The Risks Of Downsizing Security For New Nuclear Reactors

The Nuclear Regulatory Commission (NRC) is undertaking numerous activities related to the licensing and oversight of small modular light-water reactors (SMRs) and non-light-water reactors. The NRC expects, but does not require, that these so-called "advanced" reactors will be safer than large conventional LWRs. Based on this expectation, the NRC is undertaking two rulemakings that would reduce security and emergency planning requirements for advanced reactors by allowing applicants to take credit for additional safety features in their designs. However, the expectation of enhanced safety may not always be realized in these new designs, and enhanced safety does not always correlate with reduced susceptibility to terrorist attack. If applied without sufficient consideration of uncertainties and contingencies, these new rules could jeopardize public health and safety by allowing unanalyzed vulnerabilities to occur that could be exploited by adversaries to cause radiological sabotage or steal special nuclear materials. This paper will discuss some of the potential risks of these new rules.