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

The process that NRC used to revise its DBT for nuclear power plants was  generally logical and well defined. However, certain elements of the revised DBT, such as  the weapons that attackers could use against a plant, do not correspond to  the staff’s original recommendations for two reasons. 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. NEI argued against the inclusion of a number of weapons. However, according to NRC, the  agency made a deliberate decision as part of the process for revising the  DBT in 2003 to have the threat assessment staff analyze intelligence  information and obtain stakeholder feedback simultaneously, rather than  sequentially, in order to accelerate the process in response to the increase  in the terrorist threat. Nuclear Power Plants Made Substantial Changes to Their Security to Address the Revised DBT, but NRC Inspections Have Uncovered Problems

The four nuclear power plant sites we visited made substantial changes  after the September 11, 2001, attacks and in response to the revised DBT,  including measures to detect, delay, and respond to the increased number  of attackers and to address the increased vehicle bomb size. For example, we had recommended that NRC strengthen the  force-on-force inspections by (1) conducting the inspections more  frequently at each site, (2) using laser equipment to better simulate  attackers’ and security officers’ weapons, and (3) requiring the inspections  to make use of the full terrorist capabilities stated in the DBT, including the  use of an adversary force trained in terrorist tactics. Nevertheless, in observing  three force-on-force inspections and discussing the program with NRC  officials, we noted the following issues that continue to warrant NRC’s  attention:  Problems with laser equipment. At two of the force-on-force inspections we  observed, we noted areas in which “operational security”—the  protection of information about the planned scenarios for the mock  attacks—could be improved. While we recognize that  procedures such as safety walk downs and prepositioning of adversary  teams are necessary to the proper conduct of the force-on-force  inspections, lapses in operational security have the potential to give  security officers knowledge that would allow them to perform better  than they would otherwise and raise questions about whether the force- on-force inspections are a true test of the sites’ protective strategy. Recommendations for Executive Action

To improve the process by which NRC makes future revisions to the DBT  for nuclear power plants, we recommend that the NRC commissioners take  the following two actions:  Assign responsibility for obtaining feedback from the nuclear industry  and other stakeholders on proposed changes to the DBT to an office  within NRC other than the Threat Assessment Section, so that the threat  assessment staff is able to assess the terrorist threat to nuclear power  plants without creating the potential for or appearance of industry  influencing their analysis. The resulting report is substantially the  same as the classified version of the report, with the exception that the  classified version contains additional details about the DBT and security at  nuclear power plants. To review NRC’s progress in strengthening the conduct of force-on-force  inspections, we observed a total of three inspections at two sites.
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, is responsible for regulating and overseeing security at the plants. In April 2003, in response to the terrorist attacks of September 11, 2001, NRC revised the design basis threat (DBT), which describes the threat that plants must be prepared to defend against in terms of the number of attackers and their training, weapons, and tactics. NRC has also restructured its program for testing security at the plants through force-on-force inspections, which consist of mock terrorist attacks. GAO was asked to review (1) the process NRC used to revise the DBT for nuclear power plants, (2) the actions nuclear power plants have taken to enhance security in response to the revised DBT, and (3) NRC's progress in strengthening the conduct of force-on-force inspections at the plants.

What GAO Found

NRC revised the DBT for nuclear power plants using a generally logical and well-defined process in which trained threat assessment staff made recommendations for changes based on an analysis of demonstrated terrorist capabilities. The process resulted in a DBT requiring plants to defend against a larger terrorist threat, including a larger number of attackers, a refined and expanded list of weapons, and an increase in the maximum size of a vehicle bomb. Key elements of the revised DBT, such as the number of attackers, generally correspond to the NRC threat assessment staff's original recommendations, but other important elements do not. For example, the NRC staff made changes to some recommendations after obtaining feedback from stakeholders, including the nuclear industry, which objected to certain proposed changes such as the inclusion of certain weapons. NRC officials said the changes resulted from further analysis of intelligence information. Nevertheless, GAO found that the process used to obtain stakeholder feedback created the appearance that changes were made based on what the industry considered reasonable and feasible to defend against rather than on an assessment of the terrorist threat itself. Nuclear power plants made substantial security improvements in response to the September 11, 2001, attacks and the revised DBT, including security barriers and detection equipment, new protective strategies, and additional security officers. It is too early, however, to conclude that all sites are capable of defending against the DBT because, as of November 1, 2005, NRC had conducted force-on-force inspections at about one-third of the plants. NRC has improved its force-on-force inspections--for example, by conducting inspections more frequently at each site. Nevertheless, in observing three inspections and discussing the program with NRC, GAO noted potential issues in the inspections that warrant NRC's continued attention. For example, a lapse in the protection of information about the planned scenario for a mock attack GAO observed may have given the plant's security officers knowledge that allowed them to perform better than they otherwise would have. A classified version of this report provides additional details about the DBT and security at nuclear power plants.