Report to the Chairman, Subcommittee 

on National Security, Emerging 

Threats, and International Relations, 

Committee on Government Reform, 

House of Representatives 

United States General Accounting Office 

GAO

April 2004 NUCLEAR SECURITY

DOE Needs to Resolve 

Significant Issues 

Before It Fully Meets 

the New Design Basis 

Threat 

GAO-04-623 
www.gao.gov/cgi-bin/getrpt?GAO-04-623.

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-04-623, a report to the 

Chairman, Subcommittee on National 

Security, Emerging Threats, and 

International Relations, House Committee 

on Government Reform 

April 2004

NUCLEAR SECURITY

DOE Needs to Resolve Significant Issues 

Before It Fully Meets the New Design 

Basis Threat 

DOE took a series of actions in response to the terrorist attacks of 

September 11, 2001. While each of these has been important, DOE must 

press forward with additional actions to ensure that it is fully prepared to 

provide a timely and cost effective defense. 

• DOE took immediate steps to improve physical security in the aftermath 

of the September 11, 2001, terrorist attacks. DOE’s most visible effort 

involved moving to higher levels of security readiness, known as security 

condition (SECON) levels. While this effort has increased the visible 

deterrence at DOE sites, it has been expensive and has resulted in 

fatigue, retention problems, and less training for most sites’ protective 

forces. In addition, the effectiveness of these increased SECON levels 

generally have not been assessed using the vulnerability assessment 

tools, such as computer modeling and full-scale force-on-force exercises, 

that DOE routinely uses to develop protective force strategies for its 

sites. 

• Development of the new DBT took almost 2 years because of (1) delays 

in developing an intelligence community assessment—known as the 

Postulated Threat—of the terrorist threat to nuclear weapon facilities 

and (2) DOE’s lengthy comment and review process for developing 

policy. In addition, during the DBT development process, there were 

sharp debates within DOE and other government organizations over the 

size and capabilities of future terrorist threats and the availability of 

resources to meet these threats that contributed to the delay. 

• While the May 2003 DBT identifies a larger terrorist threat than did the 

previous DBT, the threat identified in the new DBT in most cases is less 

than the threat identified in the intelligence community’s Postulated 

Threat, on which the DBT has been traditionally based. The new DBT 

identifies new possible terrorist acts such as radiological, chemical, or 

biological sabotage. However, the criteria that DOE has selected for 

determining when facilities may need to be protected against these 

forms of sabotage may not be sufficient. 

• DOE has been slow to resolve a number of significant issues, such as 

issuing additional DBT implementation guidance, developing DBT 

implementation plans, and developing budgets to support these plans, 

that may affect the ability of its sites to fully meet the threat contained in 

the new DBT in a timely fashion. Consequently, DOE’s deadline to meet 

the requirements of the new DBT by the end of fiscal year 2006 is 

probably not realistic for some sites. 

A successful terrorist attack on 

Department of Energy (DOE) sites 

containing nuclear weapons or the 

material used in nuclear weapons 

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 

the potential size and capabilities 

of terrorist forces. The terrorist 

attacks of September 11, 2001, 

rendered the then-current DBT 

obsolete. GAO examined DOE’s 

response to the September 11, 

2001, terrorist attacks, identified 

why DOE took almost 2 years to 

develop a new DBT, analyzed the 

higher threat in the new DBT, and 

identified the remaining issues that 

need to be resolved in order for 

DOE to meet the threat contained 

in the new DBT. 

GAO is making a series of 

recommendations to the Secretary 

of Energy to strengthen DOE’s 

ability to meet the requirements of 

the new DBT and to strengthen the 

department’s ability to deal with 

future terrorist threats. DOE did 

not comment on the specific 

recommendations, but said that it 

would consider them as part of its 

Departmental Management 

Challenges for 2004. 
Page i GAO-04-623 Nuclear Security 

Letter 1

Results in Brief 5

Background 8

DOE Took Immediate Steps to Improve Security in the Aftermath 

of September 11, 2001, but the Effectiveness of These Steps Is 

Uncertain 12

Development of the New DBT Took Almost 2 Years Because of 

Delays in Developing the Postulated Threat and DOE’s Lengthy 

Review and Comment Process 15

The May 2003 DBT Identifies a Larger Terrorist Threat, but in Most 

Cases is Less Than the Terrorist Threat Identified by an 

Important Intelligence Community Assessment 18

DOE Has Been Slow to Resolve a Number of Significant Issues 

That May Affect the Ability of its Sites to Fully Meet the Threat 

Contained in the New DBT 23

Conclusions 27

Recommendations for Executive Action 28

Agency Comments and Our Evaluation 29

Appendix I Comments from the Department of Energy 30 

Appendix II GAO Contact and Staff Acknowledgments 31 

GAO Contact 31

Staff Acknowledgments 31 

Contents 
Page ii GAO-04-623 Nuclear Security 

Abbreviations 

DBT design basis threat 

DOD Department of Defense 

DOE Department of Energy 

EM Office of Environmental Management 

NNSA National Nuclear Security Administration 

SECON security condition 

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Page 1 GAO-04-623 Nuclear Security 

April 27, 2004 

The Honorable Christopher Shays 

Chairman, Subcommittee on National Security, 

 Emerging Threats, and International Relations 

Committee on Government Reform 

House of Representatives 

Dear Mr. Chairman: 

The Department of Energy (DOE) has long recognized that a successful 

terrorist attack on a site containing nuclear weapons or the material used 

in nuclear weapons—called special nuclear material—could have 

devastating consequences for the site and its surrounding communities. 

Weapons or special nuclear material are present at the three design 

laboratories—the Los Alamos National Laboratory in Los Alamos, New 

Mexico; the Lawrence Livermore National Laboratory in Livermore, 

California; and the Sandia National Laboratory in Albuquerque, New 

Mexico—and two production sites—the Pantex Plant in Amarillo, Texas, 

and the Y-12 Plant in Oak Ridge, Tennessee, operated by the National 

Nuclear Security Administration (NNSA)—a separately organized agency 

within DOE.1

 Special nuclear material is also present at former production 

sites, including the Savannah River Site in Savannah River, South Carolina, 

and the Hanford Site in Richland, Washington. These former sites are now 

being cleaned up by DOE’s Office of Environmental Management (EM).2

Furthermore, NNSA’s Office of Secure Transportation transports these 

materials among the sites and between the sites and Department of 

Defense (DOD) bases. Contractors operate each site for DOE.3

 NNSA and 

 1

NNSA is responsible for the nation’s nuclear weapons, nonproliferation, and naval 

reactors programs. We did not include Naval Reactors in our review because that office is a 

semiautonomous entity with a unique security structure and program. 

2

At the time of our review, the Rocky Flats Environmental Technology Site in Rocky Flats, 

Colorado, was in the process of shipping its remaining Category I special nuclear material 

primarily to the Savannah River Site. This has now been completed. In addition, 

responsibility for the Idaho National Engineering and Environmental Laboratory, in Idaho 

Falls, Idaho, which is also a Category I special nuclear material site, was transferred from 

DOE’s EM to DOE’s Office of Nuclear Energy in May 2003. 

3

Federal employees instead of contractors operate the assets of the Office of Secure 

Transportation. 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-623 Nuclear Security 

EM have field offices collocated with each site. In fiscal year 2004, NNSA 

and EM expect to spend nearly $900 million on physical security at their 

sites. Physical security combines security equipment, personnel, and 

procedures to protect facilities, information, documents, or material 

against theft, sabotage, diversion, or other criminal acts. 

All the sites listed above have facilities that contain Category I special 

nuclear material. Category I material includes specified quantities of 

plutonium and highly enriched uranium in the following forms: (1) 

assembled nuclear weapons and test devices; (2) pure products containing 

higher concentrations of plutonium or highly enriched uranium, such as 

major nuclear components and recastable metal; and (3) high-grade 

materials, such as carbides, oxides, solutions, and nitrates. The risks 

associated with Category I special nuclear materials vary but include the 

nuclear detonation of a weapon or test device at or near design yield, 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 Category I special nuclear material poses such risks, DOE’s 

effective management of the safeguards and security program, which 

includes developing safeguards and security policies and overseeing 

contractors’ activities, is essential to preventing an unacceptable, adverse 

impact on national security.4

 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. The DBT is a key component of DOE’s well-established, 

risk-based security practices. DOE requires the contractors operating its 

sites to provide sufficient protective forces and equipment to defend 

against the threat contained in the DBT. The effectiveness of these 

protective systems is periodically assessed through a process known as a 

vulnerability assessment. 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, 2001, attacks. 

 4

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

Safeguards and Security Program, GAO-03-471 (Washington, D.C.: May 30, 2003). 
Page 3 GAO-04-623 Nuclear Security 

Following the September 11, 2001, terrorist attacks, you asked us to 

review physical security at DOE sites that have facilities with Category I 

special nuclear material. Specifically, as agreed with your office, we (1) 

examined DOE’s response to the September 11, 2001, attacks; (2) 

identified the reasons DOE needed almost 2 years to develop a new DBT; 

(3) analyzed the higher threat contained in the new DBT; and (4) identified 

the remaining issues that need to be resolved in order for DOE to fully 

defend against the threat contained in the new DBT.5

To determine how DOE responded to the terrorist attacks of September 

11, 2001, we reviewed relevant DOE policy and planning documents, 

including orders and guides, particularly DOE Order 470.1 and DOE Notice 

473.6. In addition, we met with officials from DOE headquarters and site 

offices, as well as contractors who operate DOE sites. The primary offices 

we obtained information from were DOE’s Office of Security, DOE’s Office 

of Independent Oversight and Performance Assurance, DOE’s Office of 

Environmental Management, NNSA’s Office of Defense Nuclear Security, 

and NNSA’s Nuclear Safeguards and Security Program. To review 

augmented security measures put into place after September 11, 2001, 

from March 2002 through June 2003, we visited nine DOE sites and one 

DOE program office that handle Category I special nuclear material. 

Specifically, we visited the Los Alamos National Laboratory and the NNSA 

Office of Los Alamos Site Operations in New Mexico, the Sandia National 

Laboratory and the NNSA Office of Kirtland Site Operations in New 

Mexico, the Lawrence Livermore National Laboratory and the NNSA 

Livermore Site Office in California, the Y-12 Plant and the NNSA Y-12 Site 

Office in Tennessee, the Pantex Plant and the NNSA Office of Amarillo 

Site Operations in Texas, and the NNSA’s Office of Secure Transportation 

in New Mexico. We also visited the Savannah River Site and EM’s 

Savannah River Operations Office in South Carolina, the Rocky Flats 

Environmental Technology Site and EM’s Rocky Flats Field Office in 

Colorado, the Hanford Site and EM’s Richland Operations Office in 

Washington, and the Idaho National Engineering and Environmental 

Laboratory and EM’s Idaho Falls Operations Office in Idaho. 

To determine why DOE needed almost 2 years to develop a new DBT, we 

reviewed historical documents, the four draft DBTs produced between 

 5

We testified on these issues before the Subcommittee on National Security, Emerging 

Threats, and International Relations, House Committee on Government Reform, on June 

24, 2003. See U.S. General Accounting Office, Nuclear Security: DOE’s Response to the 

September 11, 2001 Terrorist Attacks, GAO-03-898TC (Washington, D.C.: June 24, 2003). 
Page 4 GAO-04-623 Nuclear Security 

May 2002 and April 2003, the final May 2003 DBT, and other threat 

guidance provided to us by DOE’s Office of Security. We also reviewed 

associated field and program office comments on the draft DBTs and 

threat guidance. We discussed the DBT development process with DOE’s 

Office of Security, DOE’s Office of Independent Oversight and 

Performance Assurance, EM and NNSA headquarters security offices, and 

federal and contractor personnel at all of the sites and field offices we 

visited. We also discussed postulated terrorist threats to nuclear weapon 

facilities with two DOD organizations: the Office of the Assistant Secretary 

of Defense for Command, Control, Communications, and Intelligence; and 

the Defense Intelligence Agency. We also reviewed The Postulated Threat 

to U.S. Nuclear Weapon Facilities and Other Selected Strategic Facilities, 

henceforth referred to as the Postulated Threat, which is the intelligence 

community’s January 2003 official assessment of potential terrorist threats 

to nuclear weapon facilities. From May 2002 to May 2003, DOE denied us 

access to the draft DBTs it was developing; however, in May 2003, we were 

able to obtain access to the documents and complete our review. 

To analyze the higher threat level contained in the new DBT, we examined 

previous DBTs and related documents provided to us by DOE’s Office of 

Security. We traced how key parameters of the new DBT, such as the size 

of terrorist forces and the treatment of improvised nuclear devices, 

evolved during the 2002 through 2003 DBT development process and 

compared these parameters with previous DBTs and the Postulated 

Threat. We discussed the higher threat level and other key threat aspects 

contained in the final 2003 DBT, such as the graded threat approach; 

improvised nuclear device concerns; and radiological, chemical, and 

biological sabotage criteria; with DOE’s Office of Security; DOE’s Office of 

Independent Oversight and Performance Assurance; EM and NNSA 

headquarters security offices; federal and contractor personnel at all of the 

sites and field offices we visited; DOD’s Office of the Assistant Secretary 

of Defense for Command, Control, Communications, and Intelligence; and 

the Defense Intelligence Agency. In order to determine what industry 

security standards exist to prevent terrorist acts of sabotage at industrial 

chemical facilities, we reviewed a report we issued in March 2003 on 

measures used to protect commercial chemical facilities.6

 6

See U.S. General Accounting Office, Homeland Security: Voluntary Initiatives Are Under 

Way at Chemical Facilities, but the Extent of Security Preparedness Is Unknown, 

GAO-03-439 (Washington, D.C.: Mar. 14, 2003). 
Page 5 GAO-04-623 Nuclear Security 

To identify the remaining issues that DOE must resolve before it can fully 

meet the threat contained in the new DBT, we met with DOE, EM, and 

NNSA headquarters security offices, as well as field security officials. We 

also reviewed relevant documents these offices provided. In particular, we 

reviewed recent Office of Independent Oversight and Performance 

Assurance inspection reports that identified some of the challenges 

associated with meeting the threat contained in the new DBT. DOE did not 

provide us with preliminary cost estimates for meeting the requirements of 

the DBT on the grounds that these costs had not yet been officially 

determined; however, DOE’s Budget Office did outline for us potential 

mechanisms for funding DBT implementation over the next several years. 

We performed our work from December 2001 through April 2004 in 

accordance with generally accepted government auditing standards. 

DOE took immediate steps to improve physical security in the aftermath 

of the September 11, 2001, terrorist attacks. DOE’s most visible effort 

involved moving to higher levels of security readiness, known as security 

condition (SECON) levels. On September 11, 2001, within a matter of 

hours, DOE sites went from their then-normal SECON level 4—terrorist 

threat level low—to SECON level 2—terrorist threat level high. Sites were 

required to increase, among other things, the number of vehicle 

inspections and badge checks, the distance between public and sensitive 

areas to protect against large truck bombs, and the number of protective 

forces on duty, and to more heavily arm these forces. While sites are now 

at SECON level 3, most of these requirements still exist. Increased SECON 

levels have been expensive in both their financial cost and their toll on the 

readiness of the protective forces. Specifically, operating at the increased 

SECON levels has resulted in between $18,000 to $200,000 in unplanned 

costs per week at each site—primarily the result of overtime costs for the 

protective forces. More importantly, according to a June 2003 DOE 

Inspector General’s report, the large amounts of overtime needed to meet 

these SECON requirements have resulted in fatigue, retention problems, 

and less training for protective forces.7

 While the SECON levels have 

increased the visible deterrence at DOE sites, the effectiveness of the 

SECON levels in place at most sites has not been assessed using the 

vulnerability assessment tools, such as computer modeling and full-scale 

 7

Audit Report: Management of the Department’s Protective Forces, DOE/IG-0602, 

Department of Energy, Office of the Inspector General, June 2003. 

Results in Brief 
Page 6 GAO-04-623 Nuclear Security 

force-on-force exercises, that DOE uses to develop protective force 

strategies for its sites. Consequently, DOE cannot assure itself that these 

enhanced requirements are providing effective increases in security. In its 

comments on our report, DOE has agreed to explore procedures to 

incorporate the evaluation of increased SECON levels into its vulnerability 

assessments. 

Development of the DBT took almost 2 years because of delays in 

developing the Postulated Threat and DOE’s lengthy review and comment 

process for developing policy. DOE’s new DBT is based on a study known 

as the Postulated Threat, which was developed by the U.S. intelligence 

community. The intelligence community originally planned to complete 

the Postulated Threat by April 2002; however, the document was not 

completed and officially released until January 2003, about 9 months 

behind the original schedule. According to DOE and DOD officials, this 

delay resulted from other demands placed on the intelligence community 

after September 11, 2001, as well as from sharp debates among the 

organizations developing the Postulated Threat over the size and 

capabilities of future terrorist threats and the resources needed to meet 

these threats. While waiting for the new Postulated Threat, DOE 

developed several drafts of its new DBT. During this process, debates, 

similar to those that occurred during the development of the Postulated 

Threat, emerged in DOE over the size of the future threat and the 

availability of resources to meet it. DOE developed the DBT using DOE’s 

policy process, which emphasizes developing consensus through a review 

and comment process by program offices, such as EM and NNSA. 

However, many DOE and contractor officials found that the policy process 

for developing the new DBT was laborious and not timely, especially given 

the more dangerous threat environment that has existed since September 

11, 2001. As a result, during the time it took DOE to develop the new DBT, 

its sites were only required to defend against the terrorist group defined in 

the 1999 DBT, which in the aftermath of September 11, 2001, DOE officials 

realized was obsolete. 

While the May 2003 DBT identifies a larger terrorist group than did the 

previous DBT, the threat identified in the new DBT, in most cases, is less 

than the terrorist threat identified in the intelligence community’s 

Postulated Threat. The Postulated Threat estimated that the force 

attacking a nuclear weapons site would probably be a relatively small 

group of terrorists, although it was possible that an adversary might use a 

greater number of terrorists if that was the only way to attain an important 

strategic goal. In contrast to the Postulated Threat, DOE is preparing to 

defend against a significantly smaller group of terrorists attacking many of 
Page 7 GAO-04-623 Nuclear Security 

its facilities. Specifically, only for its sites and operations that handle 

nuclear weapons, is DOE currently preparing to defend against an 

attacking force that approximates the lower range of the threat identified 

in the Postulated Threat. For its other Category I special nuclear material 

sites, all of which fall under the Postulated Threat’s definition of a nuclear 

weapons site, DOE is requiring these sites to be prepared to defend against 

a terrorist force significantly smaller than was identified in the Postulated 

Threat. DOE based its departure from the Postulated Threat on the 

conclusions of its own subject matter experts on what they judged likely 

to be the most credible, near-term terrorist threats to its facilities. The new 

DBT also identifies new possible terrorist acts such as radiological, 

chemical, or biological sabotage. However, the criteria that DOE has 

selected for determining when facilities may need to be protected against 

these forms of sabotage may not be sufficient. For example, for chemical 

sabotage, the 2003 DBT requires sites to protect to “industry standards.” 

However, in March 2003, we reported that such standards currently do not 

exist. Consequently, without appropriate standards, DOE cannot ensure 

that its sites and facilities are adequately protected against the full range of 

consequences that might result from terrorist acts. 

While DOE issued the final DBT in May 2003, it has been slow to resolve a 

number of significant issues, such as issuing additional DBT 

implementation guidance, developing DBT implementation plans, and 

developing budgets to support these plans, that may affect the ability of 

DOE sites to fully meet the threat contained in the new DBT. For example, 

DOE has only recently issued additional DBT implementation guidance—

several months behind DOE’s original schedule—and developed initial 

DBT implementation plans. DOE officials currently do not have any 

official estimates of the overall costs of DBT implementation. In addition, 

DOE officials believed that budget information provided by sites for 

inclusion in the fiscal year 2005 budget was of generally poor quality 

because most sites had not yet completed the necessary vulnerability 

assessments to determine their resource requirements. Moreover, other 

important DBT-related issues remain unresolved. For example, the 

Secretary of Energy has not yet designated, as called for in the new DBT, 

which, if any, of DOE’s sites have improvised nuclear device concerns. If a 

site is designated to have such a concern, it may be required to shift to a 

more demanding and costly protection strategy. As a result of these issues, 

DOE is unlikely to meet its own fiscal year 2006 deadline for full 

implementation of the requirements of the new DBT. Specifically, some 

sites estimate that it could take as long as 5 years, given adequate funding, 

to fully meet the requirements of the new DBT. Because some sites will be 

unable to effectively counter the threat contained in the new DBT for a 
Page 8 GAO-04-623 Nuclear Security 

period of up to several years, these sites probably are at higher risk under 

the new DBT than they were under the old DBT. 

We are making recommendations to the Secretary of Energy that are 

intended to strengthen DOE’s ability to meet the requirements of the new 

DBT, as well as to strengthen the department’s ability to deal with future 

terrorist threats. We are also recommending that the Secretary report to 

the Congress on departmental progress in meeting the threat contained in 

the new DBT and reducing risks to critical facilities at its sites. 

We provided DOE with a draft of this report for review and comment. In 

its written comments, DOE said it was committed to the development and 

promulgation of an accurate and comprehensive DBT policy. DOE did not 

comment specifically on our recommendations other than to say that the 

department would consider them as part of its Departmental Management 

Challenges for 2004. DOE has identified the DBT as a major departmental 

initiative within the National Security Management Challenge. 

From the beginning of the Manhattan Project in the 1940s, a primary 

mission of DOE and its predecessor organizations has been to design, test, 

and build the nation’s nuclear weapons. To accomplish this mission, DOE 

constructed a vast nuclear weapons complex throughout the United 

States. Much of this complex was devoted to the production and 

fabrication of weapons components made from two special nuclear 

materials—plutonium and highly enriched uranium. 

The end of the Cold War changed the department’s focus from building 

new weapons to extending the lives of existing weapons, disposing of 

surplus nuclear material, and cleaning up no longer needed weapons sites. 

NNSA is responsible for extending the lives of existing weapons in the 

stockpile and for ultimately disposing of surplus nuclear material, while 

EM is responsible for cleaning up former nuclear weapons sites. 

Contractors, who are responsible for protecting classified information, 

nuclear materials, nuclear weapons, and nuclear weapons components, 

operate both NNSA and EM sites. 

In addition to NNSA and EM, DOE has two other important security 

organizations. DOE’s Office of Security develops and promulgates orders 

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

security programs. DOE’s Office of Independent Oversight and 

Performance Assurance supports the department by, among other things, 

independently evaluating the effectiveness of contractors’ performance in 

Background 
Page 9 GAO-04-623 Nuclear Security 

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 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 has been 

traditionally 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 terrorists. Other 

adversaries considered in the DBT include criminals, psychotics, 

disgruntled employees, violent activists, and spies. The DBT also considers 

the threat posed by insiders, 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 

• a variety of integrated alarms and sensors capable of detecting intruders; 

• physical barriers, such as fences and antivehicle obstacles; 

• numerous access control points, such as turnstiles, badge readers, vehicle 

inspection stations, special nuclear material detectors, and metal 

detectors; 

• operational security procedures, such as a “two person” rule that prevents 

only one person from having access to special nuclear material; 

• hardened facilities and/or vaults; and 

• a heavily armed paramilitary protective force equipped with such items as 

automatic weapons, night vision equipment, body armor, and chemical 

protective gear. 
Page 10 GAO-04-623 Nuclear Security 

Depending on the material, protective systems at DOE Category I special 

nuclear material sites are designed to accomplish the following objectives 

in response to the terrorist threat: 

• Denial of access. For some potential terrorist objectives, such as the 

creation of an improvised nuclear device, DOE may employ a protection 

strategy that requires the engagement and neutralization of adversaries 

before they can acquire hands-on access to the assets. 

• Denial of task. For nuclear weapons or nuclear test devices that terrorists 

might seek to steal, DOE requires the prevention and/or neutralization of 

the adversaries before they can complete a specific task, such as stealing 

such devices. 

• Containment with recapture. Where the theft of nuclear material (instead 

of a nuclear weapon) is the likely terrorist objective, DOE requires that 

adversaries not be allowed to escape the facility and that DOE protective 

forces recapture the material as soon as possible. This objective requires 

the use of specially trained and well-equipped special response teams. 

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 

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. 
Page 11 GAO-04-623 Nuclear Security 

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 such things as 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 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. In addition to 

routine oversight, DOE Orders require field offices to comprehensively 

survey contractors’ operations for safeguards and security every year. 

These surveys, which can draw upon subject matter experts throughout 

the complex, generally take about 2 weeks to conduct and cover such 

areas as program management, protection program operations, 

information security, nuclear materials control and accountability, and 

personnel security. The survey team assigns ratings of satisfactory, 

marginal, or unsatisfactory. DOE’s Office of Independent Oversight and 

Performance Assurance provides yet another check through its 

comprehensive inspection program. This office performs such inspections 

roughly every 18 months at each DOE site that has specified quantities of 

Category I special nuclear material. All deficiencies (findings) identified 

during a survey require the contractors to take corrective action. 
Page 12 GAO-04-623 Nuclear Security 

DOE took immediate steps to improve physical security in the aftermath 

of the September 11, 2001, terrorist attacks. These steps included the 

following: 

• Raised the level of security readiness. Presidential Decision Directive 39, 

issued in June 1995, states that the United States shall give the highest 

priority to developing effective capabilities to detect, prevent, and defeat 

terrorists seeking nuclear weapons or materials. In response, DOE Notice 

473.6 specifies SECONs that have to be implemented at its Category I 

special nuclear material sites in response to a terrorist threat. On 

September 11, 2001, within a matter of hours, DOE sites went from their 

then-normal SECON level 4—terrorist threat level low—to SECON level 

2—terrorist threat level high. Sites were required to implement nearly 30 

additional measures, such as increasing vehicle inspections and badge 

checks; increasing stand-off distances between public and sensitive areas 

to protect against large vehicle bombs; activating and manning emergency 

operations centers on a continuous basis; and more heavily arming and 

increasing the number of protective forces on duty. Sites maintained 

SECON level 2 through October 2001 before dropping to an enhanced 

SECON level 3. The sites have returned to SECON level 2 several times 

since September 11, 2001, most recently in December 2003, when the 

national threat warning system was elevated to Orange Alert. The new 

baseline for security at DOE sites is generally assumed to be the measures 

currently associated with SECON level 3. 

• Denial protection strategies. On October 3, 2001, the Secretary of Energy 

issued a classified directive ordering all sites to develop and implement 

plans to move to a denial protection strategy. DOE Manual 5632.1C-1 

states that a denial protection strategy should be used where unauthorized 

access presents an unacceptable risk. In this regard, denial programs are 

designed to prevent an unauthorized opportunity to credibly initiate a 

nuclear dispersal or detonation or to use available materials for on-site 

assembly of an improvised nuclear device. Denial has typically been 

understood to mean that terrorists would never gain access to certain 

types of special nuclear material. The October 2001 directive also 

increased levels of performance testing for the protection of special 

nuclear material at DOE’s most critical facilities to ensure that these 

denial strategies were effective. 

• Conducted security reviews, studies, and analyses. DOE conducted a 

number of security-related reviews, studies, and analyses. For example, 

within days after the terrorist attacks, DOE and NNSA officials conducted 

a classified assessment of their facilities’ vulnerabilities to an attack by 

aircraft, such as the attacks that occurred on September 11, 2001, or large 

DOE Took Immediate 

Steps to Improve 

Security in the 

Aftermath of 

September 11, 2001, 

but the Effectiveness 

of These Steps Is 

Uncertain 
Page 13 GAO-04-623 Nuclear Security 

vehicle bombs. NNSA also organized a 90-day Combating Terrorism Task 

Force, composed of 12 federal and contractor employee teams that looked 

at a number of security areas. One team, the site-by-site security review 

and vulnerability assessment group, identified and set priorities for over 80 

security improvement projects, totaling more than $2 billion, that could be 

completed within 5 to 6 years. These projects ranged from hiring 

additional protective forces to consolidating special nuclear material. 

• Increased liaison with federal, state, and local authorities. Before the 

September 11 terrorist attacks, DOE headquarters offices and sites 

maintained a variety of relationships, memoranda of understanding, and 

other formal and informal communications with organizations such as the 

Federal Aviation Administration, Federal Bureau of Investigation, and 

state and local law enforcement and emergency management agencies. 

After the terrorist attacks, DOE officials increased their communications 

with these organizations and established direct links through sites’ 

emergency operations centers. Because of the potential threat of aircraft 

attacks created by the September 11 attacks and because of such attacks’ 

potentially devastating consequences, sites worked closely with the 

Federal Aviation Administration and the U.S. military. 

Several benefits have resulted from these immediate measures. With 

respect to improved security, DOE security officials believe that the 

implementation of SECON levels 2 and 3 has, for example, increased the 

visible deterrence at DOE sites by placing more protective forces around 

the sites. Studies and analyses have also resulted in different and less 

vulnerable storage strategies for some special nuclear material. For 

example, one NNSA site purchased special fire and blast-resistant safes to 

store special nuclear material. Finally, some long-recognized security 

enhancement projects have received more funding, such as the 

construction of a new storage facility at an NNSA site, and efforts to 

control access to public areas and roads adjacent to several NNSA sites. 

While these measures have produced several positive outcomes, they have 

also had the following negative impacts: 

• First, the role of the implemented SECON measures in improving DOE 

physical security is uncertain. While DOE Notice 473.6, which established 

the department’s SECON levels, does not explicitly require SECON 

measures to be performance tested, DOE Manual 473.2-2 states that 

performance tests must be used to realistically evaluate and verify the 

effectiveness of protective force programs. While some of the SECON 

measures, such as vehicle inspection checkpoints, have undergone some 

limited performance testing of their effectiveness, most DOE sites 
Page 14 GAO-04-623 Nuclear Security 

generally have not assessed the SECON level measures in place using the 

vulnerability assessment tools, such as computer modeling and full-scale 

force-on-force performance tests, that play such a key role in developing 

and verifying protective strategies at their sites. Consequently, the 

effectiveness of SECON measures against other aspects of the 2003 DBT, 

such as a larger group of well-armed terrorists, is largely unknown. In its 

comments on our report, DOE agreed to explore procedures to 

incorporate the evaluation of increased SECON levels into its vulnerability 

assessments. 

• Second, increased SECON measures have been expensive. DOE sites 

estimate that it costs each site from $18,000 to nearly $200,000 per week in 

unplanned expenditures to implement the required SECON level 2 and 3 

measures. Most of these expenses result from overtime pay to protective 

forces. The costs of the higher SECON levels, however, can be measured 

in more than just budget dollars. Specifically, a June 2003 DOE Inspector 

General’s report found that the large amounts of overtime needed to meet 

the higher SECON requirements have resulted in fatigue, reduced 

readiness, retention problems, reduced training, and fewer force-on-force 

performance tests for the protective forces. Additional protective forces 

have been hired and trained in an effort to provide some relief; however, 

the DOE Inspector General has found that the deployment of additional 

protective forces has been delayed by slow processing of the necessary 

security clearances. 

• Third, the increased operational costs associated with the higher SECON 

levels can hinder or preclude sites from making investments that could 

improve their security over the long term. For example, according to a 

NNSA security official, because of the high costs of maintaining SECON 

measures, one site had to delay purchasing weaponry and ammunition for 

its protective forces to use to defeat commercially available armored 

vehicles that could be used by terrorists. 

• Fourth, the sites did not complete the implementation of the Secretary’s 

October 3, 2001, denial directive because of confusion over its meaning 

and because of the projected high costs of implementation. Over the years, 

DOE has issued varying guidance on denial protection strategies and, as a 

result, the sites have approached denial protection from different 

perspectives. For example, some NNSA sites and operations have 

implemented the most stringent form of denial, which is now defined as 

denial of access. In contrast, other NNSA sites have plans in place to 

interrupt terrorists who have gained access to materials, now called a 

denial of task protection strategy. Most EM sites have practiced 

containment protection strategies augmented by recapture and recovery 
Page 15 GAO-04-623 Nuclear Security 

capabilities. For sites that did not already have a denial strategy in place, 

moving to a full denial of access strategy appears to be enormously 

expensive, with some sites estimating it would cost from about $30 million 

to $200 million to implement the directive completely. Moreover, the 

performance testing requirements of this directive have generally not been 

conducted because of the already large amounts of protective force 

overtime required by the higher SECON levels. For example, a NNSA 

security official at one site estimated it would have to conduct as many as 

30 full-scale force-on-force performance tests each year to comply with the 

Secretary’s Directive. The 2003 DBT, however, has now replaced this 

directive by explicitly defining denial of access and denial of task 

protection strategies and when these strategies should be employed. 

• Finally, while liaison with other agencies is important, DOE officials 

anticipate that any terrorist attacks on their facilities will be short and 

violent and be over before any external responders can arrive. In addition, 

because some DOE sites are close to airports and/or major flight routes, 

they may receive little warning of aircraft attacks, and U.S. military aircraft 

may have little opportunity to intercept these attacks. 

Under DOE Order 470.1, the DBT is intended to provide the foundation for 

all of DOE’s protective strategies. For example, DOE Order 473.2 states 

that protective forces must be trained and equipped to defeat the terrorist 

groups contained in the DBT. In the immediate aftermath of September 11, 

2001, DOE officials realized that the then current DBT, issued in April 1999 

and based on a 1998 intelligence community assessment, was obsolete. 

The September 11, 2001, terrorist attacks suggested larger groups of 

terrorists, larger vehicle bombs, and broader terrorist aspirations to cause 

mass casualties and panic than were envisioned in the 1999 DOE DBT. 

However, formally recognizing these new threats by updating the DBT was 

difficult because of debates over the size of the future threat, the cost to 

meet it, and the DOE policy process. 

The traditional basis for the DBT has been the Postulated Threat, which is 

conducted by the U.S. intelligence community, principally DOD’s Defense 

Intelligence Agency, and the security organizations of a number of 

different agencies, including DOE. For example, DOE closely based its 

1999 DBT on the 1998 Postulated Threat assessment and adopted the same 

number of terrorists as identified by the 1998 Postulated Threat as its 

highest threat to its facilities. Efforts to revise the Postulated Threat began 

soon after the terrorist attacks of September 11, 2001. The intelligence 

community originally planned to complete the Postulated Threat by April 

Development of the 

New DBT Took 

Almost 2 Years 

Because of Delays in 

Developing the 

Postulated Threat and 

DOE’s Lengthy 

Review and Comment 

Process 
Page 16 GAO-04-623 Nuclear Security 

2002; however, the document was not completed and officially released 

until January 2003, about 9 months behind the original schedule. 

According to DOE and DOD officials, this delay was the result of other 

post September 11, 2001, demands placed on the intelligence community, 

as well as sharp debates among the organizations involved with 

developing the Postulated Threat over the size and capabilities of future 

terrorist threats and the resources needed to meet these projected threats. 

While waiting for the new Postulated Threat, DOE developed a number of 

draft documents that culminated in the final May 20, 2003, DBT. These 

documents included the following: 

• December 2001—Interim Joint Threat Policy Statement. DOE and DOD 

worked on this joint draft document but abandoned this effort later in 

2002 because neither agency wanted to act without the benefit of the 

Postulated Threat. 

• January 2002—Interim Implementing Guidance. DOE’s Office of 

Security issued this guidance so that DOE programs could begin to plan 

and budget for eventual increases in the DBT. This interim guidance 

suggested that sites begin planning for an increased number of adversaries 

over the 1999 DBT. 

• May 2002—Draft DBT. DOE produced its first official draft DBT and 

labeled it an interim product pending the release of the Postulated Threat. 

• August 2002—Second Draft DBT. This draft introduced the graded threat 

approach, which is an important feature in the final DBT. 

• December 2002—Third Draft DBT. 

• April 2003—Fourth Draft DBT. This draft was the first to consider the 

final January 2003 Postulated Threat. 

• May 2003—Final DBT. 

Like the participants responsible for developing the Postulated Threat, 

during the development of the DBT, DOE officials debated the size of the 

future terrorist threat and the costs to meet it. DOE officials at all levels 

told us that concern over resources played a large role in developing the 

2003 DBT, with some officials calling the DBT the “funding basis threat,” 

or the maximum threat the department could afford. This tension between 

threat size and resources is not a new development. According to a DOE 
Page 17 GAO-04-623 Nuclear Security 

analysis of the development of prior DBTs, political and budgetary 

pressures and the apparent desire to reduce the requirements for the size 

of protective forces appear to have played a significant role in determining 

the terrorist group numbers contained in prior DBTs. 

Finally, DOE developed the DBT through the standard DOE review and 

comment process for developing policy as outlined in DOE Order 251.1A 

and DOE Manual 251.1-1A. This process emphasizes developing consensus 

and resolving conflicts and involving a wide number of DOE organizations 

and affected contractors. Once DOE formulates a proposed policy, it 

typically allows 60 days for review and comment and 60 days for issue 

resolution. While developing the 2003 DBT, DOE’s Office of Security 

distributed the draft DBTs to DOE program and field offices and invited 

them to provide comments. Field offices distributed the drafts to 

contractors, who were also invited to provide comments. DOE’s Office of 

Security considered these comments and often incorporated them into the 

next version of the DBT. DOE’s Office of Security also continued to 

coordinate with the other federal organizations that have similar assets, 

chiefly DOD and the Nuclear Regulatory Commission. Having followed 

this process for 21 months, the Deputy Secretary of Energy signed the 

revised DBT in May 2003. According to the Director of Policy in DOE’s 

Office of Security, the DBT was developed as fast as possible, given delays 

in completing the Postulated Threat and the constraints of the DOE policy 

system. He added that using the DOE policy process was difficult and 

time-consuming and inevitably added to delays in issuing the new DBT. 

Many officials in DOE’s program offices and sites, as well as contractor 

officials, also found the process to be laborious and not timely, especially 

given the more dangerous threat environment that existed after the 

September 11, 2001, terrorist attacks. 

During the 21 months it took to develop the DBT, DOE sites still officially 

followed the 1999 DBT, although their protective posture was augmented 

by implementing SECON level 2 and 3 measures. EM sites continued to 

conduct vulnerability assessments and develop Site Safeguards and 

Security Plans based on the 1999 DBT. In contrast, NNSA largely 

suspended the development of Site Safeguards and Security Plans pending 

the issuance of the new DBT, although NNSA did embark on a new 

vulnerability assessment process, called Iterative Site Analysis. NNSA 

performed Iterative Site Analysis exercises at a number of its sites. EM 

also conducted an Iterative Site Analysis at one site. Also during this 

period, DOE’s Office of Independent Oversight and Performance 

Assurance continued its inspections; however, it initially reduced the 

amount of force-on-force performance testing it conducted because of the 
Page 18 GAO-04-623 Nuclear Security 

high levels of protective force overtime caused by implementation of 

SECON level 2 and 3 measures. This office also planned to begin 

performance testing at levels higher than the 1999 DBT, but it had done so 

only once before the 2003 DBT was issued. 

Reflecting the post-September 11, 2001, environment, the May 2003 DBT, 

among other things, identifies a larger terrorist threat than did the 

previous DBT. It also mandates specific protection strategies and expands 

the range of terrorist objectives to include radiological, biological, and 

chemical sabotage. However, the threat identified in the new DBT, in most 

cases, is less than the terrorist threat identified in the intelligence 

community’s Postulated Threat. Key features of the 2003 DBT include 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 or NNSA 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 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 judges 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, an NNSA 

site that, among other things, assembles and disassembles nuclear 

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

NNSA sites, some of which fabricate nuclear weapons components, or EM 

sites that store 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. 

The May 2003 DBT 

Identifies a Larger 

Terrorist Threat, but 

in Most Cases is Less 

Than the Terrorist 

Threat Identified by 

an Important 

Intelligence 

Community 

Assessment 
Page 19 GAO-04-623 Nuclear Security 

• 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, such as denial of access, denial of task, or 

containment with recapture for their most sensitive facilities and assets. 

For example, one NNSA site is required under the new DBT to implement 

a denial of task strategy to prevent terrorists from stealing a nuclear 

weapon or test device. In contrast, other DOE sites are required to 

implement a containment with recapture strategy to prevent the theft of 

special nuclear material. However, if these sites have an improvised 

nuclear device concern, they will have to implement denial of access or 

denial of task strategies. Finally, 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. Previously, in an 

April 1998 policy clarification, DOE’s Office of Security had stated that, 

assuming that baseline security requirements were met, radiological 

dispersal sabotage events were not considered attractive to terrorists. 

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

DBT establishes a team to report to the Secretary of Energy on each site’s 

potential for improvised nuclear devices. Based on the teams’ advice, the 

Secretary of Energy will have to designate whether a site has such a 

concern. This official designation should help address the general 

dissatisfaction with previous DOE policies for improvised nuclear devices, 

knowledge of which is carefully controlled and not shared widely with 

security officials. For example, some EM sites have had no information at 

all on their potential for this risk, and at least one NNSA site official 

believed that scenarios for such risks have not been fully characterized. 

• Introduced aircraft threats and mitigation measures. In the 1999 DBT, 

DOE only acknowledged the risk for unspecified air attacks but did not lay 

out any protective measures to mitigate this risk. In the 2003 DBT, DOE 

considers aircraft as airborne improvised explosive devices. DOE’s new 

policy is to rely on other federal government agencies, such as the 

Departments of Homeland Security and Defense, to defeat such a threat. 

DOE sites are expected, however, to consider measures, such as how they 

handle and store their materials, to mitigate the consequences of an 

aircraft attack on existing facilities, and new DOE facility designs are 

expected to include features to mitigate the consequences of an attack. 

While DOE’s 2003 DBT makes some important advances, aspects of the 

DBT raise several important issues. 
Page 20 GAO-04-623 Nuclear Security 

First, while the May 2003 DBT identifies a larger terrorist group than did 

the previous DBT, the threat identified in the new DBT in most cases is 

less than the terrorist threat identified in the intelligence community’s 

Postulated Threat. The Postulated Threat applies to nuclear weapons sites, 

which the Postulated Threat defines as research and development 

facilities with nuclear weapons, components, or special nuclear material; 

weapons production facilities; sites for long-term storage of nuclear 

weapons; and nuclear weapons in transport. With respect to these sites, 

the Postulated Threat specified the following: 

• There is a credible threat to U.S. facilities with nuclear or chemical 

weapons or biological agents. 

• A well-organized terrorist group presents the greatest and most likely 

threat in most circumstances. 

• Terrorists may use aircraft as weapons. 

• Terrorists may use multiple vehicle bombs loaded with explosives. 

• Terrorist groups would probably consist of a small to medium sized group 

of well-armed and trained members. A larger force is possible if the group 

thought this was necessary to attain an important strategic goal. 

• Terrorist objectives include the theft of a weapon, detonation of a nuclear 

weapon in place, radiological sabotage, mass casualties, and/or public 

panic. 

In contrast to the Postulated Threat, DOE is preparing to defend against a 

significantly smaller group of terrorists attacking most of its facilities. 

Specifically, only for its sites and operations that handle nuclear weapons, 

is DOE currently preparing to defend against an attacking force that 

approximates the lower range of the threat identified in the Postulated 

Threat. For the other DOE sites that have Category I special nuclear 

material—all of which fall under the Postulated Threat’s definition of a 

nuclear weapons site—DOE is currently only preparing to defend against a 

smaller number terrorists—or approximately the same number contained 

in its DBT in the early 1980s. 

Second, and more critically, some of these sites may have improvised 

nuclear device concerns that, if successfully exploited by terrorists, could 

result in a nuclear detonation. Nevertheless, under the graded threat 

approach, DOE requires these sites only to be prepared to defend against a 
Page 21 GAO-04-623 Nuclear Security 

smaller force of terrorists than was identified by the Postulated Threat. 

DOE’s Office of Security cited subject matter expert opinion as support for 

this distinction. However, according to officials in DOE’s Office of 

Independent Oversight and Performance Assurance, sites with improvised 

nuclear device concerns should be held to the same requirements as 

facilities that possess nuclear weapons and test devices since the potential 

worst-case consequence at both types of facilities would be the same—a 

nuclear detonation. Some DOE officials and an official in DOD’s Office of 

the Assistant Secretary of Defense for Command, Control, 

Communications, and Intelligence disagreed with the overall graded threat 

approach, believing that the threat should not be embedded in the DBT by 

adjusting the number of terrorists that might attack a particular target. 

DOE Office of Security officials cited three reasons for why the 

department departed from the Postulated Threat’s assessment of the 

potential size of terrorist forces. First, these officials stated that they 

believed that the Postulated Threat only applied to sites that handled 

completed nuclear weapons and test devices. However, both the 2003 

Postulated Threat, as well as the preceding 1998 Postulated Threat, state 

that the threat applies to nuclear weapons and special nuclear material 

without making any distinction between them. Second, DOE Office of 

Security officials believed that the higher threat levels contained in the 

2003 Postulated Threat represented the worst potential worldwide 

terrorist case over a 10-year period. These officials noted that while some 

U.S. assets, such as military bases, are located in parts of the world where 

terrorist groups receive some support from local governments and 

societies, thereby allowing for an expanded range of capabilities, DOE 

facilities are located within the United States, where terrorists would have 

a more difficult time operating. Furthermore, DOE Office of Security 

officials stated that the DBT focuses on a nearer-term threat of 5 years. As 

such, DOE Office of Security officials said that they chose to focus on 

what their subject matter experts believed was the maximum, credible, 

near-term threat to their facilities. However, while the 1998 Postulated 

Threat made a distinction between the size of terrorist threats abroad and 

those within the United States, the 2003 Postulated Threat, reflecting the 

potential implications of the September 2001 terrorist attacks, did not 

make this distinction. Finally, DOE Office of Security officials stated that 

the Postulated Threat document represented a reference guide instead of a 

policy document that had to be rigidly followed. The Postulated Threat 

does acknowledge that it should not be used as the sole consideration to 

dictate specific security requirements and that decisions regarding 

security risks should be made and managed by decision makers in policy 

offices. However, DOE has traditionally based its DBT on the Postulated 
Page 22 GAO-04-623 Nuclear Security 

Threat. For example, the prior DBT, issued in 1999, adopted exactly the 

same terrorist threat size as was identified by the 1998 Postulated Threat. 

Finally, the department’s criteria for determining the severity of 

radiological, chemical, and biological sabotage may be insufficient. For 

example, the criterion used for protection against radiological sabotage is 

based on acute radiation dosages received by individuals. However, this 

criterion may not fully capture or characterize the damage that a major 

radiological dispersal at a DOE site might cause. For example, according 

to a March 2002, DOE response to a January 23, 2002, letter from 

Representative Edward J. Markey, a worst-case analysis at one DOE site 

showed that while a radiological dispersal would not pose immediate, 

acute health problems for the general public, the public could experience 

measurable increases in cancer mortality over a period of decades after an 

event. Moreover, releases at the site could also have environmental 

consequences requiring hundreds of millions to billions of dollars to clean 

up. Contamination could also affect habitability for tens of miles from the 

site, possibly affecting hundreds of thousands of residents for many years. 

Likewise, the same response showed that a similar event at a NNSA site 

could result in a dispersal of plutonium that could contaminate several 

hundred square miles and ultimately cause thousands of cancer deaths. 

For chemical sabotage standards, the 2003 DBT requires sites to protect to 

industry standards. However, we reported last year that such standards 

currently do not exist. Specifically, we found that no federal laws 

explicitly require chemical facilities to assess vulnerabilities or take 

security actions to safeguard their facilities against terrorist attack. 

Finally, the protection criteria for biological sabotage are based on 

laboratory safety standards developed by the U.S. Centers for Disease 

Control, not physical security standards. 
Page 23 GAO-04-623 Nuclear Security 

While DOE issued the final DBT in May 2003, it has been slow to resolve a 

number of significant issues that may affect the ability of its sites to fully 

meet the threat contained in the new DBT in a timely fashion. Fully 

resolving these issues may take several years and the total cost of meeting 

the new threats is currently unknown. Because some sites will be unable 

to effectively counter the higher threat contained in the new DBT for up to 

several years, these sites should be considered to be at higher risk under 

the new DBT than they were under the old DBT. 

In order to undertake the necessary range of vulnerability assessments to 

accurately evaluate their level of risk under the new DBT and implement 

necessary protective measures, DOE recognized that it had to complete a 

number of key activities. DOE only recently completed two of these key 

activities. First, in February 2004, DOE issued its Adversary Capabilities 

List, which is a classified companion document to the DBT, that lists the 

potential weaponry, tactics, and capabilities of the terrorist group 

described in the DBT. This document has been amended to include, among 

other things, heavier weaponry and other capabilities that are potentially 

available to terrorists who might attack DOE facilities. DOE is continuing 

to review relevant intelligence information for possible incorporation into 

future revisions of the Adversary Capabilities List. 

Second, DOE also only recently provided additional DBT implementation 

guidance. In a July 2003 report, DOE’s Office of Independent Oversight 

and Performance Assurance noted that DOE sites had found initial DBT 

implementation guidance confusing. For example, when the Deputy 

Secretary of Energy issued the new DBT in May 2003, the cover memo said 

the new DBT was effective immediately but that much of the DBT would 

be implemented in fiscal years 2005 and 2006. According to a 2003 report 

by the Office of Independent Oversight and Performance Assurance, many 

DOE sites interpreted this implementation period to mean that they 

should, through fiscal year 2006, only be measured against the previous, 

less demanding 1999 DBT. In particular, the 2003 report found that one 

NNSA site was planning to conduct certain operations starting in 2003 that 

involved special nuclear material using security plans that did not comply 

with even the 1999 DBT. Consequently, the Office of Independent 

Oversight and Performance Assurance recommended that the site suspend 

these planned operations until it had adequate security plans that reflected 

the new DBT. NNSA security officials concurred with this 

recommendation and postponed the site’s proposed operations. 

DOE Has Been Slow 

to Resolve a Number 

of Significant Issues 

That May Affect the 

Ability of its Sites to 

Fully Meet the Threat 

Contained in the New 

DBT 
Page 24 GAO-04-623 Nuclear Security 

In response to this confusion, the Deputy Secretary issued further 

guidance in September 2003 that called for the following, among other 

things: 

• DOE’s Office of Security to issue more specific guidance by October 22, 

2003, regarding DBT implementation expectations, schedules, and 

requirements. DOE issued this guidance January 30, 2004. 

• Quarterly reports showing sites’ incremental progress in meeting the new 

DBT for ongoing activities. 

• Immediate compliance with the new DBT for new and reactivated 

operations. 

Other important DBT-related issues remain unresolved. First, as noted 

earlier, a special team created in the 2003 DBT, composed of weapons 

designers and security specialists, finalized its report on each site’s 

improvised nuclear device vulnerabilities. The results of this report were 

briefed to senior DOE officials in March 2004. Based on this team’s report, 

the Secretary may officially designate some sites as having an improvised 

nuclear device concern. If this designation is made, some sites may be 

required under the 2003 DBT to shift to a denial of access or denial of task 

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

may most affect EM sites because their improvised nuclear device 

potential had not been explored until this review, and their formal 

protection strategy remains at the less demanding containment with 

recapture and recovery level. DOE officials have not identified when the 

Secretary will make these designations. 

Second, DOE’s Office of Security has not completed all of the activities 

associated with the new vulnerability assessment methodology it has been 

developing for over a year. DOE’s Office of Security believes this 

methodology, which uses a new mathematical equation for determining 

levels of risk, will result in a more sensitive and accurate portrayal of each 

site’s defenses-in-depth and the effectiveness of sites’ protective systems 

(i.e., physical security systems and protective forces) when compared with 

the new DBT. DOE’s Office of Security decided to develop this new 

equation because its old mathematical equation had been challenged on 

technical grounds and did not give sites credit for the full range of their 

defenses-in-depth. While DOE’s Office of Security completed this equation 

in December 2002, officials from this office believe it will probably not be 

completely implemented at the sites for at least another year for two 

reasons. First, site personnel who implement this methodology will require 
Page 25 GAO-04-623 Nuclear Security 

additional training to ensure they are employing it properly. DOE’s Office 

of Security conducted initial training in December 2003, as well as a 

prototype course in February 2004, and has developed a nine-course 

vulnerability assessment certification program. Second, sites will have to 

collect additional data to support the broader evaluation of their 

protective systems against the new DBT. Collecting these data will require 

additional computer modeling and force-on-force performance testing. 

Because of the slow resolution of some of these issues, DOE has not 

developed any official long-range cost estimates or developed any 

integrated, long-range implementation plans for the May 2003 DBT. 

Specifically, neither the fiscal year 2003 nor 2004 budgets contained any 

provisions for DBT implementation costs. However, during this period, 

DOE did receive additional safeguards and security funding through 

budget reprogramming and supplemental appropriations. DOE used most 

of these additional funds to cover the higher operational costs associated 

with the increased SECON measures. DOE has gathered initial DBT 

implementation budget data and has requested additional DBT 

implementation funding in the fiscal year 2005 budget: $90 million for 

NNSA, $18 million for the Secure Transportation Asset within the Office of 

Secure Transportation, and $26 million for EM. However, DOE officials 

believe the budget data collected so far has been of generally poor quality 

because most sites have not yet completed the necessary vulnerability 

assessments to determine their resource requirements. Consequently, the 

fiscal year 2006 budget may be the first budget to begin to accurately 

reflect the safeguards and security costs of meeting the requirements of 

the new DBT. Reflecting these various delays and uncertainties, in 

September 2003, the Deputy Secretary changed the deadline for DOE 

program offices, such as EM and NNSA, to submit DBT implementation 

plans from the original target of October 2003 to the end of January 2004. 

NNSA and EM approved these plans in February 2004. 

A DOE Office of Budget official told us that current DBT implementation 

cost estimates do not include items such as closing unneeded facilities, 

transporting and consolidating materials, completing line item 

construction projects, and other important activities that are outside of the 

responsibility of the safeguards and security program. For example, 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 
Page 26 GAO-04-623 Nuclear Security 

• close and de-inventory two facilities, 

• consolidate excess materials into remaining special nuclear materials 

facilities, and 

• move consolidated Category I special nuclear material, which NNSA’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. 

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. Similarly, the costs to transport the material between sites 

are borne by NNSA’s Office of Secure Transportation budget and not by 

EM’s safeguards and security budget. A DOE Office of Budget official told 

us that a comprehensive, department-wide approach to budgeting for DBT 

implementation that includes such important program activities as 

described above is needed; however, such an approach does not currently 

exist. 

The department plans to complete DBT implementation by the end of 

fiscal year 2006. However, most sites estimate that it will take 2 to 5 years, 

if they receive adequate funding, to fully meet the requirements of the new 

DBT. During this time, sites will have to conduct vulnerability 

assessments, undertake performance testing, and develop Site Safeguards 

and Security Plans. Consequently, full DBT implementation could occur 

anywhere from fiscal year 2005 to fiscal year 2008. Some sites may be able 

to move more quickly and meet the department’s deadline of the end of 

fiscal year 2006. For example, one NNSA site already has developed 

detailed plans and budgets to meet the new DBT requirements. 

While this site may be already close to meeting the new DBT requirements, 

other DOE sites are at higher risk to the threats specified under the 2003 

DBT than they were under the old 1999 DBT. For example, the Office of 

Independent Oversight and Performance Assurance has concluded in 

recent inspections that at least two DOE sites face fundamental and not 

easily resolved security problems that will make meeting the requirements 

of the new DBT difficult. For other DOE sites, their level of risk under the 

new DBT remains largely unknown until they can conduct the necessary 

vulnerability assessments. Because some sites will be unable to effectively 

counter the threat contained in the new DBT for a period of up to several 
Page 27 GAO-04-623 Nuclear Security 

years, these sites should be considered to be at higher risk under the new 

DBT than they were under the old DBT. 

DOE took a series of immediate actions in response to the terrorist attacks 

of September 11, 2001. While each of these actions have been important, in 

and of themselves, we believe they are not sufficient to ensure that all of 

DOE’s sites are adequately prepared to defend themselves against the 

higher terrorist threat present in a post September 11, 2001 world. Rather, 

DOE must press forward with a series of actions to ensure that it is fully 

prepared to provide a timely and cost effective defense. 

First, DOE needs to know the effectiveness of its most immediate 

response to September 11, 2001—the move to higher SECON levels. The 

higher SECON levels, while increasing the level of visible deterrence, have 

come at a significant cost in budget dollars and protective force readiness. 

We believe that DOE needs to follow its own policies and use its wellestablished vulnerability assessment methodology to evaluate the 

effectiveness of these additional security measures. 

Second, because the September 11, 2001, terrorist attacks suggested larger 

groups of terrorists with broader aspirations of causing mass casualties 

and panic, we believe that the DBT development process that was used 

requires reexamination. While DOE may point to delays in the 

development of the Postulated Threat as the primary reason for the almost 

2 years it took to develop a new DBT, DOE was also working on the DBT 

itself for most of that time. We believe the difficulty associated with 

developing a consensus using DOE’s traditional policy-making process 

was a key factor in the time it took to develop a new DBT. During this 

extended period, DOE’s sites were only being defended against what was 

widely recognized as an obsolete terrorist threat level. 

Third, we are concerned about two aspects of the resulting DBT. We are 

not persuaded that there is sufficient difference, in its ability to achieve 

the objective of causing mass casualties or creating public panic, between 

the detonation of an improvised nuclear device and the detonation of a 

nuclear weapon or test device at or near design yield that warrants setting 

the threat level at a lower number of terrorists. Furthermore, while we 

applaud DOE for adding additional requirements to the DBT such as 

protection strategies to guard against radiological, chemical, and 

biological sabotage, we believe that DOE needs to reevaluate its criteria 

for terrorist acts of sabotage, especially in the chemical area, to make it 

more defensible from a physical security perspective. 

Conclusions 
Page 28 GAO-04-623 Nuclear Security 

Finally, because some sites will be unable to effectively counter the threat 

contained in the new DBT for a period of up to several years, these sites 

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

were under the old DBT. Consequently, DOE needs to take a series of 

actions to mitigate these risks to an acceptable level as quickly as possible. 

To accomplish this, it is important for DOE to resolve a number of DBT 

and DBT-related issues and go about the hard business of a 

comprehensive department-wide approach to implementing needed 

changes in its protective strategy. Because the consequences of a 

successful terrorist attack on a DOE site could be so devastating, we 

believe it is important for DOE to inform the Congress about what sites 

are at high risk and what progress is being made to reduce these risks to 

acceptable levels. 

In order to strengthen DOE’s ability to meet the requirements of the new 

DBT, as well as to strengthen the department’s ability to deal with future 

terrorist threats, we are making the following seven recommendations to 

the Secretary of Energy: 

• Evaluate the cost and effectiveness of existing SECONs and how they are 

implemented using DOE’s vulnerability assessment methodology. 

• Review how the DBT is developed to determine if using the current policymaking approach is appropriate given the dynamic post-September 11, 

2001, security environment. 

• Reexamine the current application of the graded threat approach to sites 

that may have improvised nuclear device concerns. 

• Reexamine the criteria established in the May 2003 DBT to determine 

levels of risk from radiological, biological, and chemical sabotage to 

ensure that they are appropriate from a security standpoint. 

• Ensure that all remaining DBT and DBT related-issues, such as the 

designation of improvised nuclear device concerns and the new 

vulnerability assessment methodology, are completed on an expedited 

schedule. 

• 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. 

Recommendations for 

Executive Action 
Page 29 GAO-04-623 Nuclear Security 

• Report regularly to relevant congressional oversight committees on: (1) 

the status of DBT implementation as reflected by the required quarterly 

DBT implementation progress reports and (2) which sites and facilities are 

currently considered to be at high risk under the new DBT and what steps 

are being taken to mitigate these risks to acceptable levels. 

We provided DOE with a draft of the classified version of this report for 

review and comment. In its written comments, DOE said it was committed 

to the development and promulgation of an accurate and comprehensive 

DBT policy. DOE did not comment specifically on our recommendations 

other than to say that the department would consider them as part of its 

Departmental Management Challenges for 2004. DOE has identified the 

DBT as a major departmental initiative within the National Security 

Management Challenge. In an enclosure attached to its comments, DOE 

also provided some additional technical information that we incorporated 

where appropriate. DOE’s letter commenting on our draft report is 

presented in appendix I. 

We are sending copies of this report to the Secretary of Energy, the 

Director of the Office of Management and Budget, and appropriate 

congressional committees. We also will make copies available to others 

upon request. In addition, the report will be available at no charge on the 

GAO Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please call me at 

(202) 512-3841. Major contributors to this report are listed in appendix II. 

Sincerely yours, 

Robin M. Nazzaro 

Director, Natural Resources 

 and Environment 

Agency Comments 

and Our Evaluation 
Appendix I: Comments from the Department 

of Energy 

Page 30 GAO-04-623 Nuclear Security 

Appendix I: Comments from the Department 

of Energy 
Appendix II: GAO Contact and Staff 

Acknowledgments 

Page 31 GAO-04-623 Nuclear Security 

James Noel (202) 512-3591 

In addition to the individuals named above, Jonathan Gill, Chris Pacheco, 

Andrea Miller, Chris Abraham, Jill Berman, Carol Hernstadt Shulman, 

Joyce Evans, and Gail Traynham also made key contributions to this 

report. 

Appendix II: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(360451) 
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