ML24250A174

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Security for New and Advanced Reactors_Slides
ML24250A174
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Issue date: 09/06/2024
From: Anthony Bowers
NRC/NSIR/DPCP
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ML24250A173
Download: ML24250A174 (1)
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Security for New and Advanced Reactors

Tony Bowers, Deputy Director Division of Physical and Cybersecurity Policy Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission NRCs Security Initiatives

  • Alternative Physical Security Requirements for Advanced Reactors (Limited Scope Rule)
  • Risk-informed, Technology Inclusive Regulatory Framework for Advanced Reactors (Part 53) o Physical Security, Cybersecurity, Access Authorization, and Fitness for Duty
  • Micro-reactor Policy Papers o SECY-24-0008, Micro -reactor Licensing and Deployment Considerations: Fuel Loading and Operational Testing at a Factory;

Enclosure:

Technical, Licensing, and Policy Considerations for Factory-Fabricated Micro-Reactors (ML23207A250)

o SECY-24-XXXX, Micro -reactor Licensing and Deployment Considerations: Nth-of-a-Kind Micro-Reactor Licensing

  • Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE)

Act of 2024 Alternative Physical Security Requirements for Reactors Advanced Reactors (Limited Scope Rule)

Status: Proposed rule published August 9. Public Meeting on September 19. Public comment period closes on October 23, 2024 [Docket ID: NRC-2017-0227]

Applicability: Small Modular Reactors (SMR) or Non-Light Water Reactors (LWR)

Eligibility: Radiological Dose Consequence

Alternative Physical Security Requirements:

1. Eliminates requirements for minimum number of onsite armed responders.
2. Law enforcement or other offsite responders can interdict and neutralize Design Basis Threat (DBT) adversary.
3. Allows for alternative means for accomplishing delay other than with physical barriers
4. Allows for an offsite secondary alarm station.
5. Allows for removal of designation of offsite secondary alarm station or its secondary power supply as vital areas.

Cybersecurity Considerations: This rule does not contain any specific cybersecurity requirements. The requirements of 10 CFR 73.54 and the associated guidance in RG 5.71 and NEI 08-09 would apply.

Risk-informed, Technology Inclusive Regulatory Framework for Advanced Reactors (Part 53)

Status: Sent to Commission on September 4 (anticipate 4-week review). Projected proposed rule and supporting documents to be published the week of October 14th with a 60-day comment period.

[Docket ID: NRC-2019-0062]

Applicability: All new reactor licensees and types

Eligibility: None; Radiological Dose Consequence for Certain Provisions

Highlights:

  • Covers a broad range of technologies and source terms
  • Performance-based, graded approach versus prescriptive requirements
  • Includes physical security, cybersecurity, fitness for duty, and access authorization
  • Leverages experience from research and test reactors, large light water reactors, certain fuel cycle facilities, and medical isotope facilities
  • Proposes a class of reactors that would not be subject to the DBT
  • Promotes innovation and enables the use of technology advances in security and fitness for duty
  • Includes provisions for factory fuel load Applicable Draft Guides (DGs)

Draft Guides for Alternative Physical Security Requirements for Advanced Reactors:

  • DG-5071, Target Set Identification and Development for Nuclear Power Reactors (Not publicly available) - Note: DG-5071 is also applicable to Part 53
  • DG-5072, Guidance for Alternative Physical Security Requirements for Small Modular Reactors and Non-Light-Water Reactors (ML23263A997)

Draft Guides for Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors (Part 53):

  • DG-5073, Fitness-For-Duty Programs for Commercial Nuclear Plants and Manufacturing Facilities Licensed Under 10 CFR Part 53 (ML23286A251)
  • DG-5074, Access Authorization Program for Commercial Nuclear Plants (ML23286A268)
  • DG-5078, Fatigue Management for Nuclear Power Plant Personnel at Commercial Nuclear Plants Licensed Under 10 CFR Part 53 (ML23286A286)

Radiological Dose Consequence Analysis

Under either proposed rule, the radiological dose consequence analysis would estimate the potential offsite radiological dose that could result from a postulated security-initiated event.

  • Considers a significant release of radionuclides from any source, not core damage and spent fuel sabotage
  • Limited Scope Rule - allows SMR and non-LWR applicants and licensees to consider a limited number of operator actions and physical security features in the analysis.
  • Part 53 - new reactor applicants and licensees would have to assess the potential offsite radiological consequences of a postulated, unmitigated DBT attack. Only the facility design and siting can be considered.

If the offsite radiological dose consequences are at or below the appropriate dose reference values (25 Rem):

  • Limited Scope Rule - applicants or licensees would be permitted to implement any or all of 5 proposed alternative security requirements.
  • Part 53 - applicants and licensees would be:

o Relieved from the requirement to defend against the DBT o Would not be subject to NRC force-on-force inspections o Instead, would be required to implement, and maintain physical protection programs like those to protect special nuclear material of moderate and low strategic significance or Category 1 or 2 radioactive material, as applicable (10 CFR Part 37, 10 CFR Part 73.67) o Graded approach to cybersecurity Reliance on Offsite Responders

A licensee would be required to:

  • Maintain the capability to detect, assess, interdict, and neutralize threats;
  • Provide adequate delay to enable law enforcement or other offsite armed responders to fulfill the interdiction and neutralization functions;
  • Provide facility information and make periodic training available to law enforcement or other offsite armed responders;
  • Describe in its safeguards contingency plan the role(s) that law enforcement or other offsite armed responders will play in the site protective strategy [enabling NRC to make an independent, adequate protection determination];
  • Identify criteria and measures to compensate for the degradation or absence of law enforcement or other offsite armed responders and propose suitable compensatory measures.

A licensee would be relieved from the following requirements:

  • Most of the training and qualification requirements related to armed response personnel in section VI of appendix B to Part 73 for law enforcement responders.
  • Location-related requirements in 10 CFR 73.55(k)(5)(iii) and in section II.B.3.c.(iv) of appendix C to Part 73 related to armed responders.

Note: A licensee would be required to meet the performance evaluation program requirements in section VI.C.3 of appendix B to Part 73 for all armed response personnel, including law enforcement (tactical response drills and force-on-force exercises).

Security by Design

  • Important to consider and integrate safety and security in the new reactor design process, as early as possible.
  • Effective security designs are developed around good estimates of the threats, whether from external (or outsider) sources or internal (or insider) threats.
  • Security by design provides designers the opportunity to incorporate physical security features into the design that may include:

o Hardening interior and exterior walls o Minimizing access points to vital equipment and operations areas o Below grade construction

  • Modeling and Simulation Software:

Numerous tools exist to help new reactor designers and vendors design physical security elements into their new reactor facilities.

Micro-reactors

SECY-24-0008 (ML23207A250; currently with the Commission): Micro-reactor Licensing and Deployment Considerations: Fuel Loading and Operational Testing at a Factory

  • Provides the Commission with options for regulating certain aspects of fuel loading and operational testing of commercial factory-fabricated micro-reactors. This paper also seeks Commission direction on whether a factory-fabricated micro-reactor that includes features to preclude criticality would require a facility operating license or a combined license when loaded with fuel.
  • Enclosure (ML23207A251) to SECY-24-0008 includes various topics related to the licensing and deployment of factory-fabricated micro-reactors as well as NRC staffs near-term strategies and next steps for addressing each topic.
  • Multiple considerations for Siting:

o Timeframe for Authorization to Operate o Replacement of Factory Fabricated Modules o Autonomous and Remote Operation o Transportation of Fueled Factory Fabricated Modules o Mobile Micro-reactors

SECY-24-XXXX (currently under development and internal review): Micro-reactor Licensing and Deployment Considerations: Nth-of-a-Kind Micro-Reactor Licensing

  • The NRC staff is exploring approaches to review operational matters at the design approval stage (ML or DC) for a standard micro-reactor design considering site specific operational programs (Security and Emergency Preparedness).

ADVANCE Act of 2024

  • Requires NRC to take several actions, particularly in the areas of licensing of new reactors and fuels, while maintaining the NRCs core mission to protect public health and safety. Nuclear safety and security will always come first!
  • The NRC will undertake efforts in multiple areas to address the Acts requirements, including:

o implementing initiatives to achieve efficient, timely, and predictable license application reviews o establishing an expedited procedure for reviewing qualifying new reactor license applications o developing a regulatory framework for fusion technology o implementing changes to how the NRC recovers fees from licensees, including establishing a lower hourly rate for advanced reactor applicants and pre-applicants o assessing the licensing review process for new nuclear facilities at former fossil-fuel power plant sites and brownfield sites o developing strategies and guidance for microreactors o removing certain limitations on foreign ownership of some types of licensed facilities o continuing to support international coordination on nuclear technologies and licensing activities o implementing new requirements relating to nuclear fuel o updating update its mission statement to ensure efficient regulation and licensing of civilian radioactive materials and nuclear energy, without unnecessarily limiting their societal benefits

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