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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 [email protected]
• Wilkins Smith, Sr. Project Manager Advanced Recycling [email protected]
• Yawar Farez, Sr. Project ManagerGNEP Advanced Fuel Cycle Facility [email protected]
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