ML23118A253
| ML23118A253 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/2023 |
| From: | NRC/OCM |
| To: | |
| Shared Package | |
| ML23067A028 | List: |
| References | |
| M230420 | |
| Download: ML23118A253 (114) | |
Text
1 UNITED STATES NUCLEAR REGULATORY COMMISSION
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MEETING
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THURSDAY, APRIL 20, 2023
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The Commission met in the Commissioners' Hearing Room, One White Flint North, 11545 Rockville Pike, Rockville, Maryland, at 9:00 a.m.
EDT, Christopher T. Hanson, Chair, presiding.
COMMISSION MEMBERS:
CHRISTOPHER T. HANSON, Chair JEFF BARAN, Commissioner DAVID A. WRIGHT, Commissioner ANNIE CAPUTO, Commissioner BRADLEY R. CROWELL, Commissioner ALSO PRESENT:
BROOKE P. CLARK, Secretary of the Commission MARIAN ZOBLER, General Counsel
2 NRC STAFF:
DANIEL DORMAN, Executive Director for Operations JOHN LUBINSKI, Director, Office of Nuclear Material Safety and Safeguards (NMSS)
CARRIE SAFFORD, Deputy Director, Division of Fuel Management, NMSS YAWAR FARAZ, Senior Project Manager, Fuel Facilities Licensing Branch, Division of Fuel Management, NMSS LINDSEY COOKE, Fuel Facility Inspector, Division of Fuel Facility Inspection, Region II BECCA RICHARDSON, Deputy Director, Division of Physical and Cybersecurity Policy, Office of Nuclear Security and Incident Response JACOB ZIMMERMAN, Deputy Director, Division of Fuel Management, NMSS NORMA GARCIA SANTOS, Project Manager, Storage and Transportation Licensing MARK HENRION, Health Physicist, Decommissioning, ISFSI, and Reactor HP Branch, Division of Radiological Safety and Security, Region I JOHN MCKIRGAN, Deputy Director, Division of Engineering, Office of Nuclear Regulatory Research Production and Utilization Facilities, NRR 1
3 1 PROCEEDINGS 2 9:01 a.m.
3 CHAIR HANSON: Good morning, everyone. I convene the 4 Nuclear Regulatory Commission's public meeting for the purpose of discussing 5 NRC strategic programmatic considerations associated with the Fuel Facilities 6 and the Spent Fuel Storage and Transportation business lines.
7 As always, it's important to keep the public informed, and I 8 look forward to a good discussion this morning.
9 We'll hear from two NRC panels, the Fuel Facilities Business 10 Line panel will present first, then we'll take a short break, and we'll hear from 11 the Spent Fuel Storage and Transportation panel. With each panel, we'll hold 12 questions to the end and then we'll hear questions from the commissioners to 13 the panelists.
14 Before we start, I'll ask my colleagues if they have any 15 comments they'd like to make?
16 (No audible response.)
17 CHAIR HANSON: No? Okay. With that, Dan, it's over to 18 you.
19 MR. DORMAN: Thank you, Chair. And good morning Chair 20 Hanson and Commissioners, it's the staff's pleasure to provide you an update 21 today on the Fuel Facilities and Spent Fuel Storage and Transportation 22 Business Lines.
23 The NRC's Fuel Facilities Business Line provides for public 24 health and safety and protection of the environment through our regulation of 25 the sole uranium conversion facility in the United States, enrichment facilities,
4 1 nuclear fuel fabrication, non-reactor licensees possessing greater than a critical 2 mass of special nuclear materials, and through leading NRC's efforts on 3 fulfilling international safeguards and domestic material control and accounting 4 obligations.
5 The Fuel Facilities Business Line continues to see growth in 6 work related to new fuel fabrication, and enrichment for advanced reactors, and 7 accident-tolerant fuels of higher enrichment for existing reactors.
8 Today you'll hear about our continued efforts to risk-inform 9 processes to meet the Agency's mission, our efforts to meaningfully engage 10 stakeholders, and the ongoing efforts to ensure that the NRC has a talented 11 workforce to meet the demands of the future. Next slide, please.
12 For this panel, John Lubinski, Director of the Office of Nuclear 13 Material Safety and Safeguards, or NMSS, will provide you with strategic 14 insights for supporting the Fuel Facilities Business Line.
15 Carrie Safford, Deputy Director for the Division of Fuel 16 Management in NMSS, will discuss current and future considerations for the 17 Fuel Cycle program, and share an overview of the evaluation and effectiveness 18 of the oversight program.
19 Yawar Faraz, Senior Project Manager in the Fuel Facilities 20 Licensing Branch in the Division of Fuel Management in NMSS, will give an 21 update on the Fuel Facilities Licensing program and significant licensing 22 activities, and an overview of the New Fuels Atlas.
23 Lindsey Cooke, Fuel Facility Inspector for the Division of Fuel 24 Facility Inspection in Region II, will discuss oversight for current and 25 under-construction facilities.
5 1 And lastly, Becca Richardson, Deputy Director of the Division 2 of Physical and Cyber Security Policy in the Office of Nuclear Security and 3 Incident Response, will provide an update on activities related to security of 4 special nuclear material and our efforts to establish a more graded, 5 risk-informed approach to regulatory oversight.
6 I'll now turn the presentation over to John.
7 MR. LUBINSKI: Thank you, Dan. And good morning, Chair 8 and fellow Commissioners.
9 I am very proud of the individuals who support the Fuel 10 Facilities Business Line activities and I am happy to report that the Business 11 Line is performing very well, meeting its mission and providing reasonable 12 assurance of adequate protection in safety and the environment. Next slide, 13 please.
14 I will use my time this morning to discuss the NMSS focus 15 areas, which apply to all the NMSS business lines. Our definition of a focus 16 area is areas that require additional attention, the three areas in short are 17 People, Trust, and Workload.
18 You will notice that the words mission, safety, metrics do not 19 appear in the focus areas. This is because the folks supporting the business 20 line have and continue to understand their importance and are continuing to 21 meet the mission and ensure safety.
22 People includes hiring, training, and retaining great people.
23 Absent an immediate safety issue, hiring is our number one priority and we 24 have aggressive goals.
25 Regarding training, our folks are outstanding at supporting
6 1 each other through on-the-job training. I am happy to report that I'm hearing 2 from our new folks that we bring into the organization, during meet and greets, 3 that they are seeing that as well and getting the support they need, as part of 4 on-the-job training.
5 We are increasing our focus on ensuring effective knowledge 6 management through other means, such as formal training and qualification 7 programs.
8 Trust includes increasing trust between all internal folks, 9 including confidence of our external stakeholders, as noted in the NRC's new 10 strategic goal to inspire stakeholder confidence in the NRC.
11 Internally, we are focused on our leadership model and 12 behaviors to strengthen our organizational culture, accounting for all feedback 13 we receive, including feedback from the Federal Employee Viewpoint Survey, 14 or FEVS.
15 Most importantly, senior leaders are ensuring we are living 16 the values, implementing the leadership model, communicating effectively, and 17 encouraging an inclusive culture. We are discussing our decision-making, 18 including the basis for our decisions and how all views are considered.
19 We are living up to our commitments, such as meeting 20 deadlines to support our folks and adhering to previous alignment agreements.
21 We have asked our folks to continue to provide us feedback on how we as 22 senior leaders can do better.
23 Workload is identified because we have seen increases in our 24 work, coupled with less than a budgeted staff with newer folks in different 25 stages of training and qualifications. I am confident that folks are continuing to
7 1 ensure safety and high-quality reviews over schedules.
2 In this area, we are ensuring that we have appropriately 3 prioritized our activities. Our organizations have identified certain activities that 4 can be deferred or shed and are appropriately communicating these to our 5 stakeholders.
6 We are strategically utilizing contractors in areas that are 7 sensitive, to increase work until more staff are hired. Going forward, we 8 anticipate the planned web-based licensing enhancements, combined with the 9 use of data analytic dashboards, will yield efficiencies in our work planning, 10 prioritizing, and monitoring of activities.
11 We recognize that deferred activities are important and we 12 will ensure that they are addressed once we see the successes of our hiring 13 and training activities. Also, we continue to think innovatively to make 14 processes more efficient, which will result in shedding of certain activities.
15 I believe continuing to improve in our focus areas will improve 16 the culture in the organization, and a great culture is key to retaining great 17 people.
18 This concludes my remarks, and I will now turn to Carrie.
19 Next slide, please.
20 MS. SAFFORD: Thank you, John, and good morning. Good 21 morning, Chair Hanson and Commissioners. It's a pleasure to be here today to 22 talk to you about the Fuel Facilities Business Line.
23 Over the last year we've had a number of significant 24 accomplishments, a few of which I'd like to highlight here to acknowledge the 25 hard work of the staff of the Division of Fuel Management as well as our partner
8 1 offices.
2 Last August, we issued a renewed license and final 3 environmental impact statement for the Westinghouse Columbia Fuel 4 Fabrication Facility in Hopkins, South Carolina that authorized operations for an 5 additional 40 years. This was a major activity for our business line and 6 represents the culmination of a significant amount of effort.
7 We issued two renewed special nuclear material licenses, 8 one to Oregon State University and one to Idaho State University, each for an 9 additional 10 years. We completed three licensing reviews for existing fuel 10 facilities, with plans to increase uranium enrichment and manufacture fuel with 11 high-assay low-enriched uranium, or HALEU fuel and and we regularly engaged 12 with multiple international counterparts.
13 And this slide, that was up previously, contains a photo of the 14 Westinghouse facility in South Carolina. Next slide, please.
15 Pictured on this slide is a photo of the America Centrifuge 16 Plant, Centrus, located in Piketon, Ohio, and a photo of one of our newer staff 17 in the Division of Fuel Management, Nicole Cortez, who is a Chemical Safety 18 Scientist.
19 As John mentioned, recruitment and hiring are high priority 20 focus area for us, the EDO has set a goal for the NRC to hire more than 400 21 people by the end of calendar year 2023.
22 In the Division of Fuel Management, we've been applying 23 strategic workforce planning to hire the right number of people to support our 24 existing work activities, the budgeted workload for future years, and to account 25 for attrition.
9 1 To support our staffing goals, we're focused on recruiting the 2 expertise needed to continue to support current fuel facility licensing activities, 3 and ensuring staff readiness as the future of fuel production continues to 4 evolve.
5 We're employing creative solutions to employ stopgap 6 measures while hiring is underway. For example, we're leveraging internal 7 rotations, the Nuclear Regulator Apprenticeship Network, or NRAN, 8 apprenticeships, contractors, and more importantly, we're cross-training within 9 the division to utilize our own resources to the maximum extent possible by 10 training our division staff in both the Fuel Facilities and the Spent Fuel and 11 Transportation programs.
12 We're also placing a high priority on developing our people 13 and capturing institutional knowledge.
14 Staff is increasingly using Nuclepedia, a useful part of our 15 day-to-day practice. In the past year, staff in the Division of Fuel Management 16 have created over 13 pages on topics, such as applying the Be riskSMART 17 methodology in NMSS, a consolidated list of questions and answers in NMSS, 18 a detailed page on nuclear material control and accounting, and many more.
19 One example I'd like to highlight is a new Nuclepedia page 20 that one of our NRANers, Miranda Ross, put together on reprocessing. It's a 21 comprehensive resource on the history of reprocessing, including an overview 22 of international efforts, MOX fuel, Department of Energy and commercial efforts, 23 and what the NRC can do to prepare to review an application for a reprocessing 24 facility. It's already been used to our staff, as public interest in reprocessing 25 has increased in recent months.
10 1 We're also bringing back the weeklong training course on the 2 fuel cycle processes. The course provides an overview of the nuclear fuel cycle 3 for mining through conversion, and enrichment to fabrication. The first session 4 is scheduled in May and will be open to internal participants, and a second 5 session will be held this fall and will be open to our federal partners, states, and 6 tribes. Next slide, please.
7 Pictured on this slide is a photo of the EDO Dan Dorman, our 8 Senior Physical Scientist and NMSS International Program Coordinator Shawn 9 Smith, and our Division Director Shana Helton, at an international workshop on 10 the management of spent fuel, radioactive waste, and decommissioning that 11 was held in Ottawa, Canada last November.
12 Our staff is prepared for workload associated with new fuels.
13 To understand and be better prepared for anticipated licensing requests, we 14 conduct outreach directly with potential applicants and partner with staff in the 15 Office of Nuclear Reactor Regulation, and the Office of Research.
16 Communication, early and often, is a key component to an 17 effective regulatory review. Engaging in pre-application meetings allows us to 18 generate a shared understanding of what's required for a successful licensing 19 review; this also contributes to a higher quality application submission. Past 20 experience has taught us that when applicants have a well-defined scope of 21 review, combined with a high quality submittal, it results in a more efficient 22 licensing process.
23 Our biannual Fuel Facility Stakeholder Meeting is another 24 example of a public forum for healthy dialogue with our stakeholders. There we 25 focus on technical and regulatory issues, we discuss ways to increase
11 1 communication, and other areas of mutual interest.
2 Additionally, we regularly engage our international and 3 interagency counterparts. For example, last July we signed Addendum Five to 4 a Memorandum of Understanding with the Department of Energy on the 5 Nuclear Energy Innovation Capabilities Act.
6 The MOU allows the NRC and the Department of Energy to 7 coordinate technical readiness and facilitate the sharing of technical expertise 8 and knowledge on advanced nuclear reactor technologies and nuclear energy 9 innovation. The latest addendum addresses technical coordination regarding 10 research activities related to the safety of advanced fuel technologies.
11 And on the international side, our staff participate on 12 committees and working groups at the International Atomic Energy Agency, the 13 Nuclear Energy Agency, and in various bilateral meetings. We're building 14 relationships with the future in mind. Next slide, please.
15 In this slide is the picture of the Honeywell Uranium 16 Conversion Plant located in Metropolis, Illinois, and a picture of DFM staff Tilda 17 Liu and NRC staff Mark Lesser at a site visit at Honeywell.
18 Inspection and oversight are important components of the 19 business line activities. Over the past year, we completed all core inspections 20 for fuel facilities, two special inspections in response to safety-significant 21 events, and began development of a comprehensive construction inspection 22 program for new types of facilities licensed under 10 CFR Part 70.
23 While our existing regulatory framework has demonstrated its 24 flexibility in licensing new technologies and is ready for novel designs, we're 25 working on evaluating the existing inspection and oversight programs to be
12 1 prepared for new Category Two facilities.
2 I'll conclude by mentioning that, in 2021 we implemented the 3 Fuel Cycle Smarter Inspection Program, this was the result of several years 4 looking for areas to risk inform our inspection program.
5 Last year we conducted an inspector pulse survey to gauge 6 implementation, the results showed that our inspection program provides 7 reasonable assurance of adequate protection for fuel cycle facilities. Since 8 most inspections are on a three-year frequency, the Fuel Cycle Smarter 9 Inspection Program self-assessment will be completed once a comprehensive 10 set of data is available, which is anticipated to be in 2024.
11 And that concludes my remarks, and I'll turn it over to Yawar.
12 MR. FARAZ: Good morning, Chair Hanson and 13 Commissioners. The overview photo you see on the slide is of the Global 14 Nuclear Fuel - Americas, or GNF-A's fuel fabrication facility in Wilmington, 15 North Carolina. I'll be presenting four slides on our Fuel Facility Licensing 16 Activities. Next slide, please.
17 The Fuel Cycle Business Line regulates the possession and 18 use of source and special nuclear material, or SNM, for a broad range of 19 facilities, including uranium conversion enrichment and fuel fabrication.
20 In addition, the Fuel Facilities Business Line licenses the 21 possession and use of SNM at facilities, such as university and research 22 centers, typically referred to as Greater Than Critical Mass, or GTCM, facilities.
23 The Business Line continues to successfully review and 24 complete a large number of both routine and complex licensing actions, to 25 support these and new fuel cycle facilities. Over the last few years, the
13 1 business line has been processing just over 40 fuel cycle licensing actions per 2 year; this includes reviews, amendments, and renewals.
3 In addition to last year's accomplishments that Carrie 4 mentioned in her presentation, the Business Line completed and published 5 NUREG-2159, which applies to Category Two Material Control and Accounting, 6 or MC&A, plans.
7 The Business Line approved Framatome's amendment 8 request to possess and use SNM at a high enrichment, Global Nuclear Fuel -
9 America's Criticality Computer Code Validation Report for high-assay 10 low-enriched uranium, or HALEU, enrichments, and Centrus Energy Corp's 11 subsidiary American Centrifuge Operating LLC's, or ACO's, request to extend 12 its HALEU approval.
13 We also supported Honeywell's UF6 conversion facility, which 14 is restarting operations this month. There were no amendments required for 15 Honeywell to go from its idle to operating state. Next slide, please.
16 The Fuel Cycle Business Line is aware of, and responsive to, 17 the increase in importance and complexity of review requests from licensees 18 and applicants.
19 Last year, TRISO-X, a subsidiary of X-energy, submitted an 20 application for a new fuel fabrication facility for TRISO Fuel enriched to 20 21 percent in Oak Ridge, Tennessee. The 32-month review is scheduled to be 22 completed in June 2025.
23 In February of this year, American Centrifuge Operating 24 submitted an amendment request to produce 1,400 kilograms of HALEU in the 25 form of UF6 by the end of 2024.
14 1 Last December, the NRC published for comment in the 2 Federal Register the draft NUREG-2212, which is the standard review plan for 3 Greater Than Critical Mass facilities. The comment period ended on March 31; 4 the comments are currently being reviewed by NRC staff.
5 In June 2022, Global Nuclear Fuel - Americas submitted a 6 license amendment request for an enrichment increase to eight percent. We 7 anticipate completing the review in October of this year.
8 Finally, the NRC staff anticipates completing its review of 9 Sensor Concept's and Applications license renewal request by the middle of 10 this year. Next slide, please.
11 The Fuel Cycle Business Line strongly encourages potential 12 applicants and licensees to hold pre-application discussions with the NRC so 13 that we can establish a shared understanding of the licensing pathways, 14 timelines, and resources that will be needed for the NRC's regulatory process.
15 The engagement also facilitates completeness and quality of submittals.
16 Later this year, the NRC staff anticipates an application from 17 American Centrifuge Operating to address its contract with DOE, which 18 includes three three-year production cycles of the 16 centrifuges in a cascade 19 with a production rate of 900 kilograms a year of HALEU from 2025 through 20 2033.
21 Last month, Global Nuclear Fuel - America submitted a 22 supplemental environmental report for fabricating metallic Natrium Reactor 23 HALEU fuel in a new facility to be built -- a new process to be built at the Global 24 Nuclear Fuel - America site in Wilmington, North Carolina. The NRC staff 25 anticipates the safety portion of the application to be submitted this year, in
15 1 October. The NRC is contemplating a 24-month review.
2 In addition, GLE anticipates submitting an application to 3 enrich depleted uranium purchased from DOE to natural levels, at a new laser 4 enrichment facility to be built in Paducah, Kentucky.
5 Since early 2022, the NRC staff has conducted 6 pre-application engagement with Niowave for its planned for commercial 7 molybdenum medical isotope facility in Lansing, Michigan. For the NRC, 8 Niowave's application will be the first-of-a-kind review of a large medical isotope 9 facility entirely under Part 70.
10 Finally, Framatome plans to submit an application to possess 11 and use uranium enriched to above five percent in mid-2023, and a criticality 12 computer code validation port for HALEU up to 20 percent later this year. Next 13 slide, please.
14 The New Fuels Atlas, previously referred to as the Advanced 15 Fuels Roadmap, consists of a regulatory planner and communication tools.
16 The goal is to use the Atlas to identify the needed actions and activities to 17 ensure the NRC's readiness to regulate new fuels.
18 The regulatory planner will consolidate information on what 19 we are doing and what we expect will need to be done. It will cover 20 programmatic areas, such as licensing, oversight, and research activities 21 associated with enrichment, fabrication, and transportation of the different 22 anticipated fuel technologies such as TRISO, metallic, and molten salt fuels.
23 You'll hear more about this regulatory planner in the next 24 panel's discussion on the back end of the fuel cycle.
25 The Atlas is also intended to enhance our stakeholder
16 1 communications through use of an infographic, part of which is pictured here, 2 and a new HALEU public website. We hope to enhance public confidence in 3 our abilities to effectively regulate these new fuel technologies by showing how 4 our existing regulatory framework is able to accommodate them.
5 This concludes my remarks, I now turn it over to Lindsey 6 Cooke. Next slide, please.
7 MR. COOKE: Good morning, Chair and Commissioners. I'm 8 Lindsey Cooke, a Fuel Facility Inspector in the Division of Fuel Facility 9 Inspection, or DFFI, in Region II.
10 Region II has the inspection oversight responsibility for all the 11 fuel facilities across the country. I will briefly speak about the year we've had 12 and years to come. Region II realigned our focus areas this year to represent 13 who we are and what we value more adequately.
14 To that end, we call our focus areas MVP, which signify our 15 mission focused, value centered and people driven philosophy. In keeping with 16 these areas I will describe how we meet our mission, live our values and 17 intentionally support and develop our people.
18 Next slide please. Our mission has remained our top priority.
19 In terms of time, this past fiscal year we've conducted over 4,800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of 20 direct inspection, spread out over 93 inspections to ensure our core program is 21 complete. We've accomplished this through the hard work and vigilance of 21 22 traveling inspectors, from four divisions, and two resident inspectors, who have 23 applied their knowledge, skills and abilities at all ten of our operating facilities.
24 Beyond our core inspection program, DFFI analyzed 27 event 25 reports at licensed fuel facilities last calendar year and conduced special
17 1 inspections at two facilities as a result. These events warranted increased 2 inspection and we sent teams to the sites to evaluate the circumstances and 3 the licensee's actions.
4 Shifting to the future, DFFI's work appears to be increasing.
5 Over the next few years, we expect several new applicants to apply for 6 licenses, and existing licensees have signaled that they plan to build new fuel 7 facilities, as you've heard from others during this meeting.
8 Some of these facilities will supply advanced fuel to the next 9 generation of nuclear power plants. Others will provide medical isotopes to 10 support nuclear medicine. And some may supply other aspects of the nuclear 11 fuel cycle.
12 With this increased workload Region II and DFFI remain 13 focused on developing and executing construction and operations oversight 14 programs to reasonably assure public health and safety and common defense 15 and security at these novel facilities.
16 Next slide please. In Region II, our values serve as our 17 compass on our journey to mission success. Our seven values continue to 18 guide our actions and interactions.
19 We serve our stakeholders with integrity and openness, 20 exemplified in our interactions with the public during our licensee performance 21 review meetings and fuel facility stakeholder meetings. Specifically, we 22 ensured that the location and format of our LPR meeting for Westinghouse's 23 Columbia Fuel Fabrication Facility was amendable to underserved residents in 24 Hopkins, South Carolina. Similar, we engaged with the local government of 25 Metropolis, Illinois as Honeywell began their restart efforts.
18 1 We stay committed to our mission and each other. We 2 leverage our technical and nontechnical excellence to improve ourselves and 3 focus on what matters. To that end, we've continued invoking risk insights 4 through our use of Be riskSMART tools to make timely decisions at all levels, 5 from inspection to budget.
6 We stay committed to each other by mentoring new hires, 7 streamlining qualifications and ensuring that we are purposeful in our presence 8 in both our physical and virtual environments.
9 Finally, we work cooperatively and respectfully within our 10 region and with other organizations inside and outside the agency. Weve 11 fostered an environment where all individuals have a seat at the table in 12 resolving concerns. This is seen in our thoughtful and frequent discussions 13 with OGC, OE and NMSS through various unique and challenging issues.
14 We've continued to welcome the diversity of thoughts and 15 opinions from inside, and outside the Agency, by encouraging participation from 16 external stakeholders, including industry, NEI and the public, for various 17 interactions. In all, our Region, and our Agency, keep our core values centered 18 in our minds and exhibited in our actions.
19 Next slide please. Our mission is not achievable, and our 20 values are not expressible without knowledgeable, skillful and talented staff. To 21 that end we've taken our signpost and markers from our mission. Both what it 22 is today, and what it may become, and acted on it.
23 We've used strategic workforce planning to assess present 24 and near-term gaps and harmonized that with our attrition, utilization and 25 budget to manage our staffing needs. We recognize the potential growth in
19 1 new and novel facilities, and the skills needed to become and remain an 2 effective regulator.
3 As shown in the chart on this slide, to accommodate for this 4 potential growth, as of today, DFFI currently has 14 qualified inspectors, five 5 individuals in training and two openings to meet our near-term staffing needs.
6 We determined that growth today would facilitate technical competency in the 7 future.
8 Focusing on our people, wevre removed barriers and built 9 scaffolds to support development. We've updated our guidance for inspector 10 qualification, increased flexibility in getting material control and accounting 11 courses for our staff, actively participated in leveraging and growing our 12 Agency's knowledge management, and instituted an ambassador program to 13 ensure that new hires are paired with seasoned and welcoming senior 14 inspectors who can help them navigate and acclimate to our culture and 15 expectations.
16 While we cannot predict the future of our mission with the 17 exactness one may desire, we remain confident that by building and supporting 18 our staff we will grow and maintain the expertise needed for whatever the future 19 may hold.
20 This completes my portion of the presentation. I'll now turn it 21 over to Becca. Next slide please.
22 MS. RICHARDSON: Thank you, Lindsey. Good morning, 23 Chair and Commissioners. I'll be providing an overview of security activities 24 supporting fuel facility licensing and oversight, with a focus on staff activities 25 related to security of special nuclear material, or SNM, and evaluation of a
20 1 graded risk-informed approach to regulatory oversight.
2 Next slide please. As an overarching message, fuel facility 3 reviews are both complex and diverse. This has required NRC security 4 regulatory framework, which includes the regulations, along with any additional 5 supplemental security measures and orders, which are made part of the 6 license, to remain flexible and adaptable as licensee and applicant security 7 programs evolve.
8 The current regulatory framework ensures adequate 9 protection of public health and safety and the common defense and security.
10 The staff is evaluating the effectiveness of this framework, to include 11 strengthening stakeholder confidence in accordance with the NRC's strategic 12 plan goals.
13 With HALEU coming and fuel aging, it is important to ensure 14 we continue maintaining adequate protection. The staff has been actively 15 seeking opportunities to optimize the security regulatory framework. This 16 includes taking a risk-informed graded approach to the security regulatory 17 structure. Like applying material attractiveness and the grading of physical 18 protection requirements for fixed sites and transportation of SNM.
19 This approach allows the Staff to focus physical protection on 20 the material itself, as opposed to on the facility that possessed it. Thereby 21 promoting a consistent level of protection regardless of its location.
22 The staff has used the Be riskSMART framework in a matrix 23 that uses the principles of good regulation in a structured manner to assess 24 options under consideration in commission papers.
25 Next slide please. As I mentioned, we are evaluating
21 1 potential changes to our regulatory framework for security for SNM to provide 2 more regulatory stability, predictability and clarity. The combination of risk 3 insights and changes in the types of facilities and materials being regulated by 4 the NRC since 1979, when the NRCs current regulations for physical protection 5 of SNM were revised, has led the Staff to consider the benefits of using a more 6 risk-informed material attractiveness approach for physical protection of SNM.
7 Simply put, the more dilute the material and correspondingly 8 the more difficult the acquisition and processing of the SNM, the less attractive 9 it is to an adversary. Specifically, Staff is developing a commission paper with 10 potential options for enhancing security requirements for SNM in response to 11 Commission direction in SRM-SECY-19-0095.
12 To support this paper, Staff have been engaging in focused, 13 technical discussions with stakeholders through a series of public meetings on 14 the following five topics. Topic Alpha, security for Category 2 quantities of 15 SNM. Topic Bravo, self-protection limit for security of spent nuclear fuel. Topic 16 Charlie, security for spent nuclear fuel. Topic Delta, security for alternate 17 nuclear material, or ANM. And this includes fissile nuclides, such as americium 18 and neptunium, which can be produced through reprocessing activities. And 19 topic Echo, security for Category 1 and Category 3 quantities of SNM.
20 Staff is doing this both to understand if regulatory gaps exist, 21 and to assess whether the current and potential future regulatory burden is 22 reasonable. These public meetings were widely attended, and stakeholders 23 provided feedback on a number of important topics.
24 Specific issues that were mentioned or discussed in detail 25 included, the Staff rationale for thresholds among proposed dilution levels, the
22 1 use of separability and the definition of SNM attractiveness, the types of 2 facilities to which potential changes in the regulations would apply, the extent to 3 which NRC Staff can provide the public an understanding of security 4 requirements, the need for regulations to combine performance-based and 5 perspective requirements, and ensuring analysis provides the justification for 6 changes to the regulations. This SECY paper is due to reach the Commission 7 in October.
8 Next slide please. NSIR Staff have supported many of the 9 licensing and oversight projects that Yawar and Lindsey discussed in the area 10 of physical protection. I'd like to highlight a few of those today.
11 First, after the Department of Energy informed the NRC that it 12 would no longer serve as the authorizing official of classified networks for NRC 13 licensees of Category 3 enrichment facilities in late 2020, the NRC 14 demonstrated adaptability of NRC security framework when it took on the 15 authorizing official function. This was made possible by Staff from a number of 16 offices across the NRC coming together to develop a framework that ensures 17 programs, such as communication security, foreign ownership controller 18 influence, and counterintelligence are appropriate addressed.
19 As a result, all licensee systems are authorized to operate 20 and are continuously monitored for compliance with federal policy for the 21 protection of classified information information systems.
22 Second, Staff is also increasing efficiency of licensing reviews 23 through effective early engagements to understand the unique aspects of the 24 different facility design features and operations. Once license applications are 25 received, Staff will leverage the knowledge gained through these early
23 1 pre-licensing engagements to perform analyses that consider the material 2 attractiveness that is the forms, dilution and quantities of material as it relates to 3 improvised nuclear devices and proliferation risk in order to establish 4 appropriate security requirements for the facilities.
5 Third, on March 14th, a final rule implementing commission 6 preemption authority under Section 161(a) of the Atomic Energy Act was 7 published. Section 161(a) authorizes the Commission to designate those 8 classes of licensees eligible to apply for permission to use certain firearms, 9 weapons, ammunition or devices notwithstanding local, state, and certain 10 federal firearms laws and regulations prohibiting such use.
11 Under the fuel facility business line staff have received 12 inquiries from more than one licensee on potentially holding a pre-application 13 engagement meeting regarding a possible license amendment to obtain 14 combined preemption authority and enhanced weapons authority under the 15 Commission's new regulations in 10 CFR 73.15 and 73.17.
16 It is efforts like these that highlight the Staff's continued 17 application of risk insights, as well as the importance of assessing new and 18 emerging technologies and materials and engaging with stakeholders. This 19 concludes my part of the presentation. I'll now turn it over to Dan.
20 MR. DORMAN: Thank you, Becca. And I want to thank all 21 the panelists today, the Staff who supported the preparations for this 22 Commission meeting, and all of the headquarters and region staff working to 23 support the fuel facilities business line. This concludes our presentations for 24 this panel, and we welcome your questions.
25 CHAIR HANSON: Thanks, Dan. We'll begin questions this
24 1 morning with Commissioner Baran.
2 COMMISSIONER BARAN: Well thank you for your 3 presentations. It's a busy time in the fuel cycle area of our work because we're 4 seeing applications for new facilities for the first time in quite a while.
5 Yawar, I think most of my questions relates to the topics you 6 cover, but anyone on the Panel should feel free to chime in. You mentioned the 7 TRISO-X application for a new fuel facility, which was submitted last year. This 8 would be for a Category 2 fuel fabrication facility, which NRC hasn't licensed 9 before. How is that review going so far, and are there any particular challenges 10 the Staff sees for that review?
11 MR. FARAZ: Commissioner, the review is currently on 12 schedule. We recently reviewed responses to a set of RAIs that we had issued 13 on the environmental review. We plan to be issuing the safety of the RAIs 14 soon.
15 In our acceptance letter we had identified that we would need 16 additional information on electrical and digital instrumentation and control, I&C, 17 by August of 2023. So that's something we are expecting from TRISO-X. Any 18 kind of delay in receiving that information could challenge the schedule that we 19 have provided in our acceptance letter.
20 COMMISSIONER BARAN: Okay. And you also briefly 21 discussed the American Centrifuge amendment request to produce 1,400 22 kilograms of HALEU. How is that review going so far?
23 MR. FARAZ: On April 13, the Staff accepted the amendment 24 request for a detailed review. The Staff anticipates issuing any requests for 25 additional information, RAIs, in May. And then completing the review ahead of
25 1 the requested February 2024 completion date.
2 COMMISSIONER BARAN: Okay. And if the American 3 Centrifuge application to do more or longer term HALEU production comes in 4 as anticipated later this year, how will that review compare to the current 5 review? Will some of the key technical issues be resolved? Are there kind of 6 links between those two applications?
7 MR. FARAZ: Yes. So the basic review that was completed 8 was in June of 2021. That was for the demonstration project.
9 And so these amendments that we are receiving for ACO are 10 essentially extensions of that demonstration project. So it's basically the same, 11 16 Centrifuge Cascade that would be used for these additional time periods.
12 COMMISSIONER BARAN: Okay. And so, I take it then that 13 the technical issues around that cascade are resolved and now we're --
14 MR. FARAZ: Most of the technical issues are resolved, 15 correct.
16 COMMISSIONER BARAN: Okay. So --
17 MR. LUBINSKI: Excuse me, Commissioner, if I could --
18 COMMISSIONER BARAN: Sure.
19 MR. LUBINSKI: -- add to that?
20 COMMISSIONER BARAN: Yes.
21 MR. LUBINSKI: For the current review, and Yawar may be 22 able to expand, as he said we just received the application for the current 23 review. We are looking at us being ahead of schedule.
24 There is one issue that I'll say is a bit unique, and it's with 25 respect to the emergency preparedness, or emergency planning and what
26 1 they're looking at there. So they have provided us some information looking at 2 their hazard analysis and their consequences of the most, you know, worst 3 case credible accident.
4 That's a bit unique in review. We are definitely working with 5 our technical reviewers in NSIR. It's too early to tell whether or not what they 6 provided is acceptable or not since we've only had it for one week now.
7 COMMISSIONER BARAN: Okay.
8 MR. LUBINSKI: We do believe that we're able to address that 9 issue adequately with respect to the current review, that would be addressed in 10 the subsequent review as well.
11 COMMISSIONER BARAN: Okay, thanks. Global Nuclear 12 Fuel - Americas has submitted an application to build a new facility to fabricate 13 Natrium reactor HALEU fuel. How is the environmental review going so far, and 14 are there any particular challenges the Staff sees for the safety review that's 15 expected to begin later this year?
16 MR. FARAZ: So yes, we received the supplemental 17 environmental report to possess and use 20 percent U-235, which would 18 support the Natrium fuel in March of 2023. So our environmental review is just 19 beginning at this point.
20 As part of a safety review, we will need to appropriately 21 consider the complexities involved with addressing the requirements for 22 Category 2 and Category 3 material under one license. So that's one issue that 23 we might confront. We have addressed similar issues before and we will 24 leverage lessons learned from those reviews in this case.
25 COMMISSIONER BARAN: Okay. Can I ask just kind of a
27 1 broad question? It sounds like things are moving along pretty well, in all these 2 reviews you're not really anticipating major challenges. Given that we hadn't 3 done Category 2 facilities before, are we finding it challenging to do those types 4 of reviews? Are there issues coming up that we weren't expecting?
5 MR. FARAZ: In the case of ACO we did do a Category 2 6 review. So the ACO's demonstration program is for a Category 2 facility.
7 COMMISSIONER BARAN: Right.
8 MR. FARAZ: But that's with UF6. With fuel fabrication, we 9 haven't done Category 2 reviews. And again, as they, as we review the 10 application I think we'll address the issue as they come up.
11 COMMISSIONER BARAN: John?
12 MR. LUBINSKI: Thank you, Commissioner. If I can add one 13 other reasons I think that it has been positive and why we have not seen the 14 issues is the outreach we've had with the community and the pre-applications 15 meetings they've had with us. That's a very important aspect to understanding 16 before they come in.
17 Understanding which issues may be more challenging. We've 18 been out to the sites, and pointing toward Becca's folks in NSIR in the security 19 area, they were out for pre-licensing application visits. We're continuing to work 20 with them, not just on the security side, but the information handling side at 21 some of the Cat 2 facilities. And being able to identify some of the technical 22 issues early so that we can provide some expectations, whether it's formal 23 guidance or informal guidance to them.
24 One of the areas that we did provide more formal guidance 25 was on the MC&A area for Cat 2 facilities. So being able to provide that
28 1 information out through guidance has helped to facilitate addressing those 2 technical issues early.
3 COMMISSIONER BARAN: Great. The Honeywell Metropolis 4 Uranium Conversion Facilities restarting this month, that was mentioned earlier.
5 Any issues or challenges expected with that restart or inspection activities 6 there?
7 MR. FARAZ: Um, yes, go ahead.
8 (Simultaneously speaking.)
9 MR. COOKE: I can take this one. Thank you, Commissioner 10 Baran, for your question. DFFI, the inspectors, we do not anticipate any issues 11 or challenges with the restart of Honeywell. No issues or challenges have been 12 incurred thus far with restart activities.
13 Following Honeywell's announcement in 2021 to restart the 14 facility, the NRC commenced frequent startup and coordination meetings with 15 Honeywell. And starting in 202s and going forward, the core inspection 16 program was restored to a nominal conversion facilities inspection frequency 17 from the reduced inspection frequency that it had been at.
18 Additionally, we established milestones for inspections of 19 various functional areas of the facility prior to restart of operations.
20 Regional inspectors have completed a 100 percent validation 21 of the safety controls prior to restart, resumption of a functional areas operation.
22 In addition, regional inspectors have conducted supplemental inspections 23 throughout 2022 and 2023 to verify that staffing, training, security and the 24 emergency response organization, were restored as required by the license 25 application.
29 1 In addition, the site's post-9/11 security order was reinstated 2 to its full effect. And full operation of the facility is expected to resume around 3 early May.
4 COMMISSIONER BARAN: Excellent. Thank you. Thanks, 5 Chair.
6 CHAIR HANSON: Thank you, Commissioner Baran.
7 Commissioner Wright.
8 COMMISSIONER WRIGHT: Thank you, Chair. And good 9 morning. Yes. Yes, this is one of my favorite Commission meetings because of 10 what you all do. It's very interesting to me.
11 And I know that there is a lot going on. And I recognize and 12 appreciate very much what it takes to prepare and what it takes your staffs to 13 prepare you for these meetings, so thank you for that. And that also goes for 14 my team as well.
15 John, I'm going to start with you. You know, you mentioned 16 that hiring is the number one priority for this business line. And in your opinion, 17 this is your opinion, okay, does our process take too long?
18 And as a follow-up on that, you know, are you using or are 19 you able to use all the tools in your toolbox? I mean, everything maybe from 20 like relocation flexibilities all the way to direct hire authority.
21 MR. LUBINSKI: Thanks. If I could start, before answering 22 the question, thank you for recognizing the folks that not only support the 23 business line but support us today. We're here at the table doing the 24 presentations, but it was really the hard work helping them prepare, and so 25 thank you for that.
30 1 Overall I would love to see the processes go faster. And if 2 you're asking my opinion, yes, overall we are taking longer than we should in 3 moving forward.
4 With that said, as we continue to try to speed up our 5 processes we needed to make sure that they continue to ensure we hire high 6 quality people, ensure equity and fairness in our hiring, and making sure that 7 we're getting diverse and highly inclusive candidate pools. So we need to keep 8 that insight as we make changes. And we cant put speed and efficiency ahead 9 of that.
10 Overall I don't have statistics on how quickly hiring goes in 11 NMSS compared to in the past. But I know OCHCO is starting to look at that, 12 with the purpose being, if they find areas where there are any bottlenecks or 13 hangups that we can make those more efficient to help those processes. And 14 I'm really glad the team is working across the Agency together to do that.
15 I will say in NMSS, while I don't have statistics on how fast we 16 hire, I have looked at last year to this year. For the first half of last year NMSS 17 hired 12 folks into the organization. This year in the first half of the year we've 18 hired 29. So that's more than double the amount of folks at the rate of hiring 19 this year.
20 As a subset of those, last year at this point we only hired 21 three people external to the NRC into to NMSS. This year the number is 21.
22 So it's a factor of seven more that we're hiring external to the Agency. So I'm 23 very proud of those numbers in what we're doing to bring people in.
24 While there are still challenges, and I'm cautiously optimistic, I 25 do think we need to speed up the process. With respect to tools, we are using
31 1 all the tools in our toolbox across NMSS right now. And in some of those I think 2 we need to do a better job of using them more often, if you will.
3 In direct hiring, we have done direct hiring of folks of veterans, 4 persons with disabilities, grants recipients, selected occupational series, such 5 as general engineers and scientists, as well as converting summer hires and 6 co-ops into permanent staff members, which has really helped.
7 We are going to be part of the May 11th hiring fair that we're 8 having at the Marriot across the street. For those online, if you're interested, 9 please be there. If you have friends, please encourage them to attend.
10 We also put together tools such as Tiger Teams to look at 11 hiring folks and use our over-hires in areas such as areas in administrative 12 assistance where we've seen a continued growing need. And we over hired in 13 that area because we find that they're continuing to internally get new positions 14 in the agencies. So we're keeping a good backfill there. So over-hires is 15 another tool we've used.
16 Finally, with respect to relocation, that's probably been one of 17 our biggest challenges. While we have put some flexibilities in place to allow 18 people to maybe do short-term telework as they're trying to work into the 19 organization, we have been challenged financially to support all of the requests 20 we've gotten for relocation and paying relocation costs to move people to our 21 offices.
22 And we have, while we've posted positions as Rockville 23 location only, we've had people apply who have said, okay, I'll take the job but I 24 want a full-time telework and I don't want to move, and we have not been able 25 to accommodate that in all cases because we've seen the importance of having
32 1 folks in the building.
2 COMMISSIONER WRIGHT: Thank you so much. That was 3 more than I thought you were going to be able to come back with.
4 (Laughter.)
5 MR. LUBINSKI: With it being our number one priority there is 6 a lot of interest in this area.
7 (Laughter.)
8 COMMISSIONER WRIGHT: That was very complete. Thank 9 you so much.
10 I'm going to turn to FEVS scores for a second. You know, 11 you mentioned that the senior leaders are doing, what you're doing to focus on 12 the leadership model and behaviors and stuff like that. Looking at the data 13 though, it appears that first-line supervisors are really outperforming the senior 14 leaders in these scores. And how can senior leader, or senior managers, right, 15 build upon the continued success that the NRC's first-line supervisors have 16 been experienced in over maybe the last five years or so?
17 MR. LUBINSKI: Yes, thanks. Before I go into your positives 18 there I'm going to say, when the FEVS scores came out I took it very seriously 19 and I took it to heart. Maybe even went through the stages of grief and 20 acceptance of those as we went through that.
21 But as you said, what we looked at is the positive of our 22 first-line supervisors, our branch chiefs and our team leaders. I've always said 23 they have the most difficult job in the agency being our line supervisors. And 24 they do an outstanding work. And that's reflected in the FEVS scores.
25 We've reached out to them to ask them what's the secret,
33 1 give us the tools. They brought up a couple of things. Number one is trust.
2 And there is a high trust between them and the folks in our organization. And 3 they believe that is because of the amount of interaction and the relationship 4 building they have.
5 How are they building that trust is continued communications 6 and nurturing those relationships. They've advised us to continue to increase 7 our communications. We've done that in a formal way by having chats, open 8 doors across the office, allowing people to bring up any topics, any discussion 9 points.
10 We've had meet and greets with all the new staff coming into 11 the organization so that we, again, can help build a relationship with folks as 12 they come in. And make it more comfortable that they can come down and talk 13 with us about issues.
14 We've heard from folks in the branch chief saying, explaining 15 our decisions is probably the most important. We want diversity, we want to 16 hear diverse opinions, but how are we making sure that we're communicating 17 our decision making, why we made the decision, so that people can learn from 18 that going forward.
19 And then finally, my last part on workload is not workload just 20 from the standpoint of getting our mission done, but it's the impact it has on 21 people and the trust that they have with us. We've implemented a philosophy in 22 our office called 80/20.
23 What we've determined is, with about 20 percent of the effort 24 you get 80 percent towards the solution you're trying to get to. And we've 25 learned that with our branch chiefs, that's where most of the folks have that
34 1 conversation. They put 20 percent of the work in, they communicate with the 2 branch chiefs to say, here's where I'm going, are we aligned, where are we 3 going here.
4 But many times that doesn't happen with the senior leaders 5 until later. And they have to put in extra time and effort. They feel they need to 6 come in with polished presentations and be perfect in those presentations. And 7 we're trying to say, no, as you do that, let's have those engagements early so 8 that we can make sure before we're spending too much time and effort on an 9 issue, we have full alignment. And I think that helps build the trust so that 10 someone doesn't come in at the end with what they believe is a very perfect 11 polished product, and then we have to course correct at the end.
12 COMMISSIONER WRIGHT: Okay, thank you. This is an 13 important area, so I'm glad you're paying attention to it.
14 Carrie, I want to come to you a second. So first off, you 15 mentioned in your testimony there that, or your comments, that you had a 16 weeklong course coming up in May and again in the fall. Is that something 17 Commissioners can do too?
18 MS. SAFFORD: Absolutely. Absolutely. We encourage 19 Commissioners, your Staff. if you'd like to participate it will be offered hybrid as 20 well.
21 COMMISSIONER WRIGHT: Yes.
22 MS. SAFFORD: Yes.
23 COMMISSIONER WRIGHT: I'm going to see if we can't fit 24 that in my calendar.
25 MS. SAFFORD: Look forward to it.
35 1 COMMISSIONER WRIGHT: Now, you spoke about this pulse 2 survey that you did and conducted last year. Can you give me a little bit more 3 detail about, maybe the findings and maybe what you really ask in that, what 4 you're looking for, and what did you pulse, and are you planning to do another 5 one?
6 MS. SAFFORD: Sure. Okay. I'll start, and then might look 7 over, I'm not sure if anyone else in the panel has more details on it. But 8 basically we were looking to get some risk-informed insights to make sure that 9 the appropriate focus is applied in our inspection activities. The areas that are 10 most important for safety.
11 And some of the feedback that we got from the pulse survey 12 was that the smarter inspection program is helping focus inspections on safety 13 and risk significant issues at fuel cycle facilities. So it's doing its job. It's 14 helping to focus in.
15 And a lot of the respondents also felt that it was useful to 16 have during the COVID pandemic environment. So it helped them to, it didn't 17 impact, it didn't impact the inspections any more than any other inspections 18 going on at the Agency.
19 Obviously if anything that was of any significance in the safety 20 or public health arena came up, that would have been addressed immediately, 21 and that wasn't the case. So that's the good news that's coming out of it.
22 My understanding is that a couple of the areas that we're 23 going to be looking at going forward are going to be inspection resources 24 estimates, inspection frequencies and the scope of inspections. But again, 25 that's all preliminary information. And as I indicated, it's going to be a, it's a
36 1 three-year cycle. So once that three-year cycle is complete we'll take a look at 2 the entire program.
3 I don't know, I don't know if anyone on the panel, are you 4 aware if we're going to do another pulse survey? But we certainly can if we 5 need to.
6 MR. COOKE: I'll add maybe just a little bit. We did, yes, we 7 wanted to do that one-year review just to make sure that we felt comfortable 8 that we were still completing our core inspection program, kind of like before.
9 And then we deliberately wanted to get, some of our 10 inspections are triennial, so we wanted to make sure we got at least one of 11 each kind of inspection at all of our facilities before we worked with our program 12 office to do a more holistic assessment of the smarter inspection program in 13 2024.
14 But that we are still capturing feedback from the Staff to 15 identify, you know, where we have challenges. And so, one example of where 16 that occurred was in the material control and accounting inspections.
17 Specifically at the Category 1 fuel facilities.
18 Some inspectors identified that they had needed some 19 additional time to complete the inspections and so we stood up a working group 20 and are currently looking at the inspection procedures to make sure there is 21 adequate guidance and sufficient flexibility within the inspection procedures to 22 execute the program effectively and efficiently.
23 And then just adding, as an inspector, we recognized that the 24 inspection procedures for the smarter inspection program, the resources are 25 estimates. And I have never gotten any push back from my management if I'm
37 1 at a site and I need more time to look at something to complete my inspection, 2 I'm able to do that. So we are confident that we continue to complete our 3 program.
4 COMMISSIONER WRIGHT: Great. Thank you so much.
5 CHAIR HANSON: Thank you, Commissioner Wright.
6 Commissioner Caputo.
7 COMMISSIONER CAPUTO: Good morning. I'll just add my 8 compliments, thank you very much for all preparing and being here today.
9 I'm going to start with Ms. Safford. Discuss the strategies the 10 business line is employing to recruit and do knowledge management.
11 I'm going to start with one question. Is Miranda here today?
12 MS. SAFFORD: I don't think she's --
13 COMMISSIONER CAPUTO: No?
14 MS. SAFFORD: -- in the office.
15 COMMISSIONER CAPUTO: Okay. All right.
16 MS. SAFFORD: She might be on line, but I'm not sure. But I 17 did give her a heads up, so I do believe she's listening on line. I told her --
18 COMMISSIONER CAPUTO: Well I sure hope so. Miranda, 19 thank you for your efforts on the reprocessing page. I look forward to giving 20 that a review and refreshing myself on the things that I haven't looked for awhile 21 and learning everything else that's probably quite a treasure trove in that 22 Nuclepedia page. So thank you for your work, Miranda.
23 So, Ms. Safford, when looking at the types of applications that 24 are coming in, do you think we have the workforce and the skill sets that we are 25 going to need to review these applications?
38 1 MS. SAFFORD: Yes. So I think we do have the skill set, for 2 sure. It's a factor of, do we have experienced skill set, yes, we do. We're also 3 bringing on additional people so the skill set is being developed at the same 4 time. And I think that plays into whether we have the workforce at the moment.
5 Right now if everything came in the door all at once, no.
6 Right? But everything is spaced out across the next year, year and a half.
7 COMMISSIONER CAPUTO: Well, the good news is it doesn't 8 all come in the door at the same time, and the good news is you finished that 9 whole tranche of work, given the list of accomplishments. So theoretically, that 10 frees up time for people to move on to the next task.
11 But, you know, I have to admit, I've got a question here.
12 Obviously there are statements in here about potentially having some delays in 13 some of the work and not having the manpower, or people power, necessary to 14 meet what's going on now.
15 So I have sort of a broader question. And this is going to be 16 for Dan, because I think this potentially effects the whole Agency.
17 You know, when I look at the fee recovery rule, we're going to 18 have 650,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of work that we will bill to licensees and applicants for 19 licensing reviews and inspections. So I'm going to focus on inspection for just a 20 minute because I think that's potentially where the challenges are that you're 21 looking at.
22 You're hiring, you're bringing people in. If they're new, 23 obviously then there is a fair amount of run time that they need to get and 24 training they need to get before they're really ready to be useful and take on, 25 you know, what is fairly technical, fairly challenging work. What ability do we
39 1 have to reassign people that are currently in the Agency that are not 2 necessarily doing this work?
3 Because this 50, this 650,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of work, this is our 4 mission. Right? This should be our focus is making sure that that is a priority 5 for staffing. And if we have a sector of expertise that ends up being somewhat 6 of a training ground that people do this for a while and develop expertise and 7 are then recruited away to other areas within the Agency, that kind of becomes 8 a struggle.
9 So, Dan, I want to understand, to what extent are we able to 10 keep or attract people to actually doing the mission direct work, because if we 11 have people have shifting from mission direct into mission indirect, that's a 12 challenge.
13 MR. DORMAN: Yes, thank you, Commissioners. So, sure, 14 that's a management challenge that at any time in the organization's history, but 15 I think the mission direct work is the priority and we will do what we need to do 16 to make sure that that's appropriately staffed.
17 I think part of the, perhaps the nuance to that challenge in the 18 period that we're in, and you touched on it in your question is, we are 19 experiencing higher attrition than we have historically because of the 20 demographics that we've built over time. And combined with that, you know, 21 offsetting that, we're bringing in new staff.
22 And so the new staff, as they come in and get qualified, are 23 not, as they're developmental work, until they're qualified, is not charged as that 24 direct work. So we need to have the experience people walking with them 25 through that as they get qualified.
40 1 COMMISSIONER CAPUTO: Well, good --
2 MR. DORMAN: So --
3 COMMISSIONER CAPUTO: -- because our licensees and 4 applicants shouldn't be basically a training ground --
5 MR. DORMAN: Right.
6 COMMISSIONER CAPUTO: -- across.
7 MR. DORMAN: Right. Well it's -- yes, let me qualify that. I 8 need to get those up and coming inspectors in the field with seasoned 9 inspectors. The seasoned inspectors are doing the core inspection. The 10 inspectors under development are alongside them, but their time, when it's 11 developmental time, is not getting billed hourly to the licensee as the direct 12 inspector is.
13 COMMISSIONER CAPUTO: But when it comes to licensing, 14 what's our ability to reassign people that are elsewhere in the Agency that might 15 have the expertise that Ms. Safford needs to keep up with her workload --
16 MR. DORMAN: Yes.
17 COMMISSIONER CAPUTO: -- because that's our primary 18 mission.
19 MR. DORMAN: Yes. So it's, we obviously have the ability, 20 management has the ability to direct work so we can pivot resources as we 21 need to.
22 And that's part of our, John alluded to it in some of his 23 remarks, is our add, shed, defer process. As we look at the work that's in front 24 of us, we want to make sure we've having, the highest priority work is getting 25 accomplished first. And if that involves reassigning people among projects then
41 1 management has the ability to do that.
2 COMMISSIONER CAPUTO: So are we going to do that here 3 to make sure that we don't have to defer work?
4 Because this is a growing portion of our portfolio, and if we 5 are at this point in time in a position where we have to defer and delay licensing 6 work because we don't have adequate manpower, we're going to end up behind 7 a curve that's going to progressively get steeper over the next few years.
8 And I get it that you're hiring, you're bringing people on --
9 MR. DORMAN: Yes.
10 COMMISSIONER CAPUTO: -- but we need to make sure we 11 don't fall behind the ball or we're going to have a hard time catching up.
12 MR. DORMAN: Yes, agreed. That's the urgency behind the 13 hiring. It's also, you know --
14 COMMISSIONER CAPUTO: Yes.
15 MR. DORMAN: -- there are --
16 COMMISSIONER CAPUTO: You're coming back to the hiring 17 --
18 MR. DORMAN: Yes. But --
19 COMMISSIONER CAPUTO: -- but my question is about the 20 reassigning.
21 MR. DORMAN: Yes. So yes, we can reassign people. Also, 22 part of our human capital strategies can include bringing back people to support 23 the knowledge transfer and to support projects as needed through rehired 24 annuitants, various, a couple different authorities that we have in the toolbox in 25 that area as well. So there are a number of tools available to the managers to
42 1 make sure that we get the right talent on the high priority work as we go.
2 COMMISSIONER CAPUTO: I have to say, I struggle as a 3 Commissioner, when we get, certainly questions externally, like yesterday, and 4 there are constant discussions, constant comments about, are we ready, yes, 5 we're ready, or we will be ready, we're preparing, you know, et cetera, et cetera, 6 and yes, we are hiring to develop the skills that we need. But when we are at 7 the same time trying to convey a sense of confidence that we can handle the 8 challenges that are coming, but at the same time in a position where we're 9 deferring work, that tells me that our strategic workforce planning really hasn't 10 been strategic enough to anticipate where we are today. Which then gives me 11 pause about whether it's adequate going forward.
12 So what are you looking at in terms of strategic workforce 13 planning to make sure that if that is a tool and a process that we are supposed 14 to rely on to ensure that we have the right people in the right place at the right 15 time, that that strategic workforce planning is actually up to the task?
16 MR. DORMAN: So, I think one of the areas that we're looking 17 at in our evidence building plan is to do an assessment of our strategic 18 workforce planning. So I think that's an opportunity we have to make sure that 19 that's serving us in the best way.
20 I think you're aware that our strategic workforce plan is built 21 around an environmental scan that's conducted every year to look out five 22 years and make our best estimate of the workload that's coming before us over 23 that period of time and to identify the critical skills associated with that work and 24 to incorporate that into our staffing strategies.
25 So I think, right now I think our biggest challenge is getting up
43 1 to our authorized FTE and getting those people in and qualified in support of 2 our strategic workforce plan. So it's really, at this point, I think our biggest 3 challenge in executing the strategic workforce plan is getting the talent in the 4 door.
5 COMMISSIONER CAPUTO: I get it with the hiring, and I 6 agree with the 400. I think we have known for a very long time that we had a 7 significant component of extremely experienced people who would, at one 8 point, head into retirement. We're definitely seeing that in our attrition.
9 MR. DORMAN: Yes.
10 COMMISSIONER CAPUTO: So the hiring that's being done I 11 think is necessary. And I share your sense of urgency there. But I do have a 12 note of caution.
13 Because at some point the mission direct work that we're 14 looking at is such a small portion of our budget, and a small portion of our FTE.
15 And if that is where we don't have people adequate to meet that workload, then 16 I struggle with the nature of the other 79 percent of the budget and the number 17 of people that are doing mission indirect.
18 Who is in that mission indirect mess of people who could be 19 helping here with the mission direct work that needs to get done and needs to 20 not slip?
21 MR. DORMAN: Yes. We can certainly take that back and --
22 COMMISSIONER CAPUTO: I hear you that we're --
23 MR. DORMAN: -- get you some additional insight --
24 COMMISSIONER CAPUTO: -- focusing on priorities --
25 MR. DORMAN: -- on that.
44 1 COMMISSIONER CAPUTO: -- but when I hear licensing 2 work like this in a critical area is going to slip, that's a sign to me that we're not 3 focused on priorities.
4 MR. DORMAN: So I think what I heard here from our 5 responses is a number of key projects that are moving ahead on schedule. I 6 think we see similar things in some of the applications that we actually have 7 before us in the new reactor arena. But we'll continue to focus on that and 8 make sure we're supporting those activities.
9 COMMISSIONER CAPUTO: All right.
10 MR. DORMAN: Thank you.
11 COMMISSIONER CAPUTO: Thank you.
12 CHAIR HANSON: Thank you. Commissioner Crowell.
13 COMMISSIONER CROWELL: Thank you, Mr. Chair.
14 Hopefully, that's stops. I have a squeaky chair and a bad microphone today.
15 Okay, we'll see.
16 So, I have more questions than I'm going to be able to get 17 through for the panel, so I may follow up with folks afterwards. And I'll just warn 18 Carrie and Becca that I'm probably coming to you guys first with questions. But 19 before that, I going to not ask a question to John and Dan, and just make a 20 comment.
21 The morale and culture and workforce issues, John, that 22 you've answered questions about already, I just want to say thanks for your 23 commitment to that and dedication to trying to get it right.
24 In terms of a strategic workforce plan, my personal feeling is 25 that the most important precursor to a successful hiring or retention policy is
45 1 having a culture and morale that is of the highest quality; that it's a place where 2 people want to be.
3 And so, we heard this at the hearing yesterday, and I think 4 that's the most important thing we need to solve, to the extent it needs solving, 5 and where it needs solving within the Agency, because our hiring efforts are not 6 going to be successful unless we solve that riddle first. So, I appreciate your 7 efforts in that regard.
8 All right, let's talk about spent fuel and waste. Well, actually, 9 recycling first, Carrie.
10 You mentioned that there's been interest in recent months in 11 reprocessing. Can you elaborate on that?
12 MS. SAFFORD: Sure. There have been some discussions in 13 the past, I don't know, maybe four to six months, with a potential applicant who 14 wants to come in for preapplication discussions on submitting an application for 15 a reprocessing facility.
16 COMMISSIONER CROWELL: And you're not going to want 17 to answer this, but what's your gut on whether we need to revisit a rulemaking 18 in this regard, or whether we continue to do it under our current guidelines?
19 MS. SAFFORD: So, my gut is, based on everything that I 20 know and all the information I have available to me, is that we don't need a 21 rulemaking at this time; Part 50 can handle it. It's going to be specific to the 22 technology that comes in in the application. So, we can handle any deviations 23 or Commission orders and exemptions.
24 COMMISSIONER CROWELL: Okay, thank you. And then, 25 switching gears, how have you or your staff been engaged with the Canadian
46 1 nuclear waste management organization on the siting of a high-level repository 2 in Canada?
3 MS. SAFFORD: I'm going to pass that to you.
4 MR. LUBINSKI: Thank you. So, our second panel is more on 5 the waste side. So, we're on the front end of the fuel cycle.
6 But I can say that I've personally met with folks up in Canada.
7 Shana Helton, who is the director of Division of Fuel Management and has met 8 with folks to understand where they are on siting.
9 We had a really good meeting about where they are in looking 10 at a consent-based siting-type activity.
11 We believe most of the technical issues they're dealing with 12 are the same type of technical issues we had with respect to a deep geological 13 repository here in the United States.
14 The issues are some of the same issues that I'm going to say 15 are in the Department of Energy's roles and responsibilities in site selection, 16 from the standpoint of consent-based licensing.
17 I believe they're down to two sites at this point that they're 18 looking at, and they still haven't made their decision yet on where they are in 19 moving forward with those sites.
20 But really, it's on the consent-based licensing, and I think the 21 technical issues are very similar to ours and are not insurmountable.
22 COMMISSIONER CROWELL: I know were in second panel 23 territory here, but one of those two sites along Lake Huron obviously got some 24 attention at the hearing yesterday, and there's interest from elected officials on 25 that and something we need to take into account.
47 1 You don't need to address it necessarily, but would you say 2 that we're more engaged with our Canadian counterparts on their 3 consent-based siting efforts than we are with DOE and their efforts?
4 MR. LUBINSKI: No. We continue to work with DOE to 5 understand -- again, it's their role and responsibility in determining 6 consent-based process.
7 We have not looked at, in working with Canada or DOE, in 8 trying to get into the definitions of what's consent-based and where they go. It's 9 up to them to make the decision on where the siting goes.
10 We are coordinating with them to understand schedules, 11 processes they're in, so that we can understand where it comes to have our 12 interactions with DOE.
13 Because, again, we do have to with DOE to make sure we 14 could be in a regulatory role. I'm going to say, from the standpoint of Yucca 15 Mountain, it was very clear that we had a regulatory role. We continue to have 16 a role.
17 It's unclear in the future where we'll be, depending on where 18 DOE comes out. So, we do need to make sure we understand, depending on 19 what Congress does, whether we have a regulatory role there.
20 Again, with Canada, most of our conversations are on the 21 technical side. But from a scheduling standpoint, understanding where they are 22 in consent-based licensing is important.
23 With respect to the Great Lakes area, I will respond that we've 24 continued to have communications with in the area of the Great Lakes. It looks 25 like that at this point the siting their looking there for is not going to be high-level
48 1 waste, it's going to be low- to intermediate-level waste, which is a little different.
2 We are continuing to share, again, our technical expertise 3 with them. As the Chair responded yesterday at the hearing, is we do want to 4 continue to share our expertise with them as well.
5 Regarding policy decisions, policy decisions are within the 6 country's decision.
7 COMMISSIONER CROWELL: Thanks. Carrie, on the course 8 that Commission Wright asked you about, is it pass/fail?
9 MS. SAFFORD: There is a test at the end, but you don't have 10 to take it.
11 COMMISSIONER CROWELL: Okay, noted. More 12 importantly, for the course aimed at external stakeholders, what is the appetite 13 or interest in that course at this point, and how are you doing outreach, and is 14 there more effort needed to get people interest in doing it?
15 I'm particularly thinking about state, local, and tribal-type 16 entities.
17 MS. SAFFORD: Yeah. Yeah, we're right at the outset of that, 18 and that was a little bit of a late-breaking confirmation with my colleagues, that I 19 knew we were going to open the course up to federal agencies. For example, 20 Department of Energy.
21 That have some other staff that it might be beneficial for them 22 to come over and take the course. And the question was asked, well, what 23 about states and tribes? And we said, of course, there's no reason they 24 couldn't come.
25 So, I think that's a great idea, and we are going to be making
49 1 sure we're advertising it, engaging with them so that they're aware of it.
2 So, the second course isn't geared towards external 3 stakeholders. It's just going to be a replay of May's course. And then we can 4 open it up. May is sort of the test run, for example.
5 COMMISSIONER CROWELL: As a former state regulator, I 6 can tell you that it would be incredibly valuable to state folks to participate in 7 that course.
8 Oftentimes, even the more sophisticated states only have a 9 couple of people who really know this stuff well.
10 So, if you want to talk about how to expand outreach and get 11 people interested, just let me know. I'm happy to help in that regard.
12 MS. SAFFORD: Thank you.
13 COMMISSIONER CROWELL: Becca, so you're overseeing a 14 topic that's of great interest to me and I didn't really fully appreciate until 15 recently, in preparation for this Commission hearing.
16 But the issue of aging in spent fuel, and special nuclear 17 materials security, has your staff assessed when and where existing aged 18 spent fuel will become a security concern?
19 MS. RICHARDSON: Thank you for the question. So, I'm 20 going to be careful what I say here in an open forum, but if you want to talk 21 more about it after, we can.
22 There have been studies that have been completed, where 23 there's estimates on fuel that may no longer be self-protecting.
24 Some of those studies, we think we would need to do 25 additional analysis, just based on the way the methodologies that were used
50 1 and whatnot.
2 But we are working with our partners and our interagency 3 folks to understand studies that have happened in the past, and kind of try to 4 understand where we're at now on the issue.
5 Obviously, this issue just gets worse over time. So, trying to 6 understand where we are today is important in figuring out how to move forward 7 on the security.
8 But one thing that we look at, the threat we look at, the 9 vulnerabilities, the consequences and the mitigation.
10 And when you look at spent fuel, the packages that the spent 11 fuel is in is part of the consideration. Is it all of the spent fuel? Is it only 12 portions of it? Are all considerations on the risk for that for somebody to do 13 something with that fuel?
14 So, we are actively looking at it as part of the paper that we 15 will be putting up in October. One of the discussions.
16 COMMISSIONER CROWELL: Yes. It's a somewhat ironic or 17 different way of thinking about, over time, as the health risk diminishes, the 18 security risk increases.
19 MS. RICHARDSON: Yes.
20 COMMISSIONER CROWELL: And that's a different dynamic 21 than we're used to in most cases.
22 On the enhanced security requirements that you're evaluating 23 and looking at, how do those compare to, say, DOE's requirements and 24 protocols for special nuclear material?
25 MS. RICHARDSON: Yeah, so it is different. We're both
51 1 looking at material attractiveness.
2 When we look at material attractiveness, we've tried to make 3 it simple, and we're looking at just the dilution factor is what we're proposing.
4 So, it simplifies it a little bit, looking at non-dilute, moderately 5 dilute, or highly dilute. DOE has, I think, four or five different ranges. So, we're 6 looking in a more simple form.
7 But we do work closely with them to understand how they do 8 it and how the material is protected, understanding there's differences in the 9 material that we're looking at protecting, versus what they protect.
10 COMMISSIONER CROWELL: Thanks. And if I may, with no 11 more time left here, but really quickly, just to - Yawar. For the Paducah laser 12 enrichment process, would DOE continue to own the uranium tails?
13 MR. FARAZ: That's a good question, Commissioner. I don't 14 know the answer to that, but I can get back to you on it.
15 COMMISSIONER CROWELL: Great, thank you. Thank you, 16 Mr. Chair.
17 CHAIR HANSON: Thanks, Commissioner Crowell. I think 18 Carrie and Yawar, I'd like to start with you guys this morning, and kind of dive in 19 a little bit on the TRISO-X facility review.
20 Can you discuss some of the outreach with X-Energy, in 21 terms of kind of pre-application engagements on TRISO-X, and how are we 22 incorporating lessons from those pre-application engagements?
23 MS. SAFFORD: Okay, sure. I can kick it off. And, Yawar, if I 24 leave anything out, fill in for me.
25 MR. FARAZ: Mm-hmm.
52 1 MS. SAFFORD: We've done a lot of outreach with them, I 2 think just from the get-go, pre-application meetings, trying to understand what 3 the scope of the project was going to be, timelines, what their plans were for the 4 application -- timing, as you know, with the TRISO application that came in, in 5 sort of a bifurcated manner.
6 CHAIR HANSON: You mean in terms of the safety and the 7 environmental side?
8 MS. SAFFORD: Yeah, yeah. So, the environmental came in 9 first on TRISO, and the safety piece came in after that. In November, we did 10 issue an acceptance of the complete application. Right? So, that kicks off the 11 timeline moving forward.
12 I think what we've said here, and what I know I've said 13 repeatedly and a lot of our stakeholders here repeatedly, is that these 14 pre-application meetings are really important, to the extent there's any novel 15 approaches, or maybe, not necessarily disagreement, but a difference of 16 opinion, on certain aspects of the application and the technology, and what 17 needs to be included, and timing of things.
18 So, those issues are really important to hammer out early on.
19 It not just helps get a good application in the door, it sets expectations, it helps 20 us in budget space, it helps us with staffing, and all of those lessons learned 21 can be applied for future applications with other applicants and other facilities.
22 CHAIR HANSON: Okay. The environment report was 23 submitted just about a year ago now, right?
24 MS. SAFFORD: Exactly.
25 CHAIR HANSON: So, how close are we then to completing
53 1 the review of the environmental report? Or is that something where it has to get 2 kind of synched up with the safety review at some point, or can those be 3 separate?
4 MR. LUBINSKI: Yeah. Actually, it was, in this case with 5 TRISO-X, it was the safety report that came in first.
6 CHAIR HANSON: Oh, I'm sorry. Right, because it was the --
7 (Simultaneous speaking.)
8 MR. LUBINSKI: And then we had a current one that came in 9 for GNFA, where we've received the environmental and it was flipped.
10 CHAIR HANSON: I see. Thanks, John. That's for that 11 clarification.
12 MS. SAFFORD: My apologies in that. Sorry.
13 MR. LUBINSKI: So, we were just completing the acceptance 14 review of both at the same time. But that was just this fall.
15 MS. SAFFORD: And to answer your other question, they 16 don't have to be, over time, synched up, necessarily. And there's no 17 requirement for that. The environmental process typically takes longer, with the 18 public engagement and the outreach.
19 CHAIR HANSON: Ah. Okay, thank you. I guess, you know, I 20 think we heard last fall about the time for the acceptance review on the 21 TRISO-X facility, and the sense, I guess, at least on X-Energy's part that that 22 maybe took longer than they had anticipated.
23 Did that schedule incorporate these pre-application 24 engagements? And, if so, how? And I think part of the discussion that 25 happened around that time -- John, it may have been with you -- was, well,
54 1 yeah, the acceptance review took longer, but we're going to kind of see the 2 benefit on that in the overall review.
3 And so, I guess part of my question is, in terms of that 4 acceptance review, how did that benefit from the pre-application engagements?
5 And then, does that 32-month schedule actually incorporate what I understood 6 to be some of the advance work that was maybe done as part of the 7 acceptance review?
8 MR. LUBINSKI: Yeah, thanks for the question. I'll go back a 9 little in history before --
10 CHAIR HANSON: Yeah, please.
11 MR. LUBINSKI: -- on why some of the bifurcation happened 12 as well between the safety and environmental.
13 CHAIR HANSON: Okay.
14 MR. LUBINSKI: We had been working with TRISO for 15 pre-application meetings before the safety part of their application came in.
16 We felt we were dealing with many of the technical issues 17 associated with that. The reason that they had a delay was they changed sites 18 where they were going to actually build the facility.
19 So, that changed our environmental review. But they wanted 20 to get the safety review in-house, and they did that. And they came in last April 21 time frame, Yawar, if I'm remembering correctly. So, it was last April when they 22 came in.
23 From a technical standpoint, we think they hit all the technical 24 marks that they started along the way.
25 Where the confusion came during part of that review was the
55 1 level of detail needed in an application, because they still weren't completing 2 their design process yet.
3 As part of the review, they needed to do an ISA, an integrated 4 safety analysis. They needed to identify all of their items relied on for safety --
5 IROFS.
6 And they had a misunderstanding -- maybe a disagreement --
7 with us that the level of detail that was needed to be provided in the application, 8 vice what was needed to be provided later when we were going through the 9 process.
10 So, once we reached that, not only do I think we're in a better 11 place with them, we're also in a better place with the industry, from a lessons 12 learned of, for brand new applications, how much detail is needed in an 13 application, with respect to an ISA, as well as the IROFS.
14 It also identified, as Yawar said, one of the areas for electrical 15 and instrumentation and control, where that was an area that we felt we needed 16 a little more detail on the review than they had on the front end, and they've 17 agreed to provide that by next August.
18 So, to say we're taking advantage of it. I think we did have a 19 bit of an advantage on the major technical issues.
20 The ISA and the level of clarity in the application I think is 21 something that we learned after we received the application, and it's going to 22 benefit others.
23 But I think our review of the technical issues as we go 24 forward, is going to benefit from those pre-application reviews we had 25 beforehand.
56 1 It'll be a real question to raise next August, when we get the 2 electrical and the I&C part, of whether or not that continues to be the case.
3 CHAIR HANSON: I see. Yeah, thanks, John. That's very 4 helpful.
5 From our side of the house, I've been really interested in the 6 lessons-learned, our own lessons-learned assessment from the NuScale 7 review. Right?
8 And there were a couple of things really about the 9 management of these reviews that I think seems portable or applicable to kind 10 of other ways of doing this. Right?
11 One was about having a core team. So, you've got that core 12 group of people. Another one is that integrated review of the application up 13 front. Another one is kind of management vetting of RAIs.
14 So, I guess my question is, how are we taking some of those 15 lessons learned from the reactor side of the house in terms of the management 16 of those reviews, the focus on the most safety-significant aspects, and applying 17 them to fuel facilities going forward?
18 MR. LUBINSKI: I'm going to start, and then ask Yawar, who's 19 leading this a bit, but I wanted to get the compare-and-contrast to the other side 20 of the house as well.
21 So, from a NRR perspective, most of the organization is very 22 matrixed, from a project management standpoint, on the technical side.
23 Doing teams like that really is a benefit as you continue to 24 move forward.
25 We do have a benefit that we're in one division. So, it's not
57 1 just even one office. One division has all of the technical people, as well as the 2 project management people, that have worked on, not just these applications 3 together, but other applications together. So, we already have a little bit of that 4 team approach.
5 The other part is, we have benefitted from having a 6 reorganization we did of NMSS back in 2019, where we combined the two 7 divisions together, of the fuel facilities, as well as the spent fuel storage and 8 transportation, where we have the ability to reach across to the other business 9 line and bring people in as needed.
10 If we need structural engineers from that side of the house, 11 we can bring them in on specific reviews.
12 But Yawar can talk a little more how that we see any benefits 13 the way we put the team together now on some of those reviews.
14 MR. FARAZ: That's a very good question, Chairman. So, I 15 can give you an example of how we're using the NuScale experience, I cant 16 say for Niowave, because I'm not directly involved in that.
17 CHAIR HANSON: Mm-hmm.
18 MR. FARAZ: So, we've looked at how we did the 19 pre-application engagement with NuScale, and we're trying to apply that same 20 model to Niowave. We've got a review team already set up.
21 We've had multiple engagements with Niowave. We plan to 22 have site visits of the technical reviewers to the site to look at the equipment, 23 and maybe even to Argonne, because Argonne is helping Niowave in that 24 regard.
25 So, clearly, it's not at the same level as NuScale, because I
58 1 think Niowave is a fuel that's going to be under Part 70. It's a simpler facility.
2 But clearly, we're using the NuScale model to apply in this 3 case. And as far as TRISO-X is concerned, our pre-application engagement 4 was a fairly long engagement, and one of the reasons was, is that they 5 changed sites. So, it was like almost two years of pre-application engagement.
6 So, there was sufficient time for us to visit the site and engage 7 with them. So, that helped.
8 CHAIR HANSON: Okay. Yeah, thank you. In terms of the 9 32-month schedule, at the end of that they get -- I think of it as a combined 10 operating license. I know that's not really what it is, but they're good to go.
11 There isn't any additional hurdle at the end of that, right?
12 MR. FARAZ: So, the licensing aspect ends whenever we 13 complete that review.
14 However, following that, we have these operational readiness 15 reviews, or inspections, to ensure that the facility is built as described in the 16 application, and the programs are as described in the application.
17 So, then it goes over several months. And then after that, the 18 region would issue, if everything is okay, then they would issue the go-ahead to 19 accept, receive material.
20 CHAIR HANSON: Okay, thank you. Just real quickly, that 21 32-month schedule, I mean, is that fully staffed? Is that fully resourced? Is that 22 sensitive to additional resources, or additional shifting of staff?
23 MR. LUBINSKI: Right now, as Carrie responded earlier, we 24 do have right now that 32-month schedule assumes the other applications that 25 we have coming in. So, we have looked at that from the standpoint of what the
59 1 other impacts are.
2 It also has made some assumptions about our continued 3 workforce and our continued hiring, as we continue to move forward.
4 To say fully staffed, are there 100 percent full-time people of a 5 team working on it? No. But have we accounted for all the other work?
6 Again, as we continue to move forward, if other priorities were 7 to come, we would look at those. But we have kept at the top of our list of 8 prioritization, inspection is number one, inspection overall.
9 And I really have to give compliments to Region II in this area, 10 who has all the fuel facilities to make sure that we're keeping up and make sure 11 we have qualified inspectors out and completing our inspection programs. So, 12 thank you for that.
13 We're also making sure we're cross-training our folks to help 14 in that area. We also are making sure that any licensing actions that are 15 supporting continued operations are high on the list. And we continue to have 16 full funding of those.
17 Then, we're looking at applications that are supporting other 18 areas, such as, like, a TRISO-X is an example. It's going to support advanced 19 reactors as we continue to move forward. So, we've kept that at a high priority.
20 So, I really have difficulty envisioning anything that would 21 change a prioritization that would delay us by not having staff to do this work.
22 We would definitely be looking at much lower things, like 23 additional infrastructure work that we're doing on guidance documents and 24 preparing for that. And doing delays in those types of activities instead.
25 CHAIR HANSON: Okay, great, thank you. Thank you very
60 1 much. That's very helpful. Thank you for the first panel. We'll take a 2 ten-minute break, and let's say we'll reconvene here at 10:40. Thank you all.
3 (Whereupon, the above-entitled matter went off the record at 4 10:30 a.m. and resumed at 10:38 a.m.)
5 CHAIR HANSON: All right, we're back for the second half of 6 our meeting this morning. We're going to be talking about the spent fuel and 7 transportation business lines. Dan, I'll hand it over to you.
8 MR. DORMAN: Thank you, Chair, and good morning, once 9 again, Chair Hanson and Commissioners.
10 As you said, our second panel is featuring our Spent Fuel 11 Storage and Transportation business line.
12 This business line continues to make strides with 13 risk-informing our regulatory approaches. And in addition, we continue to 14 maintain an appropriate focus on our mission for the safe and secure 15 management of spent nuclear fuel, while also maintaining effective external 16 communication, transparency and stakeholder engagement, as we prepare for 17 the use of new technologies.
18 I'd like to note that this past February, two months ago, the 19 NRC's Office of the Inspector General issued a special inquiry report on the 20 inspection of independent spent fuel storage installations, or ISFSIs, at 21 operating reactors in NRC's Region II.
22 In 2019, the staff had initiated an effort to evaluate and 23 enhance the NRC's existing ISFSI inspection program, by developing a clear, 24 more risk-informed, comprehensive and consistent approach to ISFSI 25 inspections across the four regions, focusing on those areas most important to
61 1 safety.
2 This resulted in an enhanced ISFSI inspection program that 3 was implemented in January of 2021.
4 The staff has looked at the recent OIG report and has not 5 identified a concern or safety issue that would require the NRC to take 6 immediate actions on prior inspections conducted.
7 Based upon a detailed review of actual inspections 8 performed, the NRC has reasonable assurance of the long-term safe storage of 9 spent fuel at ISFSIs.
10 The staff is evaluating the findings from the OIG's report and 11 plans to respond next month, and I'm confident that the IG's findings associated 12 with the inspection program implementation have been addressed through the 13 enhanced ISFSI inspection program that was implemented in January of 2021.
14 Next slide, please.
15 On this panel, John Lubinski, director of the Office of Nuclear 16 Material Safety and Safeguards, or NMSS, will provide you with strategic insight 17 supporting the Spent Fuel Storage and Transportation business line.
18 Jake Zimmerman, Deputy Director for the Division of Fuel 19 Management in NMSS, will discuss the Spent Fuel Storage and Transportation 20 Program environment, how we are leveraging risk insights in licensing reviews, 21 and share an overview of the evaluation and effectiveness of the oversight 22 program.
23 Norma Garcia Santos, a project manager in the Storage and 24 Transportation Licensing Branch in the Division of Fuel Management, will give 25 an update on the Spent Fuel Storage and Transportation Licensing Program, its
62 1 significant accomplishments and licensing activities, and an overview of the 2 new Fuels Atlas application for the back-end of the fuel cycle.
3 Mark Henrion, a senior health physicist in the 4 Decommissioning ISFSI and Reactor HP Branch in the Division of Radiological 5 Safety and Security in Region I, will share insights on how we are maintaining 6 inspector bench strength, maintaining openness, and engaging with 7 stakeholders, and the recent success in applying the very low safety- significant 8 issue resolution, or VLSSIR, process.
9 Finally, John McKirgan, Deputy Director for the Division of 10 Engineering in the Office of Nuclear Regulatory Research, will provide an 11 update on spent fuel research activities, and our engagement with external 12 stakeholders on new and advanced fuels.
13 This concludes my opening remarks, and I'll now turn the 14 presentation over to John Lubinski.
15 MR. LUBINSKI: Thanks, Dan. And good morning again, 16 Chair and Commissioners.
17 It's my pleasure to be here today to discuss the great work 18 and people contributing to the Spent Fuel Storage and Transportation business 19 line.
20 Our coordination and partnership with the regions and other 21 headquarters offices is demonstrated by the participation on our panel today.
22 The business line ensures the safety and security mission of 23 transportation of radioactive materials, and the storage of spent fuel, including 24 fuel for current and new reactor designs.
25 The business line is responsible for licensing and inspection
63 1 of approximately 100 transportation package designs, and fifteen spent fuel 2 storage system designs.
3 As of today, the business line has licensed, and continues to 4 provide oversight, to more than 3,900 dry casks across the nation.
5 The business line is focused on ensuring an effective 6 framework for transportation of fresh and used nuclear fuels, including current 7 fuel designs, accident-tolerant fuels (ATF), and advanced reactor fuels.
8 The business line has successfully reviewed and approved 9 seven transportation package designs to support use of ATF and advanced 10 reactors.
11 It is also focused on understanding and addressing any 12 differences with the eventual safe storage of those reactor fuels. Next slide, 13 please.
14 During the previous panel, I introduced our focus areas, which 15 were people, trust and workload, and that applies to this business line as well.
16 While these areas need more attention, the business line is 17 continuing to meet safety and security mission by continually assessing and 18 prioritizing our licensing and inspection activities, to ensure they are 19 safety-focused, and support timely regulatory decisions commensurate with 20 industry operational needs.
21 Regarding people, we are recruiting, developing, and 22 retaining, a highly skilled and engaged workforce. We continue to promote an 23 organizational culture that focuses on knowledge management and staff 24 training, and qualifications, and embraces cross-training programs and career 25 development.
64 1 We are also ensuring strong knowledge management through 2 our internal business line dashboards and use of Nuclepedia.
3 Regarding trust, we are enhancing public outreach and 4 inspiring stakeholder confidence though openness and transparency with our 5 regulatory decisions.
6 A particular success in this area occurred just this past 7 December. We held a public meeting with the industry, representatives of the 8 Nuclear Energy Institute, and members of the public, to discuss current fuel 9 facility activities, and we jointly addressed prioritization of work areas in the 10 business line.
11 This proved to be a vital and meaningful exchange between 12 staff and industry, and demonstrates our continued efforts to increase 13 stakeholder confidence, and make more informed regulatory decisions.
14 Regarding workload, we are leveraging technology to inform 15 data-driven decision-making. The business line continues to expand its use of 16 web-based licensing, to track work and plans for licensing activities.
17 This concludes my remarks, and I'll now turn to Jake 18 Zimmerman.
19 MR. ZIMMERMAN: Thank you, John. Good morning, Chair 20 Hanson and Commissioners.
21 It's a pleasure to be here today to brief you on the 22 programmatic aspects of the current and future environment for the storage and 23 transportation business line. Next slide, please.
24 As has been said, the business line ensures the safe and 25 secure storage and transportation of spent fuel and radioactive material
65 1 transportation.
2 The budget for this business line in fiscal year 2023 is 3 approximately $27 million. Of that, 75 percent of it is on licensing and oversight 4 activities.
5 The budget reflects an emphasis on our safety-focused, 6 cost-efficient and timely regulatory reviews and inspections.
7 The major workload drivers include reviews of transportation 8 packages and dry storage cask designs, ISFSI licensing, and oversight to 9 support the safe transport of NRC-regulated radioactive material, and then the 10 transfer and storage of spent fuel to storage at reactor sites, and then also 11 standalone ISFSIs.
12 We also began activities in support of Project Pele, a project 13 of the U.S. Department of Defense to deploy a prototype mobile nuclear 14 reactor.
15 We proactively plan and prioritize and adjust our activities and 16 our resources to effectively manage our workload.
17 We frequently use the add/shed/defer process. This process 18 is used to balance existing planned or emergent higher priority work, or just 19 resources to accomplish the work.
20 For our people, we are focused on attracting, developing and 21 maintaining a high-performing, diverse, engaged and flexible workforce, with 22 the skills needed to carry out our mission now and into the future.
23 Over the past two years, the business line has had a strong 24 focus on managing its resources.
25 During this time, the Division of Fuel Management -- and as
66 1 indicated in the previous panel, is responsible for both business lines, so that's 2 why I'm speaking about it that way -- has lost 21 staff members due to 3 retirement or taking other positions, either internal, or external to the NRC.
4 Being understaffed brings new challenges on how we 5 manage our workload, as we need to allow time for new staff to be fully 6 qualified, and experienced staff to train them.
7 Notwithstanding, progress has been made by onboarding new 8 staff and hosting several NRAN participants, which I'm personally very excited 9 about. I'm a Class of 1993 reactor engineer intern.
10 We have increased our hiring in headquarters and the regions 11 in the last year, to support our inspection and oversight programs. Many 12 regional inspectors are cross-qualified and support various business lines, to 13 help with the scheduling challenges.
14 In addition, our headquarters staff supports the regions as 15 needed with those activities.
16 For outreach, over the last year we've received several 17 inquiries from stakeholders that serve to better understand their concerns 18 associated with our business line.
19 We've participated in various technical and regulatory 20 knowledge exchanges with the International Atomic Energy Agency, the 21 Nuclear Energy Agency, and our regulatory counterparts, which were discussed 22 in the earlier panel of the Canadian Nuclear Safety Commission.
23 Our participation in the Transport Safety Standard Committee, 24 and other transport activities, have also helped to raise awareness and promote 25 coordinated approaches related to transportable nuclear reactors.
67 1 These forums serve for keeping awareness on progress in 2 international programs, identifying cooperation activities and mutual interest, 3 and building connections between organizations.
4 We continue encouraging early engagement with our 5 applicants and licensees, and most notably, pre-application meetings seems to 6 be a continuing theme, and I think we've been successful.
7 In other formal or informal communications, they serve to 8 identify possible cross-cutting issues that impact our overall schedules, if not 9 timely addressed. The next slide, please.
10 We apply risk insights, lessons learned, and a variety of 11 regulatory tools, to perform reviews more consistently and efficiently, resulting 12 in early identification of cross-cutting issues, improve review schedules, and 13 resource predictability.
14 Last year, we provided the Commission a high-level overview 15 of our efforts of developing a risk tool.
16 The staff used this tool to focus the acceptance reviews of dry 17 cask storage systems applications. The tool includes risk insights, based on 18 extensive knowledge collected over several decades of certifying these 19 systems.
20 Based on the pilot, the staff found that the tool and the job aid 21 enhanced staff's awareness regarding risk significance of each component.
22 The staff also found that the technical basis needed to be 23 strengthened to facilitate the use of the tool, and better support knowledge 24 management for risk-informing dry cask storage reviews.
25 This year, we plan to extend implementation of the tool to
68 1 acceptance reviews on amendments received from May through October of this 2 year.
3 We plan to periodically evaluate the tool to determine whether 4 its use enhances staff's practices that support risk-informed review 5 prioritization, and decide if further revisions are necessary, as more insights are 6 gained. Next slide, please.
7 We meet our safety and security mission through 8 implementation of the inspection program for spent fuel storage and 9 transportation.
10 We are in the process of completing a self-assessment of the 11 enhanced ISFSI inspection program that, as Dan indicated, was implemented in 12 January of 2021. So, we're two years through our triennial cycle.
13 The interim findings, so far, have confirmed that 14 enhancements made to the program were effective in appropriately focusing on 15 the most risk-significant activities, and are being implemented consistently 16 across the four regions.
17 Revisions in inspection procedures and priorities described in 18 associated manual chapters, facilitates focusing on higher-risk activities, and 19 should benefit newer inspectors.
20 This year, the staff also completed an annual operating 21 experience assessment to inform future inspections and licensing reviews that 22 informed our annual Agency Action Review Meeting paper to the Commission.
23 This assessment validated the staff's actions to address the 24 issue of licensees applying administrative controls during short duration outdoor 25 cask storage operations.
69 1 There were no identifiable trends that warrant a change in the 2 oversight and inspection program.
3 Another area where the staff continues to focus is aging 4 management of dry cask storage. More ISFSIs are reaching the period of 5 extended operations.
6 The staff developed a new aging management inspection 7 procedure. This was informed by lessons learned from a temporary instruction 8 that assessed licensees' activities for managing age-related degradation.
9 The lessons learned provided the staff with operating 10 experience to assess and adjust some of the acceptance criteria for important 11 safety systems, structures, and components, due to credible aging mechanisms 12 and effects during the period of extended operation.
13 The procedure is the final piece to an operation focused to 14 manage the potential age-related degradation for dry cask storage systems.
15 We plan to issue the new inspection procedure this summer.
16 This concludes my part of the presentation. I'll now turn it 17 over to Norma Santos Garcia.
18 MS. GARCIA SANTOS: Thanks, Jake. Good morning, Chair 19 Hanson, Commissioners.
20 I appreciate this opportunity to provide an update on activities, 21 accomplishments, and the New Fuel Atlas, as this relates to the Spent Fuel 22 Storage and Transportation business line.
23 I started my career in NRC as a chemical safety reviewer for 24 fuel facilities, and I'm currently a Storage and Transportation project manager.
25 Next slide.
70 1 The pictures shown in this slide represent some of the many 2 people across the agency that support the licensing business line. Next slide, 3 please.
4 The business line continues to receive and process a large 5 number of licensing actions. In fiscal year '22, we completed 63 reviews.
6 During this period, the staff deferred some lower priority 7 licensing actions, including reviews of some decommissioning funding plans, or 8 DFPs, for independent spent fuel storage installations, or ISFSIs.
9 These were necessary to support higher-priority actions, such 10 as the HI-STORE Consolidated Interim Storage Facility, or CISF, application.
11 So far this fiscal year, we have completed 64 licensing 12 reviews within the established licensing matrix.
13 This is the largest completion rate this year, since we have 14 completed some of the deferred work in fiscal year '22, as well as incoming 15 work.
16 Examples of significant licensing reviews include issuing a 17 package amendment authorizing transfer of accident-tolerant fuel assemblies, 18 with up to seven percent enriched uranium.
19 We also issued subsequent renewal of the GE-Morris waste 20 storage independent spent fuel storage installation license for an additional 21 20-year term, for a total of 60 years of license period. The renewal also 22 incorporated aging management programs. Next slide, please.
23 This pie chart depicts the inventory of all ongoing licensing 24 actions in our business line. We currently have 49 licensing and certifications 25 actions, which approximately 28 are scheduled to be finalized this year.
71 1 Ongoing actions include the HI-STORE CISF application, and 2 three applications related to advanced reactor fuel assemblies, up to eight 3 percent enriched uranium, or TRISO fuel.
4 Another activity includes the review of the first topical report in 5 the shielding area, which, if approved, will streamline the process of approving 6 future amendments to certificate of compliance for storage system designs.
7 The projection of our workload includes an increase in 8 Department of Transportation review requests of foreign approved package 9 designs or re-validations, packaging applications to support advanced fuels, or 10 ATF, and dry cask storage amendments to support decommissioning facilities.
11 If we complete the ongoing work scheduled to be closed in 12 fiscal year '23, the trend of our workload is increasing. Next slide, please.
13 The licensing program ensures safety by leveraging our 14 risk-informed performance regulatory framework, and engaging with applicants, 15 licensees, and vendors, early in the licensing and certification process.
16 We have routine engagements with major vendors and other 17 federal agencies, to discuss expectations, future work, and status of current 18 licensing reviews, as well as encourage using pre-application meetings for 19 review of new or complex designs. For example, in the review of the packaging 20 design to transport high-assay, low-enriched uranium, or HALEU, the staff 21 conducted multiple pre-application meetings and used Tiger teams. This 22 approach made the review more efficient and resulted in only one round of 23 requests for additional information. It is relevant to know that the feedback 24 provided by the staff during pre-application meetings could result in a better 25 quality of applications.
72 1 In terms of risk-informing in calendar year '22, we received 2 two additional applications implementing a methodology similar to the graded 3 approach pilot, to increase clarity and use a certificate of compliance.
4 One application has been accepted for review, while the other 5 is in the acceptance review.
6 Lastly, regardless of the workload challenges, there have 7 been improvements in our data collection and analysis capabilities in the 8 Web-Based Licensing System.
9 The data gathering is used in reports and dashboards, 10 increasing our capability to manage and monitor licensing reviews, to better 11 inform us about the status of our licensing metrics. Next slide, please.
12 In the previous panel, Yawar introduced the New Fuel Atlas.
13 The atlas consists of communication tools that include the infographic and the 14 HALEU website.
15 The atlas also consists on the regulatory planner, as shown in 16 this slide. To create this planner, the staff is working to consolidate a large 17 amount of information related to the New Fuels into a central location, and then 18 accessing information technology needs to help develop useful user interface.
19 This data varies and will include information on different 20 anticipated advanced non-light water reactor fuels at different phases of the 21 nuclear fuel cycle, and programmatic areas, such as licensing, oversight and 22 research.
23 As you can see on this slide, the atlas is organized in a matrix 24 manner. This format will help us to better plan and adjust to new and 25 unexpected developments of advanced fuels activities, by providing the
73 1 capability to develop multiple roadmaps.
2 For example, as you can see in the orange rectangle, we 3 could use the planner to develop a roadmap of research across the molten salt 4 fuel cycle, or as you can see in the blue arrow, to identify oversight needs 5 associated with spent fuel transfer for different types of fuel.
6 The planner will help us to focus on the appropriate things at 7 the appropriate time.
8 This concludes my presentation. Now, I'll turn it over to Mark.
9 MR. HENRION: Thank you, Norma. Good morning, Chair, 10 Commissioners. I very much appreciate the opportunity to speak with you all 11 this morning. Next slide, please.
12 One of our main areas of focus is staffing. We are working 13 hard to get new ISFSI inspectors onboard and qualified.
14 Limited resources, balancing multiple business lines within 15 our branch, which includes operating reactor health physics inspections, which 16 are a part of the reactor oversight process, and constantly changing schedules 17 and ISFSI loading campaigns and dry runs, leads to challenges in inspection 18 coverage and resources.
19 Despite these challenges, the diligent work of our inspectors, 20 and support from the Division of Fuel Management, has allowed us to 21 effectively implement the ISFSI inspection program according to the guidance 22 in the NRC Inspection Manual 2690.
23 We are focused on hiring new staff and building our roster of 24 qualified ISFSI inspectors, by placing our new inspectors in the field earlier in 25 the training process, to gain experience and familiarity with the ISFSI program
74 1 objectives and inspections.
2 Currently, I am serving as ambassador and mentor to two 3 new inspectors whose first qualification with the NRC will be in the field of 4 ISFSI.
5 We are partnering with the program office to conduct robust 6 training, coupled with in-field experience, led by qualified senior inspectors.
7 The regions work closely with the program office by holding 8 monthly counterpart calls and annual counterpart meetings, to discuss how we 9 manage schedules and evaluate issues, how we face challenges, and 10 successes, to ensure consistency throughout the business line, and ensure that 11 our people are properly engaged and prepared. Next slide, please.
12 Our stakeholders in Region I, which encompasses the 13 Northeast United States, are very engaged and active in following our 14 inspection efforts.
15 This makes open and transparent communication with the 16 public especially important.
17 We try to alleviate concerns and apprehension by engaging 18 with the public via live presentations and webinars, in concert with our partners 19 in NMSS.
20 This is illustrated by a recent joint effort by headquarters and 21 Region I, where a webinar was held to engage with the public on aspects of 22 emergency preparedness and security requirements for reactor facilities 23 undergoing decommissioning.
24 Approximately 90 members of the public participated in this 25 meeting, and the staff answered a number of questions associated with spent
75 1 fuel storage, and risks associated with ISFSIs.
2 This was supplemented by an in-person public meeting held 3 approximately one week later, near Indian Point, where Region I and 4 headquarters staff presented information associated with spent fuel and the 5 process of loading ISFSI canisters.
6 Approximately 110 members of the public attended this 7 meeting, both virtually and in person, and the combined effort between 8 headquarters and regional inspectors resulted in open communication and 9 engagement with our local public.
10 One of our goals is to take the mystery out of spent fuel 11 storage by speaking in plain language when directly answering the public's 12 questions.
13 We believe that engagement with the public on ISFSI issues 14 allows the staff to provide more information and focus on concerns and 15 questions from external stakeholders. Next slide, please.
16 Members of the ISFSI inspection program regularly work 17 together to disposition complicated issues. In fall of 2021, Region I identified a 18 violation related to tornado missile hazards.
19 During counterpart calls with other regions and NMSS, it 20 quickly became apparent that similar issues were identified at other sites across 21 the nation.
22 Headquarters partnered with the regions to better understand 23 these issues and worked diligently to separate aspects that differed from plant 24 to plant.
25 This effort was reflected by great communications among all
76 1 the inspectors and the program office, where the staff was able to discern the 2 nuances of each issue, while avoiding the application of a one-size-fits-all 3 approach to each individual site.
4 This enabled the staff to glean relevant information and, with 5 assistance from the Office of Enforcement, carefully evaluate each unique 6 situation.
7 The staff applied the ISFSI program's first use of the very low 8 safety-significance issue resolution, or VLSSIR process to an ISFSI, as it was 9 warranted at a site and separately applied enforcement discretion at several 10 sites where the VLSSIR process was not deemed appropriate.
11 This concludes my presentation. I will turn it over to John 12 McKirgan. Thank you.
13 MR. McKIRGAN: Thank you, Mark. Good morning, Chair 14 and Commissioners. It's a pleasure to be here today on behalf of the Office of 15 Nuclear Regulatory Research, and I'll update you on the status of the activities 16 we've been conducting to support the business line.
17 In my talk today, I'll touch on two topics, the spent fuel 18 research activities and how we're engaging with external stakeholders on new 19 and advanced fuels.
20 Be Ready is our mantra in research and we want to do that by 21 providing the right data, tools, and training to prepare the agency for both the 22 current fuel challenges as well as new and advanced fuel issues to ensure the 23 continued safe and secure transport and storage of these materials. Next slide, 24 please.
25 So, in discussing data, I want to talk about how we in
77 1 Research support the program office. The staff takes a systematic approach as 2 it relates to data, such as identifying any new data needs or assessing new 3 data that becomes available.
4 We commonly use Phenomena Identification and Ranking 5 Tables or PIRTs, along with operating experience, and modeling and simulation 6 tools, as well as experiments to focus our research efforts on the most 7 significant safety issues for storage and transportation of spent nuclear fuels.
8 An example of this is our research activities in obtaining data 9 on how fuel cladding behaves in storage. It is crucial we understand key 10 phenomena such as fission gas release, hydride reorientation, and creep rates, 11 as these have been shown to be important.
12 The data to understand and confirm our existing knowledge of 13 these phenomena will better position the staff to review industry requests as 14 these fuels move into dry cask storage.
15 Research leverages its international and domestic partners.
16 For example, with creep rates, the staff, together with partners, are participating 17 in multilateral programs like the Studsvik Cladding Integrity Project or SCIP, to 18 obtain creep rate data on high burnup fuels.
19 This data will be used to validate our fuel performance code 20 FAST and enable decision making by the program office. Next slide, please.
21 Another item I want to touch on is building tools to better risk 22 inform the reviews. Here, the staff has developed a risk tool for storage reviews 23 that enables the technical reviewers to focus on the most risk and safety 24 significant items.
25 In developing the tool, the staff ranked the phenomena with
78 1 respect to which particular review items warrant greater attention based on their 2 significance and which items might not need as much attention.
3 Of particular interest here is with new reviewers. The risk tool 4 can enable them to come up and be more efficient in their reviews quickly.
5 Now, the tools that we've developed to date have really 6 focused on storage, but we're also thinking about transportation. The Office of 7 Research is supporting the business line in the review of a risk-informed 8 approach on the transportation of microreactors.
9 You've heard that the Department of Defense's Strategic 10 Capabilities Office is working on a transportable microreactor, Project PELE.
11 Pacific Northwest National Laboratory, in support of the DoD, is developing a 12 risk method tailored to the transportation of microreactors, and with the 13 expertise and skill sets available to us in the Office of Research, we're able to 14 provide support to that activity.
15 Staffing for risk and reliability analysts has been a challenge, 16 and so we're working very closely with the program office to make sure we're 17 applying these highly valued staff where they are most needed. Next slide, 18 please.
19 So, we talked about data and I talked about tools. Next, I'd 20 like to talk about training, which is an essential component to keeping our staff 21 ready.
22 One of the activities that we've completed recently is a series 23 of training modules in the area of computational fluid dynamics or CFD. This is 24 an important tool that's been used in the thermal analysis of spent fuel storage.
25
79 1 Increasingly, industry is looking to put hotter fuel into 2 canisters and that's required a close look at the heat transfer characteristics. It 3 is a complex set of phenomena and the tools require specialized training.
4 Our senior level advisor in this area has been working with 5 some of the senior staff in the program office to produce a series of training 6 modules. These modules were recorded and are available on the Nuclepedia 7 page.
8 These are available to both current staff that want to sharpen 9 their skills in CFD and also very importantly to new staff coming on board so we 10 can get them up to speed quickly.
11 These are just some of the data tools and training the Office 12 of Research has been developing to support the business line. I could go on, 13 but let me pivot and talk about some of our outreach activities. Next slide, 14 please.
15 So, the Research resources in the business line are modest, 16 but that's not an indication of their importance, and we want to make the most 17 of these resources by engaging with stakeholders. An example of this is the 18 High Burnup Demonstration Program at North Anna and the Sibling Rod 19 Project.
20 This is an effort sponsored by the Department of Energy and 21 the Electric Power Research Institute, or EPRI, looking at higher burnup fuels in 22 storage. With every project, we seek to leverage where we can and coordinate 23 our activities so we don't duplicate research.
24 In the North Anna demo project, there is an instrumented 25 cask containing high burnup fuel assemblies. This ongoing effort will yield a
80 1 tremendous amount of data. The outcome we're looking for is ensuring safe 2 storage of high burnup fuels as these materials move into dry cask storage.
3 In the thermal analysis area, the instrumented casks provided 4 valuable validation area. Further, as part of the program, a number of high 5 burnup rods were taken for extensive nondestructive and destructive testing.
6 The DOE and EPRI are putting up the vast majority of the 7 resources, on the order of $20 million all told, and the NRC is achieving a great 8 return on our modest investment. Through our memorandums of understanding 9 with DOE and EPRI, we were able to engage with these stakeholders and 10 express our interests and data needs to gain the maximum benefit from the 11 program.
12 Data from this program will provide additional validation data 13 to enhance the staff and industry's criticality codes. The additional data will 14 enable reduced uncertain in thermal and criticality analysis and enable 15 additional flexibility for the licensees in moving high burnup fuels to storage 16 while maintaining safety.
17 Another area I'd like to touch on involves our readiness for 18 advanced reactor fuels and their storage and transportation. The staff has 19 previously developed a series of reports to identify technical information needs 20 for advanced reactor fuels, and that work has helped guide our research and 21 positioned us to engage with stakeholders like the Advanced Research Projects 22 Agency for Energy or ARPA-E.
23 I believe the Commission heard from Jen Shafer at a prior 24 meeting and I'd like to follow up with that on a discussion with some further talk 25 on one of those programs, ONWARDS, which is Optimizing Nuclear Waste and
81 1 Advanced Reactor Disposal Systems.
2 So, through this program, ARPA-E is funding a number of 3 universities and industry entities to research some of the specific waste forms 4 that will be produced by advanced reactors, including molten salt and TRISO 5 fuels.
6 One of the programs is looking at identifying improved 7 processes that will be used to treat the spent fuel, as well as looking at different 8 storage and transportation considerations.
9 By observing these activities as they are proceeding, the NRC 10 staff have been able to get a very early look at the technologies and prepare for 11 any issues that may impact safety. In return, the staff were able to point to 12 current regulations and guidance that the staff would rely on to evaluate these 13 technologies.
14 Engagements such as these will enable the staff to be ready 15 for what lies ahead, and with that, I'll turn it back over to Dan for some final 16 words.
17 MR. DORMAN: Thank you, John. I want to express my 18 appreciation to all of the NRC headquarters and regional staff that continue to 19 make the spent fuel storage and transportation programs successful. I also 20 want to thank the people here at the table today and the whole team who 21 helped us to prepare for the briefing, and we look forward to your questions.
22 CHAIR HANSON: Thanks, Dan. We'll start again with 23 Commissioner Baran.
24 COMMISSIONER BARAN: Thank you for your presentations 25 and your work. Dan, you mentioned early in the presentation the Inspector
82 1 General's report that raised concerns about how ISFSI inspections were being 2 performed in Region II. Can you walk us through the specific changes that 3 have been made that address the IG's findings and concerns?
4 MR. DORMAN: Yeah, thank you, Commissioner. I'll start and 5 the team can add as needed. I think the root of the concern that initiated the 6 IG's review was concern from some of the inspectors in Region II that were 7 being assigned work on ISFSIs that they had not been appropriately trained 8 and qualified to do those inspections, and I think that was substantiated to a 9 degree.
10 So, then the question then is so the work that was done 11 during that period, you know, does anything additional need to be done to 12 address that? But I think the work that was done to build the program from 13 2019 until its implementation in January 2021 got at those issues and revised 14 the program to make sure that we're applying it consistently.
15 Part of the challenge there was that in, I think it was 2003, the 16 Commission consolidated the fuel facilities inspection program in Region II and 17 moved the materials inspection program under other parts of the materials 18 safety program to Regions I, III, and IV.
19 And so, ISFSI inspectors were in the DNMS division, the 20 Division of Nuclear Material Safety in our former structure in Regions I, III, and 21 IV, but there was no comparable division in Region II, so Region II was drawing 22 on other skilled inspectors and perhaps had not given them the full set of 23 training that was needed.
24 So, I think part of the focus of the transition and the 25 implementation of the revised program in January of 2021 was looking at the
83 1 procedures and making sure we're risk informed and focused on the most 2 important things, but also looking at the qualification program for the inspectors 3 and making sure that we caught that up.
4 MR. LUBINSKI: Thanks, Dan. The only things I'll add to that, 5 as Dan said and repeating what part of it is, part of it was the qualifications of 6 the inspectors in Region II and the other was the level of effort being put 7 towards each of the inspections.
8 We were looking at that and had identified in 2019 and put a 9 group together to do that. So, in parallel, while the IG was looking, we did that.
10 And as the IG referenced in its May, or February report, they had looked and 11 recognized our program, and believed it addressed many of the issues.
12 We appreciate the IG looking at this because we always like 13 to have another set of eyes on it. We also have the benefit that we have now 14 been through two years of implementing the new program. Most of the 15 inspections before were on a triannual type schedule and we implemented this 16 a third of the way into that, so we're through one cycle of that program.
17 We're doing a self-assessment at this time, so it's really great 18 that it parallels with getting the IG report so we're looking at our own 19 self-assessment results as well as what's been noted by the IG.
20 We think the issues noted by the IG were issues that we were 21 aware of and were part of our development of the new program, so now it's 22 looking at whether we adequately implemented those changes and addressed 23 those.
24 COMMISSIONER BARAN: Okay, well, I'll be interested in the 25 results of that. Jake, you mentioned the Project PELE prototype demonstration
84 1 of a mobile nuclear reactor. My understanding is that this is a first-of-a-kind 2 application because it will involve transportation of the entire reactor. What 3 does that review involve and how is it going so far?
4 MR. ZIMMERMAN: Okay, so thanks for the question. So, 5 that's a high-priority review for us. There's two main roles. There's the review 6 of the risk-informed methodology, and as you indicated, that's a novel approach 7 for us, and then there's also the review of the application from BWXT to 8 transport the package containing the microreactor.
9 So, right now, we're focusing on the risk methodology. We 10 just issued an RAI last week and we expect the Strategic Capabilities Office 11 with the Department of Defense will have a response to us by mid-June.
12 We've been also holding pre-application meetings. So, as far 13 as PELE, it's going very well. We don't expect the application for another year, 14 the full application, the submittal, but all of these pre-application engagements 15 are going well.
16 And then again, we're having pre-application discussions with 17 BWXT and their contractor over the next month or so, and we're trying to 18 identify best practices in our licensing and making sure we have a shared 19 understanding of the regulatory approach that we're going to ultimately be 20 looking to license this to.
21 COMMISSIONER BARAN: Thanks for that update. Norma, 22 you talked a little about revision, or reviews rather, associated with certifying 23 transportation packages for fresh and spent advanced reactor fuels. Can you 24 give us some additional detail about the current and expected workload in that 25 area?
85 1 MS. GARCIA SANTOS: We currently are reviewing three 2 applications for advanced fuels. And in terms of what do we expect, I will defer 3 that to Jake, but currently, we are doing three applications. We recently just 4 received what we call a re-validation that's also with advanced fuels from a 5 package from Japan. So, Jake, do you have anything to add for the expected 6 ones that we may have?
7 MR. ZIMMERMAN: I don't have actual numbers, but, you 8 know, we've been keeping our pulse with many external stakeholders, but I 9 can't give you an exact number.
10 But I can tell you that we, you know, I'm going to the Used 11 Fuel Conference next week. You know, we talk about, I'll be talking about 12 pre-application engagement, making sure you know our plant, your plans, 13 giving us the early heads-up. I don't have specific statistics to answer your 14 question, but I can get that for you.
15 COMMISSIONER BARAN: My sense is, just kind of thinking 16 back to maybe two or three years ago, this was kind of, or four years ago, it was 17 really coming down the pike we were going to be having to think about these 18 issues. It seems like there's been a fair amount of progress made. We're 19 getting submittals, and reviews are happening, and it's becoming pretty 20 concrete.
21 MS. GARCIA SANTOS: Yes, we are ready to review about 22 seven different packages, some for ATF, some for advanced fuels, so there is 23 some mix there.
24 MR. LUBINSKI: If I could add to that, as Norma said with 25 those packages, what we're finding is, again, there's a finite number of
86 1 packages we've approved, but they can be used in many different areas as 2 well.
3 So, when you think about many of our fuel vendors, they may 4 be using similar-type vendors for shipments even though you have nine 5 different fuel manufacturers out there as well as different enrichers.
6 So, the package has a lot of flexibility based on its content, so 7 that helps as well, also from the standpoint of business decisions by licensees 8 when they start to look at the enrichment of whether or not they can use current 9 packages with maybe different levels of fuel and enrichment within the package 10 as well.
11 Now, that creates a little bit of inefficiency on their part on how 12 much they can ship, but from an early standpoint, that provides them some 13 flexibility, and then in the longer term, we may see them coming up trying to 14 gain efficiencies by coming up with new designs to the packages.
15 COMMISSIONER BARAN: Okay, thanks. John on the other 16 side, thanks for the discussion of the high burnup demonstration program at 17 North Anna. It sounds like that's going to produce valuable data on higher 18 burnup fuels in dry cask storage. Can you talk about the time frame associated 19 with the program and when you expect the staff to see results and data?
20 MR. McKIRGAN: Sure, yeah, thank you. Thank you for that 21 question, Commissioner. It is a major program for the Department of Energy, 22 and for the industry, and for us as well, and so I'm very appreciative of the 23 collaborations that we've had with DOE. They've been very open to hearing our 24 data needs and our interests, and so thank you for the question.
25 So, there has already been some really good data generated
87 1 by the program. The thermal analysis data that I mentioned has been key in 2 really benchmarking a lot of our thermal analysis codes and it's really 3 demonstrated the value of our predictive capability.
4 Really, the biggest item that people are looking forward to is 5 opening the canisters after a certain period of time. The original plan called for 6 a ten-year period for the canisters to sit on the pad and age as they would, and 7 then open it up.
8 During the loading of the package, what was found was that 9 the temperatures weren't quite as high as they had hoped for or had planned 10 for, and so the Department of Energy with EPRI and other stakeholders are 11 thinking about whether ten years is still the right time frame to open that 12 package, so those dialogues are ongoing and no decision has been made yet, 13 but that will really yield a great deal of data.
14 The other piece of that overall program, of course, is the 15 Sibling Rod Program, and you might have heard about that in other talks. That 16 has already produced some very good data, and we'll continue comparing 17 those sibling rods to the data that's generated once the cans open will be 18 incredibly valuable.
19 COMMISSIONER BARAN: Great, very interesting. Thank 20 you, thanks.
21 CHAIR HANSON: Thank you. Commissioner Wright?
22 COMMISSIONER WRIGHT: Thank you, Chair. So, again, 23 thank you for your presentations, and I renew my earlier comments to you and 24 your staffs for getting you ready for today. It's been a good meeting so far.
25 Jake, I'm going to come to you first. So, thank you for your
88 1 answer to Commissioner Baran's questions about what the staff's doing in 2 regards to, you know, PELE. Is there anything more going on there with PELE 3 that you haven't mentioned?
4 MR. ZIMMERMAN: Nothing that I think I could expand on. I 5 don't know if John wants to add anything.
6 MR. LUBINSKI: The only thing I will expand on on PELE is I 7 really appreciate what our folks are doing looking at the PELE application, 8 working with the applicant, working with BWXT, and the prioritization of the 9 work. We will, as we continue to move forward, keep the Commission informed 10 because we're talking about novel ideas.
11 COMMISSIONER WRIGHT: Right.
12 MR. LUBINSKI: Closely related to this is also what's gone on 13 at NRR with respect to --
14 COMMISSIONER WRIGHT: That's where I was going.
15 MR. LUBINSKI: -- the microreactors. We have definitely 16 engaged with them, and in fact, our key technical reviewer, Bernie White, is on 17 both projects, for the PELE as well as working on what we're looking, for the 18 transportable reactors in NRR, to making sure that, number one, we're 19 addressing the same issues, but number two, that if there's any lessons learned 20 out of this, generic issues, that they can be factored into what NRR is looking at 21 overall for the transportable reactors, and we are working right now on 22 providing information to the Commission on what we're doing on those reactors.
23 If I can also, while this is a business line briefing on more of 24 the spent fuel pool side, or spent fuel side and the transportation side, that 25 paper also looks a lot at the environmental side, which, as you know, NMSS
89 1 has the Environmental COE.
2 So, we're definitely looking at the environmental impacts as 3 well when we start to look at those microreactors and working very closely with 4 NRR on that.
5 COMMISSIONER WRIGHT: Yeah, that was exactly where I 6 was going.
7 MR. ZIMMERMAN: Just something else, thank you, John, I 8 thought to mention is that, you know, with reviewing of the risk methodology 9 and I mentioned the risk tool in my presentation, the risk tool is applicable to the 10 storage reviews that we do, and so a natural question might be, you know, well, 11 what are you doing in the transportation area?
12 We think that there's going to be a lot of knowledge gained 13 from looking at the risk methodology, continuing to apply the risk tool in our 14 storage reviews, but taking lessons learned from what we're getting with PELE 15 and then ultimately other potential microreactors, for example, the eVinci, and 16 then seeing how we can apply lessons learned from that and feed it back into 17 our licensing and our oversight program.
18 COMMISSIONER WRIGHT: Very good. Thank you for that.
19 I'm going to stay with you a second here. So, I believe I've been told you're 20 kind of fairly new really as it goes to this particular position, but you're not new 21 to the NRC, right. You've been around. You've experienced things.
22 So, talk to me personally about what you might see as the 23 most important areas for success in the spent fuel storage and transportation 24 business line.
25 MR. ZIMMERMAN: So, thanks for that. Yes, 25 years in
90 1 reactors, six years in fuel facilities, six months in storage and transportation.
2 (Laughter.)
3 MR. ZIMMERMAN: So, I think there's six important areas 4 personally for the business line, and it's people, it's process and procedures, it's 5 the technology, both what we use to manage our work but also the technology 6 that we're responsible for regulating, our budget and our resources, our 7 products, and then performance management. That's kind of been my personal 8 leadership focus on different positions that I've had.
9 Right now, I believe, in the current environment with our 10 staffing and our hiring, the most important, the three most important areas for 11 me are people, connecting with the staff, making sure I understand, you know, 12 their knowledge, skills, and abilities, what we need, employing training and 13 knowledge management, strategic workforce planning, communication and 14 collaboration.
15 And then on process and procedures, just making sure that 16 we have, and I think some of my fuel facility staff will probably be chuckling 17 about this, but clear expectations, guidance, roles and responsibilities, and 18 then, you know, making sure we understand what we do, how we do it, and why 19 we do it.
20 And then the last one, budget and resources. It's fiscal 21 responsibility for FTE and contract dollars, making sure that we have the tools 22 that we need to appropriately review our FTE utilization and our contract 23 expenditures, and we're looking for indicators when you apply that to other 24 metrics of where we need to take action, and that all relates to our current and 25 our future workload, which obviously ties into staffing.
91 1 And then a big focus for me is just balancing our workload.
2 We've talked a lot about, in the previous business line, about our staffing 3 challenges. We have a wonderful staff. On average, our staff work more than 4 what an FTE, we budget an FTE for.
5 Our staff are working 1,600 to 1,700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> per person versus 6 what we budget for, and because they're doing that, we're able to do, keep up 7 with the work that we have going on.
8 So, for me, work-life balance is really important, but again, the 9 other areas are too, but those are the three that I'm primarily focused on right 10 now, especially hiring.
11 COMMISSIONER WRIGHT: Thank you, very good. I agree 12 with the work-life balance thing for sure. Norma, good morning.
13 MS. GARCIA SANTOS: Good morning.
14 COMMISSIONER WRIGHT: So, Im going to ask you this 15 question because you referred to it in your presentation --
16 MS. GARCIA SANTOS: Yes.
17 COMMISSIONER WRIGHT: -- right, but I would understand if 18 you want to like phone a friend here on the panel as well.
19 MS. GARCIA SANTOS: I will phone a friend if I can.
20 COMMISSIONER WRIGHT: So, you said that last year, you 21 completed 63 licensing --
22 MS. GARCIA SANTOS: Yes.
23 COMMISSIONER WRIGHT: -- reviews, and this year, you've 24 already done 64 --
25 MS. GARCIA SANTOS: Yes.
92 1 COMMISSIONER WRIGHT: -- right? And I know you said in 2 your comments that the completion rate was larger this year because you're 3 finishing up some stuff that was --
4 MS. GARCIA SANTOS: Yes.
5 COMMISSIONER WRIGHT: -- delayed, right, from the 6 previous year, but, so explore this with me a little bit because it seems like you 7 found something here maybe, all right. I don't know whether it's --
8 I guess, first, are all the reviews you do exactly the same or 9 are they, you know, basically, are they -- because if they are, you know, maybe 10 you've found some efficiency here, and you've found some things that work that 11 you're able to just repeat and get done.
12 And, you know, if not, what's the driver of the apparent 13 increase in success that you've had here with these reviews? I mean, is it were 14 they not as complex or was there some other issue?
15 MS. GARCIA SANTOS: Thanks for the question. None of 16 the reviews are the same. We have some that are more complex than others.
17 Last year, we completed 63, this year, 64.
18 For this year, we have one of the applications that we 19 finalized, there were 11 revisions of one COC, so that one that one, we counted 20 as 11, yes, and that didn't require a lot of complexity.
21 We have received more of what we call re-validations, which 22 are requests from the Department of Transportation to review foreign packages.
23 That's part of our memoranda of understanding. They can do that. So, we are 24 receiving more of that, like we used to receive three, five - we are at ten right 25 now and we may be receiving 12 this year.
93 1 The other is we also are counting our decommissioning 2 funding plans reviews. This year, we have completed about 21 or so. Last 3 year, there were maybe eight or ten, so that's building up into that.
4 The other is, yes, your questions about efficiencies, yes, we 5 are trying to do that, like if we see a review that, let's say it's a spent fuel 6 package, same changes and they are similar, we are trying to have the same 7 team reviewing all of those applications.
8 I have three cases like that, like we call cases actions, and 9 they are spent fuel. They are doing like the IAEA regulations, the same 2018.
10 They are removing contents, kind of similarities. So, for those three reviews, I 11 tried to have the same team because their knowledge is common and they can 12 apply their lessons.
13 They can streamline the processing of generating the 14 documentation, the SER and everything. So, yes, we are trying to really look at 15 the efficiencies because of the work that we are having.
16 COMMISSIONER WRIGHT: Very good. Thank you so much.
17 And I got one last question. I don't think it will take you much to answer it, I 18 don't think. I hope not. But I noticed in your slide in the New Fuels Atlas, 19 there's a space for rulemaking.
20 MS. GARCIA SANTOS: Yes.
21 COMMISSIONER WRIGHT: Can you tell me more about 22 what, if any, rulemaking the NRC staff currently thinks might be necessary in 23 order to be ready for these advanced fuels, if one is necessary at all?
24 MS. GARCIA SANTOS: Yes, our understanding is our 25 current regulatory framework is adequate at this point and it's enough to just
94 1 review the applications that we have.
2 However, we want to use that Atlas or what we call the 3 planner to identify areas that we may need to improve or may need more work 4 on, like rulemaking, if we need to revise regulations or our regulatory 5 framework. So, that's kind of the idea of having this planner, but, Jake, do you 6 want to add something?
7 MR. ZIMMERMAN: I'll just add that we have all of the, I call 8 them the buckets, and they're aligned to --
9 COMMISSIONER WRIGHT: Right.
10 MR. ZIMMERMAN: -- the budget, and so the point behind, 11 even if there's no rulemaking, we want to make sure that we've at least 12 highlighted it so we're thinking about, at each one of the phases I call it in the 13 fuel cycle, hey, is there anything in licensing we need to do? Is there any 14 research we need to do? Is there any rulemaking?
15 So, that, you know, there's a lot of great people that worked 16 on developing this and coming up with, you know, how do we make sure going 17 forward, the things that we've thought about, hey, don't forget that, and so we 18 want to make sure that the model or the Atlas would include that.
19 So, there may not be any rulemaking that's needed, but we 20 want to make sure there's that constant reminder in each one of those areas 21 that we're asking ourselves and we're questioning, and when you look back, is 22 there something we're doing at the end that we need to make a decision on the 23 end, at the back end that we should be doing things, you know, hey, we're 24 going to have to start working on that six years ahead in order to get to that 25 point.
95 1 COMMISSIONER WRIGHT: Great. Thank you so much.
2 CHAIR HANSON: Thank you. Commissioner Caputo?
3 COMMISSIONER CAPUTO: Good morning. Thank you all 4 for coming. Mr. Zimmerman, I'm going to stick with you. I have a question. So, 5 you mentioned the risk tool in your comments and a few minutes ago with 6 Commissioner Wright. Why wouldn't we implement that tool in all of our 7 storage reviews?
8 MR. ZIMMERMAN: So, we did the pilot, and the pilot was on 9 two applications, which two pilots is not enough data, but we learned a lot of 10 good lessons from that. I see Ms. Diaz over there. She wrote the assessment 11 report that was issued last summer.
12 And so, coming out of that, when I joined the group and as I'm 13 coming up to speed on this, I felt that we needed to reinvigorate our use of it, 14 make sure that we've captured the lessons learned from that, and then I wanted 15 to make sure that we've got more data on the staff using it.
16 So, we're going to use it from May through October, collect 17 information from the staff. You know, as in any change, there's a culture 18 change associated with this. You have some people aren't embracing it and 19 some people are fully embracing it, and we want to make sure that we all are 20 using it and testing it.
21 I believe the risk tool is more of a knowledge management 22 tool, and I think there's things that we can do to further enhance it. It's not the 23 silver bullet that, if you use the risk tool, you automatically have a six-month 24 schedule and it's only going to take 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> to do the review. That's not the 25 purpose of the risk tool.
96 1 There is information on that that would help to guide your 2 level of review, but it's just, I look at it from my reactor experience that it's risk 3 insights that we use when we think about defense-in-depth, safety margin, 4 subject matter expert operating experience.
5 So, it's an additional insight that we can use, and then 6 through using it, we can go back and we can update it so that it's a living 7 document that, as people leave, we're capturing the senior experience and 8 even the staff newer that are using it, and making sure we'll be successful into 9 the future.
10 So, I personally believe that it's more of a knowledge 11 management tool. The industry is very interested in resurrecting using it, and 12 so we actually have been talking about them taking the tool independently and 13 using it, and then we're going to get together and we're going to talk about, you 14 know, the things that they learned from it and how we can enhance it and 15 improve it going forward.
16 COMMISSIONER CAPUTO: So, you don't expect to gain any 17 efficiencies from using this tool going forward?
18 MR. ZIMMERMAN: I do believe there will be efficiencies. I'm 19 not -- I cannot quantify it right now, but naturally, I think that, going back, when 20 you identify the process, the procedure, and you've given people the tools, I 21 think there's a natural tendency.
22 So, for example, I think our newer reviewers will be more 23 efficient because they won't have to go and sit -- without this document or 24 without capturing this knowledge, they have to go and sit with a senior person.
25 That doesn't mean we don't do that because there's
97 1 tremendous value in on-the-job training and direct presence with a purpose, but 2 it gets them further faster by having tools like this.
3 So, I do think there's going to be efficiencies. I think there's 4 going to be effectiveness as far as in our reviews, the quality. I think things 5 could become more stable, consistent, and predictable by using the tool, but 6 enhancing it further.
7 COMMISSIONER CAPUTO: All right, thank you. Ms. Garcia 8 Santos, I have a question for you as well.
9 MS. GARCIA SANTOS: Sure.
10 COMMISSIONER CAPUTO: You mentioned a topical report 11 in shielding which has the potential to streamline storage system licensing 12 reviews, and I understand this business line just recently adopted the use of 13 another topical to streamline, well, using topical reports in general to streamline 14 processes for addressing issues on a generic basis.
15 You also recently approved a topical report on thermal and 16 are now reviewing one on shielding. Are you seeing efficiency gains by using 17 the topical reports process and benefits from the reports that you've approved?
18 MS. GARCIA SANTOS: Thank you for the question. We 19 currently only have one application that has applied the topical report on 20 thermal, so, and that's for heat load pattern. So, the efficiencies that we expect 21 or our applicants will gain is they don't have to come up for an amendment 22 every time that they change the heat load pattern.
23 In the past, if they just changed the heat load pattern, that will 24 trigger an amendment. So, for this particular case for the thermal topical, it only 25 applies currently to two systems and it's only for one vendor because that was
98 1 kind of the parameters of that one.
2 For the shielding topical, that's broader. The intent is that 3 applies to like kind of across the board to different systems, and when we say 4 streamline, it has to do with the fuel qualification tables that they use to load 5 fuel. It will be made a methodology that will identify like maximum enrichment 6 or burnup and decay heat.
7 So, if it's within those parameters, then the possibility of -- if 8 they use the methodology to analyze those parameters, they can, it's the same 9 effect. They don't have to come for amendments to, you know, make changes 10 to the certificate. Because currently, if they make changes, they have to come 11 to amend it, so that's the intent of that.
12 We cannot quantify it right now because we only have one 13 application, but as we receive more, we are going to assess if there are 14 efficiencies gained through that process.
15 COMMISSIONER CAPUTO: Okay.
16 MR. ZIMMERMAN: Could I just add something to that? One 17 of the important aspects of a topical report is that the end user applies it 18 appropriately. So, we only have one under review right now, but again, thinking 19 about our reactor experience, when you start to deviate --
20 And I think it's more of a challenge. There's more diversity 21 over here on the storage and transportation side. It's incumbent upon the 22 applicant to make sure that they explain those deviations from the topical 23 report.
24 We would love to take advantage of a topical report, 25 streamline our reviews, be able to do it more efficiently, but when people take
99 1 exceptions to it without fully understanding and then fully explaining 2 themselves, that can create challenges.
3 So, I'm kind of giving a plug for anyone in the industry that's 4 listening in that when you're applying these, please make sure that you're 5 applying them appropriately and you're explaining the differences.
6 MS. GARCIA SANTOS: Yes, and just a little bit more, as 7 Jake was saying, any deviation from the approved methodology then will need 8 to come to us.
9 COMMISSIONER CAPUTO: So, I'm going to stay with the 10 two of you and maybe John wants to add in. So, between the use of the risk 11 tool and the topical reports, are you doing anything to risk inform certificate of 12 compliance reviews in general?
13 MR. LUBINSKI: Thanks. If I can, I will say that the bigger 14 project we had there was a graded approach to looking at certificates. That 15 was the intent there, that it would provide some flexibility to folks.
16 Many times, when they were doing their certificate of 17 compliance, it was coming in. It was very narrowly focused on the design, a 18 little bit as Jake was talking about, even in the topicals, staying very specific.
19 We believe there's a lot that they can broaden which would allow them to do 20 changes on their own without coming in for reviews.
21 What we're hearing from the industry on that point is that it's a 22 cost to come in and change their certificate for compliance and get it changed, 23 so they're waiting until they get to either a revision to the certificate of 24 compliance or go through a renewal process and are trying to bring a graded 25 approach together at that time.
100 1 So, they have not set a plan for us on when these graded 2 approaches will come in, but the ones who have come in so far have seen that 3 it has provided efficiencies overall and has provided much more flexibilities, so 4 it's more of a performance-based.
5 From a risk standpoint, it also provides a lot of great risk 6 insights because now we're using the knowledge we have already to say where 7 can we expand and provide flexibility to the users that these are low-risk 8 changes and allow that flexibility in certificate of compliance.
9 That's where I really see the risk informing going on the 10 graded approach. The topical report is more along the efficiency line that I see 11 that.
12 COMMISSIONER CAPUTO: All right, thank you. Unless you 13 have, do you have anything to add?
14 MS. GARCIA SANTOS: No, I just was going to say that the 15 first step was the graded approach. The graded approach was to start that 16 risk-informed and performance-based kind of process, and then after that, 17 things that couldn't be addressed through that, then that second step was kind 18 of the topical report.
19 COMMISSIONER CAPUTO: Okay, wonderful. Thank you 20 very much.
21 CHAIR HANSON: Thank you. Commissioner Crowell?
22 COMMISSIONER CROWELL: Thank you, Mr. Chair.
23 Following yesterday's Senate hearing, today is a good reminder of how nice it is 24 to be on this side of the table.
25 (Laughter.)
101 1 COMMISSIONER CROWELL: And Jacob, I want to start with 2 you because you win the prize today for the best tie, and Lindsey, you're now 3 the runner-up by the way.
4 (Laughter.)
5 COMMISSIONER CROWELL: But I also have an important 6 question for you, Jacob, which is, you know, you're talking about age-related 7 degradation of dry casks and I'm hoping you can put a little bit more color to 8 that, like what kind of degradation are you seeing that is of concern and that 9 needs to be addressed?
10 MR. ZIMMERMAN: Yeah, mainly corrosion aspects, and so 11 we've got research going on that I think John's talked about and I'm going to 12 kick it over to him as to -- he can provide more details on that.
13 But through our inspections, you know, just as we implement 14 the TI, the information that we gathered there, now with the inspection 15 procedure, it will be insightful to see just how much more information we get 16 that could either lead to a new age-related, an age-related degradation that 17 we're not currently focused on.
18 But right now, there's nothing that's jumping out as a 19 showstopper on age-related degradation. I mean, we have to keep an eye on 20 through our inspections, through the inspections that the licensees are doing, 21 and then feeding that back into our program. Is there more research we need 22 to do in that area? But I'm going to ask my friend, John, over here to talk a little 23 bit more about it.
24 MR. McKIRGAN: Thank you. Thank you, Jake, and thank 25 you, Commissioner. And it's funny, I'm actually not going to talk about the
102 1 research component. I'm going to talk about another piece, Jake, that I'm sure 2 you're aware of is the AMID database, and so, this is a, it's an aging 3 management database.
4 It's built into our aging management program which was 5 designed to be a learning program so that industry would be feeding in the 6 operating experience, the observations from their inspections, and the staff as 7 well, and then the staff has the ability to look at that database.
8 And through that, the industry then is able to gather data 9 across the whole fleet, across the universe of data and not only see -- this is a 10 feature of the plan. It's not only to report the bad thing. It's don't only report 11 problems that you find, also report things that you're not seeing. For example, if 12 you're not seeing corrosion, that's actually a valuable piece of information in the 13 database.
14 And so, we're still relatively early. In the 40-year life span of 15 these systems, we're still kind of relatively early in collecting data into that 16 database, but that will really be the tool for the industry and the staff to figure 17 out if we need to increase inspection frequencies or perhaps there might be 18 areas where we can decrease frequencies.
19 COMMISSIONER CROWELL: So, either within the, you 20 know, 40-year, you know, hard experience time frame or through models, 21 what's the time frame in which you are seeing corrosion?
22 MR. McKIRGAN: Let's see, I don't know that we have 23 identified any specific concerns at this time. I don't think we have any 24 observations that would indicate that there's any actions that needs to be taken.
25 And I do need to differentiate this. I mean, there are wear
103 1 marks. There are, you know, handling features on the canisters that we have 2 seen, and I'm not -- I'm trying to differentiate, so I wouldn't call those corrosion.
3 So, you're using a very, a broad term that applies to a lot of 4 things, you know, rust, for example, that wasn't actually part of the canister, it 5 was part of a handling procedure that loaded the canister.
6 COMMISSIONER CROWELL: Any degradation of concern. I 7 mean, Jacob, you said corrosion, so I just went with that, but any degradation of 8 concern is what I'm interested in. John, do you want to jump in?
9 MR. LUBINSKI: Thanks, if I could add to that, so one of the 10 key points of the aging management program is to identify if there is something 11 of a degradation, whether it's corrosion or other degradation, and as John said, 12 even wear marks that may end up being more susceptible.
13 It's to identify early enough before it becomes a safety issue 14 so that the licensees can take specific action to address it. What we've done is 15 we believe that the numbers we put in place are conservative and looking at 16 many times a five-year time frame for doing much of this.
17 One of the more burdensome inspections would be actually 18 lifting the canisters off the pad to look underneath the canister, and that's an 19 area that we've gone longer and that's an area where we're really looking at are 20 we seeing degradation underneath the canister at this point? Again, it's 21 important to know and it's important to know early.
22 As John said, a lot of the findings are not just -- well, it's two 23 parts. One is with the specific canister, are you seeing something that requires 24 action?
25 And number two, are you seeing trends that tell you either,
104 1 one, we need to do these things more frequently, or two, we may not need to do 2 them as often because, again, the databases we have on the degradation 3 mechanisms aren't set up for exactly this exact system, right?
4 We didn't test the canister being out on a pad in these 5 environments for this period of time, but this is where we're starting to gain the 6 data. So, I think our numbers right now on the aging management are 7 intentionally on the conservative side and we'll learn more as we move forward.
8 COMMISSIONER CROWELL: I assume that the potential for 9 degradation or management issues of concern are increased with the storage 10 of higher burnup fuels in dry casks?
11 MR. McKIRGAN: I think it's still very early. I think we're still 12 looking at that. I don't know that I have a definitive answer for you on that 13 today. We do look at high burnup fuels in storage.
14 If I could make sure I understand the question, you're talking 15 about canister performance, which I differentiate from cladding performance, 16 and so we are doing a fair bit of studies. The cladding is part of the overall 17 defense-in-depth of the system, so we're doing a lot of work monitoring cladding 18 and the high burnup effects there.
19 I'd have to think a little bit more about how that would 20 propagate out and if there's anything unique to the canister performance that 21 we'd have to think about.
22 COMMISSIONER CROWELL: Mark, you inspect these 23 things. Do you have anything you want to add?
24 MR. HENRION: No, I mean, I look forward to when the new 25 inspection procedure comes out and, you know, hopefully on the inspector side,
105 1 we get training with what we're going to be looking at.
2 We do, on the triennial period, even if a site doesn't have an 3 active loading campaign during that period, we still go out and do a program 4 inspection, so, where, you know, we are looking at material conditions and daily 5 logs for temperature checks in the canisters and things like that.
6 MR. LUBINSKI: If I can clarify, Commissioner Crowell, to 7 make sure from the terminology, many times we use term inspection and it's 8 really used in two ways.
9 One is the licensee doing an inspection, and as Mark said, 10 the licensee is required to do certain inspections at their facility. Aging 11 management programs are on them to do the inspections, not us. We then do 12 the inspections to verify that they have completed their inspections under aging 13 management programs and verified the results of those inspections that have 14 been done.
15 So, sometimes when we use the term inspections, we're 16 referring to the licensee doing it under their aging management programs.
17 Other times, it's us inspecting the licensee's implementation.
18 COMMISSIONER CROWELL: And I appreciate that, and I 19 may get to that point if I have time left. John, going back to you for a second, 20 looking at a different part of the process here, you noted in your presentation 21 some specific technical concerns with the loading of spent fuel into dry casks at 22 high temperatures.
23 And I haven't passed Carrie's fuel process course yet, so I 24 don't know what hydride reorientation and creep rates are, so can you tell me in 25 like plain language what this is all about?
106 1 (Laughter.)
2 MR. McKIRGAN: Thank you and thank you for reminding me 3 that I do need to work on my plain language.
4 So, there are a number of phenomena that have the potential 5 to impact the integrity of the cladding, and so now I'm actually going back to the 6 answer I was providing previously about the high burnup fuels.
7 Some of the alternate cladding approaches that are being 8 used for ATF, there are damage mechanisms that are at play with the cladding, 9 and one of the things we do is we use these phenomena identification and 10 ranking tables and a lot of expert elicitation to identify the specific mechanisms 11 that potentially exist in these material systems, the cladding.
12 Hydride reorientation is one and the feature there is to make 13 sure we understand the physics, understand the environment, and understand 14 when those issues start to come into play so that we can have an appropriate 15 inspection program.
16 COMMISSIONER CROWELL: So, I'm going to let you off the 17 hook for now, but I still couldn't repeat to you what hydride reorientation is, so 18 let's -- and I don't want to lose my time here because I have one more question 19 to make. Either Dan or John earn their paycheck today.
20 You know, after the -- if I may, Mr. Chairman, just a few 21 seconds longer. Thank you. You know, after the rail incident in East Palestine, 22 Ohio, one outcome of that was some suggestions that this is an example of why 23 we can't and shouldn't transport, you know, nuclear waste by rail.
24 It wasn't necessarily substantiated, those comments. I 25 wanted to give you guys an opportunity to give, you know, a publicly
107 1 understandable version of why we feel it can be done safely.
2 MR. DORMAN: Yeah, thanks, Commissioner, and as you're 3 talking, I'm thinking of the Baltimore rail fire many years ago that we studied 4 closely.
5 And the bottom line is that the Commission's requirements for 6 the design of these packages with respect to collisions, with respect to fire, with 7 respect to drop, with respect to immersion, conservatively bound what we've 8 seen in these various activities to demonstrate that yeah, there will be rail 9 accidents at some frequency, but the packages are very robust.
10 And this is not just a theoretical application. There's a long 11 history of full-scale testing of packages under these conditions, so --
12 COMMISSIONER CROWELL: And that's -- yeah.
13 MR. DORMAN: -- I think that's --
14 (Simultaneous speaking.)
15 COMMISSIONER CROWELL: If it's all right, I'm going to 16 speculate a little bit. Is it maybe fair to say that if the, like in the East Palestine 17 example, if the materials that were released were included in the same style of 18 the packaging that nuclear waste is transported in, they may not have had a 19 breach?
20 MR. DORMAN: Yes.
21 COMMISSIONER CROWELL: Okay, thanks.
22 CHAIR HANSON: Thank you. All right, well, with the 23 acknowledgement that I'm the one standing between everyone and lunch, let 24 me just tackle, I think, one thing.
25 John, I wanted to kind of get an update on the tornado missile
108 1 issue. And, you know, Mark had this great slide of these axes and there were 2 at least two elements of that issue, right, and let me try and kind of summarize 3 them and then you can, I'm going to let you jump in, right.
4 One was about administrative controls, and we address that, I 5 think, through the VLSSIR process, and I think that was exactly -- you know, my 6 view is that that was the way to go. The other one had to do with an 7 unanalyzed condition and the licensing basis, and that put us into enforcement 8 discretion space.
9 Now, you know, per Mark's slide, right, there were kind of two 10 ways to address that. One was to change the licensing basis and then one was 11 to do a rulemaking.
12 So, I guess my question to you is are we still in enforcement 13 discretion space with regard to that issue on, you know, with regard to the 14 unanalyzed condition, and if we are, what's the pathway to get out of that 15 space?
16 Because I think, you know, as a matter of kind of 17 transparency and reliability, both for the public and for our licensees, I think we 18 have to kind of find out way through that, and so I'd like an update from you 19 about kind of where we are.
20 MR. LUBINSKI: Great, if I could ask, if we can, as we're 21 talking, if you could pull up the slide, Kelly, that he was referring to that had the 22 VLSSIR on it?
23 MR. DORMAN: Slide 40.
24 MR. LUBINSKI: Slide 40. Thank you, Dan. So, let me, in the 25 slide, I'm going to talk a little bit about the difference between VLSSIR, which is
109 1 the lower left-hand quadrant --
2 CHAIR HANSON: Right.
3 MR. LUBINSKI: -- okay, versus the lower right-hand 4 quadrant, and I'm going to go where Mark was when he was talking and he can 5 help correct me when I go along here.
6 But we had certain situations where we were in the lower 7 left-hand side that we had, when you say unanalyzed conditions, we may have 8 had an unanalyzed condition, but it was unclear whether or not it was in the 9 licensing basis.
10 CHAIR HANSON: Okay.
11 MR. LUBINSKI: And we started to pull the string and we said 12 it is still unclear whether it's there. How far do we want to pull this string? Is it 13 worth the effort? Because we determined it is of very low safety significance for 14 one reason, and that is because the administrative controls were in place.
15 So, that kept us in that lower left-hand side and we ended up 16 with folks who were, again, unclear licensing basis, but it's very low, so why do 17 we need to deal with it? Because they put the administrative controls in place.
18 CHAIR HANSON: Okay.
19 MR. LUBINSKI: Now, I'll go to the right-hand side, which is 20 where you were, you know, words of how do we get to the end fix? Now we 21 ended up with more of those issues, as Mark identified one in Region I, that it 22 was clearly in the licensing basis.
23 CHAIR HANSON: Okay.
24 MR. LUBINSKI: And I use that term because I will say that 25 along the way, internally within the NRC and externally, there was
110 1 disagreement about whether or not it was clearly in the licensing basis, and I 2 appreciated the differing views that came up and I appreciated the 3 professionalism to get to the point to say yes, these are in the licensing basis, 4 and appreciate the CRGR committee on, well --
5 CHAIR HANSON: Yeah.
6 MR. DORMAN: Generic Requirements.
7 MR. LUBINSKI: Yeah, thank you, Dan, appreciate that.
8 (Laughter.)
9 MR. LUBINSKI: So, but, and agreed it was in the licensing 10 basis. So, now we had a clear issue that was in a licensing basis.
11 CHAIR HANSON: Right.
12 MR. LUBINSKI: The licensee said well, we could fix this in a 13 number of ways. One, we can go modify the certificates of compliance, a lot of 14 work to do that. Number two, what they said is we could do this under a term in 15 our regulations, 10 CFR 72.48, that allows licensees to make changes to their 16 licensing basis without coming into the NRC for review, and we said, well, you 17 can't do that today because under the regulations, it doesn't allow you to put 18 administrative controls in place under 72.48.
19 CHAIR HANSON: I see.
20 MR. LUBINSKI: So, our fix to this is two parts. Number one 21 is we issued a memorandum called an enforcement guidance memorandum, 22 EGM, working with the Office of Enforcement that says as long as you put these 23 administrative controls in place, you can basically work under a 72.48-like 24 framework.
25 We're going to give you enforcement discretion, not to cite
111 1 you, and you continue to do your loadings, but that's only in place until such 2 time as you come up with another fix such as either getting a certificate 3 modified or putting a process in place that allows this under 72.48.
4 That's the process we're in now. The industry has developed 5 a guidance document. The guidance document says this is a process, a 6 methodology that's acceptable to the NRC. Once NRC approves this 7 methodology, rather than calling it an administrative control, you're calling it a 8 method that's been approved by the NRC. That's where we are now. The 9 industry had provided that document to us. We're in the process of reviewing 10 and going through a final endorsement of that.
11 CHAIR HANSON: Okay.
12 MR. LUBINSKI: We expect that endorsement to occur by the 13 end of this year. We're in 2023. I believe, and I can correct this later, but I 14 believe the enforcement guidance memorandum continues into '24, so we have 15 allowed ourselves time to get the guidance document reviewed and approved.
16 So, once the guidance document's approved, now it would 17 allow users to use 72.48 in that lower right quadrant --
18 CHAIR HANSON: Right.
19 MR. LUBINSKI: -- to say yes, it's clearly an issue, but my 20 72.48 works because I'm relying on an NRC-approved methodology.
21 CHAIR HANSON: I see, okay. Jake, did you want to jump 22 in?
23 MR. ZIMMERMAN: I was just going to add from a schedule 24 standpoint, I just reviewed and concurred on the draft Reg Guide yesterday. It's 25 working its way through the process. We plan to issue it in June for comment
112 1 for 30 days, and during that 30-day comment period, we are going to have a 2 public meeting, and we're targeting to issue the final Reg Guide by October of 3 this year.
4 We've also already engaged with ACRS to see their interests, 5 and they've discussed it in their most meeting and they've declined to review it.
6 So, it's moving forward and --
7 CHAIR HANSON: Okay, well, I appreciate the update, I really 8 do, because I think kind of getting out of this place that we've been in, I think, is, 9 it's really, I think it's really important, right, and getting some of that clarity out 10 there.
11 MR. LUBINSKI: Thanks, and I would add it does not take the 12 flexibility away from licensees either. Jake, I appreciate what his staff's doing 13 and I'm glad we're going to get the guide out this year. We have had some 14 licensees, as part of their new certificates of compliance or some of their 15 renewals, actually add this change to it that would allow for the use of 16 administrative controls, so they have that aspect as well and we're reviewing 17 and approving those.
18 CHAIR HANSON: Thanks. I guess my follow-up question to 19 that, and John, you kind of touched on it a little bit, was kind of Norma talking 20 about risk informing the certificate of compliance review process then. You kind 21 of suggested maybe the COC change as maybe a more onerous way to go, but 22 is that ameliorated in some way by these other processes we're putting in 23 place?
24 MR. LUBINSKI: When I said it was more onerous, I was 25 referring to the fact that if you were to do it solely based on going through a
113 1 certificate of compliance change --
2 CHAIR HANSON: I see.
3 MR. LUBINSKI: -- to put this place. If you already are going 4 through a new certificate of compliance, it is very easy, very simple to make it 5 part of that because again, we already have the methodology we've approved.
6 We have approved it for Interim Storage Partners. I 7 mentioned the Consolidated Interim Storage Facility. We've approved that 8 methodology to use these administrative controls, not in the exact same way, 9 but in a similar-type way. So, we have precedent that we could do this as other 10 reviews.
11 So, it becomes more streamline when they make it part of a 12 current review, but my comment on being more onerous was if you were doing 13 it simply to add this methodology.
14 CHAIR HANSON: Okay, thank you. Right on time, almost.
15 Well, thanks to everyone this morning for the presentations and for the 16 discussion. You know, look, I appreciated throughout, and I think among the 17 Commissioners, we touched on this in a variety of ways, of kind of 18 incorporating, the importance of incorporating risk-informed approaches into our 19 work, and Jake, I think you hit the nail on the head when you said look, this is a 20 cultural issue as well.
21 And look, my modest contribution in this area -- my kids gave 22 me a t-shirt a couple of years ago for Christmas, right. In lieu of ties in my 23 house, it's t-shirts, and the t-shirt says your risk of being killed by a bunny is 24 low, but never zero, and --
25 (Laughter.)
114 1 CHAIR HANSON: -- and yet I go about my day-to-day 2 activities not actually trying to mitigate against, you know, trying to address the 3 risk of being killed by a bunny. And, you know, but it does kind of, as we think 4 about taking on risk-informed approaches, I always remember this t-shirt that I 5 have in my drawer.
6 I don't get to wear it very often. Maybe one of these days, I'll 7 wear it to the office at an all-employee event or something --
8 (Laughter.)
9 CHAIR HANSON: -- but, you know, it's kind of a funny thing, 10 but it is kind of maybe a little humorous way of thinking about how we're trying 11 to tackle these issues.
12 So, with that kind of tangent, I think I'll let us all go to lunch, 13 and thanks again, everybody.
14 (Whereupon, the above-entitled matter went off the record at 15 12:03 p.m.)