Information Technology Solutions

Design and Operational Requirements Issues

Development of Regulations for 

Spent Nuclear Fuel Reprocessing Facilities

REGULATORY GAPS 

DISCUSSED IN THIS 

SECTION: 

9 Gap 7 – Licensed 

Operators and Criteria 

for Testing and 

Licensing Operators 

9 Gap 9 – Baseline 

Design Criteria / 

General Design Criteria 

9 Gap 11 – Technical 

Specifications 

Although risk assessments enable NRC to understand the risks and hazards from the 

operation of nuclear facilities, these methods are not perfect and a certain level of 

uncertainty is always present. To compensate for these uncertainties, the NRC 

complements risk-informed decision-making with the concept of defense in depth. 

Defense in depth is an approach to safety where multiple and redundant layers of 

protection are used to prevent accidents, mitigate consequences, and reduce 

uncertainty. Some of the ways through which NRC will implement a defense in depth 

approach for reprocessing facilities are: 1) establishing specific design criteria the 

facilities must meet; 2) requiring limits on the operations of the facility; and 3) requiring 

specialized training and qualifications for personnel operating these facilities. 

NRC’S DEFENSE IN DEPTH APPROACH TO 

NUCLEAR SAFETY 

Defense in depth is an element of the NRC's 

approach to nuclear safety that employs 

successive measures to prevent accidents or 

mitigate consequences from events or 

accidents at a nuclear facility. In addition, the 

concept of defense in depth is applied 

throughout many of aspects of NRC’s licensing 

and oversight of nuclear facilities. These 

include, among others: 

• Requirements for high quality design, 

fabrication, construction, and testing 

• Requirements for designs with multiple 

barriers to radioactive releases 

• Redundancy and diversity in safety 

systems 

• Specific limits on facility operations 

• Requirements for detailed emergency 

preparedness plans 

Defense in depth is an important approach to 

increase safety assurance and compensate for 

uncertainty in the understanding of risks and 

hazards at nuclear facilities. In addition, the 

NRC's defense in depth approach serves as an 

important complement to risk-informed 

decision making. 

GENERAL DESIGN CRITERIA 

The NRC establishes minimum requirements 

for the design of nuclear facilities, to ensure 

that the facility provides: 

• Assurance that structures, systems, and 

components (SSCs) important to safety 

will have the ability and reliability to 

perform their intended safety functions 

• Assurance that uncertainties and errors 

from design and analysis are adequately 

addressed 

• Adequate defense in depth 

• Redundancy and diversity 

• Assurances that balance of plant and 

unanalyzed situations do not negatively 

impact safety 

NRC regulations frequently identify these 

minimum requirements as General Design 

Criteria (GDC) or Baseline Design Criteria 

(BDC). 
will be used, and the level of safety 

protection they must provide. Technical 

specifications are reviewed and approved 

by NRC staff prior to operations, as are 

any changes. 

The Atomic Energy Act, as amended, 

requires technical specifications for the 

licensing and operation of any production 

or utilization facility, such as a 

reprocessing facility. Accordingly, 10 CFR 

Part 50 establishes criteria for technical 

specifications. However, 10 CFR Part 70 

does not require technical specifications. 

Under 10 CFR Part 70, the systems and 

controls needed to maintain safety are 

identified through a risk-assessment 

process called an Integrated Safety 

Assessment (ISA), and are identified as 

items relied on for safety (IROFS). The 

specific settings that these systems must 

meet to provide the required level of 

protection are determined through the ISA 

process. 

Accordingly, the NRC will consider 

regulatory requirements for technical 

specifications for reprocessing facilities 

that bridges the gap between the use of 

technical specifications in 10 CFR Part 50 

and the use of IROFS in 10 CFR Part 70. 

The NRC recognizes certain advantages in 

the use of risk assessment methodologies 

to implement technical specifications, and 

expects to adopt the use risk-informed 

considerations when determining the 

proper technical specification 

requirements. 

LICENSED OPERATORS AND CRITERIA 

FOR TESTING AND LICENSING 

OPERATORS 

The Atomic Energy Act, as amended, 

requires the NRC to establish criteria for 

licensing operators of production and 

utilization facilities, determine the 

qualifications of individuals applying for 

operator licenses, and to issue licenses as 

appropriate. Accordingly, NRC regulations 

in 10 CFR Part 55 establish the criteria for 

testing and licensing operators. However, 

these regulations are not wholly applicable 

to operators of reprocessing facilities. The 

NRC will consider testing and licensing 

criteria for reprocessing facility operator, 

either by revising 10 CFR Part 55, or by 

including these criteria in a revised rule for 

reprocessing facilities.

Design and Operational Requirements Issues

(Page 2)

Currently, Appendix A to 10 CFR Part 50 

contains the General Design Criteria 

applicable to nuclear reactors. Although 

the GDCs listed in Appendix A are not 

explicitly applicable to reprocessing 

facilities, many of them establish design or 

safety features that are analogous to those 

that would be potentially necessary for a 

reprocessing facility. NRC regulations in 

10 CFR Part 70 also contain some BDCs 

that can be applied to reprocessing 

facilities. However, these BDCs are more 

applicable to the hazards of fuel cycle 

facilities that do not handle highly 

radioactive materials. Accordingly, the 

NRC may need to develop appropriate 

GDCs that properly encompass the 

operations and processes encountered in a 

reprocessing facility. 

TECHNICAL SPECIFICATIONS

In general, technical specifications are a 

set of limits, controls, or settings required 

to maintain the safe operation of 

production and utilization facilities. 

Technical specifications would establish 

the safety limits for processes at 

reprocessing facilities in order to guard 

against the uncontrolled release of 

radioactivity. Technical specifications may 

include settings for safety alarms, for 

automatic safety systems, or other 

protective equipment. Technical 

specifications are generally developed by 

the applicant during the licensing process, 

and their content is based on the proposed 

facility design, its proposed operating 

conditions, the types of safety systems that