Radioactive material is used in thousands of locations throughout the United States for medical, industrial, and research purposes. But in the hands of terrorists, radioactive material could be used for a dirty bomb. The Nuclear Regulatory Commission (NRC) considers the health risks from short-term radiation exposure when determining how to safeguard radioactive material. But experts told a Government Accountability Office (GAO) investigation that factors such as deaths during an evacuation and the cost of environmental cleanup should also be considered.
NRC is responsible for regulating the security of radioactive material in the U.S. Failure to secure this material could result in a radiological dispersal device (RDD) causing socioeconomic damage. GAO’s April 4 report examined the extent to which radioactive security experts agreed that NRC’s assessment of risk includes all relevant criteria. During its investigations, GAO reviewed NRC policies and procedures, worked with the National Academies of Sciences to convene a meeting with 18 experts in radioactive security, and reviewed 3 recent Sandia National Laboratories studies. GAO used the views of security experts to define high risk, and they generally agreed that high risk includes both larger and some smaller quantities of radioactive materials.
The 18 experts generally agreed that the NRC assessment of risks of radioactive material does not include all relevant criteria. NRC limits its criteria to prompt fatalities and deterministic health effects from radiation, which, according to the experts and recent studies, are unlikely to result from an RDD. Two studies from Sandia measuring consequences of RDDs, released in 2017 and 2018, found that there would be no immediate fatalities from radiation. The experts at the meeting generally agreed that socioeconomic effects (e.g., relocations and clean-up costs) and fatalities that could result from evacuations are the most relevant criteria for evaluating the risks of radioactive material. The two Sandia studies found that a large RDD could cause about $30 billion in damage and 1,500 fatalities from the evacuation, and a considerably smaller RDD could cause $24 billion in damage and 800 fatalities from the evacuation. By considering socioeconomic impacts and fatalities resulting from evacuations in its criteria, NRC would have better assurance it was considering the more likely and more significant consequences of an RDD.
Using the Fukushima disaster caused by an earthquake and tsunami as an example, the report said more people died from the evacuation process than from radiation releases or the effects of the natural disasters.
NRC’s own 2016 report evaluating its security requirements for high-risk radioactive material, required by Public Law 113-235, considered only the security of larger quantities of such material and not smaller quantities. Experts who attended GAO’s meeting stated, and two 2018 Sandia studies agree, that if smaller quantities of certain radioactive material were used in an RDD, the impacts would be comparable to an RDD with a considerably larger amount of such material. For example, a 2018 study from Sandia found that malicious use of certain radioactive materials in smaller quantities could cause significant socioeconomic consequences. By requiring additional security measures for these smaller quantities of high-risk material, NRC can have better assurance that its security requirements are sufficient to secure all high-risk radioactive material from theft and use in an RDD.
As a result of its review, GAO is making three recommendations to NRC. NRC generally disagreed with the recommendations, stating that GAO’s evidence does not provide a sufficient basis for recommended changes.
The first recommendation calls for NRC staff to consider socioeconomic consequences and fatalities from evacuations in the criteria for determining what security measures should be required for radioactive materials that could be used in an RDD.
NRC disagreed with the recommendation, stating that its current regulatory requirements provide for the safe and secure use of radioactive materials, and that it felt GAO only focused on potential consequences of an RDD without consideration of the two other elements of risk—threat and vulnerability.
The second recommendation involves additional security measures for high-risk quantities of certain category 3 radioactive material, and an assessment of whether other category 3 materials should also be safeguarded with additional security measures.
NRC stated that it has already considered the issue of aggregation of radioactive material and has taken or is in the process of taking actions to clarify relevant guidance and procedures. While GAO acknowledged that NRC is taking action to better educate licensees on how to comply with requirements related to aggregation, it said these actions do not address the issue of licensees taking advantage of NRC’s security requirements which permit the storing of multiple category 3 quantities that are just below the threshold for category 2 at the same facility. Finally, for the NRC recommendation to consider additional security measures for high-risk quantities of category 3 materials, NRC said that it has been considering GAO’s recommendation in connection with its response to the recommendations in GAO-16-330. However, after GAO issued GAO-16-330, NRC staff subsequently recommended that the NRC Commission not implement the recommendations from that report.
The final recommendation in the April 4 2019 report calls for NRC to require all licensees to implement additional security measures when they have multiple quantities of category 3 americium-241 at a single facility that in total reach a category 1 or 2 quantity of material.
NRC did not specifically address this recommendation but broadly criticized GAO’s evidence.
NRC’s response to the recommendations will do little to quell the criticism that it is overly deferential to the nuclear industry.