Nuclear Power Plant Security and
Vulnerabilities
Mark Holt
Specialist in Energy Policy
Anthony Andrews
Specialist in Energy and Defense Policy
August 28, 2012
Congressional Research Service
7-5700
www.crs.gov
RL34331
CRS Report for Congress
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epared for Members and Committees of Congress
Nuclear Power Plant Security and Vulnerabilities
Summary
The physical security of nuclear power plants and their vulnerability to deliberate acts of
terrorism was elevated to a national security issue following the attacks of September 11, 2001.
Congress subsequently enacted new nuclear plant security requirements and has repeatedly
focused attention on regulation and enforcement by the Nuclear Regulatory Commission (NRC).
More than a decade after the 9/11 attacks, security at nuclear plants remains an important
concern.
The Energy Policy Act of 2005 (EPACT05, P.L. 109-58) imposed specific criteria for NRC to
consider in revising the “Design Basis Threat” (DBT), which specifies the maximum severity of
potential attacks that a nuclear plant’s security force must be capable of repelling. In response to
the legislative mandate, NRC revised the DBT (10 C.F.R. Part 73.1) on April 18, 2007. Among
other changes, the revisions expanded the assumed capabilities of adversaries to operate as one or
more teams and attack from multiple entry points.
To strengthen nuclear plant security inspections, EPACT05 required NRC to conduct “force-on-
force” security exercises at nuclear power plants at least once every three years. In these
exercises, a mock adversary force from outside a nuclear plant attempts to penetrate the plant’s
vital area and simulate damage to a “target set” of key safety components. From the start of the
program through 2010, 136 force-on-force inspections were conducted, with each inspection
typically including three mock attacks by the adversary force. During the 136 inspections, 10
mock attacks resulted in the simulated destruction of complete target sets, indicating inadequate
protection against the DBT, and additional security measures were promptly implemented,
according to NRC.
Nuclear power plant vulnerability to deliberate aircraft crashes has been a continuing issue. After
much consideration, NRC published final rules on June 12, 2009, to require all new nuclear
power plants to incorporate design features that would ensure that, in the event of a crash by a
large commercial aircraft, the reactor core would remain cooled or the reactor containment would
remain intact, and radioactive releases would not occur from spent fuel storage pools.
NRC rejected proposals that existing reactors also be required to protect against aircraft crashes,
such as by adding large external steel barriers, deciding that other mitigation measures already
required by NRC for all reactors were sufficient. In 2002, NRC ordered all nuclear power plants
to develop strategies to mitigate the effects of large fires and explosions that could result from
aircraft crashes or other causes. NRC published a broad final rule on nuclear reactor security
March 27, 2009, including fire mitigation strategies and requirements that reactors establish
procedures for responding to specific aircraft threats.
Other ongoing nuclear plant security issues include the vulnerability of spent fuel pools, which
hold highly radioactive nuclear fuel after its removal from the reactor, standards for nuclear plant
security personnel, and nuclear plant emergency planning. NRC’s March 2009 security
regulations addressed some of those concerns and included a number of other security
enhancements.
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Contents
Overview of Reactor Security.......................................................................................................... 1
Design Basis Threat ......................................................................................................................... 2
Large Aircraft Crashes ..................................................................................................................... 4
Spent Fuel Storage ........................................................................................................................... 6
Force-on-Force Exercises ................................................................................................................ 8
Emergency Preparedness and Response .......................................................................................... 9
Cybersecurity................................................................................................................................. 10
Plant Security Personnel ................................................................................................................ 11
Overview of NRC Actions after 9/11............................................................................................. 11
Contacts
Author Contact Information........................................................................................................... 12
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Overview of Reactor Security
Physical security at nuclear power plants involves the threat of radiological sabotage—a
deliberate act against a plant that could directly or indirectly endanger public health and safety
through exposure to radiation. The Nuclear Regulatory Commission (NRC) establishes security
requirements at U.S. commercial nuclear power plants based on its assessment of plant
vulnerabilities to, and the consequences of, potential attacks. The stringency of NRC’s security
requirements and its enforcement program have been a significant congressional issue, especially
since the September 11, 2001, terrorist attacks on the United States.
While NRC establishes security requirements within the boundaries of commercial nuclear sites,
the Department of Homeland Security (DHS) has broad responsibility for coordinating
government-wide efforts to prevent and respond to terrorist attacks, including attacks on nuclear
power plants. DHS works with NRC and other agencies to protect nuclear facilities and other
critical infrastructure.1
Nuclear plant security measures are designed to protect three primary areas of vulnerability:
controls on the nuclear chain reaction, cooling systems that prevent hot nuclear fuel from melting
even after the chain reaction has stopped, and storage facilities for highly radioactive spent
nuclear fuel. U.S. plants are designed and built to prevent dispersal of radioactivity, in the event
of an accident, by surrounding the reactor in a steel-reinforced concrete containment structure.
However, as the March 2011 Fukushima accident in Japan demonstrated, reactor containments
cannot completely block radioactive releases under the most severe circumstances.
NRC requires commercial nuclear power plants to have a series of physical barriers and a trained
security force, under regulations already in place prior to the 9/11 attacks (10 C.F.R. 73—Physical
Protection of Plants and Materials). The plant sites are divided into three zones: an “owner-
controlled” buffer region, a “protected area,” and a “vital area.” Access to the protected area is
restricted to a portion of plant employees and monitored visitors, with stringent access barriers.
The vital area is further restricted, with additional barriers and access requirements. The security
force must comply with NRC requirements on pre-hiring investigations and training.2
A fundamental concept in NRC’s physical security requirements is the design basis threat (DBT),
which establishes the severity of the potential attacks that a nuclear plant’s security force must be
capable of repelling. The DBT includes such characteristics as the number of attackers, their
training, and the weapons and tactics they could use. Specific details are classified. Critics of
nuclear plant security have contended that the DBT should be strengthened to account for
potentially larger and more sophisticated terrorist attacks.
Reactor vulnerability to deliberate aircraft crashes has also been a major concern since 9/11. Most
existing nuclear power plants were not specifically designed to withstand crashes from large
jetliners, although analyses differ as to the damage that could result. NRC has determined that
commercial aircraft crashes are beyond the DBT but published regulations in June 2009 to require
1 Homeland Security Presidential Directive 7: Critical Infrastructure Identification, Prioritization, and Protection,
December 17, 2003, http://www.dhs.gov/xabout/laws/gc_1214597989952.shtm#1.
2 General NRC requirements for nuclear power plant security can be found in 10 C.F.R. 73.55.
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that new reactor designs be able to withstand such crashes without releasing radioactivity.
Nuclear power critics have called for retrofits of existing reactors as well.
Since the 9/11 attacks, NRC and Congress have taken action to increase nuclear power plant
security. NRC issued a series of security measures beginning in 2002, including a strengthening
of the DBT and establishing the Office of Nuclear Security and Incident Response (NSIR). The
office centralizes security oversight of all NRC-regulated facilities, coordinates with law
enforcement and intelligence agencies, and handles emergency planning activities. In 2004, NRC
implemented a program to conduct “force on force” security exercises overseen by NSIR at each
nuclear power plant at least every three years. The Energy Policy Act of 2005 (P.L. 109-58)
required NRC to further strengthen the DBT, codified the force-on-force program, and established
a variety of additional nuclear plant security measures. In March 2009, NRC published a series of
security regulations that require power plants to prepare cybersecurity plans, develop strategies
for dealing with the effects of aircraft crashes, strengthen access controls, improve training for
security personnel, and take other new security measures.
Design Basis Threat
The design basis threat describes general characteristics of adversaries that nuclear plants and
nuclear fuel cycle facilities must defend against to prevent radiological sabotage and theft of
strategic special nuclear material. NRC licensees use the DBT as the basis for implementing
defensive strategies at specific nuclear plant sites through security plans, safeguards contingency
plans, and guard training and qualification plans.
General requirements for the DBT are prescribed in NRC regulations,3 while specific attributes of
potential attackers, such as their weapons and ammunition, are contained in classified adversary
characteristics documents (ACDs).
Fundamental policies on nuclear plant security threats date back to the Cold War. In 1967, the
Atomic Energy Commission (AEC) instituted a rule that nuclear plants are not required to protect
against an attack directed by an “enemy of the United States.”4 That so-called “Enemy of the
State Rule” specifies that nuclear power plants are
not required to provide for design features or other measures for the specific purpose of
protection against the effects of (a) attacks and destructive acts, including sabotage, directed
against the facility by an enemy of the United States, whether a foreign government or other
person, or (b) use or deployment of weapons incident to U.S. defense activities.5
The Nuclear Regulatory Commission (NRC), the AEC’s successor regulatory agency, says that
the rule “was primarily intended to make clear that privately-owned nuclear facilities were not
responsible for defending against attacks that typically could only be carried out by foreign
3 10 C.F.R. §73.1.
4 It was feared that Cuba might launch an attack on Florida reactors. Government Accountability Office, Nuclear
Power Plants—Efforts Made to Upgrade Security, but the Nuclear Regulatory Commission’s Design Basis Threat
Process Should Be Improved (GAO-06-388), March 2006, p. 2. Regulations at 10 CFR 50.13.
5 10 C.F.R. §50.13. Attacks and destructive acts by enemies of the United States; and defense activities.
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military organizations.”6 NRC’s initial DBT, established in the late 1970s, was intended to be
consistent with the enemy of the state rule, which remains in effect.
However, the 9/11 attacks drew greater attention to the potential severity of credible terrorist
threats. Following the attacks, NRC evaluated the extent to which nuclear plant security forces
should be able to defend against such threats, and ordered a strengthening of the DBT, along with
other security measures, on April 29, 2003. That order changed the DBT to “represent the largest
reasonable threat against which a regulated private guard force should be expected to defend
under existing law,” according to the NRC announcement.7
In the Energy Policy Act of 2005 (EPACT05), Congress imposed a statutory requirement on the
NRC to initiate rulemaking for revising the design basis threat.8 EPACT05 required NRC to
consider 12 factors in revising the DBT, such as an assessment of various terrorist threats, the
potential use of substantial explosive devices and modern weapons, attacks by persons with
sophisticated knowledge of facility operations, and attacks on spent fuel shipments.
NRC approved its final rule amending the DBT (10 C.F.R. Part 73.1) on January 29, 2007,
effective April 18, 2007.9 Although specific details of the revised DBT were not released to the
public, in general the final rule
• clarifies that physical protection systems are required to protect against diversion
and theft of fissile material;
• expands the assumed capabilities of adversaries to operate as one or more teams
and attack from multiple entry points;
• assumes that adversaries are willing to kill or be killed and are knowledgeable
about specific target selection;
• expands the scope of vehicles that licensees must defend against to include water
vehicles and land vehicles beyond the four-wheel-drive type;
• revises the threat posed by an insider to be more flexible in scope; and
• adds a new mode of attack from adversaries coordinating a vehicle bomb assault
with another external assault.
The DBT final rule excluded aircraft attacks as beyond the reasonable responsibility of a private
security force, a decision that raised considerable controversy. In approving the rule, NRC
rejected a petition from the Union of Concerned Scientists to require that nuclear plants be
surrounded by aircraft barriers made of steel beams and cables (the so-called “beamhenge”
concept). Critics of NRC’s final rule charged that deliberate aircraft crashes were a highly
plausible mode of attack, given the events of 9/11. However, NRC contended that power plants
were already required to mitigate the effects of aircraft crashes and that “active protection against
6 Nuclear Regulatory Commission, “Design Basis Threat,” 72 Federal Register 12714, March 19, 2007.
7 Federal Register, May 7, 2003 (vol. 68, no. 88). NRC, All Operating Power Reactor Licensees; Order Modifying
Licenses.
8 P.L. 109-58, Title VI, Subtitle D—Nuclear Security (Sections 651-657). Section 651 adds Atomic Energy Act Section
170E. Design Basis Threat Rulemaking.
9 Federal Register, March 19, 2007 (vol. 72, no. 52), NRC, Design Basis Threat, Final Rule, pp. 12705-12727.
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airborne threats is addressed by other federal organizations, including the military.”10 Additional
NRC action on aircraft threats is discussed in the next section.
NRC Commissioners in January 2009 rejected a proposal by the NRC staff to strengthen the
classified portion of the DBT to include additional capabilities by potential attackers, according to
news reports. The staff proposal lost in a 2-2 vote, with one commissioner position vacant. In an
interview afterward, NRC Chairman Dale Klein said the vote could be reconsidered after
completion of an ongoing interagency study.11 Critics contend that the DBT excludes major types
of weapons used by terrorists, such as rocket-propelled grenades, and is generally not based on
the maximum credible threat identified by the intelligence community.12
Critics of NRC’s security regulations also have pointed out that licensees are required to employ
only a minimum of 10 security personnel on duty per plant, which they argue is not enough for
the job.13 Nuclear spokespersons have responded that the actual security force for the nation’s 65
nuclear plant sites numbers more than 5,000, an average of about 75 per site (covering multiple
shifts). The industry also points out that nuclear plants all have integrated communications and
emergency response plans that include local, state, and federal security forces. The integrated
response by outside security forces is intended to handle attacks that might overwhelm an
individual plant’s security force.14
Large Aircraft Crashes
Nuclear power plants were designed to withstand hurricanes, earthquakes, and other extreme
events. But deliberate attacks by large airliners loaded with fuel, such as those that crashed into
the World Trade Center and Pentagon, were not analyzed when design requirements for today’s
reactors were determined.15 Concern about aircraft crashes was intensified by a taped interview
shown September 10, 2002, on the Arab TV station al-Jazeera, which contained a statement that
Al Qaeda initially planned to include a nuclear plant in its list of 2001 attack sites.
In light of the possibility that an air attack might penetrate the containment structure of a nuclear
plant or a spent fuel storage facility, some interest groups have suggested that such an event could
be followed by a meltdown or spent fuel fire and widespread radiation exposure. Nuclear industry
spokespersons have countered by pointing out that relatively small, low-lying nuclear power
plants are difficult targets for attack, and have argued that penetration of the containment is
unlikely, and that even if such penetration occurred it probably would not reach the reactor vessel.
Fires and explosions caused by an aircraft crash outside the reactor containment could disable
10 NRC, “NRC Approves Final Rule Amending Security Requirements,” News Release No. 07-012, January 29, 2007.
11 Jeff Beattie, “NRC Chairman Questions Case for Tougher DBT,” Energy Daily, February 17, 2009, p. 1.
12 Edwin S. Lyman, “Security Since September 11th,” Nuclear Engineering International, March 2010, pp. 14-19.
13 10 C.F.R. 73.55 (k)(5)(ii) states: “The number of armed responders shall not be less than ten (10).” The previous
requirement, in 10 C.F.R. 73.55 (h)(3), stated: “The total number of guards, and armed, trained personnel immediately
available at the facility to fulfill these response requirements shall nominally be ten (10), unless specifically required
otherwise on a case by case basis by the Commission; however, this number may not be reduced to less than five (5)
guards.” The change was made in NRC final regulations published in March 2009, op. cit.
14 Doug Walters, “Security Since March,” Nuclear Engineering International, May 2010.
15 Meserve, Richard A., NRC Chairman, “Research: Strengthening the Foundation of the Nuclear Industry,” Speech to
Nuclear Safety Research Conference, October 29, 2002.
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systems required to cool the reactor core and spent fuel pools, and post-9/11 NRC regulations
require nuclear plants to be able to mitigate such effects. According to former NRC Chairman
Nils Diaz, NRC studies, which have not been released, “confirm that the likelihood of both
damaging the reactor core and releasing radioactivity that could affect public health and safety is
low.”16 However, groups critical of nuclear power consider NRC’s mitigation requirements for
fires and explosions to be insufficient to protect against aircraft crashes.17
NRC proposed in October 2007 to amend its regulations to require newly designed power
reactors to take into account the potential effects of the impact of a large commercial aircraft. 18
As discussed in the previous section, NRC considers an aircraft attack to be beyond the design
basis threat that plants must be able to withstand, so the requirements of the proposed rule were
intended to provide an additional margin of safety. The proposed rule was drafted to affect only
new reactor designs not previously certified by NRC, because the previous designs were still
considered adequately safe. Nevertheless, Westinghouse submitted changes in the certified design
of its AP1000 reactor to NRC on May 29, 2007, proposing to line the inside and outside of the
reactor’s concrete shield building with steel plates to increase resistance to aircraft penetration.19
Under NRC’s 2007 proposed rule, applicants for new certified designs or for new reactor licenses
using uncertified designs would have been required to assess the effects that a large aircraft crash
would have on the proposed facilities. Each applicant would then describe how the plant’s design
features, capabilities, and operations would avoid or mitigate the effects of such a crash,
particularly on core cooling, containment integrity, and spent fuel storage pools.
In response to comments, the NRC staff proposed in October 2008 that the aircraft impact
assessments be conducted by all new reactors, including those using previously certified
designs.20 The NRC Commissioners, in a 3-1 vote, approved the change February 17, 2009, 21 and
it was published in the Federal Register June 12, 2009.22 The new rule added specific design
requirements that all new reactors must meet:
Each applicant subject to this section shall perform a design-specific assessment of the
effects on the facility of the impact of a large, commercial aircraft. Using realistic analyses,
the applicant shall identify and incorporate into the design those design features and
functional capabilities to show that, with reduced use of operator actions:
(A) the reactor core remains cooled, or the containment remains intact; and
16 Letter from NRC Chairman Nils J. Diaz to Secretary of Homeland Security Tom Ridge, September 8, 2004.
17 Committee to Bridge the Gap, Nuclear Information and Resource Service, and Public Citizen, “NRC Votes Against
Requiring Reactors to be Protected from Air Attacks or Large Numbers of Attackers,” press release, January 29, 2007,
http://www.committeetobridgethegap.org/pressrelease/012907release.html.
18 Federal Register, October 3, 2007 (vol. 72, no. 191), Consideration of Aircraft Impacts for New Nuclear Power
Reactor Designs.
19 MacLachlan, Ann, “Westinghouse Changes AP1000 Design to Improve Plane Crash Resistance,” Nucleonics Week,
June 21, 2007.
20 Nuclear Regulatory Commission, Final Rule—Consideration of Aircraft Impacts for New Nuclear Power Reactors,
Rulemaking Issue Affirmation, SECY-08-0152, October 15, 2008.
21 Nuclear Regulatory Commission, Final Rule—Consideration of Aircraft Impacts for New Nuclear Power Reactors,
Commission Voting Record, SECY-08-0152, February 17, 2009.
22 Nuclear Regulatory Commission, Consideration of Aircraft Impacts for New Nuclear Power Reactors, Final Rule, 74
Federal Register 28111, June 12, 2009. This provision is codified at 10 CFR 50.150.
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(B) spent fuel cooling or spent fuel pool integrity is maintained.
As noted above, NRC rejected proposals that existing reactors—in addition to new reactors—be
required to protect against aircraft crashes, such as by adding “beamhenge” barriers. NRC
determined that damage from aircraft crashes at existing reactors would be sufficiently mitigated
by measures that had already been required by all reactors. In 2002, NRC ordered all nuclear
power plants to develop strategies to mitigate the effects of large fires and explosions that could
result from aircraft crashes or other causes.23 As part of a broad security rulemaking effort, NRC
proposed in October 2006 to incorporate the 2002 order on fire and explosion strategies into its
security regulations (10 CFR Part 73).24 In response to comments, NRC published a supplemental
proposed rule in April 2008 to move the fire and explosion requirements into its reactor licensing
regulations at 10 CFR Part 50, along with requirements that reactors establish procedures for
responding to specific aircraft threat notifications.25 Those regulations received final approval by
the NRC Commissioners December 17, 2008,26 and were published in the Federal Register March
27, 2009.27 A key provision in the new rule states:
Each licensee shall develop and implement guidance and strategies intended to maintain or
restore core cooling, containment, and spent fuel pool cooling capabilities under the
circumstances associated with loss of large areas of the plant due to explosions or fire, to
include strategies in the following areas:
(i) Fire fighting;
(ii) Operations to mitigate fuel damage; and
(iii) Actions to minimize radiological release.28
Spent Fuel Storage
When no longer capable of efficiently sustaining a nuclear chain reaction, highly radioactive
“spent” nuclear fuel is removed from the reactor and stored in a pool of water in the reactor
building and at many sites later transferred to dry casks on the plant grounds. Because both types
of storage are located outside the reactor containment structure, particular concern has been raised
about the vulnerability of spent fuel to attack by aircraft or other means. If terrorists could breach
a spent fuel pool’s concrete walls and drain the cooling water, or disable cooling systems so that
cooling water evaporated, the spent fuel’s zirconium cladding could overheat and catch fire.
23 Nuclear Regulatory Commission, Final Rule—Consideration of Aircraft Impacts for New Nuclear Power Reactors,
Rulemaking Issue Affirmation, SECY-08-0152, October 15, 2008, p. 2.
24 Nuclear Regulatory Commission, “Power Reactor Security Requirements, Proposed Rule,” 71 Federal Register
62664, October 26, 2006.
25 Nuclear Regulatory Commission, “Power Reactor Security Requirements, Supplemental Proposed Rule,” 73 Federal
Register 19443, April 10, 2008.
26 Nuclear Regulatory Commission, “NRC Approves Final Rule Expanding Security Requirements for Nuclear Power
Plants,” press release, December 17, 2008, http://www.nrc.gov/reading-rm/doc-collections/news/2008/08-227.html.
27 Nuclear Regulatory Commission, Power Reactor Security Requirements, Final Rule, 74 Federal Register 13925,
March 27, 2009.
28 10 CFR 50.54(hh)(2).
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The National Academy of Sciences (NAS) released a report in April 2005 that found that
“successful terrorist attacks on spent fuel pools, though difficult, are possible,” and that “if an
attack leads to a propagating zirconium cladding fire, it could result in the release of large
amounts of radioactive material.” NAS recommended that the hottest spent fuel be interspersed
with cooler spent fuel to reduce the likelihood of fire, and that water-spray systems be installed to
cool spent fuel if pool water were lost. The report also called for NRC to conduct more analysis
of the issue and consider earlier movement of spent fuel from pools into dry storage.29
NRC agreed with some of findings of the NAS study but disagreed in several areas. In a report to
Congress in response to the NAS report, NRC stated:
In summary, the NRC believes based on information developed in NRC vulnerability
assessments, that the Committee has identified some scenarios that are unreasonable. The
NRC also disagrees with some NAS recommendations and its conclusion lacks a sound
technical basis. The NAS finding that earlier movement of spent fuel from pools into dry
storage would be prudent is one such example.30
NRC conducted the site-specific analyses recommended by NAS with funding provided by the
FY2006 Energy and Water Development Appropriations Act (P.L. 109-103, H.Rept. 109-275).
NRC’s March 2009 regulations cited above include “spent fuel pool cooling capabilities” as a
function that must be addressed by nuclear plants’ mitigation strategies for large fires and
explosions. Protection of spent fuel cooling also is included in the design requirements for new
reactors under NRC’s June 2009 aircraft impact regulations.
NRC has long contended that the potential effects of terrorist attacks are not “reasonably
foreseeable” impacts that must be included in environmental studies for proposed spent fuel
storage and other nuclear facilities. However, the U.S. Court of Appeals for the 9th Circuit ruled in
June 2006 that terrorist attacks must be included in the environmental study of a dry storage
facility at California’s Diablo Canyon nuclear plant. NRC reissued the Diablo Canyon study May
29, 2007, to comply with the court ruling, but it did not include terrorism in other recent
environmental studies outside the jurisdiction of the 9th Circuit.31 The U.S. Court of Appeals for
the 3rd Circuit subsequently ruled that NRC did not have to consider the impact of terrorist attacks
in the license renewal application for the Oyster Creek plant in New Jersey.32
Long-term management of spent nuclear fuel is currently undergoing review, but spent fuel stored
at reactor sites is expected to be moved eventually to central storage, permanent disposal, or
reprocessing facilities. (For details, see CRS Report RL33461, Civilian Nuclear Waste Disposal,
by Mark Holt.) Large-scale transportation campaigns would increase public attention to NRC
transportation security requirements and related security issues.
29 National Academy of Sciences, Board on Radioactive Waste Management, Safety and Security of Commercial Spent
Nuclear Fuel Storage, Public Report (online version), released April 6, 2005.
30 U.S. Nuclear Regulatory Commission Report to Congress on the National Academy of Sciences Study on the Safety
and Security of Commercial Spent Nuclear Fuel Storage, March 2005, p. iii, http://www.nrc.gov/reading-rm/doc-
collections/congress-docs/correspondence/2005/domenici-03142005.pdf.
31 Beattie, Jeff, “NRC Takes Two Roads on Terror Review Issue,” Energy Daily, February 27, 2007.
32 U.S. Court of Appeals for the Third Circuit, New Jersey Department of Environmental Protection v. U.S. Nuclear
Regulatory Commission, March 31, 2009, http://www.ca3.uscourts.gov/opinarch/072271p.pdf.
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Force-on-Force Exercises
EPACT05 codified an NRC requirement that each nuclear power plant conduct security exercises
every three years to test its ability to defend against the design basis threat. In these “force-on-
force” exercises, closely monitored and evaluated by NRC, a mock adversary force from outside
the plant attempts to penetrate the plant’s vital area and simulate damage to a “target set” of key
safety components. Actual damage to such components could result in radioactive releases from
the plant. Participants in the tightly controlled exercises carry weapons modified to fire only
blanks and laser bursts to simulate bullets, and they wear laser sensors to indicate hits. Other
weapons and explosives, as well as destruction or breaching of physical security barriers, may
also be simulated. While one squad of the plant’s guard force is participating in a force-on-force
exercise, another squad is also on duty to maintain normal plant security. Plant defenders know
that a mock attack will take place sometime during a specific period of several hours, but they do
not know what the attack scenario will be. Multiple attack scenarios are conducted over several
days of exercises.
Full implementation of the force-on-force program began in late 2004. Standard procedures and
other requirements have been developed for using the force-on-force exercises to evaluate plant
security and as a basis for taking regulatory enforcement action. Many tradeoffs are necessary to
make the exercises as realistic and consistent as possible without endangering participants or
regular plant operations and security.
NRC required the nuclear industry to develop and train, under NRC standards, a “composite
adversary force” comprising security officers from many plants to simulate terrorist attacks in all
force-on-force exercises conducted after October 2004. However, in September 2004 testimony,
the Government Accountability Office (GAO) criticized the industry’s selection of Wackenhut
(now G4S Regulated Security Solutions), a security company that guards many U.S. nuclear
plants, to manage the adversary force, including non-Wackenhut employees. In addition to raising
“questions about the force’s independence,” GAO noted that Wackenhut had been accused of
cheating on previous force-on-force exercises by the Department of Energy.33 Exelon terminated
its security contracts with Wackenhut in late 2007 after guards at the Peach Bottom reactor in
York County, Pennsylvania, were discovered sleeping while on duty.34
EPACT05 requires NRC to “mitigate any potential conflict of interest that could influence the
results of a force-on-force exercise, as the Commission determines to be necessary and
appropriate.” NRC prohibits officers in the adversary force from participating in exercises at their
home plants. As in previous years, NRC’s 2010 annual security report to Congress found that the
industry adversary teams “continued to meet expectations for a credible, well-trained, and
consistent mock adversary force.”35
33 GAO. “Nuclear Regulatory Commission: Preliminary Observations on Efforts to Improve Security at Nuclear Power
Plants.” Statement of Jim Wells, Director, Natural Resources and Environment, to the Subcommittee on National
Security, Emerging Threats, and International Relations, House Committee on Government Reform. September 14,
2004. p. 14.
34 Washington Post, “Executive Resigns in Storm Over Sleeping Guards,” January 10, 2008.
35 Nuclear Regulatory Commission, Office of Nuclear Security and Incident Response, Report to Congress on the
Security Inspection Program for Commercial Power Reactor and Category 1 Fuel Cycle Facilities: Results and Status
Update; Annual Report for Calendar Year 2010, NUREG-1885, Rev. 3, June 2011, p. 8, http://www.nrc.gov/reading-
rm/doc-collections/nuregs/staff/sr1885/r4/sr1885r4.pdf.
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Through calendar year 2010, NRC had completed the second three-year cycle of force-on-force
exercises at the 64 U.S. nuclear plant sites.36 From the start of the program in 2004 through 2010,
136 force-on-force inspections were conducted, with each inspection typically including three
mock attacks by the adversary force. During the 136 inspections, 10 complete target sets were
simulated to be damaged or destroyed, indicating inadequate protection against the DBT, and
additional security measures were promptly implemented, according to NRC. The inspections
resulted in a total of 72 findings of security deficiencies, 58 of which were of relatively low
significance. Follow-up force-on-force exercises are sometimes conducted to verify that the
necessary security improvements have been made.37
Emergency Preparedness and Response
After the 1979 accident at the Three Mile Island nuclear plant near Harrisburg, PA, Congress
required that all nuclear power plants be covered by emergency plans. NRC requires each plant to
have an Emergency Planning Zone (EPZ) with an approximately 10-mile radius. Within the
emergency EPZ, the plant operator must maintain warning sirens or other systems and regularly
conduct emergency preparedness exercises evaluated by NRC and the Federal Emergency
Management Agency (FEMA).
In light of heightened concern about terrorist attacks since 9/11, proposals have been made to
expand the EPZ to include larger population centers. NRC determined that the 10-mile EPZ
remained adequate, but it issued a bulletin in July 2005 identifying enhancements for emergency
response plans in the case of “security-based events at a nuclear power plant.”38
The potential release of radioactive iodine during a nuclear incident is a particular concern,
because iodine tends to concentrate in the thyroid gland of persons exposed to it. Emergency
plans in many states include distribution of iodine pills to the population within the EPZ. Taking
non-radioactive iodine before exposure would prevent absorption of radioactive iodine but would
afford no protection against other radioactive elements. In 2002, NRC began providing iodine
pills to states requesting them for populations within the 10-mile EPZ.
NRC completed one of its final regulatory responses to the 9/11 attacks by issuing wide-ranging
revisions to its emergency preparedness regulations on November 23, 2011. The changes include
requirements that plant staff with emergency duties not have potentially interfering
responsibilities; that hostile actions be included as a type of emergency that requires plant
coordination with local, state, and federal agencies; that emergency plans include protection of
plant personnel from hostile action; and that hostile actions be included in emergency
preparedness drills. Some non-security changes were also included, such as a requirement that
36 NRC generally lists 65 U.S. plant sites, but the adjacent Hope Creek and Salem sites in New Jersey are considered to
be a single site for security exercises. E-mail message from David Decker, NRC Office of Congressional Affairs,
March 13, 2009.
37 NRC Office of Nuclear Security and Incident Response, op. cit.
38 NRC Office of Nuclear Security and Incident Response, Emergency Preparedness and Response Actions for
Security-Based Events, NRC Bulletin 2005-02, July 18, 2005, http://www.nrc.gov/reading-rm/doc-collections/gen-
comm/bulletins/2005/bl200502.pdf.
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evacuation time estimates be updated after every census or whenever major population changes
occur.39
Cybersecurity
Existing U.S. nuclear power reactors, designed in the 1960s and ’70s, are controlled primarily by
analog systems that are resistant to cyberattack. However, new reactors are being designed with
digital controls, and existing analog plants increasingly rely on computers to run auxiliary and
monitoring systems. This increasing use of digital systems in nuclear power plants, along with
post 9/11 security concerns and at least one “worm” infection at a U.S. reactor,40 have prompted
increased NRC attention to cybersecurity.
A year after the 9/11 attacks, NRC issued an order that included cyberattacks among the threats
that nuclear plants would be required to defend against. Additional guidance for dealing with
cyber threats was released during the next several years, and NRC issued formal cybersecurity
regulations in March 2009 (“Protection of Digital Computer and Communications Systems and
Networks,” 10 CFR 73.54). NRC published a regulatory guide for the program in January 2010.41
NRC’s cybersecurity regulations require each nuclear power plant to submit a cybersecurity plan
and implementation schedule. The plan must provide “high assurance” that digital computer and
communications systems that perform the following functions will provide adequate protection
against design basis attacks:
• Functions that are safety-related or important to safety;
• Security functions;
• Emergency preparedness functions, including offsite communications; and
• Support systems and equipment that, if compromised, would adversely affect
safety, security, or emergency preparedness functions.
Nuclear power plants are also required by the Federal Energy Regulatory Commission (FERC) to
comply with cybersecurity standards issued by the North American Electric Reliability
Corporation (NERC). However, nuclear plant computer systems that are covered by NRC
security regulations are exempt from the NERC standards. As a result, the NERC standards apply
mostly to “balance of plant” (non-reactor) systems at nuclear power plants.42
39 NRC, “Enhancements to Emergency Preparedness Regulations,” final rule, Federal Register, November 23, 2011, p.
72560.
40 Kesler, Brent, “The Vulnerability of Nuclear Facilities to Cyber Attack,” Strategic Insights, spring 2001, p. 15,
http://www.nps.edu/Academics/Centers/CCC/Research-Publications/StrategicInsights/2011/Apr/SI-v10-i1_Kesler.pdf.
41 NRC, “Cyber Security Programs for Nuclear Facilities,” Regulatory Guide 5.71, January 2010,
http://pbadupws.nrc.gov/docs/ML0903/ML090340159.pdf.
42 Federal Energy Regulatory Commission, “Mandatory Reliability Standards for Critical Infrastructure Protection:
Order Addressing Compliance Filing and Approving Implementation Plan,” Docket No. RM06-22-011, March 18,
2010, http://www.nerc.com/files/CIP_ImplementationOrder-03182010.pdf.
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Plant Security Personnel
After video recordings of inattentive security officers at the Peach Bottom (PA) nuclear power
plant were aired on local television, an NRC inspection in late September 2007 confirmed that
there had been multiple occasions on which multiple security officers were inattentive.43
However, after a follow-up inspection into security issues at the Peach Bottom plant, run by
Exelon Nuclear, the NRC concluded that the plant’s security program had not been significantly
degraded as a result of the guards’ inattentiveness. NRC issued a bulletin December 12, 2007,
requiring all nuclear power plants to provide written descriptions of their “managerial controls to
deter and address inattentiveness and complicity among licensee security personnel.”44
The incident drew harsh criticism from the House Committee on Energy and Commerce. “The
NRC’s stunning failure to act on credible allegations of sleeping security guards, coupled with its
unwillingness to protect the whistleblower who uncovered the problem, raises troubling
questions,” said Representative John D. Dingell, then-Chairman of the Committee.45 NRC
proposed a $65,000 fine on Exelon Nuclear on January 6, 2009.46 NRC modified its standards for
plant security personnel in a major revision of its security regulations published March 27, 2009
(discussed in the next section).
Overview of NRC Actions after 9/11
Following the 9/11 terrorist attacks, NRC conducted a “top-to-bottom” review of its nuclear
power plant security requirements. On February 25, 2002, the agency issued “interim
compensatory security measures” to deal with the “generalized high-level threat environment”
that continued to exist, and on January 7, 2003, it issued regulatory orders that tightened nuclear
plant access. On April 29, 2003, NRC issued orders to restrict security officer work hours,
establish new security force training and qualification requirements, and increase the DBT that
nuclear security forces must be able to defend against, as discussed previously.
In October 2006, NRC proposed to amend the security regulations and add new security
requirements that would codify the series of orders issued after 9/11 and respond to requirements
in the Energy Policy Act of 2005.47 The new security regulations were approved by the NRC
Commissioners on December 17, 2008, and published March 27, 2009:48
• Safety and Security Interface. Explicit requirements were established for nuclear
plants to ensure that necessary security measures do not compromise plant safety.
43 NRC, NRC Commences Follow-up Security Inspection at Peach Bottom, November 5, 2007, http://www.nrc.gov/
reading-rm/doc-collections/news/2007/07-057.i.html.
44 NRC, Security Officer Attentiveness, NRC Bulletin 2007-1, Washington, DC, December 12, 2007.
45 Committee on Energy and Commerce, Energy and Commerce Committee to Probe Breakdowns in NRC Oversight,
January 7, 2008 http://energycommerce.house.gov/Press_110/110nr149.shtml.
46 NRC, “NRC Proposes $65,000 Fine for Violations Associated with Inattentive Security Guards at Peach Bottom
Nuclear Plant,” press release, January 6, 2009, http://www.nrc.gov/reading-rm/doc-collections/news/2009/09-
001.i.html.
47 Federal Register, October 26, 2006 (vol. 71, no. 207), NRC, Power Reactor Security Requirements, Proposed Rule.
48 Federal Register, March 27, 2009, op. cit.
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• Mixed-Oxide Fuel. Enhanced physical security requirements were established to
prevent theft or diversion of plutonium-bearing mixed-oxide (MOX) fuel.
• Cybersecurity. Nuclear plants must submit security plans that describe how
digital computer and communications systems and safety-related networks are
protected from cyberattacks, as discussed in the cybersecurity section above.
• Aircraft Attack Mitigative Strategies and Response. As discussed in the earlier
section on vulnerability to aircraft crashes, nuclear plants must prepare strategies
for responding to warnings of an aircraft attack and for mitigating the effects of
large explosions and fires.
• Plant Access Authorization. Nuclear plants must implement more rigorous
programs for authorizing access, including enhanced psychological assessments
and behavioral observation.
• Security Personnel Training and Qualification. Modifications to security
personnel requirements include additional physical fitness standards, increased
minimum qualification scores for mandatory personnel tests, and requirements
for on-the-job training.
• Physical Security Enhancements. New requirements are intended to ensure the
availability of backup security command centers, uninterruptible power supplies
to detection systems, enhanced video capability, and protection from waterborne
vehicles.
A proposal by NRC staff to release more details about the results of nuclear plant security
inspections was defeated by the NRC Commissioners in a 2-2 vote on January 21, 2009. Under
current policy, NRC announces after a security inspection whether any violations that were found
were of low safety significance or moderate-or-higher safety significance. Critics of the current
policy contend that the public needs more detail to be assured of plant security. The policy’s
supporters counter that greater information about security inspection findings could inadvertently
provide useful information to terrorists.49
Author Contact Information
Mark Holt
Anthony Andrews
Specialist in Energy Policy
Specialist in Energy and Defense Policy
mholt@crs.loc.gov, 7-1704
aandrews@crs.loc.gov, 7-6843
49 Jenny Weil, “Commissioners Reach Stalemate on Security-Related Amendment,” Inside NRC, February 2, 2009.
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