 Now rounding out our commissioner plenary presentations I have the honor of introducing commissioner Stephen Burns who began his service at the commission on November 5th 2014 with the term ending June 30 2019 mr. Burns serves as the 16th nrc chairman from January 1st 2015 until January 23rd 2017 now as a commissioner he continues to be engaged in the work of the agency and its safety and security mission This is his 28th regulatory information conference and his fourth as a commissioner Commissioner Burns has had a distinguished career within the nrc and internationally Immediately prior to rejoining the nrc commissioner Burns was the head of legal affairs of the nuclear energy agency at the Organization for Economic Cooperation and Development in Paris and he served there from 2012 until 2014 prior to assuming his post at the NEA Commissioner Burns served as a distinguished employee of the nrc for 33 years from 1978 through 2012 and he served in a variety of roles during his career including being appointed as the nrc's general counsel from May 2009 until April 2012 and also of note commissioner Burns served as the executive assistant to former nrc chairman Ken Carr and As the director of the office of commission appellate adjudication commissioner Burns received his JD degree in 1978 from George Washington University here in Washington DC and his bachelor of arts degree in 1975 from Colgate University in Hamilton, New York the title of the commissioner's presentation this morning is reformed and reforming Adapting the regulatory process to meet new challenges ladies and gentlemen, please join me in welcoming commissioner Burns Well, thanks everyone. I was looking over here Apparently, this is the hot seat up here because there's a burn mark from an iron on the on the platform over here So I hope it's not coming for me Something like that. I appreciate Mike mentioning my educational background as someone reminded me today The Colgate women have made the frozen four in hockey and we're going all the way So the heck with Alabama. We're we're here for We're here for hockey anyway I've titled my remarks today reformed and reforming adapting the regulatory process to meet new challenges and the theme expands upon an article I recently wrote for the OECD nuclear law bulletin Which was specific to the licensing of advanced reactors and reflecting on the licensing process over the years How are in reflecting on what I'd speak to you all about today? I wanted to expand on that premise of my article to cover the topic more broadly. I first joined the NRC 40 years ago fresh out of law school in fact first I was in my official personnel file which is all electronic now and believe it or not. I found my NRC application now there may be something about cyber in there Why the heck do they still have an application? I made 40 years ago and typed by hand in in the file There's too much information out there But anyway, I found my law school transcript and my college transcript and you know There were some classes I did well in and there's one in law school I never forgave the professor for But in any event in any event It struck me over the course of my 40 years in this field that there is often a central conundrum in regulation And we continue to be challenged by that conundrum today Let me elaborate There's often broad agreement that the level of safety or security established by certain regulations License conditions or other legally binding instruments is in the judgment of technical experts to Conservative based on outdated information or it imposes an unnecessary regulatory burden The regulation says for perhaps that you need to have a 12 inch diameter widget But professional expertise and for the research tells us that an 8 inch diameter widget will be just fine What it what to do both the regulator and the regulated seem equally frustrated Asking themselves, why do we spend so much time trying to resolve issues of little safety significance? Part of the cause may be what some refer to as paralysis by analysis or process It is where we we may get so caught up in a following a particular way of doing things that we lose sight of the bigger picture Or we can't seem to reach the point of satisfaction in analyzing a problem and thus the process becomes paralyzing I've seen this over and over again across the course of my career without any Lasting solution proposed or implemented and if you're hoping that I would come here with one today Sorry This is again as some others my predecessor said this is a destination Not a journey not an actual a specific outcome that I can offer But I do intend to focus on this journey of nuclear regulation and not necessarily the destination And my intention is to give you perhaps a new lens through which to think about some of our current challenges I'll offer these three current examples where this tension is playing out Itself out as we speak as some others have mentioned already this morning digital instrumentation and control an accident tolerant fuels and the licensing framework for advanced reactors in my view They're these are concrete examples where we have struggled to find reasonable solutions in large part because we do feel inextricably tied to our regulatory structure and we have been slow to acknowledge at times some of the difficulties in Adapting that structure however and however in some respects I would argue that we are seeing some success in overcoming the dilemma But before I really get into it and certainly before I begin looking toward the future I'd like to tell you how a story about how past is prologue Back in November 1971 I was an 18 year old college freshman from Virginia at Colgate University getting used to academic life in upstate New York And if you remember your freshman year, you know there are a lot of adjustments to make and most students are focused on dealing with new teachers and new campus new friends and so I was But I was also determined to cast my vote in the first election for which I was eligible Right after the 26th amendment to the Constitution gave 18 year olds like me the right to vote And so I went to the university registrar's office to fill out my absentee ballot because I needed to have it Notarized by this Commonwealth of Virginia those days now I intended at that time to vote a straight Republican ticket to support that party's push under Governor Libwyn Holton to shed Virginia's legacy of segregation But I accidentally selected two candidates on my ballot for the House of Delegates for whom I did not intend to vote I Carefully crossed out those names and wrote in do not desire to vote for these two on the ballot All good all clear as far as I was concerned Unfortunately the Board of Elections thought otherwise and ruled that my ballot was defaced and it was rejected Which unbelievably enough led to a tie vote for that house seat? Sorry as An aside yes every vote does count So I give leave that lesson with you But in the case of a tie in verge according to Virginia law the winner is left to chance and Literally drawn from a hat well in this case a silver cup and by the way my candidate won in 1971 and the Washington Post recently we told the story So why why is it relevant now fast forward to? 2017 46 years after my voting snafu Virginia faced exactly the same unlikely predicament Involving a disputed ballot a tied race and the tie-breaking lucky draw to settle a state house race The Post retold the story for the same reason I'm recalling it now Because we often think of that what we're facing today in politics and academia in regulatory space is Completely novel something never seen before and it's just not true Here's an nrc Press release the headline from an nrc press release Nuclear regulatory commission direct staff to take experimental steps to improve licensing process I Didn't think I was funny, but anyway Mike Okay, nothing particularly surprising there, but no the press release is dated October 20th 1978 Two months after I began my career at the nrc And you hear something else that might sound familiar Both the New York Times or the Washington Post ran front-page stories President offers plan to reform federal agencies now which president president you asked It was John F. Kennedy and the story ran on April 4th 1961 And I'd note actually the headline that day was about the successful orbit of earth by cosmonaut Yuri Gurgarin Undoubtedly we could find similar stories under more recent presidents And you know from Reagan to Obama, but actually going back in the 1930s under Roosevelt Truman And Eisenhower and I don't mean to be dismissive of the underlying premise that regulatory reform and effectiveness Demand our attention it clearly does But certainly from a regulator's perspective neither the evolution of technology nor the Institution of major regulatory reform initiatives is new or novel Every administration in the modern era has engaged in some sort of regulatory reform initiative And while some of the technology and processes behind advanced reactors Accident-tolerant fuels or digital INC might be new or novel the challenge of appropriately regulating new technology technology is not The regulatory conundrum I mentioned at the outset man itself manifests itself in a number of ways prescriptive versus performance-based regulation Deterministic versus risk-informed thinking compliance base versus safety focus regulation Whatever you call it. They all share a similar characteristic The NRC has put in place a legally binding mechanism or an interpretation of such be it a regulation an order a License or guidance that contains a requirement or guideline that is challenged by some as being too conservative unnecessary or outdated and as such then it's argued unnecessary and Necessary hindrance to innovation improvement or progress the basic tension in these expressions underlies much of what I have in the past called Or referred to as the regulatory craft At the very at its very heart this tension underlies a fundamental notion of our form of government Which is based on law and not the whim of individuals as John Adams said a government of men a government of laws not men This conflict between the so-called rule of law versus the rule of man dates far back to the beginnings of democracy and Although many of us have heard or used those that expression the rule of law or the rule of man How those terms are precisely defined is somewhat difficult to come by and varies based on Context I would offer that the collective societal recognition of the supremacy of law Even those laws that we as individuals might not agree with is essential to our system of government The supremacy of law is based on society's acknowledgement that laws were enacted through an agreed upon legislative process Such as that defined in the US constitution through which the people of this nation have had some Opportunity usually through the political process to voice their views or have their influence on the other hand what at times is can be and Synthetical to the rule of law as the so-called rule of man in the context of our discussion today I'm referring to those situations in which individuals or groups reject laws for their own reasons or Alternative that alternatively the government entity responsible for implementing the laws arbitrarily chooses to ignore them When parts of society be at the government or the public choose not to follow its law This is essentially a breach of the social contract posited by philosopher Jean-Jacques Hussot We as regulators go through complex legal processes involving significant public input to adopt regulations or to issue licenses Regulatory decisions can manifest themselves in the application of expert engineering or professional judgment or even simply common sense Requirements reflecting the regulations and our licenses are therefore in a sense the law of the land and Choosing to arbitrarily ignore them comes with consequences and at times we may come up against however, some rule or regulation that just doesn't make sense as Plato noted a failure by rule makers to acknowledge and take action when a rule has ceased to achieve its intended purpose is Quote like a stubborn stupid person who refuses to allow the slightest deviation from or questioning of his own rules Even if the situation has in fact changed and it turns out to be better for someone to Contravene those rules unquote In other words sometimes simply asserting that this is the way we've always done it is just not good enough and in fact It may be counterproductive to optimizing regulatory effectiveness and thus there's a natural tension Between the societal need for predictable rules and the need for flexibility to apply common sense or acknowledge new Information when needed. This is the heart of the regulatory conundrum that I speak of today The imperative addressing this conundrum increases during times when resources are limited and agencies are Facing increased political pressure to rationalize or Reese or reset their practices This can manifest itself in general government-wide reform efforts Initiated as I noted by almost every in administration in the modern era And there's also constant pressure on the regulator to be more risk-informed efficient predictable The NRC has been notably Proactive over the last few years when it comes to taking a hard look at itself Examples of course our project aim the reassessment of our budget requests and staffing levels reforms to the rulemaking process and the initiation of retrospective review of regulations in My view the NRC statutory mandate in the atomic energy act to provide reasonable assurance of adequate protection Gives the agency significant flexibility to adjust itself over time to account for the regulatory a conundrum I've discussed Reasonable assurance is not a static concept It should be fluid and adaptable to the current state of the art and science and technology and reflect the current security environment what was deemed necessary in 1954 is not necessarily the same as what's deemed necessary in 2018 Compliance with NRC's regulations for example has long been understood to ensure adequate protection But there are times when the regulations are deemed not enough or too much After the 2011 accident Fukushima Daiichi plant for instance the NRC determined that the level of protection for US nuclear power Plants was not sufficient and accordingly the NRC took action to increase those standards getting input from the public and from the industry Both expert judgment and common sense dictated that to be the case But in the acknowledgement and importance of the rule of law the changes were made to existing standards through established and transparent processes On the other hand the NRC at times must acknowledge when its existing Standards of safety may be higher than necessary to achieve adequate protection an Example is requirements for decommissioning of power reactors from a technical and safety perspective We understand that these facilities do not need to be regulated to the same standards as operating facilities They don't pose the same kinds of risks yet our rules is currently written don't really distinguish between the two And so recognizing this the NRC is granted exemptions under its regulations to adjust the level of regulation Necessary to achieve adequate protection at decommissioning facilities And we're also engaged as others have noted in a rulemaking to codify that judgment Again, we do so through a public formalized transparent process consistent with the rule of law Yet another example where the regulatory conundrum comes up is the inspection process you can imagine a situation I know for many we'll say it's not imaginary Which an NRC inspector makes a finding that a licensee is not in compliance with a regulation or a provision of its license Both the inspector and the licensee may agree In fact that compliance is is marginal or not or that the licensee isn't in compliance And they may even also agree that the non-compliance has marginal safety significance So what's the inspector to do ignore it ignore the issue? Not document her findings because in her expert judgment the issue is not safety significant In other words should that inspector apply her Personals discretion to decide unilaterally that the license provision makes no sense and doesn't need to be adhered to Some might say of course that this is just common sense and to initiate a Regulatory process to deal with a trivial issue is a waste of resources and time But again the license is law and if we have all truly have respect for the law Then out of out of principle should we allow this to occur? If the situation were different that licensee disagreed with the inspector on both the interpretation of the license and its safety Significance of the violation would we be comfortable in allowing the inspector to exercise her judgment? I would suggest that we would not So what's my point? Every day we confront this regulatory conundrum Be it in regulations licenses inspection findings regulatory interpretations issuance of exemptions But we have to be careful and making snap judgments based on particular facts or circumstances That either our regulations or regulatory interpretations are infallible or that bad requirements can simply be ignored The integrity of our system depends on principled adherence to the process Even when it makes little sense at times to someone that said the NRC There's a regulator can and should be flexible when it comes in finding ways to deal with the conundrum as Ralph Waldo Emerson Common commented a foolish consistency is the hobgoblin of little minds Adored by the little statesman and philosophers and divines wonderful quote So I said this tension challenged us every day and here again. I've come back to the examples I mentioned earlier we take digital instrumentation and control. We've had a good discussion of that. I think in the three my three predecessors up here on the stage and and it's really Probably the best example Currently that demonstrates the difficulty of overcoming Or adapting regulatory controls that don't appear to align with some of the technological advances And in this case the safety criteria do not readily address How a typical regulatory concerns manifest themselves in digital systems? And while we all agree that digital systems have the potential to improve safety and operational performance When compared to analog systems, we've been unable to overcome those hurdles of the existing process to license them Even as other industries with similar low-risk tolerances such as the defense and aerospace industries have succeeded And the irony is that in a legitimate effort to ensure that plants are safe The NRC may be imposing regulatory obstacles that prevent the implementation of safety improvements There's the conundrum The NRC and industry continue to be discussing these issues and in fact are meeting again this week I understand and the executive director mr. McCree has recently created the transformation team as he talked about To target this subject as one that we need to do work on Another example is the industry's pursuit of accident tolerant fuels several fuel vendors and coordination with the Department of Energy Have announced plans to develop and seek approval for various fuel designs and enhance that that enhance With enhance accident tolerance The first test bed for these efforts involve licensees that have reached agreements with fuel vendors to load lead test assemblies or their At their plants lead test assemblies are important first step in the licensing because they can provide data about the performance of new fuel In a reactor environment as well as provide materials for subsequent research and testing And even though lead test assemblies have been installed at many plants in the past the agency in the industry have been challenged Agree on the appropriate licensing path forward for those plants planning to load lead test assemblies in the near future This is a practical example of the tension between adherence to establish regulatory regime and allowing adaptation or flexibility to address new innovations Our past practice has been largely require approval of exemptions to our ECCS requirements and often license amendments before lead test assemblies could be loaded at an operating plant This is despite the fact that in most cases the safety significance of loading these test assemblies and these quantities is extremely low I would note however that upon closer examination of the existing requirements It does appear that exemptions and amendments may not always be required So I think it's fair to say that with both digital I and C and with accident tolerant fuels We've been struggling with the process Some of the agency appear to be reluctant to let go the existing requirements even even when some expert judgment Or perhaps even common sense dictates those regulations don't squarely address the exact problem Or may be too heavy-handed and it seems we struggle to be flexible and honestly acknowledge that level of risk Rather many are finding it easier to cling to what is known. What is proven and deterministic in? Contrast I would offer the third example our work on advanced reactors Despite some early criticism that the NRC has been slow to act and existing regulatory structure made it this Difficult for new entrance to get involved in the field I would argue that NRC has designed a strategy that is extremely flexible and forward-looking and Simplest turns the conundrum is represented by the fact that our current technical standards as others have mentioned this morning Applied a plant that are applicable to plant licensing have been largely drawn from experience with light water reactor technology It's been argued that these standards are overly conservative not risk-informed or simply an Inapplicable to some advanced technologies The appropriateness of current regulatory standards and the need to make changes to address advanced reactor technologies is an important issue and The one that may well warrant regulatory change in the future in the long term But at least in the near term case-by-case assessments of the particular relevance of generic standards and requirements to the technology being put forward In an application will be necessary Let me discuss some Examples however where the NRC has proactively tried to address the limitations in its framework Beginning in 2010 for example The staff began work on relooking at a number of policy licensing and technical issues that might warrant further commission engagement as the staff prepared For the review of SMR designs those issues included accident source terms site suitability emergency planning security and safe safeguards requirements and the application of defense in depth and I think we're making progress on those issues in 2013 the NRC and DOE initiated a joint effort to address the licensing framework for advanced non-lightwater reactor technologies that ultimately led to the 2017 issuance of a draft reg guide addressing the general design criteria and in late 2018 the NRC issued the vision and strategy Statement and develop implementation action plans to address actions to achieve its objectives We've also looked for experience with stage approaches to licensing from other agencies Federal Aviation Administration the Food and Drug Administration use them and in the international community our Canadian colleagues to the north and those in the United Kingdom with the Vendor design review or the general design approval process in the UK The staff also recently issued its regulatory Roadmap review roadmap in December 2017 and it illustrates how a stage approach can align with the current licensing process So to sum up, what does this all mean? I purposely use the title in my title of my law bulletin article the phrase Reformed and reforming and although that phrase is generally used in an ecclesiastical context and for those of us who mark the 500th anniversary of the Protestant Reformation, you'll know what I'm talking about The phrase underscores my view of the historic and ongoing approach that the NRC has taken to meet challenges put before it We continue to examine ourselves our Processes our approaches to adapt them when necessary and to reflect in good faith on experience Gained and then reform yet again when needed to meet new challenges in Order to come up with practical and implement Implementable solutions to our current challenges We must first and foremost acknowledge the reality that we live within a system of laws and those laws have meaning and those laws include statutes regulations Licenses we can take we can't take shortcuts simply for the sake of expediency or because the rules or the processes of changing them seem inconvenient at the moment a Principled and consistent acknowledgement of the rule of law is essential To the integrity of our system But then again our rules should not be viewed as infallible unbending or or unchangeable Rules that don't serve their purpose or that are because of advancements in technology or operating experience During deemed to be overly conservative can and should be changed and we should make realistic Acknowledgements of risk and always keep in mind our mandate of reasonable assurance of adequate protection The notion of being risk-informed can apply equally to our processes as well I mentioned at the outset the processitis or paralysis by analysis And it seems that sometimes we can get stuck on processes and not solutions So adjusting our standards or processes to keep up with the times cannot move at a glacial place When I started the agency 40 years ago rule makings took on average about two years Now it's about four years, and I remember Commissioner Ed McGaffigan complaining about that two years When he was here Blind adherence to process simply for its own sake does not advance nuclear safety and does not reflect well on the NRC as an effective and efficient regulator and at times that it can also cause us to lose sight of the forest for the trees No doubt the trees are important They make up the forest after all but the forest like nuclear safety is the bigger picture and we cannot lose our focus on it And to do this we must be honest with ourselves and be able to assess if our processes are fully furthering the mission of safety And security and we must be willing to reassess The reformation of the NRC is not a destination. It is a journey as some others have Reference earlier today. We'll never be able to say mission accomplished and trying to reach some of these Ideals nor should we much like the technology we regulate we as the regulator should be constantly evolved and reforming So I'll leave you with a quote from Thomas Jefferson If you've ever visit visited the Jefferson Memorial along the tidal base, and I'm sure you've seen passages from Jefferson's writing inscribed on the walls and a quote on the southeast portico seems apropos Quote I am not an advocate for frequent changes in laws and Constitutions Jefferson writes but laws and institutions must go hand-in-hand with the progress of the human mind as that becomes more Develop more enlightened as new discoveries are made new truths discovered and manners and opinions change with the change of circumstances institutions must advance also to keep pace with the times we might as well require a man to still wear the coat Which fit him when a boy as a civilized society remain ever under the regimen of their barbarous ancestors Jefferson's words align with my view of why the NRC must continue to examine itself its processes and approaches to adapt them when necessary and To reflect in good faith on experience gain and then reform yet again when needed to meet new challenges Propalente reformata Semper reformanda the agency is reformed and is always being reformed Thank you for your attention today. I'll be happy to answer your question So thank you commissioner. That was a bit similar to fully confident, but never fully satisfied So a common theme in all three of our presentations this morning. So appreciate the perspectives As you might well imagine we got some questions related to your comments on rule of law How does NRC ensure that its statutory mandate to protect with reasonable assurance is interpreted appropriately and consistently throughout NRC headquarters in the regional offices and a related question How does NRC management ensure NRC is not regulating to an absolute assurance standard? Well, I I think there are roles across the agency From the commission itself down to the individual employee within the agency that takes that on that takes that on I mean part of our role. I think as commissioners is we provide the general Oversight we are in a sense in our system of governance. We are in effect the political accountability For assuring that and it's or assure consistency and again now, you know a draw on You know my again my background as a lawyer and particularly as an American lawyer You know versed in the common law we we as I think commissioners View and I think Chairman Savinica alluded to this we view What our predecessors have done before us as very important and influence Influencing how we we come Come to that so at that that's at the highest level at a management level Certainly with it was senior management and I experienced this in terms of both general counsel, but it's also, you know first line supervisor Again, it's knowing that agency experience Working through it Communicating that to new employees. I think this was a theme for example my speech last year about you know We come out of school. I come out of law school or somebody Chairman comes out of engineering school and if you come directly in the NRC You don't know how necessarily to be a regulator You've got to be versed in the things that are within the scope of our Responsibility and then be trained and learned and learn how those things accomplish. I think I take For example some of the issues the EDO has done in the last couple years One of the things Issues that has come up is the question of about sort of the fidelity of our application of the back fit And I think to the EDO's credit and the credit of other senior staff management instituting better training Looking for the consistency issues across the board though. Those are some of the efforts So there there there comes it's a it's a wonderful question because there's we could probably talk for hours in terms of You know what what the role of? Everyone in the agency is and I missed the other one. What's the other one absolute assurance? Well, I think this goes to again I'd stand by the answer. I just gave is that's that's the role of supervision. That's Not only the supervisor You know again looking back on my own experience in the agency when when you become more versed As an employee when you're a more senior counsel within the general counsel's office If you're a more senior project manager, you're there and part. I think what you do You need to do and I think our employees are encouraged to do is pass that knowledge that experience that shaping onto New folk, but there there's a lot of I think accountability across the agency in that area Okay, similar question. You said adequate protection is fluid over time Does this mean that a plant's licensing basis is also fluid that it is something that? Evolves and is subject to subsequent reinterpretation well the licensing basis My answer is this you have a licensing basic the way it is fluid over time Is if that basis has changed and that may mean for example? If you have a plan that is licensed in say 1980 there are things that have been added to that licensing basis since 1980 it might be post TMI For 1980 plan it might be post TMI requirements. It might be the maintenance rule and you know 1990 if after the 2001 terrorist attacks where the security profile is post Fukushima. So my view is not that So much that the the licensing basis is Totally fluid and what it's whatever we want it to be in terms of what was adapted or adopted at a part of time but there is a discipline I think in the process for Backfitting for the addition of new requirements and those are the things where the licensing basis accrues New aspects to it, but it's not sort of saying well the licensing basis of 19a. It's whatever I want it to be today Okay, thank you This commenter found your comments regarding the rule of law as a refreshing reminder So in light of that, what are your thoughts on the government refusing to implement the nuclear waste policy act? It seems that it's an excellent example of the rule of man Superceding the rule of law this person was really listening to your okay. I Don't think that's what Plato had in mind But you know seriously This is Yeah, I'm not gonna dive waited into the the nuclear race policy act debate But this is one where the political process, you know, God bless it Has a lot of tension in it The you know the fact of the matter is I I could look at where things are with that process and say that's exactly It's what the rule of law or the absence of Pushing law has taken us You know we we know in this agency and then you know, there are some out there who Will put my name on or blame me for it in terms of when the agency Basically stepped down From from review, but we had the mandamus. There's the rule of law court tells the agency We had certain amount of funding left You know modest as it was he said you need to go and spend every last time That's that's part of the rule of law But beyond that I Am within the rule of law because I don't have any other Appropriations I don't have a willing applicant Or I haven't had a willing applicant Up in the time and so that political process needs to work itself out Okay, thank you The agency's received our first application for subsequent license renewal If nrc acts positively on that request for another 20 years Will that greatly increase the risk of nuclear accidents? And what is nrc doing to ensure safety for the subsequent license period? Well, I I don't see it as substantially increasing The the probability of accidents. I think the staff Has done The you know has been doing its homework in terms of looking at what is it In terms of a subsequent license renewal, what is important for the focus of the agent of the agency There's research that's been done. Some of it's sponsored by the department of energy We you know incorporate those research results and a focus on it. So What I think where we've come to this is not Again some arbitrary decision. Okay. Oh, yeah, we're ready to go This is really a matter of where we have looked at a process We have looked at what the technical we think are the significant technical issues are ready to move on that We'll continue to be informed By other experience and by other You know research. I think there's some other research that's out there. You may know better than I Mike But and we'll continue to be informed by that But I think we've prepared ourselves to move new move forward in that area Okay, this question uh tracks to your uh experience in international nuclear law The convention on physical protection and nuclear material cppnm addresses international transport of nuclear material The 2016 amendments to that convention extended its application to domestic transport of nuclear material What is nrc doing to address this amendment? I you know, I I think I'd have to defer to Some of the staff. I don't know immediately and I will be first confess. I am not a cppnm expert I think we have uh through our post 9 11 security requirements imposed additional requirements which bring us generally into into compliance with the 2016 amendments, but yeah But maybe you know, maybe we can discuss it further. Yeah And this this comment comes on the topic of culture Transformation at the nrc The commenter recognizes that real transformation as the edo's remarked Requires a change in in culture or a change in paradigm Since it's difficult to change culture with the same leadership that Implemented the current paradigm What is nrc doing to ensure that leadership is strong and effective in leading the cultural transformation? This will be your last question So I don't get the movie question. Uh, okay. Anyway, um I've already up to a dozen of those. I'm not avoiding. I'm not avoiding this one. So yes I mean the the difficulty always is that things on transformation Reformation whatever it says you got folks who've been steeped in it And steeped in the culture steeped in processes And in some respects I hope I hope that's so Because you need the informant you need to be have informed judgment That can look at where you've been what you need is leaders that are open to That kind of change or understanding that I you know, I may not You know, I look back on that experience And that we really could have come through that better And that's what I referred to where I think and again using this phrase reform to reforming I actually think and over the course of my 40 years associated with the nrc or or or at nea Looking back at the nrc I think that's where we we have been as an agency because I can think of those things About you know the the r.o.p. I can remember, you know, jim taylor the former edo And it was you know a lot of respect for but you know, he was throwing crockery in his office So to speak because and I don't blame I might have a couple shards left I ducked when it but but jim was frustrated over things like the millstone event and the main yankee event It says why can't we get ahead of this? You know, we tried in terms of evolving with the salt program for assessment in the 19 Excuse me in the 19 in the 1980s, but it just wasn't doing it. So it's those types of things Yes, I've been involved with this process, but I'm I'm honest enough to to face You know facing in the mirror and say something has got to move And I think that's what it is and some of these folks like like vick have been bill dean some some others You know We're involved as some of this this came about so that You know, yes, I also agree having sort of fresh perspectives having people come in new Folks come in who are outside of the club if you will that's a good thing too um, but all of you know, we all have I think as as leaders or as effective leaders Asking ourselves, where is the the Where is the opportunity to change? What is it the old thing about the the roman emperors riding into on the chariots into Into rome or whatever and you always had the person there all his vanity all his vanity whispering her in the air Well, we kind of need that too. I'm sorry. We're not going to hire some of that. We have a limited fte, but Um, but the it's the notion that's the notion is that that's the notion in the back of your head asking yourself those types of questions Very good commissioner. Thank you very much and then ask for the movie