Table Of Content
The DBT rule has been amended in several significant respects to reflect the current physical, cyber, biochemical, and other terrorist threats. For example, the radiological sabotage DBT has been enhanced to reflect the requirement that the licensees have a capability to defend against attackers with the ability to operate in several modes of attack, including as multiple groups, attacking from multiple entry points. Additionally, in § 73.1(a)(1)(i)(C), the phrase “up to and including” was changed to simply “including” to provide flexibility in defining the range of weapons available to the composite adversary force. However, these limitations on weapons and defensive systems available to private security forces do not undermine the Commission's confidence in those forces to provide adequate protection. The defense of our nation's critical infrastructure is a shared responsibility between the NRC, the DOD, the DHS, Federal and State law enforcement, and other Federal agencies.
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Thus, they suggest that because the proposed rule did not contain specifics of the DBTs, the NRC is free to change the specific requirements without notice to the public, effectively conducting a secret rulemaking in violation of the APA. National Guard, local law enforcement and other non-licensee security personnel already stationed at the owner-controlled boundary or entry portals of some licensee facilities are not part of the licensee workforce and not subject to NRC regulatory authority; hence, they are considered beyond the scope of the DBTs. Typically, these organizations have their own internal screening procedures to determine reliability and trustworthiness. The NRC recognizes that those processes exist and provide an appropriate level of assurance against an insider threat to that organization. Furthermore, first responders, law enforcement, and National Guard personnel are not given unescorted access to the Protected Area (PA).
Grid Security News
The IAEA trains experts from numerous countries on using DBT and RTS by providing practical workshops. Using examples of potential physical and cyber threats, scenarios, and case studies, as well as interactive exercises based on a hypothetical nuclear facility, the workshops allow the IAEA to assist participants build their capacity in nuclear security. Attendees, therefore, gain experience in how to adapt the methodologies outlined in the guidance to their national specificities and consider situations beyond their national borders.
Group III: Out of Scope Comments
“The nuclear security measures a country adapts should always correspond to the threat posed to nuclear and other radioactive materials. The revised guidance provides a specific methodology for identifying physical and computer security threats applicable to both nuclear and other radioactive materials. On the basis of this updated methodology, the IAEA can tailor bespoke assistance focussing on a country’s specific needs and available resources,” said Kristof Horvath, Head of the IAEA’s Nuclear Material Security Unit.
V. Guidance
The NRC FOF exercise program is designed to provide a realistic evaluation of the proficiency of licensee security forces against a threat consistent with the supplemented DBTs reflected in the orders issued by the Commission on April 29, 2003. After the attacks of September 11, 2001, the agency has expanded and refined its FOF program to make the exercises more realistic. These changes have significantly increased the level of complexity for each exercise in terms of planning, preparation, and logistical support. It should also be noted that most RTRs possess limited quantities of nuclear material on-site, and that the nature and form of this material is not easily dispersed or handled. As a result, the NRC has determined that RTRs pose a relatively low risk to public health and safety from potential radiation exposure and has tailored the security requirements and oversight for these facilities consistent with their relatively low risk.
Threat based training
The NRC believes that individual fire protection exemptions have had a small impact on plant risk. The NRC agrees that a credible, well-trained, and consistent mock adversary force is vital to the NRC's FOF program. Therefore, the NRC has worked with the nuclear industry to develop a composite adversary force (CAF) that is trained to the standards issued by the Commission.
Suite of Tools for the Analysis of Risk (STAR) Fact Sheet
Furthermore, transportation of the MOX fuel assemblies to Catawba will be done by the Department of Energy's (DOE's) Office of Secure Transportation, that has legal responsibility for the MOX fuel assemblies until custody is transferred to the licensee. Afterwards, the spent MOX fuel is cooled and stored like other spent fuel on site and is subject to the radiological sabotage DBT while stored in the spent fuel pool inside the Protected Area of the plant. NNSA’s security risk management philosophy is based on establishing and maintaining a graded approach and defense-in-depth safeguards. The DBT policy the team developed is designed to represent a set of goals for the planning and implementation of Departmental safeguards and security programs for the next three to five years. Developing a series of DBTs can help ensure that grid planners have a reasonable basis to plan for blackstart to rapidly recover from successful attacks.
Changing the guidance in the ACDs or RGs based on changes to the threat environment would not change the requirements of the rule. Finally, in early March 2006, the NRC hosted an Interagency Aircraft Attack Tabletop Exercise at NRC Headquarters. The purpose of the exercise was to explore Federal responsibilities and interfaces, consistent with the National Infrastructure Protection Plan and National Response Plan, for terrorist incidents at nuclear power plants, with a focus on an aircraft attack on the facility.
However, that decision should not be misconstrued as lack of consideration of the factors themselves. Nor should the Commission's statement in the proposed rule soliciting comments on “whether or how the 12 factors should be addressed in the DBT rule” be interpreted to mean that the Commission deferred consideration of the factors until after it received comments. Rather, the Commission proposed requirements that would require licensees to defend against threats the Commission considered appropriate at that time, subject to change in the final rule after further consideration of public comments. National Strategy to Secure Cyberspace suggests that the cyber threat likely will increase both in capability and frequency in the future. In February 2002, licensees subject to the DBTs were directed by ICM Order (EA–02–026) to consider and address cyber safety and security vulnerabilities. In April 2003, NRC Orders (EA–03–086 and EA–03–087) that supplemented the DBTs contained language concerning the threat of a cyber attack.
Although authority recently granted the Commission under the EPAct of 2005 will allow the Commission to authorize the use of more sophisticated weaponry, the most powerful weapons and defensive systems will remain reserved for use only by the military and law enforcement. Thus, it would be unreasonable to establish a DBT that could only be defended against with weapons unavailable to private security forces. In addition, the Commission previously decided not to require licensees to defend against attacks by “Enemies of the State” as defined by 10 CFR 50.13. Finally, aircraft attack, another threat likely to result in fires was also considered and studies analyzing the consequences of successful commercial airline attacks were performed.
In the Commission's view, establishing set boundaries demarcating a division of responsibilities is neither possible nor desirable. Currently, these integrated response planning efforts include prearranged plans with local law enforcement and emergency planning coordination. Licensees also must comply with event reporting requirements to the NRC so that a Federal response is readily available, if necessary. Further, multiple commenters expressed concerns regarding the vulnerabilities of nuclear power plants and other licensed facilities to terrorist waterborne attacks. Commenters suggested that the revised DBTs should require nuclear power plants and other licensed facilities situated on navigable waterways to be equipped with visible, engineered physical barriers. After careful consideration, the Commission also chose not to adopt elements related to some EPAct factors as part of the rule text.
The amendments to 10 CFR 73.1 reflect requirements currently in place under existing NRC regulations and orders. As of February 18, 2006, all power reactor licensees have implemented the enhancements to their EP programs with the exception of the drill and exercise program. A majority of nuclear power plant licensees indicated that adoption of the security-based EP drill and exercise program is contingent on NRC and the Department of Homeland Security (DHS) endorsement.
The Commission's consideration, public comments, and responses to the public comments are provided for the 12 factors described in Section A. Finally, the International Physical Protection Advisory Service (IPPAS) is a critical component of the IAEA’s work in nuclear security. IPPAS missions review the threat assessment methodology employed by the host nation and assist the strengthening of national nuclear security systems and measures. Potential external adversaries include terrorists and other criminals who might seek to use nuclear or other radioactive material for malicious purposes, or to sabotage a facility. Insiders are individuals with authorized access to facilities, activities or sensitive information who could commit malicious acts or help external adversaries to do so.
The proposed rule discussion contained, under a section designated “Proposed Regulations,” (70 FR 67381) a detailed listing and clarifying discussion of the 12 factors and a specific request for public comment on “whether or how the 12 factors should be addressed in the DBT rule.” (70 FR 67382). The text of the proposed rule provided ample information to enable meaningful comment on what the current level of protection for nuclear power plants and Category I fuel cycle facilities should entail. Members of the public can and have provided the Commission their views in this rulemaking on the number of attackers, amounts of explosives, and types of weapons that licensees should be required to defend against, even without having access to classified information or SGI. Therefore, access to the ACDs and the RGs was not necessary to enable meaningful public comment on the proposed DBT rule. It is important to note that the Commission was careful to set forth rule text in the final rule that does not compromise licensee security, but also acknowledges the necessity to keep the public informed of the types of attacks against which nuclear power plants and Category I fuel cycle facilities are required to defend. During the course of this rulemaking, the Commission considered if it would be necessary to add some type of airborne threat as part of the DBTs.
After soliciting and receiving comments from Federal, State, and local agencies, and industry stakeholders, and reviewing an analysis of intelligence information regarding the trends and capabilities of potential adversaries, the NRC imposed supplemental DBT requirements by order on April 29, 2003. The Commission deliberated on the responsibilities of the local, State, and Federal stakeholders to protect the nation and the responsibility of the licensees to protect individual nuclear facilities before issuing the April 29, 2003 DBT Orders. The DBT requirements in 10 CFR 73.1 describe general adversary characteristics that designated licensees must defend against with high assurance.
As shown by the unavailability of a number of blackstart generating units in ERCOT this past February, it is far from clear that the existing blackstart infrastructure is sufficient to rapidly recover from these new and emerging threats. All Transmission Operators are required to have blackstart plans in order to restart their systems and eventually tie each restarted system into a stable, interconnected grid.[3] These plans, which are updated as blackstart resources retire, new resources are added, and system topology changes, have been in place for decades. One change is being made to the rule to add a cyber threat as an explicit element of the DBT rule for both external and internal adversaries. The NRC has granted and continues to grant exemptions when a licensee meets the criteria of 10 CFR 50.12 and demonstrates that the alternate means provide an adequate level of fire safety.
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