 Good afternoon, everyone, and welcome to the regional session. I'm Commissioner Jeff Barron, and I'll be moderating today's session. One of the best things about this session is that there are no opening statements or long presentations. It'll be 100% Q&A with the panel, so we can focus on the issues that you're most interested in. As you think of questions, please submit them through the RIC platform. We'll work hard to get through as many questions and topics as we can. To get things started, we have some prepared questions. But we're counting on the audience to come up with questions to sustain a great discussion. Because it's a big panel, in most cases, I'll ask one of the regional administrators to respond and invite the other panelists to weigh in if they have thoughts they want to share on the topic. But every panelist should always feel free to jump in with a different perspective or a point they want to make. Let me start by introducing our terrific panel. First are four NRC regional panelists. From our Region 1 office outside Philadelphia, we have Ray Lorton. From Region 2 in Atlanta, we have Laura Dudes. Jack Geissner is here from our Region 3 office outside of Chicago. And Scott Morris is our Region 4 administrator from Arlington, Texas. We're also lucky to have executives from two of our licensees joining us, Duke's Chief Nuclear Officer, Kelvin Henderson, and Maria Lacalle, Executive Vice President and Chief Nuclear Officer for the Arizona Public Service Company. For the first time, one of our state partners is joining us on the panel, Jeff Symanchic, Director of the Radiation Division of the Connecticut Department of Energy and Environmental Protection. Rounding out the panel, we have Ed Lyman, Director of Nuclear Power Safety at the Union of Concerned Scientists. I know we're all looking forward to hearing their views on a range of topics. So let's get started with the first question. During the COVID-19 health emergency, some reactor inspections need to be performed remotely. What lessons has the NRC learned about the effectiveness of remote inspections compared to in-person inspections? What did we learn about technologies that could be used to supplement or enhance in-person inspections? And what did the non-NRC panelists think about the relative merits of remote and in-person inspection? Scott, do you want to start off on this one? Yeah, sure, happy to. Can you hear me okay? Yes. Great, yeah. This is a really interesting and important question. Obviously, because of the public health emergency, we out of necessity had to do a lot more remote inspections in order to complete the nominal, or at least the minimum set of samples for our baseline inspection program at all operating power reactors. And I think we were, I don't think, we were successful. It was challenging that we learned a lot. We're still learning. We talk about this all the time. It's an important issue that I know that NRR and the other regions are actively focused on and looking for ways to enhance our guidance. But I'll say this. I think we were successful in large measure over the last couple of years doing remote inspections because we started with a set of highly qualified inspectors to begin with. These are folks who are seasoned inspectors who've been in the field, done most of these inspection procedures, what I'll call live and in-person. And so it was a little bit easier of a transition for them to go to remote in the first place, because they kind of knew the right questions to ask and who to talk to. That becomes less impactful the more and more people that we lose through attrition and the more new people we hire. So that elevates the importance of in-person inspections. But I'll also say, but I will say there is, I think, I personally believe, and I'm sure others will weigh in here, there is a role for some remote inspections going forward. It's not the end all be all. Yes, we can get some efficiencies out of doing it. For example, we can do document reviews, corrective action program document, or program looks. We can look at self-assessments. We can conduct some interviews, but as a consequence, the time that we do spend on site I think can be more sharply focused on things that really do require in-person inspection. So again, I think there's a role for remote inspection. I think in part, it can also help supplement team inspections. We do a number of team inspections and we've had cases where we've got one or two folks who are back in the office, so to speak, and some guys in the field and there's so mutual support that happens that way. That's something we've done for years, by the way. It's also unfortunately not the end all be all. I think most of us would agree that on-site inspection, in-person inspection is more appropriate, more effective for a lot of reasons. I think about remote inspections kind of, it's almost like looking through a straw. You can only see what's on the other end of the screen in some cases. You don't necessarily get all the other contextual things that you would get by walking around a plant, listening, hearing, smelling, all those other sensory inputs. We add a lot of value, I think, as an agency and most licensee that I speak to would agree. Just our walking around with our inspectors and leaders and managers to on-site visits, seeing, touching, doing is helpful because we see things that licensees don't necessarily see. There are not many of which are not particularly significant but there are observations that we make and we can share those with licensees in real time and bring them to their awareness. We wouldn't see through remote inspection and I think we add a lot of value as an agency by sharing those what I'll call low-level observations with licensees that never find their way in inspection reports, never find their way in assessment documents. But a lot has been learned, we're still learning, there is a role for remote inspection but at the end of the day, I think we have much more effective, meaningful engagements and learnings through on-site inspection and if we have enough time, I can share some examples to help illustrate that but I'll stop there and let others weigh in. Good, any other panelists wanna weigh in on this issue of remote inspections versus inputs and inspections and the relative merits? Sure, commissioner, I'll weigh in if that's okay. I think we've proven that we can continue to have very effective inspections remotely. I know that we immediately provided our resident inspectors with technology computers, gave them access to anything and everything that they wanted access to whether it was parameters and being able to monitor our plans remotely to being able to participate and engage in all kinds of meetings. I think it's also really helped us focus on our resources, the less time in airports and airplanes and a lot more time during the inspection activities. We've also really honed in on our communications and making sure that we kept our residents and the region involved and engaged and communicated at all times. And I think we've learned a lot during these past two years. I know at APS, we're transitioning to a hybrid workforce. We're not necessarily all gonna come back to the site but it'll be more of a hybrid where we'll be on site and some folks where it makes sense to be at home. I think the NRC can do the same when it comes to inspections. We'll continue to review documents remotely, use teams, meetings, et cetera. And then we've got our resident inspectors so if there's anything that needs to be observed or any sort of activity that needs to happen on site the resident inspectors are here can certainly do that for the inspection team. I'll say we had a great example of that during this timeframe. We had a rad material control inspection where there was a lot of question around a particular aspect about our storage facility. And so our senior resident went down, did a walk down, took photos and provided that information directly to the inspection team and we were able to resolve the inspection team's questions without necessarily have them come to the site. So I think this hybrid approach, we've learned a lot and we can continue to think about that going forward beyond hybrid and really try to manage our costs and our precious resources. Thanks, Maria. Any other thoughts on this issue? If I could just add one thought related to remote inspections. With respect to some of the technology and the tools there has been a benefit for us, particularly when it comes to off hours event response and some cases we've seen situations where the plant may trip middle of the night in the past, the resident inspector might leave his house and drive in the plant early in the morning whereas now we can use our remote tools to determine whether or not we need to go in immediately or if we can wait a little while. So we have achieved some of the benefits but I would also echo what Scott talked about. There's really no substitute for direct on-site visual inspection. Thanks, Ray. Ed, you have something you wanna add as well? Yeah, just as an outsider, I am impressed by the, well, first of all, I think what the inspection teams have done is just amazing to deal with this crisis. And certainly at the height of the pandemic, there was very good reason to move to that remote posture. But certainly going forward, I am impressed by the anecdotes that I've been hearing that there is no substitute again for the on-site inspection. I would submit that rather than remote tools be used in lieu of critical inspection functions that they be used to augment and supplement those and that moving forward once hopefully the public health emergency resolves that there should be a resumption of a more normal posture. So that's my view, thank you. Thanks, Ed. Jeff, do you have something you wanna add as well? Yeah, I would just also kind of echo from Ed, you know, the presence of NRC resident inspectors on the site during the height of the pandemic, it was pretty quickly a public interest item that was engaged, that we got engaged at a state level. And I thought at least originally here they did a great job of keeping us informed of what was going on on-site, what was going on off-site, what was being done hybrid. And I think also a good common focus on maintaining safety and integrity for the operators at the plant to make sure we weren't putting them at any additional risk that wasn't necessary for it. But on the whole, I think it went very well and communication was good on it. So thank you. Thanks, let's move to another question. What impacts has the public health emergency had on nuclear power plant sites and plant safety and what effect has it had on your organization's planning and staffing? Jack, do you want to take the lead on this one? Yeah, can you hear me, commissioner? Can you hear me okay? Yes, when I think of this question, I break it into two parts. I break it into the impact and safety on the people, people running the plant and the oversight. And I also base it on, you know, plant safety. They're not mutually exclusive nor does one guarantee the other. So when we work on looking at this issue, let's face it, this is a huge challenge, continues to be a huge challenge to the families, to the people, but the processes and the procedures and the contingencies that the utility's built and the processes and procedures and contingencies the NRC built and frankly, the exemptions that provided that temporary flexibility by the program office of headquarters ensured the plant continues to operate safely. But I don't want to underestimate the impact to the people when we initially started the protocols generally more than what was implemented by the, you know, the federal outlines, we as good neighbors at the NRC followed those, whether it was masking, social distancing and testing, we were able to provide that framework. The resident inspectors went in periodically, every couple of days and some inspections and work continued. Our operator licensing needed to continue. It was a mission critical function. So I wanted to make sure folks understand there's a huge challenge to the people, but that balance of ensuring safety of our inspectors, safety of the utility folks, we needed to meet and ensure that we could oversee correctly and also ensure that the safe operations of the plants continue. We came up with a methodology that looked at yourself, looked at the outside community, looked at the site, and then we looked at the risk. Ray mentioned we might not have gone in for a trip, but if it was a complex evolution could have been a difficult item in an outage, incident response, especially in SIT teams, we would send those out. They would take the appropriate precautions. So in short, we did ensure and the plants operated safely. Big challenges continue with the staff and we continue to work through the processes that we have with the help from our folks in the program office. That's all I had, commissioner. Thanks. Jeff, did you have anything to add on this one? Yeah, we had a couple of things I would say from the local perspective. The first part is early in the pandemic, we worked with plant staff and hit the local power plant to do things like get them priority access to offsite testing when that was running scarce, get them on vaccine lists for critical workers and in the right phases of those. So we help kind of do our partners, partners in the area. The other thing we did is we took a strong look at our offsite emergency plan for the COVID during the pandemic again, during the early parts prior to deployment of vaccines and other measures. We really took a look at, would we use shelter in place, advice aggregation of large personnel, where we could do a hybrid on the offsite response teams and how do we minimize spreads on that? So through that whole process, we engaged with all the stakeholders and we're able to really, I think, come up with some of those modifications and also to exercise those modifications, like continuing to do some drills to damage state proficiency in those. Thanks. Great, thanks, Jeff. Any other comments on this question? Well, I'll put in a, if you don't mind, commissioner, I'll put in a shameless plug for a session. I'll be facilitating tomorrow morning, where we had a real-time opportunity to respond to a real-world event, Hurricane Ida, going through Southern Louisiana, right over the Waterford site and how all of us work together to combat that in a COVID public health emergency environment. So we'll explore some of these issues related to this question during that session as well. Sounds good. Let's turn to Kelvin next. Yeah, thank you, commissioner. So it really did have an impact, really only on how we execute our business at the plant. Our key resources, such as operators, maintenance, radiation protection, chemistry folks, the folks that run the plant day in and day out. I mean, they were there from day one of the public health crisis and they were there through the end. We learned how to operate by coaching each other from a safety standpoint, social distancing, wearing of masks, things of that nature. The people that were sent home and working remotely, they still came in for critical, critical evolutions. So from a plant safety standpoint, plant safety was never jeopardized or even challenged. It was just how we executed work. We executed all of our refueling knowledges in 2020 and 2021 and not removed one piece of scope. And we're able to do it successfully within the bounds of the allocation for those outages. So the organization really learned to adapt and we're carrying some of those learnings to how we operate today. Great, and it looks like Maria and Ed both have comments. Let's start with Maria and then go to Ed. Yeah, thanks, Commissioner. I think we would be remiss to not recognize the support from the NRC on exemptions to the work hour rules. We submitted those and Johnny on the spot, very, very timely support. So just really appreciate and thank the NRC for their quick turnaround on those sorts of things. Much like Kelvin said, we've got two refueling outages every year. So we executed all four of our refueling outages without really any incident whatsoever. I think one of the things that we quickly learned was how important it is to be intentional regarding staying connected to those remote workforce and making sure that we had leaders checking in on them and having that heightened communication to just to make sure that their heads were on the street as well, because they weren't here on site and you wanted to make sure that things were operating well from home. So that was a big learning for us as well. Ned? Yeah, thank you. And I guess from the public perspective, it's a little hard for us to really assess the impact of all this. So I hope that the NRC will be collecting data and putting it in a forum that's publicly accessible so that we can see at least through the usual metrics how safety may or may not have been fully maintained during this period. I've been doing my own, you know, non-scientific analysis with regard to one program or at least unplanned scrams. It looks like 2021 was actually lower than it's been. So you can't say anything from one data point, but it doesn't look like there was a sudden explosion of operator error and deferred maintenance related scrams. So that's positive. But again, I'd love to see a comprehensive analysis once this situation is, so thank you. Thanks, Ed. Any other thoughts on this question before we move on to the next one? All right, well, a new feature of the reactor oversight process is the very low safety significance issue resolution or VLSR process. We got one question about this already. Ray, can you describe the process and give us a regional perspective on it? I'd also like to hear what the non-NRC panelists think about the process and how it's being implemented. Yes, thank you, Commissioner. The very low safety significance issue resolution process or VLSR was incorporated into our inspection program in 2019. And what we did was we had a lot of internal discussion and we developed the process so that we could take issues that previously we might spend an awful lot of time on that we would acknowledge were very low significance, but we would try to do further investigation to determine if there was an actual violation or not of a regulatory requirement. And so with the VLSR process achieved for us and folks can refer to it, it's in manual chapter 612, is it allowed us to make a conscious decision for some issues that are of low risk significance to not expend an order and amount of time trying to determine if there was an underlying compliance issue or not. And so it was just another tool that we had to allow us to better focus our efforts. So that in kind of a high level was what it is. It's been used successfully and approximately a dozen times across the agency that I'm aware of. So it is being used. It's something that we routinely think about as we're pursuing issues. That's a little bit about what VLSR is. It's probably also worth talking about what it is not. And it's not a substitute for restoring compliance. If we determine that there's a compliance issue and we take some type of formal action, say for example, an enforcement action, the issue still has to be addressed. And if there's a disagreement with the action we've taken, then there would be a process for contesting that. And so that would be outside of the lesser process, but it would be an avenue by which a licensee could express disagreement with a conclusion we've reached. Or if we've reached a conclusion and taken enforcement action, but we all agree it's of low significance, the licensee has other means that they can use to remedy the issue. For example, they could correct the condition or they could request an exemption. To that extent, a couple of years ago in our developed a risk informed process for requesting an exemption that streamlines the exemption process. So all three processes all kind of work together, if you will. And I think it's just important that we all recognize the importance that the VLSR tool has provided to us to focus our time on things that are most important. Great, thanks for that overview, Ray. Maria, do you have thoughts on this? Yes, sure. Commissioner, thanks. I agree with Ray. This is a very effective way of using our precious resources. We had a really good example here recently with the use of this process. During the NRC's review of an interim change that we made to staff augmentation time due to the COVID-19 public health emergency, this was an emergency response organization, staff augmentation time change. And so the NRC and their review raised some questions regarding facility augmentation times that have been resolved with the NRC really decades earlier. And so the NRC originally had approved our emergency response organization change to this augmentation time back in the early 1990s, like 1994 via letters with the NRC region versus NRR. And that approval letter at the time didn't have a safety evaluation. And so even though our example didn't really exactly fit into the type of cases that I think were originally believed to be part of this B-Lister process, in our case, emergency plan, the team really quickly and effectively resolved and saved a lot of time and resources, again, due in large part for the NRC's application of this process. And so it was captured on a condition report and now we've included the basis for the original approval. So I agree that really focusing our time and energy on the more safety significant issues, mitigate our distraction on the lower level things and really helps us maintain laser focus on the things that really matter. And actually at the end, it ultimately improves our nuclear safety posture. So I appreciate the work that was involved in that application for us. Thanks, Maria. Jeff, do you have thoughts on this? Yeah, I think that, you know, time will tell certainly on this to some extent, as we see more of these, you know, issues resolve this way. You know, I think there is a challenge with complicating and already complicated process for them from the public's point of view, right? It's just kind of more adjectives thrown on and a little more screening and it looks like there's a problem that's not getting fixed, you know, can give that appearance. And so, you know, I think, you know, I'll withhold judgment on it from that point of view, but I think the public struggles with resource balance of utilities and NRC with respect to running nuclear power plants, they kind of see it as a endless resource. And, you know, so we have to monitor. I do applaud the fact that at least the documentation of this and the inspection reports gives us all a chance to kind of look at it in the public view and see what happens. So, you know, I think the book's still open a little bit on it, but, you know, there is obviously some benefit to it in general, but I just have to be cautious about how we kind of approach it and make sure, you know, the public fully understands it. Thanks, Jeff. And it is, of course, a new process. Laura, do you have thought you want to share on this? Yeah, thanks. And I really appreciated Jeff's comments about the documentation because I think it's important to recognize that there's transparency in this process and we're sharing with everyone. Here's what we're doing with this. We're not pursuing it at this time. And then it's also important to realize that if new information becomes available to the NRC or the licensee, it doesn't preclude us from revisiting this issue at a different time. So I really just wanted to highlight the transparency of the process. Thank you. Ed, do you have something you want to share? Yeah, and I think Jeff hit the nail on the head and from our perspective, if there's a safety problem and it looks like, and the lay characterization of this process as well, maybe it's not worth trying to figure out whether or not it's an actual violation. And even if we do that, maybe we'll not require that it be fixed. And those are problematic for us. And this stems from our concern about perhaps the overuse and over-align some PRA in these inspection determinations. I think we would want more assurance that these are really very low safety significance. And I'm not sure that's always borne out by the PRA analysis because as we all know, there are uncertainties and deficiencies in emissions and the use of things like flex credit, which I'll talk about later, which we have concerns about because of their potential lack of validation. So, we don't want to see safety issues essentially being thrown out because no one wants to take the time to dig through the history and find out if it's really a violation or not. That says something about maybe the way the licensing basis has evolved and it would be great to take a fresh look, I agree, at the safety significance, but maybe not the way it's playing out here. Okay, any final thoughts on this question before we move on to the next? Yes, sir, I had a thought on this. So, I think really the main genesis of this whole process is, I mean, the safety significance piece is certainly an element of it. But the real driver for me and in our experience, at least in Region 4 has been when you talk about is it or isn't it a violation? What we're really talking about is the licensing basis that define around this issue clear or not, or is it ambiguous? And if that's the case, and it happens to be low significance from a safety or risk standpoint, then exercising VLISR and all the transparency that Laura talked about is gonna happen. So, it really gets to the ambiguity of the licensing basis given the issue, not the safety significance is solely. And I will say, if there is a safety significant issue and it's not in the licensing basis, we're still gonna deal with it. I mean, we're not gonna walk away from a safety significant issue, regardless of whether or not it's in the licensing basis. Okay, any other thoughts? Ed looks tempted to respond, Ed, yeah. Right, but then you get into back foot space, right? And that's the problem. If it's too hard to follow through on a back foot, then that's a very blunt sword you have. And Jeff, go ahead. Yeah, I'd also indicate that from a reassurance to the public saying you have an ambiguous licensing basis and don't really understand it, so therefore we'll pursue it, is less than satisfying. So, I think if there's an ambiguous licensing basis or some effort to resolve, to clarify that would make sense to me. Yeah, it's a question of the amount of resources necessary to do that. And in a world of limited resources, we obviously wanna be very smart and focus on the most important things. But your points are very well taken. Well, good discussion on this. It's kind of early days on this program and we welcome the feedback today and going forward on it. Let's turn to a question from the audience and maybe I'll ask Laura to answer this or take a first stab at it. With retirements and other attrition contributors depleting the workforce of inspectors, what incentives training and knowledge management programs are being employed to ensure new inspectors are being recruited, educated, and maintained in the most efficient way? Great question. Although I think we could have had a whole rec session on VLIS or given that the very spirited conversation, but I like looking forward to in terms of the next generation of NRC inspectors and our EDO Dan Dorman has a focus on hiring for this year and he's got all of the senior leadership focused on hiring and then I think the question gets to the fact of, all right, so once you hire them, how do you transfer 30, 40 years of inspection knowledge to this new generation? And we have multiple strategies in place. I mean, I think one of the things we're really proud of now is our Nuclopedia or our Wiki tool, that's a great knowledge management tool that people post videos and discussions about knowledge management. And the great thing is that it is a one-stop shop, right? And as we build that, it'll continue to grow in terms of knowledge management. But beyond that, we're really focused on competency modeling which is a qualification process and really identifying what competencies need are needed for inspectors, aligning them with senior inspectors so that they're able to work and get on-the-job training. And then competency-based qualifications is another item that we're focused on to make sure that our inspectors are really getting a 360 degree knowledge transfer and training. NRC always has very good training programs and we continue to use our technical training center to give people firsthand experience and simulators and then working with our operator licensing folks because they also have a tremendous amount of plant knowledge. And so I think there's a lot out there. And but this is something that we are all as a senior leadership team laser focused on as we look at the demographics of the agency and how we bring new people in. And I will say the challenge that we have and one of the things that we're all very, we're trying to communicate and coordinate on is we're bringing people in in a hybrid work environment, right? And I think Scott mentioned this earlier in terms of the reasons we were able to be so successful with our remote inspections is because of the quality of our inspectors. And so now as we are working in this hybrid environment we have to be incredibly intentional about taking our new hires, getting them out to the sites, having the senior inspectors spend as much time in OJT as possible. So let me pause there and see if there's other comments. Any other and our folks wanna weigh in? Scott. I just say, we've taken, Laura's points are all absolutely dead on. I mean, we've taken another, we've taken other steps. We have weekly question and answer sessions in the region, for example, where all of our, anyone can come in, seasoned inspectors and brand new ones and it's an open forum where people can just ask questions. What does this acronym mean? Why is this issue important? Why did you pursue this line of questioning? And just an open exchange that happens every week, very robust sessions. We do inspection debriefs. Every time we do have an inspection that inspector comes back and debriefs to their colleagues what they did and what they found and that there's an opportunity for conversation and learning there. We're trying to take advantage of, opportunities at the sites. I know a lot of region force sites, we've had a fair amount of attrition in our resident inspector cadre. And we've taken, we've obviously got a lot of new folks out there, but we try to match them up with seasoned people. And we're putting a lot of our newer hires out in the field for observational, rotational assignments and details. Again, it's to maximize that OJT and accelerate that learning. We all know that training and qualification is great. It's important, but it doesn't make you a proficient inspector and the proficiency comes with time, wisdom and just being out there. Let me ask kind of a related question so folks can keep answering this one but I'll further this as well. We had an audience question of, how do you deal with the challenge in terms of mentoring new staff where you have the more experienced inspectors who may be busy or kind of overworked as is and may not have the time that they would want to have to mentor? How does the agency address that to make sure that this really vital part of the role of the more seasoned inspectors, they have the time and the bandwidth to convey that knowledge and that experience and help bring newer folks up to their level of capability? So I think that's a great question, but I'll go, this is a phrase that's often used. It takes a village, right? So you need your entire organization engaged in attracting this talent and retaining the talent. And so it's not just the seasoned inspectors and I'll give you a great example. We have a lot of new resident inspector development program hires. And so we had three branch chiefs take them up to the technical training center for three or four days. And they went through just how do you respond to an incident they had the simulator going? So that's just one example. And so as an agency and an organization we need to utilize all the resources that we have, bring people together for intentional focus training on specific topics. So it's not just hooking them up with a senior inspector, but it's using the branch chiefs. It's using the former inspectors at headquarters and seeing if you can have specialized topic sessions. So that you're coming again, giving the employee a full 360 experience with the tremendous skills and experience we have in the agency. Thanks, Scott. You have something you want to add? Yeah, I'll just real quick. So one of the ways that we have every NRC employee has a performance plan that's part of that becomes the foundation of their individual performance assessment at the end of every year. And one of the elements of every individuals performance plan, including our inspectors is this notion of organizational effectiveness. What have you done to help the organization get better? Not just what you've done to make develop yourself personally and professionally in your own career, but what have you done to commute, to contribute to the whole organization? And so directly to your question, how do we do mentoring is one way of doing that and imparting knowledge, creating Wikipedia, nuclear pedia pages, conducting KM knowledge management sessions and on and on and on. So it is an over expectation on the part of our staff. Great. Any other thoughts on this before we move on to another question? All right. Let me ask one about inspection findings. Since 2015, the number of nationwide inspection findings has declined from 821 per year to 269 per year. That's a 67% decline. All four regions have seen this trend in inspection findings. What do you think is driving this significant decline in inspection findings? And are you concerned about it? Who wants to chime in on this one? I'd be happy to, but I feel like I'm dominating the screen. Well, let me just kick it off then. So yes, am I concerned about it? No. Is it something we need to pay attention to? Yes. Have we done analysis, detailed analysis to try to understand the drivers? Yes. In fact, NRR teamed up with us and they did a very detailed analysis of this very issue and what were the drivers behind it? And I think that analysis is available it was done about eight or nine months ago. So I don't remember all the details, but I will say the main drivers in my opinion and what sort of came out of that analysis, many aspects. Number one, we are more focused on spending time on risk significant issues, right? There are less, and we are more focused on the threshold between what's truly minor and what's more than minor and therefore gets documented in a report. So there's more scrutiny around of that. There are more questions being posed by branch chiefs and others during these inspection debriefs, for example, where folks are saying, well, why is this more than minor? I think many people would be surprised that the kind of dialogue that happens in those inspection debriefs, there's a lot of, why did you even look at that? Or why did you, why are you even talking about this? How does this meet the minor more than minor exceed the criteria? That's one piece of it. Risk models are better. There's more margin that's been identified. So the significance of issues that are identified are now potentially less risk significance than once that we once thought because the modeling is better. I think our, this notion of consistency among regions, there's been a lot more crosstalk, a lot more dialogue across and between regions to make sure there's better alignment, sharing of examples to help people understand. And there's a whole bunch out of the reasons, but one of the bigger and most fascinating things that I recall from the NRR analysis last year was one of the biggest drivers was inspectors. This notion of management really questioning and challenging inspectors on whether or not an issue that they're working on or have raised really meets the criteria of being more than minor. There's a lot more focus on that. And I think in my estimation, that's a big driver here. And I also, I would be remiss if I didn't say something about industry performance. I mean, I think the industry collectively is performing. They continue to show improvement year over year, I think. And there's a lot of data to support that, not necessarily NRC data. I'll stop there. Jack, do you have thoughts you wanna share? Yeah, I do. Oh, first, I wanna say that at least the preliminary data we have for 2021 shows, I think a 15 to 20% increase in findings. And I think the dip probably in 2020 was probably less onsite time. So we'll get that data. So this precipitous drop that people are worried about, I do sense that we're coming to this level. I agree with Scott's assessment. It's probably complex. One thing I wanted to add is, I do think the back fit training added a lot of value, things that were criterion three in the past. We've done a good job focusing on that. One thing that I'm most slightly different than Scott is, concern's not a bad thing. I just have a little concern because in some of the feedback we've heard that, well maybe some inspectors won't bring up these very low issues. When I, and it's not that somebody's saying that they're just gonna not inspect and just bring up issues. But when you hear that there's potential culture perspectives in there, it gives me pause. So I like to pull the data. I do think we have more work to do to make sure that it is a combination of better ideas from minor, better industry performance, understanding back fit. But anytime there's a drop like that, I wanna make sure that we're focused on the engagement with the frontline inspectors, our specialty inspectors and residents to make sure there isn't something there that we need to address. So I think it's something that's always on our radar and we're gonna get feedback on it. That's my two cents, commissioner. Okay, let's get one more NRC perspective and maybe hear from some of our external panelists too. Ray, do you have thoughts? Yes, just briefly. I agree with everything that Jack and Scott have already discussed. But in particular, I'd like to focus on concerns, not the right term, but I just wanna make sure we're not putting unnecessary barriers in place that preclude the inspector from going off and identifying issues and bringing them to kind of fruition, if you will. We were aware of the survey that was done of inspectors that NR had developed a report for. And on the top of that, Scott brought up a management engagement. We were very concerned that make sure that what we're doing as a management team in terms of our actions, behaviors are not precluding or inhibiting inspectors from identifying issues or pushing, pursuing issues to their final conclusion. And so we did basically, we call skip level meetings where myself and Dave Lew, the regional administrator met with every inspector in the region just to try to get their perspectives and make sure that we were not behaving in a way that put forth these artificial barriers. And so we were very pleased with the results from that, but that was not necessarily a concern, but we just wanna make sure we weren't making it too hard on folks. Thanks. Thanks, Ray. Ed, do you have something you wanna say on this topic? Yes, so I hope that this isn't, I hope this is tied to better performance and not a dynamic where inspectors are afraid to raise issues because they get too much pushback. And that's not only, and if Scott is referring the same report I recall, that concluded that there was no clear improvement in overall safety performance that would explain it. So that makes me concerned. And it's not just the total number of findings, but it's also the number of findings that are escalator greater than green. And I did hear also in ROP meetings that the use of flex credit has significantly dropped the number of greater than green findings and that that might be one factor. And that again concerns me because of the potential lack of validation for not only flex human error probabilities, but also flex equipment reliability that I think we'll be talking about later. So I would certainly not wanna see the dynamic where there's pressure on inspectors not to rock the boat and allow these findings to be missed or not dealt with. And as with the law safety significance resolution process, the accumulation of the aggregation of minor findings could lead to something that's greater than some of its parts. That's my concern. Thank you. Thanks, Ed. Jeff, you wanna chime in? Yeah, just a couple of things. It would be nice to kind of have kind of a comprehensive review and evaluation of the drop vice kind of anecdotal evidence on there to really understand what are the drivers and determine those. So that would be helpful, especially with maybe some outside perspective as well into some comprehensive review on that. And then I would just kind of caution that you wonder from an external point of view, the previous discussion about bringing on new staff and experience, does that tie into the ability to identify findings or the willingness to raise them? But again, that would be also be anecdotal and speculative, but it would be good to have that good understanding. Because I think certainly if a utility had a drop of 67% the number of condition reports they were submitting or the we'd certainly be interested to understand what the difference was that caused that. Anyone else wanna weigh in on this issue? Maria, did you have something you wanna add? Yeah, I just wanted to add a couple of things. Let's not forget about info. We, info's been just a phenomenal, I guess standard center, right? With standards of excellence that we all have to meet. And I think that definitely has helped us continue to improve our performance in all aspects of operation. Actually, NEI put out a really good document in 2020. It's NEI 2004. It's called the nexus between safety and operational performance in the US nuclear industry. And it clearly shows how the industry has continued to improve its safety posture year over year. A lot has to do with the regulations that have been imposed over this timeframe. But clearly it shows that the industry in general has continued to improve. And it looks at a number of different areas and there's a lot of good metrics there. And there's a lot of really good basis behind this analysis, which a lot of the information comes from the NRC. So that's a pretty good document to take a look at and really truly understand the improvements that the industry has shown in safety over the last 10, 20 years. I think also just like the NRC does and shares amongst the different regions, we do the same thing, right? We share amongst the different sites on inspection findings. We do assessments across sites in preparation for inspections. Clearly our problem identification and resolution programs continued to strengthen and that includes low level training and analysis. Our issue evaluations and looking for that extended condition and making sure that we really close the issue with a lot of rigor and looking for similar gaps in the programs or processes or equipment, et cetera. All of those things truly have, I believe, kept us focused on the important things. And I think the risk-informing regulations and that risk-informed thinking really helps us focus on the more safety-safety issues and get those resolved quickly and early. Thanks, Maria. Kelvin, you wanna jump in? Yeah, the only thing that I would add to Maria's comment, it also starts with leadership and leadership behaviors in the drive for continuous improvement and really identifying issues at such low levels that we promptly get those created. And that starts with me as a CNO, setting a tone throughout the organization that our purpose is to find our own problems and make sure that we quickly identify those, quickly get them into the corrective action program and place the right sense of urgency to get them resolved. And I think that is reflected in what we're seeing as far as industry performance over the past few years. I think it's a direct tie to it, but it really starts with us as CNOs and the tone that we set with our organizations. All right, well, I think it's been a good discussion. Let, in the course of the discussion up to this point, we've heard a couple of references to flex equipment. Let me ask a question on that. One of the most significant post-Wupishima safety enhancements is the presence of flex equipment at reactor sites. Maria or Kelvin, can you discuss flex operating experience? And then other panelists may want to weigh in about what has been learned about the maintenance and use of flex equipment. Maybe Ray, Maria, you want to start? Sure, we, you know, when flex came upon the number of years ago, we really focused on how do we make our dollars count, not just during the emergency, but in our day-to-day operation of our plans. And so if we're going to spend this, you know, large amount of money and resources on flex, let's make sure that, you know, we design and install our modifications and procure our flex equipment such that it'll help us increase our margins to safety from a day-to-day perspective. And so that was a real big focus for us from day one, was maximizing the use of flex to maximize our safety posture. I'll say that at Palo Verde, we extensively use our flex and our portable equipment as, you know, mitigating actions for maintenance rule. We routinely deploy our flex team generator makeup pumps and our portable diesel generators to mitigate risks during certain plan maintenance activities, you know, as well as an emerging equipment issue. It's baked into our procedures. And so it's really part of our work management process now as part of our plan maintenance activities. It maintains our risk profiles low in the green band and making sure that we have the right focus and attention on our risk management action levels. I'll say, you know, prior to flex, our outages were such that we would be in yellow risk for almost the entire outage. So clearly a large part of our refilling outages. And now with the deployment of flex, we maintain low in the green band posture throughout our entire outage duration. Our modifications for the connections to flex equipment were designed so that it kept our operators in mind and, you know, making sure that you would perform once it was top of mind. So they have easy access, all external connections. They don't, you know, we don't require any doors or anything to be left open. We don't traverse cables and hoses, et cetera, throughout the site. It's really, the other thing I think that we've learned a lot is the proficiency. And we talked about that a little bit of our operators and our maintenance personnel from deploying this equipment a lot. They've got a very high level of proficiency regarding the use of the equipment. At Palo Verde, we're fortunate to have a standalone fire protection department. And that consists of full-time firefighters, maintenance personnel, and engineering personnel. And so our maintenance, fire protection, maintenance organization, they do a fantastic job maintaining our flex equipment in very top shape, keeping sure that we maintain, you know, the records at numbers and making sure that we do all the preventive maintenance, et cetera. I'll say we had early on some indication of some battery failure issues, which we've communicated to the industry and we have since resolved those. But as an industry, we collaborate. There's a committee that's focused on flex equipment, sharing operating experience, having routine communications around these. We've got dedicated program owners to share this operating experience. We've partnered with EPRI to capture, you know, the data that we have across all of the stations to make sure that we've got a good reliable database and we share best practices. So this is all in a very shareable, retrievable database for knowledge retention. And I think just this continued interaction between EPRI and the industry, sharing that operating experience using our flex equipment has just been very, very valuable from a reduction of, you know, I'll say an increase to safety as a result of flex. Thanks, Brea. I think we've got a lot of panelists who want to weigh in on this one. How about we have the order be on Kelvin and then Jeff can weigh in and if Ed wants to weigh in and then Ray. Yeah, thank you, Commissioner. So I agree with everything obviously Maria said. And the interesting thing is, you know, I can remember when we first put flex in place, it was equipment that existed. And now it's more part of our overall risk reduction strategy that's ingrained in all of our procedures. Maria mentioned, you know, how it's deployed during refueling outages where in the past, that we would have elevated risk levels during certain configurations in the refueling outage. Now we, you know, our procedures will require use of staging flex and make sure we, you know, we have the right things in place to minimize that risk. We also have leveraged opportunities where we've had degraded components online that we've taken the opportunity where we could take that component out of service online by deploying flex that allow us to improve the reliability of that safety piece of equipment. And obviously overall improving the, improving plant safety in the past, we really didn't have that flexibility. But all that's ingrained now in our procedures and processes and strategies. So it's not just some equipment that exists, it's really part of our overall strategy and how we manage risk. Thanks, Calvin. Jeff? Yeah, I would think in general, you know, we kind of really applaud the use of flex and the implementation of flex. You know, in general with response to Fukushima, you know, that it provides a real tangible benefit that we can articulate to the public and demonstrate a kind of commitment to safety as opposed to say a re-analysis or a refinement of something there with, you know, so it's from the public perspective, they see an action and it's good. And I also applaud the use of it to reduce real risk and refilling outages and online issues too. So, you know, we do appreciate that because, you know, ultimately that improves safety for all of us. I think the one part I would like to see is it integrated more in emergency plan exercises and just challenging it in those time frames to kind of see its real use in those roles. It would also allow the off-site folks to kind of, to internalize the ability to have that equipment on and prioritize actions to assist in responding in those type of events. Thanks. Thanks. Ed, you have thoughts? Yes, thanks. Since I already raised this a couple of times, I think the main problem here is the regulatory footprint. And since the beginning, we did not think that the current requirements for maintenance and inspections of flex equipment were sufficient given their importance and given that they're now being relied on for these other uses, including pretty safety significant maintenance tasks that it's important that the credit for flex does not get beyond the level of reliability and assurance that the NRC has over that equipment. So, you know, looking at the issues that River Bend and Clinton with the diesel generators and potential common cause failures, you know, I'd like to have more confidence that the NRC has the regulatory authority to make sure that equipment is in adequate working order. Again, commensurate with its potential expanded uses. Thanks. And Ray, do you want to go next? And maybe just, you know, for those who aren't familiar in the audience with River Bend, maybe talk just a minute about that or Scott can chime in on that please too. So people have that background. Yeah, Scott, do you want to go over River Bend and then I'll follow you? Well, yeah, I mean, I don't want to, it's all a matter of public record at this point. So, but I will say in essence, you know, it came down to a number of portable diesel generators that unfortunately when they went to start them, they didn't start or they started but didn't continue to run for a variety of different reasons. And it ultimately got traced back to maintenance practices, preventive maintenance practices, maybe, and some initial design issues, but not bought. And, you know, we obviously expanded our sample and look at that issue across the fleet, particularly in region four and particularly the energy fleet since River Bend is one of the energy facilities. So, you know, at the end of the day, yes, there were challenges with that. You know, I don't want to go into a lot of detail. I will say that when we, when the initial inspection we called a temporary instruction was performed by the NRC staff. After all, licensees had essentially reported in that they had completed implementation of their flex strategies. You know, our inspections at that stage were not, were more are the licensee strategies for flex in line with every any guidelines that we endorsed. And, you know, had training been performed, were procedures available, that type of thing. Those inspections, those initial inspections were not what all called design inspections where we actually looked at the design of the generator and looked at was the manner in which the system was installed or built in line with the design that had been proposed or ordered or expected. Those are the types of inspections we're doing now. We've moved to that degree of inspection as opposed to what I don't want to say cursory, but sort of a high level, yes, have they taken steps to implement the guidelines to the procedures and training exists. Now we're taking a more, a deeper look into some of the, what I'll call engineering aspects of the equipment. Thanks. Thanks for that background Ray, you want to take it from there? Yes, yes, follow up and certainly agree with everything I've heard. I think to Maria and Kelvin's point, obviously licensees have made big investments in flex and so, you know, they expect to see some credit in terms of the reduction in overall plant risk profiles. And we would agree with that installation of equipment that wasn't there originally can lower the risk profile. But, and I would add the caveat, if it's properly designed to perform the function and if it's properly maintained to perform the function. And so Scott talked about some of our initial actions we did in terms of inspections following the original implementation of flex. We've embedded review and inspection of flex equipment as part of our baseline inspection program. We have had some findings related to maintenance of flex equipment, to my knowledge, none of the findings have gone beyond the green range if you will, but certainly we are looking, we are finding issues. We recently had a case of a significant diesel failure, a flex diesel failure at one of our sites that were still evaluating, but the point is the diesel failed in a manner that hadn't been anticipated. So I think to Maria and Kelvin's point, flex does offer a benefit, but the benefits only achieved if the equipment is properly designed, installed and maintained. Second point, with respect to use of risk, we agree with the reduction in risk in general space, but I think Ed brings up a very good point. We need to be careful that we don't over credit how much credit we give for the use of flex as a risk reduction tool. And so to that extent, we have used flex in terms of adjusting some regional findings where we've seen findings that may have gone from white to green when you consider flex. We're very careful and very mindful of how we do that in part because we don't have a lot, we think there's a level of uncertainty related to the reliability data associated with the flex equipment. I know a key aspect of industry right now is trying to get better numbers that we can use to give ourselves more reliability with respect to the uncertainty of this equipment's performance. So we have used it as a tool to lower inspection findings. That being said, we are very careful how we use it and make sure that we're not making inappropriate assumptions related to how we use flex. So thank you. Good discussion. Any other points anyone wants to make on this? Okay, we've got about 20 minutes left. So I'll just give our audience a reminder that if you have a question, get it into the queue and we'll try to get to it. Let's turn to one of the questions we got from the audience and it's about kind of gazing into the future a little bit on inspection and also I maybe expanded to operations of plants. Any considerations for future inspection using robots or artificial intelligence as an effective tool and maybe either one or both of the CNOs who want to chime in at all about the degree to which they're using AI or robotics at their plants. I think probably folks will be interested in that as well. So commissioner, I'll start from a CNO perspective. So we are really deploying use primarily of robotics. I mean, we have robots that now can crawl pipes. We have robots that we can send into basis where we would have to set up a different configuration to allow a person to go in that space. For example, from a dose standpoint, where we have robots that can walk upstairs, can pick up things that can take pictures in more in some hazardous environments. And we've leveraged technology to identify early signs of equipment performance. We've used technology to pick up small vibrations even on large transformers. And we're doing it from a standpoint that it helps us optimize our staffing resources because before people would do all that. And now we have robots that's able to go in and gather a lot of this data for us. We're starting to work through use of artificial intelligence primarily on data analysis and things of that nature to help us predict either where we could have some performance challenges either with behavioral gaps or equipment gaps. And we're pretty far along in that process. And we're actually leveraging others in the industry on what they've learned through use of AI that a lot of technology uses, at least within the Duke system that we've deployed here over the past few years. Thanks, Kevin. Any other thoughts from an NRC perspective, industry perspective or other perspective? Just to add one more to Kelvin's list. We do a lot of very similar approach with the use of robotics in radiological controlled areas and minimize dose, et cetera. But also we're using drones in our cooling towers and that has significantly saved from a industrial safety perspective, not having to build scaffolding, et cetera to try to get to all these areas in a way of high, et cetera. And so that's been a technology fairly decent that has proven to be very successful and you can get up close and personal to what you're trying to see through the use of these drones. And so there's a lot of technology out there. I challenge our vendor partners every day. They know a whole lot more about what's going on globally and what's being used out there globally and bring that back to us so that we can evaluate and assess whether it makes sense here in the United States at Palo Verde, et cetera. And so that is a big focus area is how do we continue the use of technology to improve the way we do business, to optimize the way that we do business, whether it's robotics, drones, artificial intelligence, et cetera. It was a really good session yesterday on the use of artificial intelligence at the RIC. That was very good. Yeah, I moderated a panel on artificial intelligence last year and I was just fascinating. From the NRC folks, anything, Laura, did I see a hand up or Jack? I saw Jack, go ahead. Why don't you start Jack? Not just make a quick comment is that is an area where we're gonna have to get up to speed quickly. I have heard a lot of utilities using artificial intelligence to call through data make decisions on what to maintain. And that's an area where we don't have expertise, but we will get the expertise. We'll have to figure that out. So that's an area that's on my to-do list, looking forward to the future. That's all I had, commissioner. Thanks, go ahead, Laura. Thanks, Jack. No, I think I agree with what Jack said and I think that there's a lot of benefit to this. I think we need to keep leaning forward. We need to get the expertise on AI, but we also always have to be mindful of the cyber issue as well as we're deploying these technologies. I'm all for it, I'm in favor. I've seen drones go into containment to rapidly identify a leak. In the past, you would have had to send humans in there. There's a lot of challenges with that. So I think there's a lot of benefit to it. I've actually driven one of the robots down at St. Lucy and actually they use it to go into their resin rooms. I mean, that saves a tremendous amount of dose and that's really a positive for the worker's safety. But again, we need to just proactively lean in and discuss the cyber issue and find solutions to that issue because I think the technology's great and we should be deploying more of it but we just always have to be mindful. And there's a solution for the cyber but we've all got to be coming to the table to talk about that. Thanks. Anything you want to add, Scott? Yeah, Laura actually made a couple of the points I was gonna make. So I appreciate that, I also agree with Jack. I just, at the end of the day, the product, one of the products that we produce as an organization is on behalf of the American people is our independent assessment of overall licensee performance relative to safety and security. So I think all these tools, any of these tools, any and all should be used. I'm certainly open to it. I'm admittedly a bit skeptical at this point, particularly when you move away from inspection and into assessment and sort of particularly safety culture assessment. I'm not quite sure how you would, AI would necessarily help us with that. But hey, I'm open to the future but I need to know more, I think. There's a lot to be learned here. Great. Well, let me, let's turn to another question. This one's probably more for the NRC folks. The regions, and it's a follow-up on the lesser. The regions have firsthand experience using the V-lesser process. NMSS, so the material side of the house for NRC is currently evaluating how it can use V-lesser to address potential issues associated with extreme weather events during fuel offload activities. Are the regions engaging with NMSS to discuss how best to apply the V-lesser process to that kind of situation? I'll start. Laura, are you looking to? Yeah, a short answer is yes. We're actively engaged with the program office and we're talking through the various scenarios but going back to Ray did a very good job of talking about the distinction on V-lesser is it a compliance issue or not? And then the significance. I think we agree on the significance. We just need to make sure that we work with the program office to identify the compliance aspects but yes, we're very engaged on that issue. Okay, here's another one. Have the regions identified any trends in inspections not being completed within the scheduled timeframe or requiring subsequent re-exits? If so, are there any insights you can share about that? Any takers on this one? I'm struggling to come up with one but the one that kind of left to my mind and I don't know if it's a great example or not but there are certain things that can only be done during planned outages, right? There's only certain times you can go into containment, et cetera, et cetera, particularly at a boiling water reactor. So we've had to defer some of that stuff and some of the required inspections that licensees have to perform have been deferred through the exemption process. So that's been done proactively and deliberately with good thinking behind the how and the why. But I mean, for the most part we've been able to get it done it's just we've had to adapt and flex a little bit and leverage different resources but I can't think of a really, an example really that fits that. I don't know, maybe my colleagues. Ray? I could just follow on Scott and like Scott I only know of one inspection that we were not able to complete during calendar year 2019. I don't know of any inspections that we were not able to complete in 2020. The 2019 was a COVID related impact kind of a short fused opportunity that we just missed because you can only see certain things nor in certain times as Scott mentioned. So we haven't had a significant backlog of if you will, uncompleted inspections. We report on that every year to Congress and so we endeavor to complete the inspections on time. Okay, great. Let's ask maybe a little bit more of a big picture question but Jack, I'm sorry, did you want to get in? Yeah, we did have in 2020 there were a couple of inspections that we didn't do and we validated the reasonable assurance of safety by other means. A couple were security inspections and a couple of health physics inspections and those were related to high COVID incidents in the surrounding community. And we were able to use the resident staff and the review of records to follow up and ensure that delaying the inspection to the following year was okay. And also we also have containment entry where we elected based on where we were at COVID to not do it and do it later on. So I think those are well documented on the public record and I think it shows as I talked about before the balance of safety of people and still ensuring safety of the plant. So I just wanted to highlight ours. Thanks. Thanks, Jack. Well, let me turn to this kind of more bigger picture question. In your work, and this could really I think apply to the NRC folks or others, but in your work, how do you ensure that the interests of local and other non-licency stakeholders are considered? Someone from NRC wanna start with that? Laura's gonna take it. Well, I mean, I think to the extent that we can be engaged with our local community, that's the first step. And I know we have made ourselves available and had gone out to various community activities such as the Augusta River Walk or the Vidalia Onion Festival and had a booth and so we have to start to have a relationship with the community first and then if there are issues with that community, you can hear from them. But the first step is starting that relationship, engaging with people in the local area and then once you have that dialogue and that relationship, their interests, their thoughts will be shared with you. I do know that our residents will typically meet with local community leaders at least once a year. And so it's really about listening first and then and developing relationships. So I'll pause. Thanks, Jeff, do you have something you wanna share in this one? Yeah, this is an interesting one out there. I spent 23 years at a local power plant as both the licensed senior licensed operated management. And when I came over to the state and became the state liaison officer, I think I mentioned in one of the early conferences I had more exposure to senior NRC leadership as a licensee than I did as the state liaison officer. To the commission's credit, I think you guys responded well to that but I also learned that I've got to really make that those interests known. And so I think there's some ways to make sure that Commissioner Barrow, when you came up for a visit, I was informed of the visit. We had an opportunity to sit and meet and hear kind of concerns we have. And I think it's important because while I may understand the authorities, the Atomic Energy Act, the public really doesn't. And so often my phone's the first one to ring when there's issues or concerns or things in the paper and how the public might perceive it. And I think we're a valuable resource for that. We've also worked through the National Organization, the Conference of Radiation Control Program Directors to form a working group of state representatives that have power plants. So we can kind of keep an eye and look at some of those issues that might be affecting those and feed that perspective up. And I think just kind of reaching out for state and local partners is also important. I think we've learned that through the material side of the program. And I think although it varies from state to state and how much interest is out there, I think we can be a valuable resource. And an example I would provide is there's a production facility in New Haven here that was getting remediated. And the typical approach for the public meetings was put it on the website, let people come see. We kind of were able to reach out and let them know that New Haven's got a very unique community led structure that's below the mayor's system and got the team to the community management team meetings, meetings with the local alders. And that really helped to get a lot of information out to the public and get some of those direct concerns from in this case, a very EJ community that didn't have access to internet and things like that. And so getting those out there, we were able to help navigate kind of that process. So I think all those things are really important and I think state local partners are a good starting point for it too. Thanks, Jeff. Looks like Ray's interested in chiming in and then Ed. Thanks, commissioner. I agree with basically everything I heard from Jeff. We work very hard to try to maintain an effective and a strong relationship with our state partners. Jeff, I know you've been out on inspections, been on inspections with you. And so we do have just for awareness, we do have state liaison officers in each regional office they report directly to the regional administrator. And so they keep kind of our conduit with information and concerns that or if there's something that we're doing of interest, we wanna communicate to the state. So we try to be very forward leaning, very proactive and try to maintain an effective working relationship. We have memorandums of understanding with many of the states in our region. And so often, well, we have an inspection, we'll make them aware of significant inspections, activities in advance and invite them to come and participate in all of our inspections from an observation process. Last point I wanna make is, we have another number of plants in region one that are currently undergoing decommissioning. And as part of decommissioning, that is of course a very much a public process and all of the sites have some form of some sort of citizen's advisory panel. And so we were frequently will go and provide information upon request and just to kind of communicate with the local governmental officials and also with members of the public regarding what our activities entail and kind of what's the next step in the cleanup process. So I think it's a very critical relationship. Appreciate Jeff's participation today and also everything you've done to help us interact with things going on in Connecticut. So thanks, Jeff. Ed. Yeah, so just really quickly, I'd certainly like to make a plea for more transparency and in this context, a lot of the processes we've been talking about, you know, very low safety, significance, determinations, SDP and significance determination process and are all pretty inscrutable to the public. And there's only so much you can do to explain those often complex proceedings but the more open and transparent you are about how decisions are made, I think better. And that involves these qualitative aspects like the human element to the way, as we heard, to the dynamics of management inspections, I think our inspector findings, it's very interesting and humanizes the agent stand but at least makes people understand that it's not just this mechanical black box but there is this human aspect to it and some subjective judgment. Thank you. All right, well, we have just a couple of minutes left. Maybe we have time for one more question. As always, we have more questions coming in that we really have time to get to but let me ask this one and I'll just kind of read this one. The industry is adopting the so-called value-based maintenance and converting many time-based preventative maintenance work items to predictive maintenance. And the question is interested in knowing, I think at least NRC's folks view about whether existing compliance activities are going to be adequate to assess the safety impact of that, particularly if licensees are going below the manufacturer recommended preventative maintenance work. Any insights anyone wants to share on that in our last couple of minutes? Well, I'll just, I'll start by saying this. It's something we're aware of and focused on, commissioner. It's also when it comes to key equipment, particularly safety related or important to safety equipment or things that can cause plant trips and challenges, we do have a performance-based rule in place, 10 CFR 5065 effectually known as the maintenance rule, but it does factor in ultimately the performance of the equipment and condition monitoring of the equipment. And so there is a role for modifying maintenance frequencies and test frequencies based on operating experience, based on better data and analytics, but it has to be done in a measured way. And I think our regulatory infrastructure is set up to detect significant challenges in that area should they manifest themselves. Any other thoughts on this issue? Jack. Yeah, I'll just add that a lot of the processes that has some risk conforming already have a feedback loop. For example, the surveillance frequency control program, if you extend the frequency of what you're doing your surveillance and you do have a failure, you're required to go back and reassess that. So in addition to the maintenance rule, the processes that are allowing the licensees a little more flexibility have a tool in them for feedback loops. So I think I agree with Scott, we need to check on that. And our processes are gonna ensure that we don't inadvertently miss that. So, Jeff. Yeah, just one aspect of this is just kind of, I guess, tangentially related. It would go back to Ed's call for more transparency. Well, generally we're supportive of risk-informed programs. There's some of them, like the surveillance frequency control program or 5069 classification of components, that once they're in the house to the utility after the initial license amendment, the transparency of those changes is gone, right? They become opaque. And so you change the diesel surveillance frequency. There is no longer a public piece of that. There's no longer opportunity for state and local feedback on those processes. So, unlike 5059, which kind of has that annual report that kind of talks about what safety valves were done. A lot of these programs, I think, especially in aggregate, it would be nice to see something that enhances the transparency, even if it's kind of a review after the fact to understand what major changes were done. And so that folks outside of the NRC and the licensee are aware of them. Great. Well, I think we're up to stop at that suggestion. It's been a great discussion, I think. Thank you all to all of our terrific panelists. I think it was, we had covered a lot of ground, a lot of different topics and got a variety of perspectives on so many of them. So thank you all. Thank you to those who have been watching and submitting questions. We really appreciate it. Sorry, we didn't get to all of them, but I think we got to almost all of them. So thanks so much and enjoy the rest of your day, everyone. Thanks.