INSTITUTIONALIZING SAFEGUARDS-BY-DESIGN: HIGH-LEVEL FRAMEWORK

The application of a Safeguards-by-Design (SBD) process for new nuclear facilities can reduce proliferation risks. A multi-laboratory team was sponsored in Fiscal Year (FY) 2008 to define a SBD process and determine how it could be incorporated into existing facility design and construction processes. The possibility to significantly influence major design features, such as process selection and plant layout, largely ends with the conceptual design step. Therefore SBD’s principal focus must be on the early inclusion of safeguards requirements and the early identification of beneficial design features. The result could help form the basis for a new international norm for integrating safeguards into facility design. This is an interim report describing progress and project status as of the end of FY08. In this effort, SBD is defined as a structured approach to ensure the timely, efficient, and cost-effective integration of international and national safeguards, physical security, and other nonproliferation objectives into the overall design process for a nuclear facility. A key objective is to ensure that security and nonproliferation issues are considered when weighing facility design alternatives. Central to the work completed in FY08 was a study in which a SBD process was developed in the context of the current DOE facility acquisition process. The DOE study enabled the development of a “SBD design loop” that is suitable for use in any facility design process. It is a graded, iterative process that incorporates safeguards concerns throughout the conceptual, preliminary and final design processes. Additionally, a set of proposed design principles for SBD was developed. A “Generic SBD Process” was then developed. Key features of the process include the initiation of safeguards design activities in the pre-conceptual planning phase, early incorporation of safeguards requirements into the project requirements, early appointment of an SBD team, and participation in facility design options analysis in the conceptual design phase to enhance intrinsic features, among others. The SBD process is unlikely to be broadly applied in the absence of formal requirements to do so, or compelling evidence of its value. Neither exists today. A formal instrument to require the application of SBD is needed and would vary according to both the national and regulatory environment. Several possible approaches to implementation of the requirements within the DOE framework are explored in this report. Finally, there are numerous barriers to the implementation of SBD, including the lack of a strong safeguards culture, intellectual property concerns, the sensitive nature of safeguards information, and the potentially divergent or conflicting interests of participants in the process. In terms of SBD implementation in the United States, there are no commercial nuclear facilities that are under IAEA safeguards. Efforts to institutionalize SBD must address these issues. Specific work in FY09 could focus on the following: finalizing the proposed SBD process for use by DOE and performing a pilot application on a DOE project in the planning phase; developing regulatory options for mandating SBD; further development of safeguards-related design guidance, principles and requirements; development of a specific SBD process tailored to the NRC environment; and development of an engagement strategy for the IAEA and other international partners