Regulatory Considerations for Domestic Reprocessing Facility Physical Security
U.S. advanced non-light-water reactor vendors may pursue collocated on-site reprocessing activities. Therefore, these facilities are likely to possess formula quantities, or Category I quantities, of special nuclear material (SNM) during normal operations. The U.S. Nuclear Regulatory Commission (U.S. NRC) has yet to formally establish a regulatory framework for commercial reprocessing. While Category I requirements would explicitly not apply in this circumstance under current regulatory requirements, regulatory certainty does not exist. A novel framework should be developed to ensure public health and safety while also risk-informing the physical security requirements. This report reviews the relevant background of related rulemaking activities and proposes risk-informed physical protection requirements to satisfy these objectives. Insights from NRC security-related rulemaking activities provide a substantial technical basis to approach potential establishment of physical security requirements for reprocessing facilities. If a licensee can provide justification that the material satisfies a sufficient self-protecting radiation dose threshold, the material may not be subject to theft or diversion requirements and only potential sabotage requirements would apply. Furthermore, if the material can be justified to be moderately dilute, a set of risk-informed requirements could provide adequate protection of public health and safety. A revised performance objective for prevention of theft of moderately dilute Category I SNM may be detection to allow prompt recovery by a local law enforcement agency. However, a significant caveat to the proposed categorization scheme is the unknown integration of radiological sabotage with requirements for the protection against theft. Future licensees should consult with the NRC regarding treatment of this regulatory topic. Additionally, the self-protecting radiation dose threshold (either the existing or a proposed future threshold) would need to be considered. An integrated approach may apply graded potential requirements for protection against the design basis threat of radiological sabotage currently applicable to commercial nuclear power plants and Category I SNM facilities defined within 10 CFR 73.1(a).