Security since March

20 May 2010

Since September 11, 2001, the industry has spent $2 billion, and added in the order of 5000 security officers, writes Doug Walters of the Nuclear Energy Institute in response to ‘Security since September 11th’ by Edwin Lyman, NEI March 2010, pp14-19. We are constantly doing exercises and training. We have made upgrades to the security of sites almost every year, or every other year.

When the industry has spent that amount of money, and put in the kind of enhancements that we have, I am not sure that I would say that security upgrades have been slow.

The issue of security of offshore power is not new to us. We are able to deal with that. That has been a known vulnerability, if you will, for a long time. We deal with that from a security perspective.

In terms of aircraft impact analysis, I note that the author references documents that he received from the NRC under a Freedom of Information Act request. The NRC website says that they are not publicly available. [Editor’s note: The NRC has confirmed that we may post them:] But my reaction is that the industry did do aircraft impact assessment, and we have this paper from EPRI that he references, which is publicly available.

With regard to assessment, we looked at commercial aircraft used for domestic travel – I think it was a Boeing 767 we looked at – and we made assumptions about how much fuel it carried, and its speed. We made an assumption that the plane would be perpendicular to the centreline of the containment. The NRC did its own analysis. They did more than one, from what I recall. They did one analysis with similar assumptions to us, and they had similar results. Based on that, we felt that we were on the right track. There were discussions with [former NRC commissioner Edward] McGaffigan, but I am not aware of any discussions in which we asked the NRC to slow down.

The tests were similar, and the results were similar. Having said that, it is true that a bigger plane, going faster, with more fuel, would have had a different result. We looked at a 767 in 2003-4. But do we need to look at the next big plane that comes to market, do we need to redo the analysis because there is a bigger plane? We didn’t think so; we are satisfied with the assessment we have done. We have put in measures to mitigate the effects of those impacts and I think we are pretty comfortable with what we have done in aircraft.

“Do we need to redo the analysis because there is a bigger plane? We didn’t think so; we are satisfied”

We would not agree at all with the statement that some plants are still not fully-prepared to defend against a blast wave. Lyman criticises the number of exception requests. But what happened was that the NRC had pursued a rulemaking to codify enhancements made under security orders. When it was trying to get back into bureaucratic measures, it added some different requirements. Based on that, some folks felt they needed exemptions. Now, some utilities are even going beyond the requirements of the current round.

For example, some sites are moving the protected area. If you look at a particular site, there is an owner-controlled area. As you move in closer to a plant, you come to a sophisticated fencing system. That typically defines the protected area, and in some cases they are moving it out, which gives a licensee more time to interdict if there is a ground-based assault. That is very expensive to do, by the way.

Another criticism I hear is the idea that we are not protecting against the real threat. We have a design-basis threat, and that protects against what we saw on September 11, with 19 attackers, and so on. I would like to make two points. First, security officers at nuclear plants are private citizens, part of a private security force, not a government security force. As a private security force, we have limitations in terms of weaponry, and liability issues, just as I would as a private citizen. While it is easy to criticise us for not protecting against a much larger threat, there are limitations. The NRC has come out stating that the design-basis threat is the largest threat against which a private security force should fight.

Second, we don’t stop there. Regardless of what the threat is, if our security force is overwhelmed, there will be an integrated response. We train with offsite folks, a local sheriff or police force, and they would respond. At a state level, we would see a response from the state police or national guard, and even a federal response depending on the threat. The NRC has directed us to make sure that we train with them, and that we have a communications plan that will be used when we have a situation in which we need an integrated response.

We are required to do an annual exercise every three years at each site. There are 65 sites in the USA, and over a three-year period they all do a force-on-force exercise with a dedicated team of adversaries in a mock attack. The NRC observes and evaluates the site response. But in the off-years, the sites are required to do training, so every shift on the off-years does an annual exercise, and quarterly drills. It struck me that Lyman’s article criticises the fact that plant management were notified months in advance of an exercise. But when we do force-on-force, we do three attacks on subsequent days. Terrorists would not have the luxury to do three attacks and learn from them. We recognise that there is some artificiality in what we do; but on the other hand the inspection programme is robust and as realistic as anything, anywhere.

Author Info:

Doug Walters is NEI vice-president of regulatory affairs

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