NASA Procedural Requirements

NPR 8715.26 Effective Date: February 03, 2022 Expiration Date: February 03, 2027

Subject: Nuclear Flight Safety

Responsible Office: Office of Safety and Mission Assurance

Chapter 4. Nuclear Flight Safety Requirements

4.1 Overview of Requirement Characterization

The level of rigor required for nuclear safety analysis and review, the level of authority required to authorize launch or reentry, the degree of interagency coordination warranted, the degree of RCP needed, and several other relevant characteristics are all a function of the mission categorization described in the previous chapter. This formulation provides a graded and risk-informed approach to supporting the decision-making process. Table 1 provides a mapping of the various required characteristics for each of the differing possible tiers and categories. This chapter provides the actual requirements associated with each unique element. Appendix E provides a notional process flow for nuclear flight safety-related activities.

4.2 Nuclear Safety Analysis

4.2.1 The following requirements apply to the development of a nuclear safety analysis via either a mission SAR or a Safety Analysis Summary (SAS), in accordance with Table 1. As discussed in the associated definitions in Appendix A, the distinction between these two documents is the degree of rigor and quantification. Additional contextual information is also provided in Appendix C.

4.2.1.1 The NASA Program or Project Manager shall compile the inputs required by the safety analysis preparer (e.g., information about the launch vehicle and launch operations) in a timely manner to support safety analysis preparation, as well as ensuring any needed revisions are addressed as the mission progresses.

4.2.1.2 The NASA Program or Project Manager shall arrange for the preparation of the nuclear safety analysis (SAS or mission SAR) by the safety analysis preparer.

4.2.1.3 The NASA Program or Project Manager should ensure sufficient coordination between the NFSO, the INSRB (when applicable), the program, the launch vehicle inputs provider, and the safety analysis preparer, including agreement to a schedule (typically to be developed prior to Key Decision Point C or its equivalent) for the delivery of a mission SAR using a phased approach, with the complete final mission SAR being delivered in accordance with the timeline listed in Table 1. Information potentially useful in the generation of this schedule is provided in Appendix C and Appendix E.

Table 1. Summary of NASA Nuclear Flight Safety Process Characteristics

4.2.1.4 In all cases in which a comparative analysis is being utilized (e.g., a system-specific SAR), the NASA Program or Project Manager shall obtain from the safety analysis preparer and any separate entity responsible for launch vehicle inputs, an assessment of the gaps and evaluation findings identified during the prior analyses (and its reviews) relative to improvements in the state-of-knowledge in the intervening time, prior to adopting a comparative analysis approach. Additional information is provided in Appendix C.

4.3 Nuclear Safety Review

4.3.1 The following requirements apply to Tier II and Tier III missions, which for NASA-sponsored missions require an INSRB review and SER, in accordance with NSPM-20:

4.3.1.1 The NASA Program or Project Manager shall engage the INSRB early in the safety analysis process, typically to occur prior to Key Decision Point C and after the conceptual design of the mission is generated, in accordance with NSPM-20’s requirement for INSRB engagement early in the safety analysis process.

4.3.1.2 The NASA Program or Project Manager, with concurrence by the INSRB, the Chief, SMA, and the cognizant MDAA, shall document the terms of the INSRB review, including any estimated costs of the review. Given NSPM-20 requires the terms and costs of such a review to be agreed to by the NASA Administrator and the head of the agency requesting the review, for NASA internal missions the terms and any costs of the INSRB review need the concurrence of the Chief, SMA and the applicable MDAA.

4.3.1.3 The NASA INSRB representative may, as the designated interface between the INSRB and the NASA mission, provide recommendations to the NASA Program or Project Manager on areas for additional analysis when gaps are identified, and do so in a timeframe that allows mission planners to address them without creating unnecessary delays in the launch timeline, in accordance with NSPM-20.

4.3.1.4 The NASA INSRB representative shall, as the designated interface between the INSRB and the NASA mission, ensure that any omissions or gaps identified by the INSRB during review of a NASA mission, along with any recommendations for corrective actions, are provided to the NASA Administrator (or their designee) prior to completion of the mission SAR, in accordance with NSPM-20.

4.3.1.5 The NASA INSRB representative shall, in coordination with the INSRB, ensure that the SER is ready in the timeframe identified in Table 1, and that a publicly-available Executive Summary is produced.

4.3.2 The following requirements apply to Tier I missions and other (non-tiered) missions with radioactive material requiring a nuclear safety review as specified in Table 1; in these cases the nuclear safety review takes the form of an RSR (described in Appendix A).

4.3.2.1 The NFSO shall perform a Radiological Safety Review (RSR), to include a publicly-available Executive Summary, in accordance with the timeframe identified in Table 1. Appendix A describes the general form of the RSR.

4.3.2.2 For Tier I missions only, the NASA Program or Project Manager, in coordination with the NFSO, shall ensure that significant gaps in the safety analysis are identified and provided to the safety analysis preparer, prior to mission SAR completion.

4.4 Launch and Reentry Authorization or Concurrence

Note: The requirements below are intended to work in tandem with the nuclear flight-specific payload and range safety requirements for the launch and reentry of SNS or other radioactive materials contained in NPR 8715.5, NPR 8715.7, NASA-STD-8719.24 and NASA STD-8719.25.

4.4.1 The MDAA should request Agency Views (this is the historically-used term, and is defined in Appendix A) from the other 6 INSRB-participating agencies for SNS missions in Tiers II or Tier III, if any of the following conditions exist: (i) the SER concludes that the nuclear safety analysis is of insufficient quality to support decision making, (ii) the INSRB has been unable to reach unanimity on the SER contents and a formal dissent by an INSRB member is being attached to the SER, or (iii) an agency represented on the INSRB has specifically requested the opportunity to provide an Agency View. The MDAA can always request Agency Views of their own volition. In all other cases, the mission SAR and SER would be transmitted to the Head of the INSRB agencies (or their designee) as a courtesy, in parallel to proceeding with the launch authorization request.

4.4.2 Launch and reentry authorization or concurrence (as applicable) is obtained in accordance with the authorities and timelines indicated in Table 1, and outlined as follows:

4.4.2.1 For SNS in Tier III, the Administrator shall request and obtain the President’s authorization through the Director of the OSTP. Per NSPM 20, the Director of OSTP may authorize such launches, unless the Director of OSTP considers it advisable to forward the matter to the President for a decision. To support the Administrator’s request, a briefing by the applicable MDAA, the nuclear safety analysis preparer, and the INSRB on the mission SAR, the SER, and the radiological contingency plans will be provided to the Administrator. If a Tier III mission included a planned return to Earth (reentry or fly-by), that would be part of the mission profile addressed by the mission SAR, and thus covered by the launch authorization.

4.4.2.2 For SNS in Tier II, the MDAA shall request and obtain authorization from the NASA Administrator. The authorization request will include a briefing by the applicable MDAA, the nuclear safety analysis preparer, and the INSRB on the mission SAR, the SER, and the radiological contingency plans. If a Tier II mission included a planned return to Earth (reentry or fly-by), that would be part of the mission profile addressed by the mission SAR, and thus covered by the launch authorization.

4.4.2.3 For SNS in Tier I, the MDAA shall request and obtain authorization from the NASA Administrator. The authorization request will include a summary of the major findings from the mission SAR and the RSR, as well as information regarding the radiological contingency plans. If a Tier I mission included a planned return to Earth (reentry or fly-by), that would be part of the mission profile addressed by the mission SAR, and thus covered by the launch authorization.

4.4.2.4 For missions involving radioactive material, but not including an SNS, the MDAA, in consultation with the cognizant Center Radiation Safety Officer(s), shall request concurrence from the NFSO or Chief, SMA (in accordance with Table 1), except where an Office of Safety and Mission Assurance (OSMA)-issued categorical relief memo is being applied (in which case only a notification is required). This concurrence request needs to account for radioactive material integrated into the spacecraft as part of mission design, as well as radioactive material that may be included in the launch or reentry (e.g., cargo). When the mission involves planned return to Earth (reentry or fly-by), this will be included in the launch concurrence request and will be covered by the launch concurrence. Appendix F provides a suggested format for the radioactive material reporting portion of the request.

4.4.2.5 For any planned return to Earth (reentry or fly-by) of radioactive material not covered by a launch concurrence (such as return from an orbiting research platform) the NASA Program or Project Manager shall request reentry concurrence in accordance with the analysis, review, and timelines identified in Table 1, except when an OSMA-issued categorical relief memo is being applied (in which case only a notification is required).

4.5 Contingency Planning and Coordination

4.5.1 For missions designated to require RCP in Table 1, the MDAA as the lead programmatic authority and the Center Director affiliated with the applicable range as the lead institutional authority, in coordination with the Chief, SMA and the NFSO, shall negotiate and implement a process to assure the safety of the public and NASA workforce in the event of a mishap that may create radiological risk, in cooperation with OCHMO, OIIR, OPS, the preparer of the nuclear safety analysis used for launch approval, relevant U.S. government agencies (including explicit Authorities and established Agreements therein, such as ones with the DOE), relevant local and State authorities, and international partners.

4.5.2 In developing the process to assure safety in the event of a mishap that may create radiological risk, the MDAA and Center Director should address:

a. Definition of an appropriate radiological contingency planning risk posture, comparative or otherwise, to inform decisions regarding radiological safety.

b. Development, reporting, independent review, and acceptance by relevant authorities of an assurance case tailored to the defined radiological contingency planning risk posture substantiating sufficient radiological material control and mishap preparedness, including the information necessary to make informed and reliable decisions regarding:

(1) Invoking contingency plans (with such plans being developed) to control where the radiological material will impact when vehicle or spacecraft control is possible;

(2) Monitoring, assessment, analysis, and communications capabilities sufficient to determine whether a release of radioactive material has occurred, characterize the location and nature of the release, and develop protective action recommendations for the safety of personnel and the public;

(3) Invoking material recovery plans (with such plans being developed);

(4) Disseminating information about the mishap and any recommended protective actions at the local and State levels;

(5) Coordinating with the Department of Homeland Security’s FEMA to support Federal-level coordination, and meeting the expectations of the National Response Framework and the Nuclear/Radiological Incident Annex to the Response and Recovery Federal Interagency Operational Plans (including NASA’s role as Primary Authority, when applicable);

(6) Working in concert with nuclear and other flight safety authorities or licensing entities to ensure additional relevant requirements therein are being met;

(7) Preparing, obtaining approval of, and issuing communications to the general public and to international partners, via the appropriate communications channels;

c. Implementation and exercising of the above process, plans, and capabilities, and integration of the above process within the mission-wide mishap preparedness and contingency planning (MPCP) process, which is developed in accordance with NPR 8621.1.

4.5.3 For missions that fall in to NSPM-20 Tier I, II, or III, and for other missions with an A2 mission multiple greater than 1, the NASA Program or Project Manager should consult with the Office of the General Counsel to determine if any additional actions need to be taken with respect to alignment on relevant nuclear/radiological-specific insurance and indemnification provisions. Missions other than those described above, would generally not warrant this step.

4.6 Life-Cycle Activities Relevant After Launch Authorization

4.6.1 General (Tier I, II, and III missions only)

4.6.1.1 The NASA Program or Project Manager shall incorporate nuclear flight safety considerations starting with program or project formulation through the point at which the SNS or other radioactive material no longer has the potential to affect Earth’s biosphere. Examples of the types of considerations that apply include: factoring radiological risk in to the launch vehicle selection process, managing radiation exposure to equipment, managing access to the spacecraft and the SNS, managing SNS maintenance, managing SNS control (when applicable), managing criticality safety, managing SNS malfunctions, biasing aimpoints for Earth gravity assist trajectories, and managing operational procedures and training.

4.6.1.2 The NASA Program or Project Manager, in coordination with the CHMO and the Mission Directorate with human rating responsibilities, shall address radiation exposures from the SNS into mission planning and execution for missions involving crews, or for missions where the SNS is anticipated to come into proximity with crew from other missions.

4.6.2 Lead-up-to-Launch and Post-Launch Operation (Tier I, II, and III missions only)

4.6.2.1 The NFSO should ensure that the results of the nuclear safety analysis and nuclear safety review are factored into SMA oversight after launch authorization, including consideration of the safety guidelines in NSPM-20. Appendix C presents two alternative approaches to accomplishing this best practice.

4.6.3 Decommissioning and Disposal of SNS (Tier I, II, and III missions only)

4.6.3.1 For SNS-enabled missions designed to operate in low Earth orbit, the NASA Program or Project Manager shall demonstrate by analysis that the mission design enables for disposal of the SNS in a sufficiently high orbit (as defined in Space Policy Directive-6), including the incorporation of a highly reliable operational system to ensure effective and controlled disposition of the reactor.

Note: Considerations for fission reactor systems are discussed in Section 3(a)(iii) of Space Policy Directive-6, dated December 16, 2020. All activities related to safe storage and orbital decay should involve the Orbital Debris Program Office.

4.7 Internal and External Reporting

4.7.1 The NFSO shall transmit a copy of gap identification documents, the mission SAR or SAS, the SER or RSR, and launch and reentry authorizations or concurrences, as applicable, to the NASA Headquarters National Environmental Policy Act (NEPA) Manager and the CHMO.

4.7.2 On an annual basis, the NFSO shall provide a report to the Chief, SMA for transmittal to the Director of OSTP listing all launches that the agency has sponsored in the past calendar year of spacecraft using radioactive sources containing total quantities in the range of 1,000 times to 100,000 times the A2 value (i.e., the mission multiple calculated in Chapter 3), and listing all such launches planned for the coming calendar year.

4.7.3 The NFSO shall execute an annual briefing by NASA staff (and relevant interagency stakeholders) to OSTP and the National Science and Technology Council on the status of safety analysis for all planned NASA-sponsored Tier II or Tier III missions that will involve the launch of an SNS.

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