 The purpose of this panel discussion is to hear perspectives from the representatives of the NRC, the U.S. nuclear industry, and the Sandia National Laboratories on some of the physical security programs initiated and implemented in recent times at the U.S. operating reactor sites and how they have insured adequate protection at the sites. The panel will also discuss its views on how best to ensure adequate protection for future commercial reactors. I just wanted to pause and remark that NRC is closely tracking the evolving situation in Ukraine. We are in contact with our U.S. government and international counterparts and we are receiving regular updates. The NRC stands in solidarity with our counterparts in Ukraine. The International Atomic Energy Agency is closely monitoring developments relating to nuclear facilities in the region and is in contact with the State Nuclear Regulatory Inspectorate of Ukraine. The IAEA is publishing regular statements on its website. Next slide, please. Here's the agenda for our time together. We will use the slides to help guide the panel's discussions. After my opening remarks, I will introduce our panelists for this session. As suggested by our session title, there will be two parts under this umbrella topic. For the first part, that is the security inspection program now ensuring adequate protection. The discussion will focus on three areas. One, security baseline inspection during COVID-19 public health emergency. Second, force on force inspection program during the public health emergency. And third, the concept and application of reasonable assurance of protection time. A new concept that was introduced in the NRC staff's policy paper SECI-20-0070 that recognizes existing layers of protection from both safety and security standpoints that support the nuclear power plants continued defense against threats up to and including the design basis threat. For the second part, ensuring adequate protection for future commercial reactors, the panel will discuss security related to new reactors under construction with the focus on security related inspections before commercial operation. In addition, the panel will also delve into physical security considerations for future commercial reactors. Next slide, please. I will now introduce our panelists. First is Mr. William Gross, who is currently the director of incident preparedness at the Nuclear Energy Institute. In this capacity, Mr. Gross supports NEI's efforts related to physical and cyber security, emergency preparedness and access authorization and fitness for duty. He engages industry, the Nuclear Regulatory Commission, and other federal agencies such as the Federal Emergency Management Agency, Department of Homeland Security, and the Department of Energy on matters of policy affecting the nuclear industry. Mr. Gross is the secretariat of the Nuclear Sector Coordinating Council and facilitates both the industry's security and emergency preparedness working groups. He will be providing industry perspectives on the topics of discussion today. Welcome, Bill. Our next panelist is Dr. Douglas Osborne, who currently is a distinguished member of the technical staff at the Sandia National Laboratories. Dr. Osborne has worked at Sandia for more than 17 years and has led projects for various nuclear safety and security efforts across a diverse set of domestic and international entities. He's been a nuclear engineer for almost 30 years in educational and research fields, and he also has operational experiences, including his time in U.S. Navy. Dr. Osborne also served as the U.S. Department of Energy, Lightwater Reactor, Sustainability Programs, Physical Security Pathway Lead. In this position, he engages the U.S. nuclear power industry's physical security community to help address physical security issues through novel advancements across many disciplines, such as risk, sensors, barriers, response force, strategies, and modeling simulations. Dr. Osborne will be providing his perspectives on the topics, but he'll be presenting a short set of slides later focused on risk-informed physical security using dynamic force-on-force modeling tools. Welcome, Doug. Our next panelist is Mr. Scott Sullivan, who is currently a senior security specialist in the Security Oversight and Support Branch in NRC's Office of Nuclear Security and Incident Response. Since joining the NRC in 2008, he has performed oversight of the security baseline and core inspection programs. His work has encompassed developing inspection programs, significant determination processes, and maintaining the security inspection program for new reactors, operating reactors, decommissioning reactors, materials licensees, and fuel cycle facilities. Prior to joining the NRC, Mr. Sullivan worked in the nuclear industry, holding various positions related to the protection of nuclear power reactors, ranging from response team leader to a security ship supervisor. He will start off the panel discussion today by sharing NRC staff's baseline security inspection experiences during the public health emergency. Welcome, Scott. And finally, I'd like to introduce Mr. Jefferson Clark, who is currently the chief of the Security Performance Evaluation Branch in NRC's Office of Nuclear Security and Incident Response. He and his staff are responsible for conducting NRC-led force-on-force inspections at U.S. nuclear power operators, reactors, and also at Category 1 fuel cycle facilities. Mr. Clark has over 35 years of experience in the security field with 13 years at the NRC, serving as an inspector and team leader for NRC force-on-force inspections. He retired from the U.S. Air Force after serving 23 years with distinction. Mr. Clark will share the NRC, Mr. Clark will share the NRC inspectors' experiences with conducting force-on-force inspections during the public health emergency. Welcome, Jeff. And again, I'd like to welcome all of our panelists and the audience who have joined us. And at this time, I'd like to kick off the panel discussion by going to the next slide and ask Scott Sullivan to share his views on NRC's security baseline inspection during COVID-19 public health emergency. But before I transfer the microphone to Scott, I'd like to inform the audience that as you listen to the panelists share their views, if you have questions for the panel to address, to elaborate further on a point or to clarify prior statements, please submit the questions via the virtual environment. The session coordinators will relay the questions to us, and we will do our best to work in your questions to the panel's discussions as we go forward. With that, Scott. Thank you, Sam. So right now, I want to talk about what we've seen in our baseline security and spectrum program as a result of the last couple of years for, you know, with COVID-19 public health emergency. So, you know, inspections that operating power reactors continue, as we've seen, you know, with the various variants that have come up in the U.S. and across the globe, it's been a dynamic process. You know, once we get through one stage of the public health emergency, another variant, you know, comes up, and we've had to deal with that. So, fortunately, we built in flexibilities within the program to address various conditions that may arise. The COVID-19 represented one of those conditions. And so, I'm going to talk a little bit about some of the flexibilities that we had previously implemented in the program, and then some of those flexibilities that we implemented as a result of COVID. So, the flexibilities allow the NRC to develop and use the right approach for each licensee, you know, based on localities, licensees have different impacts. Some areas are impacted more than others. And so, the flexibilities have allowed us to really target areas of the country where we needed to and implement various aspects of our program that mitigate, in some cases, risk to NRC inspectors and risk to licensees. So, it also has allowed us to look at how we inspect. We've evaluated how much we need to be on site, how much we can do in a remote capacity. Other things that we looked at were really looking at and inspecting the most risk significant activities while we're on site. So, we have reg guides that were developed as a means to provide additional guidance for licensees as they implement their programs. Those reg guides, as I said earlier when they were developed, provided latitude to deal with various situations that potentially represent a safety issue or hazard to inspectors or licensees. And what we've seen, especially in certain areas for licensees, is that they're implementing the provisions that are allowed under these reg guides to ensure the safety of their staff. So, one of those areas has been specific to training. And evolutions that require a large number of staff to participate, those are areas that we've really kind of targeted and we've seen licensees employ these flexibilities, whether it's a simulation in an exercise or maybe an increased artificiality in an exercise, because we didn't want to see a large number of people congregate in singular areas. And that probably been the biggest area that we've seen these flexibilities really help utilities and us as regulators. So, some of the feedback that we've actually received from NRC inspection staff and industry has been specific to those flexibilities that licensees implemented regarding their annual exercises. One of the comments that we received back was that it allows a more inclusive drill and exercise for all participants, even those who may not see action during an exercise or drill. You know, one of the other challenges that we've seen is, you know, how do you get to the range? You know, how do licensees conduct range work when you've got, you know, many people in close areas? And we've seen some licensees, you know, really be innovative in how they approach those types of training activities. How much of that we'll see carry on? You know, I think that's dependent upon, one, how long, you know, the public health emergency last, how long certain areas are impacted by these types of issues and, you know, obviously positivity rates and things like that, new variants that potentially come out. But some of the other things that we're really trying to do is look at what we've learned from the last two years and determine where we can implement some of these things, whether it's an efficiency that we've been able to identify or whether maybe it's just a better way of a licensee evaluating something and it gives us a, from an inspection standpoint, another method to, you know, verify compliance with the regulations. And we want to learn from those things. You know, we continually assess our programs for lessons learned that can be, you know, leveraged in a manner that facilitates changes to strengthen the efficiency and effectiveness of our programs. So with that, Sam, if we've got a question or, you know, if another panel member would like to add in something, I'd really like to hear those comments. Sure. Thanks, Scott, for those comments. Appreciate that. Bill, before I go to you to, you know, seek your thoughts from an industry perspective, one of the questions I wanted to ask Scott is, is that as you recount the flexibilities that were applied in the recent years due to the COVID impact, can you talk a little bit more about the elements of the security baseline inspection program that you thought were most important to preserve during the public health emergency and why? Yeah, so, yeah, and I'll speak specifically from a regulatory perspective and that, you know, open communications with licensees and understanding the, you know, the challenges that they were faced with and whether it was meeting a specific regulatory requirement, you know, based off of, you know, whether maybe they had to implement, I know different times they implemented a pod type, a pod type environment where they limited the number of people that could be in certain areas, that really challenged licensees and how they were going to meet some of the training requirements. And it was through that open dialogue, whether it was between, you know, the utility and headquarters or utility and original inspection staff that enabled us to understand the approach that the licensee would take. And we could then, you know, look at the regulatory requirements, determine whether that was something that we would find acceptable or not. And of course, you know, documentation, you know, we would receive documentation when we were on site, we were really focused on the most risk significant areas that licensees were implementing. And that allowed us to to really make sure that the most risk significant things were continuing to be met, even faced with the challenges that utilities had. So obviously communications and then focusing on those most risk significant areas. Thanks, Scott. Bill, did you have any thoughts from an industry perspective on how the security related inspections in recent times have gone from your perspective? Thanks, Sam. I think they've gone well. And Scott mentioned in his remarks, communication between the NRC and the site. I think if we tried to think about how we as an industry would respond to a pandemic and how the NRC would continue to perform its oversight activities, if we had performed this in 2018, we never could have foreseen the scope of impact, the types of impacts or the interconnectivity of those impacts from different groups at the sites. And the communication has been vital between ensuring that the site understands what the expectations are, how the exercise or inspection would be conducted and then work with the NRC to find the way forward where the NRC could inspect the elements that need to get inspected in a way that recognizes the need for both the plant and the NRC to protect its people against, you know, potentially contracting COVID-19. That communication piece has been vital. We saw it not just with the baseline inspections, but also with the the NRC evaluated force on force program and making sure that those oversight functions could continue to be performed. So I think it has gone well. I think the ability for the utility to send material to the NRC to review in advance where historically maybe that activity would have been done on site has been good. It helped us keep our folks from getting together too much and providing that information where you guys could review that while being not on site is good. I think that, you know, there are elements that have to be done on site, you know, walk downs or observations and kind of coordinating off those into must must do on sites versus can be done someplace else. I think the right balance was really struck there. Thanks for that, Bill. And I recall the chairman's remarks from this morning of what he called the contact sport, you know, likening the the inspection efforts to such analogy and and appreciate the acknowledgement that the balance was practiced and continues to be. Scott, you mentioned in your remarks that you refer to some of the lessons to be gleaned from this. I'll turn to Scott first and then and then to Bill and others who would like to chime in is what are some lessons that that were gleaned from these experiences that could help inform the future of of the baseline security inspection going forward. Anything that that you could share that that we could envision as to how they could be applicable in the future? Well, I think I think one of the key elements is, you know, and Bill kind of alluded to it, you know, what things do we truly need to be on site for? You know, what can be achieved maybe in some type of remote activity? A lot of the paperwork reviews, you know, verification, of paperwork was done in a remote capacity. We also looked at the number of training evolutions and and how those were conducted and what, you know, is there something there that that we've seen that benefits, you know, protection at the site that maybe the regulations were a little maybe overly stringent, you know, maybe there's room that we can eliminate some conservatism and still maintain margin. You know, those are the things that we're continuing to evaluate. Obviously, you know, we've been in this condition for a number of years. We're really starting to come out of that. And until we get through a period of time where we've implemented the program as it was prior to covid, that's still our lessons learned period. We're still evaluating, hey, is there a decline anywhere? I would say maybe after a year of full implementation, when we get back, we'll really have a better picture of were they efficiencies and, you know, is there any negative impact? We'll have a better view of what we've what we can do and what we potentially can do. So it may be premature to say, hey, we definitely see this and we need to change that. Any other thoughts by anybody else on the panel? Yes, Sam, I just have one that, you know, was a change in the paradigm on conducting the force on force inspections in regards to the the length of the day that's involved with conducting the exercise. There are, you know, several different briefings that have to take place, you know, for for control of the exercise and for safety briefings for the controllers and the players that are involved with the exercise. And once we did, you know, change our format, you know, we looked at conducting some of these meetings, you know, virtually in a computer-based training module that, you know, the individuals, the licensed individuals could take, you know, and not be in the presence of a large group, you know, that we were trying to avoid. And, you know, the caveat with us was as long as it did not reduce the margin of safety that's involved, you know, it looked like it would be a good efficiency. And this is something that we're evaluating on, you know, to to carry on in your future cycles for the force on force, because not only is there a reduction in time that the the licensed these individuals have to be on site, you know, time taken up, but it's less time that the inspectors, you know, actually have to be there in all these meetings. So I think it's a it's a benefit for for both. Thank you, Jeff. I appreciate that. So thank you for that, Sam, go ahead into that. So so, Jeff, that that that was one area that we not only saw on the force on force, you know, specific to NRC, Triennial Force on Force, but we also saw licensees implement in their own programs where, you know, they were doing some modules that typically were done the day of in a CBT based module. For example, you know, how they deal with miles and some miles training of illusions, and it really, in my mind, was an efficiency and, you know, to to and really, I don't want to say burden reduction, but it allowed the NRC inspection staff to focus on things outside of just your normal every day single occurrence that, you know, many of these licensee officers have have seen, you know, miles and operated with miles for years. We view that kind of probably not as a risk significant area and we allowed us to focus on other areas. Thanks. Good discussion. And speaking of force on force, at this point, I'd like to shift now from discussing baseline security inspections to force on force inspections, force on force inspections serve as as a capstone evaluation of licensee's ability to use their security resources to detect, assess, and respond in an integrated fashion to a threat. So at this time, I'd like to go to the next slide and give Jeff Clark of NRC an opportunity to share his perspective on NRC led force on force inspections during the public health emergency. Jeff, Jeff, I think you're on mute. Second year in a row, I've done that. The cap on what you said, Sam, that the force on force being the capstone is integral, you know, part of the inspection program, you know, to provide assurance that the licensees have developed adequate protection in protecting their their site. So, you know, for 2020 was a challenge. We started off the year with one complete inspection and then had to pause the program while we were trying to develop a new inspection procedure, you know, a completely new inspection procedure that would evaluate elements of the strategy and taking in all the mitigative measures to, you know, reduce the number of people that were involved maintaining the safety of the licensee personnel as well as the NRC inspector personnel. And I think that, you know, Scott and Bill, you know, both said it well that communication was key in this because the schedule was constantly changing. The conditions at the sites were constantly changing and the communications between the teams and the licensees was an integral part of being able to get out and get on site and to do this. But with that inspection, they'd only look at the limited scope technical response drills. We were not able to get an assessment of the licensee strategy, which is what, you know, we are tasked to do. So starting in 2021, what we did was we developed a modification to our force on force inspection procedure that allowed us to be able to evaluate the strategy using the minimum number of people involved. And what we did was, along with that, we developed what we call a temporary staff guidance that identified criteria for the sites to use to be able to justify not being able to conduct that inspection procedure and to revert back to the the inspection procedure that used the limited scope drills. For 2021, you know, again, the way that the the states, you know, conditions changed, regions conditions changed, you know, we had a we had a mix of both the force on force modified inspections and the limited scope drill. Inspections, but we felt that, you know, in 2022, you know, it was time to try to start to return back to normal and, you know, in alignment with the memos that were sent out by NRR and NMSS, we established another tier to this where that if the licensees could safely conduct the force full force on force exercises, then we were going to implement the full force on force inspection program and with the allowance to revert back to the modified force on force inspection program and justified hardship criteria, go back to the to the limited scope drills. Communication was key in, you know, any of these inspections, any of these transitions, you know, that went from, you know, the full force on force to the limited scope drills. The licensees needed to understand what needed to be submitted to us for approval. And, you know, we've we've had, you know, all of them used over the last two years now. So, you know, we've we've found merit in using the limited scope drills. You know, typically a successful force on force exercise, the licensee may not have to use a lot of their personnel based on the way that the site is configured, their layers of defense. They may be able to a trit, eliminate the adversaries very early on. The limited scope drills allowed us to look at the other elements, you know, that were, you know, deeper into the site, you know, other, you know, concentric layers of their defense key in key engagements, you know, that we felt, you know, were crucial for the defense of the site. So it has been very beneficial for us to use those, you know, when we haven't been able to to evaluate the strategy for for the site. Again, you know, we we hope that, you know, this year that with, you know, some of the relaxing of, you know, some of the mandates and the increased numbers of vaccines, the site conditions, the state conditions, you know, are going to allow us, you know, to get back to to the full force on force inspection program, you know, so that we can, you know, say that we have, you know, adequately, you know, assess the sites and we are fulfilling our regulatory oversight. And I will ask for for Bill's comments. Thanks, Jeff. Appreciate that. Bill, I don't know if you had some comments that you wanted to make from your perspective. I do have some questions. So would you like me to go with the questions first or would you like to make some comments first? Let's go with the questions. OK, so one of the questions that I wanted to ask Jeff that if you could just, you know, help us, the audience to to go in a little zoom in on on on the actual activities that that that you and your team perform during these exercises. So you mentioned, you know, the the the various comparison, various scope of inspections that were conducted, depending on on the site conditions. What were some of the the techniques that the inspectors used to to reduce the scope of the exercises while still maintaining the ability to assess the effectiveness of the licensees protective strategy? And I know you mentioned that that the limited scope drills, you know, had had some limitations there. But can you at least compare between the full exercise and the modified exercise that that that allows you to to glean that that information? Yeah, sure. So the you know, the force on force inspection is heavily dependent on site inspection because of the level of, you know, sensitivity to to the information that's involved in, you know, we need to have hands on of looking at the site profiles and everything that's involved. But, you know, some of the efforts that we did were, you know, reduced the number of individuals that were involved in the different activities, you know, such as presentations for underprotective strategy, tabletop drills, you know, trying to glean down, you know, only the minimal number of people that needed to be involved with that for us to be able to, you know, successfully, you know, complete that inspection objective for the limited scope drills, you know, picking out the, you know, the smallest number of people that needed to be involved with that. And then when the modified force on force only looking at, you know, those individuals that, you know, would have the engagements necessary to provide the assessment of the strategy. So there was a, you know, a delineation there of, you know, either looking at elements of the strategy or being able to look at the, you know, the entire strategy. The challenges with this were of the site layout, you know, the site strategy structure. So we had to look at these individually. There was no cookie cutter for this that we could go out and say that we were going to do, you know, X for each of these sites. You know, we had to go out, you know, on site, be able to communicate with the licensees on, you know, who needed to be involved with this for either being able to, you know, conduct this assessment of their strategy or understanding the challenges involved and, you know, reverting back to the limited scope drills for the inspection activities themselves, really nothing changed as far as, you know, our planning week activities, you know, everything that we went out there to do to look at the building blocks that we need to develop the scenarios involved for the exercises. If the exercises didn't come to fruition, we took the elements from that exercise and we made drills out of those. And then, you know, going back to the full force on force with all of the site individuals involved, you know, we just added up, you know, more people. Thanks. So chime in any time, Bill, whenever you want to. And also I would ask Doug, but wanted to ask a couple of questions, just a couple of series of questions. And one is, Jeff, you talked about the, you talked about the efficiencies in the tiered approaches that you described. Were there any elements of the modified inspection formats, whether it's the modified 03 or the limited scope inspections that actually enhanced your assessment capabilities? Were there any parts that you, that, so let me just stop there. Were there any elements of the exercises that actually enhanced your assessment capabilities? So, you know, I would say that there were, but there were also added artificialities that challenged the ability for the Lycee to be able to demonstrate their strategy. When you're, as a team leader on site, if you're using only a limited number of personnel, when you would have more personnel that you would have to be able to respond or interact with, it put an added burden on them that was, you know, separate from what their training and experiences were. The Lycees did a really good job of doing lessons, learn and benchmarking and being able to understand that as the year went on. The added benefit to doing, you know, like I said, with the limited scope drills, you know, we were able to look at the individual tactics. We were able to look at the individual responses for some of the, you know, the Lycee personnel that we wouldn't really get to see if we conducted the full force on force, you know, exercise. And we're limited that by either the engagement itself of, you know, where it takes place on site or the oversight that we have for the inspection personnel on site or, you know, the control cell. Thanks for that. Before turning to Bill and maybe even Doug, and I'll just ask the question and give you the opportunity to think about this. And I'll put the burden on back on you, Jeff, to maybe address this first and then we'll turn to Bill and Doug. So, you know, based on these experiences and the and the benefits of the tiered approach that have been applied, are there any elements from the modified approach of conducting the the inspection that you believe that should be considered for inclusion in the force on force inspection program in the future? And and and the question that I'll just have for Doug, for him to think about is, is there anything from from from your perspective that you could that could be used to enhance the assessment capabilities of the inspection staff when the ability to observe a full scope exercise is is limited? So with that, I'll turn to you, Jeff, first, anything that from these approaches that you believe could be considered for inclusion in the in the future of the force on force program? Yeah, you know, I stated before the you know, the way that we've restructured the the briefings in in the meetings, you know, that you know, is a reduction in burden for the licensee and the inspection staff. You know, is one of the things we're looking for is a long term carryover to the program and, you know, the having the the caveat to for the site to be able to get the full assessment of their strategy, you know, when all the personnel, you know, can't be involved in the exercise. It's not something that we look at, you know, doing is a routine basis. It's not, you know, what we're tasked to do. It's shown that we can do it, you know, if the individual, you know, conditions come up, you know, there may be similar conditions that we may see in the future that may challenge the site from being able to to, you know, post all of their individuals and how we would have to look at that, you know, again, you know, on such a site specific basis, you know, that I really couldn't give a, you know, a full answer that, you know, something that we would look at, you know, wholesale across the program. Thanks, Jeff. Bill, any any thoughts from from your your perspective there? Yeah, there's a couple of things that Jeff and his in the early part of his presentation talked about the different maybe I'll call them tiers or different methods the NRC could use to conduct the force on force throughout COVID-19. And, you know, that was arrived at through a lot of back and forth with the NRC and the industry. And I think we ended up in a really good place, a place that, as I mentioned earlier, allowed the NRC to do kind of as much as they could do safely, recognizing the conditions that are that are in place. And and that continues to be the place now, as Jeff talked about, you know, we were able to conduct a full three or the full NRC evaluated force on force exercise this year for the first time since they're early to, you know, 2020. And I think the industry and the NRC are both looking forward to getting back to where where we're doing those exercises. It's a it is a good a bill. It's a good exercise for the licensee to demonstrate the full capabilities of their protective strategy in a way that's very difficult to do. You know, as Jeff talked about, if you're using, you know, limited scope exercises to perform that. And one of the elements, I think that has made this program successful over the last two years is is that continued engagement that the evaluated exercise, there's a lot of moving parts. It takes a long time for both the NRC and the industry to prepare for them. And, you know, you can't you can't rely on the fact that site conditions are going to be as you intend them to be when when it comes time for the exercise. So I really want to kind of compliment the NRC on having periodic check-ins with the site as you get closer to that inspection so that the so that the exercise can be appropriately tailored to sort of be the maximum that they can do recognizing the need to to maintain the safety of the plant and of the people. So that's been very good. I think there are some administrative elements to how we kind of prepare for these exercises that that could continue to be included. And Jeff talked about one of them. But I think it's also important to recognize the the important role that the evaluated exercise performs, which is to recognize the full scope of the licensees protective strategy. So it is important that we that we strive to get back to to the most realistic exercise possible, the fewest number of simulations, the fewest number of kind of limited scopes where where we can and recognize that that protective strategy is designed for for a specific function and we need to test that function. The last is, you know, we we have spent a lot of time considering what did we what have we learned over the last two years relative to a proposal that's in front of the commission now related to changes to the evaluated force on force program. And while there are maybe some administrative elements that we could incorporate into how that's implemented, we don't think changes are needed to what's in what's in front of them now. I think the program that's proposed there is is still solid and sound. And that as if that were to be implemented, we could over time take a look at further enhancements to that program. Thanks for that, Bill. And and and I appreciate your your your complimentary words on on on NRC staff's continuous engagement with the industry. And I recall when when the tiered approach, you know, wasn't panned out initially and and we were looking for how best to conduct these exercises. I remember just internally within NRC, how we were trying to apply principles of good regulation, as the chairman described this morning, as as to how we would apply those and how we would conduct force on force in these uncertain periods. And and we came up with those tiered approaches, which I think is serving well today. And and so and we appreciated the the interactions that we've had with the all of the stakeholders to get feedback and how and how our strategies were developed in concert there. So so thank you for that feedback. Doug, did you have any thoughts that you wanted to share from your perspective on this or did you want to save your remark until later? Oh, I can I can go ahead and comment now. Thank you, Sam. So a lot of what both Scott and Jeff Clark talked about as applicability over in the Department of Energy as well, specifically through DOE's Office of Security. I do like the idea of developing lessons learned. Hopefully the NRC and DOE's Office of Security can can provide maybe a lessons learned sharing capability. Again, covering things from how how range activities were done to looking at these limited or some force exercises. The Department of Energy has been doing limited scope performance tests for quite a while now. It's very well established over there. It's a great way to actually go and test out parts of the protective strategy. But again, nothing, nothing ever replaces the full scope force on force exercise to go and again, provide that validation point within within the regulatory. I think right now, we'll go ahead and hold off other comments for me. Thank you. Okay. Thank you, Doug. Appreciate that. Thank you, Jeff and and the others for that informative discussion at this time. I'd like to transition to the third and last area under the umbrella of ensuring adequate protection today theme. And that third area is the concept of reasonable assurance of protection time. As I mentioned earlier at the beginning of the session, this is a concept that recognizes that there are many layers, existing layers of defense from both safety and security angles that that work together for protection of the site. And this framework allows for a specified time that supports the licensees continued defense against threat up to and including the design basis threat. So let's go to the next slide. And and I'll ask Scott Sullivan to elaborate further and provide his perspective on the development and implementation of reasonable assurance of protection time. Thank you, Sam. So, you know, Sam led off, you know, reasonable assurance of protection time. That's something we've actually talked about at a previous rick. But that was back during some of the developmental phase of it. We had just kind of really explored the concept and had defined it at that time. And what we've been able to do since then is make adjustments to our regulatory guidance, specifically Red Guide 576. We issued a revision to that red guide in November of 2020 that really incorporated the rap door. And again, that's the reasonable assurance of protection time. And as Sam noted, it does recognize the existing layers of protection available to sites along with how the safety and security of the site would evolve over the time following the initiation of an attack. So the rap reflects the determination that, you know, the licensees physical protection program meets the general performance objectives identified in 7355B. Which is to provide reasonable assurance that the site can defend the public health and safety and that they can do so independently for a timeframe of at least eight hours. But I think what we all recognize is that, you know, at some point in time, there's going to be added resources that will come into play. And I'm not going to say that it's always at that eight hour mark. It's likely much sooner than an eight hour mark. And what I'm talking about there are, you know, law enforcement, you know, engagement. So law enforcement is going to respond to the site. They bring a certain level of assets along with them that, you know, can support the site and, you know, and defending it against potential DBT, you know, anti-epic attack. The site has other capabilities, whether it's recalled security officers, you know, that they can supplement the onsite response force. You know, so there's other elements that go in that went into the rap. I'll speak a little bit about some of those as I go through this. You know, one of those is licensees implement, you know, flex equipment. And flex equipment, when I'm talking about that, it's diverse and flexible coping strategies. Some of that was, you know, came into play after Fukushima. And as a result of some B5B, you know, work that was completed. But what that does is there's additional equipment that licensees have access to that they can use to potentially mitigate and can utilize to maintain long-term cooling, spent fuel cooling and containment integrity. They also licensees also have the ability for operator actions, where, you know, operators are able to realign various components, systems to ensure continued cooling as well. You know, and lastly, you know, one of the things we really thought about is your DBT adversary, you know, over time, their capability, you know, likely is going to decrease, you know, the assets that they have available to them, whether it's ammunition or whatnot, you know, is likely to decline. So while you see a decline in adversary capability, you're seeing an increase in what the site's capability is. And so when we looked at that and we looked historically back at, you know, where industry is and where they've performed through our force on force, and we've got multiple cycles of force on force data to pull from, you know, we determined that, you know, licensees are in pretty good shape. And, you know, they're demonstrating that they can defend against the DBT. You know, so in understanding that, you know, the RAP enabled licensees to refine their protective strategies in a risk-informed manner. Industry stakeholders have expressed that the RAP concept adds a greater level of regulatory clarity because it provides a consistent framework for target set development. While implementation of the RAP might require some revisions to site documentation, it does not require any additional commitments beyond the current regulatory framework. And so while we put a lot of work into the, to develop in the RAP and having it issued in the red guide, what I'm starting to see is that licensees are starting to submit whether, I don't want to say a law, but, you know, different program documents that are starting to incorporate the RAP into their program. And we're having an opportunity to evaluate that. And I would anticipate over the next, you know, several years, you know, those things will increase over time. And, you know, so this was one of the major changes in my mind over the last, probably, decade that we've made regarding a real risk-informed approach to security. So with that, I'm really interested to hear from Bill on this topic and, you know, glean his insights. Thanks. If I thought it was appropriate, you probably see me get up and dance. I really feel like RAP is a significant step forward in the NRC's regulatory framework regarding nuclear power plants. You know, Scott talked a lot about the rationale for why RAP is reasonable. Utilities, as far back as I can recall, including just after 9-11 and post-9-11 ASMs, started developing and maintaining relationships with their local law enforcement and local federal enforcement. So maybe the FBI. And they have been building and maintaining those relationships ever since. And it's, and as Scott alluded to, it is absolutely the case that if a site calls, people are going to come and help us with that response. And it's reasonable to recognize that not only have utilities been building and developing and maintaining those relationships, but the capabilities of local law enforcement and the FBI have greatly increased across the country after 9-11. And, you know, not only do we see RAP as being a great way to sort of recognize the relationship, but we also get the benefit of the fact that there's been a lot of advancements in Homeland Security since 9-11. You know, 9-11, we didn't even have a Home Department of Homeland Security. That's a post-9-11 creation. Office of the Director of National Intelligence. A lot of additional capability has been brought to bear to help to secure the homeland. And I see RAP as just a great way to connect all of that stuff together. Scott, one of the other elements you talked about was you're seeing paperwork related to licensees evaluating or making changes to their protection programs based on RAP. And I just, that's of course very good news. But just take the moment to emphasize maybe to your listeners that when licensees make changes to the plan, those happen in a transparent manner through one of two vehicles. Either the licensee performs an evaluation and determines that the change does not decrease the effectiveness of the program. And they're able to make that change without prior NRC review and approval. However, they are required to submit some information to the NRC about the change. And the NRC is able to inspect those changes, the technical basis for those changes, and determine whether or not the licensee made adequate determinations there. The other path, of course, is a case where the NRC prior review and approval is needed. And of course, you have visibility into that. So, you know, it's not like RAPT comes out. We can make all of these changes. No one ever gets to see it all happens, you know, behind the iron curtain. That's all inspectable. And then ultimately, in the end, what we've been talking about this morning are the NRC's baseline inspection program, which includes the licensee conducted, NRC observed annual exercise, and the capstone force on force exercise, really is the test of whether or not the changes the utilities have made continue to ensure the capability to adequately protect the blades. Bill, thanks for that. And that's an important piece. I'd like to just take a minute to talk about that as well. So, you know, we actually revised our baseline inspection program a number of years ago to include an inspection procedure where we look at those plan changes that Bill alluded to. And that procedure gives us the ability to, when a licensee makes a plan change, to go in, look at the plan change, evaluate the basis of the change to determine whether there is or potential for a reduction in effectiveness. And we can take action at that point if we identified something like that. So, you know, I think that's a key element to our oversight program is that, you know, licensees provide us those documents and basis as to why they're making the changes, and we have the ability to inspect it, which ensures continued protection of public health and safety. But one of the key things I wanted to talk about with, you know, Bill talked about a lot of those relationships that licensees have with law enforcement. And in my mind, the implementation of the RAPT and the, you know, just really this, I don't want to say codifying, but, you know, the concept that we actually applied it and have it in regulatory guidance, I think it strengthened that desire for licensees to maintain those relationships and foster them more than what they had already done. And, you know, I think we're all better served for that. Yeah, Scott, that's a great observation. I'm firmly aligned with you. It certainly creates a positive incentive. Thank you for those exchanges, Scott and Bill. One of the questions that, you know, that we get time to time and it's kind of generic in nature is, you know, we, there's a lot of buzz about risk informed and what risk informed actually means and what it looks like. So in physical security space, what are the practical approaches for risk informing? And with respect to, you know, this concept of RAPT, how do you ensure that site protective strategies focus on the most important risk systems? And how are any efficiencies gained in the risk space? Can you speak to those? So from an inspection perspective, you know, we've actually risk informed our inspection program. So what we do is we have the regulations. We've constructed the inspection procedures to look at the most risk informed regulations at a higher frequency or periodicity than lower risk informed areas. From an overall perspective related to oversight, you know, I think what we've really done and I think the RAPT kind of led toward that is, you know, previous to where we were before the RAPT and really when we looked at reasonable assurance, you know, the regulations talk about high assurance and security, but what does that mean? Does that mean that there's zero risk or does that mean that there is some inherent risk applied, you know, when any licensee implements the regulations? And I think what we really meant was that there's, you know, we're looking for reasonable assurance of protection. And, you know, that doesn't necessarily mean that it's zero risk because there's always risk associated. And so we've tried to model our program in a manner that, you know, we all, we understand there's some assumed risk, you know, and for the RAPT, we set a time frame of eight hours. You know, that's pretty conservative when we, you know, I could sit here and tell you that we all know that there's going to be more support, you know, for the site provided by external agencies before they date hour mark. But that's some of the risks that we are applying in our program now. You know, whereas if you looked at it from a zero risk mentality, you know, we would, you could, one could almost say the licensee would have to, you know, defend the site indefinitely for, you know, however long. And we all know that that's just not a reality. So Bill, you may be able to add in and I would assume Jeff, you may have something as well in a force on force perspective. I'll add a couple of things. But before Jeff, you know, this term, this term risk informed is, you know, when I hear that term, or I have conversations with folks, everyone sort of hears that term through a specific set of lenses. You know, if I would I talk to Doug, I was born about risk informed, it means something very different to him. What I see in wrapped and the work, for example, we're doing with Cindy on unattended openings or penetration, you know, crawling through small spaces, or the industry's work to put together guidance on how to develop more realistic adversary timelines. The word I like to use is realism. It's, and Scott even talked about it when he was doing his overview of wrapped. It's realistic to assume offsite response is going to come. To me, that's much more of a sort of a tangible way to talk about how we can further integrate elements into how we do these exercises or how do we evaluate the plants is what's really likely to happen in the real world. And to me, that's a little different than risk informed. And so I prefer the use of realism as a better term for that type of engagement. Thanks. Appreciate that. So I wanted to turn to Doug, and at this point, and Doug, just wondering, are there any similar approaches or concepts that you've seen from your line of work? And how is it integrated into the planning processes? Have you seen any concept like this before applied? No, I have not. This is, I think you guys are absolutely leading the way in this area. I've heard from other regulators in other countries, the great interest in seeing how wrapped is being applied at the nuclear power plant sites. Again, the basis of risk in the security world really is the design basis threat. At or below that is the accepted risk that the site must take above that is the risk that the country takes in ensuring protection of that facility. So that's simplistically enough that the design basis threat is an actual risk statement in and of itself to take and apply a time limit. And again, it's very reasonable to assume the eight hour time limit that's being suggested. And the thing is when you look at the safety security interface, this isn't just a security silo. Physics still applies. It still takes time to blow down the reactor to heat up the core to go through all the various types of steps that would be needed in order to achieve the actual radiological sabotage. And being able to consider and credit those times is really what you're looking for. I know that's kind of a lead into my presentation materials, but that's where we're really seeing the NRC as a leader when it comes to developing such a concept as well. Thanks, Doug. Appreciate that. And just to speak in different words here, so Scott, when you talked about coming up with eight hours as the reasonable assurance protection time, that eight hour timeframe, this is not to say that at eight hours, everyone sits down or the response force sits down and quits fighting, but that at eight hours, it is reasonable to assume that the site will have additional resources to defend against the threat and whether this be recalled office, off-duty personnel, or law enforcement, and or the use of beyond design basis strategies. At the same time, regardless of what the time-to-core damage calculation may be, the protection of your most risk-efficient systems, like the front-line systems and any supporting systems, with a prompt functional failure that could result in core damage, those still are being identified as target sets to be protected. And so I just wanted to reinforce that when you speak of risk, it's just not one side, it's not just reducing unnecessary conservatism, but you're also making sure that what needs to be protected is kept protected. Exactly. And at this time, what I'd like to do, so thank you, Scott, and others for chiming in. And it is a rather very innovative concept that is being applied here. So thank you for that. If I could just add in just one more thing, Sam. This goes also back to the individual site-specific layout and location that not one response is applicable to another. So it's important that the licensees take this into account of where they are as far as the capabilities. And I know back even early on is the development of the 2003 DBT orders, we were trying to consider the balance between the licensee responsibilities and the responsibilities of the local, state, and federal government. So yeah, it's up to them to look at those and coordinate. And as Bill said, it may be a catalyst to establish and keep those relationships. Thanks. Thanks for that, Jeff. One last question before we move on, Scott, and that is one of the questions from the audience is why and how eight hours? Why not keep it open with no limits? Yeah, so I can tell you we had numerous discussions of where we felt that happy medium was. And a lot of data was reviewed. I couldn't tell you how many exercises that we looked at, whether it was force on force-based type exercise evolutions. We looked at a lot of information from utilities and had a lot of engagements with our law enforcement community, FBI, and really tried to understand where we felt was a good time frame with some margin built in that we knew that there would be all site support. We knew that licensees could take certain actions. We knew that licensees would be able to identify those important systems. And we knew that licensees could get those off-duty security response force members back and actually implement them or integrate them into the response that they have. And so it was a lot of data assessment and evaluation that we reviewed to come up with that determination that eight-hour was a good time frame. Thanks Scott, I appreciate that. But we didn't keep it open because we wanted to at least draw a limit on it. And I think that's an important thing that you do have a box. Sam I'm just going to add a little bit to that. We do appreciate the box. It's always nice to have an irrefutable hard line in the sand that you can all get behind. But the NRC has considered and is still considering a methodology that would allow a site to do a site specific assessment that could result in a less than eight-hour security bounding time. That's not final yet. It's still something that the NRC is considering, but it does recognize that different plants are in different places and the capabilities of the off-site and the timeliness to response could be different. So having a method that could allow you to get less than eight is reasonable to consider. But it is nice to have something that's set in stone. Thank you for that. Appreciate that. At this time and boy, we're so far into the time here. We have about 20 minutes left in this session. What I'd like to do now is to go to the next slide and switch gears to focusing on security inspection program and sharing adequate protection for future commercial reactors. And I'll turn to Scott to kick us off by sharing his experiences and perspective with a focus on security inspections related to new reactors under construction. And then we'll turn to Doug and get his take. So with that, next slide and Scott, please. Sure. And so, you know, I've been fortunate to be involved in this effort from the development of the new reactor construction inspection procedures, whether it's inspection procedures that look at the test and acceptance criteria of components, you know, various security components and whatnot to their operational program inspections. And so I'm going to be specifically referencing, you know, Vogel units three and four as they're being constructed here domestically in the US. So as Vogel three approaches commercial operations, NRC has been inspecting its security program. And again, that includes the installation and functionality of all the security systems and components. It also includes the inspections of operational programs. And those are the programs that the licenseeal implement to meet, you know, part 7355 of the Code of Federal Regulations. You know, one of the really interesting areas revolves around plant designs for these new reactors. You know, here domestically, after, you know, 9-11, you saw a lot of sites be retrofitted with physical security, you know, design features, whether it was adding hardening or, you know, various things like that. But these sites, they were designed with those things as a forethought. So, you know, they're extremely robust. That's the one thing that I've really taken out of, you know, my time on site watching it. I was out there when it was just a dark field. And as it's been coming up, you watch, you know, different security features actually built into the design. And, you know, that's been one of the most interesting, you know, elements of, you know, my time out going out to the site. And so we've put in, I want to say, there was over close to 700 hours of inspection activity, just in the design segments of the inspections at Site Vogel. From the physical, you know, protection perspective, we still have a number of inspections that are outstanding. Well, a couple that are outstanding. But they're getting close for Unit 3. And then, you know, obviously through this evolution, we've had a lot of learnings that will apply as we look at Unit 4 as well. This was a brownfield site, not a greenfield site. When I talk about a brownfield site, it's encompassed within a, they'll all be in a one contiguous PA. So it'll be Unit 1, 2, 3, and eventually 4. Whereas a greenfield site would have been a standalone, you know, reactor, you know, without an existing unit. And I think there was some benefits there in that, you know, the utility, you know, their programs for Unit 1 and 2, whether it was training, you know, various programs were already constructed. So there was some definitely efficiency that they gained from there. Seeing that we're, to some extent, short on time, and I know we've got a couple of the presentations, I'll stop there. And I'm very interested in any questions that anyone may have. Thanks, Scott. And what I'm going to do is hold off the questions related to what you just discussed and then really turn now to the Doug and then give him an opportunity to present his slides. And Doug, go ahead. Thank you. So we've been doing work over the Department of Energy's Light Water Reactor Sustainability Program now for about three years with a focus on providing some technical solutions. Can you hang on for a second? I'm not seeing the, I'm not seeing the slide. Can we get Doug? There it is. Okay. Thank you. Appreciate that. And one of the things that we're looking at is developing an approach to look at linking safety and security modeling in such a way that you can evaluate various types of safety systems and potentially credit those within a protective strategy. Go ahead to the next slide, please. So this work is actually being done out of Idaho National Laboratories. They're one of the national labs involved with the LWS program in physical security. And what they're looking to do is use an existing dynamic event tree tool that's used over in the safety analysis and link that with reactor system response, thermohydraulic response, and security modeling, force on force modeling. And look at how crediting additional operator actions inside the plan, additional emergency response equipment or built-in, you know, level one, level two types of flex equipment that are on site and see how those could potentially be credited within an actual sabotage attack. Go ahead to the next slide. What you see here is really kind of a timeline that lays out how you would look at an overall attack and how you would, even after the act of sabotage occurs, what types of emergency response could be brought to bear, again, to mitigate that sabotage event in such a way that you go and preclude radiological release. Go ahead to the next slide. And lastly, what you're doing is you're looking at the thermohydraulic response after the effects of a sabotage event, looking at the timing, more importantly, the timing. That's one of the big things that everybody likes to talk about, risk-informed approaches using security PRAs. PRAs do not do a very good job at capturing the uncertainties associated with timing, and that's why we're looking at other types of risk techniques to better address that. And this is one of those using dynamic event tree modeling to capture those uncertainties and timing and better apply reactor physics, thermohydraulics, associated with after the effects of a sabotage event. This is really what you see here is kind of that linked safety security modeling where the security aspects are on the order of minutes, and then the thermohydraulics and system responses or the deployment of flex happen on the orders of an hour or longer. That I do believe that's the last slide. Maybe you want to be mindful of that in 13 minutes. Thanks, Doug. Just staying on the topic, with many new reactor designs focusing on efficiencies relative to resources, are there any innovations or technologies that you're seeing in physical security area that could lend to a more efficient program? Yes, absolutely. Some of the work that we're doing within the Light Water Reactor Sustainability Program is looking at how to use security sensors in such a way that you're able to add to complementary security sensors to better detect and assess an adversary. Looking at uncertainties associated with adversary timelines, a list informed timeline tool to not only look at uncertainties with the timelines, but also what's the likelihood of success across each of those tasks and how does that look as far as an adversary pathway? Other technologies we're looking to evaluate, a major force multiplier is obviously the remote-operated weapon systems and how you go and evaluate those and incorporate those into protective strategies. Then applying these within a security by design approach. I know Scott brought this up when you were talking about the Volvo site in the bill, but how you actually provide that forethought of adding security technologies, adding security features to your design in such a way that it makes it a lot easier to defend against a radiological sabotage attack. You're going to see that moving forward in any really future reactor design, be it the larger reactors or even the more advanced small modular reactors. Thanks, Doug. If I could go back to the discussion on construction sites and the inspections and the lessons from there, Scott and others. First two-part question. Because you listed on your slides, you mentioned both the ITAC, which is inspection tests, analyses, and acceptance criteria program, as well as the pre-op security inspection program. Can you talk a little bit more about the distinction between the two? And really the second part is that compared to when the construction first started, has the NRC's approach to completing ITAC inspections in the security area and in the pre-operational security inspection program changed as the first of the two new reactors near completion? So two-part questions there, Scott. Sure. So first, ITAC is really the place setting and constructing of the security equipment and components. So in other words, the licensee builds it or their contractors build it, put it into functionality. So it's got to be in place or constructed as designed, and it's got to function as design. So that's really what ITAC looks at. Your operational program inspections now take that and incorporate it into your overall physical protection program. How does your physical protection program use that in defending against the site? Do you have a maintenance program that it understands how to test it, calibrate it, maintain it in a manner that it performs its intended function for you? Other aspects of your operational program inspection has to do with physical protection, where are your officers trained in the performance of their duties? Do they know what to do, whether it's at the search area, access control, access authorization, the different elements of that? So that's kind of the difference between those two inspectable areas. Now, you asked if we'd had any change of how we inspect things. I can tell you that it's been very interesting to watch. One of the things that we, when we initially really kind of built this program under part, as a part 52 support was we viewed it that the licensee would construct the site. We would do some ITACs as it was being constructed, finish those up, and then we would have an opportunity to do the operational program inspections. Likely at a hard cutoff, that didn't happen. That hasn't happened. So we were fortunate that when we developed the ITAC inspections, we did, or the operational program inspectors, we did understand that we would likely be looking at maybe some paperwork for your procedures and processes under the operational program inspection. So we knew there might be some overlap, but there's been a ton of overlap. So we're still closing ITACs out. We still have operational program inspections that are going on. So what we learned was they're going to happen at the same times. Now, you may have a lot more ITAC early on, but there's a ton of overlap. The second piece of that, when we originally designed the program, it was 100%. We tested every single element, every detection zone, every microwave head, any IDS element that was there, we tested every single one of those. And what we did, we took a step back and kind of looked at that. And so we determined that the licensee is testing those. There's acceptance testing that goes into play, comes into play. And so what we came back with was we're going to sample these programs. Obviously, if you run into an issue, we increase the sample. There have been times when we've had to increase the sample. But those were changes that we were able to implement as we kind of went through this process. It has been a learning process for us. I would anticipate that we'll likely see changes. You know, the program really was designed more for green field sites. I kind of talked about what those were before, not necessarily our brown field site. So in other words, there are ITACs that look at a licensee central and secondary alarm stations. If those central and secondary alarm stations are already constructed, why do you need to verify that they've been constructed appropriately when they're already there? We know they already meet regulations. Is that something we need to look at if it's a brown field site? Likely not, right? Now, you want to ensure that the alarm capability, the communication capability, crosses over to the new reactors, but not necessarily do I have to verify that the walls are of such a thickness and whatnot. So those were things that we're really looking at now. How can we learn from what we did here and apply that as we move forward? Is there a program? Do we need to integrate the ITAC and operational program inspections together and have one program moving forward? Do we need to have something that distinguishes or separates between a brown field site and a green field site because they're going to be different? And so those are some of the lessons learned that we're looking to take out of this. Thanks, Scott. Appreciate that. Bill, did you have any thoughts that you wanted to share from your perspective? No, Scott. Well, yeah. Scott, you made a number of good observations. At the moment, we've got one data point, one set of new plants under construction. And I know they're learning a lot of the lessons you're learning too. When there's overlap, there's opportunities for efficiency. And I think the NRC, you've talked about looking at where you could optimize or look for overlap and kind of plan and prepare. I think the utility has to do the same thing and be smart with their use of resources. If they're going to go out and do a surveillance on something, can they do just a little bit more and take credit for two different things at the same time? If they think of these things completely in isolation, there's inefficiencies on both sides, on our side, and of course on your side. One of the things that I think is relevant is when we have the operating reactor fleet, we share lessons learned real time. I mean, it happens all the time and it's great. Here, we're collecting an awful lot of lessons learned, I think, regarding how to do this at this advanced, this new reactor that's being constructed. But there's not another one in the pipeline that we can easily apply those lessons learned. I know we are going to be looking to how do we work with the utility to try to glean as much of those lessons learned and catalog them so they can be available for future use before all of that institutional knowledge goes away. If there's not another one kind of ready to go where we can apply that knowledge, it fades over time. Thank you, Bill, and I appreciate that perspective and the timely conclusion to our discussion. We're two minutes out. Let me just pause here, and I'd like to thank each of the panelists for your willingness to be on this panel and share your perspectives today. I'd like to thank the session coordinator, Jared Justice, for spearheading the production of this technical session who is himself a security specialist in our oversight branch, and he will be serving as a panelist on technical session W20 on NRC oversight and inspection during periods of site inaccessibility. I'd like also to thank Jeanette Curry, who is the security assistant, provided support. And let me also thank everyone who attended the session. Thank you for your attention and your questions. I hope this session was informative and that you'll enjoy the remainder of the conference. I'll just note that the last slide is the contact information for all of the panelists, so please feel free to reach out to us, and I know we didn't get to a couple of the questions, but if you reach out to us, we'll be happy to address them. So thank you all again for for stimulating and informative discussion.