On Monday, March 13, 2017, the U.S. Nuclear Regulatory Commission (NRC) issued preliminary draft guidance concerning how “advanced reactors should consider safety and security requirements together in the design process.” The draft guidance notes that the Commission expects advanced reactor companies to incorporate security features early on into the design of the reactor that lessen the need for human actions. The core of the draft guidance document is a table containing seven physical security design considerations (items 1-7 below), and three cybersecurity design considerations (items 8-10 below), concerning the following concepts:
- Intrusion detection systems.
- Intrusion assessment systems.
- Security communication systems.
- Security delay systems.
- Security response.
- Control measures protecting against land and waterborne vehicle bomb assaults.
- Access control portals.
- Defense model architecture.
- Cyber security defense-in-depth.
- Least functionality.
These design considerations pull from concepts found in 10 C.F.R. Part 73, “Physical Protection of Plants and Materials,” supplemented with cybersecurity insights. The agency is seeking comment on the draft by April 27, 2017—not only on the specific design considerations listed, but also on “the scope of the security design considerations” generally, and on “general principles and good practices for designs of engineered [systems, structures, and components] to achieve physical and cyber security functions.” We encourage the interested community to submit comments.
It is an exciting time for the advanced reactor community. The same day as this guidance was released, GE Hitachi Nuclear Energy announced a cooperation agreement with Advanced Reactor Concepts LLC on “the development and licensing of an advanced small modular reactor (aSMR) based on mature Generation IV sodium-cooled reactor technology.” Collaboration between small ventures and established entities hold significant promise for the industry. But these collaborations are not only effective for improving technical prospects for commercialization; they also provide the new venture a means by which to better understand and influence the regulatory landscape, especially as it develops now for advanced reactors.
The NRC is actively seeking stakeholder input as it develops a regulatory framework for advanced reactors, including holding public meetings such as one planned for March 22, 2017 on “Possible Regulatory Process Improvements for Advanced Reactor Designs.” The fact that established nuclear players are part of the advanced reactor community can provide a useful perspective to inform NRC guidance. For example, on the issue on physical and cyber protection, established players can offer insights based on their experiences with the current regulatory framework and practical challenges that result, which can lead to a better guidance document for everyone.