 Well again, I do want to welcome you to the session and I want to welcome our panelists today in this regional session We have in fact a very distinguished panel a set of panelists And I'll introduce them Dan Dorman who is the regional administrator for region one big McCree Who is the regional administrator for region two Cindy Peterson? Who's the regional administrator for region three and Mark DePaul who is the regional administrator for region four? You know my other side we have Randy Eddington who is the executive vice president chief nuclear officer for Arizona? Public service company and Joe Grimes who is the executive vice president chief nuclear officer for Tennessee Valley Authority So welcome panelists to the session also So as I indicated the format for this session is really a question and answers We I Prepare to start that session off with a number of questions for the panelists But we really intend in the session to elicit your questions So the panelists can respond to things that are of interest to you So again, please don't hesitate to identify questions on a card or come to the microphone when you want to raise a question So let's get going without further ado The first question There's been we've talked already in various sessions at the regulatory information conference about the reactor oversight process There've been several activities that have been conducted to identify potential changes to the reactor oversight process To continue to improve its efficiency and its effectiveness Recently there's been a lot of discussion on potential changes related to the reactor oversight process action matrix threshold for threats for Transition from column two to column three to the substantive cross-cutting issues Area of our process And to the sides and scope or focus of the component design basis inspection a CD bi program And so I have a question for the NRC panelists what actions are being taken on these programs? How do the region's view each of the proposed changes? Summarized above and I'm going to ask mark and and Dan if you'll take those questions first And then following that I'm going to just to warn you guys Our industry colleagues what safety benefit or detriment do you see from the current processes? In these areas and what changes would you think would be most beneficial to safety? Again as it relates to the reactor oversight process. So mark you want to start like Hopefully folks can hear me. Okay here. Let me start out with the one aspect there for which I'm sure there's a relatively little interest And that is the substantive cross-cutting issue process here By way of background our I'll call it the ROP founding fathers back in the 1999 2000 time frame Incorporated cross-cutting areas into the original Reactor oversight process or ROP framework because that group Determined that these items generally manifest themselves as the root causes of performance problems We the NRC further developed the subs of current substantive cross-cutting issue process In response to commissioned direction to the staff to enhance the reactor oversight process treatment of cross-cutting issues to more fully address safety culture And as many of you should be aware the intended purpose of assigning a substantive cross-cutting issue is to inform the Licency that the NRC has a concern with the licensees performance in the cross-cutting area and to encourage the licensee to take Appropriate actions before more significant performance issues emerge We've had various public meetings over the last couple years where the industry Has expressed their concern and their central concern regarding the current substantive cross-cutting issue process Is that you know challenging the premise that four findings with the same cross-cutting aspect in a 12-month period is indicative of potential performance problems, especially Considering that the findings are primarily a very low safety significance You know we have green findings for which we would look at a cross-cutting aspect typically another concern that was expressed by the industry was the Significant resources required to address and disposition the substantive cross-cutting issues for the perceived very low safety benefit The industry has provided us with an alternative model for oversight of licensee safety culture in lieu of our substantive cross-cutting issue process That process the industry process which would be voluntary is described in the nuclear energy Institute or NEI guidance document NEI 0907 entitled the fostering a healthy nuclear safety culture Back in February of last year Brian McDermott led an independent assessment And that study was provided it was dated February 18th and in that study There was a recommendation that the staff perform a comprehensive Analysis to determine whether the use of cross-cutting issues and safety culture provides Regulatory value in terms of licensee safety performance for the resources expended As a result of that recommendation Office of nuclear reactor regulation division of inspection regional support Led a working group that conducted an effectiveness review of our substantive cross-cutting issue process and then developed a number of recommendations That working group can had three overarching conclusions. The first conclusion was It is difficult to prove that licensee corrective actions Resulting from identification of a substantive cross-cutting issue prevented more significant performance issues Especially for those licensees whose performance was steady before and after an SCCI or substantive cross-cutting issue was identified Consequently the staff was unable to determine if the substantive cross-cutting issue process was effective in preventing more significant safety issues The second overarching conclusion was that substantive cross-cutting issues are not a leading indicator for declining licensee performance Licensees moved right in the action matrix 86 times without identification of a substantive cross-cutting issue And then the third conclusion from the working group was the resource cost for implementing the substantive cross-cutting issue process is Significant without an apparent commensurate increase in the safety benefit I should mention that that working group did consist of safety culture experts Staff from NRR the Office of Enforcement and each of the regions were represented Again the original problem statement was the level of effort to develop open and close Substantive cross-cutting issues is not commensurate with the perceived value Stated differently regulatory actions and outcomes from identifying and monitoring substantive cross-cutting issues do not achieve gains and Protecting public health and safety that are commensurate with the resources expended Based on those conclusions in that problem statement the working group had a number of recommendations the first recommendation was to Not endorse the proposed industry process that is captured in the NEI 0907 and the various reasons for that were there were concerns within consistent implementation of the program Recent revision to NEI 0907 revision one which was issued recently further reduces standardization of the process and providing several different options for Licensing implementation There was some concern that revision one removed the process requirement for an independent safety culture assessment The working group had some concerns with the lack of Transparency for the public with the industry's process the substantive cross-cutting issue process provides a formal means of communicating an NRC Concern with the licensees performance in a cross-cutting area to the public through a very transparent Process in the semi-annual assessment letters And then there was the recognized assertion that if a licensee is effectively implementing the NEI 0907 safety culture monitoring process the likelihood the NRC would issue a substantive cross-cutting issue is significantly reduced Another recommendation was to revise the terminology eliminate substantive due to negative connotation Which may or may not be valid the implies an issue with higher significance than may be justified by using substantive Increase the threshold for a cross-cutting theme from four to six findings with the same cross-cutting aspect That should reduce some of the resource burden and be more indicative of a trend And the thought was a higher threshold could result in substantive cross-cutting issues being a better predictor of declining licensee performance Now there were a couple additional recommendations regarding creating a backstop of 20 and 12 findings in the cross-cutting area of human performance and problem identification resolution respectively When you look at the process that was being proposed with the change in the threshold from four to six Theoretically you could have a theme of six findings with the same cross-cutting aspect Whereby you have as many as 70 findings with human performance cross-cutting aspects and not meet the criteria for a cross-cutting theme similarly, you could have as many as 30 findings in the area problem identification resolution and Without reaching the criteria for a theme and the staff felt that these numbers of findings would be indicative of a systemic problem in human performance or with or with the corrective action program There was a recommendation that the subjective questions prescribed by inspection manual chapter 0305 Which is our operating reactor assessment program should be eliminated in more objective criteria established for opening a Substantive cross-cutting issue the first occurrence of the theme that would be after a 12 month period So that would be a minimum of six findings with the same cross-cutting aspect The recommendation was to document the theme in an assessment letter Consider reviewing licensee cause you cause it will now list and corrective actions through a focused problem identification resolution sample For the second consecutive occurrence, so we're now looking at over a period of 18 months the We would document the theme in an assessment letter review licensee progress in addressing the theme and conduct a PI in our sample if not done earlier Then for the third consecutive occurrence and that would I'd offer while you're looking at a 12 month rolling Period in turn in determining whether there are six findings a minimum of six findings with the same cross-cutting aspect By the time you get to the third consecutive period you've had issues there over a 24 month period At that point we were to sign a cross-cutting issue And then we would develop a standard cross-cutting issue closure criteria We would recommend a follow-up inspection similar to the 95 double or one to review licensees causal analysis and corrective actions if at the time we issue a Cross-cutting issue and the following assessment period which would be six months later We still had not closed the cross-cutting issue Then we would look at potentially some additional regulatory actions like having the regional administrator Indoor the executive director for operations meet with the licensees board of directors Discuss the licensee at the agency action review meeting With the potential for recommending that that licensee meet with the commission And then if you're a licensee in column four of the action matrix All cross-cutting issues would be closed out as part of the confirmatory action letter closure process So those are the various recommendations that were put forward by the working group and my understanding is that the staff is proceeding to implement those changes and Sky you can tell me the time frame for that. I think we're looking in the next for mid-cycles for the next mid-cycle assessment period But those are the recommendations and those are the actions going forward that we decided to implement to address That the suggestion from the independent assessment that we look at the cross-cutting issue process We currently have them place holistically and determine what changes are appropriate Thanks the action matrix threshold and the CD bi so I'll start with the action matrix threshold The issue that was raised here from the independent assessment is is looking at the entry criteria into column three of the action matrix Which is called the degraded cornerstone and and the current criteria for entering column three is one yellow input or Two white inputs in any cornerstone and the question is focused on the two white inputs piece Two white inputs are our inputs that are in the ten to the minus six to ten to minus fifth risk band As opposed to the yellow would be in the ten to minus fifth to ten to minus fourth and the fundamental question is if you have two White inputs that are low in that ten to minus six band They don't add up to be equivalent to a ten to the minus five and so is it appropriate to have that that kind of Regulatory response to two white inputs and and the regulatory response just for perspective On a column two we respond with a 9501 inspection, which is focused at the specific issue that behind is behind the white input And is in the neighborhood of 40 hours of inspection effort If you get into column three and the degraded cornerstone We're going to do a much more intrusive inspection that's going to look at cross-cutting aspects and get deeper into a license Root-causing corrective actions for the issues that got them into column three And that inspection effort for the staff can be upwards of several hundred hours of Inspection effort and there's a significant increased Corresponding in the level of effort that a licensee puts into preparing for that So the question was should we go to three white inputs in one cornerstone as a threshold for entering column three? That was discussed in a public meeting that that NrR Sponsored in January The proposal that is being put forward would be to go from two white inputs in a cornerstone to three white inputs in a cornerstone There would be corresponding adjustments to the 9501 inspection procedure because now you would have the potential for Having two white inputs in the regulatory response column And so we would have adjustments to the sample sizes and the inspection hours under 9501 to reflect multiple White inputs in that in that performance area so there's There was a basis that the staff put forth in the discussion for that looked at The there in the history of the R.O.P. There have been 75 plants that have entered into column 3 31 of those plants have entered into column 3 based on two white inputs. So the staff focused in on those There are some of those that entries into column 3 that were in cornerstones that don't have quantified Significance determination process and so So they don't provide a lot of insight from the risk perspective so the staff has developed the the the discussion on on What what is the really the significance of two white inputs? They also look back at the original discussions in the establishment of the R.O.P. There was input from our our senior risk analysts at that time that suggested that that five white inputs may be correspond to a yellow the The decision at the time was two white inputs was recognized to be a conservative decision The the staff revisited that decision and brought it to the Commission in 2003 and at that time the Commission agreed to keep it at two white inputs We're looking at that again with a lot more history and data to look at So the the NRR plans to put together a commission paper on this issue. It is Threshold of the action matrix is fundamentally a policy issue in the structure of the reactor oversight process So the expectation is by the end of April we'll see a commission paper that will go to the Commission And let them decide on the issue. There are a number of Diverse views within the staff within the working group that was put together on this issue Those will be reflected we expect in the Commission paper by presenting different options to the Commission and discussion of the pros and cons for those options Moving on to the CDBI question of the three topics. This is the one that is perhaps the the least developed In in terms of where the staff will go on this issue But it has been an issue that's been under discussion for some time the component design basis inspections is a portion of the baseline inspection program under the reactor oversight process that in which the inspectors will go into a licensees design basis documents and drill down for a particular system To look at at the what the basis was for the design and maintenance of that system and how effectively the licensee is maintaining that design basis in their ongoing operations and maintenance of the system and over time the results of those inspections have I think early on there were more greater than green findings recently there have been more green findings out of these inspections and so the question is being raised appropriately in the context of our ongoing assessment of the baseline inspection process of are we focusing our resources in in the best areas for safety And a white paper has been provided to the staff from the industry making some suggestions on ways to improve the this inspection area We did have a public meeting in January to discuss this area. I think a couple of key points out of that meeting from the NRC's perspective this Inspection is one of the most important inspections in the baseline inspection program most of the the Operations and maintenance related inspection areas are focused on the the The current operability of systems and the effective operation of systems and maintenance of the systems This is the one that really drills down to is the licensee maintaining the plant as it was licensed to be built and operated Also from our experience This is not something that you do for one inspector for a week to do an effective job in this type of inspection And so for us the the team structure is key to the success of these inspections We note that that we also had some input from public stakeholders that they viewed this as one of the most important inspections that we do But we also have feedback from the industry that that based on their performance in this area that no longer warrants an Inspection of the scope and impact of the current inspection They note that they do a significant amount of effort to prepare for these inspections And they wonder if there's a way that we can give credit for that self-assessment process Being effectively conducted as part of the inspection activity and to enable us to kind of scale that back So the bottom line is where we are we're fairly fairly early in the process in looking at the component design basis inspection There is a diversity of views both within the staff and with outside stakeholders And so there will be a continued dialogue on this one as we work forward to it to recommendations Very good. Thank you mark. Thanks Dan for those answers. Joe. Let me just turn to you for for an industry perspective Again, what's the safety benefit or detriment that you see in the current processes and what changes would you see as being most beneficial? Sure. Thanks Mike and good morning Overall we support the ROP as a very good tool to determine how to respond to licensee performance and I'll start in this area with the action matrix, you know the potential move to raise the presentation or the Transition threshold to column three to three white inputs is a positive move in our opinion and should alleviate some of the pressure that occurs When we over respond early in the SDP phase and I think most importantly it aligns us better to respond Truly to the safety significance of each of the individual issues This should also be a positive effect on column four potentially Which is a very large concern to the industry obviously because of the cost for entry and the extremely significant activities to recover So overall, you know a step in the right direction And we give both the NRC in the licensee's room to focus more on Fixing the actual problems and debating the risk significance up front Let me talk a little bit about cross-cutting issues, you know, we welcome the changes as a first step Most of the utilities have established You know respond thresholds and actions in this area include performance analysis that understands common linkage of the issues And then in addition there's also Many other sources of data the corrective action process which is well used well understood and well talked about The safety culture monitoring program and others that the utilities all rely on For a plant performance which provides very clear insights into trends and and the necessary response actions To both anticipate and then to arrest any declines that could occur in performance So given that we would encourage the NRC to continue to assess the changes You're talking about in the cross-cutting thresholds and again Maybe in two years to come back and look at the impact of this first step revision that you're considering Versus key plant processes and how well they overlap And then lastly CDBI, you know, we recognize very much the importance of this inspection as Dan said The industry recognizes its safe operation depends on the maintenance of the integrity of the plant design and the fidelity to it The inspection in its current format has become a significant burden to the station Operations the site engineering resources and over time is yielding less in the area of significance and safety Significance at all. So we believe this should be shifted in focus from design Verification more so to a validation of the programs that maintain the health of the design basis Especially for those risk significant systems and components and in using the self-assessment processes that the industry has Overall, we think this will allow for reducing the scope We believe it will also impact the duration and especially the team size and just overall impact for the inspections Okay, very good. Thank you, Joe Randy anything to add you don't have to but you're welcome It'll be hard to be Very very good. This next question really relates to regional differences and I'm going to start off with Actually, I'm going to address the industry panel first. Here's the question in September of 2013 the government Accountability office issued a report that identified differences and the number of green findings and not escalated violations in the regions since inception of the reactive oversight process and so my question is What's your perspective regarding the consistency with which the in the regions conduct the rop? Activities and is this a significant problem from your perspective Randy. Do you want to take that one? Yes, I'll take it You know having a strong and independent Regulator is something that we feel is important to everyone. We have an industry that's matured Dramatically and we're used to comparing information Across the various venues whether it's impo or metrics and from that we get very strong Views of our performance. So we do think it's important to have consistency. We're not looking for the snap-suit carbon But we think evaluating those differences adds a strength and credibility to the regulatory process You can find sometimes an area that maybe has been driven by one area And we don't think that is a good for good for us good regulation overall so we do believe that a Regular comparison between the regions and seeking reasonable consistency would be very important to Continuing the effort for a credible regular regulations We also think again, there's opportunities as we compare those those areas to look for areas to strengthen again Either an issue that's identified that that needs to be broadened or in other cases where one is being unfairly Pushed on in one region. So those are we do think that's important We think it's capable very capable right now and again We're looking for a strong independent and credible regulator just like you are Very good. Thank you, Randy So now let me turn to to the NRC Your question related to this topic is how do you view the GAO report and what have the regions done about it? I'm gonna ask Vic to start but before Vic does I can't resist this I Gotta ask you does Vic have on a white shirt with gold tie Or how many people see black and blue? Yeah Should I give the answer? Go ahead please. It's it's actually brown and gold. No It's blue and gold, you know, this this is an interesting question. It's one that we've Addressed before I think this is the seventh opportunity. I've had to Participate in this particular regional session and invariably the question of regional differences arise So it's clear it's apparent that we've not Addressed it in a sufficient manner And there's also some differences here optical differences You'll know if you're looking that the regional administrators on one side of the dais and the industries on the other so we are our which symbolizes our Principle of good regular regulation of independence, so we're separate but independence doesn't mean isolation and definitely on this particular subject as as background about 18 months ago the Government Accountability Office Issued a report based on an audit it had done on our implementation of our reactor oversight process and how we identify issues How we evaluate them for significance and how we resolve them and that report included a number of observations findings one of which was noteworthy is that That in comparison among the regions we identify About the same number of quote safety significant Findings and violations, but of lower significance findings green non-sighted violations Green findings in lower risk less severe violations. There was significant differences among the regions They noted that this was previously known long-standing. In fact the audit covered a 13-year period from 2010 to 2012 Although in fact the differences actually preceded the reactor oversight process And although there were several initiatives that we had taken over the years It was concluded that those differences weren't that Significant because again in most cases licensees would enter those issues into their corrective action programs and be available for the regions to Sample the effective implementation of corrective actions But the report concluded accurately that we had not Conducted a comprehensive analysis of the differences and that our quote oversight efforts Are to confirm that they're objective and consistent and know whether the regional offices or inspectors are applying a regulations and guidance consistently, so we took that to heart and in our lead an effort Over the last year to conduct a tabletop review which included about 56 folks about 53 from the regions both inspectors and and supervisors and others from NLR and they conducted Participated in a survey where scenario specific questions were asked and answered and non-scenario specific questions to get folks views on On how performance issues are identified What the threshold should be in terms of minor and more more than minor? How they would credit identification Because in our process we would grant credit for licensees if a licensee identifies The issue of itself identified or of course if it's NRC identified That has merit in our process in terms of whether and how an issue is documented and the responses to those questions were evaluated and there were there were two noteworthy Themes that came out of the re out of the review one is that There's differences in how we implement The more than minor screening using the more than minor screening questions in our guidance and secondly how we Assign identification credit again as licensee identified or self-revealing and Those results generally generally aligned with the results of the of the GAO survey So we use that as input to to base our follow-on actions Which which are ongoing, but I'd like to ask Cindy if she would go into a little bit more detail on this. Thanks Vic. Good morning everyone The working group that looked at these various things did take a lot of input from Various inspectors and branch chiefs throughout the agency So the next step was to take that and try to align on where we wanted to move forward in these areas of noted difference and so the regional senior leaderships got together and Did the same? Evolution of going through these scenarios to come up with ways in which we could align So the agency would move forward and just give you a couple of examples where the division directors working with NRA on the regions identified some differences one was in the area of Calculational errors and a noted difference was in how much of a change or how much of a revision was necessary for An inspector to call that more than minor So that was an example where differences in the threshold were being used Another one that was noted was the self identification or self revealing particularly in the area of surveillance There were noted differences in how the regions chose to implement that Another area was in the area of equipment deficiencies Even though it may be able to provide its function Margin was lost. So how much margin is too much margin to cross the threshold and Another one of the noted differences was in answering the question of if left uncorrected Would the issue become a more significant issue? So those are some examples of areas we identified for need for further work Now all the regions have agreed that we do need to make changes to clarify our guidance Such that we have more reliable outcomes for those types of areas So what will happen is another working group will be put together to work out those particulars in the guidance documents and then those guidance documents will also be shared publicly as part of our normal process For making changes to our inspection program So that's an opportunity for members of the public and for industry to provide feedback on that I'll just note that even though there'll be some changes It's not to say one way was right or one way was wrong in the past We identified some if you will ability to to implement the guidance differently And so the need here is to tighten up that guidance such that for a similar set of facts a similar outcome comes forward in addition Bill Dean and his staff in NRR have identified a desire to look a little bit more Programmatically at our implementation of the inspection program We do that in other areas already in operator licensing for example our materials programs and others But the ROP oversight process We're going to look at we in the regions and with working with bill and his group to come up with a way That we can have a little more ongoing Rop oversight Thanks, big thank go ahead big please The one other area that Cindy and I failed to mention is training one of the important Discoveries if you would from the review that was done is that of the two main factors driving the differences One was the guidance and different interpretations of the guidance the second one was was training and that one's a bit Thorny if you would because the regions do implement training Some of it's on the job training and how we train people to implement the guidance or use Again use the guidance and what was noted was that there was difference in the training that the different regions were giving So one of the areas we're going to look at is is providing better sharing of that of that training and perhaps using in our as a resource to make sure that we're Training and developing our inspectors and our supervisors to implement the guidance the improved guidance more kids more With fewer differences more more reliably All right, very good And just staying with that topic and I think Cindy maybe you were touching on this a little bit a question from the floor Our initial license exams being reviewed as part of the comparison between the regions to verify consistency and exam difficulty There's actually a another effort going on in the area of operator licensing operator licensing has a routine basis been overseen by and or are on a Every four-year basis that I remember right and I think in our off years. We do our own self-assessments in the regions But there was a notable Licensing reversal that came out through the court system and after that a Working group on the agency's part was put together to examine the lessons learned from that and so that is an area It's separate from this particular Reliability effort looking at the findings, but we do have a parallel path that is looking at a number of enhancements to be done In the operator licensing area There are some that were taken very soon after the court decision was made, but we have more that we're looking at So that's yet to come Okay, very good question for the industry Please describe any challenges associated with vendors Supporting vintage INC equipment Please describe any challenges associated with vendors supporting vintage INC equipment I'll start I'll start like I think that most of the vendors are very engaged in working on this issue You know obsolescence is a challenge for the industry as well as the vendors For the most part I see a lot of engagement on that. I think there's some areas where Some of the specific instrumentation is hard to get and you know, you're really looking at doing an upgrade or a modification I think the industry has gotten better at doing those over the years Certainly at times it leads into a challenge Can you move in the digital space on some of these or not and how easy is that and what are the challenges that that brings? I would also say obviously with obsolescence vendors that have also had dramatic turnover just like all of the Industries and NRC And supporting our existing systems are extremely important It will be necessary to make control changes in the digital and of course This is an area that itself takes up a lot of very specific But I would just emphasize at this time that this is a challenging area as we work through the obsolescence That we'll need to continue to support Each other as we work through those areas Working with the vendors and then eventually the upgrades that will be necessary as we go forward Very good. Thank you So I'm going to stay with the topic of digital technology For a few minutes and I've got a question I'd like to pose to the panel and it is the industry's face with opportunities and challenges associated with moving forward with equipment upgrades For digital components. What's your perspective on ways the industry and the NRC can work together to improve our overall Effectiveness and efficiency in our respective roles and sort of as a related question to that A question from the floor given that all equipment degrades and wears with time Please describe any age related issues with instrumentation and control equipment. So So the topic is instrumentation and control How do we how do we work in in a way that is? that is more conducive to progress Industry and RC and then any particular challenges associated with instrumentation and control digital So Mike I Think they're can you hear me? Okay? Hello? Yeah, good. So Mike I I think I think there have been some pockets of success in the area of use of digital INC technology even in some safety applications and Guidance has been developed and we've endorsed some industry guidance NEI 101 specifically that have supported some of the digital modifications and upgrades that have been made But I think there's still significant room to improve And in that regard, I think those improvements will be most successful and most timely if we keep the communications open They're continue to be Good healthy communication among the industry counterparts in the eye, and I know every has a role there as well as NRR I Do understand that NEI and EPRI have recently formed a working group to look at a significant modification to NEI 101 if not a replacement to it to address some of the challenges that That exists in that document and that document Provides guidance again that we've endorsed to enable digital modifications under 10 CFR 50 59 And that EPRI is actually embarked on a technical review if you would to To address the common cause failure concerns that that exist in a number of the Potential upgrades Also, there's opportunity to upgrade the guidance for 50 59 modifications the NEI 0607 I believe to support the licensing reviews So again, there's a lot of work ongoing We as an agency need to remain engaged with the industry to make sure that Anyone who chooses to take advantage of those Digital upgrades do it very thoughtfully and with a shared understanding of what the Requirements are and in that regard this is an area and there are a number were pre-application Meetings with the NRR staff are extraordinarily important. So there's a shared understanding of Processes and contents of the application and the expectations Or shared expectations on between the licensee and NLR I also understand from an NRC perspective that there's a pilot Use of interim staff guidance six regarding licensing reviews that again It's being piloted should be completed complete at some time this year And there will be an opportunity or will certainly create opportunities to engage the industry On that interim staff guidance number six And let me just let me just stop there Okay. Good. Thank you Vic. Joe. Do you want to? Yeah, if I could just come in I mean, I think there's I think we both face the same issues in this area You know digital of OBS quickly and and the knowledge base to keep up with it is a challenge I think for both the regulator and for us and I really think that is Vic said I think continuing to keep the dialogue going is very important the working group I think we'll we'll you know bring some new issues to light and try to readdress some of the Approaches that were originally out there. I think you know There's generic regulatory concerns with some of the specific digital technologies that we need to make sure we're dialoguing on Getting clarity up on the places that there may be gaps in some of the regulatory guidance and really just making sure that We develop more generic information that you know is very supportive of growing regulatory confidence and given us confidence on the industry side That we can keep moving forward Very good This next question is really Directed at the regional administrators, although I'm gonna I'm gonna open it up I'd like everybody to have a chance to answer this it and the question is Are there themes? And it relates to an activity that we just completed in terms of looking at the performance of plants and as a part of our annual Roll-up are there any themes or low-level issues that are concerning you for your respective? Regions and I would ask the industry folks are there are their themes or low-level issues from your perspective That we ought to be mindful of and so I guess I'll start with the NRC and then but I'll ask the industry to weigh in as Well, Mike maybe I could start that discussion off What are the areas that we've been noting in our end of cycle and mid-cycle before that is weaknesses and operability determinations we've seen Quite a number of sites that have not Done very well in that area that we've had findings and a number of issues So we are partnering With the other regions as well as with industry to put on an operability Workshop and I'm going to look for a call-out May 12th May 12th, thank you Location in the Chicago area and that's going to be an opportunity for the agency the regions and NRR to engage with Utilities and members of the public on Operability determinations and evaluations so that's an area that we've identified We've seen as a trend and that's what we're doing in response to it Similarly similarly to what Cindy said we've seen some challenges with the quality of operability determinations But as a result of the most recently completed end of cycle assessment Last month one of the things that we noted was some real challenges with the quality of the operator licensing examinations there have been a number of Licenses in region four where there've been a significant turnover of staff and you have some relatively inexperienced folks that are involved in preparing the exam and Resulting in a fair amount of resource expenditure by the region and working with the licensees to develop the exam To address the deficiencies and in some instances Rejecting the exam and I know there are a workshop coming up and there's going to be some discussion about Exam questions and how to address the gap in terms of difficulty of exams So hopefully that will be productive, but that's an area where I noted and sitting in To each of the end of cycle discussions that I thought was a trend That I didn't recall from some of the previous assessment discussions So I'll I'll echo the lower and the question was lower level Issues or trends and I would echo that as well We've also seen a couple of examples of Turban building concrete Degradation just a couple of examples of that Where there were water intrusion issues clogged drains In the turbine building, so we're trying to better understand what that is and if there's any generic insights that could be drawn from that that may be of value and Several examples of maintenance inadequate maintenance rule implementation Again, not a significant trend, but lower level issues where we've given feedback on in fact, some of them may have even been minor violations But it wouldn't have gotten in a report, but at least in region two but fortunately But fortunately it was an opportunity to give feedback to the licensee who was very receptive to it I do appreciate the the question lower level issues and the fact that the question is asked means that you value that Feedback and would take action to address those issues before they become a regulatory concern Yeah, thanks just I would second the comment on the the rigor of operability determinations and expand it to include corrective action program issues in Rigor in the in the root cause of valuations and development of corrective action plans the other thing I would put out there is is Broadly equipment reliability, I think licensees are doing a good job in maintaining the equipment that is the greatest risk contributors But then the other equipment that is supporting That equipment and supporting the operators in response to events Sometimes we don't see the same rigor in that equipment and we see that coming up as Challenges to operators when something happens to the plant One or two other things happen and and complicate the operators response to the events So again, it's not it's not the the diesels in the hip season the ricksies It's it's more the the supporting equipment, but it just complicates life for the operators unnecessarily Okay Randy Jeff I just comment the equipment area. I really think you know ensuring the corrective actions really stick I mean most issues we all know previously occurred somewhere in the industry in many cases We've solved them ourselves and then they come back, you know at different times And I just think we need to continue to make sure that Those issues as they reoccur that are really getting the appropriate attention in the corrective action process I would Go a slightly different. We're talking about themes in area. We have lots and lots of new people in all our industry Yeah, we have an industry that has everywhere from pre-general design criteria plants to general design criteria to new plants So that the kind of the redefining of regulations, you know as we're going along we think we have this We have new people and the next thing we know well, that's not what it meant So that's a theme that I would that I'm concerned about I know a lot of people out here are that you know what the rules continue to be challenged which again, I kind of go back to the Question you had where we should be comparing note across region because it may start here And there's a chance for us to look at those and say what a second. Let's do a reset But you know the reality is we do have our licenses from pre-GDC to GDC early and late to new That challenge especially as we break it new people of Ensuring that we maintain our license of basis and new upgrades were necessary But be careful that we're not redefining things Without going through a new process Thank you. Good answers everyone and I brandy you Started me on a topic. I was going to go to Maybe a little bit later, but I'll you took me there So we'll go there now and it relates to the workforce in the industry and the fact that that workforce Nice talk about industry broadly is aging And retirements are increasing and so the question is what actions are being taken by licensees in the NRC to retain knowledge and important Areas like the one that you just described brandy to retain knowledge of experienced workers NRC staff so on and so forth Let me brandy ask you if you want to continue with an answer on that topic and then I'll shift over and get it I can open it up. It's an area that I'm quite interested in The first of all enough so that the young people that we're bringing in the capabilities is just fantastic But an aggressive in my particular case if I hire a hundred and fifty people this year I can still go down 30 people Because of the turnover that we're dealing with So it is extremely important to do knowledge transfer and we frequently think of the knowledge transfer from operators and all But I'll go back to kind of the thing. I started the regulatory knowledge the regulatory transfer Many cases were not as formal on ensuring that that history isn't fully understood and the rules and the licenses So I do think that's an area that could use that not only at the Well certainly at the utilities, but again, I would ask what the regulator is doing ensure that the plants that are pre GDC Which are many of them or early GDC plants are? Getting a fair shake as they go through that type of area Okay, so do you want to take that one? Sure We too have the similar problem and actually I asked for a couple of statistics thinking this topic might come up and today in the NRC 19% of our workforce is currently eligible to retire and in five years that number climbs to 62% Now not everybody retires upon their eligibility, but you know those numbers are rather shocking So it's certainly something that is on our minds and we're doing a number of things certainly one of them is hiring the right people and getting Experienced people and people that we need to develop Into our pipeline and so we're doing that In a mindful way you heard a lot during this about aim 2020 and how we're anticipating the agency may Get smaller, but that's not Gonna have us stop hiring the right kind of people because we are going to continue to have that need So we're looking to do things like what we call double encumbering if we know people are going to leave We need to want to bring them in such that we can have that turn over in a meaningful way with those experienced people that are Leaving and we're also doing what we call over hiring if we don't know a specific person that may be going We know an area that we're going to need and so we're bringing people in While we have the talents still before they retire to start sharing that knowledge We're doing a number of other things There are a number of things that for example the Office of Research is doing is putting on Seminars and those are being recorded some of them are being developed into new regs for more broad Distribution as an example. I know all the regions and offices are also having Call them knowledge management sessions or knowledge transfer sessions where we're bringing various topics and spreading that knowledge throughout our Organization again trying to capture those things when we can though honestly We're struggling a little bit about how you captured some of that knowledge such that it's retrievable from people So, you know if people have good ideas to share about how to capture that in a retrievable way For years to come that's something that we certainly could learn from and those are just a couple of things that we're doing so far Anyone else want to weigh in on that topic? Again, you're not constrained to or compelled to All right very good, so I have a couple of questions really that are follow-ups to other questions or answers given one relates to with respect to Component design basis inspections And this really I think Dan directed at you and Joe, but anyone can weigh in as well What one? What are your views about what activities or areas? Should be focused on to get the most bite for the buck as it relates to see DPI inspections anyone to start sure. Thanks Mike Joe Suggested earlier Industry suggestion of looking at some programmatic areas that support the design basis I think there's there's kind of an underlying principle when we went to the ROP that we were moving away from Programmatic type inspections and looking for more performance-based inspections. So, you know, we'll we'll explore that option and But I think the going-in point from some of the folks who've been around the ROP and remember before our RP is Reluctant to go in that direction. I think the the there are other elements of the Reactor oversight process that relate to the implementation of changes to the plant design modifications that are areas where you can look at How effectively the licensee is examining the existing licensing basis and design basis in evaluating the change to the to the plant 50-59 evaluations the implementation of design modifications Those those can look at how effectively The licensee is is maintaining their design licensing basis as they're looking at changes to the plant I think what the CDBI gives us though is that I wouldn't want to lose is is sort of the insidious changes to the plant the unintentional De-evolution if you will of the design basis. So how we how we it may be a shift in how we Address the balance between those two components Yeah, I would just just a couple comments I you know, I think insidious is as the good focus Dan I mean latent designers as the place you really I think can provide a lot of benefit as you're looking at that I also think that um, you know just considering some some sort of performance base approach You know that's really based on the known assessment of utility performance over time in this area Would give you a pretty good feel for it I think you you have a good understanding of where many of the utilities are now I think you could focus the teams much more effectively if you took that into account Am I yes, go ahead mark. Please just one comment to add having looked at the NEI white paper one of the things that I noted in particular was The suggestion that we modify the CD bi a scope to focus more on Validation of the health of various station programs that if not effectively implemented could adversely affect design margins example being modification process versus The current focus of CD bi's which is more in the area of design verification, and I think we need to maintain The appropriate balance there I would not be a proponent of shifting strictly to Assessing the health of Licency programs that could have an impact on the design basis I think there is value in going back and and looking at the design verification Aspect and I know there's an issue that we're looking at with a current CD bi where we have a question on The acceptance criteria and it goes back to the original design assumptions And so I think there is value in continuing to keep that aspect of the CD bi And I would offer there probably is room for some scope reduction in that area But I certainly wouldn't want to lose that element and focus more Just strictly on verification of the health of a licensee program that could impact the design basis Just really quickly Mike. I agree with mark I also Open to the comments that Joe has made and this is an area of our oversight were over the years We've grown. It's matured. In fact, when I first started with the NRC a long long time ago Mike and I were in the same division and my super supervisor was Jim Dyer the first Inspection I was on was an engineering inspection engineering We called them back then safety system functional inspections And when we transitioned to the react oversight process some 15 odd years ago We changed the name to safety system design and performance capability Inspection with a slightly different focus and not long after that. I think four or five years We actually piloted the Component design basis inspection approach in region two and it was expanded Nationwide I think that that story Tells me that we're open and interested to feedback and we want to improve this important area of our oversight process it is truly fundamental in my opinion to to safety and I Think I hope we're mature enough in our understanding of our process and significance to know that simply because every inspection does not identify a white Finding or yellow finding does not mean that it is not adding value Green is not necessarily good Minor perhaps should be green But there are opportunities to learn and grow and we need to take advantage of performance improvement But still modify our program as appropriate to still derive the value from it So we're committed to do that. It's consistent with our our principles Efficiency And and that's what we'll do and we'll certainly provide opportunity to engage the industry Randy please yeah in this area, sir I've been a lot of good discussion on it I think a few things that came out though is what is the appropriate scope adjustment to get better use of our resources How do we take some credit for what the licensees work is going on? Which there's quite a bit of that and that's an effective use and then I throw in the last piece So try to be real careful not to redefine our design as we're going through these and that we have accepted designs and license places and again that creep it gets to be Nothing we should watch out for Okay Very good Switching gears a little bit now. We're going to talk about new plant construction. So Joe and Vic You guys should listen to the question Are there any lessons learned from new plant construction or licensing and Execution that informed or benefited the operating fleet either in technical issue closure or in safety in sites so things that you've learned gleaned from new reactive construction Execution that have informed could inform us technical issues or otherwise Do I start bigger Joe? So We're still learning and I'm sure once What's bar unit 2 is is completed and when the AP 1000s are completed will update the guidance documents on lessons learned from the next wave of Nuclear construction in the US. I think among The lessons that will be spoken to I don't know if Glenn Tracy is in the audience one of the challenges that we're seeing is that it's the quality of Components in the nuclear supply chain supplier quality and That's that's an issue that I think has Relevance in with the operating fleet as well and efforts to assure the right quality the right pedigree of Equipment that even operating facilities need And also, I think another area is Oversight of Contractors oversight of work And that's been manifest and not only At some of Joe's sites, but other sites I know in in region 2 have had lessons learned in terms of the amount of effort and ownership and oversight that you have to Give to assure that Quality work is conducted on site. So those are just two thoughts Joe Yeah, just a couple comments, Mike I think we've taken very good advantage of past industry experience even though in some cases It's been a while certainly a lot of work that's gone on in the modification process and others have really enabled us to update a lot Of the parts of the plan in a fairly efficient way and probably better documented than we did in previous times building plans You know interesting enough I think we've also had a chance to deal head on with some long-standing industry issues with facing a new license in front of us and In some cases been able to engage a different technical approaches and I think a deeper dialogue It's enabled both sides to see issues From a different perspective and I think there's some advantage in in that that'll flow back to the operating fleet If I could have asked or also introduced a design finality and Constructability without going into a whole lot of detail. I think those are important areas as well Go ahead. I think part of the question was benefits to the operating fleet and I just pick up the the theme that Vic touched on in terms of oversight of contractors and It I think there have been other issues in the operating fleet that go to not just oversight of contractors on site for the operating fleet That's especially during the outages But also oversight of contractor services and safety analysis in the procurement chain of quality of equipment So I I think there's there's a broader issue there that that is something that the operating fleet needs to stay on top of as well Thank you very much I've got a couple questions related to cross-cutting issues and I saw me. I'm trying to get this card back from Randy You know whether he was holding on to it because he didn't want me to ask it But Joe you've got one also Cross-cutting issues the question for you Randy and really there's similar questions What's the most significant cross-cutting issue identified and open at Palo Verde what corrective action? I think that I think that they're really the theme of the thrust of the questions are if you think about cross-cutting issues at the sites You talk about one of those or and then You know how they've how they've Really affected you what you've able been able to do with those cross-cutting issues as you move forward terms of corrective actions So as I read that it was talking about the most significant cross-cutting issue Interesting enough. I'm sitting there trying to work through my head of what is the most significant one You know we do the monthly views like many sites where we're looking at all the cross-cutting issues We do the reviews Constantly and then so every area gets tackled I would probably say the biggest theme we've been dealing with a little bit is some of our human performance errors You know you're looking at my surface level and then you start looking deeper It was really a lot of again so much turnover and the real depth of understanding of the why so the training It was showing up as a human performance error But it was really more of a training issue and that we We were teaching a lot of the howls and watts and not as in depth of the wise and Doesn't hit you until you have enough new people that that aggregate amount. So if I put two new people on crew That's it was a lot of experience but currently we have lots of new people on crew and that experience factor is down and The training is great and the procedures are great and the simulators are great But they're really depth of understanding can manifest itself as a human performance error If you're not careful, you go fix the symptoms of the root cause and the root cause is not easy because you've got to really go back And teach a real strong depth of understanding Because you're now trying to make up for years of experience on a crew and again the people that we deal with is just fantastic that If you ever get down in your energy, just go visit one of your classes that you have now And of course most of them weren't born when TMI happened It's Mike's for an interesting discussion on the wise and the depth of understanding Thank you, Joe Well just add on that Randy's a little bit You know human performance is one of those things that just takes constant steady pressure to stay in front of it It's always out there for all of us but you know the one they really get your attention is if you get something in the safety culture area and You know, we all know we're always trying to prevent that I think you get tremendous amount of learnings about your organization and you know What what you haven't been paying attention to and where the leadership really needs to focus and Probably most importantly, you know, why wasn't the leadership focused in the right places and so you know out of that I think you can not only Address a specific issue, but you can really get after a number of other issues that are impacting your performance across the board And so I encourage folks to not go there to find out that answer But it but it definitely gets you from a perspective of a significant issue Very good. I'm going to switch gears now. I want to talk about a little bit. I want us to talk about significance determination processes And so I'm going to start with the NRC The question is on occasion the SRAs in some regions Will default to higher significance determinations Using very conservative assumptions when there's an absence of technical input and certainty from the inspection team It's the context for the question What efforts do the regions undertake to ensure? consistent use of technical inputs and PRA processes to ensure predictability and Consistency of outcomes between the regions and then for our industry counterpart similar Interactions with sites during the significance terminations produce assumptions in a wide with a wide range of quality What level of quality and data and assumptions for risk analysis is appropriate for input for input and decisions regarding regulatory response To licensees performance. So again a focus question on STP's mark. Do you want to take that? Yeah, thanks, Mike I'd offer a since I arrived in region four about 18 months ago I've had the opportunity to be involved in some rather challenging significance determination processes dealing with flooding deficiencies and some of the some other challenging events and I would offer that our preliminary risk significance determinations They're based on the best available information at the time the determination is Reformed and if you in the absence of specific technical information, we look at conservative assumptions and those may need to be applied But to ensure at least some consistent application when we conduct a phase three assessment that is a peer reviewed senior reactor analyst the same region four is conducting a preliminary risk determination that Result is peer reviewed and then for any preliminarily greater than green findings that we receive a second analysis performed by the program office of I think it's the division of risk analysis DRA in the Office of Nuclear Reactive Regulation and Then the results of that are discussed at significant enforcement review panel or SERP and we ensure that we reach consensus on what should be the appropriate agency conclusion prior to issuing that preliminary finding and then As part of our process there is the opportunity for a licensee to communicate their perspective regarding the Risk assessment and many times in developing our preliminary risk assessment Our senior reactor analysts the inspectors are fully aware of the views and assumptions that are being used by the licensee's PRA Specialists and The other thing is that the senior reactor analysts are in frequent communication with each other and their counterparts in the program Office to ensure they share Any specific learnings their monthly teleconference calls in their semi-annual or counterpart meetings And that's all in the vein of ensuring sufficient knowledge transfer, but when you're dealing with uncertainty You may have to resort to use of qualitative factors when you can't determine make a specific point estimate there on either say initiating event frequency and The manual chapter 0305 allows you to use qualitative factors and and when you do enter into use of qualitative factors Clearly there is subjectivity that enters into that But we try and apply the guidance to the best of our ability and ensure we're sharing the approach that we're exercising With risk analysts and peers to ensure to the best of our ability that there is a consistent application Okay Joe do you want to take that one also? Clearly consistent application is the challenge for all of us and you know the real challenge when you get into some of these STPs is how do you get the high-quality data combined with the timeliness of pulling that data together? so that you have the right the right discussions going on at the right time and We come from the perspective in the industry I think is the regulator does it the quality of the data of the assumptions and What we know about those assumptions when we're doing the STP is the key to our success And I think it's very important in those conversations to know You know how close and how much you believe in each of the assumptions and what's really behind them So the high-quality data is very important And I think the open interaction between what the utilities find in STP space and those assumptions and what the SRAs are doing is very important Consistently get to the right answer Hey Mike Yes, really. I'm sorry. Thank you Joe. Yes, Mark Just one quick additional perspective to offer I think we face challenges with the timeliness of STP determinations particularly when you're dealing with an issue where you're looking at what's the appropriate credit for recovery actions And I know we're working with the program office to improve our guidance there and look at Delivering an STP result in as timely a manner as we can because I think it can be challenging To communicate to members of the public if you have an event and then you look at the length of time It takes before the agency delivers their final risk Significance determination You end up being challenged and having to explain well here is the Reactive inspection we conducted to ensure the public health and safety was not at risk during that period of time while we're finalizing the risk Significance, but I don't think we do ourselves a service there when it is a you know a year after the initiating of Event that we're trying to determine the significance of the performance Deficiency when we deliver that final result and there are a number of factors that can contribute to those unique situations, but I think You know working with the industry to make sure we fully understand the assumptions that they would offer should be used and Communicating the assumptions that we use in our risk assessment and reaching closure on that risk determination in as timely a manner as we can I think serves the public well in ensuring that we're communicating a consistent safety message Yes Anyone else want to weigh in yeah like to There's been a lot of growth in this area for quite a while that the subjective areas of how you fly human performance factors and all It's always been an area that it seems to be one the toughest and we're gonna add to that now that we have added a lot more equipment Or by then this year we'll have the flex equipment available. We're trained operators and others use so this area of subjective Use of and the human performance factors and all it's certainly an area. I've got now I have equipment I expect my people to use it How are we gonna credit those and all and I know Mark and I have had some discussion in this area And so we're in we got a lot of beyond design basis of equipment That people are gonna be functionally trained on and and how to appropriately Credit that is gonna be an interesting area and it's in an area that we've had many discussions with in the past and Disagreements, thank you, Randy. I'm not gonna let Mark talk on that issue Yes, please do Scott I'm Scott Morris I represent the Division of Inspection and regional support at NRR and many of the topics that the panel has addressed today Fall into our wheelhouse clearly And STP is certainly one of them significance determination process. So I just wanted to just to Let the folks know in the room. I know the panel probably knows this but the Commission has actually directed the staff to tell them or For us to tell them what we're doing to enhance the STP and the words they use in their direction was to streamline the STP Which mean to me means efficiency Among other things. So we're doing that. We completed a business process improvement initiative about a year ago looking at the existing process to try to find ways to tune up the existing process To you know mitigate some of the challenges that mark mentioned and others so In addition we are and we'll be given opportunities to interact with the the industry and the public on the direction We think we need to go with respect to Streamlining the STP that's a near-term activity. So and to To Randy's point I would just mention that we're also fully engaged in an effort to assess the the how to Incorporate things that are captured mitigation equipment for beyond design basis events, but also Things that are already required to be incorporated as a consequence of what was formerly known as B5B equipment But now To equipment so all those things are under consideration of the myriad of activities that we're working on to enhance the program This is one that's very important to us in central and I think key to the process moving forward Thank you, Scott, but you're gonna ask a question This next question that we're gonna switch gears a little bit the question is Can each of you comment on the usefulness of regular of regional utility group meetings and Including whether you personally attend so rug meetings how useful are they and do you attend mark? Do you want to start? Yes, I've had the opportunity to attend to rug meetings since I assume my Responsibilities as regional administrator and I view those as a highly valuable forum for communication exchange to understand issues of concern on the part of the industry as represented by the Regulatory assurance managers that attend so I personally attend and if I'm not able to attend Deputy regional administrator attends in fact we have a rug meeting coming up on April 1st, and I'll be accompanying one of the commissioners to a couple plants that week and so my deputy regional administrator Chris Kennedy is supporting that rug meeting We actively reach out to make sure we understand what topics The representatives would like us to address so I think they're very valuable and important Communication exchange, so I fully support that initiative We too have rug meetings in region 3. I would say we're going through a bit of an evolution To try to make them even more valuable We've had kind of I'd say a bit of a mix in our history in in how those have gone And so there's a concerted effort on both the industry part and the region's part to make those more valuable experiences It's typically supported by our division directors Myself or my deputy may go Periodically, but we've added another type of meeting to our mix that I think is proving to be quite Quite valuable, and that's a meeting at my level with the site vice presidents And so we've kind of a bit of a mix and I know other regions do some of this as well But that combination I do think provides a valuable opportunity for interchange and feedback So I think similar to regions 4 and 3 region 2 supports regulatory users group meetings at least twice a year and Similarly we meet with the plant managers region 2 plant managers at one point where we're doing a region 1 2 plant managers meeting a couple of times a year either in region 2 or region 1 And we I meet with the site vice presidents and I guess to the question of the level of participation if I can't attend one of my Deputies participates in that valuable opportunity for sharing the mooses proverbially always on the table So any issues that are relevant are brought up and the feedback is is always is Usually positive So we really look forward and to and value those those sessions I guess I didn't realize they even had proverbial moose in Georgia Having been in the job for three months I have a hundred percent record of going to one out of one Rug meeting since I've been there I found it to be a very valuable Conversation and I expect that I will continue either myself or my deputy and participating in those in those meetings I think it's a it's a good dialogue At the read at the reg insurance level and I also agree with the comments that were made about routinely meeting with the site vice presidents and and I also had at the rug meeting that I did participate in In encouraging open communications also support fleet meetings Because at this point we have a number of fleets that that that touch several of us Am I the only thing I'd add is that at those same meetings? We always invite an NRR representative or an insur representative and they typically show up and Oftentimes they do more sharing than than the regents do because of the importance of the initiatives ongoing now in the agency so again a valuable opportunity to share Yeah, I believe anytime we can have open professional communications talking about our industry and the challenges I've had participated in the past I get briefed on some of them now whenever issues are there I think they're a great opportunity and if anything I would just encourage us to Be aware of our young and up-and-coming and add a few more to these meetings who can get exposure at this time now While we're still around very good Yeah, and I would agree with Randy. I think they're vital exchanges of information I would encourage it There's probably Opportunities to keep some of the more challenging issues in front of those groups and talk about resolution paths You know especially on some of those long-standing issues that we all all have in front of us just another forum for that kind of dialogue Thank You Joe and and as it reminds me we have also another I think valuable opportunity to meet in terms of the meeting that we have With the industry chief nuclear officers with us on insi act those meetings where we have an opportunity to share information raised issues that are that need to be focused on so that's just another example of a Really good opportunity for us to get together and make sure that we make in progress on issues that are important I've got a number of questions. These are all right. Incidentally, I just got to tell you the audience audience is raising great questions Usually you get two or three throwaways that you don't dare ask, right? Haven't gotten any throwaways. I've my problem is my problem is getting marked to finish quickly enough so I can get on to the next I think we're noting a substantive cross-cutting issue trend here But actually mark a I do have a question I'd like you and Dan to field and it relates to the the songs lessons learned activity that we've been engaged in and It's not yet I think then publicly available, but it certainly has wrapped up and a couple aspects to that I'd like you guys to talk to one is and these are questions one relates to The 50 59 reviews and the weaknesses in those 50 59 reviews and so Dan I know you did a lot with that before you left In our deputy to go to region one so if you could just talk about that a little bit and then mark if you could talk about the inspection program changes or or Inspection program changes that would be conceivable based on that activity. So please Yeah, so there's a number of issues 50 59 Related to songs and some not related to songs The the the underlying issue songs replaced team generators. They did it under 50 59 one of the generators in unit three failed tubes failed Halfway through the first cycle raised questions about the the the adequacy of the 50 59 review and That was done as well as questions about well, you know did region for miss something in looking at the 50 59's I think ultimately the staff's conclusion was that there was a Green finding cited against the 50 59 evaluation But that the root cause of the of the problems with the generator were design control issues not not a 50 59 issue fundamentally IG looked into that they Had some some broader perspective in their in their report on on some Issues that they put on the table that I would characterize as open questions about other aspects of the 50 59 that the staff had Not dug into in their inspection activity, which also feeds into the question of a do are we given the inspectors the right guidance in the 50 59 inspection procedures in looking at Licensees screenings and evaluations, but also There was also a question of is there something unique about a large component like a steam generator versus other components and so all of this was folded into our songs lessons learned project that Mike alluded to the Edo provided direction to N. R. R. O. Who had the vendor oversight component of it and region for? To look at a range of issues related to the songs experience in the 50 59 and inspection of 50 59 Was an important component of that and during that lessons learned review the IG report came out and so evaluation of the IG report Got folded into that effort So I think the bottom line there as Mike alluded there is a draft report. I think it's close to being finalized I think there are some things that we can improve in in the Oversight of 50 59 but fundamentally the staff concluded that 50 59 itself is sound it is appropriate for Large component replacement. It doesn't really 50 59 is agnostic on how big the component is It's really how does the component affect the safety margins in the licensing basis of the plant? In and it's important to may point out that 50 59 is not a safety determination 50 59 is a decision-making tool relative to whether a licensee needs prior NRC approval before implementing a change and there are specific criteria laid out in the in the 50 59 rule and expounded upon in guidance that was developed by NEI and endorsed by the staff Many years ago And and it has been a very effective tool in ensuring that both industry and the staff are focusing our attention on the most safety Significant issues, so I don't think you'll see fundamental shifts coming out of the songs lessons learned activity in the area 50 59 I think you will see areas for improvement in in our staff training on 50 59 and and in how we Look at 50 59's and and it's both in the inspection piece and also For the for the things that a licensee evaluates under 50 59 and concludes that they can go ahead and make that change without prior NRC approval they are required to provide an annual report of those changes And and how we how we review that report when it comes in as well as the associated changes to their FS a ours That are required to be updated, so so I think there are improvements coming as a result of the song's effort I think their improvements on on the margins and the implementation of it Okay, Mark. You'll have the last answer. Yeah, thanks, and I will attempt to be succinct here I only have three quick points here Obviously as Dan indicated there were some learnings regarding our review of the licensees 50 point 59 evaluations and learnings communicated from the Office of the Inspector General's perspective and the views that were delivered by those that were responding to the songs lessons learned tasking memo clearly there will be a change to our enhancement of a guidance inspection guidance regarding our review of a 50 59 product I think we would be looking at ensuring we had experienced inspectors that have had you know have had the opportunity to review a 50 59 fairly extensively I There also will be a change to the I'll call entry criteria for when you might conduct a vendor inspection I think historically those vendor inspections have been reactive in nature when there has been an issue identified and there will be some enhancement regarding a guidance for when you could initiate a vendor inspection And also some guidance regarding when it may be appropriate to conduct a more detailed evaluation For a large component replacement like a reactor vessel or a steam generator and leveraging the various procedures that we have If the region in coordination with the program office thinks that there's some unique aspects that would warrant a more comprehensive review Then just looking at the 50 59 evaluation Thank you. Thanks. Good good set of questions a great set of answers. I got to tell you I have somebody didn't get to There's one that asked about timelines for some of the things that we talked about in terms of the ROP enhancements And when those things are rolled out will I get that answered? There's a question about substantive cross-cutting issues and That meeting and what came out of that meeting what was committed to and so we'll get an answer To that question up on the web page There are a couple of questions actually in different handwriting I was actually wondering whether someone was hadn't was getting a little frustrated that I hadn't asked this question And so wrote a second question, but I'm pretty sure that's not the case This question really deals with pre pre GDC plants and and Issues around our knowledge related to pre GDC plants and and our approach to resolution of those issues and so another set of questions that we'll get answers to up on the web page and then finally there's a question about the reactor oversight process and and Sort of the initial set of that process which which really allowed 30 days to complete a root cause and and but a part of that because is is maybe Benefited by having the NRC's an indication of the NRC violation And so it talks about the timeness of those issues as they roll out and have as we originally attended it In the original ROP as we set it up. So You'll you'll see the full question. You'll see that question answered on the webpage. I apologize for not getting to those I think we had a full set of questions again in a great set of answers to those questions. I do want to Enclosing thank of course the the panel coordinator, Rob He's very he's very disappointed that I mentioned his name. I Want to thank the panel a very distinguished panel good answers again Thank you for your time and your answers and I want to thank the audience of course for being attentive and Great question. So please we're free. You're free to go. Please enjoy the rest