NUCLEAR
CONTROL INSTITUTE
COMMITTEE TO BRIDGE THE GAP
1000
Connecticut Avenue N.W.
1637
Butler Avenue
Washington,
D.C. 20036
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Angeles CA 90025
Inadequate Protection of Nuclear Power Reactors Against Millennial
Terrorist Attack
December 23, 1999
The Honorable Richard Meserve
Chairman
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Dear Mr. Chairman:
We are writing to protest in the strongest terms an unannounced NRC "advisory"
issued two days ago to operators of nuclear power reactors that there is no
need for them to take heightened security measures to protect their plants against
terrorist attack during the immediate millennial period.
We ask for your personal intervention to countermand this NRC staff advisory,
given the elaborate security precautions now being taken by other Federal, state
and municipal authorities, and also given the generally lackluster performance
of nuclear power plant security forces against mock terrorist attacks organized
by the NRC. We further ask that
you order enhanced security during the Y2K period, as specified below.
This is not the first time NRC staff has taken highly questionable and
imprudent action on physical protection of nuclear power plants; nor would it
be the first time that such action was countermanded by the Chairman.
Just a little more than one year ago, NRC staff cancelled the Operational
Safeguards Response Evaluation (OSRE) program (the mock attack program noted
above) without informing the Commission of its action, and then-Chairman Shirley
Jackson ordered the program reinstated within two days after the cancellation
became publicly known. We ask you
to take similar, decisive action in response to the current staff advisory
because in this case the issue is not the results of mock attacks but
the risk of real attacks that potentially put millions of American lives at
risk if terrorists gained access to and caused radiological sabotage at a plant
near a major metropolitan area like New York City, Chicago or Los Angeles.
NRC staff responsible for the advisory have told us the advisory states
that in the absence of any intelligence information of a specific threat against
nuclear plants or materials, there is no need for licensees to escalate security
precautions at nuclear power plants. We
also were told the advisory states the NRC will remain in contact with intelligence
authorities and will pass on any new information to licensees.
The logic behind this advisory defies both common sense and the Commission's
own "Operating Assumption Covering the Use of and Reliability Placed in
Information from the Intelligence Community" (SECY-78-158), quoted below.
To our knowledge, there is now no known specific threat against any
domestic target in the United States, yet officials at all governmental levels
(with the apparent exception of the NRC) are acting prudently to beef up security
at critical infrastructure facilities against what they fear is a greater likelihood
of terrorist attack associated with Y2K.
The two recent arrests of suspected terrorists at U.S.-Canada border
crossings, one of them transporting high explosives, indicates that such prudence
is clearly warranted. The recent
arrest in Florida of the regional commander and "brigadier general"
of the Southeastern States Alliance, a militia group allegedly planning to destroy
the Crystal River-3 nuclear power plant with stolen explosives, also suggests
there is a basis for heightened concern by the NRC.
Given the unique devastation that would result from the release of the
intensely radioactive contents of the core of a one-billion-watt nuclear power
plant in the event of a meltdown caused by sabotage, it is inexplicable that
the only major Federal agency not increasing security against terrorists during
the millennial period is the NRC.
Beyond common sense, SECY-78-158 provides guidance the Commission and
NRC staff are supposed to follow in avoiding over-reliance on intelligence information.
It states in part:
Given the dire consequences which could arise from the theft of SNM or sabotage
of a licensed facility, it will be necessary for NRC staff to operate on the
basis of a conservative assumption to preclude over-reliance upon information
from the U.S. intelligence community....
A prudent, viable safeguards system should not rely for its effectiveness on
the accuracy and timely availability of intelligence information concerning
the plans, characteristics and intentions of a hostile adversary....Therefore,
safeguards for licensed material and facilities should be structured to prevent
theft and sabotage regardless of whether or not such information is known in
advance....
This operating assumption accommodates the conservative perception that, given
the manifestation of a significant threat to the nuclear industry, there is
a possibility that the U.S. Intelligence Community would not be able to collect
and report to the NRC in a sufficiently accurate and timely manner so that appropriate
safeguards actions might be taken to thwart the threat.
Given this official guidance, and the highly problematical state of physical
protection at nuclear power plants, the NRC should be ordering heightened
security at these reactors---and in particular, at the 99 of 103 plants that
will be on line in the United States during the Y2K period.
Our two organizations successfully petitioned the Commission to promulgate
a truck-bomb rule in 1994 [10 CFR 73.1(a)(1) and 10 CFR 73.55(c)(7-9)], following
the attack on the World Trade Center and the intrusion at the Three Mile Island-1
plant, but we have been unsuccessful in persuading the Commission to upgrade
the rule to protect against the larger-sized bombs subsequently used against
the federal building in Oklahoma City and the U.S. Air Force barracks in Saudi
Arabia. All of these attacks occurred
without prior warning. We also
were successful in helping to bring to public attention the cancellation of
the OSRE program and in winning the reinstatement of that program.
But now NRC staff is engaged with industry in a highly questionable process
to replace the NRC-run OSRE program with an industry-run "Self-Assessment
Program" (SAP) for testing defenses at nuclear power plants.
Absent strong regulatory oversight and enforcement of physical-protection
requirements, site security at these plants will only become weaker and nuclear
power plants will be perceived as "soft targets."
At present, these plants are potentially vulnerable to large-scale truck-bomb
attacks, and nearly half of these plants have failed to repel mock terrorist
attacks run by the OSRE program. Under
these circumstances, we do not believe existing physical protection is sufficient
to warrant the NRC staff's advisory to nuclear power plant operators to simply
maintain security measures at current levels during the millennial period.
We ask that you direct NRC staff to issue a new advisory, directing nuclear
power plant licensees during this period to take extra measures to ensure denial
of access to terrorists. Licensees
should be directed to activate their contingency plans for the next several
weeks, and upgraded security measures should include, at a minimum, increasing
the size of the guard force and frequency of armed patrols, upgrading vehicle
barrier systems, and suspending non-essential visits and deliveries.
We urge your immediate attention to this urgent matter.
Sincerely,
Paul
Leventhal
Daniel Hirsch
President
President
Nuclear
Control Institute
Committee
to Bridge the Gap
cc: President
William Jefferson Clinton
Members, Nuclear Regulatory Commission
Dale L. Watson, Director, FBI Counterterrorism Division
Richard A. Clarke, National Coordinator for Critical Infrastructure and Counterterrorism,
National Security Council
Chairman and Ranking Minority Member, Senate Subcommittee on Nuclear Safety
Chairman and Ranking Minority Member, House Subcommittee on Energy and Power
Representative Edward Markey
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