 Well, good morning, everyone. It's truly amazing that crowd just quieted down as we were approaching the starting point of the session. So I guess we'll just go ahead and get started. I want to welcome you to the regional administrator senior industry executive session. And I hope you've come prepared to ask questions and hear a lot of good dialogue on a number of important issues that are facing us in terms of implementing regulatory programs. I wanted to start off with a few housekeeping reminders for you. Of course, questions and answers will be handled via written cards. Of course, you would have had to be comatose at this point in the rick to not know that we're handling questions and answers in that way, so there are no microphones. I would ask that you pass questions and answers when you have them to the folks who'll be walking up and down the aisles. Unanswered questions will no longer be collected and answered and made available on the rick website. So if in fact there is a question and you haven't gotten an answer, I'd ask you after the session's over to make your way forward and we'll try to stick around if we can to answer any questions that may be lingering, but also invite you to send us an email and we'll try to deal with them in that way as well. Of course, your feedback is very important to us. The technical session and overall evaluation forms are available electronically by scanning the QR codes accessible on signage throughout the conference center at the kiosk or via links on the RIC website. So again, we do very much want to get your feedback on the session. The real purpose of the session, I think, is for us, as I indicated or alluded to, to tee up questions and then to get some answers and engage in some dialogue with respect to issues that are of relevance to us. So I've come prepared. We've come prepared with answers or with questions and hopefully some good answers to those questions based on interests that we know exist among the industry, for example. And so I'll start with those questions. But again, we really do invite you to raise questions. So I really am asking you to actively engage and fill out the question cards. Let me, before we begin, introduce or just really just give the names of our panelists. I know that you are familiar with all of these individuals. So Dan Dorman, a regional administrator from Region 1, Kathy Haney, a regional administrator from Region 2, Cindy Peterson, our Region 3 regional administrator, Mark DePaul, Region 4 regional administrator, Fadi Dia, who is the senior vice president and chief nuclear officer for Amron, and Tim Rauch, who is the senior vice president and chief nuclear officer for Tallinn. So again, we've got a very distinguished set of panelists and who are well-equipped to answer the questions. And so we look forward to the question and answer session. I wanted to begin to get us going, turn to a question that relates to treatment of low significant safety significant issues that potentially impact operability. And for context, as you're well aware, the NRC regulations and plant specific operating licenses, including technical specifications, establish requirements for structure systems and components to ensure that plant operation does not pose an undue risk to public health and safety. And when a degraded and non-conforming condition associated with one of those structure systems and components is identified, a prompt evaluation needs to be conducted to determine if equipment can continue to perform its intended safety function. So recognizing when equipment is in a degraded and non-conforming condition and then conducting a timely operability determination is a critical aspect of a licensee's safety responsibilities. Now, all of that is a long-winded context to get to some specific questions that we're going to ask. For the NRC mark, the industry contends that inspectors continue to challenge the operability of structures, systems, and components that perform a function in response to very low probability events or that are associated with low risk significant non-conforming conditions, such as minor vulnerabilities to external events like tornado-generated missiles, seismic events, and flooding. And that this has resulted in licensee entry into shutdown action statements associated with the plant's tech specs that is not warranted by the significance of the issue. And so the question is, what's the NRC's perspective and what action is the NRC taking to address those issues? And before you answer, Mark, I want to also tee up sort of the parallel question for Fatty. The NRC continues to identify examples across the regions where licensees have not recognized that a degraded or non-conforming condition exists and or initiated timely operability determination to ascertain whether degraded or non-conforming equipment can still perform its intended safety function. And this concern is not limited to low safety significant or low probability events or degraded or non-conforming conditions, but rather the NRC observed trend applies to a broad range of risk significant equipment prescribed in the plant's technical specifications. And so, Fatty, I want to know from you, do you share that perspective and what's being done about it? So let's start with an answer from Mark. Thanks, Mike. Just a couple of things that I wanted to add to provide some additional context regarding the operability determination process. Before I speak more specifically to what we're doing as an agency to define how best to approach addressing low risk significant non-compliance issues. Many of you know when you have an inoperable or I should say a degraded or non-conforming condition of a structure, system, or component, you have to assess whether that particular piece of equipment is able to perform its intended safety function as defined in the current licensing basis. And for those of you that aren't fully familiar, what do we mean by the current licensing basis? It's that set of NRC requirements applicable to a specific plant plus the licensees docketed and currently effective written commitments for ensuring compliance. So there's a two-step process that licensees use when they need to conduct an operability determination to determine whether a specific piece of equipment that is described in the technical specifications can still perform its intended safety function. That first step is an immediate operability determination, which is conducted by the operating shift on duty at the time. And then many times there may need to be a more detailed analysis that needs to be conducted as part of the prompt operability determination. The operability determination process is purely deterministic in nature. You basically have to answer the question as the structure system or component meet all aspects of the current licensing basis, including all postulated initiating events based on the best available information at the time of discovery. You're not allowed to bring probabilistic risk assessment into that process because a probabilistic risk assessment, when it looks at the probabilities of currencies of accidents or external events, is not consistent with the assumption that the event occurs and is therefore not acceptable for making operability decisions. However, the PRA results can be used for determining the safety significance of structure systems and components. And that plays into the timeliness of when you need to complete the prompt operability determination and timeliness of corrective actions. So with that, let me talk about how we are approaching this issue. When you look at our enforcement policy in the description of adequate protection standard, there's reference to the NRC having the authority to exercise discretion to permit continued operations despite the existence of a non-compliance, where the non-compliance is not significant from a risk perspective and does not, in the particular circumstances, pose an undue risk to public health and safety. When non-compliance with NRC requirements occurs, the NRC must evaluate the degree of risk posed by that non-compliance to determine whether immediate action is required. So in that context, the process that the staff envisions and is working with the industry to more fully formulate involves developing that risk-informed process that would ensure that the level of licensee and staff resources applied to a non-compliance issue correlate to the potential risk and safety significance of the issue. The staff envisions that this approach would first focus on evaluating the risk significance of the non-compliance. If the risk significance is determined to be low, then the staff interaction with the licensee would focus on establishing a reasonable timetable for corrective action by the licensee combined with implementing appropriate interim compensatory measures that would maintain adequate safety while the corrective action is being taken. The approach would include enforcement discretion, potentially for a long duration, to provide the licensee adequate time for implementing corrective action. And that approach is envisioned to be an improvement over the current practice and that it would eliminate the need for urgent actions, which is necessitated by entry into short duration technical specification action statements that are taken for low risk significant compliance issues. So, let me tell you the status of that particular effort. There was a public meeting with industry back on February 3rd and some key items that resulted from that meeting where industry is interested in this initiative. There's high industry interest. The industry proposed that we hold the workshop to provide a better definition of the project statement. And this would help identify issues that would be candidates for the new process. At that workshop, there would be the desire to work through some sample issues, both NRC and provided to see how the process might work. And there are a number of questions that still need to be answered. What's the pedigree required for licensee's probabilistic risk assessment? Does the low risk have to be quantitatively demonstrated? If quantitative, where do we set the bar for low risk, what is the threshold for issue inclusion? And I'll give you an example of what I think is a clear issue that has low risk significance but represents a non-compliance issue. And this is an issue that has been identified at some sites in region four. And that's when you have electric cabinet doors that are open for some period of time. And we've had inspectors ask, where is your operability determination to address the seismic vulnerability? Well, obviously the probability of a seismic event during that limited period of time that those doors are open because there's maintenance activities being performed would dictate is there a better approach there than you need to immediately declare the equipment inoperable and enter the associated tech spec action statement or initiate compensatory measures. There is at least one non-governmental organization that has engaged us questioning the advisability of this proposed process and the staff is proposing an answer to that challenge. Next steps going forward. We'll be working with the industry to plan the workshop, tentative dates. We're looking at late March to mid-April. And then following the workshop, there would be a procedure that's drafted and routed internally for concurrence. There would be briefings of management as appropriate and then we'd hold a public meeting to share with the industry and obtain feedback from both the industry and the public regarding this proposed approach. The goal is to have a process we can pilot by the end of the year. So that's what we are working on right now to address those issues that involve very low, risk significant, low probability of occurrence of the initiating event that would require that equipment to be operable. So that's where we are and look forward to any questions you might have when we have that opportunity here about this initiative. And from an industry perspective, we do share the, a college and share the perspective that we do need improvement in operability determination. We need to improve our performance and operability determinations. And one of the actions we're taking as an industry is to develop a guidance document for operability determination process. And a focus of this guidance document really is to provide clarity, refocus, make sure we're getting back to basics and focus on safety and simplicity. Energy, Tom O'Connor is the sponsoring Chief Nuclear Officer for this guidance document. And we started this effort last winter and we expect to issue it for comments by August of this year. And also we expect to have this guidance document for NRC enforcement, NRC endorsement by the end of the year. That's one of the actions we're taking. Also other actions we're taking is that we do share with each other. One of the great things about our industry and one of the strength of our industry is that we are ready to jump in and help each other, ready to jump in and share with each other. So as we have issues with operability determination, we share that operative experience among each other and we learn and we get better as a result of it. And also we have been conducting training and educating our people and making sure that we continue to improve our performance. And as we issue this document, we will have additional training and education to make sure we continue to improve our performance in this area. We do acknowledge and agree that it is very important that we keep open dialogue with the NRC and the development in this guidance as well as in addressing this issue and making sure that we continue to improve performance. And then in a day, our focus is the safe operation of our nuclear energy facilities and protecting the health and safety of the public and that's what we're focusing on. Okay, thank you very much. All right, let's turn to a different question. This question relates to the significance determination process and I'm gonna ask that Cindy and Tim take this question on. The context of the question is that we've had some runtime, obviously with the significance determination process. The program, the reactive oversight process is mature, 15 years of implementation. Yet in 2014, we conducted an examination of the SDP to figure out if there were ways that we can improve that process. And we established a working group, that working group has conducted a look at the significance determination process and in fact, that working group has identified four major areas of enhancements, including revisions to the SDP, performance metric, implementation of an inspection finding review board, use of integrated risk decision making and improved interaction with licensees. And so the question that I wanna tee up for both Cindy and Tim is, what do you see as a primary challenges to the effectiveness and the efficiency of the significance determination process and what are your thoughts about how we could or should address them? Cindy, do you wanna start? Thanks Mike, good morning. As we always like to do, we always like to examine our processes and so this is no different that we're looking at the significance determination process and we certainly have believed it to be effective but in this time, I think we all are looking at ways we can be more efficient, faster and with less resources as always a good goal. So that's where we are and we're looking primarily on the timeliness piece of it and we do have a history of, I will say a few outliers where it's taken us more than a year to come to a resolution of what the significance of a finding has been. So we're looking heavily at timeliness and it's important that we're timely because we have a desire to certainly be assessing current licensee performance. It's important that we communicate with our stakeholders what our assessment is and it certainly influences, actually it dictates some of our further inspection activities so it's important that that's being done in a timely way. In general, it does not impact corrective actions, licensees take corrective actions upon identification of an issue but on rare occasion, there could be an associated corrective action that follows the final determination. So for those and other reasons, it's important that we try to improve our timeliness while still maintaining the quality of our decision making. So a few of the things that the working group is looking at and I'll let you know there's a full discussion of this tomorrow at a 1030 session here at the RIC. So plug your attendance at that one as well. But the working group is looking at a 255 day start to finish of our determination process and that changes our start on the front end of our metric where sometimes we've done a fair amount of assessment or inspection work before the clock starts. We're now looking at starting the clock at, maybe there's an event that is driving the finding or maybe there was something in the corrective action program or some other form of inspection. So we'll be starting that 255 day clock earlier. There'll always be a few exceptions and we recognize some complex issues may take longer than that but that's what we're shooting for. We're also looking at increasing senior management involvement earlier on our part. Mike made reference to a review panel that would be led by division director is what's being considered currently to really ensure we have that engagement of the senior NRC manager up front that then could lead to a dialogue between NRC senior manager and licensee senior manager earlier in the process. But I think one of the main issues and one of the biggest challenges for us and I'm very interested in Tim's perspective on this is the amount of information we get and we receive from the licensee when we get it, how we assess it and how much is there. We're certainly not intending to create research projects out of every finding and there's this balance we all have been struggling with and how much information, when do we get it, how it's assessed before we get to a final conclusion. So I think that in our maintenance of the quality of the decision is a big thing that we need further dialogue with our stakeholders on and ensuring we get the right amount of information to make the right decision. And it'll be critical that it's not only the inspection staff that's interacting with the licensee but our risk analysts at both the NRC and the licensees as well. We have heard that there is a concern that we may use more qualitative factors through our appendix M process and appendix M refers to manual chapter 0609 that defines our significance determination process. Our past has been about 13% of our cases have used appendix M, so it's not a large number. Actually many of those also were an external flooding. Hopefully our external flooding findings will be in the significant decline based on all the work industry and the NRC has done. But that was a case where we didn't have a SDP that will fit, so we needed to use appendix M. But the new streamlining process has not a defined outcome of whether we will or won't use qualitative factors more. But there is a separate look being done at appendix M to look at our entry conditions for use as well as the guidance. So that's a parallel path, but they do certainly intersect. The next steps are further public communication and information and engagement on the process and also we are planning to pilot whatever change process we have get this year in 2016. And again, more discussion tomorrow at the 1030 session. Thanks. Thanks, Cindy. Yes, I think from our perspective, the most important thing that we have to preserve is we've got to get it right. So we fully support and embrace the efficiency that we're trying to get out of the process and we realize that that's gonna be important for the licensee to have a change in behavior and action to supply the data more efficiently to the regulator and then the process that would feed the shorter process, the most more efficient process. We look forward to the draft documents to look at those and provide our input to the process as it's being built. We are cautious about increasing the use of the qualitative information. So, as you said, the appendix M is being looked at and I think that's a very important part of this is to make sure we get that right because we don't wanna risk go to the qualitative piece just to speed the process but not get it right. So we do have some caution or reserve feelings on that. I do like the idea of the inspection board or the inspection finding review board. I think that's gonna bring some consistency and some rigor to the process that will not only help ensure the quality is there but also the sooner that that is acted upon, it feels like that would really help motivate the process to go a little bit more smoothly. I think we need to, there was some discussion in previous conversations about how this would be rolled out too. And I think my opinion on that is we had to use case studies or test examples, if you will, versus rolling out the modified program and applying it to real, to actual findings because since we're manipulating that process for efficiency and if we were to be dealing with someone's real findings, we may not get it right while we're working our way through that pilot program. So I would be interested in supporting however we can from a licensee standpoint more of a tabletop or a test case kind of validation of the revised process versus using actual findings. So I'm very interested in it. We're very interested in the industry. We understand that our part of it is gonna be to turn that data around more efficiently and we look forward to reviewing those documents and moving forward. Thank you guys. So let me just ask, I'm curious, given the topic, how many people have been physically or have been directly touched by AppendixM, know what we're talking about with respect to AppendixM, just raise your hands. Okay, and then how many people have been satisfied with that experience? I wanted you to keep your hands up. So, okay, all right, okay, all right. I just wanted to do that. I was looking at the guys over and to the right of me who are working on making that process better so I wanted them to have that visual. Good work. I should point out that the commission has directed that as a part of changes that we might make to the SDP that we would pilot them. So we are gonna be moving forward in a thoughtful way, particularly as it relates to work that we would do on improving our consideration of, I guess I would say integrated risk, I guess is how I would refer to that particular piece of that process, improvement. I'm gonna shift gears now and talk about Fukushima, post Fukushima. Obviously, we've had already a lot of discussion in various sessions on Fukushima. Of course, Friday marks the fifth anniversary of the earthquake in the tsunami. And by the end of the year, most plants will certainly have complete implementation of extensive modifications and procurement of mobile equipment and other actions to significantly improve, I would say, the safety of U.S. plants to be able to deal with a similar sort of an accident. The inspection activities that we are planning are beginning to crank up, if you will. We're conducting inspections throughout the year and we'll be conducting inspections next year. And so just a question for Dan and for Fadi. Dan, first, what is the NRC doing to ensure that the inspections of the Fukushima-related enhancements are conducted in a manner that recognize the differences between the design basis and beyond design basis. That's a first part of it. But also, how do we promote consistency and predictability in this area? So Dan will take that question and then Fadi, what plans does the industry have to share lessons learned? And particularly, lessons learned based on what comes out of NRC inspections as we go forward. So Dan, you wanna start? Yeah, thanks, Mike. So a little bit more context. In March of 2012, the commission issued orders to all licensees. You've heard a lot about the FLEX program or mitigation strategies that the industry calls at the FLEX program. The other order was the spent fuel pool level instrumentation that would provide indication of level all the way down to top of fuel and provide remote indication to assist operators in an accident to ensure that the spent fuel was adequately covered and cooled. And these orders were required to be implemented by the second refueling outage after the guidance was issued and in no circumstances greater than later than December 2016. So most licensees, most units have completed this work. Some sites are multi-unit sites or have their second unit or the last unit at the site completing the implementation either this spring in the outage or in outages in the fall of 2016. But enough of them have completed that we have started to do the inspections. The question of how do we, the FLEX strategy is the question indicated a beyond design basis activity. It's not subject to the treatment of the equipment and of the connections at the level of an Appendix B top level safety system. So how do we make sure that our inspectors understand those distinctions as they're looking at how these procedures are maintained, how the training is done, how the equipment is stored and so forth. And that really has been built into the process from the beginning to start bringing our people up to speed. At headquarters, they were engaged very early in the process, in the development of the guidance and then in the licensing approval of the licensees strategies. And as they went through that process, there were several steps in the process. First, the licensee provided a plan for how they were gonna implement a strategy and it didn't have a lot of the design details of how that was gonna be implemented but it described where connections were gonna be, what types of equipment would be, what the capacity of that equipment would be, how it would be stored. And the staff produced, and headquarters produced what we call the interim staff evaluation that bought into the plan. And as part of that review, there was an onsite audit that was conducted by headquarters licensing people and the regions sent people to accompany those and that was kind of the first step to start bringing regional people into an awareness of what was going on in implementing these strategies. In parallel with the reviews that were ongoing, we developed the temporary instruction that will guide the inspectors on the full implementation inspections. The regions were involved in the development of that temporary instruction. And the first unit to achieve compliance was actually the new unit, Watts Bar Unit Two, was required to achieve compliance prior to fuel load. So they were the first one that got the inspection under the temporary instruction. And inspectors from all of the regions came and went to Watts Bar and observed and participated in that activity so that they could see it being implemented and get a common frame of reference for the further implementation of the TI in each of the regions. So now that licensees are completing implementation, that when they've come out of that outage and they've completed their implementation, they provide a letter to headquarters certifying that they have completed implementation of the order. At that point, the staff and headquarters, the licensing staff completes the safety evaluation that establishes the licensing basis for the flex strategy and the spend fuel pool instrumentation going forward. And that safety evaluation will be a tool that will guide the inspectors. So when we talk about the difference between design basis and beyond design basis, that is a tool that will guide the inspectors in what is the accepted licensing basis for each facility, because given the uniqueness of the facilities, each of them has a fairly unique approach to the strategy. And so to ensure that there's a shared understanding of that safety evaluation and how it's applied in the temporary instruction, a member of the license review team will accompany the regional inspectors in implementing the temporary instruction so that we ensure that alignment remains for that site relative to its licensing basis. And then finally, we'll be having a management review panel. I think it's being called the Inspection Findings Review Panel. Any finding from any of the inspections at any site is gonna come to this review panel which will consist of managers from NRR who've been involved in the development of the guidance and the licensing process as well as management representatives from each of the four regions. So all of us will be together looking at the findings and ensuring that we are applying the guidance and the requirements consistently across all the regions. Thanks. Eddie. I mentioned earlier that one of the strengths about our nuclear energy industry, or one of the great things about it is that we readily share with each other and we readily help each other out. And in that spirit, we have a number of avenues where we share the lessons learned with each other and making sure that we are learning and continuing to improve every moment or every day. And so a couple of the avenues we have is that through the coordination, through Nuclear Energy Institute, we have a weekly conference call with the Fukushima Project Implementation Leads and we share the lessons learned, not just inspection lessons learned, but also other lessons learned from an implementation standpoint and we make sure that that continues every week and make sure that we're learning from it. Also, from a senior leadership of the industry, we have a number of forums where we share lessons learned with each other. As a matter of fact, on Monday we had the ANSIAC meeting that's the Nuclear Strategic Issues Advisory Committee meeting. It's a chief nuclear officers as well as senior leaders from NEI and INPO and making sure that we share with each other in terms of the lessons learned and continue to get better. Also, we're looking at the NEI webpage and making sure we expand that webpage and add those lessons learned so it's readily available for everyone. And then the most important avenue we share lessons learned is that we pick up the phone and call each other and talk to each other and make sure that we're helping each other get better. Okay, thank you very much. I want to go to a question that we got that I'm gonna ask Mark to answer. It really is a question I think directed at the NRC staff and it's regarding safety culture. And the question is, the safety culture policy applies to the nuclear industry. How does the NRC apply safety culture policy and to its regulatory inspection and licensing activities? And so Mark, would you start that answer and then if others wanna weigh in, feel free to. Yeah, thanks, Mike. I would offer that while the safety culture and policy statement does not apply to the NRC per se, we are very focused as an organization on safety culture. We have, I think it's every three years, the Office of the Inspector General conducted safety culture and climate survey and that looks at a number of attributes with respect to how do we conduct business internal to the NRC? How do we engage with external stakeholders including members of the public and how do we interact with those entities that we regulate? One of the key aspects of healthy safety culture is the staff's confidence that they can raise an issue or express a differing view and not be subject to any adverse action or repercussions as a result of that. And I know that we, as a management team, strive very strongly to ensure that staff have a comfort level regarding raising issues. One of the things that I try and profess in region four is when it comes to decision making, we want the views of everyone to be considered and then clear feedback provided on the basis for the decision and how individuals' particular input was considered in arriving at a decision. With respect to how we interact with licensees and members of the public, we wanna abide by our values, integrity, service, openness, commitment, cooperation, excellence and respect. And respect is, relates to how do you interact, how do you communicate? We hold ourselves accountable to those values. We are very focused on the aspect that behavior matters. And we approach our regulatory responsibilities with a trust but verify. Well, how you go about engaging in that verification process? Are you clearly communicating issues to licensees? So there is a shared understanding of what the particular inspector has determined is the regulatory or safety significance. And we do have what we call objectivity reviews where we have first line supervisors who will observe inspectors in the field and will evaluate how they go about implementing the inspection process. And there are procedures that govern the inspection process as there are procedures that govern licensing reviews. So those are just some thoughts that I would offer. Thanks. Anyone else wanna weigh in on that? No, no takers? Okay, well Mark was very thorough as he always is. So I wanna switch gears and retie up the topic of project AIM, again recognizing that we've had a lot of discussion on this topic, certainly in this RIC. So the agencies embarking on or has embarked on an initiative that this project AIM we're well underway with respect to that initiative as you've heard in other sessions. Of course the nuclear industry is facing similar challenges and has embarked on a very sort of an analogous sort of activity delivering the nuclear promise. And so the question that I have relates to first Kathy and then Tim, what's your perspective Kathy about project AIM and how will the project ensure that we successfully overcome challenges, expected organizational challenges, fiscal challenges resulting from changes in the regulatory environment? And how will we do that while continuing to maintain our focus on safety and security? And then for Tim regarding delivering the nuclear promise initiative and its objectives, how will the industry ensure that the objectives or the promise are met in a manner that doesn't diminish safety and security? So again very parallel questions on parallel initiatives, Kathy first. Thanks Mike. Well I do welcome the opportunity to discuss project AIM from the regional perspective I think in many of the commissioners and the chairman's opening remarks. They touched on project AIM as well as there was a session yesterday on project AIM where you heard about the goals of the project from the agency level but as you would assume the goals at the regional level parallel and actually are fully supportive of that. What, if you recall back to what we've been hearing is there have been the rebaselining efforts and while most of that work has been done out of headquarters, all the regions have been very heavily involved in any of the decision making at the staff level that's been made and in the prioritizing of the work that has been done. Chris Kennedy, Mark's deputy regional administrator supported the regions on that meeting and the effort of reprioritizing and forming some of the elements and the material that went into the commission paper that recently contained staff's recommendations with regards to the rebaselining effort. If you look through that list a lot of them have to, the actions have to do with rulemaking activities, administrative support issues, travel, training but you do see examples in there that pertain directly to the work that the four of us are overseeing. Some of the examples that you see are the stopping mid-cycle reviews, that's one of the items that's in the near term, the six month, another one is a recommendation in reducing resources in the construction area which that one pertains specifically to my region, also looking at efficiencies in the fuel cycle. I bring up these other business lines just to say the reductions in the rebaselining efforts go across to all of our business lines. Then we touch on efficiencies in streamlining the significance determination process as Cindy mentioned and again another plug for tomorrow's session and then another one to mention, again these last two are in the longer term, the 18 month period, efficiency is in the reactor inspection report documentation. As we've looked at the proposed reductions, really we're looking at from our standpoint at the region, are we able to continue to carry out our safety and security mission and the answer is yes, we think we are able to do that with minimal adverse impact. Now that's not to say that there won't be changes in the regions and how we go through our day to day operations but from the standpoint of meeting our mission of safety and security, we're very confident that we'll be able to do that. One of the quotes I think that I would take away from yesterday's session and I think it might have been Maria that had said it but it applies to us as well as everyone, the NRC as well as all the industry and other representatives in the room. I think the key for us is really having the right person in the right place at the right time and this goes directly to making sure that we're identifying the critical skill set that we need to perform the areas and while I may in region two have that critical skill set, if Cindy needs it in region three, that we can share resources across the different lines and that's how I think we'll meet the future. We're doing that in several areas already as we're sharing inspectors between different regions, license examiners between different regions but that's one of the keys that one of the tools that we'll use as we move forward in carrying out, making sure that we're meeting our missions. Thanks, Kathy. Yeah, for delivering the nuclear promise, our objectives are to continue to build on the safety and the reliability piece. We think that we've done that well over the last decade in terms of continually improving our reliability and safety at the stations. However, what we've kind of left untouched or haven't focused on as much is driving the efficiency into the way we do that and therefore controlling our cost and our cost of escalated overall about 28% over that same decade and it's to the point now where economically, many of the stations without action will become very challenged in depending on what market they're in and their viability to remain economically viable to continue to do that, to operate. So the focus is in every case balanced with ensuring that we're not going to reduce safety or reliability through the initiatives. That's viewed at the steering committee. We have 35 initiatives that we intend to roll out in 2016, 2017, and each one of those is reviewed by the steering committee, which is 10 CNOs, an executive from NEI, an executive from IMPO, to make sure that the approach that we're taking is not going to reduce safety or reliability. There's then a webinar that would be used for each of these to inform everyone on how to implement it by maintaining that focus on safety and reliability. We have assessments at the stations that will be done, assessments across the fleets for those stations that are in fleets, and then we have IMPO, who is traveling with us during this whole journey, and they're making adjustments to ensure that we're not limiting our look or our scope in terms of our pursuit of excellence. So as they come in and they do their evaluations, their assist visits, as they trend information for any individual station or the industry as a whole, there will be thresholds that will introduce additional challenge to make sure that we're addressing any early signs of decline or adverse results that we were not expecting. So we've built quite a bit of check and balance into the process, and we'll be rolling each one of those out with using a consistent methodology of the training webinar, if you will. They'll all come out in a bulletin form with very specific guidance on how to implement. Some of them, obviously, are easier than others. We have rolled out four of such bulletins. We approved six more earlier this week, and those will be released in the next few days. So we'll have 10 bulletins on the street here within a couple of days that will begin our delivering of the nuclear promise. So we've got a pretty significant goal of reducing all-in costs by 30% across the industry. We've made good progress on that in the last several years, and I think we've got a very intriguing set of 35 initiatives that are gonna help us get a good portion of that 30% over the next two and a half years. Great, thank you, Tom. I have a couple of questions that are related, so I'm gonna tee those up. I think they are directed at the NRC, so you guys will get a chance to decide who you want to weigh in on this. They both relate to consistency across the regions. So one question is, how are the NRC's efforts to provide consistency in the process of addressing low-level findings being effective? I'm sorry, how are the NRC's efforts to provide consistency in the process of addressing low-level findings being effective, or how effective are they, I guess I would say, and what have been the results to date? And then the second question, very related topic, or same topic, what are you doing as regional administrators to address the significant differences between regions on the number of green findings or violations, as noted in a recent GAO audit report, and what are you doing to approve the consistency of inspection and decision-making between the regions? How can headquarters staff help you with this? So, who wants to take that? Nobody. Dan Dorman, the issue arises from a GAO study, actually a couple of years ago that found, I would say statistically significant differences between the regions on the numbers of low-significance findings. They, for the greater-than-green findings, they did not find an inconsistency. A year or so ago, there was an effort that was led by NRR, Division of Inspection and Regional Support, to understand what those differences were. They developed some, I would say, tabletop scenarios. They described performance deficiencies that might be discovered in inspection and the circumstances surrounding that, and brought in experienced inspectors from all of the regions, and had them independently develop the finding associated with those scenarios. And I think the area that that focused us on the most greatly was the minor, more-than-minor distinction. So the action out of that is to develop into the manual chapter additional guidance and examples to help inspectors and their management in the regions to be more consistent in applying those standards. I think we're still early in that process. It's too early to say how effective that is, but that is the steps that we're taking on that. And just one thing to add. Another factor in why there have been differences in the number of green findings gets to credit for identification. When is it self-revealing? When is it licensee-identified? When is it NRC-identified? We're looking at, if you identify an issue, as part of a surveillance test. Should you get credit for that in terms of licensee-identified? Or what if the deficiency that was manifested during the surveillance test was not part of the planned surveillance scope? So there's been quite a bit of discussion between the regional offices and the program offices, the Division of Inspection and Regional Support that is led by Scott Morris, on how to resolve some of the differences in credit for identification. And then the specific question, how are we as respective regional administrators engaging to ensure consistency? I can speak to my involvement in processes in region four. We have inspection debriefs. Every resident report, quarterly inspection report, is debriefed with DRP and appropriate DRS management in attendance. And the senior resident and resident inspector explain the findings that have been identified and the basis for determining why they were more than minor. We have the Division of Reactor Safety has inspection debriefs. I've attended those debriefs and there have been times where we have decided that the finding was not appropriately characterized and there were some changes made, but I would offer, by and large, with few exceptions. It's been my experience that the more than minor determinations have been appropriate. And so that's one thing that we're doing. And then the other thing is when I listened to the mid-cycle and end-of-cycle discussions, there's a very extensive collaborative discussion there to ensure the characterization of licensee performance is appropriate. And another thing I would offer is that we did relatively recently revise the criteria for determining a cross-cutting issue there and their deterministic backstops. But I think one of the industry concerns was if you have more green findings, you have more findings with a cross-cutting aspect there and you potentially cross the threshold for substantive cross-cutting issue, that criteria has changed. And as you know, it takes, I think, six findings with the same cross-cutting theme and then human performance as an example, a deterministic backstop is 20 findings. So for me, the most significant outcome of that GAO report was consistency across the regions regarding greater than green findings. And I hope that we don't lose focus on that because that to me is really the most important aspect there in terms of consistency across the regions because that results in obviously resource expenditure by the industry to address those. Maybe just to add a little bit more, this is Cindy. We've been trying to do a better job of pre-planning our inspection activity from the perspective of when we enter into new areas. For example, as Dan mentioned, the post-Fukushima temporary instruction will be doing. We're creating into the process a cross-regional with NRR support process to screen all of those issues such that we have and develop a more common understanding of the more than minor, minor threshold. So I think we're trying to project a little bit better when we're gonna need these types of integrations, if you will. And I think that is gonna serve us well and has served us well in the number of areas we've done it in the past. Another thing, we have opportunities where we do benchmarking cross-shared resources across. We've done some more of that. And we've also encouraged and have ongoing counterpart conversations at various levels through the organization. And they're very focused on this as well. And so I think we're trying to do a few more things proactively to get ahead of it and build it into our process instead of waiting to see if the outcomes are different. And then, Mike, if I could comment. This is Kathy. For those of you in the audience from Region 2 who are aware that I've only been in this position about six weeks. So this is a great opportunity for me to engage in this area. More of an anecdotal story than a specific example as Cindy and Dan and Mark have given. When I was assuming the position in Region 2, one of the things that was very early in the process brought to my attention was this GAO report. And I've been able to, with fresh eyes, be able to come into the region as well as into the program areas. And really one of the areas that I am focusing on is this. And I think it's a testament to the fact that this is very key on all of our minds and that we are working together in just this energy that's created amongst the different regional administrators and bringing, drawing the attention to this very important matter. Okay, very good. I have a couple of questions that are follow up to our, I think, earlier discussion on the significance determination process. And one is for the industry. So I don't know, Tim, if you wanted to start with this one or in fact, you guys decide. As the NRC makes efforts to streamline the enforcement process, SDP specifically, to improve the timeliness of finding disposition and reduce resources, licensees and NRCs used to finalize significance determinations, will the industry be willing to reset the inclination to reanalyze and to challenge final determination? So will the industry be willing to reset the inclination to reanalyze and challenge final determinations? Is the question, Tim? Fatty, that sounds like a good one. Yeah. Well, part of the changes that we will make is that as an industry, we'll have to be and will need to be and we are willing to be more timely and responsive in doing our evaluations and making sure that we bring it to closure the right way. And we are interested in focusing our efforts on safety and reliability and risk and wanna make sure that we're doing the right evaluations and the right reviews in a timely way to bring that to closure. So we stay focused on safety and reliability and risk. Yeah, and I would just add that I think in the process, as we look at the process enhancements or revisions, we would entertain that opportunity to do less of that or not do that any longer if that's the case, but the process has to be built to support that kind of outcome. So we'll be very interested in being engaged in that review process and providing that input when that comes around. Thanks, Fatty. Thanks, Tim. Also, related to the significant determination process, this one for you, Kathy, as a follow-up. Has the NRC considered using some of the same new SDP process enhancements that are being considered for the reactor oversight process in the construction reactor oversight process? For example, the inspection, review board, the early senior manager interaction, so on and so forth. So thanks, Mike. Very good question. In Region Two, we really have the opportunity to benchmark the operating against the construction, the construction against the operating on a day-to-day basis. So while we're working routinely with NRR on the operating side, we're working routinely with the Office of New Reactors, also on a daily basis. So we're well aware of the activities that are going on with regards to the operating reactors, and we are considering that with regards to the new plants and how we can bring best practices from both sides. And we want to pride ourselves in being a learning organization as even beyond just the reactor oversight program if there are things that we can bring from one side to the other and vice versa. We do that. Also, we really take it so far as even in Region Two, unique from the other regions, we have the fuel facilities. Again, there are lessons learned operating experience that we bring between all three different business lines, large business lines that we have in Region Two. Okay, thank you. There are a couple of questions related to decommissioning, and so they're, I think, and they're directed at Dan, so I'm gonna tee them up. And Dan, you can take them in any order. The first is Region One has experience with decommissioning of public utility-owned plants. What is your perspective on the decommissioning of merchant plants and their inability to rely on rate payers for decommissioning costs, I guess is the question. And the second question is, is there any thought around restructuring or changing Region One organization and for approaches based on large numbers of plants in Region One going into decommissioning? Okay, so Kathy gets to build them. Unfortunately, the deregulated markets in the Northeast, as you all know, are very challenging for the merchant nuclear power plants, and we have had the permanent closure of Vermont Yankee at the end of 2014. We have announced intentions for permanent closures for Fitzpatrick in January of next year for Pilgrim no later than mid-2019 and for Oyster Creek by the end of 2019. So to the question of thoughts around restructuring or changing Region One, clearly we know that as those plants transition from operating status to permanent shutdown and decommissioning, we will be getting smaller. The next one that will impact us is the closure of Fitzpatrick, and so that impact will come next year. And so that is in our thoughts in terms of how that will impact our organizational structure. I think at this point, it means we'll get a little smaller and how we do that specifically within the organization is still under discussion. The other question had to do with the distinction between a publicly regulated utility and the presumption there is that even in a decommissioning status, that utility could go to their Public Utilities Commission and get approval for some fee to be passed through to a rape payer if there was some shortfall in the decommissioning trust fund versus Vermont Yankee. There's been a lot of discussion, a lot of interest from the community and from the state around whether the trust fund is adequate. The decommissioning trust fund for Vermont Yankee is upwards of $600 million. The estimated cost of decommissioning the facility is upwards of $1 billion. There was, if you heard Commissioner Barron this morning talking about the decommissioning rulemaking, this is an area of great interest in the decommissioning rulemaking is the decommissioning trust funds and what's the role that the state and local communities can play in helping in the decision-making process in the decommissioning. Where we are right now is when a plant enters decommissioning status, the frequency of updates to the NRC on the decommissioning trust fund status is the frequency is increased to every year. There is a small cadre of financial experts in the Office of Nuclear Reactor Regulation that examine the balances and the investments of those funds which are managed by independent trustees and examine those from the standpoint of the licensees decommissioning strategy and decommissioning cost estimates to assess whether there is reasonable assurance that those funds will be invested and will grow in a manner that will support that decommissioning plan. In the case of Vermont Yankee, they have indicated a plan to use the safe store option that exists under the current regulation that allows them to wait as much as 50 years before beginning the dismantling and decommissioning. I think the projection based on the existing trust fund and the projected growth of the trust fund is that they will begin that work in the 30 to 40 year timeframe and by rule they have up to 60 years to complete that work. So based on our review of their trust fund, their investment and the projections of the growth of that fund and the cost of the decommissioning activities, the staff has reasonable assurance that that fund will support the decommissioning of that plant. We'll have similar reviews, I'm sure, as we go forward with the other merchant plants as they enter into decommissioning and we will continue with the decommissioning rulemaking and take that wherever the commission takes us. All right, very good. Thank you, Dan. Tim, this question is for you and I think you'll be able to answer very quickly. Actually, I should point out that Tim's first name is not really spelt with two M's. We can blame us for that. But this question is to Tim and it is, are these 35 initiatives talking about delivering the nuclear promise? Are the 35 initiatives you talked about publicly available? And let me just broaden the question. How much of delivering the nuclear promise is publicly available? If a member of the public wanted to go find it, what would they find? That's a good question. I'm not sure. I know that we do have some communication materials that have been developed for the public. And in those materials we summarize some of the initiatives that, or the types of initiatives that we're pursuing. The 35 initiatives are on the NEI website, but currently that's for members only. So NEI has a communication plan and we'll take that feedback back to NEI and try to determine how much of it we should be putting out there for the public to view. But there is a document that's been created for public use and public communication of the initiative in itself. Doesn't get down into the detail of the 35 specific opportunities. Okay, all right, very good, thank you. This next question relates to, well, I think should be answered. We're gonna try to answer it by the NRC, but also by the industry. It relates to New Reg 1022 Rev 3. And the question is, that New Reg included a discussion that SSC is not meeting the tech spec LCO is considered not capable of performing its safety function. This caused licensees to submit hundreds of 5072 and 5073 reports that add little value, for example, secondary containment LCOs. What's the NRC doing to reduce this licensee burden? And I guess I wanted to, also an industry perspective if you have one on this issue. That's a good one for them. Oh, would you want me to start first? Okay, I was just gonna add a couple of thoughts. Well, I'm no expert on the New Reg, so I'll tell you that up front. But I think just from a general perspective, if there are items that you think are of little value or low value, those should be things that are brought to the table. And NRC has routine periodic meetings on the ROP. That would be an example. If it's something very specific to a particular licensee, maybe, you need to look, do you need a tech spec change or something that would alleviate the problem. But obviously, you're accountable to your existing rules and regulations. If you think there's something there that's not of value, we've got various processes in which to pursue that. I'm not aware of any widespread examination we're doing to try to reduce 5072s or 5073 reporting. Yeah, for the industry, we're working through NEI really on a process enhancement around operability determinations. So we've got that drafted. We will be seeking NRC input on that document. It will be out in the second quarter for industry to review and comment on and engage NRC on. And our goal is to have a draft that's in real good shape by the third quarter of this year. And so that would help us ultimately treat these kind of issues with more efficiency, more consistency, repeatability, and hopefully it eliminates a lot of the unnecessary reporting and so forth. So NEI's got the lead on that through the licensees. I'll offer just one quick perspective. I think some of these examples may very well fall into that arena that I was speaking to regarding low risk, significant compliance issues. And I mentioned the workshop where the industry and the NRC would be asked collectively to identify examples and helping to define that threshold. And perhaps some of these examples, you're referencing the individual that offered the question regarding 5072, 5073 reports. I assume there are operability decisions associated with those. And perhaps those could be included in that workshop discussion and dialogue. If I could just add one thing there was a mention in the question, I think of secondary containment and one of the particular issues that arose out of that revision of New Reg 1022 was situations where by human error for a matter of seconds, the inner door and the outer door of the airlock are opened at the same time. And that one did produce a large number of reports to the NRC under 5072, 5073. The NRC took a look at the wording in 1022 relative to that and concluded that 1022 was adequate but that some plants had very restrictive tech specs that resulted in those reports. And so there has been an initiative to have a standard tech spec revision that would support that. There are some plants I know in region one that have gotten the change. I think there are some that are still under review. So that adjustment, that's where the adjustment is being made on that specific issue. Dan, just the last we heard that TISTF was due out around June of this year, is that still the timeline? I'm looking around NRI, I'm getting shoulder shrugs from NRI but we'll get back to you on that. But I think that my recollection is at least one of my plants has already gotten the amendment. So, but we can get back to you on that. Okay, thank you. No lifeline takers. No. Okay, no lifeline, right. Okay, this question or these questions actually follow up on the operability discussion that we had Mark and Fatty, so I'll direct them to you. They actually touch on the same issue. Regarding the low probability compliance issues, impacting operability, the process sounds like or the process that we described sounds like a long-term N-O-E-D, which goes against the N-O-E-D intent. Similarly, it sounds like an intrusion of probability into the oppeval process. How do you reconcile this new process with previous agency and industry guidance and expectations? And so the related question, the very same question maybe, is Mr. DePaul referred to a longer duration enforcement discretion for low-risk items. How does the agency envision implementing this? For example, revise the N-O-E-D process, new process, et cetera. Paul offered an initial thought, and then I think Rob Elliott's here in the audience here. I may use him as a lifeline here since he is the individual in DIRS that has specific ownership for this initiative. But the intent here is not to bring probability into play regarding the deterministic operability determination. Thanks. As I mentioned earlier, you cannot bring probability into that equation. Licensees would have to determine the compensatory measures they can take. Is the particular structure system or component operable performance-intended safety function? What we're talking about is NRC inspectors is not focusing a lot of attention on that operability determination that is made by the licensee, but looking at, if we both agree, that it is of low safety significance here, what is the timeframe for correction? Is there discretion such that that condition can continue to exist for some period of time based on the safety significance as determined by bringing a probabilistic risk assessment to the equation? But it is not intended to, if you will, restructure the operability determination process to allow probability to come into play, because the assumption there is that the event occurs and then you have to look at, can that structure system or component provided the appropriate mitigated function? So I apologize if I left you with the impression that we are looking at bringing probability into that OD process, that's not the case. I'm gonna ask Rob if there's anything he wants to add to that. I bet you didn't expect that, did you? Yes, I did give him a heads up, I may use him as a lifeline. So yeah, what Mark said is true. We're not introducing operability into the operability determination process. The concept of whether or not we're looking at NOEDs differently, that's a potential solution path. The devil's in the details about how we work this process out, but one of the ways that we're looking at it that we might implement it is to utilize a different version of the NOED process, and that would probably require notifying the commission that we're changing the way we originally told them that we would do NOEDs. And from an industry perspective, we're still developing this guidance document, and we appreciate your feedback and we'll make sure we're clear in the document in terms of what it is and what it's not, and so appreciate the feedback on that. I just offer the overarching goal here is not to continue to expend agency resources and the industry expend resources on addressing issues that are very low probability, low safety significance here, and so can we carve out a process there which is allowed when you look at the language that I referenced in the enforcement policy for us to disposition issues that are of low risk significance, and that can include exercising enforcement discretion to achieve an outcome that in our view is not putting public health and safety at risk. Okay, a question related to Project AIM or actually more directly related to delivering the nuclear promise, I think it's directed at the regional administrators actually. Economics and nuclear power, economics around nuclear power generation are driving individuals, individual and industry-wide changes. How are the regions ensuring that initiatives like nuclear promise are not compromising safety? So how are you ensuring that those changes are not compromising? I can start, I imagine multiples of us probably want to add into this. It's certainly an area that is of significant interest to us because there are the potentials for performance to be impacted and areas of performance that we regulate. So certainly it's something that's of interest to us. I know in region three specifically we included a discussion about delivering the nuclear promise as part of our end-to-cycle internal meetings to make sure our staff was familiar and we will likely have another briefing on that in an upcoming seminar, but we're making our staff sensitive to the issue and sensitive to looking for could there be negative performance changes with that. Also, we've started a dialogue among some of us just recently about whether we need to do things more broadly in looking at this and the potential for performance so we don't get into see previous question on regional consistency. So we're looking at ways that we want to be thinking about this, but certainly we do have interest in the area because it does have the potential to change performance. I guess I would just add that our baseline inspection program is focused on safety outcomes, not on dollar figures investments to the plants. So that doesn't change. So our focus is still on the outcomes. I would say a related but slightly different issue that we have in region one with the announced closures is we have plants that are gonna potentially operate several cycles where they have announced a closure and that's changing how they're looking at the future of the plant potentially and the types of investments and the frequency of the investments that they're making in the plant. And again, our focus within the baseline inspection is to target our samples in that direction of operations and maintenance and are they doing the things to ensure that the licensing basis, design basis of plant continues to be met right up until the last day and ensure the safe operation of the plant right up until permanent closure. We have flexibilities in our sample selections within the baseline program and we experienced that with Vermont Yankee as they got up to their closure at the end of 14 and we are doing similar things with the other plants that have announced closures. But again, our focus is on the safety outcomes not where the dollars are spent. Tanak, previously when we were talking about delivering the nuclear promise, I had mentioned a document. So this is the document you can find on the NEI website available to the public and it was published in February. So it's an up to date document on what we've shared publicly so far on delivering the nuclear promise. And from a safety perspective, it's our top priority. And through delivering the nuclear promise, our goal is to advance safety and reliability while again in efficiencies. And as an industry, we'll put a lot of checks and balances in place to make sure we stay focused on safety. And so that's our responsibility and we take that very seriously. Very sad one additional comment. I don't see some of the delivering the nuclear promise initiatives being in conflict with our regulatory role. An example of that is, as I understand it, I think you have involvement with this, Tim, the design change control process looking for one standardized process that can be used across the industry. When we conduct our inspection activities we're still gonna look at, is there been appropriate training as the 50-59 process been followed? What is, Dan said, what are the outcomes there? Independent of what is the process that is being used there. So I don't see those at cross purposes. I would expect the process that the industry comes up with to address the same elements that are associated with our design control regulatory requirements would be encompassed in that process that would be used. And where we identified instances where the implementation of that common procedure, if you will, for the design change process isn't implemented adequately, we would write an appropriate violation and safety significance would be what it is based on the circumstances. So I don't see those being a disconnected or a cross purposes per se. I agree, and just to add on that, it actually, if industry goes to a standardized process in the area such as engineering design, it actually could make us more efficient because our inspectors don't have to go and learn 65 different engineering change processes. So I agree that the goals are not in conflict. There are potentials in some areas to actually be complementary, but the reiteration of the bottom line is we're still gonna be looking at the safety performance and that'll be, not where your dollars go has been said, but how the performance is. Yeah, and just to stay with that theme from back to the standard design process, when it's implemented, then we're sharing lessons learned across the whole industry to further improve the safety, the reliability, as well as the efficiency. So where I have my own program now, I can share with others that have similar design programs, we all have exactly the same design program so the lessons learned will come out 100 stations at a time. So we'll be learning more efficiently across the entire industry. Anyone else? Thank you, very good. All right, so this question is for Kathy. Regarding I think AIM 2020 or actually how we move forward I think in the area of construction, our inspection manual chapter 1245 and inspection manual chapter 1252 being combined into one program. And I think that really points to a question of maybe a more general question about how do we, how do you see construction and operations moving forward as units move from construction to operations? Well, thanks, Mike. That is one of the things that we're discussing on a daily basis. So from the standpoint, I'm gonna address it two ways, Mike, one is the qualification. And this does relate to project AIM and this is the agility and the fungibility of our inspectors to cross lines between operating reactors and new reactors and new reactors and operating reactors. And it gets on my comment earlier about making sure that we have the individuals with the right critical skills where we need them and being able to leverage different divisions, different programs within the region as well as between the regions. So we will be looking forward from a qualification standpoint of our inspectors, how can we best accomplish that and then making sure that our manual chapters follow that. Taking it to the even broader step is the aspect of that transition between when does a reactor under construction move into an operating reactor? And we're seeing that now with Watts Bar in that transition. We've, from a structural standpoint within the region, we had a branch that was set up to focus on the construction as we're moving back into operations with unit two at Watts Bar. That will go back into the normal line management and will make us a very small organizational change as a result of that. And with regards to Vogel and Summer, the same thing will be applied there as they move forward and get closer to operating. We're looking at what's the best way on an interim basis to have the region organized to handle it. Do we need, for instance, do we need two sides to the region? One focused on operating plants, one focused on construction plants and asking ourselves, when is the right question to merge those areas? And that's something that frequently I would say, at least at my level, comes up on a weekly basis. And I'm sure in some of my staff's discussions and conversations, it comes up more frequently. Now, with regards to that, those conversations really, we're also having with NRR and NRO because we want to sync any regional movement with regards to organizational structure and who's talking to who, also with how that's handling between the two headquarters offices. So again, there's a plan there, there's discussions going on there and we'll continue. And I think as we move forward over time with the construction of the plants, those questions and firmer and more concrete plans will become even more in the forefront of our mind and rather than be thinking about it on a weekly basis, it will be on a daily basis also. Okay, thank you very much. So there's a question that I'll ask that I just want fairly crisp response to from the RAs. Many of the questions asked are being discussed in detail at rug meetings with your support of rugs. Do you think all RAs should support the rug by attending? If other RAs disagree, please have them explain. So I wanted to just get the rug issues, support RAs question out for you guys to respond to. I happen to think regional administrator attendance at the rug meetings is very important and I have strived to attend every rug meeting that has occurred while I've been a regional administrator in region four and if I'm not able to attend due to a conflict that I can't resolve then I have Chris Kennedy, the deputy regional administrator attend. So I think it's very important that we support those at that level within the regional office. So that's my perspective on it. There's no one down the line. I, we have been trying to support, often it's been at the deputy regional administrator level. I guess what I would say is that, yes, I think we can support those, we should support them if we're ensuring the content of the meeting is appropriate and focused. I think we need to have the right attendees from both sides. So I would say it's dependent on what the agenda of the meeting is and then we should support with the right players. I'm gonna let it skip over Kathy because she hasn't been there long enough to have a rug meeting. But similarly in region one, either I or my deputy attend the rug meetings. If you're not familiar with what a rug meeting is, it's the regional utility group that, it's an industry meeting, typically of the licensing and regulatory affairs managers for an NRC region. And they get together, the region one rug, I think meets three times a year. And they invite us to come and participate for several hours of their meeting around specific agenda topics. As Cindy indicated, there will be different senior inspectors or managers from the region that come for particular agenda topics. But either my deputy or I attend those meetings and I think it's extremely valuable from my perspective to ensure the front office awareness of the issues and concerns that the licensees that we are overseeing have. Okay, there's another question on significance determination process. And I'll just throw the issue out and I'll ask again, NERA or Timor Faddy, if you guys wanna take this on, I think because there are two perspectives on this or two viewpoints on this issue. So the question is regarding potential findings that are greater than green, the interactions between the region SRA and licensees PRA analysts that are open and frank and iterative usually yield more accurate, more timely results. And it asks, are we looking at that? And in fact, in terms of one of the things that we're considering to make that process work better. So I do want you, someone to talk about the importance of open and iterative conversations both from an NRC perspective and from an NRC perspective. Well, I can start, I fully agree that those conversations are extremely important to being able to assess the particular finding. And I think having those open and frank dialogues sooner rather than later is a benefit to all of us in trying to get timely resolution. And it's important, very important on what the assumptions are and things like that. And we may not always agree, but we should understand each other's set of assumptions going into the assessment of risk. And so I fully support having those conversations, having those conversations early and in detail so we at least both understand how we're modeling it and how we're coming to our results. I fully support the open exchange of information between the regional senior reactor analysts and the licensees risk analysts or specialists. I think there have been challenges regarding when we have communicated that we are looking at an issue as potentially greater than green. And so the licensee did not appreciate that's where we were. And so they did not appropriately engage their resources. And then subsequently when we had a communication at a more senior level that we're looking at a greater than green issue that has resulted in the licensee then engaging resources and evaluating the issue. And so I think we have had opportunities where we could do a better job as a regulator communicating why we consider the issue to be potentially greater than green so that the licensee can then engage. And I would offer licensees should be looking at that issue as well and not necessarily wait for the NRC communication regarding that. But we have had a couple of instances in region four where I think we could have had more effective communications. And then I have to acknowledge that there are is variability in the degree of engagement by the senior reactor analysts with the licensee counterparts in risk analyst space. And that's something that we can look at. And we do need to ensure there is consistency across the individual regional offices within a region and across the regions. There are differences there. From an industry perspective, we fully support the open and healthy dialogue early on between the licensee and the senior reactor analysts. And from a personal experience, the earlier on those conversations happen and the more open these conversations, the better we focus on the issue and make sure we bring it to resolution. And our goal is to really safety and reliability and risk. So we welcome those conversations and also acknowledge that from an industry perspective, we can do a lot of work on our end to really open up those conversations up front and we'll make sure that we get better in that area. Okay, very good. This next question and perhaps it's our last question, depending on how vigorously we discussed this issue. How can stakeholders be sure of the NRC's sincerity about reducing resource expenditures on low significant safety issues or low safety significance issues when the agency is forging ahead on low or no safety significant issues such as tornado missile, service life, and open phase and others? So this is clearly directed at Fatty, just kidding. This is clearly one that you guys, should take on our NRC, please. I can start with I guess an NRC perspective. A number of those kind of issues are active in current and region three. I think we're all struggling with our ability to use our resources most wisely. And we certainly are looking at being more efficient. Industry is looking at being more efficient. And so I think it's appropriate that we ask ourselves these questions. I think part of the difficulty is how do you determine how much resources to put on these issues? Because they still are compliance issues and compliance is mandatory. I mean that's the foundation of our presumption of safety is meeting the requirements. Now we all recognize that various requirements have different impacts on safety. That's clear. So we're trying to figure out how best on our part as well as industry's part to use our resources wisely. So it is an issue that we are dealing with if we're trying to become more efficient. We're trying to find a way that we can risk and form that. But we still do have to disposition compliance issues. Well I agree altruistically with we need to disposition compliance issues. But when I'm at a site and I'm talking to the resident inspectors and they seem to be pursuing an issue that in my view clearly doesn't have safety significance. My guidance is I think there are other issues that you could be spending your time focusing on that would have a greater return on that inspection investment in terms of safety significance there. I cannot tell an inspector don't pursue this because ignore the non-compliance. But it's how do you spend your time when you're at a site there and what are you focusing your activities on? And frankly I guess to be remiss if I didn't have the opportunity to say this at least once during this presentation the juice isn't worth to squeeze on some of these issues. It just is not. And so how do you change that culture? Well it takes ongoing engagement. I see Troy Pruitt the division director for the division reactor project smiling. I know he and I have talked and he's had specific discussions with some of the inspection staff like you know hey let it go. Focus on some other things that we think will have a greater return on that safety significance you know that investment in terms of time spent. So I offer that perspective. Well I think that actually was the last question that we'll have time to deal with. I do note that we have three additional very intriguing questions. If the questioners who didn't get your questions answered want to come up or please feel free to do so after this session. I certainly want to take time at the very end to thank Joel Rivera Ortiz for helping us organize this session. I certainly want to thank the panelists. Please join me in a round of applause for the panelists. And thank you. This concludes our session.