NUREG-2261, Dfc, Artificial Intelligence Strategic Plan Fiscal Years 2023-2027, Draft Report for Comment

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NUREG-2261 Dfc, Artificial Intelligence Strategic Plan Fiscal Years 2023-2027, Draft Report for Comment
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Issue date: 06/30/2022
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Office of Nuclear Reactor Regulation
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NUREG-2261
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NUREG-2261

Artificial Intelligence Strategic Plan

Fiscal Years 2023-2027

Draft Report for Comment

Office of Nuclear Regulatory Research AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS

NRC Reference Material Non-NRC Reference Material

As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at the libraries include all open literature items, such as books, NRCs Library at www.nrc.gov/reading-rm.html. Publicly journal articles, transactions, Federal Register notices, released records include, to name a few, NUREG-series Federal and State legislation, and congressional reports.

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information notices; inspection and investigative reports; licensee event reports; and Commission papers and their Copies of industry codes and standards used in a attachments. substantive manner in the NRC regulatory process are maintained at NRC publications in the NUREG series, NRC regulations, The NRC Technical Library and Title 10, Energy, in the Code of Federal Regulations Two White Flint North may also be purchased from one of these two sources: 11545 Rockville Pike

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Address: U.S. Nuclear Regulatory Commission The NUREG series comprises (1) technical and Office of Administration administrative reports and books prepared by the staff Digital Communications and Administrative (NUREG-XXXX) or agency contractors (NUREG/CR-XXXX),

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NUREG-2261

Artificial Intelligence Strategic Plan

Fiscal Years 2023-2027

Draft Report for Comment

Manuscript Completed: Ju ne 2022 Date Published: Ju ne 2022

Prepared by:

M. Dennis, T. Lalain, L. Betancourt, A. Hathaway, and R. Anzalone

Matthew Dennis, NRC Project Manager

Office of Nuclear Regulatory Research COMMENTS ON DRAFT REPORT

Any interested party may submit comments on this report for consideration by the NRC staff.

Comments may be accompanied by additional relevant information or supporting data. Please specify the report number NUREG -2261 in your comments and send them by the end of the comment period specified in the Federal Register notice announcing the availability of this report.

Addresses: You may submit comments by any one of the following methods. Please include Docket ID NRC-2022-0 095 in the subject line of your comments. Comments submitted in writing or in electronic form will be posted on the NRC website and on the Federal rulemaking website http://www.regulations.gov.

Federal Rulemaking Website: Go to http://www.regulations.gov and search for documents filed under Docket ID NRC-2022-0095.

Mail comments to: Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Division of Resource Management and Analysis Staff.

For any questions about the material in this report, please contact: Matthew Dennis, Reactor System Engineer Data Scientist, Tel. 301-415-3702 or by e-mail at matthew.dennis@nrc.gov.

Please be aware that any comments that you submit to the NRC will be considered a public record and entered into the Agencywide Documents Access and Management System (ADAMS). Do not provide information you would not want to be publicly available.

1 ABSTRACT

2 The U.S. Nuclear Regulatory Commission (NRC) recognizes that interest in artificial intelligence 3 (AI) is growing rapidly in both the public and private sectors and anticipates increased use of AI 4 in NRC-reg ulated activities. For the purposes of this document, AI refers to a machine-based 5 system that can go beyond defined results and scenarios and has the ability to emulate human-6 like perception, cognition, planning, learning, communication, or physical action. For a given set 7 of human-defined objectives, AI can make predictions, recommendations, or decisions 8 influencing real or virtual environments. The AI Strategic Plan focuses on a broad spectrum of 9 sub-specialties (e.g., natural language processing, machine learning, deep learning, etc.) which 10 could encompass various algorithms and application examples which the NRC has not 11 previously reviewed and evaluated. Anticipating the industrys potential application of AI to 12 NRC-regulated activities, the NRC has developed a strategic plan to ensure the agencys 13 readiness to review such uses. The strategic plan includes five goals: (1) ensure NRC readiness 14 for regulatory decisionmaking, (2) establish an organizational framework to review AI 15 applications, (3) strengthen and expand AI partnerships, (4) cultivate an AI-proficient workforce, 16 and (5) pursue use cases to build an AI foundation across the NRC. The overall goal of this 17 strategic plan is to ensure continued staff readiness to review and evaluate AI applications 18 effectively and efficiently.

iii

1 TABLE OF CONTENTS

2 ABSTRACT................................................................................................................................. iii

3 LIST OF FIGURES..................................................................................................................... vii

4 LIST OF TABLES....................................................................................................................... vii

5 EXECUTIVE

SUMMARY

............................................................................................................. ix

6 ABBREVIATIONS AND ACRONYMS........................................................................................ xi

7 1 INTRODUCTION...................................................................................................................1-1

8 2 VISION..................................................................................................................................2-1

9 3 PURPOSE AND DRIVERS...................................................................................................3-1

10 4 STRATEGIC GOALS............................................................................................................4-1 11 4.1 Strategic Goal 1: Ensure NRC Readiness for Regulatory Decisionmaking...................4-2 12 4.2 Strategic Goal 2: Establish an Organizational Framework to Review AI 13 Applications....................................................................................................................4-3 14 4.3 Strategic Goal 3: Strengthen and Expand AI Partnerships............................................4-3 15 4.4 Strategic Goal 4: Cultivate an AI-Proficient Workforce..................................................4-4 16 4.5 Strategic Goal 5: Pursue Use Cases to Build an AI Foundation Across the NRC.........4-4

17 5 CONCLUSION......................................................................................................................5-1

18 6 REFERENCES......................................................................................................................6-1

19 APPENDIX A GLOSSARY.................................................................................................... A-1

20 APPENDIX B USING ARTIFICIAL INTELLIGENCE TOOLS TO ENHANCE NRC 21 ACTIVITIES..............................................................................................................................B-1 22

v

1 LIST OF FIGURES

2 Figure 1 Artificial Intelligence Hierarchy and Relationship with the NRC AI Strategic Plan 3 (adapted from [5] and [6])............................................................................................1-2 4 Figure 2 Overview of Strategic Goals........................................................................................4-1 5

6 LIST OF TABLES

7 Table 1 Notional AI and Autonomy Levels in Commercial Nuclear Activities............................1-3 8

vii

1 EXECUTIVE

SUMMARY

2 For the purposes of this document, a rtificial intelligence (AI) refers to a machine-based system 3 that can go beyond defined results and scenarios and has the ability to emulate human-like 4 perception, cognition, planning, learning, communication, or physical action. F or a given set of 5 human-defined objectives, AI can make predictions, recommendations, or decisions influencing 6 real or virtual environments. AI is one of thefastest-growing technologies globally and has the 7 potential to enhance decisionmaking processes for the nuclear industry by providing insights 8 into vast amounts of data generated during the design and operation of nuclear facilities. As a 9 result, the nuclear industry has expressed a growing interest in researching and using AI 10 technologies to improve operational performance and mitigate operational risk. The AI Strategic 11 Plan focuses on a broad spectrum of sub-specialties (e.g., natural language processing, 12 machine learning, deep learning, etc.) which could encompass various algorithms and 13 application examples which the U.S. Nuclear Regulatory Commission (NRC) has not previously 14 reviewed and evaluated. T he NRC is committed tocontinue to keep pace with technological 15 innovations to ensure the safe and secure use of AI in NRC-regulated activities.

16 17 The NRCs AI Strategic Plan, covering f iscal y ears (FY) 2023-2027, establishes the vision and 18 goals for the NRC to continue to improve its skills and capabilities to review and evaluate the 19 application of AI to NRC -regulated activities, maintain awareness of technological innovations, 20 and ensure the safe and secure use of AI in NRC -regulated activities. The AI Strategic Plan 21 includes five goals: (1) ensure NRC readiness for regulatory decisionmaking, (2) establish an 22 organizational framework to review AI applications, (3) strengthen and expand AI partnerships, 23 (4) cultivate an AI-proficient workforce, and (5) pursue use cases to build an AI foundati on 24 across the NRC.

25 26 The AI Strategic Plan complements the NRCs mission, broadly aligns with the agencys 27 Principles of Good Regulation, and is tied to multiple NRC FY 2022-2026 Strategic Plan safety, 28 security, and o penness strategies [1]. The NRC will consider the actions recommended for the 29 short-term (<1 year), mid-term (1 - 3 years), and long-term (3 -5 years) time horizons and will 30 guide budgetary requirements and resource planning within the NRCs standard planning and 31 budgeting processes to achieve the strategic goals in this document.

32 33 The overall goal of the AI Strategic Plan is to ensure the staffs readiness to effectively and 34 efficiently review and evaluate the use of AI in NRC-regulated activities.

ix

1 ABBREVIATIONS AND ACRONYMS

2 AI Artificial Intelligence 3 AICoP Artificial Intelligence Community of Practice 4 AISC Artificial Intelligence Steering Committee 5 FR Federal Register 6 FY Fiscal Year 7 NRC U.S. Nuclear Regulatory Commission

xi

1 1 INTRODUCTION

2 For the purposes of this document, a rtificial intelligence (AI) refers to a machine-based system 3 that can go beyond defined results and scenarios and has the ability to emulate human-like 4 perception, cognition, planning, learning, communication, or physical action. F or a given set of 5 human-defined objectives, AI can make predictions, recommendations, or decisions influencing 6 real or virtual environments. These systems use machine-and human-based inputs to perceive 7 real and virtual environments, abstract such perceptions into models through analysis in an 8 automated manner, and use model inference to formulate options for information or action [2].

9 The AI Strategic Plan focuses on a broad spectrum of sub-specialties (e.g., natural language 10 processing, machine learning, deep learning, etc.) which could encompass various algorithms 11 and application examples which the U.S. Nuclear Regulatory Commission (NRC) has not 12 previously reviewed and evaluated.

13 14 An AI algorithm is a computer program that has been trained on a set of data to recognize 15 certain types of patterns. AI use various types of algorithms to reason over and learn from this 16 data, with the overarching goal of providing solutions that mimic human-based decision and 17 predictions for problems. Unlike developing and coding a traditional software program with 18 specific instructions to complete a task, AI seeks to learn to recognize patterns and make 19 predictions. This AI Strategic Plan considers an evolving landscape where computers use data 20 and unseen behavior to construct the underlying algorithmic model, draw inferences, and define 21 the rules to achieve a task. Advances in computing technologies have led to the expanded use 22 of AI across multiple disciplines in the public and private sectors, both domestically and 23 internationally. AI provides new opportunities for organizations to enhance safety and security, 24 improve processes, leverage historical and current data, identify research needs, and even 25 explore autonomous control and operation. As a result, the nuclear industry has expressed 26 interest in deploying these technologies. The NRC is committed to enabling the safe and secure 27 use of new technologies, especially those that can enhance the safety and security of nuclear 28 facilities. The NRC is committed to keeping pace with technological innovations to effectively 29 and efficiently carry out its safety and security mission.

30 31 The AI Strategic Plan complements the NRCs mission1, broadly aligns with the agencys 32 Principles of Good Regulation, 2 and is tied to the following:

33 34

  • NUREG-1614, Volume 8, U.S. Nuclear Regulatory Commission Strategic Plan: Fiscal 35 Years 20222026, issued April 2022 [1]

36 37

  • NRC, International Strategy: 20212025, issued August 2021 [3]

38 39

  • NUREG-1908, Volume 4, Information Technology Information Management Strategic 40 Plan: Fiscal Years 20202024, issued November 2019 [4]

41 There are numerous fields of work that involve data and foundational concepts in AI (e.g., data 42 analysis, statistics, computer programming, engineering), many of which the NRC already has 43 experience with. However, given major advancements in AI, it is critical to establish how AI 44 builds upon and relates to other data fields to understand the potential uses of AI in NRC-

1 The NRCs mission can be found at https://www.nrc.gov/about-nrc/values.html.

2 The NRCs Principles of Good Regulation and other values can be found at https://www.nrc.gov/about-nrc/values.html#principles.

1-1 1 regulated activities. Figure 1 illustrates these relationships in two different ways. On the left is a 2 pyramid representing the increasing levels of complexity and maturity needed to implement AI 3 within an organization. The foundation of this pyramid is data collection, which establishes the 4 databases from which the AI is developed. Next is data infrastructure, which includes tools to 5 organize and transform the collected data, make it available, and govern its use. From this 6 point, the data may be used in data analytics, which provides plots and descriptive statistics that 7 can be used in decisionmaking. Once the organization is capable of data analytics, it can 8 pursue data science, which entails predictive modeling using data. Ultimately, at the apex is AI.

9 As shown Figure 1, this AI Strategic Plan primarily covers AI and data science applications.

10

11 Figure 1 Artificial Intelligence Hierarchy and Relationship with the NRC AI Strategic Plan 12 (adapted from [5] and [6])

13 The right side of Figure 1 illustrates an overview of major fields within the scope of the AI 14 Strategic Plan. As shown in the figure, this AI Strategic Plan considers machine learning, deep 15 learning, natural language processing, and robotic process automation to be subsets of AI.

16 17 AI technologies provide the underlying capability for autonomous systems. While AI enables 18 autonomy, not all uses of AI are autonomous. For example, many AI capabilities may be used to 19 augment human decisionmaking rather than replace it. Table 1 provides notional AI and 20 autonomy levels in potential commercial nuclear activities. Higher autonomy levels indicate less 21 reliance on human intervention or oversight and, therefore, may require greater regulatory 22 scrutiny of the AI system. AI Strategic Goal 1, discussed further in Section 4.1, will assess the 23 current regulatory framework and establish the appropriate regulatory requirements for varying 24 degrees of AI and autonomy. Lastly, the NRC recognizes that there are differences between

1-2 1 automation 3 and autonomy in potential uses of AI in NRC-regulated applications. As such, the 2 NRC will treat these differences with the appropriate level of regulatory scrutiny.

3 Table 1 Notional AI and Autonomy Levels in Commercial Nuclear Activities

Notional AI and Potential Uses of AI and Autonomy Levels Autonomy in Commercial Nuclear Activities Level 1: Insight AI integration in systems is used for optimization, operational (Human decisionmaking guidance, or business process automation that would not assisted by a machine) affect plant safety/security and control Level 2: Collaboration AI integration in systems where algorithms make (Human decisionmaking recommendations that could affect plant safety/security and augmented by a machine) control are vetted and carried out by a human decisionmaker Level 3: Operation AI and autonomy integration in systems where algorithms (Machine decisionmaking make decisions and conduct operations with human oversight supervised by a human) that could affect plant safety/security and control Level 4: Fully Autonomous Fully autonomous AI in systems where the algorithm is (Machine decisionmaking responsible for operation, control, and intelligent adaptation with no human intervention) without reliance on human intervention or oversight that could affect plant safety/security and control 4

5 The NRC recognizes the output of this AI Strategic Plan may also support the agency us e of AI 6 tools to enhance internal NRC activities. For example, the NRC will gain additional knowledge 7 and expertise in AI and data literacy to support expanding use for decisionmaking across the 8 agency. When assessing agency processes for improvement, the NRC will include in its 9 assessment potential ways AI tools could be incorporated. Further di scussion related to 10 considerations on internal agency use of AI can be found in Appendix B.

3 Automation is considered to be a system that automatically takes action on a specific task according to pre-defined, prescriptive rules. For example, reactor protection systems are automatically actuated when process parameters exceed certain defined limits. In an autonomous system, both the point at which action is taken and the action that is taken are the result of training an algorithm on data collected about the system.

1-3

1 2 VISION

2 The NRCs vision is to continue to keep pace with technological innovations to ensure the safe 3 and secure use of AI in NRC-regulated activities.

2-1

1 3 PURPOSE AND DRIVERS

2 The purpose of the AI Strategic Plan is to ensure the staffs readiness to review the use of AI in 3 NRC-regulated activities as the nuclear industry has expressed interest in deploying AI 4 applications. Based on feedback from the NRCs Data Science and AI Regulatory Applications 5 Public Workshops 4, the nuclear industry could start deploying AI technologies in the near future 6 and has already begun investigating, developing, and assessing how such technologies can be 7 used. Licensing applications that include the use of AI technologies may be submitted to the 8 NRC for review and approval in the next five years.

9 10 In fiscal year (FY) 2021, the NRC began actively coordinating within the agency and across the 11 nuclear industry to better understand activities and plans for AI by (1) conducting an internal 12 scan to ascertain the scope of existing NRC projects that may fall within the technical area of AI, 13 (2) issuing a Federal Register (FR) notice 5 to solicit feedback on the nuclear industrys AI 14 readiness and applications, and (3) hosting a series of Data Science and AI Regulatory 15 Applications Public Workshops to provide a forum for the NRC, nuclear industry, and relevant 16 stakeholders to discuss the state of knowledge and research activities related to data science 17 and AI and their application in the nuclear industry. In February 2022, the NRC issued 18 NUREG/CR-7294, Exploring Advanced Computational Tools and Techniques with Artificial 19 Intelligence and Machine Learning in Operating Nucl ear Plants [7], documenting the current 20 state of practice of AI tools in the nuclear industry. The staff used these insights in the 21 development of this AI Strategic Plan. The NRC also reached out to the nuclear industry, 22 U.S. Government agencies, nonprofit organizations, academia, international counterparts with 23 mature or developing AI programs, and the public to gain valuable insights to inform the 24 development of this AI Strategic Plan.

4 The NRC hosted a series of Data Science and AI Regulatory Applications Public Workshops in June, August, and November 2021 to provide a forum for the NRC, nuclear industry, and stakeholders to discuss the state of knowledge and research activities related to data science and AI and their application in the nuclear industry. At these workshops, the NRC worked with internal and external stakeholders to identify the benefits and risks associated with the use of AI in regulatory activities and discussed ongoing and planned projects in the nuclear industry. For more details, see the NRC public W eb site at https://www.nrc.gov/public-involve/conference-symposia/data-science-ai -reg-workshops.html.

5 See 86 FR 20744, Role of Artificial Intelligence Tools in U.S. Commercial Nuclear Power Operations, at https://www.federalregister.gov/documents/2021/04/21/2021-08177/role-of-art ificial-intelligence-tools -in -us -

commercial-nuclear -power -operations.

3-1

1 4 STRATEGIC GOALS

2 The AI Strategic Plan sets out the five strategic goals shown in Figure 2 to ensure readiness for 3 reviewing the use of AI in NRC-regulated activities.

4 ENSURE NRC READINESS FOR REGULATORY DECISIONMAKING: Establish a robust and flexible AI regulatory framework that provides a sound basis upon which regulatory decisions can be made and enforced.

ESTABLISH AN ORGANIZATIONAL FRAMEWORK TO REVIEW AI APPLICATIONS: Create AI governance, collaboration, coordination, and communication networks at the NRC to prepare the NRC to review AI applications.

STRENGTHEN AND EXPAND AI PARTNERSHIPS: Engage the nuclear community to maintain external awareness of industry plans and foster strong partnerships across the Federal Government, academia, and international counterparts to leverage AI expertise.

CULTIVATE AN AI-PROFICIENT WORKFORCE: Bring critical data science skills into service by recruiting the AI workforce of tomorrow while simultaneously cultivating the talent of NRC's existing highly skilled workforce.

PURSUE USE CASES TO BUILD AN AI FOUNDATION ACROSS THE NRC: Establish the necessary AI foundation to prepare the staff to review of AI in NRC-regulated activities.

5

6 Figure 2 Overview of Strategic Goals

7 As shown above, the first strategic goal is the ultimate outcome of the implementation of this 8 strategic plan, which is to continue to keep pace with technological innovations to ensure the 9 safe and secure use of AI in NRC-regul ated activities through existing or new regulatory 10 guidance, rules, inspection procedures, or oversight activities (AI Strategic Goal 1). AI Strategic 11 Goals 2 through 5 directly support preparatory activities that culminate in successfully 12 supporting technical readiness for regulatory decisionmaking activities desired in AI Strategic 13 Goal 1. The establishment of the organizational framework ( AI Strategic Goal 2) ensures all 14 aspects of the NRC are represented in the preparations for reviewing AI in NRC-regulated 15 activities. Strong partnerships are essential to ensur ing the safe and secure use of AI in the 16 nuclear industry. The NRC is committed to engaging the industry and relevant stakeholders to 17 maintain awareness of industry efforts ( AI Strategic Goal 3) and prepare for regulatory reviews.

18 The NRC will also engage in workforce development and acquisition to ensure that the NRC 19 staff and contractors have the critical skills required ( AI Strategic Goal 4) to evaluate the use of 20 AI in NRC-regulated activities. The NRC recognizes the establishment of a foundation in data 21 science as a fundamental requirement for evaluating AI applications. Therefore, the NRC will 22 build the necessary AI foundation to pursue use cases across the NRC ( AI Strategic Goal 5),

23 which will help build an organizational experience that supports future regulatory reviews and 24 oversight activities.

25 26 The AI Strategic Goals are listed in order of priority and are expected to be initiated during 27 different timeframes. All organizations within the NRC play a significant role in achieving the 28 strategic goals. The NRC will also continue to monitor external factors that may influence the 29 ability to achieve these strategic goals. The NRC will consider the actions needed for the short-

4-1 1 term (<1 year), mid-term (1 - 3 years), and long-term (3-5 years) time horizons and will guide 2 budgetary requirements and resource planning within the NRCs standard planning and 3 budgeting processes to achieve the strategic goals in this document.

4 5 The NRC developed an agency evidence-building plan [8], as required by the Foundations for 6 Evidence-Based P olicymaking Act of 2018, for identifying and addressing priority questions 7 relevant to the agencys programs, policies, and regulations. The NRC will leverage the 8 resulting evidence gathered through the execution of the agency evidence-building plan to 9 support the AI strategic goals. The AI Strategic Goals may inform the use of AI tools and 10 enhance agency activities, as discussed in Appendix B of this AI Strategic Plan.

11 12 4.1 Strategic Goal 1: Ensure NRC Readiness for Regulatory Decisionmaking

13 The deployment of AI technologies by the nuclear industry is on the horizon. The NRC 14 anticipates that within the next five years an existing licensee, new, or advanced nuclear 15 technology applicant may employ AI in such a manner that it requires NRC regulatory 16 consideration or oversight. The NRC needs to con tinue to be effective and efficient as it 17 conducts its safety and security mission.

18 19 This goal focuses on developing the regulatory guidance and tools to prepare the staff to assess 20 AI as part of NRC regulatory activities. The NRC recognizes that the nuclear industry is likely to 21 use AI in applications (e.g., notional AI and autonomy adoption levels in Table 1) that may 22 require regulatory approval or oversight. Therefore, the NRC will assess whether any regulatory 23 guidance (e.g., regulatory guides or standard review plan sections) or inspection procedures 24 need to be updated or created to clarify the process and procedure for the licensing and 25 oversight of the use of AI in NRC-regulated activities. The need for revision will be based on the 26 information gathered through the execution of this AI Strategic Plan, engagement with external 27 stakeholders (AI Strategic Goal 3), and experience obtained through pursuing internal use 28 cases and their impact on the agencys regulatory framework (AI Strategic Goal 5). For 29 example, the NRC will leverage its experience reviewing relevant historical models as it 30 determines the requirements for new, more detailed models. Lastly, additional options for long-31 range changes for AI regulatory reviews and oversight that would require rulemaking will also be 32 considered.

33 34 The NRC will undertake research to develop an AI framework to determine the approach to 35 assess areas such as, but not limited to,explainability, trustworthiness, bias, robustness, ethics, 36 security, risks, and technical readiness of AI. The NRC will also work with agency stakeholders 37 and the international regulatory community to determine the currently available AI standards 38 and identify the technical areas (e.g., explainability, trustworthiness, bias, robustness, ethics, 39 security, risks) where gaps may exist. In addition, the NRC will participate with standards 40 development organizations and work with F ederal agencies and the international regulatory 41 community (AI Strategic Goal 3) to offer critical expertise and perspectives to inform the drafting 42 and revision of AI standards and guidance documents.

43 44 The development of the AI framework will be communicated with agency stakeholders and the 45 public to maintain transparency and clearly communicate regulatory guidance to the nuclear 46 industry as early as possible in the process (AI Strategic Goal 3). For this goal, a successful 47 outcome is providing, as needed, the regulatory guidance and tools to ensure readiness for 48 reviewing the use of AI in NRC-regulated activities.

49

4-2 1 4.2 Strategic Goal 2: Establish a n Organizational Framework to Review AI 2 Applications

3 The successful implementation of the AI Strategic Plan requires effective coordination and 4 collaboration across the NRC, at both the management and staff levels. The NRC will establish 5 an Artificial Intelligence Steering Committee (AISC) to provide cross -office coordination and 6 direction to ensure readiness for regulatory decisionmaking and develop AI governance. The 7 AISC will need to include division or deputy division directors with management responsibility for 8 AI technology across the agency. T he AISC may engage external subject-matter experts with AI 9 expertise to assist with specific issues, as needed. The AISC will also leverage existing 10 information technology, data, and security communities and expertise. They will coordinate with 11 the Information Technology and Information Management Portfolio Executive Council to ensure 12 direct prioritization of the activities that will enable the achievement of the strategic goals 13 outlined in this document.

14 15 To support staff engagement and collaboration, the NRC will need to establish an AI Community 16 of Practice (AICoP) to provide a forum to (1) discuss best practices for reviewing requests that 17 include the use of AI technologies, (2) provide agencywide awareness on active and potential 18 use cases, and (3) facilitate the sharing of best practices and lessons learned. The AICoP will 19 be compromised of NRC staff members from across the agency who are active in or interested 20 in AI policy, technology, standards, and programs. In addition, AI working groups will support 21 the AISCs efforts as needed to execute the AI Strategic Plan, such as prioritization of AI 22 research, technical workshops, and specific subject-matter tasks as assigned. Membership for 23 the AIworking groups to support relevant subject matter expertise can be drawn from the 24 AICoP.

25 26 A successful outcome of this goal is an organization that facilitates effective coordination and 27 collaboration across the NRC to ensure readiness for reviewing the use of AI i n NRC-regulated 28 activities.

29 30 4.3 Strategic Goal 3: Strengthen a nd Expand AI Partnerships

31 Strong partnerships across the F ederal Government, with the nuclear industry, and with 32 international counterparts are essential in order to gain valuable information to benchmark the 33 agencys AI activities and serve as force multipliers to optimize resources and effort. Scientific 34 and technological exchange keeps the NRC current in the rapidly evolving field of AI.

35 36 The NRC will continue to strengthen and expand strong AI working partnerships with domestic 37 and international counterparts within the nuclear industry to stay abreast of industry interests, 38 activities, and plans to deploy AI. For domestic AI activities, the NRC will continue to engage 39 with stakeholders, including the public, nongovernmental organizations, and regulated entities 40 through existing and new memoranda of u nderstanding, public meetings, and workshops. For 41 international AI activities, the NRC will continue to engage with international counterparts and 42 multilateral organizations to collaborate in sharing information on the use of AI in NRC-regulated 43 activities, conduct cooperative research, and influence the development of international 44 standards and guidance.

45 46 The NRC is not the only Federal agency faced with the challenges of safely and securely 47 deploying, overseeing, and evaluating AI technologies. Other G overnment agencies and 48 industry sectors are facing similar challenges. In some cases, other G overnment agencies have 49 more experience with assessment and implementation of AI. Their experience and lessons

4-3 1 learned provide the NRC with a unique opportunity to engage in intergovernmental information 2 sharing, collaboration, and potential technology transfer from those agencies. The NRC will 3 continue to build partnerships with other G overnment agencies to facilitate the exchange of 4 ideas, practices, and procedures.

5 6 Incorporating the information and knowledge gathered from external organizations, including 7 regulatory research, industry, F ederal partners, standards, and international bodies, into the 8 NRC staff knowledge base will allow for informed regulatory decisionmaking. The NRC will 9 coordinate external interactions, disseminate information from these interactions to the 10 appropriate NRC staff, and support technical training and workshops to build AI awareness 11 across the NRC offices. When achieved, this goal will provide established mechanisms to 12 (1) maintain awareness of industry plans, (2) establish communication forums to discuss future 13 plans and regulatory needs, and (3) effectively partner with other agencies on AI topics of 14 mutual benefit.

15 16 4.4 Strategic Goal 4: Cultivate a n AI-Proficient Workforce

17 The NRC recognizes the value of acquiring, developing, and retaining a skilled workforce in the 18 area of AI. The term AI is often used generically to encompass a wide range of applications, 19 from data analysis to fully autonomous systems. The NRC will develop a common 20 understanding of AI by providing the NRC staff with seminars, workshops, and training.

21 22 This goal focuses on developing the technical information, knowledge, and tools to prepare the 23 staff to review AI applications. The NRC must have the right number of people with the right 24 skills at the right time to conduct effective and efficient regulatory reviews and oversight 25 activities to accomplish its safety and security mission. Given the competitive marketplace for AI 26 talent, the NRC will establish and stabilize a pipeline for AI talent by using the Strategic 27 Workforce Planning and Competency Models to meet this strategic goal and support NRC 28 needs. A primary mechanism for building this pipeline is leveraging existing hiring processes 29 (e.g., NRC Integrated University Program, internships and cooperative education programs, the 30 Nuclear Regulator Apprenticeship Network program, and the Information Technology Fellows or 31 Graduate Fellows programs). In addition, the NRC will fully use Federal retention authorities to 32 maintain a skilled AI workforce and allow talented experts to contribute to AI research and 33 development activities.

34 35 The NRC will cultivate the talent of its existing highly skilled workforce by investing in 36 comprehensive training for NRC staff and managers working on use cases ( AI Strategic 37 Goal 5). The NRC AI training program will use a tiered approach, providing training ranging from 38 basic to advanced concepts, applications, and AI tools tailored to the interest level and 39 proficiency desired for staff as needed.

40 41 The goal is to adopt the appropriate training programs and tools to develop the requisite skills in 42 the NRC workforce. A successful outcome of this goal is to ensure appropriate qualifications, 43 training, expertise, and access to tools exist for the workforce to review and evaluate AI usage 44 in NRC-regulated activities effectively and efficiently.

45 46 4.5 Strategic Goal 5: Pursue Use Cases to Build an AI Foundation Across t he 47 NRC

48 AI technologies may pose novel challenges for the NRC regulatory framework. As the NRC 49 prepares for regulatory decisionmaking, internal uses of AI tools that would also support

4-4 1 industry use for AI-based decisionmaking and control will increase staff knowledge of and 2 experience with these tools for future regulatory reviews and oversight.

3 4 This goal focuses on developing and pursuing use cases, consistent with priority question 2 of 5 the agency evidence-building plan (as discussed in Appendix B of this AI Strategic Plan), to 6 build technical expertise for reviewing the use of AI in NRC-regulated activities. To build this 7 expertise, the NRC needs to create an ecosystem that supports data science, assessment and 8 integration of emerging AI tools, and hands -on talent development for reviewing the use of AI in 9 NRC-regulated activities. To better understand how AI algorithms, models, and claims are 10 validated and tested, the NRC needs to undertake research to develop use cases with data 11 from various sources and in multiple forms. These use cases will help the staff gain AI expertise 12 that could be used in performing regulatory reviews or assessments for a wide range of 13 potential AI applications. In addition, the NRC will engage the nuclear industry to pursue 14 potential pilot studies and proofs of concept to serve as a foundation for reviewing the use of AI 15 in NRC-regulated activities. These pilots and proofs of concept will help in identifying challenges 16 associated with getting the AI applicati ons through the AI framework.

17 18 The NRC will provide staff with access to AI tools, which are often software based. The NRC will 19 ensure it has access to training areas within applicable AI tools to allow the NRC staff to engage 20 in training exercises that mimic regulatory reviews of potential AI in NRC-regulated activities.

21 This will allow staff to identify and address potential gaps in future regulatory reviews.

22 23 For this goal, a successful outcome is one in which the NRC staff possesses an ecosystem that 24 supports AI analysis, integration of emerging AI tools, and hands -on talent development for 25 reviewing AI applications from the nuclear industry.

4-5

1 5 CONCLUSION

2 The NRC is committed to ensuring that the use of new technologies is safe and secure. New 3 technologies, like AI,have the potential to enhance the safety and security of nuclear facilities.

4 This AI Strategic Plan presents the vision and goals for the NRC to cultivate an AI-proficient 5 workforce, keep pace with AI technological innovations, and ensure the safe and secure use of 6 AI in NRC-r egulated activities.

5-1

1 6 REFERENCES 2

[1] NRC, "U.S. Nuclear Regulatory Commission Strategic Plan: Fiscal Years 2022-2026,"

Washington, DC, NUREG-1614, Vol. 8, ML22067A170, 2022.

[2] 116th U.S. Congress, "H.R.6395 - National Defense Authorization Act for Fiscal Year 2021:

National Artificial Intelligence Initiative Act of 2020," 2021. [Online]. Availabl e:

https://www.congress.gov/bill/116th-congress/house-bill/6395/text.

[3] NRC, "International Strategy: 2021-2025," Washington, DC, ML21236A120, https://www.nrc.gov/docs/ML2123/ML21236A120.pdf, 2021.

[4] NRC, "Information Technology and Information Management Strategic Plan: Fiscal Years 2020-2024," U.S. Nuclear Regulatory Commission, Washington, DC, NUREG -1908, Vol. 4, ML19323D858, https://www.nrc.gov/docs/ML1932/ML19323D858.pdf, 2019.

[5] O. Osagie, "medium.com," Medium, 21 February 2021. [Online]. Availabl e:

https://medium.com/swlh/the-ai -hierarchy -of-needs -9b015d061f29. [Accessed January 2022].

[6] A. N. J. P. a. R. S. Andy Ho, "A Data Science Approach to Defining a Data Scientist," SMU Data Science Review, vol. 2, no. 3, 2019.

[7] NRC, "Exploring Advanced Computational Tools and Techniques with Artificial Intelligenc e and Machine Learning in Operating Nuclear Plants," U.S. Nuclear Regulatory Commissi on, Washington, DC, NUREG/CR -7294, ML22042A 662, https://www.nrc.gov/docs/ML2204/ML22042A662.pdf, 2022.

[8] NRC, "Evidence Building Plan, Fiscal Year 2022," U.S. Nuclear Regulatory Commissi on, Rockville, MD, https://www.nrc.gov/docs/ML2206/ML22066B056.pdf, ML22066B056, 2022.

3

6-1

1 APPENDIX A GLOSSARY

2

  • ARTIFICIAL INTELLIGENCE (AI): The term AI refers toa machine-based system that can 3 go beyond defined results and scenarios and has the ability to emulate human-like 4 perception, cognition, planning, learning, communication, or physical action. For a given set 5 of human-defined objectives, AI can make predictions, recommendations, or decisions 6 influencing real or virtual environments. AI systems use m achine-and human-based inputs 7 to perceive real and virtual environments, abstract such perceptions into models through 8 analysis in an automated manner, and use model inference to formulate options for 9 information or action (adapted from [1]).

10

  • AI APPLICATION: An AI application represents a use case, project, plan, or other topic area 11 that uses various AI technology and tools to conduct research and development or create a 12 production product, service, or goal.

13

  • AI TECHNOLOGY: AI technology represents the algorithms and methods that are used 14 within the available machine learning and AI software tool sets.

15

  • AI TOOLS: AI tools represent the computer software, code, information technology 16 infrastructure, and service provider utilities (e.g., Azure Cognitive Service, IBM Watson 17 Studio) that are used to facilitate AI applications.

18

  • DATA ARCHITECTURE: Data architecture is defined by where the data resides; how it is 19 collected, managed, secured, and accessed; and who has access to it. This architecture is 20 constructed using purpose-built repositories, tools, and techniques, and it is controlled 21 through the implementation of governance standards and policies.

22

  • DATA SCIENCE: Data science is a multidisciplinary field that involves computer 23 program ming codes, such as Python and R; collaboration with other technical disciplines ;

24 and communication using charts, graphs, or dashboards and by transforming data into 25 insights using techniques in statistics, analytics, and machine learning [2]. Data scientists 26 use computer programming languages, such as Python, to develop algorithms that classify, 27 predict, and suggest outcomes from data. In comparison, data analysts use historical data to 28 create visualizations and predictions using dashboard development tools, such as Tableau 29 and PowerBI.

30

  • DATA ANALYTICS: The goal of data analytics is to derive and effectively communicate 31 actionable insights from a vast quantity and variety of data. It covers a broad spectrum of 32 activities, including data management and quality, mathematical and statistical methods for 33 data modeling, and techniques for visualizing data in support of enterprise -wide 34 decisionmaking [2]. Data analysts use historical data to create visualizations and predictions 35 using dashboard development tools, such as Tableau and PowerBI. In comparison, data 36 scientists use computer programming languages, such as Python, to develop algorithms 37 that classify, predict, and suggest outcomes from data.

38

  • DEEP LEARNING: Deep learning is a subset of machine learning in which multilayered 39 neural networks, modeled to work like the human brain, learn from large amounts of data.

40 Within each layer of the neural network, deep learning algorithms perform calculations and 41 make predictions repeatedly, progressively learning and gradually improving the accuracy

A-1 1 of the outcome over time. Deep learning is differentiated in that it can ingest and process 2 unstructured, unlabeled data [ 3].

3

  • MACHINE LEARNING: Machine learning means an application of AI that is characterized by 4 providing systems with the ability to automatically learn and improve on the basis of data or 5 experience, without being explicitly programmed [1].

6

  • NATURAL LANGUAGE PROCESSING: Natural language processing is the use of 7 algorithms to determine properties of natural, human language so that computers can 8 understand what humans have written or said. It includes teaching computer systems how 9 to extract data from bodies of written text, translate from one language to another, and 10 recognize printed or handwritten words [4].

11 12

  • ROBOTIC PROCESS AUTOMATION: Robotic process automation is used for software 13 tools that partially or fully automate human activities that are manual, rule-based, and 14 repetitive. It works by replicating the actions of an actual human interacting with one or more 15 software applications to perform tasks such as entering data, process ing standard 16 transactions, or responding to simple customer service queries [5].

17 18

  • USE CASE: A use case is a specific situation in which a product or service could potentially 19 be used.

20 21 REFERENCES

22 1. 116th U.S. Congress, "H.R.6395 - National Defense Authorization Act for Fiscal Year 2021:

23 National Artificial Intelligence Initiative Act of 2020," 2021. [Online]. Available:

24 https://www.congress.gov/bill/116th-congress/house-bill/6395/text.

25 2. North Carolina State University, "Institute for Advanced Analytics," [Online]. Available:

26 https://analytics.ncsu.edu/?page_id=2. [Accessed May 2022].

27 3. IBM, "What is Deep Learning?," [Online]. Available: https://www.ibm.com/cloud/learn/deep-28 learning. [Accessed May 2022].

29 4. DeepAI, "Machine Learning Glossary and Terms," [Online]. Available:

30 https://deepai.org/machine-learning-glossary-and -terms/natural -language-processing.

31 [Accessed May 2022].

32 5. Association for Intelligent Information Management, "What is Robotic Process Automation?,"

33 [Online]. Available: https://www.aiim.org/what-is -robotic -process -automation. [Accessed May 34 2022].

A-2 1 APPENDIX B USING ARTIFICIAL INTELLIGENCE TOOLS 2 TO ENHANCE NRC ACTIVITIES

3 The U.S. Nuclear Regulatory Commission (NRC) will also pursue internal opportunities for the 4 use of artificial intelligence (AI) tools for business process automation and knowledge mining.

5 The NRC continues to build a flexible, agile, and innovative information technology and 6 information management environment that is prepared for the rapid development of new 7 technologies and changes in the nuclear industry. Technological advances continue to change 8 the way the agency works and interacts with stakeholders. The increased use of data analytics, 9 cloud computing, and AI may improve efficiency and provide support for the workforce. These 10 activities increase dependency on a robust and resilient ne twork and information technology 11 infrastructure. While AI Strategic Goals 4 and 5 principally support agency preparation for 12 external AI usage in NRC-regulated activities, Goals 4 and 5 may also benefit the agency in 13 preparing for internal agency AI usage. In conjunction with AI Strategic Goals 4 and 5, the NRC 14 will gain knowledge and expertise in a wide range of skills and capabilities such as artificial 15 intelligence and data literacy, to support expanding the use of data for decisionmaking in the 16 agency.

17 18 Several actions taken by Congress or executive branch agencies are prompting the NRC to 19 further consider the best way to strategically integrate AI technology into agency internal 20 processes and work products in addition to the regulatory oversight functi ons discussed in the 21 AI Strategic Plan. The AI Strategic Plan aligns with and supports the provisions of the following:

22 23

  • Administrative Conference of the United States, Statement #20, Agency Use of Artificial 24 Intelligence [1]

25

  • Foundations for Evidence-Based Policymaking Act of 2018 (Evidence Act) [2]

26

  • National Artificial Intelligence Initiative Act of 2020 [3]

27

  • Office of Management and Budget M 06, Guidance for Regulation of Artificial 28 Intelligence Applications, [4]

29 30 AI tools may be used to enhance internal NRC activities, which could better allocate agency 31 resources to higher value activities and emerging mission priorities. However, AI tools are highly 32 dependent on the quantity and quality of the data that support them. In carrying out the agencys 33 mission, the NRC captures, creates, manages, and uses data from a variety of sources and in a 34 variety of forms. These data inform the agencys operational and regulatory decisionmaking and 35 support all Federal reporting requirements. As part of the NRCs Information 36 Technology/Information Management Strategic Plan, the agency will provide future 37 enhancements to identify and coll ate data more effectively and efficiently [5].

38 39 The NRC has also developed an agency evidence-building plan, as required by the Evidence 40 Act, for identifying and addressing priority questions relevant to the agencys programs, policies, 41 and regulations [6]. As part of the evidence-building plan, the agency will identify what NRC 42 decisionmaking processes could benefit from AI tools and prioritize the data collections that 43 would have the most significant impact on agency decisionmaking, AI tool use, and stakeholder 44 use. By improving how the NRC collects data and information, AI tools can be used more 45 readily and potentially make decisionmaking more efficient. The evidence-building plan also 46 discusses how processes and procedures are vital to ensure consistency, clear expectations,

B-1 1 performance measurement, and established roles and responsibilities consistent with 2 established policy. As part of the evidence-building plan, the NRC will assess the agencys 3 processes to determine what improvements can be implemented to continue as a more modern, 4 risk informed regulator. When assessing processes for improvement, the NRC will include in its 5 assessment, potential ways AI tools could be incorporated into processes, as well as for 6 continuous process monitoring and optimi zation.

7 8 REFERENCES

9 1. Administrative Conference of the United States, "Agency Use of Artificial Intelligence," 2021.

10 [Online]. Available: https://www.acus.gov/research-projects/agency -use-artificial-intelligence.

11 2. 115th U.S. Congress, "H.R.4174 - Foundations for Evidence-Based Policymaking Act of 12 2018," 2021. [Online]. Available: https://www.congress.gov/bill/115th-congress/house-13 bill/4174/text.

14 3. 116th U.S. Congress, "H.R.6395 - National Defense Authorization Act for Fiscal Year 2021:

15 National Artificial Intelligence Initiative Act of 2020," 2021. [Online]. Available:

16 https://www.congress.gov/bill/116th-congress/house-bill/6395/text.

17 4. OMB, "Guidance for Regulation of Artificial Intelligence Applciations," Office of Management 18 and Budget, Washington, DC, https://www.whitehouse.gov/wp-content/uploads/2020/11/M -

19 21-06.pdf, 2020.

20 5. NRC, "Information Technology and Information Management Strategic Plan: Fiscal Years 21 2020-2024," U.S. Nuclear Regulatory Commission, Washington, DC, NUREG -1908, Vol. 4, 22 ML19323D858, https://www.nrc.gov/docs/ML1932/ML19323D858.pdf, 2019.

23 6. NRC, "Evidence Building Plan, Fiscal Year 2022," U.S. Nuclear Regulatory Commission, 24 Rockville, MD, https://www.nrc.gov/docs/ML2206/ML22066B056.pdf, ML22066B056, 2022.

B-2 NUREG-2 261 DRAFT

Artificial Intelligence Strategic Plan June 2022

Fiscal Years 2023-2027

Draft Report for Comment

M. Dennis, T. Lalain, L. Betancourt, A. Hathaway, R. Anzalone Technical

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852

Division of System Analysis Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

The U.S. Nuclear Regulatory Commission (NRC) recognizes that interest in artificial intelligence (AI) is growing rapidly in both the public and private sectors and anticipates increased use of AI in NRC-regulated activities. AI generally refers to a machine-based system that can and has the ability to emulate human-like perception, cognition, planning, learning, communication, or physical action. For a given set of human-defined objectives, AI can m ake predictions, recommendations, or decisions influencing real or virtual environments. The AI Strategic Plan focuses on a broad spectrum of sub-specialties (e.g., natural language processing, machine learning, deep learning, etc.) which could encompass various algorithms and application examples which the NRC has not previously reviewed and evaluated. Anticipating the industrys potential application of AI to NRC-regulated activities, the NRC has developed an AI Strategic Plan to ensure the agencys readiness to review such uses. The AI Strategic Plan includes five goals: (1) ensure NRC readiness for regulatory decisionmaking, (2) establish an organizational framework to review AI applications, (3) strengthen and expand AI partnerships, (4) cultivate an AI proficient workforce, and (5) pursue use cases to build an AI foundation across the NRC. The overall goal of this AI Strategic Plan is to ensure continued staff readiness to review and evaluate AI applications effectively and efficiently.

Artificial Intelligence, AI, Machine Learning, ML, Natural Language Processing, NLP, Robotic Process Automation, RPA, Strategic Plan

NUREG-2261 Artificial Intelligence Strategic Plan June 2022 Draft Fiscal Years 2023-2027

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