Year
2010
Abstract
In light of the Obama Administration’s cancellation of the Yucca Mountain Project, it is likely that spent fuel will need to be stored at reactor sites for many decades to come, where it will remain vulnerable to sabotage attacks. The Christmas Day 2009 attempted bombing of a U.S. jetliner over Detroit is a stark reminder that U.S. infrastructure remains an attractive target of international terrorism. Nuclear plant licensees and the Nuclear Regulatory Commission (NRC) should be taking steps now to ensure that Independent Spent Fuel Storage Installations (ISFSIs) will have robust protection against attack over the long-term. The NRC is currently undertaking a rulemaking to revise the physical protection requirements for ISFSIs, motivated in part on the results of vulnerability assessments that, according to a December 16, 2009 notice in the Federal Register, challenged “previous NRC conclusions on the ability of a malevolent act to breach shielding and/or confinement barriers and thus release radiation or radioactive material.” However, the NRC’s proposed approach for the rulemaking suffers from a number of flaws. Under the proposal, the NRC would not require any ISFSI licensee to protect the facility from the design basis threat (DBT) of radiological sabotage, and would not require ISFSIs to be targets in force-on-force exercises. Moreover, the proposal does not require that the licensee’s security force be able to interdict and neutralize an adversary, provided that the projected dose at the controlled area boundary from a sabotage attack does not exceed 5 rem. Thus the need to apply a denial of access strategy at a particular ISFSI would depend on the results of calculations. However, such calculations are of dubious reliability because they have not been validated with experimental data (and the Department of Energy cancelled a program that would have provided such data). This paper will discuss the problems with the NRC’s proposed approach and suggest a better path forward.