Written Testimony of
Chief Nuclear Officer
Committee on Environment and Public Works
United States Senate
Nuclear Power Plant Security Legislation
June 5, 2002
Mr. Chairman, Members of the Committee: I am Jack Skolds, Chief Nuclear Officer for Exelon Nuclear, the nuclear division of Exelon Generation Company. Exelon Generation is a wholly owned subsidiary of Exelon Corporation, which was formed in 2000 by the merger of Unicom Corporation of Chicago and PECO Energy Company of Philadelphia. Exelon Generation currently owns and operates approximately 37,000 megawatts of diversified electrical generation, including 17 nuclear reactors that generate 16,970 megawatts of electricity. Exelon is the largest nuclear generation operator in the country with approximately 20% of the nation’s nuclear generation capacity, and the third largest private nuclear operator in the world. We also own 50% of AmerGen Energy, which is a partnership with British Energy of Edinburgh, Scotland. AmerGen owns three of the 17 units in the Exelon fleet, with plants in Illinois, New Jersey and Pennsylvania.
Thank you for the opportunity to appear before you today to discuss legislative proposals addressing several important security issues at commercial nuclear power plants.
I would also thank several members of the committee for their efforts to investigate the issue of nuclear plant security first-hand. Senators Graham, Clinton, Corzine, Smith, Voinovich and Specter have all toured nuclear power plants to receive briefings on plant security since September 11, as have several of the committee’s staff members. In fact, Senator Specter has toured three of the five nuclear power plants in Pennsylvania, including two Exelon facilities.
My testimony today will focus on three areas:
First, I will address legislative proposals pending before the Senate on nuclear plant security.
Second, I will provide the Committee with an overview of nuclear plant security.
Third, I will provide the Committee with recommendations regarding actions the Federal government can take to address nuclear plant security issues in the post-September 11th environment.
Before addressing these issues, however, let me make a few preliminary comments.
Let me begin by assuring the Committee that the nuclear power industry is absolutely committed to ensuring that our plants are operated safely and that all necessary steps are taken to protect the health and safety of the public and our employees. No one has a greater interest in protecting the safety and security of nuclear plants than the owners and operators of those facilities.
In addition, it is important for the Committee to understand that commercial nuclear power plants are the most well-protected industrial facilities in the United States today. In fact, many businesses are turning to the nuclear industry as a model for providing security and emergency planning at their industrial complexes.
Finally, as the United States acts to strengthen homeland security in light of new threats to the nation’s security, it is imperative that Federal, state, and local officials work cooperatively with nuclear plant operators to build upon the solid foundation of emergency response capabilities that existed prior to September 11th.
The Committee’s letter of invitation requested comments on two legislative proposals pending before the Senate: S. 1586, “a bill to amend the Atomic Energy Act of 1954 to authorize the carrying of firearms by employees of licensees, and for other purposes” and S. 1746, “a bill to amend the Atomic Energy Act of 1954 to strengthen security at sensitive nuclear facilities.” My comments will address these bills, as well as H.R. 2983, legislation to reauthorize the Price-Anderson Act of 1954, which was passed by the U.S. House of Representatives and which is awaiting action by the Senate.
S. 1586, introduced by Senator Jim Inhofe, amends the Atomic Energy Act to authorize NRC licensee employees to carry firearms, provides limited arrest authority to such employees, and establishes a fine or imprisonment for the sabotage of commercial nuclear facilities. These provisions were submitted to Congress by the Nuclear Regulatory Commission several years ago and were approved by the Senate during the 106th Congress as part of S. 1627, the NRC Fairness in Funding Act of 2000, and as part of separate appropriations legislation.
The nuclear industry testified in support of the provisions as part of its testimony on S. 1627 during the 106th Congress, though some NRC licensees have recently expressed concern about the possible legal implications of providing wide-ranging arrest authority to private security forces. The industry stands ready to work with the Committee to resolve these concerns.
S. 1746, introduced by Senator Harry Reid and other members of the Committee, makes sweeping changes in the manner in which security at commercial nuclear facilities is addressed. Unfortunately, S. 1746 puts the proverbial cart before the horse by mandating radical legislative solutions to issues that have not been identified as problems.
Section 3 would substitute a statutorily-mandated design basis threat for that developed by the independent Nuclear Regulatory Commission and would federalize security at commercial nuclear power plants by establishing a nuclear security force within the NRC and by requiring the Commission to develop a security plan for each of the nation’s sensitive nuclear facilities. Section 3 also levies a tax on sensitive nuclear facilities to fund a newly created Nuclear Security Fund within the Treasury to pay for these massive and sweeping new federal responsibilities.
Exelon is concerned about the imposition of a statutorily-mandated design basis threat which prejudges the nature of the design basis threat without a comprehensive review by the NRC in conjunction with Federal intelligence and law enforcement agencies. If legislative action in this area is deemed necessary, Congress should first direct the President to conduct a comprehensive review with the various energy, intelligence and law enforcement agencies of the various threats facing nuclear power plants. Once such a review is completed, the NRC should be directed to adjust the design basis threat accordingly.
With regard to Federalization of nuclear plant security forces, Exelon strongly opposes such a drastic and unjustified change in security requirements. Security forces at nuclear power plants are highly trained professionals. Substituting Federal employees to safeguard sensitive nuclear facilities may actually degrade security. The background check requirements, hiring qualifications, and training standards in the bill are actually less stringent than those currently enforced by the NRC.
Federalizing the nuclear security forces would also eliminate some of the best candidates for nuclear security forces by effectively barring recipients of Federal pensions from serving as Federal employees. Some of the current members of nuclear security forces are military retirees who would be forced to choose between resigning their position or giving up their Federal pensions. In addition, nuclear power plant security forces work in an integrated manner with plant operators during a security event to coordinate responses to security threats. Integrated command and control of plant security forces and plant operations personnel is essential to assure the protection of public health and safety. Finally, Federalizing nuclear security forces would fundamentally change the mission of the Nuclear Regulatory Commission. Hiring, training, and managing a security force of 7,000 employees would be a massive undertaking and might well detract from the Commission’s core mission of assuring that plants are operated in a manner that protects the public health and safety. It also places the NRC in an active role in day to day operations at the nation’s nuclear power plants – a dramatic reversal of the efforts the Congress, the executive branch, the Commission, and the industry have made over the past 30 years to ensure the NRC is a regulator, not an operator.
Similarly, requiring the NRC to develop security plans for each of the nation’s sensitive nuclear facilities within 180 days would be a significant task that would result in an unnecessary – and perhaps dangerous – diversion of Commission resources. The NRC currently has detailed regulations governing security requirements at plants, and plant personnel can best handle the coordination of plant security forces with state and local law enforcement officials. As with federalization of nuclear plant security forces, requiring a federally-developed security plan for several dozen sites is unnecessary given the complete lack of evidence that the current system is deficient.
Finally, a tax on nuclear plant operators would fund a new and unnecessary Federal bureaucracy and would be unparalleled in the private sector. Simply put, the tax would fund an activity that is currently being effectively managed by the private industry. In addition, the tax potentially would force nuclear power plant customers to inappropriately fund national defense activities and would likely result in some nuclear plants subsidizing the cost of security at other plants.
Section 4 establishes an Operation Safeguards and Response Unit at the NRC. The existing NRC Operational Safeguards and Response Evaluations (OSRE) program has been applied and interpreted in an inconsistent and at times arbitrary manner. Anti-nuclear groups and the NRC have at times inaccurately characterized licensee performance under the existing OSRE program by claiming that licensees have “failed” a significant portion of force-on-force drills.
It is important to note that the OSRE program evaluates plant security, and not plant safety. Given the ability of plant operators to safely shut down an operating reactor in a matter of seconds, OSRE drills alone are not an accurate reflection of plant safety.
The NRC has been striving to develop a more objective methodology for determining the ability of nuclear plants to respond to design basis threats. The program would potentially result in more frequent force on force drills than in the past. The Commission has also moved to enhance its organizational structure with respect to security by creating a new office dealing with security policies and programs.
Senator Reid’s legislation seeks to address problems with the current program by mandating a highly-prescriptive program that could prevent the Commission from establishing a more effective and more appropriate program to evaluate the performance of plant security forces.
Section 4 also inappropriately expands the emergency planning zone around sensitive nuclear facilities from a 10-mile radius to a 50-mile radius. There has been no evidence to suggest that such a radical change in the current regulatory system is warranted to protect public health and safety. Extending the 10-mile emergency planning zone to a 50-mile radius would require planners to address an area of 7,857 square miles (as opposed to the current emergency planning zone which encompasses 315 square miles). Such an expansion would only serve to diffuse the resources available to and distract the personnel responsible for emergency planning from focusing on enhancing planning that may have been ignored in other sectors prior to 9/11 and from continuing to ensure current planning is satisfactory. Again, absent compelling evidence on the need to undertake such a massive effort, Congress should defer to the NRC, FEMA, and EPA in determining the appropriate radius for emergency planning purposes.
Section 5 directs the Commission to establish a stockpile of potassium iodide tablets and to develop plans for the prompt distribution of potassium iodide tablets within a 50-mile radius of all sensitive nuclear facilities. The NRC, in conjunction with the Environmental Protection Agency, the Department of Health and Human Services, and the Federal Emergency Management Agency, has recommended that potassium iodide be made available at the request of state governments for distribution within the 10-mile emergency planning zone around commercial nuclear power plants. There is no scientific basis for expanding the distribution of potassium iodide to an area within 50 miles of a sensitive nuclear facility.
Section 6 of the legislation directs the Commission to request assistance from Governors and the President in the event of war or other national emergency. While such assistance may be appropriate in the event of war or other national emergency, the Commission is not barred under current law from requesting such assistance. In addition, as the Commission stated in its review of the legislation, such assistance may not be appropriate in all circumstances and could divert resources from more vulnerable parts of the nation’s infrastructure.
H.R. 2983, which was passed by the U.S. House by voice vote last year, includes an amendment by Representative Ed Markey to address the nuclear security issue. Under the Markey amendment, the President is directed to conduct a study to identify the types of threats that pose an appreciable risk to NRC licensed facilities. The legislation includes a number of issues to be considered during this study, including each of the issues enumerated in Section 3 of S. 1746. The President is also required to classify each type of threat as being the responsibility of the Federal government or of NRC licensees.
Exelon strongly supports the Markey amendment as an appropriate first step in identifying what additional changes may be necessary to protect commercial nuclear facilities in he aftermath of September 11th. The amendment allows the White House to tap all Federal intelligence and law enforcement resources to assess the nature of the threats that are faced by commercial nuclear facilities. The amendment also directs the White House to clearly delineate between threats against which licensees must defend and threats against which law enforcement officials and the Federal government must defend. Only after such an assessment is conducted can Congress make a well-informed decision regarding what additional resources and requirements are necessary to protect commercial nuclear facilities.
Protection of public health and safety requires both the safe operation of nuclear plants and the physical protection of the plant against potential threats.
The industry today is operating the nation’s 103 nuclear reactors more efficiently and safely than ever before. The average capacity factor for nuclear plants reached an all-time high of 91 percent in 2001 according to preliminary data from the Nuclear Energy Institute, while the industrial safety accident rate for nuclear plants in 2000 was a record-low 0.26, compared to an average accident rate in the manufacturing sector of 4.0.
As another measure of safety, the Nuclear Regulatory Commission monitors the number of “significant events” at each nuclear reactor (broadly defines as occurrences that challenge a plant safety system). The average number of significant events per unit has declined from 2.37 per year in 1985 to 0.03 per year in 2000, the latest year for which data is available.
Nuclear power today provides 20 percent of the nation’s electricity each year, and it does so without emitting any of the pollutants associated with acid rain or global warming. In fact, nuclear power has played a major role in allowing many regions of the country come into compliance with Clean Air Act requirements.
The industry’s commitment to safety also extends to plant security. In fact, commercial nuclear power plants are regarded by many to be the most well protected industrial facilities in the United States today. Indeed, many other industries are turning to the nuclear industry as a model for providing security at a variety of commercial facilities. For example, in addition to unique physical protections employed at commercial nuclear facilities, the nuclear industry is alone among critical infrastructure industries in using the Federal Bureau of Investigations to run criminal background checks on applicants for positions at sensitive facilities.
Existing Federal statutes and regulations provide strict standards requiring licensees to take actions necessary to protect the public health and safety. NRC requirements and industry programs are predicated on the need to protect the public from the possibility of exposure to radioactive release caused by acts of sabotage.
The current design basis threat – the threat against which a plant licensee must be able to protect – assumes a suicidal, well-trained paramilitary force, armed with automatic weapons and explosives, that is intent on forcing its way into a nuclear power plant to commit radiological sabotage. The design basis threat also assumes that the attackers will have insider knowledge of plant systems and plant security plans and even insider assistance.
This assumed threat forms the basis for security response plans and training drills. These plans and drills are tested regularly by the NRC as part of their Operational Safeguards Response Evaluation (OSRE). The OSRE program has also provided the industry with the opportunity to identify areas where security can be improved and enhanced.
A number of defenses exist to counter such a threat. Nuclear plants, by their very design, provide a redundant set of physical barriers designed both to keep radiation and radioactive materials inside the plant and to keep intruders outside the plant. The reactor core is protected by a containment structure comprised of several feet of thick reinforced concrete walls, a steel liner, additional concrete walls within containment, and a several inches-thick high tensile steel reactor vessel. The metal cladding on the fuel itself also serves as an additional protective barrier. In addition, there are multiple systems of the safety equipment needed to safely shut down the reactor. This “defense in depth” design explains why the FBI considers nuclear plants to be “hardened targets.”
Nuclear plant sites have three distinct zones, each of which has different levels of physical and human defenses. The first zone, called the “owner-controlled area,” includes all of the property that is associated with the plant. The owner controlled area typically ranges in size from several dozen to hundreds of acres of land and serves as an effective buffer zone around the critical areas of the plant.
The second zone, the “protected area,” is a physically enclosed area surrounding the plant into which access in controlled. Physical barriers to intrusion include barbed wire and razor wire fences, microwave and electronic intrusion detection systems, closed circuit television systems, isolation zones, extensive lighting, system monitoring by redundant alarm stations, and vehicle barrier systems. Access to the protected area is restricted to a select population of site personnel with a need for entry.
To access the protected area, plant employees and visitors must pass through a metal detector and an explosives detector. X-ray machines are also used to screen material brought into the protected area by employees and visitors. In addition, employees must utilize a hand-geometry device to confirm their identity before entering the protected area.
The third zone, the “vital area,” includes those areas within the protected area containing equipment essential for operating the plant safely and successfully shutting down in the case of an event. Additional barriers are in place to protect vital areas of the plant, including concrete floors, walls, and ceilings; steel locked and alarmed doors; and key card access doors. Access to the vital area is even further restricted to a select population of site personnel with a need for entry. These access lists are routinely reviewed to confirm the need for access. The defensive contingency plans used by security forces are geared towards protection of these critical areas.
In addition to the robust physical structures protecting the plant, licensees maintain a highly trained, well-equipped security force to guard each facility. Security personnel, many of whom have law enforcement or military experience, must undergo extensive background checks, including fingerprint submittal for an FBI criminal record check; physical and psychological testing and screening; credit and reference checks; education and work history verification; and routine drug and alcohol screening. The nuclear industry is unique among energy industries in having a cooperative relationship with the FBI to facilitate such criminal record checks.
In addition, security personnel are subject to rigorous training requirements. Initial nuclear security officer training includes a wide variety of topics, including NRC requirements for nuclear facility physical security, recognition of sabotage devices and equipment, contraband detection devices and operation, firearms training and tactical response training. Annual supplemental training covers areas such as weapons proficiency, physical readiness, stress fire course, force-on-force drills, and table top drills. A significant amount of annual training focuses on force-on-force training, which covers such topics as threat assessment and tactical response, response force deployment and interdiction, protection of specified vital equipment and protected areas, multiple target acquisition and engagement, and the use of armored body bunkers, ballistic shields, and other specialized security equipment.
As a further protection to the public, each nuclear power plant has an extensive and well-honed emergency response organization and systems in place to respond to and mitigate any emergency that arises. Emergency response plans are tightly integrated with local, state and federal regulatory and emergency authorities and undergo regular training and drilling. The emergency planning zone includes an area within a 10-mile radius of the plant, an area encompassing roughly 315 square miles. Since September 11, Exelon Nuclear has conducted security briefings for state and local officials in each of the states in which we operate to reinforce the coordination and response plans in the event of an emergency.
Upon notification by the Nuclear Regulatory Commission on September 11, all nuclear plants immediately increased their security to Level 3, the highest level of security maintained at commercial nuclear reactors. All U.S. commercial reactors remain at Level 3.
Since September 11, nuclear plants have also extended the point of initial screening of people entering the plant site from the protected area boundary to a point in the owner controlled area boundary. This initial screening includes an identification check, confirmation of the purpose for entering the site, and a thorough vehicle inspection for all visitors. State police and, in some cases the National Guard, have augmented this effort. In addition, armed patrols have extended their patrols to include a larger portion of the owner-controlled area. These patrols are coordinated with onsite personnel to enhance detection and deter potential threats.
Given the uncertain nature of potential attacks, Exelon Nuclear and other reactor operators took a variety or protective measures in conjunction with NRC guidance. These included actions to harden site access, increase security resources, and improve operational readiness.
To harden site access, Exelon has:
· established armed owner control area checkpoints for all vehicles entering the site
· implemented additional vehicle pre-screening and control of all on-site deliveries upon entry to the owner-controlled area
To increase security resources, Exelon has:
· increased the number of security officers
· procured additional weapons and upgraded armaments
· added armed security posts at key plant locations
To enhance operational readiness, Exelon has:
Since shortly after September 11, the Nuclear Regulatory Commission has been engaged in a top-to-bottom review of the Design Basis Threat to reevaluate its adequacy. As an interim measure, the Commission issued Orders on February 25th of that year which imposes significant additional requirements on licensees pending the completion of a more comprehensive review of safeguards and security program requirements.
While many of the specifics regarding the NRC Orders are classified as safeguards information and cannot be disclosed to the public, issues addressed by the Orders include security officer staffing levels, protection against potential vehicle and waterborne threats, protection of used fuel, enhanced access authorization controls, and mitigation efforts in the event of an attack.
As the United States acts to strengthen homeland defense in light of new threats to the nation’s security, it is imperative that Federal, state, and local officials work cooperatively with nuclear plant operators to build upon the solid foundation of emergency response capability that existed prior to September 11.
In particular, there are several steps that we believe the Federal government should take to address security issues at nuclear power plants.
· There must be a clearer delineation of responsibility between government and plant licensees. Federal law currently requires NRC licensees to protect against a variety of potential threats to commercial nuclear power plants, but the law also considers many threats to be outside the scope of licensee responsibility and instead relies on law enforcement agencies and the military to protect against certain threats. Congress and the Administration must determine where the line between licensee and government responsibility lies in light of the new threats faced by nuclear power plants and other facilities that make up the nation’s critical energy infrastructure.
· There must be improved communication and coordination among licensees and the various Federal, state and local agencies involved in emergency response planning. The Federal government has a role in financially supporting many of the actions necessary to accommodate this improved communication and coordination.
· The Nuclear Regulatory Commission has incurred – and will continue to incur – additional costs to address new security concerns. Congress should support the NRC’s request for additional funding to support additional actions undertaken in support of homeland defense.
· The Nuclear Regulatory Commission should revise its protocol of threat levels to conform with that used by the Office of Homeland Security.
· In determining the resources necessary to protect nuclear power plants, the Federal government should consider the potential vulnerability of these plants relative to other potential critical infrastructure targets and allocate limited Federal resources to those facilities deemed to be most vulnerable to terrorist attack.
The most pressing challenge facing Congress and other Federal policymakers is how to allocate responsibility for protecting the nation’s critical infrastructure against attacks by terrorists and other enemies of the state. Federal law currently requires Nuclear Regulatory Commission (NRC) licensees to protect against a variety of potential threats to commercial nuclear power plants. Federal law considers many potential threats to be outside the scope of licensee responsibility and instead relies on law enforcement agencies and the military to protect against certain threats. The question facing Congress and the Administration is where the line between licensee and government responsibility lies in light of the new threats faced by nuclear power plants and other facilities that make up the nation’s critical energy infrastructure.
The events of September 11 have presented the nation with a variety of new challenges. Protection of the country’s critical infrastructure is among the most important of these challenges, but it is a challenge that I am confident the nuclear energy industry can and will continue to meet.
Exelon Nuclear fully supports the NRC’s efforts to conduct a top-to-bottom review of security requirements pertaining to nuclear facilities. We continue to assess security at our plants and have taken appropriate steps to increase security measures as a result of the heightened state of alert.
As Congress and the Administration debate what changes in Federal law and policies are appropriate in the aftermath of the September 11 attacks, strong consideration should be given to building upon the existing regulatory system which distinguishes between threats for which licensees are responsible and threats for which law enforcement and the military are responsible.
As I mentioned earlier in my testimony, the House of Representatives endorsed one such approach last year as part of H.R. 2983, the Price-Anderson Amendments Act, which passed by the House by voice vote. The House legislation directs the President to conduct an assessment of potential threats against nuclear facilities and to classify each threat as one for which the Federal government should be responsible or as one for which NRC licensees should be responsible. The measure also requires the Nuclear Regulatory Commission to promulgate a rulemaking to ensure that licensees address the threats identified in the report as a licensee responsibility.
Exelon strongly supports the Price-Anderson provisions as a reasoned approach to this very important issue. The Presidential study will allow the White House to coordinate the efforts of a number of Federal agencies to conduct a comprehensive threat assessment. Such an approach will also allow personnel knowledgeable in security matters to make decisions in coordination with intelligence officials to ensure that nuclear facilities are treated in a manner consistent with the protection of other critical infrastructure facilities.
The need for improved communication and coordination among licensees and Federal, state and local government agencies is perhaps best illustrated by an event at AmerGen’s Three Mile Island (TMI) plant last year. The Nuclear Regulatory Commission notified AmerGen on October 17, 2001, that the federal government had received information that it believed constituted a credible threat against the plant. A number of Federal agencies and organizations, including the NRC, the FBI, the FAA, and NORAD, were involved in the subsequent response to what was later determined not to be a credible threat.
Site personnel took immediate action to secure the plant, which was in the midst of a maintenance and refueling outage. The company also requested – and received – additional security assistance from the Pennsylvania State Police.
The “threat” against Three Mile Island showed that the regulatory system currently in place can work effectively in response to a potential threat. As the licensee, AmerGen took immediate action to secure the site physically and called in additional assistance from the law enforcement community, while the federal government and the military took action to protect the plant against potential threats that fell outside the design basis threat against which AmerGen is responsible for defending.
At the same time, the TMI event also provided both the industry and the government with some valuable “lessons learned,” including the need to work more closely with Federal officials to clarify the nature of threat information, the need to develop coordination procedures with multiple Federal agencies, and the need to communicate effectively with local elected officials and emergency services personnel.
The Commission took a step towards addressing some of these issues earlier this year when it established an Office of Nuclear Security and Incident Response to consolidate and streamline selected NRC security, safeguards, and incident response responsibilities and resources. While this should address some coordination and communications issues, other Federal agencies must engage in similar efforts.
Finally, it is important that the NRC be integrated into the intelligence community’s process for assessing and communicating potential threats against commercial nuclear facilities and other NRC licensees. Nuclear plant licensees are highly dependent on receiving threat information from the NRC, so it is essential that the Commission itself be fully integrated into the intelligence community’s threat assessment process.
The Nuclear Regulatory Commission has incurred – and will continue to incur – additional costs to address new security concerns. While the Commission plans to reallocate existing resources to support the new Office of Nuclear Security and Incident Response, the NRC’s mission with regard to security is likely to expand as the Federal government reassesses the responsibilities of various parties for providing nuclear security. NRC’s efforts should be coordinated with the broader efforts of the Office of Homeland Security. Congress should support the NRC’s request for additional funding to support additional actions undertaken in support of homeland defense.
As I noted earlier, the NRC currently uses a three level security classification system. Each of the nation’s 103 reactors have been at the top level, Level 3, since September 11 and the Commission has indicated that plants will remain at Level 3 for the foreseeable future. This situation begs the question of how meaningful the different security classifications are if the highest level of alert effectively becomes the only level of security. Given these concerns and the need for consistency in communicating the urgency of potential threats, the Commission should revise its protocol of security levels to conform to the five level classification system established by the Office of Homeland Security. Such a system would also allow the Commission and licensees to distinguish between the current generalized heightened state of alert and a more specific threat against a plant or plants.
As the NRC develops a new security level classification, it should establish security requirements that correspond appropriately to the various threat levels. In essence, the Commission must redefine the baseline security requirements for plants assuming a “green” alert level where no threat exists. The Commission should then require appropriate additional security requirements as alert levels are upgraded. This will allow plant operators and emergency response officials to develop readiness levels commensurate with the threat level that exists.
In determining the resources necessary to protect nuclear power plants, the Federal government should consider the potential vulnerability of these plants relative to other potential critical infrastructure targets and allocate limited Federal resources to those facilities deemed to be most vulnerable to terrorist attack.
For example, some in Congress have advocated federalizing nuclear plant security forces. As I mentioned earlier in my testimony, the industry has a highly trained force of security personnel guarding commercial nuclear plants. Replacing these forces with Federal employees is unnecessary and would complicate the ability of licensees to coordinate the response of plant and security personnel in the event of a terrorist attack. Federalizing nuclear security forces would also unnecessarily limit the pool of potential guards by prohibiting retired military and other government officials who would be prohibited from serving as Federal security personnel and continuing to draw their Federal pension.
Others in Congress and elsewhere have advocated placing anti-aircraft artillery installations at nuclear plants to protect against an air attack. The industry believes that Federal resources would be more properly focused on increased airport security to ensure that terrorists are denied access to the large commercial airliners that are of most concern.
Given the strong physical structures at nuclear plants and the highly trained guard force to protect commercial nuclear facilities, resources may be more appropriately focused on other critical infrastructure facilities.
Mr. Chairman, thank you for the opportunity to discuss these issues with you. Let me close by reiterating that the nuclear industry recognizes our responsibility for protecting the public health and safety, and we are committed to taking the steps necessary to do so.
I would be pleased to answer any questions you may have.