 All right, if I could ask everyone to take their seats and we can get started. I welcome everybody to the best technical session of the RIC, you know, it's T1. So, and we have the QR code up for those of you who are in person here for asking questions, just scan in the QR code, and then you can ask your questions. We'll be monitoring questions for the speakers. And what I plan to do is I'll introduce all the speakers and we'll go through the presentations. If an interesting question comes up that is very particular to a speaker, I may ask it at the end of the speaker, but my plans in general is to engage the whole panel in the discussion. Again, my name's Ray Furstinam. I'm the director of research here at the NRC and I welcome you to the session. Beyond Earth, the future of nuclear technology in space. So some of you may, the last time we had a RIC session on space nuclear was a couple of years ago in 2021 and I had the honor and pleasure of sharing that session as well. We heard from various agencies what had been done in the last 60 years from DOE's perspective. For example, we heard from DARPA of the work that they were doing on space nuclear and their Draco mission. And we heard from NASA about the different missions planned as well. This year, we have a different set of speakers. We'll be sharing perspectives on the current and future happenings for nuclear technology in space. We're gonna have some perspectives on safety and regulation from Tina. Tina goes, she's a member, our alternate member to me on the Interagency Nuclear Safety Review Board. She really should be the member. I'm the member for the NRC, but Tina does all the work. We'll make no mistake about that. So, and we also have the FFA member to the insert that Carl Garmin who will also be speaking. And then we also have NASA and BWXT to get a view from commercial perspective. So, I'm gonna do that a little bit more on each speaker and then we'll get started with the presentations. So, Tina goes, I'm very fortunate to have her in my office of Nuclear Regulatory Research. And she has been with the NRC for 18 years and she's a senior reactor systems engineer and has led completion of some pretty significant studies at the NRC on uncertainty analysis in our state of the art reactor, a consequence analysis project. So, she's really well suited to represent the NRC on the Interagency Safety Review Board. She holds a BS degree in civil engineering from Princeton and MS in technology and policy from MIT and a PhD in Nuclear Engineering from MIT. So, thank you Tina for being on the panel. And next speaker after Tina will be Carl Garmin. He's an aerospace engineer in the office of commercial space transportation at the Federal Aviation Administration here in DC. And his role in that office is R&D and Innovation Branch includes being the research and development lead for commercial nuclear spacecraft. And he's also on the INSERV as well, the Interagency Review Board. Prior to his current role, he led R&D programs in the epic phase next generation organization to integrate unmanned aircraft space systems into the national airspace systems. Dr. Garmin, he earned his PhD in Earth and Atmospheric Sciences and MS in Aerospace Engineering on Purdue and also MA from the US Naval War College. Outside of his FAA duties, he's also assigned as a reserve officer. I got to get the Navy ranks, right? It's commander, right? I keep thinking Lieutenant Colonel, but it's the same thing, right? And in the Coast Guard, he's assigned to the Joint Chief of Staff at the Pentagon. Next, we'll have Jay Jenkins, Jay's program executive in the Exploration Science Strategy and Integration Office within NASA's Science Mission Directorate and was part of the early team that kicked off NASA's commercial lunar payload services project. Mr. Jenkins, he's a recipient of the SME International George Westinghouse Silver Medal and two of NASA's exceptional service medals. And he's now in his 14th, I'm sorry, you're not in your 14th year, the Lunar Orbiter Reserve, it's 14th year, I'm sorry. But he served as a program executive for the NASA Lunar Precursor Robotics Program, which includes the successful lunar reconnaissance orbiter now in its 14th year of orbiting the moon, providing data to NASA's Lunar Exploration Program Artemis. And next, we'll say for last is Justin Casper. Justin works for BWXT Advanced Technologies and is the Chief of Technology supporting the development and demonstration of new nuclear power and propulsion systems for terrestrial and space applications. Before coming to BWXT, Justin was a professor at the University of Michigan College of Engineering and he was a civil servant at the Smithsonian Institute. Dr. Casper is an experimental physicist with 25 years of experience. He had his A.B. in physics from University of Chicago and his Ph.D. in physics from MIT. So it looks like we have some couple of MIT alumni here on the panel. So with that, I'd like to get started with Tina Ghosh if you'd like to begin with your remarks. Thanks. Sorry, I thought those slides had to switch. Welcome everybody and thank you for coming to our session today. I wanted to start with just a very brief timeline that is most certainly not to scale, but just to kind of remind all of us that space exploration now has been going on for many decades and actually some nuclear component has been a part of it almost since the beginning. And really also, again, going way decades back, there's always been some kind of focus on safety. So for example, NASA's Nuclear Flight Safety Program was established many decades ago again and there were safety reviews back then and up to more recently through the ad hoc interagency nuclear safety review panels and I'll talk a little bit more about more recent changes with respect to that. And then also in terms of national policy and international policy and guidance that's been put out, in the 70s there was already the National Security Council's Presidential Directive 25. The United Nations also put out their principles for using nuclear power sources in outer space in 1992. And then the IAEA had a safety standard series, which is referenced in further policy now. I'll get to a little later. For example, the safety standard series number six. On the top of the timeline, I just note a couple of the more recent missions that I'm sure you all are familiar with, the Mars Science Lab in 2011 and most recently NASA's Mars 2020 mission, which had radio isotope power sources aboard. There's also radio isotope used for heater units and there's one US mission that had a reactor that was sent to space as well. So there's a rich history but what I will really be talking about for the rest of my talk is the recent policy that was put out, NSPM 20, the Presidential Memorandum on the launch of Spacecraft, containing space nuclear systems, which established the standing now Interagency Nuclear Safety Review Board, which I will talk about more in the rest of the talk. There are also a couple of other policy directives in an executive order that has been significant in spurring a lot of commercial interest in this area as well. And that's Space Policy Directive six. The National Strategy for Space Nuclear Power and Propulsion, as well as Executive Order 13972 for the promotion of small modular reactors for national defense and space exploration, which for example asks for the development of a common technology roadmap and pathways for transitioning technologies developed through federally supported programs to private sector activities. The roles for that are mainly for DOE, NASA and DOD but just for completeness, I did want to put that on the timeline. So on the next slide, I just wanted to dig into a little bit. What did the NSPM 20 Memorandum actually do? What were some of the new aspects of it? So there are a few significant things. First is that for the first time, there are explicit safety guidelines that have been laid out in terms of risk to members of the public from space launches with nuclear materials. So in particular, it establishes some thresholds in terms of doses that the public may incur and what the associated probabilities should be limited to. I'm sorry for that. Sorry for that. Maybe I should step back a little bit. So to give you an example, for if a risk assessment shows that a dose to member of the public may be in the range of five to 25 REM, the expectation is that you could show that the probability of that is going to be less than one in 10,000. And for something larger than 25 REM, less than one in 100,000, just to give you an example. So it sets out risk criteria that are expected to be met. In addition, it establishes a risk informed adhering approach for the launch authorization itself. So for those missions that are very low risk, it's expected that there should always be a safety analysis done, but that the head of the mission organization can actually authorize that launch. And then for higher potential risk missions or those involving certain amounts of radio nuclides that are specified in terms of that IAE, a safety series six that I mentioned on the previous slide, you could either have a tier two mission or a tier three mission. And again, depending on the risk to the public as well as what radio isotopes are on board and whether or not you have a fission reactor. If you have a fission reactor on board and you're using low enriched uranium, then you can still be tier two if you meet the risk thresholds for your tier two mission. But with a fission reactor device that uses anything other than low enriched uranium, you would automatically be at a tier three. Another thing NSPM 20 specified is that the sponsoring agency has to produce a safety analysis report which demonstrates how the safety guidelines have been met or better or exceeded. And then as I mentioned, the rest of my talk is really gonna be about the INSIRB. NSPM 20 now establishes a standing interagency nuclear safety review board to review the SAR and to produce a safety evaluation report to document its findings for US government launches and potentially for commercial launches if the Department of Transportation requests it. And as an aside, I'll just mention the DOT's FAA was always the safety authority for commercial launches involving nuclear materials and they continue to be so. So now for the rest of my talk, I will focus a little bit more on this new interagency nuclear safety review board. So as I said on the timeline slide previously, there was always interagency nuclear safety review panels that were put together for mission reviews but the difference now is that NSPM 20 requested NASA to help establish a standing board that has membership from seven different US governmental agencies. So that includes NASA, the Department of Defense, Department of State, Department of Energy, the Department of Transportation, Environmental Protection Agency and the Nuclear Regulatory Commission. And the point is that the INSIRB serves as an advisor to the sponsoring agency that has a mission to provide insights on its safety review in the form of a safety evaluation report. Now NSPM 20 was pretty high level in terms of describing what the INSIRB should be. There's a total of one paragraph in the memorandum itself in terms of what the INSIRB is and what it should do. So once the INSIRB was established with the seven agencies naming members to the board, the board has gone ahead and published some additional documents, both to describe for itself and also interested parties how it's gonna work. So the first is a charter, which is about a seven page document that describes kind of how we expect that the board will work and gets into a little bit more detail with regard to how things are gonna work. So the charter is about seven pages. This is publicly available. And then there's another guidance document that goes into a little bit more detail, which we are calling the playbook so that it's not confused with other kinds of guidance documents that are out there. It's kind of a new terminology. And the playbook goes into even more detail with regard to the expectations, the board's expectations of how we will operate and how things will work going forward. And really the intention of these documents is to provide potential missions with some predictability and transparency with respect to what they can expect. We wanted to provide some continuity in the safety evaluation process and be able to have stable practices and lessons learned from mission to mission. And really the point is to help be more open, transparent, efficient and effective in our safety reviews. On the next slide, I realize that the writing is really small. But the nice thing about the RIC is that all of the slides are available on our website after the fact. And in addition, the slides have hyperlinks to the actual documents that are publicly available through the NASA's website. So if you wanted to dig into the details, you can look there. But what I just wanted to give you a glimpse of is some of the contents that are in the playbook. So this really describes this, this is a figure in the playbook that describes what the review process is expected to be and kind of who does what. So the blue boxes are activities that are performed by the sponsoring agency for a mission. The green boxes are activities performed by the entity that would be performing the nuclear safety analysis report. And the orange boxes, what INSIRB would be doing. So you can kind of, if you kind of glance at it and just look at the colors, you kind of see, obviously early in the process, you know, the mission is setting, you know, what are the requirements? Then they're getting support, you know, from the green boxes with the organizations that they have supporting them on actually doing a safety analysis. These eventually come to the INSIRB. And then again, in the playbook, there are some more details about what we would do once we have a mission on hand. So a mission specific review plan is expected to be developed. The INSIRB would designate a review group which is like a subset of the INSIRB membership. And you know, eventually there's a process by which we hope the INSIRB would be involved early in the process to provide feedback at key aspects during the safety analysis and development. And eventually the end product is a safety evaluation report that would go to the launch approver to inform their decision. There's also been some questions about who does what for different types of missions that may be on the horizon. So historically we've had a lot of experience with government missions. But again, now there's more interest in commercial entities coming forward to participate in some way. So there could be a government only mission, a hybrid government commercial mission or a commercial only mission. There's actually a lot of different possibilities. But again, the board at least wanted to start laying out some thoughts on who would do what and especially this particular table is with respect to an aspect of NSPM 20 where it discusses that there is an expectation that there would be technical peer review of the safety analysis. And in addition that if there is already a system safety analysis report that's available that for efficiency a mission for the launch approval stage could rely on that system SAR to help demonstrate its safety case. So this table is kind of an attempt at laying out who does what. So the first case, the blue case, case one, this is the traditional case that we've seen a lot with for example, NASA's Mars 2020 mission would fall into that case where the DOE and its contractors produce a nuclear safety analysis report. There are some technical peer review as part of the DOE process. The DOE produced a SAR. And then in that case, it was the interagency nuclear safety review panel who took care of the interagency portion of the review. So this is for a nuclear system and then the same for the flight aspect. You have these different bodies doing the different steps and then who actually does the launch authority again depends whether it's a government or a commercial mission. Again, the second case is an example where you may have a Department of Defense space reactor. The last time we had a rec session on space nuclear, everyone heard about the Draco mission so something like that would fall into this category. And then the third is one where you would have a purely commercial mission. And so in that case, for example, NRC is the licensing authority for everything that occurs on earth. So any manufacturing, transportation of nuclear materials, testing if there's gonna be any testing and so on. So all of that could then be referenced in the future launch application where the interagency review comes in. So there's more on this in the playbook but this is just to give you an example of kind of the things that the NSERP has started to lay out in its documents. And that was my last substance slide. As I said, all of the links in the slides if you go on the web are hyperlinked and you can actually get to those documents. And, oh, sorry, that's okay. The last slide was just a list of references and I will just also point out that the NSERP documents that we have on the website, we collect feedback, we had solicited stakeholder feedback and we continue to do so. So there's an opportunity to comment on it and the board would periodically consider those comments in the future updates to those documents. So they're not set in stone forever but they're meant to give everybody a look at what the current thinking is with regard to guidance. Okay, and I think that's it for me. All right, thanks Tina. And I think the links you talked about are, it's important if you're interested in this kind of stuff, go into those links, there's a lot of good information there and I think Tina did a good job at kind of getting it all in one place. So thanks for doing that Tina. Next we have Carl Garmin who's from the FAA and gonna give his perspective on space nuclear, Carl. Thanks, Ray and Tina. So a couple of things up here, not only is part of FAA office of commercial space transportation, not only is part of the NSERP but also as part of the larger US Department of Transportation. I say that because we're not the only modal agency as we say with a stake in this. There's also the Pipeline and Hazardous Materials Safety Administration, PHMSA that also has a tie in with nuclear related things. But since the NSERP is actually made up of DOT members, FAA is one of those modal administrations along with PHMSA. I just happen to be from the FAA perspective in that case. So I just wanna step back a minute and just articulate with a nice backdrop of what is FAA's role in this? What is the Department of Transportation's role? Really, we're the public safety regulator. The FAA Office of Commercial Space Transportation really has its starts in the 1980s. And that happened because in the early to mid 1980s there was a growing sense of that non-government agencies could be a part of the space field. But there wasn't really a regulatory pathway to that, there wasn't really one unified type of office in order to facilitate those different types of public safety related issues, concerns, deconfliction with air traffic, things like that. So there was the Commercial Space Launch Act of 1984 which really formed the impetus and the regulatory basis, legislative basis I should say, for the commercial launch and reentry field and then assigned that role to the US Department of Transportation and since then has been delegated down to the FAA. So sometimes you'll hear about commercial space being a new entrant. I kind of want to dispel that myth because FAA has been licensing commercial space launches and reentries for quite some time now. I mean the first launches, commercial launches were in the 1980s, late 1980s. So if someone is a new entrant, how many decades does one have to be operating to not become new, you might say. So what is our role in this particular field? Well, we've got the statutory authority and is assigned to carry out those responsibilities of ensuring public safety, national security and foreign policy interests of the United States as they pertain to commercial launch and reentries. And so that's done through Title 51 US Code and also through Title 14 of the Code of Federal Regulations CFRs. Primarily, there's a little bit here and there but primarily it's Title 51 US Code and then Title 14 of the Code of Federal Regulations. Just passed an important benchmark. Recently we regulated the 500th commercial launch and safe launch. I was without any issue to the uninvolved public and we define that as death, serious injury or major property damage to a member of the uninvolved public. And that uninvolved public thing really is the focus of our safety mission. And we regulate through a multiple of different means, launch license, we deal with the public safety licensing for the hazard areas, debris, et cetera, mitigation but then also on the reentry, on the return piece. If there's a reentry license, we'll be the ones issuing it, we'll be the ones regulating to it. And then also of course deconfliction with air traffic. Our regulations tend to be focused around protecting the public against a shower of shards if there's a mishap. So, you know, the nuclear field is quite new to us, you know. But then again, we've administered rules that have been on the books for quite some times, dealing with toxic, dealing with environmental, so we're very familiar with NEPA processes, National Environmental Policy Act, et cetera. And one of the things that we do for radioisotopes is review on a case by case basis. I think that's kind of an important thing. When you look at regulation of aerospace work and regulation of nuclear topics, you kind of think at first, what does one have to do with the other? But you'll find a nexus in one location, you'll find a nexus in another location, you make it go, hmm, there are some similarities behind different things, even though it's a, there seem to be very different topic matters. And one of those is the case by case thing, is that case by case, looking at the particular situation and particular design aspects of different applications has a lot of heritage in the atomic energy field. And it's also what we do here. I mean, we have a rule on the books that is case by case, we'll evaluate that on a case by case basis whenever there's a nuclear, I should say radioisotope is the actual term in the rule regarding that. But of course, this is a new area. And like Tina had mentioned, there's NSPM 20, but realistically, just take a step back, take a deep breath in and issuance of a presidential memorandum is not going to instantly make an industry or even a regulatory framework instantly mature. So there's naturally a transition space involved in there. And of course, for rulemaking, there's a lot going on or a lot involved in a rulemaking, I should say. So the rulemaking, there's proposed rulemaking, there's a draft rule, then it goes out for public comments and legal review, et cetera. And then that is a multi-year process because you're dealing with regulated parts of the public. You're dealing with members of the public who naturally have a stake in public safety related things. So there's that rulemaking piece is part of the formula here, but that tends to be pretty long on the horizon. It's just the way that the administrative procedures act at all, prescribe things and how long those things end up taking. So a few interesting things. Tina had mentioned kind of the spectrum of different mix of activities. One could be government-only launch, one of them could be scenario, could be a mixture of commercial and government, and then another one, even purely commercial. This is something that NASA and FAA, for instance, already has done and continues to develop. If you look at the recent launches of government astronauts, government astronaut, government employee, government mission, but those were actually on commercially licensed and commercially conducted FAA licensed launches, and so are the re-entries. So there is, again, a nexus in this kind of field. So those are the basic framing aspects that I wanted to share with you of this, because this is not an aerospace audience, primarily a nuclear-related one, and to preempt the questions of, what is the Department of Transportation, FAA's role in these types of things? People usually think of us as air traffic, keeping cylinders of people with wings on them from colliding or having close calls with each other in the airspace, or regulating egress paths in aircraft for the flying public. What is the OTFA's role in this? And I just want to give some framing thoughts as to where that is and then whether we're tending, and hopefully that'll better inform discussions in Q&A over what are some things to do and then how to go about that collaboration in the future. Thanks. Thank you, Carl. Appreciate your remarks there. Next up, we have Jay Jenkins. He's the program executive for the NASA Science Mission Directorate. So I'll hand it over to Jay. Thanks. Thanks much. It's, excuse me. It's really a pleasure to be here. It is a new environment for me, an NRC conference versus a NASA conference. Also interesting thing is that NASA deals with technology all the time and actually the biggest innovation that I'm gonna be talking about today is procurement. So what am I here to talk about? I'm here to talk about the Commercial Lunar Payload Services Initiative that we started up at NASA back in around 2019 kind of timeframe. And the interesting thing about it and the innovation here is that it really is a procurement innovation. What it is is that we're procuring as a service, frequent, rapid and affordable access to the lunar surface. We're trying to adopt a model which is as close to like a FedEx model or a UPS model as possible. We wanna take our payloads and them over to a vendor and buy the service of having them delivered to the surface of the moon and then operate them for us. To the greatest extent possible, we wanna be completely hands off in this entire process. So we've got a field of about 14 competitors under an IDIQ that is indefinite duration, indefinite quantity contract. And then they competitively bid for firm fixed price task orders. So again, this is another new thing, a relatively new thing. I know that there's been a lot of firm fixed price procurements but generally speaking NASA does cost plus fixed fees of things we continue to change requirements and as a result we have cost increases and delays and changes of scope. So going with this firm fixed price approach, we start out with the payload. We write our requirements very firmly and we basically say thou shalt accommodate this payload and operate it on the surface of the moon and then we don't wanna change any requirements from that point on. Ideally we want to be one of many customers. This is not something, several of my colleagues will often refer to this as us being an anchor customer or anchor tenant. I hate that expression because you can't ever get rid of an anchor. I like the idea of being a first adopter instead. My career will be a success when one of the Clips providers goes without a single NASA payload on board, right? We want this to be a true commercial venture. We want it to enable a space economy in the course of doing this. And that's really why we're initiating this as a first adopter kind of approach. But the thing about this then is that these are not NASA missions, right? These are purely commercial missions even though NASA has this active part in it and yes, admittedly, we are buying 90% of the available space on board a lander for any particular delivery, sometimes 100% of the space. But that's not the intent in the long term. We realize we've got to take the lead in terms of buying most of this capability so that they can get their feet underneath of them. But they are not NASA missions and as a net result, we don't impose upon them any of our NASA standards, which is different. Plus, NASA's not a regulatory agency anyway but NASA does a launch, we regulate ourselves. We are a participant in the insert process. As you saw, we have that distinction that there's a distinction from Tina's chart with the government launch of nuclear versus commercial. So all of the stuff that we would normally do for ourselves, for example, an RPS launch is something like that, is not something that we're doing for a commercial launch. So the Clips providers are responsible 100% for all of their systems, they're responsible for the procurement of the launch vehicles. We do not have NASA launch services program for procuring launch vehicles and so they don't have that history that of the involvement that our LSP folks, that's launch services program, contributes into a commercial or into a nuclear launch in the past. They're not leveraging that experience directly. So NASA has no oversight and very limited insight into any of these. We don't even receive status reports. I do not get a monthly report from the vendors. I don't get risk five by fives. A lot of what we're doing is basically by virtue of the, in the trenches interaction between our payload integration managers and the integration managers of the Clips providers. So when we're looking at the business model for Clips, we want them to be able to do business with any entity or any government entity in exactly the same fashion. We don't want it to be more difficult to do business with NASA than it would be to go with a commercial provider. So this is just, I'm not gonna go into a whole lot of detail here on this chart but this is basically to show, this is real. This is real. We've got eight deliveries and a ninth one that's coming up very shortly. Now admittedly one of those there, the 19C with Mastin several of you may have heard that Mastin is undergoing bankruptcy proceedings. So we don't anticipate that one to actually be fulfilled but the remaining seven, they're all on track. We've got three deliveries that we're anticipating going to the surface of the moon as a commercial service here in 2023 as early as next May. So why is nuclear policy relevant to all this? Right, I'm not demanding a nuclear technology that's being launched. NASA's interest in this in particular are to have a survive the night lunar capability. Right now all the clips deliveries basically land at lunar morning and they end at lunar evening. For those of you who are moderately aware of astronomy and that, that the moon does go through day night cycles and their day is the same as our month, right? And so you've got two weeks of daylight and two weeks of night. And so we have to combine right now where we're at in terms of the technologies of surviving on the lunar surface, we're basically only doing our operations during the day. And that's very, very limiting, especially for experiments that we'd like to go for a very long term for months or years in order to monitor geophysical properties in order to monitor various other aspects of the moon. So survive the night capability or STN is very highly desirable. We want the clips providers to be able to provide the platform to operate our payloads both during lunar day as well as in the lunar night as well as in permanently shadowed regions. There's some areas in the poles of the moon that the sunlight never gets to. And we believe actually we've confirmed the presence of ice, water ice in the bottoms of those permanently shadowed regions. So when you're operating with the solar powered vehicle, it's kind of difficult to be in that permanently shadowed region and extracting those volatiles in order to use it for exploration of science purposes. And so we do have an abiding interest in having this survive the night as well as this permanently shadowed region operational capability. Now this could apply at the system level. Under the clips model, again, we say, here's our payload, you're responsible to accommodate it. That means we're expecting you to handle the fields of you. We expect you to not freeze it and we expect you to not cook it. We expect you to take it to the surface of the moon and operate it according to the parameters that we need and give us our data back in the process of it. So indirectly we end up encouraging the clips providers to start providing the survive the night capability and then what solutions they come up with whether it's a battery solar array arrangement or if it's a commercial radioisotope arrangement or even fission. Well, fission is not going to be very likely given the power levels but we do anticipate that a commercial radioisotopes are going to take a significant role with the clips providers in order to provide a survive the night capability. You can do things with solar arrays and batteries but the battery mass just becomes enormous when you start trying to operate for two consecutive weeks of night. Or this can apply at the payload level. Maybe the clips providers aren't going to be ready for this and we have to start coming up with some technological solutions and incorporate that survive the night capability within our individual payloads. So it's two different circumstances here, right? So the clips providers totally responsible for the launch and totally responsible for the mission or you could have a government or non-government payload that has a nuclear capability that we then hand over to the commercial entity and then execute it as a commercial launch or of course it could be a combination of the two. And again, we want to make sure that whenever the clips providers doing business it's the same whether they're doing business with a commercial entity or with the government. So this brings to about a whole bunch of questions about the nuclear landscape. These are kind of ongoing subjects of conversation that NASA has been engaging with the other agencies that are related to the nuclear launch activities. We're actively engaging and having several discussions as to who's on first and et cetera. We have this increasing need to survive the winter night. We have this increasing need or interest in the development of commercial radioisotopes. So this is demanding and increasing clarity for the regulatory environment. Whereas NSPM 20 is very clear about who the authorities are. It's less clear as to exactly what the regulatory pathways are, who calls up whom, who's setting the requirements for what. So we do anticipate having to deploy nuclear systems on the lunar surface. And I say it's not unrealistic that we would want to do it within the next decade. Honestly, it's not unrealistic that we'll want to be able to do this within five years or less. We are starting to buy payloads that are meant for investigations that go beyond one lunar day. So whereas the US government does have our experience in terms of launching radioisotope systems, we don't really have that direct experience in terms of regulating a commercial entity to do it. Yes, we've done safety assessment reviews. But the people that were anticipating would have to do the reviews, they haven't. And they haven't been imposed with any specific requirements to do so. So whereas, again, the NSPM 20 is very, very clear, the exact details of it are less clear. Similarly, the space treaty and how we're all going to be peacefully using outer space and the agreements of the UN copious, it's all laid out on a country level. That's fantastic. But there's a lot of aspects of that that don't necessarily flow in a regulatory capacity down to a commercial entity. And so we have to figure out in the absence of regulatory authority how do we address specific things or when we identify who the regulatory authority is and start flowing down the specific requirements for the compliance to US treaties and such. So I just kind of wanted to queue up those as general topics of conversation. It's that intersection between what we're doing in terms of space, specifically commercial space and the commercialization of the moon. Of course, there are additional activities going on with Artemis and that, that's not my specific area, but I'd be glad to entertain whatever questions you have that may have about that to the best that I can. But with that, I'm looking forward to engaging groups of people and agencies that I'm typically not accustomed to engaging as we go forward together in order to define this regulatory pathway to enable this commercial capability. Thanks. Thanks, Judy. Next, we have Justin. Justin Casper's going to talk about the commercial perspective on the nuclear. Well, thank you everyone for the opportunity to share a commercial perspective with you. I'm just going to start by way of introducing myself, sharing two surprises from early in my career. I started out in space exploration, working on missions like Lunar Reconnaissance Orbiter, which has been orbiting the moon since 2009. And on this chart, there are just two discoveries that we had from that mission that motivate me to this day in advanced technologies at BWXT. I worked on an instrument that measured the radiation dose humans would experience in deep space. And on the left, what we did was we took the dose at the moon and we converted into how many days an astronaut could survive in a deep space mission, say on the way to Mars, before they met their dose limits. And what you can see is this oscillating kind of 11-year period cycle. The Apollo eras highlighted towards the left of that plot. Now, why is the maximum safe duration changing on an 11-year period? That's the solar cycle. So when you have more solar activity, the allowable mission changes in duration. One of the things that really surprised me, solar maximum is the safest time to travel. So the longest duration safe missions are during periods of solar maximum. And that's a little unintuitive. But when our sun's acting up, it's actually pushing the much more dangerous radiation from our galaxy out of the solar system. Our sun, for one reason or another, has been a little less active over the decades since Apollo. And so what we discovered was, during solar minimum these days, a mission could last maybe 200 to 400 days in deep space, maybe double that during solar maximum. A chemical rocket can't get a crew to Mars and back in this amount of time. One of the motivations for nuclear thermal propulsion, which you're hearing about NASA working on, and I'll give you some examples of our involvement in those programs, is that a nuclear-powered rocket, so much more efficient than a chemical rocket, could half the time it would take astronauts to get to Mars and allow us to provide a means of transportation that fits within the regulatory limits for radiation exposure. On the right, I show a plot that we made that Jay alluded to. We discovered that the moon's poles, anywhere on the moon where the sun has set, but especially the poles in some craters that never see sunlight, it's really cold. Some places only tens of degrees above absolute zero. That's a real challenge for operations. That's one of the motivations for radioisotopic heat sources, or fission power sources, just to allow our hardware to survive at night. But it's also an incredible opportunity for exploration in human presence and deep space, because those craters, it turns out, appear to trap ice from comets. Billions of years of comets striking the surface of the moon deposit ice, and it's so cold that the ice survives there. So if we can establish a human base at the south pole of the moon, as NASA has declared its intent, if we can harvest that ice, we can make fuel from the hydrogen. We can make oxygen to breathe. We can sustain a human presence on the moon and use that fuel to explore the rest of the solar system. But what does it take to melt and convert a kilogram of water into a kilogram of hydrogen for fuel? About 40 kilowatts, all right? We need a 40 kilowatt system if we want to produce a kilogram of hydrogen an hour. Not a surprise, NASA wants to develop a 40 kilowatt electric fission power system within this decade and field it on the surface of the moon. That could both provide the heat that astronauts would need to survive the night, could provide the power to produce fuel. Now let me tell you a little bit about BWXT. We've been innovating in the fields of nuclear technology for more than 75 years. Our company is dividing the two operating groups, a government operating group and a commercial operating group. A lot of our work in government involves nuclear naval propulsion. We also do nuclear environmental restoration management, and we have an advanced technologies group, which I'm part of, where we develop our new defense and space nuclear power and propulsion systems. We also have a commercial component where we're working on clean energy solutions, novel modular reactors, fuel and components for large commercial utility reactors. We also do nuclear medical manufacturing. Within advanced technologies, I want to share with you three programs, two of which are related to space, that BWXT advanced technologies is engaged in that are related to today's discussion. First, on the ground we have two programs we're developing future high temperature gas reactors for commercial and DOD applications. We have a department of energy program called Banner, where we're attempting to half the cost of advanced fuels for small modular reactors, and we have the DOD project Pele, where in about two years we're going to field a megawatt class microreactor out at Idaho National Lab. This is a reactor that could fit in a standard shipping container, be transported anywhere around the world and set up just within a few days, and once it was activated, provide sustained power for years continuously. Moving on to space, we want to apply the same technologies that we're developing for those programs and use that to enable exploration and continued and expanded human presence in space. Two of the programs I wanted to talk about today that we're engaged in are space propulsion and space power systems. So for instance, with the Department of Energy and with NASA, BDXT has been working on space nuclear propulsion technology, nuclear thermal propulsion development. Why is nuclear thermal propulsion so much more efficient than a chemical rocket? It's pretty straightforward. Imagine the space launch system, the SLS, or the space shuttle taking off. The shuttle or SLS combines liquid hydrogen, liquid oxygen, combusts it, makes water. And in making that water, the energy that's released superheats that exhaust, that's your plume that then provides the thrust. With the nuclear propulsion system, we skip the chemical reaction. We don't need an oxidizer like oxygen, which is the bulk of the mass of the fuel on the space shuttle. Instead, we just have tanks of hydrogen at cryogenic temperatures. We have a reactor maybe the size of a 55-gallon drum and you turn it on, generates hundreds of megawatts of heat and simply heat the liquid cryogenic hydrogen up to the same temperatures you would get in a rocket motor. And that produces the thrust much more efficiently than a chemical reaction. You could half the time it takes astronauts to get to Mars. Astronauts could be halfway to Mars, realize they have an issue and they could just fire the rocket again, turn around and come back without having to fly out to Mars. So a tremendous enabling technology for space exploration. There are potentially commercial applications to having that kind of reliable, high-thrust capability in CIS lunar space as well. On the space power side, we've already heard a couple discussions about how challenging it is to operate on the lunar night, which is not Earth night. It's two weeks at a time. It's very difficult to imagine a battery that you're gonna land on the moon and charge up that can carry two weeks worth of electricity. So instead, we and two other teams selected by NASA are currently designing a 40 kilowatt electric vision power system that could land on the moon, one of the existing commercial landers, and then be turned on and provide 40 kilowatts of electricity for 10 years continuously. Again, a game changer for lunar exploration. Now what role does a company play in developing these products? A lot of the work we do is in technology development, coming up with ways to apply our knowledge of advanced manufacturing to figure out how to make these products using advanced materials so they perform better, but also figuring out how to make them manufacturable so the cost is reasonable. We use things like artificial intelligence to design these reactors so that instead of the highly enriched uranium of half a century ago, we can design nuclear thermal propulsion systems, vision power systems that only use HALU and yet still fit in a total mass that can be landed on the moon or bring astronauts to Mars. We apply advanced manufacturing techniques to develop new fuels, develop ways of manufacturing, even 3D printing, high temperature alloys and insulators as part of the reactor. And I wanted you to take away from this discussion just how real this is. This isn't speculative fiction. This is a jar of NTP fuel, nuclear thermal propulsion fuel that BWXT manufactured for the Department of Energy and NASA back in 2001 that we then delivered to Idaho National Lab and to Marshall Space Flight Center for testing and characterization. So we are already making fuel, NASA's investing in these technologies to enable these systems and commercial plays a role in developing these products. We've also developed advanced techniques for 3D printing other materials, including 3D printing HALU so we can produce objects in very special shapes that allow us to maximize heat transfer, get the most efficiency from these rockets. So just wanted to close with this slide to kind of highlight some of the capabilities that a commercial organization like BWXT can bring to the table when we're developing new nuclear technologies for space, early R&D development, lab scale pilot capabilities and then eventually production in category one nuclear facilities. Thank you. Well thanks to all of our speakers. We had quite a variety there. I'm going to try to ask questions to get all the panelists involved, but some of them, since we had such a wide variety of topics here, some of them might get pointed to certain folks. So we've got plenty of time for questions here. The first one I'll ask is that it kind of is a broader one that might touch on most of you. We had a question come in on NASA's payload. If NASA's payload, I think Jay, this starts probably with your discussion. If NASA's payload contains NRC regulated technologies, how does that commercial delivery company get involved in the licensing process? Do they separately apply for a license to transport or how would NASA and the space FedEx, if you will, work together for licensing? How do you see that happening? And anybody jump in, why don't you start, Jay? So actually you're posing the exact questions that we have. This is a relatively new thing. I'm aware that the NRC- I think the microphone's a little bit, you're on, but just get a little closer there. Okay. So actually you're asking the exact questions that we ask, and it's relatively new for us. I do know that in the terrestrial sense that the NRC has well-established guidelines for licensing and for all the activities that are going on on the ground, but when we do hand over to Eclipse provider and expect them to then launch, are we expecting them to have an NRC license or can this be done by extension of another license? I don't know the answer to that question. But again, this is a relatively new territory for us. And so I'm sorry that the answer is not all that satisfactory. I do agree with the question for what that's worth. And I would encourage our NRC friends to hopefully flush out that answer. I think- Is this on? Yeah, it's on. Okay, thanks. Yeah, so if I understood the scenario correctly, there's some NRC licensed material that would then be put on a commercial vehicle to be launched. So this sounds to me maybe similar to the case three that I showed in one of my slides where I guess whoever the mission owners are who wants to do this, they would have to go through multiple steps of potentially of kind of licensing and safety reviews. So anything that's happening, civilian use of nuclear materials terrestrially, NRC has established regulations and procedures that you would have to follow to get the material where it needs to go while it's still on earth and so on. And then if it's going to be a commercial launch, eventually you would have to go through the FAA's commercial launch process in order to apply for authorization to then get like a nuclear payload review and then the launch approval itself. So there's multiple steps involved in the process and I think as Carl mentioned, I mean certainly there's been plenty of commercial launches, there's a rich history there, so that part is not new. I think what may be new here is bringing in the nuclear safety aspect now for a commercial launch. It's certainly been done with government launches, but as we're entering a new world and we're gonna figure this out together and of course the first missions that go through this will, you can lay out all the guidance and everything up front, but it's always the first one of a certain kind that goes through something that everybody learns together on. Thanks, Jay and Tina. Really from what DOT FAA looks at this is really the public safety aspects of things and that's really carried through a licensing lens. So I'll go back to some of my opening remarks that public safety, national security and foreign policy interests of the United States piece. So the rule that we have in the books is in the current time when there is radio isotope on a proposed commercial launch or reentry that we evaluate that case by case basis. So in that case the regulated party is the one making that application for the number of different types of licenses and approvals that we administer. So like launch license, reentry license, payload approval, safety element approval that it is the commercial entity who's the operator in that case. And so what Jay mentioned in his opening remarks about his views on what the framework should be regardless of who the material owner is. Well really DOT FAA ends up looking at as who's the regulated entity and of course NASA being government it's a very different type of thing than dealing with the folks that we regulate which are the commercial operators. So there's a huge range of potential and postulated cases of radioactive material being a component in a launch or reentry. And so that's where that case by case piece is really something that is I think the focal point here. Everything from a small amount of radionuclide in a science experiment all the way up to the types of things that Justin postulated alluding to even a first stage launch vehicle. That would, I won't speculate but I guess that that would be pretty involved in shall we say interesting NEPA to go through. But I don't wanna prejudge anything. I'm not proposing a first stage nuclear. But you said space shuttle. No, no, no. Space shuttle was. Space shuttle was an example of something that burned hydrogen and oxygen. Okay. But nonetheless is that there's thanks for the clarification on that. No problem. So there's a wide variety there. So I think that looking at through the lens of who's the regulated entity who's making the application for that license or payload approval or safety element approval to make application, come to our office and then we'll look at it. And again, case by case. And a lot of those things that might seem new or strange and unusual, you know, well maybe they just haven't been applied in the particular case of commercial launch of nuclear material so far. But those things like National Environmental Policy Act, I mean that's been on the books for decades. But you know, with every new use case, you learn and experience new things. Okay. I'm gonna start Justin with you on this next question and then maybe there'll be input from others as well. From the commercial perspective that you're with, what do you see is, you know, we all talked about the stages that we're in with regard to a commercial nuclear and even nuclear propulsion, whether it's commercial or government sponsored. But from your standpoint, commercial, where do you, what uncertainty in the process, the more the regulatory process concerns you the most? Yeah, sure. I think two things on our mind. One, to what extent does existing nuclear technologies that's been deployed in space serve as a good point of departure? So, you know, we'd love to understand like, okay, you know, Department of Energy and NASA have a great track record in licensing and then using certain clattings and other technologies to protect nuclear materials during launch. You know, to what extent does a company point to that when they're, you know, arguing for the safety basis for a similar but different design? You know, maybe a different isotope or maybe it's a fission system. And then the second issue is, I think there are great examples of, you know, government led programs paving the way in certification. You know, we're doing that right now with the Department of Energy and INL with our paylay program out at Idaho, right? So, you see these NASA led or government led space nuclear programs, they sort of pave the way, but if the process is slightly different for commercial, you know, we're really interested to see that spelled out. You know, what can we use from the existing space nuclear authorization process that'll carry over into licensing it for commercial application? Very similar comments to what other folks have said here. Yeah, Carl, I guess to go along with that question and whatever you're able to say about it is, you know, what are the most frequent questions you get asked on companies or organizations inquiring about space nuclear launches? Thanks, Ray. I think that depends a lot on the concern in the head of the asker. And I'm thinking through my answer before I speak rather than the opposite. I think if I'm listening to a stakeholder who is from the commercial world, their interest in, interest tends to be, you know, those very commercial types of things, capability and then the schedule and budget, you know, the wallet and watch type issues. I spent some time in commercial industry before becoming government and a civil servant and that capability, that market piece and the wallet and watch, you know, issues were always constantly in the front of the mind. When you're talking to members of the uninvolved public, space tends to draw, I mean you can see the sparkle in people's eyes, but when it comes to launch of nuclear materials, suddenly very different emotions come through the face because very different perceptions come out of and then the first type of thing you're often to hear is, is it safe? And I think that that public acceptance piece is something that the regulations don't explicitly talk to, but it is in the back of people's minds and I'm responding to that kind of as, as the point of what kind, to the question of what kinds of things, you know, come my direction, I would say they tend to fall into those categories based upon what is in the mind and in the concern of the person asking the question. So I think a lot of it is just person to person situational based upon what their perspective is. Okay, thanks. I'm gonna go into maybe some more, might just be specific to certain speakers now, and then go back to some more general questions. Maybe this one you can take on, Teen, I think. The questions about the, does the NRC, USNRC use a different frequency consequence curve when performing the risk informed safety evaluations for space applications as compared to terrestrial applications? Yes, I guess, yeah, one point of clarification. NRC doesn't regulate, you know, space applications, we regulate terrestrial, you know, use and applications, and then we've contributed in the past to the interagency safety reviews and we will continue to do that. So I just wanna clarify, we don't have, you know, NRC doesn't have its own, you know, space criteria, but just in terms of, you know, how the NSPM 20 targets kind of compare, NRC certainly has, I think those of you who are familiar or, you know, with our regulations, NRC does have, you know, targets in terms of the safety goals that we use for risk informed regulation. It's hard to match up to compare, you know, what our safety goals or the quantitative health objectives that are tied to those safety goals, how they would compare to the targets in NSPM 20, just because it's not really an apples to apples comparison. So for example, if you're looking at the risk to a member of the public who's living in the vicinity of a nuclear power plant the whole year round, you know, we often will use the, you know, the QHOs or the surrogates of core damage frequency or largely release frequency for people living in that vicinity to compare against the safety goals. With a launch, with a mission, you know, risk, it's very different. This is like a one-time thing or it's maybe a mission that's gonna go over a few weeks or a month or something. It's not something that's constantly present in the background that you can kind of compute, you know, so again, it's not an apples to apples comparison, but certainly the idea of having risk targets and having more scrutiny as you get into, you know, higher potential consequences and wanting to have lower frequencies associated with that, that is very much, you know, how the NRC does its own risk-informed, you know, regulation. So maybe I hope that helps to answer that question. I've got another INSERB related question. Again, the INSERB's acronym for Interagency Nuclear Safety Review Board that's came out at NSPM 20. And maybe, you know, Carl or Tina, since you're on the INSERB, maybe you can help with this question. It's kind of a question of what INSERB looks at and what it doesn't look at. You know, the nuclear safety aspects, but does INSERB review other safety-related activities of the launch or just nuclear? I mean, there's, I mean, for example, a NASA launch, you know, the launch authority is going to look at a lot more than just nuclear safety from that standpoint, but from an INSERB standpoint, is that part of the planned INSERB process or is it just nuclear? You want to take that? Okay. I think just the thing that kicks off the INSERB piece is the word nuclear. Once you have that involved, that brings in the INSERB aspect. Now, the risk numbers are kind of going to be a convolution of both the nuclear safety-related aspects and the launch safety-related aspects. So if you have a vehicle which has a higher likelihood of a launch or reentry mishap, you're going to have different numbers naturally in that aspect of the risk computation and an analogous type of thing on the nuclear side. And then the end risk number is really kind of an amalgam of those two. So I don't think it's one or the other. I think you always are looking at both. Okay, thanks. This is an interesting question. I'm not sure we'll give a shot to folks on the panel, but how is the disposal or abandonment of nuclear materials in space managed? I think it's kind of the question of when does it belong to nobody, I guess, so. Any thoughts on that or? Ray, you touched on one of the items that's keeping me up at night. I don't have a clear answer to that. Yeah, it's a very good question. I don't have an answer for that either. When does the primacy of the material, if it leaves, once it leaves the earth, who's responsible for it from a regulatory standpoint at that point in time? I think those are good open questions that have to be looked at as more and more of this, space nuclear launches, whether it's radioisotopes or power systems and then commercial launches as well. Ray, I can take you a little bit more. Don't mean to give you a glib answer on that one. So on that piece, our current regulatory mandate is really from the beginning of the launch operation until the end of launch. It really is the last exercise of the launch vehicle after the launch. And then you have analogous definitions when you have a reentry license. Now on the topic of long-term disposal, those are, as I say, these are topics and issues that are kind of new and emerging because there hasn't really been an urgency yet in order to address every speculative type of thing. And now we're not dealing in a world where it's gonna be speculative for very longer. But I would still tie DOT's authorities to that piece in Title 51, which includes the foreign policy and national security interests of the United States and then tie things to that. Whether that gets implemented in the initial issuance of the launch license, that's a piece where, again, looking at that, looking at the regulatory authorities, the current rules, and then the case-by-case aspect, we'd have to assess that. So rather than give like a global catch-all answer to everything, again, I'll just kind of go back to that piece in US code of the, not just the public safety aspects, but also the national security and foreign policy interests of the United States and then say, okay, given current authorities, is that something that DOT can carry out? And if not, that's a conversation to be had with the folks on the other end of the other end of Maryland Avenue. Okay, thanks. Yeah, Tina. I just wanted to mention something because I think one thing we, maybe our talks didn't quite cover is what risk are we actually looking at when we talk about safety review? And I just wanted to mention one other aspect. So we keep talking about the launch, but in fact, in both the DOTs, regulations, and as well as what INSERB is expected to review, we also consider a potential unplanned reentry of any material coming back down. So it's not that if you launched it successfully and then something goes terribly wrong later and it's coming back down that nobody looked at that possibility. That is an expectation that when you do your safety assessment, your risk assessment, you should consider the entire kind of life cycle of whatever it is that you're launching and also consider the possibility that it may not get where it was going and may come back down sooner than you wanted. So at least from that perspective, there's an expectation that you will have thoroughly looked at it and that the safety reviewers are gonna be looking at that aspect as well. And one other thing I'll just throw in, you know, this thought about space that or space getting more and more crowded and eventually what's gonna happen to all that stuff. This is very much a topic of discussion at international conferences and at aerospace conferences. It's not just a nuclear issue. It's really become a very important and popular topic of conversation. And I don't know if, I know there are some international treaties and I don't know to what extent, you know, they cover this issue and exactly what is described but I can say just from a personal experience at recent conferences that this is a very hot topic of discussion so there may be more coming in that area. So it is very timely a conversation to have and of course NASA is also addressing this from an international standpoint, right? We've got the Artemis Accords that we're getting each of our partners in exploration to be signing. And of course we have the definition with you on copious and the outer space treaty. The challenges of course come into getting those broad concepts and those broad agreements from that do exist on a country level and how do you get that filter down into a regulatory level? How do you get it to specific requirements? We've got commercial entities that want to comply but they don't know what to comply with, right? They want to know what do we need to bring to the table and what is the standard of good enough? And these are the kinds of things that again where we have top level agreement, we all know we want to be able to handle these things safely. We want to be sure that we don't have a bunch of live nuclear sources around that astronauts are going to have to tiptoe around. Same thing goes for non-nuclear hazards as well, right? We have to be able to create an environment that the zoning problem for the South Pole is going to become increasingly difficult as time goes on. But yeah, very timely and it's good that the EFA does have that hook in the case-by-case assessment in terms of international policy compliance. Right, I had one question, I think I'll direct it to Justin here and I don't know how much you can say about but there was a question of somebody interested in explaining more about the application of the PAYLA project. You brought it up as something that BWXT is working on and technology related to that. Oh yeah, sure, I think there are a lot of reasons to be excited about that kind of capability. First, there are a lot of remote locations even in the United States where we spend so much money just shipping coal or oil to provide power. It's very expensive and it's easy to disrupt, just weather. So there's interest in these very small power systems to provide a little energy security there, maybe even more cheaply than current practices. It's obviously on everyone's mind figuring out ways to reduce CO2 emissions and the Department of Defense is aware of the amount of CO2 they produce just from producing electricity over the year. So something like PAYLA or larger versions of PAYLA are similar systems for fixed installations. Could be very valuable as well. And I think I've heard the example of a natural disaster recovery. So consider like Puerto Rico after a hurricane. If we could come in with reliable power, provide enough electricity to start recovery efforts but not be distracted shipping fuel back and forth that could make a big difference as well. So those are some of the use cases that I like to think of. All right, thanks. Carl, I think this one's probably directed at you. Maybe you can provide some clarification. The questions, does the FAA license all commercial launches and re-entries or just those containing or carrying radioactive materials? We're the launch and re-entry licensor for the commercial sector. So it would be. Nuclear or non-nuclear. Or exactly, right. I mean, if it is a non-governmental entity and it's a launch that's conducted in the United States or it's by a U.S. person or entity, then yeah, that's within our regulatory scope. Here's kind of a general question. We have time for just one more. This a general one. Can all of you share your thoughts and insights on the use of risk assessments to inform decisions and how you might go about gathering or generating appropriate data, particularly for the first few missions? And I think that's done by commercial companies like BWXD and certainly as we review safety cases for launches. Anybody like to start on that? I'm gonna put Justin on the spot. I'm wondering how you factor that into your risk assessment decisions on what you're gonna do with regard to space nuclear activity. Yeah, that's a great question. Obviously, since it's such new territory, there isn't as much existing basis. We're fortunate with a lot of the nuclear propulsion effort that there was a very large and extensive NTP development effort in the United States that went on for decades. And then that program came to an end, but every datum that was collected there is still very useful for informing how to control those systems, what issues to be concerned of. We use digital models and digital twins to explore all the unusual edge cases or to help us identify edge cases that we might not be thinking of just with a pencil and paper. And then just good old fashioned, destructive testing of sub-assemblies to inform you about the limitations, always important, especially when you're trying to qualify a system for use in space. Anyone else like to comment on that? Go ahead, Rick. Once again, I'm just echoing the importance of the question and the timeliness of it because when we've done launches in the past, we've had independent assessment of the probabilistic, probabilistic assessments of the launch vehicles. Well, now all the launch vehicles that we've ever launched anything on are no longer operating, right? The Atlas is gone, the Delta is gone. And now we've got the Falcon 9 and Falcon Heavy, we've got the Vulcan coming up. So we have this whole new wave of new commercial launch vehicles that don't have launch data books available yet. Now that's a function that typically had been supported by the NASA Launch Services Program, or LSP, done at KSC. So now if we have these commercial entities and LSP's no longer engaged, it does draw the question of you've got commercial folks and you're trying to have them do a risk assessment of their own product. As opposed, so how do you get the independence of the risk assessment into the loop there? It is an ongoing question. I want to echo Jay's part about the independence of review because by the time you get to the nexus of nuclear and space-related stuff, the communities get pretty small. And so that question of what constitutes an independent review when you're dealing with very niche types of things and even the intersection of different niche communities. From my original contribution to this particular question, this particular query, I'll just say one thing that comes to my mind is the regulated aspects of toxics and environmental, NEPA, you know, National Environmental Policy Act topics. Because at least in the commercial launch field, when we thought of compliance with the toxic hazards rules and to mitigate those hazards, it was often in the sense of looking primarily at hypergolic fuels, fuels that burned on contact with each other, but they're also highly toxic, tend to be highly toxic, at least the ones that we have legacy data on. And secondly, the environmental aspects. My gut sense, and not going deep, deep into detail here, so forgive me if there's a corner case that I haven't covered with this comment, is that generally those rules were formulated on generally not using radioactive materials as the main things that one would find interest in mitigating the risks of when it came to like a launch or reentry accident and dispersal. So the question, how appropriate are those when we're dealing with radionuclides? How appropriate are those when we're dealing with radionuclides in larger quantities than, you know, on a science experiment, that you take up, you do the experiment, you come down, say, in the space station? The level of appropriateness of fission products, let's say, on a reentry in particular or other things that we haven't even considered then. I think that is something that would drive some novel, unique risk assessments and, you know, those corner cases that I think are hard to explore unless you are already looking at a particular application, a particular use case. So it's those types of things that I think are going to be my personal professional viewpoint of this probably going to be the most interesting and the hardest nuts to crack on this. All right. So, Tini, you get the last word on that question and then we'll wrap up the session. I've been at the NRC a long time as you said in the introduction. I'm a huge believer in risk assessment and I think, you know, it is the appropriate vehicle to both demonstrate, you know, to analyze safety and demonstrate, you know, that hopefully something is safe enough and to be able to review that. I think, you know, risk assessment in this process is likely going to be an iterative thing where, you know, now that we are looking at new systems and maybe, you know, new vehicles that haven't been used before for launch, et cetera, you can always start with your risk assessment somewhere and, you know, the key is kind of to take a risk informed approach and kind of hone in on areas that may be more risky or have more uncertainty and try to kind of beef up the technical basis in those areas. Because, yes, there's a lot of unknowns but not everything matters, you know. It really depends on, you know, you get a diverse group of subject matter experts who understand all the different pieces and figure out kind of where is the biggest pieces of risk lying and the biggest uncertainties and then kind of work to beef up, you know, the supporting data, you know, whatever you need to do to have a firm technical basis in those areas. So that's very high level but that's kind of, you know, just general risk informed principles, I think, are very good for this type of thing. Well thanks, I think that was a good question to ask at the end of the panel session. I think it's, you know, we're all in kind of an exciting time here with Space Nuclear. And I think, you know, through the presentations, there's still a lot of work to do on the regulating of this and I think in the meetings I've been in with INSERV and the government agencies, we really recognize the need that we really do want to enable Space Nuclear commercial launches as well as government launches and not prohibit it. I mean, that's what it's all about. I think we're all working towards that same direction and we're really looking forward to kind of a bright future in Space Nuclear applications. So with that, I'm going to end the session and I think I'd ask the panelists to maybe stick around outside, they want us to vacate the room so they can get ready for the next session but stick around a few minutes out in the hallway if any button has further questions of you. And I really appreciate everybody attending. We had a great turnout and hope you have the rest of your week and the RIC is good and thanks for your attention. The session's closed.