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Testimony: 

Before the Subcommittee on National Security, Emerging Threats, and 
International Relations, House Committee on Government Reform: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 2:00 p.m. EDT: 

Tuesday, April 4, 2006: 

Nuclear Power: 

Plants Have Upgraded Security, but the Nuclear Regulatory Commission 
Needs to Improve Its Process for Revising the Design Basis Threat: 

Statement of Jim Wells, Director, Natural Resources and Environment: 

GAO-06-555T: 

GAO Highlights: 

Highlights of GAO-06-555T, a testimony before the Subcommittee on 
National Security, Emerging Threats, and International Relations, 
Committee on Government Reform, House of Representatives: 

Why GAO Did This Study: 

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, regulates and oversees 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 also 
restructured its program for testing security at the plants through 
force-on-force inspections (mock terrorist attacks). This testimony 
addresses the following: (1) the process NRC used to develop the April 
2003 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 efforts to strengthen the conduct of its force-on-force 
inspections. This testimony is based on GAO’s report on security at 
nuclear power plants, issued on March 14, 2006 (GAO-06-388). 

What GAO Found: 

NRC revised the DBT for nuclear power plants using a process that was 
generally logical and well-defined. Specifically, trained threat 
assessment staff made recommendations for changes based on an analysis 
of demonstrated terrorist capabilities. The resulting DBT requires 
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 what an assessment of the terrorist threat called for. 

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 
March 30, 2006, NRC had conducted force-on-force inspections at 27, or 
less than half, of the 65 nuclear power plant sites. 

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 GAO’s report 
provides additional details about the DBT and security at nuclear power 
plants. 

What GAO Recommends: 

In its March 2006 report, GAO recommended 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. 

www.gao.gov/cgi-bin/getrpt?GAO-06-555T. 

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 wellsj@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss our recent work on security of 
the nation's 103 operating commercial nuclear power plants, located at 
65 sites in 31 states. My testimony today is based on our report being 
released today, entitled Nuclear Power Plants: Efforts Made to Upgrade 
Security, but the Nuclear Regulatory Commission's Design Basis Threat 
Process Should Be Improved (GAO-06-388).[Footnote 1] 

As you know, nuclear power plants were among the targets considered in 
the original plan for the September 11, 2001, terrorist attacks. 
Furthermore, according to the Nuclear Regulatory Commission (NRC), 
which regulates and oversees the safe operation and security of nuclear 
power plants, there continues to be a general credible threat of a 
terrorist attack on the nation's commercial nuclear power plants, in 
particular by al Qaeda and like-minded Islamic terrorist groups. Such 
an attack could cause a release of radioactive material and endanger 
public health and safety through exposure to an elevated level of 
radiation. 

To defend against a potential terrorist attack, NRC issues and enforces 
security-related regulations and orders, and nuclear power plant 
licensees implement security measures to meet NRC requirements. In 
particular, NRC formulates a design basis threat (DBT)--the threat that 
plants must defend against--and tests plants' ability to defend against 
the DBT. 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 periodically reviews the 
potential terrorist threat to determine whether to make changes to the 
DBT. Most recently, NRC revised the DBT in April 2003 in response to 
the September 11 terrorist attacks. After revising the DBT, NRC 
required nuclear power plant sites to submit new security plans by 
April 29, 2004, for its review and approval and to implement the 
security described in their new plans by October 29, 2004. In November 
2004, NRC began using its force-on-force inspection program to test 
sites' ability to defend against the revised DBT. This program employs 
mock terrorist attacks as the principal means to test the sites' 
security. 

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 at all times 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 by an "enemy of the United States," 
whether a foreign government or other person.[Footnote 2] 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 works with 
other federal agencies to coordinate an integrated response to a 
terrorist threat or attack on a nuclear power plant. 

Our March 2006 report examined (1) the process NRC used to develop the 
April 2003 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 efforts to strengthen the conduct of its force-on-force 
inspections. For the report, we reviewed documents detailing the 
process NRC used to revise the DBT and interviewed the NRC 
commissioners and staff. We also 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, and we 
reviewed a sample of NRC's baseline and force-on-force inspection 
reports. GAO staff with security expertise accompanied us on our visits 
in order to assist in our review of the sites' security strategies. 
Finally, we observed a total of three force-on-force inspections at two 
other sites. We performed our work from November 2004 through January 
2006 in accordance with generally accepted government auditing 
standards. 

Summary: 

NRC revised the DBT for nuclear power plants using a process that was 
generally logical and well-defined. Specifically, trained threat 
assessment staff made recommendations for changes based on an analysis 
of demonstrated terrorist capabilities. To enhance the predictability 
and consistency of its assessments 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 to evaluate particular terrorist 
capabilities, or "adversary characteristics," for inclusion in the DBT. 
The resulting DBT requires 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. 
The revised DBT 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. 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 the following two principal reasons for these differences: 

* 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 them to be 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. 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, this situation 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. 

* Second, in deciding on the revised DBT, the commissioners largely 
supported the staff's recommendations but also made some significant 
changes. These changes reflected their policy judgments on what is 
reasonable for a private security force to defend against. However, the 
commissioners did not identify explicit criteria for what is and what 
is not reasonable for a private security force to defend against, such 
as the cost of defending against particular adversary characteristics. 
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. Furthermore, instead of providing a 
reason for its decision to remove these weapons, the commission's 
voting record showed that individual commissioners used differing 
criteria and emphasized different factors, such as cost or practicality 
of defensive measures. We believe the absence of reviewable criteria 
reduced the transparency of the decision-making process. 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. In some cases, the 
sites went beyond what NRC required. For example, one site added 
electronic intrusion detection equipment to its outer perimeter, which 
was not required. According to NRC, other sites implemented security 
enhancements similar to what we saw at the sites we visited. Despite 
these considerable efforts, it is too early to conclude that all sites 
are capable of defending against the DBT because, as of March 30, 2006, 
NRC had conducted force-on-force inspections at 27, or less than half, 
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. Most notably, we observed a force-
on-force inspection at a site in which the licensee's performance at 
the time was at best questionable in its ability to defend against the 
DBT. 

NRC has made a number of improvements to its force-on-force inspection 
program. 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, the level of security expertise and training 
among controllers, who observe exercise participants to ensure the 
safety and effectiveness of the exercises, was inconsistent. 

Our report included two recommendations to address the shortcomings in 
the process NRC used to revise the DBT. First, we recommended 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 undue industry influence on 
the threat assessment itself. Second, we recommended 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 
reasonable for a private guard force to defend against. In addition, we 
recommended that NRC continue to evaluate and implement measures to 
further strengthen the force-on-force inspection program. In commenting 
on a draft of our report, NRC commended our efforts to ensure that the 
report was accurate and constructive. NRC also provided additional 
clarifying comments pertaining to the process it used to revise the DBT 
for nuclear power plants. For example, NRC requested that we revise the 
report to explain that it made a deliberate decision to develop the 
revised DBT while simultaneously seeking input from stakeholders in 
order to expedite its response to the September 11, 2001 terrorist 
attacks. We revised the report accordingly. 

Background: 

NRC is an independent agency established by the Energy Reorganization 
Act of 1974 to regulate the civilian use of nuclear materials. It 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 the Department of Homeland 
Security (DHS), the intelligence and law enforcement communities, the 
Department of Energy (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. 

Force-on-force inspections are NRC's performance-based means for 
testing the effectiveness of nuclear power plant security programs. 
These inspections 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 in order to commit radiological sabotage that 
results in an elevated release of radioactive material to the 
environment. NRC also conducts baseline inspections at nuclear power 
plants. During these inspections, security inspectors 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. 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. 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. 

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

The process by which NRC revised the DBT for nuclear power plants was 
generally logical and well defined in that trained threat assessment 
staff made recommendations for changes based on an analysis of 
demonstrated terrorist capabilities. The NRC commissioners evaluated 
the recommendations and considered whether the proposed changes 
constituted characteristics representative of an enemy of the United 
States, or were otherwise not reasonable for a private security force 
to defend against. However, while the final version of the revised DBT 
generally corresponded to the original recommendations of the threat 
assessment staff, some elements did not, which raised questions about 
the extent to which the revised DBT represents the terrorist threat. 

NRC's Process for Revising Its DBT Was Generally Logical and Well 
Defined: 

NRC made its 2003 revisions to the DBT for nuclear power plants using a 
process that the agency has had in place since issuing the first 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. (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.) The staff analyze this information both to 
identify specific references to nuclear power plants and to determine 
what capabilities 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. 

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. The staff use initial screening criteria to exclude 
from further consideration certain adversary characteristics, such as 
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, such as 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. Finally, on 
the basis of their analysis and interaction with intelligence and 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. 

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.[Footnote 3] NRC staff recommendations regarding other 
adversary characteristics also reflected the staff's interpretation of 
intelligence information. For example, the staff considered a range of 
sizes for increasing the vehicle bomb in the revised DBT and ultimately 
recommended a size that was based on an analysis of previous terrorist 
attacks using vehicle bombs. 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. 

In addition to analyzing intelligence information, 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.[Footnote 4] 
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. 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. Despite these differences, both agencies used similar 
intelligence information to derive key aspects of their DBTs. For 
example, both DOE and NRC based the number of attackers on intelligence 
on the size of terrorist cells, and DOE officials told us they used 
intelligence similar to NRC's to derive the number of attackers. 
Likewise, DOE and NRC officials provided us with similar analyses of 
intelligence information on previous terrorist attacks using vehicle 
bombs. DOE and NRC officials also told us that most vehicle bombs used 
in terrorist attacks are smaller than the size of the vehicle bomb in 
NRC's revised DBT. 

Changes to the Threat Assessment Staff's Initial Recommendations Were 
Not Clearly Linked to an Analysis of the Terrorist Threat: 

While NRC followed a generally logical and well-defined process to 
revise the DBT for nuclear power plants, two aspects of the process 
raised a fundamental question--the extent to which the DBT represents 
the terrorist threat as indicated by intelligence data compared with 
the extent to which it represents the threat that NRC considers 
reasonable for the plants to defend against. These two aspects were (1) 
the process NRC used to obtain stakeholder feedback on a draft of the 
DBT and (2) changes made by the commissioners to the NRC staff's 
recommended DBT. 

With regard to the first aspect, the process NRC used to obtain 
feedback from stakeholders, including the nuclear industry, created the 
appearance of industry influence on the threat assessment regarding the 
characteristics of an attack. 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. 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. During this same period, the threat 
assessment staff continued to analyze intelligence information and 
modify the draft DBT. 

In its written comments on the January 2003 draft DBT, the Nuclear 
Energy Institute (NEI), which represents the nuclear power industry, 
objected to a number of the adversary characteristics the NRC staff had 
included. Subsequently, the NRC staff made changes to the draft DBT, 
which they then submitted to the NRC commissioners.[Footnote 5] The 
changes made by the NRC staff--in particular, the size of the vehicle 
bomb and list of weapons that could be used in an attack--reflected 
some (but not all) of NEI's objections. For example, NEI wrote that 
some sites would not be able 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. 
Similarly, NEI argued against the inclusion of certain weapons because 
of the cost of protecting against the weapons. NEI wrote that such 
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 its 
final recommendations to the commissioners, the NRC staff reduced the 
size of the vehicle bomb to the amount NEI had proposed and removed a 
number of weapons NEI had objected to. On the other hand, NRC did not 
make changes that reflected all of the industry's objections. For 
example, 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. 

With regard to the commissioners' review and approval of the NRC 
staff's recommendations, the commissioners largely supported the 
staff's recommendations but 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. Based on such considerations, the commission 
voted to remove two weapons the NRC staff had recommended for inclusion 
in the revised DBT based on its threat assessment. However, the 
document summarizing the commission's decision to approve the revised 
DBT did not provide a reason for excluding these weapons. For example, 
the commission did not indicate whether its decision was based on 
criteria, such as 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. In our view, the lack of such 
criteria reduced the transparency of the commission's decisions to make 
changes to the threat assessment staff's recommendations. 

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 
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. These security enhancements were in 
addition to other measures licensees implemented--such as stricter 
requirements for obtaining physical access to nuclear power plants--in 
response to a series of security orders NRC issued after September 11, 
2001. According to NEI, as of June 2004, the cost of security 
enhancements made since September 11, 2001, for all sites amounts to 
over $1.2 billion. 

To enhance their detection capabilities, the four sites we visited 
installed additional cameras throughout different areas of the sites 
and instituted random patrols in the owner-controlled areas.[Footnote 
6] Furthermore, 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 as well as 
inside the reactor and other buildings. Sites also enhanced their 
ability to respond to an attack by constructing bullet-resistant 
structures at various locations in the protected area or within 
buildings, increasing the minimum number of security officers defending 
the sites at all times, and expanding the amount of training provided 
to them. (See fig. 1 for an example of a bullet-resistant structure.) 
According to NRC, other sites took comparable actions to defend against 
the revised DBT. 

Figure 1: Example of a Bullet-Resistant Structure: 

[See PDF for image] 

[End of figure] 

In addition to adding measures designed to detect, delay, and respond 
to an attack, the licensees at the four sites we visited installed new 
vehicle barrier systems to defend against the larger vehicle bomb in 
the revised DBT. In particular, the licensees designed comprehensive 
systems that included sturdy barriers to (1) prevent a potential 
vehicle bomb from approaching the sites and (2) channel vehicles to 
entrances where security officers could search them for explosives and 
other prohibited items. 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. 

In general, 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. For example, one site with a 
predominantly external strategy installed an intrusion detection system 
in the owner-controlled area so that security officers would be able to 
identify intruders as early as possible. The site was able to install 
such a system because of the large amount of open, unobstructed space 
in the owner-controlled area. In contrast, security managers at another 
site we visited described a protective strategy that combined elements 
of an external strategy and an internal strategy. For example, the site 
identified "choke points"--locations attackers would need to pass 
before reaching their targets--inside the protected area and installed 
bullet-resistant structures at the choke points where officers would be 
waiting to interdict the attackers. 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. 

In addition to the security enhancements we observed, security managers 
at each site described ways in which they had exceeded NRC requirements 
and changes they plan to make as they continue to improve their 
protective strategies. For example, security managers at three of the 
sites we visited 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. Similarly, 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. 

Despite the substantial security improvements we observed at the four 
sites we visited, it is too early to conclude, either from NRC's force- 
on-force or baseline inspections, that all nuclear power plant sites 
are capable of defending against the revised DBT for the following two 
reasons: 

* First, as of March 30, 2006, NRC had completed force-on-force 
inspections at 27 of the 65 sites, and it is not planning to complete 
force-on-force inspections at all sites until 2007, in accordance with 
its 3-year schedule. NRC officials told us that plants have generally 
performed well during force-on-force inspections. However, we observed 
a force-on-force inspection at one site in which the site's ability to 
defend against the DBT was at best questionable. The site's security 
measures appeared impressive and were similar to those we observed at 
other sites. Nevertheless, 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. As a result, NRC decided to 
conduct another force-on-force inspection at the site, which we also 
observed. The site made substantial additional security improvements-- 
at a cost of $37 million, according to the licensee--and NRC concluded 
after the second force-on-force inspection that the site had adequately 
defended against a DBT-style attack. 

* Second, we noted from our review of 18 baseline inspection reports 
and 9 force-on-force inspection reports that sites have encountered a 
range of problems in meeting NRC's security requirements. NRC officials 
told us that all sites have implemented all of the security measures 
described in their new plans submitted in response to the revised DBT. 
However, 12 of the 18 baseline inspection reports and 4 of the 9 force- 
on-force inspection reports we reviewed identified problems or items 
needing correction. For example, during two different baseline 
inspections, NRC found (1) an intrusion detection system in which 
multiple alarms were not functioning properly, making the entire 
intrusion detection system inoperable, according to the site, and (2) 
three examples of failure to properly search personnel entering the 
protected area, which NRC concluded could 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 licensees at these two sites, as well as at the 
other sites where NRC inspection reports noted other problems, took 
immediate corrective actions. 

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. For example, we recommended that NRC conduct the 
inspections more frequently at each site, use laser equipment to better 
simulate attackers' and security officers' weapons, and require the 
inspections to make use of the full terrorist capabilities stated in 
the DBT. Actions NRC has taken that satisfy these recommendations 
include conducting the exercises more frequently at each site (every 3 
years rather than every 8 years), and NRC so far is on track to 
complete the first round of force-on-force inspections on schedule, by 
2007. Furthermore, NRC is using laser equipment to simulate weapons, 
and the attackers in the force-on-force exercise inspections that we 
observed used key adversary characteristics of the revised DBT, 
including the number of attackers, a vehicle bomb, a passive insider, 
and explosives. 

Nevertheless, we identified issues in the force-on-force inspection 
program that could affect the quality of the inspections and that 
continue to warrant NRC's attention. For example, the level of security 
expertise and training among controllers--individuals provided by the 
licensee who observe each security officer and attacker to ensure the 
safety and effectiveness of the exercise--varied in the force-on-force 
inspections we observed. One site used personnel with security 
backgrounds while another site used plant employees who did not have 
security-related backgrounds but who volunteered to help. In its force- 
on-force inspection report for this latter site, NRC concluded that the 
level of controller training contributed to the uncertain outcome of 
the force-on-force exercises, which resulted in NRC's conducting a 
second force-on-force inspection at the site. 

Furthermore, we noted that the force-on-force exercises end when a 
site's security force successfully stops an attack. Consequently, at 
sites that successfully defeat the mock adversary force early in the 
exercise scenario, NRC does not have an opportunity to observe the 
performance of sites' internal security--that is, the strategies sites 
would use to defeat attackers inside the vital area. When we raised 
this issue, NRC officials appeared to recognize the benefit of 
designing the force-on-force inspections to test sites' internal 
security strategies but said that doing so would require further 
consideration of how to implement changes to the force-on-force 
inspections. Based on our observations of three force-on-force 
inspections, other areas where NRC may be able to make further 
improvements included the following: 

* ensuring the proper use of laser equipment; 

* varying the timing of inspection activities, such as the starting 
times of the mock attacks, in order to minimize the artificiality of 
the inspections; 

* ensuring the protection of information about the planned scenarios 
for the mock attacks so that security officers do not obtain knowledge 
that would allow them to perform better than they otherwise would; and: 

* providing complete feedback to licensees on NRC inspectors' 
observations on the results of the force-on-force exercises. 

Mr. Chairman, this completes my prepared statement. I would be happy to 
respond to any questions you or the other Members of the Subcommittee 
may have at this time. 

GAO Contact and Staff Acknowledgments: 

For further information about this testimony, please contact me at 
(202) 512-3841 (or at wellsj@gao.gov). Raymond H. Smith, Jr. (Assistant 
Director), Joseph H. Cook, Carol Herrnstadt Shulman, and Michelle K. 
Treistman made key contributions to this testimony. 

FOOTNOTES 

[1] We also prepared a classified version of our report, which includes 
additional details about the DBT and security at nuclear power plants 
that NRC does not release to the public. For more information on NRC's 
oversight of security at nuclear power plants, see GAO, Nuclear 
Regulatory Commission: Preliminary Observations on Efforts to Improve 
Security at Nuclear Power Plants, GAO-04-1064T (Washington, D.C.: Sept. 
14, 2004); and Nuclear Regulatory Commission: Oversight of Security at 
Commercial Nuclear Power Plants Needs to Be Strengthened, GAO-03-752 
(Washington, D.C.: Sept. 4, 2003). 

[2] 0 C.F.R. § 50.13. 

[3] In this report, "terrorist cell" refers only to terrorists who 
participate in an attack, not those who support but do not participate 
in an attack. 

[4] For further information on the DOE DBT, see GAO, Nuclear Security: 
DOE's Office of the Under Secretary for Energy, Science and Environment 
Needs to Take Prompt, Coordinated Action to Meet the New Design Basis 
Threat, GAO-05-611 (Washington, D.C.: July 15, 2005); and Nuclear 
Security: DOE Needs to Resolve Significant Issues before It Fully Meets 
the New Design Basis Threat, GAO-04-623 (Washington, D.C.: Apr. 27, 
2004). 

[5] The NRC staff submitted their final draft DBT to the commissioners 
for their review and approval in April 2003, together with a summary of 
stakeholder comments. 

[6] The owner-controlled area refers to the land and buildings within 
the site boundary that the owner can limit or allow access to 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.