Year
2024
Abstract
| The process of developing export control regulations is a long slog process that includes numerous U.S. Government (USG) Departments and Agencies, international regimes, and both technical and foreign policy experts. Science and technology far outpace regulatory development. Export controls also have weaknesses - a number of States have found loopholes and workarounds for export control regulations that include complex language that requiring deep technical expertise, a lack of enforcement ability, and companies in third countries that are unknowingly (or knowingly) serving as transshipment points for proliferators. However, regulatory weaknesses do not dilute the need for control of commodities and technologies, including many essential to the INMM that also support R&D for other emerging technologies. To that end, the National Energy Technology Laboratory (NETL) has undertaken an effort to identify and understand sensitive areas associated with a range of research efforts undertaken at or with NETL known colloquially as a Programmatic Assessment of Technology Sensitivity (PATS). Each major research area is divided into research thrusts and each of these thrusts is assessed as non-sensitive or sensitive, with additional low/medium/high rankings discussed in the associated narrative. These assessments provide baselines from which a more thorough assessment could be completed to include processes like foreign national approval processing (as outlined in DOE Order 142.3) to broader research security efforts. While many research areas, such as carbon capture technology, do not have obvious connections to weapons of mass destruction (WMD) research areas nor commodities associated with their production, controlled commodities and could be used as part of carbon capture efforts, such as sensitive membranes that capture CO2 and store it for sequestration. Research in to refining these membranes is an ongoing area of active research and, depending on the formulation and production, could come close to NP or CB controlled membranes. Therefore, one could assess that an overall carbon capture research program is “non-sensitive,” but research advancing membrane technology could be assessed as “low sensitive” because of the dual-use nature of the research being able to support efforts like uranium enrichment. This INMM paper and associated presentation will discuss the process that NETL underwent to develop these reports to include programmatic thrust identification, identification of sensitive areas, feedback from stakeholders, and finalization. These reports could serve as a template for other institutions to identify particularly sensitive research and prioritize those research areas for additional review. Most institutions have limited resources to commit to overhead functions like export control and research security, identifying high and low sensitivity research areas will help prioritize limited resources. |