 All right, good morning everyone and welcome to the last day of the rick We're glad to be here today to talk to you about citing for new reactors In our session entitled how exciting it is for new reactors. So you have me to blame for for that title Hopefully the session will live up to its name My name was Brian Smith and I'm the director of the division of new and renewed licenses here at the NRC our division is responsible for the Licensing for leaving the licensing reviews for licensed renewals as well as for licensing of small modular light-water reactors So with me today is Kristen Kerwin Allison natcher natcher who was joining us virtually from Alaska Martin Ben Staden and Scott hit So I'll provide the bios for each of the speakers really quickly and then we'll get into the presentations followed by some Q&A so Kristen Kerwin serves as the environment safety and health director within the u.s. Department of Energy office of clean energy demonstrations or OCD in This role she leads environmental health and safety compliance for OCD a New office responsible for delivering 21 and a half billion dollars from the bipartisan infrastructure law to support large-scale clean energy demonstration projects Kristen has over 18 years of environmental compliance experience in supporting DOE's clean energy mission Most recently she served as a NEPA division director at DOE's golden field office Kristen has a master's of professional studies degree in environmental science from the state University of New York and a master of public administration degree from Syracuse University Allison natcher is a United States Coast Guard veteran with over 10 years of experience in hazardous materials Transportation emergency response operations port safety and security contingency planning and force readiness Shoals a bachelor's degree in history from Whitman College and a master's degree in public health with a focus on environmental health from American military University From 2015 to 2017 she worked with the Alaska Department of Environmental Conservation Or a deck on the spill prevention and response team as an environmental program specialist Following a move to Anchorage in 2017. She transferred to the Alaska Department of Health as a health and social services planner In 2021 Allison returned to a deck and was appointed as the Alaska State Liaison Officer to the USNRC By Governor Mike Dunleavy in addition to her duties as state liaison officer She manages interagency coordination conducts public outreach for a deck and serves as the Alaska regional response team coordinator Dr. Martin Ben-Sodden has a PhD from the University of Johannesburg That's 33 years of experience in the power generation industry Of which the past 25 years has been spent in the design of high-temperature small modular reactors He is currently the vice president for design engineering at X energy and is also the XC100 commercial reactor program manager He leads the design team of more than 200 in-house engineers Supported by more than 30 companies who are providing support to complete the design licensing and commercialization of XC100 plant X energy was awarded one of the two DOE advanced reactor demonstration program awards Totaling 2.4 billion dollars to complete the design licensing fuel fabrication facility in a four reactor demonstration plant Scott head will be our final presenter today and Scott has been an industry leader on NRC licensing projects for the past several decades He spent most of his career on the South Texas project or STP Playing a leading role in the licensing under part 50 of STP units one and two and then leading the effort Under part 52 to successfully receive the COL for STP units three and four While at STP he also managed a licensing project for the special treatments exemptions Which was used by the NRC in the industry as the pilot for the 5069 rule change He also directed the project team ultimately responsible for the approval of the license amendment for the NRC pilot for risk-informed Completion times, which is now embodied in TechSpec Traveler 505 Scott is currently the business development director for search rec and serves with NPR as the regulatory affairs manager for UAMS Carbon-free power project to deploy the first new school SMR facility at the Idaho National Laboratory So before we get into the presentations, let me just go over a few things first So please remember to silence your electronic devices We will be doing a Q&A session similar to all the other sessions that you sat in this week So if you haven't yet, please scan the QR code for those of you here in the room If you're doing it virtually, you'll see the Q&A tab on the screen We're also going to be doing polling questions In this session. So for those of you in the room the slides showing the poll include instructions for participants to text their responses So in person participants will text the code next to their choice to 2233 And for those of you participating virtually you should see the tab for the polls on your screen So since this is the last day of the RIC, I wanted to say that feedback is important to us So please let us know what you thought about the RIC this year your insights help us to shape next year's program You can provide feedback through the platform by selecting the feedback tab in the session or by accessing the link from the RIC website So if you could post our first live polling question Do that for us Can you post the the first polling question, please? All right, well, maybe we'll move on to the first presentation. We'll come back to the polling question So if you could start my slides Right, or do I oh? Okay, sorry So do you know what citing is? Yes, I'm intimately familiar a little bit curious a little more and no clue or that's why I'm here so So you have a three only three choices this time or other sessions had quite a few so All right if you could Go do it go to my slides, please so So while we're bringing those up, so so why a presentation on citing well over the last couple of years We've seen Interests from new utilities who are new to nuclear as well as non utilities like such as dial chemical Who are expressing interest in a nuclear power now? And there's also a number of new reactor vendors that were interacting with as well We haven't been through this process. So we thought it'd be a good idea to highlight The citing process and the challenges associated with that and so in my presentation I'll give a kind of a quick high-level overview of citing and on Tuesday afternoon There was a session related to environmental reviews And so hopefully a lot of you attended that session as well Because that session pairs really well with the topic of citing Okay Okay So this photo may not look exciting at first glance But through the course of this panel you'll learn why this site is exciting So each proposed site is different from is different from its flora and fauna to its historical significance It's geology and its proximity to industries and populations and that is why we're here today Selecting a suitable site for a nuclear power plant may require a significant commitment of time and resources Including safety and environmental considerations site selection involves consideration of the human environment public health and safety engineering and design economics institutional requirements environmental impacts and other factors The NRC governs under three laws the Atomic Energy Act the National Environmental Policy Act or NEPA and The Energy Reorganization Act under these laws are specific regulations that have citing requirements For new nuclear reactors. These regulations include licensing processes that fall under 10c afar parts 50 51 52 and 100 Part 50 governs domestic licensing of production and utilization facilities And is known as a two-step licensing process and that an applicant must apply for a construction permit and an operating license Part 52 governs the issuance of early site permits standard design certifications combined licenses standard design approvals and manufacturing licenses for nuclear power facilities Part 51 contains our environmental protection regulations applicable to NRC's domestic licensing and related regulatory functions Part 100 establishes approval requirements for proposed sites for stationary power and testing reactors subject to parts 50 or 52 a Few of the relevant citing guidance documents include regulatory guide 4.7 or general site suitability criteria for nuclear power stations probably the one of the most important ones for citing regulatory guide 1.206 combined licensed applications for nuclear power plants New reg 0800 our standard review plan for the review of safety analysis reports for nuclear power plants and new reg 1555 the SRP for environmental reviews as I said This is just a few of the guidance documents related There are many others that are specific to the different review areas that are required to be evaluated as part of citing in the overall environmental review So the basis for citing is primarily in part 100 which requires the NRC to consider population density How the site will be used including proximity to man-made hazards and the physical characteristics of the site including seismology meteorology geology and hydrology and Determining the acceptability of a site from nuclear power reactor These citing factors and criteria are important in assuring that radiological doses from normal operation and postulated accidents will be acceptably low That natural phenomenon potential man-made hazards will be appropriately accounted for in the design of the plant that site characteristics are such that adequate security measures to protect the plant can be developed and that physical characteristics unique to the Pro site that composes significant impediment to the development of emergency plans are identified Our regulations also state that no person may begin constructing a nuclear power reactor until issuance of a construction permit Combined license early site permit with a limited work authorization or the issuance of a limited work authorization itself So as I said you have to have a license before Starting construction. So what is considered construction? Construction includes the list of items that you see there on the screen such as the driving of piles subsurface preparation placement of backfill concrete or permit retaining walls The general idea is that construction includes on-site in-place activities with a reasonable nexus to nrc regulated safety or security issues So to provide some additional clarity the provisions in 10 CFR 50.10 a to provide examples of what is not considered construction Some examples include excavation and site preparation and exploration Building fences and roads in essence those items not those items without a nexus to safety or security issues If an applicant desires to start some safety related construction prior to receiving a license then a limited work authorization Or LWA is required LWA's can be used for the driving of piles subsurface preparation placement of backfill concrete or permanent retaining walls within an excavation Installation of the foundation including placement of concrete any of which are for System structure component of the facility for which a combined license or a construction permit is otherwise required The LWA review timeline is dependent upon the scope of requested activities as well as the degree of pre application engagement with the nrc However, this process includes development of an environmental impact statement Reviewed by the acrs and a mandatory hearing before the Commission In evaluating of a post site for a new reactor the nrc staff looks both inward and outward from the looking inward perspective The nrc considers site safety factors by evaluating the design of the facility to protect against natural phenomenon hazards That is environmental factors that affect the design such as earthquakes floods and tornado missile tornado missile Tornado generated missiles. Excuse me. The staff also considers the consequences of postulated accidents and other hazards and emergency and security planning From the looking outward perspective the nrc considers environmental values as part of its NEPA responsibilities by evaluating the facility impacts on the human environment Such as water use and quality socioeconomics terrestrial and aquatic species and routine and accidental releases So this graphic depicts various areas reviewed and analyzed as part of the stash review of new reactor applications The areas are diverse and look inward and outward with respect to the design of the post facility and its impact on the environment In the site selection process Coordination between applicants and various federal state local and Native American tribal agencies will be required Information related to all of these areas on the slide will be necessary to develop an application Some of the information will be readily available from published reports public records public and private agencies and individuals knowledgeable about the site Other information will need to be developed through on-site investigations so this slide shows some of the prior activities that were considered by applicants for LWA's and you can see on the screen here as in it and it's generally consistent with The requirements for LWA is such that you could work on the reactor building foundation through the placement of rebar pouring a concrete Crane foundation retaining walls that can be abandoned in place to then become part of the structure itself So another other activities So in summary the siting review process evaluates the availability and identification of suitable sites It depends on local specific situations Policies and regulatory and legal structures It may define unique critical safety and design interfaces and mitigations for adverse and environmental impacts Based on site specific characteristics The process provides early opportunities for all stakeholders to participate in the licensing process and includes site Suitability determinations with simply requires Engagement of permits from state and local authorities So this ends my presentation. Let's take a look at the first poll question results if we could Good a lot of folks here And virtually are familiar with the siting process But a lot would like to know more Great All right. Our next presenter is Kristen Kerwin While Kristen is making her way to the podium if we could bring up our second polling question Do you plan on going through the siting process? Yes, no or Considering it so if you leave it up for about a minute and then we'll get back to Kristen and we'll We'll look at the results of the this question following Kristen's presentation All right. Well, good morning, and thanks Brian for the introduction. I always find it's a lot nicer to be introduced Then have to introduce myself. It's kind of like a sandwich. It always just tastes better when somebody else makes it I think I woke up hungry today, but I can always talk about food in addition to NEPA I'm really happy to be here to have the opportunity to talk about the Department of Energy's regulatory responsibilities related to financial assistance projects And I'll take it just a minute to give you a bit of background on the Department of Energy's office of clean energy demonstrations Which will set the scene I think for for why I'm here talking today Oh, so it is a new office in the Department of Energy and it was established in December of 2021 as part of the bipartisan infrastructure law As you may be able to deduce from the name. Oh, so it is an office focused on the demonstration of clean energy technologies Technologies that will include advanced nuclear reactors along with clean hydrogen carbon management long-duration energy storage industrial decarbonization demonstrations in rural areas and On current and former mine lands and more. It's a very exciting new office Just steal a little bit from our session name Ossid's mission is to deliver clean energy demonstration projects at scale in partnership with a private sector To accelerate the deployment market adoption and equitable transition to a decarbonized energy system Ossid was established to accelerate clean energy technologies from the lab to market and fill a critical innovation gap on the path to achieving our nation's climate goals And Ossid is currently managing two projects in DOE's advanced reactor demonstration program As you're probably very much aware DOE has a long history of supporting the advancement of nuclear technology over the past two decades DOE has supported several designs in different ways and And this slide here shows a montage of the advanced reactor designs that DOE through both the office of nuclear energy And Ossid is currently supporting via cooperative agreements DOE sees government financial assistance for new nuclear technologies as a way to mitigate the inherent technical and market risks and enable broader fleet level deployment by domestic utilities and other power users So the original ARDP funding opportunity issued by DOE's office of nuclear energy addressed three pathways Advanced reactor concepts risk reduction for future demonstrations and advanced reactor demonstrations These three pathways cover the technology maturity spectrum with the advanced reactor demonstrations being closest to commercial viability The X energy XE 100 high temperature gas cooled reactor and the terra power Natrium sodium fast reactor were selected by any for the advanced reactor demonstration pathway in fiscal year 2020 Management of these two demonstration projects was moved to Ossid under the bipartisan infrastructure law along with 2.5 billion and additional funding And DOE is working closely with TerraPower and X energy on the development of these two projects and to assure that DOE is regulatory responsibilities including those associated with NEPA are fulfilled And that really brings me to the heart of this presentation, which is DOE's regulatory requirements including but of course not limited to NEPA for financial assistance agreements So financial assistance is a broad term that covers various forms of assistance that non federal entities Received from the federal government DOE's cooperative agreements with TerraPower and X energy are of course examples of financial assistance agreements and Both the council and environmental quality and DOE's NEPA implementing regulations regard financial assistance as a major federal action subject to NEPA review So that doesn't mean that DOE is required to analyze the impact of the funding action Paying invoices transferring funds and that kind of thing rather it means DOE is required to analyze the impacts to the human environment That will result from the actual physical work that is enabled by the federal funding As the NEPA practitioner going on 20 years, I'll admit that NEPA is my comfort zone. It's my safe space But as we were reminded during Tuesday's fantastic panel on NRC's environmental review processes When NEPA practice winners like me say NEPA we most often mean much more than just NEPA And by that I mean in addition to being a major federal action subject to NEPA financial assistance It's also subject to section 106 of the National Historic Preservation Act Meaning DOE must consider how projects impact historic properties And financial assistance requires DOE's compliance with section 7 of the Endangered Species Act and the Marine Mammal Protection Act and more And as I think about it, I'm not really sure why I put the Marine Mammal Protection Act as an example on this slide It's not that likely to apply to projects that you're considering But should anyone propose to build an offshore advanced reactor with DOE funding? You can be certain. We'll be talking about Marine Mammals A few regulatory requirements that are more likely to be applicable to advanced reactor projects include DOE's floodplain and wetland review requirements And the Farmland Protection Policy Act Now it's really important to understand that DOE is required to comply with these regulations for financial assistance actions Even if the projects are not occurring on federally owned land Even if the only DOE nexus to your project is funding DOE is required to comply with these regulations Further DOE requirements begin as soon as projects are selected for negotiation of a cooperative agreement Prior to executing a cooperative agreement or other financial assistance award And thereby authorizing the expenditure of DOE federal funds DOE is required to be in compliance with all of the applicable federal environmental regulations for the proposed scope of work So at this point you might be asking So what why is this important? Neep is not new. I know what the Endangered Species Act is. I've done this before What's your point, Kerwin? Which is a question I ask myself a lot And I guess what I really want to emphasize is that DOE cannot authorize the expenditure of federal or cost share funds For any activity until DOE is in compliance with the applicable regulations DOE must complete a NEPA review and comply with the other requirements before project activities can be started and Project activities include everything from conceptual design to site characterization site preparation all the way through obviously construction and operation of a facility And don't get me wrong DOE recognizes NRC's regulatory Authorities and the NRC will be the lead federal agency in the preparation of EISs for issuance of construction permits and licensing of nuclear facilities And DOE plans on cooperating with NRC to the extent possible in preparation of these EISs But that doesn't relieve DOE's responsibility to complete NEPA and related requirements for activities that occur prior to NRC's authorization of construction activities And as we all know we're all here We know from experience that compliance with NEPA and regulatory requirements takes time and it costs money Which means that federal compliance with these regulations has the potential to impact your project schedule and budget And that really brings me to a discussion of best practices that can help the various federal review processes go well Minimize unnecessary impacts to your project and enable DOE to make better More informed decision regarding the expenditure of federal funds, which after all is the purpose of NEPA Before I start talking about best practices, I want to note that none of these best practices that I'm going to talk about provide a road map to Taking an end round or end run around or short cutting the process. That's certainly not my goal DOE and all federal agencies, of course need to balance the need to be on schedule With our duty to comply with the regulations in a way that is diligent comprehensive and legally defensible To that end I'll begin by encouraging you to start early It's in it's important to incorporate NEPA and required related considerations like cost and schedule alternatives Connected actions and potential mitigation into your project at the earliest stages possible So start thinking about NEPA early in the planning process And if your project has federal and government or federal government involvement beyond the NRC Like agencies providing federal funding for example Be sure to consider how the agency requirements and the timing of those requirements fit within your project schedule and budget How should you go about doing this? That brings me to the next bullet Communicate early and often with NEPA representatives from the federal agencies that will have a role in your project. I Think it was less than an hour into the Rick program on Tuesday when I first heard the phrase communicate early and often Chair Hanson really kind of stole my thunder on that one. I got scooped by a full two days But honestly surprises as you know in the world of federal environmental regulations are not fun And they're most unwelcome So communicating with NEPA teams that all of the federal agencies involved in your project early and often will help everyone To more fully comprehend the regulatory landscape and reduce potential for unwelcome surprises Taking that concept a step further you can facilitate communication between the federal agencies With involvement in your project. I imagine that all federal agencies are pretty familiar with NRC's role in the NEPA process for nuclear projects And we all know that all federal agencies have NEPA responsibilities But it's really important to ensure that there's communication between those federal agencies regarding each agency's proposed action and respective regulatory requirements So as early in the process as possible federal agencies should really be working together to establish a common understanding of each agency's roles and Responsibilities and the timing of required reviews throughout the course of your project Identify existing NEPA documents studies and other resources One of the key tenants of NEPA is to not duplicate work So think about and work with your your federal agency NEPA representatives to think about whether there are existing resources that can Inform the NEPA process for your project Identify existing NEPA documents that can be incorporated by reference into agency reviews and therefore streamline the process I would encourage you to plan of sufficient time for meaningful engagement with tribal entities that might have an interest in your project As we know meaningful engagement takes thoughtful planning It takes time and resources and you can really enhance the federal engagement with tribal entities by sharing information and working to build those Relationships early in your print planning process. I would encourage you also to engage with stakeholders early the point of public participation in NEPA and section 106 for that matter Is not to send form letters to everyone under the sun and insert and hope we don't hear back Meaningful engagement with the public and stakeholders is critical and it adds value to the NEPA process So as I see it there are two key through lines in this list of best practices communication and planning as Entirely mundane and unearth shattering is that might be communication and planning can go a long way toward effective navigation Of the federal environmental review processes and set your project up for success that I'd like to thank everybody for their kind attention today and NRC for the opportunity to present. I look forward to hearing from the rest of the panel But if you have questions that I didn't answer today or want to reach out to OSID here's an email address I encourage you to do so And thanks so much All right. Thank you Kristen We actually have had a couple of companies come to us to talk about the potential for floating reactors So the marine mammals act may may come into play For you know it So let's take a look at the results of our second polling question. Do you plan on going through the siding process? Wow, 57% yes, some no and others are considering it. So all right good Okay, so so that means our maybe our the timing of our session was was good Our next person is Allison natcher who is joining us from Alaska Allison. Are you there? I am good morning. All right, you're up Great. Thank you So good morning everybody. My name is Allison natcher with Alaska Department of Environmental Conservation In this presentation the hat that I'm wearing is the state liaison officer US NRC Next slide please So I get asked this question quite a bit Especially since we do have a microreactor Project going on with Ilesen Air Force Base Who regulates nuclear power in the state of Alaska? So nuclear facilities are regulated by the US NRC through siding licensing inspection and enforcement However, Alaska law also includes state regulation of radiation and nuclear facility siding in title 18 chapter 45 atomic energy This was actually originally passed in 1959 during the same year as the original atomic energy act Updated in 1981 and then again in 2010 Next slide please So as I said our landscape within the state of Alaska is changing We did actually have to update title 18 chapter 45 In 2022 so in January 31st, 2022 Senate bill 177 an act relating to nuclear facility siding permits And relating to microreactors was transmitted by governor Mike Dunleavy and this was to go ahead and Be an important step towards securing Alaska's energy independence Created a pathway for a new and alternative energy opportunities throughout Alaska Ensured a retention of Alaska's global leadership role with regards to sustainable microgrid Technology and then of course supporting military readiness specifically the Ilesen Air Force Base microreactor pilot project Currently Alaska does not have an operating nuclear reactor or a fuel cycle facility So we had to go ahead and create these updates Next slide please So this is about the Ilesen Air Force Base microreactor pilot project Speaking of communication The state of Alaska sort of found out through Open source media that this was going to be a thing but at Ilesen And so it was kind of a bit of a surprise and a shock to some of us So we weren't alerted ahead of time, but moving forward We went ahead and we're working with the Air Force With their pilot project to develop at least one microactor by december 2027 The microreactor would be located on Ilesen Air Force Base It was going to be commercially owned and operated and us nrc licensed The goal is to provide the installation with clean reliable and resilient energy support technology for critical national security infrastructure This is the first pilot project of its kind And the microreactor pilot project must undergo significant scrutiny and coordination From the agency is involved to ensure its success And this also includes working with the Alaska department of environmental conservation Next slide please Within title 18 chapter 45 atomic energy We actually have a requirement That The applicants have to obtain a license or permit for the activity in which the person proposed to engage from the nrc And so this means that the person may not manufacture construct produce transfer or possess a Special nuclear material by product material Special nuclear material facility by product Um Without first getting a permit and license from the us nrc. So it's actually written into our statutes I have received questions. Well, does that mean that you know, we just go through the nrc solely and it's no We work in conjunction with each other Next slide please So this is what we currently have for facility siding permit required It just basically it says that you have to obtain a permit from the department of environmental conservation To construct the facility on land designated by the legislature Um, we actually just had law go ahead and review our new siding of microreactors regulations So I actually can't speak to that finally and so it's a bit more nuanced. We are actually requiring A pre application and notice requirement for a nuclear facility siding permit applicant Um, the applicant has to have like procedures obviously for nuclear facility siding Um, we are requiring a nuclear Siding permit processing issuance Modification termination appeal and so this is stuff that we're working on right now. Um, and then also Going into detail kind of dovetailing with nipa is describing location requirements for a microreactor facility Next slide please So as I said the legislature, um Is heavily involved with this and they're the ones that actually designate by law the land in the state On which a nuclear fuel production facility nuclear utilization facility A nuclear processing facility may be located Legislature needs to act in just of regulating the economics of nuclear energy and shall act to protect the public health and safety Next slide please And this is basically the the department of environmental conservation shall adopt regulations governing issuance of permits required by this section Um, however permit may not be issued until the muni with the jurisdiction over the proposed facility site to approve the permit So a little bit more about alaska We don't have counties. We actually have munis and then if it is not in muni Then it is usually overseen by the legislature Next slide please So here are all the updates that we that we went through um So again kind of going back to the facility sighting permit required Permit and I may not be issued until the muni with jurisdiction over the proposed facility site has approved the permit Or if the proposed facility site is located in an organized borough until the legislature has approved the permit Next slide please So we amended this section For facility sighting permit required um Person that is otherwise compliant with this chapter may construct a microactor on land that has not been designated by the legislature Next slide please So we do have the requirement to conduct studies concerning changes in law regulations with a view of to uh, atomic industrial development um and so We conduct exhaustive and incitinous studies of nuclear development related risks and then we engage with different state agencies So it's de c department of health department of labor and workforce development department of transportation and public facilities department of commerce department of fishing game department of Natural resources and other state agencies as applicable Next slide please So we also amended this section to exclude microactors from the ongoing study requirement in recognition of extensive research taking place inside and outside of Alaska This includes Studies that are ongoing at the Idaho national lab. We've been working with them quite a bit And then in addition that um, if the de c received notice that a person has submitted an nrc license application for microreactor located in the state The de she actually goes and coordinates amongst all the different agencies within the state and submits comments To the nrc All right next slide please So this is our current de c siting regulation timeline This is based on the request that was made by the united states air force So we did actually conduct a 30 day public scoping for regulation development and started on december 13th It ran about 30 days. We did this because as a state of Alaska We have a requirement that we do actually have to Engage with people discuss, you know upcoming Regulatory development And the public does have the right to go ahead and make comments on that But we kind of want to go ahead and socialize it initially at the beginning So it didn't become it wasn't quite a surprise So we did receive multiple submissions pertaining to future development of draft microreactor siting We received initially about 79 comments And after that occurred We drafted initial siting and then of course law went ahead and conducted a thorough review And then during that time working in conjunction with law, we actually do have a discussion about You know issues considerations And we talk amongst ourselves within the de c and then of course law is heavily involved as well Next slide please So moving forward We actually just started the siting regulations Formal comment period and we're doing it 60 days a minimum public comment period is 30 But because it's microreactors, it's new And we want to have a lot of engagement with the public and to actually understand what their concerns are recommendations are We moved it to 60 days And then the goal ultimately is to have everything finalized and adopted and signed by august 2023 Again, this is something that The united states air force requested that we do Since they're on moving forward with their aisles and project All right next slide That's all I had All right, so actually we have our final poll question up up here now. Thank you, allison to start right there Whose perspective would you like to learn more about in our cdu e industry or or the state? So next up will be dr martin ben statten Well, thank you brine and thanks to the nrc's rec organizing committee for inviting x energy And from from my perspective at x energy I can't think in the last 25 years of my involvement with nuclear That there's been a more exciting time for advanced nuclear reactors or for nuclear in general, so You just get to advance the slides So i'm going to quickly give an overview of our reactor because i'm not sure how much everybody knows about our design And I think the most prominent thing about our design is our fuel. That's extremely unique So the picture on the slide there shows you one of our fuel elements It's a graphite fuel element And it's filled with about 19 000 trisocoded particles And one of the big advantages of this fuel is that we can retain a really high percentage of the radionuclides within the fuel and That is extremely important when we look at siding at the end of the day and you'll see a bit about that We also utilize the concept of functional containment Which means that We don't necessarily need to rely on these large physical structures and barriers to retain the radionuclides and that That we can actually meet the regulatory dose limits at site boundary without Needing to rely on some of those our fuel uses high s a h a l e u and We know that is a challenge, but we we we've already started addressing that with with many Stakeholders And and I think one of the the the big advantages of this fuel is that it allows reactor designers to look differently at how you design the plant And so just give a quick overview of our reactor or our main power system On the right hand side, you see the reactor And the arrow is showing the flow of helium. We use A high-temperature pebble bed reactor We use helium as a heat transport fluid very important. It's not a coolant in in in the sense of a traditional reactor The helium flows through to a helical called steam generator. We regenerate steam The the steam is high temperature at 565 degrees c 16 and a half percent NPA pressure and We've specifically designed this reactor the power system to provide either steam for electricity generation So matching the temperatures of high efficiency steam turbine generator sets Or to be able to use this as a process heat application So a very important distinction of of many other reactors I've added just a quick slide on what the the reactor nuclear island looks like versus the balance of plant and from day one We've really purposely Segregated the nuclear island from the balance of plant and the reason for that was that we knew From day one that we're going to be designing a plant that's going to be dual use So we could either use it for electricity generation Like the slide shows or we could do process heat extraction Or we could just provide process heat depending on the temperature requirements from the customer So that gives you a very A flexible application in in in the design and and from a licensing perspective We're looking at licensing. What's in the gray box? And so our entire control system is based only on parameters that feed the reactor that are within the gray box And essentially we don't need to know what's going on in the back end from the steam side In fact, the the everything in the green box could be a mile away Depending on the the type of application that will be applying So why is this this is really for us exciting When you look at the the side footprint on the slide there This is a a notional plant layout This one is for a Is that the water cooled a water cooled layout? We can use either dry or wet cooling But what's important here is to look at the red line which is showing us the protected area boundary That's where the the four reactors are our plant consists of four reactors and four steam generators And four turbines. So we've got a very modular approach allowing allowing a customer to add Additional modules as required or to be able to do sequential construction while you're operating the first reactor Um, and then when we look at the blue line, we are looking at a exclusion zone Uh emergency planning zone of around 400 meters. So Depending on that site What that means is that we can meet we believe we can meet the regulatory requirements in a worst-case accident even if we release all our helium with a small amount of Circulating already nuclides in the helium to a site boundary Without taking credit for things like the containment the building or the pressure boundary Now why is this important? Because it really allows us to bring our plant Into closer proximity of things like a large petrochemical plant So I've just grabbed some some images of the internet there. This is not a specific plant But we've done multiple studies where we're looking at location of our plant Next to these large chemical plants and what you're seeing in in that first left hand side slide is two four packs So a total of eight reactors that we can place Right up to the up against the boundary of a petrochemical plant And feed the steam literally over the road into that petro into that petrochemical plant And giving you idea of of how the the site footprint that we're looking at and similarly on the right hand side We've also been involved in a number of siding studies I think the most recent one is the warrior run siding study just here in maryland That's a public the outcome of that study is public. I think it's on the the maryland website So you're welcome to go and have a look at that and that's looking at repurposing of coal sites a coal fired sites Or even We believe we're going to be repowering a lot of the gas powered sites as well But also showing here how we can utilize existing land and and and apply multiple four packs To replace coal fired plants and and that's where we believe the the biggest Market drive is going to be in these two areas in the next 10 to 20 years So quickly go over the siding process Brian's actually given you guys much of what what's on this slide here But really important that we've we've learned that it's energy You know, there's there's a business case to be made and the siding process is a key part of that being able to Look at the engineering assessments for that site the facilities and studies Site alternatives, you know, we need to look at multiple sites economic And socio-economic studies and regulatory studies You know and depending on the outcome for each of the sites you evaluate You know, there's a certain amount of site specific design work that might go into that So I'm not going to go through this slide in detail. I know we're running a bit short of time And then I won't say much on this either You know, these this is the regulatory process that we use to Systematically assess the sites Brian also went through that in a little bit more detail So I'm not going to cover that in any further detail Um, I think what's what's really the most exciting to us now and most of you might have heard in the Last two weeks. We made the announcement that our first demonstration plant We'll be partnering with our chemicals and we are in the midst of site evaluation with our chemicals To identify a site in the Gulf Coast area So this is very relevant to to x energy. It's an exciting time for us to be Involved in nuclear nuclear and also exciting to see the regulatory bodies Like the DOE and the NRC are fully engaged in this. So thank you very much And this is just a video that I'll plan. I don't need to comment on that Of our site layout. Thank you Thank you, martin We'll see Okay, this is just the question of him. We'll bring the results up after scott. Well, we'll bring the results up We'll look at the results after after scott gets his presentation and we get into the q&a Thank you, brian Good morning. It's a pleasure to be here today to talk about this very interesting and timely subject My name's scott head and i'm the regulatory affairs manager for the carbon-free power project I'm going to share some perspectives today on our Including activities that we've undertaken at the site to support our application Uh as well as share some perspectives on limited work authorizations Uh, I was also the regulatory affairs manager for the south texas projects units three and four And I hope to weave some insights with respect to that project that are relevant to today's topics Basically a green field versus a brownfield comparison if you will Some background on the carbon-free power project It's a carbon-free power project as a wholly owned entity of the utah associated municipal power systems or uamps Uamps is an association of 50 public power utilities in seven western states Most folks in this room know that we'll be using the new scale technology for carbon-free power project Using six modules that will deliver 462 megawatts of power These modules will be essentially identical to the modules that were covered by the certified design But with a significant upgrade This upgraded capability is addressed and new skills recently submitted standard design approval application Cfbp will be located In a high desert environment and we'll be using air school condensers It'll be cited at the Idaho national laboratory on the west side of that Idaho national laboratory And I'll show you some more details in a second. We are being supported and participating in a DOE cost sharing arrangement And I mentioned new skills submitted the standard design application in december of last year Which we will be referencing in our application And the we expect the nrc review to be started on that application in the very near future And we'll be licensed under part 52 This slide shows the location of the carbon-free power project It'll be located on the far western side of the Idaho national laboratory, which is a department of energy site It's a it's a 900 approximately 900 square mile site and since the late 40s has hosted More than 50 reactors in its history And we are planning for it to host six more It's a high desert environment and for someone like me who has lived and worked on the texas gulf coast all of his life It is a very very interesting and fascinating area to visit There's a timeline for that's that's germane or subject to the to today's discussion The initial interactions regarding the project were started back in 2009 And the interviewing intervening years discussions were held with both new scale and DOE And we received the DOE funding arrangements award in 2020 After a number of NEPA required studies were performed the site was selected in june of 2021 And we accessed the site in june of 2021 We then embarked upon and completed our seismic studies our core boring campaign and well drilling Groundwater monitoring was started in february of 2022 Our cultural studies and ecological surveys are still ongoing As I noted earlier new scale submitted the sda application in december of 2021 And we expect to say the nrc to initiate the review in the very near future We expect to submit a limited work authorization in july of this year And at the same time we will be submitting an exemption to allow us to proceed with our excavation activities We expect to submit our combined operating license in january of next year With the respect to the theme of this session, let me make a couple of points The time between we access the site to begin site characterization activities To support our application and our planned application date is approximately two and a half years Compare that to the south texas project The time between starting site work until we submitted our application was approximately 14 months You would expect this time difference At stp We had an incredible amount of environmental data available already as an operating nuclear power plant As well as meteorological data The site was well characterized from its geological standpoint And most importantly is we had an environmental report from 25 years before That had not changed that much at all and was used as our model to create the environmental report as we move forward So if you're building an application schedule for a greenfield site Keep these differences in mind as you build that schedule A number of people in the room are expecting to be siding Going through siding activities in the near future and here's something you can look forward to I say not only to you but I would offer that that the country As well as the local communities hope to see these activities soon also activities such as Well water drilling for well monitoring ground water monitoring Core boring Developing and establishing a meteorological tower And of course tour groups The other group pictured there on the far right was in fact the the team that was supporting a Pre-engagement Insight visit by the environmental folks My other topic today is a limited work authorizations The process is allowed by regulations And it's a codified and 10 cfr 50.10 It should be noted that limited work authorizations have been not been used many times Searching through the dockets you will find the southern company filed for two lda's for the volgule 3 and 4 project and both were approved Progress energy applied for an lda for the levy county project, which was subsequently withdrawn And next error applied for an lda for turkey 0.6 and 7 and it was subsequently withdrawn And i would note that we filed for an lda at the south texas project But promptly withdrew it and pursued an exemption instead An important aspect of the current rule is because of the rule change in 2007 as brine noted earlier Excavations except under certain circumstances do not require an lda I would draw your attention if you're contemplating it to read the secchi 07-0030 In which the nrc provides a detailed argument why applicants should be able to proceed with excavations without nrc approval It's a very good read Under certain circumstances depending on the construction technique you might need an lda for an excavation or at least an exemption An lda supports a major federal action And as such will require a deeper review which will need to be supported by an environmental report and an lda will need to be supported by safety analysis The lda process requires a mandatory hearing It's also a lengthy process The nrc's generic public schedule states that an lda could take up to 36 months to approve Which will lead me to my most important point of my presentation If you plan to be an applicant You need to avail yourself of the opportunity of pre-application engagement meetings with the nrc And these interactions you can share your plans and identify crucial issues and you you see with your application and receive nrc feedback It was during a series of these interactions that we ultimately developed a plan Uh that would that do we now expect our lda to application to be completed in substantially less than 36 months That completes my presentation and I look forward to your questions Scott So we go playing up bring up the results for the the final poll question I just respect we'd like to learn more about It's pretty even pretty even across the board So we do have a few questions and we do have plenty of time to address the questions that we have Um, if you could put the qr code back up so the folks here in the room could scan that if it didn't have time beforehand And we'll start With the first question that we have here Uh, this is for the panel Um With coal to nuclear transitions identified as a promising application for advanced reactors What consideration is given to potential? Circular liabilities How do companies plan to address the assumption of liability? I assume that has to do with the cleanup of the coal plan and the ash ponds Does uh anyone want to try to address that? From a from an rc perspective, I'll I'll attempt to address it I know we're starting to look at the the coal to nuclear transition And the different issues that that may bring up Ash ponds is clearly one of them looking at it from a total site decommissioning standpoint Does that have to be factored into the decommissioning plan for the for the applicant or not? Is that handled separately? The the radiation aspects from the ash pond as well is something that we're starting to look into as well Does that have to be taken into account when they do the original site surveys for the application? But like I said, we're we the nrc just started to look into some of those issues now So a question for allison Did alaska use guidance from legislature past in other states when revising its atomic energy regulations? And are any elements of it in conflict with federal laws passed in the 1960s and 70s? Any thoughts on how those old laws may be updated for modern times? All right. Good morning. Thank you for that question. Um, we actually did so it was a group effort I with spill prevention and response. So that's where I kind of fit my organizational chart The other side is environmental health And so we worked in conjunction with each other to kind of go ahead and address these new regulations And new sightings specifically. We did actually go ahead and Talk with law I from my end went ahead and I actually talked with different state liaison officers and thanks to every single one of them That agreed to speak with me. So I spoke to different groups different people A lot of stuff in california for instance and a lot of different information coming from connecticut A lot of my other state liaison officers provided insight And also we went to and looked at utility of reciting regulations as well a question for christin Considering the diverse portfolio at oced How large an office is this and and what fraction are dedicated to the ardp projects and what sort of interaction is there between the different portfolio managers And and does oced as you called it perform the nipah evaluations for these projects or do the applicants or does do e or And if oced does not perform the activity them, what does oced do to facilitate? So basically if you could just talk a little bit more about oced Description of it and how you handle the environmental reviews Sure, i'm happy to that's a great question. Um, I think i'll be Better able to answer the nipah portion of that question than the oced portion. Um ardp makes up a A good portion of the Oced staff all of the provisions in bipartisan infrastructure law as well as the As well as ira have have staff in osud they're supported the Closer Yeah, sorry The the program staff are supported by Um The esn age group as well as financial assistance grants agreements officers Legal counsel and the like so we're a rapidly growing organization and and really working together To support the execution of the provisions under under bill With respect to nipah and who does nipah? In financial assistance agreements, it's most common to have a three-party agreement. So applicants hire nipah contractors The nipah process can be funded with approval from the contracting officer with project funds And the applicant doe and the nipah contractor work in a three-party agreement where The contractor is paid by the applicant, but produces a doe document We have a memorandum of understanding or agreement letter that we line out Very clearly the roles and responsibilities in the nipah process And what we expect The process to look like and that's typically how it's handled in in financial assistance agreements Okay, great. Thank you. So a question for me So brian the laws involved here date from 1954 to 1974 yet the The siting regulations continue to evolve Over time are the laws in need of updating? And consolidation or is there a sufficient leeway in interpreting these These laws to justify past updates and future updates without further congressional oversight The the laws even though they were dated from 1954 1974 continue to be updated As as congress sees fit and will probably always have congressional oversight Um I haven't heard of any discussion on the need to change the laws with respect to siting We we take those laws and we put them into the regulations and provide additional requirements in there as well um I think there is sufficient flexibility to To make changes to the guidance And how we interpret our regulations and and and enforce those regulations and we're doing some of that now Scott mentioned it earlier, and I think martin did as well in that We did a sake paper back in 2020 addressing population related siting considerations for advanced reactors and proposing to the commission that we Modify our guidance to take a more risk-informed technology Performance-based approach We are working on guidance to the commission to respond back approving the staff recommendation in that In that paper We do have some draft guidance that we hope to get out. I believe next month That will help The industry potentially locate plants closer to More densely populated communities than what the guidance currently allows for now That's certainly as martin showed in his in his graphics Um, we've also Uh, I've been looking at our environmental guidance We have an advanced reactor guys Generic environmental impact statement that's up with the commission now For review that would help Somewhat streamline the environmental process the review process from most applicants perspective as well as the nrc's perspective We also issued What we call an interim staff guidance related to micro reactors A couple of years ago as well from looking at it from an environmental perspective how Because of the small size and the small impact on the environment and potentially small releases You could do a scaled environmental report to be able to submit to us and we could in turn Scale our environmental impact statement that we have to do to to address that So so there are a number of ways in which we are making the process a little more efficient By modifying by modifying our guidance without having to modify the National regulations or the or the laws associated with that So a question for scott How can the lwa process be made more efficient and coordinated? With the col process Well, one of the uh, one of the parts of about the lwa process Which I didn't mention but uh You you do all your work all your work that you would embark upon an lwa at risk There is no presumption that you will get and receive a combined operating license And doing it at risk You also have to create a redress plan in case you don't receive your license or you withdraw from the project So what what puzzled me when we first started looking at the lwa process is the need for the mandatory hearing It's affiliated with the fact that it's part of a construction a A construction permit, but there will be a mandatory hearing for the for the col As part of the col application And it seemed like if you're doing it at risk and you have a redress plan That uh requiring a mandatory hearing in that extra four months of time or more potentially is uh, Is really probably unnecessary and a duplicative And uh, and so that's something to consider because uh, it As as you noted, it's not been used many times and I think the length of time is uh, as part of the issue with uh With the lwa process That's one thing at least Okay, thank you scott All right, so a question for the panelist Uh to all the panelists. What are the biggest barriers to timely siting reviews in each of your domains? I can maybe start um, and I see molten Our siting Managers is smiling One of our biggest challenges obviously is is number one getting a plant owner so that you can get to a site You know, I think that's from an advanced reactor developer perspective being one of the bigger big challenges Um, so I don't see it as being a regulatory issue. It's about having industry commit To to building a plant and and getting a committed site Uh, so that we can actually start these processes. I think the processes From from a new pair and from a we will be looking at a construction permit approach using the port 50 route But just getting a site so that you can actually start these processes is most probably one of the biggest hurdles We've faced over the last couple of years and so that's why the the excitement from ex-energy's perspective signing Dow chemicals as a customer We will be announcing the actual site within I think about the next two months. So dow is working the stakeholder engagement And as soon as that's been completed, we'll be making that announcement. So Then a molten if you want to add anything there, but I think from our perspective That's probably the the biggest hurdle we've faced And so I would agree for a greenfield site, you know Determining the the location of the plant is a is a very lengthy process and I don't know that it can be you know, especially on a greenfield side. I don't know how much it could be You know made shorter But it may be helped if you have someone that you already have a you know as a as a target applicant. So, uh, but it's uh It's it's part of NEPA and and it's part of it's part of the work you have to go through and So I'd like to say but but it is a significant significant part of the process All right, well I'll answer um And I guess my answer isn't specific to either of the ardp projects that do is uh, or that osa is supporting It's it's specific more into project development in general and and it's it echoes what what martin just said is You know, we can't really begin NEPA without a site NEPA is site specific And we can't finish anything that we don't start and so Absolutely the the the number one important thing in and starting and finishing A NEPA review in a timely manner is identifying a site not changing that site And and gathering the the specific details needed to do a detailed and thorough analysis All right. Thank you Um, I would just say from a nrc perspective I'll make another plug here that you've heard multiple times in this rick is pre application engagement so Don't wait until you have your application ready before you come in and talk to us Um, and and none of the applicants are doing that they're they're coming in and they're talking to us well in advance We've been talking to cfpp for a number of years now x energy as well Um, not just from the safety perspective, but also the environmental folks. I've got some of those folks here in the room with us today Um, come in and come in and talk to us. You have questions about the sliding aspects the environmental aspects We're we're here to we're here to help So a question question for me What is the purpose of the safety application and safety review for an lwa? Considering the lwa work is performed at risk of the applicant It's subject to redress and the lwa has no bearing on issuance of a cp or a c u l So I would say it goes back to Like the definition of construction And what is considered construction? and the lwa is Covers those things that fall under the definition of construction And so that means those activities have a nexus to either safety or security portions of the facility and so That's why we have to do a safety review as well As part of the lwv review process taking consideration all of the the Geology and the seismology and all the other oligies we have to look at In the design of the facility itself All right, so a question for scott You mentioned that the 25 year old site characterization reports for stp were a great template In your opinion Would the data have been helpful if it were not a nuclear pedigree? I'm thinking about reuse of data from an old coal plant for a new nuclear plant Based on your experience. Do you think that site characterization data associated with an old coal plant will offer much value? Well, it certainly could you need to explore all options And all potential information that's available to you. So it's certainly better than You know the people there have a lot of experience already and you should avail yourself of that I would note that with with our project Doe and its contractors had an incredible amount of cultural ecological environmental Data that was available to us that really jump started our our preparation for the environmental report And so if you have that information available to you then you certainly should should find some way to use it And I would expect some of that information. You got a coal plant would be available to you to use Martin you you said you were part of a review that looked at coal plants in the state of maryland Is that something you evaluated as part of that? We didn't go to to that extent yet. They were they were there was some environmental data available But I think the the review we did was a higher level You know fit for site application for the warrior run site We didn't have a lot of environmental data available from that site at all So, you know, it just didn't Didn't make any difference at this point I know the department of energy Did a study in the last year as well looking at the reuse of coal sites for for nuclear plants and actually identified I guess a couple hundred of those using Various criteria. I mean I really had a chance to look at that in detail I imagine they looked at the the amount of environmental information available as well as part of that. So Okay, another question for nrc staff or for myself. Does nrc consider floating reactor siding? so As I mentioned earlier floating reactors is something we've had a couple of companies come talk to us about In those cases those are going to be like stationary and not not on ships But kind of permanently moored in a in a bay type area The same siding requirements would apply to a floating reactor as well If it was going to be stationary if it's going to be a ship That's a mobile. That's something else. We'd have to to look into into that And so So this was where the marine mammals act make them into play So, uh, there's there's a lot of different other aspects, especially the aquatic life that may be that may be around so Another question for me What are nrc salts on fast-tracking the siding process for new nuclear on existing facility land? We haven't thought of fast-tracking the process The process is what it is but by exist by choosing to site on an existing reactor site You're going to have a lot of the same information as scott mentioned earlier in his presentation at stp That will make your your information gathering and application preparation that much quicker And being it's it's information that we're as an agency probably already familiar with That would help our review process as well So that that could then in terms speed up our review process and getting documents out more quickly So Brian could I add could I add to that? Sure? So this this Response is really, you know 15 years old But it's it's germane now to what we're what we're looking at as an industry Uh, you know my first nipa real nipa experience was was on stp 3 and 4 and and when I encountered the The the question and issue of alternative sites That uh, I was I was you know quite puzzled about why That would be an approach you would have to have for an existing nuclear power plant That I I had that we had to go try to find an obviously superior site to something that That already has a nuclear power plant on it the environmental impacts are already established and well known and and to to embark upon that Knowing that the probability of finding that obviously superior site was essentially zero Seemed like a you know a significant waste of time and effort That's not applicable to the carbon free power project. You know we embarked upon you know from the from the very start But with respect to coal plants and other things that we're attempting at this point in time it it seems like that there ought to be a A categorical dispensation or or some sort of Screening that could take place that if if you're building they're offering to build a nuclear power plant on a previously Significantly disturbed with the infrastructure and everything else is there The answer ought to be obvious that the the probability of Of finding a superior site to that one is so low But but the counterpoint is is that I will guarantee you you will When when you when you publish these alternative sites the the The communities in that area We'll find out about that and they will now think that there's there's a potential they're going to build a nuclear power plant You know in my community now that'll be both a positive and a negative reaction You would expect that but it doesn't it doesn't seem like given You know given What you're offering to do that to embark upon that course for either a nuclear power plant or a coal plant or You know a chemical plant like dow is something that's uh that there ought to be another option I think in in circumstances like that Yeah, so uh public outreach, uh that is something Allison mentioned it in her presentation about getting surprised About what the air force was planning to do at aisles and air force base In in my past here at the nrc and doing licensing of big projects I've seen it done poorly and done really well actually by the same company They had such a negative experience That they completely changed their ways when they chose their their next site and and The the community really welcomed them with all of the outreach and and explanation and information they provided to them So so that that to me that's key Uh in your process as well Interact with those around the area where for the site that you've selected early and early and often Can I make a comment regarding that please? Yeah, go ahead Allison great, um So obviously with a microreactor, um, you know specifically for aisles and uh, you know, it was a surprise to the community Uh, they the air force did hold a town hall and quite a few people said, you know We felt like we were just all untold like congratulations. You're getting this And so um to the air forces credit They said, you know, we made some mistakes and here's how we're going to improve things moving forward So they actually have a dedicated website now They're actually posting videos and doing a lot more Engagement with the people of Fairbanks. So I did want to give them credit for that But in addition the state of Alaska were actually developing a roadmap and part of that roadmap for microreactors is Basically community engagement, you know, what does that look like? How do we get people to engage? How do we bridge that gap between the vendors? The, you know, local communities tribes that was a huge part of that And also, um, you know, how do we get, you know, specialists? Basically from University Alaska Fairbanks Also to be able to have these conversations and have it being meaningful so, um As I said, just it's really important to go ahead have these conversations but also recognize that, you know Transparency is also key Otherwise if you don't have these conversations early and often you might encounter a lot more roadblocks All right, great. Thanks, Allison We have time for one more question, which is for me and then I'll get into some some closing remarks So will the nrc be more proactive in consultation with tribes early in the siting process? For example in pre-opication nrc becomes aware of several potential sites industry would already be engaging but cannot represent government government consultation Is the nrc prepared For this early engagement ahead of accepting an application and and I would say yes That was a big topic of discussion In the panel on tuesday afternoon Ken gave an example of how They went out to the state of Idaho and met with the the tribes out there in relation to the carbon-free power project so I know we're we plan to do more of that as more sites are selected and In the future So, uh, we have like 30 seconds left. So, um, I want to thank all my panelists Great job. I thank the the audience for some really good questions We covered a lot of topics and and I want to go over a couple of key key takeaways For me the siting process is not simple and it can take a significant amount of time The siting process can take a lot of coordination With state and local officials as well as your native american tribal governments, which we just talked about Uh, the state and local requirements can vary. Allison went through just what's going on in alaska Every state is going to have its own nuances. So you're going to have to take that into account And also finally whether locating on a du e site or receiving funding from du e The du e has nipa obligations That it has to do itself as well as us. So In that case, it's early to come talk to us early So we can coordinate our nipa efforts to make sure it's the most efficient So, uh, with that the session is closed. Thanks everyone