 Alright well good afternoon everyone and welcome to the regional session I'm Commissioner Jeff Baron and I'll be your moderator today for the past four years I've been trying to get to this session which everyone always raves about I never managed to do it so this year to make sure that I attended I decided I would moderate I volunteered and they agreed so I'm thrilled to be here one of the best things about this session is that there are no opening statements or long presentations it'll be a hundred percent Q&A with the panel so we can focus on the issues that you're most interested in we'll be passing out cards for your questions as you think of questions please fill them out and send them up to get things started I have some pre-prepared questions but we're really coming out on all of you to come up with questions to sustain a good discussion because it's a big panel in most cases I'll ask one of the regional administrators to respond and then invite one of the licensee executives and our public interest panelists to weigh in if they have any thoughts on the topic but other panels feel free to jump in with a different perspective or a brilliant point that they want to make let me start by introducing our esteemed panel first our four regional administrators from our region one office outside Philadelphia we have Dave Lue from region two in Atlanta we have Kathy Haney Darrell Roberts is here from our region three office outside of Chicago and Scott Morris is our region four administrator from Arlington Texas we are also lucky to have executives from two of our licensees joining us Dukes chief nuclear officer Preston Gillespie and Tim Powell president and chief executive officer of the South Texas project nuclear operating company rounding out the panel we have Dave Lockbaum independent safety expert who until recently was the director of the nuclear safety project at the Union of Concerned Scientists I know we're all looking forward to hearing a range of views on various topics so let's just dive right in with the first question and get started first topic first question relates to trends and inspection findings since 2015 the number of nationwide inspection findings has declined from 821 per year to 457 per year that's a 44% decline all four regions have seen this trend in inspection findings what do you think is driving the significant decline in inspection findings has the threshold for more than minor findings increased and do you see this as a positive or negative trend maybe we'll start with Scott Morris thank you Commissioner so this was one of the pre-prepared questions and in anticipation that many of books would be interested in in a response and so I want to give you my perspective and I would invite my colleagues and others to chime in as they feel appropriate you know I think I've a number of thoughts about this you know it's true the number of findings overall have gone down the bulk of those are white findings as you would expect I mean green findings as you might expect white findings and above have tended to be pretty stable in terms of over the years there's no no substantive trend but when you look at the green findings there clearly has been a reduction and I think you can attribute that to a number of things but not the least of which is the fact that we as an agency and when I was the director for Durst which is now in the good hands of Chris Miller in NRR we took a hard look at this and admittedly prompted by the fact that we had some external auditors take a look at our program GAO in particular issued a report about the the range or that the I guess the inequity of the number of findings across the four regions and it prompted us to look into that and we did did quite a bit of work on that survey wise etc and ultimately what we concluded was that the real issue that was driving the disparity was how the different regions interpreted the minor more than minor criteria whereas one region might be presented out of facts would reach one conclusion about whether a particular issue found would be considered minor another region presented with that same fact pattern might reach a different conclusion in my region in particular has been I hesitate to use the word outlier but certainly for the last several years it's been the highest in terms of per unit in terms of find a green findings now it those numbers all have gone down which the commissioner mentioned and I again I think the reason is in part because of the actions we took starting at the program office level a few years ago but continuing to resonate throughout the industry through leader senior leadership discussions down to our first line supervisors and ultimately to our inspectors in the field about really really asking themselves about whether or not something is in fact should be considered minor and I just think by simply shining a light on that when we when our folks raise issues has caused the added level of consideration and subsequent interactions that they have with their supervisors to you know to start to drive those numbers down and I think we've seen that I also want to give credit to the industry to I don't have hard data on this but I think it's it's fair to say that there have been a lot of modifications made to facilities hardware equipment components programmatically that have continued to drive risk down so that one issues do arise and they get evaluated their overall risk numbers are down because the plant is the issue less risk significant because of some of the changes that I made so I think it's a combination of us focusing more on the issue making it making the company having a much more robust conversation about what is minor or what is more than minor the cross regional discussions we've had at senior leadership levels all the way down in counterpart meetings etc it's shining that light and combination with the safety enhancements that have made at the plant I think ultimately that's what's the result of what's driving okay Tim do you have thoughts on this one yes I do I appreciate Scott talking about our improved performance that is what to me with the key the industry has worked very hard at improving overall performance we've done a good job there's a every study that came out that shows that over the past five years the core damage frequency has improved over that time period and that improved performance along with the maturity of the reactor oversight process has helped to improve the differentiation between the minor and more than minor issues I think that was really driving the decrease in the numbers more than anything else and there was some that asked whether or not we saw this as a change in how the inspections will be in performed and I have not the inspectors are just as diligent as they always have been they show up and do the entrances very thorough inspection and then the exits what I have just noticed is the change in the conversation on the driver behind minor and more than minor okay anyone else want to chime in on this one commissioner if I could just to kind of close on that I think they're actually I think to the industry's credit I mean I know that there's the conversation around more than I mean they're the industry and the sites that we regulate and inspect aren't shy about pushing back either and I think we've seen some of that as well particularly in this conversation about what's minor more than minor and folks at the licensee folks asking the inspectors you know directly how does this how does this compare with the criteria and how did you arrive at the decision you did that it fell on one line one side of the line and the other so I think again it's it's more about defining what that line is and then perhaps you know the industry challenging vectors as well as us being more introspective about it is I think it's a combination of all those things and just a very very quick comment I think regardless of whether it's minor or green all issues all violations all corrected they are required to be put into the corrective action process so a lot of this is consistency I think consistency does create greater credibility for the agency is it this is the there's a paradox I think when we talk about these minor more than minor because by definition we're talking about very low significance issues by definition and so in the interest of being risk informed and applying resources to try to you know you know be good much more consistent about making those decisions across all the regions you know that takes resources to kind of balance and venture and and so but and so it's a little bit of a paradox because it's a very low safety significance by definition and we're spending resources to try to get better at it so there's a that's one argument to do nothing but then the other argument is yeah but we're we profess to be and we aspire to be as reliable and consistent as we can possibly be that's one of our principles of good regulation and so if that's our interest then it we do need to invest energy in this to try to get better across the board so okay let me ask a couple questions on the impacts of potential power reactor shutdowns in the last few years seven reactors have permanently shut down licensees have announced plans to shut down up to a dozen more reactors by 2025 how does the reduction in the number of operating reactors affect nrc's regions and how do you think the regions should adapt to this reduction so I think this morning a session touched on this in a insolved way the chairman and the EDL both talked about transformation as one decision at a time and I think you know for region one we do have a number of plants impacted and that we have been making one decision at a time and we've made many decisions for the last few years since the announcement of some of these plant shutdowns and and as we make these decisions I think it's with an eye toward being positional for multiple scenarios these scenarios may be near return some may be further out I think the other thing I heard this morning and you may have heard this morning is nrc has declined by 25 percent since 2010 in region one since 2015 four years ago we went from 229 FTE full-time employees to 183 that's a 25 that's a 20 percent reduction in the four-year period so certainly a lot of decisions that we've been making over time has has to do with people but it's not just people I think it's how we do our work how we leverage technology how we more efficiently use office space and those types of the decisions the results of those won't be known for a while because we're trying to position ourselves for the future I think one of the other things that we look at very closely is making sure that we do them have the right skills the right competencies for the right work I was talking to Jeff place earlier this morning and it just occurred to me as we were talking I'm not sure how we came came talking is you know an example of a decision that we made in region one TMI had now this closure September of 2019 and so we've made decisions and plans over a year ago it's interesting as time has gone by you know our ongoing assumption was that they were gonna likely shut down in September of 2019 well that's not all that clear to us now as we're as we're looking at the environment as we're looking at these changes and multiple scenarios one of the things that we have to deal with is we have residents at the at the site and the residents have families kids go school and so it's very difficult for them to know whether or not they stay or not and I think it's that uncertainty so one of the decisions that my management team was proactive they actually reached out to the TMI residents and guarantee them a year of work at home after 2019 this provide them certainty and I think no those types of decisions to to account for multiple scenarios allow them to focus on safety and security allow them to take care of their families I think it's a win-win situation so there's a lot of these decisions how have we done don't really know because we continue to make a lot of these decisions they would they will not stop and the results sometimes are delayed but that said I think we have been maintaining our safety focus safety and security focus I think the residents inspectors to have transition or backfill near plants that were showing down that has gone seamlessly and this is based on feedback from both inspectors as well as licensees in fact one licensee most recently made a comment to me that they could not have done a better job I think the other thing I would want to highlight is based on surveys staff engagement remains one of the highest in the federal government despite a 20 percent reduction of staff in four years so again I think it's similar to transformation it's one decision at a time that positions us for multiple scenarios Tim do you have thoughts on this one yes as he was just stated as the reactors are shut down the RC scope is by definition changing and with any corporation as things change you have to change your organization in your process to match whatever your current scope is and it's very important that we make those changes in a manner that does still focus on the safety and reliability of the stations more of the safety aspects from the NRC's concern more the reliability from our concern I mean we're also being impacted because in the ERCOT markets very challenging I've had to adjust my organization and my processes so that we can continue to produce power in a safe and reliable manner likewise the NRC will need to adjust their organizations and processes to fit the scope the one thing I would really want to avoid in all this is as the scope changes that there's no not a necessarily a change or an increase in the recoverable fees adding to the burden on the stations just because the other stations are shutting down it's more important that we get the proper resources adjusted within the NRC and the fees remain flat throughout the period of change Dave I think in the environment that the plan owners are in with such significant cost pressures to control costs I think the NRC needs to look at its oversight process in that environment the NRC's oversight process tends to focus on actions taken by plan owners modifications to the plan tests and inspections changes to procedures and whatnot more and more plan owners are deferring or canceling more and more activities I think the NRC's oversight process needs to include a parcel that looks at those decisions to defer or cancel activities to ensure that they're properly justified to make sure that the safety and reliability doesn't fall as cost cutting proceeds and I agree with that Dave I do agree with that I think we have some experience in learning about plans to have announced shutdowns I do remember back way when Oyster Creek the first time announced their plan shut down and there are lessons to be learned from that I think we incorporate a lot of those lessons and still more for us to learn into our inspection oversight and we have an appendix gulf and I'm not sure what the title of that appendix gulf is in our manual chapter that looks specifically at plans shutting down that focuses on our scope that focuses on retention of licensed operators work you know work control and backlogs so I think it's another I agree with you that's an area that we need to really focus on because it's a change and we'll continue to learn from that let me brought it out of slightly on the second question this area in this dynamic environment what single change would you most like to see happen and what single outcome would you most like to avoid folks either chime down the last one or else wants to express a view on that Kathy so I I'm gonna pick up on something that Dave said I really think the the focus either and I can turn this either a good or a bad direction answer both of them it's really focusing on the critical skill sets and having the right individuals the right inspectors the right license reviewers the right individuals in research working on a project at the right time to meet the needs to meet our needs as well as the industry needs so it's really that focus on the people that I think is so so important in what we're doing yeah the thoughts of this one I think the single change if I king for a day I get one change it'd be the NRC safety culture needs to improve the numbers that the NRC's had for the last five ten years or as bad as Davis best see in its worst millstone in its worst TVA watts bar in its worst but nothing is being done to fix the NRC safety culture they're seeing those what those fixes are because it required them to be done to those plants but it tolerates as bad or worse safety culture eternally that's got to change I guess I've just had you know one of the things I think is it's not so much a change but maybe in the area that we can improve better is communications I think it's always a challenge whether it's on-site with inspectors whether it's the regions with the program office whether it's with the NRC or the industry I think what I see a lot very often is you know while we may communicate 80% not very well it's that 10 or 20% but we don't communicate very well that it results in a significant amount of time resources attention being drawn away and you know quite frankly it can also detract from safety as well I think relative to things that I want I would definitely want to avoid similar to what Kathy says I think we need to make sure that we have the right skills the right competencies to be a credible regulator okay well maybe we'll turn to potential reactor oversight process changes we're already getting some questions from the audience on that as part of the current conversation on transformation at NRC staff is considering potential changes to the reactor oversight process how do you think the NRC staff should approach the many suggestions for changing the ROP that have come from within the agency and from external stakeholders are there suggested ROP changes that you see as particularly good or particularly bad ideas and we had a question for the audience what do you think are the most viable changes being considered for our P maybe on this one start with Dave Lou and then get Preston's thoughts as well those a lot of questions actually I was so wondering like a big compound question was actually I was so wondering do you want to switch places I think this question but I I think how we want to approach things is we do want to approach things with an open mind I think that's important because I think that's part of part of innovation is being receptive to ideas I think even if you you know you may have a reaction to an idea if you just stopped you know take a step back and look at what's the underlying driver for that for that recommendation or that view I think you'll find that there will be value as you integrate into your overall assessment I think one of the RP enhancement there's a lot of a lot of issues out there I think maybe I should probably touch on hot topic one and that's why findings and you know this is and I was trying to keep this short the two points because I'm sure a lot of people may want to weigh in on why finds by this see a public interaction engagement last week on on white findings and on the RLP enhancement one of the things I've noticed is that we're not very clear in our definition of terms and use of terms we seem to sometimes use core damage frequency core damage probability CDP the same as Delta CDP and there is a difference and when we talk about white findings we're talking about the risk contribution for performance deficiency that's identified as site and while that may be considered low I think it's also in the context of what that what that finding is in because the plant risk changes over time we recently had a white finding in the context of the white finding there was also another safety equipment that was our service that equipment was our service because of a deficiency although there was not performance deficiency there was efficiency and what that when you layer that over top it's not additive and it's much closer than to the quality of the safety goals so I think that's a perspective that we need to sort of think about relative to what we're measuring with a performance deficiency the other thing which and probably a more important point at least for me is I do agree that plants are safer than no than ever modifications and and other things have lower risk and so from the perspective of the threshold for white findings okay a plant that actually reaches that threshold now has a lot of things have to have gone wrong a lot of holes have to have a line and and so when we take a look at that and reaches that threshold you know there's two questions one of the performance is getting better and we're maintaining the threshold the idea of raising the threshold is not intuitive to me the other aspect of it is if a lot of holes are matching up the question that we have to ask is this this isolated was this the stem systemic we need to ask that question I think when we look at operating experience we've had two plants that have gotten to column four that there's perry and pull them just on white findings and so there were systemic issues and I think when we look at the underlying basis of the reactor oversight process there has to be a vehicle in which we get to that to those issues for those outlier plants so you know I think you know there's a lot to be there's a lot of other issues associated with it I'm sure there's a lot of perspective so I'll just stop there and have others chime in and weigh in I mean certainly the ROP has been the most impactful process on on our day-to-day operation I think you look at if you look at the results it's produced it's by and large been a force for good I mean it's been effective it's improved safety and it's been around for 20 years I would say though what what tool have we used for 20 years what process have we used for 20 years and then turn around say there's not some room for improvement there's not something we can do to make it a force for better good you know I think it would be I think it's entirely reasonable for us to optimize the ROP and working a way that can eliminate any of the redundancies it creates it act we could aggregate the efficiencies that exist within the process you know perhaps more importantly make sure that the ROP is is being used is being used for the benefit of safety and not the benefit of you know expanding or or or making larger some new regulation or some some new rule and you know when I look at the when I look at what we get out of it you know I just I've got a I've got a finite amount of resources and I'm going to invest them in something time energy money and am I going to go and I want to invest and chase low safety significant issues that I can fix quickly or but we're too focused on that at the expense of something that perhaps is bigger in the in the operations and I just I just think the ROP ought to be continue to be used as a force for good and continue to make sure that we're focused on improvements in real safety I want to get Dave lock bombs too but Preston is there if you're thinking about the universe of potential changes what would you have at the top of your list is like the thing that you think would be most beneficial for a change well we talk about white finding so you know I'll move heaven and earth to avoid a white finding I have spent countless amounts of dollars where we end up in some you know frothy area about some tiny number it's not changing a single action I'm taking all the students taking more time you know for me to complete it we treat a white finding just like we do any other findings and I again I think that I think that detracts I would like to get to where you know how you move across the columns I think is there's a good way of doing that you know the white was kind of that great in between and I just think there are opportunities where you know I thought it was interesting we talked earlier about you know green findings the number of green finding you know the number of you know what are significant findings what are less significant NCVs you know we count the findings but in the end I capture comments in my career they only have to be a finding me to act on we capture the comments and in the end once it enters into the corrective action program that the color of the the color of the driver kind of goes to the background we were compelled to at least we feel compelled to fix it so here just the baggage that goes along with this with this white finding it slows us down it slows us down and it creates a level of attention that that's not commensurate with the safety significance I put that one at the top of my list commissioner Dave did you want to share some thoughts I think the ROP in the maintenance rule two of three best things the NRC's done I think the ROP offers their model to be applied to changes to the ROP the ROP uses performance indicator supplemented by inspection findings as its key drivers similarly changes the ROP could be monitored for effectiveness using either metrics or annual periodic assessments to ensure that the expectations that everybody had for improvements or optimization have actually been achieved and without any unintended consequences so I think using the ROP model to evaluate changes to the ROP could get that to the endpoint that we all want any other thoughts on ROP changes yeah Scott were you so I just want to I appreciate respect Preston's comments and and I've seen that not just it's not just an anecdote it's true that the moving heaven and earth to avoid a white finding and not to be overly provocative here but I guess you know as one of the founding members of the working group who created this thing we now call the ROP and the process that we went through collaboratively with the industry granted it was 20 years ago and with Dave and other externals and members of the public the idea was you would have a graded approach obviously and that you know there would be some threshold there would be thresholds built in that would enable the regulator to gradually and to increase its oversight posture as more risk significant issues popped up I guess my point is and I will also say that we have made changes to our oversight program to account for some of what you're talking about I'm not just talking about risk informed thinking in general terms of more specifically we've changed the inputs required to get to move columns in the action matrix from two to three whites for example and so part of that was to address this concern about the implications of a white finding and you know to kind of relieve some of that urge to push back so hard on a white finding which was never intended I can tell you was never intended to be this you know major thing it was expected that there would be a lot of white findings so not pushing back but I'd like to personally understand more about what why is it that the industry feels so compelled to quote to use your terms move heaven and earth on quote to avoid a white finding when at the end of the day what we're really concerned of is about safety and agreeing on what the performance deficiency is and more importantly focusing on the corrective actions that are that are appropriate and durable so it's really a it's a difference in views and I know that from the regulator side and I've heard this said what's the big deal it's a 40 hour inspection this is awkward that we're just sitting here talking the audience didn't push back but they but you know you know it's a 40 hour inspection when in fact it's so much more than and the fact that you know how we move across the columns it's a step in the right direction but it's still a vulnerability and in fact you could take you could take these white findings and put them together and they might not equal anything but just the fact that they exist now when further some bigger problem and I would tell you that if you aggregate if you if you go across the way and you aggregate white findings and that starts pushing you across the columns something else has broken down in our monitoring something else has broken down in our assessments that have that has allowed that to happen I mean you've had root causes that have looked at extent of conditions you've got there's something going on in the corrective action program there's something going on in the sites oversight there's something going on with the with the operation of the facility when we find ourselves you know in a position having moved across the column of move across columns simply based on white findings and I will just add to that thank you the the bit about the supplemental inspections the 40 of the nominal 40 hours you know I think it's we've done we've looked at that we're probably still looking at that to try to enhance what you know not only the nominal amount of resources but what it is we're trying to accomplish refine the procedure that's associated with a 95001 for those of you know so I think work has been fully up to speed on where we're at with all that stuff but I do believe to your point that there's room for us to improve on you know to be held more accountable so to speak on the amount of resources we spend once a white finding is identified to follow up on that so I'm not I won't I won't push back I'll go a little bit further and I agree with you that there is a difference whether it's one or two within a period of time when there's one you can you can make the argument that he's isolated but you still have to ask the question and in fact most plans to transition to column two transition back to column one I think when you do have to then you need to ask the question is there something more systemic the highlight the systemic over the the isolated and I think that's what we're trying to do and it's beyond I think as we're looking at this again input and views I think it's beyond just the number of hours I think it has to be what's the scope you know what is the scope of say one white input versus two white input because there is a difference there is a difference in terms of the belief there's something systemic going on we are and all day on this topic so probably should move on let me let me ask one more sub question on this because you're right we're totally inundated with questions and you can't spend too much more time on potential ROP changes but I did want to ask what do you think about crediting licensees self assessments and Lou of NRC baseline inspections I personally am totally neutral on this topic but I do your thoughts on it I think there's a role for self assessments but you know I think we do do it right we do do it with emergency preparedness and other things but I think there's a balance there's a balance in terms of how much self-assessment versus how much independent inspection I think there is there is also a value of self assessment in terms of trying to allow licensees to hold that skill within its own organization and that does have a overall safety benefit but again the harder question is not that I'm open to it but what's the right balance so I had a beautiful set of notes on this topic and then a set in the session earlier and I just started scratching through them all furiously you know when I look at you know life the self assessments and how they should be looked at I mean adoption is the sincerest form of flattery so if you look at what's going on with inspect we prepare we prepare for the for the inspection in fact I mean we get the inspection procedures are publicly available we use those as a template we supplement those actions that better in the inspection procedure with our own with our own preparation activities and we we come out with a better product so we find things earlier so by the time the team has arrived on site we've done we've done a lot of that work it's not saying we don't the team the NRC team will come in inspectors they still find things but you know this could be why some of the things they find are less significant than what they did before and it's because you get 40 50 years of operation under your belt you get you know all these years of inspection OE that that you've had the benefit of and you learn from that and you apply it so I'm on the other side of the fence on this one I think the fact that we're mimicking what fact that we're mimicking those activities and the fact that we do it with integrity and I would invite the regulator I invite the industry I invite our own oversight folks to come in and and test you know test whether we're performing these activities with integrity and creating a product and if you do that in the product I think we've got the outcome and if you've got the outcome and it's it's an outcome that's conducive to safety how can that be a how can that be a bad thing this is a to me this is a this is the great thing about our business is that I don't know how many other businesses where the outcome the regulator desires the outcome that the operator desires I mean they overlap there they're a shared mission this idea of safety is a shared mission and so far I would tell you that the work that we've done to mimic what the regulator has done has created better outcomes and it's driven our regulatory performance indicators in a good direction it's driven the plant performance indicators in a good direction I was initially very much against self-assessments but the working group that the NRC formed to investigate this issue came up with a fairly good model for allowing self-assessments to be in the concern I had with self-assessments was a point that Preston spoke to us we're not invited in to look NRC is invited in or is in but the public isn't so the public needs some assurance that the self-assessments is of the same rigor of the same value as an NRC inspection and what the NRC's working group proposed was to have annual inspections modules that would be done some by NRC some open for self assessments that process would allow the public to compare the results from inspections done of similar areas to see if they're similar similar detail and similar results for example the industry self-assessments had an average of eight findings per inspection the NRC found nothing which probably would happen but or vice versa that would give you an indication of what was the value of the self-assessments versus the NRC inspections but there needs to be something on the back end to allow the public to see that the self-assessments were comparable to or perhaps better than the NRC inspections absent that I'm against self-assessments if I could add I I'm all in for self-assessments we think I mean I think my counterparts would agree self-assessments are a great tool they've identified a lot of things I just don't know to Dave's point how adopting a licensee self-assessment in lieu of NRC inspection meets our fundamental principle of being an independent regulator and I struggle with that so I look for innovative ways if there are innovative ways to do it then again I think they're beneficial but and again I'm not picking on Preston but you know the self-assessments and you and you absolutely you identify your own issues and you said it yourself our guys come in and often will find more issues so there's something in that too right so there's there's value being added in in both in both camps obviously safety is fundamentally in your camp where it should be but again this notion of being an independent regulator I think we're gonna struggle we have struggled and I think we'll continue to struggle and be smarter than me figures out a way to take credit for that and call it an independent review so I I would tell you that I'm aligned with you on the independence there's I mean certainly you have to go in and either pulse sample the product to make sure that it's being done with what is being done with rigor and again it's being done with with integrity so you know I don't know that a self-assessment in and of itself needs to close the door on on independence so we have a we have a resident on site he doesn't spend you 100% of his time in any one area in the plant but he's still he's assessing the operation of the of the facility and making sure we're doing that in compliance with our with our license so I think we could work around the independence piece without you know bringing in an entire another team to basically duplicate the effort of the licensee with regard to finding things I agree with you they find things I could bring in I could create a site team and I could go bring in a second site team they would find something and if I brought them in a third time I'm sure they would find something so the you know the fact that they find things I don't in my mind is not does not mean that the does not really say anything about the quality of assessment just means that we found things if we use that we wouldn't send a second team back you find things have to go look again at the same same facility so the independence piece is making sure that the public is aware of what's going on in the in the assessments I think those are all valid concerns I think they're all concerns that are entirely solvable there I'll look like you want to go in there so I think everybody at the table here at these degrees and principle that conceptually the idea of a self assessment aspect to the ROP is something to consider and you're really talking about a self-policing how much should the industry be allowed to self-police what it does and how it operates and that's not a foreign concept to the NRC right we've instituted that in the operating licensing process where you know one at one point we wrote all the exams for operating license for licensed operators we've turned that over to the industry for the most part with the exception of one that we write for proficiency purposes team inspections I know that there's an element of our ROP and our team engineering inspections for example or are where we credit licensees or we allow licensees to take credit for issues that they identify as part of a self-assessment before we get there before the team gets there the recent paper that the Commission issued the SRM on force on force inspections where we now are going to be allowing licensees to conduct a force on force on top of the one that we conduct all of those are aspects of I would what I would call self-policing the question I think becomes or the issue becomes at least for the staff is you know what's the aggregate impact of all of that right so when you institute this this change you know how does that aggregate with the other aspects of self-policing that are already in our oversight processes and to what extent can the NRC still be involved in that right so if we do allow a self-assessment you know aspect to our oversight you know can NRC staff at the working level or the staff level still be engaged somehow and to what extent does that engagement take place so I think conceptually self-assessment is not you know alone the issue it's just you know to what extent does that aggregate Kathy so thanks I had the opportunity of being a little bit closer to the discussions about the engineering inspections last year that Dave mentioned the working group is one of my division directors was leading that effort and it was interesting for me to watch the thought process evolve over last year with regards to giving ration to the credit for the licensee self-assessment and I think a little bit different approach from my peers is I think it's the how you do it that we need to focus on and then I think at this point going back to I think to the original question is how do you move forward on this should there be a decision from the Commission to go forward on it is it's really that dialogue that needs to take place between the public interest groups between the NRC and the licensee is about how would we give the credit and how much so I think from my perspective there are a few more questions that need to be answered it's more that process oriented aspect because we have evolved a lot over the last year with regards to giving credit for the licensee self-assessment and even if you go back to I think three years ago the same panel had a discussion on life licensee self assessments and it was it was it almost I don't want to say a definite no but it was a lot more to the no side than the yes side so I think it's it's the benefit of more dialogue on this over the upcoming year we should probably move on Dave your comment earlier about NRC safety culture got at least a couple cards one one of the questions is directed at you and then there's a question directed at the regional administrators the question for you was can you explain a little bit more about your statement of NRC safety culture and what you were basing your conclusions on and for the regional administrators maybe one of you want to take this or others have thoughts just any reaction to Dave's comment about NRC safety culture well yes you should my report called NRC the safety culture do as I say not I think it's still available on the UCS website I also think it's in NRC's Adams I went through a number of case studies looking at Davis Bessie Millstone South Texas not South Texas Susquehanna Watts bar sorry he didn't kick me on you look at the numbers available that drove the NRC to take actions to address safety culture issues those plants and then use studies from the annual workplace survey that's conducted by federal agencies including the NRC and the Triennial OIG Inspector General's surveys of the NRC workforce if you look at the numbers from those surveys and compare them to the numbers that existed at Susquehanna and Davis Bessie and so on the NRC's numbers are worse or nearly as bad or worse and yet nothing is being done to fix other than hoping it fixes itself nothing is being done to fix the NRC's internal safety culture it was a big problem to the NRC when it occurred at what Davis Bessie was born these plants and yet the NRC doesn't hold a mirror up to itself to fix its own problems of equal or greater magnitude that's just unacceptable so I'll go first I'm sure my counterparts here will have something to say so from the standpoint of I guess yes I wear a Dave's that report and I guess I would take in your comment Dave relative nothing being done to fix because I think the agency over the years has done things to try and address the safety culture I'm not going to speak from the agency perspective but I'll speak from the regional perspective so within the region we really are looking at the different aspects of what can we do and a lot of it falls down to increasing dialogue and communication with our staff and over the last couple years we've done training and speed of trust training which is the Covey we've done looked at increasing emotional intelligence but I would say really when it gets down at the end of the day it's really that that face-to-face conversation that makes the big difference whether it's between the regional administrator and an inspector or a division director and an inspector but it's improving that communication that I think is is going to make the difference and I think in region two I would say it has made a difference over years and we have several other initiatives underway but I think I'll want to leave time for my peers here to comment also yeah I would just add to that speaking specifically for region three we've done a number of things to address what we think is an area for improvement I don't believe that it's I don't believe the problem is as Mr. Lockbom has stated is as dire perhaps as it was made to sound in the agency but specifically in region three we've had a number of communications about issues involving disputed violations or violations or enforcement issues that occur in region three that involve a number of differing views with that and you know honestly I think those require an additional level of communication so that staff understands you know the bases for decisions that are made sometimes it requires more I'll call it care and feeding for lack of a better word you know there are some recent issues in region three for example that were overturned enforcement actions that were you know reversed from what region three had proposed and we've taken a number of issues to communicate around that because we know how sensitive those are and in arriving at those decisions we you know had opportunities for many many opportunities for diverse views to be expressed by staff so I don't know that the problem is as dire as what was communicated but I know that we've taken actions in least this region and as Kathy has stated her region in the other regions as well to address that kind of issue so I could just add about this time last year a little bit earlier just slightly over a year ago the NRC itself we should report looking into differing views program and among the things that report found which we obtained by FOIA eventually because the NRC did not make it public was it more than 100% of those that raised differing views felt they were retaliated against for doing so 100% what score mills to any of those plants had 6% 7% saying they'd been retaliated for raising a safety concern NRC be all over like ugly on an 8% 100% of NRC employees raised safety concern felt they were retaliated against and there's he's not doing much about it well I'm sorry I stand corrected they are taking actions you're just not taking effective action to fix the problem I would I wouldn't thanks David I would echo what Daryl and Kathy mentioned and supplement it with the folks don't know the study or the report that Mr. Lockbaum refers to there actually is underway in fact just got unveiled fairly recently all the actions that we're taking the office of our Office of Enforcement owns that program we all own it but they're not only in charge of the procedure and counting and tracking and managing the overall effort and there's a lot of a lot of the new initiatives and mechanisms that were about ready to roll out to enhance the program so yes they're not visible yet but they're coming but more specific to Region 4 you know we're we've gone all in on the Franklin Covey speed of trust in Region 4 you know and I'm not gonna make you in experts on what that is but essentially it comes down to 13 fundamental behaviors that enhance trust relationships and at the end of the day in order for there to be effective and meaningful exchange of information you have to trust the source and you have to trust you have to trust the information and so we are including that language of speed of trust in our day-to-day business we we are trying to and we are asking our staff the whole leadership accountable for when we're not demonstrating those behaviors we encourage it and then when we they pointed out to us we make we make a big thank you you know I mean we and we'll share that stuff as broadly as we can and and I think more perhaps more importantly all the you know when it comes to the technical work that we do that safety work that we do our inspectors virtually every inspection is debriefed in front of their peers and their management and it allows it does a number of different things number one it enables other people to examine it makes you a better inspector and enhances your ability to articulate thoughts and ideas in a clear and comprehensive way that's number one but more I think more team it enables the rest of the staff and management to inquire as to what the issue is why it why it's being assessed the way it is and offer different thoughts and ideas and it really engenders a really good conversation around all the technical issues that we're batting around and weighing and oftentimes that results in us changing or initial the initial vector that we're on and I think ultimately it makes us better and it enhances trust and it enhances obviously communication and ultimately I think will make us continue to make us a better regulator I think any safety organization we need to as a safety organization really always have to be thinking about safety culture and how we can do better and and it's hard sometimes to measure you know but you have data points one such data point is I think I think I've been told I'm flat wrong by my staff like once a day and I'm sure after this meeting I'm going to be getting text messages that you're flat wrong Dave we've gotten some questions on specific rules or inspections let me let me start with one on the maintenance rule what are your thoughts on industry's initiative to relook at the maintenance rule and as the questioner characterizes it in the context of having better inspection technologies that can increase effectiveness and reduce costs of maintenance rule implementation thoughts on the maintenance rule and potential changes to it I mean I would say with regard to the maintenance rule the maintenance rule has overall been has been good it that points out things about your equipment and it allows you it gives you a very structured way to ensure high levels of reliability of equipment that's important to safety but again if there's a there's a way to do the maintenance rule better to do the maintenance rule more effective to do the maintenance rule with less resource and and achieve the same outcome then then I'll sign up for other thoughts on maintenance rule either it's current effectiveness or potential changes to it really all the same things we're always looking for ways to make things more efficient if there's a way to check and adjust making more efficient that's good we use the maintenance rule quite a bit because we use it as a backstop to our risk and form technical specifications because it helps give us that extra piece of information that is operating well while we're using the condition risk based tech specs and have the extended lco times to do work it helps us get that understanding that we're not for lack of a better word abusing our ability to do that under risk managed text I guess I'll just try mean I do remember when the maintenance rule came to play and we were trying to how do we regulate that from outside and I think it was a learning curve but think over time I think you know the issues and concerns have been largely resolved and just the absence of any any feedback that I get from my staff I don't know that there is a huge issue there that we need to adjust from the regulatory point of view given how many other things that we need to work on I guess I would just add echo what Dave said you know from a regulatory perspective I don't know that the maintenance rule itself needs to be changed as long in as much as it has flexibility to allow licensees to use their own risk profiles to categorize systems within the maintenance rule to manage online risk and those things if there are changes in the risk profiles at various plants then those insights if there if there been significant improvement in the risk at a site then that insight should be used to affect how a licensee might the house of how licensee might implement in terms of what systems are how systems are treated and so on but the rule itself I don't know to what extent that needs to change from my perspective we also got a question at least initially directed at the regional administrators interested in your perspective on the efficacy of the EQ program inspection well let me start so so just a little bit of history as we as we first look began when I'm back this was a few years back when I was in NRR we were challenged to you know look hard at our what we component design basis inspections CDBI's which you know by any measure is a is it is a tough inspection you know it's resource intensive it digs deep but intentionally so it was intended to be a deep dive in a couple of different areas you know whereas we tend to inspect you know this is about analogy a mile wide and an inch deep on a lot of things that happen day to day the plant this is one of the few areas where we actually took a deep dive and you know drill a borehole into an area and again I mean as the name would imply was to assess the the maintenance of the plant and its consistency with the design basis for which we you know we originally licensed it and so you know it tended to yield a lot of low significance issues sometimes it it identified some pretty significant issues but but more importantly it gave us some programmatic insights which you know I know that program programmatic inspection is somewhat of a four- letter word and on a piece base but it truly did give us insight into how well engineering programs were being you know it gave us a certain amount of confidence that the programs were viable etc but when we were challenged to examine how we conducted that inspection one of the changes we we made was to to whereas we used to do a three-week focus deep dive in a number of different areas 17 to 22 samples or 25 samples we backed off on that the two weeks and took a one and did a pilot again we don't do much without trying out first so we did a pilot one week programmatic inspection instead of the quote-unquote deep dive in the one particular system or set of components so we we batted around well what program should we look at and one of the things that came up on the list one of them was motor operated valves I mean there were a bunch of different things but how could what one thing should we look at holistically and the idea of the environmental qualification 5049 programs came up and in no small part because we haven't looked at that in a long long time and it's but but I think more importantly it was there are a lot of fundamental assumptions about what's going to work and what systems are required to work and operate reliably if God forbid a major design basis accident occurs and a lot of those safety systems that are going to be called upon to operate in that on those under those circumstances are going to be in harsh environments the sensors etc and so we simply hadn't looked at environmental qualification issues in like two decades and we thought well here's an opportunity if we're going to pilot this program here's a perfect opportunity because all these risk models that we talk about and rely on to inform our decision-making fundamentally are predicated on assumptions about what's going to work and how reliable it is and we don't test eq components under harsh environments certainly not so this was an opportunity for us to programmatically focus on eq and I think it taught us a lot we learned a lot yes it identified a lot of issues yes we've we've learned a lot yes the industry's learned a lot yes we've learned about how to manage our program and I think based on those learnings we're continuing to evolve our engineering inspections president Tim any thoughts on that I mean we've eq eq is one of those areas where I feel less smart coming out of the conversation than I did going into it's and it's almost universally true when we deal with it but my experience with eq is I value the eq inspections because you know our plants have personally benefited from many of our eq inspections it's a I can recall it's probably been six or seven years ago now where our tech staff took a position very hard position on eq we were wrong the this is in this case the inspector was was exactly right because of the inspection we had an opportunity to fix that we've got examples that goes in the other direction but certainly this is one where you know our view of whether things would work or not was different to scott's point we are going to rely on these these these important pieces of equipment under very harsh conditions we ought to know we ought to have confidence that they will work so the value of the eq inspection I'm totally in line with the way we go about it or we might have issues with long-standing URIs I feel like we get a lot of URIs on eq now that I wish the that my technical staff and the agency's technical staff could somehow get to a quicker agreement on what's required but beyond that that in no way should detract from the importance of this idea of eq qualifications on our equipment. So I would so scott did a good job at looking backwards I would say what did the agency learn from this and going forward and some important lesson learns from us there were a large number of URIs in the from come resulting from the region to inspections Preston mentioned a few of those are unresolved issues yes unresolved issues sorry sorry okay I was tested to see if you really read the new reg so we have really been focused on the eq inspections down a region to recently and we're moving forward with with resolving those unresolved items but I think there are a few things that we need to what we pride ourselves in being a learning organization and whether we call it a formal lessons learned or an informal lessons learned I think one of the key things was is when we is looking at what we learned from doing the eq inspections and should we go forward with these focused engineering inspections to try to apply some of these lessons learned and from my perspective it really is very important to have the guidance available for inspectors as they launch on these engineering at you the focused engineering inspections in developing that guidance again a very key thing is the having the public meetings where there's clear understanding on all parties on what we will be looking at and what's acceptable and then again in several of the areas when we get into these focused inspections is setting up a cross regional panels for when we do have the inspection findings again of course when inspector comes back there's dialogue within the region itself but then as we move forward if there's any potential for enforcement action what at whatever level is just to make sure that we do have consistency across the region and this this really goes to some of our cores of the consistency and the transparency so my really hope outside of doing the eq inspections and the focus on the importance for that and the safety impacts of the things that we looked at and that is but from learning from these eq inspections and then applying them to moving forward if we do go into the focused engineering areas inspections well maybe we could switch gears a little bit we had several questions that are resource related some of them for the regional administrators some of them for our industry executives that maybe we could start with the regional administrator questions and I'll just take a couple of them and throw it out at you all in a compound question and you can address those as you will one question relates to staffing in the regions notes as Dave alluded that the staffing has been reduced significantly in recent years should staffing levels continue to be reduced what is the right size and then related potentially given power reactor shutdowns what do you think of consolidation of the regions so let me let me take the last question first I think I just want to emphasize you know we talked about transformation one one decision at a time and so we would not be you know I don't focus on that particular future as the likely future or not I think what we want to do is we want to continue to do those things that allow us to be positioned for whatever situation that we come in and when you think about that when you do that it does you know where you put your resources you know in terms of you know how much space that we use how do we communicate with each other how do we leverage information technology and it's not until you get to that point and then you get to the point of trying to decide I think you have to take a look at the cost benefit all right and you have to take a look at the and it's not just the dollars but cost benefit of people of effectiveness of safety so you know I think you know that's one of those hypothetical questions which I think what we do now is we do as we are doing with everything one decision at a time that positions us well for the future and I have to talk for so long I think I forgot the first part of the question but I just remember staffing levels so so you know I think it's not you know from my perspective I think the regions are fully funded for the work that we have to do I think this agency does a great job showing that we have the right resources for what we need to do and and and the way it's done is they do take a look at the work that we're assigned and so as plants are shut down you know they recognize that we have less work and they they plan accordingly and we'll continue to do that I think and I and I don't see anything in the horizon that doesn't say that a top priority for this agency is our our inspectors out there in the field as our eyes and ears so I would so region 2 while we don't have any plants that are decommissioning in region 2 specifically what my challenge is is the new construction areas because last year we had the sudden drop in resources when summer made the decision to not go forward with a new build looking forward to a few years from now the need for construction with the Vogel site will also go down if assuming the plans go forward as southern has planned for the Vogel 3 and 4 so with that again that will have a significant impact on the region because the individuals that were doing construction now will no longer be doing the construction inspection unless there is some new build in the United States so I still am kind of a similar to where Dave has the challenge say with the decommissioning plants I have the challenge with regarding balancing the right staff within region 2 relative to new construction so I think so we all have our own unique challenges with that with that being said I think region 2 again is that we're always mindful of making sure that we have the right critical skills and available to us and that may not necessarily be individuals that are housed within region 2 because should I need a resource I have available three other regions that would be very happy to help me I think and and of course resources that could come to bear from headquarters said we do have the opportunity to reach out when we do need help and then the last thought that I would say is the thing that I really look for when we're looking at staffing is really identifying what we need to do and then we resource it where I have the most challenges is that you know and just being told you have to take an X percentage cut because I think we really need to develop the inspection program that matches goes out and looks at safety and security and from that we build what our staffing needs are yeah I guess I would just piggyback on on that on both what Dave and Kathy said that I don't have a specific answer to the question on what you know whether or not consolidation at this point is the right thing I would offer that there are a number of factors that go into that decision or that analysis one obviously is the number of plants you know down the road number of plants that are permanently shut down between now and time X another is this the ongoing changes that we're looking at now the R.O.P. enhancement efforts that the efforts to streamline our oversight and quite frankly that's you know let's be frank we're talking primarily about changes in the reactor oversight part of our mission because that makes up two-thirds of the agency's budget so obviously that's big impact on the regional structure going forward our materials program is a smaller fraction of that obviously and we have in the agreement states you know across the country so that's not changes in that area aren't going to really impact the decision I don't believe as much as the factor piece but as long as those two factors that the permanent plant operating status or the future shutdown status as well as ongoing changes to our oversight processes are in play I think those are the two main things that need to factor into our our decision on that so I'm gonna touch on the staffing piece and I'll speak to region four but I think it's germane to the other regions and perhaps the agency as a whole the thing that worries me the most well first of all let me just say this I'm biased towards inspectors I have a high affinity for for our folks in the field who are working at the sites who are doing the day-to-day safety mission in this agency I did that job for seven years so I'm highly biased towards the importance of that work we have great inspectors in region four as we do in the other three regions two of whom are in the room here with us today from region four and why do I bring that up because I am concerned and this this is a this is a legitimate concern of mine and a continuing downward pressure downward with the continuing downward fiscal pressure on our staffing and our resources which is appropriate I understand it it makes sense the practical implication of that has been till now that we are not bringing in at a sufficient rate of new staff at the same time and you heard some of this this morning at the same time where our our current inspector cadre is aging wants to get off the road is going to retire moves into management whatever it is when we're in a declining budget environment and we lose somebody it takes us a year to a two years to get somebody fully qualified and I'm talking about qualified I'm not talking about proficient I'm talking about qualified and what we need are highly proficient inspectors and so what does that mean that means that as people start leaving us leaving inspector ranks we need to capture their knowledge before they leave in sufficient time we need to hire new people to fill their shoes and give them an opportunity double encumber in my opinion to enable knowledge transfer such that the overall proficiency doesn't suffer there was a live polling question on I forget which session it was it might have been I can't recall but but it said what is your biggest concern about the workforce and and I voted technical competency others voted external awareness I voted technical competency why because of this issue because I'm very concerned that you know we are contracting appropriately so but up to date we've not been afforded the opportunity to to to bring in sufficient number of new folks to fill the shoes of the people who are leaving that concerns me greatly and so I think you know and I don't mean to speak out a turn here I agree with being more efficient I agree with you know budgets being reduced consistent with the size of the industry but at the same token there is a practical implication of that if you push it too far so I believe we need the latitude to be able to bring in the new folks and train them up before the aging folks leave because otherwise our technical competency and ultimately our credibility as a regulator is going to suffer anyone else want to chime in on this topic otherwise I do have a precedent I just I mean the view from the other side though is you know it doesn't feel like my my fees went up 8% this year that doesn't feel like a declining budget the you know when we look at the number of people if I go back and compare you know prior to the Renaissance the staff up compared to where our staffing levels are now I don't think we went back to where we were before so I would just say within the industry we're having to find new ways better ways more efficient ways to to accomplish our task without sacrificing safety without sacrificing reliability but doing it in a way that's less resource intensive so well I think the fact that the agency is filling that filling that pressure as well is not surprising I just it's but it is a burden I mean it's a regulatory burden on the industry to have fees going up at that rate when we're also operating in a declining in a declining budget so far this has been good you know we we have found many efficiencies that we've absorbed these costs but there'll be a point when you know you reach similar what you're talking about Scott you'll reach you'll reach the line where this is this is exactly what it takes for this day in time to operate this facility safely and if we can't do it and still remain financially viable we'll have to make other decisions so I would just you know I would like to keep the challenge on the table for for the for the staff to just stay focused on your mission but also realize the very real impact that it's having on those that you're that you're overseeing that's a good segue to a question that was written for you and for Tim and I'll just read it describe your personal messaging to address balancing safety performance relative to financial performance of your operating nuclear fleet for balancing safety performance versus financial it's a no-brainer safety is always number one it's the key to the game it's what you have to have to even have a right to be in the game at all safety always comes first in financial performance what you have to find a way to do is be able to operate financially sound mannered while maintaining safety above all other things we're having to do the same but this is an area that you have you have to be diligent because you can say the words but if you don't follow through on the actions to demonstrate the value then you can still you can find yourself mouthing the phrase but it not penetrate the organization so this idea of safety versus cost we've not we're not you know we're not relenting one bit on on safety we're not really while we go after costs and so far we've been able to do that if you look at how our plants operate they operate they operate safer now than they and they have in our history we're doing it at a cost structure that's better than than what we've done before but if I go back to David your comment earlier about you know if you look this idea of you know oversight in the presence of cost cutting I think it's a it's a it's a great council in fact we've we put additional teams oversight teams in place in our organization to independent teams teams of industry experts come in and look not only at what we've done but how we've implemented it and how we've done it in a way that's not impacting the safety of the facility so I mean it's a it's a it's an ever-present issue this idea of balancing and we have to we have to find we have to find those opportunities to highlight where we're going to opt for the safe over the cost and those opportunities exist we do it every day we just we don't advertise in there enough just to go back a little bit real quick David made a comment earlier about concerns on whether or not we were going to have the right funding to make sure that we're implementing safety related modifications and I can guarantee you that we do get those funds and we've actually gone through and changed our prioritization process to ensure that those projects that impact safety have the highest priorities are the ones that get impacted first it's the enhancement items the ones that just make life easier but may not add to the safety that are moved down on the list and aren't implemented the ones that impact safety are definitely always the first ones that have the highest priority okay we have about nine minutes left so that's just kind of a warning that we're running out of time but we've gotten more than one question related to the fact that sometimes NRC struggles with situations in which compliance with a regulatory requirement causes the agency and licensees to focus on issues of lower safety significance how come this and how do you think NRC should address these situations maybe start with Kathy on that yeah I'll start from the standpoint of acknowledging that statement and what is and answering a question of what is NRC doing about that so most recently we established a group it's called the low safety significant compliance effort and this is actually it's being let out of headquarters but my deputy Laura dudes is providing leadership to that effort and the idea here is to can we from an agency perspective look to see are there ways that when we identify items that are of the low safety significance that we can I'm going to use the term resolve them with spending significant and our C resources as well as significantly licensees resources on bringing them to closure so what this group is going to do is develop a strategy of how we can move forward in this area and it really goes to it's it's a link to part of the overall agency's effort on doing better in the area of risk informing decision-making with a mindset of that we do want our resources as well as the licensees resource focused on the most safety significant items but yet this would be something going down this approach this group is very mind aspect of documenting any decisions that are made so it would be transparent to the public as well as to industry anyone really wanting to look to our inspection reports to see how different issues were resolved and one of the challenges where I think this does come up and I guess one of the the questioner was raising the issue about the frequency that this comes up and we tend to see this a little bit more on where there's some question on the licensing basis for example inspectors out in the field identify something but then there's the question about is it part of the licensing basis or not and in the past you know way past if you look at a significant resources have been expended and looking at does this issue is it part of the licensing basis we finally make a decision you know yes or no but let's say yes then we go through the process and we find out that it was of a very low safety significance so then even we are asking ourselves was that worth the time and energy that went into that aspect fully recognizing what Dave said earlier is if there is a problem we do expect that you to the licensees to regain compliance in this area now again there's a little bit of fuzziness I'll admit there is if the issue the root of this is is it in the licensing basis or not because then you could question whether it was a compliance issue or not so I think the again this might be a good question for next year to ask us on where we went with us this effort is looking at really over the next six months to come up with with a proposal for senior management consideration on how we go forward with this but the idea is true at the end whichever way we go you know there would be the final result whatever the decision make made would be is that it would be documented and be available for everyone to see president do you have anything I would just say that you know this is one it's an important question and we'll get hung up when we talk about compliance you know like Kathy said I think most of our issues actually come up when there's a question of compliance and we're interpreting a licensing basis it may be less than clear previously accepted you know I've got a plant that's been in service for over 40 years it was issued a license and then you know in an inspection 42 years later a question of compliance is raised you know once that happened I think it I think it is right for us to go look and say if we're just asking a question of compliance to get to some firm answer if it's of low safety significance then why is it worth the investment historically we've had no issues where there is a compliance issue there's there's a rule that says do this we're outside of we're outside of that rule we take actions to go bring ourselves into compliance that that becomes a much different a much different problem when you know the very the very basis of which the plant was either licensed to or designed and now we have to make a fundamental change that can really create a decision do you continue to operate the facility or not that's where it's vitally important to bring in these risk perspectives and ask ourselves you know is this one too that we got to get to some hard answer on especially given the 40 years of documentation what was really meant by a letter that was written in the in the 70s and what was really said in some meeting where prior to the signature occurring we just invested and we have we experienced where we invested way too much time energy and dollars into resolving an issue that really didn't make the plan I will tell you in our case we we probably did some things that was a step away from safety trying to keep us in compliance as opposed to moving the plant closer to safety anyone else have thoughts on this Dave I think the the actions the NRC takes to address this issue should include looking at inspection procedure 711 finification and resolution procedure to me that's the most important procedure the NRC does it looks at corrective action programs that the licensees have I also think it's the least effective procedure inspection that the NRC does and that gap needs to be closed it needs to remain important but may be made more effective if you look at problems that wandered into columns three and four a common thread has been a deficient or less than effective corrective action program in many of those cases the NRC's P and IR problem identification and resolution inspections gave it good grades up until the point that some event or something moved the plan out then all of a sudden it went off a cliff into very bad you get a very bad it's not that big a gap the perception was too bad early or too good early and then too bad later that P that inspection needs to more accurately reflect what the condition of the corrective action program is if you had that confidence if you had that greater awareness then it would be easier to throw or not throw to dismiss low issues of low priority into the corrective action program with confidence that it's going to be addressed in a timely and effective manner but right now that procedure is not giving that confidence it needs to any tarot do you want to chime in just Darrell might have just been looking my direction any other any other final thoughts on how we kind of strike the balance or address these issues of of compliance in the intersection of that with lower safety significance I would just add or offer that it is something that the staff struggles with or deals with I should say probably we've had numerous conversations in region three about that it does get at some of the questions about whether an issue is within the licensees design bases or not but once you get past that point and and agree that something is a compliance issue or you know should be fixed or corrected in the corrective action program that's I don't believe something that is of dispute here I would offer that maybe one of the things that I'm looking hoping comes out of the effort that Kathy referred to that Laura Dudes is overseeing is for some of it for us to look at the policy the enforcement policy which currently tells the staff you know how to treat compliance issues and it doesn't you know discern between you know those that you allow to you know continue or don't address in a corrective action perspective and those that are above a certain threshold so I think the enforcement policy ought to be looked at from the standpoint of what does it tell inspectors to do for these low safety significant issues and how to dispatch those all right well I think we should probably wrap it up there the 90 minutes went quickly to all of you who submitted questions thank you very much we didn't get through every single one but we did get through most of them and hopefully the topics that came up addressed your question if we didn't get your individual question please join me in thanking the panel for this discussion and enjoy the rest of the conference thank you