 Welcome to the regional session, which will focus on current topics related to NRC's oversight and inspection programs. I'm Annie Caputo, an NRC commissioner, and I'll be moderating today's session. This session is a discussion panel with a question and answer format, so I have some prepared questions that we'll start the discussion with, but I encourage the audience to submit questions throughout using the electronic RIC application. We'll try to get through as many questions and topics as we can in the hour and a half we have planned. For those of you joining virtually, once you have logged on, quote, joined the session, end quote, and there's a tab for the Q&A box where you can input your question. For those of you in the room, you may have scanned the QR code for this session from the displays in the foyer, but if not, please take a moment and scan the QR code displayed on the screen using your device. QR code will drop you to a page specific to this session and will have a tab for Q&A where you can input your question. So let me introduce today's panel. Each of our four regional offices are represented today. From Region 1 Office outside Philadelphia, we have Ray Larson. From Region 2 in Atlanta, we have Laura Dudes. From Region 3 outside of Chicago, we have Jack Geisner. And from Region 4 in Arlington, Texas, we have John Moniger. We also have two executives from licensees joining us today to provide industry perspectives. Kimberly Cook Nelson is the Executive Vice President of Nuclear Operations and Chief Nuclear Officer for Energy Services. And Rick Libra is the Executive Vice President and Chief Nuclear Officer for Southern Nuclear Operating Company. So with that, we'll get started with the first question. The NRC has instituted several risk-informed programs as part of its effort to become a modern risk-informed regulator. One of these programs that our regional offices have the lead in implementing is the Very Low Safety Significance Issue Resolution Program, or VLISR for short. Could each of the regional administrators briefly describe the experiences with that program in their region and how they share these experiences with each other in terms of communicating best practices? And I'd also appreciate any input from our external panelists as well. I think I'll start off. So when we envisioned this program about four years ago, there were two main entry pieces that we looked at. A licensing basis that was complex or ambiguous, and the key part was that the safety significance by our own processes were very low safety significance, i.e., would be green if there was a performance deficiency. And when the reason we did it, we were getting feedback from internal and external stakeholders so that we could focus on more important things. But also, and I try to stress this, sometimes it's forgotten, is our own inspectors were asking for this off-ramp. We trained our inspectors for years to be so detailed, to always get to the right answer, because they're good inspectors, very detail oriented. We wanted to provide a process that gave them the off-ramp. And so now we're four years in, we have 21 VLISRs, every region has at least a couple under their belt. We've done one self-assessment. We've expanded it to do traditional enforcement, other offices are looking to do it. How are we doing? We think we're making progress. And I'd also say we still have some work to do. We're putting a lot of effort on some of these, effort that could be done in other areas. And I believe there is a culture change that still needs to happen to make more progress so that people are okay, so that the inspectors, those front lines inspectors know that I'm supporting them. I have trust in them and that if they use this process, it's going to be okay. And that to me is the accountability that I have. But I think we're making progress and I think we got some work to do. I'll ask other folks to weigh in on that. Okay. Well, thank you, and I agree with Jack. I mean, we've used it, I think, 10 times thus far since its implementation, and I'm not going to get into all the details. One of the things I'm really proud of is, in my role, I've really not had to talk about it. Our inspectors are embracing it as an opportunity, as Jack said, to spend resources on the most important things. And so when they have this ability to document an issue and move on, take their time and put it on something more important, they like to do it. Really proud that we branched out a little bit in 2023 to work with NMSS on a low safety significance issue, having to do with ISPACI or independence, spent fuel storage cast, loading, and possible tornado situations. And the inspector came to me with a briefing and said, you know, I think this is how we're going to do this and use it. They worked it through the program. So I think it's a great tool. I do think we need more education, communication, and support there. But for our licensees, I'd also offer that it's a specific tool, right? Sometimes we're in the middle of an inspection and I might hear, well, is this VLISR? And I heard it from someone this past year talking about a technical specification issue. And I said, well, no, that's not VLISR. So we also need to keep it in its box, right? You know, it's that nebulous licensing basis piece in the FSAR. It's not a tech spec get out of jail thing. So if we all stay, have a common understanding of what it is, what it isn't, and how we can use it, I think it's a tool that will continue to serve us and help us put our resources on the most important things. And I would echo largely what I heard from both Jack and Laura. I think a couple points. It's a process. We heard a lot about the inspectors, but if you look at the actual process, it's really the inspection branch chief that's responsible for that particular inspection and has to make the decision whether or not the issue itself relates to risk, because it's something that falls into the VLISR process from a risk perspective. And secondly, is if we additionally provide additional resources and time and effort to resolve an issue, are we likely to get to an endpoint or a conclusion related to some of these ambiguous situations we may find ourselves in? As Laura mentioned, it's not there to be a substitute where we have a known compliance issue. Those are dealt with separately. But it is there as a tool to help us manage our time and effort and focus so we can continue to provide the right level of oversight on areas that really matter. The one thing that I will note is that we have used it in the region, and also it's helped us in terms of we don't have a backlog or a large number of unresolved items that are awaiting final disposition that in the past we may have spent a long period of time trying to get to an answer. So we have used it, we used it successfully, and it's just important to understand what the tool allows us to do and what it does not allow us to do. So, John Monger from Region 4, and I would just fully agree with everything that's been said. In terms of the numbers, I think it's important to think about the program. To a certain extent, you would hope the numbers in utilization are low. The reason being, plants generally are approaching 35 years. You would hope that the licensing basis is pretty clear after so many years in addition to all the inspections that have occurred through those years. So you would hope that the number of licensing basis issues that aren't clear would be relatively low. In addition to that, you would hope that our staff aren't pursuing issues that aren't significant. So those two combination, those two issues up front would lead you to a belief or a desire for relatively low numbers. With that said, within our Region 4, we didn't have the opportunity this past year to use it. And what's interesting to me, it deals with issues of fitness for duty and materials prohibited on site, alcohol, and there are extracts, flavored extracts used in our cooking. The actual ambiguity in terms of it wasn't as much in terms of the licensees as it was the NRC's guidance out there in various presentations that we have presented over the years. So we're able to effectively use V-LISR for that issue. And what I would say is in that example, the huge aspect of the ambiguity was the NRC's guidance that was out there in conflicting statements out there. Rick? Yeah, thanks. You know, I'd agree that it's great that we're using that process. And I hope that, goodness, my utility isn't the tech-spec example. Great. That would be terrible. There's no one in Region 2. It was an international discussion. Okay. All right. Great. All right. Thanks. My team's out here, so good job with that. What I would say, though, there is a difference between regions, and I'm speaking from my peers on the panel as well, and I think there's opportunity. It's great to hear that you're assessing, like the effectiveness and the use. I know we're going to talk later on about proficiency of the workforce and inspectors, and in my experience, kind of the less proficient, you know, challenged with understanding how to navigate a licensed basis and can lead to an inspector focusing on, perhaps, less significant aspects of the inspection. And, you know, it's important. We got to get it right all the time. However, that takes away, I think, from the focus for those that would add the most value. And I just reinforce that continue to assess, you know, try to really determine why is there differences between the regions? Is there something beyond? Is it a proficiency gap? I'm quite sure that our plants are very similar with respect to some of the ambiguity and some of the issues. We try to learn from that, but I think there's opportunity there. Yeah, I think most of what I would, I will punctuate that, you know, what's been discussed about encouraging use, consistency, and I'll just also punctuate the communication, transparency, and the open dialogues on both sides of the table of whether it comes into play, when it comes into play, if it's being considered and just letting the dialogue play out. Thank you. The NRC recently changed its engineering inspections from a three-year to a four-year cycle and added changing focused inspections starting in 2023. For example, one of the proposed new focused engineering areas that has been mentioned is aging management. This is an interesting choice given the extensive review effort that the NRC puts into approving those programs as part of the licensed renewal efforts that would have occurred in the near past. So what factors do the regions take into account in helping to choose the focused inspection areas for the engineering inspection cycle and how are those areas harmonized with agency efforts holistically? And let's start with the regions. Thank you, Commissioner. The couple items I'd just like to point out relative to the question. First off, there's a discussion about the aging management programs that are developed as part of the licensing basis for a plant to go into the period of extended operations. Those are reviewed extensively by NRC as part of the licensed renewal approval process, but that's separate from what we say age-related degradation that we're doing on a daily basis as we do our engineering inspections to look at basically phenomena that can affect the reliability components, both active and passive. So there is a difference there. More fundamentally, there's a difference between what NR is doing in the review of the aging management programs and what we'll actually look at as part of our inspection program. We do inspect aging management programs as part of our licensed renewal inspections. And what we're really looking for is to see whether or not the commitment the licensing requirements have been developed as to support the period of extended operation, have they been effectively translated into the actual plant operation and maintenance? And so when we've seen cases through our inspection process whereby the aging management programs and requirements haven't been effectively implemented. So it's a difference between, in NR space, they were saying this is what's required to be done to satisfy that the systems continue to perform well from an aging management perspective versus the field inspection, we're saying, hey, here's a case where your aging management program was not implemented effectively. And so we recently had an inspection where as part of the aging management program, LICY had an obligation requirement to look for external surface corrosion on tanks and components. We find one of the most risk important components in this facility had not been inspected as required by the aging management program. So we went and took a look in the field. When we looked at it, we actually found degradation on the tank that is now in a licensee program to assess and to mitigate if necessary. So it's a difference between approval of a licensing basis versus actually verifying whether or not the licensing basis requirements have been effectively translated and implemented at the site. But getting back to the issue of the focused engineering inspections. It is a four-year engineering inspection. It was developed. We got approval from the commission to go from what was previously a triennial inspection to a quadrennial inspection. And in the age-related degradation, I mentioned earlier, we're looking at both active and passive components for a wide range of potential aspects that could impact equipment reliability. We focus on the risk-important components. We're taking consideration not only risk. We look at operational experience. We look at the engineering controls that have been developed to ensure that the component remains healthy, and that would include things like preventive maintenance programs. It could be things like performance monitoring. It could be assessment of the component when it's not fully performing up to its complete design requirements. And so the age-related degradation is an ongoing inspection that we do during the operating cycle of the plant. The aging management programs that were developed as part of the license removal inspection are focusing on the translation of the requirements for the plant to enter extended operation. But relative to the final part of the question, which is, what do we consider when we develop these new focused engineering inspections? Because presumably we'll complete this four-year program and we'll go into develop another area to focus on. They give us assurance that engineering requirements are being properly translated to plant operation. Key thing is that some of these engineering requirements are there to ensure that components will work properly in areas that go beyond what we see during normal operation testing and maintenance. And so we're really kind of focused on that. It's something that's developed between all four regions and NRR. We have a lot of interaction engagement with the public and industry, and coming up with the focused engineering areas. And so it really is a group effort. One other point I'd like to highlight is at the end of this initial four-year engineering assessment, like I say, this is a change from our previous three-year cycle. There was some reduction in terms of engineering inspection oversight, in terms of just total number of hours. We do have a self-assessment that's been mandated as part of the commission's approval of that four-year process. And so we'll complete that at the end of this cycle. And from that, we hope to see what additional learnings we can gather to make the program even more robust. Good job, right? I guess I have a question. So with aging management programs in place that have been approved by NRR, resident inspectors are not doing sampling of the requirements in those aging management programs in the course of their duties? Resident inspectors and occasionally region-based inspectors do have some samples related to aging management programs, specifically to look at what NRR has approved. Is it actually being implemented by the licensing in the field? So it's an implementation effect in this review. My only comment is the group of four have said I'm the least speaker of the group, so I'm trying to hold the forum there. Am I right? Yes. I guess I would just ask our panelists about these. We get a lot of feedback in each region in our regional utility group meetings about the engineering inspections and a rate-covered age-related degradation quite well. I'm thinking about commercial grade dedication, which is another one we're talking about. And in terms of choosing these, I think back, the last commercial grade dedication inspection I did was 1998, and that kind of went away. So I think they're also trying to look at areas where, hey, is this an area that we should look at? But I guess I would offer to see if you all have any perspective about the topics we've chosen. So a couple items. First, I would like to say that I do appreciate the movement of the inspection frequency and the combining of some of the other areas into that inspection. And as we do go forward, we will be looking for more opportunities to combine, reduce duplication, remove hours. Just like we talked about with the VLASER, we all have finite resources that we're dealing with. And we have to make sure that we're spending those resources on what's most important, certainly what's most important for safety. And one of the things I was considering was, as I understand it, there's not industry input into the focus areas as they are chosen. Now, I understand that there's workshops and early engagement as soon as they're picked. And then the engagement starts. And that's very appreciative. But there may be some discussions we could have on the front end of, ultimately, your decision on which you want to come look at. But it may be input like what you just said. Many years ago, we looked at this as we haven't looked at it a while. It may be a good one to think about. So if allowing some industry input on the front end would be appreciated. Yeah, I think the first-time performance of these collective changes, I think there's been some scope that's been challenged from time to time that I understand that's assessed and some changes are made, which is great. But maybe through Kimberly's suggestion that scope could be centered in a way that there wouldn't be so much documentation requests, et cetera, at the front end. And I think that could make your job more efficient, again, focusing on the right areas. I know the regions collaborate in advance to make sure there's alignment region in region, which I think is awesome. So you don't get the one-offs. And then you have to fix that from an assessment standpoint. So that's great. If I could just make a follow-up comment. I think it's a little surprising to hear that there's a view that there's not industry input on the front end. I'll take that back, because that's contrary to what I understood. But regardless, I think the piece you have talked about is regional consistency. And I just want to highlight some of the things that we do at the NRC. Any time we roll out a new inspection procedure. And it's common. I've seen it several different procedures we've rolled up. But typically we'll do some type of training, except we'll evaluate, is there a need for training of the inspectors in this area? There might be something we haven't exercised that muscle memory on. For in the latest case, you mentioned commercial grade dedication. If something we're looking at that we haven't looked at in a long time, we're going to have to go back and evaluate what are the training requirements. They're common across the regions. We'll typically establish cross-regional panels, whereas issues are identified. The regional branch chiefs that are responsible for inspection program implementation, in particular, will have meetings. And they'll include the program office to say, hey, we have an issue here. And then we'll kind of share views on it to make sure that we're kind of being consistent and sharing information. And then more broadly, our division directors are collaborating as we develop new issues and what we're seeing. And also myself, Laura, Jack, and John, we frequently talk. I think it's a minimum of every two weeks, but usually it's almost multiple times a week. And a lot of it is focused on specific issues. Hey, we have this issue here. Have you seen it before? What have you done with it? So we can always be more consistent, perhaps. But I will offer there's a lot that goes on behind the scenes. That's great. Is there a plan? Is there a goal going forward? Like you got a queue of potentials. I'm just kind of wondering the engagement for the going forward effort to create synergies between some of the inspection activities. I'm asked a great question, commissioner, about the resident interface versus a programmatic. Is there a plan? Well, I know one of the things we are doing now, mostly to share resources, is we're sharing resources between regions. And to get the best practices, often one of the better things is, hey, let some folks go to region two to see how they do in this year. So I think that's the first step as far as sharing insights, whether it's best practices or not. We do do things differently somehow, and that normally gets filtered out and say, hey, I hear region two is doing this. Oh, why aren't we doing that? So that's how it normally starts out. That happens at the plants too sometimes. Yes, yeah, I'm sure it does. Sharing the resources does help with that consistency, so that's good. I see your question or your point, Rick. Do you mean, is there a plan going forward for the future inspections to see if there's synergies so that we're not overlapping and using resources to touch things in multiple ways? You mentioned a few cases, and Kimberly, like we are very appreciative of the effort. I'm just wondering if there's a forward-looking strategy to say what's next, what would that look like? Is there a better engagement that we can provide in the industry to suggest areas? I think I'm staring right at the program office right now, and they're vigorously taking notes or thinking about it. And yeah, there is a plan. I think there are some things that we should engage on in that area. We hear in the speeches a lot of discussion about putting all of our resources on the most important things. So one of the challenges that we're working through, and this goes to the engineering inspections, is where things have been centralized, right? If it's a centralized function, do I need to inspect it six times fully at each of the sites or three times? Or is there a hybrid of that? I'm not saying that it's not less for the sake of less, but it should be not more for the sake of the overlap, because there's probably the same three people that are doing commercial grade dedication. And do I bring them to all six plants, or is there an efficiency there? And I know that the program office is working on that, and that you all are engaged, because I think that, and as we go forward choosing additional inspections, that's where I think there's a lot of room for us to find the sweet spot. That was, that sounds great. With a lot of bang for the buck there, for sure. All right, so I have a question that may be about the program office, but since they're not on the panel to defend themselves. So I'm curious, getting back to the development of engineering inspections and document review, et cetera, what's the role when these inspections are being developed and conceived? How does the organization go about looking at safety significance in terms of screening what that scope is? So in terms of the current ones or in terms of the future, well first, NRA and the agency will do an effectiveness review of these procedures. There's the ROP, the reactor oversight process, has an effectiveness review, and these be it the engineering commercial grade inspection or fire protection, they'll be done as part of the effectiveness review. Then there'll be a solicitation across NRA out to the regions, based upon operating experience, based upon risk insights, et cetera, what are the areas that we should potentially pursue? They'll bring the agency together and there'll be some discussions and eventually engage with industry, but it'll be heavily focused on operating experience and risk insights. I don't believe we're in that cycle yet of soliciting topics for the next quadrennial cycle, but yeah. Okay, thank you. All right, a question from the audience. Mr. Libra mentioned inefficiencies. He has seen from less experienced inspectors. However, we've been challenged over the last few years with resident inspector staffing, resulting in sending residents to the sites with very little NRC experience. I've noticed that myself, it seems like we are struggling a little bit more. We're doing I think some impressive work in qualification and speeding qualification, tracking that with data. I know that's been a particular effort in region two, but we are finding ourselves in situations of sort of what I would call just in time delivery with residents. So what other difficulties have you seen related to resident inspector experience and what is NRC doing to recruit, recruit, train and retain resident inspectors? So yeah, I'll take that one. Although I didn't hear the part about you seeing inefficiencies in there. Yeah, I didn't say it. Yep, I was so clear about that. I hope that wasn't... All right, but it's a great question because it's not just an NRC issue, right? This is something that we are all dealing with right now. We have to be intentional. We have to step up to this moment and realize that our staffs are turning over by 20, 30, 40% and in the next few years, it's gonna continue and what are we doing as an industry to make sure not only are we, do we have a pipeline for people to come in? All of the regions are bringing in early career, mid-career, new hires, so we have a mix and we go out, we have some great recruiting. Anyone looking for a job, please see any one of us on the way out. We're happy to talk to you about what a great job the resident inspector role is and there's been a lot of promotion on that. So recruiting, we're working together to do that, looking in some of our historical success places in the military services and others in the shipyards, in Merchant Marine Academy, other others, we're going to universities, we have our NRAN program. So I think that in terms of bringing numbers on, regions have been very successful in the past couple of years statistically and you're seeing that because you all are seeing new people at your sites. Now our challenge is training them to the high quality that we expect and the truth is we just, when 30 years of experience walks out of my door or your door, that's something we're gonna have to deal with and we're gonna have to mitigate it, right? We're not gonna be able to replace 30 for 30, so how do you mitigate it? And we have various programs. When, I know here in region two and I think others are starting to do this as well, when I have a 30 year senior resident who's ready to retire and we have several and we said, hey, how would you like to stick around for a couple of years and train our new cadre of people? And they are loving it and so we do that and what I'm seeing and then we kind of created a little bit of a program and procedures around that and I'm watching Time to Competency for our new people coming on board. We're shrinking that. So that's one strategy. The agency is moving to competency-based qualification which is more of an intentional individual talent development. If Ray and I come to you for a job, we have very different skill sets and so are you gonna qualify us to the same program or are you gonna tailor that program to the needs that will get us to competency? In a more efficient and effective manner. So those are the types of things that we're doing. It's also making sure that it's not just the qualification, it's the mentoring, right? Because folks qualified is not journeymen. Maybe it's the apprentice level. You're qualified to go out and do this job. How do we provide mentors that are going out and helping the inspectors as they're developing their skills? So I think it's a challenge for all of us and there's new magic bullet. I mean, there's probably an IT question a little later that might help us, AI and other things we'll talk about that could help us with the training and qualification but hire the people and then having a really intentional way to train them and qualify them, I think is the answer. Others? So I'll chime in some. So yesterday there was a really good session on the 50-year anniversary of the resident inspection program. Commissioner Wright provided some remarks in addition to five current or former residents. One of the things that's interesting is these challenges in the resident program come about generally every 10 years or so. There's some pretty significant challenges to the program, be it pay, be it forced relocation, be it benefits, et cetera. And so we are currently in one of those cycles. And if you just look three years ago, the staff reported to the commission in an update paper that the resident inspector ranks the level of experience was very high. The level of turnover was exceedingly low. A tradition was exceedingly low. That was just three years ago. However, the staff did point out that there are significant opportunities showing up within the agency. And many inspectors had been expressing interest in promotion opportunities. And they had expected that to change. Well, it changed. And it changed pretty significantly in the past three years. If you look at just region four last year, calendar year, we experienced a 60% turnover in resident ranks, a 60% turnover in senior resident ranks. If you were to look historically, residents staying at the sites four to five years that would have been in 20 to 25%, or if they stayed for the seven-year term, it would be 15%. So 60% is significantly greater than 15 to 25%. So we have a lot of activities underway. To me, one of the most beautiful things is the branch chiefs within region four. Their number one priority is staffing, training, qualification, and development. And they actually have a very close teamwork with our HR representatives within the office of the chief human capital officer. If you look at their ability to recruit and hire, it's less than 100 days because of that close cooperation and collaboration between OChico and our branch chiefs. The agencies run 140 days. So it can be done. It can be done significantly better. In addition to that, Laura mentioned the rehired annuitants. We've had great success with rehired annuitants. One is they can provide coverage, but the other is they're very good in terms of knowledge, management, training, development, qualifications. Our senior staff, the senior project engineers, their number one duty is to focus on these new individuals. With that said, I think we do have many, many new people and it does have an impact on our licensee. And what we've tried to do within our region four is to be very frank and open and transparent with licensees, talking about the potential impact. It would be one thing if those new individuals were coming permanently, but a lot of those individuals were just putting them out for three weeks, six weeks, two months, et cetera. So it has a definite impact on our licensees in terms of access to their systems, et cetera. So yeah, so we do recognize the challenges and I think full throttle is really on the staffing training qualifications and development. With that said, I don't believe the regions will be in a much better place until we the NRC globally address our staffing challenge. A lot of the staff that we've lost from the region have for the good taken senior positions in headquarters. It's wonderful to have that experience come to NRR, to NMSS, to ENSER, to OE, to the EDOs office, et cetera. So we've lost many more people to headquarters, which is, I shouldn't say loss. Individuals have been promoted to senior positions, which is phenomenal for the agency, but it's a large, it's a much greater number than historically. I think in addition to just the NRC, if you look at industry, there's challenges and with advanced reactor is coming along the line. So I think the nation really needs to address STEM in the future, all STEM areas, but in particular nuclear, so yeah. Well, I think this is also certainly evidence of how our workforce planning and the nature of how we go about hiring needs to be more strategic because for these talented and qualified people to rise through the ranks and take various positions in the agency is inevitable, but the nature of how we plan for that and accommodate that and backfill, I think we need to be a lot more strategic. I also think there's probably room for more data-driven efforts here. In my visit to region two, one of the things that the staff showed me was how they are using just data-driven technologies and data analytics to look at the qualification program and to track where people are in the process in an effort to sort of accommodate the scheduling and keep them moving through the process as expeditiously as possible. And I think that's one of those opportunities where we as an agency can really start to embrace the use of technology in these ways. Question for the regional administrators, how has the NRC in general and your region specifically embraced the use of technology in inspection and oversight? And how do you perceive these strategies have impacted the nuclear industry? So I'd like to hear your perceptions on how you think they've impacted the industry and then we'll hear from the industry on what they've seen. So there's kind of two pieces to this. So it's us embracing technology to execute our mission and then impacts. I think some impacts. So I'll talk about the technology and then you guys, you all can help chime in on the impacts. I'm hoping it's a positive because I think the more IT that you're using to execute your inspections, the less paper, the less requests, I know that we learned a lot through the pandemic in our inspections just how to operate in these electronic data systems for requests for information. And so perhaps that's a benefit. But I think and it was brought up in an earlier session about attracting the next generation of nuclear professionals and do I hand them a notebook and a pen and a piece of paper and a drawing and say, go out. And I have to tell you, that's how I did it, right? I would carry all this stuff around the plant with me and then I'd have to get it in and out. But I go on a tour with a senior resident now who's really embracing technology and they've got their tablet and we're in the diesel room and they're pulling up there the PNIDs and then the procedure for how we walk down the diesel and then they're taking pictures. And so we as an agency, one of the things I wanna thank the utilities through the pandemic, one thing we all learned very quickly is the technology that you all provided to our staff helped us continue to focus on our safety mission. But we as an agency need to jump into that and provide tablets. I know one area where we've gotten a lot of efficiency is in the operator licensing exams and doing that all in tablet form and embracing that IT rather than having a three ring binder that you're trying to secure and walk around the plant with having this tablet where you're able to execute that more efficiently. There's so much in the IT world that I think we still need to work on but I see and this kind of dovetails to the previous conversation. I see in the future, right? You're, and we do this now in our own lives but I can picture an inspector, hey Google, I'm standing in front of a Fairbank's Morris diesel. Here's a picture of it and then use it between AI and everything else that we have that this is another way to help our inspectors and help our staff in general get a lot of information quickly to help them complete their job. So I think we're embracing technology. I know right now we're working with the CIO. We're gonna be distributing tablets to all of our staff in the near term or at least those who want them because we are in a bit of a bridge of a generation. I'm not sure everyone wants them. Some people are still comfortable with that but eventually we'll get there. We've got some work going on right now with the Office of Research to try and see if there's some information where we can start an AI platform to begin developing the knowledge management tools and these types of things. So I think there's a lot out there more to be done, impacts to you all. I don't know, I think some of the OL exams are very positive and perhaps the shared reading rooms but. I know from my perspective, anything that the NRC can do to embrace the technologies and apply them can only help us. Whether it's reduction in hours or getting to the right areas very quickly. And I would say that goes both ways. We're looking at digitization and tech enablement in a lot of ways in AI, in applying AI to end the E to the CAP process to monitoring of equipment. Use of technology in drones and robots and all those other remote monitoring, all those other really neat things that are happening out there and how you support us in those endeavors and being open to the things that we can do with that will be helpful. My team knows that I always spout out this. Once I learned about chat GPT and what it could do, I now have this vision of a corrective action program that there's probably very few in all of our years, very few issues that we haven't solved somewhere. And if you put all of that in one thing, you could put our new issue in and it'll write, it'll screen it for you and it'll let you know what reportability might be and it could write a cause analysis for you. And again, all of this to me ends up being that we're not applying resources in the area of administration and we're applying them in the area of safety, what is most safety significant? Monitoring the equipment, knowing what's happening, addressing it in the right ways. So the support both ways is helpful. I'd share a couple of thoughts. One of the questions we were talking about prior to this was around technology and artificial intelligence on some level and corrective action programs is being used at our utilities and several utilities are being expanded. I've been in our industry 40 years. We love documentation left or, you love documentation left and right, right? We love documentation left and right. It's all over the place so it's ripe for the use of technology to sort, sift and make us a lot, I'm talking utilities, a lot more efficient around corrective action processes all the way from the front end to interface with work orders to the back end repeat issues and then being able to deal and be more effective from a reliability and safety standpoint. But I was, did some research with, we're doing research with EPRI right now as an industry. You mentioned NDE technology, right? So you can imagine NDE, you get all this data and there's a ton of it and you're looking at a screen and you're trying to find outliers and there's software that does that for you. Well now AI technology is able to take the equivalent of four miles of NDE data and get it down to like 400 feet where you still can't take the human out of it but you can certainly look at the outliers and be able to effectively use your time to figure out what's that indication that we have? How can we interrogate that? What does it really mean? How does it compare to past results, things like that? And that's gonna make us better. I think that it can help you all as well. There's hundreds of use cases that EPRI using not just nuclear industry but non-nuclear for the uses of AI technologies as a roadmap over the next three years that needs to go out beyond that but I think there's a ton of opportunity just in that not to mention other technologies. I love the direction we were at. I hated the pandemic, that was terrible but what was great about it is it taught all of us including me different ways to do our work. And guess what, I get more job satisfaction, more time with my family, same with my workforce. So I think it can benefit the NRC as well by leveraging as much as possible what happened during that to be effectively used technology. I see the future for us staying connected on AI. I was at an operator licensing exam and one of the things that the crews still struggle with are making tech spec calls during an event. Can you imagine the future where you could have AI produced after the event? It looked at all that stuff and the computer says, hey, you're in this tech spec, this comp action and of course the human makes the final call. I think the future's there. The question I have is how do we work together so that I know your three-year roadmap so that we as a program office can be ahead of that and the region can say, hey, let's stay connected on that versus being informed that you're at this milestone. Yeah, and if English is not your primary language, just to kind of finalize the realm of possibilities. Let's say English is not your primary language. AI technologies now is being used English and another language to interpret technical data delivered to you or me to be able to make the best decision possible and that's being used today. So I'm with you, there's gotta be a way that we can imagine a future that's different and then try to figure out how it leverages that for both of us. So in keeping with this discussion of AI and documentation, we have a question from the audience. What do you think is the key driver for the increase in overall high level of preparation and doc hours being charged by the inspection staff and how could that be affected by the embrace of technology? I'll let you guys answer that one. Yeah. Is that a question for us? No, I thought she was looking at us too, so. I'll start and then look for a lifeline. I think it's a very good question and really boils down to what are the necessary activities we have to complete to give us the ability to go into get the inspection in a prepared manner. So we've identified up front, what is the program? What are the limitations of the program? What are the things that are doing that might go beyond what others are doing? What are they doing that might be going less than what others are doing? And how does it relate back to the overall requirements and what are the risk activities to look at? So tremendous amount of work has to go into the upfront preparation for an inspection. So when we hit the site, we're able to inspect and make best use of the time while we're on site, being mindful of the impact that has on the licensee. A moment ago I think we heard a lot about different technology approaches to do different programs, whether it's ISI, corrective action program, or anything of that nature. I think it behooves us as we look at the inspection program of the future to understand how those technologies are being used, understand what are their limitations, understand where their benefits. And so then we can adjust our inspection footprint, if you will, to leverage some of the work that might be happening. So for example, corrective action program, if the program, this AI algorithm, does an outstanding job of trend analysis and reporting, maybe that's not a focal point for our inspection. Maybe a focal point for inspection has expanded review of conditions to ensure that they're translated accurately into the program or the model that's gonna be used to look at the model. So we need to be nimble looking forward at the inspection program as technology develops. In the moment though, we're still continuing to operate and implement the program we have, which has inspectable samples, and we need to get sufficient amount of information to allow us to do that. Is it too much or too less? We think we generally do pretty good, but I would encourage folks, if you get a document request or something that you believe is unnecessary, doesn't facilitate the effective completion of the inspection program or sample, and you think that may be unwarranted, please communicate back to the regional office, our branch chiefs, they are the first line supervisors who are responsible for implementation of the program. I would encourage you to talk to one of our branch chiefs or division director or give myself a call. I'd be happy to discuss a document request that might appear burdensome, thanks. So maybe I'll add in, so we should easily be able to slice and dice through the data to determine what are the procedures, what are the particular organizations, the individuals, et cetera. So we should be able to explore that issue and come up with a response. With that said, I would not at all be surprised if it isn't a factor of turnover in the staff. If you've had a senior inspector 20, 30 years that has gone to the same site over those 20, 30 years, he knows the programs, the processes, the procedures, he's done the inspection procedure. New individuals, it's gonna take them a lot more time to come up to speed. And it will be a reflection of where we are as an organization. So I wouldn't be at all surprised if there aren't some revelations in there in terms of turnover in NRC staff and the need for those individuals to come up to speed with the licensees, programs, policies, et cetera, so. And based on a chart I saw the other day with the variations in preparation hours for inspections and it wasn't even an overtime. I mean, it was pretty sawtooth. I think a self-assessment is probably a good place to start. And certainly as we go through that, if there's anything we need to do differently and how we present the data, that feedback would be very helpful because whatever we can do to help reduce those hours. Brian. Yeah, I think there's a combination of new people. We have sometimes new team leaders that were trying to train. Sometimes when we go to a utility, the experts say we're doing a vertical slice on service water and then the expert for service water is not available and then you're into somebody that's less experienced. So we've seen both but I believe we both have some ownership and the best way to do it is to communicate, especially with the supervisor, to say, hey, something's not going right. And I've gotten feedback on that. I think it's a good pushback when you say, hey, something doesn't seem to be going. That way we talk to each other and we figure out what it is. And then we can consistently compare our notes across the regions. But if you just think about the point, the original part of the question is, how can AI help, right? How is it gonna, and I think that there is a lot of opportunity there. I agree with you. There's a lot of variation in that area and it is level of experience and various things. But if, and it's not, and everyone gets worried because they said, well, you're just gonna rely on this machine to prep. No, that's not the case. But you are gonna rely. And I think it's a pretty reliable. Think about how many people let their phone take them anywhere today. So I think that you could rely on the machine to do an initial search, right? To get through a pile of data and show you, here's what I think the most important things are. Now you'd validate that in some way. On the other end that you mentioned that we didn't really talk about doc. I mean, I think we have enough in place that doc should be fairly standard now. And if it's not, then that's something that really needs to be looked at. The only time documentation of a report would get incredibly, or more complicated and extend out would be if there's maybe an issue of violation, something that's taking a little longer to write. But I mean, the program office has done a lot to standardize that process. And so that variation should be minimal. I mean, and AI would just help us, you know, you probably wouldn't even have to enter anything to the computer. You just tell it to write your report because you didn't find anything in that particular inspection. So. Well, that would be an incredible savings in person hours, wouldn't it? Well, and I have to think that documentation, you know, for inspectors has got to be one of the least pleasant parts of the job as well. So there's probably some improvement to be had in job satisfaction and engagement by making that simpler and straightforward and streamlined. All right, here's a question from the audience. What is NRC leadership doing to change the culture and hold the staff accountable to being a modern risk informed regulator using the BRIS Smart process and implementing inspection program processes and procedures? I think, I mentioned it when I talked to V. Lisser, it's the change of the culture starts from me. I have to hold myself accountable, demonstrate the behaviors that say, this is what I'm looking for. And if something's not going right, you have to provide honest feedback. But on the back end, you have to build trust with the staff. The staff has to know that in the old days, back when I was an inspector many moons ago and like mid aughts, there was no, failure was not an option. You couldn't have any, there was zero risk. So you were really working detailed every little eyes dotted. What we're saying now is on these very low risk items and items like that, we're gonna move on. The staff has to know that you're gonna have their back and that the buck's gonna stop with me. So I believe it's a leadership function. It's by demonstrating by the behaviors that we have our values and those behaviors. So accountability is here. And if something's not happening, I expect somebody to come to me and say, this is what I'm seeing. Whether it's the utility saying it's not working or an individual staff member. I think that's the model that we need to see. And I believe we're making progress. The v-lister proves that, but it's gonna take time. And I think people wanna see faster results. That's kind of my take. Ray, how are you encouraging that culture change? I think risk is central to everything we do in the inspection program. We use it for sample selection. We use it to decide when we've looked enough in a particular area. And we use it when we decide to document. I apologize. I thought I had it on silence. It's not a blast dial, is it? No, it's not. It said time's up. So we just wanna make sure it wasn't the headquarters operations officer. So we use risk for everything we do. And in particular, the one thing I like to focus on is the whole idea of be risk smart. And I think to be risk smart, you really have to identify what is the risk you're talking about? Is it a reputational risk? Is it a communication risk? Is it a business risk? Is it an operational reactor safety risk? And if you choose the operational reactor safety risk, we have to be able to quantify the issue to some extent to be able to explain what is it that's driving the risk? So one of the things that I look for is that folks, I don't wanna hear necessarily it's low risk, high risk, medium risk. I'd rather hear it's low risk because and here are the assumptions. Here's the methodology we've used. Here's the mitigating and redundant systems that drive risk lower. Or here are the assumptions that if they turn out to be not true, we'll drive risk up. So we use risk. It's a central focus to everything we do. We have three senior reactor analysts that are qualified right now in region one. They're integral to our inspection teams and they help out with sample selection. They help with assessment of potential findings and they also help out with the overall adjudication of anything we might find. So I think risk is a central point of everything we do. We certainly can always do more but I do wanna focus on when I say be risk smart that we all have a common understanding or what are the real drivers to risk? So are you seeing, are you seeing your employees really embrace that approach in using risk information? I think so, at least in the examples and the issues I'm aware of, I do believe that we have a good insight in terms of focusing on the issues that matter and discontinuing efforts on issues that we believe don't matter. I think you both, I agree with a lot of that. I'm gonna be a little glass half full in this conversation about the regions and we've been risk informed since 2020, right? With the ROP and the significance determination process and we can always do better. I'm sure you might have some comments on that and we welcome them. We really do welcome them because this is, we're never done. We're gonna continue as the plants evolve, as technology involves risk, the definition of risk as we see it is gonna change. We have to be in continual communication but I think of everything that we process from our risk informed samples to the number of inspections that we do that get processed and findings that are then issued to the public. So that's a really big basket of stuff that gets processed every year. Now, do we have issues? Yes and hopefully we raise those issues early where we have disagreements about the risk significance or what process we're in. But if you think about the number of those issues versus the big pool of independent safety inspections that are done every single year with the information going on to the public, I do think that that's a success story. That's not saying we're done. We have to continue to stay on it and when issues come up, the one thing we always encourage, I know across the board for all of you is to call us because we want, it's always the one offs that cause, take 90% of the resources. But let's remember that every year we complete baselines at every site and get a tremendous amount of independent safety assessment, which helps us all. So maybe one thing I'll add in there and I fully agree with Jack in terms of needing to lead the way and the remarks with Ray and Laura. So to me, you can bifurcate the various areas. The reactor oversight process fully risk informed and benefits from years and years of PRAs, et cetera. Be risk smart is somewhat- Fully risk informed. Is significantly risk informed. Significantly risk informed. Commencer with a state of art and PRA technology. So then you have be risk smart. So you have the lesser that is related to maybe risk quantification, et cetera. But be risk smart. We can use be risk smart in our administrative processes. Do we decide to do a public outreach meeting? Do we decide to change the resident inspection program? What are the risks in proceeding with that decision and the impact on the agency and the impact on the staff? So the whole reason be risk smart was developed was you don't have these quantifications of core damage frequency for all these other areas. Be risk smart was intended for just internal agency processes. One of the things we did when we reorganized region four a couple of years ago was we looked at our internal meetings. What meetings can be eliminated? In eliminating meetings, you potentially, information flow may not be there as much, but you save hours, you save time. We also looked at our procedures. What internal procedures can be eliminated because they essentially duplicate the agency procedure? So there's very wide areas that are really right for be risk smart across the agency and not for the technology areas, but in the way that this agency operates. Again, we can celebrate the fact that our movement is in a positive direction relative to risk, but I'll just say two things. One is from a leadership standpoint. The awesome thing about being in our industry is hopefully we celebrate the successes and in the same breath we say, and here's the next level of performance. We're not satisfied with that. We wanna get to something greater. I think when I listened to Chairman Hansen's speech on Monday and I listened to the other commissioners, it's a great aspirational message. Trying to translate those aspirations into actions around that next level performance is difficult for me to see. And so the feedback I'd say is like, what is that translation into aspirations and action and progress? We've talked about a couple of examples of self-assessments and it's good, but if you look at cybersecurity, you look at how long it takes to make an EP change and then you look at the risk aspects of it. I just gotta say it's like, we can do better, I think, and we have to do better because we don't have the resources to keep going in circles on some of these risk aspects and I agree RLP made some solid progress, but I think as leaders, we just gotta say, you know what, that's great. Now here's the next thing we're gonna do. Here's how we're gonna get there. This is what it's gonna take to get there and that's where conversations fall short at times. Yeah, I think better is more and better is also timeliness. You know, I know we've had a couple of, or at least one I can think of risk informed initiative coming through for approval and it just took a long time. It was something for a passive component that seemed like it would take less time. So, you know, however, Jack, I think you said it well with the, right, it starts with the leadership, setting the clear expectations, the outcomes we're looking for and then, you know, engaging and empowering our folks to go make that happen and that's a big focus for us in the industry of getting all our folks involved. You know, they feel valued when they get to do that. They get to do these new innovative things and they bring them forward and then what takes so long for them to get the answer squishes them down a little bit. So, timeliness is helpful. I do sense that the feedback loop is important. So, if something that we're doing is not working right, you gotta give us feedback. I know we got a lot of positive feedback on the risk informed completion times, I'm sure internally. You're saying that's like the best thing since sliced bread. So, folks are gonna be giving us feedback. Yeah, I agree totally. But as, you know, part of our industry is okay, great. Now what's next? They can enhance safety, not degrade safety in any fashion that can enhance safety and there are other areas that we can do. So, I have 50, 69 risk informed completion time. There's a ton of examples that are awesome. So, I know one other program out there is called the Right Program, the risk informed process for evaluations. One of the sites within our region four is submitted to amendments using that approach, one this month and one last year. There are areas that are within the licensing basis that are of low safety significance. So, they've used the right process to change tech specs or to change their design. And because it's within this program, the amount of NRC review time, licensing time is supposed to be significantly decreased. So, I know Palo Verde is a site that had success with one and they have a second application and now I'm not sure across the agency the number of ripe applications, but. All right, another question. Two questions that are a bit related. Just given the challenges in workload planning, how is agency leadership trying to adapt to manage that challenge? So, challenges, I'm a little confused about the question workload planning. I mean, we plan our workload every year. I think they're the broader, I'm gonna answer a different question and then, you know, we can iterate on a specific unless you wanna clarify. Well, workload, workforce, I suppose some of this gets into budgeting space, perhaps. Well, yeah, I see, in my mind, the majority of what we do every year, we can predict, right? I mean, there's emergent issues that we have to do. I think that the bigger issue for us is levelizing workload, is cross qualification, is, and that goes to workforce and budgeting. You get a fixed amount, but there's just certain skill sets that I think are more fungible that we're not using and developing as much as we can, also sharing resources across the regions. If I need five of something and you need five of something and you and you just because we need five of something instead of really looking at as the landscape's changing, what do we need and how can we share so that we're, but you want a bench strength there too. So, I mean, I think when I think of workload planning, I think of trying to levelize across any given work year so that I don't have specialty resources that are only engaged at a certain time and I'm able to use them for a broader set of inspections. So there's a related question along the lines of the numbers of hours of inspection hours. It seems the number of inspectors for some inspections are higher and seem high for the nature of the inspection. Are these standard numbers or are they decided as the inspections are scheduled? Oh, they're pretty much out of the inspection procedure. If somebody thinks we're adding additional inspectors, then they should contact the supervisor. Somebody under training would not be charging to the licensee and maybe we need to be more clear. I think that's the other half of it. Yeah, and I think, and we are doing that. We may have somebody in mechanical, somebody in electrical to shadow somebody. For those people, we would not charge to the licensee but they may be there so it may look like the team is big but generally, unless there's some unusual thing where it's a special inspection, the team's makeup is already kind of already decided in the inspection procedure that's been agreed upon. I don't know of any case where we've deviated but if there's that the case, I would just say contact the supervisor to get this information to us. Unless anybody disagrees with that. So, Kimberly, Rick, is there anything you've observed along those lines? I have heard some feedback on expecting to have one or two for a week and ending up with four for three weeks for certain inspections. I didn't ask about that trainee piece though so certainly we need to look into that. But we have, as I understand, given feedback. So if we have it, John, please let me know. So we did receive this question, this topic at a recent executive rug and we took an action item to run it down and we have a rug meeting later this month that will present out the data. So we're going through sample the past three to past five inspections per site within the region. How many staff were budgeted? How many did we send, et cetera? But one of the questions we had up front to our staff, the team leader is, when we go out there, do we say individual A and B, they're in a training, are we clear and explicit on that? The initial feedback was yes. So I'm not sure if it's in there or not. But the data is out there. So we'll run it down and report back out at our rug later this week. But one of the difficulties is many a times a week, we're looking for inspectors to go out on inspections because we don't have the base number of inspectors to go out. We're currently on an engineering inspection now, it's supposed to be five. We only have four individuals out there and we've had to pull in individuals that typically would not go out there. So there are many opportunities, many times across the region, we're asking for additional bodies to support inspections to meet the basic compliments. So it's surprising to think that there's this other set that we're overloaded on unless it's this notion of individuals in training. But the data is out there. We committed to get back to the rug later this week. All right. I swear, this is a question from the audience. I have a friend out there. I swear I didn't ask her to plant this question. But obviously we had discussions about gender equality, gender balance, women in the workforce, what data is there on women in the resident ranks and what are you doing to improve bringing women into the resident ranks? That's a great question. And I was just thinking about it and during the last few sessions I was doing the math and I had, I'm like, I have three senior residents and I have three residents, four residents, three residents, so that's six. And I'm like, that number's too low. And we talk about that, but here's how we have to approach that as we're out hiring. You have to do an all of the above in the pipeline, right? And so you're recruiting from multiple places. You're out at the HBCUs, MSIs, you're going out to SWE and WIN conferences so that when you're bringing in your pool of resident inspector development program individuals, that pool comes from many different sources and you start to bring them in. I mean, it's an important thing to keep focused on. I'm happy with that I can at least say there's, I have the senior residents in the pipeline, but I'd like to see more. And if there's any women in the audience, I had this job a long time ago and it's a really great job, so please consider doing it. Yeah, I would just follow on, I would agree with Laura completely. And also we have a current or projected opening for a senior resident inspector at Hope Creek. So if there's any female residents anywhere in the NRC, you are welcome, please get it hold to me after the meeting. But to answer your question, commissioner, I think we need to do a much better job and it really starts with, in my view, the university engagement. That's where we're likely to find more candidates that may come with diverse backgrounds than some of the more traditional hiring pipelines we do. We might do a service academy, we might do some type of, we'll get some folks who will apply for jobs that are coming out of completing a career in industry so we get folks all throughout the career spectrum, but it really gets into the kind of university engagement to bring in a wide range and diverse group of candidates. That's where I think we could do a much better job, particularly in region one. We don't have, we at least weren't aware of the numbers of minority serving institutions up in region one. They tended, if you look at the NRC's list, they tended to be in the southern portion of the United States. Well, that really didn't service well when we were doing hiring at places that were local to our area. But in addition to hiring more women and more minorities into the region, then that will make them candidates. They'll be in developmental positions to become resident inspectors. I think it's more important too, we also do more targeted recruiting at universities that are located in areas where our plants are. Because sometimes we'll bring folks into the regional office and they'll get settled in King or Prussia and this applies for all categories of employees. But then when I have an opening at a site, say a site up on the southern shores of Lake Ontario, which I believe you're going to the south, then we don't get as many applicants as we would like. But if we can do more targeted recruiting for the universities in those areas, when we offer those jobs and those jobs become available, now I have somebody that wants to take the job because they're going home. So I think it's both enhanced university outreach and being more targeted and strategic in where we do some of that entry-level hiring. Yeah, I agree. We have a lot of work to do. But the universities have a lot of work to do. In fact, Andrea Cook and I, I don't know if she's in the audience. I think we went to a big university that's very highly ranked in nuclear engineering and we had a tour for all the grad, so post-grad, doctorate, post-doctorate, visited 18 different groups, 40 people, not a single woman. And I went to talk to the department chair afterwards. The first question I said is, I notice we didn't see a single woman. And other than that was, they were concerned that was my first question, but I thought it was important. So it was back to discussion we had earlier about, by the time a lot of women are already teenagers, they're already disincentivized to go into the field. I go to the control room. I went to seven control rooms in the last eight months, one woman. I gave license things out to five, oh well, I go to all the operator licensing dinners, two women out of 70. So yes, we need the net bigger, yes, we need to do it. This is a nationwide issue. I think Jennifer Yule said it because I think we're not getting our targets. And the Byron senior residence open too for, in beautiful Illinois. So I'll just offer that a grand golf is also open. Plus there's a 50% relocation bonus to grand golf. So no, in terms, and I fully agree with insights, we're at a meeting with Wolf Creek and is talking to Cleave Reesner and Jamie. And I guess Cleave is part of a NEI working group on human workforce development. And we've expressed interest in being part of that team. Cause realistically, the NRC, the Department of Defense, the Navy, the nuclear industry, advanced reactor, etc. We shouldn't be fighting for the same resources. We should be developing the broad pool within the US. One of the things they had mentioned was individuals in terms of pursuing STEM or not, that decision is, you know, sixth grade, you know, when they're 12 or 13 years old or so. So we do look forward to being part of that working group. And I don't have the number for the resident inspectors. I would offer though, you know, within region four, our, the past four branch chief positions, leadership positions selected for region four have been the best qualified individuals and those individuals were all women in terms of our SES, our senior executive, our senior management ranks, you know, very well represented in terms of minorities, the rotations down to region four. The past several have been individuals from headquarters that just happened to be women interested in region four. So I do also agree that there's quite a bit that we can do and look forward to being part of that group. Yeah, glad to hear you joined that group too. One thing that, you know, pipeline is gonna be key, particularly for the future. And, you know, to really, to expand our slate, we need to expand our scope as well. And similar to, as I've heard and mentioned, you know, it's, the universities are good but getting into the high schools, getting into the middle schools, we've even adopted an elementary school and using that to our advantage to start teaching folks about, you know, energy careers in general and just making folks aware of us and all the different opportunities. And then, you know, when we are recruiting and even from the universities, I think back to when I was an obstrector and trying to get some more diversity and yes, we had some engineers and yes, we had some Navy nukes, but to get some of the diversity, you know, I hired a lawyer that, because she was looking for something new. I hired a pre-vet. I hired a math major, I guess, sort of with the engineer, but, you know, that had to expand the scope of what was possible to get more diversity into the slate. And once you get the diversity into the slate, it'll start coming. There's a lot of work on the front end. And then be personally accountable for mentoring and development of those individuals in your organization who you feel have the potential or has the desire and try to make the connection between their life situation, which can be different at times, especially when you have rural plants. You know, I've got three sites that are relatively rural. Vidalia, Georgia, Dothan, Alabama, you know, great jobs, but the opportunities have to be presented in and you have to have rotational assignments, mentoring assignments, things like that. So you have to take personal accountability for that investment that's gonna yield operators that can be leaders in the future, because that's our strategy is we'd love for folks to go through the control room, understand and operate a plant to be an executive. And our industry has a next program to get to develop executives, executive women. It's been very successful. We got to do a lot more, though. I mean, I think at each of our utilities. I'm gonna speak up just a little bit on my own history because this, you know, this has been such a challenge for such a long time and it's so important to see leadership focus on it and leadership speak about it. I, in my days at Exelon, CEO John Rowe, was constantly trying to improve diversity in the company, but particularly in the nuclear group, because it is tough when you are pulling engineers which are typically male dominated or you are hiring out of the Navy, which is either all male or mostly male. It becomes incredibly hard depending on the pools that you're pulling from. And it was a personal focus for him, which I always respected and much like you all are making your sales pitch here would so often say, I've got this perfectly good nuclear engineer in Washington. I can't get her anywhere close to the nuclear group again. And things haven't, in those pools, changed a lot either. It is still difficult. My undergraduate, when I was an undergraduate, there were five women out of 45 undergraduates. And I don't expect that it's much different now. I talked to a university department chair who's a friend of mine because I have a son who's a white male interested in engineering and so many engineering colleges will focus on encouraging and drawing in women and minorities. Like, does my son even have a chance at this point? And the sad reality that came back to me was even with all of those efforts, they are lucky to hit 25% in that incoming class. And so all of these efforts help, but then once again, you're still in this position where the pool that you're pulling from to try and improve that diversity is small. It's sought after. There's a lot of competition for it. And it's an ongoing challenge that remains many years later. So I do really appreciate all the efforts that you all are engaged on to try and improve having more women making the workforce and the workplace more amenable to women, but it is a challenge to improve diversity. Back to, well, this is an enforcement question. What tools does NRC have to drive consistency and enforcement among the regions? Well, I think fundamentally, when we're in that space, I'm looking over your shoulder commissioner at Dave Pelton. And I mean, when we are going into enforcement, we're having a panel, we have a group of people talking about it, we do look at past precedent. So I think it's as consistent, and what's challenging sometimes is the word consistency and enforcement, so that's a great discussion. But you have to understand the circumstances of the case. Each case is different. We wanna make sure that we're putting the appropriate regulatory footprint on the specific case and the circumstances around it. But to the extent practical, I think that the tools we have is either sharing with one another, going through our enforcement panels, where it's a very collegial way to come to consensus on what the appropriate action is. I agree, I think we are pretty consistent. The Office of Enforcement is in every SERP, every potentially greater than green item the regions talk about in the panels there. The area that I know we've gotten feedback, and it's fair feedback, are on the green, very low safety significance. I've heard there are differences between the regions. Several years ago, we changed what was minor more than minor, and I thought we, I won't say we put a stake in it and ended it, because I think it'll always be a discussion. But I think we're making progress there. I haven't heard, it's a good question, but I think we're long past in the head long direction making great progress on consistency. I'll be interested if you're seeing that or you're not so, body language is the same, maybe you don't agree. Okay. That's fair. It depends. It can get emotionally at times for the staff because if you got to that point, then obviously there was a disagreement early on, right? And so there's a lot of engagement. I think I've learned some lessons along that line. Unfortunately, I would hate to go through that process often, that's for sure. But I think the more experienced you are, the more, I understand it's, to me, it's generally fair, okay? I'm not gonna say that, I don't have a lot of gripes about the process myself. It's transparent into the day. I can have conversations about it. I gain a better understanding about my staff and their ability to interrogate our license basis and how we navigate through it, which is important to me. And from that, it's a benefit, actually. I hate going through it, but having gone through it a couple of times, I think it's a fair process. And I really don't have much to say about it. Same. We've won some and lost some, right? So. Yeah. And I think through all of them, there's been learnings on both sides. I know we've had some of those discussions before too. All right. A question here, it's a fairly recent issue. Well, it's been playing out for a little while, but definitely a robust discussion lately, I think. How does the NRC intend to characterize general licensee violations for the use of Holtec CBS canisters that is consistent with NEI 12-04? Can I try this? But Ray, you're gonna, because nobody wants this, right? I would have sat on my microphone if I could have, but. But. I sat. I would say we don't know yet, all right? We're working through that. And we need, we have more work to do with Office of Enforcement and NMSS to get the final answer on that. And I don't, I don't think. I think short, short term, we are looking at exemptions that folks are submitting and NMSS is looking at those exemptions, working with the regions to draw a conclusion so that they can move the canisters for their campaigns. So short term, I believe we have a licensing solution. Long term, I agree with Laura. I should have sat on my phone too. And I would just clarify, there's really two aspects to this particular issue. The first question is, is there a enforcement, what does enforcement look like for the canisters already loaded, fuels already loaded and the canisters sitting on the pad? That's a past enforcement action that will have to be addressed, as Laura said, we're still working through the process there. The second point is what Jack alluded to, which is what allows a licensee to legally load using this canister with the unapproved design change, that's something that we're pursuing in an amendment process or an exemption process, excuse me, exemption that would allow licensees the ability to load, but that's something specifically it have to be requested and then ultimately approved by the NRC. So I know there's continuing discussions on this and I think it's just another example of an area where I think there's recognized low safety significance and spent a little bit of a theme through this panel around making sure that we're spending our resources in the areas that matter most and even an exemption process, there's enough uncertainty and effort, we have one campaign that we're just gonna move out to next year and wait for hopefully it's all said and done. So as we go through these and consider those things, moving a campaign, not moving a campaign, going through exemptions, it's just a lot of management attention units for something that's very low safety significant. Same here, we had to make a decision to move out of campaign at one of our units as a result and we'll do that and we're doing a cleanup campaign in the pool instead, but there's an impact to all of that, not just space in the pool, but proficiency of the workforce, cash flows from an economic standpoint. It just seems like an incredibly inefficient way to get to where we're at would be, I don't think anybody would conclude anything different and for all of us to have to do exemptions for something like that, it's continuing the inefficiency in my opinion. It's tough to square that with the principles where we should be endeavoring to lend predictability and stability in the nuclear operation and planning process and this has definitely been a challenge in that respect. So with just a minute or two to go, I feel like Rick Kimberley, you've made some comments today, but you haven't talked a lot. I don't know if you're just considering, you're gonna try and skate out of here safely. That's what we thought you were, I know we were. I'd be curious if there is, if you have any observations you'd like to contribute or anything you'd like to add to the discussion that's gone on so far. I'll say I just appreciate the discussion and I know we've been working really hard on open communication, learning from each other, how do we work together to make the processes more efficient, make sure we're all on the same page, make sure we're all working from the same set of information and so I just appreciate the continued relationship there to do that and I know we get a little, even today, like a couple places may be a little contentious, but we're all working toward the same goal and that is recognized and as long as we keep our eye on that end goal, I think we'll get there. Yeah, and that's safety. There is no doubt that it's our intention to do everything we can to maintain and operate our facility safely. And in preparation for this panel, not everybody probably knows it, but there is some preparation that's done. I've learned some things about various processes which is good. For me, I'm a relative and I think I really were relatively new CNOs and we have a different set of responsibilities now and this was a great experience for me. It's not something I want to do every rick, by the way. We had our turn. Yeah, we had our turn. But I think it was really beneficial because it caused me to reflect differently on some of the issues that we're having as an industry because we're speaking also for our peers in preparation for this and the way that you all engaged in this conversation was fantastic and I really appreciate that. Thank you. Well, thank you all for coming. Thank you for all of your remarks today. Thank you for your preparation for today and please give our speakers a round of applause.