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Environmental Monitoring Plan - February 2016

The purpose of environmental monitoring is to promote the early identification of, and response to, potential adverse environmental impacts associated with Lawrence Livermore National Laboratory (LLNL) operations. Environmental monitoring supports the Integrated Safety Management System (ISMS), International Organization for Standardization (ISO) 14001 Environmental Management Systems standard, and U. S. Department of Energy (DOE) Order 458.1, Radiation Protection oft/ic Pubile and the Environment. Specifically, environmental monitoring enables LLNL to detect, characterize, and respond to releases from LLNL activities; assess impacts; estimate dispersal patterns in the environment; characterize the pathways of exposure to members of the public; characterize the exposures and doses to individuals and to the population; and to evaluate the potential impacts to the hiota in the vicinity of LLNL. Environmental monitoring is also a major component of compliance demonstration for permits and other regulatory requirements.

54 ENVIRONMENTAL SCIENCES↗

Nominations for the 2017 NNSA Pollution Prevention Awards

In the field of nuclear forensics, one of the biggest challenges is to dissolve postdetonation debris for analysis. Debris generated after a nuclear detonation is a glassy material that is difficult to dissolve with chemicals. Traditionally, concentrated nitric acid, hydrofluoric acid, or sulfuric acid are employed during the dissolution. These acids, due to their corrosive nature, are not suitable for in-field/on-site sample preparations. Uranium oxides are commonly present in nuclear fuel processing plants and nuclear research facilities. In uranium oxides, the level of uranium isotope enrichment is a sensitive indicator for nuclear nonproliferation and is monitored closely by the International Atomic Energy Agency (IAEA) to ensure there is no misuse of nuclear material or technology for nuclear weapons. During an IAEA on-site inspection at a facility, environmental surface swipe samples are collected and transported to the IAEA headquarters or network of analytical laboratories for further processing. Uranium oxide particles collected on the swipe medium are typically dissolved with inorganic acids and are then analyzed for uranium isotopic compositions. To improve the responsiveness of on-site inspections, in-field detection techniques have been recently explored. However, in-field analysis is bottlenecked by time-consuming and hazardous dissolution procedures, as corrosive inorganic acids must be used. Corrosive chemicals are difficult to use in the field due to personnel safety considerations, and the transportation of such chemicals is highly regulated. It was therefore necessary to develop fast uranium oxide dissolution methods using less hazardous chemicals in support of the rapid infield detection of anomalies in declared nuclear processes.

54 ENVIRONMENTAL SCIENCES↗

Prototype Demonstration of Gamma- Blind Tensioned Metastable Fluid Neutron/Multiplicity/Alpha Detector – Real Time Methods for Advanced Fuel Cycle Applications

The content of this report summarizes a multi-year effort to develop prototype detection equipment using the Tensioned Metastable Fluid Detector (TMFD) technology developed by Taleyarkhan [1]. The context of this development effort was to create new methods for evaluating and developing advanced methods for safeguarding nuclear materials along with instrumentation in various stages of the fuel cycle, especially in material balance areas (MBAs) and during reprocessing of used nuclear fuel. One of the challenges related to the implementation of any type of MBA and/or reprocessing technology (e.g., PUREX or UREX) is the real-time quantification and control of the transuranic (TRU) isotopes as they move through the process. Monitoring of higher actinides from their neutron emission (including multiplicity) and alpha signatures during transit in MBAs and in aqueous separations is a critical research area. By providing on-line real-time materials accountability, diversion of the materials becomes much more difficult. The Tensioned Metastable Fluid Detector (TMFD) is a transformational technology that is uniquely capable of both alpha and neutron spectroscopy while being “blind” to the intense gamma field that typically accompanies used fuel – simultaneously with the ability to provide multiplicity information as well [1-3]. The TMFD technology was proven (lab-scale) as part of a 2008 NERI-C program [1-7]. The bulk of this report describes the advancements and demonstrations made in TMFD technology. One final point to present before turning to the TMFD demonstrations is the context for discussing real-time monitoring of SNM. It is useful to review the spectrum of isotopes generated within nuclear fuel during reactor operations. Used nuclear fuel (UNF) from a light water reactor (LWR) contains fission products as well as TRU elements formed through neutron absorption/decay chains. The majority of the fission products are gamma and beta emitters and they represent the more significant hazards from a radiation protection standpoint. However, alpha and neutron emitting uranium and TRU elements represent the more significant safeguards and security concerns. Table 1.1 presents a representative PWR inventory of the uranium and actinide isotopes present in a used fuel assembly. The uranium and actinide isotopes (chiefly the Pu, Am and Cm elements) are all emitters of alpha particles and some of them release significant quantities of neutrons through spontaneous fissions

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Performance Testing of Tracer Gas and Tracer Aerosol Detectors for use in Radionuclide NESHAP Compliance Testing

The Rad-NESHAP program, part of the Air Quality Compliance team of LANL’s Compliance Programs group (EPC-CP), and the Radiation Instrumentation & Calibration team, part of the Radiation Protection Services group (RP-SVS), frequently partner on issues relating to characterizing air flow streams. This memo documents the most recent example of this partnership, involving performance testing of sulfur hexafluoride detectors for use in stack gas mixing tests. Additionally, members of the Rad-NESHAP program performed a functional trending test on a pair of optical particle counters, comparing results from a non-calibrated instrument to a calibrated instrument. Prior to commissioning a new stack sampling system, the ANSI Standard for stack sampling requires that the stack sample location must meet several criteria, including uniformity of tracer gas and aerosol mixing in the air stream. For these mix tests, tracer media (sulfur hexafluoride gas or liquid oil aerosol particles) are injected into the stack air stream and the resulting air concentrations are measured across the plane of the stack at the proposed sampling location. The coefficient of variation of these media concentrations must be under 20% when evaluated over the central 2/3 area of the stack or duct. The instruments which measure these air concentrations must be tested prior to the stack tests in order to ensure their linear response to varying air concentrations of either tracer gas or tracer aerosol. The instruments used in tracer gas and aerosol mix testing cannot be calibrated by the LANL Standards and Calibration Laboratory, so they would normally be sent off-site for factory calibration by the vendor. Operational requirements can prevent formal factory calibration of some instruments after they have been used in hazardous settings, e.g., within a radiological facility with potential airborne contamination. The performance tests described in this document are intended to demonstrate the reliable performance of the test instruments for the specific tests used in stack flow characterization.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Waste Isolation Pilot Plant Annual Site Environmental Report for 2016

The purpose of the Waste Isolation Pilot Plant (WIPP) Annual Site Environmental Report for 2016 (ASER) is to provide the information required by U.S. Department of Energy (DOE) Order 231.1B, Environment, Safety, and Health Reporting. The DOE Carlsbad Field Office (CBFO) and the management and operating contractor (MOC) maintain and preserve the environmental resources at the WIPP facility. DOE Order 231.1B; DOE Order 436.1, Departmental Sustainability; and DOE Order 458.1, Radiation Protection of the Public and the Environment, require that the affected environment at and near DOE facilities be monitored to ensure the safety and health of the public and workers, and preservation of the environment. This report was prepared in accordance with DOE Order 231.1B, which requires DOE facilities to submit an ASER to the DOE Headquarters Chief Health, Safety, and Security Officer.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Hanford Site Composite Analysis Technical Approach Description: Groundwater Pathway Dose Calculation.

The purpose of this technical approach document (TAD) is to document the assumptions, equations, and methods used to perform the groundwater pathway radiological dose calculations for the revised Hanford Site Composite Analysis (CA). DOE M 435.1-1, states, “The composite analysis results shall be used for planning, radiation protection activities, and future use commitments to minimize the likelihood that current low-level waste disposal activities will result in the need for future corrective or remedial actions to adequately protect the public and the environment.”

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Photos of Lansmont PDT 80 drop test machine at Los Alamos

The Los Alamos RP-SVS Radiation Protection Services group designed and constructed a drop tower facility for TA- 55 support work. The drop mechanism was supplied by the Lansmont company in Monterey CA. Los Alamos staffers Murray Moore and Yong Tao have noticed that the system is not dropping loads correctly, and they have photographed aspects of the PDT- 80 model system. The first 10 photos show the platen loaded with a cylindrical steel bar. The next 10 photos are of the roller-cam mechanism in the drop tower, and the last 2 photos indicate the amount of looseness in the platen when it is being pulled by a person.

47 OTHER INSTRUMENTATION↗

NUSAM Methodology for Assessment.

This document provides a methodology for the performance-based assessment of security systems designed for the protection of nuclear and radiological materials and the processes that produce and/or involve them. It is intended for use with both relatively simple installations and with highly regulated complex sites with demanding security requirements.

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL P↗

Simple grab sampling methods for the measurement of WL(Rn) and WL(Tn) concentrations

If one is air sampling for short -lived radon ( 222 Rn) progeny only, then it is the so-called working level concentration (WL) that is normally determined. Often, a so-called short-term grab air sample is utilized followed by gross α counting techniques. Care on the part of health physics personnel is required here, as is an uninterrupted work time.

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL P↗

2017 Annual Site Environmental Report

Los Alamos National Laboratory’s (the Laboratory’s) annual site environmental reports are prepared annually by the Laboratory’s environmental organizations, as required by U.S. Department of Energy Order 231.1B, Administrative Change 1, Environment, Safety, and Health Reporting, and Order 458.1, Administrative Change 3, Radiation Protection of the Public and the Environment. The following chapters in this report discuss our success in complying with environmental laws, regulations, and orders (Chapter 2, Compliance Summary); how we manage the Laboratory’s environmental performance (Chapter 3, Environmental Programs); how we monitor for air emissions of radioactive materials and climate conditions (Chapter 4, Air Quality); how we monitor for effects of Laboratory operations on groundwater quality (Chapter 5, Groundwater Monitoring); how we monitor the movement of chemicals and radionuclides by storm water runoff and the levels of chemicals and radionuclides in deposited sediment (Chapter 6, Watershed Quality); how we monitor for the presence, levels, and effects of chemicals and radionuclides in plants, animals, soil, and vegetation (Chapter 7, Ecosystem Health); and finally, what radionuclide dose or risk from chemical exposure members of the public may experience as a result of Laboratory operations (Chapter 8, Public Dose and Risk Assessment).

54 ENVIRONMENTAL SCIENCES↗

2018 Annual Site Environmental Report

Los Alamos National Laboratory’s (the Laboratory’s) annual site environmental reports are prepared annually by the Laboratory’s environmental organizations, as required by U.S. Department of Energy Order 231.1B, Administrative Change 1, Environment, Safety, and Health Reporting, and Order 458.1, Administrative Change 3, Radiation Protection of the Public and the Environment. The following chapters in this report discuss our success in complying with environmental laws, regulations, and orders (Chapter 2, Compliance Summary); how we manage the Laboratory’s environmental performance (Chapter 3, Environmental Programs); how we monitor for air emissions of radioactive materials and climate conditions (Chapter 4, Air Quality); how we monitor for effects of Laboratory operations on groundwater quality (Chapter 5, Groundwater Monitoring); how we monitor the movement of chemicals and radionuclides by storm water runoff and the levels of chemicals and radionuclides in deposited sediment (Chapter 6, Watershed Quality); how we monitor for the presence, levels, and effects of chemicals and radionuclides in plants, animals, soil, and vegetation (Chapter 7, Ecosystem Health); and finally, what radionuclide dose or risk from chemical exposure members of the public may experience as a result of Laboratory operations (Chapter 8, Public Dose and Risk Assessment). This report follows plain language guidelines, as required for federal agencies by the Plain Language Act of 2010. More information about plain language can be found at http://www.plainlanguage.gov/index.cfm. You will notice we have substantially reduced the use of acronyms and abbreviations and are using active voice and personal pronouns. We hope you find this report useful. If you have suggestions for improving this report, additional questions, or want a copy of this report, please contact us at envoutreach@lanl.gov, or call the Communications Office at 505-665-7000. This report, its supplemental tables, and the 2018 Annual Site Environmental Report Summary are available at http://www.lanl.gov/environment/environmental-report.php. Note: This document has been revised since it was initially published on September 23, 2019. The revisions included corrections to figure and table references, changes in heading levels, adding blank pages where appropriate, and changes of an editorial nature.

54 ENVIRONMENTAL SCIENCES↗

Environmental Monitoring Plan

The purpose of environmental monitoring is to promote the early identification of, and response to, potential adverse environmental impacts associated with Lawrence Livermore National Laboratory (LLNL) operations. Environmental monitoring supports the Integrated Safety Management System (ISMS), International Organization for Standardization (ISO) 14001 Environmental Management Systems standard, and U. S. Department of Energy (DOE) Order 458.1, Radiation Protection of the Public and the Environment. Specifically, environmental monitoring enables LLNL to detect, characterize, and respond to releases from LLNL activities; assess impacts; estimate dispersal patterns in the environment; characterize the pathways of exposure to members of the public; characterize the exposures and doses to individuals and to the population; and to evaluate the potential impacts to the biota in the vicinity of LLNL. Environmental monitoring is also a major component of compliance demonstration for permits and other regulatory requirements.

Environmental sciences↗

Tonopah Test Range Air Monitoring: CY2018 Meteorological, Radiological, and Wind Transported Particulate Observations

In 1963, the U.S. Department of Energy (DOE) (formerly the Atomic Energy Commission [AEC]), implemented Operation Roller Coaster on the Tonopah Test Range (TTR) and an adjacent area of the Nevada Test and Training Range (NTTR) (formerly the Nellis Air Force Range). This operation resulted in radionuclide-contaminated soils at the Double Tracks site and Clean Slate I, II, and III sites. This report documents observations made during ongoing monitoring of radiological, meteorological, and dust conditions at stations installed adjacent to the Clean Slate sites and at the TTR Sandia National Laboratories (SNL) Range Operations Center (ROC). The primary objective of the monitoring effort is to support the DOE Environmental Management Nevada Program (EM NV) in the safe remediation of the environmental legacy of nuclear device development and testing by determining if wind blowing across the Clean Slate sites is transporting particles of radionuclide-contaminated soil beyond the physical and administrative boundaries of the sites, and to provide information for designing long-term monitoring of the sites. The monitoring program in 2018 included five stations. Station 400, located within TTR Area 3 and near the ROC, monitors conditions near the local workforce center. Stations 401 and 403 are located on the northern and southeastern perimeter fence lines, respectively, of the Clean Slate III site. Stations 404 and 405 are along the northern and eastern boundary fence, respectively, at Clean Slate II. The stations are generally downwind of the contaminated areas during either northwesterly or southerly winds, which are the predominant wind directions. The stations—which are similar in design to the Community Environmental Monitoring Program (CEMP) stations operating at locations surrounding the Nevada National Security Site and TTR—include meteorological instruments and continuous-flow, low-volume air samplers. Three pressurized ionization chambers for measuring gamma energy are in use at Stations 400, 401, and 403. Saltation sensors and saltation traps are deployed at the stations adjacent to the Clean Slate sites. Detailed meteorological data are recorded on data loggers, with periodic uploads via a satellite system to the Western Regional Climate Center (WRCC) at Desert Research Institute (DRI), to monitor instrument and site conditions. Air filter samples are collected every two weeks and the deposits in the saltation traps are collected when a sufficient sample mass for analysis has accumulated (generally a six- to eight-month interval). Monitoring at TTR in calendar year (CY) 2018 provided surveillance of both ambient conditions, and ground disturbance associated with remediation activities at Clean Slate II and III. The first half of CY2018 data from Stations 404 and 405 at Clean Slate II were collected during remediation activities at that site, and data collected during the final third of the year at Stations 401 and 403 at Clean Slate III coincided with remediation work at the site. Ambient conditions prevailed at Station 400 throughout the year. Dust transport by suspension and saltation is strongly dependent on wind speed. Concentrations of PM 10 (particulate matter of aerodynamic diameter ≤10 micrometers [μm], a size fraction of small particles that are suspended in the air and can be easily inhaled) remain low until winds exceed approximately 32 kilometers per hour (km/hr) (20 miles per hour [mph]). Saltation particle counts also increase above the same general threshold wind speed. Wind speeds in excess of 32 km/hr (20 mph) occur less than three percent of the time at the sites. Ground disturbing remediation activities were carried out at Clean Slate II from October 31, 2017, until July 26, 2018. Station 404 is located closest to the remediation area and is downwind of the area when winds are from the south. By late November, analysis of dust from the air sampler at Station 404 registered increases in plutonium-239+240 ( 239+240 Pu) concentrations. Peak plutonium concentrations, accompanied by elevated gross alpha concentrations and the detection of americium-241 ( 241 Am) by gamma spectroscopy, occurred between March and May 2018. During spring and early summer of 2018, elevated radionuclide concentrations were also measured in dust collected from the air sampler at Station 405, which is more than twice the distance from the remediation activity as Station 404. A minor but sustained increase in gross alpha concentration of suspended dust collected at Stations 400, 401, and 403 was also observed starting in May 2018 and continuing into August. Stations 401 and 403 are approximately 4.8 to 6.4 km (three to four miles) from Clean Slate II and Station 400 is approximately 13 km (eight miles) from that site. The radionuclide content of material that saltated into the passive Big Spring Number Eight (BSNE) traps during the Clean Slate II remediation period increased in both the traps facing toward and away from the fenced contamination area at Station 404, with the largest increases in concentration (almost five times the previous 239+240 Pu concentration) observed in the traps facing the fenced area. The radionuclide concentration in material in the trap facing away from the fence more than doubled from that measured in 2017. A similar increase was observed for the saltation trap facing away from the fenced area at Station 405, although no increase was observed for material captured in the trap facing the fenced area. Particles ranging in size from 50 to 500 µm generally move by saltation processes and are not expected to significantly contribute to dose for someone breathing in the standard respiratory zone for adult humans (1.5 to 1.7 m [4.9 to 5.6 ft] above ground level) because they are too large to be entrained in the air as suspended dust. Remediation activities at Clean Slate III began on September 5, 2018, and continued until a brief hiatus started on December 20, 2018. Although Station 401 is much closer to the remediation area than Station 403, the first increase in gross alpha and 239+240 Pu concentrations was noted in dust from filters collected at Station 403 in early November 2018. The highest radionuclide concentrations of 2018 at the Clean Slate III stations were recorded in air samples taken from Stations 401 and 403 in late December 2018 and these concentrations were comparable between the two station locations. Gamma rate data measured by the PICs was slightly higher than the annual average at Stations 401 and 403 after remediation activities began, but no single measurement was outside of the range observed in 2018 prior to remediation activities. No increase in radionuclide concentration was observed for the Clean Slate III remediation time period on air filters collected from the other stations. Radiological monitoring at Station 400—which is located at the ROC, and therefore the closest regularly staffed work location to the Clean Slate sites—recorded a higher mean gross alpha activity from dust collected on air sampler filters than in previous years. The individual biweekly air filters yielded measurements of gross alpha that were at or below the mean plus one standard deviation measured in CY2017, except for the period from April 25, 2018, through September 12, 2018. Nonetheless, gamma spectroscopy of all air filters from Station 400 identified only naturally occurring radionuclides, with no detection of americium-241 ( 241 Am) (which is used as an indicator of plutonium-241[ 241 Pu]). Alpha spectroscopy of selected air filters collected at Station 400 did not detect plutonium-238 ( 238 Pu) or 239+240 Pu above the analytical detection limit. Gross beta and gamma exposure rate data were comparable to data from regional CEMP stations. No saltation traps are deployed at Station 400. Considering the ambient monitoring periods during CY2018, the monitoring stations adjacent to the Clean Slate sites recorded above-background 238 Pu and 239+240 Pu concentrations (SNL, 1998; Turner et al., 2003) in samples collected by passive saltation traps and on selected air filters. These observations were consistent with previous years and indicated that radionuclide movement occurred under ambient conditions by processes of both saltation and suspension. The presence of radionuclides in all saltation traps, both upwind and downwind of the fenced contamination areas, was consistent with previous radiological survey results (EG&G, 1979) that show lower concentration radiologically contaminated material dispersed outside the fenced area. Although 239+240 Pu concentrations in the air filter samples were sometimes orders of magnitude higher than background, the concentrations were below risk-based action levels defined for an industrial area worker scenario (U.S. DOE, 2014). The interception of airborne dust with above-background radionuclide concentrations demonstrates that dispersal processes are continuing. Strong winds are the driver for both suspension and saltation of dust and soil. The recorded wind speed and PM10 during remediation activities at Clean Slate II and III identified discrete wind events lasting approximately five to eight hours each, which accounted for the greatest PM 10 concentrations at the monitoring stations. These events captured the effect of winds from the northwest and from the south. The observed differences in dust loading and radionuclide concentrations for the monitoring stations when they were either upwind or downwind of the contamination area identify the remediation area as a source of plutonium contaminated dust. The increase in concentration of radionuclides in airborne dust during the remediation activities, compared with measurements under previous ambient conditions (mean 239+240 Pu concentrations during remediation activities are approximately nine to 40 times higher compared to pre-remediation concentrations, depending on monitoring station), highlights the impact of land disturbance on wind-borne contaminant transport from the Clean Slate test areas. The meteorological and particulate matter monitoring indicated that conditions for wind-borne contaminant movement exist at the Clean Slate sites, and that transport of radionuclide-contaminated soil by both suspension and saltation occurred under ambient conditions and accelerated when the sites were disturbed. The 239+240 Pu alpha spectroscopy results indicated that airborne concentrations during remediation activities ranged from 2 × 10-16 to 380 × 10-16 µCi/ml. These results can be compared to the derived air concentration limit for 239 Pu of 6 × 10-11 µCi/ml for occupational workers contained in Code of Federal Regulations 10 CFR 835, Occupational Radiation Protection. Even though the air sampling results document an increase in concentration during remediation activities, the observed concentrations are less than 0.06 percent of the occupational limit. The Corrective Action Unit (CAU) closure strategy uses a risk-based approach, whereby acceptable contaminant concentrations are determined as a function of anticipated human exposure.

54 ENVIRONMENTAL SCIENCES↗

Criticality Accident Response

The document outlines procedures and priorities for Radiation Protection personnel response should a nuclear criticality accident occur.

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL P↗

Big Data Health Physics

This project, in completion of the Illinois Institute of Technology’s Professional Masters of Health Physics program, represents a two part independent study wherein (1) a Statistical Analysis is performed on a new data process implemented at a Los Alamos National Laboratory facility and (2) a Project Management Plan is designed for the successful implementation of this new radiation protection management process.

62 RADIOLOGY AND NUCLEAR MEDICINE↗

Proposed guidance for preparing and reviewing a molten salt non-power production or utilization facility application

Development of non-power molten salt reactors (MSRs) are under consideration to further establish an MSR experience base, support the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.43(e), and provide any additional analyses needed for development of a full-scale MSR. Guidance provided in this report is based on MSRs operating with liquid fuel (i.e., fuel dissolved within a molten salt). These reactors, unless owned by the DOE or DOD, will require licensing by the US Nuclear Regulatory Commission (NRC) staff. Standard review plan (SRP) guidance for large light water reactors (LWRs) is available in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants; Light Water Reactor (LWR) Edition. However, NRC staff observed that NUREG-0800 is very cumbersome to apply to non-power reactors “because of the great differences in complexity and hazards between non-power reactors and nuclear power plants.” Therefore, a program to develop performance-based guidance applicable to non-power reactors was initiated. In 1996, NUREG-1537, Parts 1 and 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, was published. Part 1, the format and content guide, suggests a uniform format for presenting information in non-power reactor applications that is acceptable to the NRC staff, but conformance with the format and content is not required. Part 2, the SRP, ensures the quality and uniformity of the staff review of an application. Unfortunately, the application guidelines and SRP do not provide adequate guidance for all advanced non-LWR technologies and applications. This discrepancy eventually led to the 2012 development of interim staff guidance (ISG) for NUREG-1537, which includes criteria for describing and reviewing aqueous homogeneous reactors (AHRs). Specifically, NUREG-1537 ISG, 2012 expanded the original document to address three areas: 1. updated criteria for heterogeneous non-power reactors, 2. criteria for licensing AHRs, and 3. criteria for licensing a Part 50-licensed isotope production facility. In 2015, the US Department of Energy (DOE) opted to build on the AHR NUREG-1537 ISG experience by performing a gap analysis of the guidance that would be used to license a non-power MSR. MSRs represent one of the advanced non-LWR technologies selected by DOE for development through a multiyear cost share award with Southern Company Services. Under this Advanced Reactor Concepts 2015 (DOE Advanced Reactor Concepts [ARC] 15) award program, the DOE tasked Oak Ridge National Laboratory (ORNL) to evaluate the guidance changes that the NRC may need to consider when licensing an MSR non-power reactor. ORNL staff, with support from Boston Government Services, LLC, focused on five system-related chapters in NUREG-1537 that were considered most relevant to inform the effort that would be required for a non-power MSR applicant. ORNL documented this review in a technical report, ORNL/TM-2018/834, Proposed Guidance for Preparing and Reviewing Molten Salt Non-Power Reactor License Applications (NUREG-1537). The report was subsequently shared with industry and the NRC. The 2018 review was limited in scope, focusing on key system chapters based on the expected significance of each chapter relative to expected differences in addressing advanced non-LWR technologies, specifically non-power MSRs, compared with heterogeneously fueled non-power reactors. In the ORNL report, proposed generic adaptations were suggested for the following NUREG-1537 chapters: Chapter 4, “Reactor Description”; Chapter 5, “Reactor Coolant Systems”; Chapter 6, “Engineered Safety Features”; Chapter 9, “Auxiliary Systems”; Chapter 11, “Radiation Protection Program and Waste Management” The inclusion of Chapter 11 in the previous review effort was intended to provide guidance for categorizing the waste-handling process for an MSR operating with homogenous fuel. The introductions from Parts 1 and 2 of the 2012 NUREG-1537 ISG provide guidance for the application and review of production facilities. After a period of operation, non-power MSRs with homogenous fuel will include gaseous and soluble fission products. The gaseous fission products will be collected and held for decay in an off-gas system. There might also be an initiative to polish or filter the soluble fission products in the fuel salt by some mechanical or chemical means. The treatment and handling of fission products in the non-power MSR fuel salt and the description of this process in the safety analysis report (SAR) must be very precise to avoid the waste treatment facility being construed as a co-located special nuclear material (SNM) fuel cycle facility (see Section 2.3 of this report). Subsequent to the release of ORNL/TM-2018/834, NRC staff expressed a desire to continue the regulatory gap analysis that was begun in that report. This would provide additional clarity and information addressed in certain sections of the original report, while also providing new guidance on certain topics not addressed in the original report. This revision would benefit the NRC staff reviewing applications involving non-power MSR designs and would help developers understand how the NRC staff might approach the review of such applications. The focus of this report is to provide infrastructure support to the NRC staff for the regulatory review of non-power MSRs.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗