 Good afternoon everyone go ahead and take your seats and we'll get started here I want to welcome you to this session where we're going to talk about Innovation and advanced reactor construction oversight. My name is Rob Taylor I'm the deputy office director for new reactors at the NRC and I'm joined by an esteemed panel that all introduces They make their presentation. So thank you for coming today and joining us at this session I'm looking forward to a good discussion and we look forward to your insights perspectives and questions as we go So we're going to follow a moderated panel discussion format Following the presentations from our panelists We will have a guided discussion and take questions from the audience with any time remaining So please use the QR code for the session to ask any questions Because if you don't I have a bunch lined up for them and I'd rather get to your questions And make sure that we have plenty of time to ask those So you may submit them at any time. There's no need to wait for the QA portion of the session to begin So as you've heard a major theme for the NRC and the industry is the deployment of SMRs and advanced reactors And in looking at that We have to take a holistic look at all the aspects that are needed to support the transformation needed to deploy these technologies And we recognize that advanced reactors are going to propose new and unique challenges in a number of different areas Including construction oversight So as as we undertake these activities We need to be make sure that they're commensurate with the risk profile of these designs and I ask what inspections are truly necessary For us to implement and ensure that the plants are designed are constructed as design As you'll hear from the panelists We issued a commission paper in June of last year to share our vision for construction oversight for advanced reactors Including the seven key principles that are vital to the effective design and implementation of such a program We're committed to hearing a variety of stakeholder inputs to ensure the program is designed Consistent with these principles today's session is one opportunity We will continue to have public engagement and meetings going forward to seek your input and Insights into a number of key topics that must be identified as we build the program And then we engage the commission with any critical policy issues that we need to undertake So with that and without further ado, I'm going to start to introduce our panelists and they'll start to give their Presentation so to my right is Nicole Kuvert the acting director of the division of construction oversight in region 2 She's responsible for the management of NRC's oversight of construction activities at Vogel 3 and 4 And is now working on the inspection program development for new construction and fuel facilities advanced reactors and non-power production and utilization Facilities I know Nicole for a number of years here And she was instrumental in the agency's activities to oversee the safe Construction of Vogel and ensure it was ready to commence commercial operation to her right is John Greaves He's the chief of the division of operating reactor safety in region one He's responsible for the implementation of the reactor oversight process for three operating large light water reactors in addition to these duties He took on an opportunity and responsibility to help us provide leadership to the NRC team Responsible for the development of the advanced reactor construction oversight program So now I'll turn it over to Nicole and John to start their presentation Thank You Rob and good afternoon everyone The potential I'm sorry the next slide please Okay, thank you The potential future for the advanced reactor construction landscape is projected to be very diverse This diversity includes different reactor and containment designs that may be entirely new designs or may have had limited or no prior commercial applications in the United States I would like to provide a disclaimer that the potential designs that I will discuss have not been licensed and or these designs may be in Some cases conceptual and are subject to change but for the purposes of this discussion It's important to highlight the diversity that is on the horizon and how does the agency consider? This input when developing and implementing construction oversight framework Advanced reactors can be small module reactors micro reactors and include light water and non light water designs But in general these designs are anticipated to be simpler with enhanced safety margin and risk profile and as a result require less safety related structures systems or components or SSC's and as applicable less ITAC which is inspections tests analysis and acceptance criteria Compared with the traditional large light water reactors built in the US in the past Additionally some general design criteria which is listed in appendix a of 10c far part 50 may not be applicable Based upon the proposed licensing and design basis for example a reactor and coolant system May be designed such that a potential accident scenario is not credible One proposed design may not need to consider a loss of coolant accident as a credible event or May not need a containment structure for the purpose of containing fission products Proposed advanced reactors designs may have minimal or not required active safety systems Have minimal or no safety related electrical systems or have minimum or no operator actions needed to mitigate the consequences For an event while still ensuring reactor core safety and public health and safety For example one passive design feature uses natural circulation With no electrical power or active pumps and provides decay heat removal during normal operations and post-accent response These potential designs also foster new reactor fuel types to be used in commercial plants in the US like Triso fuel pellets and molten chloride salt fuels in addition to the standard light water reactor fuel Based upon the pressure and temperature of the normal operating system Standard industry construction codes may be also be different Additionally proposed designs may introduce new initiating events or material interactions like interactions with sodium and Or in water steam or air interactions that may result in unintended reactions All of these examples might be considered as new inspection attributes to incorporate into the construction inspection process programs other items to consider for oversight framework include Wide range of sizes and locations for nuclear reactor sites including co-location with fuel facilities The construction of advanced reactors may include higher uses of modularization Including greater uses of system installation and testing off-site locations like manufacturers Construction strategies may also result in overall shorter construction and operational readiness schedules and last depending on the advanced reactor licensing paths for part 50 52 or 53 licensing requirements dictate what types of information is required for specific licensing actions and as a result applicable design information may differ during different stages of construction times that are used to inform inspection scoping and planning Next slide, please In addition to design and associated margin and risk profiles It is important to consider previous construction projects lessons learned and best practices Some of the oversight framework that the U.N.R.C. has utilized since 2010 are for the AP 1000s reactors licensed under part 52 Watts Bar unit 2 construction under part 50 licensing Non-power production and utilization facilities or n-puffs for shine also under part 50 and fuel cycle facilities under part 70 the NRC construction inspection staff that conducted these inspections for fuel facilities and puffs in reactor construction projects are Working together with the program offices to identify the best practices across the different energy business lines To develop consistent inspection guidance and by taking this approach lessons learned and best practices are leveraged Across the different areas which results in more efficient and effective oversight programs That also benefit in cost savings across the energy Across the agency the industry and the US taxpayers Next slide, please The staff is considering Construction recommendations from both external and internal lessons learned for external lessons learned the NRC is collaboratively working with International regulators along with reviewing lessons learned from international projects Industry working groups and industry stakeholders were appropriate and applicable The staff also leveraged internal lessons learned report performed for the part 52 and construction at Vogel 3 and 4 and VC summer Units 2 and 3 the Watts Bar unit 2 and new reg 1055 These are all publicly available reports and the and the Adams ML numbers are listed on the slides Most recently for the part 52 lessons learned report the staff noted that although the targeted inspections were Successfully implemented in the construction reactor oversight process or CROP For the first of a kind AP 1000 plants in the United States The NRC's process for targeting ITAC and the programmatic requirements for their inspections were found to be too prescriptive and Did not provide for a flexible or user-friendly means to adjust when planned inspections could not be performed due to the changing construction schedules The working group recommended for future oversight programs There should be a flexibility to select a representative sample of inspections throughout any construction area and not require pre-selected ITACs to make up the baseline inspections This would promote more agile inspection coverage while continuing to maintain reasonable assurance The facilities are built and will operate in accordance with their approved designs and licensing basis Next slide, please The NRC is taking a holistic approach to the revisions and the development of the construction oversight framework Where in the past inspection program guidance was written for the specific project occurring at the time Now staff is intentionally considering future oversight processes and inspection scoping that is risk-informed Scalable performance-based and technology neutral that can accommodate different types and sizes of projects Additionally, future oversight processes and inspection scoping needs to be flexible without focusing on inspection planning on Discrete or specific items that can lead to inefficient uses of resources Especially with changing construction schedules. Next slide, please In addition to inspection oversight framework includes enforcement and assessment Lessons learned for the enforcement process for facilities and construction are first Significant determination should appropriately characterize findings Significance based upon risk to future operations and should be comparable to risk thresholds in the reactor oversight process or ROP Second determining the significance of construction findings should be based upon a risk-informed safety focus inspection and enforcement process with time spent proportional to the safety and risk Significance of the SSC along with the potential for an issue to have remained undetected and impact plant operate operations in the future Next slide, please Last the assessment element for an overall construction oversight program provides a key method for Determining and resolving issues impacting safety Looking forward advanced reactors may have shorter construction time frames and Therefore include faster completion times for structures and systems The current annual assessment frequency in the C-ROMP was based upon an annual assessment period Unlike the ROP for operating reactors with consistent annual baseline inspections Facilities under construction have dynamic schedules and performance From one year to another the amount and type of work including different contractors and vendors involved will differ So one year's performance comparison to another is not always equal Additionally assessment periods may potentially be too long for a faster moving project as a result future construction oversight programs Should consider a system of more continuous assessment and more frequent public communications I will turn it over to John Greaves to discuss aspects and considerations for the future construction oversight process for advanced reactors Thank you. Thanks, Nicole Next slide, please The objectives of the construction oversight program remain unchanged in that it supports the NRC mission by providing independent verification that Facilities are built and will continue and will operate in accordance with their approved licensing basis to do this Oversight for advanced reactor construction focuses on the verification of the quality of those SSEs that are integral to the safe operation of facility and verification that security and other operational programs are in place To support operations said another way the construction oversight program Supports the NRC's licensing decision to allow operation of the facility through either issuance of an operating license for part 50 applicants Or 103g finding for part 52 applicants by providing an independent verification through a risk-informed performance-based sampling program to meet the objectives of the construction program in June of last year we documented seven key principles That are that are key to development of the oversight program. We documented that in SECI 230048 Those principles in of those principles risk-informed and performance-based remain pillars to any oversight program and will guide us to ensure that we focus on the most risk significant aspects of design and that we consider the Observation and review of infield performance in addition to paperwork reviews when appropriate and possible and then we use our assessment process to adjust our oversight footprint Technology inclusive refers to ensuring that the program covers the full spectrum of reactor technologies that Nicole described earlier That are being considered for NRC licensing Scalability is important because it ensures our inspection efforts remain commensurate with the facilities public health and safety risk Informed by experience such that it implies the construction oversight experience and leverages lessons learned from past and current NRC inspection programs and other external sources Comprehensive in that in that the program is designed to consider all possible manufacturing models and diverse licensing approaches And lastly innovative in that it leverages new inspection tools and approaches to enhance efficiency and effectiveness whenever possible Next slide, please To construct a technology inclusive program that can be used to develop inspection plans and assess construction performance for all new designs We started by looking for safety-based commonalities across all reactors while each designer will develop their own methodology for SSC Classification in accordance with standards and guidance applicable to their design We found that orienting the program to three fundamental safety functions in each That are inherent in each design namely reactivity control heat removal and radio-nuclide retention and that by orienting the program in that way We would ensure that we do the minimum amount of inspection necessary to verify that the plant has been constructed in accordance with its license Orienting the inspection to these three functions in addition to inspection of security and operational programs enables efficient and effective inspection Next slide, please Building off this technology inclusive framework our team is looking for at three key areas of our oversight framework to optimize our approach Performance monitoring enforcement including significant determination and assessing perform an assessment We are identifying options for each of these three areas and planning extensive internal and external outreach To ensure our program fully meets the vision described in SECI 23-0048 and is consistent with the program's guiding principles that were previously Mentioned as well as our principles of good regulation Next slide, please While performance monitoring includes inspection Allegations and use of operating experience or construction experience the team is currently focused on how we determine the scope of our inspection And how we execute those inspections Regarding inspection scoping. We are currently considering a range of options That ensures our inspection footprint is risk-informed and performance-based while fully leveraging past experience For inspection scoping there are three options that we're currently evaluating that include various levels of flexibility On one side of the spectrum a targeting process can be used to ensure that we focus on the most most significant items Think of that like plugging your destination into map quest printing out your map and heading out on your road trip In that case the program will tell you the route tell the driver exactly where how to get from point A to point B While this has benefits by making sure that we focus on the most risk significant items our experience with the AP 1000 construction Demonstrated it can be less than optimal On the other side of the spectrum is availability based inspection where we inspect Activity that is occurring on site while we're there and cover the remainder through document reviews Think of this like grabbing your hard copy map and setting off on your road trip You have the most flexibility, but can obviously find yourself in a less than efficient trip In the middle is using baseline inspection scoping matrices Which provides sufficient information about plant design as well as plant construction risk to allow inspectors to make informed decisions About the best inspection samples to choose within ranges determined appropriate by the design In this case ample information and options are provided via their preferred navigational application To that the driver or our inspection staff can reach their destination in the most optimal way possible Next slide please As articulated in previous Commission direction that that Nicole referenced our enforcement actions need to be assessed from the perspective of impact of future plant operations It is recognized that there is limited nuclear safety risk during construction any deficiency identified needs to be assessed Based on the likelihood that it could have gone on to exist during operations And then the consequence of such deficiency on the safe and secure operation of the facility With that paradigm in mind the team is developing options to assess the risk significance of identified issues in a technology inclusive and efficient manner such that new risk tools are not needed to be developed for each design And that we can reach an accurate assessment of risk without the need for extensive quantitative analyses Inherent in this is the recognition of the barriers that exist during construction to ensure that deficiencies are identified and corrected Prior to plant operations which includes all the equality assurance program attributes that are fundamental to the approval of a permit or license Next slide please In oversight program the assessment process is used to guide our decision-making and response licensee performance For advanced reactor construction oversight some acts aspects will remain while the new landscape guides us to relook at these feedback loops as They can to continue to evolve in an ongoing basis our program needs to be flexible to evolve as we rapidly develop construction experience This includes adjusting the amount of baseline inspection as we gain confidence with a licensee's ability to implement their quality assurance programs processes and procedures as well as responding to performance issues In a risk-informed and predictable manner it also includes adjusting our oversight program from the first reactor through the nth So that our oversight program is appropriately scaled to the specific circumstances that each build represents Next slide please While construction to lead projects isn't expected for a couple of years Our team is aggressively developing options and we'll be working over the next two years to refine those options into a second inspection documentation for use by staff We expect this effort to include a large amount of out outreach so that the various viewpoints are heard In fact, we're currently in the middle of the series of public workshops where we're presenting options to interested stakeholders and intend to leverage that feedback to build the best program possible We're committed to keeping all stakeholders informed of our progress including the commission and we'll engage on potential policy issues early To provide clarity while we recognize the need for a working program while we recognize the need for a working program in time for these early projects We also acknowledge that the program will continue to evolve in the future as new technologies are introduced both for licensees as Well as and manufacturers as well as for inspectors and experiences gained during construction of earlier builds We remain committed to the evolution of the program into the future. Thank you for your time and I'll turn it back over to Rob Thanks, Nicole and John Appreciate that overview of what the NRC is currently thinking and as you indicated were early in the process And now is the opportunity for stakeholders to really engage us and help us shape the program as we go forward So with that in mind, it's my pleasure to introduce Ben Holtzman who is the director of new nuclear at the nuclear energy Institute He is currently focused on developing a more efficient risk-informed regulatory framework accelerating industry deployment readiness and engaging with investors and new end users to understand new nuclear opportunities then please Thank you. Thank you. Good afternoon. I'm Ben Holtzman director of new nuclear at any I I'm happy to be here today to discuss industry's perspective on advanced reactor construction oversight I'd like to thank NRC for paying attention to this important topic and Rob Taylor for chairing the session Construction oversight is an important function that is needed to ensure new reactors are constructed in accordance with our approved design and licensing basis thereby providing reasonable assurance of their safe operation once completed as Part of this presentation I will impress why developing a more efficient construction oversight process is important for both the NRC and industry as Well as highlight acute key a few key considerations that we believe should be in a successful program Next slide, please As seen on this North American deployment map, there are over 25 nuclear power projects in development today Vogel units 3 and 4 leading the way for new nuclear It's also worth highlighting the ARDP projects ex-energy and Natrium in Texas and Wyoming respectively GE Etachi collaborating with OPG on the BWX-300 with TVA as a fast follower There are also micro reactors and low-scale test reactors Utilities are including nuclear as part of their integrated resource plans TVA has stated that they need 20 or more SMRs Duke's IRP showed a similar number Dominion submitted their plan for six to 18 SMRs in Virginia alone But this is just the tip of the iceberg Globally over 6,000 companies are looking to decarbonize themselves and supply chains Here in the United States 85% of the population is serviced by utilities who have pledged to decarbonize But just being clean isn't enough. We also need reliable energy the combination of reliability Resiliency and zero carbon emissions is staking a strong position for nuclear energy In fact the DOE's pathway to commercial liftoff along with numerous other studies and surveys Indicate a lot of new nuclear in the decades to come The DOE liftoff projections are shown here with two different deployment scenarios The first shows nuclear deployment starting in 2030 at 13 gigawatts per year Which corresponds to about 43 300 megawatt electric SMRs annually The second figure shows new nuclear deployment starting in 2035 at a rate of 20 gigawatts per year Corresponding to about 67 300 megawatt electric SMRs coming online This would mean over a hundred SMRs are in construction at any given moment since it takes more than a single year to construct a new plant If we think that some of this new nuclear growth will be micro reactors Then there's even more reactors per year and of course if we think some of them are large light waters or larger reactors in general Then there's fewer. I don't want to focus on the specific number of new reactors per year for two reasons first because all models are wrong although some are useful and Second while we may not know the exact number of new nuclear plants per year We're looking at a lot of new nuclear not one or two It's no longer a matter of weather to build these versatile reliable and clean reactors It's a matter of how fast we can build them Of course the future is a big place anything can happen in 2008 we saw no one saw the price of natural gas falling from ten dollars to three dollars due to fracking But there's a real opportunity here if we can seize it and Part of how we can do just that is by rethinking construction oversight because if we do things as we've always done We would need an unreasonable number of workforce for both the industry and NRC as Such let's talk about how to do things more efficiently Next slide please The NRC also realizes that the status quo is not scalable to support the deployment of hundreds of reactors Risk-informed thinking is required as such the NRC developed our cop to support the realization of large-scale deployment of new nuclear Now as we've heard new nuclear is a diverse set of technologies which requires the oversight program to access Assess the relative risk in a technology neutral manner Furthermore our cop should incorporate the lessons from construction experience both domestically and internationally Applicable lessons can be gleamed from the existing fleet research and test reactors the AP 1000 experience and even international projects such as Baraka new nuclear designs come in a variety of shapes and sizes and the best practices from one experience may or may not be applicable to a specific new design project for example non Lwr micro reactors may be much closer to a research and test reactor Than a large light-water reactor and as the Commission noted yesterday the hours spent on oversight should reflect the safety Significance and risk associated with the activity Some of these best practices and lessons learned are already being documented But we'll still need to be incorporated into the our cop program The most recent construction lessons learned report came out this January It discusses the lessons learned from the part 52 construction for Vogel and VC summer projects focusing on Potential improvements for the oversight of future construction projects using the same part 52 licensing framework As it's already been discussed more specifically of what this covers it highlights again itax and licensing activities during construction additionally, NRC has the opportunity to improve the construction regulatory process by incorporating improvements as identified during the 50 52 lessons learned rulemaking activity these changes can also improve regulatory efficiency during construction and play an important role in enabling widespread deployment of new nuclear It's important that the risk-informed our cop program work through and articulate how oversight would actually change between different deployment scenarios We encourage engagement and discussion with industry to ensure that the program is indeed scalable technology neutral and comprehensive There are many key questions that still need to be worked on where does enforcement oversight get applied? How does off-site manufacturing and assembly interface with a facilities QA program in the past? All construction activities were done on site. So it was straightforward that the licensee was responsible But it's less clear what happens as work shifts to off-site locations as Parts modules and even reactors are completed in advance potentially without even knowing their destination Our takeaway message here is that a flexible strategy to right-size construction oversight would be a benefit to both industry and NRC Next slide, please. I also want to highlight some of the things that industry is doing to ensure that we can deploy new nuclear reactors more efficiently First the NEI is establishing an advanced reactor oversight task force to act as a focal point for industry to engage with NRC on the development of advanced reactor oversight guidance But success really starts from the beginning and new nuclear being designed with intent by designing with construction inspection and oversight in mind from the start Industry is also learning from the past We've implemented best practices in design construction maintenance and inspection These best practices will help industry ensure that designs can be constructed and inspected faster Resulting in less upfront capital before revenue is realized These include the NEI construction best practices documents including our latest implementation guide Which was posted this week and discusses three primary topics first of a kind managing construction labor efficiency and Moderalization benefits and drawbacks These documents will help industry deploy new nuclear projects safely on time and on budget But one of the first documented best practices is the importance of design maturity The design isn't just the large isn't the largest cost component in new nuclear projects But it casts the largest shadow in that if the design needs to be redone a lot of other downstream work also needs to be reworked a Detailed completed design enables better project planning and execution Including using more detailed construction methods Tools like digital twin and 4d construction module models do require upfront capital investment But will enable more efficient construction and inspections Faster construction not only saves money, but it also helps resolve the Gordian knot of workforce as faster construction Means less plants and construction at any given moment and therefore less workers Similarly shifting modules and manufacturing activities off-site will further reduce the onsite construction workforce requirements Other best practices are more generally applicable EPRI developed a report last November that provides information on maintenance and inspection That can provide insights not only for industry, but also NRC as it can help streamline pre and service inspections and oversight Another key aspect that will both increase the efficiency of both construction and oversight is increased standardization We need to build airplanes not airports Standardization is not only building the same plants numerous times Enabling improved outcomes due to lessons learned moving down the lessons learned learning curve But it is also improved supply chain procurement by getting the same components This results in easier inspection not only because it is the same plant design But the same components that are in that design So it is the same process as each as those plants go forward for inspection This in turn helps standardize how our cop is applied across multiple deployments of the same design Through these efforts industry and NRC can ensure this flexible program will yield regulatory Predictability and certainty for oversight and oversight activities while being grounded in safety to reach a reasonable assurance that these designs will achieve safe operation once completed Predictability and certainty being two key enablers for new nuclear to achieve economies of numbers and Realizing the widespread deployment that so many models industries and experts see in our future. I Never said it would be easy. I only said it would be worth it Next slide, please And with that, thank you, and I look forward to the rest of the discussion Thanks, Ben really appreciate those perspectives and we look forward to the industry's insights as we continue to build this and get into the specifics of some of the key elements and activities that you discussed so we recognize the importance of Looking for at two different audiences for input and perspective because we may not have all the right ideas within the traditional nuclear Family so with that it's it's a pleasure to welcome Robert Cox to our panel He's the associate professor of electrical and computer engineering at the University of North Carolina at Charlotte Where he also serves as the associate director of energy production and infrastructure center He focuses his research on applying digital engineering to various problems in energy conversion Robert. Yeah, thank you very much Yeah, so non-traditional Contributor to this conference, but we're really welcome to be here next slide, please So what I wanted to talk about here today Is is basically digital engineering? So I've been here spoke a little bit about building the airplane and rather than the airport So it's for context here what we're talking about is applying digital techniques Everybody talks about digital twins these days and I'm going to use terms I apologize in advance digital this or that throughout this whole thing But I'm gonna try to level set at the beginning a little bit Going back about five or six years ago our team at sorry I'm at University North Carolina Charlotte and our team focuses on on issues related energy production But going back about five or six years ago We were looking at a lot of what we were doing the advanced manufacturing space And beginning to think about how some of the digital engineering techniques that are used in advanced manufacturing could begin to be applied to construction generally And nuclear construction specifically right a lot of the issues that we that we see in building nuclear plants I always say kind of relates relates back to Moving dirt and pouring concrete right those those are a lot of the issues that affect schedule and cost And the issue with with building, you know an airport is is that you're everything's sort of one of a kind But given the move towards really using advanced manufacturing techniques to prefabricate a lot of parts of the plant We have the ability to potentially leverage some of those digital tools in a better way And so some of the work that we're doing right now that my team is is doing is part of the advanced construction technology initiative Under Enric and that's why I mentioned it here on this slide So I want to talk a little bit about how we do that. So I'll roll through the next couple of slides real quick here on the on the next one What we talk about with with respect to what a what is a digital? Twin it's always a tricky a tricky question Next slide is it there we go So when I talk about what is a digital twin just a level set We see there on the left is is an actual physical object and what you see on on the right is is a model of that Now one question we ask is that a twin and I would say no it's not it's it's a model That model looks like the real thing, but it's not quite a twin next slide and The next question I always come up with is this is the same sort of structure if I have a model of that structure And that model can be updated to match reality. Is that a twin? That's approaching much more like what I would what I would say is a is a real twin But ultimately the bigger picture if I talk about what is a true digital twin if we go to the next slide What I what we ultimately talk about in the content in the research context is ultimately a digital twin Is that bottom picture where I have the physical world and I have a model of the physical world and those two things are Seamlessly interchangeable and there's automated data flow from the real world to the model and from the model back to the real world We're nowhere near that yet, right? That's the highest level of digital twin What we're really trying to do is to begin this sort of pathway of using digital tools to really improve I don't like the term twin But unfortunately everyone's using it and so we need to talk about what that what that means So where are we on this path so next slide? What we what we kind of talk about in general the term that I like to use is it is in the manufacturing world We talk about product lifecycle management, and if we talk about aircraft All everything kind of fits into this product lifecycle management World where basically what we do is we use model based systems engineering, okay? So essentially what we do is we have models that we develop at the design stage And we carry those models throughout the entire life cycle of a component So at the top there is basically a chain where we go from design through construction all the way to end of life What you could begin to do is if you use this model based systems Engineering approach you develop models at the beginning of the life cycle of a component or a product You map it across all of the serial numbers of that product that you make And you also try to track everything throughout the entire life cycle of an individual component There's two key things about that one is that you begin to take data and you untether it from documents Right, which is important because I can begin to make linkages between things my second point there about I begin can begin to link Models to each other so here. I've got a simple steel composite structure that we made in our laboratory We're basically we have the CAD model and the finite element model for that thing that are inherently linked If I make a change in one it makes a change in the other right? That's that's one of the powerful things about these digital engineering techniques Next slide and what next one I guess there we go Yeah, so what a lot of what our team was trying to focus on was basically how we begin to Use those techniques based on some of the findings that have come out of the last couple of years with respect to Opportunities to use digital tools so going back a couple years of NEI report every report MIT report that talked about construction specifically And and sort of four key areas that we looked at coming out of that was first of all You know there's been a long-standing history of using outdated design processes and construction in general, right? So how can we begin to introduce digital techniques into that? digital techniques can help you to better manage documentation packages and Really begin to allow you to do better decision-making and really exploit the benefits of modularity So what I have there is sort of an example I'm going to talk about but basically, you know a lot of these structures are going to be built A lot of the say the reactor building is is you know likely to be circular likely to be underground for a lot of these newer SMR's So what you see here is is basically if I you know with steel composites, right? For instance with the with the X 300 one of the things they're looking to do is steel composite for the reactor building You can begin to because those are going to be those modules we built off-site, right? You can begin to do some interesting things potentially to track those Modules as they move through their lifetime, and I'll use some examples of that as we go through next slide So one of the things that we look at trying to do say so documentation packages is a potential issue That's always been noted in in the construction process one of the things that we've done is is utilizing basically a Something called dynamic product navigation. So basically each of the modules that you have there We've basically created it so that you you have a clickable model of this particular the entire structure And you can basically drill down and track the entire Life cycle of documentation associated with that particular module So if you want to know what was happening at the at the fab if you want to know what's happening on site at some Different aspect of the construction someone could pull up that information on site even on a tablet, right? So that's that's something that we can easily kind of leverage moving forward, and it's a pretty powerful technology next slide Now we often refer to these things as kind of the single source of truth because one of the concerns always is if I have Multiple documents and everything there can be errors between those documents So we begin to talk about a single source of truth where essentially there's a single database where all of the key Information is tracked so if you think about that that image that I showed on the previous slide if you clicked on one of the Modules I should be able to see all of the data for that module and be able to see how it's progressed throughout It's entire lifetime and that's tracked in a computer rather than an insert of a standalone hard copy document So, you know essentially what we talk about is is I could begin to and I'll use this example here Essentially, I could have a surveyor that's on site That is collecting information about the actual actual construction build He could take that he could take data from a scan or a laser tracker measurement something like that Proce process that data on site and have it immediately update the the CAD models and the finite element models And to be able to share that information with team members broadly and you can do that in a matter of minutes Okay, at least with some things that we'd like to be able to do you can do it a matter of minutes next slide So as an example of that What we what we do here is this is again example from our laboratory We're basically what we can do is we have our as designed models are and then our as designed finite element and as built models We can basically track using information that we've gotten from our scanners We can go back and say this is what we designed it to be This is what it is right now and we can update those two things and we can go back and forth interchangeably to compare the design to to what was actually built next slide Now what what is important about this as I said is a single source of truth So essentially what we have is a database behind all of this where as an example here I'm looking at as for my example Steel composite module I've gotten the lab where basically individual parameters like the length of that thing Exists as individual parameters I can track what it was on any given day throughout the actual Life cycle of it from the time it was designed to the time where it is right now today in real time So with that to my next slide One of the things that we look to be able to do with this is to leverage technologies like laser scanning and laser trackers So in my image there, I'm not going to go through all the gory details of this But if I look at my image there on the left what I have is something called a laser tracker Right, so if you go on a construction site, you can see people with with a with a laser tracking device What I can do is basically do a quick scan and I can if I have targets on those modules What we can do is we can actually track where the modules are placed in 3d space We can take that information Feed that information back into our systems in the cloud and then update You know where a module is placed and we can also use Laser scanning to be able to get sense of how wavy potentially the surface may be of one of those one of those modules So on the next slide there So here's an example of where we might use that so imagine if we're building steel composite structure So it should be a great benefit to use modular construction techniques I can prefabricate things before I bring them on site well when you begin to place those modules on site There's there's a question of tolerance management, right? How do I make sure that when I place one module? I have it offset it too much that I need to worry about where I place the next one So what our team is looking to do basically is to take that image there on the bottom basically again This is a this those are not obviously still composite modules. This is what we're doing the laboratory right now It's implied wood, but basically it's the same concept Essentially trying to take the laser tracker data and be able to feed that information back into our models to to update things and basically using that for Being able to help us Implement a tolerance management program so you can begin to imagine where this sort of thing might be useful In the construction process the next slide Yeah, jump ahead there. Yeah, so now the question as we develop this is the interface on the regulatory side if we talked to folks in the construction world that they like a lot of the concepts associated with this but what scares What frankly what scares the crap out of them? I think is that the regulators could see all the gory details of what may happen in the process But one of the key things that we need to think to is is how do you actually expose this information? Appropriately to a regulator given that you I mean you've got enormous amounts of data that you can track It's got to be useful, but we don't want to track so much Potentially or expose it at the wrong times that if we if we get data that we're not certain about we can begin to get into an Analysis paralysis loop, and I think that's the concern that a lot of folks have But it's an exciting time to leverage some some really new and interesting technology So with that Thanks Robert. I know I learned a lot from that and I appreciate it I now want to come down and maybe take a class from you And learn even more so thank you for that With that I'd like to introduce our last speaker today and some of you may be aware that the NRC and our Canadian colleagues at CNSC have been partnering on a number of activities related to SMRs and advanced reactors and so we welcome Sarah Eaton the director general of the directorate of advanced Reactor technologies at the CNSC her directed as her directorate is responsible for licensing new nuclear reactors Pre-licensing activities including the vendor design review and leading SMR readiness writing this project for the CNSC Ensuring a coordinated matrix approach to organizational readiness for regulating SMRs and new advanced technologies. So with that Sarah, please Awesome. Thanks so much. The benefit of going last is I can just say agree with Nicole Agree with Jonathan agree with Ben agree with Robert and call it a day But I am really happy to be here to talk about the Canadian landscape and the work that the Canadian Nuclear Safety Commission is doing in this space next slide, please So I know every single one of you lie in bed every morning as an American and think I wonder what is going on in Canada Well, luckily today, you'll get your answer So on this slide we have on the right where we are today And on the left on where we think will be in five years and even since I've finished this slide I feel like the five-year slide probably is out of date already So today we currently have 17 can do reactors that are either operation or refurbishment And then we have three separate SMR projects with three separate technologies Looking at five year out five years. We have additional SMR projects Likely some of the same technologies we're reviewing today possibly another some of different ones We have new advanced technologies and we have to be determined large nuclear power plants So I'm not going to walk through every project in the timelines But I am going to draw focus on what's been mentioned before on Ontario power generation's proposal to deploy the BWX 300 at the Darlington site as this is the project That's front and center for us today So we have a scenario where we're moving from a group of can-do experts a Comfortable spot of being experts in our field to needing technical expertise in a minimum of five additional technologies And to be honest industry probably is going to throw in at least one more So of these technologies can't as pose to be potentially the first Deployer in three of the three or four of those technologies So it's a little bit of an unenviable position as a regulator to have everything bends laid out in front of us on Scale of deployment on rate of deployment But luckily we've been thinking about this for a while over a decade and if we go to our next slide It brings us to our SMR readiness project And so we talk about SMR readiness in how it will prepare us for advanced nuclear for small module reactors But it will present prepare us for any new nuclear deployment that occurs in Canada doesn't matter about size in 2022 we initiated this project which represents an integrated approach to optimizing our regulatory readiness for small module reactors and advanced reactors We have a budget of fifty point seven million dollars a five-year timeline and through that we aim to address 60 objectives Over 60 objectives, which will help us prepare for new nuclear We've organized our project into four pillars the first being regulatory predictability Everyone's favorite pillar which really helps us be able to ensure that our regulatory framework is up-to-date technology Neutral and has the necessary guidance and information that new applicants will need to be able to navigate the regulatory space We have policy and shared responsibilities Which is our work with our federal and domestic partners to ensure that we are having a one regulator approach And that we're sharing and leveraging information where we can We have international collaboration where we talk about the work We're doing with many of our partners including our very good partners here at the NRC Which helps us ensure that we are finding efficiencies where we can in our regulatory processes and finally capacity and capability Which is really ensuring that we have the talent we need that they have the skills They need to address what we have in front of us, which is a massive culture of change for us and what comes cuts across all these pillars is that need for cultural change as we transition from expertise in one technologies to expertise in multiple technologies Increased collaboration with other partners and the rate at which industry wants to deploy Innovate and change and so it's a culture shift for us And this readiness work really helps us build that culture change and be able to support it next slide, please So I want to sort of bring our readiness project to the panel the topic of our panel today Which is looking at advanced construction So if similar to what Jonathan and Nicole spoke about their key principles also align with our key principles So our newest can do's the newest can do's we have began construction the same year. I was born 1981 and so as today is my birthday. I really tried to link first concrete for thank you very much. Thank you very much I really tried to link first concrete for today to today to March 13th But sadly I could not it was in June So as a regulator we haven't overseen new reactor construction in over 40 years So as a result we have no modern compliance oversight plans and this objective deals with that gap This objective ensures that we have a generic plan that we can tailor for different technologies And we will use it should OBG be approved for the deployment of the BWX 300 the team that developed this plan was Came from across the organization ensuring a two key approach from our technical services branch and also operations branch and While we don't have the recent experience as Nicole and John and Jonathan and Ben have described There's lots of experience out there. So we've leveraged that experience to ensure that we can Learn from those from from the lessons that were learned and be able to find efficiencies in our program And we also leveraged the lessons. We've learned from our own can do refurbishment Which is obviously been massive projects, which has allowed us to be able to modify and have agile construction and sorry agile compliance plans And so during this period of novel approaches to designs and the construction It's critical for us to focus on the novel features the first of a kind features Using a risk-informed approach on what really matters and this generic plan as I said will be tech neutral We'll be able to use it for multiple different technologies next slide, please So our inspectors and our inspection program is robust and it's world-class What we learned from COVID that was while virtual inspections are a great tool to add to our to our toolbox In-person inspections are critical for compliance oversight and that is especially true for novel and new features Like all mature regulators We have a variety of inspection tools and all of these will come into play for our current inspections and for any future inspections for advanced construction We use a performance-based risk-informed approach Multi-year inspection plan that allows us to consider that allows the flexibility to consider for innovation and new licensee approaches and the innovation tools for inspectors that we're looking at today such as virtual reality drones artificial intelligence are Going to change at a rate that will be uncomfortable for us as regulators and will require again additional culture change But burying our hand our head in the sand and having a mouthful of sand isn't that comfortable either And so we have an expert group in our organization who's supporting us working very closely with the Canadian industry To see how they are using innovation and how we can use those innovation tools to support our compliance oversight Next slide, please So I'm not just going to talk about how much we love working with the NRC because we love working with the NRC But our this collaboration really has been pivotal in our preparations for new nuclear in Canada From our perspective collaboration builds positive relationships among regulators, which for us is necessary for the safe and effective deployment the broad deployment of small-modge reactors in 2019 we signed a memorandum of cooperation on advanced reactor and SMR technologies to enhance our bilateral Collaboration and last evening we were able to sign a trilateral agreement to bring the UK O&R into that as well Our memorandum of cooperations allows us to do pre licensing engagement Licensing reviews to share science research and to develop common regulatory positions For the BWX 300 we have a very unique five-party was it was five party as of when I wrote these speakers notes now six-party agreement Which allows us to be able to work together on technology specific aspects So we've been doing a joint review On advanced construction techniques, and we're looking to we're looking to work towards where we can harmonizing compliance plans Leveraging supply chain inspections, and this is really the lifecycle collaboration We need to be able to be efficient and effective effective regulators once we have these standardized designs and Of course our staff are learning from NRC staff on the Vogel Lessons learned and we're looking to be able to capture those best practices as we continue to update our new compliance plans But also our existing compliance plans next slide, please So building trust all of our readiness work Collaboration with international partners will mean nothing if we aren't seen as a trusted regulator and we're and we are known for our independence Through our trust strategy. We're strengthening our relationships with the public environmental groups and indigenous nations and communities developing strong relationships with indigenous nations and communities is deeply important to the CNSC and we're committed to building long-term sustainable relationships and So part of that relationship building has been a request from indigenous communities to participate in our independent environmental monitoring program and also to observe observe how we conduct inspections and from our perspective This is a really important way for us to be able to share our experience that can help build a common understanding of the safety of Our ongoing facilities and also the safety of these novel construction approaches These approaches are first of a kind and so as scientific-based people as regulators We're working through how how we can look at that through a safety lens But for the public it's brand new for indigenous nations. It's brand new So it's really an opportunity for us to be able to share that information and to be able to Include the lessons that we can learn from indigenous nations and communities and continue to build that culture of change Next slide, please So in closing We are committed to innovative risk-informed decision-making processes when building our compliance programs We don't necessarily have as much time as was shown on the NRC Schedule to be able to integrate these plans and to be able to use them And that's why for us integrating those lessons international lessons learned are key for our perspective International Collaboration is a critical part to our work and it has to be a life cycle collaboration to ensure that we're able to Gain those efficiencies over the life cycle And as we look at this period of growth from the industry It's a period of growth for regulators as well where we have to build Capacity and capability we need to find talent in a place in a time when talent is not easy to find And we also have to assess how we continue to assess multiple projects different technologies at the same time Building culture for change is critical whether it's for advanced instruction Whether it's for international collaboration or indigenous nations building relationships and indigenous nations and communities But I know that we are up for the challenge. I know we're well-placed to do so. So, thank you very much Thank you So thank you Sarah and happy birthday and your present will be that we will not sing a happy birthday to you at this time Maybe later So I want to thank the and I think you you hit a really good a point is and it's something I'm going to elaborate on is that I think we're recognizing the United States Canada UK and many other countries that that nuclear deployment is a global activity now It's not just a national Activity and the more we collaborate on that effort such as these the more we can harmonize and Enable the the safe deployment of some of these technologies as we go forward. So I do want to thank the audience We're going to move into Q&A. We have a number of questions already from the audience We have 31 minutes left. So that is wonderful. I want to thank my panelists for moving through their presentation so efficiently and That'll give us plenty of time to answer some questions. So if you have questions, we're gonna have some time in here So please put them in based on the presentations. You've heard and we'll hopefully get to to a number of these so the first one and and I think I'll send this one to my NRC colleagues and to To Ben is is an important one and it highlights a difference With what the type of technology will see and no type of construction will see going forward So as the industry is moving to true modular factory built approaches How is the NRC preparing for oversight and a scene in industry preparing for oversight of the modular fabrication activities Completed in a central factory. So Nicole John, you want to start and then Ben can chime in. I'll take that, you know the It's a really good question It does present a bit of a challenge has been kind of alluded, you know mentioned in in his discussion Our past practice our past experience was really stick-built designs Everything, you know was happening under the office of the oversight of a licensee at a particular site We've always inspected vendors that provide You know components or maybe small systems But the bulk of the activity was done at the site and the new landscape really presents a different challenge There are a lot of similarities to how You know Being able to inspect off-site but but being able to do it in a way that we're inspecting the right things at the right time So that we're not in a position where we're just inspecting everything, right? That's not where we want to we want to be in a risk-informed and performance-based framework So it's one of the things I you know talked about was looking at kind of an integrated inspection scoping matrix Where you look at the project and you say what are the you know based on this design that a licensee or an applicant has submitted? What are important things? But you know, what can I leverage from what I know? You know a risk-informed You know process underpinning risk-informed obviously we talk about Likelihood and consequence underpinning that is uncertainty And so one of the things with modular construction Especially as you go from a first-of-a-kind build through second third to end-of-a-kind as you learn a tremendous amount of information And we have to have a system that that is able to factor that information in if certainly if it if the industry gets to deployment schedule that that Ben talked about where You know dozens are of reactors are being constructed in a year We need to be able to leverage that experience so that we aren't necessarily performing the same level of inspection for Each one of those units and we're learning as we go along and scaling ourselves Appropriately so it presents a challenge. We are thinking about that one of the best parts of of Getting into where we're at now where we're starting to engage through workshops as being able to learn about the different deployment models that some of our some of the vendors are are You know contemplating so that we can make sure that our system is flexible enough to adapt to any of those realities So it's it's really an exciting time. We are thinking very hard about that to make sure we come up with a program That will ultimately address it But we look forward to continued engagement with with you know Any eye as well as any of the vendors to make sure whatever we're coming up with does satisfy the landscape that's ultimately gonna come Yeah, so just to add to that I I appreciate the The the initial the initial comments and I think it's a good question the the challenge of course is that The the devil will always be in the details And so I I can't come here and say well clearly We're going to do XYZ and that's gonna work for every possible iteration that we're gonna come up with but I think the Right framework or the way that we're thinking about this is is right in the sense of As we're moving activities away from site Clearly we don't want to be doing the same activities in terms of oversight and inspection both at where this is being Manufactured and then again at the site But depending on what we're building how we're building it how accessible is it going to be after shipment? Those are all going to impact when and where you can actually do the oversight most effectively Now of course if you let's let's just say that on the most extreme case. It's a microreactor. It's all sealed up at the factory You do your inspections and oversight there when it shows up at site There's still probably something that we have to do in order to ensure that it It was received and it's still In the right condition for operation once it gets there What does that look like exactly? We're we're working on that right it's clear that you don't want to have a one-to-one Recheck of everything, but it's also clear that you should do something to reassure that you have a reasonable Assurance that it's going to operate and work the way we think it is and I think as we as Jonathan was mentioning as you start going forward and we figure out exactly what the process and what some of these deployment scenarios Actually look like we'll have more details But I think at the same time as we start laying out Here's what the strategy for this deployment actually looks like of the different designs and technologies We'll enable ourselves to kind of come up with here is how this flexible framework is going to be enacted For this design for this application and then we'll be able to apply and move that forward consistently for the that design Thank you, the only thing I would add to that is So some of these concepts are not new to new the NRC, you know, we have inspected modularization. We have Looked at vendors. We have looked at factory acceptance testing So some of these concepts are new but applying them more globally across more different technologies More consistently over a number of different sites or facilities That's where we have to be innovative and that's where our framework is looking at How do we be scalable? Technology neutral, but you know, we're going to continue to use the lessons we've learned from the past to apply it through the future so Modularization is a complex issue that we saw from both the regulatory side and then from the industry side So there's learnings to be happened and from all perspectives For you know for the future of this if it's going to be primarily focused in that area of construction Thank you Thanks This next one I'm gonna Start with Robert Recognizing that we're looking at risk-informed and performance-based approaches I'm gonna specifically target this question towards the technology. How can it be? How can the technology really benefit us in terms of cost and schedule efficiencies for the construction of these these facilities? Where do you see the biggest impacts being? Sure. Yeah It's a great question. I think one of the one of the areas that we've you know looked at is Ultimately like as an example we talked about these these Modules as they move through from the factory to the site You know one of the areas that we look at and first of all is just better document management And and if you look back at that sort of past experience all of the issues associated with being able to just again Just from a construction perspective being able to track where art where art is all of the information about all of the The modules and whatnot, but we'd be able to leverage the technology to be you know Scan a code on the on the side of the module to be able to pull up on a on a tablet all the documentation that you would need Associated with that so document turnover becomes better managed for instance, which is one of the things that's been noted is That's really slowing down a lot of processes in a lot of ways You know the the other example would be you know that I kind of always go back to is Things like you know tolerance management as you're placing, you know modules you can begin to You know sort of better be able to track if something's been misplaced What's the what's the impact on that and so if you if you have a nonconformance, you know And you have to go back through and do analysis and disposition, you know the significance of that You should be able to do a lot of that analysis a lot more rapidly and that's that's one of the big advantages that we see The other element that we look for ultimately is you know, I didn't talk about it a whole lot here, but Leveraging sensor data on site, you know, for instance one of the things that we're going to that you have a lot of issues with if we have underground Shafts for instance How do we how do we leverage sensor data to be able to sort of track what's happening throughout? construction And and that's something that You know, we're working on testing right now But that's there's a lot of opportunities to be able to use data to speed up a lot of the aspects of say underground inspection And the geotechnical side of the build So, you know, it really is is a matter of being able to sort of I think we're talking about leveraging the modularity But you know, how do we how do we begin to sort of better track the information use the ability to track it? and use sensor data and with with with an understanding that Sensor data needs itself to be trusted and validated on a regular basis So those those are where a lot of the questions lie I think but but there's there's a significant opportunity I think to begin to in particular look at the notion of If if something happens in the process in the construction process How do you do a much quicker analysis of of what the issues may be associated with that? And how do you better control document management and turnover? Thank you for that Robert greatly appreciated Maybe to the to the panel right if we're a few years from now and we've implemented these activities And we talked a little bit about assessment throughout the the effort What is your measuring stick for whether you'll know whether we've been successful in developing a program? And one that works the way we envision it And maybe I'll start with Ben and ask him to to define success for this at the end of the day And then ask other panelists to To weigh in that's what I get for making eye contact, right? Yeah Yeah, so I think it's a I think it's a good question. I mean Where we are today? We can look at what is the oversight and program look like went for Vogel for example and Vogel was I think five inspectors and several thousand hours worth of worth of work and If we say okay, we've developed this program and you know what that's that's where we are we have no No measurable gain. Well, well clearly that was a problem. We didn't succeed at that one We didn't assess and implement a risk-informed process. I Think if we can look at it and we say yeah this we can see how designs that have less risk of public health and safety have less Oversight associated with them. We were accessing this in the right framework one one thing I think that we would want to see in this program is the differentiation of Protection of public health and safety versus the protection of the asset itself There's a difference right between having Saying that we have a design and if we turn it on there's a problem And we're going to have a radiation release or some dose or something that's going to go wrong and saying well You've destroyed your you've destroyed your asset. It's not actually going to be able to operate But there's no real risk to anyone. It's just you're not going to make any money I think figuring out how to differentiate and specifically target You know, how do we ensure the the adequate protection of public health and safety for will be a keyed enabler Of whether or not we have a successful program Great others on the panel want to weigh in so Maybe I would add, you know what when we're designing the program typically when you think about an oversight program You come up with okay. Here are a list of inspection procedures. We're going to execute and we're going to do an X number of samples And and that's going to result in X number of hours of inspection what we're designing I think is a little bit different because Maybe you know complimenting what what Ben just said each of these designs is going to present Different a different risk profile a different level of complexity Passive versus active systems number of systems number of itax so we need to design a Decision-making process that stands up to the rigor so that when we receive a new design a new application or a new You know design certification new you know manufacturing license that we can implement that that decision-making processing gauge with the applicant To make sure that whatever oversight framework looks like for that Particular design that it's right-sized to that design And and appropriate to the circumstances and with holds you know holds up to the scrutiny That it should so so I think that's where you know success for me is We've developed a decision-making process so that we can right size develop a scaled inspection footprint And we have the appropriate decision-making processes down the line so that we can continue to evolve that that that inspection plan for future builds And in consistent with those principles and our principles a good regulation. I think that would be success for for us Sarah you want to weigh in Thanks, I think I'm going to define my success a little differently And I think it's because we have a scenario where we could have constructions at this site In Canada starting in 2025 And so I think from from our perspective we would look at the early measures of success was was the project able to be executed correctly You know safely According to timeline and schedule Were we able to do the inspections that we needed did we get the information? We had we needed and then to do an assessment after that to say okay What would we need to do for the same unit? You know if there was to be unit 2 unit 3 or this unit another location to be able to look at at that aspect I think it's important that we can plan for every possible scenario But we need to execute on the one in front of us And so we certainly are focused on executing on the one in front of us while Acknowledging that there's definitely work to be done There's so many interesting deployment scenarios, and I think Ben's part about the models is totally true Who knows what's going to happen? But for the ones that we have in front of us we have to focus our energies to make sure that we're doing those right Thank you Sure, please so what I would note is you know from the nrc's mission statement You know our success measure is public health and safety protection of the environment and security of these facilities There are some challenges out there that what does that look like with these new and their questions? They're not necessarily challenging the actions that we have to work through. What does it look like for a Potential mobile reactor, what does it look like for the environment? What does it look like for protection of public health and safety? So you know to me the success measure is that the regulatory decisions the licensing and inspection oversight that's done provides reasonable assurance while continuing to make our mission and and there's Because there's new questions in the future We don't know what those needs do and working through that is going to be of the highest importance. Thanks so John was touching on something that I think is important to follow up and we had a good question here from somebody Maybe it would be good for the panel to elaborate on their vision related to this So considering the huge design differences between advanced reactors designs will there be separate our cop guidance for each type of reactor? Or will the guidance be so general as to potentially not be useful? fair question, so I think you know, so I'll point to two things So one of the things when we're developing or thinking about a technology inclusive framework We really need to think about what's common across all the designs and there are some things that are common so certainly What systems structures and components are used to satisfy and I talked about the the fundamental safety functions each designer is gonna You know use their or develop their design to to ensure that they control reactivity. They remove the heat remove, you know That's that's generated and they control radio nuclides, but then underpinning all of that and I that I mentioned was Every designer and as they go through construction is going to need to implement quality assurance program attributes and so if we're inspecting and looking at how they're Building their SSC's, but really what we're looking at is how are they implementing their quality assurance programs? and and then can use that level of inspection to Draw conclusions about things that we're not there for right. We do a sampling based inspection program We're not going to look at at every single component that's constructed, but they're using the same processes procedures And programs to affect the results that they're looking for so I think that that's a common, you know regardless of technology You know quality assurance programs. They'll define what what that is and that'll be approved in their in their application But that's a good basis and generally common that I think we see so when we when we develop inspection guidance What we would really want to be looking at is how are they implementing their qa programs and is it resulting in a quality output? You know a quality component quality system quality plant And and so if we focus on that, I think we can general we can get some some common Threads that that'll that'll give us good guidance regardless of design. Certainly. I think there are some Different aspects that we'll have to create specialized inspection for Right, we may need to look at, you know, how you know salt content of you know, if it's a molten salt reactor Right, there may be some aspects that are specific to that that may warrant some specific guidance And we can address that on a case-by-case basis But underpinning that there's there should be quality assurance attributes that are ensuring that they're they're meeting So it's still largely very similar And then we can look for what specific design differences warrant specific information for inspectors So I'm going to do a very dangerous thing and slightly disagree with you And the reason I'm saying that it I want to say that is I think the question which was a very interesting question is Missed an opportunity for a third choice And the third choice I think that we're missing is you know when we described this system We described the oversight program of what we're trying to set up here It is a risk-informed performance-based technology neutral framework and If we set this up correctly It works for all the different technologies because we have Principles that we apply to that technology and it yields a different answer depending on what your technology looks like This is the same process that we've been working with NRC We industry been working with NRC on for many years now the licensing modernization project and We've already had all several successes already under our belts in the development of different guidance and industry is using this To develop topical reports to develop Applications and I think this is just another step in that using the licensing modernization technology neutral risk-informed performance based approach and so I don't necessarily know that we'll need to have specific Guidance that will have to be overly prescriptive or something. That's so general that we can't use it I think we build the tools and then the tools will be applied to the different technologies to yield an acceptable and workable solution Said said maybe another way I think we share a common vision is that the the tool if built properly will focus you on the right things to inspect Yeah, and those will be different depending on the technologies But shouldn't build it overly complex for one technology versus another and you want to test the program Over and over again with sanity checks to make sure it's focusing on the right right things. That's part of the assessment program. Yeah. Yep, great Robert Love the technology love the idea of leveraging the technology I Had the opportunity to work on vocal and Nicole did as well We saw a number of challenges with the first of the kind construction that vocal was going through and we saw with unit 3 they encountered some challenges they learned from those and then they applied them to unit 4 and construction went much more efficiently How can the technology help us avoid those first of a kind challenges for for new? construction builds Yeah Well, that's a good question You know where it really begins to help is when I do second of a kind right and third of it because because you have The ability to carry carry the information through and you don't have to rebuild everything in the same way that you did before Effectively you're building twins. I guess if I use that continue with that terminology You know, I think as it relates to the the first of a kind Technique again, I think a lot of it as is we need to begin to look at how we leverage the technology to build out better QA processes right At some level that's really a lot of what the tool is able to or tools are able to do is to leverage Those technologies my fear is what's going to happen is that as they as you do first of a kind technology is going to be both costly and and potentially slow things down And that's that's that's the fear that I think I have with a lot of the use of of technology that the advantage is probably going to come further further down And and so that's something that I think that that needs to be worked through For sure, but but you know, it's clear that you know, particularly for you know Looking at you know, you know, for instance some of the things that we've seen with in talking to folks of ogle the opportunity to be able to leverage Technology for QA QC. I think that's where you know, I think we see a lot of the advantages and opportunities For first of a kind, I think that's where it really does get to be challenging because my fear is that it could slow things down When you're testing and piloting things But I think you know, I think it's once you break through that I think you're going to see that the the benefits are Exponential as you begin to move to two and three and beyond Yeah, I'm gonna add to that a little bit. I think that so I think Certainly you're you very well stated that you know in order to when we build the models when we put all the pieces in place That's that's additional cost and there's additional effort in order in order to do that I think one of the things that with these tools will help us do is Some there's some aspects I think the tools will help us do and I'll come back to that in a second But I think the sheer act of ensuring that we have all of the information To the level of detail that we could use the tools right will help us a lot for the first of a kind Deployments because a lot of the challenges that we've seen are not Related to okay. Well is the tool itself going to cause challenges, but it's related to well We didn't have the does the design finished enough and we weren't able to have We didn't actually have the the supply chain set up to have this piece come in and the work point when we have the Workers actually doing the construction activities at the site We didn't make we didn't realize that we had an issue and then we weren't sure where those workers We're gonna be able to go because they couldn't do the activity that we originally had them planned for for that day and some of the tool some of the advantages of setting up the these advanced tools is that now because I can see Better the totality of the project. I can say okay. Well, this was late and yes That'll improve as we move down the you know the From first of a kind towards end of a kind But if I know okay I can move these workers over here to do this other activity because all of these components are available Even though that's not necessarily the first the thing that's most urgent on my schedule today That enables me to still move projects forward in terms of completion So just I just wanted to add that to your response But I think that was and I just that I don't I mean that those are a lot of the driving principles Yeah, that you would look for and I think Just the notion that you would be able to You know In nuclear I think it's always you know is the design finished You know we want to be done done there's always the term that I hear But you know you you have much more of an ability to be able to do a lot of these what-if scenarios and construction That Ben that Ben was talking about and I and I think the challenge I you know is really just to say Once you have that ability you can start asking a lot of questions And I think the the fear that I have for the first couple is if you begin to ask too many of those questions Does that ultimately slow things down? And I would say that the size and scalability the projects will have a big impact on you know The impacts of first-of-a-kind issues, you know when you're talking about a design That is robust that has you know less significant safety welds or Components or systems or testing, you know those kind of if you have Learning growing pains as you're working through these systems It's not going to have the significant resource timing Scheduled delays that you would for a large light water reactor. So you know there's going to be some pros and cons to this new type of technology I'd also, you know, maybe to add in from an oversight piece to I think digital technologies, you know add There's we talk about risk-informed I think design risk is is fairly well understood this component this You know vessel has is of such-and-such safety significance because in this accident scenario performs this function But the other aspect of risk-informed that we think about in construction oversight is construction risk And the way we talk about that is what's the likelihood that a deficiency would Make it to operations and I think some of the digital technologies that allow for self-checking audit, you know One of the features in a lot of digital IFC systems that are being deployed is because you can eliminate a lot of different testing Because it's going to self-test all the time and and if there are our technologies out there that are being deployed that ensure that deficiencies are Recognized very quickly and then can be brought into the models and and and resolved that Lowers the construction risk right and we need to be able to factor that into our decision-making To to reflect that right and and so we shouldn't necessarily need to inspect to the same degree if the system's inspecting itself And maybe what we're actually looking at is is you know part of the QA check is well What what sort of self-checks and and you know QA at you know QA? Attributes are being employed at that level so I think you know even on first of a kind I think we those are things we need to be aware of And and and certainly make sure it's factored into our into our decision-making Great so we have three minutes left and I want to get one last question in because I think it's an important one And it gives us an opportunity to talk about something that we haven't had a chance to touch on So I'm going to direct it to Nicole and John just a little bit here and invite others to weigh in Some new reactor designs claim that the fuel cannot fail which serves as a key assumption for the overall safety case With this assumption there seems to be a heavy reliance that fuel design and manufacturing is of the highest quality What are we doing with fuel manufacturing oversight to ensure the safety case is met? Can you guys elaborate on how we're interfacing with those building the fuel cycle oversight program? Going forward and making sure that we're integrated in in our approach to overall safety for the facilities Yeah, thank you Rob I think that's a great question because when I when I talked about earlier in the presentation about a holistic approach this This perspective on oversight framework development For scalable flexible technology neutral. This is not Isolated to our cop. This is for fuels fuel facility. This is for the non-power production utilization Facilities. This is the the fuel cycle life's the life cycle of the fuel system. So What's happening is with fuels because it's the first to be developed We're working with the program office the same folks are working with the program office to ensure that That our inspection guidance is scalable is flexible It's able to consider the different fuels that are going to be built to support these these new advanced reactors We're also going out. We're we're working with the program office and the Licensing application applicants we've had several public meetings the same as As John was talking about for the our cop the workshops having open platform communications to have this dialogues because they're also asking the same questions from you know fuel cycle perspective, so it's an important time for the regulatory framework and We're trying to be at the forefront of this new this new generation of advanced reactors advanced fuel and The fuel cycle is absolutely part of that that key that key program So we have just under a minute anybody else want to add to that I would I would probably just also add in you know We certainly are leveraging and partnering with the research and test reactor oversight You know as as been mentioned before some of these new advanced reactors are gonna from a risk standpoint may look a lot Closer to what a research and test reactor so although they you know, they have a separate oversight program We certainly need to learn from them leverage their experience It's a good opportunity to Benchmark and and look at how our decision-making process how would it apply to an RTR And is it right-sized would it give us a right-sized approach or not and then go back and adjust? So that's another program that we're certainly stayed tied in. Yeah, that's absolutely included in the overall framework Well, great So we did not get to all the questions here So if you did not get your question answered we'll be around here shortly after this So please come up to us talk to us and we're happy to elaborate or if you had a question You need to get it didn't get a chance to put in please do so So with that I'd like to ask the audience to to join me in thanking the Participants in the panel and their contribution and and their efforts on this very important topic. So thank you guys With that we'll close out the session. Thank you all