Strategic Programmatic Overview of the Fuel Facilities, Spent Fuel Storage, Transportation - 050726

Okay, good morning. Call this meeting to order. Today we're going to meet about the NRC's fuel cycle facilities and spent fuel and transportation business lines and as as safely enabling the entire nuclear life cycle is vitally important to America's energy security and our national security. on on the front end, the United States depends too heavily on foreign and uranium and enrichment and that has to change. And on the back end, safe and secure transportation of spent fuel is vitally important for public trust and confidence in our technologies. And as the NRC continues to deliver results in this moment, we are focusing our efforts on strengthening America's entire nuclear life cycle front end to back end. And it's really evident in the results that have been achieved right with the TRISO X fuel fabrication facility license issued several months ahead of schedule. Also the recent announcement of the expedited review schedule for radiance um micro reactor assembly facility as well as the improvements that we're looking at in our transportation regulation. So, I really want to commend the NRC staff here at headquarters for all this incredible work as well as the staff in the region that are overseeing the fuel cycle and spent fuel and transportations um activities across the country. This work is really important. Again, it's Americans energy security and national security. So, uh be before I uh get into the staff's presentation, I want to see if any commissioners have any comments they'd like to make. None. Okay, I'll turn it over to staff and I do not know we will take a five minute break after the first panel. Is that correct, Madam Secretary? Great. Okay, Mike, you got it. >> Yeah. Good morning, Chairman Knee and Commissioners. It's great to be here with you today and we really appreciate the chance to walk through where we are and where we're headed in the two business lines that are central to meeting the nation's nuclear energy needs, fuel facilities and spent fuel storage and transportation. Across both of those, we're modernizing, we're streamlining, and we're looking hard at how we can do our work smarter, all while keeping safety and security as our northstar. That commitment has not and will not change. This morning is really about showing how our staff is stepping up to meet the rapidly evolving energy landscape and how we're positioning ourselves together for what's coming next. Next slide, please. The fuel facilities business line is really at the front edge of what energy transition means for us. The demand for new fuels is growing rapidly and our team has been leaning in to make sure we're ready. We know the challenges out there both at home and internationally and we're tackling them headon. We've been refining our licensing and oversight approaches making them more efficient and more predictable. We're also staying tightly connected with our international partners so we can continue to shape high standards for fuel cycle safety and security globally. And at the center of all is our staff. Their expertise and dedicated service have enabled us to keep pace and meet the moment. Next slide, please. As we adjust how we regulate, we're staying anchored in safety and security, but we're also recognizing that our mission includes enabling the safe deployment and innovations and fuels. So, we've been busy improving how we communicate, how we plan, and how we make decisions. We're also getting ready for our June 15th reorganization. We expect that will help us line up our structure with the needs of our growing workload. A lot of good work is already happening to make sure this transition happens smoothly. This morning's panel is going to walk through how we're preparing our people for new demands, holding ourselves accountable to national priorities, delivering meaningful accomplishments, and making sure the improvements we're seeing today are sustainable for the long term. Let me take a moment to introduce our speakers. Andrew Cook uh will kick us off this morning with an overview of the business line. Shaina Hilton will take a uh will highlight some of the key accomplishments we've had and that what we're implementing with the advance act in the executive order 14300. Samantha Lav will carry cover new fuels and how we're coordinating closely with DOE and Chad Olstrom will bring in the regional oversight perspective. Andrea, over to you. >> Good morning chairman and commissioners. It's our honor to provide you an overview of the fuel facilities business line. I'm really proud of the staff's hard work to meet the nation's energy needs by safely regulating fuel facilities. Next slide, please. The fuel facilities business line budget for this year is 79 FTE and $4.7 million. This budget supports an operating fleet of eight operating fuel facilities, one facility that's under construction, one facility that's licensed but hasn't been constructed, and 10 greater than critical mass fuel facilities. We anticipate that the number of operating facilities will grow substantially. There are multiple reasons for this. First of all, the operating fleet is prioritizing power up rates and they are achie achieving those up rates through use of new fuels and we have issued amendments for both uranium enrichment and fuel fabrication amendments to support these upgrades. Secondly, the ban on the use of Russian uranium, which the chairman mentioned, goes into full effect in 2028 and has resulted in an urgent need to increase the domestic capacity for enriched uranium. In addition, the interest in artificial intelligence has spurred an interest in small module reactors and many of those reactors use high assay lowenriched fuel or halo. And last year, the president declared a national emergency to greatly increase the current electrical generation capacity. This has produced a great deal of activity. For example, the DOE recently issued $900 million to create a domestic Halo capacity in the country. And we have seen a great deal of interest in new conversion, deconverbs, fuel facility, and uh fabrication technologies including reprocessing technologies. Our projection of what that translates to in terms of the number of licensing applications from fiscal year 26 to 30 is depicted on this slide. And since the last commission briefing, the staff has completed 28 licensing actions with 14 current actions in house. We project an increase to about 102 licensing actions through 2030. And if all the applications that we expect to come in do come to fruition by 2032, we project a total of 28 operational fuel facilities. Next slide, please. We are boldly responding to the urgent call for fuel to fuel the nation's nuclear power reactors. And one indication of this bold action is our licensing of the Tricox fuel fabrication facility, three months ahead of schedule and with 14% less resources. Shaina will provide more information on how we were able to accomplish this and some of the regulatory flexibilities that we applied. And since we last briefed the commission, we set expectations for licensing more efficiently. And we implemented several improvements to reduce schedules and resources while continuing to ensure safety. And as a result of our efforts under the materials, licensing, efficiencies, and processes team, we've reduced schedules by 15% and reduced our resources applied by 15% in comparison to historical execution. Shaina will talk through how we've accomplished this. In addition, we're shifting our behaviors, that's the how of how we do our work. We have embraced the new communications model and we've increased accountability with regular project check-ins and quarterly meetings at the office director level for major applicants when applicable. We used established precedents from previous licensing action so that we can focus on just what's new or changed. We've also done a great deal to streamline our environmental review process. And we're leveraging our years and years of regulatory experience to take on new challenges. For example, in the EO14300 rulemakings that we're working on, we're addressing multiple legacy challenges. Samantha Lav will present on how we're leveraging previous experience to prepare for reprocessing technologies. And if I could just take a minute to talk about Samantha and what she's done, not just on reprocessing technologies, but in in addressing multiple complex challenges throughout her career at the NRC. She will be leaving the NRC in a couple weeks. Um, but I just wanted to mention all of her accomplishments. She's assisted and presented in multiple commission meetings like this through her career in every business line at the agency. I want to thank her for her service and she will be greatly missed. So, continuing on with my presentation, as we've seized the opportunity to further improve our oversight process that Chad will talk through, we've done this by building on what we did with the Smarter Inspection Program that began in 2021. And then building on that through the advanced act section 507 improvements, we took further steps to meet the moment, keeping our commitment to safety while becoming even smarter and more risk informed. Due to the smarter inspection program enhancements and the advance act enhancement that Chad will discuss, our baseline inspection program resources have decreased by an annual average of 10%. We are working on additional enhancements through the advance act actions that will be implemented that will continue to improve our efficiency and you'll hear more about this in Chad's presentation. Next slide please. We are focused on preparing our people today for tomorrow and we've adopted a few strategies to help in this way. We are applying strategic workforce planning to align what our current and future needs are to our workload demands. And this proactive approach to talent management will ensure that we have the staff that we need who are qualified to license and inspect fuel facilities. We're also working to establish a strong cultural foundation by identifying and communicating our priorities and our focus areas so the staff can see how their work fits in with our mission. We're using communication tools such as teams to make sure we have consistent communications across the business line. and we are fully utilizing our culture team who provides constant feedback to our leadership and executive teams um through just feedback informally and through surveys. We're also trying to smartly manage our workload. We're use utilizing the shed defer process where we need to and we're using dedicated project focus times to complete our work so that we maintain balance. We have also been diligently working toward reorganizing. Like Mike said, this will better support completing our licensing and inspection workload more efficiently. We'll be realizing the benefits of nationwide inspection planning and a business line centered approach to decisions. Next slide, please. We are holding ourselves accountable to our stakeholders by monitoring the execution of our budget. This business line is budgeted for 79 FTE this year and so far we're currently projected to spend 78 FTE or utilize 99% of our budget. And while we're close to our budgeted FTE and utilization in an effort to continuously ask ourselves where we can do better, we evaluate quarterly our our execution and any deviations from the way that we anticipated to execute our budget. We are overexpending in our licensing product line by a significant amount due to increased number of unanticipated licensing actions and pre-lication activities that our staff is supporting. And to support this unanticipated work, we've shifted resources internally and we're working to hire in areas where we have less depth for the necessary skills that we need. We do anticipate that annual fees for the fuel facilities class will continue to decrease in fiscal year 2026 in comparison to last year due to a reduction in the budget and an increase in direct fee billable work. And Shaina will be providing more details on how we are assessing fees and ensuring fee stability within the business line. This concludes my remarks and I'll now turn it over to Shaina. >> Thank you and good morning chairman N and commissioners. As you heard from Andrea, we have a small but mighty business line and I have a lot of accomplishments to share with you. I'll start there on the next slide. As the chairman noted, just last week, we accepted the application from Radiant for a special nuclear materials license for its micro reactor fabrication facility in Oakidge, Tennessee. We plan to complete our safety review over 50% times faster than our new NEMA metric. In March, we issued an approval to Frammatome, allowing fabrication of fuel enriched up to 6 and a half weight%. We used only 85% of our projected resources to complete this review. This fuel will support operating reactors seeking deploy accident tolerant fuel for power upgrades and to improve their operational performance. And over the past year, we've issued several approvals to the Centress Enrichment Facility in support of the DOE's Halu demonstration project. The uranium produced by Centress will support the fuel qualification and testing of advanced reactor designs. And as the chairman noted in February, we issued the TISOX license for their new fuel fabrication facility. This achievement represents the dedication and hard work of both the NRC review team and the applicant. I think all who are involved with this review would agree that over the course of the licensing process, this was a tale of two NRC's. We certainly became savvier with our risk use of tools and data such as leading indicators and project dashboards. We use those to effectively manage our projects. Today, these good practices have become part of our standard day-to-day. But one of the biggest changes within our staff was cultural. As we became a more enabling regulator, we shifted to an approach of mutual problem solving. We used riskinformed thinking to develop safe ways to get to yes without being constrained by our traditional regulatory approaches. For example, we found a solution to the building is IRS issue that we're also considering for an upcoming rulemaking. Similarly, we're finding new ways to meet our mission and oversight. Our region 2 inspectors proposed reducing inspection hours for the Solstice conversion facility. We we were able to do that using updated risk information and by drawing from our many years of inspection experience. This reduced our inspection resources for the facility in 20 2026 by 25%. And during this trial period, we're closely monitoring the performance of the plant and if needed, we can adjust our oversight approach to ensure safety. Next slide, please. So annual fees cover work that is not tied to direct licensing or oversight and remain a focus for the business line giving the small number of fee paying facilities. Back in 2016 you can see on the slide fees had risen so much that a cat one fuel facility annual fee was on par with that of an operating power reactor. We took measures to reduce the fee impact resulting in the downward trend that you see starting in 2017. Additionally, at that time, the workload was very stable. Sites were decommissioning, budget overall was decreasing, and there really weren't any significant plans to pursue new fuels. But then you see a 19% increase in 2023 and a 24% increase in 2024. This sharp rise in annual fees was largely driven by a dynamic external environment. Unfortunately, there was some latebreaking unforeseen delays of planned licensing simols which results in shifting that cost from the part 170 budget into the annual fee that's levied on our uh eight eight licensed uh facilities that actually pay the annual fee. So to give a sense of how impactful these workload shifts can be, if just one new application review is budgeted and does not materialize, that can result in an increase of about 5 to 10% in the annual fee. When this occurs, the staff can take mitigating actions. We can inform the commission during the review of the budget. We can work with the office of management and budget during their review of our proposals. And during execution year, we can look at moving resources between business lines as we did this year to support the fuel facilities increased work. Um, unfortunately in 2023 and 2024, the timing of the shift in workload just wasn't conducive to a total fix for the fees. But in 2025, you see that the fees start to trend down. This is not by accident. We conducted extensive outreach to federal partners and to industry to better assess when work would be realized. We revised our confidence rankings that we use for projected licensing and we budgeted fairly austerely for mission indirect work. In addition, the NMSS licensing expectations that Andrea mentioned direct our staff to focus their time as much as practical on work that is directly build to lences and applicants. I'm pleased to show these efforts are working and fees are coming back down and this is an area that we continue to monitor and manage closely. Next slide, please. As we're preparing for the coming workload, we're focusing closely on our people. The efforts within my division, which does include staff funded by multiple business lines, makes for a pretty good case study that is representative of the fuel facilities business line. Overall, we're closely monitoring attrition and budget projections to identify critical skill sets and prioritize our recruitment and retention efforts. to fill immediate needs. We're leveraging rotational assignments and work sharing across business lines and across organizations. We are cross-qualifying staff so they can fill multiple roles. And we've recently revamped our qual process so we can speed the time it takes to qualify. And we've modernized the program to include today's expectations for how we work, including our licensing and oversight efficiencies we've developed for the advance act and use of B- risk smart principles. Over the past three years, we've qualified about 22 staff and we have seven more in progress. And I just like to recognize the many staff who support the mentoring, qualification activities, and knowledge management that really need to occur to prepare our staff for success. I'm really thankful for their efforts and that in doing so, they've built a team environment. Next slide, please. So shifting gears, I'll discuss some strategic initiatives aligned with our national priorities. We're using the EDO procedure as a guide for constructive dialogue with applicants during our enhanced pre-application process. This facilitates the preparation of a highquality submitt to the NRC. We've recently launched a new applicant landing page. The QR code is shown on the slide to get to that page. And this is to make our regulatory process more accessible to newcomers. Our environmental staff have made major improvements to the to their process to meet the fiscal responsibility act and the advance act. These initiatives helped us accept GLE's Paduka laser enrichment application within 30 days of receiving it for acceptance. And we've published the environmental impact statement without needing to request any supplemental information. The schedule we established for GLE falls within our new NEMA milestones and we're closely monitoring progress to ensure we catch and resolve issues timely. We launched a construction oversight program and published a major revision of the associated inspectional manual chapter. This is in use today to inspect the activities at new facilities and also to inspect the expansions taking place at existing facilities. This guidance has also been helpful in encouraging good communication between the industry and NRC as construction plans progress. For operating facilities, we've implemented new inspection metrics to ensure we close out open issues within 45 days. And we are in the process of rebaselining our existing inspection program. This effort will explore whether we may safely expand the risk informed approach that I described for the solstice facility. Next slide, please. And lastly, I'll touch on NRC's role in fulfilling the president's executive order on deploying advanced nuclear reactor technologies for national security. This directed the establishment of at least 20 new nuclear cooperation agreements. These are a frontline non-prololiferation tool that advanced both US strategic and commercial interests in support of international partners who are seeking safe, secure, and reliable nuclear energy solutions. The US State Department is responsible for international negotiations with the technical assistance and concurrence of NSA and in consultation with NRC. NMSSS staff in the fuel facility business line supports the office of international programs policy work by performing a technical review ensuring that the tracking and safeguards obligations can be implemented in our system that tracks nuclear material that flows in and out of the country and it also monitors obligated material around the world. Our staff's work does not end with the signed agreement. They provide onhand implementation support of the agreements themselves. Over the past year, our progress has significantly accelerated and the US has signed new agreements with El Salvador, Armenia, and South Africa. Looking ahead, our agreements with Argentina and Saudi Arabia are nearing completion and as shown on the slide, planning continues for several more. That concludes my remarks and I'll now turn it over to Samantha. Thank you. >> Thank you, Shaina. >> Good morning, chairman and commissioners. It's my pleasure to update you on our efforts to enable deployment of new fuels for advanced reactors and on reprocessing. Next slide, please. The Department of Energy's fuel line pilot program is establishing a secure domestic supply chain for the DOE reactor pilot. These fuel fabrication facilities will begin operation under DOE authorization and may transition to NRC licensing for commercial operations after the pilot. In March, DOE brought in this effort by launching the nuclear energy launchpad, which expands the program to include enrichment and reprocessing pilot lines. The launchpad may result in additional facilities transitioning to NRC in the future. Today, the fuel line pilot program includes five companies that will produce trico, metallic, and saltbased fuels, and several of them are already planning to transition to NRC licensing under part 70. Our goal is ensuring that this transition is safe, efficient, and predictable and that it ultimately supports US energy security. We we will leverage the DOE authorization where appropriate to inform our independent safety, security, and environmental findings. To support this, the NRC staff is working closely with DOE on a transition roadmap designed to provide regulatory clarity and predictability. The roadmap will help future applicants leverage their DOE authorization and understand what gaps they need to address in their NRC license application. We hold weekly meetings with DOE and their contractor on the road map. These meetings allow us to identify gaps early and align expectations. Because the road map will not be completed until after the authorization review starts for some of the pilot lines, we are prioritizing topics that could lead to rework or redesign if not addressed early. DOE with our feedback is mapping DOE requirements to the NRC's and categorizing the differences as administrative, operational or facility level. Our early focus areas include natural phenomena hazards, building codes, safety classifications of structure systems and components, security, emergency preparedness, environmental reviews, material control and accounting, and construction oversight. These subject matter meetings are also helping NRC staff gain a better understanding of what is in the authorization and how it can be leveraged in future license application reviews. We've also been recording these meetings for knowledge management. Overall, this roadmap will be an important tool to help applicants meet applicable NRC requirements, will support the NRC's independent findings, and will enable a predictable and efficient transition into the NRC regulatory framework. Alongside the roadmap development, the NRC is also observing DOE authorization process itself. Next slide, please. Throughout the DOE authorization process, NRC is actively observing and engaging so that we understand facility designs, safety bases, and operational strategies well before NRC licensing begins. We hold bi-weekly calls with DOE and observe their authorization activities at the request of prospective applicants. These observations give us insight into DOE processes, highlight potential gaps, and support early alignment as prospective applicants prepare for eventual NRC submissions. To provide consistent direction, the NRC issued an expectations memo that clarifies staff involvement during DOE authorization observations. It also outlines what prospective applicants should expect if they plan to reference their DE authorization in their NRC application. and it encourages them to invite us to observe key activities as part of pre-application engagement for their future NRC license application. We provided this guidance to the pilot fuel line participants and those who plan to transition to NRC licensing have invited us to observe the authorization process. In addition, staff from the office of nuclear reactor regulation and from the office of nuclear regulatory research are detailed to DOE to support the review of authorization applications. Their insights along with regular communication help us understand the evolving designs and identify any gaps relative to NRC requirements. All these activities strengthen our readiness and promote consistency and regulatory expectations as these facilities move toward NRC oversight. Shifting now to our second topic, I'll discuss NRC's readiness to license reprocessing facilities under 10 CFR part 70. Next slide, please. Indust industry interest in reprocessing continues to grow. Multiple vendors are exploring aquous empire processing technologies and the NRC is already engaged in formal pre-lication interactions with two applicants. We have had informal interactions with several more. The various reprocessing technologies may process oxide or metallic spent fuel and produce a range of outputs such as uranium hexafflloride to be enriched re-enriched mix oxide products or metal ingots of uranium or uranium transuranic mixtures. In addition to the uranium and plutonium used in fuels, some prospective applicants are also planning to separate other elements to be used in industrial and medical applications. Early engagement is helping us identify any technical or regulatory challenges upfront. VA DOE activities are also contributing to technology maturation and providing early operational pathways through DOE authorization process before potential NRC licensing. As I mentioned, DOE's nuclear energy launchpad includes reprocessing activities that may begin under DOE and then transition to NRC. DOE surplus plutonium disposition and utilization programs provide material that may be reprocessed or down blended and used to produce plutonium based or mixed uran uranium transuranic fuel. Companies receiving this material may operate under DOE authorization and later transition to NRC or they may apply directly to the NRC for a license. NRC maintains regular coordination with DOE's office of nuclear energy, the advanced research project agency energy or RPE, National Laboratories and the National Nuclear Security Administration to stay aligned on technology development and safeguards considerations. ARPA E's converting used nuclear fuel radioisotopes to energy or cury program and DOE any DOE any research and development funding can make NRC licensing more efficient by de developing reprocessing methods and the process monitoring material accountancy and safeguards technologies that future applicants can use to demonstrate safety and security with this increasing interest the NRC is preparing for future licensing needs next slide please NRC's earlier work on a dedicated regulatory framework for reprocessing provides a strong technical foundation for future licensing. Beginning in the mid-200s, NRC conducted substantial preparatory work, including the 2009 regulatory gap analysis, which identified 23 gaps needing resolution, the 2011 draft regulatory basis outlining potential regulatory approaches, and the 2013 recommendation to develop a new part 70X based on riskinformed insights. Although that rulemaking was terminated in 2021 based on limited near-term applications expected at the time, we continue to use this foundational work in our pre-application interactions. Per commission direction, the NRC the NRC staff has maintained awareness of developments and reprocessing and invested in strengthening technical expertise. Since 2022, the Office of Nuclear Regulatory Research has developed four reports that expand our understanding of engineering scale pyroping, off gas and ventilation systems, chemical process safety, and emerging technologies such as vexidation oxide reduction and fluoride volatility. These products are informing updates to regulatory guides and standard review plans to ensure we fully address hazards and accident mechanisms across different reprocessing technologies. Under NR's leadership, we have also reviewed existing regulatory guides and began developing a draft annotated outline of a standard review plan for reprocessing under part 50. Staff across the agency participated, helping build reviewer capacity that will be valuable whether licensing occurs under part 50 or 70. Building on this foundation, the NRC is now focused on using flexible, riskinformed methods to close regulatory gaps and support licensing under existing regulations. Next slide, please. The NRC can license reprocessing facilities today under the existing part 50 or 70 regulations using exemptions and license conditions. We are leveraging past rulemaking efforts, technical research, and recent readiness activities to ensure future licensing decisions are grounded in a modern and robust technical understanding. These efforts also help inform pre-lication engagement and help us develop develop flexible approaches to closing regulatory gaps. Licensing reprocessing facilities under part 70 offers several advantages. It supports a streamlined one-step licensing process. It provides a riskinformed performance-based technology neutral framework and it reduces burden by eliminating eliminating duplicative exemptions or prescriptive requirements. NRC is also helping applicants navigate atomic energy act requirements for reprocessing facilities that are also production facilities. Based on the risk profile of each facility, we're assessing whether a facility would be a production facility and exploring flexible methods tailored to the facility risk. For example, the act requires the NRC to license operators who manipulate the controls of a production facility. An applicant could propose a definition of these controls based on a consequence threshold. If a facility does not have accident sequences that would meet that threshold, license operators would not be required. However, this would not eliminate the requirement to have a robust training program as part of their management measures program. Similarly, we're working with applicants to align on the appropriate subset of safety limits, limiting conditions of operation, and surveillance requirements that should be included in technical specifications based on the specific risks of the facility. In closing, the NRC is proactively preparing for the emergence of new fuel types and reprocessing technologies through strong coordination with the with DOE, early engagement with industry and development of flexible risk informed approaches. We are ensuring that applicants have a predictable pathway into the NRC regulatory framework. Our goal remains the same to enable innovation while maintaining the highest standards of safety and security. That concludes my remarks and I'll turn it over to Chad Olstrom. Thank you. Good morning, Chairman N and commissioners. Thank you for the opportunity to brief you today. I will provide a regional perspective on our ongoing enhancements to fuel cycle oversight and inspection, including how the smarter inspection program has provided a base for gaining efficiencies, the enhancements informed by the advanced act and our construction operational readiness in inspection program for fuel facility expansion and new fuel technologies. Next slide, please. To provide region 2's perspectives on oversight enhancements, I need to begin with a brief overview of the smarter fuel cycle inspection program or SIP. To illustrate how SIP is the foundation for our approach to gaining efficiencies while maintaining safety, region 2 has been executing the SIP for over four years. While the SIP considered all phases of the program, the major initiative focused on the baseline inspection program and represented a a sustained riskinformed transformation of our inspection program. SIP focused on three major areas. Inspection frequency and resource allocation, reducing overlaps and enhancing guidance, and programmatic and process improvements. In 2024, we completed a comprehensive self- assessment of the SIP's effectiveness. The assessment concluded that SIP successfully met program goals and improved regulatory focus and consistency while maintaining safety. For example, the SIP identified nuclear criticality safety as an essential inspection area and ter and determined that shifting critically related inspections samples from other inspection areas to inspectors with specific criticality safety expertise would enable for more focus and effective inspections that support reasonable assurance of adequate protection. This more targeted, risk-informed approach resulted in an average of 16% annual resource savings in this area without degrading oversight effectiveness. The SIP assessment also identified areas where additional clarification and flexibility is needed to address emerging trends, enhancements in training and knowledge management, refinements to inspection guidance, and continued improvements in staffing and scheduling. Overall, the SIP has demonstrated that inspection effectiveness, efficiency, and safety assurance can be strengthened simultaneously by also adapting to the evolving facility risk profiles and staffing realities. Next slide, please. Over the last year, we have continued to improve the program with the advanced act section 507 recommendations. These improvements to the program built off the SIP success, use the SIP assessment, and applied a risk informed approach. This past year, we have implemented the enhancements. These include implementing the revised solstice conversion facility principal inspection plan based on the facility's evaluated risk profile and implementing the first wave of advanced act 506 507 recommendations resulting in an additional 3% resource hour savings to the overall oversight program. Some examples include shifting the licency performance reviews from bianial to trienal and basing the need for public meetings on licency performance and public interest, incorporating very low safety significance issue resolution into inspection guidance and limiting the need for inspection entrance and exit meetings to reduce the burden on inspectors and lenses. In addition, working with the division of fuel management, we have made additional recommendations for enhancements under the advanced act section 507 recommendations. One example is we recommend recommended combining the plant modification annual and triannual inspections into one bianual inspection. These staff recommend recommendations will build off the previous enhancements and are expected to result in additional resource savings without reducing safety focus. Staff recommendations are currently in the review and approval process with implementation in calendar year 2027. Next slide please. The efficiencies gained through SIP implementation and subsequent enhancements have strengthened region 2's inspection program and enabled more effective use of resources in areas of greatest need. With the gain efficiency, we are pursuing the previously discussed opportunities provided in the SIP assessment, including increasing inspector depth in specialty areas, knowledge sharing, and continued improvements in staffing. Currently, one inspector is pursuing fuel facility qualifications while other are expanding specialty qualifications to strengthen baseline program execution. For example, since the assessment, two inspectors have completed qualifications in material control and accountability inspections, increasing capability and depth in a critical program area. Region 2 inspectors are actively supporting the program office through rotational assignments that contribute to program oversight and procedural enhancements. They are also engaged in key licensing efforts such as MLEP and played an integral role in the tricox licensing process by providing oversight perspectives on the practility and enforcability of license conditions resulting in tangible benefits to both licensing and inspection. The crossorganizational collaboration particularly with the division of fuel management has strengthened knowledge sharing improved licensing insight and enhanced overall program quality. The SIP implementation together with the subsequent enhancements has ensured regions 2's ability to administer the baseline inspection program while enabling the in strategic allocation of resources to construction oversight, facility modifications, and emerging technologies. Next slide, please. We are applying the same risk informed scalable principles used in SIP to our construction oversight program. Recent experience includes implementation of the construction inspection program for TRISOX, including construction inspections that resulted in productive discussions on nuclear safety and oversight expectations. And at Frammatone, we are conducting operational readiness reviews, OR inspections, on sitewide modifications that support increased enrichment activities by performing inspections at each phase. As each phase is completed, we will reduce the overlap in volume of inspections required at the end to help support a timing layer authorization. We have modernized the construction inspection framework by leveraging lessons learned from prior fuel cycle construction efforts in part 52 reactor construction as well as insights gained through the development implementation of the advanced reactor construction program AROP. This effort reflects a coordinated approach across region 2 fuel staff, experienced construction inspectors, the program off, and the advanced reactor program staff. These insights have guided the development of inspectional manual chapters that establish a scalable risk informed construction inspection approach applicable across all fuel cycle facilities construction, replacing the prior sight specific model. inspection prioritization and scheduling tools that maintains construction oversight resources at a fraction of historical levels while ensuring safety and a sustained team of qualified construction inspectors leveraging expertise across business lines rather than increasing staffing. In addition, we've periodically updated industry on our approach and conducted construction workshops on the construction inspection program. Next slide, please. As part of our modernization efforts, we now rely on a suite of datadriven tools that strengthen our readiness, improving planning, and enhance the predictability of our construction oversight. These tools also reflect the reorganizational benefits of closer alignment between regional fuel facility staff and headquarters program policy and licensing organizations, enabling more integrated and informed oversight across the agency. To support consistent, efficient, and effective construction inspection planning, we developed a riskinformed inspection prioritization tool for items relied on for safety, IROS. This tool created by the office of nuclear regulatory research in collaboration with region 2 inspectors in the division of fuel manage management helps inspectors prioritize the most safety significant features by using a riskinformed approach that evaluates IRFs and accident sequences. applying construction inspection attributes to prioritize inspection activities, supporting preparation for operational readiness review inspections and informing construction inspection and operational readiness review planning. This tool enables consistent and defensible inspection decision-making by aligning inspection focus with risk significance and construction attributes. It has already been applied to inform the development of the TISOX principal inspection plan with strong results. To further strengthen our risk informed planning, we are developing the fuel cycles facility tracker tracker in an interactive PowerBI based platform that integrates real-time insights from region 2 and headquarters licensing and program staff to project construction milestones and confidence levels across emerging fuel cycle facilities. By unifying these inputs in a single dashboard, the tracker enhances coordination between regional and headquarter staff, improves visibility into upcoming work, and enables proactive alignment of inspection resources where they are needed most. Next slide, please. The nuclear industry landscape is evolving at a brisk pace. Many new companies and contractors are entering the nuclear landscape with limited or no NRC or nuclear experience. In the past, the NRC has provided updates to the industry about our construction inspection program and our interpretation of regulations. With the influx in new applicants and new contractors in fostering our mission, we have developed a dedicated presentation and engagement effort to help the new players understand nuclear safety and construction and demystify NRC construction oversight. The outreach is focused on how we execute our mission for public safety safety through our inspection and oversight process and the benefits of open communication between all parties, a strong nuclear safety culture and establishing programs early that ensure timely identification and resolution of construction issues. This presentation will be presented at an upcoming fuel industry stakeholders meeting. Region 2's experience demonstrates that scalable, riskinformed oversight can maintain safety, support emerging fuel technologies and help the agency adapt to growing workload without proportional increases in resources consistent with the commission's expectations and the public's trust. Importantly, the impleation of these programs and enhancements reflects a mature evolution of our oversight capabilities, enabling us to meet our public safety mission while enabling the safe deployment of new fuel facilities. This completes my portion of the presentation. I will now turn it over to Mike. >> Great. And thank you all to the panelists. Uh commissioners, happy to take your questions. >> Yeah. Thank Thank you very much for the comprehensive presentation. Commissioner Marzano, you got to go first today. >> Oh, thank you, Chairman. And thank you all uh to our panel for your uh presentations today and for your role in enabling the safe and secure operation of our nation's fuel facilities. Uh, as I stated uh during last year's commission meeting and as the chairman pointed out, the work that you all do to support the licensing and oversight of nation's fuel facilities has a direct connection to strategic national priorities. I commend you for what you have accomplished over the past year, demonstrating how the NRC isn't simply keeping up with innovation, but driving innovation in fuel cycle technology towards commercial deployment. Your efforts are supporting a once- in a generation modernization of our nuclear fuel supplies, delivering new fuels that are enabling power upgrades at existing reactors, and making advanced reactors viable. Last year, we discussed the expectation of significant growth in the fuel cycle business line over the next few years. And as we've heard during this staff's presentation, these expectations are quickly becoming a reality. Uh it is clear that the workload in this business line will be higher than ever and we must manage our resources strategically over the next fiscal years directing them where they're needed the most. Uh we must also anticipate the staff's needs and ensure that they have the tools to support and accommodate this this coming workload and the agency maintains the technical expertise required in this area. I encourage staff to seek support from the commission as needed and I thank you again for your commitment and your expertise. So with that, I'd like to begin um uh talking a little bit about reorganization um especially in NMSS and and how the regions are going to be kind of shifting and transitioning here. So um as it's uh pretty well known um regional staff are going to be reporting directly to NMSS rather than to the regional administrator. And so uh my question uh centers around with this new structure how change management how the change management plan that is implementing this uh will address the kind of organizational organizational culture aspects of the transition and specifically how you know leadership at NMSS will ensure that effective and efficient communication and cooperation between the leadership and regional staff will be maintained. Uh including an inclusive culture where people feel part of the organization. um given that the leadership is not going to be necessarily physically present. >> First, thank you for your really thoughtful comments. Um and but in terms of your specific question on the reorganization um first I'll just start with what the reorganization will accomplish um in terms of our efficiency and our decision-m and I think bringing the licensing part of our our mission together with our inspection part um will help us work through issues more quickly um and get to a risk informed approach. I think the other thing that um bringing the regions under NMSS will accomplish is looking at consistency in our approaches across the regions. Um but to get to your specific question which I think is really really important in terms of integration of the organizations um in the regions under NMSS and communications and um making sure that those organizations are integrated that is one of our highest priorities and and it is something that we need to pay particular attention to. And so we're still continuing to think through this, but a couple things that we're already working on are are more direct communications. Um so things like video communications instead of email communications. Um being physically present um in the regions. So we're making it both ways. So um you know, Kathy and I are going out to all the regions in the next few weeks to make sure we get to know the people there. Um we do need to make sure that we have opportunities from to have people from the regions um come to headquarters. So, we've set up several opportunities in the next few weeks to make sure that we do that. Um, and then I think we need to think creatively about in integration when we can't be together. Um, so making sure that we remain connected. Um, so little things we're thinking about. Um, making sure that we have like a a photo or chart instead of just an org chart with names and so that you know people's faces. It seems like a small thing, but that's that's a big thing to me to make sure that we know the people in our organization um, and they feel valued. Um and also thinking about how we can connect even virtually. So I mean yesterday we had a connect day event um where we had like people joining for lunch and we had teams um from the regions teams connecting to the regions where they had their own connection event. You know it's not ideal. It's not we're not all in one space but making sure we think about how we do those things creatively so that people feel inclusive um are just some of the things that we're thinking through but it is a critical issue and it's um really top of my priority list. >> Yeah. And I think, you know, there's there's pluses and minuses. I think there's a lot of benefit in in uh, you know, raising kind of some of the experience that inspectors and folks on the ground have on a daily basis to kind of, hey, this is a good idea. This is working or I have this idea and and being able to have that kind of more consistently applied across NMSS um, and the business lines here. I think that's very valuable. But at the same time, you know, feeling that connection to the organization, u being, you know, in a separate physical location, I think can be a cultural challenge as well. So, I appreciate the proactive steps that you're trying to take here. Um, so I'm going to shift a little bit, uh, away from, uh, the reorganization topic. I want to, uh, Samantha, one, thank you, uh, for your years of public service, and I appreciate all that you've accomplished here. Um, I'd like to kind of talk a little bit more specifics on the the transition of DOE pilot facilities to NRC. Um, has there been and in the in the fuel facilities uh uh specifically any historic examples of how uh a DOE um facility has been reviewed and approved by the commission um uh into our under our authority? >> Yeah. Um in the 1990s we transitioned the gaseous diffusion plants from DOE authorization to NRC certification under part 76. Um so there were actually a lot of lessons learned from that. There's a NRC lessons learned report. There's an NRC lessons learned report. Um and we reviewed that and are using a lot of those insights um in our interactions with DOE and the development of the roadmap and thinking about how those facilities can transition. So some of those things are directly what we're doing now. Like one of the recommendations was having a crosswalk of DOE to NRC requirements. So that's the road map. Um another one was making sure that NRC staff are trained on the DOE requirements. So in all of our interactions and our subject matter expertise discussions as well of having uh NRC staff that are detailed, we're really gaining those insights. Um, and there were discussions about readiness for transition and those are things that we're going to consider um as we develop expectations for construction oversight as well as what that transition looks like. >> Excellent. Yeah. Um I knew there was an example out there. Just going to maybe put my uh my my finger on it. But um you know again you you've mentioned kind of the observations and being involved um with the DOE reviewer specifically. Are there any areas in particular that you're seeing that are going to present kind of more of a significant challenge? I'll say, you know, that's one example, but we have lots of different players, new players, um, have a lot of familiarization to do with both DOE's authorization and ours. And so, you know, as as you've kind of gone through these, uh, observation activities, um, is there anything that I think you may anticipate would be a greater challenge than others? >> Yeah, many of the, um, pilot line applicants are new to the nuclear industry or have a um, more limited experience, right? So they're first trying to understand the DOE requirements as well as the NRC requirements. Um and with the road map coming later, it's really important for us to be able to ourselves understand what those differences are and be able to communicate that early enough so that if there's something that would require a retrofit in the future, they can consider that early enough before they start construction to say, "Okay, well, I might need to design for a slightly different design basis. Let me make sure that I'm conservative and I'm addressing both. >> Yeah. On along those lines, I mean, so there's definitely a potential scenario where, you know, a license may in transitioning from DOE to NRC may have to, you know, either augment or revise their integrated safety analysis or um make other site modifications. Is is that something that you're that is potential here? and how are we kind of working um early on with the pilot facilities uh to hopefully try to minimize or avoid those impacts. >> Yeah, that's exactly why we picked the topics that we did for early engagement. Those are areas that could potentially lead to retrofits redesign. Um and so fortunately with the pilot lines, they're they're several months behind where the reactor pilots are. So they're not quite as far along in the in the construction or even in the design review. So we have a little bit more time to to provide that. Um with the applicants who are going to transition, we are looking at um their um preliminary documented safety analysis. Um if they have that, if they want to share that with us and trying to find some of those insights and and we will be sharing those with them. >> Excellent. All right, Chad, thank you for being here. Um, I'd like to talk just a little bit about again kind of transition, right? We have a lot of focus on construction oversight, um, rightfully so, uh, with a lot of new facilities coming online. Um, but as we kind of move from construction to operational phases, um, how how are you seeing kind of this uh, how our oversight program may have to shift for new facilities uh, compared to those that exist today? So from an operational oversight perspective, can you talk a little bit more about uh what you may anticipate? >> So for for our program uh the way it is structured is we should be able to >> Okay. I know. Uh so so for the way our program is structured is that we should be able to incorporate these new facilities with into our existing baseline program. And right now as part of the advanced act we are also looking at you know what improvements can we make uh for the program. So for example we're we're able to um when we're looking at the different categories of fuels we've already started to incorporate category 2 fuel facilities into our baseline program. So in that way we we were going to be able to to continue our oversight over these programs and over these facilities. >> Okay. Thank you. Uh well my time is up. Uh I just I'll just note real quick. I think that it's very um I was very uh pleased to hear about how just aligning knowledge and background of of inspectors can pro provide tremendous efficiency. So uh I just want to plug to kind of continue to look for other opportunities in that because I think that's very powerful and it's shown in the results. So thank you Mr. Chairman. >> Thank you Commissioner. Commissioner Weaver. >> Thank you chairman. Thanks to all the briefers. appreciate the uh time and effort it takes to prepare. Um Samantha uh just a comment first. Um you may not recall, but we worked together almost 20 years ago putting together new rego 800 uh in anticipation of the first uh renaissance. And it's been a pleasure to see you uh grow within the NRC and and I'm sorry to see you leave. Um, so I um looking at the I I think it was Shaina you showed the budget numbers uh in terms of the fees over the years back in that 2016 time frame. Um I recall submitting several pointed letters to the NRC about fuel cycle fees. You could look those up. They're kind of entertaining to read now. Um, but my my points I think so I'm I'm really pleased to see the progress you've made and the work you're doing to try to manage that, right? Because I felt at that time I I didn't sense that that was happening. Um but the things to you know when I when I look back what what really mattered there was you know your your budgeting your licensing you know for what you think is going to come and some of and what what happens is somewhat out of your control but you can make better guesses based on experience and I think you're you're doing that but the other piece that I think I really focused on and and this is where my question's going to go is for um for the nondirect billable work, the bulk of your work really to make sure that it's really adding value right that it's directly related to the mission because I felt in the past sometimes we were going down roads that ultimately didn't come to fruition used a lot of internal resources used a lot of resources on the side of the lenses and applicants and then nothing came of it so um as you look ahead you I guess we'll have the 28 budget before us soon, but what are the biggest non billillable infrastructure type projects that you have in fuel cycle? Um maybe from an importance and from a size resource perspective. >> I could start and and Shaya can add. >> Sure. Um so there so we are trying to make sure that most of our work or most of our time is spent on direct feed billable work and I think if you look at the portion of our budget that is direct feed billable it is increasing over time so I think we're moving in the right direction there's still more to do so we're continuously learning organization um but in terms of answering your specific question there is also important work that happens in what we call indirect activities that do contribute to the annual fee and the biggest one is training our staff um and So we do need to continue to do that. So that's that's a big portion of what goes into that annual fee. Um another big portion rule making and um this year we're we're overspending in rulem for obvious reasons. So rulem is a big part of it and guidance development um and you know we do need to look at the value of of those various activities and make sure that the value is worth the time that we're expending. Uh we have deferred a lot of guidance development. we are thinking through um what things we need to not do anymore. Either maybe we need to do them less frequently like some kind of um annual reporting requirements that don't add a lot of value. We might be expending them or or just not doing them anymore. So we are looking at return on investment of those things. But those are kind of the big hitters. Um and I'll just have to give a shout out to my predecessor John Leinsky. I think shortly before he left he introduced a return on investment template so that it kind of forces us to ask for those indirect activities what it walking through what is the return on investment so is this worth spending our time so you know I think more to come on there I think we need more work there but we're moving in the right direction >> yeah and I'll just add um as you know in fuel facilities fees have been a focus area I think from 2016 to where we are today 10 days later 10 years leader. It's a very different It feels like 10 days. Sometimes it feels like 1000, but um you know back in 2016, I don't think we had nearly the level of rigor that we have today. And since I joined uh the business line in 2021, we've had a lot of public engagements with industry to give transparency about what exactly is in the nonfeillable aspects of the work that we do. And a lot of it is people as Andrea noted and the administrative functions that are critical to achieving our mission. We cannot get work done if we don't have administrative assistance for example. We we see that when we have a shortage of staff in that area that there becomes a backlog of licensing and we don't want to be there. Uh so there are definitely mission critical aspects even though it's nonfeed billillable work that we absolutely need and that's where we've been placing our focus. Um, one other thing about fees that I'll mention is that it's a partnership when we're looking at managing fees because the workload we're reactive to it and one of the areas that we've in addition to giving transparency about what comprises the non-fee billable we have uh and credit to Samantha uh because she laid quite the track record for knowledge management not just from this meeting but in our fuel facility stakeholders meetings we have one next week and she's presented in that forum to sort of educate ate the industry about the timing of our budget process and when staff has the ability to influence decision- making when the commission has the ability to influence decision-m because once we get on a path there are certain things that are prohibited by law or by process that we just simply can't influence from the staff level. So knowing when to give us the information I think has been helpful because we have seen increased communication from applicants and licences. They're sensitive to our timing. Sorry for the long answer. >> Thank you. I'm going to try to get in two two more questions. uh if you hit me. Uh so on the reprocessing uh work, um I think I heard there's a draft standard review plan uh under development perhaps or I'm not quite sure. What is the status of that and when would you expect to have sort of some public engagement on on that? Yeah. So the inter the working group with NR and NMSS um started out looking at reprocessing under part 50 um and looking at the existing reggg guides that was looked at in the draft uh reggg basis as well and what should continue what needs to be uh updated or modified and working with the center started an annotated outline for an SRP under part 50. Um, right now much of the interest is licensing under part 70. So, we're going to take some of what we learned in starting the development of that and consider what future updates for reprocessing guidance may be needed. So, we'll leverage that um as we evaluate additional guidance needs. >> Okay. Um Chad on on inspection. So obviously for reactors we just rolled out, you know, we're in the process of changing the the ROP. Um when when if you look back to a time before um the smarter inspection program was implemented and to where you're going to end up, can you give me some sense of how the level of effort might change in terms of the number of inspection hours at a typical lency? I I realize there's different kind of facilities and you know it may vary by facility but I'm trying to for example in RO we went from something like 2,000 hours in the baseline to something like 1300. I'm just trying to get a sense of what the magnitude of the changes that are occurring on the fuel cycle side. >> So in terms of hours um I can't provide that percentage-wise uh I can I can provide that. So when you look at what we've done for re resource savings, you need to look across, you know, the past five years with the SIP implementation, what we've introduced with the um advanced act so far, and then what we propose to uh introduce and with those reductions, what we're looking at total is roughly 30% decrease. >> Okay? >> So, >> so it's comparable. So it's very comparable to the RO. >> And as you look forward, you know, obviously fuel cycles other than enrichment facilities can start construction pretty quickly after they submit an application. Um how well are we prepared to deal with having, you know, a larger number of fuel cycle facilities under construction and and the construction oversight program? That's where these efficiencies that we've gained are extremely helpful because it's now allowed us to to take resources and focus in on construction and manage these construction projects. Now, there will be a point in the future as they're you know looking at budget and that where you know those resource uh the amount of workload will catch up to those those gains and so that that's continuing to be evaluated as far as for future budgeting and that. But for right now, we are able to, you know, focus in on on the the demand for construction. >> Okay. Well, thank you. Uh that that's all for me. Oh, yeah. Mike, I'm sorry. >> I was just going to say um you know, the work that's going on with the reactor oversight program and advanced reactor construction oversight program. They collaborated across business lines. And so all the good learnings from that have been applied here. And the the construct I think will per yield the the biggest results is they start with what is the risk of this facility to the public. Let's scale the overall plan for oversight commensurate with that risk. So if it's a higher risk facility, there'll be more construction oversight. If it's lower risk, there'll be less. And so that is uh what's baked into these programs. >> Thank you, Chairman. >> Thank Thank you, Commissioner Weaver. Thank you all for the presentation. Your work is incredible. It's so important to the future of nuclear energy in America, not only for existing reactors, but as well as the the new reactors. I really appreciate everything you and your teams are doing here in headquarters in the region. Samantha, congratulations on on your next the next chapter in your career. I wish you all the best. I'm glad we had a chance to do that TISOX showcase of the accomplishment of of the business line there. So, uh, Chad, I really like the discussion about the fuel cycle oversight program improvements. It's great that you're you're making it more risk informed. I love that you even had research helping you with the priorities. So that's great work here. I want to talk about further enabling how we can do our jobs better having a strong safety focus with efficiency and speed. I think we have an opportunity. Project Ike Orano, right? They submitted an application to the NRC and identical facilities operating in France licensed by a mature competent regulator, the ASNR in in France. Right. There's decades of experience we have with these facilities. So tell us what do you think the opportunity is for us to leverage information from a trusted competent regulator to help us arrive at a safety decision sooner rather than later? Yeah, I think this is a it is a unique opportunity and we must we must seize that opportunity because it it's unique in that we have another country that has licensed a facility with the exact design that we are now reviewing. We have another country that has more experience and things like reprocessing that we haven't done in this country in years. So that we found that's a very unusual situation for the NRC and so we are we are taking full advantage of that situation. Um we did meet with France um during the Rick to start the discussion about how we can coordinate. Um we need to take this idea of leveraging to a new level with what we're doing with um project Ike. And what I mean by that is um you know we look we've done similar things on the reactor side and and based on the timing of applications or differences in the designs that are being considered or differences in the in the frameworks that are being used in countries. we haven't been able to actually take another application and reference it and leverage that information and that's what we need to do here. Um so we're at the very beginning of the process. Um we've got a series of activities laid out for this summer to start interacting with France. Um but what we've done so far is try and identify what are the topics where we think there may be the most similarities between the two frameworks and where we need the most assistance. Identify those and go after those areas um to be able to fully leverage. We're also thinking about how we might be able to use AI to evaluate, for example, the safety evaluation. I don't know the French term for safety evaluation, but to le to leverage the evaluation that was done by the French and compare that to our uh requirements to see where there are the most similarities so that we can leverage that. Um so that's another idea that we have and we have staff going over to France actually this summer to tour the facility um to get some more of these insights. So um complete I couldn't agree more. It's a uni unique opportunity that we won't let pass us by. >> If I could have one aspect of it is it's not only unique opportunity for us to learn from and leverage what but it's also an area for us to lead in the international arena right at the IAA we were just there right uh Poland and others are trying to leverage our our previous reviews. This will allow us to play a key role in enabling the deployment of US technology abroad as well. In >> in my view this is the model for the future of global nuclear safety regulation. We all know a lot. We've done a lot and and I think this is an area where we can demonstrate leadership using another country's uh information to leverage what what we do. So that's great. I love to hear it. I want to hear more about the efficiencies we can gain there. Okay. Uh DOE and NRC coordination of fuel pilots. You know, there's been a lot of questions asked about, hey, what what is happening? In my view, this is a deliberate, coordinated federal effort to deliver nuclear energy infrastructure to America. I've talked with uh some folks that we have detailed over the DOE on the reactor pilot program. Amazing examples of how our knowledge and experience is informing the development of uh you know, improving the safety case for these designs that that may ultimately come to NRC for uh commercial applications. I heard you say it's kind of, you know, we're you're a little behind the reactor pilots, but but tell me with with the folks that uh we we have observing, tell tell me some of the things that we've seen so far and how that's going to help us uh in in commercial transition. >> Yeah. Our staff that um are detailed for the reactor pilots, some of them are they're the same people. There's a subset of them that are also working on the fuel facility pilots. So, they're learning that DOE process on both sides. Um we have staff who are looking at fire protection, um MCNA and physical security as well as quality assurance. So we're having good discussions with them. Um they are asking questions. They're asking Ris like they would um if this was an NRC review. Um there haven't been any real like major aha moments yet. Um but we are early in the review. I will say some of the things that have come out um from talking to pre-applicants is interest in how are we going to leverage uh DOE environmental reviews. So we've gone back and had discussions on that topic to look at, you know, can we IBR things if there's how do they document that? Are there things that we can leverage and how will that help us in our review in the future as well? So we're thinking about this more holistically. >> Okay, that's fantastic. Look, there there's no rubber stamping, right? whether we're going to work with another regulator or work with another federal agency, right? There there's knowledge and this knowledge helps improve our decision. So we will in all cases I believe val validate any information we have from any observation of a foreign regulator or another federal agency to you know inform and make our regulatory reviews efficient because the way I see this look we we DOE is investing significant u money and programmatic things to build the nuclear life cycle infrastructure NRC we're providing the licensing frameworks we're in separate lanes of traffic but we're all headed to the same destination which is United States leadership in nuclear energy. So, thank you for the work there. Um, with all this great stuff going on, this cannot be one and done, right? You all have made extremely amazing accomplishments in the timeliness of your decisions with a strong safety focus with efficiency and speed and that's great. Can't be one and done. So, EDIO mentioned a couple days ago, we're building a management model to instill the discipline and the consistency in how we do business going forward. So, I'm going to ask a mid-level manager, Shaina, tell me how you see an NRC management model helping us going forward into the future and sustaining this performance because I've already seen the things you're talking about with budget execution discipline, the the focus on feeds, responding to Commissioner Weaver's letters. Uh, te tell me how a management model is going to help our agency be be successful long after all of us in this room are gone. happy to share some insights and I'll try to be less longwinded than I was on fees. >> Got two minutes and two seconds. >> Yes. >> Thank you. Um, you know, I we talk about systems, we talk about data that we're using, the leading lagging indicators, the project dashboards, but the data and the dashboards are only as good as the people who are going to go and use those systems and apply them in their day-to-day behaviors. And I can tell you as a kind of a lesson learned coming out of the tricox review, it was really the shift in behaviors that started accelerating our progress and the tools helped us. Um, but I think with the organizational model that we're developing, having the focus on behaviors, uh, Andrea and I are actually leading the development of what that actually looks like, more specific behaviors. We're having a a town hall with staff next week to start to roll out our preliminary thinking about those and get feedback because we all have to see ourselves in in the management model. And I think that for the the the lessons learned that we take using those in a forward focused manner, updating our programs. Um for example, many of the lessons learned from TRIOax, we're now informing our efficiencies that we've been developing under the advance act. We're documenting those in our division instructions which are publicly available and they're going to help us and by being publicly available it's going to help our our stakeholders hold us accountable to them if they don't see us following them. So I think there's a lot of ways that the management model is going to help us and having the alignment and the leadership to help us focus on the the behaviors, the accountability, the standards that we want to set. Um I see a lot of promise in that actually. >> That's it's really great to hear. You you mentioned culture. Both of you you mentioned culture in in your discussion and Mike, thank you for for your efforts. I I I love what you all are doing. I'm I'm so proud of the leadership team and how much you've accomplished in such a short period of time and just building the framework for a discipline management model that we can use going into the future. I I think organizationally speaking, this is probably one of the most important things that we could do for the sustainability of this agency going forward. Again, our efforts here just cannot be one and done. has to be repeated over and over into the future over a long period of time. So, thank you very much. I'm done. And I think next commissioner. >> Thank you, chair. And and thank you for your comments, by the way. And if you don't mind, I'd like to associate myself with those comments because what you've identified and and and what the staff is trying to do is critically important and and it has to be durable. It has to be able to replicate itself over and over and over again. Um and I I really appreciate your um what you said and your efforts as well and thank you so much for your presentations today. Um I know how difficult it is to prepare for these things um and for the people who help support you and you know it but this is a a really important meeting because you're coming to inform us and um allow us to try to ask some questions that make sense I guess where we can get some good maybe clarity on some things. Um, Andrea, I want to take a moment and just thank you for your comments about Samantha Law. Um, uh, I, uh, um, had the opportunity to, um, have Samantha in my office. I was one of her complex challenges. She was a very valuable member of uh, team, right? Um, I remember when I hired her, um, she immediately took three weeks off to get married and go on a honeymoon. Um, uh, and then she came back and she she she worked very hard for us. Um, she uh, she but more important than that, Samantha, you do prioritize your family and I really um, you know, you know how I am about all that in the office and so I'm very uh, very proud of you in that regard. Uh, that you try to keep things balanced. Um, you know, she's fun to work with, too, just so you know. Um, she tolerated constant puns, uh, word play and dad jokes. Um, her sneezes are memorable. I know y'all have experienced that. Um, and when we traveled and we did we got to travel to different facilities around I cannot tell you the number of gigantic inflatable animals that we saw on top of buildings and in the weirdest places, right? And we laughed constantly. Uh, we didn't even have to speak to each other. When you saw it, you knew it and you just laughed about it. So, um, I appreciated that part about you. But seriously, um, you're exceptional in every way, Samantha. Uh, and the NRC is a better place because of your service here. Um, and team Wright loves you as well and wishes you the best. Okay. So, thank you. >> Thank you, Commissioner. I appreciate that. >> Well, maybe not all of it. Um, with that, I'm going to I'm going to transfer over to some questions. Um so Andre you mentioned at early in your background slide seven or so and you you mentioned that the um you'd shed certain activities right uh to focus resources better. Can you maybe add a little meat to that bone and maybe clarify or specifically what kind of activities or program elements are have been reduced or eliminated uh particularly in the licensing or framework development or guidance updates? It's an important question because um if you've been at the NRC, you know it's an area that we struggle with actually is shedding our work. And so what we're trying to do is um to be very deliberate about that. So we're actually tracking every activity that we shed and updating that um and we continue to just send that message that you know when you add something what are you taking away and then what's the return on investment on what we're doing. So at a high level that's what we're doing. But to specifically answer your question, I'm in the fuel cycle area. Most of what we've um shed is is guidance development or deferred. Um so most of you are familiar with new 1520. It's the new reg that we use for licensing fuel facilities and it does need to be updated, but we did defer updating it as as as long as well as multiple rag guides and other like internal guidance. Um like like I mentioned, we're also deferring um some like routine periodic reports um that we've maybe pushed out instead of doing it annually, maybe doing it every couple years or every five years um as well. And we're using that return on investment template um to ask ourselves, do we really need to do this and just shedding the work that is not needed. Again, more work is there as a cultural shift. Um we hire the brightest and the best and the brightest and the best like to do everything possible. Um and so we really do need to to focus in that area. So more to come. >> Okay. Maybe I might want to drill just a hair deeper on that too. So with with regulations becoming more risk informed and um you know how are you ensuring that you're keeping pace you know are is there any kind of a a sign a metric or um that you know and and and I guess what would be the plans? Have y'all developed plans on how you're going to keep how you're going to address areas where guidance seems to be outdated? >> Yeah. Um I would say the guidance in the infrastructure and Shaina talked about the importance of the infrastructure. It does need to keep pace. Um so I'll acknowledge there are probably areas of our guidance that that aren't keeping pace right now just because of the speed at which we're moving. So we we do need to integrate those activities of update updating the infrastructure um back into our work. It's just doing that at the right pace. Um and so and it might look different how so you know we we typically issue new rags. It was very resource intensive to write a new new rag or update a new new rag. we need to look at the process by which we're doing that to look to streamline the process so it's not so resource intensive or providing that information in a different form like in a in a um I like to use the example of nucleopedia you know it's information you could put out there quickly to people and it's very accessible so thinking differently about how we um actually get that information out there >> okay anybody Samantha >> just a quick example of that so when we were doing the tricoex view it became apparent to us that we needed more uh guidance on electrical and INC and what was needed there. So the staff in NR who supports us they developed two um template SCRs to kind of walk through like what would we be looking at when we're writing our STR and that really helps um TISOX as well we've provided to other applicants understand what needs to go into the application. So, we're looking at other ways that we can get that information out quicker. And that's one example, >> right? I'm not exactly sure where the questions at in this, but one of the big concerns we have and and especially in the fuel side of things is budget and and making sure that, you know, if something doesn't materialize that people don't get penalized or how we're trying to work through those things. And I know that you're um you Shaneie, you mentioned it as well that y'all are trying to do a little better job of looking in the crystal ball, right? But you know, in in the event that that doesn't hap, you know, that the crystal ball says one thing, but something else happens. Can you give me a little idea of what you're really looking at or how you're looking to get help um in in this area? as there is because it is important to the people the lenses it's important to us from resource allocation and and things as well and and I don't know are we and I guess on top is there something that we as a commission need to do to really get involved on the hill or anywhere else to to help address this. Um, so just quickly want to give a shout out to Shaya and her folks because I I think a big part of making sure that that happens less is the confidence rankings that we've developed as part of the budget and they've done a fantastic job of looking at what has caused us to receive an application sometimes that we didn't expect or not receive one that we did expect and they've rolled that into the confidence levels that we use for budgeting. So just shout out to them that should help. But in terms of your question, you know, when it does happen, what are our tools? Um, we do have tools and Shaya mentioned some of them. Um, the implementation plan when we get our budget, if something's changed, we can make an adjustment. We've got in mid year we check in to see where are we? We can shift things between business lines. We've done that. You know, where can the commission help? There isn't there isn't are opportunities through the budgeting process for us to interface with Congress and OPM to give them the heads up that hey, you know, we don't see this coming in. We don't we don't need that portion of our budget anymore. Um, we used to do that less formally and we didn't always do it consistently and I think we're we're becoming much more consistent about how we do that. Um, so I think that's where the commission can help. >> I'd just like to add to all of that and um, I really appreciate the efforts that our partners in OCFO have undertaken to work with us recognizing the sensitivity of the small fee class. So, you know, it's really key that we leverage. We've got limited opportunities. The commission has limited opportunities and making sure you have the information that we have at the right time so that you can seize that chance when you have it depending on where we are in the budget cycle is very key. So, I really appreciate what CFO is doing to help us with those communications and we'll certainly be keeping the commission informed if there's an area where we have to pivot in the future. >> Yeah. And I was just going to mention we are actively working on looking at this problem of fees and what how the commission could potentially help in this area. So >> yeah. >> Well, I appreciate your willingness and to just come visit us um from time to time just to keep us informed on this and and don't wait until it's a problem. If you see it's starting to happen, you know, something's on the horizon, you've got to you got to come to us and let us know so we can get active on your behalf. So, thank you. >> Thank you, Commissioner Rank. Commissioner Cole, please. >> Thank you, Mr. Chairman. Um, thank you to all the presenters today. Um, it's always a a blessing and a curse to go last. Um, but I think I'm going to try to be additive here in terms of value. Um, and I'll just quickly say, um, add my congrats to Samantha. I think in my comparatively short time at the commission, I think, uh, you and Shane are probably the two most frequent flyers I've encountered. So, uh, uh, hopefully I mean, you're cashing your miles hopefully. Um and um uh I think what Commissioner Weaver forgot to say is that you're always welcome back as well. Um and if it makes you feel any better, um Commissioner Wright is we all share that him as a complex challenge as well. So um Andrew, I'm probably this is probably going to default most of this stuff to you, but we'll see how we go here. Um so the the Radian announcement recently about our accelerated review timeline, that I mean that's great news. There's always, you know, a a there's always a little bit of um nervousness in announcing something like that up front because you got to stick to it. But um staying within the you know uh nonproprietary uh information space here, could you give a little bit of flavor uh you know to us and those listening like what makes a difference in terms of what we receive from an applicant that allows us to set a more accelerated timeline, a schedule? like what are the what are the the the lessons learned here for others to think about as they engage with y'all? >> I'm going to say what you probably already heard, but I can reiterate it. It's early and often communications upfront um so that we have an understanding of what we're going to receive and then really leveraging that communication m we've talked about which sounds simple but what it really means is understanding where the potential issues are early so that we can address those right up front. Um and so pre-application pre-lication pre-application um is really critical. >> What about the quality of information you receive in response to those pre-application questions? Is that an important element as well? >> That is a very important element and it goes back to that communication model. if we're able to in an early uh phase of the project identify that there's an issue where there's not enough information or there's going to be a regulatory framework challenge and then meeting directly with the applicant to talk through options of how that might be addressed. We've been able to do that in um multiple cases and the new communication model facilitates that kind of mutual problem solving solutionbased interactions um that helps us make sure that we get the information that we need right up front. And so given the the working relationship we have with DOE these days in trying to to you know uh do the development and the deployment commercialization and and that symmetry um when we're doing pre-allocation work with entities are we now also helping you know explain the difference between the NRC process and the DOE process particularly if they may be already leveraging the DOE process so they know what to expect going forward. Is that part of those early conversations as well? That is part of the early conversations and we have had cases um not with Radiant but we actually had an issue with BWXT in the fall where they are in in the DOE process and we were able to to intercede questions about how what they were doing impacted the NRC's regulatory requirements and which ones applied versus DOE and we were able to help them work through that. >> Okay. And then in in terms of workload going forward and you'll have to correct me if my math is wrong here but I looks like for fuel facility business line you say you've completed 28 licensing actions since uh May of last year so in about a year 28 and that 14 underway 102 more through 2030. Um and if you add all that together you get about that same average from May 2025 to 2026 20 mid 20s up to 30 per year. Is that accurate? So the um that is accurate in terms of the numbers. I mean what we're seeing is those licensing actions, they're less routine and they're more complex. So where we may have had just a quick amendment before and that would count one of the licensing actions, now we're seeing major new fuel facilities as part of those licensing actions and that's the real difference. >> Yeah. And and so that and then that gets you to your staffing situation and being strategic and thoughtful about being appropriately resourced. um you said somewhere in the presentation that um that you all are quote working to hire in areas where we have less depth in necessary skill sets. Can you give some flavor about what areas or skill sets those are? >> Yes. Um and I'll I'll lean on Shaina, but I mentioned that we're we're doing strategic workforce planning and and what I meant by that is we sat down and looked at a discipline way about what the work is that we expect and what skills are needed to support that work, what our attrition looks like, what retirements might look like. And then we did an assessment to say how many of each type of experts do we have versus what we need. So we did I call I called that strategic workforce planning light because we didn't use some big tool. >> Um but we we did see that we we don't have gaps but we have areas where we may only have like one or two people. >> Um and those areas are uh structural would be number one. Structural engineering is uh where we need to hire. Uh fire protection uh was another area that we um need to hire. and uh project managers um is another area where we need to hire. And so we are we have a list of prioritization for um postings that we'd like to make and um uh staffing actions that we'd like to take and we've put those at the top of the priority list. >> It sounds like under those criteria, we're talking about headquarters and region two placement types. Right. >> That's right. Okay. And a and actually I'd just like to add that, you know, I I really appreciate the help that we've received from a region too because a number of the skill sets that we need reside with our inspection staff and we've been you heard Chad talk about the partnership that we've had where we've been able to leverage not just for uh supporting us on certain uh framework developments, but the construction oversight program um we took the construction oversight experts from the Vogle experience and those were the same staff who helped us with our program. So you know it's it's been tight. This is always the kabuki dance between having the right amount of staffing uh for for the small business line without driving up fees and we've been able to manage so far but looking ahead I I agree with Andrea we're going to have to staff up >> and not just region two but be before we're bringing people into the business line to support we are looking cross agency and um just in the last two months we've been able to bring in uh people from all of the regions um to help support in the licensing area Um, so I don't know much about this area, but it's it it piqued my interest in the conversation today about what's billable and non-billable in terms of the work we do. Um, and I don't want to get into necessarily the semantics of all that today, but it does strike me a little bit, if I follow the conversation correctly, that uh, you know, guidance associated with rulemakings is not direct billable work. I would think that since the licences who pay the bills who need the guidance to implement the rule that that would be direct. Can you give some flavor about what's direct and indirect and billable or or just give me your uh unfettered like how to fix this conundrum because there's clearly some some disconnect here but it doesn't seem like it's rocket science to figure it out. >> Yeah. Um Samantha's actually one of our resident experts on this >> and she's leaving so she let her head like yeah and in my mind um and Samantha fill in the detail direct work is licensing and inspection. It's directly working on a license application or doing an inspection and you're you're correct like guidance development is not it's indirect. So indirect things are things like guidance development, rule making, like I said, training of our staff, all the things that >> it may not be direct to the license, but it's direct to the benefit of the license. And I think that maybe that's the >> and so one of the answers, and I'll let Samantha jump in. One of the ways that this could be solved is to really think about really what is direct work. Yeah. >> Um and being very specific in our budget about how we link the activities to what's direct and indirect. And that is something that we're thinking about. Let me but let me let the expert jump in. >> Yeah. I I think you know we're using the words direct and indirect collocally, right? So the activities that fall under tensf part 170 fees. So those are fee for service. That's what Andrea is referring to as direct work. That is the licensing or inspection work that is of benefit to one um entity. There's other billable work which falls under tens 171 which is referring to as indirect in this case. That's the guidance development rule making allegations enforcement. our OGC support and then there's other work that like Shaina mentioned that is actually indirect and that is our admin, our supervisors, front and utilities, all of our corporate support stuff and that gets spread out across the business line. So there's kind of like three buckets and then also the stuff that falls um as excluded activities off the feebase. >> That's you know as as we look to our budget future maybe Mr. Mr. Chairman, something we have to explore is you know how we build and characterize um you know what falls in what budget buckets and where the money comes from because we may be able to solve some of our issues just by realigning things and redefining things. Um but you know I think there's probably more of a nexus between uh direct work that should be billable than we're necessarily applying right now. So hopefully we can look at that and you know if the results the math comes out where that's going to be unacceptable burden on a small number of licences. We're going to have to figure that out too because it's not fair. So it's just something we got to solve. But these these are solvable things if we be creative and put our efforts to it. So um thank you Mr. Chair. >> Thank thank you Commissioner Cole. I appreciate it. An interesting thought. I appreciate you raising it. So we're concluding this portion of the staff's briefing today. Uh you said it's a small but mighty program. It's a it's a mighty program and it's very important to the work of the agency. I have uh the utmost trust and confidence in your ability to you know lead, innovate and execute this program efficiently and with a strong safety focus. Uh before we close out this session, any final comments from the commissioners? No. Madam Secretary, can you let us know what time we should come back, please? >> Come back at 10:40. >> Okay, 10:40. Thanks. Okay. Well, welcome back everybody. It's 10:40. We're going to continue the second half of this commission briefing and now we're going to focus on spent fuel storage and transportation. Uh Mike, over to you. >> Yep. Good morning again. Uh so the spent fuel storage and transportation business line really forms the backbone of the nuclear fuel cycle. Without safe predictable storage and transportations reactors can't operate reliable reliably and new technologies can't move forward. Our team has done a tre terrific job modernizing the way we approach this work. They're strengthening strengthening technical depth, applying lessons learned, and adapting to new needs, whether it's advanced fuels or transport of micro reactors. In short, we're building the capability we need for the future while keeping our focus exactly where it should be, on safety. Next slide, please. In this next panel, you'll hear how the business line is putting our strategic leadership and operational excellence model into action. That means holding ourselves accountable, building the technical skill sets we need, and continuously adjusting our approaches as we learn more. We're also looking ahead, keeping an eye on new developments and making sure our licensing and oversight processes stay predictable as the technology evolves. Now, let me take a moment to introduce our panels. Uh, Andrea Cook, we'll we'll start with an overview of the business line and how we're preparing for what's next. Cynthia Roman will walk through accomplishments, efficiencies, and our readiness for micro reactor transportation. Georgia Diaz will cover ongoing licensing and how we line up that work with fuel supply needs. And Bill Lynn will share our regional oversight perspective, the trends, training, retention, and how risk insights are improving our fieldwork. Andrea, go ahead. >> Good morning again, Chairman and Commissioners. I appreciate the opportunity to brief you on the spent fuel storage and transportation business line. Next slide, please. This business line does serve an essential function by maintaining safe and timely fuel transport, storage, and disposal. Reactors are able to generate power reliably, upholding the nation's energy stability goals. Here's a scale of what that looks like for us today. We oversee 82 independent spent fuel storage installations in 36 different states. We maintain 98 certified transportation package designs and then about another 50 for international package designs. And in recent years, we reviewed about 80 licensing actions per fiscal year for storage and transportation. And on average, there are between 50 and 100 shipments of spent fuel in this country that are done safely every year. One of our major areas of focus is is new fuels. Uh these advanced fuel types, they're no longer the future. I know I've said in several of these commission meetings where we talked about how we're preparing for these new fuel types. They are here now. They are reshaping the way we're doing work. To date, we've completed more than 30 licensing actions for new fuels since 2018. These are the regulatory decisions that make timely fuel delivery to reactor sites possible. Joy Diaz will discuss some examples of licensing actions that we've completed and how we've delivered on our core mission with accountability in this area. Next slide, please. As noted earlier, accountability and budget execution remains a priority. As you can see on this slide, for this year, the business line was budgeted about 90 FTE and we're currently projecting to execute about 73 FTE or about 81%. This is consistent with other business lines across the agency, but it's not consistent for this business line that executed at 100% last year. There are some factors that contribute to this year's underburn. First, the government shutdown, which was roughly 11% of the year, contributed to this. Secondly, we had fewer submitts so far, about 20% as vendors shifted their priorities. We also had budgeted for a micro reactor package transportation review that did not come to fruition and was delayed. Third, we're carrying vacancies due to staff losses. And lastly, emerging demands in the fuel facilities business line caused us to shift resources to cover licensing work in that business line. I think that's a good news story. And to mitigate this underexecution, we're supplementing our regional inspectors in the regions with staff from headquarters uh to make up inspections that we missed during the shutdown. We're also making adjustments through the implementation plan and mid-year resource reviews that we discussed during the last panel. And even with this underburn, uh we don't expect annual fees to increase for this year uh because overall the fee rule includes a $.3 million annual decrease in the business line due to reduced resources. I do want to acknowledge that budget execution is an area where we can always improve and we're taking proactive steps to do exactly that. In addition to the broader efforts that we talked about this morning, we've invested in building our team's understanding of how their day-to-day work impacts fees and resource execution. For example, last year we trained our staff to reinforce how actions just like accurate time reporting directly impact fees. These steps and our commitment to continuous improvement ensure that we use our resources responsibly, transparently, and in full support of the agency's mission. Next slide, please. The nation's clean energy goals amplify the importance of the back end of the fuel cycle and transportation to support new technologies and the business line is responding boldly. We're accomplishing this by strengthening our processes with clarity, discipline, and shared accountability. In addition to the 15% reduction in schedule and resources we applied last year through implementing licensing efficiencies, we expect to save about 5% or 5 FTE this year through the materials licensing efficiencies process team actions. These are things like early identification of the risks associated with the review that Cynthia will cover in more detail later. We're also proactively aligning our inspection program to meet future needs. Later today, Bill Lynn will provide an overview of the efficiencies achieved through the Advance Act section 507 actions. And when we consider all of the improvements that we've made over the past six years, our efforts have resulted in an overall savings of nearly 18% in resources while maintaining safety. Next slide, please. We are investing heavily in preparing our people for the future. Our technical staff oversee multiple facilities across both business lines, fuel cycle and spent fuel. So cross trainining remains an essential part of our program to maintain capability. These steps ensure we remain agile and and prepared for the advanced fuel landscape ahead. Thank you for your time. I'll now turn the presentation over to Cynthia Roman. >> Good morning, chairman commissioners. Um, today I'm going to be providing you an overview of how we performed last year and how we are preparing for the future, including how we're expecting to license micro reactors. Next slide, please. I'm happy to report that our staff deliver and we are moving faster than ever. Last year, we completed 100% of our licensing actions um within our NEMA metrics of 36 months. As you can see in the graph um when we compare our performance from fiscal year 24 um and 2025 we improve across the board. Most of our licensing actions were completed within 12 months and we also began implementing the new NEMA metrics of 12 and 18 months. While in 2025 we were not there yet. We are moving very quickly in that direction. As you can see in the graph, 94% of our actions were completed in within 18 months and more than half were completed under six months. This is attributed to a few important changes on how we work including using the new EDO guidance for communicating with applicants and improving our risk inform approaches. This is a good a good indication that we're moving to be we're going to be successful in meeting the new NEMA metrics and holding oursel accountable. Next slide, please. As you heard this morning, our landscape is changing. Therefore, it is important to meize the way we do business, including having the right tools, data, and expertise in house. We are looking for opportunities to collaborate with others so we can all benefit from ongoing research. For example, we are working with DOE on criticality benchmark experiments to support halo fuel cycles and transportation. This effort mandated by the energy act of 2020 will generate the data needed to enable the use of halo across the fuel cycle. This data is important because it will help us to be to have more realistic safety margins and to validate our computer codes. Criticality experiments are expensive and there are only a few facilities in the world that can perform them. For the criticality benchmark experiments, DOE is investing about $40 million to build and operate a new critical experiment capability at Idaho National Lab. So, how are we contributing? NRC brings decades of experience in criticality, safety, and licensing. By contributing a modest amount of staff time, we can help ensure this works meets regulatory needs and support the safe deployment of Halo technologies. We're also leveraging international partnerships. And to learn more, Jaya is going to cover that in her remarks. Next slide. Last year we talked about the changes we made under under the advance act for this business line. Now I want to discuss how we're using those changes to update how we operate. A few years ago we created the risk tool to streamline the review of spent fuel storage licensing actions. The tool uses probabilistic risk assessment or P insights to better focus our reviews. We have now updated the risk tool to reflect the efficiencies expected under under the advanced act and to make it more practical for the staff. As part of this update, we created new guidance that uses historical data to estimate the number of hours each review type requires. We then applied a 15% reduction in the number of review hours to reflect the efficiencies we anticipate from imp implementing the act. This slide shows a simplified view of how the guidance works. A low-risk action might not need a confir any confirmatory analysis and only a few rais. So that review might take about 40 to 80 hours. On the other hand, a high-risisk review might need a confirmatory analysis. Therefore, it might need more time. This approach help us to be more consistent, transparent, and efficient. We're also carrying several ideas from the advanced act into the EO14300 rulemakings. Our division support multiple rulemakings including in the area of storage, transportation and waste disposal. And we are looking at changes that can help us expedite our reviews and add flexibility where appropriate. Now I want to spend some of my time or or the rest of my time in one of those roomm part 57 and how it can support the safe transportation of micro reactors. Next slide please. First, I want to start by highlighting some of the transportation aspects we have been considering for micro reactors. It's important to recognize that part 71 testing requirements are intentionally conservative. They were developed to cover roughly 99% of all potential accidents in transportation accidents. For some micro reactors, meeting those tests and conditions might be challenging, not because they are unsafe, but because the designs are different from the packages part 71 was written for. Second, some micro reactors, especially those for emergency response, they might need to move soon after operation. This could mean higher radiation dose rates during transportation. This is why understanding how those rates vary with time, the assumptions surrounding transport, and how it could impact members of the public is important. Third, weight matters. So, micro reactors and their packages are heavy and that can create transportation challenges. Early coordination with federal partners is needed to address those potential challenges. From all this, we can agree that having early clarity on how the micro reactor will be used is key to choosing the best transportation method. For example, will the package be transported domestically versus internationally? What will be the specific mode of transportation? How much pre-operational testing they're planning to do um before transported? All those are important questions. And together these considerations will help us understand the full picture before an application is submitted. Next slide. Now to part 57. Last year I shared that par 71 works well for near-term micro reactor application and that's still true today. However, par 57 gave us the opportunity to add a few targeted improvements that support efficiency and flexibility. Today I'll focus on the main transportation change under part 57 and that is that under the proposed rule applicants could use an NRC endorsed risk methodology that show they meet part 71 both for normal or accident conditions. So how would that work? For example, in 2024 we endorsed the risk methodology for the transportation of product ple. If an applica for a trico based micro reactant meets the same assumptions they could reference the approach without needing an exemption. This year we are reviewing a similar method from PNNL for maritime transport. If we endorse it, applicants could use it under par 57. This keep us from reinventing the wheel. Once we endorse it a strong we endorse a risk methodology others can rely on it, saving time, adding flexibility and giving a clear path while still meeting the safety standards. Next slide please. We are also evaluating how micro reactors are transported at what means for public safety. We are looking at real life situations like a person stuck in traffic or a driver stopping for gas to understand how they it could affect public safety. With the support from PNL, our analysis show that under defined conditions even at higher dose rates public exposures are very very low. And with the help of our office of regulatory research, we have also improved our understanding um of the shielding needed when a reactor is moved soon after operation. This work work help us make safe and well informed decisions. Next slide please. We know that staying engaged is essential. We are having early discussions with applicants and reviewing their technical positions so we can spot transportation issues early in the design process. We're also communicating with the public agreement state travel governments about changes to the transportation requirements. Finally, we're close working closely with the Department of Transportation to make sure our approaches are aligned. In closing, we remain committed to open engagement and to using sound riskinformed approaches for transporting new micro reactor designs. Thank you, and I'll turn it over to Joy Dia. >> Thank you, Cynthia. Uh good morning, chairman and commissioners, and thanks for the opportunity to brief you today. Next slide, please. I'm starting with a simple message. We're keeping the source and transportation licensing work on track even as the workload becomes more complex and more variable. We're doing this with a structured datadriven practices that help us set realistic schedules, manage shifting priorities, and stay aligned across both the the front and the back end of the fuel cycle. Our estimating process isn't guesswork. or use a standardized methods and dashboard built on historical data calibrated to more aggressive NEMA timelines that give us a reliable schedules form the star and real time visibility to rebalance work on or spot issues early. We're seeing clear results in line with the intent of NEMA and the advance act. While the chart shows significant year-to-year swings in incoming storage and transportation case work, recent years show a much better alignment between timely completion and the incoming case work. This has been accomplished despite a staff transitions. Beyond keeping the timeline steady, we're also taking a closer look at the drivers of efficiency and those are related to the risol that has been especially valuable. The risol assessment showed roughly more than 60% drop on rais from prior years driven by clear applications and early engagement despite the case were becoming more complex due to new fuels. Last year over 70% of the reviews met the 90 to 100% of their plan timelines up from the 64 the year prior. We keep this performance going by staying closely engaged with applicants from the start. Regular check-ins, clear RAIS, and early escalation help us spot issues early and avoid rework. And by matching work to staff strengths and bringing contractor support when priorities change, we keep the case work moving without losing rigor. Together, these processes and engagement improvements have cut the level of effort by about 10%. saving roughly a 100 staff hours on a typical review. That's time we can put back into technical work, mentoring, and whatever priority comes next. And this matters because the spent fuel inventory keeps growing. There's more than 4,400 dry storage systems, nearly 2,000 200,000 fuel assemblies, and over 130 certified transport packages. With numbers like this, having a predictable, efficient licensing process isn't just helpful, is essential. Next slide, please. I'd like to highlight several recent achievements that show how our teams are delivering results to maintain momentum and adapt quickly to evolving needs. Over the last several months, our st our teams have advanced a number of actions that really show what strong execution and close coordination can deliver. There aren't abstract process wins. They're things that improve regulatory agility, reduce burden, support national research and security missions. Just a few examples. Last September, we allow applicants to rely on an already approved 10 CFR part 50 quality assurance program for a part 71 design activity before submitting the transportation application. This was the first time we approved that approach and and it let the lences start design work confidently knowing that the QIP the QIP piece was already settled. Right after the government shutdown, we moved quickly to approve an amendment so radioharmaceuticals could be shipped. That change helps medical helps medical products reach patients faster which directly increases the number of cancer treatments available. and we finished that review in just three weeks. In March, we revised the certificate of compliance so DOE in April can move the hibernob research cask from North Anna to Idaho National Lab in 2027. That review came under budget and a month early. Lastly, showing the picture, in June 2025, we completed the Traveler COC review under a year, a transportation package designed to safely transport a wide range of radioactive materials to support national security missions. Next slide, please. We're also using RI insights more strategically to make timely safety focused decisions. Let me share a recent example. review a concrete overpack design that required the concrete to reach a specified strength within a set number of days. The licences test samples didn't meet the strength in time to understand the true condition of the structure. They took core samples from the actual overpack and those samples did meet the requirement but the testing fell outside the approved time frame. So NRC approval was necessary to resolve the issue efficiently while maintaining safety. We approved a more practical code alternative. Instead of requiring the concrete to heat a strength on a specific day, we focus on what really matters. The concrete must meet the required strength before the overpack is used. Early alignment between our technical and legal teams and the use of clarification calls instead of formal supplements kept the process moving. As a result, we completed the review in two months instead of the typical six months, avoiding unnecessary demolition and reconstruction. We also approved the transportation COC for DOE's hibern research task. This will finally give us the real data on how high burnout fuel heats, ages, and performs after long-term dry storage. Data that will directly improve our risk informed reviews and support license renewals beyond beyond 40 years. Earlier this year, we held a risk informed showcase with industry to identify where risinformed methods can provide greatest regulatory benefit. The showcase confirm a strong alignment on the importance of corrosion and aging management areas essential for maintaining safety margins and fully using the flexibilities in the regulatory guide 3.7A the inservice inspection code case for dry storage and of spent fuel. Our sustained focus is paying off. A 2 million multi-year investment in corrosion research has already returned an estimated 40 million in industry savings. and ongoing work from April, including the upcoming gross structure topical report, will provide clearer criteria for evaluating fuel integrity and furthering strengthen the predictability of our reviews. When you put all together, the picture is very clear. Better data and stronger models are making our reviews more predictable, more efficient, a more recent form. Next slide, please. Finally, I want to touch on how we're getting ready for what's next. As Enra noted, we're investing in our people. Our onboarding pairs new staff with experienced reviewers, set clear expectations, and gives them consistent guidance. Even with recent staffing losses, we've kept up with we kept up with the licensing and continue to build technical depth through hands-on reviews, cross trainining, and targeted contractor support. We've also clarify roles and strengthened how we're work together so staff, especially those in transition, get the support they need. And as as fuel shipments grow, we're building more flexibility ac more flexibility across teams. A key enabler is our regular caucuses among project managers, technical staff, and legal. These early conversations let us spot issues quickly and get aligned before decisions hits our desk. A clear example, a recent example was deciding whether a general lences needed an exemption to keep loading. After looking at the issue from all angles, the caucus agreed that the exemption wasn't really needed. And because we are already aligned, we made that call fast. That quick well-coordinated decision now sets a clear expectation going forward. We're also growing knowledge through international engagement and bending embedding junior staff in the IEA transport safety standards committee or trans paired with senior mentors giving them the firsthand exposure to new standards emerging technologies and global challenges and earlier this year picture on this slide the staff presented at the IIA transport conference sharing NRC's approaches on building global connections. Finally, our partnerships and tools keep us future ready working with the office of research provides us with analytical capabilities like trico package reviews and validated criticality reviews that improve efficiency and consistency. And because the storage and transportation and the fuel facility business lines operate as an integrated system, we can align early on package systems, heat loads, criticality controls and material forms so new fuels are truly designed to ship. By coordinating with applicants and federal partners, we help advance fuels more predictably through the fuel cycle, keeping licensing efficient, rising form, and safety focus. This concludes my presentation and now turn it over to Bill. >> Good morning, chairman and commissioners. I'm here today to pro provide the regional perspective on the spin fuel inspection oversight and staff training. These areas are closely linked and central to how we're improving the inspection program. I will first touch on the oversight and then the staff training. Next slide, please. The NRC's focus of protecting public health and safety has not changed, but how we deliver that oversight is becoming smarter and more risk informed. Consistent with the implementation of the previous initiative to enhance the FCC inspection program and the events act we have increased the use of risk informed performance-based approach in spent fuel storage so that we spend time where safety significant is highest as Andrea noted earlier we realize that 18% total reduction in inspection hours including 5% from the events act and 13% reduction from earlier enhance enancement all without sacrificing safety. You see the revised program use a greater approach that emphasize important to safety structure systems and components and bringing operating experiment to inform where and how we inspect. For example, the staff recommended and implemented the changes to the inspection frequency of routine loading campaigns and monitoring operation at SSC from every two years to a trianual frequency. In addition, the staff also eliminated the inspection of non-important to safety pad expansion which do not affect safety function directly. Instead of the inspection will focus more on safety significant activities such as heavy load lifts and important to safety structures as defined by our procedures. Time save does not equate to safety reduce. We're simply being logical and not spending time on low impact not important to safety activity and spending more time where it matters the most. Next slide please. While we have strengthened dispensial oversight program by leveraging risk insight to drive more efficient and effective inspection, we're not stopping there. Our focus now is on continuously improving how we execute the program. A key part of our approach is applying the communication principle outlined in OED 0235 driving regulatory decision through effective communication. By engaging early with domestic stakeholder on emerging issues, we help prevent minor concerns from escalating into matters that demand significant NRC or licency resources. For example, similar to what Jordan had discussed earlier, staff in the reser also proactively work with industry to clarify the feasibility of license exemptions for issues arising from COC holder generated changes under 7248. Through years of conversation with our sites, Spinfield has recognized the need to clarify the regulatory framework. Historically, staff hesitated to pursue adjustment to 7248 because of the lengthy rule making timelines and we instead will attempt to address the regulatory ambiguity through policy inspection guidance changes to address this in a manner consistent with the events act and in support of the agency's strategic leadership and operational excellence goal. The staff developed inter re enforcement policy 9.4 4 enforcement discretion for general license adoptions of certificate of compliance holder generated changes IEP 9.4 clarifies regulatory expectations align enforcement with the party best position to address the issue and provide enforcement discretion while pursue regulatory changes directed by the executive order 14300 along with the IEP 9.4 Four staff had clarified through open and transparent dialogue where corrective action responsibility lies for COC holder initiated changes which reduce unnecessary licensing action requests and enabled the industry to maintain loading schedule without delay. This in turns allowed the NRC staff to focus on higher priority licensing actions. Next slide please. The next topic I want to cover is the regional perspective on staff training. While procedure guidance, it is training that prepares the staff when condition change. Spinfield training program focus on risk significant activity in the field, knowledge management through mentorship and consistent implementation and inspection throughout the program. The inspectors are trained on the expanded use of Vlister as a tool to efficiently manage very low safety significant issues and therefore allowing the inspector to focus on risk significant activities. Currently, we have strong alignment between the program office and the regional inspection staff through our regular counterpart engagement. The alignment will be stronger through the new NRC reorganization proposal where we're aligning the organization to the business line. This will allow targeted coordination of resources, better technical inspection resolution and allow for inspection schedule flexibility. With this increased flexibility, staff will benefit from more balanced workload, which in turn will improve staff retention. Sustaining program effectiveness will require continual investment in training, knowledge management, and succession planning to maintain technical depth and institutional expertise. The program must ensure all new inspectors complete the updated FCC qualification with emphasis on field experience. Expand cost qualification opportunity to increase FCC bench strength and continuously encourage knowledge management between staff during m monthly counterpart meeting through continued training and investment in staff. We're well positioned to meet the revolving challenges and expectation. The organization has embraced new performance measures to keep us accountable. Example of this is the implementation of PI 1.1.3 where we have consistently closed inspection issue with very low to no safety significant within 45 days of the scheduled end of the inspection. To ensure the future success, the program must continue to increase metrics, utili, utilize our enhanced issue resolution guidance, and to ensure that spinfield's training program prepares our staff to rise to the occasion. Thank you very much. I'll turn over to Mike. >> That concludes our remarks on the our overview of the program. Happy to answer any questions you have. >> Thank you for the presentation, Commissioner Marzano. >> Thank you, Mr. chairman and thank you panel for your presentations and everyone who's supported this work. Um during last year's meeting uh I talked about how essential our cooperation in spent fuel management and the transportation of nuclear material is in this environment defined by new use cases like transportable micro reactors and a shifting back-end fuel cycle policy. Um I maintain that we need this unified approach with our partners both across the federal government as well as states and tribes to not only fulfill our responsibility to protect public health, safety and the environment but also instill public confidence as new technologies introduce new challenges in the management of the fuel cycle. The work you do to enable the safe and secure storage and transportation of nuclear materials is very visible to the public uh and directly influences public perception of new nuclear power development. stated more clearly, your work too supports national priorities and helps ensure that the societal benefits of nuclear technologies can be fully realized. So with that, um few questions uh that I'd like to get to, but I'll start by dipping my toe in the budget uh space at my own peril perhaps. Um you know, we talked about this under utilization issue and it seems like there were some, you know, aspects that are kind of beyond the control government shutdown primarily. Um my interest here is with the reorganization, you know, I think the commission intended there to be a somewhat rethinking of the relationship between the program offices and and the in the office of chief financial officer. So um can you talk a little bit about how that effort has maybe revealed some opportunities uh for improvements in how we've managed some of these uh challenges where factors outside of our control may be uh influencing our ability to budget efficiently and effectively. Um and then kind of how these strategies can be applied just agencywide >> for clarification. Your question is how uh the reorganization will help address some of these issues. Yeah. So I think I think it will from a couple different perspectives. Um you know one of the ideas behind the reorganization is moving um resources into the corporate offices so that we centralize decision- making. And what that does is it brings um consistency to the way we're approaching things um and more of a direct um influence or impact of the CFO's office into the programmatic decisions. So they bring I think Shane said during the first panel the CFO's office brings a lot of expertise about what these things mean to us right they this is their expertise and so bringing the resources from the program office into CFO brings that thinking closer to the program office decisions and I think that's a positive thing as well as thinking about you know how did we address that in reactors versus materials and bringing all of that together make sure that we share best practices and we have more consistency in the way we're approaching those things. Yeah, well budget is very visible topic as well and and you know our our best efforts to be good stewards of rateayer and taxpayer dollars is very important. So I appreciate uh the efforts there. Um switching gears uh last week I had a chance to meet with some of the authors of the PNNL uh report on transportable micro reactors. Um, and I think that this is a really great example of how we leverage uh the expertise not just here at the agency but also across the national lab complex uh to support our own riskinformed uh regulatory oversight. Um, so are there any other areas specific to kind of transportation um itself uh where collaboration with national lab partners um is needed or contemplated as expanding? um just talk a little bit more about how you know we we take the efforts that were done here and move forward. >> Yes. Um collaboration with the national labs is going to be key as we address some of the challenges we have with Halo um fuel and what we're trying to address some of the challenges that we have with micro reactors. Right now we are working with Oakidge for example um to address some of the challenges we have in the criticality benchmark um with DOE. Um we also work with others like we work with the center as well just to address some of the aging management issues that we have on storage. Um so we are constantly working with them to address issues as they arise. Um >> yeah because we have this good you know this good work that's done in the microactory space you know the transportation of other materials I think may be uh a good opportunity uh for future work. Um, >> just add like one thing that maybe doesn't get as much discussion, but um, this business line also addresses disposal and I think that's one area where we're ramping up our coordination with Department of Energy given their reconsideration of of how disposal might work in this country. Um, we have resources that can help there. We and we recently had a meeting with them to talk about um, how we might be able to help them work through some of the technical issues and the various options that they're considering. >> Okay. Thank you, Andrew. um you mentioned uh a little bit about a methodology um to demonstrate compliance with part 71 uh through applicants coming in through part 57. Um a lot of that was based on experience with project payle. Um so if an applicant were to come with something kind of new, some alternative um you know how do we how do we address that um given some of the experience uh that we have u but stay within our established um you know metrics and timelines. >> So we need them to come early. We need we need pre-application engagements. We need um if if they are if they're going to need to use a risk infor methodology, they need to come to us and submit that technical paper almost like a topical report type type of approach um so we can review it and make sure that um what they're trying to do complies with the requirements in part 71 and then we can leverage that in future licensing actions. So um we we have a good track record. I think for project pelle we did it in about a little bit over a year and then we have a paper in house that we're trying to do just in nine to 10 months. Um so we think we can review this risk methodology fairly quick and then those can be used to um move forward with the licensing review in a probably in a shorter time period. >> What's kind of the the long pole in terms of the methodology? Is it you know a criticality safety thing? Is it uh I don't know shielding? etc. You know, what what are kind of the big aspects that that drive maybe a little bit more consideration and time? One of the things that I'm interested in as well is, you know, if as we're risk forming how we review uh transportation packages in general, you know, testing these packages is very expensive, very timeconuming. Um where can where, you know, how are we deciding what what would require a test perhaps given the novelty of an approach versus how we can risk inform uh a review? Well, precisely for for those challenges that have been identified um in terms of meeting the testing conditions is that we're allowing the use of the risk infor methodology um for example it's it's not easy to do a 30 ft drop with a micro reactor to demonstrate that it will survive the accident. So um so instead they could use a P approach to demonstrate that they are meeting um the part 17 rent requirements and demonstrate that public doses are still going to be low and the risk is going to be low. Um I think that that's going to be the biggest challenge maybe on micro reactor testing requirements um for accident conditions. Um we also have testing requirements for normal conditions but we haven't heard that being an issue but it could be depending on the weight of the package on on those considerations. So, um I think that in terms of the review, I think it just understanding how they are approaching risk, what accident sequences they are including. They're supposed to include every accident sequence if they're going to have a different approach from what we have in part 71. Um so I don't know if I can say that there's like a something that is going to take us longer, but in terms of it always shielding, always understanding that it's going to maintain criticality margin, it's it's what we pay attention Yeah. Uh just to expand a little bit on what Cynthia said, um we also have a in our regulatory framework the use of a specific exemptions and we had a lot of experience approving a special authorizations under that provision. Um so we can we can definitely leverage some of the technical areas that were discussed during those specific situations. vessel intern vessel internals being moved, shipped. These are overhaul, very heavy overhaul. So, it's not this is not going to be the first time that we're going to look at things like that. We already have been in looking at these type of issues related to accident conditions, especially because these are very heavy packages. >> Thank you. Um and then real quick, we'll stay on you Joa. Um so, high burn of fuel. Uh we have the DOE research cast. Um I imagine uh I think we can all imagine a world in which many more of these high burnup casts are going to be utilized. So um have we do we have anybody that has come to us yet or um are there applicants that uh may be considering um pursuing a a COC for for one of these high burnup casts in the commercial space. So um just to start off that most of the the fuel discharged from reactors today are hibern. So pretty much every COC amendment that we receive or new designs are for that type of fuel. Um so we have about let me see my numbers here 20 COC's that we approved so far for storage and transportation together that is going to be used for hibern fuel. Um so in terms of what the implications we're going to get from or what the results we're going to get from the hiberno research task I think I think all these licences are going to benefit from and specifically because aging management is one of the main contributors to the hibern fuel given that is a different cladding is a higher burn rate so cladding is a particular component that um it needs to have some aging management program in place so the hybrid knob rearch research has that North Anna um has right now is going to be transported and and store it's being extended storage. It's going to give us some real data that we can use that the licences can leverage as well and they have uh conditions right now for aging management. >> Okay, thank you. Um I think that that wraps up my questions but I'll just a plug for Bill. Uh you know we have a focus on on in the reorganization on on how we train uh in the new technical training organization. uh I just encourage you to kind of look for opportunities uh to help cross trainin and develop folks uh to support uh the important inspection work they do. So, thank you for being here and thank you, Mr. Chairman. >> Thank you, Commissioner Marzono. Commissioner Weaver. Thank you, Chairman. So, my last job at NRC the first time around was in spent fuel storage and transportation. So, um >> changed >> um well, I'm going to talk about that actually. So I I'm really glad. So when I was here, we were an EBB, right? So not only were we physically separated, I I think we were culturally separated. Like so to hear you talk about risk informing when I brought that up in 2011 and 12, they're like, we don't do that. Not we don't do that in spinfield. So clearly, you know, we have we have come a long way. Um, and I was really gratified to hear you talking about confirmatory analyses because when I landed in spent fuel, I was, you know, what is this confirmatory analysis thing? Because if if a lency comes in or a certificate holder and they say here's we're using an approved method an approved code within the parameters of the code normally I would expect the NRC staff to say review what was submitted and then at the time in spent fuel it was very typical well we're going to build our own model and see if we can get the same results uh as the as the applicant and that was extremely timeconuming and expensive and so I'm glad to hear that you're riskinforming ing that I would still you know ask you to take a close look at to make sure they're need when you are using them they're truly needed uh to reach your your safety conclusion. Um so a few questions um Andrea you said there were 30 uh licensing actions for related to new fuels. Um I I gather those were for transportation packages. Yeah. So so my question is you know what about the back? How are we going to store these fuels when they come out of the reactors in these new types of fuels? And uh I'm not sure who's best to speak about that. >> I can start and maybe Joda can finish. So um we have looked at are there unique aspects of new fuels that cause us to question if there's some issue we need to pursue in terms of disposal. We we haven't found anything yet. So we we don't see anything in new fuels that would say there's a safety issue or or that we need to kind of rethink um the disposal aspects. That being said, I think that is the one area of of our work where there could be more work to just confirm that. Um because that's a future problem. I think we've spent maybe less time on that to date. Um so it's something that we need to keep in front of mind, but we haven't identified that's uniquely different. Anything uniquely different? Let me just see if Joda has anything to add. >> Um, you probably cover it very well, but um, just to expand uh, what we've been discussing with some of the potential applicants, uh, particularly I think the the hurdles that we had to overcome are more in policy related type of uh, things such as the one-year cool off period that is required for um, for spent fuel, right? So we are looking into that to verify if for these specific technologies that is needed because they are very different in terms of the type of fuel. It's not lightwater reactor anymore. >> Thank you. Um I think you also said there were 50 to 100 shipments of spent fuel and I'm presuming that we're talking about like fuel rods or maybe an assembly. We're not talking about whole cast full of spent fuel are we >> correct. >> Okay. and for to I imagine to support testing and >> to support testing and um not so much for commercial shipments. Um a lot of that I think is for defense or DOE purposes. >> Okay. Um long-term sto so obviously I don't think we're we don't see a geologic repository on the horizon for high level waste. So the isses are going to be it for the foreseeable future. Do we have um are there any challenges that prevent us from you know envisioning fuel casts on is pads for the foreseeable future based on what I know there hasn't there hasn't been an issue what simply happens is that uh facilities build new pads and put more dry storage um those are very safe facilities so um for the foreseeable future we see that as a path forward. Um we did license um consolidated interim storage facilities in this country. Um whether those come to fruition is really a business case. >> Um just to expand on on the technical side, I mentioned the hybrid drycast from North Anna. It's going to get us a lot of data from storage the the performance of the fuel in extended storage. that combined with what other technical areas are looking like aging management that that is the most critical part in extended storage. So far we haven't seen um big issues in that area and uh just to include the waste confidence rule also provides some technical basis on what needs to be under storage what is appropriate for for being under storage. >> Thank you. Um, you mentioned $2 million in research resulting in $40 million in savings. Can you talk more about what what what was the research and how did the sav where do the savings come from? >> Um, I probably have to turn that over to Cynthia. >> So, uh, this is, uh, we we we have been working for years as as you might be aware on corro stress cracking research. Um so we went back and look how much have we spent and we look we spent about $2 million dollar about along the years. Um but we recently were able to um make some conclusions and issue a guidance that reduces the need for inservice inspections. Um and this is saving we anticipate that this is will save $40 million to the industry because then they don't have to do the inservice inspections at the frequencies that they had. So that research really is helping us. We are now expanding that research um to also demonstrate that even if there is an incident in which corrosion stress cracking happens, the consequences are going to be low. So, and we think that based on the preliminary result, that's where we're going to land. And that not only is going to help us to save another $2 million because it's going to help us to then maybe risk inform th those sites that are close to the coast line. Um it will also help us with public confidence. And the question you had before about extended storage, you know, it just shows that the consequences are just low. >> So, you're talking about stress corrosion, cracking of the the steel portion of the canister. Is that what we're Okay. >> Yes. >> Um I was an INL uh last week. It seems like a long time ago already, but uh and I did hear a little bit about their criticality uh experiments research. Apparently, it was very informative that we used to have 10 of these tabletop U machines and now we have zero and they're trying to create one. They were very complimentary of the staff's engagement uh on that and and sought to to continue that support which seems like a good idea to me. Um, I'm going to yield back the balance of my time to the chairman and thank you. >> Thank Thank you very much, Commissioner Weaver. Appreciate the the presentation here and I was recently reading the commission's 1999 white paper on risk informed performance-based regulation. I'll say you guys are doing it. you are uh taking actions to risk inform this program, integrating it with some of the deterministic things that we've historically used in our frameworks, but to to really achieve that vision. So, thank you for doing that. Uh Cynthia, you are the executive sponsor for one of the exec sponsors for part 57, particularly with the transportation aspects. I remember talking to you as I was getting ready to vote on that rule. appreciate your leadership there and you know those elements for this draft rule making that we just published which is a significant milestone for the agency. This is enabling regulation in motion. No pun there with the trans transportation but it's really adapting our frameworks to to new technologies and you I was I was really listening to um the high burnup cask thing and I I know that's part of the department of energy's lightwater reactor sustainability program. What what's different about these casks for high burnup fuel? >> So um the North Anna uh cask particularly um came to us with an amendment uh to in put in instrumentation thermouples to measure the temperature inside of the canister. The main question that we are trying to answer is what is the the performance? How's the fuel doing? what is the performance of the fuel by the time that some of the uh applicants right now or some general licences that already have um canisters on their pads it's going to pass 20 years by the time they transport those canisters. So the importance of that is because hybr knob is high energy fuel. So cladding the type of cladding is different and um the potential of failure of that cladding is the main concern in the storage and particularly when it goes in transportation because we we want to know what is the performance of the fuel when it goes into transport because we were expecting uh largecale transportation campaigns in the >> so do we envision that the storage and transportation canisters that are being used today would essentially be the same ones funs but just potentially accept this higher burnup fuel. >> It's pretty much Yeah, pretty much because as I was saying most of the the fuel that exists in reactors is high burn up and higher enrichments. >> Okay. Okay. Hey, I I was also um thinking about uh accident tolerant fuels, right? That's a significant enabler for long-term operations. And Mike, you said at the beginning this is, you know, kind of the backbone. Hey, if we if the back end doesn't work, you might jam up the front and middle ends. Is there anything else on the back end with accident tolerant fuel or high burnup fuel that we need to be thinking about in our licensing and oversight frameworks? >> I currently I'm not aware of any issues that we have in terms of our ability to um license uh or approve these type of COC's. Um basically we've been getting a lot of research information from EPRI from DOE. We've been working uh together with department of energies particularly uh on the transportation side. We have a very close close connection with them. >> Good. Thank you. Uh Cynthia slide 39. You you gave this chart examples of low lowrisk, medium risk, high risk. Can you tell the commission what what what are some examples of low risk, medium risk, and high-risisk licensing activities? >> I might let Joa start and then since she sees the actions more often. So, um, an example of, uh, if we receive an amendment with a change, um, a changing heat load heat patterns inside of the canister, uh, could be considered as a high um change like a high risk change because that will impact uh, the structural the structural um, configuration uh, the criticality configuration of the of the fuel. So that would be an example of that. Uh a low risk uh change might be uh something simple as changing some specific um clearances of the of the canister that may not translate into ramifications down into other sections like containment is something that we need to protect all the time in the in these canisters. >> And and just maybe to expand something about the risol. So um you can have a review that you have some areas that are high risk under the risk tool and other areas that are low risk. So the technical discipline that you would spend less time on that one maybe you don't need confirmatory analysis that but maybe shielding is higher risk and then you have to do consider whether you need or additional information. So this is used you can have a review that itself um might be high risk but you can also grade that review and have c certain parts of the review be low risk um if that makes sense. Well, thank you. I think it's great that you're, you know, being risk risk informed there. U the next area I want to explore, I I want to say upfront that I do not believe the issue I'm going to raise is indicative of current performance at the NRC. This is a new NRC here, one that's enable one that enables safe use of technologies and one that is risk informed and performance-based. But it's relatively a recent experience that I had was directly impacted by when I was working as an NRC Lency. Cascato and 7248. I know you mentioned it in your slides. Uh the these were uh re real issues that occurred in in the industry that had a significant impact in use fuel loading operations, outage planning. I mean real impacts. And the bewilderment uh from the industry side was that senior officials at the NRC clearly acknowledged there was no safety significance to these issues. yet for well over a year and even bumping up on close to two years uh things really got got jammed up. So I I do not believe that is the agency today. This is a new NRC. But I want to focus on learning. What did we learn from that experience and how are we taking those experiences with CAS NATO and the 7248 issue and and how are we building that into how we do business today? >> Thanks for raising this issue chairman. Uh and I'll start and uh others can jump in. I first of all I couldn't agree more that this was not the agency shining this moment. Um and there's a lot of areas uh to improve from that and we see that opportunity to do so and we've taken action just in that area. I think this is an area in particular where it illustrates the importance of us having a management model where we seek clear leadership alignment and understanding clear expectations. We set high standards and we put accountability mechanisms across the board in that. We've taken a lot of steps as mentioned already to change our culture in that area. But I'll just highlight some of the things that I know we've done in particular. The guidance that we put out on expectations for how you uh deliver results through effective communications has gone a tremendous way across all business lines and helping us to identify issues early and resolve them. Uh the we've also implemented measures in place to hold ourselves accountable. We've got expectations that we resolve low-level inspection issues within 45 days of completing the inspection. That's now been fully implemented across all business lines in the areas of inspections. We're getting regular. We have dashboards and now that where we track our results in that area we have expectations for even in circumstances where we don't agree where we enter our formal differing views process that we we have metrics holding ourselves accountable to how are we doing on resolving those situations openly resolving those issues based on their merits and we've baked in those accountability mechanisms into how we rate our own individual performance. It's a part of our performance appraisal process and so across the board the agency feels accountable for resolving low-level safety issues like this was and doing so in a timely manner commensurate with the significance of the issue with the right amount of resources. >> Yeah. And I'll just add and it kind of relates to the communications model that that Mike mentioned, but I mean at its core, it's asking the risk triplet that's been around since 1999, but actually creating a culture where you ask yourself those questions before you go down the the the path of asking multiple questions. You know, how likely is this actually to happen? What if it did happen? What are the consequences? So the expectation now is that before you start going down an enforcement path that those questions be answered upfront. And the way the communications model helps is setting an expectation that if you have a safety issue, you need to be able to articulate the answer to the risk triplet question of how important is this and what is the risk? Uh and so setting those expectations and then holding ourselves to those expectations. Um, and I'll give Mike credit because not only did we put the Vlistister process in place, um, I think when you were still in NRR, we expanded Vlister to it. So, if you have if there's uncertainty, not just with relate to does this relate to a licensing basis issue, but an inspection issue comes up and you're not sure if it's a compliance issue and it's low risk, it needs to stop there. And um, so we instituted Vlister and then we went one step further and expanded it. >> Thank you very much. It was I know when I was there when we started Vlistister it was hard to to get it to adopt and I'm glad to see you uh using it. Bill, you you said time save does not equate to safety reduced. I I agree with that. I sometimes say it a little bit differently. More inspection does not always mean more safety. Right. Focusing our attention and lences attentions on things that are not safety significant is actually a distracted a distraction that's counterproductive to safe and reliable operations at our our nuclear facilities that we license. So, thank you for your work. Uh, Commissioner Wright, >> thank you, Chair. Um, I'm going to come back to the cast thing real quick. Um, because that's not the only area that we we had very low safety significant issues and we got spun up, right? And and it was very costly. How are you, how is the office of general counsel, their advice, how is that adapted to the new way of doing business in this particular situation that was raised? How has that been looked at differently? Can y'all speak to that? >> Well, I'll just share my perspective. I I think uh you know over the past couple years in particular the the the relationship between program offices and the general counsel's office has become much tighter and integrated. In fact, as part of the reorganization, um we're having uh a key representative from OGC kind of working more exclusively with each program office. So there's a a key point of contact uh you know colllocated with in the in the vicinity of the office director has an office nearby um to kind of increase that level of partnership and engagement across the board. Um we're also pulling uh general counsel's office and attorneys in early into all aspects of what we're doing. we're we're in, you know, any licensing actions, activities that are significant and to help offset some of that burden, the routine actions that we don't necessarily need OGC support on, we've worked with them and they've said we don't need to be involved in those to free them up to really engage heavily on issues where there is some media issue where we need their early engagement insights on. >> Yeah. And now I I can probably I just said this earlier this week like I'm seeing solutionsbased advice from OGC on multiple issues like I can name three or four in the last couple weeks. You know the issue of pre-construction for fuel facilities. We have issues um in in decommissioning and we're moving away from a prescriptive interpretation of what the regulations say to what makes sense from a safety perspective. And so from a legal perspective, you know, you don't need to focus on the exact prescriptive words as long as we're maintaining safety and OGC is completely on board with that and I'm I'm very impressed. So, thank you. >> Yeah, I I brought you up. Do you want to say anything at all about that? >> Thank you, Commissioner. Thank you for uh that feedback. We're continuing to get the OGC solutionoriented. Options are great, but we really want to drive um solutions as long as the staff can make a defensible safety and security case. The law has got a lot of degrees of freedom and we want to make sure we get um the licences and the applications across the finish line and to support our enablement mission. Thanks. >> Thank you. I just thought that was important to bring up because I have noticed it myself. So um so the high burnup cask issue are how is um AI being used potentially right you got a 20-year you know thing you're looking at is AI being used at all looking at that >> I can start and I think Ja has some specific examples um so we're using it in like simple ways you know meeting summaries we don't we don't write those anymore AI is doing that for so just process stuff you know helping a great deal. But we are exploring how to use it in licensing actions um by doing things like scanning the application to tell us like where in the application are certain things addressed so we can go right to there and focus our efforts. Um we're developing that and I think I think there's more work to do as the AI tools get more and more sophisticated. Um but we are we are using it in several licensing actions and exploring how we can build on it and Joya probably has some specific examples. Um yes uh specifically for for the hibernob um research cast that's a DOE every um effort. Um but the way that the the staff can use AI is looking at the having a repository like a compendium of all the potential technical issues that are driving the safety significance of transporting and storing uh the cask uh particularly the hibernal fuel. >> Okay. Thank you. Um, and my last question, Bill, I'm gonna come to you. Um, so I appreciate what what you you you spoke about saving, you know, the 18% reduction and um and inspection hours with no impact on safety, right? And that's a that's a saving of resources at every level, which I think is important. So as you continue to um refine this approach, are there specific indicators uh feedback mechanisms or uh lessons learned that it's going to help you guide the future on this? >> Yes sir. Thank you for the question. What I'll say is we continue continuously to selfassess to make sure that we're realizing the sa the uh efficiency that we projected. Uh we're also in constant communication with our sites. So that way we we clearly state our expectation and they provides us with feedbacks on what they have questions about those type of issues. And I think third is we in the SSC branch we have very strong alignment between the regional staff and the program office. So a lot of time we have a lot of staff interaction to say hey what efficiency can we gain what what can we live with. So I think those are the big picture items that how we're able to like chairman said not the one oneoff type we're cont continuously to try to learn and improve on how we do the inspection program. And I'll just add uh across all our programs, not just specific program, um as we're making these adjustments to the program as part of the advanced act and executive order responses, we're really focusing on monitoring performance of of those program changes the on licences that are in their performance. If we see degrading trends in performance on the part of the licenses, these are all living programs. If we feel like we need to increase in those areas as a result of an unexpected decrease in licency performance, we will not hesitate to do so. >> Okay. Thank you so much, Mr. Chairman. Thank you. Back. >> Thank you, Mr. Chairman. I'll try to do this in 10 minutes and not steal Dave's three that he left on the table. Um, thank you all for the presentations. Very helpful, very appreciative. Lots of questions and helpful um information provided. Uh, I'll say uh for my uh typical moment of levity, I'll check Netflix tonight for uh Cascanato. I'm not I'm not I'm not familiar with that story, but I'm uh definitely going to look into it now. Um I hope Samuel Jackson stars in it. Um so most of my questions be part 57 focused for the most part, but they'll bleed into other areas. And I just want to take a step back for a second because um when we're talking about spent fuel or use fuel management in the context of micro reactors, it's different than we've talked about it in the context of the operating fleet. Um and you know, perhaps there's some differences with fuel types and burnup rates, but it sounds like there's a lot of uniformity in that as well. Um, I worry a little bit that we're moving quicker on part 57 from a rule making regulatory standpoint than we have the information to support the parameters that we're going to put in that rule. Like some of this information that we need from the national labs about um, you know, doses or transportation uh, accident scenarios and things like that. I I think we're we're doing a lot of guessing and hoping here and I don't know if that's accurate or if we're going to fill in the blanks if there's a process for that. Um, I'll say that, um, if what I just characterized, I want to be wrong about what I just characterized either now or down the road. So, I look forward to that to that confidence. Um, but why is it different? Why do we treat micros different than um the operating fleet in terms of uh spent fuel and how long it stays on site and and why and then when it can go and where it goes. So part 57 um so first I want to say we did move fast with par 57 but we had years of of been working on micro reactors since 2020 staff have been developing papers looking at information there was a lot of work that was done before we started the micro reactor rule making um we did form a really great team to work on this role um we had staff across the agency See the the number that Duke gave me is probably a 100 staff members have touched this rule because we we are trying to make sure that safety is maintained but we're also trying to add flexibilities where where it makes sense. >> Yeah. And I get the I get the philosophy but but so just tell me for example why does why wouldn't we require one year cooling period for uh use fuel at a micro reactor site when we do that for other reactors if like why why wouldn't we do that from a safety and security perspective which is our focus. What's the what's the rationale? >> Well, the challenge that we face ourselves is that we are asking the same question of why we couldn't. So, we when we started looking at the 10 milligram per hour for example and again we haven't made that change in the rule that's outside of the micro reactor rule >> that that um when we look at that number and we were trying to look at where that number came from and what data we had to kind of justify the dose. Yes, we had um good research that explained that 10 milligrams is safe, but we didn't have data to determine if we could go up and if that number would still be safe. So, we just wanted to do that research to try to understand, okay, what happens if the dose rate goes up? Is this still safe? Um and and that's when we worked with PNNO and we determined that even if we go up maybe five times over of what the current limit is, members of the public still be protected and the doses are going to be very low. So we just wanted to answer that question in terms of of that specific change. I don't know if you >> Yeah, great answer. I think probably the additional perspective I'd add is there's entry constraints into part 57 that are are much tighter than than others. And that's because of that and the potential for exposure to the public and lower risk associated with these meeting that entry criteria. It deserves attention into what what other areas could you potentially take a different approach to account for the lower potential. >> What do you mean by entry criteria? I'm not sure I follow >> like the uh >> like one you >> so so before we started even envisioning the rule we came up with an entry criteria to make sure is when we call entry criteria is who can use the rule you first need to demonstrate that you're not going to exceed one realm at the boundary in their under accident conditions. um if you meet that also and if your reactor doesn't have um a certain mass limit over 10 metric tons um and also if you meet about six um attributes that are like things about making sure that the reactor is safe you cannot use the rule you have to meet all those conditions to be able to use par 57 when we establish those principles or those entry that entry criteria that really helped the team to then decide okay if I if the reactor doesn't have this concern concern because it's going to have excessive heat. Where can I increase flexibility? So, the entry criteria was really key for why par 57 allows us to do a little bit more flexibility and ensure safety. >> Yeah, I understand. I I understand better now at least. Um, and I just to clarify my my particular interest in this topic is it's mostly relates to the transportation issues to and from and the safety and security and public health associated. think that onsite be at a micro reactor or a large light water reactor, we're pretty good at managing things on site. Um we kind of know uh storage for the time being. Um although I want to ask you more about what you meant by disposal a second ago. Um uh it's so it's the transportation of potentially hotter fuels uh more often to more places that has me concerned at at a higher dose potentially higher dose level in terms of what we've set for for public health and safety and from what I gathered your uh casks aren't necessarily changing but our ability to monitor what's going on inside the cask is the is what's novel and telling and is that data that hopefully will drive our decisions about when something is appropriate to be moved or it's how it's stored or how much it needs to cool off. Is that correct? >> Yeah, the the research coming from the DOER is going to be very telling. Um as I mentioned, aging management is a key factor of of the fuel, right? Fuel cladding. Um there are provisions in the regulations to allow for failure of cladding. uh they can do uh repackaging and that completely will satisfy the regulations for 71. Uh so not necessarily because the information from the air DOE is going to show that there may be some cladding failure. We we don't know yet but we have other alternatives in the regulation that allow for maintaining safety of these uh canisters. I I know we'll do this, but I we need to I want to get the assurance and I know the public wants the assurance that in a world where we have deployment of micro reactors that when a given micro reactor needs to be refueled so to speak that when the current unit goes back to the manufacturing facility presumably that that unit with used fuel in it I guess or assoc or have maybe been transported with used fuel I I don't know how it's all going to work, but when it goes halfway back across the country, you know, um do the communities have anything to worry about that it's going to be going through in terms of dose or accidents that's different from what we've our protocols now and the engagement we've had with those folks. Do they need to prepare for anything different? Is is it you know is accident scenarios different? All that stuff needs to be sorted out and managed on the front end. Does that make sense? >> Yeah. And I just want to add that um we have a lot of engagement with um with stakeholders uh formally u establish uh forums. We have engagements with the tribes uh through DOE. So we have Tentrek is one of the conferences that we attend. So we we need to collect information from these communities which they are very vocal in terms of transportation uh um uh safety. We will definitely take that into account and ensure that they understand what the NRC is trying to accomplish and we can get their concerns and maybe modify, you know, certain things uh in our regulations. But I just want to make sure that that it is coming across that we are having a lot of engagement with the with with these communities, the DOE, Department of Transportation as well. But we're engaging and we're getting answers that we're able to leverage and use for our own purposes. >> Can maybe can I add also some of the research that the the the office of research has helped us also to understand what happens in terms of how much waiting time you need to cool a reactor and things like that. Just waiting three months could make a big difference. So like the reason >> but it's all relative is you could still have a long way to go before it's safe even though you have a big drop in three months. Well, and and and what I want wanted to add is to like not every micro reactor they are going to want to transport right after. We were considering this also for emergency um you know like response type of micro reactors if they need to move soon after. It's is is the only case that I've heard. >> I just want to make sure we're not letting economics or cost concerns drive our policy decisions in terms of how long we require things to cool off or be before they can be stored and moved. And we cannot do that and we won't and safety will remain our northstar. I'll just say at a high level, you know, what we're doing. So micro reactor, some of them they will be transported with used fuel, right? And so the the the model for what is needed for the benefit to be obtained from the micro reactor is different. And so that's why we're looking at things like the cooling off period, but we're using our knowledge um like some of those micro reactors, we use TISO fuel. Tryof fuel is not new. Like like Cynthia said, we have a lot of experience about how these fuels behave and we're using that knowledge with what we're getting from the labs to make decisions that here's where the line in the sand is with regard to safety. That's what we've put out there in the rule is the the part 57 rule. That's what will be in the part 71 rule that comes out and we're going to seeking input from stakeholders. So if there's something that we missed, we're hopeful that it'll come up. But we're using the experience that we had in transportation to date to inform the safety decisions that we're making and and we will we will not compromise on the safety question. >> Commissioner Wright's time here really quickly. Um do we expect um uh yeah I owe like four lunches, trust me. Um, >> do we expect the existing operating fleet to request changes in their fuel, storage, management, transportation based on whatever happens when part 57 is out there and oper and and on the books? >> I sort of doubt that because it's a triedand-true system and um I mean those flex what we're trying to do is create those flexibilities if they so choose. um but it cost them time and money to change the way that they're doing things and so I would guess that we won't see a huge shift with regard to the operating fleet. and I'll just add you know early on when we were considering possible changes uh to transporting limits associated with transporting you know we challenged ourselves what could be the possible cases which could apply this new flexibility and that's why we engaged the labs to ensure hey what were the original assumptions behind the current regulatory limits for exposure for transportation and we discovered some things that were kind of surprising to us the original limit and some of this could have wasn't based on a safety issue at all. It's based on exposing film that would have been in the cab of the original transportation. So those sorts of discoveries helped us to kind of do a groundup evaluation. What's safe for these regardless of who use it, whether it's micro reactors or anybody else. >> And I appreciate you mentioning that because that's exactly the kind of stuff we're going to have to articulate when we make these changes so folks understand that we haven't lost focus of our safety and security mission. >> Right. Thanks. >> Thank you, Commissioner Croll. I'd like a lunch, too. Sometimes >> you're the boss anytime. >> This is this was a a really great great meeting. The presentation material from your panel and the previous panel as well as a dialogue with the commission I think really underscores for me that our focus is safety. Right. That that has not changed. But what this discussion this morning I think also conveys is that we we the NRC are really delivering to America what it needs as technologies evolves, as use cases change. Right? Our mission is to enable safe and secure use of new tech nuclear technologies and we're aligning regulations with actual risks and operational needs. We're u adapting our frameworks for new technologies and we're adding regulatory flexibility where safety is maintained. So I I really congratulate you all on on your accomplishments. Please continue the the good work. Uh before we adjourn, any final comments from members of the commission? Okay. Thank you. End of meeting.