 Good morning. It's my pleasure to welcome you back after the break and also to welcome you into this regulatory information conference, the 30th Regulatory Information Conference. I am Michael Weber as Brian recently pointed me out and I am the Director of Nuclear Regulatory Research at NRC. For our next presentation, it is my honor to introduce Commissioner Barron, who began his service with the commission on October 14, 2014. We welcome him to his fourth Regulatory Information Conference. Before serving on the commission, he worked at the U.S. House of Representatives for over 11 years, where he most recently served as staff director for energy and environment for the Democratic staff of the House Energy and Commerce Committee. During his tenure with that committee, he focused on a variety of topics, including oversight of the U.S. Nuclear Regulatory Commission, as a primary responsibility. Originally from the Chicago, Illinois area, Commissioner Barron earned a bachelor's degree and a master's degree in political science from Ohio University, and he holds his law degree from Harvard Law School. Ladies and gentlemen, please join me in welcoming Commissioner Barron. Thanks, Mike. Good morning. It's great to see everyone here. As Mike mentioned, this is my fourth Rick, and so that means this is my fourth Rick speech, and I had great sympathy for our chairman. I think I've gotten there faster than she did because I'm going to admit I am out of clever ideas for an opening. So here's what we're going to do. We are just going to jump right into the cheesy nuclear jokes without any special preamble. We all know they're inevitable, and you heard me right, there are more than one. Multiple cheesy nuclear jokes is how I'm going to go this morning. Think of it as an opportunity for stakeholder feedback. I'm going to share two jokes. You let me know which one you like more by whatever polite-ish means you have to convey that. I get a better sense of your collective sense of humor, and we go from there. Ready? Here we go. We're not going to just get right in. Joke number one. Two Adams were walking across the road. One of them said, I think I lost an electron. Really the other applied? Are you sure? Yes, I'm absolutely positive. I don't write them, folks. Here we go. Okay. Okay. Let's see what you think about joke number two. Why can't you trust an atom? They make up everything. Okay. All right. Based on that response, it sounds like people may have actually preferred the first one. I'm not sure what that says about you as an audience. Now, if you are one of the very, very vanishingly few people who thought both of those jokes needed work, feel free to send some suggested material my way on the comment cards. This is your big chance to wow us. We're not going to read them today. We'll instead save them for a future occasion that calls for a high quality nuclear joke. In the meantime, we should probably get down to business. There are a lot of important issues before the agency right now. Let me start with post Fukushima safety enhancements. Almost every plant in the country has finished the work to comply with the NRC order on mitigating strategies. That order requires plants to have equipment on site and off site to respond to beyond design basis events. Every site also has new spent fuel pool instrumentation in place so that operators have reliable information on the water levels in their spent fuel pools. The installation of severe accident capable hard events at BWR units with mark one or mark two contaminants requires physical modifications to the plants during outages and will be completed by the end of 2019. The remaining flood hazard integrated assessments are due by the end of this year and the seismic probabilistic risk assessments should all be completed by the end of next year. Based on those analyses, the NRC staff will determine whether any additional site specific steps need to be taken to better protect plants from earthquakes or floods. Overall, the NRC staff's focus has largely shifted to inspecting implementation of these safety enhancements and natural hazard evaluations. The pending work for the commission is the draft final rule establishing requirements for the mitigation of beyond design basis events and nuclear power plants. This draft final rule is the culmination of years of work and is a key component of the agency's response to the March 2011 Fukushima Daiichi accident in Japan. The rule responds to near term task force recommendations four and seven by making the requirements in previous NRC orders for mitigation of beyond design basis events and for reliable spent fuel pool instrumentation generally applicable to all nuclear power plants. It requires the mitigating strategies to address each plant's reevaluated seismic and flooding hazards. The rule also responds to near term task force recommendations eight and nine by requiring an integrated emergency response capability and sufficient staffing, command and control, training, drills, communications capability and documentation of changes to support this integrated response capability. To address near term task force recommendations 10 and 11, the rule sets requirements for enhanced onsite emergency response capabilities. The staff submitted the draft final rule to the commission for its review 15 months ago in December 2016. I voted on it last June and agree with the NRC staff that the provisions of this rule are necessary to ensure adequate protection of public health and safety. Unfortunately, the commission has not yet finalized the rule. This delay matters because it impacts the timing of compliance. The draft final rule was written to generally provide two years for plants to comply with the rules requirements with some exceptions and flexibilities proposed by the staff. If the rule had been issued during the summer of 2017, the general compliance deadline would have been mid 2019. Given that the rule be finalized much later than anticipated by the staff, we will need to look at adjusting the compliance timeframes in the draft final rule. Seven years after the Fukushima accident, it is crucial that the commission issue these updated safety standards so that nuclear power plants can meet them without further delay. Power plant decommissioning is another major focus area for the agency. In the last few years, six U.S. reactors have permanently shut down and eight more have announced plans to close in the coming years. In late 2014, NRC embarked on a decommissioning rulemaking to establish clear rules of the road for reactors transitioning from operations to decommissioning. The goals were to move away from regulating by exemption in this area and to take a fresh look at our decommissioning process and requirements. Since that time, the agency has gone through two rounds of public comment, first in response to an advance notice of proposed rulemaking and then in response to a draft regulatory basis. During the two comment periods, we received a total of about 200 public comments from licensees, states, local governments, nonprofit groups, and other interested stakeholders. I read them all, and I can tell you that there are some very good suggestions in those letters. As the NRC staff prepares the draft proposed rule for the commission's review later this spring, we need to thoughtfully consider the ideas presented by all stakeholders with an open mind. We should be aiming to produce a balanced rule that considers the interests of a broad range of engaged stakeholders. Because complex rulemakings take time to complete, we probably still have a couple years before the decommissioning rule is finalized. During that time, I anticipate that the agency will continue to receive exemption requests from plants moving towards decommissioning. Some of these exemption requests will be of high public interest, like those related to emergency planning, security, and decommissioning trust funds. But under our current approach, the public has no opportunity to weigh in on these important regulatory decisions. I think NRC can do better than that. We can be more transparent and involve the public in the process. There is nothing that prevents us from doing that while we work to finalize the decommissioning rulemaking. So, for the near term, I support improving the existing exemption process by soliciting stakeholder comments on decommissioning exemption requests that the staff expects will be of high public interest. The staff would then consider and respond to the public comments during its evaluation of those exemption requests. States, local governments, and the communities around these plants are very engaged and want to share their views. We need to give them the chance to do so. Our regulatory decisions can benefit from their valuable insights. Even as some existing plants are decommissioning, we're seeing a lot of interest in new nuclear technologies, whether it's advanced reactors, accident-tolerant fuel, or digital instrumentation and controls. The NRC staff has launched a transformation initiative to identify any steps the agency should take to improve its approach to reviewing new and novel technologies. I think that's a good focus for the transformation team and look forward to hearing the results of their outreach and brainstorming. Of these new technologies, NRC has probably done the most thinking about how we adapt our regulatory framework to prepare for advanced reactor applications. As mentioned earlier, I think by Vic, five vendors have begun pre-application discussions with the staff, and we anticipate additional vendors may reach out soon. We want to make sure that we have an efficient and effective licensing process for non-lightwater reactors, so we are ramping up our activities in this area. With our current resource levels, the staff is primarily focused on identifying and addressing key technical and policy issues that should be resolved early. For example, the staff is finalizing guidance for crafting principal design criteria for advanced reactors. Staff is also creating a risk-informed performance-based approach for selecting licensed basis events. In addition, the staff is working to develop the necessary computer codes to perform regulatory reviews. A significant amount of stakeholder interaction supports all of these efforts. Vendors and licensees also are increasingly focused on developing accident-tolerant reactor fuels that can better withstand higher accident temperatures and provide longer coping periods during station blackout conditions. In response, the NRC staff is working to prepare the agency for accident-tolerant fuel applications. While incremental fuel design changes could largely rely on existing data models and methods, designs that depart more dramatically from existing fuels may require a substantial amount of new testing and modeling. Just as with advanced reactors, the agency needs to determine whether any updates to our regulatory framework will be needed to enable the agency to perform efficient and effective licensing reviews. One long-delayed rulemaking pending before the commission would certainly help the agency get ready for new fuel technologies, and that's the 5046C rulemaking. Here's why this rule is important. Currently, NRC's regulations recognize only two types of fuel cladding for a full core, zircaloy and zerlo. The regulations also recognize only one type of fuel pellet made of uranium oxide. But vendors are looking at other cladding and pellet materials, such as silicon carbide and uranium silicide. Because these new materials are not addressed by a regulations, licensees would need to seek regulatory exemptions to use them. That's not efficient, and it makes it harder to innovate in ways that could improve safety. The 5046C rule would move the agency to a technology-neutral, performance-based approach that would apply to all cladding materials and fuel designs, so applicants would no longer need to seek regulatory exemptions from the existing requirements. There is also an important safety component to the rulemaking. New findings from an extensive research program call into question the technical basis of the existing regulation. The latest science shows that the combination of temperature and oxidation limits established in the current regulation are not stringent enough to prevent embrittlement of the fuel cladding. And the existing regulation does not address the new degradation mechanisms revealed by the latest research, such as breakaway oxidation. In the absence of adequate regulatory requirements, the NRC staff has been performing annual safety assessments of each nuclear power plant in order to ensure that there is no imminent safety hazard related to the integrity of the fuel cladding during a design basis accident. Essentially, the staff is conducting, after the fact, backward-looking reviews to see if the fuel at each plant would have performed safely during an accident in the prior year. Because the existing regulations do not prevent licensees from taking certain core reloading actions that could reduce the safety margins at nuclear plants, each year the staff looks back at the prior year to confirm that safety margins did not erode in a way that would cause a safety issue. This is no way to provide reasonable assurance of adequate protection of public health and safety. The draft final rule has been sitting with the Commission for two years. I voted on it 19 months ago. We need to finalize the rule to address the safety issue and to adopt a technology-neutral approach that lifts a current barrier to innovative fuel designs. That brings us to digital instrumentation and controls. I listed this as the third new technology that the Transformation Initiative is looking at. But let's face it, digital isn't really a brand new technology. It's been around for quite some time in most other sectors of the economy. But when I visit an operating reactor and go into the control room, I see a lot more analog instruments than digital ones. And the operators in the control room share their concerns about the obsolescence and reliability issues associated with analog technology. I think there is broad agreement that safety would generally be improved if more instruments transitioned to digital. Unfortunately, we have not yet been able to resolve this complex issue so that plants can safely and efficiently upgrade to digital systems. The staff is implementing an action plan, and I think we're starting to make some progress on a path forward. But let's be frank, it's been slow going. That's not a criticism of the staff or of the industry. It's just a recognition that this area of regulation has proven to be a real challenge. So we need to rejuvenate our efforts on digital instrumentation and controls. As the safety regulator, we need to make sure that digital upgrades are done safely and don't introduce any unacceptable risks. But we also need to make sure that there is a reliable regulatory framework for making these upgrades. I look forward to hearing the transformation team's ideas for how we can accelerate our progress in this area. I want to touch on two other key topics that relate to operating reactors, risk-informed regulation and security. We're seeing a significant increase in the number of risk-informed licensing submittals. In particular, there's growing interest in applications under Section 5069 to risk-inform the categorization and treatment of structures, systems, and components. 5069 is a potentially far-reaching provision that hasn't been used much until recently. The effort to risk-inform technical specification completion times also has ramped up in the last couple years. It's an important initiative that addresses the question of how we should deal with issues of lower safety significance. And I think it's far superior as an approach to some of the past efforts in this area. For example, in trying to come up with a way to address so-called low-risk compliance issues, the NRC staff began exploring different concepts and approaches. One iteration of this effort basically envisioned a type of long-term enforcement discretion that could last for years. It's no secret, and I think that's a terrible idea. If our regulations, in this case, technical specifications, need to be updated and risk-informed, let's focus our energy and resources on risk-informing the technical specifications, rather than on developing a process to bypass our own regulatory requirements. Fundamentally, compliance with our regulatory requirements is how NRC ensures adequate protection of public health and safety. We should not go down the path of allowing long-term non-compliance. And the Commission's 1995 Probabilistic Risk Assessment Policy Statement recognizes this. In the policy statement, the Commission endorsed the use of risk insights, but also stated, it is, of course, understood that the intent of this policy is that existing rules and regulations shall be complied with unless these rules and regulations are revised. So my view is, if our technical specifications would require a licensee to address an issue of very low safety significance, within 72 hours of shutdown, but a one-week or two-week or 30-day deadline would be more appropriate, we should work on revising and risk-informing the technical specifications. Let's focus on getting to the right regulatory requirement, not coming up with a process to permit prolonged non-compliance with the tech specs. At the May 2017 Commission meeting on risk-informed regulation, I heard a lot of stakeholder agreement on this point, and I'm glad to see that the NRC staff has responded by rethinking where it focuses its attention and resources. Maintaining strong physical and cyber security programs is another key priority for NRC and our licensees. The potential threats facing power plants, fuel cycle facilities, and radioactive materials licensees are constantly evolving. NRC has already established performance-based cyber security standards for the reactor fleet, and a proposed cyber security rule for fuel cycle facilities is now being reviewed by the Commission. NRC must also maintain effective physical security requirements, including force-on-force inspections conducted by NRC. Although the Commission is still considering a paper on potential changes to the force-on-force program, I can tell you how I'm approaching this issue. Currently, NRC conducts two force-on-force exercises at each nuclear power plant every three years. Under the staff's recommended option, there would be no second NRC-conducted force-on-force exercise. Instead, NRC would perform an enhanced inspection and evaluation of a regularly scheduled force-on-force exercise planned and conducted by the licensee. The licensee would both develop the exercise scenario and provide personnel for the adversary force. I do not support this option because it does nothing to enhance the effectiveness of the force-on-force program. Going from two NRC-conducted force-on-force exercises to one would provide no security benefits. The only potential benefit would be to reduce the cost of conducting the exercises, and that outcome is far from certain. If a licensee would be rated ineffective or marginal during the sole NRC-conducted force-on-force exercise, or if the results were indeterminate, then there are two possibilities. Either NRC and the licensee would need to schedule plan four and participate in a second NRC-conducted exercise, which would eliminate the modest cost savings that the staff anticipated for this option, or a nuclear power plant licensee would be allowed to operate without passing a single NRC-conducted force-on-force exercise during the three-year period. The first outcome offers no advantages over the current program, while the second outcome would be unacceptable. I support maintaining the current security baseline inspection program, which already reflects a number of recent efficiency improvements. However, I think the NRC staff should explore the pros and cons of holding an ungraded NRC-conducted active violent insider exercise in lieu of the second full-scope force-on-force exercise whenever a licensee is rated effective in the full-scope exercise. Given the global trend toward lone wolf terrorist attacks, it would be prudent to further ensure that nuclear power plants could effectively protect against an attack by an active violent insider with access to the plant. Instead of NRC formally grading a licensee's performance, any issues found during such an exercise could be entered into and addressed through the licensee's corrective action program. I think it's a potential change worth considering. I've talked a lot about reactor issues. Let me close with a radioactive materials issue, and that's source accountability. Unlike for Category 1 and 2 sources, there is currently no regulatory requirement for a vendor to verify the authenticity of a license for Category 3 sources before selling them. The Government Accountability Office highlighted this regulatory gap in 2016 when it found that a fictitious company established by GAO could produce counterfeit Category 3 possession licenses and obtain commitments from vendors to sell it a sufficient amount of material to reach Category 2 levels. In light of GAO's findings, I propose that the NRC staff take a fresh look at the question of whether and how to track Category 3 sources. My commission colleagues agreed, and the NRC staff provided its recommendations in August 2017. The commission is currently considering those recommendations. NRC's existing license verification system allows radioactive materials licensees, including the manufacturers and distributors that sell radioactive materials to other licensees to confirm that a license is valid and that a buyer is authorized to acquire the quantities and types of radioactive materials being requested. Use of the system is currently required for Category 1 and Category 2 quantities of radioactive materials. The core finding of the GAO report is that licenses can be altered or counterfeited to allow bad actors to illegally obtain radioactive material. In response, I believe we should amend NRC's regulations to require verification of Category 3 possession licenses through the license verification system or the appropriate regulatory authority. License verification is a targeted solution to closing this regulatory gap highlighted by GAO because it occurs prior to the transfer of a source in real time and can proactively prevent an illegal transfer. This would meaningfully address the problem identified by GAO by preventing unauthorized entities from using counterfeit or altered licenses to obtain radioactive materials. We did not wait for an armed attack on a nuclear power plant to establish physical security requirements or for intelligence indicating an imminent cyber attack before requiring plants to take steps to address cyber security. Likewise, we should not wait for an adversary to exploit the failure to verify the validity of Category 3 radioactive materials licenses before closing this regulatory gap. A small number of Category 3 sources can be aggregated to Category 2 levels. Given the commission's past determination that Category 2 quantities of radioactive material warrant the suite of regulatory requirements that NRC has applied to them, including license verification, tracking and national source tracking system, and physical security, it makes sense to take the basic step of ensuring the validity of licenses to obtain Category 3 sources. We also need to take another look at whether to continue issuing general licenses for Category 3 sources. Generally licensed devices such as self-luminous exit signs do not require specific possession licenses, but the radioactive material in a generally licensed device is no different than the material in a specifically licensed device. Right now, NRC does not regularly conduct inspections to ensure that generally licensed sources are used and maintained safely and securely. Although there are hundreds of thousands of generally licensed devices nationwide, there are a relatively small number of containing Category 3 quantities of radioactive material. The NRC staff has expressed concern about the lack of routine oversight and accountability of generally licensed Category 3 sources. The agreement states have expressed similar concerns. In fact, there is broad consensus among the states on the need for change. When the NRC's technical experts and our agreement state partners reach the same conclusion that general licenses for Category 3 sources do not provide for adequate oversight, we need to take action. So I support the NRC staff's recommendation to reevaluate the practice of issuing general licenses for Category 3 sources. As a safety and security regulator, we need to have an open mind about the need for regulatory change in this area. Of course, that's true for everything we do. It's essential for NRC to tackle tough regulatory issues with an open mind. It's not enough to say that's the way we've always done it or we looked at that 30 years ago. We need to be open to new ideas and new approaches. More than that, we need to actively seek them out. Stakeholder interactions are a big part of that, which is one of the reasons why the RIC is very valuable. So if you have feedback on NRC's work or a suggestion or a new idea, please let us know. I look forward to talking with many of you this week and during my future visits to power plants and other licensed facilities. I'm also happy to answer your questions now. It looks like we have about 20 minutes. Thank you. Thank you, Commissioner Barron. Starting off with a rather light note, this questioner, similar to the question that was posed to the chairman, asks you to relate your experience on the commission with your favorite movie and would give you bonus points if you sang a few bars from the movie. I'm opting not to go for bonus points. I may opt not to even answer the basic question, to be honest. And I'll tell you why. I was listening to Christine get this question and I was thinking, gosh, how would I answer that? And I had a long time to think about it and I came up with nothing. I came up with nothing. And so I could start talking about movies I love, but I'm not sure any of them really work for an analogy to my work here on the commission. So I think I'm just going to take a pass on that. Maybe ask that question sometime in the future and I'll give it some more thought. Honestly, the hour and a half I've had was not enough to come up with a good answer to that question. And it's a very challenging question. I would challenge all of you to think about that. What movie would wrap up your experience and your work day? Gosh, I have no idea. I don't even think I'd come up with a theme song. All right. On a more serious note, this questioner brings up the differing professional opinion program and remarks that it's a worthy program, but comments that perhaps that it's evolved in a way that was unintended and has unintended consequences. So there's three parts to the question. Is responding to a differing professional opinion so resource intensive that NRC managers are encouraged to make decisions that would not otherwise simply to avoid a differing opinion? Are the resources devoted to responding to these opinions, commensurate with the safety benefits gained, and how would you advise NRC managers to balance those interests? Well, thanks for the question. It's a very important program, a differing professional opinion program, as is our non-concurrents process. And I take every opportunity when I'm talking with a large audience, including with our staff, to plug those programs. We want to have a good safety culture here at NRC, and a basic component of that is having folks raising concerns if they see a safety or security issue they think is unaddressed. And these are mechanisms to do that, both the DPO program and the non-concurrents process. We also have the Open Door program where folks will come in and just share their concerns directly with the agency's decision-makers. I encourage folks to use all of those programs because I think they have had an extremely positive impact on the agency. I've been here for about three and a half years now, and in that time we've had a number of tough regulatory issues that came up before the commission where there was a non-concurrents or multiple non-concurrents or a differing professional opinion. And I found them very, very helpful to our decision-making. The decision-makers don't always agree with what the non-concurrent or the author of the DPO has stated, and that's fine, but it makes sure that folks are clearly considering those issues as part of the decision-making. And I know that I've personally benefited, and I think the commission as a whole has benefited in its decision-making from those contributions. I don't think that managers have taken an approach of reaching a decision to try to avoid a DPO or a non-concurrent other than this to say that when folks have seen potentially dissenting views or different views among the staff, I think they try to make sure that those folks are broadened to the process and those issues are fully understood, which I think is absolutely appropriate. One of the trends that I've mentioned in the past that I think is positive as a way to address areas where the staff isn't of one mind is to have that presented clearly in the decision-making paper that comes to the commission, or even if it's not a commission paper, if it's a staff-level decision, I think it can benefit in the staff-level decision-making documents. I know when I've seen a policy paper that clearly says, here's the staff's recommended view, but it's not the only view on the staff. Here's another view, and it talks about that in some detail, and you get a flavor for all points of view on the issue, that that's as a decision-maker extremely helpful. So I think that's one good way to manage it. That's a little different than a DPO or non-concurrents, because in some cases, taking that approach to representing both views in the paper actually has someone not used the non-concurrent process or the DPO process because they feel that their concerns have been raised directly to the decision-maker. So I think that's been a positive approach. I think it's a worthwhile program. I know the staff is looking at future optimization there because there is a process particularly on the DPO of a number of folks on the panels, and there is a lot of steps to that process with a fair amount, I don't want to say rigidity, but process around it. And so I know that one of the things that the Office of Enforcement is beginning to look at, and really I think with a positive approach in mind, is should we think about scaling that to the kind of significance of the safety issue, or the complexity of the safety issue? Do we want to have a one-size-fits-all type program or do we want to explore modifying that a little bit? And I think as long as the purpose of that effort is to really kind of optimize the program, it makes sense to me. So it is something we're being looked at. I think it's a good program and it's been a valuable program. Okay, thanks. Commissioner, this question points out that military, medical, and aviation sectors have successfully and safely applied digital instrumentation and control technology, yet NRC has not, as it's pertaining to the nuclear industry. But the consequences of failure might be just as consequential. Why can't the NRC benchmark these industries and make comparable progress safely and successfully in using the technology? Yeah, I think that's a great question, and I'm encouraged that the transformation team is looking at this very question, because we, for a number of years now, have been grinding away some incremental improvements in a number of areas here. And we could go into some detail on that, but whether it's the risks on how 50-59 should be used, guidance there, whether it's common cause failure, other issues, we have kind of several issues in the action plan that the staff has been working very hard on with the participation of stakeholders to move those things forward. And there's been some progress there, which I think is great. I wouldn't want to do anything that detracted from the progress we are making. But I do think it's been challenging enough that we need to ask those bigger questions of, is there some kind of different way generally we should be looking at this? And so that's really a perfect place for the transformation team initiative to take a look. And I know as part of their stakeholder interactions, they're talking to just those types of folks. They're talking to the Navy. They're talking to FAA. How did this work in aviation? You know, these are digital systems and airplanes that we fly every day. How did FAA manage to get that done? They're talking to some of our international counterparts. Some of you in this room may have done a better job on this issue than we have to date and made more progress on it. So they're doing just that. They're kind of taking that suggestion to look and see, okay, we've been doing this a certain way in terms of trying to move through this. We're making some progress. We're making some further change. We should be thinking about some different approach. We should be adopting that would accelerate our progress in this area. So I'm looking forward to see what they come up with. It's not, of course, all on the transition team. It's something as an agency and as a staff we can all think about as we go through this. And I won't say too much more on it, but I'll say this. You know, as I mentioned, I got here around three and a half years ago. And at that time this issue had already been percolating for a number of years. We've been working on it during those years. And so I think there was a degree of frustration that we weren't making, weren't collectively making more progress on this. When I got here in late 2014, and now here we are, it's 2018, some progress has been made, but I don't think anyone thinks it's going as quickly as we would like it to. I agree with the chairman on that. I think she made that remark. And so I think we can agree on that and what we've got to figure out is how can we collectively do better on that? There are really important issues to resolve. I mean, there are practical effects today that all of you know who are operating nuclear power plants. But particularly if you think out into the future, you think of subsequent license renewal and other things, I mean, are we going to walk into an operating reactor control room in 2050, and it's all going to be analog? I mean, the answer cannot be yes. The answer has to be no. We have gone to digital by then, or maybe whatever technology is after digital by then. So we need to keep working on this and really, as I said, kind of rejuvenate our efforts and think broadly about how are we approaching this and can we do it in a better way? Thank you. This commenter questions or interpreted your remarks as you're believing that current fuel designs do not have adequate safety margins in the operating nuclear power plants. So if that is the case in your view, why are you as a commissioner allowing those plants to continue to operate? Well, I should clarify remarks. I'm not saying that we have a safety issue right now. I'm saying that our current regulatory requirements are not adequate. And we're doing something that we don't do in other areas of regulation, which is rather than have adequate requirements that give us assurance that today, tomorrow, and next week we are going to have adequate margin, we're waiting to the end of a calendar year. I think it's a calendar year. Someone will correct me if I'm wrong about that. And then we're going back and looking for the prior calendar year to see if it was all okay in the prior calendar year. That is not a great approach to regulating in the health and safety area, I don't think. I don't think the staff does either. And when they sent the draft final rule up to us a couple years ago, one of the things they mentioned is in the absence of a rule, the staff may need to look at other mechanisms like orders. If there was a situation in which there was a safety issue, the staff would have to act. And so, of course, they have that option, but I think we can do better than that. I think we should have a clear rule in place that's gone through notice and comment. And so I think that's the best path forward. It gives us the benefit not only of addressing this lingering safety issue or potential safety issue, a kind of gap in our regulations and outdatedness of our regulations that needs to be updated and corrected. But it also has the advantage of better preparing the agency for these next generation fuel technologies. Thank you. This question deals with the implementation of the Fukushima enhancements. And the question is how many nuclear plants have not met their post-Fukushima requirements? Wow, that requires a complex graph I don't have, but let me do it simply. So there are only a handful of plants that are not, I believe, currently in compliance with the mitigating strategies order. And most of those plants, I think, involve Army Corps of Engineers data, am I thinking of the right thing there? We have a handful of plants where there's some kind of outstanding work related to natural hazards that still is being done. And I think some of that involves coordination with other agencies. So we have a handful there. I believe everyone's in compliance and spent fuel pool instrumentation. And then we have a relatively small number, subsets of the fleet that either have ongoing flooding integrated assessments or seismic PRAs that are going on. And those are labor intensive multi-year efforts. And in some cases, if you're talking about, say, the seismic PRAs, it's also just a limited number of people in the world who can do that work. So it has to be staggered to get that work done. So, you know, it's not going to be the same answer on all of those. There's a high level of compliance individually or completion, I should say, on each individually. I didn't mention the events. That's also something in the next year, year and a half we're going to be much closer on. So we've seen a lot of progress. And I think we're going to see really in the next year or two a lot of the ongoing work that's still happening reaches its conclusion. Okay. Thank you. This commenter questions about the responsibilities of host states in dealing with the environmental and the economic impacts of decommissioning, particularly for nuclear power plants. Should states' views be given more weight in light of those responsibilities in the decommissioning rulemaking? Well, I think we absolutely need to consider their views and we need to consider them seriously and with an open mind. You know, I think as long as we are taking that approach to all of our stakeholders, we're doing the right thing. You know, it is an interesting kind of philosophical question, I think, and I don't know that I fully know the answer to it, which is do we think that the elected government of a state, actually, their views should carry more weight than another individual commenter? You know, one could see the argument for it. I think as a practical matter, one could see the argument on the other side. As a practical matter though, I think the important thing is we seriously look at what are the ideas, what are the proposals, what are the concepts we're getting from all the stakeholders and what's the right path forward on it. So I can understand that, you know, part of the rulemaking, some of those issues have to do with what is the appropriate role of state and local governments in the decommissioning process. So that's something that I think, rightly, states have focused on as an important issue and that we need to take a close look at it in this rulemaking process. As I know we have, having, you know, read the various documents, including the comments that have come in. So it's a work in progress this rulemaking. We still haven't even gotten to the proposed rule yet. I think that comes up in May. I'm looking forward to seeing it when we get it and I'm going to continue to give a lot of thought to, you know, what are the changes that make sense generally in this area. Okay, thank you. This questioner remarks about your comments on your vote on the proposed revisions to the security oversight program. And the commenter asks, or makes the comment, the proposed change to the security inspection program is very similar to that that currently exists in the emergency preparedness inspection and oversight program. Do you think, in light of your views, that the EP inspections are not effective? And would you consider a performance indicator based approach that would be examining, integrating security drill and exercise performance be a reasonable alternative? Well, I, you know, I'll confess, I haven't taken a lot of time to look at that question on EP. I don't have the sense that what we're doing now isn't working. I have the opposite sense that it is. So I'm happy to take a look at that issue and think more about it. Thanks. Okay. This questioner notes that you mentioned interest of five SMR vendors in engaging with the NRC in a formal manner. They note Canada currently is interacting with 10 vendors with their regulator. What is NRC doing to ensure America remains a leader in the SMR regulation? Yeah, so the five, the interaction with five actually refers to advanced non-light water reactors, which can have some overlap with SMRs, but that's on the advanced reactor side. And I think the staff has been really pretty aggressive over the last few years in working to get ourselves ready for more pre-application discussions and then obviously the applications themselves. And there's a lot of work to be done there. I think, you know, everyone acknowledges that the regulatory regime we have, including for new reactors, has really been set up around light water reactors. It's been focused on that and it's worked reasonably well for that, but it's not really set up to deal with non-light water reactors. So I think the approach the staff is taking is a good one in terms of thinking through, there are a bunch of things we need to do. One of the things we need to do that the staff is focusing on is what are the technical and policy issues we need to start thinking about early. So for example, as I mentioned in my remarks, design criteria and other things that you're going to want to think through, you know, they were written for light water reactors, what is the comparable guidance for non-light water reactors. So that works happening. We have to make sure that as an agency we have in-house the technical capability to deal with this work as it comes in. And so when we have our commission meetings with the new reactors office and others, there's one of the questions I ask and that we talk about. We want to make sure we have the technical expertise we'll need for the various types of technologies because as was mentioned earlier, it's a range of technologies that we're talking about in the advanced reactor space and we need to be prepared for the different technology types. There are codes and standards issues, other issues. The staff's been very, I think, proactive and I hope, you know, for those of you who participated, you think they've been worthwhile, very proactive on having regular stakeholder engagement with vendors, with the Department of Energy, with other stakeholders so that we're really understanding both where do folks think they're going and what are the timeframes associated with that and what do they see as the key issues we need to start resolving so that we have a good regulatory framework in place as applications come in so that we can deal with them in an effective and efficient manner. Okay, last question. Okay. So recognizing that excellence is an aspiration, not a destination, I think, as presented by our Executive Director for Operations and that we all can continue to improve, haven't licensees demonstrated continuous safety improvements over the last 30 years and if so, then why is there a need to do more and more as it relates to rulemaking and regulation? Well, I'm not sure I totally agree with the premise of the question in terms of a sense we need to do more and more and more. We have regulations on the books that sometimes need to be updated based on the latest science or operating experience. I would put 5046C in that category. We have areas of rulemaking that are really areas that we haven't spoken to real clearly in the past like decommissioning in the decommissioning context. Obviously, we have a lot more decommissioning going on now than we had in prior years and it's kind of amazing that we've gotten to this point 2018, 30 years of the RIC and we don't currently have clearly in our regulations. Here are the regulatory requirements that apply to a plant that has permanently shut down. We don't have that. We're planning to do that long before I got here in 2000. 9-11 happened and there were other priorities that rightly took priority but we've gone a long time without having that clearly laid out in our regulations. So I wouldn't put that in the category of more and more and more. I would put that in the category of we haven't really clearly addressed that and it's to everyone's benefit to do so. I think particularly in the case of decommissioning, the exemption process, the kind of regulation by exemption approach we've been taking, it's really not optimal. It's not efficient. It's not efficient as it could be certainly and it doesn't involve the public. So I think there are times when it does make sense to engage in rulemaking and either to update or to go to a new requirement that maybe we don't have that we should. And one example there, for example, would be cybersecurity for field cycle facilities. That's something that's been part of the plan on cybersecurity that staff had their kind of roadmap or I think we call it a roadmap of the different types of facilities we would address in a certain order and we've gotten the field cycle facilities and so it's time to address that issue there, something that's already been addressed for the operating fleet of nuclear power plants. So it's an agency, I think as an agency we're very thoughtful about when it makes sense to do a new rule or not and it's certainly something that gets a high level of discussion and attention at the commission level and so I think that we work very hard to make sure that if a new rule is being established it's one that makes sense and is necessary. Great. Commissioner, thank you very much. Thank you.