Year
2009
Abstract
According to the principle of “security by design,” security considerations should play a role similar to that of safety considerations in the design of new nuclear facilities. The current generation of nuclear facilities was largely designed and built in an earlier era when the threats of nuclear and radiological terrorism were not viewed as serious concerns. As a result, many of these facilities have security vulnerabilities that must be compensated for with costly backfits, extensive physical protection measures, and the need for operator actions. Such weaknesses could have been minimized with proper attention to security issues in the design phase. If effectively implemented, security by design will ensure that the next generation of nuclear facilities is not prone to the same security vulnerabilities as the current generation. This would not only reduce the need for compensatory measures but also strengthen the overall security profile of new facilities, which is desirable in light of the increasing sophistication of terrorist tactics. Given the recognized importance of security by design, one would expect nuclear regulators to require the practice. However, the Nuclear Regulatory Commission (NRC) has refused to adopt a comprehensive policy that would require nuclear facility vendors to ensure that new nuclear plants are designed to withstand terrorist assaults. A case in point is the NRC’s rulemaking on the protection of new nuclear power plants against large aircraft impacts. Despite the fact that the United States actually experienced jet aircraft attacks on 9/11, the NRC has insisted that they represent “beyond-design-basis” threats, so that vendors do not have to provide “reasonable assurance” that new plants be designed to withstand them. NRC originally proposed that new designs be assessed with regard to the effects of a large commercial aircraft impact on key safety functions, but would require vendors to include features to mitigate such effects only “to the extent practicable.” While the final rule did not include this subjective escape clause, the rule has significant defects, including a requirement only that plants be designed to prevent large radiological releases to the environment in the event of an air attack, but would still allow plants to sustain significant core damage. This is not adequate to ensure protection of the public from 9/11-type attacks on nuclear plants for decades to come. This paper will analyze the implications of NRC’s policy and discuss better alternatives.