The recently published GAO report, titled “Preventing a Dirty Bomb: Nuclear Regulatory Commission Has Not Taken Steps to Address Certain Radiological Security Risks”, underscores critical concerns in the United States’ efforts to safeguard radioactive materials. This report focuses on the vulnerabilities in the Nuclear Regulatory Commission’s (NRC) current regulations and how these gaps leave the nation exposed to potential radiological terrorism in the form of a dirty bomb.

The report highlights that while the National Nuclear Security Administration (NNSA) and the Department of Homeland Security’s (DHS) Countering Weapons of Mass Destruction Office (CWMD) incorporate socioeconomic consequences—such as the costs of decontamination and the long-term denial of access to contaminated property—into their assessments, the NRC does not. The NRC remains focused on immediate fatalities and health risks from radiation exposure, neglecting the broader and often more significant socioeconomic impacts of a dirty bomb. This discrepancy has led to a patchwork of security measures across agencies, with the NRC leaving certain radioactive materials, particularly those categorized as Category 3, under-protected.

Category 3 materials, although less potent than Category 1 and 2, still pose significant risks if used in a dirty bomb due to their wide availability and insufficient regulation. These materials are often used in industries such as medical and industrial sectors for purposes like cancer treatment or sterilization. However, the NRC does not centrally track these materials, nor does it impose strict security measures for their handling, leaving them vulnerable to theft or misuse. For instance, while NNSA and CWMD focus on securing these materials and supporting the replacement of high-risk radioactive devices with safer alternatives, the NRC’s regulations have remained stagnant, and the agency has been slow to adopt recommendations that could mitigate the threat.

The GAO report highlights the disparity in approaches to radiological security, noting that NNSA and CWMD have implemented most of the GAO’s previous recommendations, while the NRC has not. Of the 18 recommendations made to the NRC between 2012 and 2024, only seven have been implemented. Among the unimplemented recommendations are critical measures such as incorporating socioeconomic consequences into risk assessments, strengthening the security of Category 3 materials, and centrally tracking these materials and their licenses.

The failure of the NRC to address these gaps is particularly concerning in light of the growing number of reported incidents involving lost or stolen radioactive materials. From 2013 to 2023, the NRC reported over 4,000 nuclear materials events, many of which involved the theft or loss of radioactive sources. Furthermore, the International Atomic Energy Agency (IAEA) reported a similarly alarming number of illegal or unauthorized activities involving radioactive materials during this period. The report emphasizes that even a small amount of radioactive material, if weaponized into a dirty bomb, could lead to massive decontamination costs and long-term exclusion of public access to affected areas.

One of the report’s key findings is the significant role of socioeconomic damages in evaluating the overall risk of a dirty bomb. A dirty bomb may not cause immediate fatalities, but it can result in economic devastation, with decontamination efforts costing billions of dollars and causing long-term denial of access to major infrastructure or urban areas. The failure to consider these consequences in regulatory frameworks creates a serious blind spot in the nation's radiological security.

In response to these risks, the GAO recommends that Congress direct the NRC to include socioeconomic consequences in its decision-making processes for radiological security and require the tracking of all Category 3 radioactive materials and licenses. These changes would align the NRC's approach with that of NNSA and CWMD, ensuring a more comprehensive response to the dirty bomb threat.

The GAO report also examines the financial implications of addressing these security risks, noting that the cost of implementing enhanced security measures for Category 3 materials, such as tracking systems and stronger verification requirements, would be a fraction of the potential socioeconomic damages caused by a dirty bomb. The NRC’s reluctance to implement these changes is attributed to its focus on immediate health effects rather than the broader, long-term consequences that could arise from a dirty bomb incident.

Ultimately, the report calls for greater coordination among federal agencies, including the NRC, NNSA, and CWMD, to address the full spectrum of risks posed by radioactive materials. By failing to incorporate socioeconomic consequences into its regulatory framework, the NRC is leaving a critical gap in the nation’s radiological security, one that could have devastating effects if exploited by bad actors.

This blog post is a summary of the GAO report and is for informational purposes only. It does not constitute legal advice, and the accuracy of the content is not guaranteed. Readers should consult with a qualified professional for legal or technical advice.