 I would like to introduce your host for today's conference, George Smith. You may begin. Thank you, Kathy. Good afternoon. I'd like to thank you all for participating in today's public meeting and webinar on 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities, a Radioactive Material Program. My name is George Smith. I'm a Senior Project Manager in the NRC's Office of Nuclear Materials, Safety and Safeguards and the Division of Materials, Safety, State, Tribal, and Rulemaking Programs. I'm the team lead for the NRC's Part 37 Assessment. We also have members of the Part 37 Performance Review Team and attendants here at the NRC headquarters and on the phone line that may ask additional or clarifying comments to ensure we accurately capture your public comments. This is a Category 3 public meeting. Your comments during this public meeting and webinar and those submitted to the NRC will be considered by NRC in preparing to report to Congress. However, the NRC does not intend to provide specific responses to comments or other information submitted in response to this request. We will entertain questions today during the public meeting and webinar and try to understand if they relate to comments you or other stakeholders may have regarding Part 37 and its guidance. The phone lines in all conversations are being recorded during the webinar. The operator will place you in a queue if you have comments to provide and inform you when you will be allowed to present your comments. Please do not provide non-public information, which is, for example, safeguards information or classified information. Site-specific information about physical security systems, including design features of alarms, barriers, cameras, security or communication systems. Information relating to on-site or off-site response force, including size, armament of response force and arrival time of such forces committed to respond to security contingency events. Additionally, do not provide information such as guard force, law enforcement, qualification and training, adversarial characteristics and related information. Information from NRC issued orders that are marked SGI or SGIM. If you do not have the opportunity to submit your comments or if you have additional comments to please go to the public meeting website to get the email and mail in address to submit this information. As most of you may know, the NRC published a final rule for the use and transport of Category 1 and Category 2 quantities of radioactive material on March 19, 2013. NRC licensees possessing the aggregated Category 1 and Category 2 quantities of radioactive material were required to comply with 10 CFR Part 37 by March 19, 2014. The House and Senate Appropriation Committee directed the NRC to evaluate the effectiveness of the new regulation and determine whether the requirements are adequate to protect high-risk radiological material and provide a report by December 2016. Today we're going to be gathering general and specific comments on the overall effectiveness and clarity of the requirements for security measures to protect Category 1 and Category 2 sources or radioactive material. And we'll be gathering comments on the usefulness of the guidance documents associated with Part 37. In addition to today's meeting, we have issued a Federal Register notice on March 14, 2016 requesting stakeholder comments. The FRN can be found on the NRC's public reading room, 2016 Federal Register notice page 13263, March 14, 2016. If you are not registered for the webinar and are only using the phone lines to participate in the webinar, please email your contact information to Part37assessmentatnrc.gov. We will identify the common areas in the 10 CFR Part 37 and the implementation guidance before soliciting public comments. At the end of the public meeting and webinar today, we will provide information on remaining webinars and public meeting dates. Actually, there's a change today. This is the last webinar and public meeting that we're going to have in regards to soliciting comments for Part 37. The only areas of the 10 CFR Part 37 that the NRC is seeking comments are from subparts A, which are the general provisions, subpart B, background investigations and access authorization program, subpart C, physical protection requirements to and use, subpart D, physical protection and transit. The only 10 CFR Part 37 guidance documents that the NRC is seeking comments are from New Reg 2155, implementation guidance for 10 CFR Part 37 and New Reg 2166, 2166, which is the physical security best practice for the protection of risk-significant radioactive material. As a reminder, we will not be providing responses to stakeholder feedback. However, we will entertain some questions today if you have some clarifying questions that we can answer. But the focus is on receiving some of your comments and feedback on the rule and its guidance. Please do not provide the non-public specific information pertaining to security measures. As a reminder, the phone lines and all conversations during the webinar are being recorded. Prior to providing comments, we ask that you provide your name and organization that you are representing. We ask that you provide very short, succinct comments during this webinar so that we can afford as many stakeholders as possible an opportunity to provide comments. We'll provide a time check throughout the public meeting and webinar today just to keep everyone aware of the time that we have left for today. So we're going to start with subpart A. And throughout the public meeting and webinar today, we'll give you an opportunity to provide your comments. If we're on another subpart or we're talking about the guidance document and if you want to provide comments on an earlier question or comment or subpart that we were talking about, you may do that. The timeline is pretty loose. So we'll give you an opportunity that if something drives your memory that you want to go back to one of the previous conversations or comments or questions, you can do that. So, Kathy, we're going to start on subpart A. Is there anyone on the line that may have some questions on subpart A? Okay, please press the star one and please record your name and your organization. Specifically, we're looking to understand if there's any comments on the clarity of definitions. Some of the comments we've gotten in the past have been about barriers. Some stakeholders believe that the definition of the barriers or what constitutes an adequate barrier that we need some clarification on that. So if you have those comments, we'd like to hear from you. Questions or comments at this time? Okay, thank you. Also, if you believe that there are some areas in part 37 that need that we should add definitions to, we'd like to hear about that. We've described security zones, but some still have questions or believe there should be a definition, for example, for security zones. So if you have that concern, we'd like to hear about it. That's press star one. Again, if we move forward and if you would like to provide that information later into today's public meeting and webinar, you could definitely do that. But we're going to move on to subpart B. We've gotten a lot of comments on subpart B, particularly where those who are not as comfortable with making T and R determinations or believe that the NRC should provide a more of description of what constitutes trustworthiness and reliability. So we've gotten some of that feedback. We'd like to get more comments if you have any comments on subpart B. And press star one. One moment. Go ahead with your question and say your name and organization. Hi, this is Karen Sheehan. I'm from the Fox Chase Cancer Center. And we're having a very difficult time with getting unescorted access for some of our people who are foreign nationals. It's taken almost close to a year from their initial application to get the information that we need from the past seven years. And another issue that we've come across is a woman who was a stay at home mom for a period of time. And we're not sure how we get any verification for this period, which was in the seven years that she was at home with her children. I would like maybe some guidance on how we could do this. Thank you. So Karen, but before you leave, and we've got a lot of feedback on foreign nationals with stakeholders, not a couple of things. You know, not being able to get the information for a seven, excuse me, sorry, for a seven year period. Also, just trying to verify some of the information when someone's from a foreign country. So, I mean, is there a clarity issue there that we should, do you have a recommendation there? Or do you just think that we're not clear as to what we require from foreign nationals, or do you believe that perhaps we should identify another process or, you know, simplify the process in some other manner? Any thoughts there? Well, our most difficult thing is confirming their education. And I would suggest that maybe if the principal investigator who hired them could possibly vouch for their education, at least in the United States, that may be helpful. That's the difficulty, because we ask for diplomas to prove their education, and that is extremely difficult to get. And I'm not sure what the solution, you know, would be for that. And as far as the stay-at-home mom, we were going to try to get some verification from her neighbors that she was actually there, or maybe a daycare center that she took her kids to. This is the first time we've run into that. So I really don't know how we can, in some situations, get the information, so what our solution would be not to give them unescorted access, because we can't follow the regulation of getting seven years' worth of information. Do you have any? Thanks for the comment. This is Paul Goldberg from NRC. I just had a question on your education concern for education within the United States. Are you saying you can't get a diploma or a transcript? No, within the United States, we're not having a problem. It's the people who were educated in another country. And because at Fox Chase, well, probably all facilities, they do have a lot of people from other countries, you know, who work at their facilities, and to get this information, for example, from Russia, is extremely difficult. Sometimes they don't even have their diplomas, even though they did, you know, graduate. So I just wanted to make a comment that this is, you know, very hard to do. And unfortunately, if we can't get it, then we're just going to have to not give them the unescorted access. We try our best and we have to have a cutoff point because there's other people waiting to take our class, our training class, which is a requirement for safe use and we can't hold up the class of others waiting almost a year to get some of the information for the foreign nationals. So we just have to move on. But I just wanted to make the comment and I'm sure everyone has the same issue that it is extremely difficult. Okay. Thank you. Yeah. Thank you for the comment. The Karen, are you still there? Yes. Now, the other one with the stay home mom, we've had comments as to, you know, for example, some stakeholders have looked at the previous employer, but then, you know, the comment was, you know, is it clear that we're supposed to verify, for example, in this case where you have someone that's a stay home mom, you know, are we required to, you know, make any type of verification there so that there appears to be some need for clearer guidance in that case, but we've not heard about, you know, someone who was a, you know, who stayed home and, you know, and so how do you document that? So we really appreciate that comment. Well, there also could be the case of someone who is just not employed for a period of time as well. Correct. And that could be the same situation. They just didn't have a job, you know, they were out of work for some reason. Maybe it was between graduation and, you know, getting a job. So that's another area that I'm concerned about. We're not going to be able to verify. Okay. Thank you, Karen. Really appreciate your comments. Bye-bye. Thank you. Kathy, do we have anyone else? No, there's no other at this time. We've also gotten feedback from others on, you know, once they provide provide the underscored access for those who are, especially in the education at the universities or research institutions. You know, you have the students that come and they go. So, you know, there's a need for that process to be able to terminate the employees. So some stakeholders have had concerns with that, with they having so many students coming through and they're providing underscored access, a mechanism to terminate that underscored access. Any other questions? Also, we've gotten feedback that, you know, some stakeholders would think that the, you know, they would like the NRC to be more involved in the TNR process and maybe making some of those TNR decisions. We have information in Annex A that help our reviewing officials to understand, to help the reviewing officials to make TNR determinations. Do you have any feedback? We've gotten feedback on Annex A to Part 37. Yeah, I'm sorry, New Rec 2155, but I don't know if anyone now, if you have any kind of feedback on that information that we've provided. Is it clear? Would you like for us to expand on the information to help in TNR determinations? Again, please press the star one. Also, you know, we recognize that we do have a, quite a bit of states to have, to register for the webinar. So we like to hear from you also, if you're from one of the states, you know, your experiences, because you're recently implemented in Part 37. So, and you would have equivalent type of requirements. So, we'd also like to hear from the states if you have some feedback that, you know, we can consider with Part 37. Oh, yeah. We do have someone in the public meeting attending the public meeting that will provide some feedback. That's a microphone. Okay. My question has to do with subpart B, fingerprinting. He let your bag know who you are. Oh, sorry. Kathy Roboto, National Institutes of Health. So, we have quite a large radiator security program for our license. 3729B has a heavily utilized text that we make use of. However, it has a tie-down condition for fingerprinting. This is for identification and criminal history records check. It mandates that as long as the fingerprinting has been within the last five years, it does not need to be redone for a new applicant. That's occasionally caused us hardship because we have long-time employees whose fingerprinting criminal history records check is greater than five years old. So, for only purposes of this one regulation, do we have to route them through the whole criminal history records check again? They don't need to repeat their background investigation, just the fingerprinting portion of it. If you look at comparing that text of the regulation with 3727, which is probably where most licensees would turn for fingerprinting guidance, there's a similar in 3727-4. There's a similar allowance that if someone came from another licensee and already had fingerprints, criminal history records check performed, you can accept it as another licensee. But here, there is no tie-down condition that has to be within the last five years. So, it just seems to be a little bit of a discrepancy to me, and if I were able to offer a recommendation that would be to my benefit, I would say, let's drop that five year. It would allow me to save people the effort of repeating the criminal history records check. So, Kathy, for clarification. So, you're saying in 3729B, if you performed a criminal history check for some other purpose, but now the person is coming for part 37, you can't use that criminal history check? If it's outside the five-year window. Right, if it's outside, but if that individual is coming from another organization, you can use their fingerprint. Because their outside organization had done the fingerprinting check for purposes of part 37. Even if it's outside of a five-year time period? It doesn't address timeliness of the... So, I would have presumed a six-year-old criminal history records check if it came from another licensee would have been deemed acceptable. That's how I read 3727A4, just to get the regulation properly quoted. Great. I hope that makes sense. Any comment from in your room? Paul, Dwayne? Okay, great. Thank you. And I would say we've gotten a lot of good feedback, like with Kathy has just provided and Karen has provided. So, again, if you have any feedback for subpart A or subpart B, we would like to hear from you at this time. Please press the star one for any comments or questions. Also, we've gotten feedback for review and officials having a health science background and not being comfortable making T&R determinations. I don't know if that's been your experience, but if that's the case, we'd like to hear about that also. Also, we've heard some stakeholders will, especially at some of the federal facilities or universities where they may have a law enforcement component, they may have the law enforcement component performing some pieces of the T&R process to figure out printing and reviewing some of the background information that they receive to help in that T&R determination. So, we've gotten some of that feedback. And we've actually got one person who was concerned that that process is bifurcated in that manner. So, if you have that concern or if you have experience that we'd like to hear from you. And we do have some folks in the room. So, I'm reading my notes. So, if you have a question, just do it, Kathy. They just get my attention. Yell at me. It's about 125. So, we do have a lot of time left. I'm trying not to rush the process. But again, if you're not clear on the barriers or if you have any comments on subpar B, we'd like to hear about it. You know, we've had some comments on a continuous barrier. The definitions of an adequate barrier. So, that was really good feedback. And again, we've had a lot of feedback on comments on subpar B. So, if you have any of those comments, please, please let us know. Okay, if we don't have any more any comments on subpar B or subpar A, we're going to move on to subpar C. Again, if, you know, within the conversation, if you believe you do have comments and you'd like to make comments, please, you can make comments on subpar A or B at any time in doing this process. Subpar C, we've got a lot of, you know, comment on the support for physical protection of the sources. A lot of feedback on local law enforcement coordination. A lot of the stakeholders believe that that requirement, that they've not had the opportunity to coordinate with local law enforcement because LLEA, the local law enforcement agency, will not commit to a certain time period because, you know, they prioritize their responses. So, if you have some of those, that feedback, we'd like to hear about it. But again, as you provide feedback again, we'd like to remind you not to provide any non-public information, especially, you know, it's easy in this piece with the, or this subpar with subpar C when we're talking about the physical security of the sources. So no public information or safeguarded information or classified information, if you do provide any type of comment. Also, from the universities, some of the feedback was around the relationship that you have with your local law enforcement at a university. And the point was is that, you know, a licensee may contact the local law enforcement for the mere fact that it's an incident that's occurring. And so where does that line, where's the distinction as to when the the licensee has to notify the NRC if they're notifying local law enforcement. So if you have that experience, if you think there needs to be some clarity there, we'd like to hear those comments. Also, with subpar C, and we'll get into that, I guess, more with the 21, New Reg 2166, but, you know, some stakeholders have talked about the fact that, you know, it's been helpful to have some of the retired police officers, or if they have a security force or a local law enforcement force at their facility, you know, they've relied upon those, that entity to help them establish physical security measures. And some have really relied on that, you know, those who have been, you know, retired law, you know, they could be law, they actually have law enforcement at their facility. And some of those, those law enforcement personnel at their facilities are actually retired law, local law enforcement. And they found that to be very helpful. You know, again, we, we'd like to hear about the continuous barriers also, which constitutes the security zone. If you have any, any comment on that, we'd like to hear about it. And please press the star one. It's about 130. So we have quite a bit of time left if you'd like to make comments. And also we'd like to remind you that if you do, if you do not make comments today, or if you, if you believe that you'd like to make additional comments, you can always please make those comments by May 13th to be considered for, for our assessment efforts. Just go to the, either www.regulations.gov or you can go to the public web page and submit your information. You can also mail that information into, to the NRC. And that's on the public web page also. We ask that you always include the docket number if you're going to send that information in via email or, or if you mail it in. The docket number is, the docket ID number is NRC 2015-0109. You know, one of the other things we're doing, doing this assessment is we're, we're looking at the outreach process that we've engaged in to inform the stakeholders on the assessment, I'm on the assessment, but part 37, the requirements, the guidance. You know, we've gotten feedback from, from some who have not, who are not getting that information timely. So if, if, you know, if you have that, that issue, we'd like to have that feedback also. We've gotten quite a bit of information on security zones as far as establishing security zones and controlling access to security zones. So if you have any feedback on, on security zones, we'd like to get that feedback. And, you know, speaking of subpart B, one of the, some of the feedback we've gotten is some believe that the 10-year period, 10-year period to reassess those for, for a trustworthiness and reliability, doing the background checks, whatever. It's just the 10-year period is a, it's a long period, it's the, that it should be maybe five years or three years or two years. If you have any feedback on that, we'd like to hear about it. I mean, one person, one stakeholder rather, made sure we understood that, you know, one to two years is, that period is, is too short. You know, it would, you know, that would be a burden on licensees to try to, because some licensees have quite a bit of employees or students that they provide uninscorted access to. But some believe that the, you know, the 10-year period, 10-year period was a, was a long period to, to have a person to, to be reassessed. Also, we've gotten some feedback on having some sort of, you know, or that some stakeholders actually implement a process where they are looking at their employees on a more frequent basis. They've instituted that process themselves, themselves, they've instituted that process. So if you have that, if you have that experience, we'd like to hear about that also and how you're implementing your process. If there are any PRT members on the line that would like to make any additional, pose any additional questions you could, you can at this time. Hello. I had a first to see if there anybody out there has any concerns about the way the word aggregated is defined in part 37. Great. That's Bob Cotone from Region 3 NRC. Thank you, Bob. So that's, that's one of the areas we're looking at, the definition of aggregation. Is that clear? Do you understand the, the, the definition of aggregation? Is that a better term to use as opposed to co-location? Is co-location clear than a term aggregation? Bob, do you have any other questions you'd like to pose? Yeah. I wondered if there were opportunities to more clearly understand what's meant in the rule in terms of monitoring, detection and assessment. Great. Thank you. In a specific context of what I've asked for, there have been some comments or discussions in previous webinars where a licensee employee drives a vehicle with two material and parks the vehicle with that material inside the vehicle in, in a hotel parking lot while the employees are in the hotel overnight. So again, this would be focused on detection, assessment and response to an intrusion to the vehicle containing that material. If there's any clarity that you think might be worthwhile, you know, for us to consider, please say so. Great. Thank you. So it's about 20 minutes till two. So we do have quite a bit of time if you, if you'd like to make comments. Again, for comments, please press the star one. And as I mentioned earlier, if you'd like to make comments and you don't make those comments today, you have to May 13th. You can email that information to us. You can mail it to us. You can get that information on the public website. You can ask to, where to mail the, the comments. The feedback that we had was involving weekly checks of category two material in terms of how to do that to comply. So if there's any clarity suggestions on that, please provide it. Okay. Not, not hearing any feedback, any statements or comments for category subpart C. We're going to move on to subpart D. And again, I'd like to remind you that you know, the all comments or conversations on the phone lines are being recorded today. Also, if you provide any feedback, please do not provide any non-public information, safeguarded information, classified information. And if you have comments on subpart A, B or C, you can provide it at any time. So if you have any comments on subpart D, we'd like to hear from you at this time. Okay. Please press the star one. Again, there was a question there were reporting of events in subpart D. So if you have any, any questions there, we would like to hear, hear from you. The clarity of the requirements to report events. One of the, the comments we have received was again, you have your facility, facility or you have a vehicle with category one, category two stores, for example, in it, and someone has broken into the vehicle. Do you have to report that information if it's clear to you that the person was trying to steal, for example, a phone in the front seat of the, of the vehicle and not get access to the, the material, the category two material in the back of the vehicle. We had gotten feedback and comments on that that, you know, that may not be as clear. Again, if you have any comments on subpart A, B, C or D, we'd like to hear from you at this time. We have one coming up, one moment. Okay, Mel, go ahead and state your name and organization. My name is Mel Frable with concrete imaging incorporated. I work at temporary job sites, industrial radiography, performing concrete radiography through at the DC Baltimore McPalton area. Questions, I keep hearing about this leaving category two material in a parking lot in a locked up vehicle overnight. My thing is, when I have a isotope in a vehicle, I was plainly told that I had to have eyes on that device the entire time that that device is out of permanent storage. Why is this being, I think that rule needs to be strickened. That should be banned. They shouldn't be allowed to have an isotope in, even if it does have any theft, GPS and everything else on it. No, no, that still doesn't, that still doesn't see well as far as samples are. Thank you. So your comments that licensee shouldn't be allowed to store a source in a vehicle overnight in a hotel? Me is, I mean, because I was plainly told, you know, by an NRC inspector doing an audit, that I had to have eyes on a device at all times, even if it's locked in the storage in the truck, there has to be eyes. There has to be someone in the truck or eyes on the truck at all times. That device is out of public storage, I mean, permanent storage. So to me, that's, you know, keeping a device in a motel, even if it has remote sensing devices and stuff, that still doesn't, that still doesn't set well as having a human being out there watching that piece of equipment. Great, thank you, Mel. Questions or comments? We do have a comment here in the public meeting. Hello, Cathy Robato, National Institutes of Health, again. So I'm going back in time a little bit to subpart B. This is 37.25 background investigations. I don't know the basis for the requirement that states the background investigation must encompass at least the seven years preceding. I don't know if that was just an arbitrary number chosen or if there's some basis for choosing seven years. In my particular case, we have to, we have quite a large program of folks, we have to TNR undergo a trustworthy and reliable determination. And at our facility, all badge holders automatically get a background investigation that goes back five years. So this seven years is a hardship because on top of the investigation, they're already required to get on the basis of their employment. Now, for categories of people who are not federal employees, anyway, I have to request this additional two-year gap. And that's a problem. An earlier caller had said four nationals in particular. That's certainly the case for us. And I would echo the difficulties that four nationals pose to become eligible for TNR. It's a really tough case. But even for U.S. citizens, this two-year gap poses a lot of administrative difficulties. Because we're such a large program, it's a workload issue. And it's also a matter of, it seems duplicative in our case that if it were possible to make that a five-year look back, then the default background investigation that OPM defines for all federal facilities as minimum would suffice. And there wouldn't be a need for an extra above and beyond two-year or however many years on top of that. That's possible to consider. Great. Thank you. Any feedback on the seven-year period, the background on that? This is Willily. Kathy, are you suggesting perhaps five years would be more appropriate and you have a reason for saying that? Five years, in my opinion, would be appropriate because it would make my program a whole lot of easier to implement. So just from my own program's perspective, five years is the default look back that everybody gets. And it wouldn't be an additional burden just for the TNR population of folks. I also don't really know what the additional two years get you from a security perspective because five-year look back versus seven-year look back, the elements won't change for most of the things you're looking at. The education won't have changed. The personal references won't have changed. It's really just the additional employment they may have had for those two-year gaps. The look back would go a little bit farther in time for an employment verification. But we already do the education verification and the personal reference with the five-year look back. So the only thing you're gaining is an additional two years beyond the most recent five years for employment verification feedback. Is that really relevant from a security perspective? Will it give you added information that justifies the burden of going seven years back versus five years? Is that along the lines of an explanation you're looking for? Well, yes. And I was trying to remember back to the part 37, the statements of consideration. I think it was discussed briefly, but I don't recall exactly where the seven years came from. But it seems like it may have been involved with some things that were in the public record, maybe like credit checks, that kind of thing. But then credit checks went away. It's not part of part 37. So thank you very much. Thank you. Thank you very much. Again, we're soliciting feedback from comments from subpart D. But if you have any comments on subpart A, B, C, or D, we would like to get them at this time. And again, a lot of the comments we've gotten, I mean, it's on the line of what we're hearing today. And if there's clarity, we could clarity that we need to pursue or really look at some of the processes such as the seven year as opposed to five years, we'd like to hear those type of comments. From Aaron Sheehan. Karen, Karen, sorry. Go ahead, Karen. Hi, this is Karen Sheehan, again from Fox Chase Cancer Center. And I'm not sure if it was you, but someone mentioned about the maybe feedback on the direct visual surveillance in subpart C. And the category two surveillance in particular, weekly verification, it states in C2 that it needs to be through physical checks, tampering, indicating devices, use, or other means. So can it be a combination of those or does someone have to every week physically walk down to check to make sure that the source is there by using a meter? I just wanted to see a clarification on that. Hi, Karen, this is Paul Goldberg. You're talking about 3749. Yes. A3, double I. It's actually C, double I. Well, it's kind of hard to tell because there isn't A at the top. 3749C, you're talking about? I think you're talking about 3749A3, double I, the weekly verification for category two material. Yes. Okay. So, yeah, it could be a combination of means. We would just want to see that the licensee had a procedure for doing this in some fashion on a regular basis. And if, for example, you ordinarily do it through use, there are materials that are taken out daily or several times a week, but there are occasions when they're not taken out for a week or two at a time, we could accept certainly that you ordinarily do it through use, but other times you do weekly verification through physical checks. Well, also we would like to include the fact that we didn't receive any alerts that any tampering indicated devices were compromised. Well, this is a separate requirement. You mean you didn't receive any checks that people entered the area? Well, they don't always, as far as use, we don't always have a user every week or every two weeks, but in the regulation, it states that it could be through tampering indicated devices. Yeah, well, these would be devices that indicate tampering which we have with the material, not just entry into the security zone. No, we have other security methods that include a indication if the source was tampered with itself. Yes, that would be adequate if those are checked at least weekly. Well, that's monitored 24-7. Okay, so these are alarms or sensors of some sort? Sensors, yes, that were put in through GTRI. Okay, and they are continuously monitored? Yes. Well, I think that would be acceptable. Okay, so it's really for us, it would be a combination of use and the physical presence and the tampering devices. I just wanted to make sure it didn't have to be a physical check only. Right, no, it has all those measures and you can combine them as necessary as long as we know that you have a program to do that. Yes. Now, Karen, just as a quick comment, Paul is commenting on what you've described to him. Obviously, Paul is not going to be the one to go out and do inspections on you, so just make sure with your regulator that describe it to your regulator so you can speak more, you can get into non-public information so you can get a good description. But I think Paul is commenting on the fact that yes, you can use a combination of those methods. It doesn't have to be a single method in order to meet the requirement 3749A3. Just want to make sure I clarify that. Yes, we certainly would review this with our regulator and it is part of our security plan. It's mentioned that we will use a combination of all of them. I just didn't want to make sure that I wanted to make sure that that was okay, that it would be a combination. Great, thank you. Based on that discussion, does anybody out there think there's a need to provide more clarity with that requirement? Great, even Karen, do you think that needs to be more clear? Yeah, I think it could be more clear. It could maybe say through one of the following or a combination. I think that would make it a little clearer. Great, thank you, Karen. Thanks for the follow-up, Bob. George, I have two comments from the webinar. Both are from Mac Richard. One on the previous topic that Karen just brought up, his comment is that constant video surveillance would also appear to meet the weekly requirement to ensure the radioactive material would be present. And then Mac had a follow-up comment to what Kathy brought up, which is that our human resources group also typically use a five-year interval for new employees. The seven years does cause an additional burden for no apparent benefit. Great, thank you. Also, I'd like to emphasize the fact that you can submit your questions through the webinar. That's one thing I didn't mention earlier. So, Paul, you had some follow-up. Yeah, with respect to the first comment there about continuous video surveillance, this would have to be somebody continuously watching the source if that's what you're talking about. We just require weekly verification. So, I'm not sure what the continuous video surveillance would involve. So, who was it? Was it Mark? Mac? So, Mac, if you've called in, if you could maybe provide more insight or you can provide that insight through the webinar. Just clarification. So, would really help Paul to understand exactly what your comment is exactly. And that would help us understand if some clarification is needed there or perhaps Paul could actually answer your question. Again, if you have any feedback and support. Mac? Yes. Your line is open. Okay, this is Mac Richard. I had trouble getting the phone to work a minute ago. So, that's why I was typing. The question about what I mean by constant video surveillance, we have video, I mean, our campus police department is tied into video on the entrance to the rooms where these sources are located. And as such, I can't say they're looking at that camera 24-7, but it's one of several constant video systems that are operational. So, that's kind of what I mean. And then, of course, the tamper indicating devices. And I think one of the other folks mentioned the GTRI systems, those tamper indicating devices are always present and they indicate if there's anything wrong with them or if they fail, we get an indicator that there's something wrong with that device. So, again, that's a constant, I mean, that's constantly operational 24-7. So, it would seem to me that if you've got constant things like that going on, the weekly verification, I mean, it's not like we go down and check off that we do this weekly. It's constantly going on. Right. Mac, just a couple of things. But in this conversation, just want to remind you not to provide any non-public information. Right, I know. So, what organization are you with again? Indiana University. Oh, Indiana, okay. Well, just a quick comment. As far as the GTRI, those, do you call it upgrades or enhancements? Okay, we'll call enhancements. So, the GTRI enhancements, do you understand as far as the GTRI enhancements meeting part and that in conjunction with meeting part 37 requirements, have there ever been a question as to utilizing those enhancements for meeting part 37 requirements? Well, absolutely. I mean, we had an NRC inspection about the 1st of March and obviously, with those enhancements in place, the inspectors feel like that our program in combination with that met all the requirements. Okay, great. Thank you. Sure. We do have a comment from Chris. Chris, please state your name and your organization. Hi, this is Chris Dugan with TV, Ryan. I had a question regarding subpart C or just a comment for clarification regarding the general security program requirements and the protection of information. Part D gives a number of documents that are required only for those with unscorted access. And my question was for clarification whether or not our actual physical license would fall within that criteria. And if so, how would that apply to the postings of that license under part 19? So your question is would your license part, I'm sorry, fall under the need to be protected? Correct. Yeah, it's not stated in part 37, but it's one of those items that have come up during numerous audits and discussions, whether or not the actual physical license should only be available to those with unscorted access given the information that's on it. And then how would that affect how I should post it for the requirements of part 19? And Chris, what's your last name and what organization again? Okay, the last name is Dugan, D-U-G-A-N, and I'm with T-U-V, Rhineland. Okay, great. Thanks. Paul, do you have any feedback? Yeah, Chris, thanks for the question. Yeah, so I think you're talking about 37, 43D provision on protection of information. So ordinarily we just require protection of the security plan, the implementing procedures, and the list of people with unscorted access. Your license itself would not ordinarily have sensitive information in it, security related information. If you somehow do have sensitive information in that, you ought to probably discuss it with your regulator, because ordinarily there wouldn't be. I don't think there's necessarily a defined sense of it. It was just the thought that with that information you could have an address, the type of location, model, make, things along that line where that might be considered part of it. Just a thought. Well, we try to avoid making public any information which identifies licensees, where Category 1 or 2, which have Category 1 or 2 material or licenses, or I'm sorry, addresses, where it's located. So yeah, as a general matter, we wouldn't, we would avoid making that public, but we don't require particular measures under Part 37 to protect it. Okay. Part 19 will require for me to post that license. This is Bob Gutton. Some of the licenses that they are, they would be marked if they're NRC that would say on the top and the bottom office use or officially help only security related information. And that goes with what Paul just said. So if you find that your license is marked like that, then you should keep it secured. And then if an inspector comes and asks, wait, why didn't you post the license? Or you could also post a note where it is or how to get to it for people that are interested in reading it. And then because that's security related information and then once the inspector understands that, then there shouldn't be an issue. Yes, Bob, that's currently the status we do. We have just a post saying that the license can be stored, you know, is found for review at the RSO's office. But, you know, sometimes it goes one step further with any type of hard copies that the guys have. They must keep controlled anything that's emailed back and forth. So I know the license doesn't fall underneath the Part 37, but just was curious. Okay. Great, thanks. Yeah, Chris, we do have some additional guidance on that under a regular regulatory issue summary document. It's designated RIS 2005-31, which says how you should handle any information that is sensitive, unclassified, non-safe guards information. Thank you. Thank you for the comment. Thanks, Paul. We do have Mac with another comment. Yeah, one of the things that from the practical side, like we're a broad medical licensee and vendors that we ship materials to will request copies of our license. And of course, that license has, you know, a list of, you know, these various sources, model numbers, etc. So the practical approach we've taken with that is to simply we will scan that license into a PDF file, redact that information, which just you basically block it out so they can't see the source information, etc., etc. And the cover letter goes with that license and basically says this license includes redacted information that is not germane to, you know, your particular use if you haven't fallen with that contact us. And that's kind of how we dealt with that. And that seems to work pretty well. Great, thanks. Thanks for the comment, Mac. Yeah, Mac, are you familiar with the license verification system? Yeah. Do you transmit, do you go through that for that purpose? If you're shipping material, the vendor, you're shipping material to the vendor, is that what you're talking about? No, no, no, we're receiving material from the vendor. All right, well, they should be able to check LVS for your license. Most of the vendors are I think are familiar with that. Well, the other thing, well, the other thing that can happen with universities, if we do have to ship material from one licensee to the other, they may ask for a copy of our license as well. So I mean, as I said, we've tried, we've done the redaction approach and that seems to work. Maybe some of the vendors aren't aware aren't aware that they can do that either. Yeah, I mean, that's an acceptable approach. Generally, if you ship on any sort of regular basis, it's maybe easier to use the license verification system. Right. Yeah, we don't, fortunately. Normally, we're on the receiving end, not on the shipping end. Well, I would just expect vendors to generally use it. So, yeah. Yeah. Okay, thanks. All right, thank you. Thanks. We have a comment from Andy Welding. Yes, this is Andy Welding at the University of Notre Dame. And it's more of a question, maybe, than a comment. We have the campus police force with sworn officers who, of course, are permitted to have unescorted access to the sources. But the question or the concern I'm dealing with is the access to the security plan and the implementing procedures. We have people on the security staff who are not sworn officers and would never really need to have a need to have unescorted access to the sources, but wanting to train them to know, for example, if there's an incident where these sources are located, and to alert dispatch people to get sworn officers to the site, how extensive do we need to do a, called a TNR program without the fingerprinting process, of course. But who should really be involved in the background checks and that sort of thing for non-sworn officers? This is Paul Goldberg. So, for people who aren't TNR, but need to know something about the security plan, you can train them on the portions of the security plan that they need to know about. If they have access to the material, they definitely have to be TNR'd. No, they would not. If they have access to the sensitive information, that is the security plan, the implementing procedures and the list of people with unescorted access, they also have to be TNR'd, but without fingerprinting. If it's something short of that, that they just need to know, if you see this alarm, call this number, for example, call local law enforcement or respond to this area that doesn't involve access to the sources, you can just train them on that without having to worry about additional the TNR requirements under Part 37. Yeah. Well, that's right. I'm just kind of questioned where the term implementing procedures stop and end. Obviously, these are not people who are going to be making an armed response, but they will need to maybe notify an officer to make an informed response. I think I've got it clear, but for example, we're going through this process with our dispatch personnel, but not necessarily we necessarily need to do it, for example, for the person that does nothing but write traffic tickets. We're training him to be alert to parking tickets. I mean, we're training him to be alert to any sort of suspicious activity near the facility, but would that require TNR for that type of information? No, I wouldn't think so. Okay. Okay. Thank you. And again, Andy, for clarity. Are you still there? Yes. Yeah. So just like that person you're training just to the person's writing tickets, you just training them to alert the other police authority if they see something suspicious. And that's it. You're not explaining your facilities and what's stored in the facilities and the process of access facility. You're not giving them any of the non-public information. Is that correct? Correct. Okay. Great. Yeah. Andy, let me refer you to Part 3743C of the rule, which is training. And in our guidance document, New Reg 2155, we have some additional questions and answers that bear on what you're talking about. On page 134, for example, question and answer for the rule requires the extent of the licensee security training for affected individuals to be commensurate with the individual's potential involvement. Okay. In the security, should all individuals on site be considered to have a potential involvement in security emergency and therefore require training? The answer is no. Although it's good practice to provide some basic training to all employees, e.g. details on how to respond to an alarm, only those individuals with security responsibilities must be trained. And so you can give partial training that's relevant to their responsibilities to people who need it without having to TNR them, unless they have access to the material or the sensitive information. Well, that's the pattern we followed. We've been doing that now for a few years. The issue there is it seems that they would at least have to know what building on campus we're concerned about, that sort of thing. And I don't know if beyond, other than telling them how to get to it, and they can't get to it because they don't have the access to it. So they don't have the codes to get in and that sort of thing. Well, again, any detailed questions about this, check with your regulator and your inspector. But as a general matter, telling them how to get to a particular building on campus shouldn't be a concern. I'm pretty comfortable with that then. Okay. Thank you. Thank you, Andy. Thanks, Paul. Any other feedback on subparts A, B, C, or D? And again, you can't press the star one. And again, you can't submit questions through webinar if you'd like me. We'd like to remind you, if you do not submit any feedback today, you should do so by May 13th. You can do it via email or mail the information in. If you go to the public website, you'll see that information on how to submit your comments. Have Mac again? Yeah, I've got a question on interpretation. It's 3723E5. It's about maintaining the list of persons currently approved for underscored access. And the interpretation question I've got is it talks about you have to remove that person as soon as possible from the list, but no later than seven working days. Now, my question is this. We typically, because we've got a large number of people authorized, we get an updated list from some of the, well, security person that kind of maintains a lot of this. On a monthly basis, we ask for an updated list. We also tell people that have underscored access that if they leave the institution, they should notify us that they are doing so, and then we would obviously take them off the list. Now, my question is, let's say a person leaves on the, I don't know, 5th of May, and we get that list, and they don't notify us that they have left, which we tell them to, but they, of course, people always do what you tell them to do. And then we get the list at the end of the month and find that that person's no longer, on that list, or that person is no longer, has a badge ID, which is how we determine their access. The question is, are we in violation of that section of the rule? Do you want to, if I can get back on it? Well, again, I think that's something that your regulator and your inspector would have to determine, but we've heard this concern before, particularly from universities, where you have students coming and going, and you may have investigators coming and going, and similar things, I think, from large medical institutions. So, we realize this is potentially an issue, but... Well, let me say this, if I were to be called on that, I guess my interpretation is that the set of the clock starts when I determine that person has left. The rule says when a licensee determines that a person is no longer, it doesn't say when the person is no longer employed, it says when I determine that, then I've got seven days to remove him or her from the list. And that would be my interpretation, especially if, you know, if somebody, well, you're in violation because that person left 14 days ago and you didn't take them off the list, but then I'm going to say, well, I didn't know they had left. So anyway, the point I'm making is it may be worthwhile to clarify that, or maybe it is clear, as long as that's the way it's interpreted, you know, I don't have a problem with it, but I can see that being interpreted, well, seven days when they actually leave. That's just my point. Yeah, I can't give you a legal interpretation, but I certainly see your point. I think it's worth trying to clarify that. Yeah, this is Bob Gatone, Mac. I can't interpret on behalf of the NRC, like Paul said, he can't either, but it appears to me that the rule, the concern about the UAA list being revised, it sounds to me from what I heard from you, Mac, that there's an opportunity to increase or accelerate the communication of those changes so that you have enough time to revise the list within the period of seven working days. So you're saying that I need to request that list more frequently? Well, it's based on what changes, if any, has occurred during overtime. So if there is, like, say, a hundred people on the list and one of them gets removed, you have to update that within seven working days, as I understand it. So if you're having trouble getting that communication, because you only get it every month, I think you said, then you're setting yourself up for potential late revisions. So there is some place where it says we have to revise that list and I think you have to keep it updated and you have to, you know, and if somebody, it has to be revised within seven days of the change, as I recall. I don't have it in front of me, but yeah. I'm looking at the rule, it just says when a licensee determines that a person is no longer requires unescured access or meets the authorization requirement, the licensee shall remove the person from the approved list as soon as possible, but no later than seven working days. Right, so as soon as that determination is made, then that's when the clock starts. Right. So I agree. I think, and like I said, it may be when I may not be notified within seven days, but as soon as I am notified, then, you know, we're going to take them off the list. Right, but if you're not the one that determines the change and you don't get notified of the change until after the seven working days, then you're going to be late. That's why I'm saying the communication needs to be quicker, it sounds like, from what I hear. Well, I'm making the determination for the licensee. Okay, well then you can do it as soon as you can, at least in seven working days. Right, we're the maintainer of the list. I guess that's the right term. Okay, then okay, I guess I didn't totally understand before. Hi, this is Margaret Cervera from the NRC. I was just listening to the discussion, and I'm staring at the requirement or another requirement that talks about the determination. So maybe this is an opportunity for a place where we can at least update the guidance or something about what exactly that determination is, if that is, when you get the list, if you only get it monthly, does the determination happen when the holder of the unescorted access list receives information about employee actions, which could be handled by an HR department or some other place, not the licensee necessarily, or does that determination happen the day an employee leaves? So maybe am I hearing that that could potentially be an opportunity for us to enhance what it is that we're aiming for? Yeah, I think so, because I mean, as I said, it's a little bit open to interpretation, and I can certainly see it interpreted multiple ways. And so I think we've pretty much got it covered, like I said, as soon as we know, and honestly, some people, when they're leaving, they do notify us. I mean, and again, that's part of the training that we provide them. So seven days is a pretty short turnaround time. I will say that, but anyway, I think there may be an opportunity and maybe in your guidance to clarify. Thank you. We'll take it under advisement. Thank you very much. Kathy, do we have anyone else? There are no more comments or questions at this time. Great. Thank you. Again, if you have any comments on subparts A, B, C, or D, we'd like to get those comments. If you had any great comments today, we really appreciate that. Also, if you have some clarifying questions you'd like to ask, we would entertain those also. But we're going to move on to Nuregg 2155, actually. If you have any comments on Nuregg 2155, we'd like to hear those comments. Again, I spoke to this earlier. Some stakeholders have actually used Nuregg 2155 to help establish their security program. If you have some of that feedback or experience, we'd like to hear from you on that. We've gotten feedback that 2155 is actually too large. There's too much information. Some of the feedback we've given in today's respect is that you could actually do a word search in 2155 if you believe it's too large. But we did get that feedback that it's too much information, that it needs to be less information and more direct information. So it's almost, it's about 225, so we do have a couple of hours left that we could provide information. So we would definitely like to get feedback, some of the comments from from your perspective. We appreciate the array of stakeholders who've actually registered for the webinar, who's calling in today. We really appreciate those who've actually come here for the public meeting. We really appreciate it. We appreciate all of the comments that we've received thus far during the four webinars and the webinar and public meeting today. So thank you again. And again, I'd like to remind you that if you would like to provide feedback later, just please do so about May 13th for us to consider it for this assessment that we're currently conducting for Part 37. A question was also posed as to how we're going to use the information that we're receiving during the webinars and during the public meeting in webinar today. We're basically taking this information and we're going to bend it and then we'll have specific comments for each of the subparts and we'll take that information and consider it for either rulemaking or revising the new regs or even taking that information and sort of doing further research to get more technical folks involved and get some, maybe get some stakeholder, further stakeholder input to see the impact of those comments. So just want to let you give you some feedback on that. We've actually gotten some feedback since the new reg 2155 is a really good product also that they appreciate the questions and answers that provide a lot of clarification. If you have that comment, we'd definitely like to hear your experiences there too that it actually helps a lot to have that product at hand. Here in no feedback, we're going to move on to the new reg 2166, the best practice document. Again, if you'd like to get feedback on subparts A, B, C, D, or new reg 2155, you can do so at any time during the webinar and public meeting today. Again, we've gotten feedback on new reg 2166 that it's a good document and some have actually used that document to help establish their security program. We've also gotten feedback that some believe that we could have gotten the document earlier and they would have appreciated to have it earlier to help establish their program. So if you have some of those comments, we'd like to hear about them. Also, if you're not aware of new reg 2155 or 2166, we'd like to hear those comments also. We have had interviews and we've gotten feedback that there have not, but whether you've had some stakeholders that was actually not aware of new reg 2155 or 2166. Again, if you provide feedback, we'd like to caution you not to provide any non-public information, safeguarded information or classified information. And again, we're also entertaining questions if you have questions for clarity. One of the things we will try to do is if you have questions, we'd like to try to bring it back to the format of the seminar and maybe there is a opportunity for clarity or revision of role or guidance with that sort of embedded in your question. So if you have questions, we will entertain those questions. Hi, this is Margaret again. I just wanted to bring up George mentioned that there were people who had mentioned that they weren't aware of the availability of 2155 and 2166. I would like to add to that list the crosswalk that we have available on our public website, which compares the orders that have been in effect for the past what almost 10 years now and part 37. So to make it easy to figure out what the differences are between those two sets of requirements and make it just that much easier for licensees to implement. So just a plug for that document as well. Thank you, Margaret. That is really good information, really good feedback. We've had some stakeholders not aware of some of the differences between orders in part 37 or some may believe that if they're in compliance with the orders, they are in compliance with part 37, but there are some differences. The orders weren't just codified where there were some other requirements placed in part 37. So good feedback on the crosswalk. If you're not aware of the document, please go to the website to look at that, the crosswalk document. Again, we'd like to have feedback or comments on subparts A, B, C, D, New Reg 2155 or 2166. Any comments or questions? Press the star one. Any other comments in the room? Okay, just as a reminder, you can submit your comments via email or you can mail that information to us. Please go to the public website to get that information. We were scheduled to go to 5 o'clock, but if we don't have any other comments, we're going to close the public meeting and the webinar out at this time. We'll give it about a couple more minutes. If you have any other comments or questions, we would like to entertain that at this time. And again, that could be on subparts A, B, C, D or New Reg 2155 or 2166. We'd like to say if you have comments, please do not provide any non-public information during your comments. We've not said it in a while, but all of the comments and the conversations are being recorded. Okay, one last time, Kathy, are there any other comments? We do have one coming up, one moment. Go ahead, Karen Sheehan. Hi, it's Karen again. I just wanted to say that 2155 and 2166 were very helpful with us developing our security plan. In fact, we used the information that is in the appendix security plan content appendix A to keep us focused on writing our security plan. And we actually each took a section and focused on that. So hopefully that comparing it to part 37, we covered everything that we needed to and we haven't been inspected yet. We are in agreement state, but hopefully when we are inspected and the inspector looks at our plan that they are in agreement that we've covered everything we needed to. Great. Kathy, get one follow-up question. We've gotten feedback from stakeholders that would like to benchmark other licensees. And some have question as to what type of information or how much information they can share. Have you have any experience in that area? No, no one's asked me. Because I guess the concern is, hey, if I shared his information with another licensee, do I have to TNR that person before I shared that information? So that's just some of the information, some of one of the comments that we've gotten back. So just want to see if you had any kind of experience in that area. Thank you. You're welcome. If there's anyone else out there who has experienced or who've experienced that, they would like to either share or benchmark other licensees, but there's a concern there as to does the licensee or individual you're going to share that information with? Does it have to be TNR? Do you have the TNR that individual? And how much information you can share? Have Steve Meyer? Great. Hi, this is Steve Meyer, Stars Alliance. I have an unrelated question I wanted to ask before you close out the meeting. I may have missed it earlier, but what is your timeline for evaluation of this feedback and in what form would we expect to see that? Like, you know, what kind of information or report are you going to produce and what will happen after that? Yeah, great. We have a report that's due to Congress in December of this year. So the information we're receiving, we're taking information back and we have a team and some of that team you've heard from today have answered some of your questions and provided some of the feedback to your questions and statements. We all take that information and we sit down and evaluated to determine, you know, if there are some possible enhancements that we could gather from that information for the new regs or is there an indicator for rulemaking? There's a separate petition for rulemaking that was submitted that the NRC is considering for Part 37. If there is any recommendation for rulemaking that the Commission believes should be included in Part 37, then we'll combine our efforts with that petition for rulemaking. And I think that effort may start in the fall of this year. But just to emphasize, we have a report that's due to Congress on the effectiveness of the Part 37 requirements to protect Category 1 and 2 material. So we'll take this information that we have to support that report. Congress only asked us to look at the events and the findings, the violation of the findings from inspections and the material events for Category 1 and 2 in order to complete that report. You know, we're doing more of a holistic review to support the report to understand if there are other enhancements that could be gained from taking a hard look at the Part 37. We've also had an independent review conducted by some consultants and their report is going to be part of this review also. And finally, within two years after we submit our report to Congress, the GAO will come back out and take a look at Part 37, the effectiveness of Part 37. Okay, thank you for that detailed response. Great, thank you. Okay, we have a comment from Mac. No, sorry. I thought I did, but I don't. My fault. No problem, Mac. And again, if you remember or you think there's something you'd like to comment, you could always submit it via email or you can mail that information into us. Okay, we'll give it a couple more minutes and then we'll close out. It's about 22 or 3. We have a couple of hours left if you want to make comments. We are here to receive those comments. And we really would like to receive those comments because it helps to have those stakeholders who are actually implementing Part 37 and those who are performing inspection oversight to give the staff the information to enhance Part 37. So we really appreciate the feedback we've gotten thus far from the four webinars and today the webinar and the public meeting. So we really appreciate that feedback. If you have any feedback on any of the subparts or 2155 or 2166, we'd like to get that information at this time. Would you have a comment from Mel? Okay. Yes, my name is Mel Frable of Concrete Imaging again. I have a question regarding agreement state requirements. Our info and documentation at the time of initial reciprocity recognition is handed over to them in order to get the recognition in which they do review and they approve. And then it's updated annually. The requirements for them is that all times when we work on temporary job sites in their state is that we were required to keep a physical documentation with us, which has all of our sensitive and non-sensitive information, training materials, everything. This book is 500 some pages big. As far as security of it, it is secured in the vehicle when it is on the temporary job site. However, I feel that with the change in times and everything that I think it needs to be addressed that we need to update this and remove this to a point to where, for one thing, I annually, like with the state of Virginia, I annually update them with my O&E and stuff like that there, like with Perlin, with digital copies of our O&E and stuff of that nature. And what I'm getting to is that it should be to where, instead of having this book, which is actually, I feel, leaving those open for violation because I mean, if that truck was to get, I mean, even though the device is not in, the truck is being utilized on the job site, the truck still, sometimes there's nobody there and that truck could be, even though it's secured, still could be broken into, they still could get that, blah, blah, blah. We don't leave it out in the open, but it's not on the dash. But what I'm getting to is, I think during this time, we should change this to where instead of carrying this physical documentation, we can start carrying like an iPad or something that has digitally encrypted software on it to where, if this thing was, I mean, it would be with the radiographer at all times because, you know, our safety vests and everything we carry now has pockets and such to where we put iPads and stuff in. And it can carry that with him. It's encrypted, password protected and everything. And if it does get lost or stolen or what have you, all I have to do is be notified, like my own personal cell phone, and I have software and that, I can track it with GPS and notify LLEO where it's at, or I can send a kill signal to it to where I can wipe the hard drive and everything and they'll basically just get an empty tablet or phone or whatever they get. I just wanted to see if that there could be like a change or something that could be brought about to try to update this because I do feel vulnerable somewhat with that, as far as the document control regulations with the federal government and the document regulations I had to deal with with the state government. Does that make sense? Well, for clarity, I don't know if anyone in here has some feedback on that, but yeah, it sounds like you're going to have to take that back to the agreement state too. Oh, we got it. Okay. Because, you know, and I'm sorry, Mel, I didn't get the entire sequence, but apparently the other team members did, so we'll take it back. Thank you. Oh, do you have a comment? Yeah, Mel, is there a reference you can give us? Is there a regulation you're talking about? Uh, this is 3731, document control. It's 3731. Yeah, I believe that's it. Okay. But it's only for when you're... Right, I'm in an agreement state. Like the other day, I just started sending them a notification to where I started using, you know, sensitive, like I do for Virginia, sensitive information, you know, with all the public's exposure, you know, 2309 and 3732. Okay. And I changed their form too, because I'm like, I better, you know, I think it's a time for you to get in compliance with this more because I'm, I'm kind of, I'm getting anxious. You know, I'm getting ready to get an order here pretty soon. I just want to make sure we walk through this one here. All right, we're gonna have, we'll have to figure out how that, how that works on reciprocity. Yeah, so just to, just to clarify, you kind of threw us here in the room just for a second, I'll be honest. So I think just to clarify what I, so I understand what you're saying. So part 37 does not require you to carry all of your security plan and your procedures with you at all times. However, what you're telling us is that through reciprocity agreements, another state is requiring that. Yes. Yes. Okay. Thank you. Yeah. Okay. Thanks, Mel. Really appreciate that. All right. Thank you. Okay. It's about a quarter to three. If you have any other information we'd like to, to hear it, subparts A, B, C or D or a New York 2155 or 2166. We really appreciate the, the comment. George, I did have one follow up question to that previous discussion when the individual took the information to an agreement state. The question to that is the work site that you were at, was that under federal jurisdiction within the agreement state or not? So, Mel, if you can come off mute and if you can provide an answer to that, we'd appreciate it. Kathy, is Mel coming off mute or can you, I don't know if you can tell? There he is. He just came back up. All right. Okay, I'm here. It's multiple sites we work at. We work at, you know, I'll work daily. I'll work, I'll work at federal sites, any site where with the book, the book is basically, I mean, we're talking human nature here. So yes, the book's in the truck every day. Yeah, my question then, Mel, is, you know, when you were at the site with that information in an agreement state, was the work location, the temporary job site, let's call it, was that under NRC jurisdiction or federal jurisdiction or was it an agreement state jurisdiction here? I say it's an agreement state. Although we do, you know, I work in two agreement states now. I did was three, but I didn't, I didn't set my, I didn't re-up my rest of property with Pennsylvania this year because there's really nothing, no work for us up there, you know, no revenue for us. So, you know, I'll let that one go. All right. So that clarifies that where you worked in that agreement state was agreement state jurisdiction. Okay, thank you. Agreement state jurisdiction. Yeah, most of that. Also, we work federal. I mean, like, you know, I've worked, I've worked in NSA and other places and, you know, I'm sorry, I didn't mean to bring out a book. Yeah, I mean, we're all over the place. And this is a document. It's a lot of large book we carry. And I think it's time that, you know, I've been doing radiography. I'm getting ready to celebrate my 28th year doing this of industrial radiography and structures do have to met problem area. And I think it's time that that role should be changed. I mean, everything else is on a cell phone anymore. It's only these smart phones and stuff. Let's go with let's go with a mobile app and everything to where I least can protect this a little bit better. And we can control it a little bit more. That's that's what I'm after. Okay, great. Thanks. Thank you. Appreciate it. Thank you. Thank you, Bob for the follow up question. Okay, one last call for any any of the comments or feedback from sub parts a, b, c and d, new reg 21, 55, 21, 66. Again, for any comments, press star one. Again, if you're not able to provide feedback today, you can email that information in or you can mail it to the NRC. If you go to the public website, you get that information. Okay, we're going to close the webinar and the meeting public meeting out. We thank you for your comments. You know, we've we've looked over all the areas that we're looking for that we were seeking comments for today from the public meeting into webinar. Again, we'd like to say we really appreciate the the feedback we've gotten during all the webinars and today also doing a webinar in a public meeting. We really appreciate your participation in the meeting today. If you did not log into the webinar, we don't have your contact information. Please send that information to part 37 assessment at nrc.gov. All right. Thank you very much. It's this is the end of the webinar and public meeting.