 Good day and welcome to the third day of the 2022 regulatory information conference or the rig. This morning we're going to have a great panel discussion about our experience executing the first part 52 combined license for boggle units three and four. My name is Omar Lopez Santiago, and I'm the deputy director for the division of construction oversight in our regional region to office in Atlanta, Georgia. I'm going to be the, the chair for today's panel discussion. This is a busy time for boggle and all of us as we work together to ensure that the first new power plants built in this country in over 30 years are safe. In today, we have the following panelists. First, Zachary Harper sack is the manager of Westinghouse plan licensing engineering team, and his group is responsible for Westinghouse licensing activities related to new plan bills. Next we have Amy Chamberlain. Amy is the nuclear development regulatory affairs manager for Southern nuclear. In this role, Amy supports boggle three and four construction licensing needs. And then we have Nicole cover. Nicole is the branch chief of the construction inspection branch one in DC O my in the same division I work for, and Nicole is responsible for managing the construction inspection program of boggle units three and four. And Nicole is Victor hall. Vic is the branch chief of the boggle prayer office in the office of nuclear regulatory regulation. Sorry, nuclear reactor regulations in our, and he's responsible for licensing and overseeing the construction of boggle three and four. In today's panel. We're going to be discussing the following topics. We're going to be talking about licensing. Itaq, and you're going to hear that word a lot. Itaq means inspections test analysis and acceptance criteria. The construction inspection program and applying lessons that we have learned throughout this process to future applications. This is a panel discussion so we are going to encourage everybody the audience to ask questions to the panelists, and please use the chat function in the application. So as an introduction and to start to kicking kicking kicking off the panel discussion. Please, a big tell us a little bit about your work with part 52. Thanks Omar and welcome everyone to the regulatory information conference. So in part 52, I won the property to lottery, and it's the jackpot because I have the best job in the world. But what I mean by that is the work that we get to do is so unique, and it's so important to other country that again I feel incredibly blessed and lucky to do by the side of the branch chief for the vocal project office in the office nuclear reactor regulation. So the tagline in our undergraduate relation is we make the safe use of New York technology possible. And as you might have gleaned from the name vocal project office we do that very specifically for the vocal construction project which is as I'm more mentioned the first nuclear construction project in this country over 30 years. So it's going to sound really corny I apologize but it's like 830 in the morning here in DC and I'm the king of dad jokes but what we do in the office is kind of magic. We make safety from nothing. As a regulator, you know we don't, we don't make a single pump or valve, you don't design anything we leave that the Zach and the good folks at Westinghouse. We don't build the plant, we leave that to Amy and the fun, the fine folks at Southern, but when Nicole and I get to do is from paper. We had create the rules, we inspect that we do we know we don't create anything but we make safety we're able to create the plant, make the plant safe. And that's kind of a cool thing we think about it's an intellectual pursuit of making something safe without actually touch them. And so it's it's a kind of a unique thing and it takes incredibly talented folks to do that there's a skill. There is a special knowledge that goes into being a regulator and making that happen. And that's where I feel incredibly lucky because I'm working with the folks in the vocal project office who are just really good at what they do we have. We're engineers, project managers, who have since the very beginning of part 52 worked on this unique process to make and make the plant safe. Part two is kind of unique beast, it's the first time we're ever going through this process. If you've heard me talk about per 50 in the past, you know it was derived from the FCC is regulations on building communications towers it was a separate construction permit for building them and then operating them so you know you're talking about 1950s type regulatory structure in part 52 which was born in the 1990s was meant to standardize plants bring some stability to the regulatory structure. And you know we we now have 20 years of experience of design certifications combined licenses. And a lot of lessons are from that and we're in the first kind of stages of this, this overseeing construction the very end which is really exciting, and getting to see all that come together so in terms of party to my experience is the last four years working with incredible people who have incredible experience and getting a chance to see this plant come out of the ground and be done safely. Okay, great. Nicole, what about you. As Omar said, I am my name is Nicole Cooper, I am the branch chief in the division of construction oversight, and that long to reach an office. And I would echo recall that the folks that I have the pleasure and opportunity to work with every day are just incredible inspectors with skill sets that go across many different disciplines and experiences. And when I say inspectors it's region to inspectors, all of us are involved in the vocal project and performing inspections. And as part of our mission we regulate and provide inspection oversight of the construction activities for the global unit three and four sites that's located in Williamsville, Georgia. And this is to provide reasonable assurance of adequate protection for public health and safety to promote common defense and security, and to protect the environment. The construction oversight also influence the inspection program, which includes resident and regional inspectors with the support and headquarters technical experts as the call was referring to. And what keeps us busy, very busy is the planning scheduling and completing the three different types of inspections, which are construction inspections, initial test program and operational program inspections. The resident and regional inspectors at mobile, they devote significant time and resources to verify that the licensees construction and completion of inspections test analysis and acceptance criteria is Omar say that said we will say that a lot today is what we call it. In the new reactor licensing process for Tennessee part 52, a combined license enables the licensee to construct a plant and operate it once construction is complete. And if certain design specific pre-approved sets of performance standards or itaq identified in the combined license are satisfied. So, essentially, the itaq are necessary and sufficient that when successfully completed by the licensee provide reasonable assurance that the facility has been constructed, and will operate in accordance with combined license, the provisions of the atomic energy act of 1854 is amended, and the NRC rules and regulations. So through licensing and inspection activities when the NRC makes that determination that all attackers satisfied, the NRC would authorize the licensee to load fuel initial point startup and operation which we also commonly call and refer to as a 52 one of the G funding. Thank you, Nicole. Amy, your turn. I'm Amy Chamberlain. I'm the nuclear development licensing manager for Southern nuclear. And I've actually spent most of my career working in part 52. For the last eight years I've been here with Southern working to build the Vogel 3 and 4 plants, and I guess the Georgia. My team is based out of our Birmingham office. So we are responsible for license amendments exemption requests alternatives, and really being the Ford looking organization to take some of that work on offer the folks at the site. And for the last eight years we've been working very closely with West House and Zach's team to process these license amendments and various changes to our license. So but before I came to Southern, I also have worked in other part 52. I've worked in applications and pre applications. So I've seen local three and four actually get constructed and getting really really close to come online. It's really personally for me. Something I wanted to see for our industry so I'm really excited like you said it's a very busy time at the at the site. It's really hard to get those I tech close. So that's, that's, that's my role for part 52. Thank you, Amy, Zach, what about you. Morning everyone, my name is Zach Harper. I'm the manager of licensing engineering here at Westinghouse. I have about 12 years of experience working in part 52 I started. And we were still developing the design certification document. And my experience there was primarily working in the ISG 11 process, which now is in rate guide 1.206 and supporting the ACRS meetings and the various chapters the responses to the NRC's request for information. And I also supported the, the different license applications for AP 1000, and as well as also supported the some international efforts in in China supported their, their licensing process as well. The design certification timeframe, I've been supporting Amy and her team to develop all inputs to their license amendment requests and the nonlar departures the that are written under the section eight B5B criteria, as well as supporting the site teams with ita closure of the engineering inputs ever pretty unique job where I get to sit between the Westinghouse engineering team that defines the requirements and specifies the design for the plant. And also work with the construction engineers on site to make sure that you know we understand their needs and how what we can do within the bounds of license to make their their job easy and easier and more efficient. So I'm working with the team, the ITAC team there on site to understand where they're struggling or in need of changes or clarification on on requirements or what design inputs they need for for ITAC closure. I'm excited to be with you today I look forward to to the questions that we can answer. So let's start with licensing. And this question is for Amy. Amy, from your organization's perspective. What do you perceive to be the greatest benefit to executing a part 52 combine operating license. I would say it's two parts. And they're kind of intertwined certainty and finality. So those, so certainty, certainty and what has been designed has been licensed and constructed. In the part 52 process, it were required to construct in accordance with our license. And I will say during construction this always this hasn't always been a benefit, and sometimes it's been a challenge. But I personally believe that when we come operational will have certainty in our licensing places reflects our constructed plan. Through the work that we have done as the licensee through the various processes, including ITAC and finality plays into that certainty. We have the DCD has finality, and that through the process has gained a certainty in the construction process also. Now if you want to chime in on finality of the DCD. Yeah, I think that that's really one of the key advantages of of the part 52 process where you get that finality, and you get those safety issues identified and resolved upfront in the process and resolved. And through the COL application that that designs application process that design has has finality and that goes up through the startup of the plant. I would say that, you know, just to jump off of the question that you have another key benefit of the part 52 process is standardization. The key, I, I perceive, you know the the part 52 process, you know the key advantages is standardization design finality, resolving those key issues upfront prior to construction so for for, you know the key success for of a new nuclear you know standardized design developed through a standard procurement and construction process and is is licensed in a standard approach, and it's perhaps the most salient lesson learned from you know the 1980s of their nuclear builds, and it was recognized through the development of the utility requirements document the URD and the promulgation of the part 52 and allowing that standard standardization and the, the, the finality of it really gives a designer and a licensee the confidence to know that once that plant is is constructed and it's going to start up and and operate. Vic, this question is for you. How has the NRC managed to cut license amendment review times in half compared to the review times for the operating fleet. Can you apply that for all licensing work done by the NRC. Yeah, maybe a little background context, because as Amy mentioned, there have been a fair number of licensing actions since the combined license from 2012. We have the NRC has issued a close to just over 200 licensing actions which includes license amendments, exemptions and code alternatives. In the last four years, really since the formation of our office to vocal project office and another group we'll talk about called the the vocal readiness group with the RG. We've managed to to keep our review time around six months which is about half of the standard time for a call to routine licensing action the rest of the agency. The important thing is we've done it with the same incredibly high rigorous standard of safety so they're you know there's this it's not like we were just doing quicker it's still it's a matter of being finding efficiencies and and doing things kind of to the pace that's required for construction because what's different about vocal obviously to the rest of the fleet is they're building the plant and there's a there's a need to change the license as things come up as construction is showing that the plant designs to be a little different than what we originally anticipated. So how we got in there. You know the first thing is we have amazing people working on this the project managers that we have on our team are extremely experienced in Part 52 and new reactors. They are problem solvers. And so they know their craft and again it is a craft to be a an NRC project manager knows the regulation that understands the engineering side of it, and can can bring those two together towards safety so we have amazing people that work on this we're incredibly motivated. And really I'm going to say huge, huge tip of the hat to communications and we've done for this project. I mentioned the vocal readiness group. It's kind of a we took our lessons learned from the Watts bar reactivation and built this. I'll call it a team but really it was still our independent agent independent parts of our agency working together and just communicating non stop we've had I think 40 different energy meetings in the last four years. And it's really just bringing together different parts of the agency. The Vogel project office chairs, part of it, Nicole's group and Omar your group obviously in the division of construction oversight region to chair it. And we have other support from NRR and we bring together all the different parts of the agency so we bring together our tech groups, we bring together our legal side we bring together security folks are EP folks, and we have discussions about what's coming. So let's solve the problems in front of us sets internally externally we've been meeting with the the licensee and with with all our stakeholders. Very frequently to make sure that we see problems are CD the questions are coming up ahead of time and socials up for success we set up a cadence of weekly public meetings for licensing actions. Two years ago and we were probably at a pace of, you know, having close to 10 to 12 licensing actions in house at a time right and so those weekly meetings were really key for us to be able to talk about the issues that were in front of us and talk about the challenges. A lot of free application engagement so those meetings were fantastic to be able to get a feel for what was coming. And frankly, again, it's it's been thanks to those types of communications that be the quality applications come in from Southern have a good enough that a lot of state to complete our views in shorter time so I think it's been just communications communications communication that really allowed us to move at a faster pace and typical. It's clear for me Omar to say that the rest of the issues they have just communicate and you'll fix it all. It's a completely different set of challenges and different, different scale of the working on but I do, I am very proud of the work that we have done at the agency in licensing. I do think there are lots of really good lessons learned so we talked about lessons learned there's lots of positives we can draw from the work we've done in licensing and again help help build our efficiency in that place as we go forward. Okay, Amy. Yeah, if I could just jump off of that I you know the communication has been key but it's been kind of specific and one of the things we did a number of years back was talk. We had the energy to define what we say are high, low and medium complexity Lars. So we knew Zach and I knew, going in what large we thought were high complexity just based on the amount of engineering work involved or the internal turn on creating the arguments and why we needed the license amendment. And so extending that those lessons learned that we have learned internally between our two organizations and opening up that line of communication with the NRC. We are we were communicating hey this one's coming in this licensing action is coming in and we think it's medium complexity because of X, Y and C. It really helped the staff prepared for those pre application meetings so that they had the right folks in the room for for those meetings and then down the road they could plan. Okay, this one is a very high complex law we are most likely going to need an audit of this work, and we would have all that planned in advance before we even submitted the licensing action. And I think that was key, but then also on the other end because, you know, we're nuclear we're always learning we're always trying to get to excellence. We took a lot of feedback from the early days of submitting these licensing actions and really work them through our, our next middle each time we learned we learned something that hey, we expect the staff to ask this question, and so making sure we had it up front in the symbols and I one interesting thing I love data. You can see from our submittals if you look in atoms at the number of our eyes, they really decreased over time as we got better with that communication. So, and as Vic said, just because I like numbers, we actually submitted turn 15 exemptions and alternatives today and we're currently on amendment 188 for unit three and 186 for unit four. I have a question for Vic. Vic, why are many advanced reactors designers not taking advantage of part 52 and instead opting for part 50. Yeah. Great question. Welcome to some of, I think it was Tuesday session on advanced reactors. And heard, I think it was the folks at x energy talking about looking at using part 50. You know, I, my guess again this is a guest because I think we're kind of focused on the back end of construction but if you look at going way back to what it takes to get a certified design and then a COL. I imagine there's some calculations that go back to how much it's going to cost for that level of work so you know we're the RC is developing a part 53 which is going to be a technology neutral framework which I know just about this much about but that might be the future for the smaller reactors. I think part 50 and part 52 are still the standard for a large light water nuclear reactor. So if you're looking at a smaller plant a small modular plant. You know I don't know how that's all going to fit together so it's a fair question. It's probably better directed at those designers were looking at advanced reactors. I think they're taking the totality of the process in the very beginning if you look back at Zach when you start with Zach and Zach initially submitted the DC for Westinghouse we're talking 2000. I'm going to mess up my math or 2002 time frame is when you first applied I think for the DC for if you 1000. So you're looking at a long span between that and where we are now I didn't show those shows going to it. So, let's move on to it for a little bit, and then we might go back when we might come back to licensing. So, Nicole, what preparation was required for complex itack, such as structural reconciliation they asked me itack or lonely items. How has the energy been inspecting itack, and how does that relate to the 103g finding. Thanks so much. Well, first of all, you know complex long lead itack, you know, as you said one of the examples is the as many safety related systems like reactor cooling system or the passive core cooling system. You know for our inspections we verify that the systems were designed constructed fabricated installed and tested to the required codes and standards for these long lead itacks the energy has been expecting. We've been doing these activities since the beginning of the construction project. And as we're approaching the unit three all itack complete milestone. We actually have relatively minimal inspections remaining compared to the amount of inspections that we've already completed. So to give you understanding of our inspection process for these complex itack. So when in the construction project, the energy perform vendor inspections and observe the initial fabrication and construction in our key AP 1000 components all over the world. A couple examples is we inspected major reactor cooling system components and containment fabrication in Japan, Korea, Italy, we had our inspectors out there at this facilities, performing those inspections. We also inspected safety related key electrical components fabrication in Switzerland. We also went to the widely labs in the United States to observe squibbell testing, and we observed fabrication of modules mechanical skids, as many system piping assemblies at multiple different vendors. And following that the NRC we also perform multiple design specification inspections and the design authority, Westinghouse and Zach was present for, I would say most of those inspections in the corporate office. And this was to verify that the design of these key AP 1000 components system structures would meet the acceptance criteria, and that the design ensure that the most probable transients the most probable occurrences that would occur during normal operation and operational transients would have least radiological risk. And those with extreme situations have the potential for the greatest risk of the least likely to occur. And essentially that's a licensing basis, the their accident analysis that is described in a licensees of being final safety analysis report. And from there the NRC inspection staff we performed installation inspections at the mobile site. We verify that the licensee constructed welded and perform non destructive testing for as the systems in accordance with Appleville code. Other inspection attributes included verified welders qualified construction activities were reviewed and approved by authorized nuclear inspectors as required. And then our final aspects inspections verify that the as well conditions meet the design. And if they don't, how are they reconciled. These inspections, they include pre operational component and system testing like verifying a flow rate, or system function happen this design, or performing components or system system walk downs to verify compliance with seismic equipment and stability and harsh environments, like high pressure temperature moisture, such that the component system would perform its intended function during design basis event. So to better inform and prepare our inspectors for these tests, including startup testing, the NRC, and the Chinese regulator national nuclear security Association, or NNSA participated in an interchanged program that lasted several years and allowed approximately 18 NRC inspectors to travel to China to the same man nuclear power plants and witness firsthand some of these activities. You know, additionally, we were able to engage with Southern nuclear and Western health staff at same man, and that helped us to get an understanding of the differences or the changes that we would see in the US 81,000 plants. So, definitely, as I described it, it was, it's a very complicated, long lead project plan for some of these ITAC. And it's happened over years and so it, as Amy had said, and they could said, one of the most important key lessons learned is to communicate and communicate often. And these other activities like the structural reconciliation, and that is to verify the, the seismic category one class structures like attainment shield building, you know, they didn't have the, the formal structure, the documentation structure like as the code does in the system and vibes. So we met with Zach, and Westinghouse and Southern company years ago to determine what those final documents would look like so all of these things are planned in advance so. So a lessons learned is for complicated long lead activities, whether it's non ITAC or ITAC, it's very important to understand what the end product looks like so that you can plan and be prepared for those those complicated issues. Next someone. Thank you, Nicole. So this question is for Zach. So do you have any lessons learned about the easiness of doing sped ITACs, ITAC. Yes, yeah. So I would just maybe leverage a little bit off of Nicole's response. She was talking about the lessons learned related to the, the planning activities I think for us, one of the key lessons in terms of inspectability for that. I think one of those long lead type ITAC or the ITAC we were having to perform very early in the project was we had an, I would say an area of struggle where Westinghouse did not necessarily appreciate what a targeted ITAC meant. You know, we would have activities such as EQ, or, or ASME, and, you know, the NRC had identified those to be inspected. But those activities, for example, were already complete. So, you know, for us, you know, us thinking okay targeted ITAC inspection, we will provide them the documentation at the end. And I think one of the lessons there for us was okay when they say targeted, we'll make sure that, you know, they're, we have to plan that out, make sure that they're on site at the vendor at Westinghouse. So the remaining targeted ITACs are on site. So it's not as applicable right now. But when we had first started, it was, I would say, taxing on both Westinghouse and the NRC to make sure that to catch up and identify, okay, how can we satisfy the ITAC and make sure that we had a good understanding of what needs to be completed. So I'd say that was one lesson learned for us. Another would be an area that for inspectability where there's not a BASIS document for an ITAC, like what you would have for a tech spec. So we really never go back and forth on what tech specs mean because there's a BASIS, there's analyses that they describe exactly what the intention of that tech spec is. There's not for an ITAC. And so I think the lesson is for us was okay for ITAC that because ITAC really just have a very basic statement. They have a design commitment, a test, and then an acceptance criteria. And in some cases that can be taken different ways. So I think clear communication between Westinghouse and Southern and Southern and the NRC on how that ITAC will be completed and the documentation that will be provided is an important part of the inspectability for an ITAC. Another example would be during testing such as hot functional testing where hot functional testing is a very dynamic evolution where a lot of tests are happening. It's a very coordinated event where the site where the plant heats up, tests are performed, and then the plant heats cools back down. So for us, something that we had learned in China that we had applied here in the US was to establish predictive analyses prior to that hot functional testing. That way, when the test is run, Westinghouse can do a quick post test analysis, confirm that the ITAC can be met, and then move on to the next test, and then the ITAC paperwork can be verified later. And then having a good understanding between Westinghouse and Southern, and if it's targeted, the NRC upfront will look at what we plan to do. But I think that's an area that I would say was a success, is having that good plan established, having those predictive analyses already run, that we know that we met the ITAC whenever we did our post test analysis. And we could just move on to the next test and not have any delays. Thank you, Zach. Amy, do you have anything to add? Yeah, I'll just echo Nicole and Zach, you know, having that over communication, especially with the dynamic construction situation, ensuring that the staff inspectors have access to see what they need to see to inspect is critical. And then on the ITAC language itself, verbatim compliance, I'll just say a little less than half of all the licensing actions we submitted were ITAC related. We need to make some sort of change. So that verbatim compliance, I think that's a lesson learned. It was for us, we learned while we went, but also for future applications, making sure that you're very clear on that language so that it can be inspected. And then, you know, as Zach said, there's no, there's no basis documents. So there's certain words that you would think we all understood what they meant. But there's a lack of definition of them. And so I would say that ensuring that those specific words like as built were in your licensing basis and your tier one and your COL could really help a future applicant so that everybody is on the same page with the ITAC. Thank you. The construction is for Zach, and it's a little bit long. So I'm going to go with me here. So the China AP 1000 project, even as a first of a kind plans were finishing about eight years and have already been in operation for a few years. It's actually more than 10 years for the construction of Bogal Units 3 and 4, which have been delayed again and again. From your perspective, what are the reasons for the delays for the Bogal project? Were any lessons learned from the China AP 1000 products used to help the Bogal project? Okay. All right. So I think just as a little bit of background, so there are four AP 1000 plants that are operating safely in China. China uses a part 50 type process where it's kind of like a modified type 50 process where they have a PCR that's required to obtain a construction permit for the AP 1000 that happened in around in the 2009 timeframe. Then they construct and to load fuel they submit in FSAR, a final safety analysis report to the China National Nuclear Safety Administration, the NNSA. And then something that's a little bit different than part 50, they have something called an RFSR, which is a revised safety analysis report, which they submit about a year after initial operation. And the plants, as the commenter makes, the plants have been operating safely in the United States for quite some, or have been operating in China for a few years now and they're performing very well. In terms of a comparison, this really gets to a comparison of a part 50 to a part 52 process. So I don't think that the delays either in China or here in the US were a result of the regulatory process. The regulatory process is robust. It's can can be trying at times, no matter what process you follow, I don't think we're necessarily victims of a part 52 process so I don't necessarily agree with that part of the comment. I think the in terms of lessons learned. Yeah, there were a lot of lessons learned that were brought from the China projects to the US. And some examples were for, you know, we for the, you know, first plant first of the kind testing where the design certification has a subset of tests that were identified as being special, where they were these tests are really there to demonstrate phenomena of the of the plant acting and make sure that the phenomenon of the plant is, is performing as expected. These are tests like natural circulation tests there's the incontainment refueling water storage tank test heat up test, so on and so forth so those tests were run in China. And we were able to demonstrate that the plants were the same build in China is here in the US, and we were able to successfully write license amendment request to take advantages of those tests and show that the performance in the United States will be the same as the performance here, or the performance in China. There's one example, another example or, you know, detailed design changes that are identified since they're, and it's the advantages of standardization where it's standard design they have the same plant. Well same nuclear island in China as they do here their turbine building is a little bit larger, because of the 50 Hertz plant, but you know those those design changes we as they are developed for China they're reviewed for applicability. Good changes to be made the world right into the design for the for the US plans. So, that's a very. So it's an active processes, it's ongoing as the plants are built and constructed there. So, I think I'll pause there if there's more questions later we can address more. Thank you, Zach. We have a question for Amy. Amy regarding documentation of attack. There was a lot of preparation including templates table top and exercise on how to close attack. Still, it seems the closure documentation for the final attack appears to have encountered a significant problem at the last moment. So, what went wrong and what lessons are there for future part 52 applicants. So, we've mentioned that we've been working to quote, as the comments suggest we've been working to close attack, basically since the beginning of the project. So, you know what we see in the ICN submittals are a list of reference to principal closure documents. And at times, these can be a lot of hundreds of documents that go in that are referenced in a single principle closure document. So, for many of the attack that are left. There are significant portions of them that are already completed, but as the comment mentions there's there is documentation that still needs to be completed, and we do hold ourselves to a very high standard. We want to complete this plant and a safe and quality way. And so we've got to get the documentation right. The documentation comes after construction is complete. So, that's, that's where that's where you would see some of why we haven't submitted all the ICNs for mobile three and four at this point in time. Okay, thank you. Let's move on to the next section of construction inspection. We have a question for Nicole. So Nicole with so much construction going on, and with inspection progress being hampered by the pandemic. How can you be sure that NRC has inspected what needs to be inspected to ensure that the plan is being built safely. Thank you all and that's a very good question a very valid question for our inspection group in our program. So, so during the COVID-19 pandemic, our inspection program kept track with Southern nuclear companies, construction activities, and at the same time, we specifically prioritized, you know, our inspections to one focus on the mission critical activities, but also during high transmission times prioritize our inspector safety and the safety of the plant workers that we interface with. During the entire pandemic, this did not change we are residents continue to connect daily with the key plant activities such as the plan of the day, and work activity pre job breeze. We also use both remote and onsite means to implement the construction program with that focus of the nearing 52 one or three G finding. So we conducted inspections remotely when possible but during times of high transmission, we specifically reserve reserve the onsite inspection for those critical must see activities, which included directly observing first of the kind AP 1000 testing and significant test that are typically only performed during once in the lifetime of the plant. So some of the examples that we were onsite that we specifically saw face to face, and observed during our inspections was the unit three reactor vessel and reactor cooling system We saw the unit three functional testing, the containment structural integrity tests and integrated leak rate test for containment for both units three and four. And we also had inspectors onsite to observe installation of safety related items that become inaccessible once construction is complete or when the planet's operating to for example we were onsite observing the rebar installation and concrete placement for the unit four seismic class one structures like containment and shield building. But I will note that, you know, as I, as I discussed in the earlier section about these long lead itech. You know, we have done so many different types of inspections over the years that we have confidence in those activities that we've expected, and when there are non components is identified, then we go and inspect those as well. But again, our inspections are not done with one specific activity but we ensure that this mission mission critical activities are observed. So hopefully that answers your question. Thank you. Thank you Nicole, big. What have you taken from the energy transformation to be a risk informed regulator for the construction inspection program. So, let me jump back because I think Nicole had a good point I want to key off and then I'll answer that question but I, I'm, Nicole you're bringing back some really good memories of good relative memories of early on in the pandemic or discussions about how we keep our people safe and and what was going on at the site and I remember pretty early on I think I think Southern was one of the very first utilities to have a massive testing facility outside the plant. And they were communicating their cases so we were able to make a judgment call as to whether it was safe for our folks so you know, Nicole and we sound like we're the same organization but we obviously don't play discussions and we don't always agree but I remember being incredibly impressed with your side of the house we're just making sure our people were safe but at the same time we're also getting the job done to make sure that we're looking at the activities we need to look at, and and making sure our folks were in harm's way. And as far as transformation goes, Amy, Amy keyed on data earlier on, and I like, I like jumped in my credit notice it but I jumped in my chair which is data because that has been to me. We're in the information age the biggest the biggest ability for us to think differently about how we do what we do we, we developed a construction inspection program. It's been about a decade, with an idea of how construction is going to play out and the first ever part 52 and of course it's not going to be exactly as you design it right it's just this this know we're human so we're going to we're not going to be able to design it perfectly. So being able to look back now at several years of experience and using that data to look at where we can be more efficient. We've seen enough of certain activities when it comes to look at an attack and really, you know, spend our time in the right places has been for me I opened we built a dashboard relatively early on in the vocal project where we just gathered up everything we could I mean it, where we build our our hours, or our folks were with special issues we're using. And that was to me key, just eye opening for us to build around the region to say hey guys, here's what we got data wise you know work we work together to adjust our inspection program. And what are you seeing as inspectors as the key places to go so to me transformation has been just this this use this wonderful use of data to be able to detail our program to be more efficient. We have a question for Nicole. Nicole, can you explain more specifically the remote inspections of itaq versus completion on site. How does remote inspection of itaq work. Okay, thank you Omar. Well essentially as the definition or of the acronym itaq its inspection testing analysis and acceptance criteria. So those all have different functions and abilities to inspect those areas so inspections can be done either on site they can be done remotely, but definitely the, the testing or the acceptance criteria and the analysis is all prime candidates for remote activities and remote inspections because you're, as, as Amy said and as Zach said, some of these documents are thousands of pages. And that's just one document that supports a closure of an itaq. So, you know, there are definitely opportunities to, to do remote inspections. We actually, you know, before the pandemic, there was, when we had big team inspections we would have a one week off site inspection, looking for documentation, and then we would have on site inspections as well so that's no different than we did before the pandemic. To handle the specific inspections that we wanted to do during the pandemic to observe testing or their inspection activity. And we would be very deliberate that we'd send folks on site to see those activities and coordinate with the licensee. When is that specifically going to happen. So there was no compromise to our inspection program, where we missed opportunities. We just did it differently. Thank you Nicole. Amy, from Southern's perspective, can you tell us about the NRC's findings on cable separation. So, we, we take these findings very seriously. We've taken corrective actions in the instances of separation nonconformances. We put measures in place to prevent recurrence going forward, as we complete construction remain focused on safety and quality as our top priorities. Thank you Amy. Now this question is for SAC, SAC from a design authority perspective. What are the key processes you have implemented to ensure the constructed plan aligns with the design and licensing basis. Yeah, well this is a good question. This is probably fair to list my lessons learned this would probably be number one. I think that so I guess a little bit of background when we had initially would Southern receive their design or their construction or their combined operating license in the 2012 timeframe. Within, I would say like one or two months. We started to identify at site there were things being implemented at the field that were not in alignment with the license. So we had, you know, had paused to take a close look. And I think, and at that point we began to implement changes within the Westinghouse within the Westinghouse process to ensure that the design aligns with what's actually constructed in at the constructed plant. So, and we really haven't had significant issues. You know, after those, those big lesson, those big changes were implemented. And so what do we do so what we didn't really have the benefit of any 9607 appendix C at that time because it wasn't written. It was written after our lessons. The, what we, the primary thing is we established a licensing basis review for every document that was developed and you can imagine how many documents that we we create. We perform a licensing basis impact determination to confirm that that document aligns with the, the applicable FSAR so the Vogel FSAR and the in the other licensing documents. And there is we developed a very robust procedure. Qualification program for people that are developing documentation qualification program for people that are identifying nonconformances at site and reviewing those nonconformances and really a culture. We developed to ensuring like what Amy had said earlier verbatim compliance to the license and making sure that we're meeting every word that that is said, we've done other things as well we've done compliance reviews we've taken certain scopes of of work. We've picked. You know the commodities within the plant the pumps tanks, valves etc, and go through their, their specifications their vendor documentation that are sent to the vendors and the vendor sends back to us to confirm that those commodities are within the bounds of the licensing basis. We've also done other reviews instead of picking a commodity we've taken a scope of the, the construction documents on site to check to make sure that they, they're, they're within the bounds of the license. So, what we did in terms of passing the lessons learn when we wrote any I 90607 appendix C in section I think 411 we added. You know, basically a sense, a few senses in there that says hey as during the construction period. You know, you document your basis for no impact of license as you go along. So that was kind of our, our attempt at passing those lessons to others in the industry, and it. I think it's important, you know, to pass those and the other is is really what I said before is the verbatim compliance making sure that that when we wrote the design certification it seemed like a good idea at the time to write, you know, ambiguous statements, like generally, or this is representative. But that was a good idea at the time because we thought oh this is going to give us wiggle room. As we go forward and as it turns out it's really difficult to inspect to to that that type of language and so throughout the construction a lot of the changes that we actually made are not necessarily design changes they are changes to the clarity of the license to very clearly state what we are going to do. There's a lot of detail in there but even with even with that said, it was, you know, loading that license with the variances that that you're that we were going to take. And in some cases getting NRC approval to do that when we're required to was a very important lesson for us to end. You know those that work in Westinghouse on the AP 1000. It's really a culture. That's what you're doing comply with the license. And it's, it's a question that, you know, our group receives a lot of questions every day on that that questioning attitude hey, can I do this can I do that. And, and when necessary we get Amy's team and involved and to make sure that they're comfortable with with those those decisions. Thank you sack and we have one more question for big and Nicole. Okay, sorry. Okay, so with the NRC established a similar branch or office like DC or BPO, during the construction of future SMR projects, small module reactor projects. So Nicole you can you can jump into but I hope so because I think I think the combination of BPO and DCO is has worked well. We are putting a lot of lessons learned together. I'm sure we'll we'll do the environmental scan to see what the future of Nicaragua looks like and put together the right type of organizations that combine the expertise, whether it's itac or whether it's a perfectly based plan with the inspection staff. Again, I think, you know, looking at the success we've had really with the VR do this vocal readiness group which brought together all the different parts of the agency. I think that's, you know, that's just, it's almost a common sense for communications and how we put it together so I think which price still are there and I think we've just gotten a construction application for Kerosin right now. And new scale obviously has their certified design but I'm sure I'm sure our senior managers will be looking very hard with what's the right organizational structure for for when we're ready for for looking at construction aspects and plans. And I can't agree with you more, because, you know, one of the one of the key lessons learned and I know that's the next topic but that the vocal readiness group really was a project as a a fantastic lessons learned from what's far that we were able to not only communicate inspection licensing issues, but we're also looking at, you know, the logistics so to speak or the budget or staffing of all of these different activities so it's, it's a very, it's a very solid structure on how to look at this, those different aspects of an organization program and oversight program. And the, the one note I would say is that, you know, whatever the organization looks like we have in this panel, we have a senior manager nuclear from the NRC, Mr. Lopez, he is our champion for the small monster reactor program so I know that we will get the DCO the division of construction oversight feedback lessons learned into what that project looks like in the future. Thank you very much. Before we move on to the next section this a question here Nicole for you. What would I tech work if the majority of the advanced reactors will be manufactured off site and in start with minimal on site construction. So that's a great question and that goes that models exactly what we did for the AP 1000 that the vendor inspectors, which went to facilities all of the world were key inspection attributes for completing it. So whether it's done on site it's done in a fabrication shop. All of them are verified to have the, the nuclear standards for appropriate quality assurance program, then they're, they're inspected with all the rigor that an onsite inspection would perform as well so it would be the same model. I'm bringing back good memories and before he used to wear ties to wear a polo shirt and hard hat and I remember I was, I got a chance with the vendor inspection staff to travel to Korea we watched the pouring of the ingot you know that piece that just lump of metal that eventually formed the reactor vessel and so we have we have inspectors were able to go all over the world and inspect these vendors are building plants. I do think we will have to think a little differently about other plants I mean it's going to be a different model versus. It's likely to be different model versus these large construction sites onsite so you know I think that's something we're looking at to and I think we'll have to be cognizant of the changing world and how we can best adapt to that. I absolutely agree with you that and we have other types of facilities like the field, many field facilities, you know that we can leverage lessons learned from multiple distance lines, not just construction of reactors or operating reactor distance lines. Okay, one more questions for Nicole. Nicole has the energy consider incorporate incorporating regulatory oversight guidelines to supplement the reactor oversight process significant determination process to help that I to remove it to some of the significant inquiries. Okay. That's, I will, I'm going to phone a friend, Mr big call, because what we do is from both the inspection process and the oversight the program office. We are continuously reviewing our procedures are manual chapters to ensure that they're not only risk informed but when we come across lessons learned that we are absolutely discussing them. We incorporate them real time so we're not waiting for the next project to make changes to our existing program. Anything else you want to add to that. Yeah, I'm sure we'll talk about this little more we talked lessons learned both we are a learning organization that's always looking to get better. Yes, I heard Amy and Zach talking earlier about the compliance versus safety, which I'm down and I think I have an attack war story here. And, you know, I think we're painting a picture of everything being rosy but not everything has worked perfectly. One of my one of my least favorite attack stories was I got a call, Amy went from one of your, your colleagues was working on attacks and hey we have a does not attack this very specific as we've been to test our cumulative tanks of water. And to test them, you need to fill them with nitrogen because the attack very specifically says test them by filling with nitrogen air. Now, that said that, because in when the plants operating they're filled with nitrogen 100% nitrogen. You can use anything you can use any kind of gas it would it would not change the flow which was the acceptance criteria. And the question was, well, can we just use air which actually is 70 some percent nitrogen anyway. And you know it was it was a tough call and legally the language law compliance said now it's got to be nitrogen. We would be a relatively easy license amendment but you're talking about time to do that in a construction environment that just it's not a realistic so I know the folks at Southern had to go find tanks of nitrogen to fill this this accumulator full of nitrogen to comply with the letter of the law for the attack language. And that was a shame to me that was that was okay those lessons that can be learned there what we really should be focusing more on safety versus just the compliance again. The right thing we were, you know, it was the letter of the law was tier one information so it was it was relatively unbendable, but it pointed to, again, certainly if you look forward to writing attack language to be more realistic and just again taking what we've learned from the last years of construction. I think we can make improvements and so along those lines. We think we're always looking to improve our guidelines for your accurate research process for the for the significant determination process so we're always looking to improve and looking for feedback there as well. Okay, thank you big. Let's go to the last section section applying lessons learned to advance reactors and future applications. This question is for Amy. Amy, what should the energy do differently. If when we have another reactor construction project differently. I think we have to look at what we've done. Well, in this, in what we've done for three and four I mean, they, the communication, the VRGs, we've already mentioned those. Those are the key features that we need to keep those communication lines open with the NRC. I know when I first came on the project eight years ago. There were some lines open but maybe they're they're not anything like what we have today that we've we've built and we've added to over time. So I think those would be key features to keep moving forward. We kind of touched along the CROP the inspection process I think there's further opportunity for that our inform that process. And then I think we have more lessons we are going to learn as we come as three and four comes online. The only really focus for me is how is tier one going to affect us as we are operating. So, those would be key things I think lessons learned things and RTC should consider going forward. Anything from usack. I agree with, with Amy I think that a lot of the struggles and towards the beginning of the project they have since been resolved with really good communication. I think that, you know, carrying that and they've been implemented at site so I think the process that that we have now today. And with the, the open lines of communication with the headquarters organization and with region to the onsite inspectors, I think that is what really needs to be taken forward. Thank you. Thank you, Nick and Nicole. What advice would you give your energy colleague who are building a construction inspection program for advanced reactors. Do you want to do a paper boxes first. Go ahead. I just volunteered sorry. Now it's a great question I'm adding everyone's obviously interested in what's going to happen with advanced reactors. I know that some most shams who's a director in Daniel and they're, they are working on what is a pretty fascinating and very interesting framework for for part 53 which is, it just meant to take us forward for advanced reactors. And, you know, from what I've seen from them it's been, again, just just really, really cool work and it's, you know, really, really give it to both was great. I'm focused on both is the best project in the world, but looking forward it's it's pretty interesting stuff and so again you're building a relatively structure that's going to work for many different technologies. You know, I think I'm sure I know for a fact that they've been taking into account all lessons learned from from what we've done in the past. And we always bring together lessons learned for this product as well which you know I'm looking forward to sharing with them and helping helping them develop the program. I think it's a great plug for our lessons aren't because I know that we, we saw our behind the scenes session moderator Jim Gaslovich is leading our effort to put together our lessons are kind of from this stage of part 52. Our goal is once 52 it went to one, once the plan goes online when one of three G, we have the first 50 to one of three G, we're looking at having public meetings and gathering more feedback and really capture and I think the other ones will capture these lessons learned in the last last few years just to get to see to describe what has gone well when we improve and help that feed the future for advanced reactors. Yeah, and then one thing I would add to the next perspective, because I agree with everything that he said is that the, the one definite recommendation is the communication as a Zagney we both said, and having those open direct understanding of your communication styles. Now that's very important to get through. If you want to be efficient and effective getting through some of these complicated issues that that's when you really challenge your communication, and you're working status, because they can get very difficult and so establishing open communications very is a key lessons learned from very beginning. And also having I would recommend a BRG like organization within the NRC, and the benefit of that is you're having key senior managers across the agency that you can leverage and resolve issues in a very timely manner or get the resources to do so. And that was when we restarted that up after once bar. That was a, it really quickly promoted a faster resolution of some of these complicated issues from an inspection standpoint, I would say that you know to continue to have a formal oversight process that allows credibility consistency, you have a defined methodology of how you're doing inspections, you understand what your inspection scope is and when it's complete. And then big picture I would say organizational flexibility and agility, you know with different things happening in the industry with with VC summer when when that situation occurred, and just the different challenges you face you, including you really have to have an organization that can turn on the dime, and still keep safety is number one focus. So those are the recommendations I would, I would have for lessons learned. Thank you. So before we go to the next question big I have a follow up for you. You mentioned that the VP of offices and sponsored in a lessons learned effort for the the vocal project three of the vocal project three and four. How do you plan to engage the public so you can get their input. Thanks Omar, we are planning public meetings. What's kind of nice about the virtual world is it's a lot easier to gather folks all around from all around the world relate to to meet in forums like this so that there is a silver lining from the pandemic it's it's kind of these technologies but I think in everything we do. We are trying to, to get as much feedback from all stakeholders. And so for the lessons learned. Absolutely we will, we will be looking to, to, to, again, engage to engage the public, engage all our stakeholders, and, and, you know, I'd like to hear the criticism I want to hear where we could have done better. And, and, and feed those those lessons are to improve the future because I think we've done great work, but we're humans, and we are a learning organization committed to getting better and learning. So, absolutely, they'll be follow up on lessons learned and I will say one more thing when it comes to communications you know we're not the IRS you can call us you don't get a reported line. If you email us or call us you're getting a person and so if you have questions if you want to follow up if you have things you want to feed us beforehand. You have my email address you have Omar's email address you have Nicole's email address and phone numbers. Reach out to us anytime. Because we do want to hear that we do want to hear as many possible stakeholders. And we do want to engage as many people as possible to get the more the more opinions to get more diversity of thought we get the better we will be in the future. Thank you, we have a question for Zach. Zach, how much did having a reference combined operating license help licensing and construction of logo, or did it, it did not help. It did help the, so the, the, so take, take back in time the. There was a design center working group that was made up of, you know, TV a Southern nuclear scanner. There was Duke, well progress at the time. And they made up a, a group and the ARCola originally was Bella font, it transitioned to vocal, maybe the 2008 timeframe ish. But ultimately what the that group didn't they partnered. There's another organization called new start. And really what they were, they were doing is establishing what a part 52 license would would look like and what those coal applications would look like so. And the reference kind of set the standard set it set, you know, what everyone else followed, and that just contributed to, you know, the standardization of the plant is when all the words in the, in the licensing basis are the same. Then, you know, you have one issue, one solution, one implementation into multiple at multiple plants. So, I think that, you know, that that process what what happened with with new start, and, you know, part of what they were doing was they were closing CLL information items, it's like CLL information items are things that are specified in the DCD requirements to a CLL that need to be closed, and they were developing plans for closure. And some plant plans closure would be hey Westinghouse go do this work. And some, some cases it would be some site specific evaluation. Others it would be ways that could be addressed by a licensee and a, in a standard way in the same. So, I think that that our coal process was helpful in bringing the licenses, moving the ball forward moving the licenses through through that coal application to a to a CLL. Now, obviously there's only one plant being built. But even, even still I still think it was advantage having all those utilities involved, because, frankly, the there was not a part 52 license before there, there wasn't a CLL that had had intended to build and having inputs from different utilities into a standard way of submitting a license I think was a big advantage, because it, you know, established in an industry precedent for for that application that was ultimately approved and is hope, you know, being constructed and will hopefully start soon. Thank you, Zach. So this question is for everybody here so, given the chance to go back in time. What would you do differently. Who wants to start. Don't make me pick. Okay, let's go with Amy. That's a great question. Let me think about it for a minute. I'll go in, you know, I'll be honest, my, my role with odd is licensing, you know, that that's where I think and I think I'd go back to the veredom compliance and what Zach mentioned on how many changes we needed to make and not just ones that required and RC approval but the departures that we made through our own 5059 like process that we had to provide so much clarification in the UFC are to allow for construction to allow for inspectability. I think if I had it to do over again with all the knowledge I have now is to go back to those days, you know, it's, it's easier to do something right, you know, do it once. You know, it's better to do it right once than having to go back and do it again. And so I, that would be the only thing that not the only thing but I think that'd be the major thing that I'd go back and do is look at the, the DCD and do well application from in that light. Zach, did you want to add. Well, I agree with you. I think that the that's good what not to repeat what you said I would also bring up the, I think the implementation of tier two star. You know if I had to go back and do it all over and give someone. You know, tell someone the future I would talk to them about tier two star I don't think that that part of the, the regulation was necessary. I think that we could have done other things in the license. Since that time we've we've implemented, you know, certain criteria, or Southern has implemented certain criteria in their, in their COL to address that, but, you know, if I go back in time then tier two star would be at the top of the list to to either identify those requirements, put them in an ITAC somehow or identify those requirements and say, Hey, this is just like an FSAR, we have to comply with the FSAR, no matter what it's, you know, a two to two tier two star requirement in terms of compliance what's actually put in its final resting You know, we're required to follow that just as much as we are to follow words in the FSAR and you know, we can, the industry has demonstrated the use of 5059 for years safely across the industry, you know, across the industry through the operating plants and you know, you know, I think that, that that was probably a bigger lesson learned that that has been implemented in several of the new, the more recent design certifications where they, they don't have that so I am happy to see that others have been able to take advantage of that lesson. And Zach, at a very, very high level, could you explain what tier two star is for the for the audience that I might not know. Oh, sure. So in a design certification there's two tiers there's tier one which is made up of mostly the ITAC there's some other information. But that anytime you change touch anything in tier one. It requires the NRC's prior approval. The in tier two that's what a traditional operating plants, final safety evaluation report looks like. It, it has the same structure it follows the red guy one point seven zero format. And you know, there's provisions within 5059 that allow you to make the allow utility to make changes without prior NRC approval. Within part 52, however, there is an additional criteria that was added to the design certification rules that information that is bracketed and italicized and has a little star next to it requires NRC approval to change. So that, at a high level that's, that's really it's a information that a traditional operating part 50 plant would be able to make changes to without NRC approval. It's for, you know, for part 52 plants that information requires it. Okay, thank you. Nicole, you want to go next. Sure. The one thing I would note if looking, if I could go back in time is I would look at a possible more flexible inspection program. And I say that because we created from the, from the construction reactor overstate process. So, as I talked about earlier we have many chapters we have inspection procedures, and that framework was outstanding in really looking at types of inspections, so that you had a good broad regulatory breath of inspections that happened over this huge project. In developing those we also made inspection plans that in some times in some cases were very restrictive and didn't allow us the flexibility that we have since incorporated into our program. And I say that because the benefit we had and the force that we were having at the time was the nuclear residences happening, we need to be prepared for multiple new construction projects at different phases. So it was, it was very important to have that kind of rigor and structure. Since we worked through bogals inspection sometimes we found areas that we could make improvement in changes. And so Vic had referenced it earlier in this discussion that we worked with BPO several years ago, and we went and we essentially looked at every single inspection hours we had done in certain areas, functional areas, types of valves, welding companies. And so we were able to go back and say, put some more flexibility into our program, because we did that assessment. So, again, Vic said it perfectly we're, we're learning organization, we're never going to be perfect but we, if we have that mindset to keep looking forward we're not stuck in, in something that's not flexible or agile. But that is the recognition I would make if I was going back in time. Thank you. Vic, what do you have for us. I think one of the things I could change if I go back and I probably wouldn't have great hair from, from, you know, changing it. There are a lot of nuggets today of I think just ideas that talk about the history of how things were developed and Zach when you talked about targeting of ITAC and I still remember early discussions when we were talking about, should we have a public list of targeted ITAC and having to balance that idea of independence and being offering clarity and openness to what we're going to inspect. In every area of those things I'd love to go back to and change but I think along the way we've incorporated all those lessons learned I think we've tried along the way to, to improve along the way so I appreciate the comments on tier two star I know that's been a sore point. Certainly the idea of this compliance versus safety and looking at the language of the ITAC. I'm going to go back and rewrite some of those ITAC I'd love to because I think there's, there's certainly room for improvement in those but having said that I think we've done a, an admirable job again, you know, making the magic happen making safety come through these words that the other humans have to understand so I'm proud what we've done. I know that there are plenty of things we can improve from, and, and looking forward to, to make a better, better safe nuclear industry. Very big. So from, from the conversation this morning. I have heard the following teams, like, for example, communications communication and frequent communication is very important to mature that all the stakeholders are on the same page and to avoid problems down the road. So we heard that when you're developing your design certification your license, your ITAC is very important to make sure that you're very specific and you're clear to avoid confusion down the road because every person has a deep will have a different many interpretations of what you intended to write. So anything before closing anything else that you guys would recommend or give any advice to the people that are trying to put in place new advanced reactors, and we have four minutes. If you were keen for the day for a day what would you change. Let's just say the folks that have joined today. The last day of the rick is usually the tough one that people are like to now from all the speeches so if you're on the call today and you're listening. You are probably way ahead of the game and they're standing on very fair processes and interest in in part 52 anything else so. I thank you for listening certainly today. Again, I would I would welcome or an advice you to to stay engaged to give us a call if you have questions about what you heard today and talk more because I think it's important to keep dialogue going communication is going to be across everything. And we talked a lot about communication. I do want to add about that is it's just it's being deliberate about how you communicate such as a matter of saying I'm going to talk more I'm going to have more meetings gosh no one wants more meetings but it I think we've been very deliberate in structuring. Who we're bringing in how we're bringing folks and making sure we're engaging the public I mean we've had, we've had over in this groups down near the site to make sure we're able to reach the local communities which is critically important for what we do in the community so being deliberate and learning the lessons for it is going to be key. Zach, you know me it's Zach. Sorry. So I don't think that I have any other really lessons learned for for the advanced reactors I think that you know I think that a lot of them are in their, are in their pre application stages at this point, and I think that you know, they're in there still developing their, their technology I would, they're, I would say that there is a lot of, you know, I get a lot of questions on on part 52. And I, I think that, you know, there are balances between part 50 and part 52, the, you get the advantages of the design finality, and you get the advantages of of the standardization, and you get certainty. And those issues in all the issues resolved up front, that's big advantages that downsides is that it can be challenging during construction to make changes to that license because you have a license and so, and as the plant is being constructed, you don't, you're, you don't want the delays and you know, don't want the licensing process to cause cause delays. So, you know, it's really a balance on on what the advanced reactors and on what their strategy is their licensing strategy is going to be. But, and I think that the, the challenge is building a nuclear reactor is, is challenging no matter what no matter what process you follow part 50 part 52 part 53, it's all going to be challenging. There's not a process it's going to make things just easy. So, but I think that, you know, the, some of the key lessons that we talked about today, apply, regardless of what process that we're following. And, you know, I just thank everybody that stuck around at this point for their for their time. And I appreciate sharing sharing with you. Thank you sack. Nicole Amy any last words. Go ahead, Amy. Just real quick, I just, I haven't said it and I almost always say it when I talk to folks. If you look at unit four, we have applied less we learned on unit three right to unit four. And so, as Zach said, standardization. We have two plants next to each other that we're building the same, and we're learning and applying it things just go smoother on unit four. So I think to future applicants that is something you should definitely, you know, look at that, even though part 52 might be difficult at times to construct. Once you apply those lessons, you, you do gain a lot of benefits going forward. Thank you, Nicole. Yes, the only thing I would add is that, you know, today you heard three different independent independent perspectives, we all have our individual roles in this. But I can tell you that from what you heard today that every one of us every position, our number one focus is the safe construction and operation of these nuclear power plants so you know that's, that's the commonality that we have even in our, in our communities. Thanks so much. Well, thank you all of you for your participation and sharing your thoughts about how well of our lessons lessons of implementing the part 52 for bubble three and four. So that's all we have. Thank you very much and have a great day.