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NRC Should Strengthen Reactor Security Requirements

UCS Comments on NRC Rulemaking

The 9/11 tragedy prompted the Nuclear Regulatory Commission (NRC) to undertake a "top to bottom" review of security requirements for nuclear power plants. As this review progressed, the NRC issued a series of orders requiring plant owners to upgrade security. The NRC ordered plant owners to implement interim measures (February 25, 2002), improve access controls (January 7, 2003), defend against an upgraded design basis threat, provide security force personnel with better training, and impose working hour limits on security force personnel to protect against impairment caused by fatigue (April 29, 2003), and defend against an updated adversary capability (March 20, 2006).

The NRC then initiated a series of rulemaking efforts to codify the various elements of its post-9/11 security requirements. On October 26, 2006, the NRC published a proposed rule in the Federal Register seeking public comments on the access control and training elements of its orders, along with some related issues.

UCS reviewed the proposed rule and submitted formal comments to the NRC. Our comments included the following:

  • The proposed rule does not comply with the requirements of the Energy Policy Act of 2005;
  • The rule should require that licensees adopt "denial of access" as the fundamental protective strategy for defense against the DBT;
  • The rule should designate a subset of "critical" security implementing procedures that are subject to Commission review and approval; 
  • The proposed rule would allow enhanced weapons to be used, but would not require an insider using an enhanced weapon against the facility to be considered;
  • The proposed rule requires protection against either core damage or spent fuel sabotage, not both;
  • The proposed rule does not close a dangerous loophole in current search requirements for law enforcement personnel and security officers; 
  • The proposed rule allows escorts to take multiple visitors with minimal background checks into protected and vital areas within nuclear power plants, but does not require that the escorts met even minimal physical and visual capabilities;
  • The proposed rule would allow a single escort to take more visitors with minimal background checks into protected areas of nuclear power plants than was specified as an external assault force in the recent design basis threat rulemaking and  would allow literally hundreds of visitors with minimal background checks to be escorted into vital areas;
  • The rule should ensure that security officers with duties other than immediate armed response are not required for protection against the DBT and are not inappropriately credited in force-on-force exercises;
  • The broad exemption of commercial nuclear power reactors using plutonium-containing "MOX fuel assemblies" from requirements for protection of Category I quantities of strategic special nuclear material from theft is technically unsupportable, irresponsible and sets a dangerous precedent.  The draft section §73.55(l) should therefore be removed;
  • The proposed rule could facilitate retaliation by plant owners against workers raising safety or security concerns;
  • The proposed rule would allow individuals known to be escaped felons or on the terrorist list to be escorted into protected and vital areas of nuclear power plants;
  • The proposed rule would require plant owners to report tampering of safety or security equipment, but does not require plant owners to train workers to recognize signs of tampering.

Our full comments, including supporting information for each of these summary comments, can be viewed/downloaded by clicking on the link at the top of the page. 

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