SECY-21-0095, Summary of June 1, 2022, Public Meeting on Staff'S Consideration of Options for a Potential Rulemaking on Security for Special Nuclear Material

Summary of June 1, 2022, Public Meeting on Staff'S Consideration of Options for a Potential Rulemaking on Security for Special Nuclear Material

ML22214A036
Person / Time
Issue date:	08/02/2022
From:	Marshall Kohen Office of Nuclear Security and Incident Response
To:	Michele Sampson Office of Nuclear Security and Incident Response
References
SRM-SECY-21-0095
Download: ML22214A036 (6)

Text

August 2, 2022 MEMORANDUM TO: Michele Sampson, Acting Director Division of Physical and Cyber Security Policy Office of Nuclear Security and Incident Response FROM: Marshall Kohen, Project Manager /RA/

Division of Physical and Cyber Security Policy Office of Nuclear Security and Incident Response

SUMMARY

OF JUNE 1, 2022, PUBLIC MEETING ON STAFFS CONSIDERATION OF OPTIONS FOR A POTENTIAL RULEMAKING ON SECURITY FOR SPECIAL NUCLEAR MATERIAL On June 1, 2022, a public meeting was held virtually using Microsoft Teams. This meeting was held to update stakeholders on the staffs progress in developing a notation vote paper in response to Commission direction in SRM-SECY-21-0095, Discontinuation of Rulemaking -

Enhanced Security of Special Nuclear Material, dated August 4, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21217A065). In the public meeting notice, the staff offered stakeholders the opportunity to make a presentation at the meeting; one stakeholder, the Union of Concerned Scientists (UCS) availed itself of this opportunity.

A member of the NRC staff provided a presentation consisting of key messages, a brief history of the project, and a description of the revised structure of the paper, i.e., into two major topics (Physical Protection of Unirradiated SNM and Physical Protection of Irradiated SNM) and the associated options for Commission consideration. Following the staffs presentation, Dr. Edwin Lyman provided a presentation on UCS perspective on the paper and attendant issues. Dr.

Lyman reiterated UCS support, particularly noting a preference for one of the options that staff was considering, that is, to resume the rulemaking from the 2015 regulatory basis document and include consideration of security of spent nuclear fuel. In these remarks, Dr. Lyman also (1) reiterated his support for infusing the concept of material attractiveness via dilution into the rule, (2) advocated for strengthening of NRCs requirements for security of Category II quantities of SNM and (3) noted the importance of increasing the self-protecting radiation threshold for spent fuel and considering security for alternate nuclear materials such as isotopes of americium and neptunium. Dr. Lymans presentation is available in ADAMS under Accession No. ML22151A166.

Stakeholders were then permitted to ask questions and make comments. Specific issues that were mentioned or discussed in detail included the relationship between this paper and one regarding security for Independent Spent Fuel Storage Installations; concerns about the utility and details of options related to rulemaking; concerns about industrys ability to provide substantive comments without sufficient information on proposed options; and the potential

M. Sampson impact of each option on non-power reactors and a corresponding reminder that Section 104(c) of the Atomic Energy Act of 1954, as amended, requires minimal regulation on this class of licensees.

There were 80 participants in the public meeting. Participants represented the NRC, the Nuclear Energy Institute, the UCS, the nuclear industry, other government agencies, and the public. A list of meeting attendees and the meeting agenda are attached. NRCs slide presentation is available in ADAMS under Accession No. ML22151A165.

Enclosures:

1. Meeting Attendees

2. Meeting Agenda 2

PKG ML22214A050; Meeting Summary ML22214A036; NRC Slide Presentation ML22151A165; UCS Slide Presentation ML22151A166; Meeting Notice ML22151A300

• via email OFFICE NSIR/DPCP NSIR/DPCP/MSB NSIR/DPCP/MSB NAME MKohen THarris ARivera DATE 7/14/22 7/14/22 7/14/22 Meeting Attendees Discuss Staffs Consideration of Options for a Potential Rulemaking on Security for Special Nuclear Material June 1, 2022 Webinar 1:00 PM - 3:00 PM Name Organization 1 Carl Storms 2 Erik J 3 Jay Spiva BWXT 4 Tim Martinson Canberra 5 James McCorkle Centrus 6 Marty Karr Centrus 7 Raymond Fischels Centrus 8 Richard Kielmar Centrus 9 Nathan Faith Constellation 10 Robert Link Consultant to NEI 11 Dan Leone Defense Daily 12 Siaka Yusuf Dow Chemical 13 Timothy Tate Framatome US 14 Scott Murray GE 15 Pat Jenny Global Laser Enrichment 16 Robert Sanders Honeywell 17 Christopher Schwarz Idaho National Laboratory 18 Margaret Ellenson Kairos Power 19 Ethan Taber Missouri S&T 20 Bill Gross NEI 21 David Young NEI 22 Hilary Lane NEI 23 Janet Schlueter NEI 24 Micheal Smith NEI 25 Nima Ashkeboussi NEI 26 Richard Mogavero NEI 27 Rodney McCullum NEI 28 Susan Perkins NEI 29 Randolph Strader NIST 30 Thomas Newton NIST 31 Alison Rivera NRC 32 Andrew Waugh NRC 33 Angella Love Blair NRC 34 Antonio Gomez NRC 35 Beth Reed NRC 36 Carrie McCann NRC 37 Daniel Mussatti NRC 38 Edward Helvenston NRC 39 Irene Wu NRC 4

Name Organization 40 James Downs NRC 41 James Maltese NRC 42 Jill Shepherd NRC 43 Johari Moore NRC 44 John Tappert NRC 45 Joseph Goodridge NRC 46 Marshall Kohen NRC 47 Michael Takacs NRC 48 Michele Sampson NRC 49 Norman St. Amour NRC 50 Patrick James NRC 51 Phil Brochman NRC 52 Shana Helton NRC 53 Stanley Gardocki NRC 54 Steve Vitto NRC 55 Tara Inverso NRC 56 Thomas Steinfeldt NRC 57 Tim Harris NRC 58 Diana Diaz Toro NRC (Office of JMB) 59 Jason Krumenacker Oak Ridge National Laboratory 60 Jim Carman Oak Ridge National Laboratory 61 Thomas Romay Pacific Gas & Electric 62 Jeffrey Guether Penn State University 63 Steven Dolley Platts 64 Chatzidakis Stylianos Purdue University 65 Jim Tomkins Radiant 66 Cameron Goodwin RINSC 67 Joseph Rivers Rivers Security Services 68 Matthew Marzano Senate EPW 69 Jere Jenkins Texas A&M University 70 Mike Callahan Texas A&M University 71 Edwin Lyman UCS 72 Amber Johnson University of Maryland 73 J. David Robertson University of Missouri 74 Jacqueline Matyas University of Missouri 75 Kiratadas Kutikkad University of Missouri 76 Ronald Astrino University of Missouri-Columbia 77 Clayton Manning USGS 78 Corey Hines Washington State University 79 William Mattern Westinghouse 80 Jennifer Wheeler X-Energy 5

Meeting Agenda Discuss Staffs Consideration of Options for a Potential Rulemaking on Security for Special Nuclear Material June 1, 2022, 1:00 PM to 3:00 PM Webinar Time Topic Speaker 1:00 PM Introductions/Opening Remarks NRC NRC Presentation NRC Remarks from the Union of Concerned Scientists Dr. Edwin Lyman Questions / Comments All Wrap Up NRC 6