 The panelists today really need no introduction and so we'll spare you a lengthy introduction for them. We're certainly joined by Bill Dean, who is the regional administrator from Region 1. Vic McCree, who is the regional administrator for Region 2. Cindy Peterson, who is the regional administrator for Region 3. Mark DePaul, who is the regional administrator for Region 4. Maria Korsnik, who is the acting chief executive officer and chief nuclear officer for the Translucent Energy Nuclear Group, and Danny Bost, who is the executive vice president and chief nuclear officer of Southern Nuclear Company. Well, as we begin the session, or before we begin the session, I want to provide an opportunity to start where really we started the session, the executive session this morning, as a number of people have noted. Certainly as we discussed in that session, both the industry and NRC senior managers had an opportunity to travel to Japan on almost, for us, almost leading up to the third anniversary that we marked on the 11th of March. We, as a group from the NRC, speaking for the NRC, traveled as a group of senior managers and found that visit to be highly impactful. And I know that the industry chief nuclear officers also found that trip to be very valuable. And so before we begin the detailed questions, I'd like to provide an opportunity for the panelists to spend a few minutes to talk about a few of their perspectives based on that trip. And so I'll start with Vic and then ask Cindy to go next. I'll ask them, Mark, to go, and then Bill, would you go? And then we'll go with the industry, Maria, and then Danny, Alast. So let me just turn over the floor to Bill. Please begin. Thanks, Mike. Well, the first thing I'd like to do is thank Mike Johnson for his foresight, and vision, and courage, actually, to take all of his direct reports out of the country for about seven days on an unprecedented visit. This was the first time that all of the reactor direct reports to Mike Johnson have taken a trip such as this. And again, I want to thank Mike for that. As you can imagine, or perhaps already know, either from the CNOs in this room, we visited last fall or others who were aware of what happened in Japan almost three years ago. This was an awesome, awesome experience. And at times, I was humbled and overwhelmed by what we saw, particularly at Fukushima Daiichi and Fukushima Dainai. And even three years later, the damage from the seismic event and the tsunami was still evident, and it was very sobering, as was indicated again this morning, driving through the towns that had been abandoned. During our visit, we had the opportunity to meet with regulatory officials, the new regulator, the JNRA, as well as industry officials, including folks from the Tokyo Electric Power Company, TEPCO, who were actually at the site on the day of the event and the days of following. And among the things that made a lasting impression upon me was their moving personal accounts of what transpired again that day and during the day's following. As we listened to their descriptions of what happened, you could hear the anguish in their voices, is that their personal impact was really evident. Even through their translators, you could just see and feel bad. Some of those folks worked for days without knowing whether their families were alive or where they were, and again, it was truly moving. They worked under some very hazardous conditions. Many talked about the fact that they thought they were gonna die at any moment. The radiation levels were very, very high, and their professionalism, their dedication, their perseverance were just very apparent. And it just reminded me as a regulator how important it is that we make the right decisions to ensure that US operators are never placed in a similar situation. At this morning's plenary, Mike mentioned the three collective or shared lessons learned in case you didn't hear them. They were one to assure that US plants and the NRC are prepared for the unexpected. Secondly, to ensure that the lessons learned from Fukushima are implemented, they're maintained, and they're exercised going forward. And thirdly, that NRC and the industry appropriately deepen the technical expertise that we need that was so necessary and demonstrated at Fukushima Dynine. And on a personal note, I gained a much deeper appreciation for the stakes involved and the hazards associated with the industry that NRC regulates and that the industry operates. And I believe it's very important that we establish and we cultivate a culture, a safety culture, if you would, that recognizes the possibility that an accident can happen. And that we put in place measures to whether it's equipment, processes, procedures, or people to make sure that we can prevent or mitigate any adverse consequences should that occur. And I believe in doing so, the health and safety of the public will be insured and the environment will be protected. Good afternoon. One of the things that I wanted to reflect on and share with you today is the striking visual images that we saw as we drove up to Fukushima Daiichi. It was a beautiful day and we should have been expecting to see people out and about, but as we drove through, you notice cars in the driveways, you notice product on the store shelves, but there are no people around. And when you think about it, it was basically a man made ghost town. These people were no longer there, they had been evacuated. And they were just ordinary people living ordinary lives, never expecting to have to move on. They trusted the operator, they trusted the regulator to keep them safe. And these accidents were just a huge breach of the public trust. They had expected to live there for their lives. Now granted, the doses were not at the point where there were deaths or significant doses to the population, you could say evacuation worked. But when these people trusted in the organizations around them, the licensee and the regulator, I'm sure they never expected to have to leave their homes, three years later, those places are still vacant. Some folks may never return to their homes. And as I thought about, if we had a similar situation here, what it must have been like for the officials to have to tell their local populations that they had to move and they may never be back. And as folks like we are that work for the public can't quite imagine how difficult that must have been for those in the Japanese communities that had to be evacuated. I certainly gained a greater appreciation. I mean, we all exercise these processes, we train on these processes, we know these kind of things can happen. But when you see it firsthand and you see the impact on the people that were there, it was really a very, very sobering experience and one that I truly hope none of us in this room or our colleagues ever have to face. Good afternoon. There were a number of things that resonated with me and left a lasting impression from our trip to both Fukushima Daiichi and Fukushima Daini. And as a result of our discussions with the various operators and site management that were involved in the event response. But one thing I wanted to share with you in particular, and similar to Vick's accounting discussion of the impact from talking to the various operators and site managers, I had a similar reaction when you listened to the first hand accounts of the individuals that were involved in providing for a response. The extraordinary challenges they faced, the continual setbacks, the tremendous difficulties that they had to overcome. It was compelling in terms of the resiliency and perseverance that was demonstrated by those TEPCO employees. In examples of some of the daunting challenges, three teams that were dispatched in order to be able to operate the air operated valve and motor operated valves in the vicinity of the tourists in order to establish a containment venting path. And they're dealing with aftershocks and safety relief valve lifting. And the individual, one individual indicated that they thought, or he thought that he was not going to get back without the loss of his life. Not knowing whether family members were safe as a result of the earthquake and tsunami, dealing with high dose, high temperatures. The environment was certainly very, very challenging. You're in a control room with, you have no power, so you have no lighting, no instrumentation, and the efforts to use car batteries to power instrumentation to obtain indications on reactor pressure vessel level and temperature as well as containment pressure. Those are just some examples of some of the challenges that the TEPCO operators and response managers found themselves having to confront. I would describe those as the use of heroic actions. And I think in understanding what the operators and managers face, the quote from Iquo Izawa, who was the shift manager for the Fukushima Daiichi units one and two during the event. He said to us when he was giving us a briefing when we were at the TEPCO headquarters in Tokyo, the impact of the tsunami was totally bigger than what we expected, trained, prepared for, or believed was possible. It was unimaginable. We must always be prepared for the possibility that something much bigger can happen. So from my perspective, the significant takeaway was being prepared for potential beyond design basis events means that we ensure that the people, and I say we, both the industry and our role as a regulator, we ensure that the people, processes, and equipment as well as the infrastructure are in place such that we don't find ourselves relying on heroic actions to ensure plant safety. I would offer if we find ourselves in that situation, we've failed as a regulator and we've failed as an industry. And so I feel that really underscores the great importance of ensuring that the Fukushima lessons learned in the required actions are fully implemented, maintained, and exercised. Thank you. So between what you heard from Mike and Dennis this morning, if you sat in on their plenary session and then what you've heard from my fellow regional administrators here in the past few minutes. There's plenty there that have resonated with all of us and what they have expressed eloquently describes many of the things that resonated with me. But there's a couple of things that I wanted to share with you and one of them is somewhat duplicative of what you heard from Commissioner Austin Dorf this morning regarding how well this agency and industry have worked to frame what are really the important issues that we should be working on in the aftermath of the Fukushima accident. And I truly came away from our visit to Japan with a strong belief that we indeed did do a very of the near-term task force in terms of framing the issues for our consideration, the efforts of the Japanese Lessons Learned Directorate and the Steering Committee in terms of providing the Commission their views on what ought to be the priorities in the Tier 1 areas and then the Tier 2 and Tier 3 and then the Commission's endorsement of that approach. So I'm fully aligned with what you heard from Commissioner Austin Dorf that we did pick the right things in my visit to Japan, reinforce that in my mind. The second thing that I took away that besides the things that you've heard already from my peers up here is the importance of our incident response program and the training of our licensed operators. The incident response program that exists in this country is pretty robust. We frequently exercise, by any of the exercises involving our state and local officials and organizations that work with the licensees and FEMA and NRC's oversight and evaluation of those exercises provide us with a fairly strong framework for assuring public health and safety if indeed those events that we don't believe will occur may occur and so it's important to sustain that robust incident response program and with respect to our licensed operators it's very important that we don't overburden our licensed operators particularly in terms of training and procedures that will distract them from their focus on safe plan operation in the here and now and so we have to be very careful in terms of the balance with which we apply training and procedural requirements on operators for these very, very infrequent and likely never to occur situations so that they can assure that they sustain their focus on what they need to know to operate the plant safely now and particularly the events that would be more predictable to occur so that we can prevent any sort of event that could create core damage from occurring. Thank you. I attended a trip with the chief nuclear officers across the United States back in the September timeframe both Danny and I did. My reflections of that time really fall into three categories. My deep respect for the response teams at both Daiichi and Dianne, the value of training and the importance for defense in depth and beyond design basis scenarios. The respect for the response teams and it was somewhat stated here. It was amazing to me the number of attempts and failures and challenges that they had really at both Daiichi and Dianne and the number of creative solutions that they tried and attempted. The tenacity that they had under such extremely stressful conditions was really, really noteworthy to me and as we stated we practice our emergency response plans frequently and I have confidence in them but it was something else to really be in the midst of it and appreciate that as a leader you might be sending somebody in the harms way in terms of the course of the accident in terms of trying to get things in a better condition and he shared that honestly with me that says I asked this team to go out and I didn't know if I was ever going to see them again and so that really as a leader puts things in perspective for you. The value of training, we take training very seriously here, the number of hours of training that we have not only for our operators but for all of our craft and engineering talent. It really left a deep impression upon me how important it is that we continue with the value that we do have of our training programs especially the hands-on familiarity that we have with our plants and with our systems and in terms of the defense in depth given that we have all the redundancy that we do have, all the procedures that we do have, the reality is even with all that we need to absolutely be able to provide the basics under all conditions and that's water and power and with those two ingredients there's no question that we will be able to safely manage our way through and that's why the value of our solution here in the United States with our FLEX program I have high confidence because I watch them do it on the fly if you will at Daini and how successful that they were and that we need to put our operators in a position where they have those tools if you will in the toolkit and they're ready under any conditions. Thank you, Daini. Okay. Getting to go last they covered all of my stuff. Guys I'm not going to go back through everything that they talked about. For 25 CNOs to band together and go to Japan to see a first-hand account of what happened there, that was unprecedented. We thought it was important. We thought it was important that we go and get that first hand account of what happened and why it did happen and gain a deeper understanding. We all had read the reports. We've all got all the timelines. We've all went through that stuff. But we very much wanted to go see it. So kind of like Cindy said it was pretty overwhelming when you start getting in close to the plant, not to the plant close to the plant. You start seeing the effects. Pretty overwhelming stuff there. I'm not going to go back through it. I thought Cindy did a good job of talking through that. Vic talked about the moving personal accounts. We heard the same thing. In fact that's one thing that I brought back with me. When you look at our emergency response organization, what we tend to do is we go find somebody that's very technically savvy and they can get through these flow charts and they're the best technically at getting through these flow charts. But if you go listen to these moving personal accounts about when I sent somebody out there I wasn't sure if I would send them to their death or if they were coming back you realize the amount of leadership that you need to have in that emergency response organization. So I brought that back with me. That's something we're working on. We need to improve the leadership capability in our emergency response organization. It's not just a technical answer, a technical business. You got to have that leadership piece. And the last thing with the flex mods that we're all doing, it'll work. It'll work. If you look at what happened there and why it happened and you look at what we're all doing at our sites for flex modifications, it'll work. So I feel very good about the changes that we're implementing for flex and the benefits that's going to bring to us. Thanks, everyone. Let me just ask, pause. Seconds, anyone? Actually, I would. Okay. It was one thing I did want to mention. One of my first impressions really is that it's not over yet. And I don't mean that the cores aren't being safely cooled because they are. But the accident really isn't over yet. If you see the number of tanks that are stored on site with radioactive water inside, and the challenges that they have even today, many years after, in terms of how to deal with that water, and I would say that until we understand and they are able to manage that large volume of water that are stored on site in those tanks and they're building more tanks each and every day to store additional water, the accident isn't over and we shouldn't feel that it's over and we should work as best we can to help them not only process that, but safely discharge it. Thanks. Maria's point resonates with me in conversations that we had yesterday, or I guess two days ago now with the regulator NRA. We learned in fact that as they continue to decontaminate the plant, there is a concern, for example, that they might undergo an activity that would result in dust, that dust being carried off site and potentially recontaminating land that has been released. And so they'll face those kinds of issues continuing as they move forward. So again, great insights from the panelists. Didn't dare start this panel without the opportunity for each of the panelists to share their insights. So let's begin the session. I want to just tell you that the session isn't intended to be an open discussion of contemporary nuclear power plant regulatory issues. To identify topics of interest, of course we communicated with the industry, chief nuclear officers to pose questions for our panel. We collected as well questions that we thought might be asked and we've developed four questions that really represent I think a compilation of the questions from the list that was provided and each of the regional administrators will respond to one of those questions and will ask one of the industry reps from where you're standing to respond to those questions. But I just want to remind you that this session really is intended to generate discussion, questions from you. So I would invite you to, as we begin working through the questions, if those questions generate questions in your mind or if there's some other question that you think we ought to ask, please jot those down on a card that will be supplied to you and we'll get them brought forward and get those teed up for the panelists. So let's get into it, if you will. The first question deals with safety culture and substantive cross-cutting issues. The question is, what is the NRC's perspective on how the adoption of common nuclear safety culture language will affect the assessment of substantive cross-cutting issues? Include effectiveness of the SCCI process or NRC openness to a different approach and I'd like also for the industry representatives then what are your perceptions regarding the effectiveness of SCCI? Bill, would you start with the answer please? Sure. So those of you who know me probably are not surprised that I spent a lot of my formative years in front of the television watching cartoons. And so one of my favorite cartoons was The Adventures of Peabody and Sherman, which is now a full-length movie. You may want to go out and see it. I haven't seen it yet. But I want to take you into the way-back machine for a couple of times as we talk about this. So back in 2008, the Commission directed the staff through a staff requirements memorandum to take an evaluation of the agency's safety culture policy and to evaluate it to see whether there was any unique aspects of the burgeoning security area in the post-911 environment that ought to be incorporated into the safety culture policy as well as looking at expanding the safety culture policy to incorporate a broader set of licensees and certificate holders within the agency. Up to then it really was sort of focused on nuclear power plant operations, and the sense was we ought to really expand safety culture to the whole suite of licensees who we have authority over. And so that was done and over about a three-and-a-half-year period, the staff did, but I believe a really phenomenal job in terms of engaging with a wide variety of stakeholders, not only industry and MPO, but they talked to fellow regulatory agencies here in the United States, they talked to international counterparts, they engaged the public and other industries to ultimately develop a safety culture policy statement that had ascribed to it nine traits, and that was issued in June of 2011. The other thing that that endeavor revealed was there was really a challenge in terms of the nomenclature and language that existed within the industry between how the NRC talked about safety culture, how industry or MPO talked about safety culture, that there was a true need to harmonize that language and be able to come up with common language that whether it was the regulator or the regulated entity, we knew we were all speaking from the same sheet of music. And so that was a very important byproduct of this effort, and in December of 2012, MPO put out a document, MPO 12-012, Traits of a Healthy Safety Culture, that now I talked about we wanted to harmonize them. They had 10 traits, our safety culture policy has nine, so we didn't achieve nirvana there, but I will say the one area that was different, the one trait that was different in MPO was one that was a fairly important one to MPO dealing with decision-making. And I'll talk a little bit about aspects of these traits. All the aspects in that decision-making trait have been incorporated into the NRC's lexicon. So in reality, we've captured that, but we just have nine traits, and MPO has ten in their document. So now let me take you in a way back machine to 1999. The Ractor Oversight Process Formation incorporated this concept called cross-cutting areas, CCAs. Human Performance, Problem Identification Resolution, Safety Conscious Work Environment, and those remain today. We have not changed those since the beginning of the Ractor Oversight Process, but what has changed over the past decade and a half is how do we take those cross-cutting areas and how do we incorporate them into our assessment of planned performance? The intent of these cross-cutting areas and the aspects assigned to each of these cross-cutting areas was to be able to provide some early warning signals, as you will, for licensees that if, through our inspection process, we determined that a number of our findings had elements of one of these cross-cutting areas. We would provide that information to the licensees so they could look at that and see if there was some trend there that they needed to address. Now, unfortunately, the cross-cutting issue process has been beset with a lot of issues, inconsistency in how they were utilized in the different regions, a high degree potentially of subjectivity in terms of how you characterize something as a cross-cutting area. Really, not much regulatory teeth, even if we identified a substantive cross-cutting issue in terms of what we could do with it as a regulator. And so there's been a lot of debate and angst over the use of substantive cross-cutting issues over the years. And I think there might be another session on the ROP enhancement project, but over the last year or two, there's been actually two independent activities, one directed by the commission, which specifically said, take a relook at substantive cross-cutting issues and see if they make sense, and then also the agency's own independent ROP enhancement project. And so we're in the process of digesting the recommendations from both of those groups. So you may see some more changes in terms of how we utilize cross-cutting areas, and I know that we've had meetings recently with industry, and we're very open to other potential alternatives in that regard. But for the here and now, at the end of 2013 was the last year that we had the cross-cutting areas as previously designed, and what we've done is we've done a crosswalk to now leverage the new traits that are identified in the agency's safety culture policy into the new approach for how we do assessment of licensee's inspection, our licensee findings through our inspection process. And so in the end of cycle letters that just came out very recently, there was a paragraph in there that described this transition. In terms of what its impact might be, my understanding is from a back of the envelope evaluation of doing this crosswalk there might have been maybe one or two sites across the country that perhaps would have gotten a theme identified in their end of cycle letter under the new criteria that didn't exist under the old criteria. So I see no real impact on how we apply. I think the real benefit is that now we are all speaking from the same sheet of music in terms of what do we mean when we talk about various aspects under safety culture. Thanks, Bill, Danny. Again, the question is safety culture, substantive crosscutting issues, your perspectives regarding how well it works, are any thoughts related to that? Thanks, Michael. For us to get to a common language, I mean, to have a common nuclear safety culture language was a positive development for us. I mean, from an industry perspective. I mean, we're having to keep two sets of books, right? One set of books that we use for the ROP language, and we've got another set of books that we use for our NEI, INPO, safety culture monitoring program and commitments that we made there. So we're having to keep two sets of books. So we get one set of books now that we can keep track of things. So we see that as very positive. I see that as positive. Bill, you talked about a number of issues in implementing the substantive crosscutting issues, and I'd agree with that. The subjective process, it's very difficult to see how it's effectively identifying a weakness or a degrading trend. I mean, if you go through and look at how we're using it, and this would be the NRC and industry, I mean, we're spending significant resources trying to decide do we open up a substantive crosscutting issue. If we do open it up, how do we address it and how do we close it, and it's just a tremendous amount of resources that we apply to that program, attracting from resources that could be placed on matters of greater safety significance. If you look at what we do, I mean, our CAP program has advanced greatly since we implemented substantive crosscutting issues, and we also implemented our nuclear safety culture monitoring that we do. So, I mean, I think we can take those two programs and get done what we're doing under the SCCI program now. So what I'd recommend is take a hard look at can we use the CAP program at the sites and our safety culture monitoring program that we do with oversight and use those as opposed to the SCCI program. Okay. Any one additional thoughts? All right, the second question really relates to the government accountability office report that was recently issued that you might have seen, and that accountability report really looked at inconsistencies or tried to get into what would be causing inconsistencies and implementation of the React oversight process across the regions. And so the specific question is what processes, measures, or approaches are used to ensure reliable and consistent implementation of the React oversight process across the regions? Cindy, would you start with the answer, please? Sure. Thanks. Farback doesn't go quite as far back as bills, but I am going to go back in history just to touch. In 2000, as you know, the React oversight process was created with a significant difference in how we had done assessment prior to that time. But the ROP was developed to be a reliable and efficient way for us to assess licensee performance and for determining appropriate regulatory response. We all use the same procedures. We all use the same guidance documents. And for those things of higher significance, we also include more people. We include the Office of Enforcement, or NRR, answer as appropriate. So for things of greater significance, our process has increased checks and balances. Now, the ROP was not created to be an assessment tool for regional performance. It was focused on licensee performance. But that said, we can use it as an input into looking at how we do our own business, because we are certainly a believer in continuous improvement. Now, the topic of reliable implementation of the ROP, or as some may say, consistent implementation, has come up multiple times, including here in this RIC forum for a number of years, and certainly in the GAO report that Mike mentioned. So it's something that we've been working on for a number of years. Specifically starting in 2010, the regions in consort with headquarters started what we called the ROB Reliability Initiative, where we started taking on various pieces of our program to look for greater reliability in our application of the process. Certain things that we did were, for example, increasing our sharing of inspectors across the regions, benchmarking at the staff level. We also had our branch chiefs go to different regions to benchmark and see how they did business. We also created a forum for discussions of various ROP topics, as an example, application of subsequent cross-cutting issues and how did each region do that, and we made some checks and adjustments. And we also, of course, looked at our documentation, our own inspection reports. And then more recently, we did a comprehensive review of the problem identification and resolution inspection and looked at how the regions all did business. Now, since we've received the GAO report, we have also taken some further actions, and those are very actively being worked right now. I do want to note that the focus of this are on the lower risk, less significant. As the GAO pointed to, those seem to be the area where they concluded there was less consistency. And when we acknowledge there is some greater variation on those lower risk, less significant findings. So we wanted to look at how to maximize our examination. So we looked at what procedures seem to have the greater differences, and we identified the following four procedures for intense review. That's the component design basis inspection, operability evaluations, equipment alignment, and maintenance risk assessment. We're currently in the process of evaluating some results of some exercises we conducted. The exercises took minor and green findings. We put them in a format where inspectors and branch chiefs could review them and come to their assessments, and then those assessments are being compared, and we're looking for themes or looking for insights. We don't have those insights yet. Those assessments haven't been finished, but those assessments and those recommendations will also be worked with NLR and NSER OE in the regions. But some possible outcomes of that could be increased training, maybe on the underlying requirement if we see some lack of clarity there, or on existing guidance. I think it's probably likely we'll see some changes in guidance to try to make it more clear and more apparent so we can have greater application. But I think we need to keep focused on we can't expect that there will be a come and outcome. We're measuring or trying to do our best to measure licensee performance, and licensees aren't all performing in the same way. So we shouldn't have an expectation that we're going to have the same outcome. And that's why we've kind of steered away from the consistency and talk more about reliable application of the ROP. And I, too, would put a plug in for the two ROP sessions that are coming up tomorrow morning, session number 35, talking about those enhancement projects. Thanks. Thank you, Cindy. Maria, you may have perspectives regarding differences seen between regions. Interested in your thoughts? Yeah, thanks, Mike. We actually have, as an industry, seen a similar trend as to what was identified in the GAO report in terms of seeing some differences across the region. Some examples of this are, you know, some over-reliance on URIs or unresolved issues in one region, say, relative to another. We have other examples of 10 CFR 5072 and 5073 reportability and seeing some of those differences as it's applied across regions. We also have seen, in some cases, where we have some newer inspectors that have a lesser understanding of some of the older plant licensing bases. And therefore, they have a tendency to really want to address everything under a more current perspective. So those are some examples where I think we do, as an industry, see this variability across the regions. There are a couple of vehicles for us to create that discussion. There's the regulatory users group. NEI has an ROP task force. And we also just recently formed, again, within NEI, a working group, a regulatory issues working group. And these are all forums where we have an opportunity to discuss and create conversation with the NRC about apparent inconsistencies that we're seeing in the application of the ROP as well as the conduct of inspection and enforcement activity. In addition, I guess I would point that the NRC region staff does use technical interface agreements, or TIAs, to ensure that the NRC headquarters is resolved, is involved in resolving technical differences and issues that might otherwise be resolved in consistently. And I think recently you guys announced that you'll take actions to make the TIA process a little more transparent. And I think that would be helpful. Thank you very much. Anyone want to weigh in additional comments? Okay, this next question really relates to the use of contractors by licensees and oversight of contractors. And so, a specific question I'll ask Mark to answer and, again, Maria, from a regulatory perspective, how well has the industry been doing with oversight of contractors and from an industry perspective, what are some of the challenges in determining the proper level of contractor oversight? Thanks, Mike. Like I'd asked earlier, when we were providing our, I guess, significant takeaways or impressions from our visit to Fukushima Daiichi and Fukushima Daini if we had any seconds, and I wanted to, I had one thought and I would plan to talk about it in the context of this question, but I was particularly, there was a particular impression I had and I think Dennis Cole talked about this in the special plenary session and that was the extensive use of contractors at Fukushima Daiichi and Daini where when the contractor staff had to evacuate the site, the workforce that remained did not have the skill sets to implement or to conduct a number of work activities and examples installing and connecting instrumentation, installing a temporary power supplies and terminating cable ends, et cetera. So I thought that was particularly of interest and I'm sure the industry looks at to what degree does that apply to their sites when you're looking at implementing flex and your onsite staffing analysis, et cetera. But here regarding regulatory insights with respect to the use of contractors, I particularly appreciate the opportunity to answer this question because we have had some significant events and conditions in Region 4 that have resulted from challenges with inadequate control of contractors. I think everyone recognizes that the licensees retain ultimate responsibility for activities affecting quality that's prescribed by 10C Bar Part 50, Appendix B. And certainly contractors can be effective for highly specialized or infrequently performed evolutions where it may not be practical for a licensee to retain the resources to perform in-house. And then you have the aspect I would call of what I termed contract or oversight cascading effect. You licensee contracts for specialized work activities and then they end up contracting with a separate engineering organization to provide an independent review because the licensee didn't possess the onsite engineering expertise to perform the oversight function. And I think most significantly is this perception regarding contractors as experts and that impression can create some additional challenges in providing contract or oversight. I was talking to site management at one site in Region 4 about controlled contractors and a significant event that had occurred at that site. And one of the observations provided by site management was that what's the expected quality or pedigree of contractor deliverables? When you contract with an organization and they have extensive experience in that area, what is it reasonable to expect in terms of a deliverable and how much oversight do you need to exercise? And it was my understanding from talking to that site vice president that there's been some discussion in the context of info in trying to understand what is the right balance and how intrusive does a licensee need to be. I think another challenge that we see with use of contract organizations for licensing and design basis modification activities, it can be problematic in that the in-depth knowledge of design basis documents does not then reside within the licensee staff and that can complicate things like 50-59 reviews for plant changes, certainly come with case inspection activities and potentially emergency response. So I would offer we have certainly seen challenges with the control of contractors and there are certainly organizations that have done a very good job in that regard, but there are challenges there and certainly an area that I think the industry needs to ensure that they continue to devote an appropriate level of attention. Maria, thanks. Thanks, Mark. Well, just to state the obvious, I mean, we absolutely as the license holder understand that we own the performance of our contractors and we take that very seriously and the relationship with the contractor starts well before they're actually on site to perform any work and I think that's very important. If you look at the contrast with our employees who are there with us each and every day, you have an environment where you can impress upon them the right standards for safety and for human performance and the right values and you don't have that luxury when you're working with a contractor. So you have to take very deliberate steps as you integrate a contractor into the broader workforce and as I stated, that starts well before the job at hand. A couple of things that we do to facilitate that is in fact meeting with members of the management team of the contracting organization and so an example for that is a refueling outage is an area where we bring in several contractors and for our vendors, we meet with them well in advance of that refueling outage and we talk about the standards that we have and how are we going to impress those standards and in some cases use contractual language for incentives or penalties based on human performance and safety performance so that they can take it as seriously, obviously as we do, as they're impressing the same message on the folks that work for them and then in addition, we have a very rigorous process as we bring folks on site and especially if they're going to play any sort of supervisory role where we conduct oral boards if you will, ask them questions and make sure that they have sufficient rigorous understanding of the standards and our practices before they're even allowed to perform that role as a supervisor and as Mark stated, as an industry we have worked together with INPO and have provided or produced some industry guidance relative to contractor oversight and ownership I would guess just about at any station that you'd go in the United States it would be very similar and that would be any contractor would have an onsite sponsor and that onsite sponsor's role and responsibility is to make sure that they're very familiar with the rules and the standards of the station and then of course span of control is important too so you need to make sure that you have the right level of supervision overseeing the contractors so that you have the right level of span of control and that's something that we monitor very closely to make sure that we have the right level of engagement and oversight but even with all that prescription it's a challenge for us obviously each and every day to ensure that we are in fact being rigorous and intrusive after you've paid for this subject matter expert to come in and do some work for you that you value their subject matter expertise but you also need to make sure that it's being brought into your organization in a way that's within your guidelines and policies Thank you Thanks Mark, thanks Maria I'm going to again offer the opportunity for seconds if anyone feels compelled Okay Thank you I was like herding cats in Japan I don't know why we're so just kidding So this next topic, 5059 is one that has been of course important that regulation is important for us and for licensees of course 5059 reviews and inspections of 5059 have gotten visibility let's just say in the last year and a half greater visibility than the last year and a half and this next question really relates to the recent results of 10 CFR 5059 inspections and I'm going to ask actually Vic to tee up to answer this question and Danny actually Danny I'll ask you to start first the question is the results of recent 10 CFR 5059 inspections indicate the need for prior NRC approval for replacement parts that have digital components in some cases this could delay safety improvements at stations are there opportunities that could provide licensees the ability to more rapidly address digital obsolescence issues so Danny the subject of 5059 and those inspections I'll go first that's fine we'll give Vic the last word so 5059 is real important to us that's what authorizes us to go and make changes to our facility without our approval it's a big deal for us our plants are getting older we're going out and we're replacing components and we're upgrading components and we're making our plants more reliable by replacing these older systems and what we're finding out is some of these newer systems we'll have some type of digital logic piece or something on it and Michael mentioned 5059 inspection that was performed at another facility not at one of mine but we're getting ready to change some cards at our far away station we're going to do that last spring spring of 2013 had to put them on hold because they needed prior NRC approval that's what the 5059 inspection concluded was digital devices and then need prior approval before you can go put those in so a year later I still don't have them in and I'd like to get them in this fall but I still don't have a clear path where yet we're getting closer we're trying to work through that but broadly speaking going forward we're going to have this in a lot of different areas of our stations and if we go through and put these types of controls on getting additional reliability in the units then we're really going to be retarding getting the units modified getting them upgraded and getting them in the shape so it's hurting reliability of the units so we need to take a look at this digital piece is this what was intended and I'm not going to get down into the nuts and bolts because it really doesn't matter the bottom line is we'd like to be able to go out and have a program don't know what the program looks like but we'd like to be able to upgrade our stations without having to get some prescribed pre-approval so that we can get them upgraded and more reliable sooner I mean that's what we want to get to Thanks and Mike we are trying to be disciplined because one of the feedbacks that we've gotten from this session is that we haven't allowed much time for our Q&A from the floor so we want to do that you know I recall from the plenary session this morning when the last questions to the panelists was what are your top few key technical safety issues going forward I remember Tony mentioned that digital obsolescence was one of them so it is an important issue you did advise everyone to please silence your phones that's a clear sign so Danny alluded to the finding last year at one plan it was a 5059 mods inspection that did identify that a complex programmable logic device CPLD a software based device had been installed through an inadequate 5059 screening it did require a license amendment request because of the potential to introduce adverse consequences unlike fixed logic devices or circuit cards which most everyone uses and this isn't a new issue the industry recognized it almost well more than 10 years ago in 2002 NEI produced or provided guidelines for digital upgrades in NEI O101 based on a technical report and NRC issued a regulatory issue summary 2002-22 that endorsed or at least okay the use of this as an acceptable approach to upgrading to digital software based devices it did include a disclaimer though it indicated that it cautioned against using this guidance for safety significant applications such as a reactor protection system or engineered safeguard SFAS systems and in this case it was introduced into a solid state protection system so there was a concern and there was perhaps a misinterpretation not just by one but perhaps several licensees because the vendor did provide a sample screening a 50-59 screening and there again may have been some misinterpretation of the NEI guidance since that time we have been engaged with the industry and the PWR owners group very closely on this issue we have received and are evaluating for acceptance review a topical report in this area we're making a lot of good progress on that NRR does plan to issue an information notice in this area very soon accompanied by an enforcement guidance memorandum that will address this issue as well again to make sure that we know exactly what's going on and there's some provisions of that that'll I know we've talked with NEI about and we also understand that NEI is planning a revision to NEI 101 or the accompanying 50-59 guidance 9607 that will also help in this regard in the end I believe it's up to licensees to do adequate 50-59 screenings I believe that part of our regulations has been well understood I believe it's been used well we don't typically identify a large number of issues in this area however this is an area where we can do better so we'll continue to work with you on that okay very good thank you this next question comes from the audience excited for that start with that question the question is with five plants starting to decommission and five plants being constructed what extra steps are the regional administrators taking to provide good communication models with the plants and can or will you apply those models to the rest of the fleet so I'll open it up for the regional administrators to touch on I think Bill, Cindy, Mark but also Vic so in any order let me just start since we have had recently the opportunity to engage in decommissioning activities associated with the Crystal River which is a Region 2 site but it was recently transferred to Region 1 ownership because of a reorganization that we did some years ago where basically Region 1 handles all the materials related activities for the entire east coast including all the Region 2 states and so we have applied some pretty I think basic communication tools we've had management meetings with the decommissioning management team from Duke that occurred not long after we took over responsibility for Crystal River there's actually been several public meetings that have been held in the vicinity of Crystal River and one which I really was happy to see was conducted by the licensee I would encourage licensees to conduct their own public meetings to talk to the public and explain to them what the process is going to be and how you're going to manage activities during decommissioning in a safe manner and we've also had use of webinars as a means to communicate with the public and I know that Cindy has used webinars quite a bit in Region 3 and so we've stalled that tactic and technique from her so I think we've had some basic things I don't think there are things that are necessarily greatly different than what we do to try to communicate with operating plants but they do carry that different cache and of course those of you familiar with the decommissioning process know that there are actually scheduled or required meetings that take place during certain stages in the decommissioning process that are already pretty well dictated maybe I'll just add a little bit it's really always by case on developing a communications strategy for a site or for the issues and so I think we try to model what it is we need to communicate based on what our information excuse me what our stakeholders are interested in so we work closely with our public affairs staff who happen to be right here to try to discern what level of communication would be most appropriate so we certainly communicate with the licensee but we also have government to government meetings if that's appropriate for the topics in the area as Bill mentioned we have used a lot of webinars as a good tool to get out information to our various stakeholders public meetings whether it's a formal meeting or it's an open house because we think people will be more comfortable in asking questions and communicating with us so it really is whether it's an operating reactor, a decommissioning or materials facility we try to create a communication strategy that fits the topics at hand in the stakeholder interest. I'd like to offer a perspective in dealing with San Onofre nuclear generating station I know a number of you in this room can probably appreciate the very interested external stakeholder environment that exists in the state of California and we have gone to I would offer great lengths to ensure that we are communicating with the public such that they have a clear understanding of how we are implementing the decommissioning process we did conduct a public meeting I think it was back in October and November where we went through the decommissioning process we had a senior manager Larry Camper that led that discussion we have also made our inspection reports available to a number of people that requested it they've been added to the list serve and as Cindy said I agree it's a case by case and we have a specific communication plan we are trying to engage the stakeholders to ensure they have a clear understanding and then I think the licensee recognizes the importance of ensuring that they are openly communicating with members of the community in the case of San Onofre they've established a community engagement panel and have generated a charter to provide for input from interested stakeholders I think the degree of public interest dictates how frequently we conduct public meetings and outreach to ensure that we are adequately communicating the information and the results of our inspection activities and we've had instances where state officials have requested to accompany our inspectors on various inspection activities and there's a protocol that we go through to provide for that so I would just underscore that the approach that we adopt is really a function of the external stakeholder environment in the interest in ensuring that our inspection results are transparent and clearly understood thanks so just quickly Mike, the question asked for communication models for the five plants being decommissioned and the five plants under construction so I think the communication first starts internally we have to have alignment within NRC within the region the headquarters program offices on first how we organize who has the lead if you would lead the role in communicating we have to have frequent interactions to make sure that there's a shared understanding internally on what we're doing why we're doing it and how we're doing it and the same goes true for our engagement with our respective licensees and we've set up the organization within Region 2 for those plants under construction a good while ago I see Lauren Plisco back there he certainly played a key role in getting us organized the right way we have frequent discussions, frequent public meetings certainly for Watts Bar we have the Watts Bar restart assessment group and their meetings that are coordinated that are held quarterly and their joint meetings between Region 2 and NRC and the licensee and they're held either near the site or in Atlanta or here in headquarters and similarly the two AP1000 sites are under the construction reactor oversight process so we're following that model in terms of the public meetings that we have to have for that process as well okay was there anyone else who was going to weigh in on that question I guess we've got this next question I think is maybe intended to be a little bit provocative I'll ask it given all of your comments on Fukushima and the importance of issues those issues that we need to work on why are we allowing inspectors to reopen licensing basis questions that were resolved years ago and have little to no safety significance it doesn't align with all of you what all of you spoke about nor what the commissioners stated in their comments about aggregate regulatory impact so I'm going to ask Mark if you'd start with that and then we'll see if others want to weigh in I asked for the opportunity to respond to this question because I do have some sites in Region 4 where site management has communicated this very point to me during my visits to the sites here as I was transitioning to my responsibilities here in Region 4 and there are a number of factors that come into play here I think it is very important that we have a shared understanding regarding what is the potential safety significance of an issue you know sometimes you're dealing with pre-GDC plants sometimes in the licensing documentation there may have been a meeting between the licensing and the NRC and there's not a lot of specificity regarding the discussions and the conclusions and other issues that we've dealt with is retrievability of the licensing documentation an inspector brought an issue forward with one licensee regarding tornado missile protection and the licensee's response was well that's not in our licensing basis and the context here was either horizontal or vertical protection and the senior resident without a lot of effort conducted some research and sure enough in the licensing basis documentation was referenced to the facility needing to be protected against a vertical tornado missile hazard so I think there's a couple of factors that come into play one it is important that the inspectors are not dedicating time and effort to issues that have relatively limited safety significance and I see the importance of the branch chief exercising appropriate oversight and understanding and ensuring there's agreement that that issue is of potential significance such that it warrants some additional follow up but I also think licensees have a responsibility to be able to retrieve the licensing basis documentation that does disposition the issues and I have examples there where we had inspectors that were bringing some issues forward in the licensee's response was well we already know we have challenges in that area but if the inspectors have a question regarding operability or the adequacy of the 5059 you know they can't just say okay licensee is aware of their challenges in that area and not address that so I guess in summary what I would say is it does take an effort by both the licensee and the NRC to ensure that we understand whether there is an issue of particular safety significance and whether we're dedicating appropriate level of resources to evaluate that but for me it is an issue that's on my radar screen and I know that there are some challenges in that area that we need to make sure we get our arms around. Danny I'm sorry with you and then also Maria ask given Danny your role with respect to cumulative effects of regulation and in the context of Fukushima as the question was posed do you have a perspective you want to share regarding issues being dealt with in the mind of the person asking the question at a low level given the issues that we're dealing with with respect to Fukushima and other issues. Yeah Michael I do have a couple of thoughts and then I'll let Maria add on you know once a compliance issues out there on the table to me that's one thing but we seem to be applying a lot of resources and inspection hours and a lot of work to me in the areas that are not as safety significant and that's the ones where we probably ought to have them directed on the items that are safety significant I mean once you got a compliance issue identified I mean we as licensees are we got to go fix that we got to go make that right and that's ours to go do we just want to make sure that we're not distracted from what our focus should be every day safe and effective operation of the units that's where we want to be and we don't need to have our operators distracted from doing a certain number of management attention units that we have at the sites as well so we're very protective right now over what are we going to add what are we going to do different what are we going to start doing from this day forward we're still having additional programs that come out over the last decade we've had additional rules have been passed so we got additional inspections we got additional scope to worry about so I do understand the question I know why they asked the question we just need to make sure we got our resources focused on what's important and what's going to bring the best safety and the best value to the both the regulator as well as the stations thanks Danny well we talked about five plants being decommissioned and five starting up and we also talked about Fukushima and I would just paint in that picture the real onus is on both of us to be effective and efficient and to ensure that we're spending our time wisely and I think there are cases where things get kicked up and we spend time energy and effort on those when you have this volume of things that you're dealing with it's very easy to get task focused and then just keep running down the path and you sort of lose sight of what's the most important thing and I think the challenge in this case really is on both sides it's on the industry side as well as it's on the regulatory side to make sure that we are focused on the most important stuff for being as effective as an efficient as we can and create dialogue when we find in fact these examples if we think that we're chasing after something that's not really value add I think the real onus is on us to create the right conversation to say I'm looking at it differently glad to fix it if it's something that needs to be fixed but really let's not spend undue time if it's not value add I'd like to just add one real quick point to that Maria said really resonated with me and that I do know some examples where when I was at the site and I asked the licensee well have you elevated this concern and the answer is no and I would offer what Maria said underscores the importance of ensuring if you feel that the inspectors are engaging in an area that as you described does not value added and would result in an unnecessary expenditure of resources to resolve that needs to be elevated such that we can step back look at that and reaffirm whether it is something that we need to pursue or if necessary quite frankly do opportunity for some coaching and calibration okay this next question actually stays with a little bit the theme regarding inspections and issues significance of those issues and we haven't said we haven't said significant determination process yet I think in this discussion the question is what insights can you provide on experience with the application of the SDP when evaluating events involving operator actions and I'm going to ask I think Cindy if you'd start with that. Yes thanks this was one that we thought might come up so we did some polling with our SRAs as well as people that have been dealing with the SDP process and it's not an easy area when we're talking about human reliability and it is an area when we do have regulatory conferences that we have a lot of discussion about what appropriate credit is and so when we look back at our risk analysts we have a certain set of tools that we use it's our SPAR-H model our folks have training in that and they are the ones that exercise that program as well as peer reviews our SRAs don't work in isolation so we're getting multiple risk analysts that put their heads together because it isn't a cookie cutter approach there are judgments involved and I think what we tend to find is what the more difficult areas is operators recovering unknown situations things that they don't have procedures for things they didn't necessarily have training for where they would have to do more diagnosis figure out what to do how to approach it and so forth and so our assessment of that hasn't always aligned with industry's assessment of that where industry tends to give a little bit more credit for that and we probably are a bit more conservative on it but it's an area where we don't have a lot of hard and fast easy to point to data and so there is some judgment involved our best set of assumptions and our best set of reviews the point I guess I would offer to you is the earlier you have insights provide them and have our risk analysts talk with your risk analysts because often we can come to some common understanding but there will be times when we agree to disagree but the earlier we can have those interactions the better unfortunately sometimes these interactions happen very late in the process and it makes it more difficult for all of us I guess I'll reflect on that I had some personal experience with that in 2013 so I'll reflect on it a couple ways appreciate the rigor of the model that the NRC uses I do think that there are valid justification to adjust the numbers used when you're talking about procedures and training ample crew staffing this kind of thing and so I think we do need to create some openness relative to sort of all of the processes that we do utilize and in some cases I think play a significant role my personal experience through this one I guess I would also offer it appears to me that we create an undue wait for automatic actuation of systems and I guess I would ask for that to be really looked at in the case that we found ourselves in you know you could have put a system in automatic which quite frankly if it had automatically actuated could have actually created a much more challenging situation to deal with and so in this case in some cases purposely don't want to have something in automatic because you want thoughtful operator action to evaluate the situation and make sure that you want something or you don't want something and by doing that and crediting that thoughtful operator action it actually worked against if you will the formula let me just say that you get sort of more credit with the automatic operation so I think this very much is a case where there's never going to be one formula that's going to work when we talk about human reliability analysis but I think there does need to be more openness relative to some of the the credits that can be applied and not just a floor or a ceiling if you will for the number. Okay we've got a couple of questions that relate to Fukushima either the near-term pass force recommendation in this case the recommendation for the seismic re-evaluation I'll give you that question in a second also a question that relates to what we were able to see in Japan regarding the use of or the installation of filtered severe accident capable vents filters on those vents for BWRs and so let me actually start with that the question is during the visit to Japan did NRA talk about its mandate to require filtered severe accident capable vents on BWRs given the commissioner's decision not to support the NRC staff recommendation for identical safety countermeasures for USBWRs please comment on your comfort level with it with it can't happen here I think I recognize his handwriting the answer to the to the instant question is no we didn't actually probe with the Japanese regulator in any depth their regulatory requirements I think the commenter earlier this morning one of the speakers earlier this morning sort of drew the parallel to the response that the agency took or the country took actually following 9-11 and how serious it was for us because it happened here and what we recognize as really the role or the posture that the regulator in Japan has taken with respect to its seriousness given what they faced I did see at for example that they are installing they are installing filters in fact they're installing two filters a filter that is below grade actually because the local prefecture wanted it was concerned about that and so we do know to see there that there is there are filters being added we were surprised or I guess one question that I had was how small that footprint was and I hadn't actually appreciated the size of the footprint and so I think we were as a group sort of impressed by that I do want to recognize that the commission does have the issue but I did decide on the issue ultimately the commission will have to decide on where we end up with respect to the recommendation and it could look like actually filters or it could look like the use of filtering strategies or a combination of the two of those so that's how I would leave the answer to that question I do want to pause and see if anyone would add anything Maria you've had really close involvement on this I told Danny it was his to answer I've been very engaged with this as you know across the industry and I guess I just wanted to be very clear it has always been our perspective that we very strongly support filtering there's no question on the need for filtering and we're very passionate about it our challenge is that there's more ways to accomplish that than simply an external filter and our passion has really been to make sure that that filtering works and by putting the right tools in the hands of our operators we are ensuring absolutely that we are maintaining containment and if we're maintaining containment then it can be used as a reservoir if you will for filtering and so we're very passionate about the fact that it needs to be filtered our challenge is again not to be locked in there's only one way to do it and we feel very strongly that there are other ways to accomplish it and in fact other ways that put the operators in a position where they absolutely know they need to add water and keep that core cool because ultimately that's the solution set that maintains containment and that is the focus thanks Maria this other question related to Fukushima and near term task force the NRC foundation 2.1 the seismic hazard reevaluation is that licensees seismic hazard submittals are due March 31st 2014 and NRC prioritization is due April 30th 2014 only 30 days how will the NRC work with the 2.1 seismic industry task force to assign group 1, group 2, group 3 priority plants and will consideration be made by the NRC the NRC industry seismic resources on existing seismic PRA projects already underway pre near term task force recommendation 2.1 so again a very good question related to how we're moving forward and the person that raising the question has the dates just right we've worked considerably here from on the part of the NRC but also in terms of working with the seismic industry seismic task force that we're clear about what we need to see in terms of that submittal on the 31st of March and how we expect that submittal to be factored in or considered by the NRC of us making near term decision with respect to prioritization and a near term decision with respect to what if any interactions are needed for those plants where they are necessary I think rather than try to answer the details of the question I want to adjust this I will say that we've had considerable interaction we issued a letter NRC issued a letter actually to the industry that talks expectations with respect to, for example, operability and reportability. That letter is certainly publicly available. We call it the lead's letter, but I'm told that Jennifer signed out the last one, I know. But it's still called to, so refer to it as the lead's letter. But I think that provides clarity with respect to sort of the immediate decisions that licensees have to make. There is a more detailed approach that we'll use in terms of stepping through the decisions that we have to make. We've begun sharing that, we'll share that broadly. We're sharing it internally, we'll certainly share that. We talked in fact, had an interaction in the last couple of days about how we roll that out from a communications perspective. We do want there to be clarity with respect to how licensees would respond. And we are, in terms of looking at, there'll be a product from the NRC that provides that bending, if you will, that was very similar to the letter that provided bending for the case of the initial work that we did on flooding, the flooding reevaluation, there'll be a very similar letter and we'll interact with the working group in terms of how we set those bends up. And we're being mindful of the fact that we do really want to make sure that we get after, if you will, the plants. We consider where plants fall out in that bend based on the priority that we see arrive at based on what's provided in the re-analysis. So I'll just try to leave it there and I will indicate that there are folks in the room who can provide additional answers and there'll be more information coming with respect to that. I want to switch gears and talk about part 37. Michael, can I add one thing to that discussion you just had? It's really from the point of prioritization, I mean, if I look at where I think our units are going to line up, I've got a pretty good feel for what priority they're going to fall in and where they're going to be and what we're going to do. But if you look across the nuclear fleet, I mean, we need some help with prioritization. You know that, we've been talking about having to go do these SPRAs. So we're going to go do seismic PRAs. We know that's where we want to go and we know there's a limited resource in providing those. So we're just asking that we take a look at how many of these are going to be required, who needs to do them and when they need to have them done and lay out that prioritization effectively. I think that's something that would help the industry out a lot in getting these things done in the right order, in the right order. Yeah, absolutely, Danny. In fact, the way in which we approach, we've sort of been alluding to the follow on steps and, for example, the use of the expedited approach, for example, the way in which we've structured all of that is to recognize that there are some things that can be done near a term. We want to screen out and then screen down and have actions in place to buy the time that we need for plants to do a seismic PRA for that small subset, hopefully smaller subset of plants that have to do a seismic PRA. So we've built that approach in mind. Again, with actions to take interim actions and actions through the expedited approach for plants that need to do that to buy that time. We've been working together, as you know, Michael, very hard on this. I'm hoping to say that we can reflect back on this one and it will be a success story of both the industry and the regulator in terms of ensuring that we are using effectively our resources. And we're spending those on the ones that need it and at the same token given credit for previous analyses like IPEEE to use the results of that to say, based on that, I don't need to spend resources on this one over here. So a lot of hard work has gone into this prioritization and this screening process. And I think job well done on both the regulator and the industry's part. Okay, so we have five minutes. I think that's time maybe for one more question. It'll be part 37. And the question is, what impacts are you seeing as result of preparations for the new part 37 rule at operating reactors? Bill, do you want to? So let's go back on the way back machine one more time. So the events of 9-11 led to a flurry of activity by the agency in terms of putting out a number of orders to a variety of licensees, both reactor materials, licensees in terms of enhanced security measures that we expected them to take. So some years ago, we issued part 73 to revise a power reactor security rule making. And when we issued that, we had a bit of a late in the game realization that, oh, by the way, this rule applies to part 50 licensees. And there's a number of decommissioned sites that are basically ISFACs, independent spend fuel storage installations that fall under part 50. And the rule applies to them as well. And that led to a flurry of activity and probably some unnecessarily regulatory burden on some of those licensees, in order to try and resolve that issue through the appropriate regulatory processes. So part 37 is basically the codification of the increased controls orders that were issued for materials licensees. And so it's being called the materials security rule making. Well, lo and behold, again, sort of late in the game. So this demonstrates that even though we talk about being a learning organization, maybe we're not as good as we can be sometimes. That power reactor licensees also had a piece of the pie. Now, that doesn't mean that our part 37 rule specifically addresses part 73 and basically exempts licensees from having to apply part 37 requirements. But basically within the protected area and taking credit for the licensee security plan. But what we didn't think about was that there are outside of the protected area at nuclear power plants, certain large components, many of them stored in robust structures, things like steam generators that were removed from the plant or reactor vessel heads and so on. So these huge monstrous components, but they meet the requirements of part 37 because they contain a category one or two quantities of material. And so here we are with the rule coming into implementation on March 19th, working to get out a enforcement guidance memorandum that will provide some relief to the nuclear power plant industry relative to these large components so that we can appropriately not cause them to be in violation of part 37 because of sort of the late thought that those needed to have the same sort of controls as materials licensees. So that EGM I think is going to be out if it's not out already. It should be out fairly soon. We concurred in it this past week. Yeah, it's been concurred in, but I'm not sure if it's been publicly released yet. So we're working with industry. I think there's been a couple of meetings in a very recent past to talk about this. I guess I'd be interested in Danny or Maria's views in terms of how they feel that dialogue. I got one thought and Maria, I'll let you have it. I mean, the biggest thing to me is if we got a part 73 rigorous security program at the plant, then we shouldn't be applying part 37 on top of part 73. To me, that's the biggest thing. We've got overlapping programs. Part 73 is robust. We know it's good. So we got it inside the fence. So I think we should support a change that says, hey, if you got part 73, then part 37 does not apply. Yeah, I agree with Danny's request. I do think ultimately we need to look at that. And the industry would support a change to part 37 that would exempt based on our already robust physical security measures that we have in place. You did mention the large components like old steam generators and reactor vessel heads. There are in some cases some sites that also have some category one and two material like resins and those kinds of things that are located in the owner controlled area. And so those are things yet that we need to ensure are covered under this part 37. But I do believe NEI has taken the appropriate action and they have an industry template for these plans to be completed. And it is expected that all of the sites will in fact have a part 37 security plan in place by March 19th. So I think the immediate items will be in place. But I do think as an opportunity for us to step back, again, going back to are we focused on the most important stuff and make sure that there was a need for part 37 to be applied as opposed to just taking credit for our already robust security plan. Okay, we're out of time. I have one more question that I held for the end hoping we would be out of time so we wouldn't have to deal with it. And I'm happy to say we didn't ask it and we won't answer it. But didn't ask it and won't answer it. But the question is if a situation like Fukushima occurred in the US, how would the regulator and I would extend that to how would the industry deal with the build up of large quantities of contaminated water? And again, we'll answer that question as we answer questions that don't get asked in session. But that question I think points to the fact that with respect to Fukushima, we will continue to learn lessons. I think it was an eye opener, as I think Tony mentioned in the earlier session, just the quantities of wastewater and how do you deal with that, the decisions that Japan is making with respect to allowing people back in. All of those things that they'll have to work through will be opportunities for us to learn and to look to see whether the things that we need to do with respect to either our posture as a regulator or things that industry would need to do. So it's a good question, we'll answer it. I want to just pause and say thanks to the panelists. Thank you all. Did a wonderful job, you're welcome. Thank you for your attendance.