 Good afternoon everyone. Welcome back from lunch and welcome to the reactor decommissioning technical session planning for tomorrow. My name is Ashley Roberts and I'm the deputy division director for the division of decommissioning uranium recovery and waste programs in the office of nuclear materials safety and safeguards. I've been with the NRC for over 13 years holding several mission and policy support positions across the agency. Next slide please. As we all know the nuclear energy landscape looks very different from what it was a few years ago. Decommissioning remains a growing part of our workload because of the increasing number of power reactors transferring to active or accelerated decommissioning immediately upon closure. To adapt to this the NRC continues to enhance and risk inform the licensing and oversight of our decommissioning programs by using lessons learned from the past as we plan for the future. This afternoon's reactor decommissioning panel is an extension of the panel we had during last year's RIP. Today you will hear about key milestones from the program over this past year and how we are continuing to build on these activities as we safely and effectively terminate licenses for power reactors entering decommissioning. Now let me welcome our four panelists representing the NRC and the Nuclear Energy Institute. The NRC panelists include Bruce Watson. Bruce is the chief of the reactor decommissioning branch, Dan Doyle, a senior project manager, and Cynthia Barr, a senior risk analyst. Representing the Nuclear Energy Institute on today's panel is Bruce Montgomery, director of decommissioning and use fuel at NEI. On the next slide you will see their contact information. With that I would like to invite you all to submit any questions via the chat function of the platform throughout the session. We will address questions during the Q&A portion after the panelists present and as time permits. Thank you for your attention and Bruce Watson over to you. Thank you Ashley. My title, my presentation, is looking forward in the reactor decommissioning program. The program continues to grow and the NRC is working hard to meet the challenge. Next slide please. The NRC's license termination rule will be 25 years old this year. The rule is performance-based and risk-informed, providing significant flexibility for the licensees. Since 1997, 51 complex material sites, 18 research reactors, and 11 power reactors have completed license termination. Or in the case of power reactors, the site is reduced to the on-site dry fuel storage facility. In 2022, a few more milestones it's worth mentioning is that 10 CFR 20 is 40 years old and the NRC EPA MOU on decommissioning is also 20 years to meet. Next slide please. Before looking forward I thought it would be prudent to look back at the past. In addition to the important work that Cynthia and Dan will be talking about, our division had a number of significant accomplishments. We terminated at the 11th power reactor license at Humboldt Bay. And in other words, we completed the final partial site release, leaving only the on-site dry fuel storage under NRC license. The staff terminated two research reactor licenses at General Tomix. These were the 17th and 18th research reactors licenses to be terminated. On the materials side, the staff terminated the license at Sigma Aldridge. Turning back to the reactor area, we were able to return to in-person public meetings and held the Indian Point and Duane Arnold PSDR meetings. We are in the process of scheduling the Diablo Canyon PSDR meeting, which has been delayed by the pandemic. Next slide please. One area that I think we can all improve in is communication with stakeholders. Licensees should proactively communicate with the states and local officials on your plans for decommissioning. This needs to be done in advance to ensure technical and regulatory issues are understood with no surprises. NRC continues to encourage licensees to sponsor and actively participate in decommissioning community advisory boards or engagement panels. This provides an organized forum for exchanging information and input from the local community. The NRC will continue to participate when invited to discuss regulatory processes at community advisory boards. Staff frequently meets with state and local officials, Native American tribes, and congressional staff. Next slide please. By 2034, only 12 years from now, based on licensee schedules and the 60-year completion requirement for the older plants, 20 plants including the GE training reactor will have licenses terminated. The inventory will be down to only a handful of plants as long as the plants, no more plants, cease operations. And I'm sure the lower level waste disposal site operators will be seeing a fairly steady stream of waste and revenues for the foreseeable future. Next slide please. At the last few ricks, I have stated that we could have as many as nine LTPs in the review process. Well, considering that we're presently reviewing the Fort Calhoun LTP, the remainder of 2022, 2023, and 2024 are going to be very interesting if the licensees do submit the LTPs on the schedules they have told us. With Fort Calhoun LTP included, I count 10. I'm sure hope the LTPs are of high quality. Speaking of high quality, NEI has been working on an LTP guidance to improve the quality of the LTPs, but I'm not so sure it will be very helpful in the near term with the expected number of LTPs expected. Next slide please. We need your help in cooperation on licensing requests. The staff understands the cost and associated with the licensing actions, so the licensees then step up and manage your licensing request. We continue to have licensing actions submitted without pre-submittal meetings. We have to continue to have requests for expected expedited schedules even though the licensee has been advised that the expected time that we need to complete the licensing action. Again, the licensees must do a better job planning and managing their license and request so the staff can accommodate the work. Dan Doyle will be discussing the decommissioning transition rulemaking status, and while this will make future plant permanent shutdowns more efficient, we have been receiving a number of first-kind requests. Next slide please. Looking forward, the NRC is addressing our resource needs. We have a Reactor Decommissioning Strategic Project Plan, which includes more resources including project managers, health physicists, and risk analysts. In concert with our HR Human Resources Support Organization, we will continue to support the Nuclear Regulator Apprenticeship Program to help develop college graduates. We also have a Comprehensive Health Physics Training Program that will help develop our health physicists. Regional offices have consolidated the reactor operating health physics and decommissioning health physics inspectors to make them more efficient with the use of resources. And then lastly, the decommissioning staff here at headquarters have cross-qualified a number of personnel to be decommissioning human inspectors. Next slide please. With a number of license termination plans expected, the licensees need a plan to allow for adequate staff time to complete the licensing requests. We have the NEMA reporting requirements to Congress that makes an encompass on licensees to provide quality LTPs. And some of the questions I have are will there be more license transfers to accelerate decommissioning? I'm still concerned about sharing lessons learned and best practices by the industries. And I think we are all concerned about the adequacy of the resources to support the decommissioning activities. And then lastly, in the long term, what potential, how will the potential approval of spent fuel consolidation and interim storage applications impact the decommissioning of the future reactor sites? With that, I'll turn it back to Ashley. Thank you. Thanks Bruce. I will now turn it over to Dan Doyle, Senior Project Manager who will discuss the status of the decommissioning role. Dan. Good afternoon. My name is Dan Doyle. I'm a Senior Rulemaking Project Manager at the NRC. And I'm happy to be here today to provide an update on the status of the decommissioning rulemaking. The timing of the RIC and this project lined up perfectly because we just published the proposed rule last week. So we are officially in the comment period right now. Next slide please. As an introduction, let me start with the official title and a high level overview of why the NRC is doing this rulemaking. The official title is shown here on the slide, regulatory improvements for production and utilization facilities transitioning to decommissioning. Sorry for the long title that it doesn't have a clever acronym. Some people refer to it simply as the decommissioning rulemaking or the transition to decommissioning rulemaking. But this is the official title that you'd see on documents related to this project. Why is the NRC doing this rulemaking? We're updating the regulatory framework for nuclear facilities transitioning from operations to decommissioning with the following goals. Maintain a safe, effective, and efficient decommissioning process. Reduce the need for license amendment requests and exemptions from existing regulations. Address lessons learned from licensees that have completed or are currently in the decommissioning process. Align requirements with the reduction in risk that occurs over time while continuing to maintain safety and security. And address other relevant decommissioning issues. Next slide please. Current status and next steps. So as I said, we just hot off the press, we just published the proposed rule in the federal register last Thursday. So that was March 3, 2022, if you happen to miss it. The comment period will be 75 days. So the last day to submit a comment is May 17. We are planning for public meetings later this month, and the meeting details for those should be coming out soon on the NRC website. After the comment period closes, the NRC staff will review all comments and prepare a final rule package and also update the regulatory guidance documents. We will hold another public meeting later in the process to focus on implementation dates. And we plan to provide the final rule to the commission for a vote in the fall of 2023. Next slide please. So taking a step back for a minute, I would like to provide some context about why the NRC started this rulemaking. One of the direct reasons is because of the increase in plant shutdowns, some with relatively short notice. And this focused the NRC's attention on the need to consider some changes to regulations related to decommissioning. There was a period of about 15 years from 1998 to 2013 where no power reactors permanently ceased operation. But since 2013, as shown here on the slide, 12 power reactors permanently shut down, defueled, and entered decommissioning. Coming up in the next few years, licensees for three reactors have informed the NRC of plants to shut down, and several other reactors may be at risk of shutting down. Factors affecting licensees' decisions, although the licensee, not the NRC, would make the decision to shut down a plant voluntarily contributing factors affecting that decision likely include current market conditions such as decreased demand, lower cost alternatives, or subsidies for renewable power, as well as anticipated plant modification maintenance and repair costs. The NRC has used case-by-case evaluations to adjust requirements designed for operating reactors once those reactors decommission. Since the reactors shut down, the number of potential accident scenarios and risks of radiological releases are greatly reduced. The licensee's focus also changes from operations to decommissioning. And based on this, licensees have requested certain license amendments, regulatory exemptions, and relief from orders that reflect this reduction in risk and change in focus. Typical amendments include changes to the emergency plan, technical specifications, and use of certified fuel handlers in lieu of licensed operators. Typical exemption requests include emergency preparedness, security, and the use of the decommissioning trust fund for spent fuel management expenses. Licensees have also requested relief from the NRC's post Fukushima orders. Other NRC actions related to decommissioning include reviewing and holding public meetings on licensees post shut down decommissioning activities reports. The NRC staff understands that the decommissioning transition process can be improved and made more efficient and predictable by reducing the reliance on license amendments and regulatory exemptions. So that is one of the drivers for this rulemaking. I would like to note that the NRC staff published a comprehensive report in October 2016 capturing lessons learned and best practices from the decommissioning licensing activities completed for plants that had shut down from 2013 through 2016. And the staff is considering these findings in the rulemaking. The NRC had initiated a similar effort in the late 1990s but it was set aside as the agency rapidly shifted focus and resources to the security of nuclear facilities and radioactive sources following the terrorist attacks of September 11th, 2001. Next slide please. This slide shows the major steps in the rulemaking process that we have completed and those that are still ahead. The yellow star in the center left box shows where we are today with the recent publication of the proposed rule. Public input has had an important role in the development of this proposed rule and this comment period is the third comment opportunity for this project. The first was when we published an advanced notice of proposed rulemaking in 2015 and the second was the draft regulatory basis in 2017. We're seeking public comment on the proposed rule through May 17th to fully inform our rulemaking and the public comment process is the public's opportunity to influence the regulation that will guide future nuclear power plant decommissioning. Next slide please. The NRC also published last week four draft regulatory guidance documents for public comment in parallel with the proposed rule so just to be clear this is a combined request for comment covering both the proposed rule and all four of the associated guidance documents together. The first one draft guide 1346 is emergency planning for decommissioning nuclear power reactors and that would be a new regulatory guide. The other three are updates to existing regulatory guides. A draft guide 1347 is decommissioning nuclear power reactors, draft guide 1348 is assuring the availability of funds for decommissioning production utilization facilities and draft guide 1349 is standard format and content for post shutdown decommissioning activities reports. I would also like to mention here that the NRC staff recommended new or updated guidance or inspection procedures in lieu of rulemaking for several topics that were evaluated back in the regulatory basis stage. These topics were the post shutdown decommissioning activities report submittals, the role of state and local governments in the decommissioning process and managing aging management of certain plant system structures and components. The staff's rationale for this approach is discussed in the regulatory basis document issued late in 2017. The proposed rule includes a section called specific requests for comments and there is one the first one actually that focuses on post shutdown decommissioning activity reports submittals and the role of state and local governments. So we are seeking input on that. Next slide please. The proposed rule takes a graded approach to decommissioning where different levels of requirements apply at different stages of the decommissioning process. Across the top of this table are the four levels used in the proposed rule as a facility goes through the decommissioning process. Level one begins after the facility dockets the two required certifications. One is for permanent cessation of operations and the other is that fuel has been removed from the reactor vessel. Level two is after a period of sufficient decay of the cement fuel which would generically be 10 months for a boiling water reactor or 16 months for a pressurized water reactor if they meet the criteria in the proposed rule. Level three would be when all fuel is in dry cask storage and level four would be when all fuel is offsite. The rows in this table show the topic areas that have updated requirements linked to these levels. Emergency preparedness would use all four levels starting with a post shutdown emergency plan in level one through level four where there is no longer a need for an onsite radiological emergency response plan because all fuel is offsite. Other topic areas that use the graded approach include physical security, cybersecurity and onsite offsite insurance. Next slide please. So to wrap this up here are the major steps for the path forward. Again we just started the public comment period for the proposed rule. The last day for comments is May 17th. We are planning for public meetings later this month and we'll post additional information on the NRC website when that's available. We will then review and address public comments and develop the final rule, final regulatory guidance. The target date to submit the final rule to the commission for review and vote is fall 2023. One final point that I'd like to make is that we developed a dedicated web page on the NRC public website with convenient links to the proposed rule and related documents as well as information about previous and upcoming public meetings. I encourage you to check that out if you will be reviewing the proposed rule. Probably the easiest way to find the link is if you find the press release from last Thursday that is featured prominently on the NRC homepage right now nrc.gov. It's currently the fourth item listed under latest news. We look forward to your feedback on this proposal. Thank you very much and I will turn it back over to Ashley. And thanks for that update. I will now turn it to Cynthia Barr, a Senior Risk Analyst who will give us an update on guidance updates as well as other decommissioning initiatives. Cynthia, over to you. Hello, can everybody hear me okay? All right, yep. All righty. Hello, my name again is Cynthia Barr. I'm a Senior Risk Analyst at the NRC and I'm here to provide an update on guidance and other decommissioning initiatives. And you can go ahead and advance it to the second slide. Okay, so guidance updates include two of three volumes of our consolidated decommission guidance, UREG 1757. Volume one is more of a process or programmatic type document for material sites undergoing decommissioning. Volume two is more of a technical guidance document focused on radiological surveys and dose modeling to derive cleanup levels. The volumes were last updated in 2006, so there were lots of updates needed. The Multi-Agency Radiation Survey and Site Investigation Manual, or MARSUM, has also been revised. The public comment period ended just last month and the MARSUM Working Group is working hard to address comments. Next slide, please. Okay, proposed significant changes to UREG 1757 Volume 1 include guidance related to changes in fees as sites transition from operations to decommissioning. New guidance on the decommissioning planning role found intensity of our 20.1406 related to minimization of contamination during operations. And this is just to help facilitate decommissioning down the road and prevent creation of future legacy sites. This is not to be confused with Dan's role that he just talked about. This is an older role. A status update on the Site Decommissioning and Management Plan, or SDMP, the SDMP was the predecessor of the license termination role and ended in 2004 after all of the program objectives were met. Next slide, please. Okay, so major changes to UREG 1757 Volume 2 are listed on this slide. I'll provide a couple of examples. Key updates to dose modeling guidance are primarily found in appendix I and J on topics such as exposure scenarios for buried radioactivity, methods to introduce more realism into the dose modeling calculations for multiple elevated areas, and support for risk-significant distribution coefficients including potential need for site-specific values. Updates to guidance on radiological surveys are primarily found in appendix G and include surveys of open excavations, substructures and materials planned for reuse, and appendix O guidance on the use of composite sampling which could alleviate costs associated with sampling for hard-to-detect radiative lines. Next slide, please. Okay, so UREG 1757 Volume 1 is being completed and is planned to be issued for public comment later this year. UREG 1757 Volume 2 was issued for public comment back in December of 2020. We received over 200 comments and nine comment letters. The comments have been addressed in final revisions incorporated into the report. Final publication is expected in the late summer of the year 2022. Next slide, please. Okay, so Marsum is a multi-federal agency guidance document that was recently updated in revision 2. The update was about 20 years in the making, so again, lots of updates were needed. I will not go through all of the changes, but some important updates include new guidance on scan-only surveys, additional examples and guidance on statistical tests and associated parameters, updated information on radiation detection instruments used in the field, and a new appendix E on ranked set sampling, which could also be useful for hard-to-detect radiative lines. The public comment period just ended in February and the document has been peer-reviewed by EPA Science Advisory Board. Next slide, please. I wanted to provide an overview of the EPA Science Advisory Board and public comments. They include comments on scan survey validation and the metrics that are used to demonstrate compliance using that method, comments on the need for additional guidance on more modern survey systems with data logging, survey methods for discrete radioactive particles or hot particles, and survey methods for subsurface radioactivity, which is harder to access compared to surface radioactivity, and comments on the measurement quality objectives, including transparency, terminology, types of, and methods for addressing uncertainty. Next slide, please. Next I'll be talking about other decommissioning guidance and co-development initiatives, including development of subsurface investigations guidance and discrete radioactive particles, communications, and or guidance. And finally, visual sample plan computer code improvements. I did want to make it clear that any internal guidance the NRC develops will be issued for public comment prior to its issuance. Next slide, please. With regard to subsurface investigations guidance, we did have a workshop last year with over 160 participants attending, so there's great interest in this particular topic. Our contractor, SCNA, is completing a draft technical report this month focused on methodologies for survey design. A second workshop is planned for May 11th. Pacific Northwest National Laboratory is also completing a scoping report for visual sample plan code improvements to facilitate subsurface survey design and data analysis. NRC staff plans to develop interventions based on SCNA's final report and the workshop findings in late 2022. Please also check out our digital exhibit on the subsurface project at the RIC website for additional details. Next slide, please. So we're also looking at survey and dose modeling methods for discrete radioactive particles or hot particles. DRPs haven't found at some decommissioning sites. Licensees should be aware of potential activities that could generate DRPs and have a program in place to control DRPs to avoid issues with assessing the presence and risk significance of DRPs at the time of license termination. Public meetings are planned for late 2022 to discuss this issue. Staff is evaluating the need for interim guidance and or some other form of communication on this topic. Next slide, please. Visual sample plan is a code developed by P&L to help design and evaluate radiological surveys. This slide lists a number of improvements to the code. The first two improvements are already incorporated in the current version of the code and the code is available for free download at NRC's ramp webpage. P&L is currently scoping out subsurface survey design and data analysis tools, which will be available in a future revision to the code. Next slide, please. So in conclusion, several guidance initiatives are completed or well underway to share lessons learned and experience from recent decommissioning reviews. NRC has contracted work to improve the guidance in two key areas as well as scoping out improvements to computational tools. NRC will continue to work with our stakeholders with additional opportunities for public participation plans. Please check out our What's New and Decommissioning webpage to be kept informed of meetings and progress on guidance development, including all the things that I discussed today. Also, many staff are involved in these projects, and they are listed in the slides at the back of this presentation. Should you have any questions or comments, please do not hesitate to reach out to NRC staff. And with that, I'll turn it back over to Ashley Rawretz to introduce our next speaker. Thank you. Thanks, Cynthia, for the details on all of those program initiatives and thanks to all of the staff in the program working on those. With that, I will turn it over to Bruce Montgomery from the Nuclear Energy Institute, Bruce. Yeah, thank you, Ashley. I always appreciate the opportunity to speak at the RIC. I lead the NEI Decommissioning Working Group at NEI, which is the leading convening authority for the decommissioning industry. And my title is Director of Decommissioning and Use Fueled NEI. Now, you might recall that last year at the RIC, I outlined a 2025 vision for what I call a new normal in decommissioning, and the steps that we would need to take to achieve the decommissioning objectives as part of a truly sustainable industry. I think we're often judged in any industry by the footprint we occupy when we build and operate, but also by the footprint that we leave behind when we're done. And in nuclear, we strive to make that footprint as close to zero as possible. So this year, I want to reinforce the premise that our success in decommissioning is key to demonstrating the policymakers, the investor community, and to the public. The commercial nuclear energy is indeed a truly sustainable enterprise. Success is not a given in a path that we've chosen, and a path we have chosen to take in the United States is accelerated decon. Using some pretty innovative business models, we need to show that we can use these business models to take a nuclear plant from shutdown to Greenfield and do so safely on schedule and within the budgetary limits of the decommissioning trust fund. Now, while there's a lot of enthusiasm that we can achieve typical schedules of eight years or less with these models, there are challenges that must be overcome if we are to achieve our goals, and I think we've heard some of them discussed already this afternoon. Next slide, please. I chose this quote from a contemporary Japanese philosopher, because I think it really applies to our situation. No matter how complex global problems may seem, it is we ourselves who have given rise to them. They cannot be beyond our power to resolve. So consider the fact that many of the plants that are in decommissioning today started from a Greenfield site that was turned into an operating reactor in only four or five years. So it seems to me it should be reasonable that we'd be able to do the reverse in eight years or even considerably less if we put our minds to it, and if the regulatory framework facilitated it. Next slide, please. Over the past year, we've seen some pretty impressive achievements in some important areas for expediting a safe and orderly transition through the decommissioning process, and I expect we'll see some more. I've listed some here and I won't go through those, but I think at the heart of these successes is what I would call sound project management being brought to bear on the business by decommissioning specialty companies. And one of the outcomes that is emerging is a growing public acceptance for the process, where the emphasis now is less focused on the decommissioning process per se, but more on how soon the site can be returned to the community for productive use. Next slide, please. I'd like to highlight a couple of notable achievements that have occurred just this past year. It's San Onofre. The energy solutions team demonstrated that an entire reactor vessel could be packaged, safely shipped, and disposed of as a unit, avoiding the need for segmentation on site. And at Oyster Creek, the Hulltech team emptied the span fuel pool and placed all fuel in dry storage in a record time, only to be surpassed by the team at Pilgrim, demonstrating that the time from shutdown to cessation of operations to all fuel placed in dry storage could be as little as 30 months. This reduces critical path for the projects. Next slide, please. So while we celebrate these successes, we must take note of the challenges that remain, and I'll put them in three bends. On the front end, we need a durable regulatory framework for transitioning out of operations and for decommissioning. The current framework, involving many license amendments and exemptions, is impractical and adds little value to public in terms of safety and security. Very heartened by the presentation that Daniel gave us on the new rule, that will not be, in effect, for the current wave of plants going through decommissioning. So we're really talking about the future for decommissioning and having a stable regulatory framework. Now in the middle, we need to achieve a higher degree of collaboration, as Bruce spoke to so eloquently a little while ago, and does every year. Collaboration in the industry in terms of sharing what works, what doesn't work, so that we can accelerate performance improvement. And on the back end, and this is what Cynthia addressed, this is becoming increasingly and painfully apparent as we need a stable and practical license termination process that is informed by the real public health impacts associated with the release of a site for unrestricted use. Next slide, please. So what was being done to meet these challenges? On the front end, again, we're very pleased with NRC's release of the proposed transition rule last week, and we're excited to offer comments on this broad-ranging rule and the associated guidance. It's an awful lot to work through, but we have a very large and diverse industry team that's been assembled, looking at all the different aspects of the rule. We'll respond to the rule, the guidance, we'll offer comments that are constructive, and we'll also respond to the special questions that have been included in the rulemaking package. So we're really eager to do that. But in the middle, we're seeking to encourage a higher degree of industry collaboration and we're pleased to acknowledge the work done by EPRI to make their extensive decommissioning library widely available to decommissioning company licensees and their contractors, companies that aren't necessarily a member of EPRI at this point in time. There are now many industry forums that share experience, industry conferences, working groups, and issue specific task forces that work diligently to bring new information to the market and share that information to improve performance. And finally, we have an NEI set of board-level executives that have formed a high-level decommissioning task force. They meet to address issues affecting the health of the decommissioning industry, including the degree to which we exhibit the principles of continuous learning and improvement. And finally, on the back end, the industry is working hard with the NRC to develop a license termination process that will reliably result in unrestricted release of former reactor sites in a way that meets public health standards. And I'll talk more about this in a moment. Next slide, please. The good news is, as Bruce Watson discussed earlier and talks about it in each break, is that we know how we know that we can demonstrate to the NRC that decommissioning objectives have been achieved and that radiological public safety goals have been met for unrestricted release of the site. Here we have the Humboldt base site, which is the latest example of that. The NRC terminated the license for this site in November. And it was a long time coming, but we've gotten to the appropriate end point. Next slide, please. But here we have the Zion site, where physical decommissioning work has been completed for some time now, but is working through a rather arduous process of final status surveys in anticipation of license termination. And here we find the licensee working through issues, some of which Cynthia has addressed, which is the need to make sure that we've dealt with the presence of this great radioactive particles and also subterfus structures. Next slide, please. And at the La Crosse site, where decommissioning work has also been completed, long been completed, the effort to achieve NRC agreement to terminate the license has been delayed. As a retired coal plant, you see in the background a fully decommissioned La Crosse nuclear plant occupied the space in the foreground. There are several reasons for these delays at Zion La Crosse and elsewhere reasons that can be reasonably attributed to both the NRC and to licensee performance. My observation is that the root cause is the lack of a universally accepted guidance on how license termination is supposed to be planned for and executed by the licensees and then reviewed and approved by the NRC. Next slide, please. Hence, the industry's main effort in decommissioning today while we review the proposed transition rule is to develop industry guidance on how to achieve license termination. NEI 2201, which is currently under development and draft form, seeks to distill thousands of pages of regulatory source material into a comprehensive but concise guide on how to plan for and execute a successful license termination process. We plan to share a draft of our document with the NRC in June with the goal of submitting the report for NRC review and concurrence by the end of the year. We look forward to the workshops that Cynthia talked about, which are going to be addressing a couple of the key technical and process issues related to how to do subsurface surveys and provide the requisite data that results to the NRC in a quality fashion and also to address the way to deal with the presence and to prove the non-presence, I should say, of these discreet or hot radioactive particles. There's a lot of work to do yet, but our intent is to achieve the goal that Bruce Watson laid out earlier, which is to provide guidance to the industry so that the license termination plans that are submitted for review to the NRC are quality plans that are accepted by the NRC and can be executed by licensees in a high quality fashion. Next slide, please. So in conclusion, I would say the future of accelerated decon while promising is still a work in progress. Whether or not we are successful here will determine the viability of these business models that have emerged to support decon. Thank you. Back to you, Ashley. All right. Thank you very much, Bruce. Okay. With that, I invite everyone to continue to submit questions and the chat function. And I think we've already received a couple so far, and the first one I have is for Bruce Watson. Bruce, the first question is, at what point in decommissioning is NRC oversight? Well, it's an easy, reasonably easy question to answer because at material sites, when the licensee demonstrates they meet the unrestricted license dose requirement, we can terminate the license and we leave. For reactors, though, it's a little bit more complicated. For reactors, we shrink the site down to the dry fuel storage facility or independent spent fuel storage facility. But that remains under license. So most of the NRC processes go away with the exception of those required to make sure the fuel stays safe and insecure in the dry storage facility. So once the dry fuel is decommissioned, then we will go completely away. And just to supplement that, we continue oversight throughout that decommissioning process. That's correct, including inspecting the dry fuel storage facility. Yes. Thanks, Bruce. Okay. The next question I have is for Dan Doyle. Dan, can you elaborate on the lessons learned that you gathered and how they are influencing the decommissioning rule that you discussed, rulemaking that you discussed? Sure. I can start with this one. And Bruce may be able to add some additional information. That there was a bit before my time, I've been involved with this project since 2018. I know that the lessons learned report that I did mention was in 2016. I pulled it up when I saw the question and I scanned the recommendations which are on page 40 there. Actually, none of those jumped out to me as something that we didn't include it in the rule. But maybe Bruce might be able to recall any. But what I can point out is if you look in the proposed rule that we just published, we have the document is organized in the discussion section by the 16 topic areas. So, for example, emergency preparedness, physical security. So you see that under the major provision section. And then in the discussion section, we have a heading for each of those with some background information about, you know, how do things work today? What is the NRC see as a regulatory, you know, challenges or issues in this area? And what are we recommending changing? How do we think it was going to address that? So folks can, if you wanted to look in there, if any particular topic you wanted to see kind of where more information about where it came from, you could look at that. And just to point out that, let's see. I think perhaps the low-level waste change from 20 to 45 days I think might have come out of those lessons learned. I'm sorry, I'm just not extremely familiar with the origin of where the input came from. And then just a final point is that so the topics, the following topics were something that the NRC staff had reviewed and as recommending changes, it wasn't specifically directed by the commission to include here. So the topics for drug and alcohol testing, cybersecurity, the foreign ownership control domination were the topics that, and I'm sorry, and then clarifications between part 50 and 52 licensees in the rural language were topics that the staff had included as a determined to be relevant to decommissioning. So hopefully that answers the question. Bruce, anything else you want to add to that? Sure. I was the chair of that lessons learned group along with a counterpart from NRC. I think the overriding lesson learned in the big picture was that we really needed to revise our regulations to make the transition from operations to decommissioning more efficient. There's a number of different examples. You gave one, which is the 10 CFR 20 appendix B, excuse me, appendix G, which reduces, increases the notification time from 20 days to 45 days for their shipment of radioactive waste. And quite simply, the reason for that is a lot of the licensees ship bulk waste by rail. And it's not a direct line like you would have with a truck. So it takes more time. And they do track the shipments during the transportation. Secondly, I was going to say most of the changes clarify a lot of our information. And we found that we didn't properly address a few different things. And especially in the spent fuel area where we have duplication. And so this clarifies all of that. So like I said, there are a lot of lessons learned that the whole rulemaking is based on. I hope that is helpful. Thanks, Bruce. Okay, the next question I have is for Cynthia. Cynthia, what was the impetus for the subsurface guidance that you talked about? Thank you, Ashley. That's a very good question. So almost all complex decommissioning sites have subsurface residual radioactivity. However, marsium is just for surface oils. So there was an initiative to develop, I think it was called Marsas, which is the subsurface equivalent to marsium a while back. And that would have been in conjunction with the other federal agencies working on the marsium and other documents. But other guidance documents took precedence over the Marsas. And so the initiative kind of fell by the wayside. And there was also this perception that it was going to be very difficult to do for all the different types of sites that the federal agencies looked at. So the other problem is that subsurface soils are harder to access. So survey design optimization can become a very complex problem. Now we did have lessons learned, though, from surveys of subsurface soils and materials at or from materials and reactor sites that we had recently reviewed. So we did update our guidance in Appendix G and J on surveys of open excavations and soils plan for reuse. And J has exposure scenarios for very radioactivity, including reactor basements of structures. However, that guidance is really focused on surveys and dose modeling for, again, an open surface where you could apply marsium to. So it was a little bit easier to provide guidance in that area. We're still looking at those particular issues and making sure those methods make sense or see if there's another method that we could use to handle open excavations as well. But the larger problem that we have is when you don't have an exposed surface, how do you go about trying to optimize a survey design for what could be a very large volume of soils? You can't scan the soils unless you dig them up. And so became this very difficult problem. And it's a problem, I think, that a lot of sites, not only NRC licensees, but other sites and internationally, I think people are looking for a marsium type document for the subsurface. Now we can't address all of that, but we did think that we could focus on the types of sites that we'd be commissioning, including rancher sites and come up with something that would be doable. And there are international and domestic examples of how to do this. So we contracted out with SCNA and PNL is also looking at some code improvements to visual sample plan. But just to develop methodologies that could be used to address this particular problem and optimize the survey process, as well as tools to determine if mediation is necessary and remedial volumes, and even to demonstrate compliance. And this would draw on a lot of prior information, basing approaches, as well as statistical approaches and just all the expertise that the experts have to offer to optimize these sampling designs and make make better decisions based on this approach. And so we hope to issue some draft guidance or this technical report very soon this month. We're going to be issuing a draft technical report from SCNA or contractor and PNL is coming in with a scope and report for visual sample plan for code improvements to implement those methodologies as well and talk about those at our May 11th workshop. And so I would just remind you we have this what's new and the commissioning website where you can stay abreast of all the activities related to those initiatives. And hopefully that answers your question. That's all I have. All right. Thank you, Cynthia. The next question comes from Spain, excuse me, Bruce Watson. Bruce, plants have a rigorous security program during operations that includes carrying out routine security drills. Can you describe how requirements typically change during the years the plant is undergoing decommissioning? Sure. At a high level, nothing really changes when the plant shuts down. The security plans and drills and training all continue. The, you know, focuses on protecting on the spent fuel. And so during the first year or so, nothing really changes. With the fuel being transferred to this drive storage, with the completion of that and with all the fuel in the dry fuel storage, it has its own security plan and requirements for drills, training and maintaining a proficient job, excuse me, security workforce. But the remainder of the site maintains a what I'll call an industrial security force. They're continuing to be armed and to protect the property. And they also have training and drills commensurate with the work that they do to protect the site. I think that's about it. Thank you, Bruce. Okay, the next question, I think we'll start Bruce Montgomery, if you want to start, and then Bruce Watson, you might have something to add here as well. In order to share lessons learned, licensees need to share information. Most decommissioning companies consider their processes trade secrets, which are proprietary and reduced to share with competitors as a result. Can you elaborate on what is being done by NEI or the NRC to share this information and capture lessons learned? Yeah, thanks, Ashley. I think there's, I'll start by maybe framing the problem a little bit because I came from the operating side of the fleet into this decommissioning business. And one of the things that I noticed right away was the stark difference in the degree to which information was being shared between the companies that were in the asset purchase model, or the license stewardship model, where you had decommissioning specialty companies running the operation. Whereas in the operating fleet, we were used to seeing the free and open exchange of information from problems to successes and how to solve the issues that are arising to the point where in the decommissioning business, there was very little of that. And not all of it is because of trade secrets or proprietary information, but just there was no framework around which to work with each other. There is no operating experience database for decommissioning companies or a venue with which to exchange. But we are working to change this and improve the situation somewhat. I mentioned the EPRI decommissioning hub, the rather significant, I'll even call it a vast library of decommissioning experience that resides at EPRI and was up to this point only available to EPRI members. It's now being made available to all folks involved in decommissioning and we're advertising that availability so folks can use it. And it's going to set up a two-way exchange of information where people can not only draw from the database, but also deposit information at EPRI that others can use. But aside from that, we do want to steer clear of exchanging proprietary information that folks have built their companies around. That's not what we're talking about here. And there's an awful lot of information above the level of proprietary information and trade secrets that we can share to improve our common performance across the industry. There are things like, gee, was there, there's even things we can learn in decommissioning from the operating fleet, like how to maintain water clarity in the reactor while we're doing major activities such as segmentation of the reactor internals. But there's an awful lot, I mean, an awful lot that we can learn from each other in terms of being successful in this whole new area of license termination processes. How to do surveys so that we can get them done very efficiently and quickly and provide the quality information that NRC needs to make a conclusion on the state of the site. How to write reports that submit information to the NRC so that they're not flooded with thousands and thousands of pages of dose readings and data that they would have to pour through and try to come to some conclusion around. We need to be much more efficient at how we collect and package and submit information to the NRC and this is all free and open territory for us to improve our performance and share information across the fleet. Bruce, thanks for that. I appreciate your comments and your focus on how you all can communicate across and how, you know, driving that, you know, improvement in quality will help us be more effective, you know, in our, in our reviews. I know that that's, that's certainly a focus for our division and for Bruce's Ornate branch specifically. So Bruce, did you have anything you want to add there? I know you mentioned some of that in your remarks as well. I was just going to add that, you know, the licensees can request that information be considered proprietary information and that it not be disclosed to the public. We really respect that information request, especially when it comes to financial information. But the bottom line here is we as the NRC want to make sure those regulations are followed very closely. So we do agree that information can be withheld and it is proprietary. So, you know, we, we do our best to make sure that, you know, we do keep the information that is proprietary, proprietary. I want to applaud the previous efforts by EPRI and NEI in the industry to share previous lessons learned. I think we've seen some of the dismantling processes evolve at like Connecticut Yankee, they used a grit blasting for, for dismantling the reactor internals. Some of the technologies have improved significantly and I think that's business information that competitors can find competitively bid to get. So and find out what the best processes are. I guess the big things are when in operating space, operating reactors, if someone does things that are not exactly done well, they generally advertise that. So others don't make the same mistakes, same mistakes. So I'm not necessarily, I think it was more freedom when they were utilities to advertise for the whole industry to improve. I'm not so sure we'll see that with the competitiveness of the companies doing the decommissioning. Thanks. Thanks first. Okay, the next question we have is for Dan. Dan, you indicated that you are seeking and the NRC is seeking input on state and local government involvement on decommissioning as part of the rulemaking. Besides those comments submitted on one or more of the draft red guides, are there any other options that state or local governments or others would have to provide more direct feedback as part of our process? Thank you. So as part of the rulemaking process, the best way to provide input is by submitting written comments. So we do have the instructions for how to do that in the proposed rule. So my short answer is to provide comments on the proposed rule if there's a specific change that you would request or recommend for something that's within the rule. For example, in response to the question, we have that in section five specific request for comments. So you could submit a comment. This is in response to that question. You could also you could provide comments on the guidance, as I said, and also participation at the public meetings. So commenting on the rule, commenting on the guidance, participating in the meetings. Thanks, Dan. And I think the next question, Dan, is for you and Bruce. Maybe we'll start with Bruce Watson and then you might want to add something as it relates to the decommissioning rulemaking as well. Bruce Watson, have you found the community state and stakeholder interaction increases during decommissioning? That's part one of the question. And part two, well, how will the rulemaking address ongoing stakeholder interaction during active decommissioning and after the PSDAR meeting? So Bruce Watson, I'll let you start if you want to turn over to Dan. Well, I think during operation, there's always a public interaction with the utility that operates the plant. Those are normally done through the public affairs officers for the company. But I do think they do shift to a slightly higher level, if not higher level, with decommissioning. I think the community wants to hear more information on what's going to happen at the plant. You know, when the plant was constructed, it was all clean material. When it's being decommissioned, you're removing all the radioactivity. And so that people are concerned about that having an impact on the community. So I think there is an increased interest in the decommissioning. You couple that with the loss of economic income, taxes, revenues to the local government. And that brings out a lot more concerns by the local community. We continue to want the or request that the utilities or the decommissioning companies continue to have community advisory boards. And to get information to the communication to the community, provide an information exchange and allow them to be more informed on the decommissioning activities that are planned. I don't know if I... The second part of the question, I think we'll let Dan start, is how will the rulemaking address ongoing stakeholder interaction during active decommissioning and after the PSDA, meaning Dan, did you want to start with Alan? I'm sure there's no specific change as part of the rule regarding interaction outside of the standard process. If there was a license amendment request that would... I'm not an expert in the license amendment process, but I believe that there's an input or an opportunity for stakeholder involvement in those is just generically, but we're not making a change to that as part of the rulemaking. So... Yes, and you're correct, there's opportunity for public engagement. So thanks for that. All right. I will go to our next question here, Bruce Watson. You touched on this a little bit in your previous response about impacting the... as plans for decommissioning. And so this question is related to that. Does the NRC have initiatives underway to help communities and address socio-economic issues where operating power reactors are shut down and converted back to green fields? Yeah, that's a very difficult situation. The NRC is an independent safety regulator. We're not a promoter of the nuclear power or anything associated with it. So we don't get involved in the economics and the business decisions with the plant operating or not continuing to operate. So the loss of tax revenues, as I've mentioned, and jobs and other things are a big impact to the community. And we would encourage the local communities to negotiate with the licensees on any commitments they may have to support the local community to ensure those continue, at least in the short term. So unfortunately, we don't have any regulatory authority that was given to us by the Congress to do anything with the economic issues. Thanks, Bruce. I'll just add a little bit on that. We do have an environmental justice initiative going on. The commission in response to the country's direction here, the NRC staff is conducting a systematic review of how environmental justice is addressed on the NRC's programs and policies. And so we're committed to openness with the local community. And that is part of openness is absolutely a core value for the NRC. And so that's something that we're committed to. So while, Bruce, just to add to those statements that you made that is continuing our communications and openness with the local communities is certainly a focus for us as well. All right. So thanks for that, Bruce. I'm just looking to pick up on the next question here. Bruce, this one is for you. The normal pace of decommissioning has surveys being done well before the license termination plan is approved by the NRC. Since the approved LTP forms the basis for the final status surveys, how can a licensee and the NRC ensure that such surveys performed prior to the LTP approval will allow for NRC acceptance? Well, that's actually a really easy answer. Our inspection program continues. Our inspectors will be looking at and observing surveys that are performed prior to the LTP being approved. We make it clear to the licensees that since we don't have established release limits or DCGLs as we would call them, that they are at risk. But we can also have the supplement the inspectors with our independent contractor and have independent verification surveys performed to make sure that we think that they are going to meet the criteria for that will be in the LTP. We've done this on numerous occasions. We mentioned Humboldt Bay earlier in this program. We did a number of surveys for them well before the LTP was approved. And a lot of these were conducted with the demolition of their two fossil units that were also adjacent to the nuclear plant. And so there's lots of ways we can ensure that the sites are cleaned up well before the LTP is submitted for approval. Thanks. And as you know, even with that Bruce, when the LTP comes in for approval, we would still be reviewing actions and their plans associated with the LTP to ensure that they're carried out in accordance with the LTP once approved. So not just because something's done before once the LTP is approved, we're still going to be following anything that's approved in the process. Just underscore your comments there. Yeah, absolutely. We're going to continue to inspect. We're going to perform independent confirmatory surveys with our independent contractor and do our due diligence to make sure that the site is cleaned up and meets all the requirements. Perfect. Thanks, Bruce. Okay. The next question, I think Dan Doyle is for you. We've gotten a few questions on the status or status update on the decommissioning GEIS. Do you want to touch on that for us, please? Yes, the generic environmental impact statement for decommissioning that the NRC will update that is not part of the decommissioning rulemaking project that I'm talking about. So it's not in parallel with that. It's but it will be updated separately. I don't have a timeline or additional information that I can provide right now about that. But I am aware that that's something that the staff is going to update. It was in the staff requirements memorandum, but it's being handled separately. So the NRC would put out more information about that in the near future. Thanks, Dan. All right. So the next question I have for Cynthia, if you want to get us started in Bruce Montgomery, I'm going to add many perspectives on this as well. How do you expect the guidance updates, Cynthia, that you discussed will improve the effectiveness of the decommissioning process? Thanks, Ash. That's a very good question. So I'm just going to tackle that from some of the guidance updates that we do have in several areas. And I think these are all really good improvements to our guidance that are really going to help increase the transparency of our guidance and provide a good roadmap to our licensees on how to accomplish decommissioning. So one area is DRP guidance, Discrete Reductor Particles or Hot Particle Guidance. So we received comments on both Marsom and New York 1757 volume two on the need for guidance on DRPs. So it's definitely an area I think that our licensees can benefit from additional information. I think some form of DRP guidance is needed, but whether that's just a consolidation of the existing record, which may or may not be complete, or new guidance drawing on a historical record with details, additional details not fully developed is what we're currently evaluating. Are there any gaps in the current record? And we're reaching out and looking at, we're reaching out to contractors to assess survey methods and dose modeling methods. And we're looking at different codes to perform dose calculations. And there's a lot of domestic and international references as well. So we're taking a really hard look at this. But I think what we end up with is going to be really valuable in the end to industry and to our stakeholders. So looking forward to continuing to work with our stakeholders on developing that guidance for communications. Composite sampling is another area that we added to our DRP 1757, that's an appendix O. So composite sampling can be useful for harder to tight rate of nuclides, where the costs associated with taking a large number of samples could become cost-prohibited. So being able to combine samples and reduce analytical costs so you can get a better estimate of the mean, I think it's going to be very helpful in a lot of situations. And the licensees are probably going to want to take advantage of that. So having better estimates of the mean, better data, and these approaches that are beneficial to the industry will just lead to better and more stable decisions, I think. And if we're worried about elevated areas, we also have the modified investigation level where you could assess if there's a potential for elevated areas as well. So we're not really compromising the survey approach, but we're ensuring protection of public health and safety in a way that maybe perhaps is a little bit more efficient. We've already talked about subsurface survey design optimization. We're also investing in computational tools. It doesn't really help to have a methodology that nobody can implement, or they don't know how to do it. So we're really investing in both the methodologies and the computational tools to increase effectiveness of decision-making by taking a more formal approach to this problem. It may not be Marsim exactly, but it's strong upon a lot of parallels that Marsim uses in making sure that you make better decisions and limiting decision errors. And so I think using all the information available that's really available, historical site assessment, expert judgment, containment transport modeling, geostatistical tools that look at spatial correlations and the data that you have, we're really taking this data-driven decision-making approach and optimizing the sampling design, which will make the whole process more efficient and its decisions better, hopefully. And my final example is scenario B. We did kind of emphasize in both Marsim and New York 1757 the scenario B method, which has an alternative null hypothesis that the site is clean until proven dirty. And that could be very useful when the DCGO is very low or close to zero or it's low relative to background variability. And so this provides a method so that you're not cleaning up below background. And so we don't want a situation where we're asking the licensee to clean up below background. So hopefully we'll have more examples and more application of that particular null hypothesis when it is appropriate. And that will be helpful as well. So those are some of my top four thoughts at the moment. So thanks for the question. Thanks Cynthia. Bruce Montgomery, is there anything you wanted to add from any eyes perspective? Yeah, I just wanted to to react to that by saying that all the work that Cynthia is setting up at the NRC with the contractors is absolutely critical to getting to the point where we understand what would be acceptable to the NRC and putting together a quality license termination plan with a final status survey plan within it and then to execute it in a way that NRC can accept the results in an efficient review process. The only caution I would have is that I see an awful lot of science coming at the NRC from the contractors and these tools that are being developed. But what we really need in the end is going to be a process. So how is it going to be expected that we can apply those tools in a statistical science that goes behind it and so forth so that we can come up with actual methodology in the field to conduct surveys and submit reports to the NRC that satisfies the need. So I think that's key. I think also there was recognition of the fact in one of the questions that was asked that these surveys are starting well before a license termination plan and submitted to the NRC. Some of these surveys are done during operation and accredited during license termination planning and execution. So you know there's going to be a need and this underscores I think the importance of this guideline we're putting together that will make the process more efficient and more timely and less costly for both us and the NRC and will directly address some of these resource challenges that we have because you know we really just need to have a better understanding of what the expectation is given the given a situation at a particular site and how we're going to go about proving that we've cleaned up to the appropriate standards of part 20. So a lot of work is being done. I appreciate what Cynthia's heading up and I think it's going to be beneficial going forward. I think we just need to keep our eye on the on the real target which is going to be practical methodologies that we put in the field. Thanks for that Bruce. The next question we have is for is for me so I'll read the question for myself here. Given given the limited resources for LTP reviews outlined by both NRC and mentioned by NEI during their presentation what is being done to address this resource issue and how might future LTP reviews be affected if resources remain limited? So that's a good question and you know for those of you who were able to listen to our EDO Dan Gorman speak earlier today you heard you know Dan talk about the focus that we have on you know recruiting and retaining our highly skilled workforce and making sure we have you know the right people to do the work that we need and of course as you as you heard Bruce and Bruce talk about you know the organizational capacity to be able to support these reviews is certainly a focus for us right now and so a couple things for those of you didn't hear you know hear Dan's remarks I encourage you to listen to those talk a little bit about this as well but you know we do have an effort right now in partnership with our office of the chief human capital officer focused on um you know enhancing our external hiring filling gaps across the program where needed those gaps are identified through our strategic workforce planning and so we are really bolstering those efforts right now you know in the while we're working on that you heard Bruce mention we're cross qualifying and leveraging inspectors across the program so we're prioritizing and you know focusing on focusing on you know work throughout the program based on our priorities and then some of the things you've heard about today is also how we're you know managing the work we have in front of us now you know we expect that we would achieve some you know enhance our effectiveness with some of the results of what comes out of the decommissioning role making that Dan talked about um the this question you know just came after you heard Cynthia um and Bruce Montgomery talking a little bit about uh some of the effectiveness uh uh process enhanced improvements from the guidance documents that we're working on and um you know again I mentioned when Bruce Montgomery was talking some of the um the what NEI is working on in terms of focusing on their um quality of you know their reviews which will in turn um you know improve the review process here in the NMC in addition to that um and we talked a little bit about this for those of you who didn't get the opportunity to listen we had a commission meeting not that long ago for the decommissioning and low-level loose business line and during that commission meeting um there was an overview and that is available also on our public website of our systematic approach to workload planning and there we are really looking at our lessons learned from what it is taking us to complete these reviews um especially with under the new business models and you know the time that that's taking us and what's required so we can have more fidelity in our resource estimate estimates excuse me um which is then again um sort of the starting point for everything you just heard me discuss and how we're focused on um recruiting and getting the right people here at the right time and retaining those individuals which is a huge um focus for our our culture focus for us as well so um those are that's a sort of wide overview of the things we were doing and I think um heard some other other uh plenary and other sessions talk about that as I mentioned as well so with that I will go to the next question um Bruce Watson this one's for you could you please elaborate on the restricted release option for decommissioning or any licensee is pursuing this option and is there any related guidance development underway well there's a really simple answer that I'm sorry Bruce you have an echo if you need the second one I think that'll take care of that I'm sorry I didn't hear you you have an echo oh there you go I think you fixed it okay yep you're better all right thank you uh yeah there's a very simple answer for this question uh the regulations in 10cfr 20 have very explicit requirements for restricted release and in new reg 1757 volume two there's a large section on restricted release um the good news is no one's really requested it we had one uh site a material site that was investigating it um number of decades ago and and they decided not to pursue pursue the restricted release so uh all of our sites that have been terminated to date have been terminated for unrestricted use so they're available for whatever purpose the licensee wants to use it for into the future I hope that answers the questions okay thanks Bruce I have one other one Bruce um and this um um is somewhat related to the you had made some comments about the surveys prior to LTP approval and and uh Bruce Montgomery made some additional comments on this as well but um just as a follow it's a follow-up question related to inspections of surveys prior to LTP approval could this approach apply to licensees of operating reactors in support of future partial site partial site release I'm in other words involving other non-nuclear facilities or structures similar to uh what was described for Humboldt Bay absolutely uh in 10 CFR 50 uh point 83 uh there are regulations for partial site release and so the the licensees can look at those particular requirements uh we have done these at other operating facilities uh we're talking with one uh licensee right now at an operating facility who wants to use some of the land for a land excuse me a solar farm adjacent to the reactor and so it's part of the license property so we've asked them if they want to pursue a partial site release to release that area from the light the nrc license so it's it's a it's a very viable option for not only reactors but there's similar regulations for material sites all right thanks Bruce and we're down to the last couple minutes here so I think I'll take this additional question and Bruce Watson if you want to start I know Cynthia you may have some things to add as well Bruce the question is can you provide us some examples of risk-informed elements and the decommissioning program in general and in the license termination process specifically yeah I think I can address a few of those the in risk-informing the decommissioning process including the license termination process is really to look at what what's the really important things to make sure they're completed and to the right level of completion so we've we've looked at the program especially recently the inspection program and have the inspectors focusing on on the most important parts so you know in the license termination area obviously the performance of the surveys and getting quality results you know no matter how you get there but making sure the techniques and the measurements and the approach are appropriate and that the results are repeatable is the key to license termination and the one area where we risk-inform our review thanks for that Bruce and I I'm glad you mentioned update you know updating our our inspection guidance you know we as you said we did you know make some updates to sort of you know codify and standardize that risk-informed approach to our oversight and strengthen the effectiveness of our program you know that allows the inspectors the flexibility to to select the reviews that have the most safety significant consequences but as we've risk-informed those procedures in the decommissioning reactor program the number of overall inspection hours didn't change as a result but we're shifted to the most risk-informed areas so I think that's a great example I'm glad you highlighted that all right with that we are down to the end of our time here I want to thank all of the panelists Bruce and Dan and Cynthia and Bruce for joining us this afternoon it was a great panel I joked it wouldn't be a panel if there weren't two Bruce's so had to get the last names in there but thank you both very much and thank all of you for your presentations this afternoon and and also I would be remiss to not thank Kim Conway and Annie Ramirez who are helping us feel questions for us so thank you very much and everyone have a great afternoon