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Duke Energy Corporation (Catawba Nuclear Station, Units 1 and 2), CLI–05–014, 61 NRC 359,363 (2005). The NRC staff is preparing new regulatory guides (RGs) to provide detailed guidance on the revised DBT requirements in 10 CFR 73.1. These guides are intended to assist current licensees in ensuring that their security plans meet requirements in the revised rule, as well as future license applicants in the development of their security programs and plans. The new guidance incorporates the insights gained from applying the earlier guidance that was used to develop, review, and approve the site security plans that licensees put in place in response to the April 2003 Orders. As such, this regulatory guidance is expected to be consistent with revised security measures at current licensees. Several commenters felt that the DBT rule should define clearly demarcated boundaries where the responsibilities of the licensee end and those of the Government begin for defending nuclear facilities.
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Identifying Threats in Your Design
For the purposes of Section 223 of the Atomic Energy Act, as amended, the Commission is issuing the final rule to revise 10 CFR 73.1 under Sections of 161b, 161i, or 161o of the Atomic Energy Act of 1954 (AEA). Finally, in the near-term, the DBTs need to consider electric grids as they are likely to be configured within the 10-year planning horizon. And the time is now to have the DBTs begin evaluating blackstart resource needs and operations for future generation asset combinations, including high levels of renewables, remote generation, storage, and low inertia. In today’s rapidly evolving world of grid threats, it is likely new threats will develop over time.
Guidance
These NRC requirements include protection against radiological sabotage (generally applied to power reactors and Category I fuel cycle facilities) and theft or diversion of NRC-licensed SSNM (generally applied to Category I fuel cycle facilities). On November 7, 2005 (70 FR 67380), the Commission published a proposed rule for public comment seeking to amend its regulation that governs the requirements pertaining to the DBTs. The DBTs are used by licensees to form the basis for site-specific defensive strategies implemented through physical security plans, safeguards contingency plans, and security personnel training and qualifications plans.
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Threat based training
The DBT rule is also guided by the Commission's knowledge that, in addition to being among the most robust industrial facilities in the world, nuclear power plants are arguably the most physically secured industrial facilities. No other civilian industry security force is subject to as much regulatory oversight as the nuclear industry. However, the Commission acknowledges that the use of private security forces to defend nuclear power facilities faces limitations. For instance, there are legal limitations on the types of weapons and tactics available to private security forces.
Design Basis Threat Development is Key to Proper “Blackstart” Grid Capability
The Nuclear Regulatory Commission (NRC) is amending its regulations that govern the requirements pertaining to the design basis threats (DBTs). Pursuant to Section 170E of the Atomic Energy Act (AEA), the final rule revises the DBT requirements for radiological sabotage, generally applicable to power reactors and Category I fuel cycle facilities, and for theft or diversion of NRC-licensed Strategic Special Nuclear Material (SSNM), applicable to Category I fuel cycle facilities. Additionally, a petition for rulemaking (PRM–73–12), filed by the Committee to Bridge the Gap, was considered as part of this rulemaking. The NRC partially granted PRM–73–12 in the proposed rule, but deferred action on other aspects of the petition to the final rule. Following the terrorist attacks on September 11, 2001, the NRC conducted a thorough review of security practices to ensure that nuclear power plants and other licensed facilities continued to have effective security measures in place to address the changing threat environment.
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The tabletop exercise reconfirmed the respective responsibilities of the participating organizations (NRC, DHS, DOD, and FBI) in the event of a nuclear plant aircraft attack and clarified protocols for response-related interagency communication and coordination. With respect to the other comments regarding protection against explosives of considerable size and modern weaponry, as stated earlier, the details of the adversary capabilities can not be specified publicly, but the Commission believes they are appropriate. Furthermore, the land vehicle bomb assault may be coordinated with an external assault, maximizing its destructive potential. The Commission has also carefully considered biochemical threats both before and after the events of September 11, 2001. The previous rule already contained requirements that provided the capability of using “incapacitating agents,” and that attribute has been retained in the final rule. In addition, armed responders are required to be equipped with gas masks to effectively implement the protective strategy and mitigate the effects of the incapacitating agents.
XIV. Regulatory Analysis
More specific details (e.g., specific weapons, ammunition, etc.) are consolidated in adversary characteristics documents (ACDs) which contain classified or Safeguards Information (SGI). These documents must be withheld from public disclosure and made available only on a need-to-know basis to those who are cleared for access. A DBT describes the capabilities of potential insider and external adversaries who might attempt unauthorized removal of nuclear and other radioactive material or sabotage. The NRC did not provide the draft ACDs and RGs to enable industry comments on the rule, nor has the Commission received or considered non-public comments on the rule. The Commission reiterates that no SGI or classified information was necessary to enable public comment, nor were any non-public comments received or considered over the course of this rulemaking.
II. Analysis of Public Comments and Consideration of the 12 Factors of the EPAct
And it is critical to develop the DBTs for likely future threats, not just review past experiences. Regarding the commenter's statement concerning the petitions and allegations documented and submitted to the NRC, the NRC is currently preparing responses to those that have been received. The Delegations Program serves as the central point of contact for the development and maintenance of DOE delegations and designations of the authorities necessary to run the Department of Energy. These authorities stem from laws; statutes; Executive Orders or proclamations; and regulations issued by other agencies, such as the Office of Management and Budget (OMB), the Office of Personnel Management (OPM), and the Government Accountability Office (GAO).
New or emerging threats may require immediate consideration and actions before DBTs can be revised. In a different approach, competent authorities can develop prescriptive regulatory requirements and ensure that operators implement nuclear security systems and measures in compliance with these and with the nuclear security objectives established in the State’s legal framework. Competent authorities can disseminate such DBTs to relevant operators, who then use it to develop facility-specific attack scenarios and to design nuclear security systems to meet the nuclear security objectives established in the State’s legal framework. DOE has access to intelligence information about many of these threats, and to the national labs, which have expertise in a number of these threats, such as cyber and EMP. Once the DBTs are developed, NERC could use those DBTs to develop and promulgate blackstart planning and operating standards. More analysis of blackstart capability and adequacy is needed now, on a larger scale, before the next threat arises.
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.
Regulatory Guide (RG–5.70), “Guidance for the Implementation of the Theft or Diversion Design-Basis Threat (Classified).” This regulatory guide will provide guidance to the industry on the theft or diversion DBT. RG–5.70 contains classified information and, therefore, is withheld from public disclosure and distributed only on a need to know basis to those who otherwise qualify for access. Regulatory Guide (RG–5.69) , “Guidance for the Implementation of the Radiological Sabotage Design-Basis Threat (Safeguards).” This regulatory guide will provide guidance to the industry on the radiological sabotage DBT. RG–5.69 contains SGI and, therefore, is being withheld from public disclosure and distributed on a need-to-know basis to those who otherwise qualify for access. These inspections, as well as additional studies, showed significant differences in the strategies implemented by the plants. The guidance was based on “lessons learned” from NRC engineering studies and included a list of “best practices” for mitigating losses of large areas of the plant.
In conducting these studies, the NRC drew on national experts from several DOE laboratories using state-of-the-art structural and fire analyses. The NRC also enhanced its ability to realistically predict accident progression and radiological release consequences. For the facilities analyzed, the studies found that the likelihood of both damaging the reactor core and releasing radioactivity that could affect public health and safety is low. Even in the unlikely event of a radiological release due to terrorist use of a large aircraft, there would be time to implement mitigating actions and off-site emergency plans such that the NRC's emergency planning basis remains valid (71 FR 36554; June 27, 2006). Additional site-specific studies of operating nuclear power plants are underway or being planned to determine the need, if any, for additional mitigating capability on a site-specific basis. In summary, the NRC considered the potential for fires during the DBT rulemaking process, as required by the EPAct.
However, relevant information is provided as background material to facilitate a better understanding of the existing security measures in place and planned for the future, and to answer the underlying questions and issues raised in the following public comments. As stated in 10 CFR 73.55(a), power reactor licensees are only required to protect against the threat of radiological sabotage. Spent fuel is not an attractive theft or diversion target due to its large physical size and high thermal heat and radioactivity (most power reactor spent fuel is considered “self-protecting”).
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.
Several commenters specifically charged that the Commission deferred its consideration of air-based threats to the final rule, thus undermining stakeholders' abilities to know the Commission's position on that factor. At the time that the proposed rule was published, the Commission maintained its view that protection against airborne attack could best be provided by the strengthening of airport and airline security measures. Accordingly, the Commission did not propose to include a provision in the proposed rule that would require licensees to provide defense against an airborne attack but the Commission specifically sought comment on the issue in the proposed DBT rule and has remained open to changing its position. In addition to being raised in PRM–73–12, the Commission has received numerous comments on the airborne threat. The assertion about the lack of APA notice with regard to the EPAct's 12 factors is without merit.
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