developing a conceptual regulatory framework for gnep ...june 2007 us nrc fcix 1 developing a...

June 2007 US NRC FCIX 1

DEVELOPING A CONCEPTUAL REGULATORY FRAMEWORK FOR GNEP

Amy M. SnyderUS NRCDivision of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and SafeguardsWashington, DC

June 2007 US NRC FCIX 2

Outline

• NRC’s Current GNEP Role

• NRC’s GNEP Activities

• Challenges

• Stakeholder Input

June 2007 US NRC FCIX 3

NRC GNEP Project Managers• Amy M. Snyder, Sr. Project Manager

GNEP Fuel Separations and Fuel Fabricationams3@nrc.gov301-415-8580

• Wilkins Smith, Sr. Project Manager Advanced Recycling Reactorswrs@nrc.gov301-415-5788

• Yawar Farez, Sr. Project ManagerGNEP Advanced Fuel Cycle Facility Issuesyhr@nrc.gov301-415-8113

June 2007 US NRC FCIX 4

NRC’s GNEP Role

• Currently- no commercial GNEP facilities

• Commission asked staff to develop a conceptual licensing process for GNEP (SRM-SECY-06-0066)

June 2007 US NRC FCIX 5

NRC’s GNEP Role (continued)

• If GNEP is to be commercialized, then:– NRC regulatory authority

June 2007 US NRC FCIX 6

NRC’s GNEP Role (continued)

• Potential facilities NRC could regulate:

– Reprocessing facility– Fuel fabrication facility– Interim storage and/or vitrification facility– Fast reactor facility– Associated Special Nuclear Material

June 2007 US NRC FCIX 7

NRC’s GNEP Role (continued)

• “NRC’s role is not to judge the policy merits of pursuing a domestic reprocessing capability.

• Our job is to provide a fair and workable regulatory framework under which such a facility could be licensed while achieving reasonable assurance of adequate protection of public health and safety and common defense of security.”

Commissioner McGaffigan(COMEXM-06-0003)

June 2007 US NRC FCIX 8

Outline

• NRC’s Current GNEP Role

• NRC’s GNEP Activities

• Challenges

• Stakeholder Input

June 2007 US NRC FCIX 9

NRC’s GNEP Activities

• NMSS Lead on Developing Regulatory Licensing Process

• Agency-wide effort• SECY-07-0081 : GNEP Facilities• Obtain stakeholder input on licensing process

• DOE/NRC Memorandum of Understanding– Obtain an understanding of new technology

June 2007 US NRC FCIX 10

NRC’s GNEP Activities

• SECY-07-0081

– 4 Options – Staff Recommendation– Commission Decision

June 2007 US NRC FCIX 11

NRC’s GNEP Activities• SECY-07-0110 Options

Potentially One rulemaking

FRN- solicit stakeholder input (Order vs. Reg]-Staff concurrently develops technical basis documents to support next step

4

One RulemakingGNEP Regulation3

Two Rulemakings-Create Part -5XSane as Option 12

Rulemaking for CFTCPotential Rulemaking for ABR

-Use Part 50-Explore suitable modification to Part 52

-Revise Part 70-Consider additional safety analysis requirements

1

CommentsAdvanced Recycling Reactor(ABR)

Fuel Sep/Fuel Fab(CFTC)

Option

June 2007 US NRC FCIX 12

NRC’s GNEP ActivitiesSECY-07-0081 Staff Recommendation

• Option 1: Phased Approach

• Develop Technical Basis Documents to Support Rulemaking

• After DOE Secretarial Decision on Scope of GNEP: Move to new GNEP Regulation.

June 2007 US NRC FCIX 13

NRC’s GNEP Activities

• NEXT STEPS– Agency wide Effort/Stakeholder Input– Waste Management– Safeguards– Decommissioning– Environmental Review

June 2007 US NRC FCIX 14

NRC’s GNEP Activities

• DOE/NRC GNEP MOU– Information Exchange– Knowledge gathering– Learn about new technologies

June 2007 US NRC FCIX 15

NRC’s GNEP Activities

• Factors affecting future NRC activities:– Commission Decision on SECY-07-0081.– June 2008 DOE Secretarial Decision- on the

scope of GNEP?– Letter of Intent?– Appropriations?

June 2007 US NRC FCIX 16

Outline

• NRC’s Current GNEP Role

• NRC’s GNEP Activities

• Challenges

• Stakeholder Input

June 2007 US NRC FCIX 17

Challenges- Regulatory

• Interdependence of facilities (each facility affects the safety, quality, effectiveness, and efficiency of the others):

– Broad array of applicable NRC regulations – Multiple NRC program offices

• Ensure a stable and reliable regulatory infrastructure is in place well before application is submitted

– Provides guidance to applicants – Supports timely NRC licensing review

June 2007 US NRC FCIX 18

Challenges- Other

• Congress on Board?– Near term funding– Sustaining funding for out years– Supplier vs User Nations issues

• New Administration• New Technology• Industry on Board?

June 2007 US NRC FCIX 19

Challenges- Other

• Technology– DOE has not selected technologies

• Lab scale tested

– Validated Models?– Cross section data

• Potential Health and Safety Challenges

June 2007 US NRC FCIX 20

Challenges- Potential Health and Safety

Issues• Time after discharge – short versus long• Intense/lethal radiation• Self-heating materials• Criticality (particularly in liquid phases)• Chemicals, toxicity, and reactivity (organics and gases)• Dissolution and insolubles/solid fines• Fire and explosion (e.g., hydrogen)• Environmental qualification of equipment• HVAC/filters/offgas.• Waste treatment, forms (e.g., HLW, hulls, LLW)

June 2007 US NRC FCIX 21

Challenges- Potential Differences from

Current Part 70 Facilities

• Usually mixtures of Pu/TRU isotopes (which ones and %s)

• Radiation• Alpha effects• “Chemically toxic” (complexed/soluble and

reactions)• Thermal – frequently “warm”• Criticality

June 2007 US NRC FCIX 22

Challenges- Potential Differences between

LWR technology

• Liquid metal (Na) coolant?• Intermediate heat transfer loop• Higher enrichment/fissile fuels• Higher burnup SNF• Larger actinide source term

June 2007 US NRC FCIX 23

NRC Oversight of Potential GNEP Facilities Phased Approach

(Yellow boxes could enter licensing now)

SNF StoragePart 72

Reprocessing and SeparationsPart 7X

ABR/Actinide Fuel FabricationAnd SNM,TRU, and New Fuel Storage

Part 7X

HLW VitrificationAnd StoragePart 70 or 7X

Cs/Sr/non-TRUWaste Solidification

And StoragePart 30 or 7X

TRU Stabilization,Waste Solidification,

And StoragePart 7X

REPU StoragePart 70

ABR 1Part 50/52

ABR 2Part 50/52

Site Boundary

June 2007 US NRC FCIX 24

Outline

• NRC’s Current GNEP Role

• NRC’s GNEP Activities

• Challenges

• Stakeholder Input

June 2007 US NRC FCIX 25

Stakeholder Input

• Licensing Process for Regulating GNEP– Licensable versus licensed?– Facilities on DOE sites?– Co-location of GNEP facilities?

• Potential Health and Safety Concerns

• Potential Safeguard Concerns

June 2007 US NRC FCIX 26

Stakeholder Input

• Ways to obtain your input– FCIX conference:

• NRC to summarize your GNEP input and place on NRC website.

• NRC staff to consider your comments in conceptual licensing process development

– NRC Feedback Forms– Other?

June 2007 US NRC FCIX 27

Stakeholder Input

• Licensing Process for GNEP– How should GNEP facilities and associated

Special Nuclear Materials be regulated?

– Comments on SECY-07-0081

June 2007 US NRC FCIX 28

Stakeholder Input

• What are your potential health and safety concerns as related to GNEP?

» Worker» Public» Environment

• How would you address these potential health and safety concerns in the licensing framework?

June 2007 US NRC FCIX 29

Stakeholder Input

• What are your potential safeguards concerns as related to GNEP?

• How should they be addressed in the licensing framework?

June 2007 US NRC FCIX 30

Overview

• NRC’s Current GNEP Role

• NRC’s GNEP Activities

• Challenges

• Stakeholder Input