ML22158A088

Partial Presentation Package NRC Fusion Public Meeting June 07 2022

ML22158A088
Person / Time
Issue date:	06/07/2022
From:	Office of Nuclear Reactor Regulation
To:
A Proffitt
References
EPID N-2022-ADV-0002
Download: ML22158A088 (152)

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Developing a Regulatory Framework for Fusion Energy Systems NRC Public Meeting 1 of 152 June 7, 2022

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 2 of 152 5:30 pm Adjourn 2

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 3 of 152 5:30 pm Adjourn 3

NEPA Overview Donald Palmrose Office of Nuclear Material Safety and Safeguards 4 of 152

NEPA Overview

• National Environmental Policy Act of 1969 (NEPA), as amended 42 U.S.C. § 4321 et seq. is a national policy for the government to consider environmental issues in the conduct of Federal activities There are also other laws, regulations, and rules that the NRC implements through its NEPA activities (e.g. ESA, NHPA)

• NEPA Section 102(2)(C) and the NRCs implementing regulations (10 CFR Part 51) require an environmental impact statement (EIS) for major Federal actions significantly affecting the quality of the human environment Or the Commission determines the proposed action should be covered by an EIS

• The NRC prepared EISs for nuclear electrical generation stations and significant material-licensed facilities such as enrichment facilities and fuel fabrication facilities.

5 of 152 2

NEPA Considerations

• Nuclear Energy Innovation and Modernization Act of 2019 (NEIMA) includes fusion in the definition of an advanced nuclear reactor

• The draft Advanced Nuclear Reactor Generic EIS (ML21222A055) before the Commission also would apply to a fusion power plant

• Staff anticipates several environmental impacts would be due to the size/footprint/location Examples are Ecology, Land Use, & Socioeconomic

• Applicants are encouraged to discuss the environmental review process during pre-application meetings 6 of 152 3

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 7 of 152 5:30 pm Adjourn 4

OVERSIGHT OF RESEARCH AND DEVELOPMENT ACTIVITIES REGULATING CURRENT ACTIVITIES WITH EXISTING FRAMEWORK Agreement State Representative to Fusion Energy Systems Working Group DIEGO SAENZ Nuclear Engineer 8 of 152 diego.saenz@wi.gov

TODAYS AGENDA Current Near-term Questions Regulations Licensing Currently Long-term Licensed 9 of 152 Licensing

CURRENT FRAMEWORK NRC STATE ELECTRONIC RADIOACTIVE SPECIAL NUCLEAR SOURCES MATERIALS 10 of 152 MATERIAL

CURRENTLY LICENSED Fusion Devices Radioactive Materials (non-energy) (tritium and activation products) 11 of 152

NEAR-TERM LICENSING Fusion Devices Radioactive Materials (non-energy) (tritium and activation products) 12 of 152

LONG-TERM LICENSING

• Fusion Devices (non-energy)

• Radioactive Materials

• Fusion Energy 13 of 152

QUESTIONS?

14 of 152

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 15 of 152 5:30 pm Adjourn 5

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 16 of 152 5:30 pm Adjourn 6

Evaluating Common Defense & Security Use of Part 30 Tools for Fusion 07 June 2022 Sachin Desai, Helion Energy Michael Hua, Helion Energy 17 of 152

Outline

• Evaluating Common Defense and Security

• Use of Part 30 Tools for Fusion 18 of 152 2

Evaluating Common Defense and Security 19 of 152 3

• Common defense and security primarily concerns the diversion of special nuclear material (SNM)

• Commercial fusion devices are not of significance to common defense and security - because they are not Summary designed to handle or create SNM

• Security for fusion materials, when needed, can be appropriately controlled via the materials framework (Part 37), not the SNM framework (Part 73) 20 of 152 4

Context: Common Defense & Security (Common Defense)

• AEA tasks the NRC to help prevent bad actors from developing nuclear weapons

• Common Defense woven conceptually throughout the AEA

- The processing and utilization of source, byproduct, and special nuclear material must be regulated in the national interest and in order to provide for the common defense and security and to protect the health and safety of the public. (AEA § 2.d)

• Concerns unacceptable likelihood of grave or exceptionally grave damage to United States (CLI-04-17)

- But what does this extend to? (see slide 7) 21 of 152 5

Context: Common Defense

• Helpful sources of legal interpretation:

- Nuclear Non-Proliferation Act of 1978 (NNPA) & related rulemakings

- Export controls case law (e.g., 647 F.2d 1345; CLI-20-2)

- Part 37 & 73 rulemaking context (e.g., 78 Fed. Reg. 16,922; NUREG-0095)

• Affects Agreement State licensing authority (AEA § 274.m), but:

- Presence of any Common Defense question does not mandate utilization facility licensing (Parts 37, 110)

- Joint Public Health/Common Defense questions need not eliminate state involvement in licensing (e.g., radiological dispersion devices (RDDs), 78 Fed. Reg. 16,927) 22 of 152 6

What is In Scope for Common Defense & Security?

• Key concern - SNM proliferation Not Fusion

- NPT & NNPA

- NRC practice

• Additional concern - RDDs

- Part 37 rulemaking

- Joint public health & safety concern

• Not in Scope - Geo-political criteria (e.g., energy security)

- Executive deference (seen in export licensing precedent) 23 of 152 7

Common Defense -- SNM Proliferation, Not Fusion

• NNPA connects Common Defense to nuclear explosive proliferation:

- NNPA § 204 (creating AEA § 126): An export will not be inimical to the common defense and security because it lacks significance for nuclear explosive purposes

- NRC decisions cement link (e.g., CLI-20-2; CLI-17-3; CLI-04-17)

• NRC explicitly links nuclear explosive proliferation to Trigger Lists (INFCIRCs 209/254)

- Part 110 Final Rule Considerations: The components, items and substances chosen [for Part 110] are essentially those on the Nuclear Suppliers Group and IAEA Zangger Committee trigger lists, thus reflecting an international consensus on items considered to be significant for nuclear explosive uses (43 Fed. Reg. 21,641, at 21,642)

• Trigger Lists focus on SNM/fuel cycle, to this day exclude fusion devices and tritium

- Note on nuclear reactor in Trigger Lists: This entry does not control fusion reactors 24 of 152 8

Focus on SNM proliferation algins with NPT & NRC practice

• NPT is focused on SNM proliferation

- NPT scope: (a) source or special fissionable material, or (b) equipment or material especially designed or prepared for the processing, use or production of special fissionable material

- Trigger Lists clarify especially designed prong, and focus on SNM/fuel cycle, excluding fusion/tritium

- Model Additional Protocol (INFCIRC/540) re-examined safeguards but still leaves out fusion/tritium

- Recognition that fusion doesnt need safeguardschanging this will require amending intl agreements

• NRC practice likewise is focused on SNM risk

- NRC definition of significance tied to SNM quantities (e.g., Parts 73/74)

- NRC inimicality reviews have looked to compliance with Part 73 (SNM-focused) (SECY-16-0056)

- NRC licenses tritium as byproduct material, even in large quantities 25 of 152 9

Commercial fusion does not use or produce SNM

• Commercial fusion devices are not especially designed (or peculiarly adapted) to produce SNM, nor even handle it

• Fusion-fission hybrids are fundamentally distinct from commercial fusion Introduce Source Remove/Modify Redesign Pump Material Lithium Blanket and Pump Power Example Modifications Establish Establish Reprocessing Enrichment 26 of 152 10

What is not Common Defense & Security

• Does not include geopolitical considerations, such as:

- Energy security

- Economic competition

• AEA points to Executive & Congress on general national security, e.g.:

- CLI-20-02: AEA export licensing criteriawhich look to common defense and securitydo not consider economic or market-based interests

- CLI-04-17: Executive Branch has key role to make strategic judgements, and NRC role is complementary 27 of 152 11

Fusion risks appropriately addressed by export controls

• The primary risk involving fusion is abuse of the technology or materials outside the US

- Tritium & tritium management systems already covered by export controls, such as:

o 10 CFR 110.9; ECCN 1C235 and 1A231

- Fusion technology and materials (e.g., Li-6) also already covered in large part, such as:

o ECCN 0D999 and 1C233, and ECCNs for other components/parts l End-use prohibitions

• USG export controls agencies already have sole jurisdiction

• Treatment of fusion by export controls aligns with current nonproliferation regime

- E.g., Fusion and tritium excluded from Trigger Lists (which clarify NPT & concern safeguards), but tritium and tritium systems are on the NSG dual use list (which concerns export controls) 28 of 152 12

See our paper: Nonproliferation and fusion power plants To be published in an academic journal; preprint can be made available 29 of 152 13

Security for materials facilities is handled in Part 37

• Risk of material diversion RDDs (dirty bombs) is addressed with physical security: Part 37 -

Phys. Protection of Category 1 and Category 2 Quantities of Rad. Mat.

- Category 1: typically used in radiothermal generators, irradiators, and radiation teletherapy.

- Category 2: typically used in industrial gamma radiography, high- and medium-dose rate brachytherapy, and radiography.

• Category threshold values come from IAEA TECDOC-1344, IAEA Code of Conduct, and International Conference on Security of Radioactive Sources 2003 (the Hofburg Conference)

• Using the same threshold calculations for categories one and two, the tritium thresholds are:

- Category 1 (H-3): ~5.6 kg

- Category 2 (H-3): ~56 g 30 of 152 14

Part 37 Part 73

• Part 73

Purpose:

This part prescribes requirements for the establishment and maintenance of a physical protection system which will have capabilities for the protection of special nuclear material at fixed sites and in transit and of plants in which special nuclear material is used

• Part 73 presumes the presence of special nuclear material; focuses on physical protection of this already existing material

• SNM not used and not present in fusion facilities 31 of 152 15

Use of Part 30 Tools for Fusion 32 of 152 16

Fusion during operation Key Concept: Fusions operational impacts are fundamentally similar to those a of a particle accelerator Fusion Device Accelerator (e.g., cyclotron)

• Neutron and photon radiation

• Neutron and photon radiation

• In-process fuel/accelerated particles and exhaust

• In-process fuel/accelerated particles and exhaust

• Activated shielding

• Activated shielding 33 of 152 17

Fusion during accidents Key Concept: Fusion impacts are fundamentally akin to those of industrial facilities Fusion Device Industrial Facility

• Reactions (fusion) immediately cease

• Reactions (decay) continue - may need to close shielding

• Device has very limited releasable inventory

• Devices have small-to-large releasable inventory

• No need for active cooling (may have pools)

• Usually, no need for complex active cooling (pools instead)

• Tritium handling is complex materials issue

• Diversity of issues to evaluate 34 of 152 18

What could the NRC need to control for?

Access Shielding Fire Operators Technical Emergencies Monitoring Device Control Personnel Survey Opernl Vault Integrity Leak Detection Maintenance General Entry & Exit EP Other Matl. Security Novel Issues 35 of 152 19

What could the NRC look to?

Access Shielding Operators Part 30 Fire Technical Emergencies Part 35 Monitoring Personnel Survey Part 37 Device Control Opernl Vault Integrity Leak Detection Maintenance General Entry & Exit EP Other Matl. Security Part 36 Novel Issues 36 of 152 20

What could the States look to?

In the state of Washington, for example:

Access Shielding Operators WAC 246-235 Fire Technical Emergencies WAC 246-240 Monitoring Personnel Survey WAC 246-237 Device Control Opernl Vault Integrity Leak Detection Maintenance General Entry & Exit EP Other Matl. Security WAC 246-236 Novel Issues 37 of 152 21

Sample design requirements usable from Part 36 Section Title Key Regulatory Concepts (Based on Part 36)

• Barring entrance to rooms containing fusion device/ancillary system during ops.

(essentially covering all potential high-radiation areas) 36.23 Access Control

• Opening of door triggers alarms/shutdown (w/ backup intruder detection)

• Alerts prior to start of operations 36.25 Shielding

• Dose rates cannot exceed 2 millirem per hour outside of shielded areas

• Heat and smoke detectors 36.27 Fire Protection

• Automated fire extinguishing when required

• Airborne material detection 36.29 Radiation Monitors

• Neutron detection

• Entry and exit detection

• Indication of on/off as well as safety system status/output 36.31 Device Control

• Ability to turn off easily (manual and automated)

• Metallurgical and leak/purity requirements 36.33 Shielding Pools

• Dose limits 36.37 Power Failures

• Automatic stop of commercial operations

• Sets forth performance requirements for above systems, as well as e.g.,

36.39 Design Requirements foundations, liquid handling, seismic, computers, wiring 36.41 Construction monitoring

• Sets forth requirement to ensure construction meets design requirements 38 of 152 22

Sample operating requirements usable from Part 36 Section Title Key Regulatory Concepts (Based on Part 36)

• Operator training, testing, safety review, and related requirements (relatively simple 36.51 Training requirements; reliance on guidance)

• Safety procedures for operators (e.g., entry/leaving, dosimeters, leak testing, maintenance checks)

Operating and

• On-site emergency procedure requirements(e.g., personnel overexposure, alarms, 36.53 Emergency Procedures equipment failures, loss of shielding pool liquid)

• Revision requirements

• (Off-site emergency requirement threshold set in Part 30/under review) 36.55 Personnel Monitoring

• Standard dosimetry requirements

• Surveys with startup and over time 36.57 Radiation Surveys

• Survey requirements and consequences of failure

• Detection of leaks from vacuum vessels (as opposed to sealed sources) 36.59 Leak Detection

• Checks for equipment before entry into shielding pools

• Decontamination of leaks

• Inspections of key active systems (e.g., access control, monitors, wiring for safety 36.61 Inspection and Maintenance systems, shielding pool systems)

• Requirement to repair faults 36.63 Pool Liquid Purity

• Basic requirements for maintaining purity of shielding pools 36.65 Attendance During Operation

• Staffing requirements for operator and additional individual(s) 36.67 Entry and Exit

• Radiation 39 of 152checks prior to entry and exit of fusion device/ancillary system rooms 23

Example: § 36.25 Shielding The following mark-ups are meant to be illustrative, not complete and comprehensive

a. The radiation dose rate in areas that are normally occupied during operation of a panoramic irradiator fusion device may not exceed 0.02 millisievert (2 millirems) per hour at any location 30 centimeters or more from the wall of the room when the sources are exposed. The dose rate must be averaged over an area not to exceed 100 square centimeters having no linear dimension greater than 20 cm. Areas where the radiation dose rate exceeds 0.02 millisievert (2 millirems) per hour must be locked, roped off, or posted.

b. The radiation dose at 30 centimeters over the edge of the pool of a pool irradiator fusion device may not exceed 0.02 millisievert (2 millirems) per hour when the sources are in the fully shielded position device is on.

c. The radiation dose rate at 1 meter from the shield of a dry-source-storage panoramic irradiator fusion device when the source is shielded device is off may not exceed 0.02 millisievert (2 millirems) per hour and at 5 centimeters from the shield may not exceed 0.2 millisievert (20 millirems) per hour.

40 of 152 24

Example: § 36.37 Power failures (shutdown)

a. If electrical power at a panoramic irradiator fusion device is lost for longer than 10 seconds, the sources device must automatically return to the shielded position shutdown.

b. The lock on the door of the radiation room of a panoramic irradiator fusion device may not be deactivated by a power failure.

c. During a power failure, the area of any irradiator fusion device where sources are located may be entered only when using an operable and calibrated radiation survey meter.

41 of 152 25

Example: § 36.41 Construction monitoring and acceptance testing

a. Shielding. For panoramic irradiators fusion devices, the licensee shall monitor the construction of the shielding to verify that its construction meets design specifications and generally accepted building code requirements for reinforced concrete.

b. Foundations. For panoramic irradiators fusion devices, the licensee shall monitor the construction of the foundations to verify that their construction meets design specifications.

c. .

42 of 152 26

Example: § 36.23 Access control

a. [Physical Barrier] Each entrance to a radiation room at a panoramic irradiator fusion device must have a door or other physical barrier to prevent inadvertent entry of personnel if the sources are not in the shielded position device is on. [cannot turn device on when door is open, opening the door must cause shutdown,

, the door cannot prevent anyone inside the room from leaving].

b. [Alarms] In addition, each entrance to a radiation room at a panoramic irradiator fusion device must have an independent backup access control to detect personnel entry while the sources are exposed device is on.

Detection of entry must also activate a visible and audible alarm to make the individual entering the room aware of the hazard. The alarm must also alert at least one other individual who is onsite of the entry. That individual shall be trained on how to respond to the alarm and prepared to promptly render or summon assistance.

c. [Detectors] A radiation monitor must be provided to detect the presence of high radiation levels in the radiation room of a panoramic irradiator fusion device before personnel entry. The monitor must be integrated with personnel access door locks to prevent room access when radiation levels are high. Attempted personnel entry while the monitor measures high radiation levels, must activate the alarm described in paragraph (b) of this section. The monitor may be located in the entrance (normally referred to as the maze) but not in the direct radiation beam.

43 of 152 27

35.1000 can help manage technology innovation

• 35.1000 establishes dynamic program to address emerging medical technologies

- NRC-led team evaluates new medical technology

- Guidance developed by NRC & partners, flowed down to Agreement States

• Concept can be applied to new fusion technologies as they emerge, such as:

- New fusion approaches

- New fusion fuels

- New approaches to shielding or fuel breeding

- New tritium management technologies 44 of 152 28

The Part 30 framework can scale to the diversity of fusion

• Horizontal scaling can address different design

• Vertical scaling can address different sizes of themes and subsystems device (pertaining to radiological impact)

• In Part 35, for example:

• Examples:

- Subpart F - Manual Brachytherapy - Part 37 scales with onsite inventory with thresholds

- Subpart G - Sealed Sources for Diagnosis

- Part 30: emergency plan required if offsite dose

- Subpart H - Photon Emitting Remote consequence is above 1 rem/5 rem to thyroid Afterloader Units, Teletherapy Units, and Gamma Stereotactic Radiosurgery Units - Part 30: exempt quantities

- Subpart K - other uses (35.1000) 45 of 152 29

Implementation of materials framework tools for fusion Available Vehicles Guidance New Part (e.g., NUREG rev.) (e.g., Part 38)

NRC Considerations

• Legal permissibility (role of guidance vs. rules to incorporate desired controls)

• Ability to support Agreement State implementation

• Ease of resolution (simplest path often best path)

Initial devices can be licensed under the current Part 3046 offramework 152 as needed, as longer-term solution developed 30

• Fusion devices are not of significance to the common defense and security

• Potential material security risks can be adequately handled by Part 37 Conclusions

• The Part 30 framework has many regulatory tools suitable to handle fusion

• There are options on how to implement these existing tools 47 of 152 31

Questions?

48 of 152 32

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 49 of 152 5:30 pm Adjourn 7

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 50 of 152 5:30 pm Adjourn 8

Public Comment on Fusion Safety & Licensing B.A. Grierson 51 of 152 1

Director, FPP Design Hub

GAs Approach to a Fusion Pilot Plant (FPP)

• General Atomics is pursuing a FPP concept and is focused on safety, licensing, and social impact

- Appropriate regulations to ensure public and worker safety

- Inclusion of safety, licensing, and byproduct disposal in FPP requirements

- Embracing the need for a social license

- Offering our voice 52 of 152 2

What is Fusion?

• Fusion is the process that powers the stars, and occurs when two light elements (such as hydrogen) combine into a heavier element (such as helium) under extremely high temperatures and pressures Key differences from fission:

Helium

• Fusion requires energy input to combine elements Deuterium

- Cannot create a runaway nuclear reaction

• Fusion is fueled by hydrogen (deuterium and tritium)

- Extracted from seawater and created with lithium Energy

• Fusion requires a vacuum

- A leak in the vessel instantly stops the process

• Fusion emits only helium Tritium Neutron

- Does not produce high-level long-lived radioactive waste or byproducts for proliferation 53 of 152 3

Safety is Essential in the Fusion Community

• Safety & licensing

- Strategic objective of Community Planning Process

- Pilot plant safety case should pave the way for commercial electricity

• Safety assessments have been performed for multiple devices

- Larger (R>6 m, 1 GWe) device: ARIES, DEMO, K-DEMO

- Smaller (R<5 m) devices: FNSF

• More compact & higher confinement devices at lower fusion power offer safety advantages

- Smaller Reduced volume for tritium inventory and byproduct materials

- Lower fusion power smaller tritium processing capacity needed 54 of 152 4

Community Plan Safety Recommendations Develop the balance of plant technology, remote handling, maintenance approach, and licensing framework necessary to ensure safe and reliable operation of the fusion pilot plant

• Establish working group to develop licensing approach

• Establish technical basis for safety and licensing

• Develop sensors and diagnostics for survey

• Establish strategies for remote calibration, alignment, maintenance, and replacement of components

• Carry out conceptual design and small-scale tests of balance of plant equipment 55 of 152 5

The Fusion Blanket A Key Component for Fusion Safety and Waste Assessment

• Lithium in the blanket provides source of tritium 6Li + n 4He + T

• One neutron is produced from D-T

- Can only get one T back

- Must add neutron multiplier (Be, Pb) to increase tritium breeding Plasma

• Choices of materials affects safety assessment

- Breeding material: solid, liquid

- Coolant: water, helium

- Structural & functional material: Steel, alloy, ceramic Example investigated in detail: PbLi breeder with dual helium/PbLi cooling, reduced activation steel w/silicon carbide insulator X. Wang, et. al., Fus. Sci. & Tech. 67 193-219 (2015) 56 of 152 6

Utilizing Silicon Carbide in a Compact Tokamak FPP

• RAFM steels superior to conventional steel due to lower Ni and better thermal properties1

• SiC offers further advantages2

- Lower activation than RAFM steel

- Reduced waste and decay heat challenge for maintenance

- High temperature strength superior to steel for high thermal efficiency

- Material compatibility with PbLi with low corrosion 1H. Tanigawa et. al., Nucl. Fusion 57 092004 (2017) 2M. Tillack, et. al., Fus. Eng. and Design 180, 113155 (2022) 57 of 152 7

Recent Advances in Silicon Carbide (SiC) Address Previous Challenges

• GAs Nuclear Technologies and Materials Division demonstrated SiC in accident tolerant fuels for fission reactors in conditions relevant to fusion

• Acceptably low He permeation at internal pressures far beyond those needed to cool a fusion first wall

• Engineered SiC/Tungsten (W) materials have superior heat removal capabilities and resistance to plasma-induced damage M. Tillack, et. al., Fus. Eng. and Design 180, 113155 (2022) 58 of 152 8

Past and Current Studies Rely on ALARA Safety Policy Principle As Low As Reasonably Achievable ARIES-AT [1], ARIES-ACT1[2], FNSF[3] studies guided by DOE-STD-6002-96

• The public shall be protected such that no individual bears significant additional risk to health and safety from the operation of those facilities above the risks to which members of the general population are normally exposed

• Fusion facility workers shall be protected such that the risks to which they are exposed at a fusion facility are no greater than those to which they would be exposed at a comparable industrial facility

• Risks both to the public and to workers shall be maintained as low as reasonably achievable (ALARA)

• The need for an off-site evacuation plan shall be avoided

• Wastes, especially high-level radioactive wastes, shall be minimized 1D. Petti et. al., Fus. Eng. and Des. 80 111-137 (2006) 2Humrickhouse & Merrill, Fus. Sci. & Tech. 67 167-178 (2015) 3Humrickhouse & Merrill, Fus. End. & Design. 135 302-303 (2018) 59 of 152 9

Previously Studied Scenarios Remain Highly Relevant

• Long term station blackout (LTSBO) can initiate two primary scenarios requiring decay heat removal:

1. Loss of flow accident (LOFA)

2. Loss of coolant accident (LOCA)

• Maintenance cycle inclusion of decay heat

• In-vessel off-normal events

- Mobilization of tritium from co-deposits

• Loss of vacuum or pumping

- Release of tritium into cryostat

- Release of tritium into stack Humrickhouse & Merrill, Fus. Sci. & Tech. 67 167-178 (2015) MELCOR (Originally SNL) modified for fusion by INL 60 of 152 10

Unique Safety Considerations

• Fusion has unique safety considerations distinct from fission power plants

- Tritium as a fuel is the primary component of fusion systems for radiation protection

- Low-level waste byproduct materials are unique to fusion components

• Tools are available for performing safety assessments for fusion devices

- MELCOR, TMAP, HOTSPOT

• Key design features and recommendations that limit tritium permeation and losses identified

- i.e. reduced lengths of cooling pipes 61 of 152 11

Tokamak Fusion Pilot Plants and Power Plant Safety The analyses show that none of these accidents are expected to breach confinement boundaries or lead to large releases of radioactive material from the ARIES-ACT1 power core.

Humrickhouse & Merrill, Fus. Sci. & Tech. 67 167-178 (2015) 62 of 152 12

The National Academies 21 Report Made a Recommendation Consistent with Studies Reviewed: 10 CFR Part 20/30

• Finding: A regulatory process that minimizes unnecessary regulatory burden is a critical element of the nations development of the most cost-effective fusion pilot plant

• Finding: Because existing nuclear regulatory requirements for utilization facilities (10 CFR Part 50) is tailored to fission power reactors, it is not well suited to fusion technology

• Finding: The current regulatory framework used for radiation protection and byproduct material provided under 10 CFR Parts 20 and 30 is well suited to fusion technology 63 of 152 13

GAs Approach to a Fusion Pilot Plant (FPP)

• General Atomics is pursuing a FPP concept focused on safety, licensing, and social impact

- Appropriate regulations to ensure public and worker safety

- Inclusion of safety, licensing, and byproduct disposal in FPP requirements

- Embracing the need for a social license

- Offering our voice We agree with the recommendation of the National Academies that fusion byproducts be classified as accelerator byproducts under Part 30 Regulation 64 of 152 14

Thank you to the NRC for the opportunity to present Thank you for your attention 65 of 152 15

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 66 of 152 5:30 pm Adjourn 9

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 67 of 152 5:30 pm Adjourn 10

Right-sizing Regulation based on Scale of Fusion Facility Hazards Patrick White (r.patrick.white@gmail.com)

Project Manager, Nuclear Innovation Alliance (pwhite@nuclearinnovationalliance.org)

Nuclear Regulatory Commission Public Meeting - June 7, 2022 Meeting Topic: Developing Options for a Regulatory Framework for Commercial Fusion Energy Systems 68 of 152

Development of regulation for fusion is challenging due to technology diversity and early stage of design Confinement Methods Fusion Reactions Fusion Fuel Cycles Power Conversion Cycle Facility Size 69 of 152 1

Regulatory requirements are the translation of social and political constraints to the technical constraints on an activity The NRC licenses and regulates Public Workers Environment the Nation's civilian use of radioactive materials to provide reasonable assurance of adequate protection of public Setting acceptable limits on:

health and safety and to promote

• Acute consequences the common defense and security

• Latent consequences and to protect the environment.

• Infrequent consequences

• Cumulative consequences

• Societally prioritized consequences 70 of 152 2

Development of regulatory requirements can be arbitrary and reflect a variety of competing stakeholder interests, assumptions Selected Regulatory Limits for Tritium Contamination of Drinking Water Australia 76,103 Finland 30,000 Switzerland 10,000 WHO 10,000 Russia 7,700 Canada (Ontario) 7,000 United States 740 European Union 100 Ontario Proposed Limits 20 California Public Health Goal 14.8 0 25000 50000 75000 Tritium Concentration (Bq/L) 71 of 152 3

Definition of regulatory requirements requires selection of prescriptive or performance-based regulatory regimes Drawbacks Prescriptive

• Predictable

• Inflexible regulation

• Consistent

• Hard to codify Performance-based

• Versatile

• Harder to review regulation

• Simple to develop

• Inherent variability 72 of 152 4

Prescriptive tiered regulatory frameworks can result in inconsistent, inadequate, or inappropriate regulatory requirements Site source term limit (e.g., 15 kCi tritium)

Class A Requirements Class B Requirements Consequence

• Radiological inventory

• Fusion facility siting

• Dose health effects

• Radionuclide form

• Release conditions

• Dose conversion relevant

• Release fractions

• Meteorological conditions

• Emergency protective parameters

• Other radionuclides

• Surrounding populations actions post-release 73 of 152 5

Performance-based tiered regulatory frameworks can result in overly burdensome regulatory requirements Offsite dose limit (e.g., 1 rem TEDE)

Class A Requirements Class B Requirements Evaluation

• Evaluation complexity

• Evaluation conservatism

• Methodological assumptions

• Reliance on engineered safeguards, relevant

• Implicit or explicit treatment of systems, structures, components parameters probability, uncertainty, risk to meet regulatory limits 74 of 152 6

Uniform performance-based regulatory requirements and scalable reviews enable consistent regulation of diverse fusion technologies Unform performance-based Scalable regulatory treatment based on applicant regulatory safety case for compliance with requirements requirements Define consistent Scale regulatory Develop applicant regulatory reviews based on specific safety case requirements safety case 75 of 152 7

Uniform performance-based regulatory requirements and scalable reviews enable consistent regulation of diverse fusion technologies Unform performance-based Scalable regulatory treatment based on applicant regulatory safety case for compliance with requirements requirements Define consistent Scale regulatory Develop applicant regulatory reviews based on specific safety case requirements safety case 76 of 152 8

Limits Comparison of regulatory limits and goals is be challenging based on technology and hazard differences 10 CFR 30.72 Material Threshold Tritium Inventory > 20,000 Ci for Emergency Planning 10 CFR 20 Appendix B Tritium Release to Air < 10e-7 µCi/ml Effluent Release Limits 10 CFR 20 Annual Dose Limit for Total public dose < 0.1 rem per year Members of the Public EPA Protective Action Limit Maximum public dose equivalent > 1 rem for Public Evacuation 10 CFR 50.32 Reactor Siting Public exposed dose equivalent < 25 rem Evaluation Limits NRC Policy Statement on Latent Total excess cancer fatalities Quantitative Health Objective < 0.1% all other causes NRC Policy Statement on Acute Total excess early fatalities Quantitative Health Objective 77 of 152 < 0.1% all other causes 9

Limits Hierarchical hazard limits facilitate development of societally consistent regulatory limits across technologies Hierarchical Assumption Total hazard inventory limit Release fraction, form Hazard release limit Release conditions, duration Concentration release limit Exposure pathway, dilution Concentration exposure limit Exposure conditions Dose/total exposure limit Dose/consequence model Indirect consequence limit Population conditions Direct consequence limit 78 of 152 10

Limits Hierarchical hazard limits facilitate development of societally consistent regulatory limits across technologies Hierarchical Assumption Maximum hazard inventory Total hazard of 78kCi Tritium inventory limit Release fraction, form Hazard release limit Release conditions, duration Additional Concentration Example Limit: assumptions release limit Exposure pathway, dilution Fusion acute hazard limits for Concentration 500 MWe power plants based exposure limit on natural gas energy emissions Exposure conditions Maximum single dose of Dose/total 0.61 rem to population exposure limit Dose/consequence model 35 lifetime excess Indirect consequence fatalities per 100k limit Population conditions 890 lifetime 90 lifetime Direct excess fatalities excess fatalities consequence limit Natural Gas Power Plant Fusion Power Plant 79 of 152 11

Limits Hierarchical hazard limits also enable applicants to define simplified regulatory requirements for operation Hierarchical Assumption Total hazard inventory limit Release fraction, form Hazard release limit Release conditions, duration Concentration Dose Based Applicant Defined release limit Exposure Limits Inventory Limit Exposure pathway, dilution Concentration exposure limit Maintain facility Maintain facility Exposure conditions Dose/total to satisfy safety inventory below exposure limit basis evaluation limit to satisfy Dose/consequence model assumptions safety case Indirect consequence limit Population conditions Direct consequence limit 80 of 152 12

Uniform performance-based regulatory requirements and scalable reviews enable consistent regulation of diverse fusion technologies Unform performance-based Scalable regulatory treatment based on applicant regulatory safety case for compliance with requirements requirements Define consistent Scale regulatory Develop applicant regulatory reviews based on specific safety case requirements safety case 81 of 152 13

Method Licensing evaluation methods do not determine safety -

they demonstrate compliance with limits Increasing Level of Detail Example Limit:

Shape must occupy less than 50% of total box area 11/16 = 69% 30/64 = 47% 84/256= 33%

Fails Regulatory Limit Passes Regulatory Limit Passes Regulatory Limit 82 of 152 14

Method Licensing evaluation assumptions and conservatisms are balanced with design changes to meet limits

• Greater safety margin

• Same safety margin

• New design, constraints

• No design constraints

• Simpler safety case

• More complex safety case 83 of 152 15

Method Licensing evaluation methods vary in their detail and inherent conservatisms when evaluating regulatory compliance Simplified Licensing Analyses Worst Case Release Evaluation Whats the worst that could happen?

Maximum Credible Release Evaluation Whats the worst that could really happen?

Deterministic Design Basis Analysis What would happen if?

Probabilistic Design Basis Analysis Detailed Licensing How likely is it and what would happen if?

Analyses 84 of 152 16

Method Selecting licensing evaluations requires characterization of regulatory and design tradeoffs Increasing Licensing Evaluation Detail Reduce hazard Reduce hazard Reduce hazard Reduce hazard by design by design by design by design Worst Case Refine hazard Refine hazard Refine hazard by analysis by analysis by analysis Release Increasing Evaluation Reduce effective Reduce effective Reduce effective Regulatory hazard by design hazard by design hazard by design Burden Maximum Reduce hazard Reduce hazard probability probability Credible Release Evaluation Deterministic Refine probability by analysis Design Basis Evaluation Probabilistic Design Basis 85 of 152 Evaluation 17

Uniform performance-based regulatory requirements and scalable reviews enable consistent regulation of diverse fusion technologies Unform performance-based Scalable regulatory treatment based on applicant regulatory safety case for compliance with requirements requirements Define consistent Scale regulatory Develop applicant regulatory reviews based on specific safety case requirements safety case 86 of 152 18

Review Facilities using simpler safety case to meet performance-based regulation should have lower regulatory burden Safety Case Basis Example Regulatory Oversight Inherent safety by technology Review hazard identification (hazards not present)

Inherent safety by design Review and validate hazard limitation (hazards limited) by design, licensing evaluation methods Passive safety by design Validate SSC performance, limiting conditions, (limited reliance on SSCs) licensing evaluation methods Increasing Regulatory Active safety by design Validate SSC performance, supporting systems, Burden (reliance on SSCs) limiting conditions, licensing evaluation methods Active safety by operations Validate human performance, all operations, (reliance on human action) limiting conditions, licensing evaluation methods Consequence mitigation Validate bounding events, facility performance, by design or operation operator 87 of 152 action, licensing evaluation methods 19

Review Applicants can develop facility-specific safety case with consideration of technical, business, and economic factors Initial facility safety case fails to meet regulatory Consideration factors include:

requirements with simplified licensing analysis

• Technical feasibility of design changes

• Economic impact of changes Changes to Changes to Changes to on design or analysis facility design, evaluation other parts of

• Schedule impacts of revised siting methods safety case design or analysis methods

• Regulatory uncertainty or duration of review Updated facility safety case meets regulatory

• Public opinion/business risk requirements and can be submitted for NRC review of new safety case 88 of 152 20

Review Regulatory frameworks can reflect the independent oversight needed to ensure compliance with regulatory limits Applicant submits safety NRC staff provide initial NRC staff reviews safety NRC staff approves case and proposes review review of safety basis, case to confirm compliance application with license scope based on methods, and confirms review with regulatory limits, can conditions, sets continued license conditions scope and goals iterate with applicant oversight agreement

• Clear, concise regulatory rule language

• Adequate regulatory guidance and reports Factors critical to

• Regulatory precedent and Commission direction regulatory success

• Effective applicant and NRC project management

• Keeping review focused on safety basis factors 89 of 152 21

Review Regulatory requirements on radiation exposure could serve as uniform performance-based requirements for scaled review Example Safety Basis Example Scaled Review

• Site-wide tritium < 10 g

• Limited NRC review to validate Fusion

• 300 m to site boundary site-wide inventory, evaluation Facility A

• Maximum credible evaluation

• Conditions on site inventory

• Site-wide tritium > 150 g

• Detailed NRC review on design, Fusion

• Safety systems credited with evaluations, licensing events Facility B mitigating accident release

• Conditions on facility operation

• Design basis safety evaluation and maintenance 90 of 152 22

Uniform performance-based regulatory requirements and scalable reviews enable consistent regulation of diverse fusion technologies Unform performance-based Scalable regulatory treatment based on applicant regulatory safety case for compliance with requirements requirements Define consistent Scale regulatory Develop applicant regulatory reviews based on specific safety case requirements safety case 91 of 152 23

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 92 of 152 5:30 pm Adjourn 11

Fusion and Tritium Accident Risks and Analysis NRC Public Meeting (June 7th, 2022)

Dave Babineau, Brenda Garcia-Diaz, Jim Klein, Bob Sindelar, Marlene Moore, and George Larsen Savannah River National Lab SRNL-STI-2022-00263 6/7/2022 93 of 152 Managed and operated by Battelle Savannah River Alliance, LLC for the U. S. Department of Energy.

Tritium Fuel Cycle: Similar Core for All Applications with Blanket Integration for Fusion

• Main Fuel Cycle Processes are Similar to Other Tritium Cycles

- Bulk separation of hydrogen isotopes from other gases

- Remove impurities that enter process (e.g. HTO, nitrogen, etc.)

- Store and account for isotopes

- Clean exhaust gas and ensure it is suitable for release

• Blanket Tritium Extraction &

DIR Unique to Fusion

- Proposed blanket technologies vary significantly and are at low TRL levels

- Need caution with SF6 used for high voltage electronics and tritiated ammonia generated from N2 used in divertor 94 of 152 2

Key Fuel Cycle Areas for Regulation and Safeguards

1. Fusion Device 4

- Primarily a radiation hazard due to activation of materials (similar to accelerator)

- Minor amounts of tritium in the device compared 2

to the tritium processing systems (however tritium uptake needs to be considered) 3

2. Tritium Processing

- Chemical plant with transferable radiological contamination hazard due to presence of tritium

- Significant experience at SRS and with NNSA on regulation/operation

3. Breeding Blanket

- High temperatures with potential for air-sensitive materials (e.g. Pb-Li, LiT) and also TF or beryllium / beryllium salts 1

4. Process Control & Safety Systems

- Tritium accountancy and/or tritium inventory needs

- Limit tritium releases due to permeation, operation and maintenance activities 95 of 152 3

Tritium Processing Regulation Considerations

• Tritium is Unique among Radionuclides

- Tritium is an exception to DOE-STD-1027 in terms of regulation

• At the recommendation of the Tritium Focus Group, the [hazard facility class] tritium threshold values were provided by the Tritium Focus Group (TFG) and are not calculated using the methodology in this Standard.

[Brown et al., Sandia2022-4187]

- Tritium has many unique properties

• Permeates solid metals

• Isotopically exchanges with protium or deuterium atoms in other materials

• Can be present as a gas (elemental or oxide), liquid (oxide or organic), or solid (hydride or organic) within the same facility

• Autocatalytic - spontaneously, but not necessarily quickly, reacts with other species

• Form of Tritium in Accident Scenarios is Critical

- Dose Coefficient (DC) for tritiated water (HTO) 10,000 times higher than the DC for tritium gas (HT) and the DC for an insoluble tritiated particle can be about ~14x that of HTO per DOE-STD-1129 (depends on particle size)

- Accident scenarios involving fires near tritium sources are often the limiting cases in accident analysis

• Since the DC for tritiated water vapor is much greater than for T2 gas, facility-wide accidents involving fires or explosions are generally the default scenarios of greatest concern for overall facility hazard categorization. [Brown et al., Sandia2022-4187]

96 of 152 4

Fires, Tritium, and Conversion of Tritium to HTO

• Oxidation Kinetics of Tritium are Not Well Studied or Understood

- There are limited literature sources that provide the chemical reaction kinetics of the tritium oxidation process available to use to address the spectrum of events. There are several references in the LA-UR-01-1825 report and kinetics data are inconsistent.

- DOE/NNSA does not have any reports that have studied the kinetics of the combustion of actual tritium in open spaces but have only used surrogates (i.e.

- deuterium or protium)

- All available tritium oxidation rates / conversion percentages borrow from limited studies of tritium oxidation with and without catalysts in controlled spaces, or use experiential data from actual hydrogen deflagrations to attempt to develop a bounding value for the percent of tritium oxide that results in certain events

- SRNL/SRS personnel have proposed needed fundamental studies with partners, because more studies are needed with actual tritium (none have been funded as of now)

• Many Tritium Oxidation / Combustion Scenarios are Based on Unconfined Spaces and Not Facilities

- LA-UR-01-1825, cited by presenters in the March 23rd meeting (ML22081A057), references unconfined space studies when analyzing hazards for a large facility

• The HTO conversion percentage of 10% that was mentioned in that report was not intended as a bounding value according to the report authors

• The 10% HTO conversion percentage assumption is not standard in DOE/NNSA analysis of hazards at tritium facilities

• Tritium conversion of elemental to oxide and MAR dispersion is very dependent on space geometry and environmental conditions at the time of the release

• Hazard Analyses for Facilities are More Comprehensive than Using Bounding Tritium Conversion Values (e.g. - 10%)

- Regulatory Frameworks and Detailed Licensing Evaluation following methods outlined in Regulatory Frameworks and Evaluation Methodologies for the Licensing of Commercial Fusion Reactors [White PhD Thesis, 2021] are much more common

- Analysis of fire scenarios where the fire is confined such as a process vessel breach or adjacent fire to a tritium release are much more common scenarios used in accident analysis 97 of 152 5

Regulatory Framework Should Allow Accident Analysis Approaches that can Best Handle Potential Bounding Accident Scenarios Tritium Processing Accident Scenarios from the Tritium Processing Accident Scenarios from the Tritium Extraction Facility (TEF) Tritium Extraction Facility (TEF) at SRS Fire External Events Fire in one or more rooms resulting in the release of Vehicle crash results in the release of tritium, with and radioactive material (DU, HTO) without fire Full facility fire results in release of radioactive material Natural Disasters (total Material-at-Risk (MAR) released as HTO) Seismic event involving all buildings causes a fire that Explosion results in release of radioactive material (bounding MAR Explosion in Primary confinement (piping, tanks) results released as HTO) in release of tritium Tornado involving all buildings causes a fire that results Explosion in Secondary confinement results in release of in release of radioactive material (bounding MAR tritium released as HTO)

Deflagration in transfer line results in release of tritium

• Defining a relevant set of accident scenarios and comparing them with Loss of Containment/Confinement how similar events are evaluated within the DOE/NNSA framework Loss of primary confinement outside glovebox (i.e. in could be helpful in determining the regulation framework transfer lines) results in release of tritium Loss of primary confinement and secondary confinement

• Fusion bounding tritium processing accidents will need to take into from piping, tanks, and beds (including process piping account hazards from other parts of the plant and stripper beds) results in release of tritium

• Pilot Plant inventory >30 g tritium would make the tritium processing Breach of underground transfer line results in release of portion of a fusion pilot plant be Hazard Category 2 in the DOE/ NNSA tritium framework 98 of 152 6

Potential Accident Scenarios for Fusion Device Operation, Tritium Breeding, and Balance-of-Plant

• Tritium Release During Fusion Machine Operation

- Tritium inventory in the plasma is likely to be small (<0.1 g of tritium), but Material at Risk (MAR) in that section of the facility is more likely due to inventory of cryogenic pellets or gas used for fueling; tritiated dust (e.g. - W or Be) from the first wall; or other areas of tritium uptake

- For example, an accident scenario for this section could be breech of containment and tritium oxidation ignited by high temperatures in the fusion machine

• Unclear if this would be a limiting accident scenario for the overall plant - more evaluation would be needed on a case-by-case basis

- In the DOE/NNSA framework, a facility containing only the fusion machine would likely be categorized as a radiological facility

(<1.6 g tritium), but presence of additional fuel or other tritium containing materials could exceed this limit

• Tritium Release from the Breeding Blanket

- Blankets vary in composition (e.g. - molten Pb-Li, ceramics, molten FLiBe) and typically will be at high temperatures

- Blankets will contain tritium derivatives based on their chemistry due to conversion of Li to tritium (e.g. - LiT in Pb-Li or TF in FLiBe)

- Breach of containment of the blanket can lead to:

• Release of tritium and conversion to HTO due to high temperatures and presence of moisture/air

• Potential worker hazards due to Pb, Be, fluorides

- Tritium inventory in the blanket is desired to be maintained low but is likely to be higher than in the fusion machine.

- In the DOE/NNSA framework, a blanket for a 50 MW pilot plant would likely be a Hazard Category 3 facility with respect to tritium (1.6 - 30 g tritium)

• Tritium Release from Power Cycle or other Tritium Recovery Systems

- The heat exchanger to the power cycle will likely permeate tritium and can lead to tritium in the power cycle or other parts of the plant where it could be released. (secondary or tertiary loops could mitigate this) 99 of 152 7

Tritium Form and Handling Hazards to Workers and the Environment

• DOE/NNSA Framework Incorporates Hazards to Workers and Environment in Addition to Hazards to Public

- Tritium fires caused by tritium stored on hydride beds are assumed to have higher impact to workers because of the potential inhalation of metal particles in addition to exposure to tritium

- DOE-HDBK-1184-2004 and DOE-HDBK-1129 are used in the DOE/NNSA framework to determine doses from insoluble tritium particles

- DOE-STD-1196-2011 is used for calculating Be dose effects to lungs if applicable from (BeOT or BeTx) or other applicable Be forms

- Tritium transport and deposition into the environment is also considered

• Hazards to Workers in a Commercial Fusion Plant

- Tritium transport and permeation is significantly different than movement of solid nuclear materials in a fission plant where releases during maintenance or with permeation, etc. have higher potential to impact workers

- Toxic components (e.g. - Pb, Be, and F) mixed with tritium from a breach of the blanket and/or neutron multiplier material would likely increase the hazard from the tritium similar to hydride beds

- Regulation around worker safety should consider both toxic hazards as well as radiological hazards from tritium and other radionuclides

• Hazards to Environment in a Commercial Fusion Plant

- Tritium emissions to the environment can be minimized, but they will not be eliminated.

- Regulation should consider effects from both the release of tritium (all forms) and toxic materials to the environment 100 of 152 8

Summary

• Tritium hazards for fusion should be evaluated for: 1) the fusion device, 2) tritium processing, 3) the breeding blanket, and

4) cybersecurity and process control risks as well as tritium safeguards (if deemed necessary)

• Tritium has unique properties when compared with radioisotopes of other elements

• Tritium oxide (HTO) and insoluble tritiated particles have health risks that are 10,000 and ~144,000 times higher than the molecular form (HT), respectively

• Risks from tritiated water make fires where tritium can be oxidized very important accident scenarios that are very often limiting cases

• The regulatory framework for fusion will need to be able to incorporate potential accident scenarios from all parts of the plant

• How regulations are approached for worker protection and environmental protection with OSHA and the EPA should be considered especially with hydride materials and breeding blanket materials

• NNSA/DOE and SRNL/SRS have extensive experience handling tritium at the quantities required for fusion machines and balance of plant systems and can be a resource to the fusion community and NRC 101 of 152 9

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 102 of 152 5:30 pm Adjourn 12

Development of Integral Management Scheme for Fusion Radioactive Materials:

Recycling and Clearance, Avoiding Disposal Laila El-Guebaly Fusion Technology Institute University of Wisconsin-Madison https://fti.neep.wisc.edu/fti.neep.wisc.edu/ncoe/home.html NRC Virtual Public Meeting:

Developing Options for a Regulatory Framework for Fusion Energy Systems June 7, 2022 103 of 152

Worldwide Effort to Develop Fusion for Next Generation in 20-40 y

• Seven magnetic fusion energy (MFE) concepts developed since 1950s:

Tokamaks Field-reversed configurations (FRC)

Stellarators Reversed-field pinches (RFP)

Spherical tokamak (ST) Spheromaks Tandem mirrors (TM).

• At the present time, main concept supporting pathway from ITER to power plant is D-T tokamak.

• Private industries will develop several fusion concepts by 2030 and examine other fuel cycles, not only D-T.

• Several countries developed roadmaps with end goal of operating 1st fusion power plant by 2050. These roadmaps take different pathways, depending on:

• Degree of extrapolation beyond ITER

• Readiness of fusion materials with verifiable irradiated design properties

• What technologies remain to be developed and matured for viable 1st power plant?

(or build 1st plant and then solve remaining problems: materials, safety, etc.)

• What other facilities will be needed between ITER and 1st power plant?

104 of 152

Majority of Fusion designs employing Reduced-activation materials generate low-level waste (under strict alloying element and impurity control),

but in large quantity compared to fission.

This is serious environmental issue that could influence public acceptability of fusion energy and should be solved at any price.

3 105 of 152

Worldwide Interest in Building Fusion Power Plants by 2050 MFE Power Plant Studies, Worldwide 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 DEMO Japan EU-DEMO EU Tokamak (33)

FRC (9) K-DEMO Korean Demo (National Fusion Research Institute) Korea

> 60 conceptual magnetic fusion Stellarator (8) ARIES-ACT Aggressive and Conservative Tokamaks (UCSD)

Mirror (5) DEMO China RFP (3)

DEMO-S steady state DEMO Russia Spheromak (2) designs* developed since 1970 to Spherical Torus (2) SlimCS Compact low-A DEMO Japan Other (1) FDS-II,III China power plant China ARIES-CS Compact Stellarator (UCSD)

Total: 63 VECTOR VEry Compact TOkamak Reactor Japan identify and resolve physics/technology US: 39 International: 24 DEMO2001 Japan PPCS Conceptual Study of Fusion Power Plants EU ARIES-AT Advanced Tokamak (UCSD)

APEX-FRC pulsed liquid walled power plant (UCLA)

RF/UW-FRC D-3He fuelled power plant Russia A-SSTR2 Combine advantages of A-SSTR and DREAM HSR Helias Stellarator Reactor Japan EU challenges.

UK-ST conceptual design EU UW-FRC UW-FRC power plant (UW)

ARIES-ST Spherical Torus (UCSD)

ARIES-RS Reversed-Shear tokamak (UCSD)

A-SSTR Advanced Steady State Tokamak Japan Most studies and experiments are FFHR Force Free Helical Reactor DREAM Drastically Easy Maintenance Tokamak CREST Compact Reversed Shear Tokamak Japan Japan Japan currently devoted to D-T fuel cycle -

LLNL Spheromak advanced spheromak fusion rx (LLNL)

SPPS Stellarator Power Plant Study (UCSD)

SEAFP Safety and Env. Assessment of Fusion Power PULSAR-I/II pulsed tokamak (UCSD)

EU least demanding to reach ignition.

ARIES-IV Second-stability tokamak (UCLA)

Stress on fusion safety stimulated ARIES-II Second-stability tokamak (UCLA)

ARIES-III D-3He-fuelled tokamak (UCLA)

Japan SSTR steady state tokamak Japan ARTEMIS D-3He fuelled FRC power plant ARIES-I First-stability tokamak (UCLA)

Apollo D-3He Fuelled Tokamak (UW)

Japan Ruby D-3He FRC reactor study research on fuel cycles other than D-T, Ra D-3He Fuelled Tandem Mirror (UW)

TITAN reversed-field pinch (UCLA)

ASRA6C Advanced Stellarator Reactor (UW/FRG) based on advanced reactions, such as MINIMARS Compact Mirror Advanced Reactor Study (LLNL)

FIREBIRD pulsed FRC power plant (U. Washington)

MARS Mirror Advanced Reactor Study (LLNL)

D-D, D-3He, P-11B, and 3He-3He.

Spheromak steady state spheromak (LANL)

CRFPR Compact Reversed Field Pinch Reactor (LANL)

UWTOR-M Modular Stellarator Power Reactor (UW)

Russia RT reactor torsatron Wildcat catalyzed D-D tokamak (ANL)

MSR Modular Stellarator Reactor (LANL)

Majority of designs provide CAD EBTR Elmo Bumpy Torus Reactor Conceptual Design Study (ORNL)

RFPR Reversed Field Pinch Reactor (LANL)

WITAMIR-I Wisconsin Tandem Mirror (UW) drawings, info on volume/mass of all FRC Compact fusion reactor (LANL)

TRACT FRC fusion reactor study (MSNW)

STARFIRE Commercial Tokamak Fusion Power Plant (ANL) fusion power core (FPC) components NUWMAK University of Wisconsin Tokamak (UW)

SAFFIRE D-3He fuelled FRC design (UIUC)

Russia TVE-2500 high temperature power plant with direct conversion (first wall -> magnet) and their support structures.

UWMAK-III University of Wisconsin Tokamak (UW)

UWMAK-II University of Wisconsin Tokamak (UW)

A Fusion Power Plant (PPPL)

UWMAK-I University of Wisconsin Tokamak (UW)

Premak University of Wisconsin Tokamak (UW) 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 calendar year

• Without going much into great details, these conceptual designs assess viability of new concepts as economically competitive energy sources, critically evaluate strengths and limitations, and ultimately guide national science and technology R&D programs.

106 of 152

U.S. ARIES Project (1988-2013) Examined Several Fusion Concepts with Commercial Perspective in Mind ARIES-ACT Tokamak (with reduced activation structure) 1988 2013 http://qedfusion.org/aries.shtml The ARIES project focused mainly on the device. Less attention was107 of 152to the BOP.

given

Worldwide Pathways to Fusion Energy ITER US-DEMO ?

1st Power Plant by 2050 EU-DEMO JET JA-DEMO

+ TFTR, DIII-D, EAST, JT-60SA, KSTAR, etc.

+ Supporting R&D activities:

Blanket Development Program, China Materials Testing Facility, Advanced or Conservative Divertor and PMI Testing Physics and/or Technology?

Facilities, Code Development and Simulations, etc.

6 108 of 152

Radioactivity Level Varies Widely with Designs High Radioactivity (Power Plant):

One-of-a-kind Devices

• High radwaste inventory

• High fusion power (2-3 GW)

• High NWL (> 1 MW/m2)

• High availability (85%)

• > 50 y lifetime

• High n fluence (> 20 MWy/m2)

This leads to RWM* challenges that require serious effort to manage radwaste.

China Building eight 1-GWe fusion plants annually, fleet of 1,000 D-T fusion power plants could provide

~10% of world electricity demand by ~2200.

Low Radioactivity (ITER): Resources Will Eventually be Limited

• Relatively low radwaste inventory Luigi Di Pace, Suitable Recycling Techniques for DEMO Activated

• 500 MW fusion power Metals. IAEA TECDOC on Fusion RWM, to be published in 2023.

• Low NWL (0.5 MW/m2)

• 20 y lifetime

• Low availability 7 ____________

• Low n fluence (0.3 MWy/m2) 109 of 152

• Radioactive waste (radwaste) management

Fusion Designs Employing Reduced-Activation Materials Could Generate Only LLW#, but in Large Quantity Compared to Fission LLW and ILW (pressure vessel)

HLW (fuel rods)

Actual volume of fusion power components in ITER, JA, EU, China, and US ARIES designs; not compacted, no replacements; no plasma chamber; no cryostat/bioshield.

What would be the public reaction to sizable fusion radwaste?

8 110 of 152

Nine Essential Criteria for Attractive Fusion Power Plants Reflect Safety and Environmental Attributes Nine essential criteria embody U.S. vision for end goal of attractive fusion power plants. These criteria provide key insights on strategic directions that U.S. program should pursue to demonstrate the feasibility of fusion during development phase and to ultimately develop attractive and economically competitive power plants that will be acceptable to utilities, industries, and public.

1. Economically competitive compared to other sources of electric energy

2. Stable electric power production with load-following capacity and range of unit sizes

3. Steady state operation with well-controlled transients and high system availability

4. Tritium self-sufficiency with closed fuel cycle

5. Reduced-activation, radiation-resistant structural and functional materials to extend safe service lifetime, and reduce cost, radwaste stream, and radiation hazards

6. RAMI: Reliability, availability, maintainability, and inspectability for all components

7. Easy to license by regulatory agencies

8. Intrinsic safety, minimal environmental impact, and wide public acceptance:

1. No need for evacuation plan even during severe accident

2. No local or global environmental impacts

3. Minimal occupational exposure to radiation/toxicity

4. Routine emissions and tritium leakage below allowable levels

5. Inclusion of proliferation safeguards by design

9. Integral radwaste management and decommissioning plan

1. Minimize radioactive waste by clever design, recycling, and clearance

2. No high-level waste; only Class C low-level waste or better (Class A).

- Report for National Academy of Sciences (NAS): L. El-Guebaly et al., Principles, Values, Metrics and Criteria for the Development of Magnetic Fusion Energy, Working Group-1 Report, March 14, 2018.

- L. El-Guebaly, Nuclear Assessment to Support ARIES Power Plants and Next Step 9 Facilities: Emerging Challenges and Lessons Learned, 111 of 152 Fusion Science and Technology, Vol 74, #4, 340-369 (2018).

Options for Managing Radioactive Materials

• Geological land based disposal - default option for fission waste for many nations.

• Transmutation of long-lived radionuclides Others came and

( proliferation concerns for fission, not for fusion).

• Disposal in space - not feasible due to international treaties.

mostly disappeared

• Ice-sheet disposal @ north/south pole - not feasible due to international treaties.

• Ocean disposal (1947-1993; Prohibited in 1994).

• Recycling / reprocessing (reuse within nuclear industry). Activated materials -

• Clearance (release to commercial market if materials are slightly radioactive, not counted as radwaste containing 10 µSv/y (< 1% of background radiation)).

Each option faces its own set of challenges 10 112 of 152

The Disposal Option

• Environmental concerns

• U.S. disposal classifications

• Status of U.S. repositories

• Key issues and needs for fusion.

11 113 of 152

Environmental Concerns and Facts

• Concerns:

• For LLW fusion, the issue is land disposal sites oversight for 100 years

• Water is prime carrier for wastes. If water infiltrates, it will corrode waste containers

• Over time, radioactivity could leak, contaminate groundwater, and eventually reach humans.

• Land-based disposal has been the preferred U.S. option for LLW from commercial nuclear facilities since 1960s.

• Of particular concern for fusion is the need to detritiate some of fusion radwaste prior to disposal to prevent tritium from eventually reaching underground water sources.

12 114 of 152

NRC Classifications of Radwaste

• Radwaste sources: nuclear industries, utilities (from 104 US commercial fission reactors),

university research laboratories, manufacturing and food irradiation facilities, hospitals, healthcare companies, and Department of Energy (DOE) facilities.

• Nuclear Regulatory Commission (NRC) 10 C.F.R. Part 61* has specific disposal requirement for each type of waste.

• LLW classified into three classes:

- Class A is the least hazardous type of waste

- Class B is more radioactive than Class A

- Class C waste must meet more rigorous requirements. Intrusion barrier, such as thick concrete slab, is added to waste trenches placed > 8 m deep in ground.

Most fusion radwaste qualify as Class A or Class C LLW.

Some may qualify as GTCC#

• US Code of Federal Regulations, Title 10, Energy, Part 61, Licensing Requirements for Land Disposal of Radioactive Waste (2020).

https://www.nrc.gov/reading-rm/doc-collections/cfr/part060/full-text.html.

1. NRC is currently preparing the regulatory basis for disposal of GTCC waste# (LLW that contains radionuclide concentrations exceeding Class C limits).

The Draft Regulatory Basis for the Disposal of GTCC and Transuranic Waste is available 13at ADAMS Accession No. ML19059A403.

115 https://www.nr c.gov/waste/llw-disposal/llw-pa/gtcc-transuranic-waste-disposal.htmlof 152

Waste Disposal Rating - Metric for Waste Classification NRC 10 CFR Part61* classifies the waste at 100 years after shutdown according to its waste disposal rating (WDR), which is the ratio of specific activity (in Ci/m3) to allowable limit, summed over all radioisotopes:

• WDR < 1 means Class C LLW (using Class C limits)

• WDR < 0.1 means waste may qualify as Class A LLW (to be re-evaluated using Class A limits)

• WDR > 1 means GTCC.

In few fusion designs, there are components with WDR >> 1 Many radionuclides of interest to fusion are not in NRC 10 CFR Part 61 14

• US Code of Federal Regulations, Title 10, Energy, Part 61, Licensing Requirements for Land Disposal of 116 of 152 Radioactive Waste (2020). https://www.nrc.gov/reading-rm/doc-collections/cfr/part060/full-text.html.

In Early 1990s, Fetter Defined Specific Activity Limits for Majority of Fusion Radionuclides Fetters waste disposal limits Fetter et al.* expanded the NRC 10CFR61 list considerably and performed analyses to determine the Class C specific activity limits for many radionuclides of interest to fusion using a methodology similar to that of NRC. Although Fetters calculations carry no regulatory endorsement by NRC, they are useful to fusion designers because they include many fusion-specific radioisotopes:

• Not in regulation form yet

• Approved by U.S. Fusion Safety Standing Committee#

• Class C limits for 53 radionuclides of interest to fusion

• No limits available for Class A LLW.

• S. FETTER, E. T. CHENG, and F. M. MANN, Long Term Radioactive Waste from Fusion Reactors: Part II, Fusion Engineering and Design, 13, 239 (1990).

1. DOE STANDARD, Safety of Magnetic Fusion Facilities: Guidance, DOE-STD-6003-96 (1996). Currently under revision.

117 of 152 https://www.standards.doe.gov/standards-documents/6000/6003-astd-1996/@@images/file.

NRC vs. Fetters Specific Activity Limits for Radionuclides NRC 10CFR61 developed specific activity Fetter expanded list of NRC 10CFR61 limits for only 9/11 elements/radioisotopes*, radionuclides and determined specific presenting a weak basis for selecting reduced- activity limits for fusion-relevant isotopes activation materials for fusion and their 39/53 elements/radioisotopes*

qualification as Class A and C LLW with 5y < t1/2 < 1012y, assuming waste form is metal.

US Code of Federal Regulations, Title 10, Energy, Part 61, Licensing Requirements for Land S. FETTER, E. T. CHENG, and F. M. MANN, Long Term Disposal of Radioactive Waste (2020). Radioactive Waste from Fusion Reactors: Part II, Fusion

______ Engineering and Design, 13, 239 (1990).

16

• Excluding actinides and fission products. 118 of 152

Fusion Radionuclide Profile

@ shutdown:

56/367 elements/radioisotopes with wide range of activities and half-lives 106

@ 100 y after shutdown:

38/71 elements/radioisotopes with various activities and half-lives Interim measures:

All fusion components should meet both NRC and Fetter's limits until NRC develops official guidelines for fusion radwaste.

119 of 152

Missing Fusion Radioisotopes in Both Limits Introduce Uncertainties in WDR Evaluation Elements / Radioisotopes

@ 100 y after shutdown Typical RAFM FW of Fusion Designs 38 / 71 NRC 10CFR61 Limits 9 / 11*

Fetters Limits 39 / 53*

What would be the impact on WDR prediction of missing fusion radioisotopes in both NRC and Fetters limit?

• excluding actinides and fission products. 120 of 152

Worldwide Materials Program Developed Reduced-Activation Materials for Fusion Applications Why?

- To qualify fusion radwaste as LLW (with WDR < 1)

- Minimize hazard and release risk

- Allow multiple recycling of radioactive materials before reaching dose limit Compositional limitations for fusion designs:

- Avoid (as much as practically possible) alloying with Al, N, Ni, C, Cu, Nb, Mo, Re, Ag, etc. that generate long-lived radionuclides.

- Specific impurities (such as Nb, Mo, Ag, Re, etc.) must be controlled to low level to avoid generating HLW.

• Nb impurity impacts WDR greatly and should be kept below 1 wppm.

• Impact of such limitations on cost of reduced-activation materials is unknown and should be assessed.

121 of 152

Examining Alternate Steels for ARIES-ACT2 FW and Blanket Nb impurity has major impact on WDR To meet U.S. LLW design requirements:

• Limit Nb impurity to < 1 wppm in F82H and EUROFER97 - both reduced-activation steels.

• Avoid using three steels: SS316 (of ITER) and Inconel-718, and D9 (of ARC design).

122 of 152

Radwaste of All ARIES Designs Classifies as LLW with Strict Alloying Elements and Impurity Control Waste Processing ARIES-ACT2 and Temporary Storage FPC Components#

(~8,000 m3 mostly steel)

1. Excluding bioshield and cryostat, balance-of-plant equipment, and external components 40% 60% (e.g., HX, turbines, cooling towers, etc.).

Class C LLW Class A LLW 5-8 m below Soil and ground surface Gravel Class A LLW

> 8 m below Containers Will be disposed of ground surface ($100s/ft3) in commercial LLW repositories.

Thick Concrete Slab Class C LLW Where?

Containers

($1,000s/ft3) 21 123 of 152

Locations of Four Large-Scale LLW Commercial Repositories in U.S.

Richland - WA LLW Commercial

?

Yucca Mountain - NV HLW (Spent fuel only; no LLW or GTCC) Barnwell - SC Commercial LLW (not politically acceptable)

Commercial Clive - UT WIPP - NM WCS LLW TRU Waste LLW Commercial For Defense Program Commercial

______________ only 22 and Government https://www.nrc.gov/waste/llw-disposal/licensing/locations.html 124 of 152

3 out of 4 Commercial LLW Repositories will be Closed by ~2050

• Barnwell facility in SC:

- 1971 - 2038

- Receives Class A, B, C LLW

- Supports east-coast reactors and hospitals

- 870,000 m3 capacity

- 90% Full

- In July 2008, Barnwell facility closed to all LLW received from outside 3 Compact States: CT, NJ, SC

- 36 states lost access to Barnwell, having no place to dispose 91% of their Class B & C LLW

- NRC now allows storing LLW onsite for extended period.

• Clive facility in Utah:

- Receives nationwide Class A LLW only

- Disposes 98% of US Class A waste volume, but does not accept sealed sources or biological tissue waste - a great concern for biotech industry

- 4,571,000 m3 capacity

- Closure by 2024.

• Richland facility in WA:

- Class A, B, C LLW

- Supports 11 northwest states

- 1,700,000 m3 capacity

- Closure by 2056.

• WCS (Waste Control Specialists) in TX:

- Newest facility for disposal, storage and treatment of LLW from all 50 states.

- Class A, B, C LLW.

Limited option for disposal 23will drive disposal cost high 125 of 152

Key Issues and Needs for Disposal Some issues/needs are related to activation areas inside FPC (that could be addressed by fusion designers),

while others are related to areas outside FPC, requiring industrial, national lab, and fission experiences, DOE-OFES and NRC involvements.

Many of the identified issues/needs overlap with fission industries, but adaptation to fusion is necessary (radionuclides, radiation level, component size, weight, etc.).

Issues:

• Large volume of radwaste (mostly Class A and Class C LLW, but some designs (like ARC) generate GTCC)

• Impact on WDR prediction of missing fusion radioisotopes in NRC and Fetters limits

• High disposal cost that continues to increase with time (for preparation, characterization, packaging, interim storage, transportation, licensing, and disposal)

• Limited capacity of existing LLW repositories

• No commercial HLW repositories exist in the U.S. (or elsewhere); fission power plants store their HLW onsite

• Political difficulty of siting new land disposal sites limits their capacity

• Prediction of repositories conditions for long time into future

• Radwaste burden for future generations.

Needs:

• Revised fusion-specific activity limits and disposal protocols for LLW and GTCC issued by NRC

• Disposal sites designed for tritiated radwaste

• Reversible disposal process and retrievable waste (to gain public acceptance and ease licensing)

• Large capacity and low-cost interim storage facility 24 with decay heat removal capability.

126 of 152

Key Takeaways:

Existing U.S. LLW sites cannot handle tritiated fusion radwaste Disposing sizable fusion materials in repository is NOT environmentally attractive, nor economic solution Shallow land burial waste management strategy may NOT be practical when large quantities of fusion waste is to be managed in 21st century*

• D. Petti, SNOWMASS Hot Topic - Chamber Science and Technology, Re-Evaluation 25 of the Use of Low Activation Materials in Waste Management Strategies for Fusion. (1999). 127 of 152

What We Suggest...

• New strategy should be developed to limit radwaste for fusion energy, calling for rethinking, education, and research to make it a reality.

• Focus on:

- Minimizing the waste by clever design

- Limiting radwaste requiring disposal

- Emphasizing recycling* and clearance# to minimize waste.

- Develop fusion-specific disposal class and regulations for any remaining fusion radwaste.

• Why?

- Fusion generates large quantity of LLW (mostly steel and concrete)

- Limited capacity of existing LLW repositories

- Political difficulty of building new repositories (for both LLW and HLW)

- Stricter regulations and tighter environmental controls

- Uncertain geological conditions over long time

- Minimize radwaste burden for future generations

- Reclaim resources by recycling and clearance

- Promote fusion as energy source with minimal environmental impact

- Gain public acceptability for fusion

- Support decommissioning goals of U.S. and IAEA in 21st century.

• Reclaim resources and reuse within nuclear industry.

1. Unconditional release to commercial market to fabricate as consumer products26 (or dispose of in non-nuclear landfill). This is currently performed on case-by-case basis for U.S. nuclear facilities. Clearable materials are safe, containing 10 µSv/y (< 1% of background radiation).

128 of 152

Decommissioning Goal for 21st Century Many organizations have given some attention to the issue of reducing the amount of radioactive waste generated when decommissioning nuclear plants U.S.:

• Department of Energy*, NRC, and Fusion Safety Standing Committee (currently under revision):

- A goal of decommissioning U.S. nuclear facilities is to minimize waste volumes, recycle, and clear as much of materials as practical. Reasons:

• Reclaim use of metal resources

• Reduce the volume of LLW requiring disposal.

• Related references:

Hrncir, T., et al., (2013). The impact of radioactive steel recycling on the public and professionals, Journal of Hazardous Materials, 254-255,98-106.

US Department of Energy, Recycle of Scrap Metals Originating from Radiological Areas, DOE/EA-1919 (2012). https://www.energy.gov/nepa/ea-1919-recycle-scrap-metals-originating-radiological-areas.

Radiological Assessments for Clearance of Equipment and Materials from Nuclear Facilities, Draft NUREG-1640, Nuclear Regulatory Commission, Washington, D.C. (1998).

ANIGSTEIN, R. et al., Radiological Assessments for Clearance of Materials from Nuclear Facilities, volume 1, NUREG-1640, US Nuclear Regulatory Commission (2003).

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1640/.

U.S. Department of Energy, Clearance And Release Of Personal Property From Accelerator 27 Facilities, DOE-STD-6004-2016 (2016).

https://www.standards.doe.gov/standards-documents/6000/6004-astd-2016. 129 of 152

Decommissioning Goal for 21st Century (Cont.)

• U.S. 1999 Snowmass Report on Chamber Science and Technology*:

- A waste management strategy focused solely on low activation materials does not address the entirely of the radioactive waste picture for fusion. We recommend a strategy that is balanced with respect to minimizing both the hazards (via low activation materials) and the volume (via reduction of ex-vessel activation). As such, we propose the following minimum design goals:

• To reduce the overall radioactive waste volume by limiting vessel/ex-vessel activation so that the bulkier large volume components can be cleared or recycled for re-use

• To minimize activated materials in a fusion plant that cannot be cleared or recycled.

_______________ 28

• https://fire.pppl.gov/snowmass02.html#Snowmass99Section. 130 of 152

Decommissioning Goal for 21st Century (Cont.)

• 2007 FESAC Report*:

- Beyond the need to avoid the production of high-level waste, there is a need to establish a more complete waste management strategy that examines all the types of waste anticipated for DEMO and the anticipated more restricted regulatory environment for disposal of radioactive material. DEMO designs should consider recycle and reuse as much as possible. Development of suitable waste reduction recycling and clearance strategies is required for the expected quantities of power plant relevant materials.

• M. Greenwald et al., Priorities, Gaps and Opportunities: Towards A Long-Range 29 Strategic Plan For Magnetic Fusion Energy. A Report to the Fusion 131 of 152 Energy Sciences Advisory Committee, October 2007. https://burningplasma.org/web/ReNeW/FESAC_Greenwald_final_report.pdf.

Decommissioning Goal for 21st Century (Cont.)

IAEA

- The 2008 IAEA report* recommends recycling and waste minimization of nuclear waste, stating: The IAEA should expand its efforts to help states establish safe and sustainable approaches to managing spent fuel and nuclear waste, including recycling and waste minimization, and to build public and international support for implementing these approaches.

• https://www.belfercenter.org/sites/default/files/files/publication/gov2008-22gc52inf-4.pdf.

Related references:

Clearance Levels for Radionuclides in Solid Materials - Application of Exemption Principles, Interim Report IAEA-TECDOC-855, International Atomic Energy Agency, Vienna (1996).

International Atomic Energy Agency, Application of the concepts of exclusion, exemption and clearance. IAEA Safety Standards Series, No. RS-G-1.7 (2004). http://www-pub.iaea.org/MTCD/publications/PDF/Pub1202_web.pdf.

30 for Exclusion, Exemption and Clearance, Safety Report Series Safety Report Series [IAEA-SRS44] (2005) Derivation of Activity Concentration Values 132 of 152 N.44 International Atomic Energy Agency (2005). https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1213_web.pdf.

What should be done to embrace recycling/clearance as prime option for fusion radwaste management?

Recyclable Clearable 40 200 cm Bioshield Typical Radial Cryostat Build Magnet Increasing Clearance 31 Potential 133 of 152

The Recycling Option

• Relatively easy to apply from science perspectives

• DOE guidelines exist

• Applied successfully to decommissioning projects since 2000

• Key issues and needs for fusion.

134 of 152

Recycling Example: ARIES-ACT2 OB Components (FW - Bioshield) 40 200 cm ARIES-ACT2 Cryostat Bioshield ARIES-ACT2 OB Components All FPC components can potentially be recycled in < 1y with advanced RH equipment*.

Cryostat (and bioshield) could be recycled with hands-on shortly after shutdown.

• Other recycling criteria may apply.

33 135 of 152

Key Issues and Needs for Recycling Some issues/needs are related to activation areas inside FPC (that could be addressed by fusion designers), while others are related to areas outside FPC, requiring industrial, national lab, and fission experiences, DOE-OFES and NRC involvements. Many of the identified issues/needs overlap with fission industries, but adaptation to fusion is necessary (radionuclides, radiation level, component size, weight, etc.).

Issues:

• Separation of various activated materials from complex components

• Radiochemical or isotopic separation processes for some materials, if needed

• Treatment and remote re-fabrication of radioactive materials. Any residual He that affects rewelding?

• Radiotoxicity and radioisotope buildup and release by subsequent reuse

• Properties of recycled materials? Any structural role? Reuse as filler?

• Handling of tritiated materials during recycling

• Management of secondary waste. Any materials for disposal? Volume? Radwaste level?

• Energy demand for recycling process

• Cost of recycled materials

• Recycling plant capacity and support ratio Needs:

• NRC to regulate the use of recycled materials from nuclear facilities

• R&D program to address recycling issues

• Radiation-resistant remote handling equipment

• Rigorous time-dependent radiotoxicity of recycled liquid breeders

• Reversible assembling process of components and constituents (to ease separation of materials after use)

• Efficient detritiation system to remove > 95% of tritium before recycling

• Large capacity and low-cost interim storage facility with decay heat removal capability

• Nuclear industry should accept recycled materials 34

• Recycling infrastructure. 136 of 152

Fusion-Related Recycling Developments

• U.S. ORNL Y-12 Team [1,2] is investigating possibility of recycling ~10 Tons of Be metal (from U.S. weapons program) to reuse as tiles for ITER FW (to avoid the disposal cost) and launched testing program to qualify Be for ITER.

• TFTR experimental facility (decommissioned in 1999-2002):

E. Perry, J. Chrzanowski, C. Gentile, R. Parsells, K. Rule, R. Strykowsky, M. Viola, Decommissioning of the Tokamak Fusion Test Reactor. Princeton Plasma Physics Laboratory report PPPL-3896 (October 2003). https://digital.library.unt.edu/ark:/67531/metadc735658/.

• 200 tons of lead was removed for re-use. Lead bricks were painted (to mitigate lead health issues) and re-used them as shield for diagnostics used on NSTXU.

• ~54 thousand cubic feet of radwaste was disposed of at Hanford site

• 400 tons of concrete shielding was stored at different locations on-site. Clearable?

• JET experimental facility (to be decommissioned in 2020s):

V. McKay and D. Coombs, Management of Radioactive Waste from Fusion - The JET Experience. IAEA TECDOC on Fusion RWM. To be published in 2023.

• Majority of solids (> 100,000 m3) either recyclable or suitable for clearance

• ~1,000 m3 of LLW and ILW will be managed, treated, disposed and/or transferred for long-term storage.

1. W. Rogerson, S. Brown (Y-12 NSC at ORNL) et al., Qualification of Unneeded US Weapons Program Beryllium Metal for ITER, presented at 21st TOFE (2014).

2. W. Rogerson, R. Hardesty, Qualifying Nuclear Weapons Enterprise Legacy Metal for 35ITER, presented at 28th SOFE (2019).

137 of 152

The Clearance Option

• Relatively easy to apply from science perspectives

• NRC and IAEA guidelines/regulations/standards* exist

• Clearance from DOE facilities has been ongoing on a case-by-case basis

• Key issues and needs for fusion.

• Anigstein, R. et al., Radiological Assessments for Clearance of Materials from Nuclear Facilities, volume 1, NUREG-1640, US Nuclear Regulatory Commission, June 2003. Available at: http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1640/.

• # U.S. Department of Energy, Clearance And Release Of Personal Property From Accelerator Facilities, DOE-STD-6004-2016 (March 2016).

• International Atomic Energy Agency, Application of the concepts of exclusion, exemption and clearance, IAEA Safety Standards Series, No. RS-G-1.7 (2004).

Available at: http://www-pub.iaea.org/MTCD/publications/PDF/Pub1202_web.pdf. 138 of 152

Clearance Example: ARIES-ACT2 Outboard Components 40 200 cm Cryostat Bioshield Cryostat, Bioshield, and some magnet constituents are clearable in ~20 y after decommissioning L. El-Guebaly and M. Zucchetti, Progress and Challenges of Handling Fusion Radioactive Materials, Fusion Science and Technology, Vol. 68, No. 3 (2015) 484-491.

L. El-Guebaly, L. Mynsberge, A. Davis, C. DAngelo, A. Rowcliffe, B. Pint, Design and 37 Evaluation of Nuclear System for ARIES-ACT2 Power Plant with DCLL Blanket, Fusion Science and Technology, 72, Issue 1 (2017) 17-40. 139 of 152

Clearance Concerns

• All CI evaluations lack numerous fusion-relevant radioisotopes that introduce uncertainties in CI prediction of fusion components.

• Discrepancies between clearance standards that could impact CI evaluation and storage period.

• Future efforts by NRC, IAEA and others to harmonize the clearance standards and reduce the differences are essential as steel products and scraps are routinely sold internationally and clearable materials may penetrate the worldwide commercial market.

38 140 of 152

Key Issues and Needs for Clearance Some issues/needs are related to activation areas inside FPC (that could be addressed by fusion designers), while others are related to areas outside FPC, requiring industrial, national lab, and fission experiences, DOE-OFES and NRC involvements. Many of the identified issues/needs overlap with fission industries, but adaptation to fusion is necessary (radionuclides, radiation level, component size, weight, etc.).

Issues:

• Discrepancies* between proposed NRC & IAEA clearance standards

• Impact on clearance index prediction of missing radioisotopes (such as 10Be, 26Al,32Si,91,92Nb, 98Tc, 113mCd, 121mSn, 150Eu, 157,158Tb, 163,166mHo, 178nHf, 186m,187Re,193Pt, 208,210m,212Bi, and 209Po)

• Radioisotope buildup and release by subsequent reuse.

Needs:

• NRC clearance limits for fusion activated materials

• Accurate measurements and reduction of impurities that deter clearance of some components

• International effort to harmonize standards and regulations of clearance

• Reversible assembling process of components and constituents

• Large capacity and low-cost interim storage facility

• Clearance infrastructure

• Clearance market.

• El-Guebaly, L., Wilson, P. and Paige, D. (2006). Evolution of clearance standards and implications for radwaste management of fusion power plants, Fusion Science and Technology, 49, 62-73. 39 141 of 152

Example of Integral Decommissioning Projects

- Fission Reactors Plum Brook reactor in Ohio:

Smith, K. Mission complete, Construction & Demolition Recycling, volume 15, number 1, January/February 2013, pages 14-18. Available at:

http://www.cdrecycler.com/digital//20130102/index.html

- ~95% of all demolished materials (concrete and metals) were reused or recycled.

- Concrete stayed on site as backfill into the void of the reactor.

- Scrap steel was scanned for radiation before being sent to scrap metal yards.

- Contaminated material was placed in boxes for disposal at the Clive facility in Utah.

Trojan plant in Oregon*:

- All concrete structures were decontaminated and released for unrestricted use.

- D&D activity only disposed of 12,375 m3 of LLW due to its minimization of waste volumes and recycling.

Big Rock Point in Michigan*:

- Half of the concrete was non-impacted so it was reused (never had the potential for neutron activation or exposure to licensed radioactive material).

- Other half of the demolition debris (19.16 Mkg of predominantly concrete and some metals) was mildly contaminated or activated and the licensee requested disposal in a State of Michigan Type II landfill.

• Banovac, K. et al., Power Reactor Decommissioning - Regulatory Experiences from Trojan to Rancho Seco and Plants In-Between, Proceedings of the ANS Topical Meeting on Decommissioning, Decontamination, and Reutilization (DD&R 40 2010), Idaho Falls, Idaho, August 29-September 2, 2010, American Nuclear Society. 142 of 152

Conclusions

• It is just a matter of time to develop the fusion recycling and clearance technologies and their official regulations.

• Possibility of material recycling/clearance could be demonstrated by directed R&D programs. Many of the identified issues/needs overlap with fission industries, but adaptation to fusion is necessary (radionuclide profile, radiation level, component size, weight, etc.).

• NRC could develop fusion-specific category for LLW and GTCC remaining waste after recycling/clearance.

• Fusion designers should:

- Integrate the recycling and clearance approaches at early stages of fusion designs

- Involve industries and address issues/needs for recycling and clearance Some issues/needs are related to activation areas inside FPC (that could be addressed by fusion designers), while others are related to areas outside FPC, requiring industrial, national lab, and fission experiences, DOE-OFES and NRC involvements.

41 143 of 152

Flow Diagram for Fusion Decommissioning L.A. El-Guebaly and L. Cadwallader, Perspectives of Managing Fusion Radioactive Materials: Technical Challenges, Environmental Impact, and US Policy. Chapter in 42 NOVA Science Publishers, Inc.: Hauppauge, New York, USA. ISBN: 978 book: Radioactive Waste: Sources, Management and Health Risks. Susanna Fenton Editor.

63321-731-7 (2014). 144 of 152

Publications 145 of 152

ARIES Fusion-Related RWM Publications

• L. El-Guebaly, D. Henderson, A. Abdou, and P. Wilson, Clearance Issues for Advanced Fusion Power Plants, Fusion Technology, 39, No. 2, 986-990 (2001).

• D. Henderson, L. El-Guebaly, P. Wilson, and A. Abdou, Activation, Decay Heat, and Waste Disposal Analysis for ARIES-AT Power Plant, Fusion Technology, 39, No. 2, 444 (2001).

• L. El-Guebaly, P. Wilson, and D. Paige, Initial Activation Assessment of ARIES Compact Stellarator Power Plant, Fusion Science and Technology, 47, No. 3, 440-444 (2005).

• L. El-Guebaly, P. Wilson, and D. Paige, Evolution of Clearance Standards and Implications for Radwaste Management of Fusion Power Plants, Fusion Science and Technology, 49, 62-73 (2006).

• L. El-Guebaly, Environmental Aspects of Recent Trend in Managing Fusion Radwaste: Recycling and Clearance, Avoiding Disposal.

Proceedings of 2nd IAEA Technical Meeting on First Generation of Fusion Power Plants: Design & Technology, June 20 - 22, 2007, Vienna, Austria, IAEA-TM-32812. Published by IAEA on CD - ISBN: 978-92-0-159508-9.

• L. El-Guebaly, P. Wilson, D. Henderson, M. Sawan, G. Sviatoslavsky, T. Tautges et al., Designing ARIES-CS Compact Radial Build and Nuclear System: Neutronics, Shielding, and Activation, Fusion Science and Technology 54, No. 3 (2008) 747-770.

• L. El-Guebaly, V. Massaut, K. Tobita, and L. Cadwallader, Goals, Challenges, and Successes of Managing Fusion Active Materials.

Fusion Engineering and Design 83, Issues 7-9 (2008) 928-935.

• L. El-Guebaly, R. Kurtz, M. Rieth, H. Kurishita, A. Robinson, W-Based Alloys for Advanced Divertor Designs: Options and Environmental Impact of State-of-the-Art Alloys. Fusion Science and Technology 60, Number 1 (2011) 185-189.

• L. El-Guebaly, T. Huhn, A. Rowcliffe, S. Malang, and the ARIES-ACT Team, Design Challenges and Activation Concerns for ARIES Vacuum Vessel, Fusion Science and Technology 64, no. 3 (2013) 449-454.

• L.A. El-Guebaly and L. Cadwallader, Perspectives of Managing Fusion Radioactive Materials: Technical Challenges, Environmental Impact, and US Policy. Chapter in book: Radioactive Waste: Sources, Management and Health Risks. Susanna Fenton Editor. NOVA Science Publishers, Inc.: Hauppauge, New York, USA. ISBN: 978-1-63321-731-7 (2014).

https://www.novapublishers.com/catalog/product_info.php?products_id=51057.

• Laila El-Guebaly, Overview of ARIES Nuclear Assessments: Neutronics, Shielding, and Activation, Progress in Nuclear Science and Technology 4, 118-121 (2014). DOI: 10.15669

• L. El-Guebaly, L. Mynsberge, C. Martin, D. Henderson, Activation and Environmental Aspects of ARIES-ACT1 Power Plant, Fusion Science and Technology, 67, No. 1, 179-192 (Jan 2015). ISSN: 1536-1055.

• L. El-Guebaly, L. Mynsberge, A. Davis, C. DAngelo, A. Rowcliffe, B. Pint, Design and Evaluation of Nuclear System for ARIES-ACT2 Power Plant with DCLL Blanket, Fusion Science and Technology, 72, Issue 1 (2017) 17-40.

• L. El-Guebaly, Nuclear Assessment to Support ARIES Power Plants and Next Step Facilities: Emerging Challenges and Lessons Learned, Fusion Science and Technology, Vol 74, #4, 340-369 146(Nov.

44 2018).

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IEA Fusion-Related RWM Publications (U.S., EU, RF, China, S. Korea)

• L. El-Guebaly, R. Pampin, and M. Zucchetti, Clearance Considerations for Slightly-Irradiated Components of Fusion Power Plants. Nuclear Fusion 47 (2007) 480-484.

• M. Zucchetti, L. El-Guebaly, R. Forrest, T. Marshall, N. Taylor, and K. Tobita, The Feasibility of Recycling and Clearance of Active Materials from a Fusion Power Plant, Journal of Nuclear Materials 367-370 (August 2007) 1355-1360.

• M. Zucchetti, L. Di Pace, L. El-Guebaly, B.N. Kolbasov, V. Massaut, R. Pampin, and P. Wilson, An Integrated Approach to the Back-end of the Fusion Materials Cycle. Fusion Engineering and Design 83, Issues 10-12 (2008) 1706-1709.

• L. El-Guebaly, V. Massaut, K. Tobita, and L. Cadwallader, Goals, Challenges, and Successes of Managing Fusion Active Materials. Fusion Engineering and Design 83, Issues 7-9 (2008) 928-935.

• M. Zucchetti, L. Di Pace, L. El-Guebaly, B.N. Kolbasov, V. Massaut, R. Pampin, and P. Wilson, The Back End of the Fusion Materials Cycle. Fusion Science and Technology 52, No. 2 (2009) 109-139.

• M. Zucchetti, L. Di Pace, L. El-Guebaly, B.N. Kolbasov, V. Massaut, R. Pampin, and P. Wilson, The Back-End of Fusion Materials Cycle: Recycling and Clearance, Avoiding Disposal. Fusion Science and Technology 56, Number 2 (2009) 781-788.

• Luigi Di Pace, Laila El-Guebaly, Boris Kolbasov, Vincent Massaut and Massimo Zucchetti, Radioactive Waste Management of Fusion Power Plants, Chapter 14 in Book: Radioactive Waste. Dr. Rehab Abdel Rahman (Ed.). InTech Open Access Publisher, Rijeka, Croatia. ISBN: 978-953-51-0551-0, InTech (April 2012). Available at http://www.intechopen.com/books/radioactive-waste/radioactive-waste-management-of-fusion-power-plants

• M. Zucchetti, L. Di Pace, L. El-Guebaly, J.-H. Han, B. N. Kolbasov, V. Massaut, Y. Someya, K. Tobita, and M. Desecures, Recent Advances in Fusion Radioactive Material Studies, Fusion Engineering and Design, 88, Issues 6-8 (2013) 652-656.

• Boris Kolbasov, Laila El-Guebaly, Vladimir Khripunov, Youji Someya, Kenji Tobita, Massimo Zucchetti, Some Technological Problems of Fusion Materials Management, Fusion Engineering and Design, 89 (2014) 2013-2017.

• L. El-Guebaly and M. Zucchetti, Progress and Challenges of Handling Fusion Radioactive Materials, Fusion Science and Technology, Vol. 68, No. 3 (2015) 484-491.

• M. Zucchetti, Z. Chang, L. El-Guebaly, J.-H. Han, B. Kolbasov, V. Khripunov, M. Riva, Y. Someya, R. Testoni, K. Tobita, Radioactive Waste Studies in the Frame of the IEA Cooperative Program on the Environmental, Safety and Economic Aspects of Fusion Power. Fusion Science and Technology, 72 (4) (2017) 609-615.

• M. Zucchetti, Z. Chen, L. El-Guebaly, V. Khripunov, B. Kolbasov, D. Maisonnier, Y. Someya, M. Subbotin, R. Testoni, and K. Tobita, Progress in International Radioactive Fusion Waste Studies, Fusion Science and Technology, Vol 75, #5, 391-398 (2019).

45 147 of 152

EU, UK, China, RF Fusion-Related RWM Publications

• UK and Europe:

o L. Di Pace, A. Natalizio, Preliminary analysis of waste recycling scenarios for future fusion power plants, Fusion Engineering and Design, Vol. 69, pp. 775 - 779 (2003).

o L. Ooms, V. Massaut, Feasibility of fusion waste recycling, SCK-CEN Report, R-4056, 276/05-01 (2005).

o R. Pampin, R.A. Forrest, R. Bestwick, Consideration of strategies, industry experience, processes and time scales for the recycling of fusion irradiated material, UKAEA report FUS-539 (2006).

o V. Massaut, R. Bestwick, K. Brodén, L. Di Pace, L. Ooms, R. Pampin, State of the art of fusion material recycling and remaining issues, Fusion Engineering and Design 82 (2007) 2844-2849.

o Luigi Di Pace, Teresa Beone, Antonello Di Donato, Patrizia Miceli, Franco Macci, Roberto Piancaldini, Egidio Zanin, Feasibility Studies of DEMO Potential Waste Recycling by Proven Existing Industrial-Scale Processes, Fusion Engineering and Design 146 (2019) 107-110.

o Luigi Di Pace, Teresa Beone, Antonello Di Donato, Alessandro Astri, Alessandro Colaneri, Angelo Cea, Daphne Mirabile, Ali Gkhan Demir, DEMO radioactive wastes: decarburization, recycling and reuse by additive manufacturing, Fusion Engineering and Design, Volume 168, July 202Luigi Di Pace et al., Suitable Recycling Techniques for DEMO Activated Metals. IAEA TECDOC on Fusion RWM. To be published. .

o Teresa Beone et al., Application of Powder Metallurgy and Additive Manufacturing to Refabrication of DEMO Components/structures. IAEA TECDOC on Fusion RWM. To be published in 2023.

o Luigi Di Pace, Teresa Beone, Patrizia Miceli, Antonello Di Donato, Franco Macci, Egidio Zanin, Fusion specific approach and critical aspects in suitable industrial-scale processes and techniques for radioactive waste management of nuclear fusion power activated materials. Presented at 9th European Commission conference on Euratom research and training in radioactive waste management FISA 2019 - EURADWASTE 19, Pitesti, Romania. Conference proceedings: https://op.europa.eu/en/publication-detail/-

/publication/fe1b968b-cbc8-11ea-adf7-01aa75ed71a1/language-en/format-PDF/source-140505052

• China:

• Q. Cao et al., Preliminary Radwaste Assessment, Classification and Management Strategy for CFETR. IAEA TECDOC on Fusion RWM. To be published in 2023.

• X. Zhang et al., Activation Analysis and Radwaste Assessment of CFETR, submitted for publication in Fusion Engineering and Design.

• Russian Federation:

• .Bartenev, S. A., Kvasnitskij, I. B., Kolbasov, B. N., Romanov, P. V., Romanovskij, V. N. (2004). Radiochemical reprocessing of V-Cr-Ti alloy and its feasibility study, Journal of Nuclear Materials, 329-333, 406-410.

• S.A. Bartenev, B.N. Kolbasov, E.N. Li, P.V. Romanov, V.N. Romanovskij, N.G. Firsin. An improved procedure for radiochemical processing of activated fusion-reactor-relevant V-Cr-Ti alloy. Fusion Engineering and Design, v. 84, issues 2-6 (2009) 427-429. 46 148 of 152

IAEA Fusion-Related RWM Publications Just published:

Overview on the management of radioactive waste from fusion facilities: ITER, demonstration machines and power plants Sehila M. Gonzalez de Vicente, Nicholas A. Smith, Laila El-Guebaly et al.

Nuclear Fusion 62 085001 (2022) https://doi.org/10.1088/1741-4326/ac62f7 To be published in 2023:

IAEA TECDOC: Radioactive Waste Management for Fusion Facilities (tentative title).

40 attendees from 11 countries submitted 26 Papers at First IAEA Workshop on Radioactive Waste Management for Fusion Facilities. October 6-8, 2021, Vienna, AT.

47 149 of 152

Time Topic Speaker 1:00 pm Welcome, Introductions, and Overview NRC 1:10 pm NEPA Overview Don Palmrose 1:20 pm Agreement States Current Oversight of Fusion R&D Diego Saenz Activities 1:45 pm FIA Presentation Andrew Holland 2:15 pm Helion Presentation: AEA Common Defense and Michael Hua and Security and Application of Materials Framework Tools Sachin Desai Agenda 2:55 pm for Fusion Break 3:10 pm General Atomics Perspectives Brian Grierson 3:30 pm CFS Presentation Tyler Ellis 3:50 pm Right-sizing Regulation based on Scale of Fusion Patrick White Facility Hazards 4:20 pm Fusion and Tritium Accident Risks and Analysis Dave Babineau 4:40 pm Development of Integral Management Scheme for Laila El-Guebaly Fusion Radioactive Materials 5:00 pm Opportunity for Public Comment 150 of 152 5:30 pm Adjourn 13

Opportunity for Public Comment 151 of 152 14

Thank You!

152 of 152 15