 Okay, all right well good morning everyone and we want to welcome our representatives from the Organization of Agreement States and the Conference of Radiation Control Program Directors and today's meeting with OAS and CRCPD is an opportunity for us to discuss matters of interest with respect to radioactive materials policy and regulatory issues of interest in the States. Commission will be briefed on a number of topics by several members of the OAS and CRCPD including the status of Part 37 implementation related to source security measures, web-based licensing implementation, nationwide environmental data sharing for foreign and domestic incidents, financial planning and sealed sources and training and webinars. Presentations will be followed by a question-to-answer session with the Commission before we begin. Any colleagues? Anything? Okay I'm gonna let the panel members introduce themselves and begin whoever is going to be in. Why don't you all introduce yourselves and then we can start with the presentations. Good morning Mike Welling, I'm past Chair of the Organization of Agreement States and the Director for the Virginia Radiative Act Materials Program. Matt McKinley, I'm the Chair-elect of the Organization of Agreement States and I am the Administrator of the Kentucky Radiation Health Branch. I'm Sherry Flaherty, I'm the current Chair of the Organization of Agreement States. I'm the Supervisor for the Radioactive Materials Program in the State of Minnesota. Bill Irwin, Chair of the Conference of Radiation Control Program Directors and I'm also the Chief of the Radiological and Toxicological Sciences Program for the Vermont Department of Health. Jared Thompson, Chair-elect, Conference of Radiation Control Program Directors. I'm Program Manager of the Radioactive Materials Program in Arkansas. Matt, we're gonna let Matt start us off. Okay. I'm the new guy so I get to go first. Yeah. Again, good morning Commission and my name is Matt McKinley with the State of Kentucky representing the Organization of Agreement States as Chair-elect. My topic today is going to be a web-based licensing implementation. In 2007 there was a congressional mandate that resulted in the development of the Integrated Source Management portfolio which includes the National Source Tracking System, the License Verification System and of course web-based licensing. Web-based licensing was the last of the three to be brought online. It was brought up in 2012 and for the NRC it was to bring together several legacy systems into one cohesive system and of course that was then to be made available to the agreement states at no charge with full tech support. So a really nice offering to make every program in the materials program nationwide as consistent as possible in terms of its data and also to assist in using the data for various purposes such as checking license status when imports come into the country and things like that. So states have the option to take it right off the shelf the NRC provides it and as of today there are two states that have actually fully implemented the program and there is a third that is expected to be online within a couple of weeks. There are 18 states in addition to those three that have expressed interest in the program. Two of those are actually they've taken the system and put it on their own server so they host it locally. The others have have are various stages of research development implementation. The NRC is only able to accommodate three to five states per year in the system and of course as you can understand with 18 interested states and about 20 more close to 20 more that haven't yet expressed interest but but no doubt at some point will at least ask the question. There could be a significant backlog in getting this implemented nationwide and so one of the organization agreement state board recommendations would be to consider perhaps a short term boost in staffing and resources for for this program in order to facilitate bringing it online nationwide to every state that wants it without taking years and years to do so because of course in addition to the implementation within the states there's going to be continued development and improvement and there's going to be tech issues of with states that have already come online so that would be one one recommendation. The other recommendation that we had was to continue developing reports that are consistent with the MPEP questionnaire and the information that is needed by MPEP teams which could be accessed by NRC staff and and the MPEP team itself prior to actually going on site which could save quite a bit of time and essentially money is what it boils down to so those those are the recommendations from the organization agreement states board and I have nothing else on this topic unless I don't know the format is this a question or last questions at the end after all the presentation okay thanks okay I think that means that I'm up next so chairman and commissioners thank you for the opportunity to be here this morning on behalf of the organization of agreement states I get the pleasure of talking about everyone's favorite topic these days part 37 its implementation and the security of sources a little bit of history you're all fully aware of the fact that on March 19th 2013 NRC implemented its 10 CFR 37 the physical protection of category one category two quantities of radioactive material then as part of the national materials program the 37 agreement states had three years to implement compatible regulations or some other legally binding requirement equivalent to that part 37 so March 19th of this year was the deadline and I'm happy to say that all 37 agreement states met that deadline and have compatible legally binding requirements in place for licensee is possessing category one and category two material so the agreement state licensees have transitioned from the increased control orders to the requirements outlined in 10 CFR 37 those requirements for the states may be in the form of state regulations or the state may have adopted part 37 by reference or they've come up with some sort of legally binding license condition so now all the licensees across the country who have category one or category two material are being regulated under part 37 or the states equivalent and we'd like to thank the staff for their timely review of the states part 37 equivalents and and helping make sure that we can all make that deadline so the security requirements in part 37 go beyond those of the previous increased controls including some specific requirements like those for reviewing officials additional background checks access controls security barriers coordination with law enforcement and then several other items the OAS board believes that the these additional security measures are appropriate for category one and category two sources and the states along with the NRC will continue to evaluate the effectiveness of these enhanced regulations as we go through and review the licensees compliance so with regards to the the task force on radiation source protection and security report we continue to work as part of that national materials program to assist with the NRC's implementation plan for the task force report and then lastly regarding source security the OAS board also agrees with the NRC that the current source security measures in place for sources below category two are reasonable and there's really no need for additional requirements at this time current regulations already require those sources to be secured and because these sources below category two by definition are unlikely to be life threatening if dispersed it seems really unnecessary to require additional security measures for these licensees we feel that imposing additional high level security requirements for category three material like medical licensees with high dose rate afterloaders would require a lot of additional resources and the board believes the additional cost really may not reap an equivalent level of benefit and so that's really all I have regarding source security and with that I'll turn it over to Mike. Thank you Sherry. Thank you Commission for today as today is my third and final presentation to you for the OAS board I'm here today to talk about financial security for sealed sources first I'd like to bring three current requirements to light that you hopefully already know first that the licensees are required for the proper disposal of the sealed sources we're just the license they were the regulators so we're holding them accountable for the return of these sealed sources during their use second these sealed sources may be returned to the manufacturer's distributors or other licensees who possess a license for that type of seal source and or device and last the financial insurance requirements in part 3035 is a solid measure for the assurance of large activity radioactive material being used by licensees as such in reviewing these requirements the OAS board is proposing the two following items first we would like a review of the possibility of a working group consisting of NRC staff OAS staff and manufactured distributor licensees to review the proposals financial security for the radioactive sources not covered by 3035 and second while this is being reviewed we propose that if not one several webinars be be held with NRC and agreement state staff and the manufactured distributors to start a conversation on the financial security issues regarding sealed sources not covered by 3035 one example being done right now as a state of Illinois requires their licensees to put they have a surcharge which that money is put in a trust fund that's used for disposal of sealed sources unfortunately that requirements will not be allowable in all states due to regulatory requirements and the fact that most of our legislators in states have access to our funds so those funds sitting there will be used for other avenues not just the disposal of sealed sources with that I thank you for your time and look forward to any questions thank you mr. Chairman and NRC commissioners for this opportunity to discuss a topic that's probably been around longer than the these briefings themselves and that's training in CRCPD OAS in the states are very appreciative of the continued NRC support and commitment to the agreement state training program this training remains the cornerstone of the national materials program and is invaluable for the regulatory consistency across the nation NRC's approach in changing some of the training methodology for some of the courses is a benefit not only to you but to us as states as well it alleviates some of our travel concerns and an office being able to get people out of state travel and things like that so it does benefit both you and us as well we are encouraged extremely encouraged by the success of the blended learning course we found that to be widely accepted by all those who've attended and is received some very nice reviews and we look forward to using that approach and possible other training areas as NRC sees fit NRC has also begun a specific issue training webinars that have been both well received and well attended by the states these were these webinars are timely and can be useful to ensure that all staff are available for the presentation I know in in Arkansas that I require my staff to sit in that way I get all of them at one time these webinars are useful as we as refresher training and it strengthens consistency within the programs these the topic the webinar topics related in these in these webinars have been primarily been focused on medical issues and security issues related to implementation of part 37 we would like to encourage NRC to broaden the topics for those short webinars to include possibly issues related to industrial and academic material use base basic health physics reviews and you and proper use of instrumentation sometimes you know we just need to put our stone a little bit and get a little sharper back in how we do our businesses finally as NRC works toward project aim it is noted that under number 75 of the project aim recommendations that attendance for agreement state representatives to the OAS me annual meeting is budgeted through the agreement state travel and training fund we are again our appreciative NRC's commitment to the agreement state program use and also use of the blended learning courses and other changes made under project aim appear to be less painful in completion of this budget goal elsewhere in the project aim recommendation it was mentioned about reducing the number of NRC staff attending meetings and conferences OAS and CRCPD hopes and recommends that the NRC will continue to fund the regional agreement state offices to officers to attend our annual meetings the RSA O's are a vital link to the states and play an important role in the national materials program personal interaction is vital to strengthening our relationship thank you and I'll be happy to answer questions thank you chairman Burns commissioner Saviniki mr. Elstendorf commissioner Baron it's a great pleasure to be here again and to share with you some of our thoughts from the conference of radiation control program directors my topic is environmental data sharing the accident at Fukushima taught the nation that we need to share actual environmental data promptly to help the people understand the ramifications of a release of radioactive materials whether foreign or domestic the states through the CRCPD have worked with EPA FEMA DOE and others to develop rad responder as the key tool to share field data immediately after it's been collected by trained personnel and verified by trusted administrators this working group is now working on developing the same capability for laboratory analytical results and hopefully we'll be able to use automated channels from the labs like the exchange network which is used for clean air act and clean water act lab results quality control methods are also being developed which will provide a high level of confidence in the data that is collected and shared among partner organizations that agree beforehand to share their data rad responder is defined as the nation's tool for these purposes in the nuclear radiological incident annex its most recent draft and similar reliance is being incorporated into plans for many federal state and local radiological nuclear emergency response organizations the CRCPD has several working groups that support these efforts one focuses on policy and field and laboratory data collection platform and procedural issues and others encourage the implementation of rad responder into FEMA evaluated exercises or training and exercises for radiological dispersal device and improvised nuclear device response and recovery. Some states are using rad responder in nuclear power plant exercises with great success. NRC participation in these efforts will close gaps in our capability landscape. There are many NRC licensees that can add great weight to these efforts but may be reluctant to do so the NRC could assist with the integration of rad responder as a field and laboratory environmental data sharing tool with its licensees. Doing so will activate a large number of high quality field collection personnel and highly capable laboratories that will improve the resolution of our understanding of the ramifications of what has occurred in one of these radiological or nuclear incidents. Thank you for your time and look forward to your questions. That concludes the presentations. We'll begin the questions this morning with Commissioner Austin. Thank you Chairman. Thank you all for being here today. I want to comment that I, from a succession planning standpoint, I admire and respect the way you have your past chair, current chair, president elect, the whole thing that you have the continuity across the board for both OAS and CRCPD. I think that's really important. I wanted to commend you for doing that. And especially since some of these issues that we're talking about today have been discussed five or six years ago. And so I just wanted to give you my plug that I think you ought to continue that on both for both organizations. I think it's really important, helpful. I think hopefully the organization I know it's helpful for us at the commission level so I wanted to make that comment. Let me start out with Matt and ask your question on the web-based licensing. I appreciate the comments associated with the appearance, some, you know, maybe some accommodating limitations on our side about how many states can come on board at one time. I am a little puzzled though that only two states have implemented so far. And I know you mentioned a third as close to that. But web-based licensing has been on the table for a number of years. I'm curious as to those states that may not have pursued or expressed interest. What is the viewpoint as to why they may not be interested in going down this pathway? That's a difficult question for me. And so anybody that wants to address that as well is in addition to you. I mean, really the only thing I can assert is my view as the administrator in Kentucky. We are on the list of the 18 that has expressed interest. There are some limitations to the system for a full program. You know, I'm responsible for not just materials but also X-ray and response and transportation and a laboratory. So to get all that integrated in is preferable from my standpoint. But that's doable with web-based licensing. It's just it's taking it and sort of modifying it within a state. So I think the hesitation might be just a lack of clear understanding as to what it might look like in your state once you've actually implemented. Several states, at least two that I am directly aware of, have taken a distributed version of web-based licensing that they host on their own servers, which I think takes some of the concern away because it brings web-based licensing to them and gives them a free and open platform to add to it as they see fit. I think the plan in Kentucky, as of right now, is to take essentially an existing system and have it communicate directly with web-based licensing so that there's no double entry of data. But that web-based licensing at the NRC server is populated with that information, which is vital to the whole thing working as it should. So there's a little bit of asymmetry between the web-based licensing content as set up by the NRC and what you deal with at the state level. Is that what the issue is or one of the issues? It's not apples and oranges. Is apples and oranges in some respects? Is that what? Well, the materials program is, for the most part, identical. So that part works fine. But our database in Kentucky, and I'm sure most states experience the same thing, is all set up as a single point so that I can go in and look at what an x-ray facility is doing right alongside what a materials program is doing. And I think there's an accounting component, too, that is necessary within a state. That's sort of the foundation of the database. And that's not even really possible to put out a generic accounting piece. But again, all those are easily added on. And I think that just it's a matter of maybe advertising and helping states understand what is there for the taking. Anybody else want to comment on this? I can add a little bit to that because I think according to your statistics, Matt, I think we're the one that, Minnesota is the one that's within weeks of implementing WBL. For us, the challenge was, as Matt said, we have multiple systems and multiple programs to run. And the accounting piece was another big piece of it. But as the NRC continues to update and make changes to WBL and make things like that that are available, where we can extract some of that information and then send it directly to an accounting system, it's making it much more attractive to the states. So I think as you continue to look at some of the issues that we have, and you start looking at ways to incorporate them, then I think it really is going to broaden the states that want to get on board. So it's been a nice situation for us to take a little bit longer because as we get closer and closer, there are more features to WBL. Did you want to add anything? I think that it may be useful to look at the way states are implementing web-based licensing. And there may be a parallel paths to adopting it. For example, Vermont, as you know, is put in its intent to become an agreement state. We hope to file our application this year. And we would like to adopt web-based licensing at the onset of becoming an agreement state and just enter into the web-based portal directly. So hopefully, the transition of all of the files from NRC to Vermont is fairly seamless. And we're able to do that fairly promptly and move right into the next steps of our requirements. Other states where they do want to try to integrate various other tools that they use in the Radiation Control Program will have more complicated efforts and that may require more resources. And so possibly that's one way to look at this, is that where those states want to adopt what is right on the web and not have it internal to their own procedures could be done more rapidly versus those that want to try to integrate. And as Sherry was suggesting, maybe there are similar kinds of issues that arise and together we can resolve those so that it's a little bit faster. Because I think it's critical that we have one place that we can go to get information about our licensees who are international, not just interstate in their commerce. Thank you. Jared, yes, please. In Arkansas, we have very similar problem what Matt's talking about. It seems like when you tie it to money, they're less they're least likely to let go of it and have access to it. I can't even get my people to talk about it with base licensing. And I've approached them three or four times. It's just, you know, because money, because accounting function, they don't want to touch it. And it's just it's probably a unique state issue for us. It's very helpful. I appreciate your your your candid comments. Sherry, let me ask you a question here in the context of part 37. And I really appreciate what OAS has done. And all your colleagues to help the NRC articulate the relative risk of different levels of sources and so forth. I know this has been a little bit of a contentious issue. We've been discussing it for several years. I continue as an individual commissioner to worry that people anytime the N word is in there for nuclear that people get are quoting nuclear sources with improvised nuclear devices and with all kinds of things. And I think your role both OAS and CRCPD is really important to help educate and provide scientific based risk assessments. So quickly in the time remaining, season, chloride, blood or radiators, frequent topic we've been dealing with for a number of years. I personally think that the security regimen we have in place for those as adequate and appropriate for our mission. What do you think about the season, chloride, blood or radiators? You're asking for the the board's opinion. You're asking for Sherry Fullerity's opinion. I'm going to ask you for Sherry's opinion. I would agree. I think that what's in place is adequate. And actually I agree our role is not to ask our licensees to take these out. It's to make sure if you're using them and you're using them appropriately that you have them secured in appropriate ways. So that's my opinion on it. Okay. Are you seeing any effort in Minnesota or any other states here seeing efforts to look at alternative technologies for season chloride, blood or radiators? The alternative technologies are out there and we don't discourage our licensees if that's the choice they want to make. It's it's a licensee's choice. Again, if if they're using the material, they're using it appropriately, they're securing it appropriately, meeting all of our requirements, then then there's really we have no other role is my my thought on that. The alternative technology is out there. Okay. You guys want to add anything? Just that so as the past chair, I'm currently on the working group, ultra technology, and we've made sure that and along with myself, the energy staff have made sure that that is annotated in the paper that we're only here to license and regulate. We're not here to advocate for or against. So if a licensee chooses to go to ultra technology, that's fine. As long as it dispose of the season chloride source properly. That's our job. Okay. See our I mean, with the season chloride, blood or radiators, the problems, you know, with the emerging technologies and things like that is disposal of the the older the old device itself. That gets to be the real problem with a lot of these facilities. They were they look at that and they see the disposal costs and they say why? So most of the time and I know in my experience, it's been they tend to keep them because of that reason. Thank you all. Thank you, Commissioner. Commissioner. Thanks. Well, thank you all for being here. It's good to see you again. And we of course appreciate all the work that you do and and NRC's partnership with the agreement states. That's very valuable to us. Bill, I want to ask you some questions about CRCPD comments that were submitted last month on the decommissioning reactors advanced notice of proposed rulemaking. I want to ask you about the comments, which of course represent the views of CRCPD as a nonprofit organization rather than the views of any individual state or locality. And Jared, please feel free to jump in on these if you have anything you want to add. NRC's current regulations give licensees 60 years to decommission a power plant. In its comments, CRCPD says that seems excessive and recommends that NRC reevaluate this timeframe. Can you talk a little bit about why CRCPD sees 60 years is too long and how you weigh the pros and cons of safe store? Now, thank you for the question and the primary interests of states where they have hosted nuclear reactors for decades is the use of the land productively afterwards. And the 60 year timeframe, frankly, only benefits licensees. The community where the facility exists could bring in some other source of electricity generation to connect to the electrical infrastructure that exists there and not only be able to use that land productively again for that purpose but other purposes if the site were promptly dismantled and decontaminate and dismantled. There are also benefits when you go to prompt decommissioning, not only for the community and the state where you have typically a lot of work occurring that keeps those who were employed there gainfully employed, probably even more people coming in and keeping the economic vitality of that region sure for some time. But there is also the knowledge of the staff who are there who are able to actually improve, in many cases, the quality of the decontamination and dismantling because they know the facility and are able to really engage in that process more effectively than oftentimes contractors who may be decades separated from historical events that might have occurred there. There are also concerns that if you wait 50 years to begin decontamination and dismantling that a variety of unforeseen circumstances could arise. Some of them may be relatively slow and non-dramatic like a leak of some facility, structure, system or component into groundwater that contaminates the local aquifer but does not lead to significant dose but does lead to a lack of mistrust of the land in that region. And so prompt decommissioning will help us to assure that anything that exists there is understood soon, taken care of soon, so that it can't fester and perhaps become a problem in an unplanned manner later. And then finally, I think that there is potentially a new industry that may be arising in our nation, recognizing that we are in a new era with the older plants to actually accomplish decommissioning effectively with the funds that exist in the decommissioning trust funds now. And that should be actually raised up as a strength in our nation to take care of these old plants now. And I believe frankly that if the nuclear industry shows that it can not only build and operate these plants efficiently and productively as they have for decades and then remove them and replace them potentially with even new nuclear facilities, that that assures the nation that this is a more viable alternative than letting these facilities sit for decades and remind people of an era that perhaps they might not have as good an impression of otherwise. How do you think NRC should determine the right time frame for decommissioning? If 60 years is too long, how do we figure out what the right number is? Yeah, that's a really good question. And I think it is a case by case basis. You know, there are some facilities that have had opportunities to build a decommissioning trust fund that is able to actually do the work. I think that there may also be economic factors that we don't realize right now because we have this safe store component that if we were to go to prompt decommissioning, again, the market may naturally identify means to do this work efficiently with the monies that exist in these funds rather than waiting decades for it to build up. But there may be some facilities where it's clear that not the inadequate funds were created. And a big part of all states' fears is that they, the states, will be left with the financial burdens of a facility because a licensee has not met its obligations either with the NRC or with others. And so I think it's likely to be in some cases prompt after a couple of years of preparation and then in some very unusual cases you may have to wait until the decommissioning trust funds exist because that's really what it takes is money as well as the right technologies. Another question is whether NRC should review and approve a licensee's post shutdown decommissioning activities report rather than just receive it. In its comments, CRCPD says that we should do so. Can you discuss why CRCPD sees NRC approval of a PSDAR as beneficial? You know, I actually understand the logic presented by the NRC and the PSDAR public meetings, why it doesn't take action. But trust is earned and it's a perceived thing that you earn. And I think that there needs to be more than holding a public meeting where you simply listen to the questions and say, yes, we understand. We know you have that concern. There should be some sort of opportunity to, like in other activities, like rulemaking, address the comments directly, give answers to the common questions so that people recognize that the NRC cares. I believe that the NRC does, but I believe that the current process gives the impression that it doesn't care as much as it really does. Another issue is whether NRC should require the formation of community advisory panels. And if so, who should establish the panel and who should determine who's invited to participate on the panel? I read CRCPD's comments on this issue. Can you talk a little bit more about your organization's views on those questions? I'm very fortunate to be on a panel in Vermont, and it was the predecessor to a panel that was used during operations, and it was a very useful panel during operations to sound out issues, and we're using that same approach now. The panel is a function of the state and is and contains representatives from the local community, as well as the licensee and state agencies. So it's a balanced panel. So I think that rather than it be a panel that is managed by run by the licensee as a requirement of their decommissioning, it needs to be perceived as an objective and external panel with freedom of expression. But there should be licensee support of the operations of that panel. I can tell you the costs of maintaining that panel are quite small compared to other things, and it's a very effective way for the community to engage and to have trust that what they have bargained for by living with a nuclear power plant in their community for decades is being honored. Let me ask you one more question. That's about when CRCPD thinks it's appropriate for licensee to deactivate the emergency response data system or ERDS. Can you talk about CRCPD's comments on this issue? Should NRC require licensees to keep ERDS operational for the data points relevant to a shutdown reactor? And if so, how long should a licensee be required to keep those elements of ERDS in place? Yeah, in Vermont, we've actually, I think, come to a reasonable compromise. I'm familiar with ERDS. I was an ERDS user until it was shut down. And I found that it was very useful for accident assessment purposes in our exercises. Of course, we never actually had an accident. We had to use it for real. And the compromise that we arrived at was the plant display system. And the plant display system provides us with the relevant meteorological and radiological conditions on the site that are appropriate to a decommissioned facility. I suggest that it's possible that transitioning from ERDS to PDS would be an appropriate way to proceed rather than just abandon the ERDS. Thanks. Well, I appreciate CRC PD submitting its views on these and other issues. And we've, I'm working my way through all these comments. There are a lot of them that we got. A lot of good comments, good constructive ideas, and we'll be taking a close look at those. So thank you very much. Thank you. Thank you, Mr. Chairman. Thank you. I want to thank Mike Welling, a company me on the Innova Hospital visit a couple of a couple months ago. And we're able to have a good opportunity for me in terms of looking at a different side of regulation in terms of the, you know, materials regulation. And so I appreciate your assistance during the visit and pointing out with that, I'll sort of turn to part the part 37. Appreciate in terms of what where we are in terms of agreement state implementation of the part 37 within the three years as noted in the one part 37 was promulgated. Obviously, this in this at the end of this year, the as many know, and I think you all know, well, the commission owes a report to the Congress on on inflammation in part 37. The commission, the staff is engaged in setting up a number of public meetings to get input on on the on implementation and challenges. I just ask you either it may not be on behalf of the organization, but sort of informally in your own observations from from implementation in your own states of part 37 requirements or the the parallel for those requirements. Are there any particular observations you would make at this point in terms of any of you in terms of how that is going or what a sherry obviously focused on the the issue of cat one in response to commissioner Austin Dorff's question. But I'd appreciate any other thoughts, stumbling blocks, places where we you think we ought to keep an eye on apart from whether or not that that finally makes it into our our last report. But let I can give you a little overview. I think. Partially the states had a little bit of an advantage because we had that three year window after the NRC implemented it. And fortunately for us Ohio kind of took the the lead and and they got their rules into place early. They also established some good practices for us to follow. They put together some public meetings for their licensees and some of the states were in a position where they could do similar things to get the information out to the licensees a little bit earlier. They also established some check lists that were really good and sent them out to licensees and we many of us borrowed them and changed Ohio to Minnesota or other things like that. I can tell you from our standpoint in Minnesota we put our part 37 equivalent in place in August and so we've been out doing some inspections and checking compliance and for the most part the compliance has been been very good. It's mainly some of the planning stuff that has been a little bit out of compliance but the security stuff and and having the checklists and having things like that has really helped our licensees be in compliance when it came to a lot of the the major security things. So that's been our experience. From Virginia's perspective I'll say we're unique in several states also where we have dual licensees. So those licensees who live and reside in Virginia who also have NRC licenses have been doing part 37 for two years now. What we heard from them was was the implementation period you know and the lack of we're in what Ohio did like Sherry said and we also did in Virginia was bounds beneficial to those licensees to read a 300 and something page guidance document for a 40 page regulation set. The licensees were inundated indoctrinated. They didn't know what to do. Every time they asked a question it was read the new rate 2155. You can read it so you're blue in the face or do you fall asleep until you get inspected and somebody says you did it wrong and you say I try to do what you told me I try to follow the guidance and one inspector sees it something differently guidance says. So I think a good lesson learned was when if in the future we come up with a new set of regulations this volume is this new we need to think about how you reach out to licensees the implementation period. Look at the two years the states had and how the states have implemented how we've worked with our licensees. I think that's a good lessons learned going forward for NRC and their licensees. It did benefit our licensees because once the NRC went out there did the inspections they get their citations once we came around everything was satisfactory and met 100 percent of the requirements. So for us it was easy unfortunate licensees had to go through the first set around to the NRC and then following it through with us. But I hope we've all learned from this lesson from part 37 of ways to get better and interactions with our licensees and especially on how it takes a 300 page guidance document explain 30 pages of regulations. OK. Any other thoughts. I think in Arkansas we had a eight month implementation period and that did help. I know NRC had a year but Mike is right. You got to have some reach out. You got to have some workshops and things like that NRC has been conducting some webinars over the last two weeks maybe three related to part 37 implementation. And there was one that was particularly for licensees and it was kind of interesting to hear them talk about the implementation and how aggressive some of them wanted to be more than what the NRC was proposing. I'll give you an example. They talked about reinvestigation. Reinvestigation is ever 10 years licensees wanted it more frequent. Surprised. But I was also surprised by the fact how how well they were all knowledgeable about what was going on within part 37. They asked good questions. I think it's been well received and that's a very positive thing. But again then again they've had the orders for 10 years but at the same time is an easy transition for them to go to the part 37. Yeah. It's still even with having the order excuse me the orders that a transition because that might get so the orders are not or the rule is not quite what the the orders are. So you know that type of transition that there's going to be some learning. But I was really surprised by they wanted tighter re-investigation re-investigation. That is that is interest and that is interesting. Any other comments on it. The other Jared mentioned that in terms of some of the webinars and excuse me we talked about training. I know that's been an important issue for the for the agreement states and there's a lot of a lot of work and I know the meeting last year we discussed about it discussed it. How do you see do you see this this is the question goes the question goes to the excuse me the balance of sort of in-person and the webinar or remote type of learning. Obviously the remote type of learning has the advantages in terms of lower travel costs things like that. Do you think we're getting that right in terms of the blend. Are there things you think we ought to take a look at or keep an eye on as we manage that bill. As mentioned Vermont is getting ready to submit its application to become 38 or 39th agreement state depending on our timing with Wyoming and we are sending three people to the agreement state training and it is wonderful. It is not only appreciated because we could not provide this kind of training on our own but because all of the people that have gone and come back to talk to me have found the learning experience with their colleagues from the other states and from the NRC to be as valuable and sometimes more valuable than the technical content in the books or that could be shared online. And I have one who is taking the full extent of it because she has less radiological protection background and is taking the blended learning program and finds that that's a very useful way to do it. So I think you're on the right track and in fact I would commend the NRC and all of us spoke with Marsha and I have numerous times tried to relate to everyone that I talked to how much appreciated Vermont is to be able to take advantage of this and also as CRCPD chair to know that all of our states are able to learn from a common curriculum and have the kind of content in their inspectors and license reviewers, whatever state of licensee might go to so that we do actually represent a national materials program. And I think in the end that is likely to be a cost savings to the nation overall. And I would hope that the powers that provide funds for this recognize this is a very valuable means of strengthening the national materials program. I think they're on the right track. I think it depends upon the course. Your contracted courses where you have contracts with individuals to provide the training, hands-on experience is very important. The radiography course, well-logging, some of the medical courses. You've got some other courses that maybe could be done more online. Maybe not even have necessarily a group gathering, but I think that would be something you'd have to look at and it's how it would impact not only the states, but how NRC would train their own staff. So I think it needs to look at a case-by-case and kind of get a balance there. I mean, I've heard some suggestions about the contract courses that you have so many days that they do online stuff and then they get together for the hands-on stuff. That approach might well work as well, but I think it's very, very important that you achieve that balance to make sure that the training is there. And you know, the world is getting where technology is the only way they learn, you know, online and things like that in younger generations. Any other thoughts? One thought to think about while we've had discussions with NRC staff on this before is instead of having to go to Chattanooga or Texas for these hands-on experiences, there are licensees and agreement states and non-agreement states in the NRC world where we can do regional training instead of where it could be cheaper, more cost-effective to fly to that city and hotels per diem per se. So we should be thinking outside the box of a couple days online webinars versus the couple days on hand. Coordination could be held at other sites than what's currently the contractor has. Thanks. Thanks. See, I know it is an art and my own experience before I came back to the NRC. I used to run a nuclear law course. And one of the real advantages of that course was, I think, as Bill said, this sort of integration. We had people from 35 countries and you start to run into them since I've left. And they are still in contact with others and even on other programs. So there is a piece of it. It's a real art, I think, getting the right balance on this. But I appreciate the comments. Commissioner Savinicki. Well, thank you all for being here this morning. I always look forward to our gatherings with our continued partnership with our agreement states through OAS and our continued collaboration through CRCPD. I'm reminded when I sit in this meeting one of the many strengths of our constitutional democracy is that we have the 50 cradles of innovation and different approaches through the states. And I think when I look at the multitude of working groups that we have between the NRC's technical staff, the engagement with the OAS and CRCPD leadership and members through those working groups is a way that we have a continual feedback, I think, of what's working for us, what's working for you. And over the years that I've been attending this commission meeting, it's a reminder to me of how it's been very much a beneficial back and forth. So I appreciate this meeting. Some years we have more topics to talk about in a more animated way than other years. This year is a little bit more, I'd say, steady as she goes. We're covering some topics that we've covered in the past. I did have one specific follow up for Mr. McKinley. If we were to look at the interest of states in web-based licensing, you said maybe there could be a NRC consideration of a temporary boost to funding in a certain year. Do you have any sense of what years that would be? We're, of course, budgeting two years out, like a lot of agencies and departments at the federal and state level. The more notice we could have to contemplate that would be better. Would we be looking maybe at 2018, 19, 20? Well, the comment was based on the fact that there are 18 states that have expressed interest and clearly at a rate of three to five per year, there's already a backlog. So I guess my answer to your question would be, as soon as possible, assuming that the advertising of web-based licensing can continue to work and as states come online, as Sherry said, she's going to be the third here in a few weeks, there will be more and more real examples of, well, this is how it works. And so I expect that number. There might be real examples of how onerous it is to transition or to adopt it. So that would be out there as well. It might actually give some states pause. Well, it could, but I think ultimately it will lead to that number, that 18 number growing. And so I think the concern would be that at a rate of three to five per year, at the current ability, which is obviously limited by resources, that the backlog could continue years into the future. OK, thank you. It sounds like the answer is just the sooner, the better. If that could even be doubled, it would be helpful and would at least minimize a backlog right now. As an agency, we're formulating and contemplating 2018. So I think in order to have advance notice that might be the soonest, we could contemplate that possible supplementation of funding. But it's very good. Thank you for looking over the horizon and trying to give us a little bit of notice, that kind of input is this beneficial back and forth I was talking about earlier. Maybe to turn to one of our animated or more challenging topics, I want to start by saying that as a government agency, I think that NRC has a lot of sympathy and understanding for the natural difficulties of once we update a regulation, the agreement states having to go through and make sure that they're in conformance under compatibility requirements. We do look as part of the MPEP reviews at any potential backlogs in coming into compatibility with NRC changes to regulations. There are instances where there can be issues going back some period of time. I guess broadly what I'm trying to ask is laying aside the natural sympathy that it does take some time for agreement states to come into conformance under compatibility. And in some instances, I know there has been a need for state legislatures to maybe make some modifications or changes. And I think NRC certainly has sympathy for the fact that you can't control when and if a legislature will necessarily take up a matter that is important to you as a government agency for some need that you've identified. But how would you characterize that I should view if there's some, an issue outstanding till 1997, a lot of 2002s, 2007. 2007 seems really recent to me until I remember that next year's 2017. So I don't know. What would you have me understand or be sensitized to in terms of having issues that kind of hang out there for long periods of time? I know that MPEP looks at this on a state, agreement state by agreement state basis. But in terms of overall organizational patience, what would you have me understand about this? A couple different levels to that answer. The first is our first problem is our legislative issues in the states. In fact, the last. I have some sympathy at the federal level for that. Yes, we do. We understand. The problem we have as a program is, in fact, the last day that just went through MRB last week, Nebraska, had submitted their regulatory package in a timely fashion. And the legislators decided to sit on it for over three years. They had submitted. They'd done their process. I'm sure they're deliberating actively and not sitting on it. Well, OK. I can't speak for them. But the problem is, is they were found satisfactory. Needs improvement. The issue is, what can you approve? Because the program had done their due diligence. They had gone through the regulatory requirements. They have written their package up to make it compatible with the NRC. They'd submitted it. And at that point, it was stopped. And I understand that. But I would note that, under the Atomic Energy Act, this is an agreement state. And when a state grows on probation, which is, thankfully, a very rare thing throughout the history of the agreement state program, our chairman will write to your governor. So I think the agency doing all it can is a necessary step. I guess what I'm asking is, what should be the programmatic patients beyond that? Obviously, most we would ask, just like children to parents, we would ask for most patients as possible. But one thing we found out last week is, some states had mentioned they're waiting for the CRCPD SSRs to be published and finalized before they will actually perform their regulatory requirement review. And I'm sorry, SSRs. This suggests it's a regulation. So a working group through CRCPD is set up to look at the regulations, write a compatible set of regulations, which then goes through a review, which includes NRC and staff. And they're a buy-off. So basically, when an SSR is written and approved, states can document, take that SSRs, just say reg, implement it into their regulations and be compatible with the NRCs. So a couple of us were kind of struck last week when you heard some states were waiting for SSRs to be approved. The due diligence is, if there isn't an SSR ready, then it's our obligation as the agreement state to either write your own regulations or find other means to make your regulations compatible, which could include a license condition, incorporation by reference or other means. So I think one of the topics we would like to discuss at this year's annual meeting is the relevance of compatible regulations, the SSRs. If they're not ready, prepared for all of us to use, what other means do we have? So it could be a good topic for us as agreement states to discuss and come up with ideas of how to not have backlog over 10 years for regulations. OK, thank you. Did anyone else want to add anything to that? I think it's very important that I speak after that comment. In particular, I think that there's a possibility that we could recognize nationally that this is an effort that may have such importance that reinforcing the national aspect of a national materials program is important, maybe critical. And it's good that you stated that your chairman can contact the governor and the legislature to reinforce the values of acting. In Vermont, we are going to incorporate the Code of Federal Regulations by reference. So our licensees already know today what their regulations will be a couple of years now when we are their regulator instead of the NRC. And when there is a change at the federal level, it will automatically be incorporated because we have incorporated by reference unless we find some reason to object to that, and we state that in our incorporation by reference language, where we do express that some aspects of 10CFR do not have relevance. There are easy places where that can be cited. For example, we don't comply with office of management and budget criteria, et cetera. But typically our reference is nearly 100%. And I think that that is a model that we could encourage across the nation. Not only would it reinforce the national aspect of a national materials program, but it would, in many ways, simplify a process that I think is overly complicated to have federal regulation written than to have the CRCPD, in some cases, write a suggested state regulation for the states to then adopt. Seems like it would be simpler simply to adopt that national regulation by reference. The states, of course, have to agree to this. And that's the challenge. And I think that the real way that you get the states to agree to that are in conversations at the national governor's conference, at the national legislative conferences to say, we in this nation are building a national materials program. We build it from the top up, but we manage it from the bottom down. And we start with regulations that are national because commerce is national. And then we actually enforce it locally because our licensees are local. Please, it sounds like that dialogue is going on. That was actually, I think, a more substantive indicator that there's an active dialogue on this than I was aware of. So I really do appreciate that. I didn't expect that we would have the answer to it. I was actually, Dr. Irwin, going to close with a quick question to you. Vermont is, of course, in the process of preparing to submit its application for agreement state status. We have one other state that's exploring it with great particularity right now. When we're first approached, we often are asked, how long will it take to become an agreement state? And our standard answer, at least in my time here, has been, it's going to take about four years. Now, I have this skepticism that when we say something's going to take about four years, it tends to take about four years because we expected it to take about four years. Does it have to take that long, particularly under the type of approach that you've talked about, where if you platform off of what already exists? And then, I guess, is it your view that we shouldn't content ourselves with that time frame and then, secondarily, as far as Vermont's informed exploration of what it would take to become an agreement state, was that information generally available to you in terms of knowing when you had questions about the agreement state process or how you should approach it? Is there a good lessons-learned community among the states to talk about this? Yeah, I'd be glad to share at any opportunity that I can that I've found the whole process to be very transparent and very easily understood and easily implemented. Specifically, I am perhaps taking a tack that you alluded to, I'm saying we're going to finish in two years. And we're trying to do it in two years. And I'm actually getting some traction with the NRC that it can be done in two years. But we are doing it in ways that we think are a little bit different. And we're able to do so in Vermont, but it may not be possible in every state. And that's why, again, I think a dialogue among all of the states about what is the real intent of our effort here in this country is really to do something efficiently that benefits the nation because there are very beneficial uses of radiation. And we need to make sure that we are keeping up with what is needed for safety, but also doing it in an effective manner that does not waste time or money for any of the parties that are involved. So we believe that we can do this in a relatively short period of time. The process is well laid out. We think that if a state takes an efficient approach to it, for example, adopting the CFRs by reference, and then working very diligently with their stakeholders in the state and with the various parties at the NRC that help us through this process, the regional office, the national headquarters, and the various other parties, including OAS and CRCPD, we have the support to get it done rapidly. Great. Thank you. Thank you, Mr. Chairman. Thank you. Anything else from colleagues? Well, again, I thank you for the discussion this morning and being here to share perspectives on the agreement state program. This is another great opportunity for us to highlight the areas where we've had good interaction and need to implement new, in the case of Part 37, new requirements. And I, again, appreciate the contribution that both the organization and the conference give to us. I want to congratulate on the implementation of Part 37 once again. We'll be adjourned, but I think we're all expected to pose for a picture at the conclusion. We are adjourned.