it got

98 1 into the details of the licensee's risk model, and our own internal risk 2 modeling software on compensatory measures, and things of that nature and 3 how the barriers are put in place to ensure safe operation. So, I think we're 4 going to continue that effort in the field, and thanks.

5 CHAIR HANSON: Yeah, thank you. Go ahead, Mel.

6 MR. GRAY: I would say we see those changes in our 7 inspection procedures in the engineering area where they accommodate 8 those plants who have implemented 50.69, and their special treatments are 9 now different treatments. So, this is a journey for us, I personally have seen 10 the benefits at a plant where they can invoke that approach and get 11 equipment back to service more quickly that's safety related.

12 So, I see benefits. I think there will be challenges in that 13 when that regulation was put out, it was not, I don't think envisioned your risk 14 bin, and then you have active -- passive, risk bin all the components, it was 15 at the system component level, and now it's going to subcomponent level.

16 That's going to be a challenge for inspectors to navigate to make sure that 17 the internals of a certain component don't affect things like the reactor 18 cooling system barrier.

19 And that binning is going to be an additional complexity 20 we'll have to work through.

21 CHAIR HANSON: Yeah, there's a systems engineering 22 kind of integrated approach overlay that has to happen on some of that stuff.

23 MR. GRAY: Right.

24 CHAIR HANSON: Yeah, very helpful, thank you. I know I

99 1 have like 15 seconds left, but Liz, I just wanted to -- she looks surprised, I 2 caught her off guard. No, so just briefly, we talk about improving culture.

3 What does that mean, what are those -- in Region I, or even just across the 4 agency, what are we talking about when we're talking about improving 5 culture?

6 Because we've got FEVS scores, and often times the 7 FEVS scores that everybody pays attention to are global satisfaction or 8 overall satisfaction. That's related to culture, but it's not culture. So, in terms 9 of the culture efforts in Region I, what are those levers, what are those traits 10 that you're actually trying to improve?

11 MS. ANDREWS: I think in Region I we're really looking at 12 the behaviors in the OCI, the organization culture inventory, those blue 13 constructed behaviors, and working towards those. And as you saw in the 14 presentation, in Region I, we have a lot of those, but there is a lot of 15 improvement that can be made.

16 So, during one of our all employee meetings, during our 17 presentation, we put up all of those attributes and said hey, choose one, 18 work towards it, and really try and master it. It's a work in progress, I used a 19 whole example about I thought I was doing great, and then I snapped at my 20 husband one day and had to start back down.

21 But I do think that its something important for the culture, 22 just to keep those attributes in mind, and actively work towards those, and 23 overall that'll help us improve our culture.

24 CHAIR HANSON: No, that's helpful, you're actually using

100 1 the things in the OCI, those encouraging humanistic, the constructive, the 2 things kind of up at that noon, 1:00 o'clock, 2:00 o'clock part of the circle 3 there, and pulling off one of those, and really focusing on that. Super 4 helpful, thank you.

5 MS. ANDREWS: Thank you.

6 CHAIR HANSON: Well, look at that, we have reached the 7 end of our time together. Thank you all very, very much. Thank you again 8 to Region I, to all the efforts that went into hosting this meeting today. Dan, I 9 know Ray is out sick today, we all wish him a speedy recovery, and hope 10 he's feeling better soon, and gets back in the game very soon. Thanks 11 again to SECY, all the advanced work that went into this.

12 And so many other folks, OCIO, both here in the region, 13 and at headquarters that have made all of this work. Thanks to my 14 colleagues, again, we covered a lot of ground as we often do on these 15 things, and I appreciate the insights and the thoughtful questions as always.

16 With that, safe travels home everybody, and we're adjourned.

17 (Whereupon, the above-entitled matter went off the record 18 at 11:57 a.m.)