 Well, good morning everyone. Welcome to day two of the Regulatory Information Conference. Welcome back for this bright sunny day, and hopefully the weather outside won't distract you from focusing your attention on our sessions here today in the plenary and also in our technical sessions this afternoon. You may have noticed throughout the course of the week that this image will frequently show on the screens. We're doing that because we want to call your attention to the Second International Regulators Conference on Nuclear Security. Some of you may be aware that NRC and other government agencies here in the United States sponsored the first of those conferences back in December of 2012. And we've been working with our Spanish counterparts to arrange and host this seminar, which will be in Madrid in Spain May 11th through the 13th of 2016. It's especially timely given the attention that the global community has right now on nuclear security. And we want to emphasize this conference to your attention so that you can participate if you choose to do so. We would certainly encourage that and hopefully we'll see you in Madrid. It is my privilege now to introduce our final commissioner plenary and that is a plenary address that will be given by Commissioner Barron. Commissioner Barron began his service at the Nuclear Regulatory Commission on October 14th, 2014, and his term ends in June of 2018. Prior to arriving at the Nuclear Regulatory Commission, Commissioner Barron worked for the U.S. House of Representatives for more than 11 years. He most recently served as the staff director for the energy and environment, for the Democratic staff of the House Energy and Commerce Committee, and that committee has oversight of the Nuclear Regulatory Commission. So it's important for his current service that he has that experience to draw from in providing oversight as one of his primary areas of responsibility of the Nuclear Regulatory Commission. While he worked in Congress, Commissioner Barron worked on a range of NRC issues, including new reactor licensing, existing reactor oversight and decommissioning, high-level and low-level radioactive waste, and uranium mining, milling, and enrichment. He helped to coordinate the efforts of six federal agencies, including the NRC, and two Native American tribes to clean up uranium contamination present on the Navajo Reservation. He also helped negotiate bills related to pipeline safety, energy efficiency, hydropower, and medical isotopes that were enacted with bipartisan support. Commissioner Barron earned a bachelor's degree and a master's degree in political science from Ohio University and a law degree from Harvard Law School. Ladies and gentlemen, please join me in welcoming Commissioner Barron. Thanks, Mike. Good morning, everyone. I hope everyone enjoyed the first day of the RIC and arrived rested and ready for day two. It's a packed schedule today. Last year, I talked a little about all the advice I was getting for my first RIC speech, and I think that all worked out fine. But here's the thing. I didn't get any advice at all for my second RIC speech. None. And so I've been grappling with big questions like, should I include a joke at the beginning of the speech? And here's what I decided to do. Here's how I decided to handle this. I decided to take a project-aim approach to this question, and I did a little rebaselining and determined that a joke was not vital to the core purpose of my remarks. I'm sorry. I know you're disappointed, but we all have to make tough choices in this project-aim environment. And the joke was on the shed list. As I recently told one of our Congressional Oversight Committees at a hearing, some cuts just make sense. Well, that was the plan until this morning anyway. And then I saw that Darius Dixon from Political Pro came through for a second year in a row with a joke for me to deliver today. So I thought, well, that's efficient. And I decided to demonstrate a little agility by throwing it into my remarks. So here it goes. Are you guys ready for this? That's...where is the enthusiasm? That is...you've had too many of these and now you know what you're going to get. Okay, here we go. A Higgs Boson particle walks into a church, but the preacher says, get out of here. You call yourself the God particle when there is only one true God. The Higgs Boson replies, well, if I'm not here, how can you have mass? If you like that joke, thank you. If it wasn't your cup of tea, please take it up with Darius. He's probably around here somewhere. I'm kidding, of course, because as Commissioner Ossendorf reminded us, I'm accountable for the telling of that joke. And we appreciate that Darius is on the NRC beat. He does a great job. And I'm not just saying that because he's my trusted supplier of nerdy jokes. I also want to note that I'm wearing a pink tie today in solidarity with Commissioner Svinike. I want to be clear that this tie is not fuchsia. Commissioner Ossendorf isn't the only one who struggles with the pronunciation of that word. In fact, my daughter Mia pronounces it phasia. Now, she's four and she also names some of her my little ponies phasia, but I don't want that to distract from the point I'm trying to make, which is that you're not alone, Bill. You are not alone in that. And I really didn't intend for my remarks to be a Bill Ossendorf roast, but unfortunately the time for that is coming sooner than I would like with his departure from the Commission at the end of June. So, Bill, I want to take this opportunity to thank you for all you've done and to let you know that I've really enjoyed our time working together. We don't always agree, but we agree quite a bit. And even when we disagree, I appreciate that we always have good, respectful discussions of our views, often finding common ground on a constructive way forward. I really appreciate that. You are a person of integrity and principle, not to mention tremendous experience, and your departure will be a loss for the Commission. The Naval Academy, on the other hand, will be lucky to have you back, but they'll have to wait a few more months as we continue to benefit from your insights. During those next few months and beyond, the Commission will remain focused on post Fukushima safety enhancements and lessons learned. Friday, of course, will mark the five years since the nuclear accident at the Fukushima Daiichi plant in Japan. It is a sobering reminder of the need for renewed and constant vigilance by independent safety regulators and power plant operators. And it is a natural and appropriate time to take stock of where we are. I will be traveling to Fukushima later this month. It will be my first trip to the site, and it will probably be the most important trip I've taken during my time as a commissioner. I've heard over and over again what a profound impact seeing the scene of the accident and the affected areas has on people. Fellow commissioners, NRC senior managers, licensee executives, they all leave Japan deeply affected by what they saw and heard and motivated to ensure that it never happens again. In the aftermath of the Fukushima accident, the Commission set a goal of completing NRC's response to the accident within five years. Now that we've arrived at the five-year mark, I think it's clear that we've made significant progress, but still have a lot of work left to do. Licensees are implementing the NRC order on mitigating strategies. That order requires plants to have equipment on-site and off-site to respond to beyond design basis events. You can see that progress on the ground. I've been to Arkansas Nuclear One, Dresden, Kataba, North Ana, Watts Bar, and if you visit these plants, you'll see a dome or other structure with equipment for responding to beyond design basis events and uniform connections for those generators, pumps, and hoses. This is new equipment since Fukushima, and I think there's broad agreement that it will enhance the ability of operators to respond to major natural disasters and other potential hazards. The efforts to comply with the mitigating strategies order should be complete at almost every plant by the end of this year. Every site should also have new spent fuel pool instrumentation in place by the end of the year so that operators will have reliable information on the water levels in their spent fuel pools. Seismic and flooding hazard re-evaluations are ongoing and interim measures are being taken in some cases, but we need to acknowledge that licensees and the NRC staff both have quite a bit of work ahead of them to complete and review these seismic probabilistic risk assessments and flooding analyses. It's going to take a few more years to finish that analytical work and determine whether any additional site-specific steps need to be taken to better protect plants from earthquakes or floods. The installation of severe accident-capable hardened vents at BWR units with Mark I or Mark II containment requires substantial physical modifications to the plants and will not be complete until 2018 and 2019. So that's where we stand on some of the most safety significant enhancements required by the commission. That's not an exhaustive discussion of every step the agency has taken, but I think it highlights several key elements of the commission's post Fukushima activities. During my time on the commission over the last year and a half, my colleagues and I voted on several Fukushima-related policy and rulemaking matters. We agreed on some of those issues and others I would have gone farther. One example is NRC's treatment of severe accident management guidelines or SAMGs. Since they were introduced in the late 1990s, SAMGs have been voluntary. The commission had to decide whether NRC should include a requirement for SAMGs in the proposed mitigating beyond design basis events rule. I strongly believe we should have done so. In the wake of Fukushima, NRC inspectors evaluated the status of SAMGs and their findings were troubling. Some plants had outdated SAMGs, others had emergency responders without SAMG training. The Fukushima near-term task force therefore recommended making SAMGs mandatory and the NRC staff agreed. They recommended requiring SAMGs so that they would be enforceable. The staff was not confident that SAMGs would be maintained and effective at every plant in the United States in the absence of such a requirement. The staff's regulatory analysis showed that making SAMGs enforceable would provide a substantial safety benefit. An industry told the commission that requiring SAMGs would have little or no additional cost, so making SAMGs an enforceable requirement would have increased safety without being burdensome. When I weighed the pros and cons, I concluded that the proposed rule should have included that requirement. Including the requirement in the proposed rule wouldn't have represented a final agency decision on whether to impose the regulatory requirement. It would merely have allowed members of the public to share their views on such a proposal. After a strong, well-supported staff recommendation to propose a SAMGs requirement, I thought we owed it to the public to solicit a broad range of views on the merits of such a requirement. I approached the containment protection and release reduction rulemaking the same way. This was commonly referred to as the filtered vents rulemaking. In this case, the staff had prepared a draft regulatory basis for the rulemaking. That's the step before a proposed rule. At that early stage in the rulemaking, the staff thought it made sense to require severe accident, water addition, and management, which licensees were already preparing to implement. But the staff planned to have the independent experts on the advisory committee on reactor safeguards review the draft regulatory basis and also get public comment on the document before presenting it to the commission. The commission decided to terminate the rulemaking prior to getting ACRS feedback without public comment. Frankly, I think that was the wrong way to go. Stakeholders were expecting a rulemaking to consider a requirement for filtered vents. I think we should have followed through and given the public a chance to weigh in on that important question before making any decisions. NRC required severe accident capable hardened vents back in 2013 because we learned from Fukushima that venting to reduce pressure and containment could be critical to safety in certain accident scenarios. If we expect plants to vent in these situations, it's reasonable to ask in a public comment period whether the vented radioactive gases should be filtered before being released into the environment. Seeking public comment is not a final regulatory decision. It's an opportunity for interested stakeholders to express their views and for the agency to consider those comments in its decision making. Let me mention one other area where I think the agency should do more work than it has to date, and that's on several of the Tier 2 and Tier 3 action items. Fukushima lessons learned activities were placed on a longer term track for completion in Tier 2 or Tier 3 based on skill set availability or the need for more analysis, not because they aren't potentially significant safety issues. The NRC staff and the commission assigned priority levels to these near term task force recommendations in late 2011 because they reflect valuable lessons from the Fukushima accident that warranted additional attention. Most of the Tier 2 action items were ultimately incorporated into Tier 1 efforts, but several Tier 2 and Tier 3 items remain unresolved. One example is an examination of the need for reliable hardened vents for containment designs other than BWR Mark 1 and 2s. The list of remaining items also includes reevaluating external hazards other than seismic and flooding hazards such as drought and extreme temperatures. My view is that NRC should do a thorough safety analysis of each outstanding item before deciding whether any additional actions need to be taken. The staff did this for some items, but I thought their recent analysis was insufficient for other items. We all share an interest in addressing the open post Fukushima items in a timely way, but we need to ensure that they are resolved and closed after an open minded examination of the safety issues based on the latest information. A full analysis would not necessarily result in additional regulatory requirements, but when someone asks me whether we fully examined all the items identified as lessons from the Fukushima accident, I want to be able to respond with an unqualified yes. So I look forward to reviewing the staff's ongoing work on the remaining open items. I'm very encouraged by the staff's commitment to ensure the proactive and routine evaluation of new external hazard information in a systematic manner. I think the staff is absolutely right that we need to actively seek out new scientific information that may deepen and refine our understanding of external hazards. Periodic or continuous reassessment of external hazards is crucial in light of the impacts of climate change on some hazards such as flooding and drought. These climate related hazards are expected to exceed historical levels in the future. We simply cannot assume that the frequency, intensity and duration of these events will be static. Improving our processes to better account for this reality is an important Tier 3 effort that I will be closely following. I want to touch on a separate issue that has implications for NRC's response to Fukushima, and that is the question of how our regulatory analysis should consider quantitative and qualitative factors. We've heard a lot of concern about the agency's consideration of so-called qualitative factors in its regulatory analysis. I think the term qualitative factors can be confusing or at least imprecise. Qualitative factors are really just non-quantified benefits and costs. In my view, we need to think about this in the context of what we're trying to accomplish with a regulatory analysis of a proposed regulatory action. A basic tenet of regulatory analysis is that it should examine all relevant costs and benefits whether they can be quantified or not. If a benefit or cost can be adequately quantified, there's obviously no need to conduct further analysis of that benefit or cost. But if a benefit or cost cannot be adequately quantified, it is appropriate and necessary to conduct a qualitative analysis of that benefit or cost. The ability to adequately quantify one or two benefits clearly cannot preclude consideration of other non-quantified benefits. Otherwise, the result would be an incomplete or inadequate examination of the true costs and benefits of a proposed regulatory action. Let me put these general concepts in the context of NRC's response to Fukushima. If NRC had only considered the benefits that we can fully quantify when determining how to respond to the accident, we likely would have missed some important benefits and probably would not have taken the actions we needed to take. A Fukushima type event is very low probability. So when you run the numbers, it is difficult for even common sense steps to pass a cost benefit test that looks exclusively at quantified benefits. In fact, it's not clear that any of NRC's major post-Fukushima requirements that had brought support would have passed such a test. The commission required mitigation strategies and initially hardened vents as necessary for adequate protection of public health and safety, which is an exception to the back-fit rule. Spend fuel pool instrumentation was required under an administrative exemption to the back-fit rule. As a result, none of these safety enhancements were subject to a cost benefit analysis. A narrow focus on quantified costs and benefits probably would have resulted in NRC taking no regulatory action at all after Fukushima. I don't think many people believe that would have been the right outcome. There's nothing new or novel about including a qualitative discussion of unquantified benefits and costs in a regulatory analysis. Under executive orders and office management and budget guidance, it is well established that quote, a complete regulatory analysis includes a discussion of non-quantified as well as quantified benefits and costs. And that has been the long-standing practice at NRC. Many of our security emergency preparedness and radiation protection requirements result in significant non-quantified benefits. Take security as an example. No one can accurately calculate the odds of a terrorist attack on a specific nuclear power plant. So the benefit of having security at that plant can't be precisely quantified. Does that mean there is no benefit from having security at nuclear power plants? Of course not. Disregarding those unquantified benefits isn't going to improve the rigor of a cost-benefit analysis. It will have precisely the opposite effect. Ignoring unquantified benefits would result in a skewed analysis that would almost certainly point to the wrong regulatory outcome. I think we intuitively know this to be true. Not every regulatory decision boils down to its effect on core damage frequency. As chairman Burns discussed yesterday, regulating is a craft. It's not a rigid formula. Defense in depth matters. Enforceability matters. Public confidence matters. Those benefits cannot be quantified, but they must be factored into our decision-making. Power plant decommissioning is another area where I believe we need to look beyond easily quantified risks. In the last few years, five U.S. reactors have permanently shut down and three more have announced plans to close in the near term. When a nuclear plant shuts down, it's a big deal for the company, for the employees, and for the community. It also changes the risk profile of the plant and the contours of NRC's regulatory oversight. But NRC does not currently have regulations specifically tailored for this transition from operations to decommissioning. As a result, licensees with reactors transitioning to decommissioning routinely seek exemptions from many of the regulations applicable to operating reactors. I see two main purposes for the decommissioning rulemaking effort that is now underway, and both are important. First, it will allow NRC to move away from regulating by exemption in this area. The exemption approach isn't efficient for anyone, and it provides no opportunity for public comment. And second, the rulemaking provides a chance for NRC and all of our stakeholders to take a fresh look at our decommissioning process and requirements. Stakeholders have strong views about important questions like the appropriate role of state and local governments, whether NRC should approve a post shut down decommissioning activities report, and the appropriateness of the three general decommissioning options and the time frames associated with those options. The rulemaking process gives us an opportunity to benefit from a range of stakeholder views. I don't know what the ultimate rule will look like at the end of this process, but I do know that we need to thoughtfully consider the ideas presented by stakeholders with an open mind. Let me turn to an organizational issue that is a major focus for the commission right now, Project AIM. The agency is implementing Project AIM to increase our efficiency and agility while remaining focused on our core mission of protecting public health and safety. The goal is to implement NRC's existing scope of work more efficiently, to identify any outdated and unnecessary initiatives, and to adjust to declining workloads in some areas. Project AIM is not about relaxing regulatory oversight of licensee performance and safety. The NRC staff has done a tremendous amount of work to generate a list of 151 proposals that would reduce costs in the coming months. The commission is reviewing those now. I think the vast majority of these items are going to make a lot of sense, but I'm going to take a hard look at these measures to make sure that none of them could compromise NRC's ability to carry out its safety mission. We'll also soon be considering additional options for streamlining our processes and procedures to allow the agency to do the same work with fewer resources. We appreciate all the suggestions and feedback we've received from those who work at NRC and with NRC. Before we turn to questions, I owe some of you a thanks for your hospitality. Since last year's RIC, I've had the pleasure of visiting a number of operating reactors, new reactor construction sites, a decommissioning site, a research and test reactor, a fuel cycle facility, a low level waste facility, and materials licensees. And I'm planning additional visits this year. I get a lot out of every site visit seeing equipment and conditions firsthand and talking directly to our resident inspectors and the workers and management of the facilities. So I look forward to reconnecting with many of you during this conference and meeting some of you for the first time, either here or in the field. With that, I'm happy to take any questions you may have. Thank you. Thank you, commissioner. We have a few questions so far. And if you have additional questions, please avail yourself of the cards that are being locked up and down the aisles. First question builds on your remarks on decommissioning. And it deals with your views on safe store and whether you're comfortable with NRC's current policy on that topic. Well, I think I think this is exactly the question or one of the questions we've asked the public in the advance notice of proposed rulemaking. And I want to get public comment on. I think stakeholders have a range of views on this issue. My understanding this was obviously before my time when the regulations were initially established in the 60 year time period was established. The thought was that that would basically allow for decommissioning to start in about 50 years after the shutdown. And at that time, the amount of low level waste would have reduced dramatically, I think by around 90 percent and radiation levels would have also reduced significantly down to about maybe 2 percent of where they were. And so I think that was the technical thinking at that time behind the 60 year time frame. We're seeing some plants now move at a much quicker pace. And obviously states and localities and people living in these communities have an interest in seeing that land in many cases return to productive use as soon as possible. And so I think we as an agency benefit from taking a fresh look at that. Let's hear from the public on this. We have the advanced notice of proposed rulemaking out there. I believe there are questions specifically on this topic in that ANPRM. And I'm really interested to see what we get back from that. We're also going to have next week, as I think was mentioned yesterday, a commission meeting on decommissioning and the rulemaking next week. And we'll be hearing from a number of state and local officials, community members who are engaged on these issues at the various plants that have shut down recently or are expecting to shut down in the near future. So I think we'll get additional feedback then too. And that meeting is Tuesday morning with the commission. You can tune in live and watch it via web streaming. Our related question is your views on the reliability of NRC's requirements for decommissioning trusts. Are they sufficient? Well, the answer I think is the same, really. And this is another topic that we have included in the advanced notice of proposed rulemaking and are taking comments on. I know there are a lot of strong views on that as well. And I think we benefit from hearing from the public on that. We also have to be a little bit careful on that because we have adjudications pending that are related to that question. So I'm a little bit limited in what I can say on that. Okay. Moving along to the CPRR rulemaking, you had some remarks on that in your comments and your presentation today. The questions, there's several questions here. One has to do with didn't the commission receive an ACRS letter on the decision to end the CPRR rulemaking? We did. We did receive one. We received it after the decision was made, but we absolutely did receive an ACRS letter on that. Okay. And then there's a related question on how do you reconcile your views on the need for containment filters with the clear results of the back fit analysis? Well, to be clear, I hadn't reached the conclusion that filtered events were appropriate. The argument I was making or my view is that at that stage in the process, that very early stage in the rulemaking process, we shouldn't have taken that option or any of the options off the table before getting public comment on them. And, you know, particularly, I think that's generally true, and you may have noticed that it's kind of a theme of my remarks. I place a lot of value on getting public comment on proposed agency's actions, either at the proposed rule stage or even earlier, whether it's on a regulatory basis, most likely what it would be, I think there's a lot of value in that. And I don't think that we have to have everything figured out at the point where we get public comment on something. I agree that it's important to have a well-baked thought through product to put out public comment. But it's not, I think, uncommon at all for agencies to be exploring different possibilities of how to approach an issue, having not reached, obviously, a final conclusion. That's just the proposed rule stage or even earlier in the process. So I think it's a good time to get public feedback on both specific proposed regulatory actions, but also the accompanying regulatory analysis. There are, I think, often going to be insights that folks will have about cost benefits and how we approach those in a regulatory analysis. And I think we benefit from that as well. So I think, particularly, though, in the context of the filtered vents rulemaking, there was a really clear expectation, I think, at the time of the commission. Again, this is prior to when I arrived at the commission. When the commission decided to go down the rulemaking path there, I think there was a clear majority at that time for at least taking a close look at filtered vents and whether that made sense as a requirement. And I think there was an expectation, therefore, among our stakeholders that they'd get a chance to weigh in on that, that there would be a proposal at some point that at least addressed filtered vents and that they would have a chance to weigh in on. And I think it was just the wrong approach to not give them that chance to weigh in on that important question. It's a tough one, though, because once you get to this stage of weighing the pros and cons there, we all face the reality, which is a positive reality, that the likelihood you would need a filtered vent is very, very low. It's a very low probability situation. On the other hand, in the event you've found yourself in that situation, a filtered vent would likely have a really huge impact on the amount of radioactive material released. So I don't know. I haven't reached a firm conclusion about how it would have come out on that, but I have reached a firm conclusion that it's something we should have asked people about. OK. Here's a couple of questions that pertain to quantitative and non-quantitative analysis. A questioner notes that quantitative analysis has generally clear methodologies upon which practitioners generally agree, whereas qualitative analysis can be more open-ended and somewhat ambiguous. Do you have suggestions for good practices that should be followed in conducting qualitative analysis? And then there's a similar related question about incorporating non-quantifiable benefits into regulatory cost benefit analyses. And what about including non-quantifiable costs in those analyses? Should it be a one-sided analysis or should it be more of a balanced analysis? Absolutely. I agree with that. And we need to look at both quantified and unquantified costs and benefits. My view is we need to be weighing all the costs, all the benefits. And in an ideal world, you would perhaps be able to quantify everything. I mean, that would be the easiest way, I think, to weigh the pros and cons of a potential action. But in the world in which we actually live, you can't quantify every benefit. You can't quantify every cost. Although I think the quantification on the cost side tends to be a little bit easier. But I would acknowledge there are costs you can't quantify. We absolutely should consider those in our analysis of the pros and cons of a proposed regulatory action. And so going to the question of do I have suggested best practices here, fortunately, that's something that is being developed. The commission agreed that with the staff recommendation that the guidance that we have for cost-benefit analysis should be updated. And particularly with respect to the qualitative piece, to make sure that we're providing our regulatory analysts with a good best practices guide. How do you evaluate qualitative factors or how do you qualitatively analyze a non-quantified benefit or cost to make sure that we're clear about how that's being done. We're transparent in how we're identifying those, how we're weighing them. And we need that transparency. We need it all laid out, both for the decision-maker, because we're going to be trying to weigh the pros and cons, but also for the public and for interested stakeholders so that everyone who's following a potential action can look and say, OK, I understand how the staff came out on this. They've looked at defense in depth, and they're weighing it in this way against the quantified costs, for example. So I think we need a lot of clarity on that. We need a lot of transparency. It's true that for benefits and costs that cannot be fully quantified, you have the challenge of how to weigh that. And there's no one answer to that. There's no simple answer. And that's really where the judgment of the commission comes in. That's why you have five or four or maybe three commissioners to weigh those pros and cons in a transparent manner and come to a decision. But I think, I guess, if you take something from my remarks on that discussion of quantitative factors and qualitative analysis of unquantified or non-quantified benefits and costs, it's this. I think we need to look at all the costs, all the benefits, whether we can quantify them or not. And I don't think we're going to get to a better result by discounting entire benefits just because they can't be quantified. I don't think that's going to lead to the right result. I think that's where you get the skewed analysis. OK, thank you. And I did not write this question as the director of research. But with respect to plant decommissioning, is there value to be obtained by collecting materials and components from decommissioning plants to use in researching the effects on operating plants, particularly those who seek subsequent license renewal? Do you have an opinion on that? I don't have a strong view on that. I would imagine, I would suspect the answer is yes. The answer is yes. Thank you. In fact, we're doing that. Here's a question dealing with spent fuel storage. What's your response to concerns that the continued storage rule, generic environmental impact statement, does not adequately address broad safety concerns at nuclear power plants? My response is that the DC Circuit Court of Appeals is going to decide this question. I was actually, I went to the oral arguments. This case is pending before the DC Circuit right now. I went to oral arguments, I guess, a couple weeks ago. They were fascinating to watch. And we'll see what the DC Circuit decides. I think that the general approach of having a generic environmental impact statement makes a lot of sense. I was not here for that decision. But it's clear to me that whether we landed in the right spot or not is going to be decided by the federal courts and we'll see what they have to say on that. I do think it's worth mentioning one piece, which is related, because we do get questions about this, which is, is the continued storage rule the agency's endorsement of leaving spent nuclear fuel on site indefinitely? And I don't think anyone views it that way. And they shouldn't view it that way. This is really an analysis of the safety of doing so. And the agency's determination that it's safe to do so is not an endorsement for doing so. It doesn't mean we think it's a good idea. I'm not aware of anyone who thinks that's a good idea. So I think that's something that's worth mentioning in that context, in that broader context of safety. OK. And in a similar vein with an election in progress and a new administration expected in 2017. There definitely will be a new administration. Yes. That's not the question, though. So the question is, would you support congressional funding for Yucca Mountain licensing to proceed in the new administration? Yeah. I don't know the answer to that question, in part because I do not know what that administration will look like. I can tell you that I have not supported it in the past for, I think, primarily the simple reason that I don't see how our licensing process, our adjudicatory process, could function well in the absence of an applicant that is committed and engaged in the process. We have, I believe, 288 contentions pending that would need to be addressed in an adjudicatory proceeding. There may well be additional contentions that would be filed. And so that is, I think, clearly by far the largest adjudication this agency would ever conduct. And of course, typically with an adjudicatory proceeding, we have an applicant who wants the license and is going to engage very seriously in what is really an adversarial trial-like process. And in my judgment, we don't have that here right now. And in the absence of that, I don't think it makes sense to seek funding for that process. OK. Beginning with the end in mind, what would you like to see as the hallmark of your service on the commission? Wow. I don't know. I just started. Christine Svinicki says, don't answer it. And I'm going to take your advice. I'm not answering it. I've taken a pass. Perhaps your jokes for the. That's right. I don't know where I'm sitting in the bar. I'm going to set it higher than that, though. Should the NRC consider requiring periodic safety reviews in accordance with the International Atomic Energy Agency guidance in order to more formally capture recommendations and evaluating newly developed approaches on external hazards? Well, let me answer it this way because I addressed this a little bit. I do think that one of the tier three items we have is the question of basically staying current on the science related to external hazards. And I think the staff recognizes that's important. And I agree with them. It is a very important thing. And so the staff this year is going to be taking a look at how to address that question. When the near-term task force looked at it, I believe they recommended a periodic, every certain number of years, check of external hazards to see was there new information? Did we need to re-evaluate an external hazard, a given external hazard at a site? And what the staff's looking at is I think potentially a better alternative. We'll see what they come up with over the course of the year. But they're looking at something that's more akin to really continuous reassessment. As I mentioned in my remarks, I think a recognition of the fact that historically the agency's been very interested in new information about external hazards. But we haven't necessarily been proactively seeking it. We're not going out to find actively is there new information we should be considering about the flooding hazard at a site or the seismic hazard at a site? And I think it makes a lot of sense to be more proactive about that. And so then that raises the question about what's the right construct? Do we have a system where every certain number of years we do a formal re-evaluation? Or can we come up with a process that on a more ongoing, continuous basis ensures that we're gathering that information, considering that information and acting on it, if necessary? I don't know what the answer that is. I want to see what the staff comes up with. I'm definitely intrigued by the idea of something more continuous and ongoing rather than something more periodic. Both because I think it could be potentially more effective if we're able to do that right because you don't have to wait large chunks of time to find out if there have been changes in the science. But also, I think, as we're thinking about efficiency, one could certainly imagine if we set five or 10 or 15 years as the re-evaluation of various external hazards at every site in the country, that is a significant effort. It may make sense to do that, but there may be ways to do it that would be more efficient. So I'm eager to see what the staff comes up with on that. I think they have been really forward leaning on this in their analysis that they sent up on this Tier 3 item. So I think they're going to I'm hopeful they're going to come up with something really good there. The questions keep coming. Oh, great. This question deals with your remarks on wanting to use the rulemaking process to provide an opportunity for stakeholders to comment on various proposals. Can you point to an example where, in your view, receiving those comments had a significant impact on the commission's decision-making? Boy, I'm probably the wrong person to ask that question too, because I haven't been here that long. And in my time here, we've had a number of rulemakings that I've weighed in on or been a part of the decision-making on. But because of the nature of the rulemaking process, it's a bit longer than the year and a half I've been here. So I haven't seen anything from start to finish on that. But I do know, just in some of the rulemakings I've seen since I've been here, I've seen significant modifications from proposed rule to draft final rule. And even, I think, in cases where there have been significant modifications from a regulatory basis to a proposed rule. And so I think there's no question that there are times where we do that, where we get a lot of good feedback on something. And I think that's going to be aided by one of the steps. This isn't directly a response, but maybe not directly. But I want to add it, which is a good step, I think, that commission took prior to my arriving, which is a move towards making sure that when we put out a proposed rule, we also put out proposed guidance with it. And that wasn't always happening historically. I think that the main benefit of that, well, I think there are a couple benefits of that, I think if stakeholders have an opportunity to look at the proposed guidance, the more detailed guidance, at the same time they're contemplating comments on a proposed rulemaking, they're going to better understand where the agency thinks it's heading or proposing to head. And that also relates back to the cost piece and our estimates of costs. I think if licensees have a better understanding of what it is we're proposing to require in greater detail, it's much easier for them to provide us good data on, well, what would that cost? If folks don't know where we're heading on something in sufficient detail, it's much harder to gauge how much is it going to cost and apply. So I think that's another, I think that is an improvement in the rulemaking process that we've had in recent years. And it's playing out. I think we'll see the benefit of that. But I think it's something that's going to both increase the quality of the comments with respect to the substance of the proposal, but also with respect to the analysis of costs and benefits of a proposal. OK. The commission has recently received the results of the Inspector General's Safety, Culture, and Climate Survey. And there's also been recent reporting on a 2.206 petition submitted by NRC staff members. What's your view with respect to this trend? Well, I have been here long enough to have benefited on numerous occasions from the thoughtful comments I've seen raised in non-concurrences or in briefings where folks have raised different views. I don't know that I'd seen a 2.206 in the time I've been here, but I don't think that's unprecedented either. I think that we have a variety of mechanisms to hear from staff who have views other than the prevailing view. And I think it's just really valuable. There have been a number of papers we've had where we've had one or more non-concurrences. Sometimes non-concurrences with lots of employees on them. Sometimes non-concurrences with senior managers on them. And I think it's been really, really helpful. It forces all of us, allows all of us, to dig that much deeper into the paper, to really understand the different perspectives people have even within the agency about a proposal or a topic. And I think we benefit hugely from that. Let me give you one concrete example of that, which is on one of the post-Fukushima issues, which was flooding analysis and how we were going to approach that as an agency or how we were approaching that as an agency. And I think there was a general view that the flooding reevaluations that our approach to that was just going a little bit more slowly or maybe even a lot more slowly than had been anticipated, that it was becoming a much bigger job than maybe had been anticipated when we set on that course. And I think what we, the staff was struggling with this, but I think the commission struggled with it as well, which is how do we balance making sure we do a rigorous analysis that needs to be done of flooding hazards at sites? And how do we also make sure that the process is moving in a timely manner so that we get to the end result? You know, if we're going to have, and I don't know if we're still in this process, but let's say we had a few plants that would benefit from additional safety enhancements, we didn't want a situation where it was just years and years and years before we got to that point. And so I think there were a lot of non-concurrences in that case. People had very strong views in different directions on it. And as we, at the commission level, waded into that, hearing those different views was just really, really valuable. I don't know that we could have done the work we did there to kind of have a constructive way forward and a slight course correction there without hearing that wide range of views that we heard within the agency. On the topic of the IG survey, that was one thing that I heard from that survey that really concerned me. I didn't want to hear that, well, I want to hear, but I was disappointed to hear that folks weren't necessarily comfortable using that process or were concerned about using that process. I don't want any employee at this agency to feel that way. I want everyone to speak up if they have a concern. This is a safety agency where safety culture is incredibly important. We have an open environment and we need to hear those views. If people have them and they're worried about something that's happening, please avail yourselves of one of the many processes we have at this agency for expressing that concern because that's something we as decision makers want and need to hear. Good answer to conclude your question and answer period. We want to thank the commissioner for his great responses. Thank you.