Urgent Action Needed to Protect U.S. Nuclear Plants from
Terrorist Attack
Existing Security
Requirements Grossly Inadequate
Statement by
DANIEL HIRSCH
COMMITTEE TO BRIDGE THE GAP
1637 Butler Avenue, Suite 203
Los Angeles, CA 90025
(310) 478-0829
There is a realistic concern
that there may be additional terrorist attacks in the United States and that
nuclear power plants may be a target, which could result in massive release of
radioactivity. Security requirements at
these reactors are grossly inadequate to deal with the magnitude of the threat
evidenced September 11, and our efforts over the last 15 years to get the
Nuclear Regulatory Commission to fix the problems have been unsuccessful. Last Friday, the NRC once again declined to
take the steps necessary to protect reactors from terrorist attack. We call on the President and the Congress
now to act before it is too late.
Each of the nations 103 nuclear plants
contains in it an extraordinary amount of radioactivity. An attack by a truck bomb, insider, armed
group, or hijacked airliner at one of our civilian nuclear facilities could
result in sufficient radioactivity released to produce tens or hundreds of
thousands of latent cancers and contaminate hundreds of miles downwind. A Sandia National Laboratory report
concluded that a successful truck bomb attack at a civilian nuclear plant could
result in unacceptable damage, i.e., a meltdown. Containment structures were not designed to withstand a 757 crash
of the sort witnessed on September 11.
Furthermore, soft targets at
these sites necessary for keeping the fuel cooled and preventing melting are of
special concern.
These are the grim facts, made
exquisitely dangerous by the new world in which we have awakened since the
World Trade Center and Pentagon tragedies.
As Dr. Bennett Ramberg, Research Director at the Committee to Bridge the
Gap, noted in his seminal scholarly book on the subject, Nuclear Power Plants as Weapons for the Enemy: An Unrecognized Military Peril (University
of California Press: 1984), a nation
that possesses nuclear power plants in effect gives to its adversaries, be they
nation-states or subnational groups, a quasi-nuclear capability to use against
it. Low-tech assaults, such as the use
of truck bombs or airliners hijacked using box-cutters, if employed against
reactors, can wreak radioactive devastation on a scale too frightening too
contemplate. Yet contemplate it we
must, given the nature of the world in which we live.
For 15 years our two organizations have
been warning the Nuclear Regulatory Commission (NRC) that its
quarter-century-old security regulations for protecting civilian nuclear
facilities from terrorist attack are woefully inadequate and outdated. They require, for a nuclear power plant, a
very small number of guards and the ability to repel no more than a very small
group of attackers, entering as a single team and with artificial constraints
on weapons and explosives, and the involvement of only one insider. Until recently, when our repeated petitions
were finally granted in part, no protection whatsoever against truck bombs was
required, although the rule adopted is weaker than we would have
preferred. No security measures against
attack by boat or air, as just occurred in New York and Washington, are
required under NRC rules. Aside from
the truck bomb rule, the NRC security regulations have not been upgraded since
the 1970s, despite the dramatic increase in the magnitude of the terrorist
risk.
The NRC has long argued that stronger
security regulations were not required for domestic nuclear facilities and
transport because of the alleged lack of any domestic threat, the likelihood of
advanced warning if a threat materialized, the relative lack of sophistication
in terrorist attacks, and a supposed reluctance of terrorists to create large
numbers of casualties. The World Trade
Center/Pentagon coordinated attacks demonstrate that all of these assumptions
no longer hold, if ever they did.
Those attacks apparently involved far
more terrorists than the NRCs Design Basis Threat (DBT) contemplates, acting
as four independent teams (only one attacking team is contemplated in the DBT),
and employing a high level of sophistication and planning. Additionally, the attacks occurred without
any advance warning recognized as such by the responsible agencies. Furthermore, current regulations state that
reactors need not have security systems designed at protecting against attacks
by enemies of the United States, be they individuals or states.
In addition, many reactors in the country
do not have security systems in place sufficient to meet even the very weak
regulations. The NRCs Operational
Safeguards Response Evaluation (OSRE) Program tests reactor security by running
black hat mock attacks. Even with six months advance warning of when
the test attack will occur, roughly half the reactors in the country have
failed these tests. The response by NRC
and industry to this dismal record was to attempt to kill the OSRE program
entirely two years ago, and now, having had to back off because of bad
publicity, they are attempting to convert it into an industry-run
self-regulation activity.
Additionally, certain industry proposals
could significantly increase the nuclear terrorism targets and riskparticularly
the push for the construction of a new generation of pebble bed reactors, made of combustible graphite
like Chernobyl and no containment structure, and the prospect of thousands of
shipments of high level waste across the country to Yucca Mountain. [We note, in this regard, recent troubling
press reports of the arrest of someone suspected of links to the recent
attacks, a man who had a license to drive trucks carrying radioactive
materials.]
The NRC response to the World Trade
Center/Pentagon attacks has to date been less than forceful in light of the
extraordinary situation we face. Rather
than order immediate activation of emergency security plans, it merely
recommended that reactor operators
consider doing so, further asserting there was no evidence of any threat. Troops or national guard apparently have not been called out to
protect the nations 103 reactors.
Furthermore, we understand the airspace over civil reactors is not
restricted.
For a decade and a half, we have worked
quietly to try to get the NRC to act responsibly and protect these facilities
adequately. We submitted petitions for
rulemaking, met with Commissioners and their staffs, submitted scholarly studies.
With one partial exception, a truck bomb rule of insufficient effectiveness,
we have failed. We have acted in this
fashion all these years because of the great sensitivity of this issue, and the
concern that one didnt want to give terrorists ideas they did not already
have.
The horrendous events of September 11 make clear that our country is
facing adversaries well able to identify this nations vulnerabilities and
extremely willing to exploit them to produce massive loss of life. The vulnerability of our nuclear plants is no
secret. Officials have warned that there
may be more attacks planned; one need not be a rocket scientist to figure out
that nuclear plants may be the next target, topping in destructive effect the
most recent tragedy. Officials have
warned that other cells may have been pre-emplaced in the U.S. months or years
ago, as were these that carried out the September 11 attacks. Could some be working in nuclear plants
here, or planning external attacks against them?
Deeply troubled about this risk, we tried
one last time with the NRC, hoping that perhaps the recent tragedies in New
York and Washington would have driven home to that agency that it can no longer
be business as usual and that the NRC must finally and immediately fix these
glaring security problems. On September
14, we wrote NRC Chairman Richard Meserve, with whom we had met the previous
year urging the NRC to fix the huge security weaknesses at the nuclear sites
under its jurisdiction. Our letter
spelled out the emergency situation and urged the NRC take the following steps
immediately:
1. order not merely recommend the
activation of the highest level of emergency security plans at the nations
nuclear facilities and keep that protection in place until regular security
regulations are dramatically upgraded and implemented. These should include dramatically increased
protections both against external and insider threats.
2. assure that all such facilities are fully
implementing emergency security procedures of the highest level, and that the
implementation is fully adequate for each facility, given the extraordinary
threat.
3. recommend that the National Guard be called
out to protect each domestic nuclear facility, and advise the Guard as to the
specific kinds of threats that need to be protected against: truck bombs, attacks by boat or air, ground
assault/penetration, and insiders.
4. commence thorough re-evaluation of all
nuclear power plant personnel in the country for potential security risks and
establish an immediate strict two-person rule to reduce risks of insider
attack.
5. on an immediately-effective basis,
promulgate new security regulations for protection of nuclear facilities that
upgrade those regulations and the associated Design Basis Threat to deal with a
threat of the magnitude that is now clear.
That security upgrade should include:
(a)
increasing the design basis threat to a significantly larger number of
attackers;
(b)
increasing the required guard force accordingly;
(c)
requiring protection against attackers working in coordinated teams, using
sophisticated techniques and equipment;
(d)
requiring a strong two-person rule and other enhanced measures to protect
against insiders;
(e)
requiring protection against a truck bomb as large as a large semi-trailer can
carry;
(f)
requiring protections against boat and airplane attacks;
(g)
requiring full security protection of spent fuel storage pools and dry cask
storage, including after reactor closure;
(h)
requiring armed escorts for all spent fuel shipments, capable of repelling
attacks by a large number of attackers working as several coordinated teams and
using sophisticated techniques and equipment;
(i)
and eliminate the exemption in the regulations from protecting against attacks
by enemies of the United States.
6. reverse the plans for an industry-run
self-regulation program on security aimed at replacing OSRE; and instead, at least tripling the number
and frequency of OSRE tests; making any problems identified subject to
enforcement action; having OSRE test against the full magnitude of the security
threat made clear by recent events (e.g., large numbers and high sophistication
of attackers, multiple coordinated attacking teams, active insider, etc.) and
the full range of potential targets at the reactor site (e.g., spent fuel storage);
and strictly enforcing the security requirements so that failure of OSRE tests
results in reactor shutdown until and unless there is full demonstration that
the deficiencies have been fully rectified.
7.
requiring any new reactors to be able to demonstrate that its design can
withstand any credible terrorist attack, even if the security system is
penetrated.
8. barring any transport of high level waste
until and unless new security requirements are put in place that require
accompanying security forces capable of meeting attacks by terrorists of the
magnitude and sophistication so dramatically revealed by recent events, and
which provide high protection against insider actions.
Last Friday, we received a reply
from Chairman Meserve to our letter of September 14. It is identical in tone and content to all our previous
communications with the Commission over the last 15 years, declining once again
to take any of the necessary actions to protect the public from terrorists,
even under the current extraordinary circumstances. Despite the current crisis, the NRC continues to stick its head
in the sand, hoping the problem will go away of its own accord.
After great soul-searching, we have
concluded that we must go public with the problems and the failure of the NRC
to responsibly address them. One must
presume that our adversaries know the plants are vulnerable. It is time the public and our elected
officials also realize this vulnerability and demand prompt action to remedy
it.
We call on Members of Congress,
particularly those with committee responsibilities in this area, to press for
prompt action to fill these security gaps.
And we call on the President and his new head of Homeland Defense,
Governor Ridge, to promptly take the steps we have outlined to protect this
country from an attack on our nuclear facilities.
Were there an attack on one or more
nuclear plants, releasing immense amounts of radioactivity over wide areas and
contaminating large numbers of people with deadly radioactivity, we would have
trouble living with ourselves had we not taken every step we could to have
prevented it. We have quietly warned
the NRC, to no avail. Now we have no
option left but to warn the public of the problem and to call on the White
House and Congress to assure these facilities are fully and immediately
protected. We pray they act before it
is too late.