Nuclear Control Institute
1000 Connecticut Avenue N.W.
Suite 410
Washington DC 2003

Committee to Bridge the Gap
1637 Butler Avenue
Suite 203
Los Angeles CA 90025

September 14

The Honorable Richard Meserve
U.S. Nuclear Regulatory Commission

Washington, D.C.

Dear Chairman Meserve: 

In light of the extraordinary and unprecedented terrorist threat that now exists inside the United States in the wake of the attacks on the World Trade Center and the Pentagon, we are writing urgently to request that you promptly advise the President and the governors of each of the 32 states in which operational nuclear power plants are located to call up National Guard forces for the purpose of providing additional security for these plants. We also urge prompt consideration of deployment of radar-directed, anti-aircraft weaponry by these forces at the plant sites.

Since 1987, when Iran issued a threat against U.S. centers and nuclear reactors, our organizations have repeatedly called upon the Nuclear Regulatory Commission to upgrade protection at nuclear power plants against truck-bomb attacks and other armed assaults. Nonetheless, half of the nation's 103 nuclear power plants are currently failing to repel NRC-supervised mock terrorist attacks involving only three lightly armed "attackers." These "force-on-force" exercises have resulted in the simulated destruction of redundant safety systems that in a real attack would result in severe core damage leading to a meltdown.

In 1994, the NRC finally agreed with our longstanding request for adoption of a truck-bomb rule, but only after the truck-bomb attack on the World Trade Center and an intruders crashing of his car into the remaining Three Mile Island plant provided the wake-up call the year before. The Commission has since resisted our demands to upgrade the truck-bomb rule to establish barriers and set-back distances sufficient to resist the larger bombs subsequently used against the federal building in Oklahoma City and the U.S. Marine barracks in Saudi Arabia.

Also, the NRC is now in the process of acquiescing in nuclear industry demands to shift responsibility for supervising the mock-terrorist attack exercises from the NRC to the plant operators in response to industry complaints that the exercises are too severe and the costs of upgrading security are not justified by the supposed low probability of an attack. Indeed, we were dismayed to learn recently that budget planning is now underway to zero out funding for the NRC-supervised exercises to make way for what amounts to an industry self-assessment program.

Since, as you know, a nuclear power reactor contains an enormous inventory of highly radioactive materials, a successful attack against a nuclear plant could produce tens of thousands of latent cancers among the downwind population over a distance of hundreds of miles from the plant and severely contaminate the area. In other words, the consequences of a successful attack on a nuclear power plant near a major metropolitan area would dwarf the human and economic toll of the recent attacks in New York and Washington. It should be clear that in the present situation, in which significant numbers of highly sophisticated terrorists may still be at large in the United States, prudent measures must be taken to avoid such a catastrophe without delay.

The current situation is made all the more perilous by the unprecedented attacks from the air by suicidal teams. There have been assertions that the containment dome of a nuclear power plant could withstand a direct hit by a large commercial aircraft. This is simply not so, and recent statements to the press by industry and NRC spokesmen appear to confirm this. Our calculations indicate that the engines of a Boeing 767, for example, could penetrate at least three feet of reinforced concrete at full cruising speed of 530 MPH---more than enough to crash through the containment domes of many nuclear reactors. Furthermore, a plane need not hit the containment to precipitate a core meltdown or comparable catastrophic radioactive releases; a direct hit on secondary systems or the spent fuel pool could produce such severe effects.

A spokesman for the Nuclear Energy Institute, the nuclear power industrys interlocutor with the NRC on security issues, has been quoted as describing the recent terrorist assault with commercial aircraft as a military-type attack which nuclear reactors are not designed to withstand. Further, as you know, Mr. Chairman, NRC regulations, specifically 10 C.F.R. 50.13, specifically provide that licensed power plant operators are "not required to provide for design features or other measures for the specific purpose of protection against the effects of (a) attacks and destructive acts, including sabotage, directed against the facility by an enemy of the United States, whether a foreign government or other person . . . . It is noteworthy that this provision covers any "person" who is an enemy of the United States, not just governments. 

It should be straightforward, therefore, that with regard to plant-design and guard-force defenses against attack by air, land or water, the present arrangements are dangerously inadequate against the extraordinary and unprecedented adversary the nation faces today. A number of European nations have deployed military forces to protect their plants in response to the recent attacks in the United States. We think the U.S. Government should do the same by means of the National Guard.

The danger here could escalate rapidly and be directed against nuclear plants, especially if U.S. military strikes against terrorist targets abroad invite retaliation inside the United States. There is a recent, unconfirmed Russian news report that Russian intelligence has warned U.S. intelligence that more terrorist attacks in the United States are expected and that the next target will be an American nuclear facility.

Even the present heightened state of alert that has been put in place at nuclear power plants at the recommendation of the NRC is a weak defense that could entice attack against what a large, sophisticated terrorist force would regard as a soft target. According to statements by plant operators appearing in the press, the security upgrade includes canceling visitor tours, positioning guards at all gates, increasing patrols inside and around the plants and ordering manual inspection of staff IDs. We suggest that in the wake of the attacks on the World Trade Center and the Pentagon, these measures are not to be taken seriously by the kind of adversary that may be at large in America today.

In view of the gravity of the current emergency and the need for a prompt response, we urge you to take the following actions:

1. Recommend to the President and to the governors of states with nuclear power plants that National Guard forces be deployed promptly to provide additional protection for these plants for the duration of the current emergency. We believe that deployment of 30 or more troops around and inside the plant at all times is necessary as both a visible show of force and as an effective deterrent.

2. Recommend that radar-directed, anti-aircraft weaponry be deployed by these forces.

3. Commence a new vetting by nuclear power plant operators and law-enforcement officials of all plant employees to determine whether known or suspected terrorists have succeeded in penetrating the work force as insiders.

4. The Commission take the additional steps itemized in the annex to this letter to upgrade protection against radiological sabotage to a level sufficient to deal with the vastly greater terrorist threat now evident.

We would appreciate receiving your response to these recommendations by Wednesday, September 19. Thank you for your prompt attention to this urgent matter.


Paul Leventhal          Daniel Hirsch
President          President

Nuclear Control Institute         Committee to Bridge the Gap



Recommendations for Upgrading Design Basis Threat Regulations

We urge the Commission, on an immediately effective basis, to 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 evident. That security upgrade should include:

(a) increasing the design basis threat to a significantly larger number of attackers than the current very small group;

(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 big as a large truck can carry;

(f) requiring protections against boat and airplane attacks; and

(g) requiring full security protection of spent fuel storage pools and dry cask storage, including after reactor closure.


Condoleezza Rice, National Security Advisor to the President

Colin Powell, Secretary of State

Donald Rumsfeld, Secretary of Defense

Robert S. Mueller, III, Director, Federal Bureau of Investigation

Joe M. Allbaugh, Director, Federal Emergency Management Agency

Senator Joseph Biden, Chair, Senate Foreign Relations Committee

Senator Jesse Helms, Ranking Minority Member, Senate Foreign Relations Committee

Representative Henry Hyde, Chair, House International Relations Committee

Representative Benjamin Gilman, Ranking Minority Member, House International Relations Committee

Senator Carl Levin, Chair, Senate Armed Services Committee

Senator John Warner, Ranking Member, Senate Armed Services Committee

Representative Bob Stump, Chair, House Armed Services Committee

Representative Ike Skelton, Ranking Member, House Armed Services Committee

Senator Jeff Bingaman, Chair, Senate Energy and Natural Resources Committee

Senator Frank Murkowski, Ranking Member, Senate Energy and Natural Resources Committee

Representative W.J. Billy Tauzin, Chair, House Energy and Commerce Committee

Representative John Dingell, Ranking Minority Member, House Energy and Commerce Committee

Senator James Jeffords, Chair, Senate Environment and Public Works Committee

Senator Bob Smith, Ranking Minority Member, Senate Environment and Public Works Committee

Senator Harry Reid, Chair, Subcommittee on Transportation, Infrastructure, and Nuclear Safety, Senate Committee on Environment and Public Works

Senator James Inhofe, Ranking Minority Member, Subcommittee on Transportation, Infrastructure, and Nuclear Safety, Senate Committee on Environment and Public Works

Senator Bob Graham, Chair, Senate Select Committee on Intelligence

Senator Richard Shelby, Vice Chair, Senate Select Committee on Intelligence

Senator Barbara Boxer, Chair, International Terrorism Subcommittee, Senate Foreign Relations Committee

Senator Mike Enzi, Ranking Member, International Terrorism Subcommittee, Senate Foreign Relations Committee

Representative Edward J. Markey


Alabama Governor Don Siegelman
Arizona Governor Jane Hull
Arkansas Governor Mike Huckabee
California Governor Gray Davis
Connecticut Governor John Rowland
Delaware Governor Ruth Ann Minner
Florida Governor Jeb Bush
Georgia Governor Roy Barnes
Illinois Governor George Ryan
Iowa Governor Thomas Vilsack
Kansas Governor Bill Graves
Louisiana Governor Mike Foster Jr.
Maryland Governor Parris Glendening
Massachusetts Governor Jane Swift
Michigan Governor John Engler
Minnesota Governor Jesse Ventura
Mississippi Governor Ronnie Musgrove
Missouri Governor Bob Holden
Nebraska Governor Mike Johanns
New Hampshire Governor Jeanne Shaheen
New Jersey Governor Donald DiFrancesco
New York Governor George Pataki
North Carolina Governor Michael Easley
Ohio Governor Bob Taft
Pennsylvania Governor Tom Ridge
South Carolina Governor Jim Hodges
Tennessee Governor Don Sundquist
Texas Governor Rick Perry
Vermont Governor Howard Dean, M.D.
Virginia Governor James Gilmore III
Washington Governor Gary Locke

Wisconsin Governor Scott McCallum