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June 5, 2002
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The Future Wellstone Deserves
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India,
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The Caterpillar
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From FDR to Mister "W.":
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Under the
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Bush 9/11 Scandal for Dummies
June 1, 2002
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Bush and Mies van der Rohe:
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Sharon's
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Crumpling the Constitution
May 31, 2002
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May 29, 2002
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June 5, 2002
Nuclear Plants and Terrorism
by Danielle Brian
[Editors' note:
This article is adapted from testimony given on June 5 before
the Senate Environment and Public Works Committee hearing on
security at nuclear power plants.]
The Design
Basis Threat
Nuclear facilities are required to protect
against a specified level of threat (known as the Design Basis
Threat or DBT) from outside attackers and inside conspirators
using a specific set of weapons. NRC's current DBT is wholly
inadequate and must be made more realistic. According to published
sources including U.S. News and World Report, the NRC's DBT requires
protection against only three outside attackers with the help
of one passive insider. This is absurd given the 19 terrorists
involved in the highly coordinated, technologically advanced
September 11 attack.
Rumors are that DOE will increase its
DBT to approximately ten outside attackers and significantly
upgrade the weaponry and tools that adversaries can be expected
to use in an attack. However, although some in NRC have also
recommended an increase to its DBT, there seems to be resistance
within the senior ranks of the NRC to committing to making these
improvements. There appears to be no justification for the NRC
to have a less robust DBT for nuclear power plants than DOE has
for nuclear weapons facilities. A successful attack on either
a nuclear power plant or weapons facility would cause unfathomable
damage to surrounding populations. We believe that the provisions
in the "Nuclear Security Act" for a new and significantly
upgraded DBT are absolutely essential.
In addition to the inadequate number
of attackers to be protected against, the current DBT does not
require protection against some of the most dangerous weapons
that are available on the open market today, such as 50 caliber
API sniper rounds that can penetrate hardened guard posts and
vehicles, nor do they use simulated chemical or biological agents
that would require the guard force to be trained with gas masks.
Furthermore, performance tests do not employ diversionary tactics
that are likely to be used during an attack, such as remote controlled
explosives. POGO agrees with the Nuclear Security Act's provisions
that the new DBT include enhanced requirements for more realistic
weapons, explosives, tools, and tactics, as well as more outside
attackers and active inside collaborators.
Poor Performance
Though the DBT is severely inadequate
compared to what we now recognize as the threat, half the nuclear
power plants cannot even protect against this current standard
of three outside attackers. David Orrik, the head of the Operational
Safeguards Response Evaluation (OSRE) program, testified before
the House Commerce Committee on April 11, that in 46 percent
of the force-on-force security tests:
"the expert NRC team identified
a significant weakness--significant being defined as the adversary
team simulating sabotaging a target set, which would lead to
core damage and in many cases, to a probable radioactive release.
It is important to note that, even with adequate time for the
plants to prepare and make themselves ready for the OSRE, that
46% still had a weakness in armed response."
Let me caution the Committee--these tests
are seriously dumbed down to favor the guard forces. The utilities
are informed of an upcoming test six to ten months in advance
giving them plenty of time to prepare, the guards are usually
aware of the attack scenarios, the mock terrorists are allowed
to be made up of the utilities' own management staff, and the
weapons used in the tests are not nearly as dangerous as those
that can easily be found on the open market. Despite their clear
artificiality and imperfections that favor the guard forces,
force-on-force performance tests are still the best test of the
performance of a guard force in protecting key targets at a nuclear
facility. This is the key issue that cannot be forgotten--can
the guard force protect the integrity of the reactor and the
spent fuel pools from a suicidal terrorist attack? The statistics
say no. How much worse would those statistics be if the DBT accurately
represented the very real and sophisticated threat we know we
are now facing?
The mindset of both the utilities and
the NRC is far too compliance-oriented--rather than performance
tested. Our security guards are regularly told that security
upgrades are unnecessary because the utility is already in "compliance"
with NRC regulations. In other words, if a checklist of requirements
for detection, delay, and response is met--to include such items
as a double-fence, alarms, a certain number of guards--the facility
is deemed secure. However, performance tests repeatedly reveal
that despite this "compliance" with requirements, physical
security and the guard forces cannot stop terrorists from causing
catastrophic damage to the reactor. This institutionalized bureaucratic
complacency may be the biggest impediment to adequate security.
A post-September 11 example of this phenomenon
is that armed guards are now required to accompany all visiting
trucks coming onto the site. We are told, there is often no extra
guard available, and therefore, a guard is required to leave
his post uncovered to accompany the truck. In these cases, the
facility may be in compliance with this new requirement, yet
guards are concerned that there is a hole in their defensive
posture.
Spent Fuel
Pools are Security's Poor Stepchild
The NRC has never tested a power plant
guard force's ability to protect spent fuel pools--possibly the
prime target of a terrorist attack. In October of 2000 the NRC
started to recognize the problem of spent fuel fires in a study
of the effects of accidents. However, in 100 pages of analysis,
they never considered sabotage by terrorists. The NRC needs to
create a target/assets list prioritized by importance.
Several spent fuel pools at nuclear power
plants across the country are only 50 yards from the double fence
line. In a terrorist attack, the initial strike would likely
be extraordinarily violent, fast, and with a significant level
of human carnage. According to Sandia National Lab's "Barrier
Technology Handbook," it is estimated that a terrorist could
penetrate the fence line and breach a door or side of a secured
building in less than 60 seconds. We encourage the NRC to immediately
recognize spent fuel pools as a primary terrorist target.
We have been advised by military Special
Forces sources of specific and obvious vulnerabilities at most
nuclear power plants that I would be happy to discuss with Senators
or staff. I am uncomfortable, however, outlining them in public
testimony.
To explain in general terms, a certain
type of explosive, which a terrorist could carry on his back,
would allow him to blow a sizeable hole in the reinforced concrete
bottom or wall of the spent fuel pool. At nuclear plants that
have boiling water reactors (BWR)--about one-third of the existing
reactors are BWRs--things could be even worse. These reactors
have the spent fuel pools above ground. In these cases, a certain
kind of explosive could even be launched from outside the fence
lineinto the side of the pool. According to an unclassified study
by Brookhaven National Lab, under certain conditions, the pool
would start draining immediately, which could result in the immediate
release of high-levels of radiation, quickly turning into an
uncontrolled radioactive fire, and the plant could do nothing
effective about it.
The Nuclear Security Act does require
a plan to increase security of these spent fuel pools. In the
meantime, we would encourage the addition of barriers and delay
mechanisms to supplement security until the spent fuel is placed
in dry casks underground.
Inadequate
Training and Weaponry
Guards from several of the power plants
have registered complaints with POGO about inadequate training
as well. For example, one facility hired a new class of guards
after September 11. The vast majority of the new recruits had
never fired a gun before. During their training, they were limited
to firing 96 rounds with their handgun, and far fewer with their
shotguns. Two guards quit after two months on the job believing
they couldn't protect the plant in the case of a terrorist attack.
They told POGO, and other guards have admitted to NRC inspectors,
that their training is so inadequate, in the face of a real terrorist
attack, many guards would use their guns simply to protect themselves
while they escaped from the plant. Other guards with decades
of experience protecting nuclear power plants bemoaned the lack
of training outside the classroom, as well as the lack of modern
tactical training. For example, their firearms training requires
only that they be capable of standing and hitting a stationary
target 25 yards away--they have no training shooting on the run
at a moving target.
Additionally, the guard forces at nuclear
power plants are severely out-gunned. Even the NRC's DBT assumes
that attackers will be armed with automatic weapons and explosives,
yet many guard forces around the country are equipped only with
shotguns and revolvers. We understand that the NRC is working
with the Committee on legislative language to address this discrepancy.
Security Tests:
More Often and More Robust
NRC's virtually defunct Operational Safeguards
Response Evaluation (OSRE) program conducts force-on-force tests
using mock attackers only once every eight years at each plant.
According to the nuclear power plant security guards and NRC
inspectors we have interviewed, this eight-year hiatus creates
a woeful lack of focus on security between tests. According to
the guards with whom we have been working, because the tests
are announced so far in advance, the utility management has time
to quickly invest in security training consultants to improve
their posture and chances of success. The guards advise us that
after OSRE force-on-force tests, the security posture regularly
returns to a bare minimum.
POGO agrees with the Nuclear Security
Act's provision to require that such tests occur no less than
every two years to ensure that heightened standards remain in
effect. POGO additionally recommends that the utility only be
given 24- to 36-hour notice and that the utility be required
to freeze in place the guard force to be tested at the moment
of notification, rather than being allowed to call in the youngest
or most capable guards.
Currently, the mock terrorists and the
attack scenarios to be tested are chosen by the utilities. The
mock terrorists can be county or state police, the utility's
own training staff, or even their own utility management staff--the
very people who have a stake in ensuring success. With all due
respect to these people, and as genuine as they may be in trying
to test the physical security of the facility, none of them are
trained to have the mindset or skills of highly trained terrorists.
POGO recommends the use of military Special Forces units that
are already trained to act as the adversarial team in force-on-force
tests.
According to the guards, they know within
an hour or two when a test will take place and what part of the
plant the mock terrorists will attack. They tell us that contrary
to the full-page ads in the Washington Post and other newspapers,
they do not normally wear flack jackets or their communications
gear, nor do they carry their semi-automatic weapons. Sometimes,
the guards are more than a football field's distance away from
their weapons and flack jackets. However, when the mock attack
is about to take place, the guards are magically wearing their
flack jackets and communications gear and have their weapons
in hand. Even more troubling is the fact that, at one-third of
nuclear power plants, the guards only have access to shotguns,
and they are locked up at a central location. In case of a real
attack, the guards would have to go to that location, unlock
the cabinet, get their shotguns and protective gear, and return
to their post. By that time, the terrorists would have achieved
their goals and caused catastrophic damage. Ongoing, limited-scope
performance tests should regularly be testing the timelines for
terrorist access to critical components.
If the facility fails a performance test,
the Nuclear Security Act requires re-testing every six months
until it passes. We would recommend, immediately calling in a
well-armed and trained National Guard unit as compensatory action
to supplement security until the facility passes a new OSRE test.
We have learned from anti-terrorism experts
that the worst enemy of any guard force is the daily grind of
nothing happening. Guards are only human. A simple way to combat
this problem is to add unannounced checks by the NRC to security
testing. Fast food chains and the Postal Service frequently use
a "mystery shopper" to use a false ID or exploit some
other weakness. Because the guards know a "mystery shopper"
may be in their midst at any time, they remain more alert. This
would be a very low cost tool that would significantly supplement
security.
Federalization
We recognize that federalizing the security
force is a contentious issue. POGO believes that the same goals
can be accomplished through far more vigorous federal oversight,
along with upgraded training, compensation, and authority granted
to security forces.
Currently, security guards who are risking
their lives are among the lowest compensated employees at many
plants. Pay scales and first responder benefits for security
forces, including life and disability insurance, should be commensurate
with those accorded to local police and fire departments. We
cannot expect our security guards to give their all when we do
not fairly provide for them in the event that they are injured
while performing this dangerous and important job.
Also, people working at nuclear power
plants, including NRC and utility employees as well as contractor
and subcontractor employees, should be given whistleblower protections.
In the current climate of fear and whistleblower retaliation,
it has been our experience that people have been deterred from
coming forward with important information that could help fix
security problems. The Paul Revere Act, introduced in the House,
and soon to be introduced in the Senate, would strengthen whistleblower
rights and extend them to federal contractor employees.
We applaud the introduction of Senate
Bill 1586 that recognizes that security forces do not have enough
authority to carry out their mission. Currently, guards are prohibited
from using deadly force unless an intruder wields a gun, or they
feel their life or the life of someone else is in danger, in
accordance with state law. In other words, if an attacker jumps
over the fence with a backpack and runs towards the reactor building
or spent fuel pool, the guard can only attempt to chase down
the attacker. We have been told of an instance when an NRC inspector
observed a guard follow a mock terrorist during a force-on-force
drill as he destroyed critical target sets in the reactor complex.
When asked why he wasn't doing anything to stop him, the guard
explained that he didn't have the authority to shoot an intruder
who was only destroying property. The NRC has been trying to
resolve this conflict for years. This legislation must remedy
this obvious failure.
Local law enforcement and first responders
should also be given clearance to receive safeguard information
so they can better coordinate emergency response plans. Currently,
local law enforcement and first responders, in many cases, do
not have adequate familiarity with the layout of critical areas
of the plant that is necessary to respond to an emergency.
If there is any expanded role for the
federal government, it should be providing independent oversight,
rather than management of security. Robust and credible federal
oversight is absolutely key to adequate security at both the
nuclear power plants and nuclear weapons facilities. POGO has
already recommended taking the security oversight function out
of DOE, and we strongly recommend the same for NRC. NRC has historically
been altogether too compliant with industry's wishes. For example,
recently agreeing to industry's demands to replace OSRE with
industry self-assessments of security was totally irresponsible.
History has shown that the critical job of security oversight
cannot be adequately performed from within these agencies. Therefore
we suggest that a small independent Office of Nuclear Security
be created, perhaps housed in the Office of Homeland Security,
or perhaps as an independent agency reporting to the Congress
and President. Its purpose would be to provide oversight over
and test the security of both government and commercial nuclear
facilities.
Danielle Brian
is the executive director of the Project
on Government Oversight. She can be reached at: beth@pogo.org
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