 Good afternoon, everyone. I think we're ready to get started. Everyone wants to find their seats. Hi, good afternoon. Thank you for coming. My name is Lauren Mayrose. I am an international policy analyst in the NRC's Office of International Programs, and I am very excited to chair the panel today that's entitled, Non-Pläforation Considerations for the Export of Advanced Reactors. We have five outstanding panelists who have joined us today from the Department of State, the Nuclear Energy Institute, the International Atomic Energy Agency, the Department of Energy National Nuclear Security Administration, and the NRC. And they're all here to discuss the potential non-proliferation considerations and actions that the US industry can take to prepare for the export of advanced reactors. Each of our speakers will only provide a brief five to ten minute presentation, opening remarks, and then once all our panelists go, we will then give them a chance to react to each other's presentations very shortly. And then we want to save the majority of time for question and answers and a fulsome discussion amongst ourselves and from you with you from the audience. The Q&A portion of the session will be through electronic means for both those here today in attendance and also virtual attendees. So for those of you who are here in the room today, please take a moment to scan the QR code displayed on the screen right here. Where is the QR code? Oh, right here. Thank you. Thank you, Joanne. So you can scan that QR code and that will take you straight to where you can submit not only your questions but also your feedback. We will also, for those of you who are joining virtually, you will find that there is a box at the right of your screen with tabs for electronic Q&As and feedback. And then all the questions that are coming from in person and virtual will all flow into the same queue. And some additional housekeeping real quick. The Wi-Fi code for our attendees today is RIC 2024. And please remember to silence your electronic devices and also just a reminder that all sessions are being video recorded. So just to start us off real quick, I wanted to do a quick introductions of our five panelists here today. The first is Mr. Jim Warden. He is the Director of the Office of Nuclear Energy Safety and Security in the Bureau of International Security and Nonpliferation at the US Department of State. I've had the privilege to serve with Jim on the US delegation that negotiates agreements for civil and nuclear cooperation. He is the lead negotiator. He's also the head of delegation for the US delegation to the nuclear suppliers group. And those are just a few of his accomplishments at the State Department. Next is, and I will introduce them in the order that they will be speaking. Next is Mr. Jeremy Whitlock. Dr. Jeremy Whitlock is a Senior Technical Advisor in the Department of Safeguards at the International Atomic Energy Agency, and he is responsible for safeguards by design. Mr. Whitlock has three decades of experience as a scientist and manager in the Canadian and international nuclear community. And prior to joining the IAEA in 2017, he spent 22 years in Canadian nuclear laboratories as a reactor physicist and manager of nonpliferation R&D. Next is Catherine Holt. Ms. Holt is the Program Director for Analytics and Innovation in the Office of International Nuclear Security at DOE and NSA. She focuses on developing innovative approaches to nuclear security worldwide. Ms. Holt has served in the legislative and executive branches of the US government for the last 20 years, where she has held a variety of program and policy positions in the WMD Threat Reduction Nonpliferation in Arms Control Fields. Ted Jones is a Senior Director for National Security and International Programs at the Nuclear Energy Institute, the nuclear industry's policy organization in Washington, DC. He is an expert on international energy markets and nuclear trade policy. And Mr. Jones leads initiatives related to nuclear energy exports, including nuclear cooperation agreements, nuclear export controls, export finance, export promotion, and related issues. And finally, last but certainly not least is Tim Harris. Mr. Harris is a Senior Program Manager in the NRC's Office of Nuclear Security and Incident Response. He has extensive experience in the protection of special nuclear material, including HALU, an advanced reactor, fuel cycle, research, test reactor, and medical isotope production facilities. And he also participates on the Internet Agency physical protection team that evaluates security standards around the world where US obligated nuclear materials held. Tim, you have some fans in the audience for the whole panel. Thank you very much. Thank you very much. So that brings us to what we'll be discussing today. Our panel of experts will provide potential considerations and actions that the US nuclear industry can take to prepare for the export of advanced reactors. Our panel today will highlight what US exporters of advanced reactors and their associated technologies, materials, equipment, components should consider from a nonproliferation perspective before deploying their technologies, such as safeguards by design and the legal requirements for export that we find in the US Atomic Energy Act. After the panelists conclude their remarks, Jim, Jeremy, Catherine, Ted, and Tim will have the opportunity to react to each other's presentations. And then in order to kickstart what I hope will be a comprehensive discussion on the benefits of taking nonproliferation criteria into consideration when approaching new reactor designs, we will then take questions from the audience. Now I will, it is my pleasure to turn it over to Jim Morden, who will get us started. Good afternoon, everyone. It's an extraordinary pleasure to be with you this afternoon, as well as to be again at this year's RIC. It's a wonderful opportunity to connect with people from all throughout the community, both within the United States and internationally, and so it's a distinct pleasure to be here. I've been asked to kick off today's panel to try to provide a kind of comprehensive, high-level set of principles for kicking off the panel as a whole, so I think mine will be pretty general, pretty quick, and then hopefully you'll get a little more detail from some of the smarter, more technically inclined panelists, but I'm very happy to kick us off. So we're going to start with a brief description of the role of the State Department when it comes to advanced reactor exports. We'll talk very briefly about whether there's a differing role for advanced reactor designs versus Gen 3 Plus and previous designs. I'll get into a little bit of detail about agreements for peaceful nuclear cooperation or 123 agreements in US lexicon. I'll briefly address the Department of State's role in export license policy for DOE Part 810 authorizations, NRC Part 110 licenses, as well as commerce dual-use licenses, and then I'll spend the last few minutes talking about specific State Department considerations from a policy perspective when it comes to advanced reactor exports. So as you might expect, the Department of State is part of the interagency group of agencies, excuse me, that sees all reactor and technology export licenses and applications. And our primary foci when it comes to the review of those authorizations and licenses are national security considerations and foreign policy considerations. We lean heavily on our partners throughout the government at the National Security Council and the intelligence community to try to form a holistic picture from a foreign policy perspective to try to make decisions about whether or not the technology in question would pose a threat, a risk, or actually might benefit foreign policy national security considerations. We look at our export licensing policy through the same prism that we see all of the work that we do in the civil nuclear cooperation space. It really is a broad sweep effort to address security considerations, strategic considerations, political, diplomatic, and then economic and commercial considerations are part of that equation from the State Department's perspective as well. But those are a few, excuse me, a few considerations among many. So I did want to take a moment just to put this up in bold. Our office has the good fortune and privilege of negotiating the agreements for peaceful nuclear cooperation, leading that effort from the State Department's perspective in concert with our interagency partners. And so I've been asked many times over the last decade or so, in order to export an SMR or a micro reactor, do we need a 123 agreement? And the answer is unequivocally, yes, yes, you do. That is not good news for me either because it means a lot more work. I realize it's a lot less efficiency from the industry's perspective. But we have a very clear signal from our lawyers that that is in fact the law of the land. So I did want to put that on screen for everyone to see. So these 123 agreements I suspect many of you are extraordinarily familiar with them. But to hum a few bars briefly for those who may not be, they are required by the Atomic Energy Act of 1954. They are necessary in order to export nuclear material, nuclear equipment. And typically when we talk about equipment, most commonly I should say it refers to a complete reactor unit. But we also reference or excuse me, we also require a 123 in place for the export of significant reactor components as licensed by our colleagues at the NRC. From a nonproliferation commitments angle, I think one of the most salient things to know about the 123 is that a partner government has to make a set of nonproliferation commitments to the United States when it agrees to finalize an agreement of this nature. And many of you will be very familiar. These are commitments related to enrichment, consent from the United States for enrichment, reprocessing, adequate physical security of US material, consent before it can be retransferred. And these are all things that not every major supplier in the United States or excuse me, in the world requires, but they are something that the United States takes very seriously. And the other big nonproliferation principle that I want to highlight here is the fact that when an agreement between the United States and a partner is negotiated, that agreement gets sent by the President to the Congress. And every submission that the President makes includes what we refer to as a nonproliferation assessment statement. And that assessment statement is a pretty comprehensive analysis. The law requires both an unclassified portion as well as a classified portion that gets into extraordinary detail regarding the nature of possible future nuclear cooperation between the United States and the partner country. The purpose is to flag any vulnerabilities or risks or anything that the Congress might be concerned about that the President believes it's necessary to signal or excuse me, necessary to note in order for the Congress to exercise its appropriate review set of responsibilities when it comes to reviewing. So I did want to bring those things to people's attention. What are our responsibilities when it comes to licenses? The Department of State has to by law provide its concurrence to Department of Energy Part 810 authorizations from the Code of Federal Regulations. That process takes place over the course of from as little as a couple months to as long as many months depending on the complexity of the authorization and the willingness of the partner government to provide a peaceful use assurance in a timely manner. Our role as I had noted earlier is to look at things through a national security and a foreign policy perspective. And that is the basis upon which we obtain views from our country desk partners as well as other stakeholders who look at things through a particular regional or thematic lens at the department. When it comes to Nuclear Regulatory Commission Part 110 licenses, the Department of State exercises undertakes a similar exercise, but it does so with the participation of the entire executive branch. It's our responsibility to coordinate views from all relevant departments and agencies throughout the executive branch and then to provide the NRC with the executive branch's view as to whether or not the potential transfer is inimical to the common defense and security of the United States. That's a that's something which so many of our NRC friends here are very familiar with. Lastly, I just want to briefly note that we also have a fully participatory role when it comes to decisions regarding the Department of Commerce's dual use licensing adjudicatory procedures. We are one of several votes in that regard, but we of course play the same role from a subject matter perspective. I'm just going to close with one last brief slide, which is a little more subjective. And that relates to, you know, when it comes to the export of advanced reactor designs, what are we most interested in? And I've already touched upon these considerations a few times, but I wanted you to see them in black and white because this really this set of considerations on the slide are really what we look to day in day out when it comes to what the impact of a particular export will be on the United States. Many of you know that we are in several ways engaged in a grand geostrategic or geopolitical competition with some states which do not have the national security interests of the U.S. in mind. And that weighs heavily on a lot of the decisions that we make, as does the potential that any government might divert technologies or items for non-peaceful purposes, as well as the prospect of a non-state actor utilizing these items in a malicious manner as well. So I just wanted to give you a little more detail on that. Hopefully that's a good scene setter for what you're about to hear from our other experts. And I look forward to any questions that may have at the conclusion of the presentations. Thank you. Next. Hello. Good afternoon. And I guess good morning if there's people online. I'm Jeremy Whitlock from the Department of Safeguards at the IAEA, the International Atomic Energy Agency. It's my pleasure to be here at the RIC to give the IAEA viewpoint on exporting of advanced reactors to the world. And of course, the big viewpoint from our point of view is safeguards. And I'm going to cut to the chase. The safeguards are going to be challenging. And one of the answers that we have come up with that will make it less challenging is to involve the industry developing the technology and helping to come up with cost-effective safeguards. So that's called safeguards by design. And that's what I will talk about in the next few minutes. Okay, so safeguards have been around for 50 plus years and everybody knows about it, but not so much in the nuclear weapon states because we don't apply comprehensive safeguards. So we have expertise, for example, in the US at the policy level, at the national lab level, but not so much in the design community. And that's because you don't have comprehensive safeguards. So you just don't see it implemented around you. And it's not taught widely in nuclear engineering schools. Hopefully that changes. However, there is a need for increased safeguards awareness. The priority we're talking about here is advanced reactors. But I also want to bring to your attention at the back end. We also have a priority today. What keeps us up at night now is applying safeguards to the increased amount of waste management going on. And actually that's something to keep in mind with advanced reactors as well. And many advanced reactor vendors are thinking about that end of things because the small footprint, the small storage of spent fuel means transfers to dry storage, perhaps a lot earlier. So we do see discussions of that. So when we have dry storage containers that have not taken into account international safeguards sealing, for example, we have to do retrofitting. And we do that today. And it's a whole mini industry at the IAEA. And a lot of those containers come from the U.S. and other nuclear weapon states. And so that's why there's no safeguards, because it's not part of the customer base. However, the international customer base does require safeguards. And that's the topic of my presentation. So it's on there to show you that there's the two ends. And they're both important. Actually, that the entire fuel cycle, the entire life cycle, wherever there's a decision design, a design decision, sorry, being made includes safeguards in the calculation. So at the 30,000 foot level, the role of safeguards internationally is not the same as physical protection security. It's to basically the prime actor, in our case, is the government itself and everybody below the government. So right down to the operator of the facility and the people sweeping the floor in the facility, they're all in on a theoretical covert activity to make a nuclear weapon. And so it sounds crazy, but that's what the NPT is saying that we're trying to protect against. But the fact that the state is the prime actor is what makes it really different from security. Because when you are negotiating your safeguards measures with the facility owner, you are in effect talking to the design basis threat. And so it's like you're talking to the inmate in the prison about how you're going to design the lock on the cell. And they're helping you design it. And so that makes safeguards very strange. What also makes it strange is that we are not interested so much at least in the Department of Safeguards with non-state actors and terrorists. That's physical protection from our point of view. We're interested in the state actors. So it's not so much, but it's both the declared material that we're tracking and also the undeclared material. So from a security point of view, everything is declared, for example. And you own it. Okay, so the challenge then. What is the problem? The problem is that we can't, we must apply safeguards when new technology is deployed. We must show up and then apply safeguards. We can't show up and say, oh, a molten salt reactor. Okay, let's sit and talk about how we're going to track this fuel through these pipes or these 240,000 pebbles. That's the wrong time to be talking about it. That is sort of when we talk about safeguards for light-water reactors or can do heavy-water reactors, because we know what we're doing with light-water reactors and can do heavy-water reactors. So you can show up closer to the construction, apply what you've always applied, and it will work like it's always worked. So that's okay. We're not going to stand in the way of deployment of advanced technology. That's fine, as long as vendors know that there's an important customer requirement. And the problem there is many of them are not aware of this customer requirement. Or if they've heard about safeguards, maybe they, well, maybe they've heard of safeguards, but they misunderstand what it means, because maybe they think it means security. So there's the international versus domestic safeguards issue. And also, there's a perception that it's an operational issue, which it is. It's legally an operational issue. It's downstream. I'm designing a reactor. Why should I invest a single cent in solving the problem of the IAEA and the operator? That's, they're going to come and they're going to put blue cameras in the corner of the reactor hull, and they're not my cameras, and they're not the operator's cameras, either, for that matter. So what, so what's the problem? So there's a perception that it doesn't impact design or design can't impact safeguards. And, okay, so the third challenge is that it actually does, that advanced reactors will probably involve advanced safeguards. And when we develop advanced safeguards, it sometimes means advanced equipment. The equipment is not designed and developed by the IAEA. It's developed by the member states. So it's going to be the member state for which the vendor, where they live. And it's going to be probably the vendor themselves. And so that here we have an R&D expectation that many vendors are not aware of. And also there's confusion about proliferation resistance. And if you have higher proliferation resistance, you're going to have less safeguards. Okay, so that's true in some cases. Usually when you talk about proliferation resistance, people are really meaning intrinsic proliferation resistance. The fuel itself is harder to get at and harder to process, for example. That's all very well and good. And that is high proliferation resistance. But how do you independently verify that there's nothing untoward going on, given that the design basis threat is the owner of the facility who has access to the fuel? And so you can actually have more complicated safeguards. And that's an important point. Okay, so we need to be ready to safeguard these things when they come along. Your floating reactors, your fleets of micro-reactors wherever they are, innovative fuel cycles, like the pebble bed reactor in the upper right, transportable cores, remote locations. So that's just a case of how do we get to these locations? And new industrial applications like gas and oil rigs. So I throw up a little map there in the bottom center just to show you where that picture is. That's actually a community in the north of Canada. It is the most northerly continuously occupied spot on the planet. It's a little military base called Alert Canada. Hardly anybody lives there. They burn diesel fuel to keep warm and generate electricity. And they do want to have micro-reactors. And so imagine trying to go there to do inspections. It can't be done. So we need to do something differently. Remote monitoring, unintended equipment, remote monitoring requires high reliability internet. You don't have that in the north of Canada. I speak from experience. It wasn't very good where I lived either. Okay, so I'll go quickly through this slide since we don't have a lot of time. But this is just to show basically what the fundamental problem is. So I made a good case. So why don't we just include safeguards anyway as a matter, of course, in nuclear engineering design? And it's because, well, safeguards starts closer to construction. Legally, that big yellow rectangle on the right is where safeguards start. So it's when you are deciding you're going to build something. And we're not changing that. That's where the legal beginning of safeguards is going to start. And that's why we say it's an operational issue. However, for the reasons that I've been mentioning and we'll get into a little bit more shortly, you can talk about it earlier and include safeguards with all the other good things you talk about in design. Throw it in there. Some people call that 3S, safety, security, and safeguards. And you integrate it, but it's voluntary. So it is voluntary. Thank you. It is voluntary. And that's one of the issues is that it's driven by the vendor so we can only move it forward by raising awareness in the design community. Okay, needless to say there are lots of benefits of safeguards by design. I've mentioned a lot of them, but the main point is that here's another slide with a bunch of them. The main point is that these benefits accrue to the operator themselves. We'll get there. And not just the IAEA. So it's not just that we're saving on sending inspectors. We will save on sending inspectors or not have to send them to the North of Canada. But also the operators are not hosting inspectors. Or there's no delay in the construction because of a need to incorporate safeguards or even develop new safeguards. So then we come to suggestions for the US industry and R&D community. So first of all, raise awareness in everything I've just said. Make it part of the culture of nuclear design. Consider the value of having one design that works anywhere on the planet. So even though you don't need the safeguards in the US for the first build or the second build, maybe the third build, you will need safeguards. Wouldn't it be nice to tell the customer that it's going to look like the same reactor prototype that you've shown them working at Idaho, for example? Consider the possibility that you may encounter international safeguards sooner than you think anyway because the US is under a voluntary offer agreement. It's going to be on the offer. The IA will probably accept it and will come and want to apply some sort of safeguards. Consider the impact of near term or improving things in near term design. So this bullet and the next one are talking about different levels of safeguards. So simple things like mounting cameras on walls. That's something that you don't want to retrofit if you don't have to. But more importantly, if you've got a molten salt reactor or a pebble bed reactor or high temperature reactor for which we do not have a safeguards approach on the books, we may need to talk about that sooner than later. So please, please, please spread that word and spread the guidance that we have that helps spread the word, which is available online. Thank you. Hello. My name is Catherine Holt. It's a pleasure to be here and to join this excellent panel. Again, I am with the US Department of Energy's National Nuclear Security Administration and within the NNSA, I sit within our Defense Nuclear Nonproliferation Cone and the Global Materials Security Program Office of International Nuclear Security. Let's see, I think. Do I advance? OK. Oh, no, you're only at other slides. It's fine. Just keep going. I'm doing a preview here for safeguards. There we go. OK. So again, focused on the security side of the house, complementing the safeguards perspective. And so again, our mission within the Office of International Nuclear Security is preventing the theft of nuclear material in the sabotage of facilities worldwide. We have a long history of working all over the globe, you know, along with our interagency partners in the IEA. So we currently work with over 60 countries internationally and have done all aspects of nuclear security, so physical security, cybersecurity, transport security, insider threat mitigation, both from actually doing upgrades at facilities as well as training and guidance development. So with that kind of background in mind, you know, when it comes to advanced and small modular reactors, we really want to take some of these lessons learned that we've learned over two plus decades, working with international partners, working with the interagency, the DOE national laboratories, and how can we think proactively? How can we think about incorporating security from the beginning, taking a security by design approach? And so again, I just want to emphasize that while I'll be speaking about international nuclear security for advanced reactors or our in-star effort out of NNSA, this is very much done in close collaboration with our colleagues, both the NNSA's arise program, which is focused on safeguards by design, as well as our Department of Energy Office of Nuclear Energy colleagues, both their advanced reactor safeguards program and the impact program. So I wanted to give them a shout out as well for the joint efforts to really think about integrated domestic and international safeguards and security by design. And if I can leave you with one takeaway, it is that think about security now, not later, and it can really be a competitive advantage. So just a little bit more about in-star and our approach. So again, very much in terms of the policy drivers set within the interagency with our state department colleagues, you know, again, we want to make sure that we're thinking about American leadership in nuclear technology and also the nonproliferation and security standards that come with having our technology out there globally. Also enabling peaceful uses. Obviously, there's a lot of focus right now on energy security. And of course, meeting climate change goals. So with that in mind, about three years ago, we stood up a technical line of effort called in-star international nuclear security for advanced reactors. And this is really about, you know, having a relationship with not only the US vendors that are developing advanced and small modular reactors, but also the embarking or expanding countries, the future buyers of these technologies and how we can talk about security. And so we really want to think about how can we improve the security of those future exports intrinsically? How can we support nuclear security regulatory as well as operational infrastructure in these newcomer countries? And how can we sort of advance and help the global regime adapt? And so we do this through a variety of approaches. So in terms of secure exports, we're really doing a lot, which I'll say a little bit about at the end of the presentation, on developing the technical basis behind what is security by design? What does this mean for generally and specifically by major advanced reactor class? And so we're developing a lot of tools and analytical products. And we're also working with the US vendors on security by design technical approaches. And I'll say more about that later. Again, we're also working to, you know, support responsible nuclear newcomers. And so this is working bilaterally, but certainly in close coordination with our colleagues at the State Department and RC and the broader department to think about strong nuclear security frameworks, regulatory infrastructure and human capacity. And again, these are the future buyers of the technology. So we want them to be driving that demand for security from the beginning. And of course, with security, this is the state's responsibility. So while there's no independent external verification regime, each state is responsible for doing this. And we do have a legal basis in the amended convention on the physical protection of nuclear material. And then last but not least, the way we're trying to approach ensuring a strong nuclear security regime is working very closely with the IEEA. There is a host of guidance documents and technical meetings underway to think about how can we either expand upon or develop new technical guidance for countries that are going to that are interested in advanced and small modular reactors. And there's upwards of about 30 or so countries that are interested in exploring this. This also includes close collaboration with a lot of our like-minded or peer partners, particularly within the G7. So this next graphic was developed to try to explain in one slide really what we mean by security by design. So I think we all know there's a host of definitions out there. And it essentially boils down to how can you think about security early, frequently, continuously throughout the design engineering process and really throughout the life cycle of the facility. But if you can design security considerations earlier into the engineering phases, we think it's going to allow for a more cost and risk-informed approach and product. And so what we wanted to do was think about this from the paradigm of a licensing model. And so obviously this is focused on more of a domestic terminology and domestic approach. But typically, as many of you know, security is sort of passed to the operator. It's in the operating license part of the equation. And so we want to think about how could we reverse that? How could we think about when a vendor is seeking their design certification? Is there a way that we can think about security by design earlier in the process as opposed to just later in that COL? So that's really what we're trying to propose here. And I also want to say a little bit about how we're trying to engage with some of the US vendors that are planning to export globally. Again, I will say that this simple approach, basically, the high points of this are that we are supporting the national labs in working directly with vendors that contact us through our nuclear nexus website. You'll see the QR code and the website down there. It has a host of information about how vendors can work with the NNSA, not only on nuclear security, but also international safeguards and export controls as well. And again, we are working through nondisclosure agreements or craters to make sure that we're supporting vendors in dealing with some technical issues and thinking about how to actually do security by design, understanding there's information protection and proprietary information. And in closing, I won't read through all of this, but I just want to highlight a couple, believe it or not. This is six items, but we have upwards of about 25 technical analytical products that, again, are looking at what is the technical basis between behind ASMR security and security by design? How do you analyze this? How do you prove this? And so we have a variety of tools that you can see here. Security economics is really looking at, again, thinking about reducing those operations and maintenance costs. HALU security risks was really a system study looking at are there, in fact, increased risks in addition to the increased physical protection requirements with HALU fuel? And so both of those have information that's available on our Nexus website. And then the last couple are some newer lines of effort that we're working on. So we're looking at, we obviously know the light water reactor fuels and how they respond to insult, to sabotage, but we want to explore the consequences and the implications of this for advanced small modular reactor fuels. So we're doing a multi-year test and evaluation project on that through the labs. ASMR class risks and mitigations. This is looking by the major advanced and small modular reactor classes and very generically stating what some of the security risks could be and potential opportunities. This is something that a lot of our foreign partners ask us for. And again, we're trying to put this out at a high level generally. And we're also undertaking a testing and evaluation project this year, looking at passive safety systems and the implications for security. And last but not least, we have a security and safeguards by design course for industry that we host at the National Labs the next one will be July at Oak Ridge National Laboratory. So that's just a summary of some highlights of our work. And again, the Nuclear Nexus website is here if you would like any more information. Thank you. Hi, good afternoon. I'm Ted Jones with the Nuclear Energy Institute. And I'm going to share today a commercial perspective on the applications that the new reactor technologies are enabling and how this is changing the global market and some implications for nuclear nonproliferation and other U.S. national interests that we see from Nuclear Energy Institute. The smaller reactors that are coming to the market are across a wide range of sizes and we are seeing a great deal of interest in the different kinds of applications that they have, not just producing electricity, but hydrogen process heat for industry to serve a multitude of uses. The one thing that they, I think, all have in common is that they're simpler. They're simpler to license, simpler to build, simpler to operate, ultimately simpler to decommission. And this is, didn't mean to go forward there, this is creating a great deal of new interest in these technologies. I would say that even before these technologies came to the market, we have seen a great deal of increasing interest in nuclear, driven by energy security goals, climate security goals, but the simplicity and range of uses is attracting a much, much greater interest worldwide. This is a slide showing some of the advanced reactors, sorry, developers who are members of Nuclear Energy Institute. There's a huge amount of innovation taking place in this space. I'm not going to go into detail on this slide, but just to illustrate that these technologies are, you know, spanning, you know, not just the size, but, you know, different temperature outputs and with different kinds of technologies. This map depicts the nuclear operating countries today, and actually, this is not the colors I expected, it's the white countries, not colored gray, that operate nuclear power. But when you look at the future, you have these additional countries in dark gray that are considering nuclear energy for the first time. And it's these where I think that some implications for nuclear nonproliferation and other U.S. national interests are most relevant. These, you know, in the global market, I think everybody knows the United States has long since ceded the commercial leadership to Russia, and that China is a fast-rising competitor. We do not control the exports from those countries, and it's, I think, quite worrisome that so many countries, especially in strategic areas of the world, are looking to suppliers that don't match the standards that my fellow panelists have outlined the United States applies for nuclear commerce, U.S. nuclear exports. Many of these countries are not deterred by Russia's invasion of Ukraine or geopolitical concern tensions with China. They've, you know, many of them already have extensive relationships. Many of them are comfortable with the state monopoly supplier model that they offer, and it's quite a challenge because they also have some tools that U.S. exports don't have. This map, again, pardon for the color shift here, shows, and I think I lost the Russia color. We have tried to highlight here, and I think it's in blue, maybe. Anyway, a lot of countries have been engaging in nuclear cooperation with Russia and China in recent years, many with both countries. And whether these countries strengthen their security with nuclear energy depends a great deal on who that supplier is. There's a great deal of leverage gained in being a nuclear supplier. You know, Russia's energy influence across Europe in nuclear fuel is dwarfed by its influence of supply of natural gas. It's, you know, these are proprietary fuel assemblies, proprietary components that have to be reverse engineered and licensed, and it's really difficult to replace. So when we meet with foreign governments, we we try to underline that nuclear can significantly advance their their energy security goals, but not necessarily if they're choosing the wrong supplier. We think it also strengthens bilateral ties. I think that's what we've heard from some of the other panelists here, that it's a great partnership between countries as well as industries that ensues from from nuclear cooperation. And it lasts a very, very long time when when we take trade missions to places like, you know, Mexico or Slovenia that deployed a U.S. reactor many years ago. We still see the regulator, you know, looking at what the NRC is doing and following it very closely. We see the you know, the industry still, you know, in most cases, relying on fuel supplied by the original vendor. There's often U.S. industry people there on the ground. And I think that's a really good thing for our standards for nuclear nonproliferation and safety. And and and and security. We we do have higher standards, I believe, than most supplier nations and certainly higher than Russia and China. U.S. Consent Rights and other unique requirements can extend U.S. influence for many decades after a reactor is built and in industry, we want to do our part to to help extend that influence to all the nations that are considering nuclear energy for the first time. So with that, I'll leave my contact info on this last slide and pass to the next panelist. Thanks. I don't know whether I like being last, Lauren. Did I have a choice? No. So my name is Tim Harris. I work in the Office of Nuclear Security and Incident Response and we support the Office of International Programs and Pete's. We introduce Pete, Lawrence Boss, staff in conducting export licensing reviews. So I'd like to start with some key messages. First, the export of advanced reactors presents new proliferation considerations. And second, as countries plan to export nuclear material from the U.S. to support their advanced reactor program, the timing of the export license process needs to be considered in project planning. And I'll discuss these a little bit more in some of the next couple of slides. So rather than focusing on advanced reactor technology and components, my presentation is going to focus on exporting nuclear material. So that's either the material itself that would be used as feedstock at a fuel facility or as finished fuel that contains the nuclear material. So briefly, I'll discuss the spectrum of advanced reactor types and the associated fuel types for context with respect to exporting nuclear material and proliferation considerations. So there's not gonna be a test after the presentation so you don't have to study this too far. I recognize it's a bit of an eye chart and I don't intend to discuss this in detail at all. Really the purpose of the slide is to illustrate the breadth of advanced reactors that's non-lightwater reactor vendors, pre-applicants and applicants that the NRC is currently aware of and the different technologies being used or proposed. These groups are focused into four broad technologies, liquid metal cooled fast reactors, high temperature gas cooled reactors, molten salt reactors and micro reactors. So this probably isn't as pretty as Ted's slide on different advanced reactor types but this presents generalized schematics of the four different reactor types I just mentioned. Most advanced reactors are proposing to use high assay, low enriched uranium or HALU fuel which approaches high enriched uranium enrichments. This HALU could be in the form of oxide pellets, triso or even metal. Some of the advanced reactor types are also proposing fast spectrum designs which could utilize plutonium or transuranic as fuel. And some designs fuel is mixed into the salt coolant or so in that case the salt acts as both the fuel and the coolant. The bottom line here is that these fuels are drastically different than ubiquitous 5% enriched LAU fuel that's currently used. So most research and test reactors around the world have been converted from HALU, sorry, had been converted to HALU from high enriched uranium and this has certainly reduced the global proliferation risk. So looking at proliferation risk, the global risk would increase slightly with the increased use of HALU fuel, right? There'll be more out there not to say that HALU fuel is necessarily a high proliferation concern. However, proliferation risk of exporting plutonium or other transuranic space fuel would need to be more closely considered. So I guess I wouldn't be a proper regulator if we didn't talk about regulatory basis. So I think as Jim mentioned, our statutory basis for proliferation reviews comes from the Atomic Energy Act and the Nuclear Non-Proliferation Act of 1978. Both these require the US government to ensure that US obligated nuclear material at foreign sites has adequate physical protection equivalent to the required by applicable regulations. This is defined in NRC's 10 CFR Part 110 Air Export Regulations as provisions set forth in the Atomic Energy Agency document nuclear security recommendations on physical protection of nuclear material and nuclear facilities are commonly referred to as Infrasurc 225. These provisions are also documented in individual country, 123 agreements as Jim mentioned. So NRC regulations in Part 110 list criteria that must be met before an export application can be approved to ensure that US obligated material is not proliferated. These include assurances of IAEA safeguards, that IAEA safeguards is applied and assurances from the country that the equipment or material will not be used for a nuclear explosive device or will not be retransferred without prior consent. The export applications review is a whole of NRC review, which includes the Office of Nuclear Materials Safety and Safeguards as well as INSER and other parts of the NRC. The NRC's Office of International Programs also consults with the executive branch, principally the Department of Energy and Department of State to obtain country assurances and to take input that the export would not be a mimical to the common defense and security. I guess in short, we have to look at a lot of things to make sure that it's okay to export the material. Sorry. So in order to provide to approve an export license, the commission considers in part the physical protection of U.S. obligated material and the threat environment of the country. Physical protection is determined by assessment visits by an interagency team which include NRC, Department of Energy, Department of State, DITRA, and is supported currently by Sandia National Labs. The U.S. visits countries that request exports category one and category two quantities of material prior to approving an export license and periodically thereafter. The visits focus on the country's physical protection framework as well as the physical protection measures at individual sites. The sites are visited to assess whether or not they meet the intent of Infrasurc 225. So it's a generalized assessment that you meet the intent, not that you may, you may do, if there's a requirement for acts, you may not do acts, but you may do something very similar to acts. So we take that into consideration. Coordination of these visits can't take several months and therefore countries planning to export U.S. materials should consider that in their project planning. In specific cases, the commission itself determines if an export application should be approved and the process to gain commission approval requires additional time to process the export application. This would include countries where the U.S. has not previously or recently exported nuclear material. And I think that concludes my presentation, but the key points are that if you're planning to export U.S. material, consider the export application process in your timing because it does take a little bit of time. Thank you so much, Tim. We saved the best for last. I'm not partial, even though we're in the same agency. Fantastic. Thank you all for your excellent presentations. I thought now what we could do to kickstart our conversation today and what I hope is a conversation and not so much question and answer is just to have our panelists reflect on what the other panelists said. I myself have so many questions floating around in my head and I just had some initial reactions, impressions, and perhaps to get your reactions kickstarted, for example. What I heard a lot of is this lack of awareness. I heard that in Catherine's presentation. I heard it in Jeremy's presentation. So I'm wondering, or Ted, Catherine, Jeremy, when you're going out and doing outreach on behalf of your agencies, what are you hearing from the U.S. industry in terms of their understanding and awareness of their export control obligations? That's the initial thought that we could get this kickstarted with. Jim, Ted's maps were very comprehensive, showing where the advanced reactor developers in the embarking countries are intersecting. How does that reflect with the prioritization of 123 agreements that the administration is now working on? Do they match up? Do they not match up, perhaps? Tim, Jeremy, Jeremy slide on what needs to be safeguarded. I thought that was really interesting. I liked the pictorial representation that responds to visual learning. But I thought that could also apply to physical protection. How are we going to physically protect a floating reactor or a reactor in the deep Arctic? So I thought, perhaps, Tim, if you wanted to reflect on how that might, the NRC is thinking about creating regulations or procedures for our physical protection visits, are you prepared to go to the Arctic to assess a small modular reactor, for example. So whoever would like to get kickstarted, those are just some of my initial reactions. Anyone like to go first? Can I go first? Yes, please. So if there's a... Sit on. Can you hear me? Maybe. So if there's a visit to the Arctic, I won't be going personally, but maybe Nancy would volunteer to go. But in any event, the NRC would have to make a visit to determine that it's appropriate to send US obligated material to that location. Thank you. Okay, sorry. You were asking about what experience do we have in raising awareness and what's the feedback that I get when I'm bringing this message to the design community. So I'm looking through these flowers at some people. So I think universally, to a person, to an engineer, the response has been positive when I say what I've presented here today. I really am presenting something that a lot of design engineers have heard very little about, but when they learn about it, they go, oh my God, this is actually an important part of the final design of this machine that I'm working on. So thank you for bringing it to my attention. How can I learn more about this? And especially when you factor in the fact that it's just good design engineering to know what your customer requirements are going to be. And also the idea that it's probably good to have, oh, thank you, but they're pretty. It's good to have one design that fits all. I know you're not gonna have one design that fits all, but to minimize the changes that you go from country to country. And with safeguards, international safeguards, there's really not a lot of changes. There's the safeguards you have in weapons countries and the safeguards you have in non-weapons countries. And there's minor wrinkles in that, but generally comprehensive safeguards are comprehensive safeguards. And so we have had vendors come and say, I would like, you know, I'm in the UK or I'm in the US, but I would like to be able to show prospective customers in Indonesia or Ghana or wherever this prototype and say that's the machine that's gonna operate and see those brackets on the wall. That's where the blue cameras are gonna go. They're not there now, but they will, that's where they're gonna go. And that conduit that goes through the concrete wall to that little room on the other side, that's gonna be the agency room where they have their server running. And it's actually part of the design, not retrofitted. I think from a security perspective, some of the conversations with vendors as well as some of the newcomers or within the IEA, everything has to have a regulatory basis, of course. And so everything needs to be derived from what are those security requirements at a national level. And I think what a lot of countries are wrestling with is how do we adapt those? And of course our licensing process as well, as we're faced with at home for advanced and small modular reactors, but also how do we update our design basis threat? How do we think about that in today's environment? Obviously in light of international events with what's happening at Zaporizhia in Ukraine, or even just looking at the aftermath of October 7th and just thinking about what are those implications for security? And with advanced and small modular reactors, again, we've talked about remote autonomous operations, what this means particularly from a cybersecurity perspective with all the digital controls that will be incorporated. So how countries are thinking about that in their DBT and again, updating their regulatory requirements is critical. And I think again, what we're trying to do is sort of cultivate that customer demand for security, but not make it to the point where it would be overly burdensome or put anyone at a competitive disadvantage. But again, we're really trying to kind of make that business case for security and security by design. Thank you. Ted? Yeah, and I'll just add my answer to the question about how U.S. trade controls and trade support align with global market demand. Was that the question? It's difficult for the U.S. trade control regime to scale up geometrically like the market demand has. I think the people at this table and in the room are doing a fantastic job to do that. I mean, getting a section 123 agreement included with the Philippines and really short order, I think is a great example of what is working and what needs to continue working better. In the meantime, I think it's really keeping U.S. companies in the game that there's really competent trade support across the U.S. agencies that are essential for U.S. companies to compete. The Department of Energy has been very actively involved in nuclear energy diplomacy and State Department of course is essential here, but also NRC's Office of International Programs and regulators around the world are looking to the NRC to help them move up a steep curve and we have to continue improving in that way. It's what we, we can meet our challenges if we keep going on that path. Thank you, Ted. Thank you for the shout out for the Office of International Programs. Jim, did you like to reflect on some of the? Sure, and I'll be responsive to your question and maybe Ted, if you wanna offer perspective where I may have strayed, the compare and contrast might be interesting to the audience. I would argue looking at Ted's maps that there is an enormous amount of overlap between the way that the NEI sees markets for advanced technologies and the prioritization that the U.S. government has been undertaking and will continue to undertake. The distinction for the sake of stirring the pot here I think lies in the fact that obviously NEI sees future markets primarily from the perspective of what's going to benefit U.S. companies and from an economic and commercial perspective. As my presentation had noted, the Department of State anyway, and I can only speak on behalf of the Department of State, I can't speak in this case in this setting on behalf of all of the departments and agencies that comprise decisions that come out of the U.S. government. But from the perspective of the State Department, we see nuclear cooperation as a tool that advances additional goals. I had mentioned in my presentation the strategic competitiveness that civil nuclear cooperation is now one tool in the toolbox for when it comes to the United States and its allies' activities vis-a-vis states that have a less democratic perspective geopolitically. And we feel as though civil nuclear cooperation is one means by which we can advance our relationships, deepen our relationships with partners all over the world, whether that's sub-Saharan Africa or Southeast Asia or Latin America to maximize the likelihood that not just U.S. economic influence is exerted and U.S. commercial relationships are deepened, but that the political and diplomatic relationships with those governments are strengthened, which allows for the United States to more broadly have both deeper relationships and influence worldwide. And the reality is that sometimes those two phenomena don't entirely overlap with one another. And so you may see some difference because of that, but I think at the end of the day there is an enormous amount of homogeneity or harmony between the way the government sees future markets and where industry sees future markets. Thank you so much for that perspective and that kind of perspective where we have to balance as we embark on civil nuclear cooperation, the different priorities of the government. And that had me thinking about the priorities of the Nuclear Regulatory Commission as the stewards of the export licensing program for the U.S. government for the export of advanced reactors. And I just have to, we try to say that we are policy neutral in our approach to export licensing, but inevitably foreign policy does impact the way we license exports out of the United States, even though we try to be technology neutral and we try to be regulatory predictable. Sometimes, and especially in the past few years with what's happening around the world, the NRC has had to issue different orders to reflect decisions made by the administration pertaining to exports to certain countries. So I'm just wondering for the panel, do you see any foreign policy issues that are, I mean this might be an obvious question that will immediately, could immediately impact the upcoming, any exports of advanced reactors coming forward? You wanna get it started as the representative of the State Department? I think everyone has important role in that dialogue, but from the Department of State's perspective, the answer is of course yes, and I've been alluding to it, we see particularly in light of the Russian invasion of mainland Ukraine, we see this as a vital time in kind of the arc of nuclear cooperation's journey to do everything we can to persuade nuclear partners worldwide, both existing and future, that the responsible path forward is to work with the United States as a supplier and its allies. We no longer believe that Russia is a responsible player in the global nuclear market, and it's as a consequence of that, that we've been working so hard with our allies and partners in our bilateral relationships in the group of seven, and in a lot of the other multinational and multilateral settings that you see in order to drive the agenda forward in a way which we think will advance both our strategic objectives as well as our economic objectives for decades to come. So I think to try to be responsive to your question, Lauren, those are really gonna kind of be the rules of the road for the next decade at a minimum. From the State Department's perspective, we would hope longer, but the reality is that because we have such a complex and unstable environment right now, these are challenges that we're going to have to navigate together. Government and industry are gonna have to navigate these challenges together, but from the State Department's perspective, we are working really hard, not just with our US government partners, but with our partners within industry here in the US, as well as with global partners, both government and industry, to try to establish a landscape going forward that minimizes these complexities, minimizes these challenges, but puts us on a better, more predictable path for the next several decades. I would just add from the security perspective, just again, thinking about the evolving threat environment and how we can try to help partners think about getting ahead of this and being prepared. So again, I think this just goes back to thinking about security early and building partner capacity to make sure that they have the legal and regulatory basis in place to detect and respond to a security event, that they have those partnerships and relationships in place both within their country, within their interagency, with the law enforcement, the national entities, with the sites, with the regulators helping support them so that they're prepared for some type of incident, and also have those international outreach and relationships as well. So again, kind of building that partner capacity on the ground as well. Sorry, Lauren, I know I'm inside the tent and it was really an outside the tent question, but... No. So I think what we're seeing too from exporting nuclear material is that we're being engaged by other countries that either hadn't exported from the US in a while, or countries that have never exported nuclear material from the US, and they're interested in discussions with the US to see how does that happen. So we're starting to see more countries, I'll say in the pipeline, I don't know if that's the right words, but yeah, we're starting to engage with more countries, I guess is the bottom line. I think out of everyone up here on this panel, the IAEA is perhaps most, has been most impacted by the events of Ukraine, an unprecedented situation where an international organization has boots on the ground in a war zone in order to ensure the safety and security of an operating, well, not technically operating right now, nuclear reactor. So do you have a perspective from IAEA on how events of the world can impact a nuclear watchdog? Yeah, and it's very personal too. Working in Vienna, you actually are, you're literally 500 kilometers from that particular border, and you have colleagues and friends that are traveling on a weekly basis, going to not just that Parisia, but all of the facilities. And that's just one of the interesting aspects of Ukraine from a safeguards point of view. The other aspect is the one that's been around since the late 80s, which is Chernobyl. So we're going to a country under war to do safeguards at a reactor that's had a massive accident. So there's interesting things going on there. I would say from the international safeguards point of view, now it's not the IAEA's role to be judging things like intent of nations, but I would say from a broad non-proliferation viewpoint, sadly, I personally see us moving into an area now of international relations where it's becoming more and more attractive to consider nuclear deterrence, to a level that we haven't seen for several decades, for several of the reasons that have been discussed at this conference and in this panel already. And so on the horizon, people might be, country states might be questioning the future value of certain international umbrellas that have been in place for a long time, and then I don't know at what level. And of course, this is me speaking at the IAEA, but at some level thinking it would be good to have a nuclear deterrent because it's suddenly becoming a realistic possibility that the umbrella that's been in place for decades is not gonna be there. So then that's at the broad level, that at the worker B level at the agency, you have that in mind when you are looking at advanced reactors to bring it back to the topic of the panel here that you have, so everything I was talking about before with cameras on the walls and penetrations through concrete walls and everything, that's sort of the bread and butter type of safeguards by design has been around for a long time. And that's really more sort of an effectiveness issue or cost effectiveness, because you're gonna put the cameras up anyway, so why not plan to put the brackets on the walls so you're not retrofitting? Okay, so that's just a cost issue. But there's actually a effectiveness, not just efficiency, but there's effectiveness. And so some of these more advanced designs, you're actually putting in the hands of a lot of countries elements of the fuel cycle that are pretty difficult to apply safeguards to. And we haven't had to apply safeguards to them to date, because where you've seen things like that in the fuel cycle, they've been in nuclear weapons countries and so not under comprehensive safeguards. Now there's a possibility to have pyro processing for example, or just a molten salt reactor with or without pyro processing where you can't see the fuel. I'm not saying that those countries that are interested in those technologies are interested in nuclear weapons, I'm just saying that other countries are watching. And if there's a certain element of effectiveness that's decreased, because the only way we have of covering the, I mean diversion is more or less easy to tell that the cleared stuff is not gone outside the gate, but misuse is extremely difficult because you're trying to verify a negative in that case. And when the negative you're trying to verify is inside of a pipe, inside of a concrete room and nobody has seen it since it came across the border on the back of a truck and it's been running for 15 years, it's very difficult to verify that misuse other than having just a sort of dotted line around the whole thing and just watching that everything looks kind of warm and fuzzy and nothing has moved. You still don't know what's going on in the inside. And again, nothing against the countries that are interested in those technologies now, but if you're a country that might be thinking of going down the road that I was talking about earlier, you might be looking at technology, like what technology can I acquire that the IAA doesn't really have good eyes on at least what's inside the concrete walls and how can that be exploited? And at the IAA we're very good at training a lot of people up to speed on what exactly we know how to do and what we don't know how to do and then sending them back out into the world after seven years or so. It's, but I digress. Thank you, Jerry. Okay, we'll switch things up a little bit and kind of turn from more policy focus questions to a little bit more of a technical question. This one is for Ted. Little known facts that a lot of vendors don't know is that you do not need to have your design certified in order to attain an export license from the NRC. So I'm wondering, have you heard from any vendors who are planning to export without first before coming into the NRC for design certification? And this sort of lends into another question we've received about 10 CFR part eight 10, which is the US regulations to export technology, intangible technology out of the United States. And so one of our question is asking how the Department of State and DOE can work together to make that authorization process run more smoothly. So Ted, if you wanna get us kick started. Sure, the only reactor I'm aware of that's looking to license first outside the United States is the Giotachi BWRX 300 in Canada with OPG is the customer there. There may be others. I'm just not thinking of them right now. And on the part eight 10 section 123 agreement question, that is definitely a potential conundrum that we could find ourselves in. We have 123s covering, we have like some two dozen covering around 50 countries or so, give or take a few. And there's so many more countries looking to develop nuclear energy for the first time. And that puts a whole lot on the State Department to conclude 123s and a really short span potentially for us to be competitive. Now, some would say you can always get a part eight 10 authorization, a specific authorization without a 123 agreement in place. And that's true, but it typically takes a long time to do it that route versus general authorization when you have a 123 agreement in place. So to stay commercially competitive, we need to be able to have meaningful commercial discussions early that are governed by, they're regulated by 10 CFR part eight 10. And we would like to get to general authorization faster. So I don't know if there's some ways that we could creatively do that. But in the meantime, we're hoping to just keep the part eight 10 process on its recent path of continued improvement so that it's very efficient. And I hope Jim and his office can implement these 123s which is really the best option because that's a long-term assurance to the customer that they're going to be able to have a clear trade control path to US cooperation for the decades-long duration of a 123. Thanks Ted. So we absolutely have recently made and will continue to make the negotiation of additional 123 agreements a priority. We do recognize the clear demand signal from our US industry partners in that regard and want to be as responsive as we possibly can. When it comes to efficiencies in the eight 10 process, we recognize there is also an increasing demand in that area. I appreciate Ted noting that we have made a lot of improvement in the last few years in terms of the timeliness of processing those authorizations. With the likelihood of a larger number of those forthcoming, in addition to having as many 123s in place as we can, within the existing human resource limitations that we have, we are willing to be as thoughtful as we can to collaborate as much with industry as we can in order to make the process as smooth and efficient as possible. We spent a lot of time studying this phenomenon and the one thing we found that takes the longest period of time is to obtain peaceful use assurances from the partner country. And we've tried a number of different techniques over the course of the last few years to make the obtaining of those assurances as quick and efficient as it can be. And we've had mixed success. So I guess the one thing I would say to my friends in industry is when you are working with partners in other governments, or excuse me, companies in other countries, please urge them to be timely in their work with the recipient government to stress the importance of providing peaceful use as assurances as quickly as possible. Oftentimes, that step takes many, many months before we're able to actual, that is the proverbial long pole in the tent, if you will, the US government itself undertakes all of the necessary activities that it must, but it's not able to actually move on an 810 or 110 until those foreign government assurances are received. Thank you, Jim. I think we have time for about two more questions if we have a little brief in our answers, Tim. I think one of the, for me at least, the cornerstone of our export licensing program reflecting our non-proliferation goals, our exports and how we assess exports are based entirely on non-proliferation criteria coming out of the Atomic Energy Act. And I think what you raised in the last slide of your presentation about the physical protection visits, those to me are the cornerstone of NRC's export licensing program and non-proliferation. And this is how we actually go out and verify that the non-proliferation bona fides of our trading partners. And so my question to you is, as someone, I was waiting. Someone who regularly does these visits is what happens if you go to a country and they do not meet the standard that we use to assess them by, which is in Cirque 225? What happens then? Boy, this is a graduate school question here. I guess the answer is it depends, right? So in any assessment, the generalized conclusion is whether the country meets or doesn't meet the intent of 225. In some cases, there may be, I'll just throw out some examples and Nancy will correct me if I'm wrong, which happens often. So let's just say it's very simple as, there was a door that we identified that maybe was a more direct access into a storage area that wasn't alarmed. We might say, hey, you should probably alarm that door. We offer some suggestions where a country could enhance their things. If they definitely don't meet 225, which is rare, I think we would probably negotiate with them steps to meet the intent and come back and do a subsequent vision to verify that they, in fact, do have enhanced things to meet 225. Thank you. And yeah, and just as a reminder, the NRC is not able to issue that export license until we can verify that compensatory measures or upgrades have been made. So that kind of shows you the confluence there. One last question on this, what has been a really fascinating panel for me personally, for Catherine. Are the in-star security technical analysis and tools publicly available for the community to use or does a contract or agreement with NNSA need to be in place before they have access to them? Thank you. You only have about one minute. A mix. Some are posted on our Nexus website. Some are getting posted on our Nexus website and some are at other levels, but we're really making an effort to make sure that they're available and accessible to the community. Thank you so much. And I think with that, that will be the last question that we asked today. Apologies for everyone. We had a myriad of questions that came in and sorry if we didn't get to your question, but our panelists will be available outside the doors of this room right after this. If you wanna try to approach one of them to ask a follow-up question or to get your question answered that we were unable to get to. Also, as we close the session, you are invited to scan again the QR code and provide us with your feedback on the session. Your insights will be invaluable on how we organize future sessions at the RIC. So thank you all for coming and thank you to Jim, Jeremy, Catherine, Ted and Tim for a fascinating panel today. Really appreciate it. Thank you.