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UCS Comments on NRC's "Design Basis Threat" Rule

The Union of Concerned Scientists (UCS) provided comments regarding the Nuclear Regulatory Commission's (NRC's) proposed rule entitled "Design Basis Threat" in response to the Federal Register notice published on November 7, 2005.

The NRC undertook this rulemaking effort to upgrade the design basis threat (DBT) in the aftermath of the 9/11 attacks. But no one should harbor any illusion that the DBT—in its proposed incarnation—can prevent tomorrow's attack for the very simple reason that it would not have prevented yesterday's attack. It is questionable public policy, at best, and regulatory malfeasance, at worst, for the NRC to take steps in response to a national tragedy that would be virtually useless in preventing a repeat of that tragedy.

UCS has two basic concerns about security at U.S. nuclear facilities in the post-9/11 world that must be addressed in the NRC's DBT rule. First, some of these facilities possess highly-enriched uranium or plutonium, which can be used to make nuclear weapons, and this material is potentially vulnerable to theft by terrorists. Second, nuclear power plants remain too vulnerable to terrorist attacks that could result in the release of significant radiation—far more deadly than any "dirty bomb."

What we find most troubling is that we see little evidence of "outside-the-box" thinking going on in the NRC in response to emerging threats or safety concerns, reflected in the very minimal upgrades to the DBT in this rulemaking. The NRC does not want to question the assumptions they have made because they are afraid of the answers they might get, especially if those answers end up costing the industry more money. But the horrific events of 9/11 provide zero doubt that America's adversaries do not place similar constraints on themselves when plotting attacks. To match the intensity and commitment of the adversaries, the DBT rule must ensure that there is real, not surreal, protection of America's commercial nuclear facilities against both radiological sabotage and theft of weapon-usable materials. UCS detailed the changes to the DBT rule absolutely necessary to prevent the theft of weapon-usable materials and reduce the risk of successful sabotage at a nuclear power plant.


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