NEI Task Force 

Closing the Fuel C

White Paper Overv

NRC Public Meeting

February 26, 2009
Closing the Fuel Cycle 

Force

 Creation of Task Force 

– Spring 2008 - NEI/Industry discussions regard

of task force

– June 2008 - Chairman Klein’s FCIX reference t

engagement with NRC on recycling

– July 2008 - Task Force Kick-off

 Task Force Members

– Utilities (TVA, Exelon, Duke, Constellation, Ent– Industrial Teams (Energy Solutions, AREVA, GE– Supporting organizations (CH2M Hill, B&W, Ta
Closing the Fuel Cycl

Force Initiative

 Licensing Framework for Recycling

– Focus of this meeting

 Other areas for later Task Force actions

– Transportation– Safeguards and Security– Environmental Standards– Waste Management– Fuel Use in Existing reactors (MOX)
Licensing Framewor

for Recycling

 Working team formed by Task force to dev

framework (B&W/AREVA, Talisman, GE)

 White paper submitted by NEI in Decembe Framework addresses Part 7x and other P Recognize this meeting is first of many st

discussions

 Proposed workshop in June in conjunction 
Topics for Part 7x Ov

 Why Part 7x Fundamental Concepts

 Scope of Framework Safety Philosophy Key Features of Part 7x Production Facility Thresholds Safety Envelope and Safety Report Baseline Design Criteria Technical Specifications Licensing of Operators Licensing Flexibility Content of Applications Outline of Proposed 7x
Why Part 7x ?

 Current Part 50

– Focuses LWR design and technology

– Does not have a design basis for a reprocessin

– Does not address the chemical hazards of a re

plant

– Is not risk informed and performance based si

Part 70 

– Has requirements that can not be met (i.e. rem

waste to a repository in 10 years)

 Current Part 70

– Recycling was not a clean fit

– Existing licensees concerned about burdening 

regulation
Discussion

Views on a new Part 
Fundamental Conc

 Move non-reactor production licensing ou Create a new Part 7x for licensing recycli

(non-reactor production facility) 

 Utilize a risk informed performance based 

based on Part 70 model

 Allow flexibility while assuring appropriat

review processes

– One or two step licensing– Single or multiple licenses on a site

 Technology neutral
Scope of Framewo

for Fuel Recycling Fa

As used in proposed 7x Recycling means (1) the separation of radioactive 

(2) the processing of irradiated materials containnuclear material.

 Fuel Recycling Facility (FRF) is a facility for recyc

associated activities on a contiguous site to the eactivities are included in the application
What is a Fuel Recyc

Facility?

Fuel Fabrication

Spent Fuel

Storage Facility

Recycling Operations

Separation and

processing of

irradiated SNM

Production Facility licensed under 10CFR7x

Fuel Recycling Facility

Fuel Fabrication Facility Licensed under 10CFR7x or 10CFR70Spent Fuel Storage Facility (Licensed under 10CFR7x or 10CFR72)

Ass

Ope

(e.g. w

and m

Associated Operations (Licensed under 10CFR7x or Part 30, State, 

etc.)

Fuel Recycling Facility licensed under 10CFR7x
Discussion

Views on Concepts and 
Framework Adopts the 

Philosophy of 10 CFR 

Utilizes a risk-informed and performance-based regul

approach

 Identification of performance requirements for p

accidents or mitigation of their consequences

 Establishes Baseline Design Criteria (BDC) Performance of an Integrated Safety Analysis (IS

potential accidents at the facility and the items rsafety (IROFS) 

 Implementation of Management Measures to en

IROFS are available and reliable to perform their 

needed

 Maintenance of the safety bases, including the re

changes to the NRC

 Allowance for licensees to make certain changes 

safety program and facilities without prior NRC a
Discussion

Views on proposed Safety Philo
Key Features of Fram

 Safety Envelope Based on an ISA us

performance requirements form 70

quantitative analysis

 Enhanced Baseline Design Criteria 

criteria from 10 CFR 50, 70 and 72

 Application content similar to 10 CF Added concept of “safety report” fo

information

 Technical Specifications
Key Features of Fram

 Licensed Operators for certain fun Use of ITAACS for combined licen Licensing Flexibility Hearing Opportunities

– Construction Permit (mandatory)– Operating license (if requested)– Combined construction and operation – ITAAC ( if requested and criteria met)
Production Facility Thr

 A FRF may encompass activities other tha

production activities

 Thresholds set to recognize unique aspec

production facilities

 Proposed thresholds are at the level of a h

consequence event involving fission produto an individual outside the controlled are

 Thresholds applies to

– Quantitative analysis within ISA– Technical Specifications– Operator licensing 
Discussion

Views on Key Features and Thre
Safety Envelope

 Proposed rule introduces the term “Safety Rep

technical portions of the application

 The Safety Report contains: 

– The description of FRF and describes application of B– The ISA Summary– The safety program that provides description of applic

• The ISA• Fire protection• Chemical safety• Nuclear criticality• Radiation protection • Management measures • Process safety information
Safety Report

Safety Report is living document of radiological li

and is controlled throughout life of FRF by change 

 Applicants and licensees must maintain the s

program, ISA and ISA Summary

 The Safety Report is expected to be made up 

volumes

 A configuration management change process 

place to evaluate, implement and track each Safety Report

 Proposed change process modeled after 10 C

consideration of 10 CFR 50
Discussion

Views on 

Safety Envelopes 

Safety Report Concep
Baseline Design Cri

 BDC are the criteria that must be applied to 

that there is reasonable assurance the perfrequirements are met

 Provide for defense-in-depth protection aga BDC are the initial set of design safety con

ISA process intended to identify additional 

 Some BDC may not be necessary based on  BDC for fuel recycling facilities derived from 

portions of 10 CFR Part 70, 10 CFR Part 50 Part 72
Baseline Design Cri

28 Criteria

 Overall Requirements ( 1-7)  Radiological Protection ( 8-14) Chemical and Hazardous Materials Prote

16)

 Equipment Services Protection (17-21) Facility Confinement Protection (22-28)
Discussion

Views on Baseline Design Crit
Technical Specificatio

 TS required by AEA for production facilitie AEA provides TS address

– Amount, kind, and source of SNM– Place of use – Specific characteristics of the facility– Such other information necessary for c

and security and public health and safe

 Information contained in the application s

proposed Technical Specification provisio
Technical Specificatio

 The proposed TS provisions limit TS to risk 

aspects of producing SNM based on the IS

 Applicants would propose TS to address I

prevent or mitigate accident scenarios thresult in high consequence events involvinproduct releases to an individual outside tcontrolled area
Discussion

Views on Technical Specifica
Licensing of Opera

 The AEA requires operators be licensed fo

facilities but does not specify the process

 Many operators at a FRF (Most Operation

70 Facilities)

 Under proposed part 7x only licensed ope

manipulate the controls which affects the mitigation of identified accident scenarioresult in a high consequence event involvproduct releases to an individual outside tarea
Licensing of Opera

 Proposed Part 7x provides for a certificati

– The application needs to provide for NRC appro

for training and certifying operators including testing, and requalification

– The application needs to identify which operat

including supervisory positions the applicant wthe NRC as technically, mentally, and physicaland NRC will license

– Certification means operator is trained and is 

medically, and physically competent based on approved certification program
Licensing of Opera

 Based on approved certification program and its 

implementation, NRC will approve and issue an op

 NRC expected to audit the facility’s certification p

satisfied that the certified operators are compete

of performing licensed operations

 NRC may observe training and examinations and r

individuals’ training and certification documentat

 NRC afforded access to training material, tests, te

practical training (simulator, if utilized)

 Under the certification concept , NRC will largely r

facility’s certification that applicant is technically based on the facility’s approved training and certiprogram
Discussion

Views on Licensing Opera
Licensing Flexibil

 Flexibility provides for appropriate regulatory revi

 Applicant may license parts of the facility early an

a single license

 May limit application for a fuel recycling facility to 

activities or to include in its application one or moactivities conducted on a contiguous site;

 Non recycling activities could be licensed under ot

or 72)

 Cumulative impacts of site needs to be fully consi

– Safety and Security– Environmental Report Allows the applicant a choice of either a one or tw

process and limited work authorization 
Discussion

Views on Flexibility
Content of Applica

(a) Material to be licensed(b)Technical qualifications(c) Safety Report

(1)Description of the Facility and Application of BCriteria(2) Integrated Safety Analysis Summary (ISA Sum(3) Safety Program

(d) Decommissioning

(e) Technical specifications

(f) Environment, effluent releases and waste mana

(g) Financial qualification(h) Emergency Preparedness Plan 
Content of Applica

(i) Material Control and Accounting Plan(s)(j) Plan for physical protection of special nuclear m

transit

(k) Physical security plan(s)

(l) Safeguards contingency plan(s)

(m) Protection of classified safeguards information (n) Financial protection and indemnity (o) Inspections, tests, analyses and acceptance crit(p) Operators to be licensed Looks very much like a Part 70 Application with en
Outline of Proposed P

Subpart A General ProvisionsSubpart B Requirement of License, Exceptions anSubpart C Requirements for ApplicantsSubpart D Licenses and License Conditions

Subpart E Amendment of License or Construction 

Request of Holder, Renewal, and Termin

Subpart F Acquisition, Use, and Transfer of Specia

Material, Creditors' Rights

Subpart G Reports, Records, and InspectionsSubpart H Modification and Revocation of License

Subpart I Licensed operatorsSubpart J Enforcement
Discussion

Views on 

Overall Content