Proposed Classifications of Remote Operations for Nuclear Reactors Based on Physical and Cybersecurity Considerations
The incorporation of remote operations into reactor operations is a topic of high interest among advanced and small modular reactor (A/SMR) vendors, with some considering it essential to the success of their business models. However, remote operations are a concept novel to the nuclear industry. While various technical aspects of remote operations have been explored, a significant gap remains in understanding the security implications of integrating remote operations into reactor designs, particularly concerning the security requirements for remote-operations facilities and infrastructure. This report aims to address this gap by first defining classes of remote operation based on the extent of remote access to reactor control systems and grounded in the existing regulatory framework with compatible terminology. Secondly, the report outlines the physical and cybersecurity requirements applicable to remote-operations facilities and infrastructure at each defined class. These requirements are based on existing licensing frameworks provided by 10 Code of Federal Regulations (CFR) Part 50 and 10 CFR Part 52, as well as the upcoming A/SMR licensing framework in the proposed Part 53. The assessment focuses specifically on security regulations, such as 10 CFR Part 73, which includes provisions for both cybersecurity (§ 73.54) and physical security (§ 73.55). This report proposes five classes of remote reactor operations. Class 1 involves remote monitoring only, with no control over reactor systems. Class 2 allows for the remote issuance of allowlisted commands to the reactor facility. Class 3 extends control to non-safety-significant, non-safety-related, or not important to safety systems and equipment. Class 4 permits remote control of safety-significant systems. Finally, Class 5 allows remote control of safety-related systems. It is important to note that these classes were defined purely with functionality in mind, without considering the practicality or feasibility of implementation for each class under current or upcoming regulatory guidance. The intention behind this approach is to enable an assessment of which security requirements apply to each class, allowing readers to evaluate the implementation possibilities for their specific use cases. Following the definition of remote-operation classes, the report assesses the specific physical and cybersecurity requirements applicable to the remote-operations facility and infrastructure within each defined class. This includes defining the types and locations of operators that are possible at each class of operation and, based on operator type and location, as well as functionality within each class, outlining the physical and cybersecurity requirements. By detailing the security requirements by class, the report provides readers with the information needed to determine the type of security program they may need to implement for their desired concept of operation. The next contribution of this report was to assess the practicality of implementing each proposed class of remote operations based upon the security requirement assessment. In short, three of the five proposed remote-operation classes were found to possibly have a practical path forward to implementation under the U.S. regulatory framework. Class 1 remote operations are currently in use in the U.S. while Class 2 and 3 remote operations may be logistically possible to implement under the U.S. regulatory framework. The final two Classes, 4 and 5, would likely be logistically difficult, if not infeasible to implement within the current U.S. physical- and cybersecurity regulatory framework. Given the results of the feasibility assessment, an example architecture is proposed for both Class 2, remote allowlisted commands, and Class 3, remote control of non-safety systems as well as security implication assessments of each architecture. These example implementations are not meant to be prescriptive in terms of how Class 2 or Class 3 remote operations should be deployed; instead, they are intended to be informative to stakeholders on how Class 2 or Class 3 could potentially be applied in order to inform their system design. An example architecture for Class 1 remote monitoring was not provided as Class 1 in already in use in U.S. nuclear operations. Example architectures for Class 4 and Class 5 were not provided due to their assessment of being likely infeasible to implement. The final contribution is an assessment of the physical- and cybersecurity implications of introducing autonomous operations into an A/SMR. What was found was that the security implications can be separated into two cases. Autonomous operations supported by SSCs located only at the reactor site, and autonomous operations supported by SSCs outside of the reactor site. For the first case, the introduction of autonomous systems will likely not change the facility’s requirement to comply with existing cyber and physical security regulation