ML23258A180

November 9, 2023 Public Meeting Presentation--Fusion Systems Proposed Rule

ML23258A180
Person / Time
Issue date:	11/09/2023
From:	Office of Nuclear Material Safety and Safeguards
To:
References
RIN 3150-AL00, NRC-2023-0071, NRC-006
Download: ML23258A180 (32)

Text

Rulemaking: Regulatory Framework for Fusion Systems NRC Public Meeting November 9, 2023

Time Topic Speaker Welcome & Meeting Logistics Dennis Andrukat Opening Remarks Adelaide Giantelli 1:00 pm Duncan White Duane White NRC Presentation - Specific Topics Cindy Rosales-Cooper Agenda Christianne Ridge Diego Saenz 2:00 pm BREAK All Questions & Answer Session /

2:10 pm All Public Feedback 3:50 pm Closing Remarks & Adjourn Dennis Andrukat Topic times are estimated and, depending on the participation level, the meeting could adjourn earlier than scheduled. If there are concerns with a potential early meeting adjournment, please inform the point of contact for this meeting.

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Adelaide Giantelli, Branch Chief State Agreement and Liaison Programs Branch Opening Remarks Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards US NRC 3

Overview &

Introduction Duncan White Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards US NRC 4

Commission Direction Fusion Systems On April 13, 2023, the Commission issued SRM-SECY-23-0001 Options for Licensing and Regulating Fusion Energy Systems (ML23103A449) directing the staff to implement a byproduct material approach to fusion energy system regulation.

BYPRODUCT MATERIAL NUREG-1556 GUIDANCE FRAMEWORK 5

Todays (November 9, 2023) Public Meeting:

ML23258A180 Presentation ML23258A182 Meeting Summary*

Previous Public Meeting: November 1, 2023 ML23258A171 Presentation Public Meetings ML23258A172 ML23258A169 Handout: Preliminary Draft Guidance Meeting Summary*

Previous Public Meeting: October 11, 2023:

ML23258A147 Presentation ML23258A145 Handout: Preliminary Proposed Rule Language - October 2023 ML23258A146 Meeting Summary

• These documents will be made public once finalized 6

Todays SPECIFIC TOPICS 7

Specific Topic:

Material Security Duane White Division of Physical and Cybersecurity Policy Office of Nuclear Security and Incident Response US NRC 8

Material Security Current security requirements in 10 CFR Part 20 and 10 CFR Part 37 are adequate for near-term designs of fusion systems.

10 CFR 20.1801 - Secure licensed materials in controlled or unrestricted areas from unauthorized removal or access 10 CFR Part 20 requires: 10 CFR 20.1802 - Control and maintain constant surveillance of licensed material that is in a controlled or unrestricted area and that is not in storage.

10 CFR Part 37 requires additional security measures if you possess an aggregated Category 1 or Category 2 quantity of radioactive material as listed in Appendix A of 10 CFR Part 37.

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Material Security

• If license application presents new elements (e.g., new activated product(s)) that do not fall under current requirements but could be considered a significant public health and safety or common defense and security concern, then existing regulations under 10 CFR Part 30 provide the authority to impose requirements on a case-by-case basis.

• Applicants are encouraged to engage in pre-application discussions with the regulator if they expect their application would contain new elements or activated products.

• Additional requirements, as necessary, would be issued by using license conditions or orders.

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Specific Topic:

Emergency Preparedness Cindy Rosales-Cooper Division of Preparedness and Response Office of Nuclear Security and Incident Response US NRC 11

Emergency Preparedness The emergency preparedness (EP) and response terminology in Part 30 may benefit from consistent Fusion facilities will be required to have terminology used by NRC utilization facility emergency response capabilities, licensees, Federal counterparts such as the Federal commensurate to the radiological hazard. Emergency Management Agency and the Department of Energy, as well as State and local offsite response organizations.

Part 30 can accommodate a graded approach to EP to account for variation in fusion system designs.

We are considering limited changes to Part 30 EP requirements to address the above and any potential unique risks with fusion systems.

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Question #1:

§ 30.4 Definitions Emergency Fusion facilities may benefit from an update to the emergency classification definitions in Part 30 to include Preparedness general emergency, unusual event, and other changes, consistent with a performance based, technology neutral approach. What are the benefits or consequences of this Specific approach to fusion systems and materials licensees under Part 30?

Questions 13

Question #2:

§ 30.32 Application for specific licenses Emergency 10 CFR 30.32 (i)(1) has emergency plan requirements based on Schedule C quantities for existing materials Preparedness facilities and technologies. What would be the benefits or consequences of requiring all fusion system applicants to submit a maximum dose evaluation and specific Specific emergency response plan for the expected quantities that will be present and generated at the facility instead Questions of applying the quantities in §30.72 Schedule C-Quantities of Radioactive Materials Requiring Consideration of the Need for an Emergency Plan for Responding to a Release?

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Question #3:

§ 30.32 Application for specific licenses Emergency The staff is considering whether to clearly specify, in the preliminary proposed 10 CFR 30.32(k)(2), the Preparedness requirement for response capabilities for protecting onsite personnel, as well as coordination with fire, medical, and local law enforcement agencies, as needed, Specific during an emergency as intended in NUREG-1140. What would be the benefits or consequences of doing so?

Questions 15

Specific Topic:

Waste Management Christianne Ridge Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards US NRC 16

Waste Management Key Issues

• Waste characteristics

• Fusion systems could generate waste with different physical forms or radionuclide contents than NRC considered during the development of low-level waste (LLW) regulations

• Safety analyses for LLW disposal facilities consider radionuclide concentrations and inventories

• Safety goals of the LLW classification tables can be accomplished in a risk-informed way with a site-specific intrusion assessment for wastes that differ significantly from waste characteristics NRC considered during the development of the classification tables

• Waste volumes

• Waste volumes are considered in the environmental review for this rulemaking

• Staff is considering whether applications should include an assessment of the disposal pathway as part of the decommissioning funding plan 17

Preliminary Proposed Rule Language Additional Changes to Part 20 New § 20.2008(c)

Waste resulting from fusion systems that differs significantly from the waste types and radionuclide concentrations considered during the development of 10 CFR Part 61 must be disposed of in a disposal facility that has completed a site-specific intrusion assessment that demonstrates the projected dose to an individual who inadvertently intrudes into the waste at the facility will be less than 5 millisievert (mSv) per year.

Notes:

• Blue text is being considered by NRC staff since the October 11, 2023 public meeting

• Guidance for determining if waste triggers the need for an inadvertent intrusion assessment will be provided in the proposed Volume 22 of NUREG-1556

• Guidance for conducting an inadvertent intrusion assessment is currently available in Draft NUREG-2175, Guidance for Conducting Technical Analyses for 10 CFR Part 61 18

Preliminary Proposed Rule Language Additional Changes to Part 20 (continued)

• Proposed rule change allows waste from fusion systems to be disposed at existing LLW disposal sites

• Proposed change uses a risk-informed approach based on site-specific intrusion assessment at LLW disposal facility to allow disposal of novel waste streams

• Does not require changes to Part 61

• Does not require changes to other sections and appendices in Part 20

• Consistent with LLW rulemaking currently underway 19

Contents of Application Item 11: Waste Management

• Application should include procedures for waste minimization, waste characterization, waste handling, safe and secure storage, and waste disposal

• Potential waste disposal methods include

• Transfer to LLW disposal facility

• Decay-in-storage (half-life < 120 days)

• Effluent releases under 10 CFR 20.1302(b)(2)

• Other methods authorized under § 20.2002 - § 20.2005

• For wastes to be transferred to a LLW disposal facility (e.g.,

tritium contaminated waste, activated components),

applicant should demonstrate whether a site-specific intrusion analysis is needed

• Proposed guidance in NUREG-1556 Volume 22 considers physical, chemical, and radiological characteristics 20

Specific Topic:

Facilities and Equipment Diego Saenz State of Wisconsin 21

Facilities and Equipment Regulations: 10 CFR 2.390, 10 CFR 20.1101(b), 10 CFR 20.1301, 10 CFR 20.1406, 10 CFR 30.33(a)(2), 10 CFR 30.35(g), 10 CFR 30.36.

Criteria: Facilities and equipment must be adequate to protect health and minimize danger to life or property. Under 10 CFR 20.1101(b) and 10 CFR 20.1406, the licensee must keep exposures to workers and the public ALARA and minimize the introduction of residual radioactivity into the site.

Discussion: Applicants must demonstrate that, together with any proposed administrative measures, their facilities and equipment provide sufficient engineered controls and barriers to protect the health and safety of the public and their employees, keep exposures to radiation and radioactive materials ALARA, and minimize the danger to life and property from the uses of the types and quantities of radioactive materials to be used.

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• Building(s) and description.

• Fusion device(s) name and specifics Typical

• A diagram and description of the locations of radiation material and radiation sources Information

• Methods used for determining shielding calculations, i.e. workload

• Written summary of each component and its shielding or Required by containment

• A separate summary table including the following for each Applicant for shielding/containment wall: Wall description, barrier type, control type, distance of occupied area, occupancy factor, existing shielding, calculated shielding, amount recommended.

Facilities and

• Equipment layout/blueprints of the area which is affected by neutron, X-ray and gamma scatter.

Equipment

• A description of the areas assigned for the production, transfer, storage, preparation, shipping, security, and measurement of radioactive materials.

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• A description and diagrams showing the locations of delivery lines, shielded areas and equipment (e.g., hot cells, waste), the Typical proximity of radiation sources to unrestricted areas, and other items related to radiation safety.

• Penetrations into the fusion device and methods to prevent Information radiation streaming

• A description and diagram of the ventilation system, including Required by representative equipment such as hot cells, glove boxes, or fume hoods. Pertinent airflow rates, differential pressures, filtration Applicant for equipment, and monitoring systems should be described in terms of the minimum performance to be achieved. Confirm that such Facilities and systems will be employed for the use or storage of radioactive materials that have the probability of becoming airborne.

Equipment

• Verification that ventilation systems ensure that effluents are ALARA, are within the dose limits of 10 CFR 20.1301, and are within the ALARA constraints for air emissions under 10 CFR 20.1101(d).

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Specific Topic:

Tritium Bioassay Duncan White Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards US NRC 25

Determination of Internal Exposure:

Tritium Bioassay Program Criteria: 10 CFR 20.1204 For purposes of assessing dose used to determine compliance with occupational dose equivalent limits, the licensee shall, when required under § 20.1502, take suitable and timely measurements of

• Concentrations of radioactive materials in air in work areas; or

• Quantities of radionuclides in the body; or

• Quantities of radionuclides excreted from the body; or

• Combinations of these measurements.

Discussion:

Bioassays determine the kinds, quantities or concentrations, and in some cases, the location of radioactive material in the human body. A bioassay can be made by direct measurement or by analysis and evaluation of material excreted or removed from the human body.

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Requirement for Bioassay

• 10% the annual limit on intake in 10 CFR 20 Routine Frequency of

• Baseline, periodic, and termination Bioassay measurements

• Conducted to assess occupational dose and Measurements confirm appropriate engineering and administrative controls in place Special

• Evaluation of abnormal or inadvertent intakes 27

Procedures for Bioassay Program

• Licensees will need to develop, implement, and maintain written procedures for determination of internal exposure that meet the requirements in 10 CFR 20.1204.

• The following items should be considered in developing procedures for collecting bioassay samples:

• the type of bioassay that must be performed (direct or indirect)

• the number of samples or data points to be collected

• the frequency of sampling (e.g., hourly, daily, weekly, once)

• the size of the sample to be collected (e.g., 24-hour urine collection)

• the ease or difficulty of sample collection

• the need for written instructions to be provided to the sample collector, who may be the contaminated individual 28

29 Question & Answer Session Please Note: the NRC is not accepting official comments during this meeting and will not provide any official responses to any feedback provided during this meeting.

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Upcoming Events/Milestones Upcoming

• To be determined Public Meeting Proposed Rule

• Proposed rule and draft guidance Schedule to Commission by Fall 2024 31

Thank You!

Contacts Dennis Andrukat, Rulemaking Project Public Information Manager NRC Public Website:

https://www.nrc.gov/materials/fusion-energy-Dennis.Andrukat@nrc.gov systems.html Duncan White, Technical Lead Duncan.White@nrc.gov Docket ID: NRC-2023-0071 (www.regulations.gov)

Presentation: ADAMS Accession No.ML23258A180 Meeting Notice / Feedback Form:

https://www.nrc.gov/pmns/mtg?do=details&C ode=20231014 32