REGULATORY HARMONIZATION OF NUCLEAR SECURITY REQUIREMENTS
FOR SMALL MODULAR REACTORS: CHALLENGES AND OPPORTUNITIES

The word “harmonization” is central to the regulatory discussions surrounding the introduction of small modular reactors (SMRs). The IAEA has recently launched a new initiative on nuclear harmonization and standardization (NHSI) that brings together policy makers, regulators, designers, vendors, and operators to develop common regulatory and industrial approaches to SMRs. The initiative explores the harmonization of regulations and standards for both safety and security with the aim “to increase regulatory collaboration, to establish common positions on technical and policy issues, to pave the way to greater harmonization, initially in the prelicensing phase for SMRs, with an agreed expectation of high levels of safety and security for these advanced designs.” But how realistic is regulatory harmonization of nuclear security requirements for SMRs? International legal instruments for nuclear security, such as the Convention on Physical Protection of Nuclear Material and its Amendment (A/CPPNM), establishes nuclear security as a national responsibility, a principle that continues to be emphasized in the Nuclear Security Recommendations on the Physical Protection of Nuclear Material and Nuclear Facilities (INFCIRC/225/Rev. 5) and in all the other relevant IAEA Nuclear Security Series publications. Furthermore, the formulation of nuclear security requirements is underpinned and informed by the State’s threat assessment and design basis threat (or representative threat statement), which involves a confidential process specific to that State. These nuclear security principles would impact the discussion on regulatory harmonization. This paper explores the challenges to regulatory harmonization for the security of SMRs by analyzing the relevant Nuclear Security Series publications and other related guidance and making parallels with similar nuclear safety efforts. It discusses the viability of regulatory harmonization in this context and offers some potential solutions to overcome the challenges identified.