Introduce Dan Dorman. Dan is a deputy executive director for operations at the Nuclear Regulatory Commission and the lead for this initiative. Dan Thank You Lance. Good afternoon everyone, and I'd like to add my welcome to this 30th regulatory information conference I'm gonna briefly go through an overview of what the task is that's been given to the transformation team and where we are in that process And key up some of the the themes that we're pondering Based on the feedback that we've gotten so far and then I'm going to invite you to Share with us your views on are we looking at the right themes or is there something else? We should be looking at What what are the impacts or the benefits if we pursue transformation in these areas and and maybe what obstacles you might see that we Need to anticipate and be prepared to overcome So on January 25th of this year our EDO Vic McCree chartered a group of NRC staff to explore possibilities for transformative change in our organization organizational culture and regulatory framework that may enable the safe use of new or novel technology and nuclear applications in This session will give you the overview of the efforts to date and in particular the themes that are developing from our information gathering But more importantly for this session the team is looking to hear from you Your impression of these themes are they the right areas or there are other areas that you think would be more important for us to consider What would be the impacts of transformational change in these areas? What obstacles do you see to achieving transformation in these areas? We want to do this to enhance the NRC safety mission effectiveness, but what mission risks should we watch out for? So in a few minutes, I'll give you the floor, but first why transformation? We all know that technology is changing faster than we can keep up Think about a decade ago when smartphones didn't exist or merely 25 years ago when very few of us even had cell phones The pace of technological change is accelerating As the quote that you see there Vic McCree used in his speech this morning also the chair of the Chief executive officer of General Motors saying that we're in the midst of seeing more change in the next five years than we've seen in the previous 50 So think about the amount of technology change then that could occur over the next 50 years In terms of changes in the automobile industry barely a century ago. We got rid of the horse Now we're getting rid of the driver There have been and will be similar advances in technology applicable to nuclear applications And while the NRC does not promote or facilitate development of new technologies when and if they arrive We must have a regulatory structure that is able to effectively efficiently and agilely regulate them as appropriate consistent with our safety and security mission and our principles of good regulation Specifically the principle of efficiency Which states that the American taxpayer is entitled to the best possible management and administration of regulatory Activities, but also the principles of clarity and reliability are essential to applicants and licensees who want confidence in a clear and consistent regulatory approach We cannot be an efficient and effective regulator unless we are continuously upgrading our regulatory capabilities to address the changing technologies NRC's regulations have effectively protected people in the environment and in that regard have served the country well They have and will continue to assure safety and security in some cases NRC regulations however were written to be technology specific and do not easily accommodate new technologies such as advanced reactors and Not so new technologies as we heard this morning such as digital instrumentation and control It is our responsibility to ensure that our regulations continue to provide the same level of safety in a manner that accommodates the new technologies What's more we want to ensure that our regulatory framework does not present a barrier to safety enhancements This is an important step to continue to be a relevant and modern regulator in the future NRC is fully invested in this effort to transform our regulatory structure We're needed to accommodate the safe use of new technologies And I'm confident that we will be successful. We have the technical expertise needed to fulfill our safety mission We have a highly motivated and competent staff Our vision is that this agency enable rather than be a barrier to new technologies They continue to meet our safety standards so that we can continue to be a modern effective regulator This statement That the nuclear industry has indicated plans to introduce new and novel technologies and because of the because the use of such New nuclear technologies would challenge our current regulatory framework We must not only innovate but also identify and implement transformative change is a quote from our Tasking memo from Vic McCree and it summarizes the why we transform that I've just discussed So let me talk a little bit about what we mean by transformation We at the NRC are defining transformation as a fundamental change or fulfilling our mission in a different way under a different paradigm We've talked within the team about Approaching an area of our regulations with a clean sheet of paper Examples of transformation are the change in the business model brought about by Amazon in the area of electronic commerce As Vic mentioned this morning for us at the NRC the development of part 52 for licensing new reactors and the changes to the reactor Oversight process about 20 years ago our examples where we have had transformational change We anticipate that the areas where we transform our regulatory framework more will more fully align us with our principles of good regulations And will enhance our effectiveness efficiency and agility As important as what transformation is is what it's not This has no intent to change our mission in any way We will continue to fulfill our mission to protect public health and safety and the environment It's distinct in our parlance from innovation Innovation is an incremental change or a better way of doing what we currently do Examples of innovation would be earbuds instead of headphones or for the NRC project aim Or streamlining the concurrence process would be examples of innovation or incremental change Innovation and transformation both benefit the agency and both are needed one does not supplant the other NRC has established innovation forums throughout the agency to promote a continuous improvement culture Innovation for us means incremental changes that improve our way of doing business and Innovation is essential to the health of the agency and our mission effectiveness But from time to time a more fundamental change is needed And finally this transformation initiative is not a short-lived effort that will pass with time Although our project task time is only 90 days The the effort is intended to engender a sustained shift in the agency's mindset to be more open to better ways to fulfill our mission We are committed to making the transformative changes needed to enable new technologies consistent with our mission and our principles as Mentioned earlier Vic McCree issued the memo to form the team at the end of January The team members represent multiple offices across the agency as well as a wide diversity of our staff with different skills and experiences The tasking memo emphasized the need for a paradigm shift in our regulatory structure and Processes to address the development of new nuclear technologies the transformation team was tasked with identifying potential transformative changes to the NRC's regulatory framework culture and infrastructure to further enhance our effectiveness efficiency and agility The four bullets on this slide are the specific Taskings in our memo in addition to these specific areas to consider for transformative change The team will identify strategies to enhance and sustain the transformative culture throughout the agency as I mentioned We have a 90-day task time and Given this short timeline the intent of our effort is not to implement transformational initiatives, but to recommend ideas for transformative changes We have been out gathering insights and ideas and after this week We will begin to shape those ideas into actionable recommendations which we expect to provide to the Commission in May the tasking memo As well as a previous Memo from the executive director to the NRC staff on January 4th, which you can find those two memos together in Adams Identified the primary focus of the team's efforts as changes to our regulatory framework to accommodate new technologies Specific areas of consideration included in our tasking memo are listed on this slide The team has engaged internal and external stakeholders in these areas directly to solicit input on the development of transformative ideas We've also conducted outreach more broadly to solicit input on transformative ideas that support the development of safe new Technologies in other areas and in addition we are considering strategies to enhance and sustain a transformative organizational culture The transformation team has conducted many outreach efforts both internally and externally We have received over 500 ideas from within the NRC and have explored best practices with diverse external stakeholders including other federal agencies nongovernmental organizations and private sector entities Here we get to the hub of the matter This this slide shows some of the main themes that we have heard in our outreach to date I want to emphasize that these are themes that we've developed from ideas that we've received and They need further development before they become actionable recommended initiatives So in a few minutes when I wrap up I will invite your thoughts on these themes or any other ideas for transformation at the NRC The most prominent theme we've heard is the need for consistent and expanded use of qualitative and quantitative risk insights in licensing decisions As most of you are aware the nrc has applied risk insights to its decisions for many years There are several existing commission policy statements that encourage the use of risk insights However, a structured approach to the licensing decision making process has not been established and consistently applied And there is little guidance for the staff on how to apply these concepts to the scope of a regulatory review and to regulatory decisions Qualitative risk considerations are not uniformly Used to inform the scope of our reviews And the feedback the team has received to date suggests that it may be warranted to expand the use of risk informed decision making Including the use of existing prior approvals or reviews to focus the scope of our reviews going forward We have also heard an interest in accepting more uncertainty for inherently safer technologies The suggestion is that these concepts would help the nrc staff to provide its regulatory conclusions with clearer context of overall risk A second theme is the potential for more flexibility for licensees to make more Non-risk significant changes to their licensing bases without prior nrc approval A third theme is the need for timely resolution to challenges associated with new or novel technologies Especially digital instrumentation and controls accident tolerant fuels and advanced reactors And with respect to specific technical areas some broad themes include The need for higher level more performance based and less prescriptive regulations And support for incremental or early involvement in design reviews At the bottom of the slide you see some of the things that we're pondering with relation to the organizational culture Both in terms of the ongoing culture of the agency But also issues that may need to be considered to ensure the success of any initiatives that we recommend to the commission So as I mentioned previously during this session We would like to receive your feedback on these themes by addressing these questions in particular What are the most important areas for us to tackle? Is it the things that were on that previous slide or is there something else that you think we need to be focused on? How should we transform in these areas or another area that you have an interest? What obstacles should we anticipate for the process of implementing the transformation? And how would this transformation be beneficial? So as Lance noted there are several ways that you can provide us ideas We have about Hour and 15 minutes here to hear from you We will have handheld mics in the aisle. You can come up to a microphone And again, we can't get everybody here in an hour and 15 minutes. So we'd ask you to be concise on your points But you can also fill out one of the cards on your seat and and obviously there's there's a limited space on those But we'll be collecting those cards and those cards will be considered by the team as we refine these themes Uh, and then finally if you want to submit a more substantive input to us this email address transformation dot resource at nrc.gov Is available for you to send us any thoughts that you want to share with the transformation team If we get your email by the end of thursday I can assure you that we will consider it as we are developing our recommendations Anything we get after thursday, we do have a very limited time to to bring this to to A set of actionable ideas. So anything beyond that time we will consider to the extent that we can So this concludes my overview that the team are sprinkled here among the audience I want to also introduce miss andrea cook is the deputy team leader for this effort And we we the team are very much looking forward to your thoughts And so now i'll turn it back to lance to guide us through the conversation Okay, thank you dan So as dan and I were talking before this session and he and he was looking at everyone coming in and saying I hope they're not coming in expecting to hear me talk the entire time because We're really here to listen to you and that's that's the the main reason that we wanted to have this session Because we are seeking to get input In terms of how the nrc should transform dan went over a couple of the ideas But again, we're we're looking to get some input, you know, are we on the right track? Do we have some ideas that you have that we should consider? So i've got richard cheng here in the front. We're going to kind of do a zone defense if you will We've got ruthan in the back So what we're hoping to do is that you'll approach one of them and Take a little bit of time at the mic Ask a question give a comment give us some ideas Um, we want to to benefit from from having you attend the session and to to get the ideas and thoughts that you may have So I guess the the real question is is who's brave enough to go first Who's feeling bold today? Come on we've got the uh The ideas up here on the screen. These are the ones that the the team has kind of come up with at this point Um after after this we can move on to the questions as well just to kind of circulate But uh again, and once you once you start with the microphone if you could uh introduce yourself and uh any group that you're with Please Thank you. Stephen dolly with s and p global plats. I added our newsletter inside nrc I I don't have a horse in this race. So I guess it's safe for me to start out I'm not entirely seeing the difference between innovation and transformation. I look at this list. I've been doing this about 14 15 years And it seems like I've heard almost all of this before Can you can you tell us, you know, we have the risk informed policy statement going back more than 20 years? We have project aim making a making the agency more efficient agile Pick your adjective How is this transformative initiative different than The numerous other transformative initiatives we've seen over the years Thank you. Thanks. Thanks, steve. Um It's a great question and and It's one of the things that the team is is looking at on any of these themes is is it truly transformational Um, I think probably the best example that we're chewing on that I would say is the most transformational would be in the area of digital instrumentation and controls Uh, it was mentioned this morning that we've gone out and talked to another a number of other agencies naval reactors faa fda About how they license digital technologies in their applications and they Just very broadly are are setting requirements at a much higher level Than the level of detail involved in IEEE 603 1991, which is the endorsed standard in the commission's regulations so as as Was mentioned this morning. There's there's been ongoing efforts There was an effort late in the last decade to try and straighten out the licensing and digital I&C and and We've got another effort trying to do that and those efforts are incremental within the existing framework I think what we're looking at as a potential area of Of transformation would be a clean sheet of paper New set of standards starting at a higher level and looking at a different oversight paradigm to To achieve the approval of digital I&C systems So so I think that that's a good example of a clean sheet of paper um, I think uh Some of the things we're chewing on in the risk informed licensing realm Are certainly Their their Evolutionary in the sense that we've been on a journey for 40 years on risk informed licensing I think we're very Good at doing extensive detailed reviews of applications that are predicated on detailed risk models I think what we're exploring here One of the things we're exploring here is how do we use risk insights at the front end of a licensing review to identify The risk significant components of the review and define the scope of the review differently than what we've done Here to four so it's a it's a different paradigm in terms of how we would approach A licensing review to support the conclusions of reasonable assurance of adequate protection So so I think uh, there are certainly Areas within these themes that would be innovative Within the definition that we're using We're exploring what what are the things that would be truly transformational So real real quick follow Steve knows of it with Duke energy Um, Ruth hand, hold on. We have a we have a follow-up real quick. Sorry Just real quickly that uh, Steve dolly again that that sounds very similar to what commissioner apostolakis's task force proposed Several years ago. So there might be some lessons learned there. Yep. Thanks. Okay. Sorry Ruth Ann, please Uh, Steve knows of it with Duke energy. Actually, mine's just kind of a question Uh, I saw that one of the areas you had listed was big data and I'm having a problem Understanding the nexus between big data and transformational change. So maybe you can explain a little further how that works sure, uh couple of things first off big data Is is in here because it was one of the areas that we were specifically tasked to look at Here on this slide the last bullet there And We're aware broadly of interest of utilities to use big data methods in their plans to Have used system performance data to to manage for example maintenance cycles Not really clear that there's a regulatory nexus there Potentially somewhere down the road I could conceive of it getting into areas that maybe Big data is used to make just to justify Intervals that might impinge on maintenance rule thoughts or something like that Um, we haven't really seen a lot You can see you don't see big data popping up in our themes because we really haven't seen a lot for us In terms of our regulatory framework We have had some discussion internal to the agency of How we could use big data methods to Search our information systems for example as part of inspector sample selection But it's that's Not something that has popped risen up to our themes here as something within our regulatory framework that we see an opportunity right now for a transformational initiative Okay, please if you could uh Yeah, you want to hand over to her Richard. Thank you Hi, jennifer plasquino with imperian services Just a suggestion. Um, I'm new to the industry, but uh power a long time power industry person looking at it almost stepping back and thinking about what your purpose is and Bringing in the right or not even the right a diverse Set of thoughts and people That might help you Be more transformative versus innovative So you might get people without nuclear engineering degrees or you know people in different sectors That could help bring some really fresh ideas to the table. Just a suggestion. Okay Thank you Okay, I think we have a question or comment in the back half in a minute West patrick cnwra A semantics aside, whether it's transformation innovation or whatever Uh, the biggest issue I think is that of change and change management and frankly in most organizations That I've been a part of over the years Management makes change sufficiently difficult that it is impossible to implement and uh, I just I guess both encourage you to try to deal with that I think it fits under your last bullet of culture Developing a culture of a willingness To implement a change no matter how small or large it may be Yeah, thanks west I I think that's critically important for two parts of our initiative. I think if if we If I can find the the tasking bullets So the first the first one there is is related to Overall the culture of the agency to support change in general And and vic talked this morning about his three pillars and and one of the propellers was Transformation innovation one of them was the leadership vision And model and and that's an area where we're exploring ideas about being more open to new ideas and and less averse to uh to enterprise risk in implementing new ideas as as kind of Catalysts if you will for for a more change oriented culture And then the the third bullet here is is related to how we would implement a particular initiative And how we would enhance the likelihood of success of such an initiative and certainly Effective use of change management tools Is going to be key to any of these change initiatives But I think I think the key to to the notion that this is not a short lived Activity for the nrc is is bringing about that broader perspective of an openness to change Which is you know, frankly, you know, we We can easily relax into a mode where we take the reliability principle of good regulation means where resistance to change And that's what a good regulator is But as you heard from uh from some of the commissioners this morning Our regulations just because they were the right regulation at the time they were put into place as the technology evolves as the performance of the industry evolves We need to be ready to to adapt to that and and be open to change all the time. So thanks for that I just want to put a Additional plug-in for west's comment. So we have reached out Internally agency and extensively outside the agency to look for just what west is talking about how can we Embrace and sustain a culture that Supports transformation and so we've gone to some other companies where they've had success and got some ideas But part of what we'd like to hear from you is if you have ideas along And what west is talking about about the follow-up to this which is going to be especially crucial to our work We would be very interested in hearing that Let's go start with richard and then go to rutham richard Good afternoon. It's uh mike mire southern company First I want to say we applaud this effort of transformation. We think this is very important and very needed Also, I want to point out when any organization changes like this It's obviously going to be difficult to change people's level of thinking to really shift the culture has been embedded for for so long Many of these organizations bring out people from the outside Just to challenge the level of thinking sometimes we can't see it ourselves I know you're getting input from external stakeholders, which is good But are you bringing somebody outside to work with the nrc on what changes you should make? so I think this is part of that but I I take your question Are we bringing in somebody under contract to help guide our process and and and we have not done that with this team? But as andrea indicated we've been going out and talking not just to people who are in our business But people outside our business um, you know one one of the We one of the organizations that the team went and talked to is an organization called di ux Which is a part of keeping the the department of defense up on the cutting edge of what's going on in the it world And and so they are Compared to us, you know, we're the we're the dinosaurs of innovation and and they're the the cutting edge of it So that's an example of of people that were trying to Help us get outside the box of our own thinking both in terms of of What we need to do to move the culture but also in terms of thoughts about what areas we might need to change I'll just add on to that as well. So that that's a Idea that we've heard, you know, we've heard need to look outward bring in diversity of use um We had one idea, you know send some of our staff to some of these companies that are Have been successful in innovation to bring back ideas. So we're processing all that Um, but to the extent that you have ideas on how to integrate that diversity of thought I mean you could say Higher new people. Okay, or is there a way that you could think of where we can integrate that diversity of thought Into our process within our current infrastructure Um any ideas you have along that would be very helpful Back of the room, please Hi, i'm rick grantum I'm independent now, but I was uh with south texas project for many years. I started my risk career in 1982 So i've seen the uh the entire breadth of risk-informed work And not work We solved many of these risk-informed problems that you're currently dealing with because we've now gone and reinvented the wheel again And It many times in my experience. I've seen a well thought out good technical risk-informed solution held up many many years by Lack of getting a finished review And I would contend to you that that's really one of the areas in terms of the change management issue that you've heard before and also in terms of How one manages through things like dpo processes Because it only takes one person to hold you up for seven years And those are the frustrations that you feel because we feel like we have good pras We have processes to make certain they're continued Well, and it doesn't look like that Intelligence capital that we have worked on for well since 82 and longer Has been fully leveraged and utilized by the nrc internally doing to increase efficiencies So i'm curious in a sense and along the change management How are you going to look at the existing capabilities and processes? And innovations that we've done in the risk world To improve the agency and meet your objectives okay thanks rick um the third bullet on this slide I think touches a little bit on one of the areas that you touched on and this is the timely resolutions to challenges and and It that's not necessarily just associated with new technology.  You know, I think one of the commissioners this morning talked about paralysis analysis paralysis by analysis, but Like also getting tied up with resolving differing views on an issue So one of the things that we've been talking to other organizations about is how do you break through things like that? Keep keeping consistent with our values of respect and cooperation How do we break through those issues and and get to resolution without dragging it on like that? so it If anybody again if anybody has experiences that that have been successful there, we're always happy to hear them Okay front of the room and then back Hi dan andrea terry rees southern nuclear Hey, i'm looking at your themes and your tasking from vic it seems focused on very much focused on licensing and change But what about um oversight? You know, we're now 19 years into the rop It's served us well, but after 19 years are we asking ourselves the question? Is it still the right model for today's operating fleet? yes, and uh, so so I think that That is a question i'll leverage to reinforce that that we're talking about we're focused on the transformation side But the innovation side is is just as critical And yes, there are people asking questions about the rop and and are there ways that we can adjust the rop I don't think you know when we develop the rop as you well know You know that was a clean sheet of paper look at the oversight process I think that the questions people are asking right now are i would say more incremental adjustments to the oversight process Some of them are bigger than others, but they are still essentially Changes to the oversight process and so there are those questions are being asked. It's just not something that we've I think we've gotten a few ideas aligned those line, but but with our Tasking being focused on new and novel technology. I think that's probably what's kept the numbers down in terms of rop But there is a certain amount of energy. I would say throughout the staff on on areas that we can do that better Hi, bill roscow with roles Royce And my comment deals with digital I&C I heard a lot about benchmarking us industries in aerospace and whatnot and that's terrific Have you considered benchmarking successful international utilities who've done digital upgrades? In the relationship between the the vendors the regulators and the oems and how they've how they've progressed we seem to be Excuse me stuck in the mud here in the us and and I have folks come in from Internationally and they're sort of amazed as to how we're caught in a quagmire here in the us and yet You know places like france are in their fourth generation of safety digital upgrades. So, uh, you might want to consider something like that Thanks, bill. That's a that's a great suggestion. We are meeting with some of our regulatory counterparts this week but I take your point that that If assuming we go forward with an initiative like in this area that that benchmarking with international vendors and Utilities would be a another useful insight, thanks Dan thanks for the comment that you made in my response Uh, I just wanted to add a little bit of additional information that we've even gone through the process of where we've had scrs approved methods And then another utility, you know tries to do the same thing And now we back to reinvent the wheel again where we have to go back And re-approve a method that has been re-approved And that has caused a lot of frustration and I would I would invite you to do Do one thing if you look at the categorization that was done in 5069 You know all of the components and functions that are really important And and if you can pull that thread through the organization I think that you'll find a lot of these efficiencies that you're talking about I I live this at south texas and saw that kind of thing happen to the organization Uh, so I would invite you to look at that kind of a Of a tool there to give you the information that might help Okay, thanks. Thanks rick. I and and I think what I'm hearing is what I would say is is in the Bin of the fourth sub bullet of the first bullet of leveraging existing reviews And I don't think we are as efficient or effective as we can be in that but I take your your last word there as as Uh develop tools to to identify those prior reviews so that we can be more consistent in Identifying them to leverage them that I'll just add a little bit to that Regarding the concept of using 5069 or some process to kind of categorize work It's interesting that we had heard from several other government agencies that they have some system like that So it is something we're thinking about and again if you have specific suggestions of what that might look like Or examples that have been used in other organizations that could help us think through that that'd be very helpful Okay, we've got the front and then the back Jason reamer nei Again, thanks for doing this my question involves the energy and the Forcing function to keep this going and really do it most of the transformation that's happened in the industry It's because uh severe market pressure Collapse of prices people had to figure out a different way to do it because it was their business How are we going to make sure that this thing really goes this time and we don't get caught into the groundhog day? because it's it's a It's a worthy endeavor But what's going to give us the energy to make this happen this time? So good good we're keeping the movie references going Yeah, so so thanks for that Jason and I and I think that that falls under the part of our our Initiative that's looking at what what's going to ensure the success of the initiatives And there's a lot of there's a lot of literature on transformational efforts and the importance of identifying the burning platform You know and so for for you guys the burning platform is your your market conditions I I will say when we went out to the nrc staff to solicit for participants in this team We were inundated with the response. There is a lot of energy within the staff I think there is frustration within the staff with some parts of our process and in a passion to move forward I can tell you there's a tremendous amount of passion on this team So I think that that's an important part of it I think building the broad support for the initiatives Which is something we'll be working on over the next six to seven weeks Within the agency working with the the management teams working with the staff to to build Alignment around these are important things to do and we need to do them in a In an expeditious manner All the way up to the support of the commission Which is ultimately the product that vic has asked us to produce is a proposal to the commission and get their endorsement for it And and so that that I think will will help move us along the path Uh, then I think that's the other piece of the tasking is what are the things we need to do to to uh To sustain that momentum and and not get mired in the details of working out the transformation initiative And I think that's going to need Continued leadership focus and continued just shining a light on this It's going to have to continue to be a high priority for the agency whatever Initiatives that we propose that the commission endorses is going to need a continued High priority for the agency and and leadership alignment to continue to move it forward So There's a bullet there under culture the second to last ones is organizational focus. It's pretty amorphous the words there But really what that means is we've heard from different organizations what has been successful and sustaining what we will start And there's different models out there that have very low varying levels of success Some organizations have set up a separate separate organization just to focus on transformation Some organizations may have a one individual as a focus other organizations don't have that and maybe it's just a um a leadership model So again part of what we'd like to hear from you is what has been successful because that is going to be a critical piece Moving forward and that's what that bullet meant Okay back of the room Yeah, my name is shawn clark with ammi risk solutions uh transformation And innovation are a great thing in and of themselves however Left to themselves. They can also create chaos Okay, without a proper focus without A sense of what you're working on the priority of those items Scheduling deliverables all those things and how they affect The people who are here especially the utilities Can you can you talk to how you're focusing your efforts? So they don't just become an exercise in transformation and innovation, but in fact Really are solving things that are plaguing this industry at this point Yeah, thanks for that Yeah, we have we have uh Not been spending a lot of time on that for the last six weeks because we're really in the storming phase of the project And and really just looking to take in as much as we can We have been that I mentioned there's over 500 ideas. We've gotten from the staff. So the team has been The team early on established a set of criteria for evaluating these ideas and prioritizing them On on their transformational nature the impact they would have the benefit to complexity the the Whether whether this is the right time in the process for for a transformational so there So so that's been Kind of the prioritizing piece of it I think over the next six to seven weeks as we look to translate these Ideas into themes and then into actionable initiatives We'll be looking at some of the exact things that you just talked about is is What what's a reasonable timeframe to accomplish this? What's what's the benefit of accomplishing this? What's what's uh What are what are the measures? You know if we pursue this initiative, how are we going to measure the success of this initiative? What what is it the impact going to be to the nrc? What's the impact going to be to the to the licensee community from from this initiative? So those are the kind of things that we will be focusing on As we develop these into actionable initiatives Fernando for ante with apri Speaking of groundhog day, I think we could probably mention more Risking form initiatives in the past and movies that have essentially failed or haven't gone far enough Just to mention one the near term task force recommendation one Which was the one that was driving really the ideas behind all the others Was one that never really went anywhere and there was the apostle like sarah moref respiration initiative So one thought maybe a suggestion is if risking forming is going to be expanded As well as improving the the current risk informing activities Then there has to be an overarching recommendation that is bold enough for the commission to actually get behind it Because some of these initiatives didn't go forward because the commission itself was not comfortable with them. So I think You know, it's a good theme. We have explored it before I I believe probably will not succeed if we try to do a piecemeal to try to let Each person or each group try to interpret what it means to them, especially if it's a cultural change Um, I think there has to be something that is overarching about risking form If you truly mean that that's going to change and the commission has to have behind it That front end. Oh, thanks for that. Okay.  Thanks So so the commission has an overarching statement of policy on the use of pra. We've had it for 22 years I've read it a couple of times over the last six weeks and I would argue that Perhaps are we are we fully living into that policy statement? Do we need a new policy statement or do we need to live into the policy statement that we have? You have a thought on that? I think in my mind And this was discussed in some commission briefings early on last year Um, I don't know that a policy statement is necessary. I'm I think the policy statement is clear enough The question is, you know, we've been living on the shadow of red guide 1.174 from in years So I think the question is do we need something in between that? That applies more broadly and it's not just plan licensing basis changes That explains what does it mean to use risk principles? What does it mean defense in depth when you're talking about Digital I and C what does it mean for areas? I haven't seen those type of concepts And so maybe something at a at a high level enough Because I don't believe asking each individual group to figure out. It's kind of makes sense But it's something that has to come from above and has to be filled with Guidance and understanding what it means to different applications. So that will be kind of my answer back Um, you know telling people just go look at red guide 1.174 I don't I don't know how that's going to help anybody at this point in time At the same time existing processes on risking form can be improved as well And so if that document comes from a higher level, you might make more Success than not and again, we try to get there somewhere. So that has to be by end That's something like that can happen and can be put at the right level Thanks Tom Weber. I'm a director of rake affairs at Palo Verde I I think the first four bullets that you've gotten into themes there. Um, I support the incremental Suggestions and ideas on those. I think the last bullet the culture is the key one at Palo Verde We actually have a leadership model And we rolled that out when we transitioned out of column four And I remember personally how is a book Going to make a difference, you know a book of philosophies and strategies How is that going to really make a difference? I couldn't I personally couldn't see it But it wasn't until the leadership from the top down Advocated daily use of that model. Did it actually make a difference? And so that we've we've I think at Palo Verde We've found some advantages and and improvements in the leadership model. We continue to use that now and we've shared some of that those thoughts with members of nrc nrr during the course so Thank you. Thank you, Tom Okay, any further thoughts ideas opinions questions that folks have I've had a Nice slow trickle of people come into the microphones, which has been great Please back the room This is philip simon from new logic solutions I come from a Different industry oil and gas chemicals So I look at it from in this discussion from that perspective And I think several people here did bring up this topic, which I'm going to reinforce right now Which is that Very often we look for solutions. I mean this been my experience. We look we tend to be given solutions to pursue before we even figure out why we are doing this and what really it should be so Sometimes I think the transformation at the nrc level. I I believe is the intent is to help the nuclear industry become profitable and Successful because they're able to function now the question is can they function more efficiently? If that's the reason then I think It's probably a good idea to get a lot of grievances from the industry I mean, this is what we would normally do in consulting to find out. What's bothering you? What is holding you back? What are your hurdles that's that we can take away? So that you can be profitable and maybe looking at it from that perspective And I think somebody brought that up here about why we're doing it. We can determine what is the Priorities to give for the transformations on the on this side of the fence so that they can be more successful I don't know if I'm Saying the same thing everyone's already thought about or just Another perspective on it Yeah, thanks. Thanks for that I think There are aspects of this initiative where We hear messages that it's it's not a question of the profit profitability of the nuclear industry Although I know for a lot of you that's a major concern But in some areas we hear we are a barrier to safety For example, the digital i and c if we're an obstacle to The effective use of digital i and c to as as vik was showing the reduction in in initiating events through scrams If more you were more widespread use of digital i and c would reduce initiating events through scrams That could enhance safety if it enhances reliability if it enhances the operator interface There are a number of potential safety enhancements out of digital i and c But that the lack of clarity and reliability in the regulatory process is is an obstacle to licensees making that investment That's not a place for a safety regulator to be so so I think At its most basic We're looking at the current environment You know accident tolerant fuels is another one could could be a a significant safety enhancement We want to be able to Regulate that in an appropriate manner without being an obstacle to that safety improvement So I think at the at the root of this and and I think it's part of the focus on new and novel technologies Is there's potential for safety enhancements where the regulatory process becomes a barrier to achieving that enhancement That is not a place for a safety regulator to be And we want to identify those areas and not be in that place. So I think that's probably a Where I would say that at the root of the task that this team has been given Matthew Gordon office of research I appreciate the list that was presented. I think you're on the right track, but I would also add managing current data Managing current data. This is a very significant problem within the nrc You know as an example, we work with a number of offices and different branches And a senior reviewer in one of those branches branches Without cynicism and without exaggeration is telling us We spend about three quarters of our time our review time Finding and refinding the information necessary to do the review And that's a cultural problem where if I may and simply my perception is I don't think the scs appraisal process adds a lot of incentive to say to their supervisor during appraisal I made sure the branch chief under me Managed and maintained a database of his predecessor. It's not innovative. It's not really change. It's just maintaining things But it is a very significant issue because it drains time resources from both the licensee and from the nrc And this extends throughout our it infrastructure We use google to find things in atoms because atoms doesn't work Every and every people starting to laugh and chuckle and nod their heads. We all know this It's an open secret and it drains morale. So please Managing data is a very crucial part of this transformation initiative. Thank you Thanks Hi, uh, pete carlone from mpr associates What's the average age of the first people on the transform the nrc organization team? And how are you leveraging the youth and creativity within the organization? In a way that those of us that have to carry on the industry into the future Who will have to live this transformation will be able to do that Yeah, thanks for that. I don't have the age demographics, but I can tell you that that the team You know, I mentioned in my opening remarks that that we have a breadth of experience in the team That breadth of experience ranges from I think in the neighborhood of 30 years at the nrc at the high end To I think about three years at the nrc at the low end And most yeah, I think there's there's kind of a bell curve So I think a lot of the a lot of the transformation team are in the range of 10 to 15 years at the nrc So we are we are looking to Kind of a mix of Level of experience level of familiarity what with what we do as well as just bringing fresh perspectives to to the effort So so I think that that's a that's a great insight there and I think it's important that that We let the people who are going to be living these processes for the next 20 30 years be the ones who are helping to build them Hi, Dan. Hi Andrea. My name is honey. I'm with the nuclear energy agency And we're part of the organization for economic cooperation and development and we're based in france and and in that job You might probably know this I have a chance to work with the regulatory bodies from all around the world And research institutions from all around the world And I was looking at your comment there about leveraging existing reviews. It's under the expansion of risk informed licensing But my observation is that I've seen in some countries a readiness and ability to accept Regulatory reviews and information from other countries as input to their decision-making process And I think it it can work So I wonder is this something that NRC might be thinking about with some of the areas that you've been stuck in or we've been stuck in I should say, you know Obviously, I'm from the NRC but working at the NEA now But like in digital instrumentation and controls But perhaps even looking forward with advanced reactors because you know other countries are Moving ahead with looking at some advanced reactor designs and as I mentioned it seems to me that in some cases Some regulatory organizations have been able to use NRC input NRC reviews as input into their regulatory decision-making. So I'm wondering what your thoughts are on that Yeah, thanks. Ho I think that's a I think that's a cultural shift for the NRC. So I think it could be transformational like going back to rick's comment earlier about You know identifying our own reviews and leveraging them Is is would would be something new for us. It would certainly be new for us to to Look to another country's review of a technology But I think we should definitely look at the merits of that And I think the hazards are the same Wherever we are in the world and and so we ought to look at Opportunities to leverage the work that others are doing I think we'll probably with the with the breadth of Options on the menu for advanced reactor technologies And I think other countries are getting out ahead of us in in the process on those We ought to be open to looking at the work that others are doing Okay, um, Dan. I thought we had a slide that had some questions on it for the group We've had we've had this one up Yeah, maybe maybe we could see if this gets a little bit of of discussion going here Um any of these questions resonate with you What do you view is the most important area for transformation of nrc's regulatory framework for new and novel technology? How would you propose we revise refocus our regulatory framework to improve this area? What obstacles would need to be overcome and what would be the benefits? Just wanted to kind of focus on this slide a little bit Just to see if this kind of got some conversation going Come on. Here's your chance. Oh, I got a hand right here Who wants to get to her first? All right, it looks like richard's got her ruthans turning around looking confused Looking for others My name is hiroko kondo a change management consultant from tokyo and um, I have a couple of questions And what is your expected outcomes for to realize the transformation? And second thing is that and I've heard that there is a kind of barriers to realize the transformation But I thought there is a kind of a strength of nrc to realize the transformation and what are the strengths of an nrc For to you know realize the transformation Thanks for that. Uh, so expected outcomes I think I talked a little bit earlier about you know, we we are at least receiving messages that we are a barrier in some respects to the Utilization of technologies that could enhance safety either at existing plants or or in in future designs And so an expected outcome would be that that perception is resolved That uh, we have a regulatory process that is consistent with our principles of good regulation to be independent clear open reliable and efficient and and results in in a process that licensees and applicants have confidence that they can work through that process and and Receive the expected outcome in the licensing of the technology. So I think that's probably the the most substantial core expected outcome of this activity um I I think the second question I Understood perhaps the stability is a strength of the agency reliability in a regulatory culture tends toward A inertia that needs to be overcome to implement change uh, and historically we tend to We pride ourselves in being a continuous learning and continuous improvement organization But we make changes that are incremental In approving improving our efficiency or improving our regulatory framework So I think in in this particular case We're asking ourselves in light of the feedback that we're getting are their particular areas where we do need to start With a clean sheet of paper as we did with the reactor oversight process um, so I think that uh the strength I guess I would like to see the strength of the agency being responding with appropriate change where change is needed And we're incremental where incremental is needed and and transformational where transformational is needed And I think the challenge before this team is what are the areas where transformation is needed and needed at this time And again, I want to remind folks that coming to a microphone at today's session is not the only way that you can provide your input Uh, if you'd rather provide them on the cards, um, we do have those and our kind of have some people collecting those as we go Uh, you can also send email to transformation dot resource at nrc.gov Looks like we have a couple hands up here in the front Jack robe excellent Dan, I think I understood that the outcome of your uh group is going to be some recommended areas to pursue transformation um Assuming that the commission endorses that what would be your expected? Uh, involvement for the industry in formulating the detailed structure for how that transformation will go forward I think it's going to depend on the the nature of what we recommend So so if for example, we recommended that the agency pursue endorsement of a a standard that sets requirements at a higher level for digital inc Obviously that is going to at some point get us into rulemaking and rulemaking It follows the procedures act and takes The time that it takes and the role of engagement will be for the industry to comment and participate in the in the standards I think one of the things that we're looking at one of the things that we've learned about transformational efforts is they need to have Quick wins So one of the things that we're chewing on is there a way to pilot that So that might be an opportunity for industry to engage in in piloting a digital system under a different standard That the agency might be evaluating endorsement of If we if we pursue You know something under the first broad theme there of systematic expansion of risk-informed licensing That may not require changing any rules that might be more in in our review guidance to our staff but I think that there would be a Need to engage the public in the development of that guidance and how we're Changing our approach to licensing and that's going to impact How licensees prepare license applications? I would think so So I think there would be probably a less structured Engagement than the rulemaking approach, but I think we would still want to be engaging with Our public stakeholders on how we are going to approach that so I would expect that Once the commission decides what Initiatives they're going to endorse what the nature of the initiative will determine what the nature of engagement will be But the one thing I'm confident of is there will be engagement Hi, tammy bloomer usnrc I wanted to focus just a little bit more on culture and keeping the movie theme going back to the future You've mentioned a couple of times the the white sheet for the rop What did we learn about our culture or what we need to do to change the culture in order to implement something like that? And how would that apply now or does it apply now? I think We are as an agency fairly risk adverse And so to change a culture to take something that's transformational and change it and to continue to let it evolve Over long periods of time is very difficult for us So do you have anything that you've thought of that you've looked at to address the culture aspect? So so thanks tammy we're we're obviously our tasking had a lot of cultural aspect to it and and you can see the themes here under culture and and The good news for the nrc people is it's not us. It's just people um and we're people there is a there is a level of comfort in in the way we do things And there there is an inertia there that we need to overcome and that's overcome by Organizational focus you see there is it it's consistent messages in leadership. It's sustaining that focus over time It's demonstrating the quick wins that I've talked about a little bit At some point You you got to move forward with the change and some people will come to the change reluctantly And and then they will see The change that you're trying to create and they'll come along and come on board So some people will be on board right at the beginning Some people will come along at different stages And we need to build that into the communications and the change management for any change initiative But especially for a transformational initiative To to bring people along continuously throughout the process um, I think you know one of one of my recollections of the rop was being at a A seminar of regional inspectors about six months into the implementation of the rop and inspectors getting up and talking about Findings that they had processed through the system and other other inspectors Who were skeptical of the new system and their ability to process issues through the system We're saying wow. Okay. It is kind of working. So You know, I think some people will be on board and and share the vision Some people will need to see the product And you need to keep the the focus and the burning platform if you will going Throughout the process to bring everybody along at the pace. They're able to come along So we spent Four or five weeks now gathering input and kind of as Dan said in the storming phase and and We are kind of moving beyond that now have had these themes and we have been thinking about What has worked in the past and what hasn't worked in the past and Previous efforts the agency has taken on through project aim. You know, somebody already mentioned the work that the plethora of work That's been done on risk-informed initiatives in the agency and trying to study Um where those went what worked and what didn't work to try and gain some insights Um into the cultural shift and and what will work best now Tom's I cry any eye So the rp was brought up a few times here, but it sounds like the suggestions that you were getting you feel are incremental Um, I think part of this effort is looking at not just a new technology for the existing fleet, but new reactors I think reactors that are smaller and more compact Do you see any need for transformation in the rop for a reactor? That's, you know, two megawatts Versus a thousand Yes, I think I think the question is when's the time for that? Um, you know, I think we're we're in the the stage of of learning what the technical issues will be for the Licensing of those technologies. I think as as those advance We'll get to that point of needing to say okay does a reactor oversight process for the existing fleet of large light water boiling and pressurized water reactors fit to a You know two or a seven megawatt molten salt or high temperature gas cold reactor obviously not So we will need to rethink that, you know, even even for the large light water ap 1000 Is going to have a little bit of differences in in the oversight process and and we have Worked through that for the transition to operation for vogal when it gets there for for Totally different technologies. Yeah, we're going to need to rethink the oversight process I I think that's going to come at a little bit later point in time Jack robe. Excellent. I'm glad tammy brought the rop transition up That that was about a four-year process two years to formulate the new rop and two years after implementation. It was routine The motivation for that was a one-third cut in the nrc budget That's pretty motivational How do you anticipate Generating that same level of energy to make these kinds of transformations. You got incentives down here But i'm just trying to envision The incentive for fundamental change and the risk behaviors of the agency When we've been doing it this way for so long So that's something we've been chewing on a little bit. We we had a really interesting talk with a guy who's who's done Four startups and he's on his fifth startup and and he and he talked to us about how motivated people were Because he has created 27 multimillionaires and we said, you know, okay, we're a government agency I don't think that's going to work for us But we do have incentive programs for the nrc staff So one of the things we're thinking about is is are there different ways that we can approach our With the resources that we have available to us the the way we approach our incentives relative to that because we We talked about a little bit earlier about the leadership model and and the creating You know vick talked about the leadership model applying to every nrc employee as a leader. It's not positional leadership. It's it's Effective leadership at every level and and that model including Being more open to new ideas and less risk averse in in embracing new ideas We'll have to think we're so one of the things we're thinking about here in the in the theme area For culture is how does that apply to our incentive programs? But I think you know you You started that question with the the one third cut to the resources Which is more of an institutional level of motivation I will say That the fact that we're doing this the fact that vick charted on this Us on this effort the fact that you heard reference to this effort from all three commissioners this morning I think there is an institutional energy behind this at the highest levels without It's a catalyst like that. We just need to deliver on it So we don't get the catalyst That kind of catalyst And we don't have the same incentive we had back when we developed the rop But it kind of goes back to what dan was saying earlier that In just soliciting volunteers to work on this for we're inundated. There is a institutional Desire to move forward I don't know that I could speak for 100 of the nrc staff, but I work here I work for a long time and I think it's inspiring to think about what we could be in the future We want to remain a relevant regulator. We don't want to be a regulator that stands in the face of a safety improvement I think 99 of the people who work in the agency. They want to do the right thing And to me that rings true. I think it rings true for a lot of the staff at the nrc We haven't heard from the back for a while. So let's go there and then we'll come back up to the front Dave lochbaum union of concerned scientists. You mentioned Quick wins a couple of time Could you really have a quick win with digital i&c or advanced reactor technology? If so, that's a pretty loose definition so so the Yeah, it is it is a Comparatively loose definition, but I think you know, we're we're not going to do a transformational change to digital i&c in three months After we're done with this project, but I think if if we can Yeah, if we end up say with a path that's looking at endorsement of an alternative standard approach to Licensing digital i&c If we can also in parallel be be working to pilot that approach as once it's sufficiently developed You know, yeah, it's not it's not a quick win like we issue our paper in the next Monday We're celebrating that but I think it's it's incremental progress and it gives some confidence that the process is moving toward a A successful outcome. So so I yeah, it's a relative term but I think one of the one of the key things I've picked up in in looking at transformational efforts is is that that Promising somebody six something six years from now and and that's all they're gonna, you know, they get to wait for that Is not something that that inspires confidence in the overall process, but if you can show progress toward that Uh, so that's part of what we'll be thinking about as we as we Develop these proposals is what are what are some ways that you can get? Some demonstrated success is just early in the process. They give you confidence that it's going to move toward a successful conclusion My name is Robert Shapiro. I'm with the Dwayne Morris law firm and I've represented Various clients before all sorts of federal agencies federal courts deadlines Nothing focuses an organization. It's the bottom bullet there Organization or an individual like a deadline and I can't think of any set of clients that I've had that have been more Challenge than electric nuclear utilities in terms of dealing with their regulator in terms of the Unpredictability of when they're going to get a decision and I would urge your group to consider The agency imposing on itself deadlines of various sorts that could actually Again transform the agency including up to the commission To get deadlines to get decisions out in some kind of reasonable time frame Yeah, thanks. Thanks for that and and I would acknowledge that that's an area that the nrc has been trying to do better in in our licensing processes as an example of of meeting our Deadlines we I'd acknowledge. We don't have the greatest history on meeting our own deadlines. So so So I think we need we need to set them, but we also need to meet them Simulate the discussion a little bit to get some of your thoughts that bullet there on timely resolution to challenges is kind of along those lines And so the thought is are there ways when you have a challenge in an organization with an issue that challenges our regulatory framework? How can you elevate that issue and allow us to move forward quickly? To meet deadlines and so if you all have thoughts on Constructs along that line that have worked that that would be helpful feedback for us because we have been thinking about about just that issue Okay, let's go to the back of the room and then back to the front All right, Tony Zimmerman Duke Energy Uh, could you please elaborate on the second bulleted theme that you have there on additional flexibilities for licensees to make changes Is is that beyond the higher level digital standards you mentioned earlier to include potential changes to 50 59 Yeah, so that that one, uh, I think comes out of a number of comments that we got internally related to staff spending time on Licensing reviews that have limited value from a safety or security perspective. So I think broadly that would include Rethinking the framing of 50 59 as well as say 50 54 p for emergency plan changes 50 or security plan changes 50 54 q for EP plan changes So really it's it's getting to are the thresholds defined in our current change management mechanisms at the right level To ensure that that both licensees and the nrc staff are focusing their time on truly Safety significant issues Hi, my name is Tonya hood and I work for the nrc and I just wanted to go back to the comment that andrea made earlier when The edo called for staff to participate and join the transformation team There was a lot of buzz in our agency for that and it's not that there's a lot of members in the nrc that aren't Thinking of moving forward with transformative actions a lot of us Come to work on a daily basis with an internal drive to do what's great We work here at an industry and in an agency that watches over the safety and culture of The environment and the people it's not just what's happening in the industry that's being monitored My family is also monitored by the work that I do The Level of detail that I put in and the thoughts that I have to make us better to think of how we can do our Jobs better is also an assistance to myself and my family as well as those around me So as an agency a lot of our Individuals here because one of the first few things I was told when I joined the nrc is you are a regulator Here to do great things for the public and for yourselves So we have the initiative internally. It's not that we have to have a whole lot of external incentives to get us to Do our job. We know our job is important and we take pride in doing it. Well Thank you Okay, we've got a few more minutes left In the session. I got a hand right there Richard This is rick grander again. I promise has been my last statement Going back to your uh, what are the priorities and uh, and then what you can suggest to help I do believe that the the use of the risk technology is the highest priority because it cross cuts every organization in the nrc Everyone has risk for their perspective and it can be used in a in an overall perspective That the question I would ask on the second bullet though. There is what kind of tools Is the nrc going to give the organizations? How are they going to know what's risk? Important what kind of training are they going to get? Um, those are the kinds of areas that I think need to have some focus What kind of performance indicator are you going to put together that says, hey, we focused on the right things And we didn't focus on the other things and those are real kinds of tools that are from a utility perspective Every time we did a risk informed application. There was a full Training aspect there was a full do they need a new risk tool, you know some way to get information So I just offer that to you to think about on the the feedback Thanks rick Okay time for one or two more comments and again, I'll remind you This is definitely not the only way that you can provide your feedback We have the transformation dot resource at nrc.gov email address Or you have a little bit more time to fill out your comment cards to be collected for this session Anybody who's been sitting there just biding your time waiting with a comment that you just had to get out before we ended now Now's the time We do all right. We got one look at that Barbershell with Duke Energy. So all of the transformations I've been involved in Live or die on the first line management. The first line management supports it.  So what are you doing about getting the first line management fully aligned with this process? so I appreciate that I think That's probably something we need to focus more on we have Been at through this stage of the process going out to all employees meetings throughout the agency getting input Throughout the agency. I think as we go back over the next six or seven weeks We're looking for organizational alignment to support the initiatives that we put up to the commission So I think we'll take that as a reflection that we need to make sure that we We're bringing along the first line management as well on on that process, but I appreciate that insight And we do have a few ideas Along the lines of how organizations can hold themselves accountable to change in different ways that different organizations have instituted accountability in the organization for making a change So again any thoughts you have on the best way to do that and what has worked would be helpful All right last chance at the microphone before I turn things over to dan to close our session Okay, dan, please Well, thank you lance and thank you everybody for sharing your thoughts with us as well as your questions I think that From here over the next six weeks or so This team will be taking these themes crafting them as as we've said into What we see as the important initiatives to put forward before the commission It doesn't mean that it all of the energy that went into 500 plus issues from the nrc staff Is going to be lost once we narrow it down to a couple of initiatives There was some talk this morning about the innovation forums. I talked a little bit about it here We will be using those forums to take the information that doesn't roll up into an initiative So we don't lose the energy and the good ideas So I mean there were some even that I heard today from nrc staff about things we can do with our own information management systems to improve And so we'll share those with our Chief information office as well So I mean there's things outside of the regulatory framework that we can do to be more efficient There's a lot of things in the innovation forums where we have our own staff can say gee This this system isn't working as well as it should or this bugs me or there's ways to to Get those into the system and bring about change So I think you'll continue to hear more about transformation and innovation at the nrc in the years to come As far as this particular project we as I said at the outset We'll have a paper in may That will put this team's recommendations with the support of the senior leadership and hopefully the first line managers to Recommend to the commission particular things that the agency should pursue in the very near term So I appreciate your attention to this session to this issue And your feedback and questions Have a wonderful afternoon the next session begins at 3 30


on my talk is named FA Notify HSM API and I will explain the name, but basically what I want to get to is something else. I want to get to discuss a problem and a solution that John and I have been working on and I just want to give you some backgrounds on how we got to the problem or what it is. So HSM is acronym for Hierarchic Storage Management which is like a very, very old term for offloading files from disk to tape and FNATIFI is how I want to create modern HSM implementation using FNATIFI. I have a wiki on that for the press. Yeah, maybe currently to state a bit about the motivation, yeah, you want essentially to offload the stuff like to cloud storage, for example. Yes, so my employer, Citera Networks, they build cloud gateway solutions which are cache to cloud storage. You have local NAS, actually people that customers used to have local NAS, but they didn't used to have cloud backup for it. So now they're replaced with a local NAS, fast NAS, many local users and it's backed up by a much larger and much cheaper cloud backend store, slower tier and the local cache, the local NAS doesn't have the disk space to hold all the cloud name space, just parts of it. So it needs to evict like page in and page out files from the cloud, that's the general use case. Windows as an example of the operating system has an API for this. If you know Windows a bit, if you've seen like a Google Drive or OneDrive, they have an API with like these icons of file like with the cloud that the file is not available locally. If you access the file, it will be downloaded from the cloud and the operating system provides some infrastructure for that like a file that's placeholder is marked with something called reparse point which is a persistent marker on the file and then when the file is accessed, a driver gets called, that's the projection, projected file system and that specific driver has an up call to a cloud sync engine which could be Google Drive, Microsoft OneDrive or whatever. So they have the infrastructure for that. Linux doesn't have anything inherent for that. So products that do this sort of thing like Cetera products and other products may, I mean we use views, that's a common implementation for gating access to files and getting them from the cloud or the local. We use views that comes with all the problems that we've heard about in the two sessions before me and I hope those problems will be solved, BPF for faster read-deer and high rearing, they can only help because honestly, I don't think we are going to be able to get rid of views for all of our use cases but what I'm going to talk about here is how we can get, not rid of views but use a different alternative for the same use case using FA Notify. DMAP is an API that Unix systems used to have. Linux only had it in XFS for a while and it's an old API from the tape ages, like it's not enough for modern day use what I, for cloud, offloading to cloud but it exists, remnants of this exist and you know about it, like Punchhole is a remnant of D-Mappy. 2010, the D-Mappy hooks, the callbacks to user space were removed from XFS. With this comment, if we'd ever get HSM support in mainline, at least the namespace events can be done much easier, say in the VFS instead of individual file systems so this is what I'm trying to do now. You know, this was like a deja vu for me, even the D-Mappy stuff but what I was trying to remember is if I remember correctly, there were basically three states you could have. The file is present locally, the file is not present locally but you know its name or maybe you know it's a name and it's a file and then in between you had like, you had enough to satisfy a stat request, you know it's creation time and you know it's file size and you know it's time steps. I'm not going to, I didn't learn the D-Mappy standard. I think that's what Windows, like the Windows API you refer. Yeah, but for our solution, yeah, we use placeholder files that are just sparse files. So first, when you access a directory that wasn't available locally, the directory is filled with sparse files that have all the metadata but don't have the data and when you access the data, the data is being downloaded. So basically you have two, I think Windows had three. It doesn't matter. I guess what I'm going to say, so you have two states. You know the name of the file and it's sparse or you know it's data and everything. Yeah. So there's two states total. That's right, there's different implementation with different states but yeah, that's the basic thing. So here is an implementation of an HSM engine using upstream FA Notify. It can be done because FA Notify was introduced for the anti-virus case. So it knows to intercept access to files in order to scan for viruses. So you can intercept the file on open event, open permission event and if the file is sparse, placeholder, you can use that open due to fill the content from the cloud and when you want to evict the content of the file, I have a POC for that. It's pretty simple. You can use exclusive write list. Take exclusive write list on the file, punch hole. Everything works great. I mean it's very naive HSM but it works. It has many limitations like you'd have to fill the entire movie that you want to watch at open time. So it's not really practical for modern use but it works. The other part of the DMAP or HSM API is monitoring which files were modified, which files are dirty that need to be uploaded to the cloud. I guess Windows has that internally with NTFS anyway but with FA Notify at least since 4.20 or 5.1, you can at least watch over the entire file system for modification events and this is important for our use case because we typically deal with many millions of files, even only in the cache, in the front, fast tier, there could be billions of files and of course the slower tier may have larger namespace so it's important to have some sort of large scale way to monitor for changes. So what I've done in order to facilitate modern HSM, what's in this slide is POC patches. This is not upstream yet although the last one is. It's POC patches, I've posted them or maybe just posted the link but they're simple. They are not very controversial, they are small patches, small changes that can be done to FA Notify to make it available for good HSM implementation. The first one is a lookup permission command. The lookup permission just allows you to populate the directory on demand when it's not available locally. Report access range is just to facilitate the access permission event with access range information. So when you're watching a movie file from the cloud you get a notification for access to a specific range and you can feel this range, very simple. The last one, a victible marks, I'm not gonna talk about it right now but it's already upstream. It has to do with scaling, scaling FA Notify to be able to deal with a lot of files and the one before last, crash safe change tracking. That's something that I've been working on for a long time now. I've had several solutions, I've talked about them in the controversy, I had overlay snapshots and then I had a different version of overlay snapshots using FS Notify as the hooks. But essentially it boils down to, in addition to open permission event and access permission event, you need pre-create, pre-name chain, pre-name space changes events. You need pre-create, pre-delete, these sorts of events blocking in order to be able to track the changes in a crash consistent way, whether it's in a database or whatever. What I do internally in our product is I store the markers for this directory has been changed inside the same file system. So I get a crash consistent state between the file system and the markers for changes. I just use directories. I do make dear of some, the ID, the ID of the directory as an indication that something has changed in the directory. So I get crash consistent safety, at least in XFS for that part, for free. This is a demo that I don't have time to show of utilizing the extensions that I've shown before. I just wanna have this slide just to show an example of what I did. I took, I just looked for a simple upstream fuse implementation which falls under the category of HSM. So I just pick one HTTP DFS. It's read only HSM. It takes a URL to an HTTP website. And as you access it, it lazily downloads the index listing and lazily fills the files, even ranges of files. So if you do the command that's listed on the second line, like you mount the fuse file system to kernel.org repository. And then you want to do, to extract the head of the tar ball of this firmware and list the beginning of the listing of the tar ball. Then it lazily populates the directories on the path from the website into the local cache directory. And then it just downloads the first megabyte of this tar ball and uses the local cache to open it. So I took this as is, and it works. I mean, if you do this example with the upstream HTTP DFS, it works and it does everything lazily. I just added the dash dash FA notify. And I replaced the fuse implementation, dropping replacement with FA notify hooks. So when you do dash dash FA notify, slash www is no longer a fuse mount. It's a bind mount. It's a bind mount to the slash cache directory. But the bind mount slash www has an FA notify mark on it. So if you access through www, the LS, www, it intercepts the access permission event or lookup permission event and fills the directory. So you get the same, but without fuse. For this use case, anything to say here? No, stash www is just a bind mount to the slash cache. Slash cache is benign. If you do LS, you see nothing.  If we have time, I can show the demo. But I wanted to get, not to this slide, which is complex, but to the next one, which is more complex. I want to try to get you to understand in order to try to get you to understand the problem in order to try to be able to sell the solution. So this is not so complicated. Maybe I made it complicated, but this is FA notify today. So FA notify today, this is the events happen in this order by time. This happens and then this and then that. This is one process that's trying to access the file. Right? No, it's clone file range. Nevermind. Some access to a file. And this is another process that's doing free thought for some reason. Maybe it's an LVM snapshot or don't know. And this process generates an access permission event, a blocking access permission event because the file was accessed. And then the Antivirus agent or my HSM implementation intercepted access permission event because the source of the copy file range file is a placeholder. It doesn't have data, for example. So it intercepts the call and then it needs to fill the file. It needs to fill the source of the clone file range. So it needs to write into the file. So then it goes into write system call and here we seem to have a loop, right? Because this process is writing is going to generate another permission event for the right. So inherently it looks like we have a loop but that was already dealt with when FNRTify was first merged because it's the same loop. Antivirus engine wants to scan the file. It needs to read the content of the file now to scan it. So this is solved by that FNRTify providing a special file descriptor which has the F mode no notify flag set. So the listener gets special privileges to access the file without generating events. So that's the basic loop that's easily prevented but I'm showing another deadlock here, another protection deadlock that I think is currently possible in upstream. What happens is this is why I use copy file range and not just read. Copy file range takes freeze protection before copy file range starts. Then the process that's handling the, maybe Antivirus scanner or myHSM, maybe Antivirus scanner wants to move the file to quarantine. It wants to make a change. So it goes to the file system and wants to make a change or write a log file or whatever and that change is going to also want to take freeze protection. And if it's on the same file system like you're moving the file to quarantine, you want to take freeze protection from this thread but if this guy comes in between and starts to freeze, then this one is blocked by the freezer. It cannot start the right and this guy is blocking the freezer from continuing so you have a deadlock. I'm sorry if that wasn't clear. It's a deadlock that I think is currently possible. I mean, it's pretty rare maybe but too rare so I don't know why nobody noticed it but exactly. So this is a deadlock that, so I wanted to solve this deadlock because it's probably more common in myHSM example than with Antivirus scanners. So the way that I approached it is currently the access events are hooked from within the LSM security hooks. So the LSM security hook has a hook security file permission or something like that and FS notify hooks into that LSM hook. So first of all, I added an explicit FS notify hook before taking freeze protection. Okay, I'm not inside the LSM, I added another one and I annotated all the FS notify hooks, also the ones within the LSM, I annotated them whether or not they are called with freeze protection taken or without and the ones that are taken without freeze protection are reported as with the flag fan pre-VFS and then the implementation, the engine knows if it's safe to do a write or not and then it has the option, for example, to just block the access instead of filling the file. But in our case, because there is a hook before copy file range starts, the implementation gets an opportunity to fill the file and then the second hook will most likely be okay. That's the solution that I gave to this problem. Maybe there are other solutions, I don't know, but this wasn't hard to do, that wasn't so hard to do. Maybe questions about before I go to this slide. I guess what bothers me is that the example I was thinking of was Apple I think and Windows, their explorer, their GUI had to be aware of these kinds of things. So the app really needed to know whether the file was offline and all that stuff and needed to know that.  Okay, you're talking about the offline bit that gives a hint to the applications, don't poke into this file unless you really want to read the content of this file because it has consequences. Well, the HSM solution is independent of that. I mean, applications can, I mean, we can, for example, talk about exporting offline bit with Stadex again, but it's independent of... Well, the reason I was asking, would it reduce the chance that this would be an issue? Because literally in a Mac, every single file is gonna be read. No, that's fine. Yeah, so, okay, assuming that you got the last slide, so I need to... What does the center box represent? Okay, so I didn't say what it is, but at the previous slide, I just said, well, somebody's doing LVM snapshot. Somebody's doing freeze-thaw. And if you cannot complete the freeze, you will not get to thaw, then you're in deadlock. That's what it stands for. But actually, it's not arbitrary because in my HSM, HSM does do freeze-thaw. At least my implementation does freeze-thaw because the way it works for collecting changes, it collects them in a batch in periods. What changed between today and yesterday and today? And to be able to be crash-safe and not say that I've recorded everything, everything that's on disk is in my database, then I do a freeze-thaw between the periods. So it's actually part of the HSM that's creating this deadlock. Okay, so the use case here has to do with change tracking. So it's similar to before, but instead of looking at the access permission event, I'm looking at a pre-create event. So pre-create doesn't exist yet. It's just part of the patches that I posted. But if we merge a pre-create event, we would end up with a problem like this. So the process on the right is just doing make-deer. It's doing make-deer, just pick make-deer, it doesn't matter what. HSM, the change tracker of the HSM, gets an event, a pre-create event and needs to record the fact that something has changed. Now, my first initial and naive implementation used the LSM hooks. There are LSM hooks for security, I don't make-deer. And just as if I used to hook to access an open, I hooked in to make-deer, generated create permission event, I didn't call it pre-create, I called it create permission. But then the HSM does something when it gets, in my example, it creates a directory, but it can do something else. And besides the loop that we've talked about before, it's creating a directory, it will create an event. This is solved very similarly by using an opath file descriptor that has the no-notify flag. So this loop, the simple loop is solved. But the other problem is the freeze deadlock again. So, okay, in order to solve the freeze deadlock, it's the same deadlock as before, I did the same thing, I didn't need the pre-VFS flags, I just moved the hook, which is a new hook, before taking freeze protection. Let's get to that, let's get to that. First of all, I was avoiding the obvious deadlock. And I did not introduce the red hook there, I just introduced an earlier hook before taking freeze protection. So HSM is always free to write to the file system. Events happened, I'm going to change the file system, please record the change before I make the change. That works to prevent the deadlock. But then I get to the races part of the problem. The race part of the problem is I get an event before making the modification. I record the event, say the engine looks at the file, it is changed, it backs the file up to the cloud, but the modification didn't happen yet. So now the modification happens and it's not being recorded because I've already did the freeze, so close everything and say everything is in sync and now the rest of the change happens invisibly. And you have a change in the file system that's not recorded, so that's a trade-off between true problems, the deadlock and the race problem and the way that John proposed to solve this is to wrap the file system modification operations in a sleeping RCU read context. So actually the way it's implemented is inside MNT won't write, I credit variants of it, MNT won't write and file start write. We embed also a start of an SRCU, a sleeping RCU read side section, which covers the entire modification period, from before you start to after you did it. And then, for example, in my AHSM, either I don't do freeze store at all because I don't really have to, or I do freeze store, but before that, yeah, SB write barrier is a synchronized SRCU. And then I'm able to maintain a view of a change tracking period. There are overlapping periods, right? You have all the changes from this time to that time, you have all the changes from this time to that time, where the overlapping period where you started to do SB write barrier means that all the changes that are being done right from here to here are recorded in both previous period and current period. So you never get to a state where you're always in a state that if you're looking, if anything is dirty, you may get a false positive of things that are dirty, but there is nothing dirty, but you cannot miss changes. Looking at your diagram, you still actually have the deadlock, don't you? Because in the third, the right hand box, you've got SB start write SRCU before that, but it looks like if that happens after the SB write, but we usually got your deadlock. So SB write barrier doesn't stop this one from proceeding. It does not. It just waits for all the ones that started to complete. That's the difference between the freeze protection and because the sleeping SRCU doesn't stop from new read sections to begin. It just waits for when it started to complete. So like the start write SRCU is not a blocking operation. Like basically how our RCU works and SRCU as well is that it just basically increments some counter and that's all. And the barrier just knows that to wait for everything that has started before it was called, but the new regions can be still started. So the red arrows do not exist. The red arrows are the prototype, they do not exist because this is not upstream, right? This is a plan. The red arrows are the first bad plan. The blue arrows are the plan that's deadlock free and the yellow ones, the attempt to solve the race. I told you ahead that it's going to be challenging. We're a bit out of, I guess I've shown what I wanted to show and we're out of time. We can also move the FS info talk to the VFS session tomorrow or start to talk about mount namespace changes, mount namespace changes, notifications now, since we're on the subject of notifications. What do you say? FS info at the empty slot of VFS mini-conference tomorrow and we start, yeah, yeah, yeah, Christian, talk to you. Yes, yes, yes. I was proposing since we now need to have a slot about FS info slash mount changes, notifications, which is a bit much for a single session even. Maybe we improvise and do, just try to do mount notifications now and FS info tomorrow. Nicholas, do you want to lead this or maybe I can start with the F and notify mount events. Maybe it's related. Okay, anyway, I didn't get any more questions. I didn't get to one part though.  No, okay, Joseph, yes. So I don't love it, I assume you've already looked at how we could probably do this with the existing freeze-thaw thing, like at another level perhaps. Yeah, so we were looking into how to do this but like current freeze-thaw has the problem exactly that it's relatively expensive operation because basically before you can tell that the file is frozen, you have to finish all the writes, flush all the dirty data and stuff like this. This is much cheaper operation because essentially it doesn't have to flush any dirty data because this really asks only about have all the writes, like wait for all the writes to finish from the moment I've asked you. So it is much less disruptive to the rest of the system while freeze is very disruptive to everything that's running on the system. This is disruptive essentially only for the one who is calling the barrier. Yes, so like really this, like because if we are not speaking about HSM, which is disruptive anyway, but if we are speaking about other use cases of like persistent file modification tracking, you ultimately want also unprivileged applications to be able to track changes, possibly not on the whole file system but on some sub hierarchy of the file system or sub directory. And then you don't want these applications to be able to hog your file systems with essentially syncs and stuff like this. So we wanted some lightweight wait for these applications to be able that all the writes to the part of the file system they are interested in are finished without imposing the performance penalty on everybody else. I forgot to say also, if I have SB write barrier, I don't need to do freeze so. It's enough to do SB write barrier and sync FS.  So it's similar, it's a complimentary API. And I was hoping that Jeff would say, yeah, that sounds interesting. I could use that for, you forgot, huh? I can use that because there was a problem discussed on the I version. Discussion, when does I version need to be bumped before the operation, after the operation? It's not clear. But it's the same conceptually, it's the same problem. If you introduce this concept, maybe it can solve other problems. And in this respect, John was hoping that we can introduce this to VFS and we can have SB write barrier and just use it. One problem is that test bots found the regression for like small writes. Because small writes do not take locks and there's a memory barrier. TMPFS, it was like visible on TMPFS write because the additional cost of taking the extraction line for SRCU were actually visible on TMPFS write. It was not terrible, but it was like 20% observable. It was observable. I solved this, I mean, I fixed the regression for my use case because what I did is for writes, I took the SRCU, there's a SRCU context which gets up to the FS notify hook and you just take it conditionally whether you're handling the event or not. But it's not a generic solution. Then we thought maybe we can use the I version observed bit to decide whether or not to take SRCU. Yeah, so the question is whether you want like similar to freeze protection, whether you want to grab the SRCU unconditionally or whether we want to somehow hide it and grab it only when someone is actually interested in this to kind of reduce the overhead for like fast systems like TMPFS which don't really care actually. So I don't know how to generalize this, but let's move on to the next. So for NFS it might be like harder. If you want to use it on NFS, basically when exporting you have to enable like I now need the SRCU grabbed for the fine system I'm exporting. So there it would have to happen like at this moment.


My name is John Collins. I am the president of Winthrop University Hospital and welcome to the 26th Winthrop University Hospital annual Christmas tree lighting. In just a few moments I will be calling up a special guest here, one of our patients from the hospital's pediatric hospital to press the button. And I'm delighted that the tree is so tall because I know you all share my thoughts and wishes that as the lights get turned on on this tree, that they shine overseas so that the good men and women serving in our military and in our armed forces know that they are in our thoughts and our prayers. We pray that they have a safe holiday season and a safe return back here to America. And suddenly all of us on the board take great pride in gathering and celebration tonight because it gives us the opportunity to gather as a group with some fidelity, camaraderie, some outside or inside later on, and really as a group reflect on all the wonderful blessings we have. So now I would ask everybody to join me in the countdown.