 Right, we'll get started with the Executive Director for Operations session and it's entitled Nuclear Regulation and a Changing Landscape, Strategies, Challenges and Opportunities. Good morning. My name is Ray Furstenau. I'm an Acting Executive Director for Operation at the NRC and welcome all of you to the second day of the RIC and I wanted to step back a second and just acknowledge all the support we've had for from NRC staff in every office to help make this a success. There's a lot of behind the scenes work that goes on and I think they've done a flawless job to date so I'd really like to give them a hand for that. I wanted to maybe first address something that Commissioner Kroll mentioned during his talk that and maybe I'll give a short testimonial here about the NRC and you mentioned that it's a special place to work and I guess a little bit on my background. I have almost over 45 years of federal service but the Civilian Service, more than 30 years in the Department of Energy and almost six years now at the NRC and when I was asked to come to the NRC six years ago I really felt lucky and fortunate and I haven't been disappointed at all. It's especially for young people coming into the federal government. It's really what you make out of it. At the stage of my career when I came over here you think many of you can tell I'm not exactly a youngster anymore but I was very fortunate to be able to come over to the NRC and really there's a lot of satisfaction in the work we do and it's really what you make out of it. I mean you can make a difference if you want to and I've been fortunate to have that opportunity so I just wanted to comment on that it is a great place to work and so that's a recruitment plug for the NRC. One thing we're going to talk about, I have the office directors from the Office of Nuclear Regulatory Research, Andrea Vail and John Lubinsky is the director of our Office of Nuclear Materials. You put me back in research? You put me back in research? You just said that. Oh, I did. That was a slick question. Andrea Vail and I worked in research together so I'm going to try to recover from that. So Andrea Vail the director of Nuclear Reactor Regulation and then John Lubinsky. Now you got me all flustered here. The Office of Nuclear Materials Safety and Safeguards and Morella Gravelas the director of our Office of Nuclear Security and Incident Response. You know and as we look into the future we have a strategic plan. Some of you may or may not be familiar with and there's three goals in our strategic plan and in a way they're challenges. We need to ensure the safe and secure use of radioactive materials, continue to foster a healthy organization and inspire stakeholder confidence in the NRC and I think Commissioner Krull you spent some time talking about that last goal. I wanted to mention in kind of a flow down from the strategic plan each quarter our leadership team at the NRC which includes all of us on the stage plus other senior leaders throughout headquarters and the regional offices. We meet to review risks to the agency that can really impact our ability to achieve the goals and objectives of our strategic plan and what we need to do to control those risks. There's currently about 25 and it varies every quarter about 25 risk items that we discuss each quarter. New ones can get added, some risk are reduced and others are removed and once the risk is sufficiently mitigated and those risks include like staffing, organization culture, NEMA milestones, kind of the ones you'd expect but for this session I wanted us to focus on two of those high risk areas for the NRC staff and those are the timeliness of new SMR and advanced reactor application reviews and the initial and subsequent license renewal reviews. So I'm going to ask each of the office directors and I'll start with Andrea the director of nuclear regulatory research. Reactor regulations. I'm going to ask each of the office directors to talk about what your office has done to help mitigate risk related to these high risk areas to the reputation of the NRC and what you are currently doing and what you plan to do to help the agency succeed in these high risk areas. So Andrea why don't you start. All right thank you Ray and the list is very, very long. This is just going to be a subset and this is really a testament to the incredible staff that I have that works tirelessly in and out every day to get these accomplishments done so I'm going to go through the list that I have here and try to leave time for everyone else. So as you've heard a few times in this Rick that the commission has given us direction on part 53 and it really is a testament to the collegial nature of the commission and how your staff work together and also to our staff who put the policy issues up to be resolved and so my staff stands ready to implement the direction that we've been given and to have workshops to have stakeholder engagement to make sure we can implement on part 53 direction. We also as you've heard a number of times issue the Kairos Hermes one construction permit which was the first time in 44 years that this type of activity had occurred and we used what we learned from that and leverage that to have an aggressive schedule for Hermes two that basically came in right behind Hermes one as a 14 month schedule and that review is going very very well. We also finalize the readiness assessment for the upcoming X energy construction permit application and we provided very critical and specific feedback to the applicant. We looked at stakeholder input both internal and external about our website. It sounds simple. A website can either kind of make or break a project but we really listened and we work with our partners in the office of public affairs to make sure we have a website now that is content rich that is more execution focused. A lot of the complaints is that you have to click down several levels to get to the information that you needed and now it's much more user friendly. We accepted the new skill standard design application approval application and we're working consistently and vigorously on that right now. This is going back a bit but we issue two second papers on microreactors. This is really a proactive effort back in 2020 and then earlier this year and we looked at policy issues for microreactors as well and breaking news will maybe not breaking because we've talked about this in a public meeting. We're really looking at the vision for how we would license anthropokine reactors and what that would look like and what ways we can make that risk informed and obviously we're continuing on that discussion. We have several bilateral agreements which we mentioned here as well in various speeches. There is the yesterday, no, what's today? Wednesday, Monday, there was a MLC signed between CNSC who we've had an agreement with for many years and kind of reinvigorated it in 2019 but now the UK has joined that effort and we've signed that MLC to exchange information but going back to CNSC we've issued eight joint reports under the MLC and there are challenging technical issues that we're looking at for specific design. There's both technical and regulatory issues. I'm almost finished and I'm going to leave you some time. We've looked at small modular reactors. We're active in every single group that the IAEA has put forth with the NACI, the Harmonization and Standardization Activity. We're very active in NEA activities. I myself am a vice chair on the CNRA and we discuss its regulators issues that are very important to all of us. And last but not least, we continue to try to help embarking countries that are looking at nuclear now and many of the commissioners have been to those countries to help give our expertise and help those embarking countries. So I guess we'll next we'll have John Lubitski. How does your organization and what your office does tie in with what NRA does to help mitigate risks in those areas? Great. I appreciate that, Ray. And I always appreciate you, Andrea, going first because there's such a good relationship between the three offices in here and supporting each other. When I start to think about what we do as an office, I'll pick up a little bit where Commissioner Kroll was, right? We're looking at the front end and the back end of the fuel process, right? The react, advanced reactors, operating reactors aren't going to be successful if we don't have a fuel supply on the front end. With respect to advanced reactors, just over the last year, year plus, we had four significant licensing actions come in related to high-assay low-enriched uranium. This is a new area. We have not licensed those kind of activities before. We were fortunate in our fuel session here at the RIC yesterday to have John Donaldson of Centris talk about the successes they had in the licensing process there, and kudos to all the folks who did that. And that's basically enriching UF-6 to HALU levels up to 20%. We've also approved multiple license amendments for fuel manufacturers out there to go above the current 5% up to an 8-way percent. Kudos to the folks who worked with the manufacturers on that because we were able to give them certainty on the front end by looking at one of the most significant areas for the fuel fabrication and that is in the criticality area. So we were able to work with them on understanding their criticality methodology going through and having approval of that process first, which provided them additional certainty when they went through the licensing process and followed the integrated safety assessment to identify their items relied on for safety. And we also approved transportation packages. Again, you're not going to get the fuel from one part of the fuel fabrication process to the other without approved transportation casc, and we've approved those above the 5% weight as well. So they're all integral to not only the advanced reactor fuels, but the accident-tolerant fuels as we move forward. We also provide support in the environmental area. I think the two biggest ones you've heard about already at the RICS, so I won't go into details, but the licensed renewal guides as well as the advanced reactor guides. Just recently, our folks working very closely with folks in NLR provided the licensed renewal guides to the commission, which is going to provide efficiencies as we continue to move forward in those processes. Outside of advanced reactors, we've continued to do environmental reviews. We've completed three final EISs, two draft EISs, as well as six environmental assessments, supporting licensing actions across the operating reactor business line as well as the fuels business lines. Andrea mentioned Kyra's Hermes. Again, it was not just the safety side of it, but it was also the environmental side, which the environmental review was completed in 18 months as well, which was significantly shorter than a prior ERS we just did for site next door. I think it was 70% to 80% shorter timeframe to complete that, while still meeting the hard look required by NEPA to complete that. And then finally, the initial implementation of Fiscal Responsibility Act changes to NEPA. We've looked at that already and have started to implement the page restrictions on that as well as the timeliness, and we've beat that already. We've looked at the months required in looking at EISs. On Kyra's, we've already done 18 months. We're going forward on Hermes II to do an EA, which, again, is a efficiency as we move forward, and we hope to use the lessons learned from both Kyra's I and Hermes I and Hermes II to make continued changes in that area. Great. Thanks, John. So how does insert play into all of this, Marilla? So good morning, everyone. Is it on? Yes, it's on. So, ENSER supports both Andrea and John. We do security and emergency preparedness for the entire agency. I don't have much to say about subsequent license renewal, but there's a general sense of excitement about advanced reactors and what everybody in ENSER can do to help regulate them and new technologies that come on board. And I'm going to start with some examples that you wouldn't think about. Our information security folk are thinking about how are we going to open the doors to sensitive and classified information for applicants who need that information. Our ops officers think, how do they need to train to receive the operations information of the future? Our intelligence analysts are thinking about all these new exciting technologies, the more powerful they are for good, the more powerful they can be for bad. So, for example, we heard a bit about AI. They're going to start thinking soon about are there anything that we need to prepare for when it comes to artificial intelligence? Inimicality, recognizing the changing landscape in terms of who owns the facilities we regulate, we worked on inimicality recently on how we review inimicality. But the bulk of the work is in EPN security where we had some significant undertakings in the recent past. As many of you know, we passed the EP rule for SMRs and ONTs. The commission approved it last year and we're in the process of implementing that. And with the implementation of that rule, we actually have a really flexible emergency preparedness framework. We have the current regulation for LWRs. We have EP regulations for materials facility. We have EP considerations for transportations. And when you put all those together, we actually have what we need to regulate anything ranging from fusion systems to reactors larger than we have today to manufacturing facilities. So what we're working on now is going to be the guidance that's needed to make sure that that technical basis is applied appropriately to all these facilities. In the realm of security, we had the limited security rule. And as the title said, the draft limited scope rule was intended to be very similar to how we regulate security at the current reactor fleet. We figured out, we followed commission direction, figured out how to use dose as an entrance criteria into the limited security rule. And it addresses a few relaxations that have to do with the number of security officers expected, the secondary alarm station, alternatives to physical barriers. But it didn't go as far as it could for advanced technologies. So we took the opportunity to literally insert ourselves into Part 53. And we were courageous in how we inserted ourselves in Part 53. We didn't start with a blank sheet of paper. We actually looked at how we regulate everything in security starting from constructions to materials to research and test reactors and of course the currently operating fleet. And that's what you will see in the draft Part 53 that the staff proposed. Another area, you know, let me mention a couple of things about Part 53. I'm very proud of what the staff did in areas like fitness for duty. They leveraged the technology that's out there to do fitness for duty differently than we're doing it for the fleet today. In cyber, they're looking at how they can use the established standards by NIST to regulate future reactors. So there's a lot of creative thinking there. And finally, the one thing that we're working on now is special nuclear materials. Advanced reactors will have different types of materials from the light-water reactors of today throughout the fuel cycle. And we're looking on how we need to address those materials throughout the cycle. That's it for me. Great. Thank you, Marilla. So we're going to spend the rest of the time with some questions and answers. So I think I'll start this one with you, John, and I'd like you to all answer. We're getting a lot of good questions coming in, but I think we see it in our workshops like at the RIC. We use the term NRC and others use the term risk-informed and performance-based quite a lot, but the question for the NRC, are you really performance-based and risk-informed or do you just say you are? So how do you answer that? Thanks, Ray. I appreciate that. And I'll start, and of course, I'd love to hear from Andrea and Marilla on this. So the short answer to that is yes, we are risk-informed and we need to continue to be more risk-informed. And let me say that when we make that statement, it is clear to me that all of the folks that the NRC are only going to approve NRC-licensed activities that they're safe. And I want to make sure that that's out there. That is our primary mission, and I believe that the intent of everyone at the NRC is to make that happen. In doing so, we have used risk information to get to where we are today. Examples of that when I think about our offices, we've looked at every oversight program that we have in the office to make sure that we're focused on the highest risk activities at each of those sites. We have pulled attention away from those areas that are lower risk because we want to make sure we're not spending our effort or licensee's effort on lower risk activities. So instead, we're focusing on a higher risk. We've completed our review of the entire oversight program to ensure that. And as I said, going forward, we're going to do that more. Risk informing is a continuum. You can't say you're there because you need to continue to do that every day and going forward. The question is how do you get there? And I think it's the training that we need to continue to develop. I want to give Kudos to Marela Gavralis for her role in the BRIS Smart and the folks that worked with her on that effort. I was fortunate enough to be part of that. And I would say that every time we make a decision in the agency, we're following the BRIS Smart model and the question, what is the real risk associated with this? What can go wrong? How likely is it? What are the consequences? How do we mitigate that? And we ask that about every decision that's going forward. Is that causing us to make changes in the way we make the decisions? The answer is yes. Do we need to continue to do that more? The answer is yes. I'm going to use Fusion as one of our other examples here. We're working right now on a rulemaking for Fusion. And I think it's very important because the rule itself is going to provide high-level performance standards. And this gets to the other part of your question about being performance-based. We'll set the standards and the regulation. But as we continue to move forward, the designs are going to be very unique. The designs are going to be very different. And we need to look at the risk associated with each of those designs and determine is the manner in which they're meeting those performance standards not only effective, but also the most efficient in moving forward. And are we making sure that as we do that, we're applying our resources in the area that provides the most risk? So we follow the BRISMAR model and ask into questions are, what are the requirements? Why are we asking the questions? Why are we putting requirements on licensees to do these activities? What the end result being is, what is the safety enhancement that's going to be made to the plant? What about you, Marilla? What are you doing for that question? So BRISMAR is very dear for me and I don't ever miss an opportunity to talk about don't be deceived by the QT role. It's actually quite defensible in terms of risk-informed decision-making process. So we're talking being risk-informed and performance-based and I think performance-based doesn't often come into the conversation but if you're risk-informed, you've used data to basically use past performance data to assess the risk. If you follow the BRISMAR framework and are in the realizing the framework, your performance monitor your decision. So I'm going to make it personal for NSER. My realization when I came to this office about three years ago was that like many on the staff in the agency, there was a perception that if you don't see yourself in a PRA, you're not risk-informed. So we brought it back to the basics and the basics are what can go wrong, how likely is it, what are the consequences and how do you mitigate it? Well, what I learned pretty soon after coming to NSER is that security had those basics built in into their risk. Threat assessment, vulnerabilities, consequences, protection. It's maps one-to-one to risk and we started having conversations around those elements. We started putting people in the room that can deal with all those elements at the same time, our intelligence analyst, our vulnerabilities experts, our security experts and the people who understand consequences. And I honestly don't think that there is any conversation that happens in security at office level that does not discuss those four entities these days. So that's how we're applying risk information in day-to-day decision making. Great, thanks for the role. How about in NRR? Yes, this is actually a really good opportunity. I agree, it's adjourned. It's 100% adjourned and we have some notable accomplishments but I really want to focus on operating reactors. We talk a lot about new and advanced reactors and rightly so but the health of operating reactors are integral and foundational to success for new and advanced reactors. So I want to go back to, I think, something that's overlooked a lot. Whenever we get notice of enforcement discretion requests, the NRR staff and other staff that they partner with across the agency basically drop what they're doing. It could be a weekend, it could be, you know, the end of a long day and they use the information that they have, risk insights, operating experience, whatever plays into that to make that decision often in hours and not days or weeks or months, right? And we do that routinely and I think that gets forgotten, you know, forgotten sometimes in terms of how we use information going forward. The second is back to license renewal and subsequent license renewal. There are a lot of activities that are going on right now but there's a few that are very much risk informed, looking forward on how we look at subsequent license renewal that's going to come in. We talked in public meetings about a tiered approach and that approach would be something like if there's information that is already especially initial license renewal, we take that information and see what the deltas are and do that review. There's another tier where if these are the two extremes, if there's something that is absolutely new, the chair talked about new, you know, aging management programs. If it's new, which there's about six or seven new programs, of course we have to do a more subsequent review on that to make sure we're making a safety decision. We're also going to leverage inspection and oversight. There's a different kind of gates as to how you look at license renewal and what inspections would happen and what would. And so we are actually making decisions on what inspections will we actually need to do and since it's a continuum with the reactor oversight process of inspections going on during the initial, either operation or initial license renewal, we can leverage what we know about that going into subsequent license renewal. So it's definitely a journey. I'm very, very proud of the staff and I want to really commend them for what they've done thus far on everything, but in subsequent license renewal in particular, it has a lot of scrutiny with Congress, with internal and external stakeholders and I'm just very proud of how the staff has kind of kept the head down and done the work and is kind of moving forward with how we're going to do, be more efficient with subsequent license renewal. Yeah, John. Great. Can I add one point on more of the performance-based part because I think we've thought a lot about the risk informed and I would also, when we're looking at a performance-based implementation of our regulations and our regulations themselves, we also need to look at the balance there because when you're looking at the balance between that and our principles of good regulation, right, if you're doing, you need to have clarity. You need to increase public confidence in what you do. So as you're starting to look at that, performance-based provides more flexibility. So therefore, things are being done more on a one-off basis, more on a unique basis, maybe associated with one licensee, one facility, whereas when you're more deterministic and where you go there, it seems to be more clear. It's not as performance-based. You get the clarity, but then you lose the flexibility. So we do need to make sure that we keep a balance there and a lot of that comes on what the issue is and what the decision is that we're making. Thanks. I'm going to shift gears a little bit. There's a lot of good questions coming in and I think, John, I'll start with you on this one and it's probably more in your area anyway. How has the staff been incorporating lessons learned and risk-informed decision making into decommissioning activities? For decommissioning activities? For decommissioning. Thanks. Great question. Number one was already mentioned that we've provided the final decommissioning rule to the commission. There were a couple of items in there that definitely start to, from a risk-informed standpoint, provide further efficiencies as we go forward, working very closely with ENSA on a lot of the requirements for EP and what an EP program would look like in the future, what a security program would look like in the future. We've put in the regulations a clear risk-informed way of looking at the risk of the plan and what would be needed in moving forward. Much of that was based on interactions we've had with current licensees. So that's how we've taken the lessons learned of what we've learned from licensees that have already had their licenses amendment going forward and codified that in the rulemaking. We've gone further also in areas like the decommissioning trust funds, where we continue to look at that to make sure that licensees are maintaining the adequate amount of funds for decommissioning going forward. But the question was how often do we need to review those? So the final rule going to the commission allowed for those reports to come in less frequently. And that's because we have oversight processes that are effective in ensuring that licensees are managing their funds. On a case-by-case basis, what we're dealing with today in the license termination plans, we had a great learning recently on dealing with discrete radioactive particles. And we were able to work with the industry overall and I appreciate the Office of Research's work where we were able to look at it from a risk-informed standpoint to say, what is the end result of this under Part 20 from the standpoint of the dose that's where we required folks to meet for the final license termination? And how are we looking at these discrete particles in that sense to say, what is the real likelihood of a dose of someone exceeding those Part 20 limits? We have not done that before. The cleanup was to remove all the discrete particles, but we found in this case that there was a demonstration where we can meet that standard based on the safety assessment. So we were able to apply that to one of our current facilities going through decommissioning. We were able to use that to develop what we call interim staff guidance, moving forward so that we can use that in applications for others. It assures we're meeting regulations, meeting safety standards, as well as providing an option to licensees for a more risk-informed way of donor decommissioning. Thanks. I'm going to go back to a question. A good question came in on risk again and the question is in the present NRC work environment where accepting more risk is constantly mentioned. What specific value does the NRC staff use for the amount of risk that is acceptable? I think that's a really interesting question. I'll kind of give my views on it and I'll ask others. I think what we should really be looking at in addressing risk is a staff and our offices that we really have to look at can we not so much, it's the decision makers that make the decisions on what risk to accept. But I think from a standpoint of our staffs, our obligations, all of us, is to try to quantify that risk if we can and qualify it, put some qualitative view on it if we can't quantify it and then leave that to the decision makers so they can have good information to make good risk decisions. So I think it's more of that than it is some particular value. What do you think, Marilla? Yeah, so some of the staff know, but few outside of the agency know that the BeRisk smart idea started as the accepting risk initiative and we went to margie down the EDL at that time and we said bad idea. It's not about accepting risk. It's about accepting the right amount of risk. It's sending the wrong message if we title an initiative accepting risk. So it's always about what's the right amount of risk and that varies with the decision that somebody has to make. We in our own personal life accept risk in some decisions and yet very little risk in some other decisions. The same holds true organizationally. So we the staff have the responsibility of putting together all the information not just the probability and consequences with error bands but we also have to tell the decision maker whoever they may be what the right level of risk is for that decision. That's the conversation that we need to have and that's the conversation that we're trying to have. Would you like to comment on that? I'll add to that. When I think about many of the business lines in NMSS we don't have as much quantitative information associated with risk as we may have in the PRAs and it's a qualitative discussion agree with Merrill 100% of what is the risk level that is appropriate as you're moving forward. But the other part of that question is what information did you use to get there and I think that's where the conversation goes of when you're talking qualitatively people may come in and have a different perspective on what is the likelihood of that and may talk past each other. So instead if you can get to the conversation of what are you really talking about of the probability of this. Also what are the consequences and can I live with some of those consequences? If the consequences are that it may require more work later maybe it's acceptable because of the amount of likelihood of it occurring but I think those conversations where you start to use those terms what is the likelihood, what is the consequence and at the end of the day saying as the decision maker I am willing to accept this risk in moving forward and having the folks understand why you made that determination to accept that risk is most important. That goes from the standpoint of communicating with our licensees, with folks within the NRC and also with our members of the public in having that communication of why we've accepted that. Nothing in life is risk-free. No matter what decision you make you're incurring some level of risk and the question is did the option you choose going forward is that an acceptable level of risk you're willing to live with? Andrea would you like to comment? I'm going to key off something Mirella said and kind of flip the focus a bit because this is literally a conversation I just had yesterday. So it's very important if you can quantify and qualify something to give to a decision maker and it's not just about like you said PRA or error bands it's in all the decisions that you make pretty much as soon as you wake up to when you go to sleep. So we were talking in our R from the perspective of workload and how to alleviate some workload of things coming up because everyone knows I'm not a micromanager if everything had to come through mean nothing would happen in our R. There could be a bottleneck just sheerly because of schedule. So we started looking at projects and figuring out what's the risk of pushing the decisions of these particular products and some of them are extremely important highly visible products. What's the risk to us as an agency or to NRR about pushing those products down and we literally went through and said how many times have we had to redirect on this particular activity if we did was it a fatal flaw was it something that could have cost either you know some there's no safety issue because we wouldn't push it down if we really needed to be involved in that but what is their reputational risk if something wasn't quite as polished as it would be if we didn't kind of look at it look at it from our perspective and we decided we're willing to take that risk on a number of products that would save people time and that would allow them to make the decisions and then like you said if you have to come back and kind of reassess after and do more work later that's the risk you take and that goes back to the be risk model be risk smart model whenever I talk about it I say legal administrative you know training HR it's not just the technical office the public affairs everyone what's the risk you're willing to take based on the information that you have either coming up to a decision maker or pushing things down for the efficiency of your organization then you can spend more time on other things yeah all good points thanks for that so I'm going to go back there's a question related we talked I introduced this with maybe the two top risk areas we were going to talk about and then we one of those was the licensing reviews for SMRs and advanced reactors so I'll start this with you Andrea can you talk about the challenges that remain that keep this risk high we talked about a revisit in the risk and it's a high risk area it should be what do you see the challenges we have some of the challenges are just the first of a kind nature of what's coming in how much time do you spend on looking at particular aspects and a lot of the aspects are highly highly highly highly technical and so we may have to spend more time making sure we're making a reasonable assurance determination we're not trying to get to something you know in addition to reasonable assurance but you have to understand you not only to be able to make the determination but something that Commissioner Crowell said being able to explain it to the public to be able to defend your decision and have confidence that the decision you made is correct the other challenge is staffing you know it can be very difficult especially in a post pandemic you know time frame that we're in and Commissioner Crowell talked about compensation and we borrowed from each other it's a very small industry so staffing even if we are able to get people in sometimes the turnover is such that our licensees have you know worked with a particular PM or particular technical expert and that expert changes so we really have to focus on knowledge management we have to focus on we do videos a lot to make sure that something is sustainable for new people coming in we have in our what's called a ET executive team chat where we impart knowledge and also a significant topic and we deep dive on some of these reviews and make sure the material is available so it can be challenging to make sure you have the people there that the people stay and that we are focusing on the most important items with this first of a kind technology so we spend a lot of time kind of talking about what should we be spending most of our time on and how do we explain that and defend that to the public I'd like to go to you on something that Andrea said about you know the first of a kind then you go to the yinth of a kind but let me back up on staffing and in your area John how do you manage the staff needs for this I mean you staff up in anticipation sometimes but how do you make sure that we have the staff that's ready to address the new licensing activities that come in thanks so appreciate that so let me go to the challenge first and hits the staffing the challenge we have right now with many of the new technologies it's first of a kind and I'll use the example on the front end of the process as well as the back end of the fuel process is the major issues in the criticality area and understanding where are you when you go from the 5% to 20% in rich uranium what kind of benchmarks do you have in place there and what we've determined and looking at that is that we had to add certain levels of uncertainty taken into account certain levels of uncertainty and making our licensing decisions because we didn't have the data we have data below 5% and we can be more efficient going forward as we get more data in the benchmarking that's going to allow us to be more efficient in the requirements we put in place moving forward I use that as an example because they say how do we prepare well we identified this is a key issue so we want to make sure that we're bringing on folks in the organization that have criticality expertise that have HP expertise those that are going to be needed for the most critical areas moving forward and then going forward from a strategic standpoint is whether they're working on an application for the front end of the process the back end of the process moving over to Andreas shop to be able to work in that area we can do that because we've got the critical skill sets that are needed for the key issues that are there in the future the challenge we see as we move forward is having enough predictability of what applications are going to come in and when during our fuel session we talked about that yesterday making sure that we have a clear understanding of what the landscape looks like when the applications are coming so that number one we can have enough folks in place to review the applications folks have the critical skill sets to counter that is we need to make sure that we're not over staffing the agency has gone through that once before where we did staff up 2005-2006 and then had to go the opposite direction going forward that has an impact on staff morale that has an impact on recruiting that has an impact on how we continue to staff the agency and for our licensees out there it has a direct impact on them because they're paying annual fees to us to support these activities and if we're budgeting up if we're putting more folks in place and then we don't get the applications coming in the end result is they're going to have to pay the additional fees that we staffed up Morella you get the final comment on challenges ahead here so hiring of course that's on everybody's mind and I'm going to just say when we need an expert we need to hire the expert that we need for the issue at hand and I'll leave it at that all right well in closing the session I'd just like to thank all of you for helping me with this plenary session here and really picking up most of the load there but I did like to close by saying I'm really optimistic about the future of advanced nuclear technologies and the future of nuclear in general and I think here at the NRC we're really up to the challenges and we're all in this together and we have to step up and show that we're we're up to and the issues and challenges we have so with that I'll close the session and thank you thank you