Chairman Carper, ranking member Voinovich, and distinguished members of the subcommittee, I am honored to address the subcommittee on the subject of “Security of Our Nation’s Nuclear Plants.”

As you know, NEI brings together and is responsible for developing policy for the U.S. nuclear industry. 

My testimony will address the following subjects:

• Security at the nation’s 65 commercial nuclear power plants. 
• The aggressive actions the nuclear industry has taken in response to security officer inattentiveness incidents; and
• The use of Wackenhut Special Operations as the contractor to support the industry composite adversary force. 

Unique among the nations critical infrastructure, nuclear plants have, even prior to 9/11 had to meet security requirements required by the U.S. Nuclear Regulatory Commission (NRC).  Following the September 2001 attacks, the NRC has increased nuclear facility security requirements numerous times by issuing orders and other formal requirements, and is now in the process of codifying additional requirements in rulemakings.

Since 9/11 the industry has invested more than $2 billion in additional security at nuclear plant sites and has increased the number of specially trained, well-armed security forces by more than 60 percent. 

The industry is proud of its security programs and the example they provide for other sectors of America’s critical industrial infrastructure.

Compared to other commercial facilities, nuclear power plants start with a clear advantage in the area of security.  The structures that house reactors and critical systems are built to withstand natural events such as earthquakes, hurricanes, tornadoes, fires and floods. 

The difficult-to-penetrate structures are just the first level of a multistage, integrated security strategy.  Nuclear power plant security is designed with concentric perimeters with increased security at each level.  Physical barriers protect against unauthorized personnel and vehicle intrusion, including truck bombs.  These security zones are protected by trained and armed professionals, who use hardened defensive fighting positions located throughout the plant, if needed. 

In the innermost security zone, access to the vital areas of our plants is strictly controlled using biometrics and other technologies.  Critical areas are constantly surveilled and monitored using state-of-the-art detection equipment.  Strict access control is maintained using biometrics and other technologies.  Industry employees with unescorted access are subject to a systematic fitness-for-duty program and a continual behavioral observation program and must undergo comprehensive background checks.

Every plant has extensive plans and arrangements with state and local law enforcement and emergency response entities.  In addition, every plant must conduct drills and exercises to ensure a well-prepared, comprehensive emergency response plan.

One of the security standards mandated by the NRC is the “design basis threat” (DBT).  Every site tests its security forces against this standard and the NRC inspects against it at mandated FOF exercises.  No other sector of the civilian operated critical infrastructure has a defined DBT.

Based upon tabletop exercises done at all sites and additional simulations done at some sites, we would expect to be successful against most credible threats even at levels greater than the DBT.  But at some point such threats require a more integrated response.  Since September 11, 2001, DHS, NRC, and the industry have recognized the importance of coordinating federal, state and local authorities with the industry to best defend against such an attack.  As a result, a program was established to integrate the response planning around nuclear plant sites.  The mechanism for this planning was called “Comprehensive Reviews” and brought together the full potential of local, state and federal capability.  Last year these Comprehensive Reviews were completed for every site.

As I just briefly described, the improvements to an already robust security program since 9/11 have been broad based and significant.
Let me turn now to the subject of Security Officer Attentiveness
In this environment of strong security and professionalism, we have had isolated situations of security officer inattentiveness while on duty.  This is neither an issue of training, nor is it necessarily an issue of fatigue.  Every company expects the on duty security force to be attentive and able to respond when called upon.  However, it is important to recognize that while there were 12 incidents of inattentive officers during 2007, security officers spent approximately 16 million man-hours on duty.  Most of the time, the work is tedious and boring.  Nevertheless, inattentiveness is unacceptable behavior. 

Following the Peach Bottom situation, NEI communicated with the industry Chief Nuclear Officers (CNOs) and recommended several immediate actions be taken by each site. 

We also emphasized the need for leadership at the site and encouraged each CNO to meet with the security organization to discuss the importance of officers being attentive to their duties and reinforce the organizational expectations and standards

The industry also created a task force which is actively engaged examining security organization cultural issues as well as additional measures that may be effective for ensuring security officer attentiveness.

The task force immediately developed two documents focused on the attentiveness issue.  One document is a shift briefing paper that reinforces the security officer’s roles and responsibilities for identifying and reporting of inattentiveness and other inappropriate behavior. 

The second document is a security post evaluation checklist that is a structured review of each security post on site. 

Over the next few months, the task force is working to define the performance and professional standards needed to promote the security culture desired across all of our plants.  This will include consideration of appropriate policy for addressing incidents where inattentiveness occurs.

It is important to recognize that the leadership at nuclear power plants expects an extremely high standard of professionalism, accountability and performance from all personnel that work at the plant.  In this regard, all of the sites have processes in place to foster and support the desired culture.

Leadership at every company and every site expects and advocates a Safety Conscious Work Environment (SCWE) program which is designed to ensure individuals feel free to raise concerns and are confident those concerns will be promptly reviewed and resolved with a priority appropriate to their significance.  Security officers, just like all other personnel on the site, are therefore encouraged and expected to promptly report concerns and issues to supervision for resolution.

Turning now to Force-on-Force Exercises and the Industry Composite Adversary Force.

The industry has not only greatly improved its physical and operational security, but has also significantly improved the testing of that security.

Prior to the tragic events of September 11, 2001, NRC evaluated FOF exercises roughly once every eight years at each site and there were no NRC requirements for annual exercises to be conducted at every site.  Also, the pre-9/11 program did not have specific performance requirements for the adversary force that participated in the evaluated exercises. 

Since 2004, each plant is required to conduct FOF testing of its security several times each year, with each security shift being tested every year as well as each site conducting an annual FOF exercise.

NRC conducts annual baseline inspections to validate the effectiveness of the overall site security training program, physical security efficacy and FOF exercises.

In 2007, we completed the first three-year cycle of NRC evaluated FOF security exercises – at every plant. 

The NRC has also established standards for the qualifications of the adversary forces that participate in the FOF drills.  Recognizing that the sites would be conducting as many as 15 drills and exercises in a three year period, the industry decided that there was value in establishing a process by which site personnel could gain expertise in performing as adversaries.  To this end, the industry has established a Composite Adversary Force that is skilled in offensive tactics and has the training and qualifications to meet the NRC standard.  The adversary force is used in the triennial NRC-evaluated exercises and thus presents a state-of-the-art challenge to the plants. In addition to evaluating the defensive capabilities of the plant, the NRC also evaluates the adversary force to ensure a robust exercise. 

We are unaware of any security forces for any private industry that are subjected to such rigorous testing that includes FOF drills using a full-time dedicated team.

The Composite Adversary Force is managed under a contract with Wackenhut Special Operations Group.  The management team is comprised of five individuals all of which have extensive special operations experience.  The rest of the adversary team consists of individuals from power plant sites that are trained to meet the NRC standards and perform as part of the team for a period of between 12 and 18 months after which they return to their site to train and participate in FOF exercises.  While some of the team members come from sites supported by Wackenhut, more than 50 percent do not come from Wackenhut sites.  Regardless of whether the adversary forces themselves consist of personnel from Wackenhut or any other entity, they must perform to the standard that the NRC has established.
 
By all accounts, the Composite Adversary Force’s performance in the first three-year cycle has been exemplary and they are meeting or exceeding both NRC and industry expectations.

In closing, our defenses were robust prior to September 11, 2001 and they are significantly better today.  It is highly unlikely that attackers could successfully breach security at a nuclear power plant and even more unlikely they could produce a release of radiation that would endanger the residents near the plant.  We take security officer inattentiveness seriously.  We have taken and are continuing to take aggressive action to ensure appropriate measures are in place to address these conditions that could contribute to inattentiveness.  We have the most rigorous testing of our security through multiple means, including numerous force-on-force exercises and we are constantly reviewing and reevaluating the performance of our security programs.  Consequently, America’s nuclear energy industry will continue to play its role as a leader and model for protecting our country’s critical infrastructure.