Nuclear Power Plants: Efforts Made to Upgrade Security, but the  
Nuclear Regulatory Commission's Design Basis Threat Process	 
Should Be Improved (14-MAR-06, GAO-06-388).			 
                                                                 
The nation's commercial nuclear power plants are potential	 
targets for terrorists seeking to cause the release of		 
radioactive material. The Nuclear Regulatory Commission (NRC), an
independent agency headed by five commissioners, is responsible  
for regulating and overseeing security at the plants. In April	 
2003, in response to the terrorist attacks of September 11, 2001,
NRC revised the design basis threat (DBT), which describes the	 
threat that plants must be prepared to defend against in terms of
the number of attackers and their training, weapons, and tactics.
NRC has also restructured its program for testing security at the
plants through force-on-force inspections, which consist of mock 
terrorist attacks. GAO was asked to review (1) the process NRC	 
used to revise the DBT for nuclear power plants, (2) the actions 
nuclear power plants have taken to enhance security in response  
to the revised DBT, and (3) NRC's progress in strengthening the  
conduct of force-on-force inspections at the plants.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-388 					        
    ACCNO:   A48937						        
  TITLE:     Nuclear Power Plants: Efforts Made to Upgrade Security,  
but the Nuclear Regulatory Commission's Design Basis Threat	 
Process Should Be Improved					 
     DATE:   03/14/2006 
  SUBJECT:   Emergency preparedness				 
	     Homeland security					 
	     Independent regulatory commissions 		 
	     Inspection 					 
	     Nuclear facility security				 
	     Nuclear powerplant safety				 
	     Nuclear powerplants				 
	     Security threats					 
	     Strategic planning 				 
	     Counterterrorism					 

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GAO-06-388

     

     * Report to the Chairman, Subcommittee on National Security, Emerging
       Threats, and International Relations, Committee on Government Reform,
       House of Representatives
          * March 2006
     * NUCLEAR POWER PLANTS
          * Efforts Made to Upgrade Security, but the Nuclear Regulatory
            Commission's Design Basis Threat Process Should Be Improved
     * Contents
          * Results in Brief
          * Background
          * NRC's Process for Revising Its DBT for Nuclear Power Plants Was
            Generally Logical and Well Defined, but Some Changes Were Not
            Clearly Linked to an Analysis of the Terrorist Threat
               * NRC Has Been Assessing Threats to Nuclear Power Plants for
                 Many Years
               * NRC Threat Assessment Staff Had to Decide on the
                 Applicability of Intelligence Information to Nuclear Power
                 Plants
               * NRC Generally Established Requirements Less Rigorous Than
                 DOE's DBT for Radiological Sabotage
               * NRC's Process for Obtaining Feedback on the Draft DBT
                 Created the Appearance of Industry Influence on the Threat
                 Assessment Staff's Analysis of Intelligence Information
               * The NRC Commission Made Key Policy Judgments about Changes
                 to the DBT without Criteria on Threats That a Private
                 Security Force Could Reasonably Defend Against
          * Nuclear Power Plants Made Substantial Changes to Their Security
            to Address the Revised DBT, but NRC Inspections Have Uncovered
            Problems
               * Sites Addressed the Increase in the Number of Attackers by
                 Implementing Security Enhancements Designed to Detect,
                 Delay, and Respond to an Attack
               * Sites Addressed the Increase in the Size of a Vehicle Bomb
                 by Designing Comprehensive Systems of Sturdy Barriers
               * Sites Have Generally Complied with NRC Security Requirements
                 and Performed Well in Force-on- Force Inspections, but
                 Problems Remain
          * NRC Has Significantly Improved the Force- on-Force Inspection
            Program, but Challenges Remain
          * Conclusions
          * Recommendations for Executive Action
          * Agency Comments and Our Evaluation
     * Scope and Methodology
     * Details of Findings from NRC Reports on Baseline and Force-on-Force
       Inspections
     * Comments from the Nuclear Regulatory Commission
     * GAO Contact and Staff Acknowledgments
     * PDF6-Ordering Information.pdf
          * Order by Mail or Phone

Report to the Chairman, Subcommittee on National Security, Emerging
Threats, and International Relations, Committee on Government Reform,
House of Representatives

March 2006

NUCLEAR POWER PLANTS

Efforts Made to Upgrade Security, but the Nuclear Regulatory Commission's
Design Basis Threat Process Should Be Improved

Contents

Table

Figures

March 14, 2006Letter

The Honorable Christopher Shays Chairman, Subcommittee on National
Security,   Emerging Threats, and International Relations Committee on
Government Reform House of Representatives

Dear Mr. Chairman:

The nation's 103 operating commercial nuclear power plants, located at 65
sites in 31 states,1 are potential targets for terrorists seeking to cause
the release of radioactive material. Such a release, which may result from
a meltdown of a plant's nuclear reactor core or damage to the spent
nuclear fuel located at the site, could endanger public health and safety
through exposure to radiation. The Nuclear Regulatory Commission (NRC), an
independent agency headed by five commissioners, licenses commercial
nuclear power plants and is responsible for regulating and overseeing
their safe operation and security. According to NRC, there is a general
credible threat of a terrorist attack to the nation's commercial nuclear
power plants, in particular by al Qaeda and like-minded Islamic terrorist
groups. For example, as discussed in The 9/11 Commission Report, nuclear
power plants were among the targets considered in the original plan for
the September 11, 2001, attacks.2 However, NRC and intelligence agency
officials we spoke with said they are not aware of current intelligence
information indicating specific plans for an attack on a nuclear power
plant.

NRC issues and enforces security-related regulations and orders, and
nuclear power plant licensees implement security measures to meet NRC
requirements. In particular, to ensure that nuclear power plants are
secure against a terrorist attack, NRC formulates a design basis threat
(DBT)-the threat that plants must defend against-and tests plants' ability
to defend

against the DBT.3 The DBT characterizes the elements of a potential
attack, including the number of attackers, their training, and the weapons
and tactics they are capable of employing. NRC established the first DBT
for nuclear power plants in the late 1970s. NRC conducts semiannual
reviews of the potential terrorist threat to determine whether to make
changes to the DBT and has revised it twice in response to changes in the
threat. First, NRC expanded the DBT to include a vehicle laden with
explosives after two incidents in 1993-the vehicle bombing of the World
Trade Center and a vehicle intrusion incident at one of the nuclear power
plant sites. NRC revised the DBT again in April 2003 in response to the
terrorist attacks of September 11, 2001. Among other changes, this most
recent DBT increased the number of attackers, refined and expanded the
list of weapons and equipment that might be used in an attack, and
increased the maximum size of a vehicle bomb that plants must defend
against.

The DBT does not represent the maximum size and capability of a terrorist
attack that is possible, but rather NRC's assessment of the threat that
the nuclear power plants must be prepared to defend against "to ensure
adequate protection of public health and safety." Furthermore, NRC
regulations do not require nuclear power plants to protect against attacks
directed against the sites by an "enemy of the United States," whether a
foreign government or other person.4 NRC originally included this
provision in its regulations in 1967 (prior to issuing the first DBT for
nuclear power plants). According to NRC officials, the provision was
intended to address the possibility that Cuba might launch an attack on a
nuclear power plant in Florida. In revising the DBT in April 2003, NRC did
not use this provision to exempt plants from defending against terrorist
groups such as al Qaeda but rather stated that a private security force
(such as at a nuclear power plant) cannot reasonably be expected to defend
against all threats-for example, airborne attacks.

Importantly, NRC also works with the Department of Homeland Security
(DHS), the Federal Aviation Administration, the Federal Bureau of
Investigation (FBI), and other federal, state, and local authorities to
coordinate an integrated response to a terrorist threat or attack on a
nuclear power plant.5 Furthermore, NRC does not directly gather
intelligence information but rather receives intelligence from other
agencies that it uses to formulate the DBT for nuclear power plants. NRC
has access to intelligence information on terrorist activities and the
domestic terrorist threat, including information from secure databases and
intelligence reports from intelligence and other agencies.

Before receiving a license to operate a nuclear power plant, owners must
develop and implement an NRC-approved security plan describing how they
will defend the site against the threat presented in the DBT. As set forth
in the security plan, the licensees employ private security forces (either
hired directly or through a contractor) and provide them with the weapons,
training, and equipment to defend the site. When NRC revised the DBT in
2003, it required licensees to develop new security plans describing their
strategy for defending the sites against the revised DBT and to implement
any security enhancements outlined in the plans by October 29, 2004. These
security enhancements were in addition to other measures licensees
implemented-such as stricter requirements for obtaining physical access to
nuclear power plants, minimum training requirements for security officers,
and limits on the work hours of the security force to address the
potential for fatigue-in response to a series of security orders NRC
issued after September 11, 2001. According to the Nuclear Energy Institute
(NEI), which represents the nuclear power industry, the cost of security
enhancements made since September 11, 2001, for all sites amounts to over
$1.2 billion.6

NRC reviews and approves the security plans, conducts regular "baseline"
inspections to verify compliance with the plans and other security
requirements, and conducts force-on-force inspections involving multiple
mock terrorist attacks to ensure sites are capable of defending against an

attack.7 NRC considers the DBT, the security plans, and the results of its
inspections and force-on-force exercises to contain "safeguards
information" and other sensitive information, including details about
security that could potentially aid terrorists plotting to attack a
nuclear power plant.8 Consequently, NRC does not make this information
available to the general public, which has made it difficult for the
agency to alleviate concerns about the level of security at nuclear power
plants. The concerns center on whether the revised DBT adequately reflects
the post-September 11 threat to nuclear power plants, and whether sites
have done enough to respond to the threat.

You asked us to (1) examine the process NRC used to develop the April 2003
DBT for nuclear power plants, and (2) determine what actions nuclear power
plants have taken to enhance security in response to the revised DBT. In
addition, you asked us to review NRC's progress in strengthening the
conduct of force-on-force inspections. In response, we have prepared this
unclassified public report, which does not include certain details about
the DBT and security at nuclear power plants that NRC considers to be
safeguards information. We have prepared a classified version of this
report in which we include such details.

To address the first objective, we reviewed the process NRC uses to
analyze terrorist and criminal activities to assess the threat to nuclear
power plants. We interviewed NRC officials responsible for analyzing
information received from the intelligence and law enforcement communities
and three of the four NRC commissioners serving at the time the DBT was
revised to determine what factors they took into account in deciding on
changes to the DBT. We compared the April 2003 DBT with NRC documents
summarizing the threat to nuclear power plants and with the Department of
Energy (DOE) DBT for its nuclear weapons facilities. We also interviewed
officials from other federal agencies, including DHS and FBI, to obtain
their assessments of the terrorist threat to nuclear power plants, and we
interviewed DOE officials regarding the DOE DBT. To address the second
objective, we visited four nuclear power plant sites (one in each of the
four NRC regions) to observe the security enhancements that sites made to
address the revised DBT. We selected the four sites using a number of
criteria, including size and type of reactor. GAO staff with a
professional background in security accompanied us on our visits in order
to provide the expertise needed to fully comprehend the sites' security
strategies. At each site, we interviewed senior plant management, security
managers, and security officers. Before visiting the four sites, we
visited two other nuclear power plants to familiarize ourselves with NRC
security requirements and the sites' security equipment and strategies; at
one site, we observed an NRC baseline security inspection, and at the
other, we observed a force-on-force inspection. We did not test the
effectiveness of the security strategies at the four sites, and we cannot
project the results of our work to all nuclear power plants. In addition
to visiting four sites, we reviewed a sample of NRC's baseline and
force-on-force inspection reports. To review NRC's progress in improving
the force-on-force inspection program, we observed a total of three
force-on-force inspections at two sites, reviewed NRC reports on
force-on-force inspections, and interviewed NRC officials responsible for
implementing the program. For other views on security at nuclear power
plants, we interviewed officials from the nuclear industry group NEI and
from the Project on Government Oversight, an independent nonprofit
organization. (App. I presents a detailed discussion of our scope and
methodology.) We conducted our work from November 2004 through January
2006 in accordance with generally accepted government auditing standards.

Results in Brief

The process NRC used to revise the DBT for nuclear power plants in April
2003 was generally logical and well defined. NRC made the revisions as
part of a process that it had been using since formulating the first DBT
in the late 1970s. NRC staff trained in threat assessment used reports and
secure databases provided by intelligence agencies to monitor information
on terrorist activities worldwide. To enhance the predictability and
consistency of its assessments of this information and its recommendations
to the NRC commissioners for changes to the DBT, the NRC threat assessment
staff developed and used a comprehensive screening tool to analyze
intelligence information and evaluate particular terrorist capabilities,
or "adversary characteristics," for inclusion in the DBT. NRC's process
also included consultation with DOE, which has a DBT for its facilities
that process or store radiological materials and therefore are also
potential targets for radiological sabotage, and with stakeholders such as
the nuclear power industry and state governments.

Using this process, NRC produced a revised DBT that generally, but not
always, corresponded to the original recommendations of the threat
assessment staff. For example, the maximum number of attackers in the
revised DBT is based in part on the staff's analysis of the size of
terrorist cells worldwide, as well as NRC's interpretation that multiple
cells along the lines of the September 11, 2001, attacks would not
necessarily target a single nuclear power plant. However, for other
important elements of the DBT, such as the weapons that attackers could
use against a plant, the final version of the revised DBT does not
correspond to the staff's original recommendations. We identified two
principal reasons for these differences:

o First, the threat assessment staff made changes to its initial
recommendations after obtaining feedback from stakeholders, including the
nuclear industry, on a draft of the DBT. A number of the changes reflected
industry objections to the draft. For example, following meetings with
industry, the staff decided not to recommend including certain weapons in
the list of adversary characteristics that nuclear power plants should be
prepared to defend against. In its comments, the industry had pressed for
NRC to remove such adversary characteristics from the draft DBT. The
industry considered these adversary characteristics prohibitively
expensive to defend against or to be representative of an enemy of the
United States, which is the responsibility of the government, rather than
the industry, to defend against. When we asked about the changes to the
staff's original recommendations, NRC officials told us the changes
resulted from further analysis of the intelligence data and the
reasonableness of required defensive measures rather than the industry
objections. Nevertheless, in our view, the process by which NRC used the
threat assessment staff to obtain stakeholder feedback created the
appearance that changes were made based on what industry considered
reasonable and feasible to defend against rather than an assessment of the
terrorist threat, especially given the high degree of judgment involved in
assessing threat information. NRC officials said they have altered their
process in order to better separate the analysis of threat information
from interaction with stakeholders.

o Second, in deciding on the revised DBT, the NRC commissioners largely
supported the staff's recommendations but also made some significant
changes to those recommendations. These changes reflected the
commissioners' policy judgments on what is reasonable for a private
security force to defend against. For example, the commissioners decided
against including two weapons that the threat assessment staff had
concluded could plausibly be used against a U.S. nuclear power plant.
Consideration of issues such as what is reasonable for a private security
force to defend against can certainly be considered by the commissioners
in approving changes to the DBT. However, the commissioners did not
identify explicit criteria for what is and is not reasonable for a private
security force to defend against, such as the cost of defending against
particular adversary characteristics. NRC officials said detailed criteria
on what is reasonable for a private security force would reduce the
commissioners' discretion in approving changes to the DBT. Nevertheless,
we believe the absence of reviewable criteria reduced the transparency of
the commissioners' decisions to make changes to the threat assessment
staff's recommendations. The absence of criteria also potentially reduced
the rigor of the decision-making process.

Licensees of nuclear power plants have made substantial changes to their
security in response to the September 11, 2001, attacks and the 2003
revisions to the DBT. At the sites we visited, these actions included, for
example, adding security barriers and detection equipment, implementing
new protective strategies, enhancing access control, and hiring additional
security officers. According to NRC, other sites implemented similar
security enhancements to defend against the 2003 DBT. The sites' efforts
have been substantial and, in some cases, have gone beyond what was
required. For example, one site added electronic intrusion detection
equipment to its outer perimeter, which was not required. Despite these
considerable efforts, it is too early to conclude that all sites are
capable of defending against the DBT because, as of November 1, 2005, NRC
had conducted force-on-force inspections at 20 of the 65 sites. According
to NRC, sites have generally performed well during force-on-force
inspections, and the results of baseline inspections show that sites have
generally complied with their security plans. However, a number of sites
have experienced problems and have not always met security requirements.
For example, a baseline inspection at one site found that detection
equipment malfunctioned and had to be fixed. Similarly, we observed a
force-on-force inspection at another site in which the licensee's
performance at the time was at best questionable in its ability to defend
the site against the DBT. According to NRC, it will complete the first
cycle of triennial force-on-force inspections at all nuclear power plant
sites on schedule, by 2007.

NRC has made a number of improvements to its force-on-force inspection
program, several of which address recommendations we made in our September
2003 report on the agency's oversight of security at commercial nuclear
power plants. For example, NRC is implementing a schedule to conduct the
inspections more frequently at each site-every 3 years rather than every 8
years-and has instituted measures to make the inspections more realistic,
such as using laser equipment to better simulate the weapons that
attackers and security officers would likely employ during an actual
attack on a nuclear power plant. These improvements are important because,
as we noted from our observation of three force-on-force inspections and
our review of NRC reports on others, the inspections have the ability to
detect weaknesses in sites' protective strategies, which can then be
corrected. Nevertheless, in observing three inspections and discussing the
program with NRC officials, we noted issues in the force-on-force program
that warrant continued NRC attention. For example, a lapse in protection
of information about the planned scenario for a mock attack that we
observed may have given the plant's security officers knowledge that
allowed them to perform better than they otherwise would have. According
to NRC officials, NRC inspectors have been instructed to be vigilant
regarding any indications that a site's security force may have received
advance knowledge of an attack scenario.

We are recommending that NRC improve its DBT development process in two
ways. First, we recommend that NRC assign responsibility for obtaining
feedback from the nuclear industry and other stakeholders on proposed
changes to the DBT to an office within NRC other than the Threat
Assessment Section, thereby insulating the staff and mitigating the
appearance of industry influence on the threat assessment itself. Second,
we recommend that NRC develop explicit criteria to guide the commissioners
in their deliberations to approve changes to the DBT. These criteria
should include setting out the specific factors and how they will be
weighed in deciding what is unreasonable for a private security force to
defend against. In addition, we are recommending that NRC continue to
evaluate and implement measures to further strengthen its force-on-force
inspection program. In commenting on a draft of this report, NRC provided
additional clarifying comments pertaining to the process NRC used to
revise the DBT for nuclear power plants, and we revised the report
accordingly. NRC's written comments are included in appendix III.

Background

NRC is an independent agency established by the Energy Reorganization Act
of 1974 to regulate the civilian use of nuclear materials. NRC is headed
by a five-member commission, with one commission member designated by the
President to serve as chairman and official spokesperson. The commission
as a whole formulates policies and regulations governing nuclear reactor
and materials safety and security, issues orders to licensees, and
adjudicates legal matters brought before it. Security for commercial
nuclear power plants is addressed by NRC's Office of Nuclear Security and
Incident Response. This office develops policy on security at nuclear
facilities and is the agency's security interface with DHS, the
intelligence and law enforcement communities, DOE, and other agencies.
Within this office, the Threat Assessment Section assesses security
threats involving NRC-licensed activities and develops recommendations
regarding the DBT for the commission's consideration.

The DBT for radiological sabotage applied to nuclear power plants
identifies the terrorist capabilities (or "adversary characteristics")
that sites are required to defend against. The adversary characteristics
generally describe the components of a ground assault and include the
number of attackers; the size of a vehicle bomb; and the weapons,
equipment, and tactics that could be used in an attack. Other threats in
the DBT include a waterborne assault and the threat of an insider. The DBT
does not include the threat of an airborne attack. However, according to
NRC officials, NRC regulations do require nuclear power plants to
implement readily available measures to mitigate against the potential
consequences of such an attack. In its publicly available regulations
governing the licensing of nuclear power plants, NRC has issued a general
description of the DBT-for example, requiring sites to defend against an
attack by several well-trained and dedicated individuals armed with
hand-carried weapons and equipment and assisted by a knowledgeable insider
who participates in a passive or active role.9 In April 2003, NRC issued
orders to nuclear power plant licensees containing a more detailed
description of the revised DBT, which NRC considers safeguards
information.

NRC requires nuclear power plants to have and implement a security plan
that describes their strategy for defending against an attack having the
characteristics of the DBT. Nuclear power plant sites are responsible for
installing barriers and intrusion detection equipment, hiring security
officers, and implementing other measures in accordance with their
security plans. NRC then inspects the sites' compliance with the plans and
ability to defend against the DBT. After revising the DBT, NRC required
sites to submit new plans by April 29, 2004, for NRC's review and approval
and to implement the security described in their new plans by October 29,
2004. The plans contain information about the sites, including

o a description of sites' physical layout, such as barriers and buildings,
and a description of any environmental features important to the effective
coordination of response operations;

o the minimum number of security officers defending the vital areas (the
areas containing equipment needed to ensure the safe shutdown of the
reactor and protection of spent fuel pools); and

o a description of the protective strategy that sites will enact in
response to an attack or threat defined in the DBT, such as an external
land-based assault, a vehicle bomb, a waterborne assault, or an insider
threat.

NRC's performance-based means for testing the effectiveness of nuclear
power plant security programs is through force-on-force inspections. These
inspections, which consist of 350 hours of on-site inspection activity,
are intended to demonstrate how well a nuclear power plant might defend
against a real-life threat. In a force-on-force inspection, a professional
team of adversaries attempts to reach specific "target sets" within a
nuclear power plant that would allow them to commit radiological sabotage.
These target sets represent the minimum pieces of equipment or
infrastructure an attacker would need to destroy or disable to commit
radiological sabotage resulting in an elevated release of radioactive
material to the environment. Force-on-force exercises do not directly test
the response of outside agencies, such as local law enforcement. However,
sites simulate actions they would take to notify local law enforcement and
other outside agencies. In addition, according to NRC officials, sites
routinely conduct liaison activity with local law enforcement and
emergency response agencies.

While the adversary characteristics terrorists might use in an actual
attack are uncertain, the DBT provides parameters for the conduct of
force-on-force inspections. For example, the mock adversary force is
constrained to using the specific number of attackers, amount of
explosives, and weapons and tactics included in the DBT. According to NRC
officials, the commission recently approved an option to conduct
force-on-force inspections using adversary characteristics that go beyond
those in the DBT. This option would be available on a voluntary basis to
nuclear power plant licensees that are clearly successful in defending
against the first two mock attacks of the force-on-force inspection, which
typically includes three mock exercises over 3 days.

NRC also conducts baseline inspections at nuclear power plants to
determine that licensees have established measures to deter, detect, and
protect against the DBT for radiological sabotage. Security inspectors in
NRC's four regional offices conduct the inspections. NRC's policy is to
conduct a baseline inspection at each site every year, with the complete
range of baseline inspection activities conducted over a 3-year cycle. One
element of a baseline inspection is evaluating the site's protective
strategy-for example, by conducting tabletop drills (simulated attacks
using a model of the site) to gain a better understanding of the strategy.
Inspectors also examine areas such as officer training, fitness for duty,
positioning and operational readiness of multiple physical and technical
security components, and the controls the licensee has in place to ensure
that unauthorized personnel do not gain access to the protected area.
According to NRC officials, agency inspectors spend a total of 136 hours
annually at a site for a baseline inspection, and the 3-year baseline
inspection cycle involves more than 400 hours of inspection activity.

For both force-on-force and baseline inspections, licensees are
responsible for immediately correcting or compensating for any deficiency
in which NRC concludes that security is not in accordance with the
approved security plans or other security orders. According to its
inspection manual, NRC has 45 days to send a licensee a report on the
results of an inspection, including any findings and the licensee's
corrective actions.

DHS has overall responsibility among federal agencies for assessing the
vulnerability of the nation's critical infrastructure to terrorist attacks
and coordinating efforts to enhance security. Nuclear power plants
represent one sector of the critical infrastructure. Other sectors include
such things as agriculture, chemical facilities, and transportation
systems. In 2005, DHS began a series of visits to nuclear power plant
sites to conduct comprehensive security reviews in order to assess the
risks and consequences of various types of events and to provide better
information on the most effective allocation of federal resources to
improve security at

critical infrastructure sites.10 DHS conducts the comprehensive reviews
with relevant agencies such as the FBI and, in the case of nuclear power
plants, NRC. According to DHS, the comprehensive reviews for nuclear power
plants focus primarily on the security of the sites "outside the
fence"-the aspects of security outside the responsibility and control of
the nuclear power plant licensees. DHS relies on NRC to regulate the
security of nuclear power plants "inside the fence." DHS officials told us
that the nuclear power sector is one of the few critical infrastructure
sectors in which the federal government has the authority to regulate the
security of sites. According to DHS, as of December 2005, the agency had
completed 14 comprehensive reviews at nuclear power plant sites.

NRC's Process for Revising Its DBT for Nuclear Power Plants Was Generally
Logical and Well Defined, but Some Changes Were Not Clearly Linked to an
Analysis of the Terrorist Threat

The process that NRC used to revise its DBT for nuclear power plants was
generally logical and well defined. In particular, the process included an
analysis of intelligence and law enforcement information on terrorist
capabilities and consultation with DOE, which also has a DBT for its
facilities that are potential targets for terrorists seeking to cause
radiological sabotage. Using this process, NRC produced a revised DBT that
usually corresponded to the original recommendations of NRC's threat
assessment staff. However, certain elements of the revised DBT, such as
the weapons that attackers could use against a plant, do not correspond to
the staff's original recommendations for two reasons. First, the NRC
threat assessment staff charged with reviewing intelligence information
made changes to its recommendations after receiving feedback from
stakeholders, including the nuclear industry. Given the high degree of
judgment involved in assessing threat information, the process NRC used to
obtain stakeholder feedback created the appearance that changes were made
based on industry views rather than an assessment of the terrorist threat.
Second, the NRC commissioners made changes to the staff's recommendations
on the basis of what is reasonable for a private security force to defend
against but did not identify explicit criteria for such policy judgments.

NRC Has Been Assessing Threats to Nuclear Power Plants for Many Years

NRC made its 2003 revisions to the DBT for nuclear power plants as part of
a process that the agency has used since first issuing the DBT in the late
1970s. In this process, NRC staff trained in threat assessment use reports
and secure databases provided by the intelligence community to monitor
information on terrorist activities worldwide. The staff analyze this
information both to identify specific references to nuclear power plants
and to determine the capabilities that terrorists have acquired and how
they might use those capabilities to attack nuclear power plants in the
United States. The staff normally summarize applicable intelligence
information and any recommendations for changes to the DBT in semiannual
reports to the NRC commissioners on the threat environment.11 In addition,
the threat assessment staff promptly report changes in the threat to the
commissioners and coordinate with the intelligence agencies to help ensure
that the staff are aware of all pertinent intelligence information.

In 1999, the NRC staff began developing a set of criteria-the adversary
characteristics screening process-to decide whether to recommend
particular adversary characteristics for inclusion in the DBT and to
enhance the predictability and consistency of their recommendations.
According to the NRC staff, the adversary characteristics screening
process, which they used to develop the April 2003 revised DBT, begins
with a thorough review of intelligence reports and application of initial
screening criteria to evaluate adversary characteristics. The staff use
the initial screening criteria to exclude from further consideration
certain adversary characteristics, such as those that are already in the
DBT or those that would more likely be used by a foreign military than by
a terrorist group.

For adversary characteristics that pass the initial round of screening,
the threat assessment staff apply additional screening factors. Examples
of such factors include the following:

o The type of terrorist group that demonstrated the characteristic. For
example, the staff consider whether an adversary characteristic has been
demonstrated by transnational or terrorist groups operating in the United
States, or by terrorist groups that operate only in foreign countries.

o The location and level of social stability where the characteristic was
demonstrated. For example, the staff consider whether the adversary
characteristic has been demonstrated in North America and other countries
with a high level of social stability or in countries with an active
insurgency or civil war. NRC considers that terrorists planning to attack
a nuclear power plant in the United States would face greater operational
security and logistical challenges than terrorists operating in countries
where there is an internal insurgency.

o The frequency with which the characteristic has been demonstrated and
its availability. For example, the staff consider the availability of an
adversary characteristic on the open or the black market.

o The type of target the characteristic has been used against, the
tactical use of the characteristic, and the motive behind its use. For
example, the staff consider whether the adversary characteristic has been
used against a target with a level of security similar to that at nuclear
power plants or against targets with less security, such as the October
2002 attack on a Moscow theater by Chechen rebels.

Depending on the results of this analysis, the threat assessment staff may
interact with intelligence and other agencies to obtain additional
information and insights about the adversary characteristics. Finally, on
the basis of their analysis and interaction with other agencies, the staff
decide whether to recommend that the commission include the adversary
characteristics in the DBT for nuclear power plants. NRC's Office of
Nuclear Security and Incident Response, which includes the Threat
Assessment Section, reviews and endorses the threat assessment staff's
analysis and recommendations.

Since issuing the revised DBT in April 2003, NRC has continued to use the
adversary characteristics screening process to consider additional
changes-for example, to consider new intelligence information on weapons
not included in the revised DBT. In addition, the Energy Policy Act of
2005 directed NRC to undertake a rulemaking to revise the DBT for nuclear
power plants.12 While the detailed description of the April 2003 DBT is
safeguards information and thus has not been made available to the public,
the rulemaking, which is under way, presents the DBT in less detail so
that it can be made available to the public and includes a notice and
opportunity for public comment. The act directed NRC to consider the
events of September 11, 2001; the potential for an attack on facilities by
multiple, coordinated teams of a large number of individuals; the
potential for suicide attacks; and other factors. The April 2003 DBT
already includes some (but not all) of the adversary characteristics
listed in the Energy Policy Act, such as attackers who are willing to
commit suicide, the potential for a waterborne assault, and the use of
explosive devices. NRC officials told us that, as part of the current
rulemaking, they would consider all of the factors listed in the Energy
Policy Act, including those not currently in the DBT.

NRC Threat Assessment Staff Had to Decide on the Applicability of
Intelligence Information to Nuclear Power Plants

Terrorist attacks have generally occurred outside the United States, and
intelligence information specific to nuclear power plants is very limited.
As a result, one of the NRC threat assessment staff's major challenges has
been to decide how to apply this limited information to nuclear power
plants in the United States. For example, one of the key elements in the
revised DBT, the number of attackers, is based on NRC's analysis of the
group size of previous terrorist attacks worldwide. According to NRC
threat assessment staff, the number of attackers in the revised DBT falls
within the range of most known terrorist cells worldwide.13 Furthermore,
the threat assessment staff told us they considered but decided against an
even larger number of attackers in the draft DBT because a larger cell
would face an increased potential of detection before it could
successfully carry out a terrorist attack in the United States. The staff
also concluded that multiple cells along the lines of the September 11,
2001, attacks would not necessarily target a single nuclear power plant.
Intelligence and law enforcement officials we spoke with did not have
information contradicting NRC's interpretation regarding the number of
attackers (or other parts of the NRC DBT) but did point to the uncertainty
regarding the size of potential attacks and the relative lack of
intelligence on the terrorist threat to nuclear power plants.

NRC staff recommendations regarding other adversary characteristics also
reflected the staff's interpretation of intelligence information. For
example, the staff considered increasing the vehicle bomb in the revised
DBT to a range of sizes and ultimately recommended a size that was based
on an analysis of previous terrorist attacks using vehicle bombs.14 One of
the largest vehicle bombs ever detonated was used in the 1996 bombing of
the U.S. military residence in Saudi Arabia, and the maximum size of a
vehicle bomb used in the United States-the 1995 bombing of the federal
building in Oklahoma City-consisted of the equivalent of 4,800 pounds of
TNT. Additional examples of NRC's interpretation of intelligence
information and recommendations for the revised DBT included the
following:

o The threat assessment staff recommended a maximum weight of equipment
and explosives per attacker. The staff based this weight on the experience
and professional knowledge of NRC staff and contractors with security
backgrounds. In developing these limits, the staff evaluated the degree to
which attackers would rely on speed of movement rather than be encumbered
by large amounts of equipment. They also considered that a relatively
small amount of explosives could cause a large amount of damage.

o The NRC staff recommended including a waterborne assault with a bomb
size based on available intelligence on waterborne terrorist bombs. In
addition, according to NRC, watercraft found near nuclear power plants
would generally be constrained in terms of payload. Furthermore, the bomb
size recommended by the staff was considered sufficient to significantly
damage a nuclear power plant's water intake structure. The staff
considered that a larger bomb would add little to the potential damage to
the intake structure.

o The NRC staff supported the inclusion of equipment that is readily
available through commercial sources but recommended against weapons with
limited use by terrorists.

o The staff recommended against including infiltration into a nuclear
power plant by air because their review of terrorist attacks did not
demonstrate significant use of such tactics against a fixed site.

Table 1 summarizes, by adversary characteristic, the key changes to the
DBT recommended by the NRC staff and the final changes approved by the NRC
commissioners.

Table 1: Summary of Key Changes to the NRC DBT for Nuclear Power Plants

                                        

        Adversary      NRC staff's recommended   April 2003 revised DBT, as   
     characteristic              DBT            approved by NRC commissioners 
Number of attackers The staff recommended    The commission supported the  
                       increasing the number    number of attackers           
                       of attackers to fall     recommended by the NRC staff. 
                       within the range of      
                       most known terrorist     
                       cells worldwide.         
Vehicle bomb        The staff recommended    The commission supported the  
                       increasing the maximum   staff recommendation.         
                       size of a vehicle bomb   
                       based on an analysis of  
                       previous attacks using   
                       vehicle bombs.           
                                                
                       The staff considered a   
                       larger vehicle bomb      
                       size but decided         
                       against the larger size  
                       after obtaining          
                       comments from            
                       stakeholders, including  
                       the nuclear industry.    
Weapons             The staff refined and    The commission retained most  
                       expanded the list of     weapons recommended by the    
                       weapons that could be    staff but removed certain     
                       used in an attack.       weapons the staff had         
                                                recommended.                  
                       The staff decided        
                       against recommending     
                       certain weapons after    
                       obtaining comments from  
                       stakeholders, including  
                       the nuclear industry.    
Inside assistance   Active or passive.       Active or passive.            
                                                                              
                                                The commission added a        
                                                provision that the likelihood 
                                                of an active insider can be   
                                                reduced by a human            
                                                reliability program, which    
                                                consists of policies and      
                                                procedures, such as substance 
                                                abuse testing, designed to    
                                                help ensure the reliability   
                                                of personnel.                 
Weight of equipment Based on the degree to   The commission reduced the    
and explosives      which attackers would    weight recommended by the     
                       rely on speed of         staff.                        
                       movement rather than be  
                       encumbered by large      
                       amounts of equipment.    

Source: GAO analysis of NRC information.

NRC Generally Established Requirements Less Rigorous Than DOE's DBT for
Radiological Sabotage

According to the NRC staff's report on recommended changes to the DBT for
nuclear power plants, NRC has a long-standing commitment to work closely
with DOE in an effort to maintain comparable protection for comparable
facilities. Thus, as part of the process for revising the DBT for nuclear
power plants, NRC monitored and exchanged information with DOE, which also
has a DBT for comparable facilities that process or store radiological
materials and are, therefore, potential targets for radiological
sabotage.15 However, while certain aspects of the two agencies' DBTs for
radiological sabotage are similar, NRC generally established less rigorous
requirements than DOE-for example, with regard to the types of equipment
that could be used in an attack. Additional information regarding key
adversary characteristics found in both agencies' DBTs includes the
following:

o Number of attackers. Both DOE and NRC based the number of attackers on
intelligence on the size of terrorist cells. According to DOE officials,
it is challenging to find intelligence on terrorist activities that can be
considered equivalent to a ground assault on a fixed facility such as a
nuclear power plant or DOE site. However, DOE officials said they used
similar intelligence as NRC to derive the number of attackers.

o Vehicle bomb. DOE and NRC officials provided us with similar analyses of
intelligence information on previous terrorist attacks using vehicle
bombs. In particular, DOE and NRC officials told us that most vehicle
bombs used in terrorist attacks are smaller than the size vehicle bomb in
NRC's revised DBT. DOE officials also said that site-specific
characteristics affect the size of vehicle bomb that sites are capable of
defending against.

o Weapons. The DOE DBT includes a number of weapons not included in the
NRC DBT. Inclusion of such weapons in the NRC DBT for nuclear power plants
would have required plants to take substantial additional security
measures. Furthermore, DOE included other capabilities in its DBT that are
not included in the NRC DBT. As discussed below, NRC staff considered some
of the weapons in DOE's DBT for inclusion in the DBT for nuclear power
plants but removed them while drafting the DBT.

DOE established an even more stringent DBT for its sites that store
nuclear weapons (or material that could be used in a nuclear weapon). The
security objective for these sites is to prevent the theft or detonation
of a nuclear weapon. DOE decided on a more stringent DBT to protect
nuclear weapons facilities than sites with the potential for radiological
sabotage in accordance with its graded approach, which provides for a
higher level of protection to sites with greater potential consequences to
public health and safety in the event of a terrorist attack. According to
DOE officials, the consequences of theft or detonation of a nuclear weapon
would be "orders of magnitude" greater than radiological sabotage at a DOE
site or nuclear power plant.

Consistent with DOE's graded approach, NRC officials told us they do not
consider comparisons between the DOE DBT for nuclear weapons facilities
and the NRC DBT for nuclear power plants valid. NRC considers that the
potential consequences of the theft of material that could be used in a
nuclear weapon could be much greater than radiological sabotage at a
nuclear power plant. Furthermore, according to NRC officials, terrorists
seeking to steal or detonate a nuclear weapon would require greater
capabilities to accomplish their objectives than terrorists seeking to
cause radiological sabotage. For example, theft of a nuclear weapon (or
material that could be used in a weapon) would require terrorists to
defeat a site's security systems when entering and leaving a site. In
contrast, attackers willing to commit suicide in the process of causing
the release of radiological material from a nuclear power plant would have
to overcome security to enter a site and reach a target set but would not
have to leave the site. Like DOE, NRC uses a graded approach to security,
and, therefore, the NRC DBT for NRC-licensed facilities that store or
process material that could be used in a nuclear weapon is more stringent
than the NRC DBT for nuclear power plants.

NRC's Process for Obtaining Feedback on the Draft DBT Created the
Appearance of Industry Influence on the Threat Assessment Staff's Analysis
of Intelligence Information

NRC staff sent a draft DBT to stakeholders in January 2003, held a series
of meetings with them to obtain their comments, and received written
comments. In addition to nuclear power plant licensees and NEI, which
represents the nuclear industry, these stakeholders included other federal
agencies and government authorities in affected states. NRC specifically
sought and received feedback from the nuclear industry on what is
reasonable for a private security force to defend against and the cost of
and time frame for implementing security measures to defend against
specific

adversary characteristics.16 During the same period that the threat
assessment staff was receiving industry and other stakeholder feedback,
they continued to analyze intelligence information and modify the draft
DBT. In April 2003, NRC staff submitted their final draft DBT to the
commissioners for their review and approval, together with a summary of
stakeholder comments.

In its written comments on the January 2003 draft DBT, NEI objected to the
size of the vehicle bomb, the inclusion of certain weapons, and the
inclusion of an active violent insider. The NRC staff's draft DBT
submitted to the commissioners reflected some (but not all) of NEI's
objections. The reasons for NEI's objections to key adversary
characteristics and changes to the NRC threat assessment staff's
recommendations included the following:

o Vehicle bomb. NEI objected to the vehicle bomb in the draft DBT because
of its assessment of (1) the low probability of a vehicle bomb of the size
proposed by NRC, (2) the likelihood that federal authorities or local law
enforcement would detect a large vehicle bomb, and (3) the inability of
some sites to protect against the size of the vehicle bomb proposed by NRC
because of insufficient land for installation of vehicle barrier systems
at a necessary distance. Instead, NEI agreed that it would be reasonable
to protect against a smaller vehicle bomb. In its recommendations to the
commissioners, the NRC staff subsequently reduced the size of the vehicle
bomb to the amount proposed by NEI. After review, the staff's reason for
agreement with NEI was that vehicle bombs as large as that included in the
draft provided to stakeholders had rarely been used in previous terrorist
attacks and would not be reasonable or practical to include in the DBT.

o Weapons. NEI argued against the inclusion of a number of weapons. For
example, NEI wrote that (1) one particular weapon recommended by the NRC
staff would render the ballistic shielding used at nuclear power plants
obsolete, and (2) another proposed weapon would initially cost $1 million
to $7 million per site to defend against, with annual recurring costs of
up to $2 million per site. Furthermore, NEI argued that these weapons (as
well as the vehicle bomb size initially proposed by the NRC staff) would
be indicative of an enemy of the United States, which sites are not
required to protect against under NRC regulations. In the final draft
submitted to the NRC commissioners, the NRC staff removed a number of
weapons NEI had objected to. The staff reasoned that the weapons had
rarely been used in armed assaults, or had been used infrequently in
terrorist assaults despite their wide availability and use by violent
criminals in the United States.17 NRC staff did not remove one particular
weapon NEI had objected to, which, according to NRC's analysis, has been a
staple in the terrorist arsenal since the 1970s and has been used
extensively worldwide. (As discussed below, the NRC commissioners later
voted to remove this particular weapon.)

o Inside assistance. NEI wrote that the nuclear power industry had taken a
number of steps to reduce the likelihood of an active violent insider-for
example, it tightened the process for granting employees unescorted access
to nuclear power plants. Furthermore, NEI wrote that the industry had been
unable to identify cost-effective solutions to defend against an active
violent insider, and that costs would range from $2 million to $8 million
per site for equipment and $5 million per site per year for additional
personnel. Despite these objections, the NRC staff recommended the
inclusion of an active violent insider in the final draft of the DBT. (The
NRC commissioners later allowed nuclear power plants to reduce the
likelihood of an active violent insider through a human reliability
program.)

The chief of NRC's threat assessment staff told us that NRC did not make
changes to the draft DBT based solely on industry views. Rather, according
to NRC officials, the changes were made based on multiple internal
analyses and discussions among the threat assessment staff and higher
levels of review within NRC and its Office of Nuclear Security and
Incident Response, which includes the Threat Assessment Section.
Nevertheless, in our view, the process NRC used to obtain feedback from
stakeholders, including the nuclear industry, created the opportunity for,
and appearance of, industry influence on the threat assessment regarding
the characteristics of an attack.

When we raised this issue with NRC officials, they told us that under
normal circumstances the threat assessment process is initially undertaken
utilizing intelligence and law enforcement information, with other
stakeholders subsequently having an opportunity to provide feedback-for
example, regarding the cost of implementing security measures in response
to proposed changes to the DBT. Furthermore, NRC threat assessment staff
and other intelligence agency officials told us they support the
separation of intelligence analysis from other responsibilities, such as
obtaining stakeholder feedback on changes to the DBT, in order to insulate
analysis of intelligence from other considerations. However, according to
NRC, the agency made a deliberate decision as part of the process for
revising the DBT in 2003 to have the threat assessment staff analyze
intelligence information and obtain stakeholder feedback simultaneously,
rather than sequentially, in order to accelerate the process in response
to the increase in the terrorist threat. NRC officials said that in
considering future changes to the DBT, NRC plans to ensure the initial
separation of intelligence analysis from interaction with stakeholders.

The NRC Commission Made Key Policy Judgments about Changes to the DBT
without Criteria on Threats That a Private Security Force Could Reasonably
Defend Against

The NRC staff provided the commissioners with a number of documents to
consider in making the final decision on changes to the DBT. These
included, but were not limited to, two assessments in the fall of 2002 on
the terrorist threat to nuclear power plants (one specifically on the
potential use of vehicle bombs) and a final paper in April 2003 with the
staff recommendations for revisions to the DBT. The April 2003 document
also included a summary of comments on the draft DBT received from the
nuclear industry and other federal and state agencies; a summary of NEI's
estimates of the cost of and time frame for implementing security measures
to address specific changes to the DBT; and an updated assessment of the
terrorist threat to nuclear power plants. The NRC commissioners told us
they also had direct contacts with intelligence agencies that provided
them with information on the terrorist threat.

The commissioners made the final decision on changes to the DBT by
majority vote.18 While the commission largely supported the NRC staff's
recommendations for changes to the DBT, it also made some significant
changes that reflected policy judgments. Specifically, the commissioners
considered whether any of the recommended changes to the DBT constituted
characteristics representative of an enemy of the United States, which
sites are not required to protect against under NRC regulations. In
approving the revised DBT, the commission stated that nuclear power
plants' civilian security forces cannot reasonably be expected to defend
against all threats, and that defense against certain threats (such as an
airborne attack) is the primary responsibility of the federal government,
in coordination with state and local law enforcement officials. In
connection with this position, the commission directed NRC's Office of
General Counsel to prepare a paper for commission approval articulating
the factors to be considered in determining whether particular
characteristics of an attack constitute an enemy of the United States.
(Officials from NRC's Office of General Counsel told us they prepared a
document with an analysis of this issue for the commission, but that the
document was not a decision paper for approval by the commissioners.)

We recognize that consideration of issues such as what is reasonable for a
private security force to defend against is an appropriate role of the
commission in approving changes to the DBT. However, in approving the
revised DBT, the commission did not identify explicit criteria for
determining whether specific adversary characteristics constitute an enemy
of the United States or criteria for what is reasonable for a private
security force to defend against. For example, the commission did not
define whether the criteria include the cost for nuclear power plants to
defend against an adversary characteristic or the efforts of local, state,
and federal agencies to address particular threats. The lack of such
criteria can reduce the transparency of commission decisions to make
changes to the threat assessment staff's recommendations. NRC officials
said detailed criteria on what is reasonable for a private guard force
would reduce the commissioners' discretion in approving changes to the
DBT. Furthermore, in NRC's view, the basis for the commission's policy
decisions and direction to the NRC staff regarding the DBT are
sufficiently articulated in the commission's voting record, in which
individual commissioners provided the rationale for their votes, and in
the related staff requirements memorandum, which documented the
commission's decisions.

As indicated in table 1, the significant changes the commission made to
the NRC staff's recommendations included removal of certain weapons, a
decrease in the maximum amount of weight carried by the attackers, and
mitigation of an active insider through a human reliability program. In
other cases, such as the size of the vehicle bomb, the commission
supported the recommendations of the NRC staff. Based on our review of the
commissioners' voting records, the commission's decisions on key aspects
of the DBT included the following:

o Vehicle bomb. A majority of commissioners voted to increase the maximum
vehicle bomb to the size recommended by the NRC staff. However, one
commissioner supported a larger vehicle bomb that the NRC staff had
included in a previous draft of the DBT. The commissioner recognized that
some sites would not have sufficient property to install vehicle barrier
systems far enough from the plants to protect against the larger vehicle
bomb and suggested NRC could provide such sites with an exemption and
require them to protect against a smaller vehicle bomb.

o Weapons. The commission decided to remove two weapons the NRC staff had
recommended for inclusion in the revised DBT. As part of this decision,
the commission directed the staff to conduct an in-depth analysis of the
additional defensive capabilities, changes to sites' protective
strategies, and costs associated with protecting against one of the
weapons. Removal of weapons from the revised DBT was significant because
of the strength of the NRC staff's intelligence analysis supporting their
inclusion. For example, in the April 2003 report to the commissioners, the
NRC staff reported that while one such weapon had not been used in the
United States, it had been found in weapons caches in the United States.
Similarly, the staff noted the use of the other weapon in captured
terrorist training videos and its ready availability. The document
summarizing the commission's changes to the proposed DBT did not provide a
reason for excluding these weapons. However, in written comments on their
votes, one commissioner identified these weapons as representative of an
enemy of the United States; another commissioner agreed that threat data
showed an increased possibility of the use of these weapons but stated
that NRC staff needed to assess whether it would be reasonable for a
private security force to defend against such weapons. One of the
commissioners supported inclusion of these weapons in the DBT, as well as
other weapons the staff had not recommended, but nevertheless told us
there was more agreement than disagreement among the commissioners about
what weapons should be included. The same commissioner told us he
supported inclusion of one of the weapons because he considered the means
for defending against it to be affordable.

o Weight of equipment and explosives. In voting to decrease the maximum
weight of equipment, weapons, and explosives (such as grenades) per
attacker in the final DBT, three of the commissioners indicated they
supported decreasing the weight that an attacker could be expected to
carry. In their written comments, the three commissioners indicated that
the staff's recommendation regarding carry weight would require further
study-for example, to determine whether the greater amount of weight could
reduce the capability of the attack force by reducing individual
attackers' mobility.

o Inside assistance. The commission added language to the DBT stating that
a human reliability program for monitoring employees at the sites could
reduce the likelihood of an active insider. To qualify, the sites' human
reliability program would have to include background checks, substance
abuse testing, psychological evaluations, annual supervisory review, and
periodic background reinvestigations. The commissioners told us they made
this decision based, in part, on the long-standing assumption by NRC that
a human reliability program reduces the likelihood of an active insider.
The commissioners also told us that other factors, such as increased
awareness about the potential for an attack in the communities where
nuclear power plants are located, would reduce the likelihood of an active
insider.

In addition to making changes to specific elements of the DBT for nuclear
power plants, the commission provided overall policy direction on NRC's
oversight of security of the sites. In particular, recognizing that an
attack on a site could exceed the characteristics identified in the DBT,
the commission directed the staff to continue coordinating with DHS and
other federal and state authorities to help assure the security of nuclear
power plants. For example, the commissioners told us that NRC works with
the Federal Aviation Administration to address the threat of air strikes
against a site. Similarly, NRC supports and participates in DHS
comprehensive security reviews of nuclear power plant sites.

Other significant policy direction included the following:

o The commission affirmed the NRC staff's operating assumption that there
may be no specific advance warning of an attack on a nuclear power plant
but indicated that a general warning of a potential attack may be
provided.

o The commission directed the staff to continue providing the
commissioners with assessments of specific adversary characteristics,
including those not in the revised DBT, and to provide additional
recommendations as part of the semiannual review of threats to nuclear
power plants. However, the commission also indicated its expectation that
there would be a period of "regulatory stability" (a period with no major
changes to security regulations) in order to allow sites time to adjust to
the changes already made to the DBT and other security requirements.

o The commission supported the clarification that sites are not required
to "defeat" an attack, because such a requirement could require sites'
security forces to employ offensive tactics beyond what is allowed under
law for private security forces. Rather, the commission supported the
requirement that sites protect against radiological sabotage by preventing
the destruction or disablement of vital equipment.

Nuclear Power Plants Made Substantial Changes to Their Security to Address
the Revised DBT, but NRC Inspections Have Uncovered Problems

The four nuclear power plant sites we visited made substantial changes
after the September 11, 2001, attacks and in response to the revised DBT,
including measures to detect, delay, and respond to the increased number
of attackers and to address the increased vehicle bomb size. According to
NRC, other sites took comparable actions to defend against the revised
DBT. Despite the industry's considerable efforts, the changes have not
been completely without problems and licensees can continue to make
improvements. For example, NRC baseline and force-on-force inspections
have found that the security changes have not always met NRC's
requirements.

Sites Addressed the Increase in the Number of Attackers by Implementing
Security Enhancements Designed to Detect, Delay, and Respond to an Attack

The four sites we visited all implemented a "defense-in-depth" strategy,
with multiple layers of security systems that attackers would have to
defeat before reaching vital areas or equipment and destroying or
disabling systems sufficient to cause an elevated release of radiation off
site. The sites varied in how they implemented these measures, primarily
depending on site-specific characteristics such as topography and on the
degree to which they planned to interdict attackers within the
owner-controlled area and far from the sites' vital area, as opposed to
inside the protected area but before they could reach the vital equipment.
(See fig. 1 for a diagram of the areas commonly found at nuclear power
plants.) NRC officials told us that licensees have the freedom to design
their protective strategies to accommodate site-specific conditions, so
long as the strategies satisfy NRC requirements and prove successful in a
force-on-force inspection.

Figure 1: Diagram of a Sample Nuclear Power Plant Site

Note: The owner-controlled area refers the land and buildings within the
site boundary, and the owner can limit or allow access to it for any
reason. The protected area is within the owner-controlled area and
requires a higher level of access control. The vital area contains the
sites' vital equipment, the destruction of which could directly or
indirectly endanger public health and safety through exposure to
radiation.

The sites we visited implemented security measures corresponding to the
three elements generally recognized as constituting an effective security
system for defending fixed sites. These include early detection of an
attack, sufficient delay for security officers to report to their
defensive positions, and capability of the security force to respond to
the attack:

o Detection. At all four sites, the owners installed additional cameras
throughout different areas of the sites and instituted random patrols in
the owner-controlled areas.19 The owner-controlled areas generally contain
undeveloped property and administrative buildings that would not be
targets for terrorists seeking to commit radiological sabotage.
Nevertheless, by upgrading security in this area, the sites increased the
chance that they would detect attackers before the attackers would be able
to approach or infiltrate the protected area, where they might be able to
gain access to vital equipment. Patrols can be used to accommodate areas
of the sites that are remote or where the view of cameras is obstructed,
while cameras provide for a safer inspection of questionable activities
than sending a security officer.

o Delay. The sites we visited installed a variety of devices designed to
delay attackers and allow security officers more time to respond to their
posts and fire upon attackers. The sites generally installed these delay
devices throughout the protected areas so that attackers would have to
defeat multiple security systems before reaching vital areas or equipment.
For example, the sites installed fences outside the buildings housing the
reactors and other vital equipment and blocked off entrances to make it
more difficult for attackers to enter the buildings. Similarly, the sites
installed a variety of delay devices within the reactor and other
buildings, some of which are permanent and others that security officers
would deploy in the event of an attack.

o Response. Each of the four sites we visited constructed bullet-resistant
structures at various locations in the protected area or within buildings,
increased the minimum number of security officers defending the sites at
all times, and expanded the amount of training provided to them.20
Security officers are stationed in the bullet-resistant structures or move
to them during an attack, at which point they can fire at attackers
through gun ports while not exposing themselves to the attackers' gunfire.
(See fig. 2 for an example of a bullet-resistant structure.) Having more
security officers on duty at any given time means that more individuals
can respond to more locations in the event of an attack. It can also
increase the sites' ability to detect attackers by allowing more security
officers to observe the owner-controlled area and monitor video cameras.
Security managers at each site told us they also made changes to their
training-for example, to train officers to use new security equipment or
to comply with NRC's training order, issued at the same time as the
revised DBT. Moreover, each of the licensees told us they implemented
measures to comply with NRC's requirements limiting the number of hours
security officers can work to 72 hours during a 7-day period.21 The
majority of the security officers we interviewed told us that their
training was adequate or had improved and that they generally did not
experience fatigue on the job.

Figure 2: Example of a Bullet-Resistant Structure

Security managers at the four sites considered the layouts of their sites
and the paths that attackers might use to reach vital equipment in
deciding where to deploy these enhancements. As a result, the sites
employed different protective strategies that primarily varied by the
degree to which they implemented an external strategy designed to
interdict attackers within the owner-controlled area, but far from the
sites' vital area, rather than an internal strategy designed to interdict
attackers inside the protected area. For example, one site with a
predominantly external strategy installed an intrusion detection system in
the owner-controlled area. While NRC requires all sites to have an
intrusion detection system at the perimeter of the protected area,22
security managers at this site decided to install a second intrusion
detection system so that security officers would be able to identify
intruders as soon as they cross into the owner-controlled area. The site
was able to install such a system because of the large amount of open,
unobstructed space in the owner-controlled area. Similarly, the protective
strategy at another site focused on the ability of security officers to
deny attackers access to the vital area buildings. The site uses cameras
and patrols to detect attackers in the owner-controlled area and deploys
security officers in bullet-resistant structures. From the structures,
located on the roof and attached to the walls of the vital area buildings,
security officers could fire upon attackers before they could enter the
buildings.

In contrast, security managers at the other two sites we visited described
protective strategies that combined elements of an external strategy and
an internal strategy. At both sites, the external strategy included
bullet-resistant structures positioned so that security officers could
fire on attackers attempting to enter vital area buildings. Other security
officers are stationed inside the vital area buildings and would move to
bullet-resistant structures within the buildings to interdict attackers
who defeat the external security. At one of these sites in particular,
security managers decided to implement a protective strategy that relied
more heavily on interdicting attackers inside the protected area. The site
uses elements of an external strategy, such as cameras and patrols for
detecting attackers in the owner-controlled area, but in contrast to the
sites described above, relies to a lesser extent on security officers to
stop the attackers in the owner-controlled area. Instead, security
managers told us they had implemented an internal protective strategy by
identifying "choke points"-locations inside the protected area attackers
would need to pass before reaching their targets-and installing
bullet-resistant structures at the choke points where officers would be
waiting to interdict the attackers. Security managers at the site also
told us one of the reasons for implementing a more internal strategy was
their desire to maintain radiation doses to security officers as low as is
reasonably achievable. In particular, the internal strategy allowed the
site to not install bullet-resistant structures on one side of the site,
where security officers who would be stationed in the structures could
receive elevated radiation doses.

In addition to the security enhancements we observed, security managers at
each site described changes they plan to make as they continue to improve
their protective strategies, such as adding fencing to block a path
attackers might use to enter the protected area and a device at the
entrance to the site that can detect explosives. Security managers at
three of the sites we visited also told us the number of security officers
on duty at any one shift exceeded the minimum number of security officers
that NRC requires be dedicated to responding to attacks.23 (The fourth
site maintained the minimum number of armed dedicated security officers.)
According to NRC's analysis, sites typically exceeded the minimum number
of responders required by NRC.

Sites Addressed the Increase in the Size of a Vehicle Bomb by Designing
Comprehensive Systems of Sturdy Barriers

To protect against the increase in the vehicle bomb size, the licensees at
the sites we visited designed comprehensive systems consisting of sturdy
barriers to prevent a potential vehicle bomb from approaching the sites
and to channel vehicles to entrances where security officers could search
them for explosives and other prohibited items. Prior to increasing the
maximum size vehicle bomb sites must defend against, NRC required the
sites to have a vehicle barrier system encircling the reactors and other
vital equipment and set at a distance far enough from the plants to
prevent a smaller vehicle bomb from damaging vital equipment and releasing
radiation. After NRC increased the maximum size of the vehicle bomb in the
revised DBT, plants installed a second vehicle barrier system at an even
greater distance from the vital equipment, while also keeping the original
vehicle barrier systems as a second layer of defense.

At the sites we visited, the new vehicle barrier systems consisted of rows
of large steel-reinforced concrete blocks, or (at one plant) large
boulders weighing up to 7 tons in combination with piles of smaller rocks.
(See fig. 3 for an illustration of a vehicle barrier system.) The vehicle
barrier systems either completely encircled the plants (except for
entrances manned by armed security officers) or formed a continuous
barrier in combination with natural or manmade terrain features, such as
bodies of water or trenches, that would prevent a vehicle from approaching
the sites.

Figure 3: Example of a Vehicle Barrier System

Licensees at the four sites adapted their vehicle barrier systems to the
unique conditions at each site. The vehicle barrier systems also shared
many features in common and generally consisted of a combination of the
following basic elements:

o Vehicle searches. Generally, the security managers told us they
implemented procedures to search vehicles at the entry point to the outer
vehicle barrier systems. (NRC requires sites to search all vehicles
capable of carrying more than a certain amount of TNT and to search a
random sample of vehicles capable of carrying a smaller amount of
explosives). Examples of search procedures included visual examination of
the compartments of vehicles and use of detection equipment to test for
explosives. Security managers told us security officers would conduct a
second search of all vehicles, regardless of size, at a second checkpoint
where vehicles pass through the inner vehicle barrier system. During this
search, security officers would look for weapons and other prohibited
equipment in addition to any explosives.

o "Overwatches." The sites stationed security officers in bullet-resistant
structures, or "overwatches," from which the officers could observe the
vehicle searches and provide backup support in case of an attack. Like the
other bullet-resistant structures installed by the sites, these structures
included gun ports for firing at attackers.

o "Active" vehicle barrier systems. These systems were installed in the
roadways leading into the plants and were designed to block unauthorized
vehicles from entering the site. They consisted either of steel plates
that could be raised or lowered or rolling gates. (See fig. 4 for an
example of an active vehicle barrier system.) Security officers in
multiple locations, such as alarm stations and overwatches, could activate
the systems if security officers manning the vehicle entrances, who are
more vulnerable to attack, were unable to do so. At two of the plants, the
barriers were always in the closed position and required two security
officers at separate locations to open them. At the other two plants, the
barriers were generally in the open position but could be closed by a
single security officer to prevent unauthorized entry.

Figure 4: Example of an Active Vehicle Barrier System

In some cases, the new vehicle barrier systems at the sites we visited
appeared to exceed the requirements necessary to protect against the
revised DBT. For example, security managers at one site told us that the
vehicle barrier system was wider than necessary in order to protect
against the vehicle bomb. Furthermore, in at least some areas of the
sites, the new vehicle barrier systems were farther from the reactors and
other vital equipment than necessary to protect the sites against the size
of vehicle bomb in the revised DBT. In particular, security managers at
the site with a more external protective strategy decided to take
advantage of the large amount of open, unobstructed property surrounding
the site to create a large zone between the vehicle barrier system and the
site buildings. Although we generally toured the complete perimeter of the
vehicle barrier systems at the four sites, we did not calculate how far
the barrier systems were installed from the vital equipment, test the
equipment performance, or determine how well security officers conducted
vehicle searches. Like other aspects of security at the plants, these
factors would affect how well the vehicle barrier systems would work in
the event of a terrorist attack.

In addition, the sites implemented other related measures, such as winding
lanes designed to cause vehicles to slow down as they approach entrances;
emergency exits to facilitate evacuation of employees from the plant;
devices to block unauthorized trains from reaching the plant; parking lots
outside the vehicle barrier system for use during an outage to limit the
number of additional vehicles entering the vehicle barrier systems and
requiring searches; and, at one site, receiving deliveries at an off-site
warehouse to limit the number of trucks entering the site.

Sites Have Generally Complied with NRC Security Requirements and Performed
Well in Force-on-Force Inspections, but Problems Remain

As of November 1, 2005, NRC had completed force-on-force
inspections-testing sites' ability to defend against the revised DBT-at 20
sites. NRC officials told us, and our review of baseline and
force-on-force inspection reports indicated, that plants have generally
complied with their security plans and other NRC security requirements and
have generally performed well during force-on-force inspections.24
However, we also noted from the reports, as well as from our own
observations, that sites have encountered a range of problems in meeting
NRC security requirements, including a force-on-force inspection in which
the site had problems demonstrating it could defend against the revised
DBT. (According to NRC officials, inspectors do not leave the site at
which a problem is identified until it is corrected or until sufficient
compensatory measures are put in place.) Twelve of the 18 baseline
inspection reports and 4 of the 9 force-on-force inspection reports we
reviewed identified problems or items needing correction. These findings,
such as failures in the intrusion detection system at one site and not
including certain elements of training at several sites, demonstrate that
NRC's baseline and force-on-force inspections are important to identifying
problems that need correction. (See app. II for a discussion of the
findings in the force-on-force and baseline inspection reports we
reviewed.)

During a force-on-force inspection at one site, we observed that although
the security measures appeared impressive, the site's ability to defend
against the DBT was at best questionable. The site's security measures
were similar to those we observed at other sites, such as an intrusion
detection system equipped with cameras for assessing alarms,
bullet-resistant structures both in the protected and vital areas, and a
vehicle barrier system consisting of large concrete blocks and large
boulders. However, some or all of the attackers were able to enter the
protected area in each of the three exercise scenarios. Furthermore,
attackers made it to the targets in two of the scenarios, although the
outcomes of the two scenarios were called into question by uncertainties
regarding whether the attackers had actually been neutralized before
reaching the targets. NRC, in turn, raised concerns about the site's lack
of "defense in depth" and concluded that it could not validate the
licensee's protective strategy in the two scenarios. NRC noted that
security officers' ability to interdict attackers was impacted due to
problems in the site's detection and assessment, and that, in two of the
scenarios, security officers left the external bullet-resistant structures
to which they were assigned and transitioned to internal positions once
they could account for the number of attackers in the revised DBT. This
meant that the security officers left positions that covered a "breach"
the attackers had made in the protected area perimeter. As a result of the
inspection, NRC required the licensee to install additional security
equipment immediately after the inspection, NRC inspectors remained on
site until the equipment was put in place, and NRC decided to conduct
another force-on-force inspection at the site.

At the follow-up force-on-force inspection at the same site, which we also
observed, the licensee told us it had spent an additional $37 million to
improve security in the 6 months following the first inspection. Some of
these changes were clearly visible, such as elevating the bullet-resistant
structures that had been on the ground to give officers greater visibility
and firing opportunities, razing several buildings to reduce opportunities
for attacker concealment, and increasing the distance between the vehicle
barrier system and the protected area in a part of the site. The licensee
also told us about other changes directly related to the internal aspect
of the protective strategy, including positioning more security officers
within the vital area, installing additional cameras to increase security
officers' ability to detect attackers, and creating new bullet-resistant
structures that provided additional protected positions for firing upon
the attackers. From the second exercise, NRC officials concluded that they
could evaluate the protective strategy and that the site had adequately
defended against a DBT-style attack.

In addition to our observations of security during force-on-force
inspections, GAO security experts who accompanied us to the four other
sites we visited suggested a number of opportunities to improve security
at the sites. While our experts did not find a lack of compliance with NRC
regulations or an inability to defend the sites against the adversary
characteristics in the revised DBT, the suggestions support our assessment
that security at nuclear power plants is an ongoing process of identifying
and implementing potential improvements. For example, at one site, we
observed a bullet-resistant enclosure in which curtains-installed to
reduce glare from the sun-obstructed the view through windows, and video
equipment associated with surveillance cameras blocked access to several
gun ports. We suggested that the site consider replacing the curtains with
tinted glass and providing the security officer in the bullet-resistant
enclosure with better access to the gun ports. At another site, we
suggested that the addition of a bullet-resistant structure on one side of
the site would provide the site's security force with greater opportunity
to interdict attackers entering on that side of the site.

NRC Has Significantly Improved the Force-on-Force Inspection Program, but
Challenges Remain

NRC has made a number of improvements to the force-on-force inspection
program, several of which address recommendations we made in our September
2003 report on NRC's oversight of security at commercial nuclear power
plants. We had made our recommendations when NRC was restructuring the
force-on-force program to provide a more rigorous test of security at the
sites in accordance with the DBT, which was also under revision.25 For
example, we had recommended that NRC strengthen the force-on-force
inspections by (1) conducting the inspections more frequently at each
site, (2) using laser equipment to better simulate attackers' and security
officers' weapons, and (3) requiring the inspections to make use of the
full terrorist capabilities stated in the DBT, including the use of an
adversary force trained in terrorist tactics.

NRC has taken a number of actions as part of its restructuring of the
force-on-force program that satisfy the recommendations we made to
strengthen the program. For example, NRC has begun conducting the
exercises more frequently at each site and is using laser equipment to
simulate weapons. Furthermore, the attackers in the force-on-force
exercise scenarios we observed used many of the adversary characteristics
of the revised DBT, including the number of attackers in the revised DBT,
a vehicle bomb, a passive insider, and explosives. In addition, NRC
officials told us that the adversaries were trained in military tactics.
Nevertheless, in observing three force-on-force inspections and discussing
the program with NRC officials, we noted the following issues that
continue to warrant NRC's attention:

o Problems with laser equipment. At the three force-on-force inspections
we observed, the sites used laser equipment to simulate firing live
weapons. In general, the equipment appeared to help make the inspections a
realistic test of security at the sites. For example, laser equipment
provides a much more reliable account of shots fired in comparison with
the equipment NRC and the sites had been using, which relied on the
judgment of individual participants to determine shooting accuracy.
However, problems in using the equipment contributed to NRC's limited
ability to evaluate security at one of the sites. In part because of
problems with the laser equipment, NRC decided to conduct a second
force-on-force inspection at this site. The second inspection made better
use of the laser equipment, which proved to be a valuable tool in
determining that several security officers engaged attackers
unsuccessfully by firing at the attackers while they were too far away.
NRC raised this issue to the licensee in the context of improving training
so that security officers would not waste ammunition on targets that are
beyond the range of their weapons.

o Inspection schedules. The way in which NRC schedules force-on-force
exercises may create artificialities that enable sites to perform better
than they otherwise would. NRC officials said they notify sites of the
date of their force-on-force inspection only 8 to 12 weeks in advance.
Nevertheless, NRC may be able to further reduce the artificiality of the
inspection schedules and thereby enhance its ability to test security at
the sites. For example, in each of the exercises we observed, NRC followed
the same schedule for conducting nighttime and daytime attacks.
Furthermore, the adversary force typically initiated the attack soon after
the opening of the exercise "window" (the agreed-upon time for the
exercise to begin). Consequently, the sites' security forces might have
been able to anticipate the approximate time that the attack would begin,
and industry observers from other sites might have more information than
necessary prior to inspections at their own sites about NRC's standard
practices for conducting the inspections. NRC officials told us that,
while the attacks began soon after the opening of the exercise window in
the exercises we observed, the attackers do sometimes wait longer in order
to increase the level of uncertainty among the site's security force and
thereby create a more realistic scenario.

o Testing of sites' internal security strategies. Given the amount of
resources invested in preparing for and implementing a force-on-force
inspection, we believe inspections should test the full extent of sites'
"defense-in-depth" strategies, including both the external and internal
elements of the strategies. However, the force-on-force exercises end when
a site's security force successfully stops an attack. Consequently, if the
security force stops an attack before the attackers enter the vital area,
NRC would not have an opportunity to observe how the security force would
perform in the event that the attackers successfully defeat the site's
external security strategy. In a number of the force-on-force exercises we
observed, the security force did, in fact, stop the attackers early in the
scenario. According to NEI officials, force-on-force inspections would be
more valuable if NRC allowed the adversaries to challenge each layer of
defense until reaching their targets, or being defeated at the last
possible point of defense. NRC officials also told us such an approach is
worth considering but that NRC would have to first determine how to
implement it.

o Operational security. At two of the force-on-force inspections we
observed, we noted areas in which "operational security"-the protection of
information about the planned scenarios for the mock attacks-could be
improved. For example, during a safety "walk down"-a physical site check
conducted prior to every exercise scenario to ensure the safety of
exercise participants-a site employee made motions that may have alerted
security officers to the targets the adversaries would be trying to reach
that evening. In another inspection, security officers could observe
adversaries getting into position inside the protected area prior to the
start of an exercise, potentially providing clues about the route the
adversaries would use to enter the site. We also observed that each
force-on-force exercise was attended by a large number of people who had
access to scenario information, after signing a nondisclosure form, thus
increasing the chance that details about an exercise scenario might be
compromised. While we recognize that procedures such as safety walk downs
and prepositioning of adversary teams are necessary to the proper conduct
of the force-on-force inspections, lapses in operational security have the
potential to give security officers knowledge that would allow them to
perform better than they would otherwise and raise questions about whether
the force-on-force inspections are a true test of the sites' protective
strategy. According to NRC officials, NRC inspectors have been instructed
to be vigilant regarding any indications that a site's security force may
have received advance knowledge of an attack scenario, and procedures for
safety walk downs have been revised to improve operational security.

o Standards for controllers. NRC relies on the sites to assign and train
controllers to observe each participant (both the adversaries and security
officers) in the force-on-force inspections.26 In the three inspections we
observed, the level of security expertise and training among the
controllers varied among the sites. For example, one site assigned as
controllers plant employees who did not have security-related backgrounds
but who volunteered to help. In its force-on-force inspection report for
this site, NRC concluded that the level of controller training was a
factor in the force-on-force exercises not being brought to a definitive
conclusion. (As discussed above, NRC decided to conduct another
force-on-force inspection at this site.) In contrast, another plant used
personnel with security backgrounds. NEI has prepared a set of guidelines
for controllers in force-on-force inspections that NRC has reviewed. NEI
has also created a controller-training workshop in which NEI shares
lessons learned from force-on-force exercises.

o Quality of feedback to licensee. The quality of the feedback among the
force-on-force inspections we observed was inconsistent. In particular,
during the first inspection, NRC failed to discuss with the licensee
several potential problems raised by the NRC team after each scenario. In
the two subsequent inspections we observed, NRC appeared to have improved
the quality of its feedback to the licensees. Specifically, the team
leader provided the licensee with concise feedback that accurately
reflected what the team members had expressed in closed NRC meetings. An
NRC official told us that, based on comments from us as well as from NRC
team members, NRC took measures to improve the quality of the feedback.

o Force-on-force inspection schedule. So far, NRC is on schedule to
conduct the first round of force-on-force inspections at all sites within
3 years. As we reported in 2004, NRC is planning to conduct an inspection
at each site every 3 years instead of every 8 years, as the agency had
been doing.27 NRC initiated a new force-on-force program in November 2004,
together with a 3-year schedule to complete inspections at all sites,
after the revised DBT took effect on October 29, 2004. NRC officials told
us they had completed inspections at 20 (or about 31 percent) of the 65
sites as of November 1, 2005. Furthermore, NRC officials told us that
three teams are conducting the inspections and that NRC is hiring
additional force-on-force personnel. Given the importance of the
force-on-force inspections in demonstrating how well a nuclear power plant
might defend against a real-life threat, we believe it is important that
NRC devote the necessary resources to ensure that it continues to meet the
inspection schedule.

Conclusions

The nuclear power industry and NRC have taken very seriously the need to
protect nuclear power plants against a potential terrorist attack and have
made important investments to this end. However, NRC's process for
revising the DBT for nuclear power plants raises a fundamental
question-the extent to which the DBT represents the terrorist threat as
indicated by intelligence data versus the extent to which it represents
the threat that NRC considers reasonable for the plants to defend against.
Specifically, NRC's process for deciding on the DBT raised the possibility
that the industry may have inappropriately influenced the staff's
interpretation of intelligence data. The NRC threat assessment staff
obtained the views of the nuclear industry on a draft of the revised DBT
while they continued to assess intelligence information, and the staff
made industry-recommended changes to the DBT even though the intelligence
information had not changed. We recognize that NRC should and would want
to obtain feedback from the industry and other stakeholders on the
implications of the proposed changes before finalizing the DBT. In
addition, NRC has stated that it has altered its process for obtaining
industry feedback so that the threat assessment staff interacts with
industry only after it has made its proposals for changes to the DBT.
However, this approach does not entirely eliminate the appearance of
industry influence. Threat assessment is a continuous process, and this
sequential approach would still allow for interactions between the
agency's threat assessment staff and the nuclear industry. Assigning
responsibility for obtaining feedback from the nuclear industry to an
office within NRC other than the Threat Assessment Section would further
reduce any appearance of industry influence on the process of assessing
the terrorist threat to nuclear power plants. The commissioners would then
be able to review the threat assessment staff's recommended changes to the
DBT with confidence that the recommendations are based strictly on an
assessment of the threat. In making the final decision to revise the DBT,
the commissioners would also consider industry feedback on the staff's
recommendations.

Furthermore, the commissioners did not have explicit criteria that they
used as the basis for removing certain weapons from the DBT recommended by
the NRC staff. Consideration of what is reasonable for a private security
force to defend against, as well as industry views on proposed changes to
the DBT, is an appropriate function of the commissioners. However,
explicit criteria setting out the factors and how they would be weighed to
determine what adversary characteristics are not reasonable for a private
security force to defend against would have provided greater transparency
for the commissioners' decisions to exclude certain characteristics from
the DBT. Such criteria would also potentially increase the rigor and
consistency of the process. The underlying process used by NRC was logical
and well defined and should enable NRC to produce a more credible DBT if
these shortcomings are addressed.

In our visits to nuclear power plants, we saw a clear connection between
the changes in the DBT and the plants' recent security enhancements. The
plants' response to the revised DBT and other NRC orders following the
September 11 terrorist attacks has been substantial and, in some cases,
has gone beyond what was required. Nevertheless, because the plants
essentially designed their security to defend against the DBT outlined by
NRC, their capability to defend against an attack is essentially limited
to how similar such an attack would be to the DBT. Therefore, it is
imperative that NRC and the plants continue to work with DHS and other
federal, state, and local authorities to ensure they have coordinated
their efforts to defend plants in the event of an attack, particularly one
that exceeds the adversary characteristics in the revised DBT.
Furthermore, although security has improved, the results of NRC's baseline
and force-on-force inspections conducted thus far have uncovered some
problems that needed to be addressed. Moreover, the effectiveness of any
nuclear power plant's security depends on the various parts and systems
working well together during the stress of an actual attack. Therefore,
NRC's continued vigilance at the plant level, especially in conducting
force-on-force inspections, is needed to ensure that plants are
consistently well protected.

In conjunction with revising the DBT, NRC has implemented improvements to
its force-on-force inspection program that put the agency in a better
position to evaluate the nuclear power plants' protective strategies.
These improvements have addressed several of our previous recommendations
regarding the force-on-force inspections. However, in observing three
inspections, we noted additional opportunities for improvement, such as
artificialities that could be further reduced to better test how plants
would respond to an actual terrorist attack. Making further improvements
to the force-on-force program would enhance NRC's ability to assure the
public and Congress that nuclear power plants are capable of defending
against a DBT-style terrorist attack.

Recommendations for Executive Action

To improve the process by which NRC makes future revisions to the DBT for
nuclear power plants, we recommend that the NRC commissioners take the
following two actions:

o Assign responsibility for obtaining feedback from the nuclear industry
and other stakeholders on proposed changes to the DBT to an office within
NRC other than the Threat Assessment Section, so that the threat
assessment staff is able to assess the terrorist threat to nuclear power
plants without creating the potential for or appearance of industry
influencing their analysis. The commissioners, in turn, could consider
both the staff's analysis of the terrorist threat and industry feedback to
make the final determination as to whether and how to revise the DBT.

o Develop explicit criteria to guide the commissioners in their
deliberations to approve changes to the DBT. These criteria should include
setting out the specific factors and how they will be weighed in deciding
what characteristics of an attack on a nuclear power plant would
constitute an enemy of the United States, or otherwise would not be
reasonable for a private security force to defend against.

We further recommend that the NRC commissioners continue to evaluate and
implement measures to further strengthen the force-on-force inspection
program. For example, NRC may be able to identify and reduce
artificialities associated with the inspections to better test how nuclear
power plants would respond to an actual terrorist attack.

Agency Comments and Our Evaluation

We provided a draft of this report to NRC for its review and comment. In
its written comments (see app. III), NRC commended GAO's effort to ensure
that the report is accurate and constructive. It also provided additional
clarifying comments on two areas of the report pertaining to the process
NRC used in 2003 to revise the DBT for nuclear power plants. First, NRC
stated that the report should provide a better description of the context
for the process by which the agency obtained industry input and the
appearance of industry influence on the development of the revised DBT.
NRC wrote that the agency made a deliberate decision to develop the
revised DBT while simultaneously (rather than sequentially) seeking input
from stakeholders, including the nuclear industry. NRC stated that this
was a departure from its typical approach and was intended to advance
public health and safety and the common defense and security, similar to
other government actions taken after the September 11, 2001, terrorist
attacks. In addition, NRC stated that it has returned to its normal
sequential approach to developing DBT revisions and seeking input from
stakeholders.

We are pleased that NRC recognizes the need to separate the process of
analyzing intelligence information from seeking input from stakeholders,
including the nuclear industry. In response to NRC's earlier comments on
the classified version of this report, which were essentially the same, we
revised the reports to clarify that NRC deliberately decided to develop
the revised DBT while simultaneously obtaining stakeholder input to speed
up the process in the aftermath of the September 11, 2001, terrorist
attacks. However, whether NRC chooses to use a simultaneous or sequential
process, we continue to believe that the best approach would be to
insulate the threat assessment staff from interactions with the nuclear
industry by assigning responsibility for such interactions to a different
office in NRC. This would best separate the fact-based analysis of the
threat to commercial nuclear power plants from policy-level considerations
regarding what is reasonable for a private security force to defend
against. We also clarified our recommendation to indicate our view that
the threat assessment staff should be insulated from interacting with the
nuclear industry and other stakeholders.

Second, regarding the criteria the commission used to make decisions
regarding the DBT, NRC wrote that a more comprehensive discussion in the
report of the commission's deliberative decision-making process would
provide important perspective. NRC stated that the agency first
established a DBT for nuclear power plants in the late 1970s and has a
long history in this area. Furthermore, NRC wrote that the commission's
decision-making authority does not require, and could be unduly restricted
by, detailed prescriptive criteria. Finally, NRC stated its view that the
basis for the commission's policy decisions and direction to the NRC staff
with regard to the DBT are sufficiently articulated in the commission's
voting record and related staff requirements memorandums.

We revised the reports to include NRC's view that the basis for the
commission's policy decisions regarding the DBT is articulated in the
commission's voting record and related staff requirements memorandum.
However, based on our review of the voting record and staff requirements
memorandum, as well as other documents related to the April 2003 revised
DBT, we remain concerned that the basis for how the commissioners made
decisions to exclude certain characteristics from the DBT is not as
transparent as it could be. We did not find that the commissioners agreed
upon a definition of "enemy of the United States" or explicit criteria for
what adversary characteristics would not be reasonable for a private
security force to defend against. For example, the memorandum accompanying
the commission's April 2003 decision approving changes to the DBT for
nuclear power plants did not provide the reason for the commission's
decision to remove two weapons the NRC threat assessment staff had
recommended for inclusion. Rather, the voting record showed that
individual commissioners used differing criteria and emphasized different
factors, such as cost or practicality of defensive measures. The staff
requirements memorandum set forth the general criteria that a civilian
security force cannot reasonably be expected to defend against all
threats. Furthermore, the intent of our recommendation that NRC develop
criteria for what adversary characteristics constitute an enemy of the
United States, or otherwise would not be reasonable for a private security
force to defend against, is not to restrict the commission's
decision-making authority through detailed prescriptive criteria. Instead,
the intent of our recommendation is to have general criteria or
definitions to guide the commissioners' decisions and to provide greater
transparency for commission decisions, the details of which are safeguards
information and withheld from the public.

Finally, NRC commented that NRC and GAO staffs discussed potential issues
related to the draft report that needed to be addressed. NRC also wrote
that the draft report contained safeguards information, which should be
removed prior to the report being made public. The potential issues have
been resolved, and we have revised the report for the purpose of removing
safeguards information. The resulting report is substantially the same as
the classified version of the report, with the exception that the
classified version contains additional details about the DBT and security
at nuclear power plants.

As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from
the report date. At that time, we will send copies to interested
congressional committees, the Chairman of NRC, and other interested
parties. We also will make copies available to others upon request. In
addition, the report will be available at no charge on the GAO Web site at
http://www.gao.gov .

If you or your staff have any questions about this report, please contact
me at (202) 512-3841 or [email protected] . Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made major contributions to this report are
listed in appendix IV.

Sincerely yours,

Jim Wells Director, Natural Resources and Environment

Scope and Methodology Appendix I

To examine the process the Nuclear Regulatory Commission (NRC) used to
develop the April 2003 design basis threat (DBT) for radiological sabotage
applied to nuclear power plants, we analyzed NRC's documentation of the
process and conducted interviews with NRC threat assessment staff and
other officials. In particular, we compared the adversary characteristics
of the April 2003 revised DBT approved by the commissioners with the
adversary characteristics in the previous DBT, as described in a February
2000 NRC staff position paper; the January 2003 draft DBT provided to
stakeholders for comment; and the NRC staff's April 2003 recommended
changes to the DBT submitted to the commissioners. Furthermore, for each
component of NRC's process, we analyzed documents and conducted a series
of interviews:

o To examine the role of intelligence analysis, we analyzed the NRC
staff's reports on the terrorist threat to nuclear power plants and the
results of their analysis of intelligence information on terrorist
activities worldwide. The three key reports we analyzed included an
October 2002 report on the use of vehicle bombs; a November 2002 report on
the potential use of other adversary characteristics against nuclear power
plants; and the April 2003 report that included the staff recommendations
on the DBT. To obtain further insight into the NRC's use of intelligence
information, we interviewed NRC officials, including the head of NRC's
Threat Assessment Section; reviewed a description of the adversary
characteristics screening process; and received briefings on the process
from NRC. We also interviewed officials from other federal agencies,
including the Department of Homeland Security (DHS) and the Federal Bureau
of Investigation (FBI). NRC redacted text from a number of the documents
provided to us if the text contained classified information from other
federal agencies, including the Department of Energy (DOE). As agreed with
NRC, we identified the selected portions of the redacted text that we
wanted to review, and NRC requested permission from the other agencies to
provide the text to us. All of the agencies NRC contacted except one
granted permission to release the redacted text to us.

o We compared NRC's April 2003 revised DBT with DOE's October 2004 DBT and
February 2004 Terrorist Adversary Capabilities List and interviewed DOE
Office of Security officials regarding the DOE DBT and differences with
the NRC DBT. We also reviewed the September 2004 final report of the DOE
DBT re-examination task force. We did not compare the implementation of
security measures at DOE sites to defend against the DOE DBT with security
at commercial nuclear power plants.

o To examine NRC's consultation with the nuclear industry, we reviewed the
written comments submitted by the Nuclear Energy Institute (NEI) on the
January 2003 draft DBT and compared NEI's comments with the changes the
NRC staff made to the draft DBT. We also interviewed NEI officials and
senior officials at the nuclear power plant sites we visited, including
some who served on the NEI working group responsible for security matters.

o To examine the decisions by the NRC commission, we analyzed the
commission voting record (including written comments of individual
commissioners), the April 2003 memorandum summarizing the commission's
final decisions, and the NRC regulation on enemy of the United States (10
C.F.R. S: 50.13). Furthermore, we interviewed three of the four
commissioners who were serving on the commission at the time the DBT was
revised and who participated in the decision-making process.1 We
interviewed the three commissioners as a group in a meeting that was not
subject to the requirements of the Government in the Sunshine Act.2 This
meant that the commissioners could discuss previous actions, including
their April 2003 decisions on changes to the DBT, but not the formulation
of future policy. For example, we did not ask the commissioners about the
potential for future changes to the DBT. In addition to this meeting, we
met individually with the two commissioners who assumed their posts in
2005 and did not participate in the decision-making process for the April
2003 revised DBT.

To determine what actions nuclear power plants have taken to enhance
security in response to the revised DBT, we interviewed staff from NRC's
Office of Nuclear Security and Incident Response, reviewed security orders
NRC has issued since September 11, 2001, and visited a nonprobability
sample of four nuclear power plant sites.3 We do not name the sites we
visited in this report because information about security at particular
sites is sensitive and considered safeguards information, and because the
objective of our visits was to provide a general description of the
changes in security sites implemented in response to the revised DBT,
rather than the changes at a particular site. Prior to our site visits, we
observed a baseline inspection at one site and a multiexercise
force-on-force inspection at another site in order to better familiarize
ourselves with NRC security requirements as well as sites' security
equipment and strategies. We selected these two sites based on the timing
of the activities.

To select the nonprobability sample of four sites we visited, we first
eliminated certain sites, such as those we had recently visited for
security-related work (including the two sites where we observed NRC
inspections) and sites frequently visited by Congress. We then selected
one site from each of the four NRC regions using the following criteria:

o sites representing different sizes and types of licensees, including
licensees that own or operate a single nuclear power plant site, licensees
that own or operate two to six sites, and licensees that own or operate
seven or more sites;

o sites with different surroundings, such as different topography and
proximity to water, in order to consider the effect of such factors on
sites' security strategies;

o sites with security forces hired both directly as site employees as well
as through a contractor, including one site that uses security officers
employed by Wackenhut Corporation, which provides security services to
about half of the nuclear power plant sites;

o sites with the two different categories of reactors licensed by NRC for
operation in the United States-two sites with boiling-water reactors and
two sites with pressurized-water reactors; and

o sites with different numbers of reactors.

At each of the four sites, we used a semistructured guide to interview
security managers and other site officials, and interviewed a random
selection of security officers. We worked with site management so that our
interviews with the security officers did not interfere with their duties.
We conducted individual interviews with security officers in private
rooms, without the attendance of plant management or other plant staff. We
also examined security equipment and reviewed documents, including
security plans, protective strategy documents, safeguards event logs,
security officer work-hour records, training materials, and equipment
testing records. GAO staff with a professional background in security
accompanied us on our visits in order to provide the expertise needed to
fully comprehend the sites' security equipment and strategies.

In addition to site visits, we reviewed 9 of the 16 force-on-force
inspection reports and a sample of 18 baseline inspection reports that NRC
had completed between November 2004 and the time we reviewed the reports.4
The 18 baseline inspection reports we reviewed consisted of reports
provided by NRC from each of the four regions, plus additional reports we
randomly selected ourselves.5 Time constraints prevented us from reviewing
additional reports. We also discussed the revised DBT and security
improvements at nuclear power plant sites with the Nuclear Energy
Institute and the Project on Government Oversight, an independent
nonprofit organization.6

To review NRC's progress in strengthening the conduct of force-on-force
inspections, we observed a total of three inspections at two sites. Two of
the inspections were at a site where NRC decided to conduct a second
inspection as a result of the agency's limited ability to evaluate
security during the first inspection. After the first inspection at this
site, but before the second, we also attended a meeting at the site in
which the licensee briefed NRC on security improvements the site had made
in response to the first inspection, and we observed these improvements.
GAO staff with a professional background in security accompanied us to the
third inspection. In addition, as discussed above, we reviewed NRC reports
on 9 of the 16 force-on-force inspections NRC had completed at the time we
reviewed the reports. Finally, we interviewed NRC officials responsible
for implementing the force-on-force inspection program. We conducted our
work from November 2004 through January 2006 in accordance with generally
accepted government auditing standards.

Details of Findings from NRC Reports on Baseline and Force-on-Force
Inspections Appendix II

Of the 27 baseline and force-on-force inspection reports we reviewed, NRC
identified no findings in 11 of the reports but did describe a variety of
problems with the sites' security in the remaining 16. The reports we
reviewed included one on a force-on-force inspection we observed, in which
NRC required the licensee to implement measures to address weaknesses in
the site's protective strategy and decided to return for a second
force-on-force inspection. The following are additional examples of NRC
findings from the 16 reports, including corrective actions taken by the
licensees:1

o In a baseline inspection at a site, several alarms failed to activate
during a test of the intrusion detection system, which alerts security
officers to the occurrence and location of a breach. Further testing
identified multiple alarms that were not functioning properly, and the
site subsequently declared the entire intrusion detection system
inoperable. Prior to leaving the site, NRC inspectors confirmed that the
site implemented compensatory measures to address problems with the
intrusion detection system, and NRC determined that further inspection of
the site at a later date was warranted. According to NRC, the subsequent
inspection at the site confirmed that the problem had been corrected.

o During a force-on-force exercise at another site, NRC observed two
officers performing duties other than their assigned patrols of the
owner-controlled area. The patrols are a component of NRC's requirement
for continuous surveillance of the owner-controlled area. Further
inspection revealed that the security officers manning the site's central
and secondary alarm stations were unaware that the owner-controlled area
was not being continuously patrolled. In the event of an attack,
owner-controlled area observations can be crucial both for setting a
response in motion by detecting intruders as early as possible and for
providing information about where attackers have entered the site and
where they are going so that security officers know how to respond.
According to NRC, the licensee took immediate corrective action. Also
during this inspection, NRC observed that the licensee deployed too many
officers in the force-on-force scenarios as a result of a
misunderstanding. In particular, the licensee had temporarily increased
the number of dedicated responders above the minimum listed in the
security plan to respond to the increased national threat level. However,
according to NRC, the additional officers did not play a role in stopping
the attackers in the scenarios.

o In a baseline inspection, NRC observed three examples of failure to
perform proper searches of personnel entering the protected area. For
example, a security officer did not examine items that had alarmed a metal
detector and allowed an individual to collect and carry the items into the
protected area without further examination. Based on discussions with
security officers and supervisors, NRC found that this deficiency was
routine and commonly accepted at the site. NRC concluded that this
situation had the potential to reduce the overall effectiveness of the
protective strategy by allowing the uncontrolled introduction of weapons
or explosives into the protected area. According to NRC, the licensee took
immediate corrective action, and security staff were required to attend
remedial training on search techniques and policy.

o In a force-on-force exercise, the attackers were able to destroy three
out of four targeted components. NRC observed that the attackers faced an
insufficient level of delay, which allowed them to reach the three
components before being interdicted by security officers. According to the
inspection report, sufficient delay is an essential component of a
protective strategy to prevent radiological sabotage. As a result of the
inspection, the licensee agreed to add delay locks to doors and relocate
security officers to ensure they could interdict attackers.

o NRC found that a number of sites ran weapons-training qualification
courses in which security officers were not trained in the way they would
be expected to perform during an attack. For example, sites did not train
security officers to use backup weapons for when they could not use their
primary weapons, or to undergo the level of physical stress an officer
would experience during an attack. At one of the sites, NRC also found
that the site had lowered the minimum qualification score related to
training security officers to use their weapons, potentially resulting in
security officers being less qualified in the use of their weapons than
what NRC believes is necessary. In addition, the licensee did not seek NRC
approval for the change as mandated by NRC's regulations. However, NRC
found that all of the security officers who had received the training
before the issue was observed and corrected had qualified on the use of
their weapons at the higher score. Furthermore, according to NRC, the
agency issued amplified guidance to all nuclear power plant sites
regarding weapons-training qualification courses.

o During the force-on-force inspection we observed, NRC inspectors found
that a site had not included the control room, spent fuel pool, and the
alternative shutdown panel among its targets. NRC required the licensee to
redevelop its target components for use in the force-on-force scenarios.
The adequate identification of target components is vital to a site's
ability to position security officers or direct them to locations where
they can interpose themselves between the attacker and target components.

o In an inspection initiated after the licensee observed security officers
who were inattentive at their posts, NRC inspectors found the licensee had
recorded 19 incidences in which security officers worked more hours in a
specific time period than allowed by NRC regulations. NRC concluded that
failure to meet the work-hour limits increased the susceptibility of
security officers to fatigue and had the potential to reduce the
effectiveness of the site's protective strategy. According to the
inspection report, the licensee identified several causes that contributed
to the problem and took immediate corrective actions. According to NRC,
the agency verified that the site updated its procedures to conform to
NRC's work-hour regulations. (At the four sites we visited, we reviewed
work-hour logs and found that each site had generally stayed within
security officer work-hour limits.)

o In a baseline inspection, the licensee was unable to provide engineering
documents to demonstrate the acceptable minimum safe standoff distance
from the inner vehicle barrier system, which is designed to protect the
site from a vehicle bomb. NRC requested that the licensee measure the
distance between several structures and the closest part of the vehicle
barrier system. The measurements showed that the barrier was too close to
at least two structures. As immediate corrective and compensatory actions,
the licensee installed additional vehicle barriers in the area of concern
and implemented direct observation by a security officer.

Comments from the Nuclear Regulatory Commission Appendix III

GAO Contact and Staff Acknowledgments Appendix IV

Jim Wells, (202) 512-3841 or [email protected]

In addition to the individuals named above, Raymond H. Smith, Jr.
(Assistant Director), Joseph H. Cook, and Michelle K. Treistman made key
contributions to this report. Also contributing to this report were John
Cooney, Doreen Feldman, Andrew O'Connell, Judy K. Pagano, Keith A. Rhodes,
Carol Herrnstadt Shulman, and Barbara Timmerman.

(360658)

www.gao.gov/cgi-bin/getrpt? GAO-06-388 .

To view the full product, including the scope

and methodology, click on the link above.

For more information, contact Jim Wells at (202) 512-3841 or
[email protected].

Highlights of GAO-06-388 , a report to the Chairman, Subcommittee on
National Security, Emerging Threats, and International Relations,
Committee on Government Reform, House of Representatives

March 2006

NUCLEAR POWER PLANTS

Efforts Made to Upgrade Security, but the Nuclear Regulatory Commission's
Design Basis Threat Process Should Be Improved

The nation's commercial nuclear power plants are potential targets for
terrorists seeking to cause the release of radioactive material. The
Nuclear Regulatory Commission (NRC), an independent agency headed by five
commissioners, is responsible for regulating and overseeing security at
the plants. In April 2003, in response to the terrorist attacks of
September 11, 2001, NRC revised the design basis threat (DBT), which
describes the threat that plants must be prepared to defend against in
terms of the number of attackers and their training, weapons, and tactics.
NRC has also restructured its program for testing security at the plants
through force-on-force inspections, which consist of mock terrorist
attacks. GAO was asked to review (1) the process NRC used to revise the
DBT for nuclear power plants, (2) the actions nuclear power plants have
taken to enhance security in response to the revised DBT, and (3) NRC's
progress in strengthening the conduct of force-on-force inspections at the
plants.

What GAO Recommends

GAO recommends that NRC improve its process for making changes to the DBT
and evaluate and implement measures to further strengthen its
force-on-force inspection program. Commenting on the draft report, NRC
provided clarifications regarding the process NRC used to revise the DBT,
but it neither agreed nor disagreed with GAO's recommendations.

NRC revised the DBT for nuclear power plants using a generally logical and
well-defined process in which trained threat assessment staff made
recommendations for changes based on an analysis of demonstrated terrorist
capabilities. The process resulted in a DBT requiring plants to defend
against a larger terrorist threat, including a larger number of attackers,
a refined and expanded list of weapons, and an increase in the maximum
size of a vehicle bomb. Key elements of the revised DBT, such as the
number of attackers, generally correspond to the NRC threat assessment
staff's original recommendations, but other important elements do not. For
example, the NRC staff made changes to some recommendations after
obtaining feedback from stakeholders, including the nuclear industry,
which objected to certain proposed changes such as the inclusion of
certain weapons. NRC officials said the changes resulted from further
analysis of intelligence information. Nevertheless, GAO found that the
process used to obtain stakeholder feedback created the appearance that
changes were made based on what the industry considered reasonable and
feasible to defend against rather than on an assessment of the terrorist
threat itself.

Nuclear power plants made substantial security improvements in response to
the September 11, 2001, attacks and the revised DBT, including security
barriers and detection equipment, new protective strategies, and
additional security officers. It is too early, however, to conclude that
all sites are capable of defending against the DBT because, as of November
1, 2005, NRC had conducted force-on-force inspections at about one-third
of the plants.

NRC has improved its force-on-force inspections-for example, by conducting
inspections more frequently at each site. Nevertheless, in observing three
inspections and discussing the program with NRC, GAO noted potential
issues in the inspections that warrant NRC's continued attention. For
example, a lapse in the protection of information about the planned
scenario for a mock attack GAO observed may have given the plant's
security officers knowledge that allowed them to perform better than they
otherwise would have. A classified version of this report provides
additional details about the DBT and security at nuclear power plants.

Barrier Designed to Defend against a Vehicle Bomb

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