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Rroar March 5 Public Meeting Transcript
ML20070K132
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Issue date: 03/05/2020
From: Andrew Carrera
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Carrera A
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NRC-0840
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Retrospective Review of Administrative Requirements Category 3 Public Meeting Docket Number:

(n/a)

Location:

Rockville, Maryland Date:

Thursday, March 5, 2020 Work Order No.:

NRC-0840 Pages 1-62 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES NUCLEAR REGULATORY COMMISSION

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RETROSPECTIVE REVIEW OF ADMINISTRATIVE REQUIREMENTS

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CATEGORY 3 PUBLIC MEETING

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THURSDAY MARCH 5, 2020

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The Category 3 Meeting met at the U.S.

Nuclear Regulatory Commission, 11545 Rockville Pike, Room 06D02, Rockville, Maryland, at 9:00 a.m, Daniel Mussatti, facilitator, presiding.

NRC PRESENT DANIEL MUSSATTI, NMSS, Facilitator CINDY BLADEY, NMSS ILKA BERRIOS, NMSS*

JUNE CAI, NMSS JASON CARNEAL, NRR*

ANDREW CARRERA, NMSS JOE COLACCINO, NRR VANESSA COX, NMSS*

DAVE CULLISON, OCIO

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 ANTHONY DE JESUS, NSIR ROB KUNTZ, NRR MARK LOHRMANN, ADM*

CATHERINE NOLAN, NSIR PAMELA NOTO, NMSS FRED SCHOFER, NMSS*

JOHN TAPPERT, NMSS GEORGE WANG, NRR INDUSTRY PRESENT JUSTIN WEARNE, NEI STEVE CATRON, NextEra Energy*

DANIEL CRONIN, University of Florida*

DAVID GULLOTT, Exelon MARTIN PHALEN*

ROBIN RITZMAN, Curtiss-Wright*

JANET SCHLUETER, NEI JIM SLIDER, NEI EDGAR SPRINGER*

AMANDA SPALDING, Westinghouse*

  • present via teleconference

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 C-O-N-T-E-N-T-S Page Introduction and opening remarks...................4 Objectives and scope...............................5 Background.........................................6 Retrospective review of administrative requirements (RROAR) strategy...................18 Question and answer...............................25 Introductions.....................................33 Discussion of evaluation criteria.................35 Question and answer...............................52 Closing Remarks...................................60 Adjourn...........................................62

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P-R-O-C-E-E-D-I-N-G-S (9:02 a.m.)

MR. MUSSATTI: Well, good morning, everyone. Let's get started. My name is Daniel Mussatti from the NRC's Facilitator Corps, and I want to welcome all of you to the Office of Nuclear Materials Safety and Safeguards Category 3 Public Meeting for the retrospective review of administrative requirements.

Our purpose here is to hear your concerns and recommendations with regard to our regulatory program. Pam, Andrew, would you like to introduce yourselves very quickly as the leaders of this?

MR. CARRERA: Yes. Good morning. My name is Andy Carrera. I am one of the leads for this initiative along with Pamela Noto.

MS. NOTO: Well, hi, I'm Pam Noto, and I am also a lead for this project.

MR.

MUSSATTI:

And our other distinguished person in the room here is our deputy or --

MR. TAPPERT: I am the Director.

MR. MUSSATTI: Okay, our Director, and a fine person he is, since he is my boss, and that would be Mr. John Tappert.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. TAPPERT: So --

MR. MUSSATTI: Yes, go ahead.

MR. TAPPERT: No, I just wanted to say welcome and thank you for participating in this meeting. This is an important effort for us. It really had its origins back in the Executive Order that was signed in the early days of the Administration.

Now we are very pleased that we are now at the point where we are seeking stakeholder input, you know, to help us move forward and, as you know, we are looking to identify administrative requirements that are redundant or outdated, that aren't adding significant value and are imposing unnecessary regulatory burden.

And that will give us the opportunity to kind of prune the regulatory framework to make it more efficient and effective and that's kind of part of our larger effort to ensure that the NRC is a modern risk-informed regulator and we are doing our work as efficiently and effectively going forward.

As you know we have issued a Federal Register Notice last month seeking stakeholder input and that closes I believe April 6th and, obviously, this meeting is part of that effort, so we greatly

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 appreciate the stakeholder input.

We are also looking internally to identify these opportunities as well, but certainly the people who are providing that information are in an excellent position I think to help us go forward.

So, again, thank you and I hope you have a productive meeting.

MR. MUSSATTI: All right, thanks, John.

I am going to be serving as your facilitator for today's meeting and my role here is to make sure that the meeting is informative and that it is on time.

And we have about 2-1/2 hours to take care of our business and we've got a lot to do so let me get started with a few ground rules as to how we are going to operate and then we can get right on into it.

With regard to getting around in the building, if you are a visitor you are our prisoner right now. You are welcome in this room, but unless you leave this room with an NRC escort we're doing something that is against the rules.

So if you have to go outside to take a call, if you have to go outside to take nature's call, whatever it is that you think you might leave the room for you have to grab one of us that's got one of

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 these badges on that look an awful lot like this.

We've all got them and we're all ready, willing, and able to escort you outside and, you know, make your needs fulfilled.

If we are asked to evacuate the building what I would like to have you do is not jump around scream and shout and yell and holler, calmly go to the staircase.

Follow the people that are in the hallways that will be your guides as far as where the staircases are. When we go outside I think you are familiar enough with Rockville to know that there is a parking lot right to the -- Is that south or north for the pet store?

MS. NOTO: South.

MR. MUSSATTI: South. Right to the south of us on 355 if you cross our little driveway that is normally blocked off and you are in their parking lot, if we go over there and gather that's what I would like us to all do.

Don't go wandering away, run across the street to get a cup of coffee at Dunkin' Donuts or anything else like that because we need to count your heads to make sure that you got out of the building, which reminds me, if you have not signed in on the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 sign-up sheet back there, that's our roll call roster to make sure that you actually got out of the building and if you've wandered off and we call your name somebody's got to come back in the building to find you and I don't want to do that, so please follow the directions, make sure we know where you are.

If you are an NRC person please come with us anyway and we'll make sure that we get your people notified as to exactly where you are so that they are not looking for you.

Okay. Like I said there are sign-in sheets by the door for everybody that's in the room.

For anybody that's on the phone the way that you sign in is to send an email to Pam that gives us your information so that we know that we can add you to the roster.

Her information is on the bottom of the first page of the announcement that you saw online at the nrc.gov that told you all about this meeting in the first place.

This is a Category 3 meeting which is designed to accommodate technical changes, comments from the public, and open houses, these sorts of things where there is a feedback back and forth between the industry with public, any stakeholders,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and with us.

The general format will be this, we are going to start with some opening remarks, there is going to be a presentation, and then a period for questions and answers, then there will be another presentation followed by a period for questions and answers, and, finally, which was not on the original agenda, we are going to wind up with the tail end of the meeting being taken by NRI. They have a -- Did I say NRI?

MS. NOTO: Yes.

MR. MUSSATTI: NEI, I'm sorry. NEI is going to give us a presentation right towards the end and then we will adjourn hopefully on time because there are other people that are going to want this room and they need time to get set up as well.

This meeting is provided for external participants on Skype. If you are on Skype you are more than welcome to watch the slides that are on there, but, please, we advise you to not use the Skype audio to listen to the meeting.

You should really be taking the NRC's bridge line as your audio input because Skype has got a narrow bandwidth and if we are trying to get video and audio in two directions at one time it can really

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 slow down things.

So if you'd just watch the video itself, or watch the slides go by themselves and listen on a separate system, our telephone line, that works the best.

If you are on Skype audio feed now you need to take a moment and call this in. Grab a pencil and paper, I'll count to five, and then I'll give you that number so you can call in.

Okay, the number is 1-888-566-1535.

Once again, 1-888-566-1535, and when you get there it's going to ask you for a passcode. That passcode is 3254942, 3254942.

So take a moment there while we are continuing on with this housekeeping business and please sign in by telephone and break the connection for your audio Skype.

For people in the room we ask that if you've got something electronic with you that buzzes, beeps, walks, squeaks, does any sort of noise making, that you please shut it off.

There are a number of us in the NRC and a number of us in the public that have a reason why we can't shut off our phones. At the NRC often it's emergency related, in case something happens we've

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 got people that are, they are special, they get to go into the control room and they get to do all that cool stuff, but they've got to be in contact 24/7 so they can't shut their phone off.

We have people that have got family illnesses and/or people that have got family issues, kids in school that we need to make sure that things are going right.

If you have a personal need or an occupational need to leave your phone on please put it on vibrate and if it starts to jingle pop up, grab an NRC escort, and please get out of this room entirely before you start talking to minimize the amount of disturbance we have in the room.

And the reason I am asking for this minimum amount of disturbance is that we have a court reporter here. His name is Sam Wojack. He is right up here in the front, the guy with the headset on.

He is going to be making a transcript of this whole thing for us and to minimize the background noise, minimize the crosstalk, which gets confusing and we have to put in parentheses "garbled" on our transcript, we ask that you minimize your disruption of the meeting when you leave for any reason at all.

To ensure a clean transcript when you are

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 speaking we need you to speak slowly and clearly into the nearest microphone, which probably means you are going to have to come forward because the microphones are all here at this desk. These green glowing disks are all microphones.

When you want to speak just queue up and I will point to you to indicate that it is your turn.

We can have one queue on either side that I can go back and forth, and occasionally I will be going back to Tara on the phone and asking her to bring people into line.

But when you get up to the phone when you speak I'd like to have you start with your name and your affiliation. Even if you spoke before please do so because it will make it easier for our court reporter and for the transcript.

And if your name is really hard to understand or it's one of those really cool foreign names that's more alphabet than it is syllables then please spell that out slowly for Sam to make it easier for him. Sam, for the record, my last name is spelled M-U-S-S-A-T-T-I.

Okay. For the folks on the phone you will be participating through our operator, Tara, and I will be asking her periodically whether we have

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 anyone on the phone who would like to speak, so please be patient.

If you are on the phone you will have that opportunity. Tara, could you please take a moment and explain to everybody on the phone how it is that they get into the queue to speak and anything else that is pertinent?

OPERATOR: Thank you. If you would like to ask a question or make a statement on the phone please press star one and record your name into the system as we will need your name in order to introduce you.

Again, if you would like to ask a question or make a comment please press star one. If somebody asks the question that you had already please press start two to remove yourself from the queue.

MR. MUSSATTI: Okay. Just out of curiosity, Tara, how many people are online now?

OPERATOR: Currently we have 14 in the room.

MR. MUSSATTI: That's very good. Thank you, I really appreciate your help. Again, we want a clean transcript for this meeting so be sure to speak clearly into your telephone or into your

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 microphone, whichever it is, starting with your name and your affiliation.

A couple of last things, I'd like to manage this meeting with a little bit less formality than Robert's Rules of Order. We have all been through this a lot of times before, we know how to do this and be adults about it, so just some basic rules here and we'll be as casual as we possibly can to get this information across at the same time, one speaker at a time, limit your comments to three minutes or less if at all possible.

If you ask a question stay near the microphones and if the question isn't answered to your satisfaction just raise your finger to me, index finger to me, and I will know that you would like to have a follow-up question, but if we have a question followed by a follow-up, followed by another follow-up, that's called a conversation and we don't want to do that here.

We want to cover as much ground as possible and give everyone a chance to speak, especially those that are from outside that have come a distance to be able to be here, so try to limit that.

If we don't have anybody speaking and we

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 are towards the end of the meeting you will have an opportunity to get that question and then, if not, after the meeting tackle them as they are trying to leave the room and ask them the question then.

I had one more pertinent thing about asking questions. I will remember it about an hour and a half from now. Okay. Especially for the people that are online that may not be used to doing this, please be respectful of the opinions of others, no ad hominem comments.

Let's try to stay as non-aggressive as possible when we are talking about things, and we want to stay on topic. This is not an opportunity to talk about things that are not pertinent to the issue that is, you know, the topic of the day, the retrospective review of administrative requirements.

We appreciate your interest in what we are doing here, but we want to stay on topic as much as possible. For NRC staff -- Yes, this is the point I was trying to get at that I had forgotten. For NRC staff attending we have the opportunity in the hallway to buttonhole somebody that is also in the staff and ask them a question any time.

Some people that have come to these meetings from the public and from industry travel a

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 long distance to get here, take time out of their days away from other meetings and everything like that, and we really appreciate your having done that and to that point I would like to ask the NRC staff if you have a question, if it's technical, kind of grassroots-y, or in the weeds-y kind of thing, or if it's something that could be handled later on please refrain from asking your questions right away.

If we have a lull in the conversation later on, yes, then by all means help me fill the gap in there with a question that you ask, but let's let our guests have an opportunity first before we start asking our own questions.

Okay. Last point, and this is rather important, these green disks, the disks up here with the green ring on them are microphones. They are always hot.

We do not want to have an opportunity to do something crazy like several of our past Presidents have done with the hot mic moments that become, you know, instant sensations.

If you are planning on talking with a compatriot for the NRC on any regulatory issues for industry on anything that might be considered confidential information or anything like that please

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 realize that these microphones are hot and you are not exactly in a private conversation.

Please take your conversations away from the table. Since we are not having breaks at this meeting anyway if you are having a conversation you are interrupting the meeting and you need to take it outside anyway.

Especially those of you that are seated at the front table that's going to be a big deal because you are right on top of those microphones and when somebody comes up to speak if we could just spread to give them a little bit of room to get there.

Okay, for industry and the public if you have any safety concerns please bring them up separate from this meeting. This is not what the meeting is for.

You can get together with an NRC employee privately after the conference. You can go on our website and you can get those sort of issues taken care of there.

And the NRC will not be talking about anything for which they are promising -- what are the words I am looking for? We are not going to be talking about anything policy oriented or towards any of our regulations that can be termed as binding.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 This is an information-seeking meeting. Do we have any questions?

Okay. As you can see from the agenda we've got a lot of information to cover and a short length of time to do it and so at this time I would like to ask --

(Off microphone comment.)

MR. MUSSATTI: Yes, I think -- yes, you're right. So I am going to ask Andrew to take over the meeting here and make the first presentation.

MR. CARRERA: Okay, great. Thank you, Dan. Good morning, everyone. My name is Andy Carrera, C-A-R-R-E-R-A, and I would like to thank you for attending this meeting on the retrospective review of administrative requirements initiative, or I will call it the RROAR initiative from now on.

I do apologize by the way the room is set up. I like to make eye contact as I am giving presentations and I'll try to do that as much as I can.

The purpose, as Dan mentioned, of today's meeting is to discuss the NRC's request for stakeholders input on outdated or duplicative administrative requirements that could be potentially

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 modified or eliminated.

I believe John mentioned earlier that the NRC issued this request in a Federal Register Notice that was published on February 4, 2020, and the reference number for the Notice is 85 FR 6103 and I will refer to this document as the February 2020 Notice going forward.

So what administrative regulations are we talking about? For the purpose of the RROAR initiative the administrative regulations are those that impose recordkeeping or reporting requirements that address areas of the Agency's organization, procedure, or practice.

Slide 3, please. The agenda for today, just to give another round of that, is the meeting will include to segments of discussions. The first segment I will focus on the RROAR initiative process and the second segment I will focus on the evaluation criteria, including its purpose, application, an example, and with opportunities for attendees to ask clarifying questions at the end of each segment to inform your written comments, and please note that the NRC will only accept written comments on the docket.

Dan mentioned a little bit earlier we had

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 added one new item to the agenda. NEI has prepared a presentation on this topic and we allowed time at the end of the NRC staff's presentation for an NEI representative to present NEI's point of view.

Slide 5, please. Moving into the objective and scope of the RROAR initiative we are hoping to gain several benefits from this review.

The review will optimize the administration of certain regulated activities without impact to public health, safety, common defense and security, and professional environment.

The review will also ensure the Agency administrative requirements remain current, up to date, and effective while reducing burdens to the regulated entities and the NRC.

Slide Number 6, please. By way of background, in August of 2017 the NRC issued a press release to announce that the Agency is initiating a retrospective review of administrative regulations to identify those that are outdated or duplicative beginning in the Fall of 2017.

Now the NRC staff developed and submitted an implementation strategy, or implementation plan, for the RROAR initiative to the Commission for review and approval and that was done in SECY-17-0119.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And the RROAR initiative implementation strategy proposed by the NRC staff included seven steps and four draft evaluation criteria and in staff requirements memorandum to SECY-17-0119 the Commission approved and endorsed the staff's implementation strategy.

Additionally, the Commission directed the staff to submit the final evaluation criteria with consideration of public input for its review and approval.

Slide Number 7, please. Based on Commission direction and in May of 2018 the NRC published a Federal Register Notice seeking public comment on the draft criteria the NRC would use to evaluate potential changes to administrative regulations under the RROAR initiative.

And the reference number for the Notice is 83 FR 19464 and I will refer to this document as the May 2018 Notice. The May 2018 Notice also discussed the process the NRC would use to conduct the review of the administrative requirements and during the public comment period for the May 2018 Notice the NRC also conducted a public meeting to discuss the RROAR initiative and the draft evaluation criteria.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Next slide, Number 8, please. The staff considered public comments in the final evaluation criteria which were provided to the Commission for review and approval in COMSECY-18-0027. of this COMSECY described the changes to the evaluation criteria that resulted from public comments. In October of last year the Commission approved the staff's recommended evaluation criteria.

Slide Number 9, please. The first step of the RROAR initiative implementation strategy began with the development of the evaluation criteria to be used in the review which is now completed with the five Commission approved final evaluation criteria.

So now we are in the data gathering phase of the RROAR initiative where we request input from internal NRC staff, licensees, and members of the

public, as well as conducting historical correspondence search for ideas that may be applicable to support the RROAR initiative.

This meeting and the next planned March 24th public meeting on this RROAR initiative are also part of the implementation strategy. Public input will be critical to identifying potential changes to administrative requirements as well as provide data

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 on the benefits and cost of existing administrative regulations.

And once the comments period closes on April 6th the NRC staff will use the five Commission approved final evaluation criteria to evaluate any public input along with the input we requested from internal NRC staff and the result from the historical correspondence review.

And depending on the outcomes of the review the NRC staff will develop recommendations to the Commission as necessary. Currently the staff plans to submit its recommendation to the Commission for review and approval by approximately December of 2020.

However, this date may change depending on the complexity level of the input that we received as well as the amount and volume of the public and NRC staff input.

The final step in the RROAR initiative is to develop a rulemaking plan to eliminate or modify requirements. This review will focus on non-substantive administrative changes.

Therefore, the NRC expects that there will be rule changes that can be exempt from the Notice and comment requirements under the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Administrative Procedural Act of 1946, as amended.

However, if the NRC foresees the potential for substantial changes to administrative regulations that would not be exempt from the Notice and comments requirement and in that instance the NRC staff will propose the elimination or modification of administrative requirements through the rulemaking plan to be submitted to the Commission for consideration and greater details on the RROAR initiative implementation strategy can be found in the May of 2018 Notice.

Slide 10, please. This concludes my presentation on the RROAR initiative process. At this time I would like to open the floor up for attendees to ask clarifying questions related to the information presented and, again, to inform your written comments, please.

Dan, I am going to turn this back over to you.

MR. MUSSATTI: Okay, great. A little bit of a clarification, we are only accepting written comments. We've got a transcript of this meeting that is going to be part of that, but we do urge you to send in written comments as well.

Sometimes what you think you said isn't

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what we heard and we would like to make sure that we get that correct.

So if you want to reiterate what you said clarify it by sending us in a transcript or this is what I was trying to say type of a note or anything new please feel free to make those written comments to us, but this room and what we are doing today will also be part of the public -- excuse me?

MR. CULLISON: I'm Dave Cullison, C-U-L-L-I-S-O-N. I am the Agency Clearance Officer. You cannot submit written comments, any new written comments. You know, this is not allowed by the Paperwork Reduction Act, only clarifications of verbal comments that you made today.

MR. MUSSATTI: I appreciate that. I was not aware of that before. I will amend my comments from this point on for all time and eternity towards the Paperwork Reduction Act. I wasn't aware of that.

Thank you.

So only clarifications and like a direct transcript of what you have done in here, but nothing new. That's correct?

MR. CULLISON: Yes.

MR. MUSSATTI: Okay. Nothing new. I'm going to write that down. Okay, I am going to open

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the floor to questions and comments now and, Tara, if you can stand by I will be coming back to you in a minute. Somebody in the room, have you got a comment or a question that you would like to make? There you go.

MR. SLIDER: Jim Slider, NEI. Just a question about what was just said with regard to clarification, did that information apply to submittals after the closure of the public comment date or was that about this meeting?

MR. MUSSATTI: Why don't you come on up to the microphone and make sure that we can get a real good --

MR. CULLISON: This is Dave Cullison again. What we are about to do and the Paperwork Reduction Act is to in a public meeting setting is get verbal comments during the meeting and we cannot request comments to be submitted, new comments to be submitted, before or after the meeting.

So we are bound for, at least in the public meeting

space, to only asking for clarification or -- You know, if you said something and, you know, like you said you didn't say it quite right then that's fine.

But I would recommend that if you have

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 any new comments to do it using the FRN and putting it on the docket there, and that's the more appropriate vehicle for doing that.

MR. SLIDER: Right. Okay, thank you.

MR. MUSSATTI: Thank you very much for that.

MR. SLIDER: Yes, and I have another question.

MR. MUSSATTI: More?

MR. SLIDER: Jim Slider, NEI. Andy, I am curious about what has to happen or what happens between the end of the public comment period on April 6th and your target date of December 2020 for getting recommendations to the Commission.

Could you give us a sense of what is involved in that? From the outside it sounds like a long period of time and I don't know what all has to take place inside the Agency.

MR. CARRERA: Yes. So the staff's plan is to look through all of the comments, and bin them into appropriate bins. After that we'll assign those comments to each programmatic office, which will have their staff going through the background of these individual suggestions, that means going back to the original statement consideration, look at why it was

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 proposed or it was implemented in the first place, and determine whether it's appropriate or not appropriate to be included in this review, and those would take a significant amount of time.

Once that happens, we have an internal NRC process for briefing of management on the type of recommendation that we are planning to make to the Commission before it gets there, so that's why.

MR. SLIDER: Okay. Thank you.

MR. CARRERA: Yes, thank you.

MR. MUSSATTI: Okay. Yes, sir?

MR. GULLOTT: David Gullott, Exelon. My question is on the previous slide where you talked about review historical correspondence, Andy, can you kind of just walk us through what that entails?

I looked at it -- When I read this I looked at it two ways, so I am just trying to understand exactly what that entails.

MR. CARRERA: Right, right. That process, well, no, it's still a -- I mean it's a work in progress --

MR. GULLOTT: Okay.

MR. CARRERA: -- where we go back into ADAMS and searched all the ADAMS documents that are publicly available with several key words, like

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 burden reduction, et cetera, and we got about 700 hits back. We are in the process of looking through those documents to see if any of the documents contain any type of information that may be useful for us to inform this review.

But if I may, my point of view is that there are documents that are older than five years, right, those, you know, have a good chance of being taken care of one way or another through the rulemaking process, et cetera.

And the suggestion of five years or newer may not be yet be addressed or actions may not yet be taken on and the issue may still be going. So those are the ones that we focused on, the last five years, and we think that the best idea to be implemented for the RROAR initiative will likely come from solicitation of the internal NRC staff and the public as we do now.

So we believe that the historical correspondence review -- well, it's important, and it is a good add-on to what we are doing now, however, we'd like to place our emphasis on the newer suggestions coming from the staff and the public.

MR. GULLOTT: Thank you.

MR. MUSSATTI: Okay. Somebody else in

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the room? Yes, ma'am?

MS. SCHLUETER: Janet Schlueter, NEI.

Given the process that the staff has been going through to date with RROAR, you know, more than one Federal Register

Notice, consulting with the Commission, getting your screening criteria approved, I would just suggest that you give some consideration to requesting Commission approval to skip the rulemaking plan phase because it's as if you've accomplished that intent with the process that you've used to date.

This is not your normal potentially rulemaking process, as you know. You know, you don't normally go out and do this sort of screening in advance.

So it seems like an unnecessary and to some degree time intensive, labor intensive process, milestone, in the rulemaking process to go back with our rulemaking plan after you've already now in December potentially going to the Commission three times on this, so I would ask that you consider that.

MR. CARRERA: Thank you, Janet.

MR. MUSSATTI: Okay. Tara, do we have anybody on the phone that is waiting to make a comment?

31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 OPERATOR: At this time, no, we do not.

MR. MUSSATTI: Okay, thank you. Well, back to room. I would like to point out to everybody that it is now approximately 9:36 and we should be well into our very first presentation by now and we're actually way ahead of schedule because the public comments weren't supposed to start for another almost 15 minutes.

So we have plenty of time here for comments if you want to make them. Yes, sir?

MR. WEARNE: Another question, excuse me. This is --

MR. MUSSATTI: And you are?

MR. WEARNE: Justin Wearne, NEI. The pictogram on the previous slide has a block about getting internal staff feedback. Can you describe how and when that process is occurring, is it past tense, has it occurred, is it ongoing, is it a formal process, can you kind of just walk through that step?

MR. CARRERA: So that is an ongoing process actually right now and we make considerable outreach into the NRC staff through internal means, you know, email communication, management briefings, et cetera, so that is an ongoing item.

MR. WEARNE: Do you have a due date of

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 when you expect the internal staff comments to be back to you?

MR. CARRERA: Yes. The due date is March 31st, which is a few days before the public's, and I know you have a lot, that you have some ideas for us.

MR. MUSSATTI: Yes, I think I saw another possible comment from the NEI end of the table down here.

PARTICIPANT: Oh, just -- this is administrative, but when you get a chance maybe you could do some intros on the phone and in the room so that we know maybe who else in the public and our members are listening in.

MR. MUSSATTI: An intro around the room and --

PARTICIPANT: Yes, please.

MR. MUSSATTI: I could have done that at the beginning, actually. That's when it's supposed to be done.

PARTICIPANT: Right, right.

MR. MUSSATTI: Well, let's take time and do that right now so that we can get that on the record. Let's start at the far end of the room and walk around the table and then we'll go out into the audience and then to the phones.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. SLIDER: Okay. Jim Slider, NEI.

MS. SCHLUETER: Janet Schlueter, NEI.

MR. GULLOTT: David Gullott, Exelon.

MR. WEARNE: Justin Wearne, NEI, on loan from PSEG.

MS. NOTO: Pamela Noto, NRC.

MR. MUSSATTI: He doesn't count.

MR. CARRERA: He does count, come on.

That's Sam Wojack. And I am Andy Carrera, NRC.

MR. MUSSATTI: And I am Dan Mussatti with the Facilitator Corp. And we'll start back here with PARTICIPANT: Anu Trinet (phonetic),

NRC.

MS. CAI: June Cai, NRC.

MS. BLADEY: Cindy Bladey, NRC.

MR. WANG: George Wang, NRC.

MR. CULLISON: Dave Cullison, NRC.

MR. KUNTZ: Rob Kuntz, NRC.

MR. COLACCINO: Joe Colaccino, NRC.

MS. NOLAN: Katie Nolan, NRC.

MR. BENOWITZ: Howard Benowitz, NRC.

MR. DE JESUS: Anthony de Jesus, NRC.

MR. MUSSATTI: Right behind him.

(Simultaneous speaking.)

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. MUSSATTI: Oh, I didn't even see you.

MR. DE JESUS: I'm hiding.

MR. MUSSATTI: Okay. Everyone that's on the phone if you could queue up and let Tara let you online so that we can figure out who you are one at a time, please.

OPERATOR: All lines are open.

MR. PHALEN: Marty Phalen, NEI.

MR. CATRON: Steve Catron, NextEra Energy.

PARTICIPANT: Tom Basso (phonetic), NEI.

PARTICIPANT: Bill Cuder (phonetic),

Entergy.

MR.

RITZMAN:

Robin

Ritzman, Curtiss-Wright.

MS.

SPALDING:

Amanda

Spalding, Westinghouse.

PARTICIPANT:

Kaily McGillicuddy (phonetic), Westinghouse.

MR. CARNEAL: Jason Carneal, NRC.

PARTICIPANT:

Juan

Florily, NRC (phonetic).

MS. COX: Vanessa Cox, NRC.

MR. SCHOFER: Fred Schofer, NRC.

PARTICIPANT:

Alex Cusco (phonetic),

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Winston & Strawn.

MR. MUSSATTI: Okay, I have counted 12.

I think a couple of people got talked over and two voices were happening at the same time. If you think that was you please try again.

MR. CRONIN: Dan Cronin, University of Florida.

MR. MUSSATTI: That's new. Anyone else?

PARTICIPANT: Deanne Riley (phonetic),

Curtiss-Wright.

MR. MUSSATTI: Okay. That's what I thought I heard. Did you get all those?

COURT REPORTER: I can just spell them phonetically, but I think that this helps, so --

MR. MUSSATTI: Okay. Please, everybody, make sure that what you do is make sure that Pam gets a copy, gets an email from you so that we can get the proper spelling of your name to pass on to our court reporter. He's got you down phonetically, but he does not have the exact spelling on everybody.

Seeing no reason not to I think we should proceed into the second set of presentations here and that's back with you again, isn't it?

MR. CARRERA: Yes, it is.

MR. MUSSATTI: Okay. So I'm turning the

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 thing back over to Andrew.

MR. CARRERA: Okay. Slide Number 11.

Okay, we are now moving back into the second segment of the presentation where we will discuss the five Commission approved evaluation

criteria, the applications, and example of the type of input that the NRC is looking for.

Slide Number 12, please. And as mentioned earlier in the background discussion the NRC published the May 2018 Notice to seek public comment on the draft criteria the NRC would use to evaluate potential changes to the administrative regulations as part of the RROAR initiative.

The NRC also conducted a public meeting to provide an opportunity for NRC and external stakeholders to exchange information on the overall RROAR initiative, implementation strategy, and the full draft evaluation criteria.

And at the end of the public comment period for the May 2018 Notice the NRC received six comment submissions containing 12 individual comments and the NRC staff revised a draft evaluation of criteria based on the public comments and provided them to the Commission for review and approval.

The Commission later approved the staff

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 recommended evaluation criteria with changes. Now to COMSECY-18-0027 described the changes to the evaluation criteria that resulted from the public comment and the ADAMS document number for that enclosure is ML-182618173.

The evaluation criteria which focused on the administrative requirements, such as recordkeeping or reporting, are included in the February of 2020 Notice.

The evaluation criteria would serve as factors for consideration in order to expedite and provide consistency in the review and guide the NRC decision making process.

The evaluation criteria, we also help identify opportunities to reduce administrative burden without impacting the mission of the Agency.

The NRC is not proposing to use the criteria to make standalone determinations.

The criteria would be weighted against other activities outlined in the RROAR initiative implement strategy, such as programmatic experience, inspection needs, comments received, and results from the historical correspondence review.

Slide 13, please.

Moving on to discussion of the individual criterion, Criterion 1

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 has not changed from the draft that was published in the May 2018 Notice.

Criterion 1

includes submittals resulting from routine or periodic recordkeeping or reporting requirements such as the records to submit recruiting reports which the NRC has not consulted or referenced in a programmatic operation of policy development in the last three years.

The objective of Criterion 1 is to focus the review on those periodic reports received by the NRC which the NRC may now consider for elimination.

Moving on to Criterion 2. So public comments received on the May 2018 Notice indicated that the draft Criterion 2 at that time should be split into two discreet items addressing two separate ideas, one is the reasonably accessible information and the other is reporting frequency.

This is because each item considered alone would likely produce different results. The NRC agreed with the comments and in the end the NRC revised a draft Criterion 2 by dividing it into two separate parts.

The first part remains numbered as Criterion 2 and includes requirements for reports or records that contain information recently accessible

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to the Agency from alternative services and may be a candidate for elimination.

And as such the objective of Criterion 2 is to focus on the review, to focus the review on duplicative information or overused in collection requirements.

Slide Number 14, please. The second part of draft Criterion 2 was added to the list of the criteria as the new Criterion 3 and this criterion focuses on administrative regulations that may be modified rather than eliminated.

The intent of this criterion is to capture situations where the Agency still needs some piece of information to accomplish its mission but requirements could be modified so that the process used to provide the information is less burdensome.

The new Criterion 3 includes requirements for reports or records that could be modified to result in reduced burden without impacting programmatic

needs, regulatory efficiency or transparency, and that may be accomplished through several different ways.

One is less frequent reporting periods.

Another one is shorted record retention period or requiring entities to maintain records rather than

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 submit a report or implement another mechanism that reduces the burdens for collecting or retaining information.

Then the objective of Criterion 3 is to focus the review on requirements that may be modified to become less burdensome.

Slide Number 15, please. The original Criterion 3 was then re-designated as the new Criterion 4 and with this criterion the NRC intends to identify opportunities to reduce administrative burden without impacting the mission of the Agency.

In its recommendation to the Commission for potential regulatory changes the NRC staff plans to assess benefits and costs for each potential change, including the cost to conduct rulemaking to implement the potential change.

And just a

point of clarification regarding the May 2018 Notice, so in the May 2018 Notice we provided an example with the draft Criterion 3 of the potential regulatory change resulting from $100,000 of burden over a three year period.

The NRC's intention with that quantitative example was to communicate to the public the type of potential change that may be recommended

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to the Commission.

The quantitative example was not intended as a quantitative cutoff value to exclude --

potential regulatory change. Changing a regulation entails a significant amount, you know, of not only the NRC's time but also the stakeholder's time and the public's time to involve in the rulemaking process.

However, some potential regulatory changes would have little impact on the overall administrative burden of the regulated entity and, therefore, the cost of pursuing that change via a rulemaking would exceed the potential benefit and a benefit value at $100,000 is roughly on the same order of magnitude as the cost to conduct and implement a simple administrative rulemaking.

This might be possible for some of the administrative changes.

So that was the clarification I would like to get out.

The new Criterion 4

includes recordkeeping and reporting requirements that result in significant burden reduction. The objective of Criterion 4 is to focus the review on potential changes that will have the greatest impact on reducing or avoiding regulatory burden and also offer

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the greatest potential benefit to the regulated entity and to the NRC.

Okay. With respect to Criterion 5, some NRC regulations require regulated entities to conduct information collections that are used by the NRC, by the public, or by other organizations. These organizations may be other federal agencies, state and local governments, and federally recognized tribes.

And Criterion 5 includes reports or record that contain information used by the aforementioned organizations will be dropped from the

review, provided the information collected is necessary to support NRC's mission or to fulfill a binding NRC obligation. And the objective of Criterion 5 is to screen out regulation from further inquiry, as to avoid unintended consequences on the regulatory objective of those other organizations.

The Commission also revised Criterion 5 to make sure that the NRC would not function as a pass-through organization for the information that is not necessary to support its mission or its binding obligation.

Slide number 16, please.

These screening criteria are not intended to be mutually

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 exclusive, given a regulation may satisfy one or more of the criteria. To be considered as being in scope for further review, the suggestions must meet at least one of the first four criteria. Criterion 5 is to screen out regulation for further inquiry only if the information collected is necessary to support the NRC mission or to fulfill a binding NRC obligation.

Slide number 17, please. We found an example of the type of suggestion we're looking for in this review and how we apply how it would apply to the criteria. And the example given on the screen is a final rule and a major rule that was published in 2007. However, this final rule also included administrative change that we think would fit nicely into the RROAR Initiative.

Now, this final rule revised, among other things, the reporting requirements in 10 CFR 19.13(b) and its conforming regulations in 10 CFR Part 20 so that licensees must provide an annual report to each worker who are monitored of the dose received for that year if one, the individuals occupation dose exceed 1 millisievert, 100 millirem, whole body or 1 millisievert or 100 millirem to an individual tissue or organ; or, two, the individual requests his or her

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 annual dose report. However, the NRC would not require licensees to provide unsolicited annual dose reports to those individuals whose annual dose does not exceed these limits.

And the goal of the final rule or that particular administrative change was to reduce the administrative and information collection burdens on the NRC and agreement state licensees without affecting the level of protection for either health and safety of the workers and the public or the environment.

As we filter this example through the five criteria, we find that the annual dose report is a routine thing for Criterion 1. And each year, the NRC publishes a NUREG report that summarizes these occupational revisions OSHA data, and the latest publication on this topic was the NUREG-0713, Volume 39, dated March 2019.

As you can see, that correct information is also available from an alternative source per Criterion 2.

Now, the NRC determined that less reporting, less routine reporting requirements would meet the programmatic needs without sacrificing or affecting the level of adequate protection to the work, the public, or environment per Criterion 3.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The NRC also determined that the rulemaking effort devoted an estimate of 132,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> and $135 million per year to the licensees and the NRC per Criterion

4. And, finally, the report was not used by another governmental agency per Criterion 5.

Slide number 18, please. That's the example that I can best come up with for you all. So the information provided is an example of what NRC is requesting from your input. To help facilitate a thorough and informed consideration of input, we encourage you to identify specific requirements that should be considered for revision or elimination.

The associated rationale, that's very important to us to determine whether that would be, you know, in scope or without scope, and an estimation of the burden that would eliminate or reduce.

And the NRC's particularly interested in identifying changes in this regulation that could have broad impact and potentially significant burden reduction. For example, a change in administrative requirements that impacts multiple regulating entities over a long time frame will generally be more likely to achieve significant burden reduction compared to administrative requirement that affect a single regulator entity one time.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We ask that you please answer as many questions when you submit your comments. Answer as many questions that are presented in the February 2020 notice as you can and with as much details as you can. And these questions include, the first question is which administrative regulation should the NRC consider changing? And if you would please include a citation of the 10 CFR part, section, and paragraph, it would be a tremendous help with the bidding process if we know where to send those suggestions to for review.

The second question is how should NRC change the regulation and can the regulation be made less burdensome or should it be eliminated entirely?

If possible, please provide specific language showing how the regulatory text might be changed to reduce burden and describe how the evaluation criteria would apply to the proposed changes.

Third question is what is the basis for the proposed change, and this is also important that you provide the rationale for why the requirement may be obsolete, overly burdensome, and any relevant supporting data that would further help making the case.

The fourth question is what burden is

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 associated with the administrative requirements. So here we are looking for a quantitative basis for the burden in terms of cost and labor hours, if available.

And if you do not have the exact number, a ballpark number would also be very helpful.

Question number five is how would the suggested change reduce burden, would reduce a one-time reduction in burden or a reduction in burden over multiple years or an ongoing reduction in burden? Please provide supporting justification for that also, if it's available.

Okay. Slide number 19, please. Public input, your input, will be critical to identifying potential changes to these administrative requirements, as well as to provide data on the benefit and cost of existing NRC administrative regulations.

We are encouraged and we look forward to your written, receive your written comments on the outdated and duplicate administrative requirements.

And to submit your comments, we prefer that you please visit regulations.gov, www.regulations.gov, and search for Docket ID NRC-2017-0214.

And the comment period on the February 2020 notice, again, the reference to that notice is

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 85FR6103, will end on April 6th of 2020.

Slide 20, please. This concludes the NRC presentation on the RROAR Initiative evaluation criteria. At this time, I'd like to yield the floor to the delegation from NEI and Exelon for their presentation. And after that, then we'll open the floor for questions.

MR. MUSSATTI: That makes sense to me.

MR. CARRERA: Justin, the floor is yours.

MR. WEARNE: Okay. This is Justin Wearne from NEI, on loan from PSEG. Next slide, please.

What we're going to be talking about today is how we've been developing the input that we're going to be giving you in the written format by April 6th. We're not going to be going through the details of what those comments will be at this time but just, rather, the process or methodology that we did to develop that.

We're also going to be highlighting what we see as the industry priority, and that's the 50.72 petition for rulemaking. And then I'll just leave some closing remarks, as well.

Next slide, please. So what we're looking at here is a large spreadsheet that we have,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and it has approximately 300 rows and we've populated that with what we see are all the requirements that are in NRC regulations that mandate a report be made or a record be kept. And it's approximately 300. As of last night, we added another one, so it's kind of, as our review continues, we're continuing to find other ones.

And the columns of the spreadsheet, we have the five NRC screening criteria, as well as two more screening criteria that we've used. And then the final category there is the column in pink.

We've binned common items in a similar bucket, and that's how we'll be displaying the issues to you in the April 6th response.

Next slide, please. So for each of the criteria, we split them up into several subcriterias.

So, for example, in Criterion 1, we split up into six subcategories. Criterion 2 is the largest, the largest bucket that we have. We see a lot of reports that we have to make that are duplicative to things that are in the corrective action program or in the records management program.

And then the subcategories that we have here are we'll have one subcategory for the power reactors and another category for the fuel cycle facilities. Criterion 2

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 is our largest category there.

So we've consolidated these into approximately ten large buckets, and that's how we're going to be displaying the information back to you.

It's not through the spreadsheet, but we'll be organizing it into ten broad categories and will be answering the five questions you posed in the February 2020 Federal Register notice on those buckets specifically.

We also developed two other criteria that we thought were important. The first one was a flag for other items that we thought the NRC should be aware of. One example of this is a flag for things that we think are candidates for a direct final rule.

Another one is there might be a preexisting commitment, for lack of a better word, to resolve the regulation that's outstanding, and we'll just be highlighting those for you.

Item seven is items that we, as industry, saw that we could take action on and reduce the burden that we've imposed upon ourselves through just bureaucracy, and we're taking effort to reduce that ourselves. An example of this is the effluent monitoring process where we report to you what the results of our effluent reports are. We've taken

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 action to default templates for those that will streamline that process for us, and we did not see that in the rulemaking or your concurrence.

Next slide, please. The 50.72 PRM, which is to eliminate the non-emergency 50.72 event notification reports, we see that as our highest priority. That is the one that yields the largest burden reduction in terms of person hours at the station, as well as the distraction at the station.

And so once we started, once the SECY, SECY-17-0119 came out, and that date escapes me, but, once that SECY came out, we recognized that the 50.72 was going to be the largest burden reduction. That's why we took action to submit that as a PRM. And following that, there's been little or no action that we've seen, no visible action that we've seen on our end on that topic, and that's going to be something that we'll be commenting on in the letter is we think that's the highest priority and the largest burden reduction.

Next slide, please. And just as an example of this, we feel it meets the criteria, and let's just talk about Criterion 4, the burden here.

So once a potential 50.72 report is identified, it can be up to two engineers, two operators, two members

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 of the licensing staff, up to the full eight hours to try to determine if it is a required 50.72 report.

So in addition to the time burden, that's also a distraction to the control room and to the plant staff as they're dealing with this, whatever the issue is.

So we see that as a high priority.

Next slide, please. So we look forward to sharing our comments back with you. We've done a lot of work over the last two years, and we're going to be giving you a lot of comments. Our highest

priority, though, is the 50.72 petition for rulemaking, and I think you see from some of our questions here, expediting ourselves through this process, we think it's important, as well.

MR. MUSSATTI: Okay. Let's go on to the questions-and-answers period here. Yes, ma'am.

MS. SCHLUETER: I'm Janet at NEI. I just wanted to add a point of clarification on what NEI has been doing. What we're going to send you will be based on input from the power reactors, as Justin said, fuel facilities, research test reactors, and maybe some uranium recovery people. But we are not representing all the Part 30 materials licensees, your medical, industrial, commercial, irradiators, and so forth. So I don't want to give a false

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 impression.

I've reached out to, like, CORAR, the Council of Radionuclides and Radiopharmaceuticals, but I have not specifically reached out to members of medical use organizations. So if NRC isn't reaching out to them directly, I would suggest that you do because we don't represent them. They have other trade associations.

MR. CARRERA: I just want to respond.

The NRC has reached out to 10:10:48 on this request, as well.

MS.

SCHLUETER:

Well, that's your internal advisory committee, though.

MR. CARRERA: Yes.

MR. MUSSATTI: Anybody else?

MS. SCHLUETER: That's not the trade associations.

MR. MUSSATTI: Yes, sir.

MR. GULLOTT: David Gullott, Exelon. I have a couple of questions, process questions, on Andy's second presentation, if I may.

MR. CARRERA: Yes, please.

MR. GULLOTT: So Criterion 5 is regarding other federal agencies' use of information. How are you going to go about determining how other federal

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 agencies or

tribes, other state and local governments, use information? How is that going to be determined? Is that through the comment process, or is that going to be done separately?

MR. CARRERA: We expect that the NRC staff or NRCs points of contact for those agencies will be in communication with those agencies and determine how they're to be used.

MR. GULLOTT: So we'll get formal interaction between the NRC and other agencies, not -- I think I understand.

Another question on, you know, process related. After the comment period ends on April 6th, will all the comments from different entities be made public? Will they be produced?

MR. CARRERA: Normally, the comments that we receive will be posted on regulations.gov.

MR. GULLOTT: Okay.

MR. CARRERA: They will be docketed with NRC first, and then we'll post them regulations.gov.

MR. GULLOTT: Okay. And then will the disposition of all those comments also be public then?

MR. CARRERA: That is something that the staff is still discussing at this time. You know,

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 if staff would make a recommendation to the Commission, we'll provide the Commission a summary of how we dispositioned the comments.

MR. GULLOTT: Thank you.

MR. MUSSATTI: Yes, sir.

MR.

WEARNE:

Justin

Wearne, NEI.

Andrew, on Criterion 5, you talked about, you used the word pass-through. I think I heard you say that the, and check to see if I heard it correctly, that the NRC did not, in fact, get asked to 10:13:24 to the other agencies. Can you clarify that just one more time for us?

MR. CARRERA: No, I'm afraid that's a poor choice of words on my part, but the Agency doesn't want to be the middle person that, you know, taking one piece of information collected that doesn't have anything to do with it and send it to the next person. So that's what I meant.

MR. WEARNE: Okay. Thank you.

MR. CARRERA: Thank you, Justin.

MR. MUSSATTI: Okay, Tara, let's go to the phones for a second. Have you got anybody that wants to comment?

OPERATOR: Thank you. Once again, please press star 1 and record your name at this time.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. MUSSATTI: Okay. I'll give them a minute to press star 1 and get into the queue and go back to you, ma'am.

MS. SCHLUETER: Okay. Yes, Janet at NEI. Just a clarifying question. You acknowledge and, as we have found, there are requirements that are screening through and hitting more than one criterion. Do you want us to include that requirement in each criteria that it meets, or do you want it just identified once? You know, take our best shot at figuring out which one it really meets?

Because I can think of a few that are screening through and hitting more than one criteria.

MR. CARRERA: Yes. If you would just set up the matrix so that you have the requirement and then you have a checkbox on those --

MS. SCHLUETER: Okay. So you don't mind it being listed in more than one criteria?

MR. CARRERA: Yes.

MS. SCHLUETER: Okay.

MR. MUSSATTI: Okay. Tara, back to the phones. Did anybody decide to make a comment?

OPERATOR: No, sir, we have no questions at this time.

MR. MUSSATTI: You have a question?

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CARRERA: Yes, I do have a question for myself. No, I'm just joking.

(Laughter.)

MR. CARRERA: No, but this question is related to the NEI delegation, given that you have about three for one suggestion. Any chance that we'll receive preliminary version of that so we know how to allocate our resources to support those suggestions? As you know, I do have a planned date to get back to the Commission and it's critical that I be able to have somebody to help.

MR. WEARNE: Jim, can you get that question?

MR. SLIDER: Jim Slider, NEI. Andrew, I'm not clear on what your question is. Are you asking for a preview of what our comments going to be?

MR.

CARRERA:

Yes, a

preliminary version. It doesn't have to include all the, you know, rule language changes that you're proposing or, if somehow we can get a list of the items that you have been thinking about so that we can get ahead of the wave.

MR. SLIDER: Well, I can't promise that, but I think we can give you a high-level view of what

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that is. As Justin said, we have delineated in a spreadsheet all 300 regulations that we've reviewed and, in that spreadsheet, we have some high-level recommendations on how we would recommend they be dispositioned according to your screening criteria.

So I think -- would that be helpful to you? Is that what you're looking for?

MR. CARRERA: I think it would be.

MR. SLIDER: Well, again, I can't promise, but I need to confer with our folks here and back at NEI and we'll get back to you on that within the next couple of days.

MR. CARRERA: I understand. Thank you very much.

MR. MUSSATTI: Okay. Does anybody else in the room have a question or a comment that they would like to make? I'm sensing we're coming close to the end of the meeting. We're going to be running out of an opportunity for you to comment very quickly if somebody doesn't raise their hand or get on the phone quickly. Tara?

OPERATOR: Again, please press star 1 and record your name.

MR. MUSSATTI: Okay. We'll give it one more minute just so that anybody that's on the phone

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 can press star 1. And if nobody does and nobody in the room thinks of one last a-ha moment that they've got to get on the record, then we'll go to the conclusion here. No nibbles, Tara?

OPERATOR: We have a question on the phone, sir, from Pete Catron. The line is open, sir.

MR. CATRON: Thank you. I just wanted to make a comment in support of the effort. NextEra Energy does appreciate the NRC recognition that many of the current administrative requirements that are imposed upon us do provide a burden to us and really don't carry sufficient additional benefit to safety to continue doing them.

I agree wholeheartedly with the NEI initiative to identify all of the reporting requirements. I've seen the list. It's quite voluminous, and I think there are some real opportunities here for the NRC to reduce the administrative burden and allow all of us to focus more on matters of nuclear safety and reliability, as opposed to meeting some of the administrative requirements that have been created over the years that really are outdated and become redundant to other methods of communication that we have.

That's really the only comment that I

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 had. Thank you.

MR. MUSSATTI: Okay. And I think we had a problem with your phones there because, when you started with your name and your affiliation, we didn't catch that. Could you repeat that?

MR. CATRON: Yes, my name is Steve Catron. I'm with NextEra Energy.

MR. MUSSATTI: Thank you very much.

Anybody else on the phone, Tara?

OPERATOR: No, we have no one else, sir.

MR.

MUSSATTI:

Okay.

Going once -- well, let's not go through that whole thing.

It looks like I should probably end this meeting for the day and give you a chance to get back to your offices a little bit early and continue working on this big problem. Do you have a comment here to make at the end?

MR. CARRERA: Yes, just a final note.

Pam and I will be at the 2020 Regulatory Information Conference next week, if that's still going to happen.

MR. MUSSATTI: It currently is, as far as I understand. Nobody has decided that it's like March Madness where they might have to shut it down.

MR. CARRERA: So we'll just have to give

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 elbow shakes, right? Well have a digital exhibit on RROAR Initiative at Table L, and we'll be there from 7:30 a.m. to noon and then 3 to 3:30 p.m. each day. So please feel free to stop by if you have any follow-up clarification questions you'd like to talk to me about. We'll be happy to speak with you.

Okay. We're also planning to conduct another RROAR Initiative public meeting on March the 24th on the same topic. John isn't here. Can I close the meeting up, or do you want to?

MR. MUSSATTI: You're welcome to. I've got a few comments I usually make about, you know, filling out forms and stuff like that.

MR. CARRERA: Okay.

MR. MUSSATTI: But go ahead.

MR. CARRERA: John Tappert has left the room, so I'll be making a closing statement for him.

So picture me as a little bit taller, okay?

(Laughter.)

MR. CARRERA: Thank you for all of this discussion today. As mentioned before, we encourage and look forward to receiving your written comments on our data for duplicate requirements, and your feedback is very important to this initiative. And as I mentioned, we plan to have another public meeting

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 on the 24th on the same topic.

Please feel free to contact me or Pam if you have any follow-up information or questions.

Please also remember to fill out the meeting feedback and give us a like. That's all I have.

MR. MUSSATTI: Okay.

MR. SLIDER: Yes, just a quick question.

Jim Slider, NEI. Andy, what will be different at the March 24th public meeting?

MR. CARRERA: It will probably be the same. There won't be any new materials at the March 24th, except that it will be Skype only.

MR. SLIDER: Okay. So your purpose is primarily to gather any last-minute questions or --

MR. CARRERA: Yes. In case someone who cannot attend this meeting today, they'll have another opportunity. The next meeting will be held in the afternoon so it may target some of the people on the Left Coast.

MR. SLIDER: Okay. Thank you.

MR. MUSSATTI: Okay. You mentioned the feedback form. Do we have some in the back of the room there? You can also get them online at our NRC.gov website, if you just go to the little spyglass up at the top of the search bar where you can put in

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 numbers and type in NRC Form 659 and follow the links and everything that are there, print out PDF, fill it out. And it's a two-sided form. You can fold it up.

If you fold it up properly, you can put a piece of tape on it and put it in the mailbox as-is and it will get back to us without any postage at all. It's already pre-stamped and everything for you.

I would like to thank you all for the decorum we had in this forum and how easily this meeting went and how quickly it went because we've gained about an hour here, and that's pretty good actually. And I would like to ask you to be safe on your way home, wash your hands on a regular basis, and we'll see you soon at the RIC.

(Whereupon, the above-entitled matter went off the record at 10:23 a.m.)

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