the 2014 nasa nuclear power assessment study...

Presented at the 2015 Nuclear & Emerging Technologies for Space (NETS-2015) Conference Albuquerque, NM, February 23-26, 2015

The 2014 NASA Nuclear Power Assessment Study (NPAS): Safety, Environmental Impact, and Launch Approval Considerations and Findings

Joseph A. Sholtis, Jr., Owner & Principal Consultant

Sholtis Engineering & Safety Consulting 2 Oso Drive, Suite 200

Tijeras, NM 87059-7632 E-Mail: [email protected]

Ryan D. Bechtel, DOE, Office of Space & Defense Power Systems

Paul K. Van Damme, Jet Propulsion Laboratory, Project Support Office J. Mark Phillips, Jet Propulsion Laboratory, Project Support Office

Ronald J. Lipinski, Sandia National Laboratories, Advanced Nuclear Fuel Cycle Technology

Introduction

• Near the outset of the 2014 Nuclear Power Assessment Study (NPAS), a Safety Team (ST) was formed

• Advise & support the Executive Council (EC), the System Study Team (SST) and the Mission Study Team (MST), including the MST ATLO Working Group, on safety, environmental impact, launch approval & security considerations & issues [Note: Security is addressed in a separate NETS-2015 Presentation] • Make observations & findings, as appropriate, and bring them to the attention of the EC

• Brief efforts, observations, and findings as part of 2014 NPAS Final Briefing to NASA/SMD

• Document ST efforts, observations, and findings within the 2014 NPAS Report

• NASA and the Department of Energy have developed shared principles for safety and environmental considerations for the development and use of U.S. space nuclear power systems

• These key principles were important considerations during the 2014 NPAS

• They served as a foundation for system studies of notional radioisotope power systems (RPS) and fission power systems (FPS) for two selected 2014 NPAS mission studies - TSSM and UOP

Overview of Presentation

• Summary of Launch History of U.S. Space Nuclear Systems

• Description of Key Safety & Environmental Principles & Processes

• Key Observations & Findings

HISTORY

• Nuclear systems have enabled tremendous strides in our country’s use & exploration of space. • Since 1961, the US has launched forty-seven nuclear power systems & hundreds of radioisotope heater units in support of thirty-one navigational, meteorological, communications, experimental, as well as lunar, solar, Martian, Jovian, Saturnian, and outer solar system exploration missions. • One mission (SNAPSHOT in 1965) involved a small 500W(e) reactor power system (SNAP-10A); the remaining missions were powered by radioisotope thermoelectric generators (RTGs) & radioisotope heater units (RHUs).

MISSION MISSION TYPE LAUNCH DATE NUCLEAR SYSTEM STATUS (#Systems/Nominal Output)

TRANSIT 4A Navigational Jun 61 SNAP-3B7 (1/2.7W(e)) Successfully achieved orbit; ops terminated 1966 TRANSIT 4B Navigational Nov 61 SNAP-3B8 (1/2.7W(e)) Successfully achieved orbit; ops terminated 1967 TRANSIT 5BN-1 Navigational Sep 63 SNAP-9A (1/25W(e)) Successfully achieved orbit; ops terminated 1970 TRANSIT 5BN-2 Navigational Dec 63 SNAP-9A (1/25W(e)) Successfully achieved orbit; ops terminated 1971 TRANSIT 5BN-3 Navigational Apr 64 SNAP-9A (1/25W(e)) Failed to achieve orbit; SNAP-9A burned up on reentry as then designed/intended SNAPSHOT Experimental Apr 65 SNAP-10A (1/500W(e)) Successfully achieved orbit; S/C voltage regulator failed after 43 days; SNAP-10A reactor shutdown permanently in 3000+ yr orbit NIMBUS B-1 Meteorological May 68 SNAP-19B2 (2/40W(e) ea) Vehicle destroyed during launch; SNAP-19B2s retrieved intact; fuel used on later mission NIMBUS III Meteorological Apr 69 SNAP-19B3 (2/40W(e) ea) Successfully achieved orbit; ops terminated 1979 APOLLO 12 Lunar exploration Nov 69 SNAP-27 (1/70W(e)) Successfully placed on moon; ops terminated 1980 APOLLO 13 Lunar exploration Apr 70 SNAP-27 (1/70W(e)) Mission aborted en route to moon; SNAP-27 survived reentry & in 7000+ ft of water in deep ocean APOLLO 14 Lunar exploration Jan 71 SNAP-27 (1/70W(e)) Successfully placed on moon; ops terminated 1980 APOLLO 15 Lunar exploration Jul 71 SNAP-27 (1/70W(e)) Successfully placed on moon; ops terminated 1980 PIONEER 10 Solar system exploration Mar 72 SNAP-19 (4/40W(e) ea) Successfully placed on interplanetary trajectory; still operational APOLLO 16 Lunar exploration Mar 72 SNAP-27 (1/70W(e)) Successfully placed on moon; ops terminated 1980 TRIAD-01-1X Navigational Sep 72 TRANSIT-RTG (1/30W(e)) Successfully achieved orbit; ops terminated 1977 APOLLO 17 Lunar exploration Dec 72 SNAP-27 (1/70W(e)) Successfully placed on moon; ops terminated 1980 PIONEER 11 Solar system exploration Apr 73 SNAP-19 (4/40W(E) ea) Successfully placed on interplanetary trajectory; still operational VIKING 1 Mars exploration Aug 75 SNAP-19 (2/40W(e) ea) Successfully placed on Mars; ops terminated 1980 VIKING 2 Mars exploration Sep 75 SNAP-19 (2/40W(e) ea) Successfully placed on Mars; ops terminated 1980 LES 8 Communications Mar 76 MHW-RTG (2/150W(e) ea) Successfully achieved orbit; still operational LES 9 Communications Mar 76 MHW-RTG (2/150W(e) ea) Successfully achieved orbit; still operational VOYAGER 2 Solar system exploration Aug 77 MHW-RTG (3/150W(e) ea) Successfully placed on interplanetary trajectory; still operational VOYAGER 1 Solar system exploration Sep 77 MHW-RTG (3/150W(e) ea) Successfully placed on interplanetary trajectory; still operational GALILEO Jovian exploration Oct 89 GPHS-RTG (2/275W(e) ea) Successfully placed in orbit around Jupiter; deorbited LWRHU (120/1W(t) ea) into atmosphere of Jupiter following end-of-mission ULYSSES Solar polar exploration Oct 90 GPHS-RTG (1/275W(e)) Successfully placed in solar polar orbit; ops ended 2009 MARS PATHFINDER Mars rover exploration Dec 96 LWRHU (3/1W(t) ea) Successfully placed on Mars; rover ceased ops in 1997 CASSINI Saturnian exploration Oct 97 GPHS-RTG (3/275W(e) ea) Successfully placed in orbit around Saturn; still LWRHU (117/1W(t) ea) operational MER-A Mars rover exploration Jun 03 LWRHU (8/1W(t) ea) Successfully placed on Mars; ops ended 2010 MER-B Mars rover exploration Jul 03 LWRHU (8/1W(t) ea) Successfully placed on Mars; still operational NEW HORIZONS Pluto/Kuiper Belt Exploration Jan 06 GPHS-RTG (1/275W(e)) En-route to Pluto w/arrival in 2015 MSL Mars rover exploration Nov 11 MMRTG (1/110W(e)) Successfully placed on Mars; still operational

Space Nuclear Systems Launched by the US (1961 – 2014)

Accidents / Malfunctions Involving U.S. Space Nuclear Systems

TRANSIT 5BN-3: US Navy navigational satellite launched 21 Apr 1964. Failed to achieve orbit & reentered at ~120km over west Indian Ocean, N of Madagascar. SNAP-9A RTG burned up during reentry— as then designed). Release (17kCi of Pu-238) equivalent to Pu-238 released from all atmospheric weapons testing. As of Nov 1970, only 5% of original Pu-238 released from SNAP-9A burnup remained in atmosphere (removal half life ~ 14mo). Using this value indicates that ~2.5 pCi remains in the atmosphere as of Apr 2014. [Note: ~10kCi still in biosphere]

SNAPSHOT: SNAP-10A reactor/electric propulsion experimental mission launched 3 Apr 1965. Reactor successfully started/operated for 43days; S/C voltage regulator malfunction caused reactor permanent/irreversible shutdown in 3000+ year orbit.

NIMBUS B-1: Meteorological satellite launched 18 May 1968 from WTR. RSO destroyed LV due to errant ascent; all debris fell into Santa Barbara channel. SNAP-19 RTG (34 kCi Pu-238) recovered intact at ~100m depth. No release; fuel used on later mission.

APOLLO 13: Manned lunar mission launched 11 Apr 1970. SNAP-27 RTG (44.5kCi Pu-238) reentered with LEM over south Pacific Ocean. RTG survived reentry; rests at 7000+ ft depth near Tonga trench.

KOSMOS ?: RORSAT launch attempted 25 Jan 1969. Believed to be a launch failure on/at the pad. KOSMOS 300: Lunikhod S/C launched 23 Sep 1969. Failed to achieve escape trajectory. S/C w/small Po-210 source reentered atmosphere and burned up on 27 Sep 1969. KOSMOS 305: Lunikhod S/C launched 22 Oct 1969. Failed to achieve escape trajectory. S/C w/small Po-210 source reentered atmosphere and burned up on 24 Oct 1969. KOSMOS ?: RORSAT launched 25 Apr 1973. Believed to fail to achieve orbit; falling into Pacific Ocean N of Japan. KOSMOS 954: RORSAT launched Sep 1977. Reactor successfully separated from S/C following end of operations, but did NOT boost to a higher, long-lived orbit. Reactor reentered over Pacific Ocean & crashed near Great Slave Lake in northern Canada on 24 Jan 1978. ~65kg of debris, radioactive objects, and fuel recovered. KOSMOS 1402: RORSAT launched 30 Aug 1982. Anomaly indicated; S/C intentionally separated into 3 parts. Reactor is believed to have reentered & fallen into the south Atlantic ~1600km E of Brazil on 7 Feb 1983. No radioactivity detected from reentry of any parts. KOSMOS 1900: RORSAT launched 12 Dec 1987. On 13 May 1988, USSR reported that contact was lost in Apr 1988 & reactor could not be boosted via ground signal to higher orbit. On 30 Sep 1988, reactor automatically separated and boosted to higher (~720km) orbit. MARS 96: Mars explorer launched 16 Nov 1996. Failed to achieve escape trajectory. S/C w/small Pu-238 fueled RTG reentered on 17 Nov 1996 and fell near the coast of Chile/Bolivia. RTG designed to survive reentry; no radioactivity detected from reentry or impact.

Accidents/Malfunctions Involving USSR/Russian Space Nuclear Power Systems

Safety Considerations & Principles for Space Nuclear Systems Safety Considerations

• An integral part of any nuclear system • Encompasses the entire system/mission lifecycle from initial conceptual design, development; through launch, insertion, operation & final disposition

Safety Principles

Purpose • Protection of the public, the environment, workers, property, and other resources from undue risk or harm

Objectives • Create a safe product • Demonstrate safety – convincingly • Obtain the necessary approvals for successful development, ground test, launch, and space mission use

Strategy • Design & build safety into every nuclear heat source & system at the outset, considering its potential applications • Demonstrate the safety of each nuclear heat source and system through rigorous analysis and limited, judicious testing • Separately, quantitatively assess the environmental impact, as well as the level of risk for each proposed nuclear system & nuclear-powered space mission

Building Safety in at the Outset Safety Issues & Strategies for Space Nuclear Systems RPS:

• Safety issues: • Potential release of the radioactive fuel material into the Earth’s biosphere as a result of a postulated pre-launch, launch, ascent, or reentry accident; and • Potential loss of physical security or positive control/cognizance over the system and its SNM.

• Safety strategies: • Design & build the nuclear heat source to be robust, with multiple containment barriers that are rugged—to prevent fuel release under normal, off-normal & credible accident situations; • Incorporate a stable fuel form with a high melting point & low solubility to minimize fuel vaporization and transport in the environment, as well as minimize fuel retention within the human body, should a fuel release occur. • Take appropriate measures & incorporate special features into the design—to prevent sabotage & terrorism against, as well as theft, loss & diversion of the system & its SNM prior to achieving the planned orbit/trajectory in space.

FPS (for in-space power and/or propulsion):

• Safety issues (more complex than those for space radioisotope systems): • Potential inadvertent criticality as a result of a pre-launch, launch, ascent, or reentry accident prior to achieving the planned startup/operational orbit in space; • Potential dispersal of nuclear material into the biosphere, including land contamination; • Potential reentry of a radioactively “cold” or “hot” reactor into the Earth’s atmosphere; • Potential release of fission & activation products, generated during planned reactor operation in space or an inadvertent criticality, into the Earth’s biosphere; and • Potential loss of physical security or positive control/cognizance over the system and its SNM

MMRTG

110W(e); ~45kg ~2.0ft long x1.0ft(housing)/2.0ft(fins) OD 8 GPHS Step-II Modules ~4.9kg Pu-238 Oxide; ~59.5kCi

GPHS Module (Step-II)

~4inx4inx2in aeroshell of FWPF w/2 FWPF GISs 2FCs/GIS FC: 1.1inx1.1in fuel pellet clad w/DOP-26 Ir alloy ~151g Pu-238 Oxide/FC 612g Pu-238 Oxide/Module ~1860Ci/FC; ~7440Ci/Module

CURRENT U.S. SPACE NUCLEAR SYSTEMS

LWRHU

1W(t); 40g ~1inx1.25in 0.37inx0.25in fuel pellet clad w/Pt-30Rh 2.7g Pu-238 Oxide fuel; ~30Ci

LWRHU MMRTG

Building Safety into the Design of U.S. Space Nuclear Systems • Clear, sound safety criteria must be in place at the outset to guide designers

and mission planners

• Such top-level safety criteria should be functional in nature, as opposed to prescriptive, so that designers and mission planners are afforded maximum flexibility to consider a wide spectrum of options regarding how the criteria are to be met

• These safety criteria will be different for RPS & FPS, primarily because the safety issues associated with RPS vary from those for FPS

• Safety issues for RPS are well understood & fully-vetted safety criteria are currently in-hand

• Although safety issues for FPS are understood, fully-vetted safety criteria do not yet exist

• Such FPS safety criteria are termed herein Functional Design & Operational Safety Criteria, to ensure that FPS safety criteria, when developed & put in place, are functional in nature & address operational situations that could occur during the FPS life cycle

Demonstrating Safety by Analyses & Testing

• In an accident, nuclear system hardware can be exposed to a number of threat environments – sometimes alone, but often in concert with others; typically sequentially

• Blast overpressure & impulse • Fragment impacts (small & large) • Earth surface impact (including water immersion) • Debris impact from above • Solid & liquid propellant fires • Reentry heating and ablation

• Impossible to test all credible sequences of environments • Tests of nuclear hardware are extremely expensive & time consuming • Testing must be used sparingly & judiciously

• Obtain materials property data • Verify response(s) of hardware (limited) • Benchmark analysis codes -- so that codes can be used to predict hardware response(s)

• Analysis, therefore, must be relied upon to predict hardware responses

• Analyses (substantial in breadth & depth) required for: • NEPA compliance • Ground test authorization • Nuclear safety launch approval (SARs & SER)

NEPA Process (for development as well as space mission use)

• Federal Register notice must be issued • EIS w/opportunity for public involvement • Record of Decision required for action to proceed

• Safety Review & Launch Approval Process (for space mission use)

• INSRP (DoD, DOE, NASA, EPA & NRC Tech Advisor) formed at request of mission- sponsoring agency • PSAR, DSAR & FSAR prepared by DOE for mission-sponsoring agency over ~3-year period • INSRP reviews PSAR, DSAR & FSAR • INSRP prepares SER for its agencies & mission-sponsoring agency for their individual review • Based on the FSAR & SER, together with the agency reviews, the mission-sponsoring agency decides if it will formally request nuclear safety launch approval from the White House • White House makes informed nuclear safety launch decision based on thorough consideration of risks & benefits; FSAR & SER are key inputs

Mandated Protocols & Processes for Space Nuclear Systems / Missions

Assessing the Environmental Impact & Risk Associated with the Development & Use of Space Nuclear Systems

Notional Programmatic NEPA Strategy

Pre-Decisional for Discussion Purposes Only

Activity Name 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

1

2

3

4

5

6

Mission Review Milestones (Estimated) MDRPDR

CDRLaunch Opp'y Opens

Reactor Technology Programmatic Environmental Impact Statement (PEIS)

T1 NOIT1 DEIS

T1 FEIST1 RoD

Programmatic NEPA Document:NASA Lead with DOE as Cooperating AgencyTiming Requirement: Decision document complete prior to tiered decision documents

DOE Facility NEPA Documentation

DOE Facility and Test Site NEPA Documentation Requirements TBD by DOETiming Requirement: Decision document complete prior to mission-specific decision document

SCHEDULE TBD BY DOE

Launch Site Processing NEPA Documentation (If Required)

Launch Site Facility/Test Site NEPA Documentation Requirements TBD by NASA/KSC Timing Requirement: Decision document complete prior to mission-specific decision document

SCHEDULE TBD BY NASA/KSC

Mission-Specific (MS) Environmental Impact Statement (EIS) MS NOI

MS DEISMS FEIS

MS RoD

Representative DatabookRisk Assessment (Estimate)

Mission Specific PD/NSC-25 Compliance SAR Databook DevelopmentSAR Development

SER DevelopmentReview

Launch Approval

Time, in years

Two Separate Processes For U.S. Space Nuclear Systems / Missions

• US Safety Review & Launch Approval Process

Databook INSRP Review

INSRP Review

INSRP Review

PSAR Draft FSAR FSAR

INSRP Review SER

NASA

Mission Sponsoring

Agency [Launch Request]

t-6months

Office of Science & Technology Policy (OSTP)

[Launch Decision]

Office of the President

[Launch Decision, if necessary]

DOD

DOE

EPA

NRC/Other Agencies

Government furnished data Independent analyses & tests Operational analyses

Government furnished data Interim tests, data & analyses

Final tests, data & analyses

~t-3.5years ~t-2.5years t-18-20months

t-8-10months

CONDUCTING A MISSION SAFETY ANALYSIS OR RISK ASSESSMENT The Analysis Steps

1. Segment mission into meaningful sequential phases 2. Identify & characterize accidents & accident environments in each phase 3. Determine nuclear system response to each accident & its associated accident

environments 4. Project nuclear system consequence (e.g., source term, radiation field &

duration, etc.) for each accident 5. Identify exposure & land contamination pathways for each accident 6. Project individual & collective doses, and any land contamination, for each

accident 7. Project consequences (prompt & LCF), injuries & cleanup costs for each

accident 8. Graphically display & textually explain results (e.g., CCDFs for the mission;

CCDFs for each phase; CCDFs for major risk contributors; footprint isopleths for land contamination; etc.)

9. Document effort & results

Safety Analysis Code Suite Databook

Ch 5 Site

Ch 3 LV Ch 6 FS

Ch 8 Acc

Ch 4 Spacecraft Ch 9 Explosive

Ch 9 Debris

Ch 3 LV Ch 9 Fire

Ch 7 Trajectory Ch 9 Reentry

Impact Presto

Zapotec CTH

Fire SFM

PEVACI SINDA

Reentry LAPS TAOS

HANDI CMA

Data Tables

Accidents LASEP

Release Records

Consequence STORM

IAT HYSPLIT FDOSE

Meteorology Population Geography

Health Physics

Health Effects, Land Contamination

Risk Integration

SAR_PostProc

Exceedance Probabilities &

Uncertainty

Legend Data Code

Criticality

MCNPX

Key Observations & Findings • RPS & FPS safety issues, although different and more complex for FPS, are well understood

• Fully-vetted Functional Design & Operational Safety Criteria have been established and applied to RPS, and this should continue

• Functional Design & Operational Safety Criteria have not been established for FPS • Sound, fully-vetted Functional Design & Operational Safety Criteria must be developed and applied to any future FPS design as soon as a commitment is made to develop FPS technology in earnest for flight; they should be:

• Developed by experts, along with stakeholders, for intended application; Criteria must be non-prescriptive [Note: Specific Design & Operational Specifications/Requirements will ultimately emerge during iterative system design & analysis effort] • Reviewed by decision-makers (e.g., agency heads) • Approved by OSTP

• Any space nuclear power system development program must include a vibrant safety program from the very outset

• Beyond safety considerations & principles identified herein, safety program should include: • Hierarchical set of requirements • Clear lines of authority, responsibility, and communications • Feedback mechanisms (for continual monitoring and evaluation) • Independent safety oversight

• Moreover, to build a “safety culture” within the development program, management at all levels should foster a safety consciousness among all program participants and throughout all aspects of the space nuclear system development program

• There is every reason to believe that new RPS & FPS can be designed & developed which will satisfy all established Functional Design & Operational Safety Criteria, as well as all Safety Objectives

Schedule Impacts - Might start processes a little sooner (~1 year sooner) because it’s a new system (relative to historical process schedules). [Note: Databook drives the NEPA & Launch Approval schedules; if Databook is not available, add ~2-3years to the front of those schedules; however, timing of a new RPS development vis-à-vis its first use would be a significant factor in developing the overall plan for NEPA and Nuclear Safety Launch Approval processes] Cost Impacts – Costs are not expected to vary much from historical costs for NEPA Or Nuclear Safety Launch Approval - if Databook is available.

NEW RPS

Key Observations & Findings

Summary of Schedule & Cost Impacts

Key Observations & Findings

Schedule Impacts - Might start processes a little sooner (~1 year sooner) because it’s a new system (relative to historical NEPA & Launch Approval process schedules). [Note: Databook availability usually drives these process schedules; however, timing of a new FPS development vis-a-vis its first use would be a significant factor in developing the overall plan for NEPA and Nuclear Safety Launch Approval processes] RTGF security modifications, or new RPS/FPS facility will require ~3-4 years; must be completed prior to shipment of fuel to the Cape for first FPS mission. Cost Impacts – Costs are not expected to vary much from historical costs for NEPA or Launch Approval processes. [Note: A programmatic EIS for FPS development would be needed; Cost: ~$2-4M]

NEW FPS

Summary of Schedule & Cost Impacts

Final Thought

“For a successful technology, reality must take precedence over public relations, for nature cannot be fooled.” -- Richard P. Feynman Nobel Laureate from: “Personal Observations on the Reliability of the Shuttle,” Appendix to Roger’s Commission Report on the Space Shuttle Challenger Accident

BACKUP SLIDES

• While space nuclear systems have contributed greatly to our knowledge & understanding of Earth & our solar system, and offer promise for even greater advances in the future, their use poses unique safety challenges. • These safety challenges, or issues, must be recognized and addressed in the design & development of each nuclear heat source as well as nuclear system intended for space use.

• In doing so, the heat source’s/system’s planned & potential uses must be considered, and normal, off-normal, as well as potential accidents and accident environments must be taken into account.

• Note: Issues for RPS well understood; sound, vetted & proven Design & Operational Safety Criteria in hand. Issues for FPS understood; but sound, vetted, functional Design & Operational Safety Criteria are not in-hand.

• Extensive safety analyses, buttressed by limited, judicious safety testing, must be conducted to determine the level & adequacy of safety built into the heat source/system for its intended uses.

• Safety analyses also must establish the adequacy of safety for nuclear system ground testing prior to launch.

• Lastly, the environmental impact & risk for each US nuclear-powered space mission must be assessed so an informed launch decision can be made within the Executive Office of the President based on benefit vs risk.

U.S. SPACE NUCLEAR SYSTEMS: THE SAFETY CHALLENGE

Space reactor systems (for in-space power & propulsion): • Safety strategies (more complex than those for space radioisotope systems):

• Incorporate inherent safety into the reactor system design and its use; • Incorporate passive safety features into the system design and its use; and • Incorporate active safety features into the system’s design and its use.

• This specified order should be followed, with exhaustion of all available options at one level before permitting serious consideration & adoption of options at the next lower level. • Examples at each level:

• Inherent safety: Ensuring that reactor is radioactively “cold” at launch would serve to preclude the release of fission and activation products for a large segment of potential pre-launch, launch & ascent accidents with no potential for inadvertent criticality. • Passive safety: Designing a reactor with a negative temperature coefficient of reactivity would immediately & automatically (without any system action having to be initiated) limit any overpower events that might occur during operation in space. • Active safety: Incorporating a fast-acting “scram” capability would act to shutdown the reactor, if needed, during operation in space.

Functional Design & Operational Safety Criteria must be established for design & development of any new space reactor system for all planned as well as potential mission applications.

BUILDING SAFETY IN AT THE OUTSET

Safety Issues & Strategies for Space Nuclear Systems

• Process has four distinct components – National Environmental Policy Act (NEPA) became law in 1969

• NASA regulations explicitly require an environmental impact statement (EIS) for flight of space nuclear power sources (i.e., radioisotope heater units, radioisotope power systems, reactors)

– Presidential Directive/National Security Council Memorandum #25 (PD/NSC-25), “Scientific or Technological Experiments with Possible Large-Scale Adverse Environmental Effects and Launch of Nuclear Systems into Space”

• Memorialized in 1977 a process formally in place since 1965 • Requires an Interagency review of a mission specific nuclear safety analysis and the

NASA Administrator to request nuclear safety launch approval through the Director of OSTP

– National Response Framework, Nuclear/Radiological Incident Annex (2008) originates with Federal Radiological Emergency Response Plan (1980) [Radiological Contingency Planning]

• Requires NASA to take the lead in planning for and responding to a potential accident involving the launch of a nuclear power source

– “NASA Office of Space Science Risk Communication Plan for Planetary and Deep Space Missions” – Approved by Margaret C. Wilhide, Edward J. Weiler (1999) [Risk Communication]

• Requires missions utilizing nuclear power sources to develop and implement plans assigning roles and responsibilities of the offices and individuals involved when communicating with external audiences about nuclear launch safety or other safety and environmental matters that may spark public concern.

• The activities required to support these processes are collectively called “Launch Approval Engineering” (LAE)

Scope of Launch Approval Engineering


Launch Approval Engineering Processes Overview


NASA NOI NASAFINAL EIS

NASADRAFT EIS

NASA RECORD OF

DECISION

RISK COMMUNICATION

MULTI-AGENCY RADIOLOGICAL CONTINGENCY PLANNING

DOE SAFETY ANALYSIS REPORT (SAR)

INSRP SAFETY EVALUATION REPORT (SER)

DOD/DOE/EPA AGENCY VIEWS

NASA REQUEST TO OSTP FOR

NUCLEAR SAFETY LAUNCH APPROVAL

OSTP NUCLEAR SAFETY LAUNCH

APPROVAL DECISION

NASA DATABOOK

NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

PRESIDENTIAL DIRECTIVE/NATIONAL SECURITY COUNCIL MEMORANDUM #25 (PD/NSC-25)

DOE – Department of Energy DOD – Department of Defense EIS – Environmental Impact StatementEPA – Environmental Protection Agency INSRP – Interagency Nuclear Safety Review Panel NOI – Notice of IntentOSTP – Office of Science and Technology Policy

RADIOLOGICAL CONTINGENCY PLANNING

• CEQ regulations at 40 CFR 1502.4(b) refer to EIS's for broad actions. – Environmental impact statements may be prepared, and are sometimes required, for broad

Federal actions such as the adoption of new agency programs. – Agencies shall prepare statements on broad actions so that they are relevant and are timed

to coincide with meaningful points in agency planning and decisionmaking. • Programmatic documents are broad in scope, or big picture (i.e., address an entire program or a

broad action) and are sufficiently forward looking to contribute to the decisionmakers basic planning of the program or connected/similar actions (e.g., Rx development and ATLO facility modifications/build and first mission launch).

• The decisionmaker, by not preparing a programmatic EIS, would in effect segment the program and the scope of the environmental evaluation.

– In other words, by addressing each component or action individually, the decisionmaker runs the risk of missing significant environmental impacts from implementing the program or connected/similar actions.

– Programmatic NEPA documents, by taking a broad view, in effect avoid segmenting environmental analyses of common concerns by analyzing them in the entire program or suite of related or similar actions (e.g., the combined impacts of rocket motor exhaust on air quality would be evaluated across the entire array of related missions).

• Programmatic documents may be followed by site- or mission-specific documents. – The follow-on NEPA documents do not have to provide detailed analyses of the shared

environmental concerns addressed in the programmatic documents. Those concerns and relevant analyses are treated by the programmatic document and are grandfathered to the extent that the analyses remain accurate. The site- or mission-specific documents, for those environmental concerns, reference the programmatic document and only summarize the programmatic analyses. The time, effort and resources for the documents can, thus, focus principally on the individual program subelement or specific action of concern.

Programmatic NEPA Documentation


• Mission specific NEPA Process for launching an RPS vs. FPS should not be substantially different – It is recommended that NASA consider the benefits to adding additional time

for NEPA and Risk Communication tasks for at least the first FPS mission given past indications of stronger opposition to use of FPS in space than RPS in space

• e.g., response to Prometheus Notice of Intent to prepare an EIS, and • past interactions with well established and funded environmental

organizations • The major difference with a reactor development for NASA use and purposes

would be the need for Programmatic NEPA documentation in advance of any mission specific NEPA documentation – CEQ regulations require Programmatic NEPA documentation for broad

Federal actions such as the adoption of new agency programs or programs with connected/similar actions

• e.g., Reactor development and ATLO facility modifications/build and first mission launch

– The decision-maker, by not preparing a programmatic EIS, would in effect segment the program and the scope of the environmental evaluation.

Programmatic NEPA Documentation


• Reactor Technology Development – NASA with DOE as Cooperating Agency – Document should describe in general terms the technology development efforts

presumed to be associated with: • Reactor technology • Power conversion technology • Electric propulsion technology

– Document should address all facilities potentially involved in the development of the reactor technology only in summary fashion as a complex of facilities, each suited for some support of particular elements of the reactor development program.

• Minimal site descriptions in Tier 1. • Potential impacts to be assessed depend on scope of alternatives evaluated in the

EIS. – Scope of alternatives is dependent on NASA’s Purpose and Need for the action (i.e.,

Space Fission Power System development) • Scoping meetings for Tier 1 NOI – Physical and Virtual

– Physical Meetings • Washington DC • Kennedy Space Center area • DOE Development/Testing site area?

– Virtual Meeting(s) • Public Meetings for Draft PEIS • Tier 1 should be complete before Tier 2 documents can be started, must be complete

before Tier 2 decision documents.

Example of a Programmatic NEPA Document Approach


• Reactor Development and Test Facility Environmental Review Document (If required – DOE decision)

– DOE with NASA as Cooperating Agency – Follows Tier 1 document – May Not Include Processing Facility at launch site – Advantages to decision documents ahead of mission specific NEPA

• Processing Facility At Launch Site For Future Mission Ground Processing Capability – NASA with DOE as Cooperating Agency – Follows Tier 1 – Requires decision on scope of processing activities at KSC – DOE DSA for Facility Required – Advantages to decision documents ahead of mission specific NEPA

• Mission Specific Application – NASA with DOE as Cooperating Agency – Advantages to following Rx development and Processing Facility NEPA

decisions – Risk Assessment Required for Mission Specific EIS

Example Documents Tiered from Programmatic EIS TIM

ING

SE

QU

EN

CE


• NASA NEPA regulations require the agency to develop an Environmental Impact Statement (EIS) when proposing to launch nuclear systems

• NEPA documentation needs to be completed early on in a Project/Program, specifically Council on Environmental Quality (CEQ) regulations require: – Until an agency issues a record of decision, no action concerning the

proposal shall be taken which would: • Have an adverse environmental impact; or • Limit the choice of reasonable alternatives

• An EIS must objectively assess potential environmental impacts of the: – “proposed action” – “alternatives” to the proposed action – and the No Action Alternative

• During the EIS process NASA collects and responds to public, federal (e.g., EPA) and state agency comments

• When a Record of Decision on an EIS is made the agency decision-maker does NOT need to choose the most environmentally benign alternative

National Environmental Policy Act (NEPA) Process For Environmental Impact Statement


• NASA NEPA regulations require the agency to develop an Environmental Impact Statement (EIS) when proposing to launch nuclear systems

• NEPA documentation needs to be completed early on in a Project/Program, specifically Council on Environmental Quality (CEQ) regulations require:

– Until an agency issues a record of decision, no action concerning the proposal shall be taken which would:

• Have an adverse environmental impact; or • Limit the choice of reasonable alternatives

• An EIS uses the best-available information • An EIS must objectively assess potential environmental impacts of the:

– “proposed action” – “alternatives” to the proposed action – and the No Action Alternative

• During the EIS process NASA collects and responds to public, federal (e.g., EPA) and state agency comments

• When a Record of Decision on an EIS is made the agency decision-maker does NOT need choose the most environmentally benign alternative

• Consider “significant new information” while the NEPA process is ongoing and through the implementation of an agency action, and determine if any NEPA steps require extension or supplementing or revisiting.

National Environmental Policy Act (NEPA) Process For Environmental Impact Statement


Schedule Considerations for Nuclear Safety Launch Approval Processes


• Databook development typically ‘drives’ the schedule – Databook event sequences and probabilities require update every 3-4 years based on flight

experience – Previous mission INSRP recommendations (made to Program) motivate test/analysis

programs that result in databook updates (e.g. ongoing RPS Program-funded solid propellant fire environment test and solid motor drop test activities)

– Preparation of databooks for new LVs and LV configurations typically take 2-3 years (e.g. Falcon 9 Heavy, SLS)

– Nuclear safety considerations can motivate additional/modified flight termination system (FTS) designs and flight rules relative to non-NPS missions

• LV FTS design can influence nuclear risk, safety testing and analyses cost and schedule

• Safety testing programs require extensive time (~1-2 years) for effective implementation and typically are completed at least 2 years prior to launch to substantively support safety analyses

• Additional Schedule Constraints – DOE requires Final SAR Databook at L-3 years – DOE Final SAR should be completed not later than L-1 year – DOE EIS-Supporting Nuclear Risk Assessment and SAR schedules cannot overlap – NEPA process typically is completed prior to PDR or Launch Vehicle (LV) Authorization to

Proceed (ATP) , whichever is earlier

Overview of Safety Review & Launch Approval Process for US Nuclear-Powered Space Missions (PD/NSC-25)

• Nuclear safety launch approval must be obtained from the Executive Office of the President for every US nuclear-powered space mission • Nuclear safety launch approval decision is based on careful consideration of mission risks and benefits • Mission risks quantitatively characterized in two documents:

• A Final Safety Analysis Report (FSAR), prepared by DOE for the mission-sponsoring agency • A Safety Evaluation Report (SER), prepared by an ad hoc Interagency Nuclear Safety Review Panel (INSRP), based on an in-depth, exacting review and evaluation of the FSAR

• An INSRP is established for each planned US nuclear-powered space mission • INSRP: 4 Coordinators (DOD, NASA, DOE & EPA) and 1 Technical Advisor (NRC) • INSRP Coordinators and Technical Advisor appointed by high-level management from within each agency’s oversight safety office

• Independent of mission and system involvement • Have the freedom and authority to raise and confront issues at any level, as well as conduct independent analyses at any point during their multi-year review and evaluation effort • Free to employ technical experts with no conflicts of interest

• When completed, FSAR & SER are used by the mission-sponsoring agency to decide whether to formally request nuclear safety launch approval from the Executive Office of the President • If nuclear safety launch approval is requested, FSAR & SER are provided & briefed to Director, Office of Science & Technology Policy (OSTP), within the Executive Office of the President • Director, OSTP may decide issue, or forward matter to the President for final determination

1 Interagency Nuclear Safety Review Panel (DOE, NASA, DoD, EPA, NRC (advisory)) 2 Responsible mission agency makes launch recommendation

MISSION & LAUNCH

VEHICLE DATA (NASA)

ACCIDENT DESCRIPTIONS

(NASA)

SYSTEM DESIGN & TEST DATA

(DOE)

SAFETY ANALYSIS REPORT

(DOE)

SAFETY EVALUATION

REPORT (INSRP)1

DOD

OTHER AGENCIES

DOE

OFFICE OF SCIENCE &

TECHNOLOGY POLICY

OFFICE OF THE

PRESIDENT

NASA2

Sandia writes the Safety Analysis Report for DOE

Presidential Directive / NSC-25 Requires Presidential Approval (or Designee) for All Launches with Nuclear Payload

1996 Revision, Par 9: “…The President’s approval is required for launches of spacecraft utilizing reactors and other devices with a potential for criticality and radioactive sources containing total quantities greater than 1,000 times the A2 value listed in Table I…” [0.027 Ci for Pu-238] National Space Policy of 2010 confirms this directive.

• Fresh fuel with minimal burn-up has very small radiological inventory, but still needs to be formally analyzed.

• Analysis would be the same as for RPSs, plus the criticality assessment • Minimizing or avoiding pre-launch testing will affect ATLO • Uranium isotopes emit alpha particles, like Pu-238 • Fission products (if any from pre-launch testing) behave differently (beta,

gamma), but can be easily inserted into the existing codes • Assuring zero or near-zero chance of criticality is likely to be essential

(submersion in wet sand, compaction, melting, reentry, etc.) • Either first-principle analyses or stochastic evaluation with detailed

mechanics and neutronics codes are possible approaches • Post-launch operations must be part of the risk analysis (assuring no

reentry following operation, planned or accidental, or assessing the consequences)

• Reentry response (burnup or intact reentry?) - safeguards & safety issues

Considerations for FPSs

Launch Safety Analysis Approach • Goal: Quantitative estimate of the risk for use by decision maker

– Mean probability of release of nuclear material (PuO2 , U, fission products, etc.)

– Amount of nuclear material released (“source term”) – Health effects (dose, latent cancer fatalities over 50 years) – Land contamination (e.g. square km of > 0.2 microCi/m2) – All expressed as mean values, percentile values, and exceedance probability

graph (Complementary Cumulative Probability Distribution) • Numerous phenomena need to be modeled

– Blast and impact – Fire and thermal – Reentry – Criticality – Accident sequence options – Atmospheric transport and consequences

• Start with detailed understanding of the response of RPS or NPS to insults

• Perform detailed simulations and Monte Carlo sequence codes used to develop the probabilistic risk analysis

Considerations for Reactors • Fresh fuel with minimal burn-up has very small radiological

inventory, but still needs to be formally analyzed. • Analysis would be the same as for RPSs, plus the criticality

assessment • Minimizing or avoiding pre-launch testing will affect ATLO • Uranium isotopes emit alpha particles, like Pu-238 • Fission products (if any from pre-launch testing) behave differently

(beta, gamma), but can be easily inserted into the existing codes • Assuring zero or near-zero chance of criticality is likely to be

essential (submersion in wet sand, compaction, melting, reentry, etc.)

• Either first-principle analyses or stochastic evaluation with detailed mechanics and neutronics codes are possible approaches

• Highly enriched uranium in a Fission Power System poses a unique security concern

• Security needs likely to be greater than for RPS (pre & post launch)

• Trajectory passes over southern Africa before orbit is achieved • Reentry from orbit can range from +/- 28o latitude to full earth,

depending on the mission • Current US policy is full recovery, not dispersion, for RPSs;

policy/criteria for FPSs not established. • However, it is difficult to guarantee vaporization & high altitude

dispersal of core (e.g., Cosmos 954 & 1402) • Intact reentry poses a retrieval concern/issue • Analysis and decision-making approach not established for this.

FPS Post-Launch Safeguards & Safety