 Good afternoon. Welcome to session Wednesday 11 of 2023 Nuclear Regulatory Information Conference. I'm Commissioner Annie Caputo. And I will be chairing this afternoon's timely session focused on how risk is being used to inform current and future licensing of advanced reactor technologies. There is a significant amount of interest, especially judging from how many of you are here. Significant amount of interest surrounding the topic of advanced reactors right now and the NRC's ability to safely and effectively license these technologies will be a key factor in determining whether any of these technologies are ultimately deployed. Today we're going to hear from stakeholders both internal and external to the NRC to gain their perspectives on several issues related to advanced reactor licensing including ongoing licensing activities and related policy initiatives such as the development of 10 CFR part 53 which was recently released. Next slide please. Next slide please. Today's session will include three live polling questions that will be posed throughout the session. I will post the results at various points in the session as well. At the end of the panel at the end of panelist presentations we'll have a question and answer session where we will respond to questions that are submitted throughout the session. For the question and answer session I will read aloud the questions that get submitted and will try to bundle questions that may be similar. You can direct questions at a specific panelist or at the entire panel. As many of you know this year's Rick is the first ever hybrid Rick so I'd like to take an opportunity to talk through the logistics of how to engage in the session whether you are attending in person or virtually. For those participating in the session virtually your session dashboard includes options for submitting answers to today's live polling questions and submitting questions for the Q&A session and for providing feedback on today's session. For those who are attending here in person today you'll need to scan the QR code. There we go. That will be presented on this slide so that you can log into the session dashboard. Some of you may have already scanned the QR codes as you enter the room today. Once you scan the session QR code and log into the session you will be able to submit questions for the Q&A session and also provide feedback on today's discussion. In-person attendees can also participate in live polling questions using the text messaging feature on your phone. When I present each question the slide will contain specific instructions for how in-person attendees can respond to each question. On those slides you will see each answer to a question has a code that can be sent to 2233 to 2333 to record your response. This session has the highest number of registered attendees of any session at the RIC over 1200 in fact. So we are expecting a lot of engagement during the live polling and the Q&A session. We're going to try to get as many questions in as possible during Q&A but it's possible and we may not get to all of them before the end of the session. Next slide please. I would like to introduce the panelists for today's session. Speaking first will be Rob Taylor, Deputy Office Director for New Reactors in the NRC's Office of Nuclear Reactor Regulation. Rob will be followed by Steven Burns, Senior Visiting Fellow at Third Way and our former NRC Chairman. Speaking third will be Jennifer Yule, Vice President of Generation and Suppliers at the Nuclear Energy Institute. Fourth speaker is George Wilson, Vice President of Regulatory Affairs at Terrapower and another NRC alumni. Rounding out our distinguished panel is Dr. Adam Stein, Director of Nuclear Energy Innovation at the Breakthrough Institute. Thanks to all of our panels for taking time out of your busy schedules to join us here today and thank you to all the attendees for tuning into the session. Next slide please. I think we're supposed to have our first live polling question. Alright so our first live polling question, how satisfied are you with the NRC response to stakeholder suggestions on part 53? So text the code to 22333 or follow the QR code. And with that I will turn over the microphone to Rob Taylor. Thank you Commissioner and good afternoon. I appreciate the opportunity to talk about NRC's experience with risk-informed licensing for advanced reactors and our ongoing activities to develop the related regulatory infrastructure. The NRC staff recognizes that more and more the federal government, states, industry and the public see nuclear power as playing an important role in combating climate change and decarbonizing our energy supply. We know that we are a pivotal element in helping the country achieve its goals. While our mission is public health and safety, we recognize that achieving our mission in a risk-informed, safety-focused, timely and cost-effective manner is critical. We acknowledge that some are skeptical of our ability to deliver based on the duration and cost of past reviews. We accept the skepticism and it is a driver for why we're working so hard to transform ourselves. Ultimately we are committed to conducting sound safety reviews that make the safe use of nuclear technology possible. Today I'm not just going to talk about PRA and how to make safety decisions. I'm going to talk more broadly about how we apply risk-informed decision-making throughout our regulatory programs to deliver on our principles of efficiency, clarity and reliability. Next slide please. The NRC is ready and in some cases has already begun to license advanced reactors on expedited schedules using risk-informed principles to manage reviews. Our success is the result of the substantial progress we have made in preparing to license new and advanced reactors. However, our journey continues as we push forward to apply lessons learned and improve our regulations, guidance and processes in accordance with our principles of good regulation. Advanced reactor designers are proposing a range of technologies at varying stages of readiness to submit applications. Under part 50 the Kairos Power Hermes Construction Permit application is progressing on budget and meeting milestones associated with the aggressive 21 month review schedule. The staff recently completed the advanced safety evaluation report with no open items. Our success is due to the risk-informed approach we have taken, the exemplary pre-application engagement with Kairos and the highly effective communications with Kairos during review. In addition, the staff has completed its review of the shine medical technologies operating license application on budget and schedule with the recent issuance of the final safety evaluation report and environmental impact statement. For part 52 the staff completed the APR 1400 pressurized water reactor and new scale small modular reactor design certifications on schedule. We recently completed a significant milestone with the issuance of the 10 CFR 52.103G finding for Vogel unit 3 that authorized fuel load in the first reactor built under part 52. Throughout Vogel construction the staff worked to ensure the NRC was not a barrier to timely construction and enjoyed a strong working relationship with Southern Nuclear Company. We've also made substantial progress in developing 10 CFR part 53, a risk-informed performance-based and technology inclusive regulatory framework for advanced reactors. Last month the NRC staff provided the draft proposed rule and associated key guidance to the Commission for consideration. While the final part 53 may only be available after the early licensing of some designs, the staff's work to develop the risk-informed requirements is paving the way for thinking differently about early movers. For example, some advanced reactor developers are leveraging the risk-informed methodologies being considered in part 53. To provide additional certainty for future submittals, 15 vendors are engaging us in pre-application activities such as the reviews of topical reports and white papers. Over the last two years the NRC has completed 63 pre-application reviews and executed these approximately 90% of the time on schedule and within budgets. This early engagement and timely resolution of issues will facilitate more efficient reviews of future licenses and permits. Next slide please. We're building on previous accomplishments and applying lessons learned to our advanced reactor licensing reviews. For example, last year we issued the new skill lessons learned report which describes how the staff and applicants can apply lessons from our earlier experience to enhance current and upcoming reviews. In addition, the staff is conducting a Vogel lessons learned assessment to capture any insight for future licensing and construction. Lastly, the staff will continue to identify and institutionalize best practices as we gain more experience with the ongoing reviews. Next slide please. Part 53 is part of a tapestry of innovative advanced reactor activities including proposed updates to other regulations. For example, the staff provided the commission for its consideration, the advanced nuclear reactor generic environmental impact statement, and the rule makings for alignment of the licensing processes and lessons learned from new reactor licensing, for emergency preparedness for small modular reactors and other new technologies, and for alternative physical security requirements for advanced reactors. These activities encompass considerable innovations for advanced reactors. We recognize that updating our guidance can also be crucial in ensuring clear and reliable safety reviews. Accordingly, we've invested significantly in the enhancements to our guidance to provide applicants clearer and more efficient approaches to satisfying NRC regulations. We've also made substantial improvements to our regulatory processes. Ten years ago, requests for additional information or REIs were the default on how we obtained information, and this led to many requests per review. We have since overhauled how we prepare and issue REIs to ensure they include a clear regulatory basis, explain the safety significance, and what information is needed to make a safety finding. We're also supplementing REIs with other regulatory tools such as audits and pre-application engagement. We expanded and enhanced our use of audits, streamlined how we prepare our safety and environmental reports, and developed an enhanced process to track and elevate issues early in reviews. For example, for our review of the new scale standard design application, we audited the PRA early and are building those insights into a holistic risk-informed review. We also changed how we organize and prepare ourselves by implementing core or interdisciplinary review teams and streamlining the phases of our reviews. Lastly, we're leveraging data for performance monitoring and accountability and developing new ways to track and monitor review progress. Through data, we're better allocating resources to the most safety-significant portions of reviews and providing more granularity in how we are performing so we can adapt quickly to resolve challenging issues. For example, the CHIRIS review is the first application with a public-facing dashboard for the applicant and public to track the review. We've developed and published similar dashboards for the Appliant Christian University review, and we'll soon put one out for the new scale review. Next slide, please. As I mentioned, near-term and mass reactor designers are submitting applications under 10 CFR Part 50 and 52. Regulations designed for large light-water reactors that may contain requirements that are inappropriate for non-light-water reactor designs. The proposed Part 50-52 rulemaking can help address this challenge. For example, in addition to aligning Parts 50 and 52 licensing requirements and incorporating lessons learned from the recent New Power Reactor Licensing Review, the staff has proposed applicability statements to several requirements for non-LWR designs, reducing the need for exemptions. Next slide, please. In the long term, completing Part 53 is critical to effectively positioning the NRC to address the changing landscape of new nuclear reactor development. The proposed Part 53 represents a paradigm shift in how the NRC performs reviews, introduces transformational approaches to addressing technical and programmatic issues, and offers significant flexibility. For the rulemaking, we're using a novel approach to help promote regulatory stability, predictability, and clarity. The proposed rule provides an equivalent level of safety that is as robust as that provided by the current regulations. Part 53 builds on risk-informed and performance-based policies and regulations, and will enable advanced reactor designs with demonstrated safety attributes to leverage safety margins in gaining operational flexibility. Some of these include a strategy for operative licensing that creates considerable flexibility, including allowance for generally licensed operators, an integrity assessment program to address uncertainties associated with limited operational experience for some new nuclear technologies, a risk-informed seismic design alternative, a facility safety program to provide flexibility in addressing new information, the introduction of the alternative evaluation of risk insights approach to provide flexibility for facilities with maximum accidents of very low consequence, and graded requirements for physical security, cyber security, access authorization, and fitness for duty. On the whole, these changes represent a significant shift from the more prescriptive and deterministic requirements in Parts 50 and 52. I want to leave you with the thought that this is not the same NRC of a decade ago. We're committed to setting and meeting aggressive schedules using risk-informed principles to focus and manage reviews. We continue to learn from our past experiences to make our processes and regulations more efficient and risk-informed, and we are successfully applying these lessons to our reviews and the development of advanced reactor regulatory infrastructure. The NRC staff recognizes the important role we play in the nation's efforts to deploy safe, reliable, and clean nuclear power. We look forward to working with all of our stakeholders to achieve this goal. Thank you. Thank you, Rob. All right. Can we have the result of the first polling question? Well, that's quite a difference of opinion and quite a spread of opinions about the response to stakeholder suggestions. Thank you for that. Next, I'd like to introduce Stephen Burns, our former chairman and now a visiting fellow with Third Way. Thank you, Stephen. Oh, thank you, Commissioner Caputo, and it's a pleasure to be here. I sort of, it tells you how much time has passed, but the last live event, a live rick, was when I was still a commissioner four years ago. So this is, you know, I just can't stay away, I guess. No, thanks very much in preparing for this and some of my activities, extracurricular activities in my retirement, I've gone back and looked at some of the history in terms of NRC and AEC regulation. And just to put this out there, the original Part 50 framework was that there was a proposed rule in April 1955 that was adopted in June, or January 1956. And just, as you know, you have to publish rules in the Federal Register for them to be good. That Part 50 took six pages. But all they did that proposed rule was six pages in the Federal Register. I know there's been a lot of talk about how long the Part 53, proposed Part 53 is. But the interesting thing, the AEC says, well, just here it is, this is what we're going to do. Those want, some of us could say maybe those were the good old days, but anyway, here we are. But seriously, pursuing a risk-informed framework and content has always been a challenge. And I think one that is perhaps magnified in Part 53 because of the scope and the purpose of it. And there has been over the years a lot of focus on trying to do things better through a risk-informed process. I can think of things when, for example, the maintenance rule in the early 90s, late 80s, early 90s, that was a passion of my former boss, Vice Admiral Kenneth Carr, who served as chair in the late 80s to 1991. And we think of the Resactor Oversight process as another one where, instead of when I came to the agency, it was working enforcement, every little violation, we sort of bang, bang, bang, here's a civil penalty, bang, bang, bang, here's another civil penalty. But we sort of didn't get things thinking about them right. And some of the incidents like at Millstone and others really sort of set us down a path of rethinking. How do we evaluate, in a greater way, the impact of particular violations or particular occurrences, even if they didn't involve a violation, in terms of their impact on safety. And the Reactor Oversight process, which has been, I think, considered a success, is one of those things that has been risk-informed as it's gone forward. And I think we take that as something as a principle as we move toward part 53 that is focused on licensing, particularly for the non-lightwater reactors and small modular and advanced reactors. So there has always been what I would call a tug and push between industry and the agency regarding where the right outcomes are. And I think we're going to see that, continue to see that, and we should see that. And NRC should expect that. And NRC should be prepared to engage in dialogue with industry and other stakeholders as we go forward on this. I think Commissioner Caputo made some useful observations this morning regarding a risk-informed framework in terms of ideals or goals we can set. And that is, in some respects, one of those goals is providing a simple, not a simplistic, but a simple, in other words, a comprehensive or comprehensible framework, as well as an innovative framework for where we ought to be going. And one that ought to be data driven, but not so much data driven that we're down chasing things and chasing data that really goes beyond where we need to go in terms of the risk impacts of the technology or the, or beyond risk insights that really require us to take regulatory action. I've characterized this before as that the task before is really straightening a crooked and bumpy road, creating one that is more adaptable to the newer technologies in terms of enabling them within the construct adequate protection of public health and safety and security. That means, I think, that to ensure that that happens we have to look at a risk-informed framework that is useful. It's one that we really creating, not the, perhaps what we see is the best of all possible machines or best of all possible routes, but one that is useful to those who may be wanting to engage in it, to pursue their technologies. It's one that needs to be adapt, I think, adaptive because I think we will not understand everything at this point in time with respect to the technologies we may have put in front of us right now or that may come down the path within a few years. And we also need, I think, this is a topic that's come up, it came up in Chairman Hanson's and Bill Magwood's conversation about harmonization, and there's been also the acknowledgement of, I think, Romina Velshi's, particularly her views on this in a number of instances, in terms of the greater framework around the world in coming together with respect to understanding how we regulate across different countries and internationally. So I think that's another thing that, looking at that risk-informed framework, is it harmonized not only with what are the non-enforceable, the so-called soft-law general standards, say, issued by the IAEA, but the common understandings that we may have across regulatory bodies. And again, I emphasize, I think, the engagement with stakeholders. We've learned from that over the years. I think one of the good examples in the last decade was in the response to the Fukushima Daiichi accident, where, looking at what the requirements ought to be, one of the things the industry came up was the FLEX initiative, as a way of providing those necessary backup supplies in the event of a severe disaster that broke off equipment and other things that places would need. And that shows how, I think, sometimes we'd be reluctant to call it a partnership, but that sort of collaboration between industry and the regulator can have an effective outcome. I sort of would say, too, we will not create the perfect part 53. I mean, that is a lesson learned from part 52. And the interesting thing about this part 53 is it may be used well before part 52 was substantially used. Part 52, people kept calling in the early 2000s the new regulatory system. I said, folks, this was adopted in 1989 as a post-TMI innovation. But we really weren't using it, except some design certifications for the AP 600 and the ABWR, which actually the Japanese relied upon. In the 1990s, it wasn't really into the mid 2000s with further design certification from Westinghouse for the AP 1000 for the Vogel and the summer COLs, that it had a substantial progress. But we've learned from some of those things. For example, in Vogel, we learned that the change control process was perhaps too restrictive for design certifications. But we looked at ways to adapt that. And then we have to have that same viewpoint, I think, going forward with part 53. I used to teach when I was general counsel, there was one quotation I always made the lawyers learn, and that is the Siegel versus the AEC case, how this agency, the Nuclear Regulatory Commission, is virtually unique with respect to the broad discretion vested in the agency and determining its standards. And it needs to apply those things judiciously and reliably and in a way that does not stifle innovation. And that means finding a sweet spot, I think, between underregulation and overregulation. I know in a prior Rick speech, I quoted Justice Breyer, who wrote a terrific book in 1991 called Breaking the Vicious Circle on Risk Regulation. And he said, when we treat small risks, medium risks, and large risks, largely the same, we're not much different than the boy calling Wolf. And that's something I think we need to be conscious of. And that's, I think, the challenge we have for us that we all have in front of us, whether on the industry side or on the regulatory side, in terms of approaching the risk informing regulation and in this particular context. So thank you. Hey, thank you, Steve. I'd like to introduce live polling question two for applications in 2025 and beyond. How likely are you to use the Part 53 Framework A? All right, let's leave that up for a few minutes so that people can cast their votes. And we'll move on to Jennifer. Okay, thank you, Commissioner. And I apologize for the rearrangement of the flowers. I couldn't see over them to look at my slides. So anyway, thank you for inviting me to provide my viewpoints here today. So my presentation, we will focus on how the use of risk and determinism really complement each other in providing a really strong but flexible fabric of safety. If we go to the first slide, we're going to focus on how we've used risk and determinism for operating plants. So I think we're all aware regulations for the operating fleet were first based on deterministic requirements. They were the foundation for the safety of the operating fleet. And when I say deterministic, that means we looked at failure modes of the plants. We identified what we thought were credible scenarios. We were not designing for a meteor strike, for example. We looked at what the worst case scenario of those credible scenarios were and the plants were designed to accommodate them. Then we got smarter and PRA was used probabilistic risk assessment. And we took a look at that. We assumed all of the regulations were being met and we evaluated what we can call the residual risk after all of the regulations are met. What is the remaining risk? And the residual risk in any system can never be zero. There is always a failure mode. The question is, as a regulator, and ANRC's tough job, is to determine what right level of residual risk ensures reasonable assurance of adequate protection. And in fact, we looked at this residual risk when it came to station blackout and said this is too high. ANRC promulgated station blackout, the station blackout rule. And that was implemented and the residual risk dropped. Time went on, more operating experience, we got smarter. The question about filtered vents came up after Fukushima. And in the same way, the ANRC looked at what the risk reduction from filtered vents would be, determined that that risk reduction would not be large enough to warrant the imposition of those requirements. Now, we have seen and we have proven that risk analysis combined with deterministic approaches improve safety. Absolutely. And in fact, if we look at the core damage frequencies before we were really using risk insights, say the beginning of the 80s and compare them to the core damage frequencies of today, we have reduced the core damage frequencies by an order of magnitude. And conversely stated, we've improved safety by an order of magnitude through the use of this determinism and risk insights. So the next slide. But residual risk cannot be zero. Can we please go to the next slide? Thank you. So residual risk can't be zero. So let's just again take a really simplistic look here. These points that I'm making, I know that they're just a repeat of what you already know, but I do think they're worth highlighting. So let's look at the risk of operating plants. If we had no diesel generators, operating plants rely on AC power. If we had no diesel generators, residual risk would be high. We would be meeting all the requirements, but we wouldn't have diesel generators. And that residual risk would be high. Okay, so let's require one diesel generator. The residuals risk drops two. Okay, it drops appreciably down to two. But for example, if the NRC were to say, I'm going to impose 27 diesel generators on the industry, well, there's common cause failure across those diesels. And we would be in a situation where we are imposing regulatory burden and not getting much safety benefit out of it because of the common cause failure. And we probably should have provided a diverse means of performing the safety function. But even that diverse means has a failure probability, a failure mode. So if we go to the next slide, let's just start comparing safety of the operating fleet and and how we are determining that safety with the advanced fleet that we're proposing and are all looking forward to. So the operating plants, we again started with determinism, then we applied risk insights, looked at the residual risk, adjusted as we needed it. Now we've come out with we have reliance on AC power. We also have diverse means of performing safety functions, turbine driven injection systems, for example. We have redundancy for safety systems. We've added margin in our assessment. We've got diversity. We've looked at or we've imposed defense in depth, multiple barriers to vision product release. We've addressed human error probability through human factors. And we have over 47 or 40. Let me just say 4000 plant operating years of experience as Commissioner Caputo had discussed this morning. Okay. We're safe. Plants are safe. Advanced reactors. Now we have a different approach. Some advanced reactor vendors want to use risk first and then determinism. They in that should be okay. Others may just want to use all determinism. That should be okay. NRC's approach should be flexible. We have designed out a number of failure modes. We are providing diverse means to perform safety functions. We've got defense in depth. We are addressing human factors issues to reduce human error probability. But we do realize uncertainties are larger. We have operating experience with these designs. These designs are based on proven reactors that have operated. But it's larger than what we have for the operating fleet. And this knowledge base will grow over time and will adjust. So if we go to the next slide though, there is a natural tension between use of PRA in a realistic manner and conservative decision making that we've used in the operating fleet. In the operating fleet we've had deterministic requirements. We've added conservatism there. We've added diversity, redundancy, defense in depth. And then we've come back in. We've used a realistic assessment of the risk through PRA. And we've identified the residual risk and we've adjusted. And uncertainties have been addressed through the conservatism and double checking through the PRA. Now we have more uncertainty with these advanced reactors and some vendors want to use a real PRA focused approach. Still going to have some determinism of course. But will the PRAs now have more margin in them? Will the success criteria in the PRAs have conservatism? Is that going to in an unintended way mask those areas of risk that do need to be addressed? We've got to think about these things. But nonetheless we do need a balance approach of risk and determinism. And we need to make sure that the state of practice is being able to accommodate that concern of introducing conservatism in the success criteria of the PRA. Next slide. So really my key takeaways here. Again, you all know this. Just wanted to reinforce risk informed decision making has served us really well. It will continue to do so. Advanced reactors, we have a great future for the industry and for the nation ahead of us. And we need to realize that future. We've removed failure modes. We're using passive systems. We have natural processes to reduce source term. We have uncertainty larger than the operating fleet, but we're going to address that through additional margin. But the residual risk is not zero. An example of failure mode for passive systems is in fact a very large seismic event. But the NRC is going to have to determine how large of a seismic event do these advanced designs have to consider. And that's the rub. No matter which approach that you use, PRA first in determinism or determinism and then PRA, NRC is always going to have to assess the residual risk and figure out how much risk can be accommodated and still have still have reasonable assurance of adequate protection. Reasonable assurance, not absolute assurance. And we need an efficient right-sized-reg framework for this wide-scale deployment that we all are looking forward to. And to conclude, being efficient as well as effective is critical. The Atomic Energy Act indicates that the U.S. should use nuclear power to make the maximum contribution to the general welfare. That's right out of the act. That is what NRC's mission is. So nuclear power, we need to play a key role in carbon reduction and the NRC's got to be effective but it also needs to be efficient. Thank you. Thank you, Jennifer. Could we have the results of live polling question number two? So how likely are you to use Part 53 Framework A? Framework A likely to be the first choice, 27%. Once again, this is a pretty broad spread of opinions. And level of interest in Part 53 Framework A. Thank you very much for your voting. Now we'll turn it over to George. Take it away, George. I'm going to focus my presentation a little bit on the Part 53 rulemaking. Next slide, please. I think the staff had a big undertaking here. The new 10 CFR Part 53 rule encompasses four rules, Part 50, 52, 55, and 100, all in the same rule. In addition, it has to go from what I would consider a microreactor, which would be a heat tube up to a macroreactor, which would be some sort of reactor bigger than what we have on the grid now as a major energy hub. So that's a pretty large undertaking that the NRC staff has to do. You know, there's different approaches to this. You know, one approach could have been that you did it in different phases based on the potential outcome of the reactor size. Next slide, please. One of the things in Part 53 had had three new regulatory requirements, facility safety program, beyond design basis event design requirements, and allara design requirements. And these requirements are based on programs in the operating reactor fleet right now. So it's, when you look at why would there be an additional requirement for an advanced reactor, which has a better overall safety profile than what the operating reactors do now, it would have seemed that you could have handled and addressed those the same way with the programs that were already in place. Next slide, please. There are also some differences between frameworks Alpha and Bravo. PRA-led approach versus a traditional approach. I know the NRC had to address both, so that's why they came up the different framework. But, you know, framework B doesn't have the facility safety program. Framework B clearly eliminates some of the three-mile island requirements in a better way. I find it hard that, you know, there's some deltas between the different frameworks. Next slide, please. I want to give the NRC credit, what credits do. I think the rule has a lot of operational and licensing flexibility in it. I know we plan on utilizing this in part of our license. It eliminates certain exemptions. We're using a risk-informed performance-based approach in the licensing modernization process, so it eliminates some exemptions you have to have from part 1552. Very open with the way that you can go about for operative licensing. Gives you a lot of resiliency. The rule along with the security and emergency preparedness rulemaking will give you a lot of variations in different ways that you can build your security program or your EP program. It eliminates some of the three-mile island requirements. It also has a reliability integrity management program for doing your in-service inspections. And it changes the way you use a risk-informed performance-based methodology for the valuation of the seismic requirements. These were great ideas that they put in the rule. Next slide, please. That's all I have. Thank you. Thank you, George. All right, live polling question number three. In developing part 53, has the NRC set the right level for what will be the licensing basis versus what would be under licensee control? Let's leave those numbers up for just a minute or two and we'll turn it over to Adam. Thank you, Adam. Hi, thank you. Adam Stein from the Director of Nuclear Energy Innovation for the Breakthrough Institute. Next slide, please. For those of you that are not aware, the Breakthrough Institute is an independent research center not affiliated with industry or the regulator. We identify and promote technological solutions to environmental human development challenges. We represent the public here. Next slide, please. There's a strong public interest in nuclear energy. There's strong consensus that it's needed for climate goals, reducing health and safety impacts from the energy system and adjust energy transition, especially for fossil fuel communities. Nuclear energy can improve reliability, safety, energy security, and environmental justice goals. For instance, with significant potential for just transition for fossil fuel communities in almost every state of the country. We in our modeling and many others have found that there is significant deployment needed to achieve that goal. That means roughly 50 to 150 gigawatts in the next decade and a half. That's hundreds of new reactors in the coming decades and that's the scope that we need to think about how to license safely and efficiently. Next slide, please. The NRC needs to have a commitment to the public welfare and should consider that overall general public welfare and all decision making. As Jennifer mentioned, the Atomic Energy Act specifically says that nuclear energy should be used to the maximum contribution to the general welfare. The Energy Reorganization Act that sets up the NRC and removes it from the ADC specifically does not change that purpose to look at the general welfare of the public. NRC safety goals state that societal risks from nuclear power should be comparable to or less than the risks generating electricity from viable competing technologies. That particular comparison is not actually made by the NRC in any decision making. I'll talk about what they do use a little bit later on. Next slide, please. The proposed part 53 draft rule, which as I note just was released to the public March 6th and thank you to the commission for getting it out a little bit early so we could take a look at it, represents a once in a generation opportunity for regulatory innovation that considers the public interest. As Steve Burns mentioned, part 52 happened in the late 80s. That was the last generation's approach at modernizing this. This does not happen often. So there's significant public interest in getting it right. That doesn't necessarily mean doing it fast. That means getting it right. The draft rule does have some significant benefits as those others have mentioned. Risk and form seismic approaches, I'm not gonna go through the list because others have already done that. So there are improvements here, but there are still some challenges. The rule is evolutionary, not revolutionary. It is based largely on part 1552 as the staff's proposed rulemaking plan said that it would be. However, there's also challenges with efficiency. In the new draft package, in enclosure three, they did a regulatory analysis and found that between the applicant and the NRC savings would be between $28 and $32 million in savings as extrapolated from person-hour savings. That represents about a five to 6% savings if you compare that to say the published cost of both direct and indirect costs that Newskill undertook. Fibers to 6% is not significant efficiency improvement. It also includes specific features of major issues such as the QHOs and frequency requirements for the alternative evaluation for risk insights methodology. Next slide please. I wanna talk a little bit about the quantitative health objectives in part 53 as this is an area that I've had significant involvement. It's an example of a major policy issue that has had significant stakeholder feedback, not just from myself. My conclusion is that the quantitative health objectives should not specifically be in on the rule. It is a measure of cumulative cancer risk that is decoupled from the qualitative safety goals of comparing to other energy sources. This is what the staff currently uses as guidance from the commission on how safe rulemaking should be. In part 53, it's included directly in framework A which poses other challenges. It's not fundamentally a performance metric. Licensees cannot demonstrate that they actually meet this requirement. There's no way to show that this is being observed in the public. And even if there was a say maximum accident as the area approach says assumes of about a 25 rem dose to the public, not only could you statistically not show that that effect did the public with statistical power as a different session I believe right after this we'll discuss statistical power. But it also suggests that further complexity doing PRA as a requirement to meet the QHOs to show that you do through PRA doesn't fundamentally help you reduce risk below the safety goals. You've already met it if you have this very high dose of the public that no reactor with a severe accident would actually have. So we need to focus on detectable risks and consider impacts relative to other forms of energy. Next slide please. The part 53 rule structure itself is a challenge in our view. It should be high level performance objectives that allow flexibility on innovative pathways to meet those objectives. Back a slide please, back a slide. Thank you. The existence of a framework A and B in the draft suggests there could also be a framework C, D, E, F and on for infinity. Meeting the requirements of the rule should be in guidance. For example, LMP is one way to meet the part 53 rule. That methodology is in guidance. The multiple or multitude of approaches to meet a part 53 rulemaking could be done in the same way and allow flexibility in the future. Otherwise a framework C would either need to be promulgated as a rulemaking, which would be tedious or it would have to address the various requirements in either framework A or B as LMP has to do in part 50. Next slide please. The NRC should be forward looking and forward moving. We have heard this concept from every commissioner this week, which I applied. The NRC can be more proactive in not just identifying through lessons learned, solutions that need to be implemented, but also actually propose and implement the solutions quickly. Here are several examples. The part 53 regulatory analysis found that there would be significant savings by averting the need for 35 exemptions per applicant versus existing frameworks. I suggest that this is not a benefit of part 53, but a failure to address an issue in the existing frameworks. They also found that the area approach could require half of the resources versus using a PRA under framework A. ACRS also recommended that the area approach could be used for every framework. The NRC staff said at the time to ACRS that that's out of scope of this rulemaking and didn't include a recommendation in their SECI for the current rule package to consider that in other rulemaking. So might it be outside of the scope of part 53? Yes, is this something that we can propose and implement a solution to in other frameworks? Also yes. Review timelines don't necessarily show an improvement with experience. The generic milestones granted they're generic, but all things being equal if you get a well-qualified applicant is 42 months for light water reactors that we have a lot of experience with and less time for non-light water reactor that has not been licensed yet. And rulemaking timelines are also a challenge. The emergency preparedness for small modular reactors which had a corollary in part 53 that now only points back to part 5047 which would be modified by this proposed rule has a review timeline in front of the commission of 18 months at this point. The new scale design certification was finalized in August of 20 and came effective only last month. 30 month timeline on the back end after the staff found that it was a safe design. Next slide please. So in conclusion the NRC has a vested interest or the public has vested interest in the NRC being timely and effective in licensing nuclear reactors. Should you consider how the safety nexus supports that approach for efficient and review while enabling innovation. Open discussion is critical to this and that's why the Breakthrough Institute in combination with other stakeholders is going to hold a workshop to develop an alternative approach to part 53 to allow the commission to consider a different option. Thank you. Thank you. Appreciate all of the panelists presentation so far. Right now we'll have the results of the last polling question and we'll start our Q and A session. Developing part 53 has the NRC set the right level for what will be the licensing basis versus what would be under licensing control. So 41% at yes. Once again a wide range of opinion in the polling question. And people are still voting. Thank you everyone for contributing to the polling questions. So let's start our Q and A session. I would like to start with Steve. What do you think a successful outcome would be for part 53? Well a rule that people are willing to use that is and I've sort of drawn some of what Adam was saying is that one that gets you through a process in an efficient and effective way. I think those are the things. And I think it is something and some of this dialogue in terms of the comments we're hearing is is it focusing on the right things? Are you focused on what are the critical things and some of the other aspects which may be programs and other things that licensees have to do through implementation and always have done. Are those really able to be accommodated through other aspects of the licensing process or the operating process? So that's not a particularly specific answer but I do think it is a focus on how you're gonna get through the process in terms of a timely way. How the information that's required is really the critical things needed to assess the technology and then other aspects in terms of how one operates, how one functions are dealt with as well but not necessarily in terms of sort of the design specific aspects of it. Thank you for that answer. I have another question here for Rob. You mentioned the reconciliation rulemaking for part 50 and 52 and that purpose is to bring consistency to applicants pursuing pathways in either. However, aren't there inherent differences built into those rules based on expectations of citing conclusions versus safety? Absolutely. There are some things we'll never perfectly align between part 50 and 52 that relate to the construct of how you go through the licensing process and what you need to demonstrate at different points and there's benefits to part 50 which we're seeing with many of the SMRs and advanced reactors who are pursuing it because it allows them to move forward with a construction permit and begin construction while they finalize design details whereas part 52 requires a more fully developed design. So we'll never achieve perfection between the two because they're meant to accomplish two different things. Our goal was to attempt to identify everything we could to make them as reasonably aligned and when the commission makes the determination on whether to move forward with that rulemaking, I think we're gonna get good public comments on it of areas where we've achieved that, areas where we might wanna look to do more. So I think it's a great opportunity for further dialog as we progress. Thank you. Jennifer, what are your thoughts on including cost-benefit analysis to new reactor licensing activities similar to the back-fit process? Well, I'm a big fan of the back-fit process. I've been, I've worked at the NRC for over 20 years and I've had to justify decisions through the back-fit process and then I've worked for the industry and I've requested back-fit analysis on some areas where I thought the staff was imposing new requirements. I think having a back-fit type approach is crucial for a regulator because we want stable regulations and we want decisions to impose new requirements based on a systematic assessment of safety. The particular question I would say is leaning to whether the facility safety program is in some way circumventing the back-fit process, I think, where the questioner was going. I would prefer if I had 100% control, which obviously I don't, I would prefer that the facility safety program not be included. I think the onus is on the NRC when imposing new requirements to justify that they are prudent and worthwhile. Thank you for that. I've got a question here. I think I'm gonna post the entire panel. Given the insights that operational experience can provide in improving regulatory processes and outcomes, excuse me, how can we manage the lack of experience with new technologies and how is this incorporated into the rulemaking process so that once operational experience accumulates, this can inform future application reviews and oversight? Rob, would you like to start? I'll start. That's an absolutely great question and one I think both the industry and the NRC are wrestling with. It's true that the advanced reactor technologies have been used in the past and have been demonstrated and there is information out there, especially on fuel performance in other areas where we have a wealth of insights of operating experience and the goal should be to leverage those to the maximum extent possible, recognizing how these will be used in the new designs as well and understanding the differences that may exist there. We had the same challenge 50 years ago as we licensed reactors, but we had less effective tools for measuring it, I think, than we do today. So operating experience and uncertainty are gonna play a role. PRA is a tool that can help us address that uncertainty, but other things can as well. So I think we all have to be open to recognizing where uncertainty exists, acknowledging it and then asking the question, does it really matter at the end of the day? Does it impact public health and safety in a manner that raises a concern about the facility's ability to safely operate or can we make a reasonable assurance determination, understanding and knowing that uncertainty but not imposing additional requirements? Anyone else? Yeah, there's a lot of operating experience whether it was on light water reactors, either boil or pressurize it, you can take a valve's a valve, a breaker's a breaker. I can take all the reliability data from there and do it. One of, and utilize it in my plant for reliability and looking at maintenance, but some of the advanced plants I know when we're looking at ours, we're gonna have a complete digital twin. And with the digital twin, I can run all kinds of scenarios through and actually show the NRC different things that some of the operating reactors can't and using the digital twin actually will increase the capability for the NRC to come and analyze stuff to a great deal. So that's another tool that we'll be able to use to show the NRC. We're taking all the operating experience, all the positives and the lessons learned from the operating fleet and incorporating them to our design to minimize human factor evaluations or to minimize equipment failures because our plants are passive. Like with ours, our safety system's always running. So we can utilize that to help the NRC and teach the NRC to show why our plants are safe and move on. Thanks, would anyone else like to comment? Yeah, I mean, I do think we all realize that we're gonna learn lessons as these plants are deployed and operated. We're learning lessons in the operating fleet with over 4,000 years of operating experience just in the US alone. And so the reg process needs to be able to account for that. And I go back to one, the industry needs to be aware of new information that comes in. It's the responsibility of the industry to ensure safety. They need to be aware of the app experience, share it, question whether does anything needs to be adjusted in the design. And the operating fleet does that marvelously. Now, when we look at it from the NRC point of view, they have to do the same. They're aware of changes, they're assessing whether or not additional regulation is required, but we need the regulation to be systematically assessed. Again, how much residual risk is coincides with reasonable assurance of adequate protection. We cannot be in a situation where new information automatically leads to more regulation beyond reasonable assurance, or otherwise we just will not be able to deploy these plants and address the climate issues that we all face. So I think the reg process needs to be systematic, needs to be flexible, but that question of residual risk is just vital in order to make the process efficient. I'd like to approach this from a little bit different point of view. If you are trying to be innovative and you are deploying tens, dozens, hundreds of the same reactor design, you make small changes or gain performance experience from the first, second, third plant, you wanna be able to easily apply that to following on designs without having to go through a challenging process. I'm not saying that necessarily is the case with part 53 right now, but you wanna make sure that it is very streamlined to be able to use those risk insights in applications that might be already underway being reviewed because you're building many of these at once and not one per decade, applications that will come in the future for the exact same design, you just have more experience. We need to make sure that enabling the innovation along the timeline, even with concurrent parallel reviews or deployment is also possible. Thank you. I'm gonna pose another question to the entire panel, although we'll start with Rob on this one. Would the staff draft of part 53 reduce the number of hours required to review advanced reactor license applications compared to historic reviews? So I think part 53 can be a key piece in doing that. It's not the only piece of that puzzle. Given that it allows for a graded performance-based approach to meeting the regulations, plants that demonstrate the margin that Jennifer talked about should be able to demonstrate that they meet the requirements in a much more efficient manner and with less rigorous review by the NRC. So it has that flexibility. Now, the other end of the spectrum is what we talked about, operational experience, right? The extent of testing and analysis and the quality of that testing and analysis will play a huge factor in the level of effort for the applicant and for the NRC to do a review. So there's a number of factors that compete, but part 53 can certainly enable it. Thanks. Anyone else? Yeah, I can add. I'm not sure yet because it's not finalized. Certainly, I do think the NRC recognizes that in the case of some designs, microreactors, for example, you can assume the worst situation, again, assuming it's credible. And if the dose guidance is met or the dose requirements are met and other deterministic factors, then the plant is safe and that should allow a very efficient process. There will, of course, I think just by the NRC being intrusive by nature would double-check the assumptions so it's not gonna be rubber-stamped, certainly. I think going to a PRA-focused approach that I'm not as confident could be done very efficiently. Just to give you an idea, we have light-water reactors been operating very well. Right now it takes 18 months to allow for a risk-informed approach to alternate treatments of components. And now we're talking about developing the design basis as a function of the PRA with determinism as well. And in my mind, I just see that as being fraught with a whole lot of questions about modeling approaches, what's considered in the PRA, et cetera. And you can't consider everything in a PRA. There's all qualitative factors that have to be considered. So that approach, I think, is gonna be difficult for the first person going through it and I wish them well. Well, in nuclear, there's a saying. Second mouse gets the cheese, nobody wants to go first. Got an interesting question here, thinking out of the box. Could we ever expect a flat fee for a reactor license? Rob? Can I hypothesize a flat fee for a reactor license? Yeah, I can hypothesize it. I mean, the commission is the ultimate arbiter of our fee structure and we propose to the commission, but I think I'll take it to something that we've talked about and maybe not enough publicly is we're asking ourselves what does two through nth of a kind of a reactor look like? And how long does a review really need to take in that case if you achieve standardization in the design or the design changes are of minimal effect as Adam kind of talked about. And when you get to two through nth of a kind, you're down to just a few things that have to be addressed, citing external hazards, environmental, so you get to a much more structured review. You should have a very predictable licensing cost. Absent unforeseen circumstances like substantial seismic risk at a site that's being proposed. So you should see a very predictable, repeatable schedule and resource estimate for those kinds of designs when standardize. So I can see certainly getting to that, whether we get to a true flat fee would be something we'd have to take up and discuss with the commission. All right, thank you. Steve, could you elaborate on why the Vogel change control process is too restrictive? Well, I think, as I said, this is a lesson learned out of in terms of the application of part 52. Again, part 52 adopted in 1989, survived judicial review was confirmed by the Congress in the early 90s. But going through where you actually had somebody constructing a facility under a part 52 license which was a combined license using a design certification didn't occur until nearly 2010 or maybe a little bit before that. And what it was, what the issue was, as I recall, was the question of how, with respect to making changes that arguably are design changes within the scope of the design certification, it's the flexibility to be able to do that. And Rob may hopefully can confirm that I'm sort of saying the right thing here, but that was one of the issues. And so normally under a license process, if you look at the good old-fashioned licenses, the part 50 license, you have your 50-59 process and if you go through that and determine that there's basically, you're within the scope of the existing license, you can make that change. You have to record it, report it, et cetera. But that wasn't really provided for in the design certification. So yes, it would still be if there was a major change in the design that you would need to go through that process. But minor things that could be considered that considered if you applied like 50-59 wouldn't necessarily go. So Steve is great points. And it's something we recognized going through the Vogel process and what we did when we approved the AP-1000 design and certified it. There's tier one information, which is controlled by the certification and is part of the rules, so you need exemptions to change it. We used a lot of tier two star, which required license amendments to the NRC. And then there's tier two information, which can be changed under a change control process by the applicant. We've changed how we're approaching those things. We wrote a paper to the commission a couple years ago that said we're gonna apply new standards to what really needs to be in tier one. So we're gonna reduce the amount of information that goes into tier one and that requires exemptions in future reviews that use part 52. That means more will fall into the bins that give licensees more control. And we eliminated tier two star in new scale. And I envision we will not use tier two star going forward, except in extraordinary cases. So that's putting more and more things into the change control process that the licensee would have the capability to adapt and adjust using their programs. And we can always inspect it and check and confirm. And if we have concerns, we'll raise those through the proper oversight program. Thank you. Well, I have a question here that specifically is for George, but I think probably all the panelists would like to comment on this. But we'll start with George. Under the new part 53 arrangements, how will the NRC make a determination of how safe is safe enough? I think it would be our capability as a licensee to demonstrate to the NRC on our safety profile that we're safe enough. We would look at what our safety systems were done. Doing that LMP process, you look at the different accident analysis, then you rate your SSCs based on the accident analysis. And I think through teaching the NRC how our plant worked and where it was, we would lay out here's where our safety case is, here's where we're safe enough and we prove it to the NRC. It becomes my, has the applicant, we need to prove the safety case. And if we don't agree with the staff or we would move it up through the chain of command saying here's why we're safe, because here's the safety profile for the operating plants, here's the safety profile for us, why are you changing us? So that'd be the methodology that we'd work with the staff to prove it. Thanks. Go ahead, Rob. Yeah. I'd say in Terrapower has done this well and a number of applicants have is one of the best things that we get in pre-application is to get a discussion of the safety strategy for that facility, to get an overall picture of how that facility is gonna demonstrate reasonable assurance of adequate protection. The earlier we understand that and the more comprehensive within reason it is, the better we'll have a holistic way of assessing the plant's safety profile as we do our reviews in whatever regulatory framework it is. So as George was indicating, he is going to make a safety case. The question is, what threshold is he making that safety case for? And I know Adam has some pretty firm opinions on this topic. Adam, would you like to discuss that for a minute? So a safety case in our view should be something that is one compared to other energy sources, meaning that you have to have the context of what you're replacing. If you are regulating to something that has no context as the safety goal is currently to say it should, then you could be potentially limiting some deployment of something that could help society with the public. Second, the safety threshold should be something that you could actually measure or observe. And the QHOs are potentially okay as a goal, but they're not an observable metric even if you did have that sort of dose to the public, you couldn't actually statistically observe it. And that doesn't align with good regulation. If it's something that you can't actually show, then you can't say whether you're providing the safety to the public or not. It's also well below what other agencies such as the EPA use as their threshold and therefore is not in line with other safety regulators. Would anyone else care to comment? Another question for the full panel, what do you see as the biggest barrier to effectively licensing and deploying advanced reactors? Rob, do you wanna start? Or Jennifer, you wanna start? Volunteer to start to give Rob a break. Thank you. In my opinion, decision-making efficiency. Again, I've been at the NRC for over 20 years, so industry side now, and so I have, I think, a unique perspective. The NRC makes decisions, I believe, based on consensus. And the purpose of that was to ensure that everybody's opinion is heard and dispositioned professionally, respectfully. I do think it has, the pendulum has swung too far. And I think now that there's a drive for consensus and to continue to discuss an issue without raising new information to allow everyone involved in the decision to be comfortable. And I don't think that that leads to an efficient decision-making process. And it's hard as a regulator to determine how safe is safe enough, right? Because we can't just use the risk values because there are issues that can't be addressed using the PRA. And qualitative factors have to come into consideration. So I'm not saying it's easy, but I do believe that focusing the decision-making to be more efficient, to be predictable, consistent is an area that the NRC could improve in. So I'll agree with Jennifer. Maybe that's because we worked together so much in the past. I think that's a great point. I think the challenge we face is balancing safety culture with timely decision-making, and we're working on that through things that we talked about, like elevating issues quickly and trying to drive decisions based on a holistic picture of safety for the facility, not just a narrow slice of that particular issue, trying to take a bigger picture perspective related to that. I'll tell you what keeps me up at night, and we've talked about it a lot in the commissioner plenaries, is making sure that we have the workforce ready to do the work and having enough people capable of doing it, and then making sure that we're consistent across the reviews, right? As we form core teams and do the reviews, how we treat a terra power should be the same as how we treat an ex-energy as a chai rose and a GE and others, and that we're applying that. I know that's going to be a significant challenge for us, and it's going to require a high level of staff and management engagement to make sure that we do that, because if we're not doing fairer and equitable treatment of those designs, I guarantee we're going to hear about it, and I want to be ahead of those kinds of issues. Jennifer, another question for you, although maybe others want to comment. What are the practical implications of design-related requirements to achieving doses that are allara as low as reasonably achievable in a manner in which they've been presented in part 53? Well, I guess as an engineer, I start with if something is still working, it's not broken, then don't fix it, because you never know if you're adding unintended consequences, and I understand the principle behind putting allara as a design criteria, but to me, a design criteria that says as low as reasonably achievable, to me there's no clear answer to, okay, what is reasonable. So we've gotten the cumulative dose down throughout the operating fleet to just extremely low numbers, and we've done that without having allara as a design requirement. We've done that through operating programs, and it's worked. So I would recommend that the NRC take a look at that and say, okay, what problem are we fixing by putting it in the design requirement? Thank you. Any other panelists like to comment? All right, I've got a couple of things. I could put just a little bit of context on that for some. It was mentioned that the design requirements aren't currently in 5052, but it's directly in 53. The context is where's the bottom? At what point is your design, as you're designing it, considered safe enough for the NRC to say this is allara through design requirements, and we can make the safety determination for the license? Reactor designers are already thinking about how do we make the system safe? And it has to meet the risk profile for the NRC to make a safety determination now. So should they be required to go beyond actually making a safety determination for allara in the design phase, and if so, where's the bottom of that well? That's the real question here. How do you even determine where the bottom is? Thank you. I've got a couple of questions on the facility safety program too, so let's start with Rob. Could you explain why the facility safety program and Framework A is important and how it can benefit licensees? And we also have a question about the advantages and disadvantages. So let's start with Rob and have anyone else come in. So we've talked about the idea that we're gonna find and identify new things as we progress through these plants as they get licensed and they start up, and hopefully at one point we'll have fleets of these out there contributing to decarbonization and climate change. The facility safety program gives the licensees a methodology for addressing whether an issue is of significance that they need to consider doing something about it. It includes screening criteria so that they can scope out issues that aren't of significance, like kind of like how you do a 50-59 where you do an initial evaluation and some things never even get into the 50-59 process, but it gives them that capability to do those assessments themselves when new information is presented. And then we become an inspection tool at that point to assess. So it's not meant to drive substantial changes at these plants and impose new requirements on the plants as they progress. It's a tool to say when there's substantial risk, something contributes substantial risk that we didn't know about, then something needs to be done and it needs to be addressed at the facility and we'll look and see how they did that and whether it's sufficient to continue to demonstrate reasonable assurance of public health and safety. Anyone else, advantages and disadvantages? I guess I would say that I think by imposing the facility safety program that is going to impose a burden that I think is unnecessary in my opinion. Obviously there are several opinions out there. I'm just gonna try to describe mine. Certainly we're gonna learn more information, new situations are gonna arise that are gonna question whether or not the plants need to adjust their design or operation as a result of it. That happens. The industry will respond as we always do and there currently is not a requirement to impose a facility safety program. Yet there's number of voluntary initiatives the industry has taken to address such issues. I also think that or maybe it's some pessimistic and knowing the NRC, I can't imagine that the NRC with new information coming in wouldn't on their own be assessing the regulatory significance of that information and questioning whether or not orders need to be written or regulations need to be promulgated to address that new information. And so by requiring the utilities to do it in a systematic way that then can be, violations can be granted or issued as a result of coming to a wrong conclusion. And oh by the way the NRC is doing the work anyway. I don't really see the net benefit. I find that duplicative and think it should stay with the NRC. Thank you. Adam, I have a question for you. What issues with proposed rule are the most important to resolve to ensure part 53 can be replicated to review and approve multiple reactors of the same design instead of just focusing on first of a kind? For that particular issue, the ability to be flexible to new innovations as I said is the most important. To get to Nth of a kind, some developers say Nth of a kind is four reactors and that'll happen in their very first plant. But four reactors is not going to push us towards national goals. So we're thinking way larger than that. Not on the plant level but on the multiple plant level. And to get there we need to be able to take lessons learned from a first plant, a first reactor in the first plant and apply them with changes easily to licenses for subsequent reactors in the same plant or every other plant after that without changing the whole design basis and requiring say a LAR licensing amendment as we currently do. More flexibility to design certification process would be beneficial to that standard design envelopes being the norm instead of the exception both in environmental review and characteristics to reactor would certainly help towards that. The Part 53 framework currently takes the licensing types from 1552 being design certification, provide our spring license. But if we make some adjustments to that instead of just adopting them, that will definitely help with more rapid deployment. Okay, great. Steve, international question. Based on your experience and interactions with regulators in other countries, how do the regulators in their stakeholders view the NRC's efforts to risk and form advanced reactor licensing? Are they doing something different that the NRC could learn from? Well, one of the things I'd start with and some of you may have heard me before, I cringe when I hear this characterization is that NRC is considered the gold standard in terms of regulation across the world. And I cringe on that only because what I think that can sometimes do is encourage you not to continue to innovate and continue to progress, be that learning organization, et cetera. So we're often looked to that way. Now, some of what I think we have things to learn from and we're doing that, I appreciate particularly the memorandum of understanding with the CNSC in Canada and others in terms of how they're approaching that. But I would not necessarily say, and I think I can recall Bill Magwood at some earlier conference along the same way, is that other than mature regulators such as Canada, France, the UK, which has a slightly different approach as well, you're not, there isn't a lot more out there. What there is, I think a continuing need for, is the dialogue among those agencies and those regulators. It's provided for, there's an SMR regulators forum within the IAEA, NEA is providing that kind of opportunity for dialogue and that's where I think you have to continue to go. And one of the aspects of that is, is particularly if you look at, and we've taught some of the speakers and I think of the discussion between Magwood and Chair Hanson this morning, a focus on is that you're looking at deployment in a number of countries that are basically what we would call new entrants, new entrant countries, places like Poland where you're looking at the, Estonia, another one, where you're looking at deployment of nuclear technology for the first time. And so what they're looking for is really reliance on what we would call a mature regulator. And that often means, particularly if the technology is coming from here, for example, you're going to see them looking at how does the NRC approach it, what is the NRC said about that technology at this point and where it's going? I mean, I think that's an advantage to places like, or to companies like Newscale to GE Hitachi in terms of some of the technology, they're starting to go and probably will be for others as they go through that process. So again, the regulatory system has been basically nationally based since the outset. And even after Chernobyl with the adoption of the Sienna, the Convention on Nuclear Safety, there's been no approach to make it an international regulatory body. I don't think that's going to happen. I don't think it should happen necessarily, but the dialogue either bilaterally, multilaterally, internationally should continue among the various regulatory bodies. Thank you. Steve, we're going to stay with you and have you put on your former general counsel hat. How do you see codifying the QHOs as opening legal exposure to operators given that there is no way to prove what causes cancer? That there is no way to... To prove what causes cancer. Though the QHOs specifically target lowering cancer risk, there's no way to prove what causes cancer. So if you're quantifying, if the NRC quantifies QHOs, does that open operators to illegal exposure? Well, that's an interesting question. And I'll answer more in the context of what I think we've seen historically, for example, with the part 20 requirements and all that, is if you're going to force me, twist my arm, make a yes or no answer. My answer might be yes, but it's always because it's opened the opportunity. Will they be successful? I have a lot of doubts about that. And the reason why is I think because of some of what's historically happened with respect to some of these cases, when they look at what the actual standards are in terms of radiation protection. And I think there will be a tendency to look, still look at those. And the QHOs, while they may be there to, if the objective is to minimize any kinds of exposures, they're still there to do that, but they're not saying that this, in effect, at that lower exposure rate is an enhanced cancer risk. It doesn't change the, for example, part 20 standards. And even within, I think, internet, even with an IRCP standards, it doesn't change that. So I think it's an uphill struggle, but hey, lawyers out there, there might be some more business. I don't know. Anyone else like to comment? I think the lawyer should have the last word. Isn't that generally the case? Folks, with that, we're out of time, so I'm gonna wrap up the discussion. Thanks to our panel for being here and contributing your comments. It's our discussion today. Thank you for the audience for participating in the polling questions, participating in the questions, the Q&A session. And with that, we are adjourned. Thank you very much. Thank you.