 Before beginning the presentations, I want to give some brief context for risk informing as a process. It's using risk information, both qualitative and quantitative, to help focus designs, approaches, and reviews consistent with safety significance. NRC has a long history of conducting probabilistic risk assessments to support its safety mission. It's important to note that it's not a static process. Risk information and risk informing activities will continue to evolve as operational experience and information grows. There's really two aspects to risk informing. One certainly is the development of this risk information and the collection of experience and data to help one understand the risk significance. But the other is, well, what do you do with that information? If you just collect the information and do anything with it, it really wouldn't be risk informing. And so today's presentations where you will be talking to both of these aspects, both the development and the understanding of risk information, as well as, well, how is it implemented, say, for a regulatory agency at the NRC in terms of reaping the benefits of the risk information? Next slide, please. Probabilistic risk studies continue to provide quantitative analysis of dry cast storage. Past studies have shown the resilience of dry cast storage designs to a wide range of potential accidents, including loading operations. All these documented studies were conducted more than 10 years ago. EPRI conducted a study in 2004 for a bolted cask. NRC did a study later, a pilot study that looked at welded canisters. The DSC for the Department of Energy and the Yucca Mountain application did some analysis of storage systems on aging pads. And so there's information out there. But it's also important, as I mentioned, this is not a static process. Information continues to grow. It's important to critically evaluate those initial risk studies, update the assessments with further modeling activities, experience and information. The NRC's Office of Nuclear Regulatory Research is doing just that today. There's a level three PRA that will update some of this earlier risk assessment work that NRC did. Brian Wagner will be talking about this as well as other initiatives to enhance NRC's risk information. Finally, Zeta Martin will be making a presentation that looks at operational risks and the experience she brings to the table in terms of the activities and risks associated with dry cast storage. That's the first part of the element of risk informing. You have to develop and have an experience base. Next slide, please. Next, what are you going to do with that information? It's just as important to how do we fold that into the regulatory process. There's some recent active initiatives at the NRC for risk informing that have been undertaken as pilot programs. First, there was with the assistance of Idaho National Laboratories, a risk tool was developed to assist the development of risk information in dry cast storage amendment reviews. NRC has also conducted a pilot program to use risk insights integrated approach to ensure the information in an amendment is appropriate place in either the license or the final safety analysis report to ensure there's an appropriate and necessary regulatory oversight. It depends on where it is. It gives different flexibilities for the use of that information. These pilot programs have been conducted in cooperation and input certainly from the industry. I would never want to suggest NRC is doing this in isolation. We also conduct public meetings to assist the input from all stakeholders. But there's also another aspect of these initiatives where industry led efforts. NEI submitted a white paper to the NRC on looking at defining spent fuel performance safety margins that provides the industry perspective. On the on the experience with loading and maintenance of dry cast spent nuclear fuel storage and transportation systems with a goal to improve the regulatory framework for licensing these systems. Rod McCollum from NEI, the Nuclear Energy Institute will provide some industry perspectives related to that white paper but also perspectives on these types of initiatives that have occurred since that paper was submitted in 2019. Topical reports are also an example of another approach for risk informing NRC's ever-involving program. Kim M. Zeong will close our presentations with perspectives on the use of risk information in development of topical reports. So you can see today where we're going to talk to both aspects, both development of information and use of that information. Next slide. The panel represents a wide range of perspectives and experience for dry cast storage. I think the discussions today benefit from this wide variety of perspectives with a common goal of ensuring reasonable assurance of adequate protection that benefits both the NRC and all stakeholders. So as a brief introduction, Brian Wagner, as I mentioned, is an NRC employee in the Office of Nuclear Regulatory Research. He's a reliability and risk engineer and specializes in topics related to risk informing spent fuel storage and transportation. Our second speaker will be Rod McCollum, who has been working on regulatory issues at NEI since 1998 but has over 35 years of experience in nuclear engineering, licensing, management, regulatory policy experience. Currently he leads industry efforts to reduce business risks associated with use fuel management, commercial nuclear power plant decommissioning, emergent material degradation issues, and a variety of topics. He brings a lot of experience to the table. Next, Zita Martin, who recently retired as the senior spent fuel program manager for the Tennessee Valley Authority, TVA. As in her role there, she was responsible for developing and ensuring program implementation of TVA spent fuel management strategies. Zita has over 42 years of experience working in the nuclear power industry dealing with all types, aspects of nuclear fuel fabrication and design, fuel and core performance, quality, heat load analysis, and wet and dry storage. And finally, Kim Manziung is the licensing manager for Holtec International. She is responsible for all of Holtec's licensing actions for spent fuel storage and transportation casts, both domestically and internationally. She is responsible for supervising the preparation and engineering change documentation to support client activities and Holtec manufacturing facilities. Kim has over 14 years of experience in the nuclear power industry. And all this wealth of experience and different views brings to the table good discussion we hope will follow. Because it's a benefit that everyone has different perspectives, different viewpoints, bringing that information to the table to risk and form for that common goal of adequate safety is critically important to the NRC. And without further ado, I want to stop my introduction and we'll lead off with our first presenter, Brian Wagner. Thank you. Thanks, Tim. As Tim mentioned, my name is Brian Wagner. I'm a reliability and risk engineer in the Division of Risk Analysis in the Office of Nuclear Research at the NRC Nuclear Regulatory Commission. So today I'm going to talk about, we can go to the next slide. I'm going to talk about some of the challenges and benefits to risk informing dry casks. I'll talk about a little bit of background on risk informing the NRC specifically for the dry cask area. I'll talk about some of the benefits and challenges, as well as some current research that we're doing. Next slide. Okay, background. I'm not going to talk about any of these in detail. I'm just going to kind of give a sampling of some of these documents. The first category is guidance. There's been a number of policy and plans to increase the use of information in the regulatory framework at the NRC. The first one I want to mention is the PRA policy statement that we put out in 1995, which basically says to, it was commissioned direction that the agency should increase the use of risk in all regulatory matters to the extent of practical. We produced a, we call it the RITM document, which is risk informed decision making for nuclear materials and waste applications. And that was guidance to help staff apply a risk informed approach for regulatory decision making. That was back in 2008. And most recently here is new rate 2150, which I don't know the title there, but it's a proposed risk management regulatory framework. And it provides a kind of strategic vision and options for adopting or risk informed regulatory framework. So, you know, we've been looking for opportunities. Sorry, I meant to mention 2150 was not just reactors that try to include kind of all purviews of the NRC, including waste and casks and all those things. There's been a number of opportunities to risk inform dry casks for a while. And, you know, we made some progress in some areas and we're trying to keep moving the ball forward with that. And there's been a number of, I think to mention these briefly, a couple of dry cask risk studies, the first category is transportation. There are two major risk studies for that. The first was performed by the NRC published in 2007, which was new rate 1864. That was considered a pilot dry cask puree to kind of showcase methodology that could be used for potential future dry cask pure is where they performed. And at the same time or on the same time, at pretty good electric power research Institute was also working at dry cask puree. To some degree, they were meant to be complimentary efforts. One with that, a PWR one with the BWR one that did a well to cast one to the bullet cask. So they, you know, they had largely consistent results although they were somewhat different. Additionally performed a number of transportation risk assessments, the BNRC has been doing that every 10 years or so. First one I got there is back in 1977. And then there's been four of them, most recently in 2014. So from just transportation risks to be, you know, acceptably low, the newer studies use some updated methods and calculated lower risks from accidents, although similar doses from regular operation. Okay, I want to talk about some of the benefits to risk informing dry cask reviews, and, and basically it's the same benefits, the same kinds of benefits as risk informing reactors, or anything else for that matter. The, you know, the previous dry cask pure is have generally found the risks to be low. Which is to say, you know, spent fuel is dangerous, and there's a lot of spent fuel in these casks, but if properly managed, the risks can be low. And this raises the possibility that there might be additional margin that we can take advantage of in risk informing. Which means that we can maybe reduce the regulatory burden on some less risk significant aspects and focus on the more risk significant aspects. So we don't really need to focus on the areas with with low risk and also have low uncertainty we can focus on the areas that have high risk or maybe higher uncertainty results. The advantage of pure is is that it's a systematic systematic process, which really creates a framework that you can do a lot of things with you can identify some of the more risk significant aspects, which are maybe areas where you want additional data and additional analysis. You can more easily test the importance of some of your assumptions. Once you have this framework once you've done the math, it's easier to input different assumptions, add failure mechanisms, and see what the results of that would be. And it gives you a framework to evaluate the significance of additional like new failure mechanisms. For example, talk about an example of that later or trying to do that. And so, most of these benefits, you know, the rest of the puree they're not necessarily unique to puree. Some of it is just having a systematic process. Next slide. So there's some challenges to realizing these benefits. These dry casks, pure as I've been done, they, they have a number of limitations in data scope, what types of casts were considered. So you really need to be mindful of those limitations when attempting to use this risk information, you need to make sure that the insights from those studies really apply to the situation that you're looking at. And kind of one example of that is, you know, when you like look at the reactor constant context, there's some components that are just so plentiful in so many reactors and running for so long, that you really just have data you don't, you also don't even models on these things some of these things like, you know, pumps and valves we simply just collect data. So then even some things that would be uncertainties, even some unknown unknowns, just get revealed in the data. So you're thinking of like corrosion and some aging mechanisms where maybe you didn't know that was a failure mechanism but it's just, it's just happened over and over so you just have data on it. Whereas, at least to some degree. Whereas that's less true for casks there's just fewer casks they haven't been around for as long. You load each of them once. So there's definitely some areas and it's not completely unique but there's some areas where you just don't have the same level of data. And you need to be a little more, a little more careful with some of your unknowns and uncertainties. There's, there's some, you know, areas where we don't have as much failure data, or as much analytical data. One example is the behavior of fuel or accident conditions. And some of these very low probability events, there's just not great data in some of those areas and that can be a challenge. The ranking purees tend to use generic analysis or conservative analysis. And that can be that can kind of skew your skew your results, particularly if you have inconsistent conservatism. So you got to be careful with that particularly when you're ranking the, looking at the relative ranking of risks compared to each other, you know you gotta be careful. It's not high but it's moderately conservatively compared to another one. Also a lot of these calculations are, you know, some of them are not necessarily done probabilistically all the way through so you need to be particularly the conservative assumptions you need to be careful of kind of clip edge effects in your success criteria and some of these calculations where, you know, if you're just over the line or just under the line, it, it makes a huge difference if the cask is not breached, you know the risk is, you know, extremely lower zero where it is breached it's at least fractionally much higher than that. So you need to be careful of those sorts of things and really make sure that your assumptions are robust for the situations that you're looking at. Worker protection, this is more of a caution than a challenge really it's, it's just that, you know worker risk is not usually included in purees it's usually just out of scope. And we have to be a little careful about that with casks, because the consequences tend to be a lot lower than we're used to for reactors. There are some cases where like for a drop event the release might happen very quickly and there's often for some of these, some of these processes, a lot of workers almost right next to the cask. So there could be cases where, you know, you calculate the risk offsite, and it can be extremely low, but that doesn't mean that there's not perhaps the significant risk to the workers so we have to, as we do these things you know we need to be careful that we're continuing to correct workers in the process. I don't have a list down here but of course, a challenge is cost, it's not free to risk inform. The risk information, the processes, etc. And that just takes, it takes time it takes effort. And in some cases it's going to be worth that time and effort and in some cases it's not. And of course there's not as much money flying around for dry casks as there is for like reactors so you, you know it's not always going to be feasible to spend 10s of millions of dollars doing analysis. Unless there's really going to be the benefit there. Next slide. Let's talk about some current research. The first one is this level three pure a project, this is a pretty big project. See full scope comprehensive site level three pure a It's perhaps unfortunate naming because it's a level three pure a but what we really mean is it's all pure levels levels one, two and three, which is to say it considers all the way from initially events through a fuel damage through off site release to off site consequences. And it also includes all major major radiological sources at the site. So, a lot of previous pure as they're just initially events for the reactor. So it includes for the reactor at power. This includes low power shutdown includes spent fuel pool and includes dry casks being stored loaded and stored at the reactor. So it's significantly increased scope compared to a lot of previous periods. So we've been working on this for over 10 years now, especially considering that the pre work we did for that. And we have a number of objectives for this project. We want to reflect some technical advantage advances that have occurred since we published new reg 1150, which was I think, all the back in 1990. We've got new scope considerations that mentioned the pools and dry cast storage. And we, we want to get new updated insights out of it. A lot's changed the industry in the last 30 years. And we want to see how that that hashes out in probabilistic risk analysis. And to see, you know, with these new scope considerations, see how the risks compared to each other to agree, you know how the reactors at power compared to a little power compared to that fuel was going to dry cask. Another goal is just to maintain and enhance the pure capability of the staff at the NRC. And to a lesser extent that the various labs and contractors that are helping us with it. So all right, so for the dry cask portion of the level 30 puree model, we, you know, we started with the methods in new rate 1864 the previous dry cask pilot pilot dry cask puree. And we updated the model here is that we thought would benefit from improvements. One example is we want to look at detailed event identification, particularly given that there's less of a knowledge base for dry cask pure is we really want to make sure that we're capturing everything to look at in the first place. So we did a hazard not really an analysis that has up to really try to, you know, do a thorough job of identifying the events and just positioning them in some way, even if it's to be screened. So we did initial analysis for some sequences, particularly rescuing scenarios. We screened some others. So we just wanted to refine that in some areas. We did some additional structural analysis because that was an area that was found to be pretty high risk. Well, one of the higher risks in great 1864 I won't say high risk. But so we really drilled it on that event did some additional structural analysis there. We enhanced and reevaluated the consequence model that that's previously been identified several times as a pretty major sorts of uncertainty for dry casks just, and it's of course important there's at least in principle there's a lot of material that is actually in the cask. So you really want to know how much of that might be able to get out. And that's something we really drilled into a lot more than we had in some previous analyses. So the results were, we found general consistency with some previous drug has pure is somewhat different mix of the contributions to that risk. We, you know, expect this to give insight on what information we have and what additional information we can benefit from. What I mentioned in the benefits of risking for dry casks is having the model and the update analysis really gives us a basis for doing additional analysis sensitivities considering new events. Having model to kind of plug those in into. And the status is we've pretty much finished the technical work. There's a few things that were responding to comments and things but we're largely done. So the report's being reviewed and we're hoping to release a draft publicly later this year. Next slide. The next big thing that we're doing, which I guess isn't purely a research effort, but it's developing the risk tool and job aid. The really, really goal of this is to use risk information to focus licensed reviews on the areas that are going to have higher risk significance rather than the areas that might have some lower risk significance. So we worked with a contractor Idaho National Laboratories, they developed the actual risk tool report, which is publicly available in our agency by document management system under the accession number I've given here. And it consists of two pieces, there's a tree drive diagram, which gives a preliminary estimation of the risks. It's organized by component and is color coded. I'll show a picture of it on the next slide. And then the the rationale document that's, you know, why it was given that risk significance. And this information is pulled from, you know, previous risk studies, safety margin investigations, some safety valuation reports and input from NRC technical reviewers. So the status of this is, I want to additionally there's a job aid that provides instructions for using the risk tool. We've been doing some pilot applications with this, we're reviewing insights from those. And we're continuing discussions about how to integrate this into our processes and how to use this information. Next slide. You know, I understand you're not going to be able to see this really it's just to give you an idea of what the risk tool report looks like. The left is the cover page, the top right is the tree diagram. You can kind of see what the structure looks like it's organizing things by component and color coding the risk significance. And then the bottom right is the rationale so there's just text there. Next slide. Last slide. So yeah, this is an area where we're trying to kind of use some of these insights and models. We're looking at risk informing consideration of chloride induced stretch corrosion cracking CISCC. And there's there's several aspects of this project, only some of it is risk informing it. So we're looking at enhancing the staff's understanding of the technical issues key to successfully managing CISCC. So we want to look at, you know, what parameters are really affecting the growth rates from CISCC. We want to look at mitigation repair methods. And then there's the risk informing piece. This just recently started. So the first step that we're working on now is reviewing existing risk information and what sequences are relevant to CISCC. We want to evaluate based on those results we want to evaluate which risk sequences that exist in current PRAs are relevant to CISCC, which one CISCC might affect. And then depending on how it goes next year, we're planning on doing some probabilistic assessment, not full PRA, not full probabilistic risk assessment but just some probabilistic analysis. To, you know, to see how CISCC might affect these sequences and what the risk looks like. And the point of all this is to have some kind of risk based, yeah risk information to inform what the inspection frequencies are. So that's all I have. Thanks. I believe we have some polling questions that if we could go to them would be useful. And our IDM is risk informed decision making in terms of implementing that at the NRC. Well, I see a strong push for we need to do more. Certainly there isn't anything that it has not done enough. So it's always good to get perspectives and it's, I like the strong support for doing more in terms of risk informed decision making. Okay, if we could go to the next question. This is sort of the same question but directed more at the industry. Next question. Seems like that was similar to both the NRC and industry. Used risk informed. As far as, as far as an official technical process. It's good to see. At least close to 50%. Yes, it's bouncing around. And then a, I believe though, the last polling question at this point, did the risk informed decision making process results in a different outcome than you expected. Okay, and then I think there's one last one, possibly. Yes. Sort of opinion is, is the nuclear industry safer today. Strong views going for yes. Thank you for participating in those polling questions. Always interesting to see other views. With that, let's we'll go to our next presentation, which is Rod McCollum from the Nuclear Energy Institute. I hope everyone can hear me if I can get a thumbs up from one of my other panelists. Okay, had nods work too. And good to see you again Tim I am. I'm out here at the waste management conference in Phoenix, Arizona, where we are having some of the same repository geology discussions that you and I used to have back in the day. And I can I'm pleased to inform you that geologists are still rock stars so. I think that also I want to I want to compliment Brian for shedding some light on the risk tool. We think that is important. We think risk and forming is important in this area, particularly in. And so we're looking forward to seeing more visibility on that look like you had some, some cool screens that you can you can share and explain your decision making processes there so that's probably a good use of technology. I want to warn everybody that this entire presentation is a metaphor. So I will welcome your challenging questions at the end to try to poke holes in the metaphor to work, work on how things fit within the metaphor. The presentation is entitled safety focus not risk informing, and that's with a purpose because improved safety focus is what you get when you successfully risk informed when you risk inform a process so you know that that's why we are doing this. And I will tell you, if maybe as an incentive to stick around to the end of my presentation, I will explain why this is important at the end of the presentation. And I was glad also to hear, Tim, you mentioned experience base being important to risk informing and Brian, you talked about the importance of having enough data. I would, I would suggest that in dry cast storage. Yes, on both accounts. Since 1986 we've accumulated a massive experience base over 36 years we've loaded 3,600 cast that's kind of an interesting coincidence and the numbers there. And we've done so and we've been very safe and we continue to be very safe and now that those cast have been out there a while we continue to innovate and drive safety improvements in our aging management technologies. So, this area is right for risk informing we have data, we have an experience base. So, let's jump into the metaphor if I can have the next slide. So, this is a very crude representation of perhaps an aperture like on a camera. It works differently than a camera. You see the, the three primary things we do to make sure we're safe here. One is regulation. And of course that has to be the circle closest to safety, none of the other circles, neither of the other circles can get inside or on top of regulation, because that would mean we would be doing something less than the regulation so you what that is the minimum level of protection. And then the next level is the licensing basis, we must negotiate our licensing bases and that's what a licensing process is a negotiation. So that not only is it outside of or bigger than it's within the regulation but it's an outside circle so maybe the metaphor falls already but it needs to be more than the regulation. It's both thicker and extends farther out. So, then the third circle is our own licensee controls and procedures. They certainly have to comply with our licensing base and the regulations. They can't get on top of those circles either. The space you see the space you see in between the circles is what I would call margin, and this is the thing we've been and Brian and Tim you alluded to these we've been working on the performance margins. And trying to get as you get more data and your experience based sharpens, you can indeed shrink these margins. The thickness of the outer circles grows as you put more and more things under licensee control. We've not seen a need to change the regulation tendency of our part 72 and part 71 work pretty well in our C reaffirmed recently part 71 in the transportation readiness assessment so we've got a really good regulation. It's a performance based regulation which is why that circle is not as thick as the other two. And but we still have plenty of margin in our licensing bases and in the other things we do. So, again, as as we use our experience base to tighten these circles to bring them closer together to strengthen the outer circles so relying less on just the regulation. And that's how we become safer. That's how we improve our safety focus so the lens on the camera, you're focusing the lens on the camera you're tightening the aperture. And so if we can go further into the metaphor now in the next slide. Or you'll see two things coming up guidance in rulemaking again, you can bring the regulation in tighter with rulemaking but we, we don't suggest doing that and dry storage we like the regulation we have. The guidance both from the NRC and as Brian alluded to from industry at times. We can also bring the circles closer together and I'm not moving the circles physically first of all, I don't want to make you dizzy with my four PowerPoint skills. And second of all, I think this is in the eye of the beholder I'd like you all to be thinking about how you see this space between the circles and and and what we can do to get these circles closer together. And in, in, in making in improving our safety focus and in strengthening the licensee controlled circles. So, going on to the next slide. I think we took a big step with the performance margin tools. We, we've done pilots, we've done parts which is these phenomenal. Risk ranking tools. In other words, we figure out between the experts what's important. And so we have we have really tightened the circles a lot with the performance margin tool. So the risk tool is one of the things that came out of the performance margin effort. The goal of the performance margin effort was to understand what's in these margins to to tighten these circles to, to, you know, not have excess margin which causes us to lose our safety focus or thinking way out to the to the sides of the rings instead of the red prize in the center. You know, again, your safety focus is blurring the camera is going out of focus. So the performance margin tools, if we use them smartly, we can tighten the circles. And the thickness, I would ask you to envision the thickness of the licensee control circle is expanding as we do this big goal of most of the perfusion performance margin efforts was to get more information under licensee control either in the licensing basis expanding the thickness of that circle the protectiveness of that circle or even beyond the licensing basis. And NRC's risk tool goes hand in hand with that, because NRC is now also tailoring its reviews what information do you need to review, based on the research significance based on NRC's understanding of the performance margin which again, after 3,600 casts in 36 years, we do have a very we have the ability to sharpen the focus we have the ability we know what we need to know to tighten the aperture here. So, we look forward to a lot of things on the NRC side, continuing to sharpen our focus to continuing to sharpen the aperture here, so we can be both safer and more efficient. The dry cast storage safety record is really impressive. So it makes it an idea. However, when we were making great progress on the through the margins effort and sharpening our focus on safety and tightening circles. We had, we start to see inspection findings in our eyes that still are not safety significant, hopefully the risk tool addresses the non safety significant our eyes. And I will hear a lute to and quite honestly to the short term operations tornado we have been working on this, it's not safety significant. Everyone in NRC and industry agrees it's not safety significant and RC has repeatedly said is there's no need to delay loading. What the short term tornado issue is is when we load a dry cast, we move from a position that is analyzed for tornado missile impact inside of building typically to another position that is analyzed for tornado missile impacts out on the pad. And as we make that journey with those crawlers and cranes and, you know, putting lids on and all that. We do pass through for short periods of time. In these periods of time configurations where we do not have a tornado missile analysis. The generic issue for industry here and this has been consistent with the way our licensing bases were constructed over the last 36 years is that we don't need a tornado missile impact for every single configuration that we go through that would be a tremendous expenditure of of resources, and it wouldn't lead us to do anything different. Nevertheless, we continue to discuss this issue. There continues to be a lack of agreement and alignment on what really licensing basics mean here. We've been at this for five months, I can tell you I have never seen an issue which is taken up in that period in that kind of a time period, as many management attention units in both NRC and industry as the short term operations tornado. It's not safety significant, but we can't figure out how to this position the issue. That is causing us to widen our aperture and blur our focus on safety. So what do we do about that. Well, in enter the very low safety significance issue resolution process. We're hoping still that we can address the short term tornado operations issue with that we can bring our focus back to the red prize in the center. We can tighten the aperture. We can make these things work better together we can we can capitalize on the margins we now understand. And I think, you know, while we're going through some growing pains using the be lists are process if I'm allowed to use an acronym that convoluted, you know, on the tornado issue. This is something we really need to become proficient on in the world of dry cast storage. Because, again, the, you know, I think Brian said it, how do you see risk informing like reactors. There's actually actually been less risk informed in dry storage where we've had more detailed licensing bases, more detailed. Our eyes when those licensing bases are under review, then reactors, even though we've had these tremendous safety margins all along and we now understand them better. So I would really invite my colleagues at nrc to engage in making dry cast storage, a real area, a test bed, an area of focus where we use this process, and maybe teach the rest of nrc a little bit because, you know, this is important in every and everything we're looking at that our lens be tightly focused on safety and that we not be diverting our resources with issues that are not important to safety. So now I come to the conclusion, and that will explain why this is important. We are living in a very dangerous world right now I don't have to tell you that I actually caught myself on the airplane to Phoenix thinking, well what happens if there's a nuclear war breaking out while I'm up here and my plane has no place to land. And then I told somebody at the conference that and they reminded me all the you don't have to worry about that. The electromagnetic pulse will just cause your plane to fall from the sky. So, okay, one less thing to worry about but in this more dangerous world. And I would tell you that climate change is just as much an existential threat as Vladimir Putin. You know, it's a threat that comes out as slower and I, you saw a lot of data about that thread in the last session if you ran on the changing weather session and kudos to nrc for putting, putting that one together. So, whatever our existential threats are. We have to have energy security to get through them. Energy security has to be achieved without putting more carbon into the atmosphere. So, out here at Phoenix, we've been talking a lot about the fuel cycle issues of advanced reactors. And I was on a panel yesterday here, where we talked about that and there are a lot of challenges, you know, fortunately we've got this experience base with dry cast storage of fuels that are pretty much the same across the board, and very well understood that we really improved the materials in and around the casks as much as we can. And I'm sure Kim you'll continue to innovate to be more competitive, but you know, so so we've gotten to a good place, but we're going to be challenged in the future. I mean, in terms of new fuel types, different types of materials we're going to have to use in these systems. If our aperture is blurry. If we're not tightly focused at these circles are not close together, and if the outer circles are not thick and strong. We're going to struggle. And that's going to have a negative impact on industry's journey towards carbon free energy not only will dry cast storage become difficult when these new fuels come out of the reactors that's kind of far down the line. But public perception will, you know, well, these guys seem to not be able to focus on safety here. People notice that, you know, we're having these discussions in public, and I'm kind of breaking the fourth wall here a little bit. But, you know, we have these discussions in public and we're not aligned on it again and these discussions if they're not on things that are safety problems. Why are we even having them. And the third reason is, and I think this is the most compelling reason why it is important that we really use dry cast storage as an opportunity to hone our risk informing muscles is is because because we have the understanding and the inherent safety of these systems with no moving impacts. We can we can do more. We can use the V Lister process, for example, more than they can in the reactor site we don't need PRAs we can do it simpler. In short dry cast storage, if we continue to sharpen our safety focus to what I would only call as qualitative risk informing I don't think and Brian you said it, we really want to spend tens of millions of dollars doing dry cast PRAs I don't think anybody in this session wants to, unless there's a real PR a fan and you're somewhere I apologize to you that that's that's the case. So, you know, the survival of our planet does rely on carbon free energy and on energy security. And we get that with a whole lot of really cool advanced nuclear technologies, in order for these technologies to be successful in order for them to be economically competitive first of all we can't have the back end. And second of all we have to sharpen our focus tighten our aperture across the industry in every aspect of the reactors and the fuel and the use fuel. So, guys we got a great opportunity here. Let's go and let's do this. I look forward to continuing to work with my colleagues in industry and an RC to drive drive drive risk informing the dry cast storage knowledge base we have. And with that I'll conclude and I guess we're taking questions at the end. So thank you. Thank you Rod for a lot of interesting concepts and challenges to the nrc always appreciate it. We do have a few polling questions also at this point. If we could bring those up, or at least the first one. And do you think the use of engineering analysis is adequately reflected in PRA models. I would say, you know, this is always must probably should be answered in a risk informed way that you can always add more detail, but given the uncertainties. Is there enough to see we have a lot of good risk animals out there that it depends. A lot of it is purpose of the analysis is always a key part of how is it adequate. Interesting. Could we go to the next question. Do you think risk informed decision making for dry cast storage systems would benefit if PRA analysis were updated and the last polling question for at this time. And here it's sort of, where do you think the focus should be in terms of benefiting the most for updating. Certainly all of the above and handling and operational accidents are figuring prominently. That's a good lead into our next speaker and Zeta market Martin will be bringing her years of experience at the Tennessee Valley Authority to in her presentation that looks at operational risks and concerns of handling etc. Zeta. Good morning. Please. So I will set up this presentation with an introduction. I'll walk you through the years with some experiences in part 72 dry cast storage, not used solving issues not using a risk informed process. Walk you through some more recent experiences where risk was taken into account in the solutions and arriving at the solutions and discuss a little bit of where do we go from here's an industry with risk informed decision making. Next slide. So two things my bio tells you. First of all, I'm old. And second of all, I've been, I've seen the storage outside of the industry grows significantly. So with that in mind, while there have been many changes over the span of my career one thing remained constant. The goal is safety and as Tim mentioned earlier, reasonable assurance of adequate protection is the goal. Safety is the main priority has been and always will be both nuclear safety and industrial safety. Utilities have to comply however with the letter of the law, which you're literal compliance I'm sure everybody knows that term. Just the intent, which is safety. So utilities are required to comply with the regulations so durable record is required. And what I mean by that is that we need some guidance something to point to that says this is if you do this you're, you're, you're going to meet the regulations and, and meet the letter of the law. So I'm going to go over compliance sometimes leads to increase industrial risk or increase dose. As you'll see later. Next slide. So I'm briefly going to go through a couple of issues that came up early on in the industry. Initially required burn up measurements were required an initial version of an interim staff guidance to confirm reactor records prior to loading fuel and cast. Burn up is an important parameter for design and loading of cast as it relates to dose and heat loads. However, industry argued on the basis of risk burn up measurements at a dose time and cost without a commensurate benefit to the health and safety of the public due to the accuracy of the already existing and core measurements. However, the end this is where communication comes into play early in part 72 NRC personnel had no part 50 experience, but industry assumed they knew the part 50 part of the operation and what we did to arrive at those burn up measurements. There was we were talking over each other, essentially during a lot of the discussions and, and that is where communication is key and continued open lines of communications between industry and NRC is key. So as the eight rev three in 2012 contains the right solution however took many years for the NRC in the industry to agree and 20 years for adorable record which is the. I guess, in case in in New York, 2215 which wasn't published till mid 2020 so as you can tell it took 20 years to resolve a relatively simple issue, because we weren't really looking at at the risk. Next slide. The issue that that came up. In the early days was Westinghouse top nozzle stress corrosion issue issue was identified in in 2001 at a utility stress corrosion cracking basically affected the handling of a fuel assemblies assemblies then then required modification for handling. The discussion on how these modifications were these modifications would be could be loaded into into cast and ensued. It took many years and many meetings to come to a determination the process to generate a durable record on what that conclusion was. It's initiated in 2010 again you're you're seeing a time span here where things take a long time to resolve the durable record resulted in an it wasn't the NRC letter issued in 2012 with an official risk regulatory issue summary, published in 23rd and late 2013 so again 13 years to resolve a relatively simple issue. The benefit of this was that any I resurrected the regulatory issue resolution protocol though the re-rip process with a lot of success. The, this process has been successfully used for several issues since, and it keeps you focused on gaps and solutions to the problem. Next slide. Another early experience issue was what we call stack up the initial questions by the NRC. So, I guess, you know, we fast forward about 10 years and we get to 2010 with the NRC starts asking questions about stack up. And then officially issues a URI unresolved issue document in in early 2011. The issue began with questions on the analytical methods used for the unrestrained stack up configuration during the loading process. There was an issue of compliance. The initial questions were about analytical methods related. A different analytical method was used in the 5059 evaluation evaluating the part 50 part of the plant and the 7248 evaluation evaluating the dry storage side of the process and obviously the same methods should be used in both. So that's where the compliance issue came in almost six years to resolve a compliance issue for basically the process of stack up which is the transfer casc being on top of the overpack to transfer the canister with the fuel down into the concrete overpack for storage outside the on this fizzy pad. So, as I stated in slide three, a compliance sometimes leads to increase industrial risk and increase dose, meeting the letter of the law versus the intent which the intent is safety. So the issue was resolved loadings performed with physical restraints, caused industrial safety concerns, and increased dose because you had these monstrous restraints that had to be added to make sure that during a seismic event the Casper not tip over when the analysis showed that it would not, but still, because of the compliance issue we were required to do that if we were loading some loadings were canceled or delayed, causing additional problems for the utilities from the problem of you know managing your pool. And again, all these things cost increased dose and and and time and and and planning. So we started out as the compliance issue resulted in the energy prescribing with the analysis should look like so risk. It was generated in in 2015 and describes the seismic analysis details for a stack up configuration. This is a result in a benefit in the sense that the risk provided guidance for the industry, but it took too long to resolve. We're looking at at a pattern here where it takes you know, 10 or or even longer in some cases years to resolve an issue that that really was not a safety issue but more of a compliance issue. Next slide. So fast forward another nine or so years and and we get to the performance margin white paper that that we've discussed already the industry initiated this paper in as a result of the high burn up field demonstration project, which provided, you know, very favorable results in the whole demo, loaded an instrumented cask and measured parameters inside the cast. The results showed large margins heat loads were significantly lower than predicted. So, as, as rod pointed out we, we thought we, you know, needed to take advantage of that, but that margin. We send it to sent the white paper to the NRC. The recommendations in the white paper were a great approach initiated some some of these great approach or at least one one pilot was initiated earlier through the re-rip process. And the other recommend another recommendation was to convene some parts. Those were the phenomena identification and ranking tables. We had four topics initially identified to address and parts. And what the parts do is they rank the items or the characteristics based on the significance and impact to safety. What that results in is that the accuracy of less significant characteristics are less important. Again, it brings risk into the equation. So going a little more detail into the great approach to a great approach pilots were proposed and initiated. So I said earlier one had already been initiated through the re-rip process. And that one was to improve the format and contact of the, of the certificate of compliance and the tech specs of the cast systems. Basically reformat it and reduce the content or, or, or, or try to streamline the certificate and the tech specs. The second pilot, a great approach pilot was, was one that aimed to at alternative licensing strategies. Again, based on the significance of the change you make a small change you add a fuel assembly type or something to that nature. And it may not require a as big of a review or detailed a review as a view, let's say change the heat load or increase the heat load of the systems. So the, although the initial effort was significant here, since we were developing a new process, I believe this will provide large benefits, allowing us to concentrate on important items. As Rod heads, you know, pointed out, this allows for the appropriate level of effort for the cast vendors and faster and RC reviews, depending on the significance of the change so efficiency improvements for both the industry in the next slide. The parts were for four categories were initially identified to perform parts on thermal decay heat, field performance and gross rupture which I'll talk in the next slide. The first meeting of the per teams was in October of 2019. Every led the effort and their reports on on these parts were published in mid 2020. Now you can see where when we incorporate risk, how the time frame has shrugged because we're concentrating not really worried about the insignificant stuff we're concentrating on the, on the important things, and the, the every reports, the parts identify substantial margins and opportunities for regulatory safety and operational benefits using potential alternative fuel performance metrics. So the, the parts identified potential relaxation of specific regulatory limits based on the latest data, the options for use of margins, discussed by the industry, what was also a result of the parts and that it was or should I say as a result of the parts. We, we think that there's other options for the use of margins. The benefit to this is again faster and RC reviews, depending on margin to limit and increased operational flexibility for utilities and the vendors efficiency improvements for both and RC and vendors due to the focus on risk, or the impact again. If you look at this effort relatively short period of time to come to the correct conclusions when we focus on risk. Next slide. So the fourth part was looked at gross rupture. The, the first meeting of the, the intent was to define gross rupture to define what field needs to be placed into individual cans before loading into into cast. If you don't want something that's, that's a falling apart to be placed into into the can because obviously the vendors have to analyze some configuration. So, the term gross rupture was was developed. So the expert team determined that some level of fuel failure can talk can be tolerated and canisters without compromising safety. So developing a new metric for defining gross rupture. As you can see, the new metric was detection of transgender annex in the RCS if you detect transgender annex you have gross rupture. And then you have to look for which assembly has has a gross rupture. The old metric or I say the current metric because I'm not sure that this has been implemented yet is that the cloud defect. It can be no greater than one millimeter so you can see it's a vast improvement based on safety. The PERT report with recommendations was issued in December of 2021 so it took us a year to make this significant determination when we just looked at the risk and the safety of what we were doing. The benefit is that there's significantly fewer assemblies required to be canned basically place it in an individual can before we actually loaded into the canister. There's significant time cost and dose, because it's less work over the fuel less work over the spend fuel pool. Again, pointing out relatively short period of time to come to the correct conclusions when we focus on risk. Next slide. So what, what should we concentrate on when issues arise. We need to ask so what, what is the safety concern. The advantage of my career is in both wet and dry storage is that I look at this as optimizing the cast loadings to benefit the part 50 spend fuel storage side of the house operation in criticality. So when fuel issues arise, and large chunks of fuel of the fuel populations are is not available to load into canisters, or such as the top nozzle stress corrosion cracking issue, or campaigns are delayed because, or canceled, such as with the stack issue. This causes real problems in your plan and in your optimization of what you load it can cause you to have campaigns that are higher and those and they should be because you have to load harder fuel. You know that's just a one example of some of the impacts of these issues. So, the bottom line is that we must focus on items that impact safety. This will ensure the utilities and the NRC attention and resources are not diverted, but rather focused on the right things. The quick resolution of significant issues when you focus is on safety. We have come a long way in my 40 plus years career in the industry and 20 plus years in the dry storage side of the house. But in how we, and I say we the NRC and industry approach issues and come to a resolution. And this is a good thing. There's there's good open lines of communication and discussions and honest and open lines of communication and discussion. And again, this is a good thing. As long as we make decisions based on risk and the safety impact. So, thank you. That's my presentation. Thank you Zeta for some very interesting thoughts and viewpoints for in an historical perspective. Our final presentation is Kim Manzion and will give us some perspectives with respect to industry led topical reports. Thank you. And I'm completely aware of the time here so I'll try and do this efficiently so you can go to the next slide. So I'm going to talk a little bit about topical reports and how whole tech has attempted to use them kind of in the part 72 space they've been used in operating reactors part 50 world before. They have not been used at least not to any great, great lengths in the part 72 world. The idea would be that these topical reports would increase the efficiency of our other licensing actions. When a vendor such as whole tech submits an amendment to our storage license. It's for a specific site that needs it for a specific loading and has a specific time frame. And so this, the approach that we're taking this topical reports is to hopefully move some of the risk informing type issues outside of that amendment process that has a need and has a schedule and allows us to address them fully and then incorporate them into an amendment later. So I'm going to talk about two different topical reports that we've been working on over the past couple of years so you can go to the next slide. The first one we submitted was a thermal topical report so for those of you who are not familiar with spent field storage casts they passively dissipate the heat from stored fuel the underlying concern is to ensure that temperature limits of the fuel and the materials in the rest of the system remain within limits up till now the NRC has reviewed these kind of individualized loading patterns will call them in each COC amendment. Whole tech has been very involved in plant decommissioning and as we were we were supporting some of those plants. We determined that if you looked very specifically at the plants fuel inventory you could come up with a loading plan or two for that site specifically that would allow more optimal loading patterns and that in terms of optimal it's both reduces the time the the defueling time so you can get pool you can get fuel out of the pool quicker as well as even lower dose if you can correctly load the assemblies into certain locations you can use some of the self shielding of older cooler assemblies to help shield the hotter newer assemblies so that so you can get an optimization both in terms of dose to the workers which obviously is a huge benefit as well as speed which is is also good for getting the the fuel out of the pool. We realized very quickly that if we were going to introduce these through license amendments, that would be incredibly burdensome, each site would have its own optimal pattern and to start having to do an amendment for each individual site just seemed a little bit overkill for both us and and for the NRC and kind of defeats the whole purpose of the part 72 general license process which is to have this kind of overarching license that can be implemented at any site. So what we came up with was a generic method to establish allowable heat load patterns so we set out specific acceptance criteria, which are risk informed because they are dealing with specifically the performance of the fuel the performance of the system those acceptance criteria are the underlying criteria that we try to meet right the heat load patterns that we put in the COC we're always intended to meet the same acceptance criteria so it's the same acceptance criteria we've already lose. We've always used, but that now is the end goal, rather than just meeting a heat load pattern. But the calculations to show how you how a site meets those acceptance criteria are left to the licensee probably with the support of the vendor such as whole tech. And so that's what I kind of outlined that this this really focuses on the risk which would be a system component, having a temperature outside what it is rated for what it what it's intended to perform to see you can go to the next slide. So we submitted the Thermal Topical Report in March. And, and this was a huge success, quite frankly because we had a final SCR by September of 2021. That is faster than just about any amendment I've ever been a part of in my nearly 10 years of whole tech so I really credit to the NRC staff for prioritizing this and working with us. It was an approach that was already based on what staff had reviewed in our our generic SR so it wasn't necessarily a significantly new technical details to review, but it still all credit to the staff for working with us we also utilized something that that the staff was calling regulatory audit and what that allowed us to do was have our technical experts sit with the technical reviewers and talk through questions before our eyes were issued. And so that that when we went to respond and we went to provide the technical information that the two sides technical had already talked together knew exactly kind of what everybody was looking for and what we were able to provide. So, want to really give the staff a lot of credit for that kind of review. And then I'll go to the next slide and talk about a few of the challenges we've had now with this topical report. So the way Part 72 works is the only way a site can implement something under a general license is if it is in our COC. And so we have to roll this into a COC amendment, which essentially says, please follow the method in the topical report if you'd like to develop your unloading pattern that simply that is what it says. And it informed us that they expect to roughly 22 month review time of this amendment to incorporate a topical report that they have already reviewed and approved. And so I think we have a few concerns on our side just about is that really an efficient use of everyone's time to spend that money, many months reviewing something that is already technically complete. One of the difficulties that we're kind of running into is is more an implementation process and this kind of aligns with what what data was saying in terms of some of the issues that take us a very long time are these kind of compliance issues and and we need to find a better way to address those, because they aren't safety significant. One of the ones that we keep stumbling on is a is a 7248 and change control provisions part 72 has a description already in it of how to do change control. But with the introduction of the topical report. There have been some struggles with NRC staff in trying to figure out. We're still allowed to use the change control process that's already outlined in part 72. So, so on our end we're really struggling with, I guess why this is a new, a new problem to solve when when maybe we thought it was already solved. So I think there's not a lot of, I think we're struggling with the risk informing on that side in that the technical approach has already been reviewed and approved. So the implementation and the compliance and the change control of it is what is now going to take twice as long as really the technical part. So then I'll go on to the next slide and said we took some of the lessons we learned from the topical report, and then also wanted to roll them into this shielding topical report which kind of has been alluded to earlier and some of the talks. Again, one of the underlying safety functions of the systems is to provide shielding for the fuel that's stored within the current cocs have some very complicated fuel qualification tables. Sometimes it's it's an equation sometimes it's a table but we'll just call them FQTs for convenience and they establish allowable combinations of burn up enrichment and cooling type. Next slide. But again, the underlying criteria that we have here is the dose rates rate. It doesn't particularly matter how what the enrichment of a fuel assembly is, if the dose that it's giving off to either the work or the public is extremely minimal. It's not the combination that I care about it's it's what's what's the actual risk to a worker to the public. And so we developed a topical report that risk informs the process again by focusing on that acceptance criteria the dose rate is the acceptance criteria. We would subject that acceptance criteria to NRC review and then licensees again would have the ability to do the calculation to determine the combination of fuel that meet those criteria. So you can go to the next slide. We submitted this in May of this year as a generic for the whole industry it's not specific to whole tech systems. It's currently under review by NRC. We're hoping the review will be done this year. So the current challenge on this one and and again it kind of goes back to risk informing is that the the RAIs we have gotten and responded to on this ask for a significant level of detail, even beyond in some cases what's already in the f stars and the cocs that and so if we are going to be so overly prescriptive in the methodology and and not allowing any changes right that if the underlying concern is the dose rate. We again at whole tech and I think throughout the industry are struggling with some of the limitations imposed by the questions in this topical report it doesn't give us any sort of flexibility and we might as well just have the field qualification tables in there. And if it's going to be so prescriptive that those combinations can't change regardless of what the dose rate is. So I'll go to the last slide and hopefully I caught us up a little bit on time sorry if I'm talking too quickly. So the topical reports. We've certainly seen a benefit in terms of the risk informed reviews right it has very much allowed us to focus on the underlying safety criteria the temperature limits, the the dose rates which which are the underlying everything that is written in our cocs and f stars, but we haven't yet been able to gain that efficiency and reviews that we were really hoping to gain, implementing a topical report into the coc seems to be an extreme difficulty that we were not really expecting. And then these kind of limitations that that have been put on that seem to go against the principle of focusing on the underlying safety criteria. They've really limit, limited the usefulness of these topical reports. So one of the things that I don't expect an answer, and just throwing this up there today is, is maybe this, maybe topical reports isn't the right way to go. Maybe this is something that we should be doing just as part of our cocs. So maybe, rather than doing a thermal topical report, we, we should have just built into the coc in the first place, if it's going to be a two year review cycle, maybe I should just build it in there in the first place. In the coc define the actual safety metric that we are trying to hit instead of trying to do these surrogates of fuel qualification tables of heat load patterns and and define that just up front in the coc. And this is something that we propose very early on in the thermal topical report discussion and and we sort of got directed. And that's fine in the in the way of the topical report. But maybe it's something that we need to revisit as we look at these kind of the graded approach that's going on in the risk informing, maybe it's something that we need to look at is this kind of focus on the underlying safety criteria something we can just build into the coc. So just the food for thought is as we kind of go forward from someone who spent a lot of time talking about topical reports in the last couple years. And that's the last thing I had on my slide so I think that's it for me thanks. Thank you very much Kim for catching us up to a degree. I apologize for you having to. You talk very fast, but but it was very clear. I guess just maybe able to get to one question but I would like to point to a phrase that former chairman Saviniki used a few years back, and she called it the frustratingly ponderous path pace of the regulatory process. She did not mean it as criticism, as much as a recognition that things move very slowly and deliberately. But I will say that's why risk informing me is an evolving process, heard a lot of good things today. Continued discussion can only benefit that. And I think we all want to be more efficient and with that I know we don't have much time but could we bring up a question or two, and I'm not. At least I have not. I can't see any comments, but here's one. Will the NRC update dry cast story transportation PRA studies using updated melcore modeling to estimate canister to environmental release fractions. Will these updated studies considering aging degradation as a new failure mechanism. And I'll say that probably if Brian if you could take a that comment about updating the Melcore. I'm afraid you're going to say that. Yeah, I don't. The answer is I don't know. We, I mean, I know we're always updating milk or modeling in general, not super involved in the transportation PRA is, you know, it just did just doing one in 2014 so I'm not sure if we're, if we have another one in the pipeline yet. I mean, obviously, the cancer environmental release fractions are an important aspect. And we want to do get the best estimate of those that we can given that the data is available. That's, of course, that's all I've got on that. Thank you Brian yes and certainly in that comment that estimating the release of material from a canister is a very important aspect, and the studies today to have carried with it a number of assumptions. And so it is important to the extent we can update things. Rod, you're have your hand raised. Yes, Tim, and I don't want to comment on Melcore but I do want to go back to your quote of a chairman Saviniki. She was dedicated throughout her term to making the process less ponderous. Yes, we must recognize it's ponderous for a reason, but we also must recognize for nuclear energy to be a competitive way to decarbonize and stabilize our planet that we have to become less ponder it's and I just want to use that as an opportunity to reiterate that dry cast storage is an excellent place to flex our muscles to strengthen our muscles in this regard. I appreciate that. We have another question that we may have a little bit of, well, no we do not. I don't know if we can continue. Can we go a little bit over I don't know if that's possible. There was a question about how the members of the panel see risk insights being applied to the transportation of spent nuclear fuel and high level waste. And I'll go with let's just go around the table. I'll go first. I think it's always useful to look at the risks associated with transportation. There have been some recent risk studies. So estimating the amount of release from a severe accident is one of the more dominant assumptions and parameters. But it is certainly similar to dry cast storage transportation cast have been shown to be very reliable and robust, and it takes a very significant accident to cause any release. So I'll turn to Brian. Yeah, I don't have much to add other than that's something that we've thought about a little bit and might look into doing perhaps in the similar vein of the risk tool. Because yeah, I think some of the same principles apply that we see, you know, kind of, we've seen that there may be some margin there. We've got to be, of course, careful. There might be some places where we can take advantage of some of that margin. Yeah, Tim, I can weigh in on that and I think it goes back to what you said at the beginning about the experience space. We have 1300 shipments of use fuel are conducted in the United States, I believe most of those regulated or many of those in the United States. And if we start shipping to them storage or repository, which I believe we should and the former sooner rather than later, you know, we're going to that experience base is going to grow. And I think it's going to give us what, you know, as that experience base grows, we're going to have more well defined answers to what you said Tim, which is that you're not going to have a significant release. I think that being able to demonstrate that an act on that is important because transportation, a large scale transportation campaign makes railroads nervous. They're not nervous because they think they're dangerous. They know that much other cargo is way more dangerous than spent fuel. But they're nervous because they're, you know, they're thinking well these dedicated trains. They might mess up our efficient commerce and if our regulatory framework for transportation is efficient. I think we were actually reducing the possibilities for, you know, delays and concerns to choke commerce. So I think it's important to our nation's rail commerce that we do learn from the experience base when we start a large scale shipping campaign. Thank you, Rod. And if I could let's go to one more question and then I think it would be appropriate to wrap up I apologize to not getting to all the comments but and are there general findings being seen for long term storage of spent fuel at decommission reactor sites and might these change and what efforts are focused on revisiting these conclusions. Certainly long term storage is a fact of the current situation in the US aging management programs are in place that continue to look for at information to support that the safety relevant structure system and components continue to function as their intended. And so I'm not aware of any information to date coming out of aging management programs that would suggest any of the conclusions from dry cast storage have changed. However, I'm happy to hear any of the other panel members to provide perspectives on that. So aging management is the key and I'll point out that every 40 years and hopefully we're not extending licenses for multiple periods of 40 years at least at the commission sites we might do that in an interim site. But, you know, it is we will have to look at what our aging management programs, which are quite sophisticated and thanks to Kim and her colleagues in the industry. We have the ability to continue to extend our insurance and safety, if we need be through aging management, the technologies we've brought to bear already and I'm thinking decades down the road those technologies will be even more sophisticated. Yes, agreed Rod. I mean that's part of what I speak of risk informing. And that is to evolve both what kinds of programs we have and and and what information what it's telling us, aging management programs 20 years ago weren't there. No one was doing that today they are with just that goal of we want to continue to ensure that safety is maintained. You know, I can't predict the future, clearly, but I think it is appropriate that the information continues to be collected. We continue to analyze it to under better understand what if any issues might arise in the future. I just point out that yes we do have aging management programs and as I mentioned for the CISCC, there's at least one example of where we're looking at how that would affect our peer results and what our peer results tell us about those, those corrosion issues. With that I would just like to end the session today. I very much appreciate the views from all our panel members comments the polling questions and emphasize again that risk informing evolves and I think so at NRC I think we all come to work. We can do better and be it be it more efficient being different focus, whatever and and that's that evolving nature of risk informing. We need to continue to challenge ourselves and to be a better regulator and with that I would like to ask if any of the panel members want to say any concluding remarks themselves, just raise your hand. Okay, my panel members are comfortable with that it possibly as a concluding remark. I really want to appreciate everyone's attendance at this and very much appreciate once again the views that at least cause us at NRC to think harder and think about everything we do. Thank you very much. Thank you Tim.