RADIOLOGICAL SABOTAGE AT NUCLEAR POWER PLANTS: A MOVING TARGET SET

The Operational Safeguards Response Evaluation (OSRE) is a Nuclear Regulatory Commission (NRC) program that uses force-on-force exercises to test the strategies and capabilities of the security organizations at commercial nuclear power plants to protect the public from radiological sabotage. Despite the success of OSRE --- which uncovered serious physical protection inadequacies in nearly half of the plants tested --- it was cancelled in 1998 by NRC staff. After whistleblowers publicized OSRE's cancellation, NRC reinstated the program. However, the nuclear industry, acting through the Nuclear Energy Institute (NEI), is attempting to significantly weaken it by influencing a revision of the NRC requirements for physical protection of nuclear power plants contained in 10 CFR Part 73.55. While this revision would require licensees to conduct periodic performance testing of their security plans, including force-on-force exercises, the testing regimen favored by NEI would be conducted under far less NRC supervision than the current OSRE program, and its results would be far more ambiguous. Ideas that have been proposed by NEI include changing the physical protection goal so that saboteurs would be able to cause substantial damage to plant systems, as long as operators were able to prevent an uncontrolled meltdown and loss of containment. In contrast, under OSRE such an outcome would have been considered a failure, even if it would not have resulted in a radiological release. No level of damage to critical safety functions should be considered an acceptable outcome of a test of the effectiveness of physical protection at nuclear power plants. Denial of access must remain the fundamental goal.