Testimony 

Before the Subcommittee on National Security, 

Emerging Threats, and International Relations, 

Committee on Government Reform, House of 

Representatives 

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 10:00 a.m. EDT 

Tuesday, June 22, 2004 NUCLEAR SECURITY

Several Issues Could 

Impede the Ability of DOE’s 

Office of Energy, Science 

and Environment to Meet 

the May 2003 Design Basis 

Threat 

Statement of Robin M. Nazzaro, Director 

Natural Resources and Environment Team 

GAO-04-894T 
www.gao.gov/cgi-bin/getrpt?GAO-04-894T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robin M. 

Nazzaro at (202) 512-3841 or 

nazzaror@gao.gov. 

Highlights of GAO-04-894T, a testimony to 

Subcommittee on National Security, 

Emerging Threats, and International 

Relations, Committee on Government 

Reform, House of Representatives 

June 22, 2004

NUCLEAR SECURITY

Several Issues Could Impede the Ability 

of DOE’s Office of Energy, Science and 

Environment to Meet the May 2003 

Design Basis Threat 

Five Office of Energy, Science and Environment sites contain substantial 

quantities of Category I special nuclear material, which consists of specified 

quantities of plutonium and highly enriched uranium. These sites have all 

developed plans for implementing the May 2003 DBT. However, there are 

several issues that could make it difficult to implement these plans by DOE’s 

deadline of the end of fiscal year 2006. Specifically: 

• Office of Energy, Science and Environment sites approved their DBT 

implementations plans in February 2004 before the Deputy Secretary of 

Energy issued his April 2004 guidance on which sites had improvised 

nuclear device vulnerabilities. As a result, some sites may be required to 

shift to enhanced protection strategies, which could be very costly. 

Consequently, the assumptions in the Office of Energy, Science and 

Environment DBT implementation plans may no longer be valid, and the 

plans may need to be revised. 

• Office of Energy, Science and Environment site plans are based on the 

May 2003 DBT; however, DOE is now reexamining the May 2003 DBT 

and may revise it. Consequently, if the DBT is changed in a way that 

increases security requirements, some Office of Energy, Science and 

Environment sites may have to revise their implementation plans to 

reflect the need to provide for a more stringent defense. 

• The plan for one Office of Energy, Science and Environment site was 

under funded. Specifically, officials in the Office of Nuclear Energy, 

Science and Technology, which is part of the Office of Energy, Science 

and Environment, told GAO that, for one site, no DBT implementation 

funding had been requested for fiscal year 2005. 

• Finally, full implementation of these plans will require the successful 

resolution of complex organizational arrangements between various 

program and security offices. 

Consequently, GAO continues to believe, as it recommended in April 2004, 

that DOE needs to develop and implement a departmentwide, multiyear, 

fully resourced implementation plan for meeting the new DBT requirements 

that includes important programmatic activities such as the closure of 

facilities and the transportation of special nuclear materials. 

A successful terrorist attack on 

Department of Energy (DOE) sites 

containing the material used in 

nuclear weapons, called special 

nuclear material, could have 

devastating consequences for the 

site and its surrounding 

communities. Because of these 

risks, DOE needs an effective 

safeguards and security program. 

A key component of an effective 

program is the design basis threat 

(DBT), a classified document that 

identifies, among other things, the 

potential size and capabilities of 

terrorist forces. The terrorist 

attacks of September 11, 2001, 

rendered the then-current DBT 

obsolete resulting in DOE issuing a 

new version in May 2003. 

GAO examined the issues that 

could impede the ability of DOE’s 

Office of Energy, Science and 

Environment to fully meet the 

threat contained in the May 2003 

DBT by the department’s fiscal 

year 2006 deadline. 
Page 1 GAO-04-894T DOE Nuclear Security 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss our work on physical security at 

the Department of Energy’s (DOE) Office of Energy, Science and 

Environment (ESE). DOE’s Office of Energy, Science and Environment 

comprises nine offices, including the Offices of Environmental 

Management (EM); Nuclear Energy, Science and Technology (NE); and 

Science (SC) and is headed by the Under Secretary for ESE. 

DOE has long recognized that a successful terrorist attack on a site 

containing the material used in nuclear weapons—called special nuclear 

material—could have devastating consequences for the site and its 

surrounding communities. This is particularly true at sites that contain 

Category I special nuclear material, which consists of specified quantities 

of plutonium and highly enriched uranium in the form of assembled 

nuclear weapons and test devices, major nuclear components, and other 

high-grade materials such as solutions and oxides. 

Because terrorist attacks could have such devastating consequences, 

DOE’s effective management of its safeguards and security program, 

which includes developing safeguards and security policies, is essential to 

preventing an unacceptable, adverse impact on national security.1

 For 

many years, DOE has employed risk-based security practices. To manage 

potential risks, DOE has developed a design basis threat (DBT), a 

classified document that identifies the potential size and capabilities of 

terrorist forces. DOE’s DBT is based on an intelligence community 

assessment known as the Postulated Threat. DOE requires the contractors 

operating its sites to provide sufficient protective forces and equipment to 

defend against the threat contained in the DBT. The DBT in effect on 

September 11, 2001, had been DOE policy since June 1999. DOE replaced 

the 1999 DBT in May 2003 to better reflect the current and projected 

terrorist threats that resulted from the September 11 attacks. 

On April 27, 2004, we testified before this Subcommittee on several key 

aspects surrounding DOE’s development and implementation of its May 

2003 DBT.2

 Specifically, we reported on our examination of (1) the reasons 

 1

See U.S. General Accounting Office, Nuclear Security: NNSA Needs to Better Manage Its 

Safeguards and Security Program, GAO-04-471 (Washington, D.C.: May 30, 2003). 

2

See U.S. General Accounting Office, Nuclear Security: DOE Must Address Significant 

Issues to Meet the Requirements of the New Design Basis Threat, GAO-04-701T

(Washington, D.C.: April 27, 2004). 
Page 2 GAO-04-894T DOE Nuclear Security 

DOE needed almost 2 years to develop a new DBT, (2) the higher threat 

contained in the new DBT, and (3) the remaining issues that needed to be 

resolved for DOE to fully defend against the threat contained in the new 

DBT. With regard to the issues needing resolution for DOE to fully defend 

against the threat contained in the new DBT, we found that DOE had been 

slow to resolve a number of significant issues including developing DBT 

implementation plans and budgets to support these plans. The need to 

fully resolve these issues may affect the ability of its sites to fully meet the 

threat contained in the new DBT in a timely fashion. Consequently, we 

stated that DOE’s deadline to meet the requirements of the new DBT by 

the end of fiscal year 2006 was probably not realistic for some sites. 

Subsequently, you asked us to examine in more detail the issues that could 

impede ESE’s ability to fully meet the threat contained in the new DBT by 

DOE’s fiscal year 2006 deadline. To carry out our objective, we 

interviewed DOE and ESE officials, including EM, NE, and SC 

headquarters security officials, as well as field security officials. We also 

reviewed relevant documents these officials provided to us. In addition, 

we reviewed recent reports from DOE’s Office of Independent Oversight 

and Performance Assurance for the ESE sites that contain Category I 

special nuclear material. We also relied on our previous work on DOE 

physical security conducted for this Subcommittee over the last 2 years. 

We performed our work from May 2004 to June 2004 in accordance with 

generally accepted government auditing standards. 

In summary, ESE sites containing Category I special nuclear material have 

developed plans for implementing the May 2003 DBT. However, we believe 

there are several issues that could make it difficult to implement these 

plans by DOE’s deadline of the end of fiscal year 2006. These specific 

issues are as follows: 

• ESE sites approved their implementation plans during February 2004 

before the Deputy Secretary of Energy issued his April 2004 guidance on 

which sites had improvised nuclear device vulnerabilities. As a result, 

some sites may be required to shift to enhanced protection strategies, 

which could be very costly. Consequently, the assumptions in the ESE site 

plans may no longer be valid, and the plans may need to be revised. 

• ESE site plans are based on the May 2003 DBT; however, DOE is now 

reexamining the May 2003 DBT and may revise it. Consequently, if the 

DBT is changed to increase security requirements, some ESE offices may 

have to revise their implementation plans to reflect the need for a more 

stringent defense. 
Page 3 GAO-04-894T DOE Nuclear Security 

• While ESE sites have developed implementation plans, even under the old 

assumptions, the plan for one site was under funded. Specifically, NE 

security officials told us that for one site no DBT implementation funding 

had been requested for fiscal year 2005. 

• Finally, full implementation of these plans will require the successful 

resolution of complex organizational arrangements between various 

program and security offices. 

We continue to believe, as we recommended in April 2004, that DOE needs 

to develop and implement a department wide multiyear, fully resourced 

implementation plan for meeting the new DBT requirements that includes 

important programmatic activities such as the closure of facilities and the 

transportation of special nuclear materials.3

Five ESE sites collectively contain substantial quantities of Category I 

special nuclear material. These include the following: 

• the Savannah River Site in Savannah River, South Carolina, and the 

Hanford Site in Richland, Washington, which are managed by EM; 

• the Idaho National Engineering and Environmental Laboratory and the 

Argonne National Laboratory-West which are located in Idaho Falls, Idaho, 

and are managed by NE; and 

• the Oak Ridge National Laboratory in Oak Ridge, Tennessee, which is 

managed by SC. 

Contractors operate each site for ESE. The ESE program offices that 

oversee these sites—EM, NE, and SC—have requested about $397 million 

in fiscal year 2005 for security. 

Two other organizations are important contributors to DOE’s security 

program. The Office of Security in DOE’s Office of Security and Safety 

Performance Assurance develops and promulgates orders and policies, 

such as the DBT, to guide the department’s safeguards and security 

programs. The Office of Independent Oversight and Performance 

 3

See U.S. General Accounting Office, Nuclear Security: DOE Needs to Resolve Significant 

Issues Before It Fully Meets the New Design Basis Threat, GAO-04-623 (Washington, D.C.: 

April 27, 2004). 

Background 
Page 4 GAO-04-894T DOE Nuclear Security 

Assurance in DOE’s Office of Security and Safety Performance Assurance 

supports the department by, among other things, independently evaluating 

the effectiveness of contractors’ performance in safeguards and security. It 

also performs follow-up reviews to ensure that contractors have taken 

effective corrective actions and appropriately addressed weaknesses in 

safeguards and security. 

The risks associated with Category I special nuclear materials vary but 

include the creation of improvised nuclear devices capable of producing a 

nuclear yield, theft for use in an illegal nuclear weapon, and the potential 

for sabotage in the form of radioactive dispersal. Because of these risks, 

DOE has long employed risk-based security practices. The key component 

of DOE’s well-established, risk-based security practices is the DBT, a 

classified document that identifies the characteristics of the potential 

threats to DOE assets. The DBT traditionally has been based on a 

classified, multiagency intelligence community assessment of potential 

terrorist threats, known as the Postulated Threat. The DBT considers a 

variety of threats in addition to the terrorist threat. Other adversaries 

considered in the DBT include criminals, psychotics, disgruntled 

employees, violent activists, and spies. The DBT also considers the threat 

posed by insiders, those individuals who have authorized, unescorted 

access to any part of DOE facilities and programs. Insiders may operate 

alone or may assist an adversary group. Insiders are routinely considered 

to provide assistance to the terrorist groups found in the DBT. The threat 

from terrorist groups is generally the most demanding threat contained in 

the DBT. 

DOE counters the terrorist threat specified in the DBT with a multifaceted 

protective system. While specific measures vary from site to site, all 

protective systems at DOE’s most sensitive sites employ a defense-indepth concept that includes sensors, physical barriers, hardened facilities 

and vaults, and heavily armed paramilitary protective forces equipped with 

such items as automatic weapons, night vision equipment, body armor, 

and chemical protective gear. 

The effectiveness of the protective system is formally and regularly 

examined through vulnerability assessments. A vulnerability assessment is 

a systematic evaluation process in which qualitative and quantitative 

techniques are applied to detect vulnerabilities and arrive at effective 

protection of specific assets, such as special nuclear material. To conduct 

such assessments, DOE uses, among other things, subject matter experts, 

such as U.S. Special Forces; computer modeling to simulate attacks; and 
Page 5 GAO-04-894T DOE Nuclear Security 

force-on-force performance testing, in which the site’s protective forces 

undergo simulated attacks by a group of mock terrorists. 

The results of these assessments are documented at each site in a 

classified document known as the Site Safeguards and Security Plan. In 

addition to identifying known vulnerabilities, risks, and protection 

strategies for the site, the Site Safeguards and Security Plan formally 

acknowledges how much risk the contractor and DOE are willing to 

accept. Specifically, for more than a decade, DOE has employed a risk 

management approach that seeks to direct resources to its most critical 

assets—in this case Category I special nuclear material—and mitigate the 

risks to these assets to an acceptable level. Levels of risk—high, medium, 

and low—are assigned classified numerical values and are derived from a 

mathematical equation that compares a terrorist group’s capabilities with 

the overall effectiveness of the crucial elements of the site’s protective 

forces and systems. 

Historically, DOE has striven to keep its most critical assets at a low risk 

level and may insist on immediate compensatory measures should a 

significant vulnerability develop that increases risk above the low risk 

level. Compensatory measures could include deploying additional 

protective forces or curtailing operations until the asset can be better 

protected. In response to a September 2000 DOE Inspector General’s 

report recommending that DOE establish a policy on what actions are 

required once a high or moderate risk is identified, in September 2003, 

DOE’s Office of Security issued a policy clarification stating that identified 

high risks at facilities must be formally reported to the Secretary of Energy 

or Deputy Secretary within 24 hours. In addition, under this policy 

clarification, identified high and moderate risks require corrective actions 

and regular reporting. 

Through a variety of complementary measures, DOE ensures that its 

safeguards and security policies are being complied with and are 

performing as intended. Contractors perform regular self-assessments and 

are encouraged to uncover any problems themselves. DOE Orders also 

require field offices to comprehensively survey contractors’ operations for 

safeguards and security every year. The Office of Independent Oversight 

and Performance Assurance in DOE’s Office of Security and Safety 

Assurance provides yet another check through its comprehensive 

inspection program. All deficiencies identified during surveys and 

inspections require the contractors to take corrective action. 
Page 6 GAO-04-894T DOE Nuclear Security 

Reflecting the post-September 11 environment, the May 2003 DBT, among 

other things, identified a larger terrorist threat than did the 1999 DBT. It 

also expanded the range of terrorist objectives to include radiological, 

biological, and chemical sabotage. Key features of the 2003 DBT included 

the following: 

• Expanded terrorist characteristics and goals. The 2003 DBT assumes that 

terrorist groups are the following: well armed and equipped; trained in 

paramilitary and guerrilla warfare skills and small unit tactics; highly 

motivated; willing to kill, risk death, or commit suicide; and capable of 

attacking without warning. Furthermore, according to the 2003 DBT, 

terrorists might attack a DOE facility for a variety of goals, including the 

theft of a nuclear weapon, nuclear test device, or special nuclear material; 

radiological, chemical, or biological sabotage; and the on-site detonation 

of a nuclear weapon, nuclear test device, or special nuclear material that 

results in a significant nuclear yield. DOE refers to such a detonation as an 

improvised nuclear device. 

• Increased the size of the terrorist group threat. The 2003 DBT increases 

the terrorist threat levels for the theft of the department’s highest value 

assets—Category I special nuclear materials—although not in a uniform 

way. Previously, under the 1999 DBT, all DOE sites that possessed any 

type of Category I special nuclear material were required to defend against 

a uniform terrorist group composed of a relatively small number of 

individuals. Under the 2003 DBT, however, the department judged the 

theft of a nuclear weapon or test device to be more attractive to terrorists, 

and sites that have these assets are required to defend against a 

substantially higher number of terrorists than are other sites. For example, 

a DOE site that, among other things, assembles and disassembles nuclear 

weapons, is required to defend against a larger terrorist group. Other DOE 

sites, such as an EM site that stores excess plutonium, only have to defend 

against a smaller group of terrorists. However, the number of terrorists in 

the 2003 DBT is larger than the 1999 DBT number. DOE calls this a graded 

threat approach. 

• Mandated specific protection strategies. In line with the graded threat 

approach and depending on the type of materials they possess and the 

likely mission of the terrorist group, sites must now implement specific 

protection strategies for Category I special nuclear material. In addition, 

sites will have to develop, for the first time, specific protection strategies 

for facilities, such as radioactive waste storage areas, wastewater 

treatment, and science laboratories, against the threat of radiological, 

chemical, or biological sabotage. 
Page 7 GAO-04-894T DOE Nuclear Security 

• Addressed the potential for improvised nuclear device concerns. The May 

2003 DBT established a special team to report to the Secretary of Energy 

on each site’s potential for improvised nuclear devices. Based on the 

team’s advice, in April 2004 the Deputy Secretary of Energy designated 

whether a site had such a concern. This official designation was intended 

to help address the general dissatisfaction with previous DOE policies for 

improvised nuclear devices, knowledge of which was carefully controlled 

and not shared widely with security officials. For example, some EM sites 

had no information at all on their potential for this risk. 

When we testified before this Subcommittee in April 2004, we stated that 

while DOE had issued the final DBT in May 2003, it had only recently 

begun to resolve a number of significant issues that could affect the ability 

of its sites to fully meet the threat in the new DBT in a timely fashion. 

These issues involved issuing additional DBT implementation guidance, 

developing DBT implementation plans, and developing budgets to support 

these plans. We noted that fully resolving all of these issues might take 

several years, and the total cost of meeting the new threats was currently 

unknown. Consequently, we stated, full DBT implementation could occur 

anywhere from fiscal year 2005 to fiscal year 2008, well beyond the 

department’s goal of the end of fiscal year 2006. Because some sites would 

be unable to effectively counter the higher threat contained in the new 

DBT for up to several years, we stated that these sites should be 

considered to be at higher risk under the new DBT than they were under 

the old DBT. 

After reviewing ESE’s efforts to implement the May 2003 DBT at sites 

containing Category I special nuclear material, we continue to be 

concerned about whether DOE can meet its fiscal year 2006 deadline for 

full DBT implementation. Specifically, while ESE sites that contain 

Category I special nuclear material have developed plans for implementing 

the May 2003 DBT, as directed by the Deputy Secretary of Energy, we 

believe there are four issues that will make it difficult to implement these 

plans in a timely fashion. 

First, ESE sites approved their implementation plans in February 2004 

before the Deputy Secretary of Energy issued his guidance on which sites 

had improvised nuclear device vulnerabilities. As noted previously, the 

May 2003 DBT created a special team, composed of weapons designers 

and security specialists to report on each site’s improvised nuclear device 

vulnerabilities. The results of this report were briefed to senior DOE 

officials in March 2004 and the Deputy Secretary of Energy issued 

A Number of Issues 

May Affect the Ability 

of ESE Sites to Fully 

Meet the Threat 

Contained in the New 

DBT in a Timely 

Fashion 
Page 8 GAO-04-894T DOE Nuclear Security 

guidance, based on this report, to DOE sites in early April 2004. As a result, 

some sites may be required under the 2003 DBT to shift to enhanced 

protection strategies, which could be very costly. This special team’s 

report may most affect ESE sites, because, in some cases, their improvised 

nuclear device potential had not previously been explored. In addition, 

ESE security officials told us that confusion exists about how or if this 

guidance applies to their sites, and they stated that they are working with 

officials from DOE’s Office of Security to resolve this confusion. The 

Director of DOE’s Office of Security and Safety Performance Assurance 

agreed that additional guidance will be necessary to resolve this 

confusion. Consequently, because ESE sites developed their plans well 

before this guidance was issued, the assumptions in their plans may no 

longer be valid and the plans may need to be revised. 

Second, the ESE site implementation plans are based on the May 2003 

DBT; however, DOE is now reexamining the May 2003 DBT and may revise 

it. In our April 2004 report, we expressed several concerns about the May 

2003 DBT. In particular, we noted that some DOE sites may have 

improvised nuclear device concerns that, if successfully exploited by 

terrorists could result in a nuclear detonation. However, under the May 

2003 DBT, DOE only required these sites to defend against a relatively 

small group of terrorists. Because we believed that DOE had not made a 

persuasive case for defending against a lower number of terrorists, we 

recommended that DOE reexamine how it applies the DBT to sites with 

improvised nuclear device concerns. Subsequently, in May 2004, the 

Secretary of Energy announced that the department would reexamine the 

DBT. Originally, this reexamination was to be completed by June 30, 2004. 

However, according to the Director of DOE’s Office of Security and Safety 

Performance Assurance this effort will not be completed until August 6, 

2004. In addition, the Director stated that the end result of this effort may 

only be a plan on how to revise the DBT. Consequently, if the DBT is 

changed in a way that increases security requirements, some ESE offices 

may have to revise their implementation plans to reflect the need to 

provide for a more stringent defense. 

Third, in one case ESE does not have adequate resources. Specifically, 

while ESE sites have developed implementation plans, even under the old 

assumptions, the plan for one site was under funded. NE security officials 

told us that for one site no DBT implementation funding had been 

requested for fiscal year 2005, even though the site recognized that it 

needed to substantially increase its protective forces to meet the new 

DBT. 
Page 9 GAO-04-894T DOE Nuclear Security 

Finally, ESE faces a number of complex organizational issues that could 

make DBT implementation more difficult. Specifically: 

• EM’s Security Director told us that for EM to fully comply with the DBT 

requirements in fiscal year 2006 at one of its sites, it will have to close and 

de-inventory two facilities, consolidate excess materials into remaining 

special nuclear materials facilities, and move consolidated Category I 

special nuclear material, which the National Nuclear Security 

Administration’s Office of Secure Transportation will transport, to another 

site. Likewise, the EM Security Director told us that to meet the DBT 

requirements at another site, EM will have to accelerate the closure of one 

facility and transfer special nuclear material to another facility on the site. 

Because the costs to close these facilities and to move materials within a 

site are borne by the EM program budget and not by the EM safeguards 

and security budget, obtaining adequate funding could be difficult. 

• At an Office of Science site, a building that contains Category I special 

nuclear material is managed and protected by the Office of Science, while 

the material itself belongs to NE. NE is currently planning to remove the 

material and process it. After processing, the material will no longer have 

to meet the protection requirements for Category I special nuclear 

material. Accomplishing this task will require additional security 

measures, the planning and funding for which will have to be carefully 

coordinated between the Office of Science and NE. 

• NE sites face similar issues. For example, the NE Security Director told us 

that EM currently owns all of the Category I special nuclear material 

stored at an NE site. EM is currently planning to have the National Nuclear 

Security Administration’s Office of Secure Transportation transport this 

material to several other locations by the end of January 2005. According 

to the NE site Security Director, NE is counting on the successful removal 

of this special nuclear material to meet the department’s fiscal year 2006 

deadline for implementing the May 2003 DBT. To implement the May 2003 

DBT, NE also needs to consolidate two of its sites into a single national 

laboratory, which will, among other things, ensure that it has an adequate 

number of protective forces. If the EM special nuclear materials are not 

moved and this consolidation is not achieved, the number of protective 

forces at this site may not be adequate. 

Because of the importance of successfully integrating multiple program 

activities with security requirements, we continue to believe, as we 

recommended in April 2004, that DOE needs to develop and implement a 

departmentwide, multiyear, fully resourced implementation plan for 

meeting the May 2003 DBT requirements that includes important 
Page 10 GAO-04-894T DOE Nuclear Security 

programmatic activities such as the closure of facilities and the 

transportation of special nuclear materials. 

Mr. Chairman, this concludes our prepared statement. We would be happy 

to respond to any questions that you or Members of the Subcommittee 

may have. 

For further information on this testimony, please contact Robin M. 

Nazzaro at (202) 512-3841. James Noel and Jonathan Gill made key 

contributions to this testimony. Don Cowan and Preston Heard also made 

contributions to this testimony. 

GAO Contact and 

Staff 

Acknowledgments 

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