 Okay, I have 1.30, so we'll go ahead and get started. So good afternoon, everybody. Welcome to our technical session on use of accident talent fuel to safely increase reactor output. My name is Beau Pham. I'm the Director of the Division of Operating Reactor Licensing in the Office of Nuclear Reactor Regulation at the NRC. And I'll be facilitating the session today. The NRC appreciates the opportunity to engage in dialogue on this topic, which will cover accident talent fuel, or ATF, and power upgrades. So first, I wanted to start with some general logistical items for everyone. The Wi-Fi code for all attendees is rick2024. Please remember to silence your electronic devices. All sessions are being video recorded. The Q&A portion of the session will be through electronic means for both the virtual and in-person attendees. For those of you physically in the room, please take a moment to scan the QR code displayed on the screen so you can participate in the Q&A portion later. For those joining virtually, you will find that there is a box to the right of your screen with tabs for electronic Q&A and feedback. Questions from in-person and virtual participants flow into the same queue, so the questions received will include those from the whole audience here. At the end of the session, if you have follow-up questions for any of the panelists or me, will be available just outside this ballroom, so please make your way to the exits to have those discussions so the next session can prepare to begin. As we close the session, you are also invited to scan the feedback QR code and share any thoughts you may have pertaining to this session or to the conference in general. Now, I'd like to welcome and introduce our panelists. Scott Krepo from the US Nuclear Regulatory Commission, Frank Goldner from the US Department of Energy, Svetlana Lawrence from Idaho National Laboratory, and finally, Jason Murphy from Constellation. As part of their presentations, each of the panelists will give some background about their work, but their full and impressive bios are also available on our online program platform. After our presentations, there will be an opportunity to engage with the panelists as part of the Q&A process. I encourage you, as you listen, to submit your questions electronically per the instructions on the QR code. As many of you are already aware, ATF concepts gained attention following events at Fukushima Daiichi. Congress, through the Nuclear Energy Innovation and Modernization Act, or NEMA of 2019, provided directions to the NRC regarding ATF, defining it as a new technology that, one, makes an existing commercial reactor more resistant to nuclear incidents, and two, lowers the cost of electricity over the licensed lifetime of an existing commercial nuclear reactor. Near-term ATF concepts include different cladding types such as chromium coated and dope pellets. For these designs, NRC can largely rely on existing data models and methods for its safety evaluations. Longer-term ATF concepts include silicon carbide cladding, high-density pellets, and extruded metallic fuel. For these concepts, substantial new data models and methods may be needed to support the NRC's safety evaluations. Both near-term and longer-term ATF concepts may include enrichment greater than 5% weight percent of uranium-235, and may increase the burn-up limit to 75 or 80 gigawatt days per metric ton of uranium. Based on our continued engagement with the industry, NRC is expecting requests for licensing actions for incremental development of certain near-term ATF concepts over the next few years and batch loads covering the entire suite of near-term ATF concepts by the late 2020s. The NRC has made substantial progress to prepare for and license ATF. To name a few of these, since NEMA, we have issued license amendments, topical reports, and generic communications to support development ATF. NRC has also held over 85 ATF-related public meetings, including three commission briefings. These accomplishments represent the building blocks to support the licensing of near-term ATF concepts across the fuel cycle. Additionally, near-term ATF technology, along with recent legislation, has revitalized industry interest in power upgrades. The Inflation Reduction Act of 2022 provides incentives for additional power upgrades across the fleet. In a 2023 Nuclear Energy Institute survey, it indicated over 50% of sites have indicated interest in power upgrades for their sites. Guidance currently exists for power upgrade reviews in our Office Instruction, LIC-112, titled Power Upgrade Process, and provides guidance for the coordination of all aspects of reviews, including roles and responsibilities for power upgrade reviews. The NRC has a well-established process for reviewing and approving power upgrade applications. This is demonstrated in over 120 upgrades that we've done over, have been approved since 2000. However, the staff is taking further actions to shore up the infrastructure to support power upgrade reviews. This includes coordination and training for staff involved and potential use of core teams in future reviews to enhance efficiency. Scott Kreppel will provide more information on this topic during his presentation. That concludes my opening remarks. Thank you for your attention. I look forward to your questions later, but now I'd like to introduce our first panelist, Scott Kreppel, from the NRC to continue the discussion. Thank you, Bo, and thank you, everyone. I'm Scott Kreppel, speaking through a sign language interpreter. I'm the branch chief for the Nuclear Methods and Fuels Analysis Branch. For those of you who aren't familiar with who I am, I am basically the supervisor for the branch that has the primary responsibility for reviewing and approving licensing safety analysis methodology with regards to code performance, as well as the operations of fuels. And so we do a lot of ATF-related work, and we coordinate quite a bit in terms of analyzing the codes. So Bo already covered a lot of this information in his remarks, so I won't dive too deep into the details here, but I will show you on the left side of the screen here the near-term ATF concepts that incorporate what NEMA defined as to where we are focusing our efforts in terms of implementation at the end of this decade. On the right side of the screen, you can see different types of power upgrades and what we have experience with in terms of licensing and what's been submitted to us. So MUR, for example, which is to capture or the recapture of uncertainty for better instruments. And then we also have the stretch power upgrades, which is sort of sharpening your pencils here, if you will, to try to optimize the power plants in converting, getting additional power without a significant expense in terms of equipment. EPU is a significant cost in terms of updating the codes. And there are some reports out there to see what are the economic benefits of using these different power upgrades. And we can kind of allude to the possibility of higher power upgrades in terms of percentages. We don't know what the actual plan is going to be just yet, and so that's why we have a question mark here. So here I'm going to briefly discuss our current state and what we've been doing so far and what we plan to do in the future with ATF and power upgrades. On the screen here, you can see a roadmap, which includes quite a bit of detailed information here, and I will not dive too deep into this, but you can find this on our website. So on the last slide, I do have a link here for you to be able to see this map and spend some time reviewing it. So on the website, it does have more information about all of the different licensing actions and activities that we've been doing, like LTA, as well as implementing some batch loading of doped fuel and other future activities with regards to supporting increased enrichment and high burn up, so on and so forth. So now with power upgrades, as you can see here on the slide, the NRC has a lot of experience in terms of reviewing power upgrades, and specifically the review guidance, we have LIC 112, which is a generic guide for power upgrades, and you can reference that specific guidance for any types of power upgrades. We also have experience with solving complex issues that arise in previous applications, so both the licensee and NRC have more experience these days about how to resolve some of those types of issues. There is a lot of industry interest in combining ATF and power upgrades, and there are benefits to doing that. In terms of having, you know, instead of having a series of LAR reviews and having a very lengthy review, you could have a review of combining a power upright, and that would shorten the amount of time and duplicate efforts in trying to take a look at those reviews. So if you were to combine power uprights and ATF, then you would have a little bit of a longer review, but at the same time, you wouldn't have a series of review. And so that is something that we are able to support, and this would also support the NEMA goals in terms of the economic benefit. However, that does come with some risks. All of those reviews and review hours are essentially getting compressed into a shorter timeframe, so the NRC and the licensees might have challenges in terms of supporting the review timeframe. Sometimes there could be a case where everything looks good up front in terms of ATF, increased enrichment, high burn up, what have you, but then perhaps there's a problem or an issue with the power upright component. From there, you wouldn't be able to implement ATF until you resolve the power upright component. So on this slide, we're trying to look at how can we get better? So obviously we want to be more modern risk-informed regulator, and so we pulled some historical information and data in terms of the power upright reviews, and towards the bottom you can see these gray dots, and those are, the gray ones are the MUR, and then the orange dots that you're seeing here are the SPUs, and then the yellow towards the top that are kind of scattered are the EPUs, with the understanding that some of those have special issues that make them more complex or more challenging reviews. Those are a bit higher than usual, and so here we can review information and see where can we support and come up with best practices. So now we're looking at what can the NRC do? Well, we are doing an internal effort to try to figure out what it is that we can do to improve power uprights and make sure that those reviews are as efficient as possible. Giving an example, obviously we have people who have reviewed power uprights in the past, and so we could use those individuals to be a part of the new reviews, and they could also work in mentoring the newer staff to make sure that they're ready for future reviews as well. And Bo had also mentioned having a core team, and so that concept we would have a dedicated team with a project manager as well as nuclear engineers and other instrumental engineers that are important and integral to this process in their specialized areas. If we have this core team, we could have multiple people reviewing the power uprights at the same time and apply their knowledge, and we could do a more uniform approach to this review. So those are some tools that have come up as of late that we think could help in terms of confirming the analysis, and it's only been used in some cases, but we do find that it is more efficient, especially when it comes to the RAI process. So this is just some of the things that we are considering now at the NRC, and we do plan to develop a project plan as well in the future, which would demonstrate what it is that we plan to do in terms of increasing efficiency. The NRC has a role to play, but the licensees also have a role to play as well. So here we have had a lot of success with ATF, and a lot of that is because we've had early engagement with industry, and we encourage licensees to come and talk to us about complex issues. The data validation, for example, and the reconstruction method was an approval for MUR, and that is the first implementation, and it could be more interesting reviews than some of the subsequent reviews, and with the power uprights, you can go beyond what has been reviewed in the past, and so that can be challenging. So we're really encouraging the licensees to engage early with us and discuss through some of those various issues. So we can get ahead of them, and we can avoid things like this last bullet point here, like what happened with the EPU review when we identified the steam dryer cracking issues, and that really threw a wrench into the EPU review at that time. Last but not least, I will say that the licensees should submit high quality and complete submittals, which means making sure that you're looking over previous reviews, look at what types of RAIs were asked, and make sure that you have that information provided up front to the NRC. That way we don't have to ask those questions. You can also provide more environmental evaluation information as well. So in my closing slide, you will see as promised that I have two links here for you. One of them is the NRC page here for the power uprights, so you can go there for more information, and the other one is the roadmap. One thing I wanna emphasize that the NRC is a regulator and the industry or the licensees and applicants each have their own roles to play, and we do maintain our independence. However, both of us really have a big responsibility in terms of supporting efficiency and timely licensing. So we can only get there if both sides do their part. Thank you for your time. Thank you, Scott. Before we move on to the next presentation, again I ask we'll hold the Q&A portion until all the presenters have gone through. Again, the Q&A process is done both in the room and online through the QR code behind me or through the tab for questions and comments online. So thanks to the wonders of technology, I can see things as they come in up here. So far I see one question which is promising, which is good, but I encourage everyone to kind of think through and provide your questions as you listen to some of these presentations. So next we have Frank Goldner from the Department of Energy. How do you do? I'm honored to be here, and I'm very pleased. I'm in the office of Fuel Cycle Research and Development. My supervisor Bill McCauhey is here, and I'm pleased to see my colleagues, Madeleine Feltas and Don Algama are also here, plus our National Technical Director, Dan Wachs. I think most of you know that the accident tolerant fuel program deals with industry and their attempts to carry out our mandate from Congress to enhance the performance of light-water reactive fuels under beyond design basis accident scenarios. We were very pleased to see the industry already interacting with us very quickly. And one thing I want to say from the beginning, I think we did two things right that I wanted to comment on. One is very early working with industry. We almost were working them before Fukushima occurred, but the other one was working with the Nuclear Regulatory Commission. One thing I think we did right was very early after the accident and we learned of the Congressional mandate was to be meeting with people in the Nuclear Regulatory Commission and interacting very early. As a matter of fact, somewhere in the audience I see Michelle Bales, who I think I interacted with shortly after Fukushima to talk about research and development, that how we share our knowledge. So I think that's something that I want to congratulate the NRC for because historically sometimes they wait till they get applicants, but we started right away very early. So we got this Congressional mandate early in late 2012 by 2013 to do what we could do to enhance our cooperation. And it turned out very early that we realized in doing suggestions that we got from the industry, which are listed on this slide, all the various concepts, was that when you enhance the accident tolerance, some of the things you do, many of the things you do, also are enabling for other things, performance, lifetime, et cetera. And so I think that came out very early that in addition to getting concepts, such as was talked about on the previous slide, we also realized that we can have additional benefits and some of these concepts even let the industry convince us that we should go for higher burn-ups, we should look into the possibility of enhancing enrichment to maybe get better performance. So that's one of the results, I think, of the Acton and Toll and Fuel program that I think we're all very proud of. And as a matter of fact, I have three background slides before I get to the up-rates discussion, but I think one of the results of our program is not only did we enable a better interaction with industry and with the NRC, but you also enhanced the facilities at the DOE National Labs. I think Don Wachs likes to talk about test beds. Well, I think we made several national test beds. To me, the most significant example would be the transient reactor test facility, the treat reactor. That was down for many, many decades. And because of its potential value tax and toll and fuel, we put in the money to start it up. I think it was like 50 million or so, which by the way, now is a bargain because there are a lot of people who wanna use it and they're paying more to the facility than we are. So I think this shows again an excellent example of how we use the National Labs. And so you see all these capabilities here, I won't go through them, but clearly these have been reinforced and stood up as a result of our program. Okay, now this is kind of my bottom slide. I don't have much more to say, but the whole question of upraits and power increase, obviously as you've heard, has been enhanced by the reduction acts, the acts that have been recently passed by Congress. And so although I use the word can here, rather than should, because it's clear that if we can, we probably should. But the reason I say can is that because of the acts, the question is, can you make more money by upgrading than by having a longer life? So in some ways, while these acts are excellent because they've added money and permitted extra considerations and extra concepts, they also have now put us in the interesting situation. I'm really looking forward to the discussions and questions to help me understand some of these subjects. For example, how do we support increased enrichment, higher burn-up and also consider the importance of using these as part of the consideration upraits? And I'm looking to the industry, to the NRC, to the other participants here in the panel. To give me supportive information because as you can imagine, all those wonderful facilities I talked about a slide ago, a lot of them are getting oversubscribed. When you have good facilities, if you build it, they will come. And that's what happened with us. There's a lot of people have come after some of our facilities. And so therefore it's important that we understand the case and we understand the priority of the people who want us to use it. That's very important. My colleague here will talk to you shortly from the LWS program. Clearly that's another part of NE, but we're really linked at the hip because we're working on the technology development to make the capability, but obviously the LWS program, I think is also very concerned of how we implement it. And so really I see these two programs very supportive of each other. So I am looking forward to the discussion I will hear almost for the first time of how we get together. I mentioned modeling because that's one of the beauties in DOE NE that we have extensive modeling program. And very early, I won't go into it, but very early they have linked up with figuring out how they can support us. And believe me, they have been very helpful as we plan out our programs. So that's very important. And so again, the last point I make, it's my again, another one of my questions is that I know it's valuable. I think the idea of both longer life and more power, the way I read that is we have to do both. Recognizing the difficulty because of prioritization, because of the funding, I think you're all here. I will recently be between the presidential debate and there's been a release of our budget request for 2025. We have lots of plans on what do we do to continue. So again, this upgrade question will clearly span beyond, right now we plan ahead to about 2025, but we're beginning to work, we have to work about the future also. And so clearly our program will move on, but something very interesting to us is what else can we do with the wonderful information we've developed in our regular program? And to me, upgrades is one of many things, which it's clear it has a value because anything that helps nuclear sustainability, which I think we do, is important. So that's why I just wanted to pose these considerations and look forward to further discussions on how the issue of power upgrades can be used, but I'm pretty sure we do our best to support it with our restrictions and limitations. Thank you all. Thank you, Frank. And next we have Spetlana Lawrence from Idaho National Laboratory. Hello, everybody, it's a pleasure to be here. Really appreciate your time to listen to us. My name is Lana Lawrence. I'm leading one of the focus areas under Lightwater Reactor Sustainability Program. We did quite a bit of research back after Fukushima looking at benefits of ITF, of safety benefits of ITF, because the goal of Lightwater Reactor Sustainability Program is to ensure safe and sustainable operation of our fleet, which feeds right into DOE and E goal of having the mission to support nations' economic energy and environmental goals. And that is why DOE has Lightwater Reactor Sustainability Program that goes after those issues and challenges with targeted research and development to address things like obsolescence of systems and aging management and economic challenges with the goal to reduce either operating costs or maybe bring a diverse way to develop revenue. And right after we did safety assessments of ITFs, we realized that there is other benefits, like Frank mentioned, there are benefits due to more robust properties of ITF that are economic in nature. And power upgrade benefit was recognized early on as one of those. But there was not enough business case to support additional power upgrade because utilities, nuclear utilities, already struggled to save, to sell electricity at market price. Well, the picture changed with the recent incentives offered by Inflation Reduction Act that this legislature provides a lot of benefits to nuclear industry, starting with the production tax credits offered for the operating reactors, extending to production and investment tax credit for new energy being introduced, including nuclear energy, and even extending further, speaking of diverse revenue to utilities that produce clean hydrogen. And LWR has had a question, well, giving all these incentives, is it now time? So is it now beneficial to power upgrade, to invest, to make these large investments in power upgrade? So we ran a feasibility study to assess those business cases. And there is a strong business case for power upgrade. And you can look up this report that is on your screen and it provides the set of business cases that we evaluate it. And we found that the business case becomes even stronger if this added power is used to produce clean hydrogen. And there could be a question, why is it we're talking about hydrogen in the middle of discussion about nuclear power upgrade? Well, the reason is because hydrogen, kind of similar to nuclear, is one of those unique energy sources that has this capability to deeply and on large scale decarbonize our economy. There are three large applications of hydrogen. First is we can use hydrogen as energy storage. So think about giant battery, but relatively cheap battery. So second one is a transportation fuel, especially for transportation sectors that really hard to electrify. So think about big mining trucks. And last but not least, we're using hydrogen now as feedstock for a lot of industrial processes. And we can expand this application to use clean hydrogen as a feedstock for many industrial processes. And those industries are really heavy on greenhouse gas emissions. So speaking of greenhouse gas emissions, this chart just gives you a quick glance on amount of carbon produced by various hydrogen production technologies. The very first one, that is a traditional, how I call it, method to produce hydrogen. And about 95, even over 95% of hydrogen produced in US is done by steam methane reforming of natural gas. And as you can see, it's really heavy on CO2 emissions. And compared to electrolysis, which has almost zero lifetime greenhouse gas emissions. And when it's supported by clean energy, but nuclear here has really great advantage compared to some other clean energy sources because of our ability to produce electricity, to produce energy 24-7 rain or shine. And also our ability to large, to scale, to really deliver on large scale clean hydrogen. And those two parameters, the availability and large scale are very important to industrial processes who rely on constant supply of hydrogen for their emission. So going back to power operates. So that is not something new. Like Scott mentioned before, NRC has approved 172 projects of power operates. And those projects deliver 24,000 megawatt thermal, about eight gigawatt electrical. But there is still more remaining to go after. We call it untapped power. So if we look at those areas, untapped power for boiling water reactors, we have about 5,500 megawatt thermal remaining. If we go using standard approach to power operates for pressurized water reactors, this number is even larger. It's about 13,000 megawatt thermal remaining available. Put things in perspective, that's about 10, 11 large light water reactors. So it's very significant. And putting in terms of small modular reactors, it can be anywhere between 50 and 100 small modular reactors that we can deliver power clean energy in the near future. So beyond the obvious benefit of clean near-term energy, it feeds directly into sustainability of our operating fleet. We are supporting fleet with a new revenue, additional revenue as soon as the power operates are implemented. We improved economics of the plant lifetime extension. And that's a great opportunity to modernize our fleet since we are making significant updates to support power operates. And then again, the business case is really strong to produce clean hydrogen from those added power in power operates. But to expand more on the benefits. So how much more benefits? Well, there is one more. And this one is really important benefit. We expect to increase nuclear power output from 100 gigawatt to about 300 gigawatt by 2050. So we need to double what we have today in next 25 years. It's a very significant undertake and we need to get prepared. So we need to pre-establish and re-engage our nuclear sector and it goes towards workforce to supply and chain manufacturing capabilities in both equipment and materials. As Commissioner Caputo talked yesterday about making regulatory framework agile and prepare for these large projects and large wave of these projects. And we really need to demonstrate to doubters of nuclear energy that we can complete this large scale project on time and on budget. So investors have better take and better feeling about investing in the nuclear energy projects. And just to quote Ben Franklin, I love this quote, by failing to prepare, we're preparing to fail. And we really cannot afford to fail here. We really need to support, do everything we possibly can to be prepared for this large new wave of nuclear power. So again, goes back to power upright. What do we need to do as an industry? Well, first we need to start with understanding the limits of power uprights. What limit us to go beyond what has been traditionally done which is about 89% for pressurized reactors, about 20% for boilers. We need to understand those limits and we need to differentiate between the real limits that are non-negotiable for our capacity and capability of our systems versus the limits that we imposed on ourselves intentionally, right? So maybe we didn't understand all the uncertainties. Maybe we didn't have operating experience when we put those conservative limits and we used bounding scenarios when we developed those safety cases. Well, we're in a different world now. We progress dramatically through in modeling and simulation area. We have done a lot of testing and experiments to understand the fuel performance. We are doing a lot of those test and experiments to understand performance of advanced fuels. So we need to take advantage of that knowledge and that experience that we gained to highlight the safety margins that we have. And then we can leverage our press-conformed performance-based approaches to demonstrate that we can go after a larger scale power operates safely. And in order to do it with an industry, we really need to work together. And that is why several DOE programs are talking with each other. We are very engaged with the industry, with Nuclear Energy Institute, with APRI, and through them we're engaged with utilities, we're engaged with fuel vendors to develop a roadmap and to identify priorities for research and development that will help us to get us there, to demonstrate how we can operate power in large scale, near-term, efficiently and effectively. Thank you very much. Thank you, Svetlana. Next we have Jason Murphy from Constellation. Thank you. All right, I'll start as we start all presentations related to the Accent Tolerant Fuel Program. I want to start by thanking the Department of Energy and as well as the National Labs without whose support. We couldn't be where we are. I'm not gonna go so far as to frank to give shout-outs to the folks in the second row, but you know who you are. So Constellation's been a believer in the ATF program and the potential for the promise of adoption ATF technology in the existing Lightwater Reactor Fleet for a number of years and look forward to seeing it bring the safety and economic benefits that we've already talked about a couple of times. You can see when you go to this chart that I think it gives you a good sense of the scale and the scope over multi-year, multi-cycle radiations and not just Constellation, but you know Southern Company's been very active. Entergy Excel as well have hosted different ATF features. So there's been a lot going on within the ATF world as you can see going back to the first commercial loading in 2018 and it's really just accelerated since that time. And I would say what's been sort of the focus over the last couple of years. I remember first going to some of the ATF meetings at the Nuclear Energy Institute a couple of years back and the focus of the time was how can we get lead test assemblies into reactors safely and with regulatory approval in a timely manner and that's kind of the beginning part of this timeline. Since then we've acquired multiple cycles in pile of radiation of a number of the different concepts. Kind of the focus over the last couple of years is really pivoted towards how do we get these concepts out to the national lab complex for postal radiation examination. It's just been exciting. You know, a lot of us within Constellation we're talking when is the last time we ship fuel to a national lab? We know it's been done before, but the number of times we've done it over the last two, two and a half years has really been remarkable and it's just been really exciting to see that happening. Now, I will say just shifting to Constellation's involvement specifically, you can see there's just been a number of different accent tolerant fuel variants, all three fuel vendors, both pellet and cladding concepts, but then I also want to add, and Frank and Svetlana alluded to it earlier, the addition of irradiation to higher than traditional licensed burn up, we've done that in both the boiling water and the pressurized water reactor fleet, inclusive of ATF as well as standard composition, fuel rods and so that's ongoing work today in the industry. So it's just been another added focus, additional work that's gone on within our fleet to see additional work coming from the existing reactors and then getting samples out to the national labs to gain valuable data to prove the safety and effectiveness of the different designs. Now, what I would say, when you look at all of these different concepts and all of the different reactor types, it becomes clear to you when you sit back that ATF is not a monolith and I think when I first came to this a couple of years ago, we sort of talked about, we used to name years and say, okay, when is ATF happening? ATF is happening in such and such year. The implication was after that year passes and there's one reload, one feature, one vendor, one reactor type, it's okay, we can sort of wash our hands of it and go on to the next interesting thing and while there are, as Svetlana said, there are interesting things out there, I'd say my current concern, if I had one around the program is we've made tremendous progress, as you can see in all the presentations today and I think we're ever closer to commercial scale deployment with multiple vendors, with multiple technologies that fully license, reload, region quantities, what I'd hate to see is if we shifted the focus away from it, shifting funding and appropriations away from it when we're so close or if we did it after we achieved it for the first technology, for the first site, we're only a couple years off and we've shifted to saying late 2020s because different features will be licensed and commercially deployable in different years, but so we've got tremendous momentum right now, a lot of positive developments. I think we've really proved the proof of concept for most of the variants, for most of the vendors, but we're sort of pivoting the program to the next phase of hard work of, while we've been able to license and sort of proved ourselves, proved to NRC and other stakeholders that yes, these are safe concepts, yes, they belong in light water reactors, doing that at the licensed reload level and doing it in a way that assures not just safety, but also the economic benefits that we've all been alluding to is gonna be some extra roll up your sleeves work and a lot of significant technical activity and interplay between the industry, the fuel vendors and NRC over the next couple years and there's gonna be a lot of coordination required to do that in an efficient and irrational manner. So with that, well, before I shift to power up rates, I'll just say, with so many concepts undergoing PIE, it is gonna be exciting to see all those results, but we do have to make sure that we're all coordinating and as we're getting that data out of the national labs with the fuel vendors, making sure we're getting the right data in front of NRC reviewers in a timely manner so that we can license these concepts on the schedule that we're looking to get there. And I did wanna fall back and say, we've all mentioned that within NEMA and trying in federal law is the safety and economic benefits that ATF provides. I guess I also think it's worth mentioning and we say periodically in the ATF community, but there are other fuel cycle benefits outside of just that reduction in the price of electricity for the operating fleet, although that's a meaningful benefit and that is reason enough, reason alone for us to do it is when we pair ATF features, as we will, with higher enrichment, greater than 5% weight, U-235 and higher burnout, it is gonna reduce the stress on the front end of the fuel cycle, which in today's highly constrained geopolitical environment, I can assure you, is more valuable than it's ever been or at least in over a decade. And there's a corresponding benefit on the back end of the fuel cycle to lower the annual volume of waste generated by our plants and so there's a sort of layer of benefits that we don't always talk about as the headline for ATF, but it's very real and it's just another reason to go forward with the program. So just pivoting to the power-up rate kind of segment of the presentation. So I'll say those who've been around the industry for a number of years, like most of you, I did like Scott's plot earlier, showing all the licensing activity over multi-decades on different up-rates. Many of you know that a lot of that activity slowed to a trickle or maybe nothing over the last five years or so as a lot of the plants in the industry were challenged up to and including the point of premature economic-based shutdown. So it's been encouraging the last couple of years to see that both from a policy, and we've hit the Inflation Reduction Act a number of times already, both from a policy standpoint, better certainty and better incentives for our carbon-free megawatts, but also just pure economics. We've seen an uplift in electricity prices throughout the country. So it's been heartening over the last year or two to see kind of finally a discrete value between policy and just market-based economics seeing the value that our carbon-free megawatts have to help facilitate the energy transition in our country. And so with that, there's, of course, been renewed interest in exploring what does it take to kind of any up-rate plans that have been on the board before, circling back to those business cases and seeing what makes sense. Now, I'd say as I sit here today, all of us are investor-owned utilities, and it's not appropriate or acceptable for us to talk about up-rates of a specific unit that we've not yet shared with our investors and others publicly. And so the only specific plan up-rates I can talk about today are the turbine-generator-based thermal efficiency up-rates that we've announced for our Byron and Braidwood units, I think just directly, the fact we're gonna invest approximately $800 million over the next several years to upgrade the secondary side of those plans to put an additional clean carbon-free megawatts onto the grid with the existing assets, at least directly would tell you that there's a business case to put those megawatts out there. But shifting to rated thermal power-up-rates, which is what most of us here are interested in in the interplay between accident-tolerant fuel and the up-rates, last year, early last year, NEI commissioned a survey to kind of get past this problem where industry feels as though, well, we can't put out public information on what we might wanna do. And that was getting in the way of NRC being able to resource plan even at a high level for what plant, what year, what might be coming down the pipeline. NEI commissioned an anonymous study to kind of get past that log jam. And that study indicated that upwards of 50% of sites have a strong interest in coupling power-up-rates and or implementing ATF, in many cases, both, to be able to capitalize on some of the tax incentives that we've already talked about in the Inflation Reduction Act, as well as just to capitalize on market conditions as we extend the lives of these plants in 20-year increments going forward. So I think that's helpful directly for an NRC standpoint to help with resource planning, but I think for the rest of us, just to see what direction that we think this is all gonna go. Now, and I was glad to hear remarks already kind of on this, but as from an industry standpoint, what we wanna see, constellation has quite a bit, we've done every species of those up-rates and things even in between over the years, and some of them have gone great and some of them have been a real challenge for a number of reasons, both from a safety and regulatory standpoint, making sure we understand all the issues, also even just on the sort of turbine, non-safety-related side of the plant, there's some pretty significant balance of plan issues that you have to get past and upgrade and analyze as part of a power upgrade. We wanna make sure that as we announce all these plans that we're engaging with all stakeholders, understanding here's the years that we're looking to act, here's what it looks the closest to. NEI is pulling industry members, but we're gonna make sure that we make recommendations to the commission on what we believe to be the most efficient resource utilization plan to get through those and that would include things such as combining licensing actions in a way that makes sense and Scott got to the heart of it that we have to be careful and purposeful the way we do that. We don't wanna pin a specific ATF concept to an up-rate and one of the two gets held up by some technical or regulatory issue, therefore holding the other one hostage, but in cases where there's a clear, well-trodden regulatory path, and I'll use the example for a BWR, extended power-up-rate melloplus implementation and then measurement uncertainty recapture. I, about little over 10 years ago, I was based at our Peach Bottom plant and because they were considered link submittals, ultimately decisions were made to conduct those three licensing actions and series and so we wound up with an extended power-up-rate dual-unit plant that didn't have melloplus features and left the operators in a very tough spot with a very narrow window core flow that resulted in them having to more frequently maneuver the plant, move control rods more often, have less operational flexibility. When ultimately two years later, we're able to prove to all of our satisfaction we could expand the normal operating domain by implementing melloplus and then two years later, implementing a measurement uncertainty recapture relight. Many of those involve task reports and products that are, you know, start as a carbon copy of each other and then just kinda iterate and redo the same calculations. It's a massively non-efficient way to go through the process and so when there are cases like that where it makes a lot of sense for efficiency both for the industry, for the vendors performing a lot of the work and for the NRC staff reviewing it, we have to be purposeful in making sure we're taking the most efficient regulatory approach to those actions going forward. But with that is I kinda sit back and look where ATF stands relative to a couple years ago and power up rates weren't even part of the discussion a couple of years ago. I'd say, you know, I've been kinda energized the last couple of weeks. We have probably, I didn't check this stat with HR but I think our largest class at college, higher end nuclear engineer starting over the next three months and it's just been heartening between life extensions, all the potential power up rate work and the significant ATF work to be able to talk to people about having a full career even with the existing light water reactor fleet in front of them. So it's definitely an exciting time, I think to be where we are. Thank you, Jason. So thank you to our panelists. I gotta say when I was listening through each year of presentation I just had a moment of self affirmation that we did the right thing in proposing this topic for this year. Some of you long time listeners, hopefully if you've been following, this is probably a third or fourth year doing a RIC session on ATF. But in keeping with our theme for the RIC this year of adapting to a changing landscape but we thought it was appropriate to pivot a little bit or define that confluence between ATF and power up rate because the changing landscape is, things like the IRA is basically the Incentive Reduction Act which has put some incentives on the table to look at ways we can utilize the things that we're doing under ATF to see what we can work with in adding more power to the grid. So we do have several questions to go through. I thank you the audience for providing them. I will be asking them. They are directed at individual presenters but I also welcome any other comments from the other presenters as well because I think the value of these conversations and having these panels is having multiple perspective on sometimes open ended or not specific areas. So I will start and I think we should have plenty of time with the number of questions we have as well. So the first question will be as asked of Frank Goldner from DOE. As to what extent is the use of accident tolerant fuel bring safety benefits for accident management or mitigation for SMR or small modular reactor? I think that's a very interesting question that we have been asking ourselves as we think about the future of our program and advanced fuels is can and what are our benefits that we are developing in ATF program that can be used for other reactors including the small reactors. There are several water reactors that fit into the context of small reactors at least four that I know of and then there's the intermediate size higher. So it's a good question and we've asked our vendors and it's part of our program thinking how to deal with what that can be. Any other comments from, okay, all right. Next, have a question for Scott Krepple. Thank you for your presentation. What are some of the challenges the NRC anticipates with ATF that our partnerships with industry can address? Well, first of all, I wouldn't say it's exactly a partnership. It's more like an engagement to make that clear. With that said, I do think that there are some new technologies that we haven't yet fully envisioned in terms of commercial batch loading. So for example, chromium coated cladding. That has been tested in LTA but we haven't arrived to a point where we're ready to roll out at a batch wide level and I think that's a great example of everything that's going on in terms of the increased enrichment rulemaking process. There is a lot of discussion with industry as well as other stakeholders within the NRC to make sure that these approaches to licensing and high burn up fuels, especially with specific phenomena like FFRD and other things that are complicated topics. Those really need to be resolved before we're able to move forward with some more of those initiatives. And I think we're doing that with discussions through industry and I think you can see that here with this presentation today. Thank you, Scott. I apologize. I read it as it's written but I think the partnerships may be, may have meant partnerships within the industry, right? And so just to reiterate on the role of the NRC in the partnership, ATF is, DOE has really been charged with figuring out ways to deploy, help the industry deploy ATF. NRC is a natural partner to DOE in that we have the task of licensing or regulating the use of the fuel. So I think our role is really to try to not just stand in the way but engage early enough so that we can be involved and be aware of the developments within the industry, okay? Well, if I could just add to that. I could also add really quickly, Bo. I would say yes, absolutely. We do have discussions on a regular basis with DOE and we also have workshops and we interact with them on a regular basis. So I do think we are up to date on information in terms of supporting industry efforts and developing research information through international research programs as well, like F-I-D-E-S. So things like that, we are definitely involved and we are doing a lot of work and a lot of engagement with the Department of Energy. I also understand that we need to understand the basis for industry's goals in the future as well. Jason? Yeah, and I was just gonna add, first I agree. Using the word partnership is probably not the right one but I do think the industry, you know, the fuel vendors and the end users have tried to be working through NEI as a conduit, have tried to be as open as possible about here are intentions, here's where we're going. It's not in our interest to surprise the NRC either with timing or scope of a product we submit for review, so we have tried to be open and just taking as example what Scott mentioned with F-F-R-D fuel fragmentation or relocation dispersal, that's been clearly advertised as hey, there has to be a solution there. There's been a ton of work done by the industry as a result of that to make sure that everyone's aligned that this is the right scope of work to resolve that safety concern. Hey, Jason. And on that topic, in fact, the next question, and now Frank will start with you, but the question is, could you comment on F-F-R-D fuel fragmentation, relocation and dispersal, the F-F-R-D issue for high burn up ATF? Well, all I know is that that's an important area in our discussions with NRC and the vendors. We all recognize that if you're going to go to high burn up, higher performance, we better understand what can happen in beyond design basis accidents. So clearly we have stood up a testing program that will support answering those questions. We have a whole set of transient tests planned, et cetera, which we'll be contributing to understanding that well enough that the mechanisms can be understood. What happens if it occurs? Is it severe? Does it affect the heat transfer? So there's many possibilities of this question of that's failed fuel relocation dispersal. That's what F-F-R-D is. And the industry is of course looking at how to address it both through our experimental basis, but also through statistical means, looking at the database that's available. So I can only recognize that that's important and we've accepted it as part of our efforts to address. Next we have a question, Scott, if you could take this one, it wasn't directly, but it says what ATF fuels have been approved by the NRC for Burnup to the 75 to 80 gigawatt days per megaton uranium mentioned? At this time, none. The NRC has yet to go beyond, or much beyond the current licensing Burnup of 62 gigawatt days per MTU, a rod average Burnup. And that does include ATF fuels at this time. Next question, Jason, if you can take this one as pretty specific, are the Byron and Braidwood updates for 135 megawatt electrical per unit or site? Well, as I try to do math in my head this afternoon, I believe that's combined, but I would have to double check that. I don't have that in my random access memory. Okay, next question is for Scott. With all the experience for more than 120 power upgrade licensing actions that I mentioned earlier, should the NRC update and modernize existing regulatory guidance, which are over 20 years old, this could enhance future upgrade licensing efficiencies? That is one of several things that we are taking a look at as part of our internal analysis that I had mentioned earlier, or internal assessment I should say. I can't give a direct answer right now because we're still working through our internal process and we do have a team that's getting together. It's a group of people who have knowledge of different aspects of power upgrades, but what I can say at this time is stay tuned. I mean, and I can add to that as well. I mentioned in my opening remarks about the existing guidance that's out there. We have an office instruction for the office on how to perform a power upgrade review. We did make that publicly available earlier this year. We do intend to engage the industry on it. We have a working group within my division right now working with the technical division to take a look at how ways we can risk and form or streamline the review process, given the experience of the data we've seen from the past reviews, right? Okay, next question is open, but it's more for the NRC staff. ATF is and should be a priority and will be great for safer and more efficient profitable operations. Have any of the use fuel storage designers and the NRC been engaged in the ATF effort to ensure that these assemblies can eventually be safely stored in a dry cast storage system? If not, what should be done to get them involved early to avoid any back end issues? Jason, I'm sorry. I can take that one. I can tell you that through EPRI that the plans for Accent, Tolerant Fuel and the features has been shared with all of the three primary dry cast storage vendors. And I just say, given the timelines that we're talking about, that is insertion and reactors late 2020s, you know, normally six years of irradiation, then some cooling time at the, I'd say the track record of the cast vendors is all that they will easily be able to accommodate back end storage solutions by that time. I think we've been more focused acutely on kind of the wet storage, just making sure that, you know, if we go greater than 5% weight enrichment that our existing spent fuel storage pools can accommodate the fuel. And all signs are that there won't be an issue there. But I think that we've been trying to share proactively with everyone on the back end, the characteristics of the fuel. And I haven't heard of any, what I'd consider a fatal flaw in that regard. This is Scott, if I could add. I would say the NRC also, well, let me back up for a second. So I've been branch chief for the last two years, but I have been involved with the AT programs before that as a technical reviewer for quite some time now. And so there was a working group that was established for ATF as well as a steering committee at Bose level. And there's been a lot of involvement at the office director level that includes NMSS as well. It includes research and various partnerships with other offices. And so we all meet on a regular basis to share information at all levels of the organization. So I would answer, yes, we are aware of what's happening and how it might affect one area or another. So we are definitely doing our best to make sure that the right hand knows what the left hand is doing. Thanks, Scott. And I would reiterate, I am part of a steering committee on that effort that Scott's referring to. There's a working group level and there's a steering committee level. And all the major programmatic offices within the agency, whether it's reactors, materials, and security, and research have all been involved and we meet on a very periodic basis, I think at the going rate, it's been monthly. Next one, I'll leave it open, but maybe you start with Jason, if you can kind of take your perspective from the industry and Svetlana, feel free to jump in on this one from INL, is if you can, can you provide the industry's perspective with respect to the incentive window of the Inflation Reduction Act, i.e. whether the 2032 timeframe is going to be a limited window to get power upgrades going. Yeah, well, I'll share, Svetlana probably has some good input this as well, but we were sort of talking about this before the session, but nuclear timelines are different than most other folks' timelines, so I mean it is a real concern and I know that everyone's aware of what is in the law and I won't, I'm not a policy person, so I won't say everything that would be pursued if that we were about to run into that, but everyone is very sensitive to the timeline there and I do think that that is driving a lot of people to act in an expeditious manner, Svetlana. Right, so there is certainly urgency there. The, I really should mention that 2032 is the number of the end date specified, but there is also extension. We should be on target with the greenhouse gas emission by 2032 or provisions in Inflation Reduction Act continuous, so I wouldn't rely on those provisions, so we do want our carbon emissions to lower, so I'm a promoter for lowering it before 2032, but we may not get there quite yet, but the urgency is here, so that's why we really need to work as an industry as a whole to come up with efficient and effective way to do those large power upgrades. Thank you. Okay, next one, Frank, if you could start with this one. What definition of ATF wantitably if there is one? What is the performance improvement criteria to be classified as ATF? Well, there I would go back to the congressional milestone or guidance to us that we should seek improvements that can be at least started to implementation in the 2020 time period that can enhance the performance of reactive fuel under severe accident conditions. And that was the starting drive of this. We saw input from the industry and that got to that second slide that I showed with the concepts. So it turns out that when you enhance performance under severe accident conditions, it looks like we're an enabler for other things and that's what I'm very pleased to be hearing about here. But basically, our mission is supposed to enhance the safety or the performance of existing light water reactive fuels under severe accident conditions like beyond design basis that can occur. Thank you. That's the tolerance, accident tolerance. Tolerance, I guess. We used words like coping time in the early days, but now we're just looking at the behavior and performance, fission gas release, et cetera. And this is, the next one is related to that, but I'll open it up because it wasn't specific. But the question is, can you explain how higher and rich or higher burn up fuels are safer? Is the, I think the conventional thing is increased burn up results in increased hydrides and resulting fuel degradation or risk of fuel fragmentation, for example. So the question is, why would we consider that to be, that fuel to be safer? We added that to our program a few years ago, especially higher burn up came in first because the industry convinced us that some of the concepts are not as cheap to make as normal fuel cladding, the normal Zirk cladding that they use. So some of the things we do to enhance the performance, I mean to enhance the safety behavior under severe accidents, they're costly or more costly and they're gonna add cost. And the industry very early on convinced us that things that you can do to balance the economics and I think high burn up was the first one that came through that, you know, and then high burn up led to enhanced enrichment. So they came in sequentially, but they obviously linked with supporting the economic viability of the concepts that under consideration, in my opinion. Thank you. Next question is for Scott. Is the NRC considering application of an upgrade or ATF decision to several plans if they are configured in the same way? For example, if they have the same fuel, RTP operation strategy, et cetera. I would say that is something that could be considered on a case by case basis. We have reviewed some LARs that are applicable to multiple plants. However, with that being said, I personally, and this is me speaking as Scott Kruppel from previous experience, that it could be a challenge simply because there is a lot of plants that are not exactly the same. So there's a lot of deviations or variations and it would depend on the licensee. They would need to address those particular concerns in the LARs. In my sense of that question, it came from someone that looks like from a testing research reactor background. So I mean, I could say on the licensing side, we license each facility with its own license, but certainly when we have lessons learned or things that we learn from other similarities between different licensing facilities, then we certainly take those lessons to heart and incorporate that as part of our efficient review going forward. So that's a standard practice that we do invoke as part of our licensing reviews. Okay, this is an open one for everyone to weigh in. Is there great description on the safety and business cases for ATF from all? What is the public sentiment on ATF? Any apprehension from nuclear host communities? Just to lead it off, I can only say that when I talk to people and try to explain our program and all, I always get positive responses from people on airplanes and trains when we give our elevator speech that we're trying to enhance. And by the fact I wanna add to the last thing I said, there's an interesting question of whether we enable the enrichment and the high burn ups or those enable us. I think it's a two way street that we're related but my interaction with the public and family and all has been always very positive that you're doing something to enhance the performance and safety of nuclear power as it affects its sustainability. It's an interesting question. I would say that the whole point of why we do these is to help understanding and promote an understanding of what Congress is charged with with respect to ATF, right? And so I think from the traditional or your typical host community, it depends on which word of the term accident, Tom, you wanna take away from it. But I think that the whole concept of ATF and why Congress felt it was important enough to address the issue was lessons learned from Fukushima and how can we increase the coping time of a facility when it's going through a loss of all power scenario like they did at Fukushima, right? Yeah, I can add from Idaho National Lab standpoint, our engagement with communities increased dramatically in the last several years. We are planning to build several reactors at the site. We're engaged with multiple communities starting from Idaho Falls and our local indigenous communities and extending to neighborhood states and people who, communities that I would never thought would be interested in nuclear, they stay in line with raised hands saying we want nuclear power in our community. So overall, not just from ATF perspective, but even advanced nuclear technology, it's a dramatic increase in public acceptance of nuclear. Thank you. So the next one it looks like for the NRC staff. So what NRC safety requirements would become unnecessary through the use of ATF? So this is not something that I could necessarily speak to directly as of right now. Obviously we have the increased enrichment rulemaking process ongoing as we speak. And so that is specifically intended to take a look at the safety requirements, which may need to be updated to better reflect ATF. And I think many of you already know that we are done with the public comment period and we just closed that recently and we will be proceeding with the proposed rule here soon. We will be doing that at the end of this calendar year. And that will be when most of you will find out what it is that we have in mind in terms of those specific rules. Thank you. Yeah, thanks, Gaten. And I would echo that, you know, I don't think we, in any rulemaking process, we enter it saying what's not necessary. But really the whole conduct of the rulemaking process is to really look at an existing rule in some cases, what the technical and policy or policy basis behind or regulatory basis behind that rule and look at it again to say is it needed at the time? Right? And so I don't think we go into the process thinking what's unnecessary but so much is going to do a full systematic evaluation of the rule itself. Okay. Frank, if you can take this one, what range of power upgrade levels enabled by ATF is enabled or are enabled by ATF using LEU plus and do you expect to see an existing PWRs? It's a very specific question. Well, I don't think I can answer the specific question because I think that's still, you know, we're still, as I said, we're evaluating how and what we can do in our program to support the up-rate question or the power. We know it's important but I've heard numbers like 20% or something like that in power level. If that were the case, it's clear that, especially with the impact of that Inflation Reduction Act monies, that can be very valuable. So I've heard numbers as high as that but the numbers I've heard mostly up to now is at least the people with the PWRs hoping to go from 18 to 24 months, which was the early justification of the value of what we're doing. So there may be a competition but I think different utilities will use it in different ways. Yeah, and that's what I was gonna start with. I think every plant has unique constraints both in the nuclear island and on the turbine island and that's sort of the starting point. I think Frank's right. I think many of the pressurized water reactors that haven't been able to economically transition from 18 to 24 month cycles, it's a huge enabler there. So I think that'll be a large focus for almost a third of the U.S. Lightwater Reactor Fleet as a result of that for other plants that have either already done an upgrade or already at 24 month cycles, then it just becomes, do you optimize your existing fuel cycle economics by loading less fuel? Do you do a power upgrade? It's really just a cost benefit. Every plant has a couple of limits that it runs into. It's just about does ATF allow you to kind of get past that limit? So it's really gonna be plant specific. Right, and power upgrades levels, fuel definitely is one big piece of it, but there are also limitations on the balance of plant sides, there are limitations on some source terms that are related to fuel but not directly connected to it. So there are multiple, Jason said, there are multiple conditions, very plant specific. In some cases, you may be limited by the grid. So it's not even your plant, it's the how much power I can add to the existing electrical infrastructure if I want to operate power. So some of those considerations that they will be taking place when utilities consider power upgrades and the size of power upgrades. Thank you all. This is interesting, a very open question here, but what, it's actually not directed anyone specifically, but it says, what is the expected increase in tolerance or coping time with ATF? And I will start by saying that as the facilitator, I absolve you of saying anything that's overly committal. Right, so I can start actually because we looked at the safety benefits of ATF right after Fukushima and it was kind of bland because the safety limits stay for the traditional fuel, right? So we would still don't have explicit safety limits that are ATF specific. So what we did, we used the safety limits for traditional fuel and we did systems analysis, thermohydraulic analysis using ATFs and we did see increase in coping time. It wasn't too significant. So in some cases it's about 30 minutes, but in some other cases it's just a few minutes. So that would not really make you to change your way you operate the plants or change your accident sequence analysis or success criteria for your plant. We did see dramatic increase in hydrogen production, which is one of the considerations that ATF, or ones of concerns that accident-tolerant fuels address. So that was really dramatic reduction in hydrogen production during accident scenario. But I suspect we will increase a larger coping time increase when we do know the real safety limits of ATF specific safety limits. At what point fuel starts to melt and molten starts changing the properties. We don't have that information yet and that's why we really work closely together between DOE programs to address that as part of the portfolio of R&D that needs to be done. I could add that obviously when we first started the program we were thinking of longer coping times that people talk of now, hours, days. And as a matter of fact, I remember a study by Professor Corridini saying that whatever coping time you have with the type of things you're considering with copings, you'll get a benefit. You'll delay because you'll let decay heat have decayed. Because of the decay heat source is decaying. Whatever coping time you have. And I always thought that was important. And I know the last, I didn't hear minutes but I've heard hours. But to me a couple of hours isn't so bad if you have to plug in an extra power source or something. So I've always found coping time interesting but very hard to quantify. Yeah, and I was just gonna comment. I mean, well, it's hard to say what ATF's gonna give us when we haven't selected which specific concepts we're gonna license and deploy. But I think some of the studies we're talking about have proven that even when you just pair it with flex equipment as an example, there's very meaningful benefits. And again, hours matter when you're doing things under the type of conditions that we're talking about. So I think NEI's published some of the studies related to that and shown that it is hours in some cases, but that could be hours that are meaningful from a safety perspective. Thank you. And we have a fairly lengthy question here. So bear with me as I read through it but it's like a thoughtful logic flow here. The new draft license renewal generic environmental impact statement provided in Secchi 24-0017 evaluated operating nuclear power plants as it relates to updates in the quantification of accident source terms, increases in licensed reactive power levels, i.e. power upgrades, and increases in fuel burn-up levels. And concluded that the probability-weighted environmental consequences of a severe accidents were small. Plant-specific population dosers for all operating plants have now been performed for all plants using level three PRA analysis. During the license renewal, SAMA analysis. And the effects of these changes can be calculated generically and on a plant-specific basis using level three PRA population dose risk values. These analysis coupled with substantial efforts from both industry stakeholders and the NRC offer a robust framework for evaluating the level three PRA population dose risk associated with severe accidents on a generic as well as plant-specific basis for several of the ATF, for several of the ATF considerations. My specific question pertains to whether the NRC staff could leverage these level three PRA analyses to provide insights into risk profile associated with new accident-tolerant fuel technologies. Given a thorough review and approval process undergone by these analyses, could they potentially alleviate some of the uncertainties surrounding ATF implementation? The question is, shortened version is, can the NRC leverage the effort that's been put into the level three PRA development to benefit our look at ATF? We do have members of the staff, I see you're going to grab the microphone, so appreciate it. Yeah, this is Don Palmrose. I'm a senior rector engineer in the environmental COE and a member of the ATF working group. It's a standard practice in NEPA and in the NRC's environmental review process to leverage prior environmental reviews, such as what was done for SAMBA reviews and license renewal. And so we look at leveraging that information to the maximum extent possible and practical. Don, can you speak into the mic a little bit more so I can make sure? Okay, is that a little bit better? Thank you. And so for a site's most current license renewal, final supplemental environmental impact statement that should be examined to determine whether the information and findings it contains can be applied in the particular licensing application for that specific site. There's other conditions that can be considered as part of that. So whether it's the part of the PRA analysis that's been updated would need to be looked at to see if it can be, need to be reassessed in that as a new significant review and that subsequent licensing action, such as in deployment at ATF and power up rates. Thanks, Don. Okay, and I think we've made it through all of the questions that were submitted. We have less than five minutes here, so I think we're doing great on time. I do again want to thank the panel members for your presentation and fielding a lot of the questions, interesting questions, and having the wonderful discussions about those. And so I thank you again for being here. I thank you for the audience for being here as well. Again, I'll point to the QR code. Please scan that and provide any feedback on the session and what we can do better in the future. And with that, I'll close out the session.