 So good afternoon everyone if you'll take your seats. We'll begin So my name is Michael Johnson. I'd like to thank you for your attendance and for your participation in the regional session of this year's regulatory information conference The purpose of this session is to hear from the NRC regional administrators and from senior nuclear industry executives on contemporary issues involving nuclear power plant operations and Regulation in the United States in the interest of time I'm going to do just some brief introductions Of course, you know these folks well and so more lengthy introduction would not be needed Let me just start with David Lu who is the acting regional administrator for region one Kathy Haney who is the regional administrator from region two Steve West the regional administrator for region three Chris Kennedy the regional administrator for region four Sam Belcher who is a senior vice president and president of first energy Utilities and last but not least Dan Stoddard who's a senior vice president and chief nuclear officer for dominion energy So the way we run this session every year is we we start the conversation off of questions that we've solicited From the industry just to get the conversation going and so I'll I'll tee up a few of those questions to to begin the conversation Of course, what we really want to do in this session though is to hear from you with respect to your questions for the NRC and the regional administrators were for our Distinguished industry executives And so please don't be hesitant to raise questions Again in the format that you're well used to just pass them to one of the monitors those questions will be brought forward and We'll tee those up as best we can to get those questions Addressed for you in this session We're going to do our best to address as many of the questions as we possibly can during the time that we have allotted so please I'm going to just in advance ask the panelists if you'll bear in mind that we're going to try to be as Concise as we possibly complete and concise as we possibly can as we move through the questions that we have in front of us So I look forward to a Very interesting session. I want to thank you in advance for your participation So, let me tee up then the first question that we want to talk about in the subject is on backfitting Licensees are concerned that inspectors are taking vintage Licensing basis documents and either reinterpreting them Reinterpreting the meaning of the document or stating that the original reviewers aired and approving the original license There have been several examples That have been ultimately resolved after the expenditure of much licensee staff time and management attention to resolve these issues And so my question my first set of questions are to Steve Steve West To what extent do you believe this is an issue and what are you doing to ensure your inspectors are not imposing backfits as Result of their inspection activities and then after Steve is finished. I'm going to ask for industry representatives either Either either of the our industry representatives either Dan or Sam To what extent do you believe this is an issue and what can it should licensees do to preclude or help resolve such issues? So Steve Thank You Mike Let me just answer the question first and yes, I believe it's an issue And I will explain why and I want to start with just a little bit of background and context I don't know if it's needed in this room. I've heard backfit mentioned in every session. I've been at today So I think it's being talked about But if you don't know the backfit rule is big like basically a regulation applies to the NRC and the NRC staff and In a sentence, it's intended to control our imposition of new requirements or staff position on licensees I'm going to just use the term backfitting But there's a comparable requirements for new reactors, which is called issue finality and most of my comments will be Focused obviously on the reactors, but there are some backfitting provisions. It also apply to some of our materials programs So when the backfit rule is followed it provides regular Tory stability and predictability And it does allow new requirements under certain conditions and circumstances which are specified in the rule itself So backfitting the word backfitting is not a bad word. So if you hear somebody mention backfitting It does have a proper context But failure to follow the rules is a bad practice and is inappropriate. And that's what the NRC is focusing on right now and there's really a I Think both the the regulator the NRC we regal administrators and other Offices in NRC and the industries that we regulate have a common interest or a common goal and seeing that the backfit rule was is appropriately followed and applied and so just as our staff and Licensee staff Understand the technical area that they're responsible for they should also have some understanding of the backfit rule So they can understand or recognize when they may be crossing into a backfit situation Not that that's a bad thing But they should recognize it so that it's handled properly because we wouldn't resolve a backfit issue through the inspection process, but it could kick off a Process that would deal with the backfitting issue if it's if it's Something we need to take a look at so last year the committee to review generic requirements the NRC CRG are Completed a comprehensive assessment of the NRC's backfitting Practices and that that tasking was made by Vicks Vic. I'ma said Vic Stella Vic McCree, I did say it That that tasking was made by Victor McCree the EDO and It took about a year maybe a little bit more than a year to do and the CRG are concluded that there are Opportunities to improve the NRC's backfitting Practices and the committee identified specific areas for improvement and corrective action Recommendations to the EDO the EDO accepted all of those committees recommendations and even added a few additional Actions for the staff to take and the areas for improvement or the areas we thought needed to be corrected And Vic agreed included the need for improved oversight by NRC senior executives and lower-level managers and supervisors Enhanced engagement by the CRG are in backfitting issues Additional training for the staff and updated guidance. We have a lot of guidance We needed to update that and also we weren't really doing much in the area of knowledge management Which I think you all will agree is critical At this time in the industry's history and so we needed to do more there So we do while we do have backfitting experts at the NRC They really know what they're doing in the area backfitting and they typically handle the more generic activities like rulemaking generic communications They do a great job but the CRG are found that The issues that typically come up involve plant specific issues and these could come up during inspections or licensing reviews For example, and that's was a real focus for what the the CRG are was looking to Achieve so basically the NRC has lost focus in an area that's important to us in the industry We recognize that and now we're taking corrective actions So Because of the extensive review that the CRG are did in its conclusions and Recommendations and the response to those by the EDO and other executives at the Commission including the commissioners I would agree that there's a problem And we are taking action To address it the main thing I'll just mention here quickly is is the training training is an area where we were not definitely not doing enough We had done more training in the past. We backed off that probably contributed to The lack of focus we see now and some of the issues that are being raised So we're doing more training. This is one way to help us to ensure that inspectors For our purposes, but also licensed reviewers leak or lawyers and others that are involved in backfitting issues to understand what backfitting is to recognize when you're in a backfitting situation how to deal with it and So the training is the big thing. I really like the commissioner burns this morning Kind of answered this question And and and he said and I agree I think we all agree it really starts at the top It starts with the Commission now the CRG are was not bold enough in its report to say that the Commission needed to do more And I don't think we thought they did they're doing doing plenty in the area backfitting But we did identify the senior leadership Which would include us here and above And we need to do more so me personally as a regional administrator. I'm putting a focus I'm new to region three, but I went in with a Concept or an idea or a priority of putting more emphasis on backfitting and our inspectors understanding backfitting Working with my senior leadership team Ken O'Brien is here one of my division directors To make that a focus for the region. We have an SES champion in the region. It's helping with backfitting So I think that will help but it's going to take time. I've seen at least two issues since I've been in the region for three four months Where I think our inspector did not identify or recognize it was a backfit situation and and Actually, I've been getting involved in those those types of issues take up time to kind of sort out later That's one reason to try and get it right from the start. So that's In a nutshell what we're doing. Also, I know There is a backfitting CRG errors having a session tomorrow morning 10 30 on this whole thing I just talked about what they did and what the agency is doing except you need more detail on that. It's probably interesting You might want to tune into that tomorrow 8 10 30 to noon All right, so Sam or Dan to what extent do you believe this is an issue and What can or should licensees do to preclude or help resolve such issues? Well, I'll go ahead and start and Dan can fill in the gaps. I do think it's an issue And I think it's a big issue and I think Steve did a really nice job of characterizing it And I would probably characterize it the same way a lot of times we find an inspector on an inspection or review Finds an issue that either challenges the original assumptions or tries to take us to a Contemporary standard or branch technical position that we weren't originally licensed to you know from a from an industry Perspective that can be very costly and very challenging and time-consuming So, you know if we just recognize we are in a backfitting situation and call it what it is and go through that process That's that's I think what we all want to do and a lot of times I think we end up debating over whether or not we are in a backfitting situation You know, I know the rugs are doing a lot of work, you know, what can industry do to help? I know the rugs are doing a lot of work and talking about Areas or issues that are coming up that they think may be potential backfitting to make sure that the right level of awareness is out There I also think one of the things that we can do is elevate it very quickly on both sides You know if we think it's a backfitting issue at a particular utility We need to take that up have those discussions at a higher level and we need to communicate at that same level with the Nuclear Regulatory Commission in the region to say hey, we think we're here Maybe you don't let's let's at least open the dialogue before we get way down this process I didn't start trying to come backwards, so then I don't know if you anything you want to add now Just just a couple things and I think you hit it real real well Sam We have we've had some issues come up during the course of inspections where Inspectors will try to inspect us to newer as you said newer design requirements and without having a good understanding of the Way our plants may have been licensed in the time that they were they were licensed But we have been successful in working through those those issues during the course of an inspection although It does take certainly takes some time What we can do to help manage that is you know first and foremost We need to have a good understanding of our own design and licensing basis And then we need to talk about through the inspection process in terms of facts and then as Sam said Elevated I'll take this and I'll be brief with this one slight twist on this It's really not so much in the back fit area But where we have seen challenges that we have not been able to effectively work through During the inspection is is in in the area of testing requirements where we have test programs ISI programs IST programs testing requirements that have been established Based on the design and license of the plant reviewed inspected multiple times and a new inspector comes in with Perhaps a different opinion and a different view point on that and we have had to then modify our program and modify our testing requirements We had to get to the point where we would agree to disagree and you know how that works out and then and then Move forward the cost of those changes was not significant for us So it you know wasn't worth going through a lengthy appeal process, but it is well not strictly a back fit It is a similar type issue. That's why I want to bring it up Alright, thank you. Anyone else want to weigh in Okay, good. So I want to just pick up on an issue or actually where Dan you left off just now So in in this question relates to the circumstance where licensees and the NRC ultimately don't agree with the outcome And and so the question really focuses on appeals and the appeal process. So there there is a perception that the number of appeals of of Green and greater than green violations is on the increase The there is also a perception that the number of NRC denials of appeals Is on the increase? And so I want to start off with a question first for the industry What are your perspectives regarding the violation appeal process? For examples, it's its effectiveness and its fairness And then what does your organization consider in reaching a decision to formally appeal for example a green or a greater than a green NCV so starting with the industry. Yeah, I'll start off with that and then and then Sam can pick up We have not Worked through the appeal process and in quite some time Generally, that's because we've found that most all the findings are very legitimate in couple cases or a few cases where Once again, we had to agree to disagree We evaluated that it was not worth the worth the Worth the effort the regulatory capital to appeal because the fixes were pretty simple and not very impactful to us and not Generic to the to the industry which kind of gets to the decision-making process and whether we would appeal a finding or not You know first first and foremost if you're going to appeal you have to be confident that you're right You have to have a good basis for understanding why you believe that that you are correct Then the appeal the the value of the appeal has to be of a successful appeal Has to be greater than what it would take to just accept the finding and move on There's no point in fighting something that has no benefit To to winning and then the really the third consideration is Is is this something that would have a generic implication or a broader implications into just a particular station? Or just a particular utility could this be an industry issue? In which case you have to understand that your peers have a stake in it as well and then make your decision based on that Yeah, I think the only thing I would add you know as far as a step up a number of appeals I think that was the opening opening comment Michael. I think maybe that is in fact a reality I think you know as as the industry looks at more and more cost looks at more and more challenges to the business They're looking at everything they can do to save money and that could include additional appeals I agree with Dan completely as far as you know what goes into the thought of an appeal Is it an industry-wide issue is a precedent setting? But you know a lot of times I think when we find ourselves on an appeal It's not so much appealing of the issue it may be appealing of the significance of the issue And you know things that are clearly white or clearly white things that are clearly green or clearly clearly green But a lot of times we find ourselves right at that threshold And you know I think we spend a lot of time talking about your spar model our PRA model Which one's more accurate which one has the the right inputs in it? You know and it feels to me like you know rather than get to the appeal process if we do that work up front and we make sure we have the right inputs going into the models and We get the same result coming out the appeal or the likelihood of an appeal I think goes down tremendously You know one thing on my challenge since I threw out the spar model is why do you even have that anymore? You know I've thought about that quite a bit that you know our PRAs are pretty robust. They've been Approved they've been reviewed and you know many times we find that our PRAs are better than the spar models So just a just a thought moving forward second All right, so we may come back to that last comment in the panel Dave why don't you take on the topic of appeals and just Regarding the the the opening perception that I threw out has there been an increase in the number of appeals of green and greater than green findings a Little bit about how the appeal process works and and also how do you wish ensure that the appeal process meets its objectives? Thanks Mike. Well, let me actually start with Changing the orders like I'll answer the first question last but relative to How does the appeal process work? You know the the the process for handling an appeal is described in our NRC's enforcement manual We also have the inspection manual chapter 0609 which is our significant determination process as well as regional instructions and the goal for completing These reviews is typically 30 days for escalated enforcement actions and 90 days for non escalated enforcement actions Process wise for escalated actions. There's typically a review panel that's prescribed Although we also elect to do panels for non escalated issues, particularly if they have brought impact and significance And and regardless of whether the issue is escalate or non escalated The approach for the review should have an element of independence And the approval of the appeal determination should be an appropriate level of management Often is usually at a higher level of management, but not always The other question was how do you ensure that the appeal process achieves its objectives? I think it's important to first define what the objective is And and I think the objective of any appeal process is to ensure that there is a good faith effort in conducting a fair appeal And I think that's achieving a large part because due to a degree of independence that I've mentioned before but also that that allows the reviewers to be Successful in fully considering the merits on both sides of the arguments to have some level of independence And so I will share with you a regional one example of a green finding that was appeal Even before the issue was Appealed we understood from the licensee that they would disagree and and this is normal through the inspection activity through the exit meeting We understand when the licensee is Planning to appeal and given the broader implications of this particular finding We had extensive internal discussions and this includes not just the regional inspectors But includes the division management from both divisions divisions of reactive safety in the vision of active projects Included regional ministry in the deputy regional ministry. So we gave a strong vetting before we actually issued the Finding ultimately we support the finding and we had the branch chief issue the report that documented finding When this was formally appealed we convened a very experienced panel I will say that we had the folks in the region that were independent If not, we probably would have looked outside of the region But we had a division director who was very steep in the reactive oversight process as well some very experienced folks They they convened the panel they interviewed a lot of folks and they recommended withdrawal of the finding And I think that reflects the independence of the finding that this faith ever even though that even though the regional Administrator and the deputy regional administrator for that finding had already weighed in So coming back to the first question. Has there been an increase in the number of appeals of green and greater than green findings? And the answer is maybe You know with respect to formal appeals We really have not seen a significant trend statistically significant trend in the data from 2012 to 2017 And if we're not an escalator actions the NRC has received that told maybe about 10 findings per year And denied roughly 75% of those findings With respect to escalated actions there has been only about four appeals over that six-year period Although two of them were in 2017 I think too early to say whether there is a statistical significant trend at this point However, I think there is a perception that That licensees are raising more concerns about the validity of the findings there and I think that may be true for during the during the inspection process itself and Often it's part of the inspection process where issues are raised that may be happening more frequently but I think the you know These issues are being part of the normal process and having that engagement and healthy communications often Licensees providing new information, you know, sometimes inspectors You know providing some insights in terms of the regulation that gets resolved and I think that's a Probably testament to the inspection process and the good communications that occur that you don't actually see That increase in actual formal appeals at least not to date Thank you, Dave. I do want to go back to the question or the the issue that that I think Sam use you raised towards the end of your comment about the spar model and and about the about our Licensees PRA and I just I know I Haven't given you guys time to think about this, but I am curious regional administrators What do you see as as driving some of the differences not in whether or not there's a finding what the significance of the finding and and would for example? What would you think of the idea of using? Licensees PRAs in lieu of spire models in terms of Determining the significance and do you see that as a way to get around some of the differences that we have? Anyone can start with that. I'll start. I think just one thought one of the fundamental premise going into the Significance determination process with it was that the NRC had an independent tool to do our own risk assessment and so that's really why we have the spar model is to So that we can take the set theoretically the same information the same assumptions put it into a model and Come out with a result that's independent of the licensees risk model And then compare the two and are there different ways to do it? I think there are but that's fundamentally that the premise of the risk assessment oftentimes we see The differences in the assumptions That actually going it's not necessarily a model thing. It's an assumption. It's the assumptions that make the difference So I would I would agree with you as well many times It is in fact the assumptions or quite frankly the inputs that we put into the model that results in a differing outcome I just think you know as we've evolved over time and spent so much effort and energy And you've spent so much effort and energy making sure our PRA models are accurate. They're up to date They're properly maintained. It seems like you know, I get understand the independent side of it But it just seems like it's a lot of redundant work on your side for something that you could independently verify as accurate Without without all the effort on your side I will offer that there is value for independent model I think often when we start getting into some of these issues We do see different outcomes out of the two different models And I think it's important for us to understand as an independent regulator to have a tool to independently verify The model because a lot of these models. Yeah, they're assumptions. They're very subtle differences in system Interactions or how a particular component is designed which sometimes makes a huge difference I will also add that I think part of the issue that we tend to have a lot of discussion on is beyond the models is you know common cause and and I think there is certainly a Valid points on both sides of the discussion But I think what's more important is for us to have an established process moving forward in terms of how we approach it because Without having some standardization in terms of the process and how we do it Then we're going to have will be subject to inconsistency And that would not in my opinion be good regulation I would just add some of the strengths of the process though as the discussions that are taking place between the industry staff and then the well in my case the regional Staff about what those differences are and and most of them do surround the assumptions But I would say the couple cases that we've had in in region two over the past couple of years It's really been the reflection from both sides how the benefit of those discussions and ultimately coming out I think with in the It in a but using an informed process to get to the answer You know we looked at the we looked at this exact question in two years ago and the NRC is risk-informed steering committee, which is chaired by the director of NRR And the industry risk-informed steering committee chaired by NEI Asked that exact question and it was assessed and discussed for about a year And I think the it did boil down largely to independence this desire on our part to have that independence and then also there was the the cost aspects and all the complications was sharing something that complicated between organizations and But but under our current process, but but we weren't being transformative then so maybe it's a good question Maybe it's a good question to re-ask so it is a good question So Maybe in that light it would be something worth taking on another peek at but I think the way our process works. We're basically Sharing results and comparing them and and oftentimes I think our our answer or our final decision Can be changed by what we're getting from a site using their plan specific information Does does does work, but but I think in theory it's a great idea, but in practice we just couldn't overcome some of our Regulatory angst it just went just one quick thing to add to that You know one thing that we found that very effective and Kathy talked about this is working together Get our PRA analysts with the region's PRA analysts and working together very early in the process and communicating effectively and Generally, we have found we get that that's where we get to very very similar results once we get a common understanding Okay, I want to switch topics now and talk about delivering the nuclear promise for a few minutes potentially cap to So I have a card that that ask about delivering the nuclear promise And so I would pose the question in this way first for the NRC Noting that the industry has implemented many of the delivering the nuclear promise initiatives How has delivering the nuclear promise been received by inspectors? Have you seen any significant trends or examples of negative or positive with respect to performance of licensees and and what guidance are we giving? Inspectors regarding Implementation or their oversight of implementation of delivering the nuclear promise So Kathy we'll start with you and then I'll pose questions for the next thanks So from the standpoint of what what the inspectors are seeing and and how we're training and I think the I'll start out with you know from from early on in the process the communication between NEI and industry and the inspectors and then Understanding what what the goals of delivering the nuclear promise were How you were going to get there? and then continuing into what the changes are and that Significant communication up front. I think was was definitely If you want to call it a best practice or something very good because it aided us in our ability to get the message Down to the staff and to our inspectors about route again what the goals were It was you know still the intent to maintain the safety of the plants and then as the process was implemented being Implemented the interactions that were taking place at the site level with regards to keeping the resident inspectors as well as the Inspectors that were coming from the region informed of what the changes were and having that early dialogue to say You know we're still in compliance with our license Where we're not getting into a situation where we're reducing safety to the point that you were Getting into say an enforcement area and just that constant exchange back and forth and ongoing I think really helped to make things go very smoothly From our perspective now with that being said I would say that really the inspectors are not you know from from my standpoint What I've heard in the in region too as well as I think it'll be supported by the other regions is we're not really seeing any significant issues arising as any of the changes that are coming about as part of Delivering the nuclear promise or anything of the bulletins that would go out so I would say and even as we're moving into the the cap to changes that Plants are at various levels as far as What they're in the implementation stages or what they plan to implement or the fact that they they feel that Their programs are adequate already again. It's that dialogue back and forth that I can't Under emphasize how much that that's really important that the inspectors see and understand and it's that Understanding what what industry is planning to do it at the licensee level what they're planning to do So if we do have changes at questions, we can ask those questions up front And then have that that shared understanding of where you're going. So so really from our perspective That's a long way of saying I think things are going smoothly and the inspectors are not really identifying any issues And from the industry perspective Do you think delivering the nuclear promise is doing what it's intended to do and and what challenges? Did you face or do you face in continuing implementation? Let me just let me start off on that and I'll start off Broadly with a couple things on delivering the nuclear promise and then maybe get a little more specific first off the The overall thrust of the of the initiative is to become more efficient and certainly as a result of becoming more efficient Become more cost-effective But you know Kathy talked about maintaining safety, but but I would argue and we have seen this in practice Where we get more efficient and where we stop spending time and energy and resources on things that don't enhance safety and Reliability that allows us to spend time energy and resources more time energy and resources on those things that do have the greatest Tied to safety so it makes us more efficient and I would argue and I have seen this I think in the performance of my own fleet is It makes us it contributes to greater safety and greater reliability and we've seen that we've seen that in practice The second thing generically is we are as I know the you know the inspectors are when they are out We are very sensitive to unintended Consequences and we continually monitor unintended consequences through our our self assessment processes and our corrective action Programs and our and our trending we have not seen issues with communications with with inspectors where Issues come up and changes come up I think that's been the good communication that we've had back and forth between the industry And the and the NRC staff and the inspectors. I think have been very helpful Cap to corrective action program being so fundamental to our business and so fundamental to the regulatory process As we embark on that and as we implement those changes That's one where we are going to have to continue to have that good Communication that good internal self assessment process and that good awareness of potential unintended consequences Because there's that that's just an area that there's going to be a lot of sensitivity to and we need to we need to Communicate very very well on that process going forward Yeah, I might add a couple couple points there and maybe just a fine tune a couple points Kathy, thank you for your comment on that You're not seeing a lot of issues because one of the one of the tenants going into this was first in alarm And it was a tremendous amount of change management that took place on each one of the efficiency bulletins to make sure we really understood the Change and understood what if any potential consequences were out there and and I agree with you completely as far as the Communication, you know, we should make that a model for how we do business moving forward in all areas If we're doing something different as an industry or you're doing something different that we get the right people together talking As we go through it rather than wait until we're finished, you know Michael I think I think the beginning of your question is did the do did delivering a nuclear promise do what we intended it to do And I would say that it has now You know, we can talk about dollars saved or hours saved or man man weeks or woman weeks or whatever We want to talk about but you know, many of us are in very challenging financial situations right now And we're asking for help from elected officials We're going to state and federal governments and asking for some help to keep our nuclear plants operating for the long term And quite frankly we would not have had much of a case to go and make that ask if we hadn't done everything that we Could do to clean up our own house before we wouldn't make that ask So, you know, we can debate how much was saved or we can debate You know, did we move fast enough or far enough? But I think we we did look at ourselves very critically We tried to get everything that was inefficient out of our business And once we did that then we felt a little more comfortable standing up in front of Congress saying hey We need to do something to save these nuclear plants Okay, thank you very good. I want to switch now and talk a little bit more about Significance determination and the the STP And so the context goes the NRC's recently implemented STP time in its metrics and the inspection finding review board in many cases the NRC and industry have expended Considerable time and effort on potential greater than green issues Only to determine that the issue is a very low safety significance or green as result the NRC and licensees have had to divert resources to significance determination For those issues where resources could have been better spent focusing on corrective actions, which licensees would have implemented anyway That's so that's the context of the question. And so I'm going to ask Chris for you to start Have changes that were made Resulted in improvements to the efficiency and the effectiveness of the inspection and significance determination process and have they resulted in Approved ability to focus on performance deficiencies Commensurate with their safety importance and then I'll pose a similar question to the industry. Okay. Thanks for the question so the inspection finding review board is part of another process, so that's IFRB and the other process is the inspection finding resources Resolution management process So we have the IFRB and the IFRM and those acronyms are often Confused, but I wanted to read to you what the objective of the inspection finding review board Is the first one is to ensure regional management and staff align on the licensee performance Deficiency the degraded condition and how the performance deficiency is approximate cause of the degraded condition to That to ensure there's early alignment on the scope schedule Scope schedule and involved resources to support an efficient and effective preliminary significance assessment Potentially greater than green inspection findings and then third provide a mechanism to effectively communicate with senior senior licensee management the inspection finding Support needed from their staff in reaching the preliminary assessment decision and the appropriate time frame to provide information So those are the objectives of the inspection findings review board and so this was Concept came up in 2016 we did a pilot in 2017 and I have to admit I kind of came in kicking and screaming Because I know you can't relate to this but a new requirement was being imposed on the regions And I know NR would say it wasn't a requirement. It was a guidance But and that is this concept of 120-day metric and so the whole the whole idea was how can we get from issue to final decision in in a shorter period of time we were going way too long and and Making a decision a final determination on an issue From the time that it actually occurred and so we were looking at a way to shorten that time so the overall process is not terribly different than the Process that we had before where we documented and agreed on what the finding was identified the performance Deficiency was it was there a violation involved and then what was the schedule and plan? For moving forward, but the change in the process which was piloted last year added 120-day metric And that's 120 days from essentially when the event occurred or when it was identified until we issued the inspection report And at first blush it's like I said it's like well here's another Requirement being placed on us and someone pointed out to me, and I've used this on the I use this on the site VPs at a couple of meetings right after that. We're talking about a third of a year You know a third of a year to get from the the issue happens until we Document it in an inspection report, and I think that that sounded a little more reasonable to me so so What happens is this the in region four anyway every week We we talk about enforcement and allegations and at the end of that The division rector projects Troy Pruitt and his group Asked he asked his branch chiefs and Tony Vagle asked his branch chiefs Are there any issues that are potentially great greater than green and these are issues in the initiating events mitigating quarter stones and barrier integrity And the branch chiefs will talk about issues that have come up and after some initial screening Where they can't screen them out immediately as green they will go on a list and that list Essentially starts our hundred and twenty day clock and from that point on we start talking about it every week And until it comes off or until it move moves forward And so that's that's the way the process works in region four So we ran this for about a year. Well, the the concept was to pilot it for about a year. That's 2017 NRR is taking a look at assessing the effectiveness of that process and Early results of the review of that process indicate that it did improve has improved the Performance in the timeliness of issuing greater than green inspection findings that it's improved communications with licensees regarding potentially greater than green performance Deficiencies and improved our internal organizational focus and alignment on potentially greater than green Deficiencies, so I think there's more to come from our effectiveness or from the effectiveness review that NRR is Conducting, but I can tell you from my perspective it it definitely focuses us on on the emergent issues and The initial pushback was well, you know, we we now have to repuradize reprioritize our resources to take a look at these issues and I heard the same thing from industry and That may be a good thing in some cases You might look at it as it kind of gets all of our attention on the issue up front And then we either take it off the table as a potentially greater than green or If it is greater than green then we're going to all focus our attention on it and also think the improvement in communications is a significant Item for me personally. I think the earlier we talked a little bit about it earlier the earlier that our Risk analysts start talking to each other on an issue understanding the differences starting to work on on the independent models, I think the quicker we get to An answer so that's all right. Thank you Chris and for the industry What can licensees do to help the process of arriving at a reasonable STP result? Such that time and resources spent are commensurate with the significance of the performance efficiency You know, I'll start and then and you can weigh in afterwards Before I do Chris, I just want to say thank you for admitting that you go kicking and screaming every time There's new regulations or requirements imposed on you just like we do so that was that was actually good to hear You know is I think about what can we do to help? Let me start with I think the 120-day thing is generally good. I think it does as Chris said focus us on what may be important and get us to Put the resources necessary to get to the right answer I just would caution all of us that 120 days I think is important but getting the right answer is more important and in some cases the right answer may take longer than 120 days That that being said as I think if we look at each issue with very open communication and a line on what resources are Going to be required to truly make that significance determination early on in the process You know, not only your resources, but our resources as well I agree on you know, we said this earlier what inputs what assumptions are we putting into either the PRA models or the Spar models make sure that we all have the Understanding of the event that's consistent because I think a lot of times we go into The beginning phases of one of these issues and we look at it and we have a view of the world And you may look at it to have a slightly different view of the world both of which may not be completely accurate You know when we get together and we have those discussions, and I think a lot of times we come to okay. This is what happened Or this is what the true issue is I think that the Continuing dialogue as we go through this process is important as well now I know at some point, you know, you guys are going to be in the pre-decisional phase And you're not going to be allowed to or want to communicate that and I understand why that exists But as much communication as we have or can't have along the process I think makes all the difference in the world and then You know as you prepare for the IFRB, you know being sort of a new View of the world, you know It might be helpful to get license the input on what you might be taking to the IFRB Just to make sure that all the facts are there and you have everything you need to make the decision that you're ultimately And I don't know if you wanted to weigh in Thanks, Sam You brought up a great point that I should have mentioned it so the 120-day metric has Scott Morris tells me reminds me It's just a it's a guideline. And so you're absolutely right. We want to get the right answer What the 120-day metric forces us to do is to make that Decision deliberately so we will make a deliberate decision that We you know despite our best efforts We're gonna need more time to work on an issue and we will take that time and we We've obviously in region 4 anyway demonstrated that we'll take that time to go beyond the 120 days to get to the right answer So thanks. Thanks for that point. Thank you All right, Chris, we're gonna get you a question on a 95 double o one That I told you I wouldn't ask unless it came from the floor But before we do I'm gonna give you a chance to rest and that Kathy or Steve actually talk about environmental qualification You know, there's been a lot of conversation of late about our environmental qualification inspections and and concerns I think on some folks minds about whether or not those inspections will generate improper backfits and so I want to start Steve with a question for you. Why on earth? Is the NRC inspecting EQ at this time and what's the NRC doing to ensure? EQ inspections don't result in a backfitt and then I'm gonna turn to the industry and ask you to what extent you believe EQ inspections are necessary and what are your concerns regarding their implementation? So Steve, please start I want to say that I have no earthly idea, but that would just be a joke I told you I wouldn't tell any jokes today Why are we doing EQ inspections at this time? Well, there's a number of reasons why we're doing EQ inspections at this time and kind of if you're just thinking about the the engineering aspects and and plan operations and plan aging and the need to have safety safety systems that are available to respond to Accidents and events Components that are environmentally qualified are important to the operation safe operation of plans, especially on design basis conditions and vents So they need to withstand events their last structured really focused NRC inspections of these EQ EQ components was probably in the 80s I'm sure some have been touched on since then but there hasn't been a focused effort The equipment is is aging Equipment has been changed systems have been changed Many probably without NRC inspection. Let's say we're picked up on a You know one of our routine inspections that would look at a plant mod or something like that So that is that is one reason we would want to do inspections of EQ at this time But actually looking at the at EQ has been on the NRC's Wishlist kind of for for a number of years a bit a number of Reports issued by the NRC where the need to look at EQ has been mentioned and One going back to 2002 as a Davis-Bessie lessons are in report that the the agency wrote and in that report For example, we said that there's probably people in this room that were involved in that looking around But in that report one of the things we assessed and made recommendations about was taking a look at Safe generic issues that had been resolved and and completed by completed by the plants and Actually so following the issuance of that report We did take a look at the number of the safety issues One paper we looked at what was out there and we looked at about 20 20 generic issues And the EQ was one that rose to the top as something the NRC should should take a look at at some point in time So that goes back to 2002 There was also a Brown's fairy lessons learned report that also mentioned it discussed more the Need to continue to do engineering inspections and what but EQ was identified as one of the Significant engineering programs that should be looked at so in 2015 when we were looking at our engineering inspections and we were making some changes EQ was kind of mentioned as hey here's something we keep talking about we ought to take a look at but we haven't done it yet So this is a good opportunity to do it It's a focused inspection in an engineering area That's what we're looking for it would be a good pilot to do for the engineering inspections and actually I think this is going to be The results of this effort are being considered By the team that's still further looking at how we're going to do engineering inspections in the future Unfortunately, there's a session on that this week. I think too I don't know if it's happened yet. Does anybody know it has not it's Thursday Thursday Okay, so if you're interested in the engineering inspections, you can get a lot more out of that but that's why we're looking at EQ now and I'm in talking with My branch chief in region three who has responsibility for these inspections I The feedback I get is are being pretty well received in the region Certainly at the the engineering inspector engineering counterpart at the site good interaction Finding some things Usually things that you know that haven't been found but by the site because they're not they're not looking for them We're out there just to look for them. So we do find things But I think they're going pretty well and he tells me things are going pretty well in the other regions too But I won't speak for them. So I Don't think any backfitting issues have come up in the at least in region three Haven't heard of any in the other but I kind of addressed earlier what we're doing just to head off backfitting issues coming up in during inspections and being inappropriately inappropriately Imposing a backfitt on on a licensee when we find something when an inspector finds something he may not like that's been previously approved That's an ongoing effort. I mean, I think that's something as the as Commissioner burn said today. It's continuous I mean, there's no beginning and end although we're certainly in a in a period where we're trying to train inspectors better and have managers more involved To try and catch those things Kind of success for me will be not when an inspector thinks there's a backfitting issue because the licensee says you're backfitting me It's when he recognizes that there's a potential backfitting issue because the licensee says I think that's been approved by the NRC already aren't asking me to do something different so the backfitted word is never used But the engineer the inspector makes the connection between what he's being told and what documentation he's given and said Oh, this could be a back fit if I pursue this so Like I said an ongoing effort I wanted to just take this opportunity Sam mentioned a couple of times actually but when he was talking about The industry Perspectives on backfitting something I should have said because I'm a firm believer in it also as the communications is is really the key not only to try and take to Get the proper focus on a potential backfitting issue or other inspection issues but many other issues that industry and the NRC deal with and in the in my short time in the region and in the in the meetings I've had with the Site and corporate leadership for this for the sites there We talk about communications and commit to one another to make sure we have good communications channels open at the various levels Doesn't mean that I get called every time there's a problem, but I'm available if if the problem Escalates to that reason, but I think communications is really a big piece of this Internally and between internal and external All right, thank you Steve and for Sam or Dan to what extent do you believe EQ inspections are necessary and What concerns do you have regarding EQ? And their implementation I would say generally you know if an important program hasn't been looked at in a while It's probably worth giving it a look The question comes in is is that a standalone focused inspection or is that something they can be rolled into another and as part of another Inspection to do it in the most efficient way possible that would be that the challenge that I would have there We have not seen issues with Backfit or really real Real major issues in the EQ looks that we have received the one challenge that I think is out there It's a potential challenge And I think it has been seen in some places as and you may have alluded to this earlier Steve is where there's a a Request for documentation of bases for a program that was created at some point in time it had adequate technical basis at the time and now You have an inspector who's asking for another level of rigor another level of technical basis that Would require significant effort on the part of a licensee to go Recreate those bases that I think is the there's the greatest potential challenge out there And I don't have specific examples, but I have heard there at least been some of those discussions Yeah, the only I guess a couple of things I would add to it to This may be an opportunity as we look at how we look at engineering overall. Is this a candidate for self-assessment? I agree with with Dan if a program hasn't been looked at something as important as environmental qualification It should be looked at is that something we do our self-assessment on a new review, you know Something to consider I would chime in we do self-assess these programs ourselves No, no, no, I was just saying maybe we can use that self-assessment as the overall inspection vehicle You know the what what concerns do we have or what concerns? Do I think about when we start looking at something that we haven't looked at in some period of time? And that's the that that whole new interpretation of existing standards discussion that we had earlier where new people are in maybe that don't have the Organizational history or the the years in the saddle if you will and they look at something differently And then we're in a debate over how do you interpret this or how do you interpret that and you know? Usually we're able to sort those things out, but that's time and resources for both of us when we go down that path Also, you know we I think I think this is one of the area where you use some contract resources to come in and help And that just compounds that problem even more where the organizational history doesn't exist You know the final thought I would add is you know then I think said it is you know We see this as potentially becoming a resource intensive And if we can find a way to meet the objective and do a good solid review of the program and not have it be resource Intensive I think that would be well received Okay, did you guys want to weigh in Steve? See you reaching for the mice. Go ahead. Please. I'm just gonna say one thing real quick. We we are considering self-assessments as a Way to do Contribute to the engineering inspections in the future and I think if I'm not gonna get into it here But I think if you go to that session on the inspection engineering inspections later this week They're gonna talk about how that could be a contributor, so it's it's on active consideration. Thank you, Steve. I Just want to touch on Dan's comment about is there in a more efficient way to have done this inspection now I think that's a good challenge for us to think about whether there was a more efficient way That said I think this is one of those areas that we haven't looked at in a long time and having a pro You know having the the approach that we took we also include a significant training of inspectors to understand what the Requirements are and and what the objectives are and I think in the long run having that Having that approach does provide for efficiency We have to be careful in terms of trying to roll things in Without that training and and a standard approach across all the regions and and I think as a result We I believe we did add a lot of value. You know this is one of those issues where I think we've identified a Couple of issues that could have been significant because the process Did not capture it and this is one of those areas that you know the process is Important because you don't test this equipment under accident conditions There's not a lot operating experience in terms of failures as a result of VQ as a result So this is unique in that way and and I think in us adding value. I think there was also You know where we saw the knowledge Knowledge gap even amongst licensees need to be brought up to a certain level Okay, everyone's nodding. That was a good answer, right? Yeah So there are a couple of questions that relate to a consistency across the region. I think I'm gonna pose this Chris give you a start on 95001 And the question reads there been several discussions regarding differences and supplemental inspections between the regions What has been learned? regarding potential causes and actions to address this again the difference in Thresholds maybe or or the way in which we approach goes out of 95001 inspections and and just following up on the EQ inspections There's a similar sort of a theme about URIs have been identified in region 2 for example Not so much in the other regions. And so again We touched on EQ. I want to touch a little bit more on consistency, but Chris would just start with 95001 Sure. Thanks Mike so With respect to 95001s, I think you know, we always oftentimes talk about Disagreements or areas of difference between industry and the NRC, but we actually have a lot of areas Where we have the same goal and I think I thought about this recently in 95001 inspections We all have the same goal. We want licensees to succeed in their 95001 inspections because it means they identified the causes Extended condition extent of cause and and took the adequate corrective actions Industry wants that and we want it and we also recognize that there are there's a lot of work that goes into preparations for 95001 inspections 95 all all of the supplemental inspections and And that they are good faith efforts to do well on those so our experience in region for before I get to that out if you if you look at the 95001 inspection procedure and it it lays out the objectives fairly clearly and that is The inspectors are going out to assure that the root causes and contributing causes of significant performance deficiencies are understood independently assess and assure that the extent of condition and extent of cause of significant performance like issues are identified To assure that correct that the corrective actions taken to address and preclude repetition of significant performance issues are prompt and effective and Fourth to assure that corrective action plans direct prompt actions to effectively address and preclude repetition of Significant performance issues, so that's what the inspectors are tasked with when they when they go out and The objectives and the inspection requirements and and even methods are described in the 95001 inspection procedure so I think where And so it's laid out. I think fairly clearly. I think where my experience where we have Run into issues where inspectors go out and they're looking at all the documentation To inspect against these objectives. I Think two areas in region for where where we've identified the most issues The first is in the root cause analysis and the procedure kind of lays out six or seven different Methodologies that could be used in determining the root cause of the issue, but there's a section in here that It talks about the root cause and it says The root cause evaluation should be conducted to a level of detail that is adequate for the significance of the problem That's kind of obvious Then it goes on to say that The depth of a root cause evaluation is normally achieved by completely and systematically applying the methods of analysis described in the previous section and by repeatedly asking The question why about the occurrences and circumstances that caused or contributed to the problem And then it goes on to say Determining that the questioning process or the depth of the root cause evaluation may be assessed by Determining that the questioning process appeared to have been conducted until the causes were beyond the licensees control So I think that's that's what they're going out and inspecting against until The causes have We're beyond the licensees control That's one of the hangups that the hiccups that we see is that we'll go out and we'll review root cause Evaluations that haven't gone that far and just kind of general example if There like we might write a violation about an inadequate maintenance procedure and In one instance we saw that the root cause was an inadequate maintenance procedure So the root cause essentially was the violation So what we're really looking for and they were contributing causes. So don't I mean, it's not That's simple. They were contributing causes identified But the inspectors go on site and they say well, they asked the obvious why question. Why was your maintenance procedure? inadequate and so those are the kinds of things they're looking for and when they don't kind of see that Then they probe further and if they're not satisfied in there, you know when they dig down deep then they Can make a determination that it's a kind of a significant weakness that was identified and The objective of the inspection procedure was not met If you don't have an adequate root cause evaluation then essentially that Very much drives extent of cause extent of condition and your corrective actions because if you haven't identified The root cause then it's not clear that the corrective actions are complete An adequate and then the second area that we've seen Problems in as objective to objective number two and that's the extent of cause and extent of condition So it's not we don't take it lightly when an inspector comes back and says, you know identified some significant weaknesses in my inspection and Either makes you know makes a recommendation or a proposal that we maintain the finding open and Determine that the objectives of the 95 double o one weren't met and that gets all as Dave talked about previously in They was denied at violations. This gets a lot of attention and so the division directors branch chiefs division directors and Scott and I review it And the inspectors make their case as to why they don't think the objectives were met and then we move forward so that's we can Agree or disagree on whether the 95 double o one guidance should be worded the way it is But a sense that's what the inspectors are inspecting Against I'll just hit on the EQ question and unresolved items. I don't know why well on the 95 double ones. I can't speak to how the other regions do That can conduct their 95 double ones. They're using the same guidance So I know I'm confident that they're implementing the 95 double one procedure and in the same matter that region four is And similarly with the EQ inspections, I can't explain why there might be differences between The regions and the EQ findings as I recall there haven't been a there were like 12 findings coming out of 12 total inspections And so not a lot of not a lot of findings. I think unresolved items are actually good It means that the inspectors have a question that they can't answer and they're seeking Additional help in getting the answer. So I think that's a good thing. I wouldn't make I wouldn't I don't The number of unresolved items doesn't have much significance to me I think it's a good thing the inspectors are going to try and get their get the right answer Okay, so let me go to the other RA is any differences between you and what you would say and Chris's answer on 95 double one Yeah, I would just add I believe and then correct me if I'm wrong I believe that there is going to be an ongoing effort within the NRC to take a look at 95001 consistency and I think that's a good thing because even though you can read the guidance There's always the interpretation of that guidance in terms of How much you know, what's reasonable and I think that's going to be something which this review will look at Okay, I've got a number of follow-up questions as well Actually, I was gonna wait till the end to ask these Sort of to try to get a quick answer to these but let me just ask you on the EQ and Inspection findings. Have there been any greater than green EQ findings to your knowledge anyone? I Don't believe that has been I did reference that there was a couple of Value-added issues that were identified at region one plants in which I believe That if it had continued for some time if not for the NRC inspectors identifying the issue I Think of extended in question the operability of some of the equipment, you know safe important equipment as safety relief valve Auxiliary feed or the pump and so it's hard to judge just simply by the lack of Greater than green that there was not significant value added Okay, so I just thank you Dave as a second part of that question and I'll it ask if there are no greater than green findings Is the Jews worth the squeeze sort of and I think I think you would yes I knew you would say that Okay for the regional administrators what level of frequency of communications do you specifically want from utilities? Please answer with respect to routine and issue-driven communication, so I'll let you answer in any order what? What frequency and level of communications do you specifically want from utilities? Please answer with respect to routine and issue-driven communications I can start first So so you know what we you know certainly I think the more communications the better you know we we Would like good communications with senior residents on the periodic basis with the plant manager and frequently with the site vice-president I Know that our brass chief to have a pretty high conversations as well We we do have joint division director Telecons telephone conferences both the art division of reactor project and the vision of reactor safety And they try and reach out periodically about once a month To ensure that communications are working well with with the licensees not all licensees have participated at this point We we do have a vast majority and we'll continue to Try and facilitate that communications And you know certainly you know we I do want to have Issues raised up through us, you know in terms of any significant concerns particularly those areas that have broad implications you know our goal is safety and Certainly we're going down the path that is not in the interest of safety That's certainly something that we want to know and make sure that we're not having that unintended consequence So from my perspective probably very similar to what Dave said as far as the frequency Obviously the issue-driven communication is really specific to the issue There have been cases where I've had weekly calls and then you know They'll taper off to quarterly and then semi-annual so I think it's it's hard to say specifically what it is but You know if there's a reason to to call on an issue if something's changing if there's an update Pick up the phone, you know call us from that standpoint. I also From the Dave address really the division director and the branch chief level But from the from my perspective in the front office I think those routine calls are just as important because it allows us to to keep that open Channel of communication, so I would encourage that you know as far as a frequency again. I think it's really at site specific So I'm not going to put out there Specificity because then everybody will be writing it down and say oh she just put a new requirement on me So I'm not going to do that But I would say at least the frequency that I hear from the plants in region two at my level is working Did I just back fit folks? Let's see I think for my inspectors and branch chiefs and Senior leadership team it's pretty much what what Dave mentioned For myself I have agreements with With senior leaders in my region usually in the from the corporate offices to do in some cases quarterly or monthly calls or drop-in visits, so I have pretty routine but most important as Kathy and Dave both mentioned are the The the calls as needed, so I wouldn't want somebody knowing that they're gonna have a quarterly meeting with me two months from now and hold An issue they should be calling me or the appropriate person as the issue is raised And I think we have really good agreements in in the region that that's happening So very similar I mean in addition to some of the forums that we have to communicate including rugs Vice president meetings drop-in visits the periodic calls we have right now are kind of Driven more by the licensees than us, so there are some licensees plants that I have calls with on a bi-weekly basis some on a monthly basis and some not at all What would I like to see not in imposing a new requirement? I think those communications are very valuable have an example recently with a plant in region four where I sense that the We were having communication issues even though I really couldn't put my finger on it and We're gonna initiate Frequent calls at my level at the division director level and at the branch chief level and sometimes when I have these Call I'll call with they have a call with Tim pal and and you know, usually worse Tim. I Know he wasn't here. Okay there. So, you know, sometimes it'll just be hey, here's the status of the plants I Don't have anything else for you Do you have anything for me and and the call will be over if we don't and sometimes it'll go on longer if there's More information to share But I think the other value in those calls at all levels is to ensure that there is alignment in communications At all levels and I think it helps to establish those relationships Even if you think that you have a good relationship with your Region, I think it's helpful to foster the relationship So that when the tough issues do come up and those critical Conversations do occur that you've already you already have that mechanism in place To have those discussions, and I know it's helped Chris Bakken and I recently to just put things on the table and talk through them and get make sure that His organization and and our region are on the same page And that we and that we force that not force but we encourage that communication to go back down Where there are gaps? Steve you don't get to ask me a question. Is it for me? Sorry to see that I want to just get a question out really quickly and then so you can answer it be at noting that we are running out of time the subject is emergency preparedness and and It's a question that we got in really to see conversation, but I think we haven't touched on the area So I'd like to quickly The industry believes that so the NRC in the industry have years of experience with the emergency Preparedness program the industry believes that EP programs are sound yet EP inspections and STP generated Disproportionate disproportionate number of greater than green findings in comparison with the other cornerstones And so the question really is around your perspectives on that. So Kathy, would you just quickly? Talk about the EP preparedness inspection program and STP and any plans to adjust that and from an industry perspective I want want to hear from you as well. Sure. Thanks Mike I think this would be the first question that we get ready for next year because I'm not going to give you a Complete answer So Mike is right. It's been about 20 years since the STP for emergency preparedness has been developed in that 20 years we've revised it's To make it more effective more meaningful The concern is does that revision need doesn't need to be looked at again, and I would say You know from a programmatic standpoint, we do have a team that is looking at that at the STP The individuals that are on it have significant NRC experience The plan is to engage the external stakeholders to get your views on it I know I had a case down in region two and It went through the STP, you know the finding made out I was like kind of Kathy why why did it come out this way? And it's like well the STP drove us that way and then you kind of scratch your head is is are we in the right place? So I do think it is a good thing that we're looking at it. So this team will take a look at the STP Make a recommendation to the senior managers Relative to is a change needed and as far as in addition to the is a change needed or not What should the scope of the review be the effort be if we do go forward with it? So as I said, we'll save this question for next year. Hopefully I'll have more information to give you then just a status update Okay To just two thoughts on on this first on the on a significant determination process for EP findings, I think it is time I think it would speak for the industry and saying that is something that needs to be revisited some greater There is a Tendency for findings to quickly go greater than green that are not commensurate with They just don't pass the sanity check in some cases. There was one example Wasn't one of one of my plans There's an example where a technical support center diesel was out of service for eight days resulted in a white EP finding an Emergency diesel generator out that same period of time one of the most vital safety systems on on the plant site was it was a green finding Somehow that just doesn't doesn't doesn't make sense So I think there is an opportunity to to revisit that and as far as emergency preparedness in general This is one of those areas where I Think things have gotten much better in recent years, but they're in the not too distant past This was an area where there was great variability among inspectors You would come to know a certain inspector had a certain viewpoint and you would adjust to that particular Inspector and you either would or would not get a get a finding and there's variability among inspectors and among among regions on that So I think it's an area of opportunity Yeah The only thing I would add to what Dan said and I think we're saying the same things Just maybe you saying it differently is you know We we're really trying to risk inform everything that we do and you know There's two pieces to risk one is probability and one is consequence and an EP it seems like we're too heavily weighted to the Consequence side, you know if we went back and said, you know, what's the probability that that's actually going to cause a problem? I think some of the will take care of itself and I'm glad to hear that we're actually going to be looking at it in the near term Okay Just a couple of follow-up questions Kathy for you What processes such as inspection procedures and inspection manual chapters have been modified to implement changes that you alluded to for delivering the nuclear promise? Please provide any examples that you're you are aware of I'm not Specific inspection procedures. I'm not aware of any changes. So I don't know if you guys are I don't think that there's any Specific changes. I think the thing that we remember also is you know our inspectors They they inspect based on performance. It's performance space So the processes that may maybe change as long as it's within the requirements or the processes and I think What you see in terms of our specters understanding the process understanding Understanding what changes that you're making I think they tailored their inspections accordingly But still it's a performance space and that that hasn't changed Okay, there was a follow-up question or actually a question from for me That I toyed with not asking but but I'll do it to be to be fair to the panel Michael how is the EDO's office ensuring that the CRG ours reviewing non-generic documents Like TIA positions etc to protect from backfits via vehicles that are by definition not generic and so We've been as a part of the initiative to improve our implementation of the back that process been leading really in terms of our interactions with CRG are and in Conversations with the regional administrators and office directors to ensure for example that they avail themselves of the services that CRG are can provide in Plant specific circumstances and so we think I've long been an advocate for a more active and a more engaged CRG are We're starting to see that through some recent actual Recommendations on the part of Brian for example Holian asking CRG are to take a look at Issues before him for example the Akoni TIA Referred to CRG are So we think that's really going to be a part of the the formula if you will for us As we as we readjust where we are with respect to implementation of the backfit rule There's also another question that talks about and this is for for for any other regional administrators The issue is objectivity Has the NRC considered rotating SES within the regions to improve objectivity In inspection and decision-making So talk about if you will just a little bit your philosophy on rotation within the region the rotation that happens between regions and between the regions and headquarters and The the ability of that to help us with objectivity I can start and I think the we do have the ability to to rotate individuals within the region most recently in region to because of just Resources we've reorganized in both DRS and DRP which resulted in Different changes at the branch chief level of over different plants So I think that it is a positive thing to have the fresh eyes But at the same time we're not going into it blindly because we know that there's the knowledge transfer that needs to occur And that we're not starting over from ground zero and that and also I think it was maybe one of the early questions I think it was Sam that you said that you know as you bring new eyes out there You know they're they're looking differently, which there's a good thing But you have to make sure they're looking at the right thing which is really what what I was hearing you say I don't think I paraphrase do exactly but but that was that was what I heard I think there is a benefit to not just at the branch chief level at the inspector level again It's the aspect of having the fresh eyes and then to at the right time Moving at the division director level we haven't really moved and region to at the division director Level in the last couple of years, but there is you know We need to balance that fresh eyes against continuity, and that's something that I think we face all the time in our jobs Agree with everything Kathy said I think you're looking at the product of just what the question asked I think all four of us have been in different Regions or headquarters and regions, so you have that aspect of it. We do rotate branch chiefs from time to time and And also division management from time to time Yeah, I agree with what what my colleagues have said. I think we do encourage SES managers to rotate Either temporarily or permanently and some do I've been to headquarters and regions back and forth a couple of times and others in the region have also All right Very good. I hear someone's alarm going off. I think their watches are a little bit fast All right, so in the last minute or two that we have in this session I'm gonna ask each of the panelists who I think have been very good actually right don't you agree? I'm gonna ask each of the panelists that if you had to leave with one thought based on I Experience in your region it's something that keeps you up at night Something that you want to focus on my industry Participants Sam Dan Something that you want to leave for the crowd in the last in 30 seconds, please Chris no more than 30 seconds Chris We'll start with in any order, please someone I'll start I guess if I had to leave with any thought is I think You know change is always hard to manage and we need to make we need to manage that Well, and what I refer to is you know, you know people are our greatest resource so they're the they're the folks to actually ensure safety and We talked a lot about culture. I heard this morning a lot of culture But we need to make very clear distinctions between safety culture and the other aspects of culture that we're talking about And and I think often when we talk about it. It has to be It's hard to discuss a topic like culture in an all-employees meeting or through Communications from email. I think it has to be a one-on-one individual discussion on issue by issue So, you know, I think as we As we moved toward transformation innovation, we need to think in terms of culture We need to change the culture but we need to define what culture we're talking about and how we do that So I'll go also to the people aspect and I'll go to it from the standpoint of the right critical skills We mentioned just talking about moving people around but we need to make sure as we put individuals into the different jobs And we bring new individuals into our organizations both on the NRC side and industry that they have the right training and the background to do the jobs My specific references into the engineering departments and again, and it's both sides and it's really Making sure that we're capturing that knowledge and setting up all of our individuals for success Most of our discussion today has been about what's wrong and what are we doing about it? But I just want to recognize the hundreds of NRC inspectors that are out in the field right now doing inspections, that's what they do and I think the NRC and the licensees would agree that most of the interactions even when there's a finding involved are our professional satisfactory and fair They're helped by SRAs in the region and their branch steves most of that's most of the help they get and also experts from headquarters Okay in the 30 seconds that I have I'll just I'll just tell you I marked up all trained Now I'll be a little more tactical. I just want to draw your attention to two recent NRC actions that were taken one with Southern company and one with Entergy related to integrity issues among plant operators and In one case an exam proctor if you're not aware of this The confirmatory order will be publicly to enter G will be publicly available today the information is out there for Southern By all measures, I think the company's identified Very good corrective actions to address these issues I encourage other Utilities to learn as much as you can About what happened in these companies and take a look within your own company take a ask how they got to where they got how they investigated it and Take a look internally at your own Companies in your own plants so that we don't end up issuing additional regulatory actions at your plant Yeah, I guess I'll go next answers. We're just going down the road, you know, I See this is one of the most challenging times That I've seen in my career for the nuclear industry as a whole including the regulator Impo everyone around the industry, you know new technologies and Political winds are challenging our very existence and I think the opportunity for us to innovate I think the Opportunity for us to transform how we do business is real and quite frankly. I think it's needed it's needed urgently and Given all that I think we can do it and we can come out of it safer more effective more reliable and something that We're all proud of you know I've been in this industry for many many years and many of you know that I'm no longer going to be a nuke effective last week I'm going to be running the utilities side of the business But I've been in this industry for 30 years because I believe in it and I believe in what we do We make people's lives better by giving them electricity without impacting the environment and let's make sure we are able to keep doing that for the long term That would have been a great net to end on I'm just going to come back to Something that Chris said and something Kathy said earlier and that's been alluded to before here First and foremost for us in the industry It's about making sure that We consistently do the right thing to the highest standards of integrity and that we we build that Reputation for always doing the right thing and secondly that goes along with that is Establishing good communications on an ongoing basis such that we have a mutual respect Relationship of mutual trust and respect we need to build that every day Because there will come a day when you have to call upon that that that were at reservoir of trust We had experienced it at North Anna when we had the earthquake in 2011 because we had built that trust because we had built that reputation We're able to get those units restarted very quickly and I would also just just again commend the folks the NRC We have over time had a very strong and productive relationship and mutually beneficial relationship understanding the difference of the Differences in what we do but also the mutual objective to ensure the safe operation of these plants. So thanks So that concludes our session I want to thank you for your attention and your engagement during the session I want to thank you again the distinguished panel of our great answers and a great closing set of statements. So Please enjoy the rest of the