Nuclear Security: Action May Be Needed to Reassess the Security of NRC-Licensed Research Reactors
Published: 2008-01-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: There are 37 research reactors in the United States, mostly located on college campuses. Of these, 33 reactors are licensed and regulated by the Nuclear Regulatory Commission (NRC). Four are operated by the Department of Energy (DOE) and are located at three national laboratories. Although less powerful than commercial nuclear power reactors, research reactors may still be attractive targets for terrorists. As requested, GAO examined the (1) basis on which DOE and NRC established the security and emergency response requirements for DOE and NRC-licensed research reactors and (2) progress that the National Nuclear Security Administration (NNSA) has made in converting U.S. research reactors that use highly enriched uranium (HEU) to low enriched uranium (LEU) fuel. This report summarizes the findings of GAO's classified report on the security of research reactors (GAO-08-156C).
section_title: What GAO Found
paragraphs: DOE developed the security and emergency response requirements for its research reactors using its Design Basis Threat--a process that establishes a baseline threat for which minimum security measures should be developed. These research reactors benefit from the greater security required for the national laboratories where they are located, which store weapons-usable nuclear materials. DOE also has concluded that the consequences of an attack at some of its research reactors could be severe, causing radioactivity to be dispersed over many square miles and requiring the evacuation of nearby areas. As a result, all facilities where DOE reactors are located have extensive plans and procedures for responding to security incidents. NRC based its security and emergency response requirements largely on the regulations it had in place before September 2001. NRC decided that the security assessment it conducted between 2003 and 2006 showed that these requirements were sufficient. While it was conducting this assessment, NRC worked with licensees to improve security when weaknesses were detected. However, GAO found that NRC's assessment contains questionable assumptions that create uncertainty about whether the assessment reflects the full range of security risks and potential consequences of attacks on research reactors. For example, Sandia National Laboratories (SNL)--a contractor NRC used to assist in performing its assessment-- found that some NRC-licensed research reactors may not be prepared for certain types of attacks. However, NRC disagreed with SNL's finding. In 2006, NRC concluded that the consequences of attacks would result in minimal radiological exposure to the public. In addition, NRC assumed that terrorists would use certain tactics in attacking a reactor but did not fully consider alternative attack scenarios that could be more damaging. Finally, NRC assumed that a small part of a reactor could be damaged in an attack, resulting in the release of only a small amount of radioactivity. However, according to experts at Idaho National Laboratories and the Department of Homeland Security, it is possible that a larger part of a reactor could be damaged, which could result in the release of larger amounts of radioactivity. NNSA has made progress in changing from HEU to LEU fuel in U.S. research reactors but may face difficulty in converting some of the remaining research reactors. Since 1978, NNSA has converted eight currently operating U.S. research reactors, including two in 2006. In addition, NNSA plans to convert 10 more U.S. research reactors by September 2014--five of which are scheduled for conversion by 2009. However, NNSA faces difficulties in converting the remaining five reactors because these reactors cannot operate with the currently available LEU fuel. NNSA is now developing a new LEU fuel that will allow the remaining five reactors to operate. However, according to NNSA, developing this fuel has been problematic, as early efforts experienced failures during testing. NNSA officials acknowledged that further setbacks are likely to delay plans to convert these research reactors.

section_title: Letter
paragraphs: Nuclear research reactors located throughout the United States play an  important role in education, medicine, industry, national security, and  basic scientific research. Currently, 37 research reactors operate in the  United States. Of these reactors, 33 are licensed and regulated by the  Nuclear Regulatory Commission (NRC) and 4 are operated by the  Department of Energy (DOE).  The DOE research reactors are located at  three national laboratories: Oak Ridge National Laboratory (ORNL),  Sandia National Laboratories (SNL), and Idaho National Laboratory (INL).  Research reactors are less powerful than commercial nuclear power  reactors, ranging in size from less than 1 megawatt (MW) to 250 MW,  compared with the 3,000 MW found for a typical commercial nuclear  power reactor.
Although research reactors are less powerful than commercial nuclear  power reactors, they may nevertheless be targets for terrorists determined  to steal reactor fuel for use in a nuclear weapon or radiological dispersal  device (dirty bomb) or to sabotage a reactor in order to disperse  radioactive material into the atmosphere over neighboring communities.  For example, unlike commercial nuclear power reactors, several research  reactors use highly enriched uranium (HEU) fuel instead of low-enriched  uranium (LEU) fuel, which make them a target because HEU is a key  component in the construction of some nuclear weapons. Furthermore,  most NRC-licensed research reactors are located on university campuses;  and while they have security systems in place, they are also accessible to  students for educational purposes.
Through a series of orders, manuals, and directives, DOE has established  security requirements for all of its facilities, including those that maintain  nuclear materials. The key component of the security requirements is the  Design Basis Threat (DBT) document. The DBT identifies the size and  capability of terrorist forces and the potential consequences of terrorist  attacks.  From this document, DOE developed the security objectives and  policies and the security measures necessary to protect nuclear weapons,  nuclear weapons components, special nuclear material, national  laboratories, and other critical DOE assets against the attacking force  described in the DBT.
While NRC maintains a DBT for the commercial power reactors it licenses,  it does not have a DBT for NRC-licensed research reactors. However, NRC  has assessed threat scenarios to NRC-licensed research reactors and has   identified as potential threats the theft of fuel for use in a nuclear weapon,  dirty bomb, radiological exposure device, and sabotage to disperse  radioactive material. In addressing these threats, NRC must ensure that its  security requirements are consistent with section 104(c) of the Atomic  Energy Act of 1954. Section 104(c) directs NRC to impose only “such  minimum amount of regulation” of a research reactor licensee as NRC  finds will permit it to fulfill its obligations to promote the common defense  and security and protect public health and safety of the public, and will  permit the conduct of widespread and diverse research and development.  Security requirements for NRC-licensed research reactors are based on a  graded approach; that is, research reactors possessing larger quantities of  nuclear material or using material potentially more attractive to  adversaries are generally required to have more security measures in  place.
Both DOE and NRC require reactor operators or licensees to develop and  implement emergency response plans to prepare for accidents and  possible terrorist attacks. Among other things, these plans are to address  the coordination of activities by emergency first responders, including  police, fire, medical, and hazardous materials personnel. These plans may  also include guidelines for when and how areas near a research reactor  should be evacuated.
Following the events of September 11, 2001, NRC assessed the security of  NRC-licensed research reactors in order to determine whether additional  security measures were warranted. Unlike a DBT, the assessment did not  prescribe specific security standards. Instead, the security assessment  analyzed the effectiveness of security at individual NRC-licensed research  reactors and the potential consequences of terrorist attacks. NRC  contracted with SNL for this assessment because, according to NRC  officials, SNL has considerable expertise in assessing the security of  nuclear facilities. To determine the types of threats that needed to be  taken into account during the security assessment, NRC and SNL used a  threat assessment developed by NRC from current intelligence  information that identified the potential threats to NRC-licensed research  reactors.
Beyond these efforts to secure research reactors and plan for  emergencies, the United States has had a policy since 1978 of reducing  and, to the extent possible, replacing the use of HEU fuel in research  reactors with LEU fuel. While HEU is a key component in the construction  of nuclear weapons, LEU is poorly suited for this use. Accordingly,  replacing HEU with LEU reduces the risk that terrorists will gain access to  the material needed to construct a nuclear weapon. To support this policy,  DOE initiated the Reduced Enrichment for Research and Test Reactors  (RERTR) program, or reactor conversion program, to develop the  technology to reduce and eventually eliminate the use of HEU in research  reactors worldwide. The National Nuclear Security Administration  (NNSA), a separately organized agency within DOE, oversees the reactor  conversion program.
In response to your request concerning the security of U.S. research  reactors, we examined (1) the basis on which DOE and NRC established  the security and emergency response requirements for DOE and NRC- licensed research reactors and (2) the progress NNSA has made in its  ongoing efforts to convert U.S. research reactors that use HEU fuel to LEU  fuel. In October 2007, we reported to you on the results of our work in a  classified report. Subsequently, you asked us to provide you with an  unclassified version of our report. This report summarizes the results of  our classified report.
To address these objectives, we reviewed relevant DOE and NRC policy,  planning, and analysis documents, including DOE’s DBT and NRC’s threat  assessment document.  Both of these documents establish a baseline  threat for which minimum security measures should be developed. We  also reviewed inspection oversight manuals, security plans, emergency  plans, and the relevant provisions of the Code of Federal Regulations. For  both DOE and NRC-licensed research reactors, we reviewed NRC, SNL,  Los Alamos National Laboratory, and INL reports and studies to assess the  potential consequences of an attack on research reactors. In addition, at  our request—an INL reactor vulnerability expert whose expertise includes  evaluating and modeling the effects of radiological sabotage—analyzed the  consequences of a radiological sabotage attack against a research reactor  with characteristics similar to some mid-powered NRC-licensed reactors.  Prior to performing the analysis, the INL expert and GAO discussed and  agreed on the assumptions that would be used in the analysis. GAO’s Chief  Technologist reviewed the INL expert’s analysis and found it met  sufficiency, competency, and relevancy standards for GAO sources.  Additionally, we interviewed a Department of Homeland Security (DHS)  expert regarding some of the key inputs used in the INL expert’s analysis.  We also discussed the INL expert’s analysis with INL management, who  stated that the analysis was technically accurate and that its reactor  vulnerability expert had done good work in preparing it.
We also visited research reactor sites, including all four DOE-operated  research reactors and 10 of the 33 NRC-licensed research reactors. To  select these reactors, we used a nonprobability (or judgmental) sample  based on reactor size in terms of power and geographic location.  Accordingly, we were able to review a variety of security measures in  place for reactors of different power levels, including some of the most  powerful, and for reactors at locations with varying relative population  densities. At both DOE and NRC-licensed research reactors, we examined  security systems and interviewed officials, including directors of reactor  operations, campus security, and local police and fire officials. A GAO  special agent specializing in security systems participated in the visits to  two DOE and five NRC-licensed research reactors. Furthermore, we  interviewed officials representing DOE’s Offices of Health, Safety and  Security, University Programs, Security Policy, and Security Evaluations;  the NNSA office that implements the reactor conversion program; and  several offices within NRC, including its Research and Test Reactors  Branch, Office of Nuclear Security and Incident Response, Division of  Security Policy, and Reactor Security Branch. Finally, we interviewed INL  and SNL scientists and officials, as well as several security and reactor  experts at universities and nongovernmental organizations, who have  conducted studies or are considered experts on the potential effects of  attacks on research reactors to obtain differing perspectives about  research reactor security. We conducted the work for the classified report  between May 2006 and July 2007 in accordance with generally accepted  government auditing standards and we conducted our work for the  unclassified report between October 2007 and January 2008.  Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
subsections: section_title: Background
paragraphs: Table 1 lists the 37 research reactors operating in the United States. Of the  33 reactors that NRC licenses and regulates, 27 are located on university  campuses. In contrast, all DOE research reactors are located in relatively  isolated locations and at facilities where public access is restricted  because weapons-usable nuclear materials associated with DOE’s nuclear  weapons programs are also stored on site.
Several factors may make research reactors a target for terrorists. For  example, most U.S. research reactors are located on university campuses;  while these research reactors have security systems in place, none are  protected with the kind of security or armed security forces that protect  nuclear power reactors. Furthermore, once inside the reactor building,  terrorists may gain access to the reactor. Figure 1 shows the inside of a  research reactor. In addition, while power reactors use LEU fuel, several  research reactors still use HEU fuel in order to produce the appropriate  conditions in the reactor for conducting a wide variety of research. HEU is  attractive to terrorists looking to construct a crude nuclear weapon. NRC’s  Office of Nuclear Reactor Regulation has oversight responsibility for all  NRC-licensed research reactors. DOE’s Office of Nuclear Energy, Science,  and Technology’s Radiological Facilities Management program is charged  with maintaining DOE research reactors in a secure manner.
To enforce safety, security, and emergency planning requirements, both  DOE and NRC conduct routine inspections to ensure compliance with  DOE orders, manuals, and directives and with NRC regulations. DOE’s  Office of Independent Oversight and Performance Assurance—which  independently assesses the effectiveness of DOE policies and programs in  safeguards and security and emergency management for DOE facilities— routinely inspects DOE facilities for compliance with DOE safeguards and  security requirements. NRC-licensed research reactors are licensed and  routinely inspected by inspectors representing NRC’s Research and Test  Reactor Section. The requirements for the physical protection of NRC- licensed research reactors are set out in NRC regulations and primarily  focus on preventing the theft and diversion of fuel. In addition to the  specific requirements established in the regulations, NRC may require—  depending on the individual facility and site conditions—any additional  measures it deems necessary to protect against radiological sabotage at  research reactors that it licenses to operate above 2 MW of power.  Commensurate with the security requirements, security related inspection  activity is based on a graded approach, where security measures are based  on the type and quantity of nuclear material on site. For example, research  reactors licensed to possess more than 5 kilograms of HEU are inspected  at least annually, while reactors that are licensed to possess less than 1  kilogram of HEU are inspected at least triennially.
NRC used its security assessment of NRC-licensed research reactors to  determine whether additional security measures were warranted. NRC’s  assessment considered an analysis of security at reactors, as well as the  consequences of attacks. The security assessment also included site- specific assessments of NRC-licensed research reactors to determine the  vulnerability of structures, security operations, and physical protection  systems, as well as access control systems at research reactors. Using  varying numbers of adversaries and capabilities, NRC assessed threat  scenarios, which included theft of fuel for use in a nuclear weapon or dirty  bomb and sabotage attacks designed to disperse radioactive material. NRC  used the number of immediate fatalities caused by radiological release  resulting from an attack at a research reactor as its criterion to measure  consequences and assessed the adequacy of the security at NRC-licensed  reactors. If NRC discovered that there was potential to affect public  health, it was to identify countermeasures to mitigate or prevent the  consequences, while considering the cost-effectiveness of these  countermeasures.
As a complement to DOE and NRC security efforts, NNSA’s Reactor  Conversion Program has a goal of reducing or eliminating the use of HEU  at research reactors. To support this goal, NRC promulgated a rule in 1986  requiring all NRC-licensed research reactors to convert to LEU if feasible  and if DOE provided adequate funding. In addition, under the 2005 North  American Security and Prosperity Partnership, the United States, Mexico,  and Canada agreed to convert civil HEU reactors on the North American  continent to LEU fuel, where such LEU fuel is available. Since 2004, NNSA  has overseen the fuel conversion of U.S. research reactors. To achieve  NNSA’s goal, in 2005, NNSA’s reactor conversion program partnered with  the DOE Office of Nuclear Energy University Reactors Program to  accelerate the conversion of U.S. research reactors by providing funding  to enable research reactors where LEU is available to convert as rapidly as  possible. INL is the technical lead for the reactor conversion program’s  fuel development effort.
section_title: DOE Used Its DBT to Develop Security and Emergency Response Requirements for Its Reactors, Which Also Benefit from National Laboratories’ Enhanced Security
paragraphs: To protect its four research reactors, DOE uses the security and  emergency requirements developed from its DBT and counts on the  security afforded by the reactors’ locations at certain national laboratories  that require heightened security. Furthermore, DOE has concluded that  consequences from an attack at some of its research reactors could be  severe and has therefore established extensive plans and procedures for  safety and security incidents.
subsections: section_title: DOE Research Reactors Are Protected by Requirements of the DBT and Their Location at National Laboratories
paragraphs: DOE’s research reactors benefit from the greater security required for the  national laboratories where the research reactors are located. The  laboratories are engaged in nuclear weapon activities or store special  nuclear material and therefore are to meet the requirements for DOE’s  2003 DBT. This DBT was developed to support DOE policies for  preventing unauthorized access, theft, or sabotage of nuclear weapons and  all special nuclear material under DOE’s jurisdiction. More specifically,  following the DBT, DOE requires its research reactors to be protected in a  graded manner; that is, a reactor possessing more dangerous nuclear  material must be safeguarded more securely than those that have less  dangerous material. For example, SNL and INL–-the locations of DOE’s  Annular Core Research Reactor and its Neutron Radiography Reactor,  respectively—store weapons-usable nuclear materials and therefore have  robust security features and specially dedicated, heavily armed guard  forces. The other two DOE reactors—the Advanced Test Reactor and High  Flux Isotope Reactor—located at INL and ORNL, respectively, have  extensive security features, including perimeter barbed-wire fences and  armed security guards at all times. In addition, DOE requires that all  personnel with routine access to DOE reactors have a federal security  clearance. Among other things, this requirement helps to reduce the  possibility of an insider threat.
We also found that DOE is engaged in efforts to improve security at the  reactor sites. For example, at the SNL and INL sites the locations of the  Annular Core Research Reactor and Neutron Radiography Reactor,  respectively, DOE recently made several security upgrades, including  installing new surveillance systems with thermal imaging cameras; these  cameras enable surveillance of the surrounding territory for up to several  miles, regardless of light and weather conditions.  Despite extensive  security features at DOE research reactors, we did find a security  weakness and some research reactor vulnerabilities. Specifically, we  discovered that the Web site for one DOE research reactor contained  information about its refueling schedule. According to security experts,  reactors are more vulnerable during refueling because large doors that are  normally tightly secured must be opened to deliver fuel. After we brought  this weakness to DOE’s attention, the department removed the  information. Concerning vulnerabilities, at two DOE research reactors, we  discovered key features at the reactor facilities that were vulnerable to  attack, as DOE officials acknowledged. In both cases, the reactor  operators store large amounts of spent reactor fuel in pools that are easily  accessible to anyone inside the reactor facility. According to national  laboratory officials at both of these facilities, this fuel is dangerous  because if it is damaged during a terrorist attack, it could cause a large  radiological release into the area surrounding the research reactor. During  visits to both facilities, the reactor operators said that an attack on their  spent fuel concerned them just as much as an attack on the actual reactor  because of the potential for release of radiological material into the  atmosphere. These operators said that the spent fuel needs to be removed  for disposal; DOE plans to remove most of this spent fuel by 2012.
section_title: DOE Has Established Extensive Plans and Procedures for Safety and Security Incidents
paragraphs: DOE has concluded that the consequences of an attack at some of its  research reactors could be severe, possibly causing radiation to be  dispersed over many square miles and requiring the evacuation of nearby  areas. As a result, all facilities where DOE reactors are located have  established extensive plans and procedures for responding to reactor  emergencies, as DOE policies require. For example, ORNL—the location  of the High Flux Isotope Reactor—has a laboratory shift superintendent  on duty at all times to classify potential events and coordinate preplanned  responses geared to the nature of the event. According to ORNL officials,  emergencies can lead to the mobilization of significant numbers of  security personnel trained to respond to emergencies at the reactor. This  mobilization could include the activation of the mutual assistance  agreement between ORNL and the neighboring Y-12 National Security  Complex to deploy Y-12’s off-duty security forces to ORNL in the event of  a terrorist attack. DOE policies also require DOE research reactor  operators, with DOE and laboratory officials, to assess the worst-case  consequences of accidents or terrorist attacks at their research reactors  and develop emergency response plans that call for evacuating areas up to  300-square miles surrounding the reactor in the event of a potentially  hazardous radiological release into the atmosphere. Decisions to evacuate  are made based on the amount of radiation to which people could be  exposed, as determined by their proximity to the reactor and the amount  of radioactivity released. Furthermore, in worst-case scenarios, DOE  reactor facility emergency plans include multijurisdictional plans outlining  the immediate coordination of regional and federal emergency response  assets.
section_title: Security and Emergency Response Requirements for NRC-Licensed Research Reactors Are Based on Questionable Assumptions, Meaning That Reactors May Not Be Adequately Protected
paragraphs: NRC decided to largely retain the security and emergency response  regulations it had in place before September 11, 2001. NRC decided to  retain these requirements after conducting a security assessment between  2003 and 2006 and determining that these requirements were sufficient.  However, we found that NRC’s security assessment used questionable  analysis and assumptions that may not fully reflect the consequences of a  terrorist sabotage attack. According to experts at INL and DHS, the  consequences of a terrorist attack on a research reactor could be more  than what NRC estimates. Consequently, even though a number of NRC- licensed research reactors have recently improved security, NRC’s  security and emergency response requirements may need immediate  strengthening to protect against the consequences of an attack.
subsections: section_title: NRC’s Security Assessment May Not Adequately Reflect the Potential Consequences of a Terrorist Attack on Its Licensed Research Reactors
paragraphs: Between 2003 and 2006, NRC conducted a security assessment of NRC- licensed research reactors to determine whether existing security and  emergency response requirements were sufficient to protect against an  attack. NRC first conducted a screening analysis to assess the significance  of the consequences of a sabotage attack at each of the 33 NRC-licensed  research reactors and established a minimum radiological dose that an  attack would have to produce before further assessment was warranted.  Eventually, NRC concluded that the potential effects of terrorists  sabotaging these 33 reactors were minimal and that the security and  emergency response regulations for research reactor licensees did not  need strengthening.
In conducting this assessment, NRC established a minimum radiological  dosage as the criterion to determine if a full security assessment was  necessary. During its initial phase of this assessment, NRC determined that  most of the reactors would experience minimal consequences from  sabotage and therefore present a low radiological risk to public health and  safety. For the remaining reactors, NRC conducted a further detailed  security assessment. NRC concluded that the potential effects of an attack   at these reactors were also minimal and that the security and emergency  response regulations for research reactors did not need strengthening.
NRC’s security assessment also included SNL’s evaluation of the security  of NRC-licensed research reactors; however, NRC disagreed with several  of SNL’s findings. NRC contracted with SNL to help perform its security  assessment, and as part of this work, SNL estimated the probabilities that  terrorists could successfully carry out an attack on NRC-licensed reactors.  SNL found that some NRC-licensed research reactors may not be prepared  for certain types of terrorist attacks. For example, SNL’s analysis of  several reactors found that under certain scenarios involving a small group  of well-trained terrorists, an attack on a reactor could be successful. NRC,  however, believed that SNL’s assumptions about terrorists’ capabilities  were excessive and that SNL did not give enough credit to the capabilities  of first responders. Ultimately, NRC disagreed with SNL about the security  of research reactors. In its final analysis, NRC concluded that, because the  radiological consequences of an attack would be minimal, no changes in  the security and emergency response regulations for NRC-licensed  research reactors were necessary.
However, NRC’s security assessment may contain important  shortcomings. As a result, NRC may not have a sound basis for  determining the adequacy of security and emergency response  requirements for its licensed research reactors. Based on our analysis and  an analysis conducted by an INL reactor vulnerability expert at our  request, we concluded that NRC’s security assessment used questionable  assumptions and analyses about research reactor security and the  potential consequences of an attack on NRC-licensed research reactors.  Specifically, NRC made the following assumptions that we have reason to  question:    NRC assumed that terrorists would use certain weapons and tactics in  attacking a reactor but did not fully consider alternative attack scenarios  which could be more damaging if carried out successfully. According to an  SNL expert, attacking a research reactor using this alternative approach  would be a difficult and sophisticated task, which would likely require  specific knowledge of reactors and sabotage techniques. Nonetheless, this  expert stated that such an attack was possible and identified detailed  information for carrying it out. Moreover, the attack scenarios that NRC  did not fully consider could lead to more significant consequences than  NRC estimates, according to an INL reactor vulnerability expert.
NRC assumed that only a small portion of a research reactor could be  damaged in a terrorist attack, resulting in the release of only a small  amount of radioactivity into the atmosphere. However, according to  experts at INL and DHS, it is possible that a larger portion of a research  reactor could be damaged in a terrorist attack. If this occurred, these  experts also noted that an attack could result in a release of a larger  amount of radioactivity into the atmosphere over neighboring  communities.
NRC assumed that insiders with access to the reactor would only  participate to a limited degree. However, in similar security assessments  for DOE facilities, DOE assumes that insiders would fully participate in an  attack, and it has designed its defenses on the assumption of full  participation. Fully participating insiders could both provide information,  such as details of the facility layout and operating schedule, as well as  participate in an attack by performing key functions, such as opening  doors or disabling alarm systems. NRC officials acknowledge that if its  assessment had assumed fully participating insiders, then the results of its  assessment may have turned out differently. “It is clear that an event as described in this report could have significant consequences.  The consequences of a successful sabotage attack in addition to the direct dose could be  significant radioactive material release and subsequent contamination of areas that have  high socio-economic impact. It is important that the risk from these reactors be well  characterized and the emergency preparedness for such an event be included  the  planning process.”
Because most NRC-licensed research reactors are located on college  campuses or in urban areas, the release of large amounts of radiation  could affect a substantial portion of the population.
We discussed the INL reactor vulnerability expert’s analysis with INL’s  Deputy Associate Laboratory Director for National and Homeland Security  Directorate, who stated that the analysis was technically accurate and that  their reactor vulnerability expert had done good work in preparing it.  However, he cautioned us that the analysis represented the efforts of only  one of INL’s reactor vulnerability experts. In his view, a more  comprehensive analysis of the vulnerability and the consequences of a  terrorist attack on a research reactor is warranted. Such a study should  include experts from a variety of technical areas, including national  intelligence sources, and involve more than one laboratory. These experts  would determine the most appropriate assumptions that should be used in  the analysis. For example, according to the Deputy Associate Laboratory  Director, one important part of such an analysis would be examining the  physical nature of damaging a research reactor. This could be done  through modeling and actual experiments. Once this is determined, it  would inform other aspects of a reactor vulnerability analysis and result in  a more comprehensive understanding of the potential consequences of a  terrorist attack.
We shared the results of INL’s reactor vulnerability expert’s analysis with  NRC, who disagreed with several of the basic assumptions and findings  concerning the consequences of an attack on a research reactor. NRC’s  reasons for its disagreement, and our analysis of these reasons, are  discussed in detail in the classified version of this report.
section_title: Despite Recent Security Improvements, NRC’s Security and Emergency Response Requirements May Not Sufficiently Address the Potential Consequences of an Attack
paragraphs: NRC maintains an active oversight program of all research reactor  licensees, which includes routine safety and security inspections. Between  2001 and 2006, NRC worked with its licensees to make immediate security  improvements to research reactors where needed. As a result of  continuing oversight activities, when NRC found additional security  measures were necessary to ensure public health and safety, NRC  requested that licensees implement additional security measures. NRC  verified improved security through inspections and issued letters formally  binding the licensees to maintain security enhancements.
During our visits to NRC-licensed research reactors, we found the  following improvements to security:  improved access controls to key areas inside reactor facilities,    augmented surveillance of activities within controlled access areas, and  improved alarm and communication systems.
For example, one NRC research reactor licensee installed antitruck bomb  barriers, including concrete and steel reinforced poles and a steel cable  gate, which are not required for the category of reactor at this particular  facility. In fact, we discovered that several of NRC’s research reactor  licensees have made security improvements that exceed NRC’s security  requirements. Similarly, to address the potential truck bomb threat,  several other NRC research reactor licensees have placed jersey barriers  near exterior parts of reactor buildings. Figure 2 shows a research reactor  building surrounded with jersey barriers. Some NRC-licensed research  reactors have added jersey barriers, installed new steel-hardened doors,  and improved camera surveillance systems. Still another licensee installed  a new alarm system that is hardwired to the closest police station, which  monitors reactor alarms at all times.
Despite such improvements, we identified potential shortcomings with  current security and emergency response requirements and measures.  These requirements and measures may require immediate attention if  NRC’s assessment of the consequences of an attack on its licensed  reactors is deficient. For example:    At two research reactors we visited, we found features of the reactor that  if damaged during an attack could make the reactor more at risk for  radiological releases.
According to an SNL security analysis of NRC-licensed research reactors,  a number of reactors could be attacked and sabotaged by well-trained  terrorists. If an NRC-licensed research reactor were attacked, the local  police would have to assess the threat and determine the appropriate  response before the attackers have completed the tasks needed to  sabotage the reactor.
At still another research reactor, we found an unlocked and unalarmed  access leading directly into the reactor room. In this case, the licensee is  relying on another security measure that might be overcome. However,  this measure could be compromised. In our view, it is both sensible and  inexpensive to put a lock and an alarm trigger on this access to the reactor  room, rather than depend on having one element of the security system  function flawlessly.
In response to the Energy Policy Act of 2005, NRC has begun to address a  potential security weakness we identified during our review. Specifically,  we found that NRC did not require research reactor licensees to conduct  extensive background checks on their staff with access to reactors.  However, starting in 2006, NRC began requiring research reactor licensees  to fingerprint staff with access to sensitive security information and  subject them to a criminal history background check by the Federal  Bureau of Investigation. Furthermore, in May 2007, NRC ordered research  reactor licensees to subject all staff with unescorted access to reactors to  this check.
All of the NRC-licensed research reactors that we visited have detailed and  coordinated emergency plans for responding to terrorist attacks, including  the deployment of police, Special Weapons and Tactics (SWAT), fire,  ambulance, and hazardous material personnel to the reactor facility. In  addition, most NRC-licensed research reactors licensees we visited have  agreements with local law enforcement and other first responders for  responses to emergencies. For example, the research reactor at the  Massachusetts Institute of Technology has memorandums of  understanding with the city of Cambridge Police Department, Fire  Department, Emergency Management Department, and Massachusetts  General Hospital outlining cooperation in case of emergencies. However,  we found weaknesses in two key areas of NRC emergency response plan  requirements—evacuation planning and first response:  Few Reactors Have Evacuation Planning. Evacuation planning is  important because most NRC-licensed reactors are located in highly  populated areas, with other buildings located near the reactor facility. For  example, one NRC-licensed research reactor is located within 100 yards of  a day-care facility, 300 yards of a university dormitory, and one-half mile of  a stadium that holds more than 90,000 fans on game days during football  season. NRC regulations for emergency plans require licensees to establish  plans for coping with emergencies, but NRC does not require that these  plans include evacuation plans for areas surrounding its licensed reactors.  Instead, these requirements only require licensees to establish limited  emergency planning zones, which vary in size depending on the size of the  reactor. The acceptable emergency planning zone for reactors that NRC  licenses to operate at 2 MW or less—that is, 30 of the 33 NRC-licensed  research reactors—is limited to the grounds of the reactor facility; there  are no evacuation plans for the areas surrounding the reactor. Two other  NRC-licensed research reactors—at the Massachusetts Institute of  Technology and the University of Missouri, Columbia—must establish an  emergency planning zone with possible evacuation of 100 meters  surrounding the research reactor; the 20 MW National Institute of  Standards and Technology reactor must establish an emergency planning  zone of 400 meters.
Some First Responders Are Not Armed. NRC regulations on  emergency response require that licensees ensure that a watchman or off- site response force will respond to unauthorized entrance or activity at  research reactors, but regulations do not require first responders for  emergencies at research reactors to be armed. At most NRC-licensed  reactors we visited, the designated first responders are armed. At a few  reactors, however, unarmed campus police—not local law enforcement  agencies—would be the first responders when alarms are set off. Such  plans are likely to delay an armed police response. According to SNL  security experts, the lack of a timely armed response increases the risk  that a terrorist attack will be successful.
section_title: NNSA Has Made Progress in Converting U.S. Research Reactors from HEU to LEU Fuel, but It Faces Challenges in Converting Some Remaining Research Reactors
paragraphs: NNSA has converted 8 currently operating U.S. research reactors from  HEU to LEU fuel and has plans to convert 10 remaining reactors by 2014.  However, NNSA will confront challenges in converting 5 of these 10  remaining research reactors because they cannot be converted with fuel  that is currently available. According to NNSA and national laboratory  officials, the schedule for fuel development is optimistic and further  technical setbacks in fuel development would likely delay their research  reactor conversion plans.
subsections: section_title: NNSA Has Converted 8 Currently Operating U.S. Research Reactors and Has Plans to Convert 10 Remaining Reactors
paragraphs: Since 1978, when the reactor conversion program started, DOE has  converted a total of 8 currently operating U.S. research reactors from HEU  to LEU fuel. In 2004, we reported on the progress of the reactor  conversion program and recommended, among other things, that NNSA  place a higher priority on converting these reactors. In response to our  recommendation, in 2006, NNSA converted 2 more operating U.S. research  reactors from HEU to LEU fuel. NNSA plans to convert an additional 10  U.S. research reactors by 2014, including 5 that can convert with currently  available fuel and 5 that cannot convert with currently available fuel. The 2  NRC-licensed research reactors that converted in 2006 were reactors at  the University of Florida and Texas A&M University, which were  converted at a cost of about $3 million and $7 million, respectively. These  recent conversions represent the first U.S. conversions since 2000 and are  part of NNSA’s expanded effort to convert research reactors worldwide.
NNSA plans to convert the remaining 5 U.S. research reactors that can  convert with currently available fuel by September 2009 at an estimated  cost of $37 million (see table 2).
section_title: NNSA Faces Challenges in Converting 5 of the 10 Remaining Reactors
paragraphs: NNSA has set a target date of 2014 for converting the five remaining HEU  research reactors that cannot convert with currently available fuel. NNSA  is now developing a new fuel that will allow the remaining five reactors to  convert; according to an NNSA official, this new fuel must be developed  by 2011 if NNSA is to meet its 2014 conversion schedule goal. We believe  that the conversion schedule may be optimistic because developing this  fuel has been problematic. For example, early efforts to develop the fuel  experienced failures during testing that caused NNSA to push back  anticipated completion dates from 2008 to 2010, and NNSA has since  delayed the completion of the fuel until 2011. Argonne National Laboratory  officials working on the fuel development effort at that time characterized  the failures during testing as the worst they had ever experienced.  According to NNSA officials and INL fuel development scientists, more  recent attempts to develop new LEU fuel appear promising. In addition, a  series of recent successful tests of the new fuel, including fuel fabrication  and testing at the Advanced Test Reactor are indicative of the potential to  successfully develop the new LEU fuel. However, NNSA and national  laboratory officials acknowledged that the fuel development schedule is  optimistic and that further technical setback would likely delay DOE’s  research reactor conversion plans. NNSA estimates that an additional $46  million will be needed to actually convert reactors once the fuel is  available. This estimate is uncertain. If any further technical difficulties are  experienced in the process of developing the new fuel, additional funding  will be required for further fuel improvements, and the estimated  conversion date will not be met. Table 3 outlines the schedule for  converting the five research reactors that cannot convert with currently  available fuel.
section_title: Conclusions
paragraphs: The NRC-licensed nuclear research reactors located throughout the  United States play an important role in education and basic scientific  research. However, because most of these reactors are located on  university campuses, they face unique challenges in both remaining  accessible for educational purposes and providing enough security to  protect neighboring communities from the potentially significant impacts  of a terrorist attack. Understanding the consequences of a terrorist attack  on these research reactors is critical to determining the level of security  needed to protect them. To understand the consequences of an attack,  NRC conducted a security assessment of its licensed reactors and  concluded that the consequences would be minimal—having almost no  effect on nearby areas. However, NRC’s security assessment may  underestimate the potential consequences of an attack because it used  assumptions and analyses about reactor security and terrorist capabilities  that we believe are questionable. Additionally, NRC’s conclusions are not  supported by the findings of SNL, an INL reactor vulnerability expert, and  a DHS expert. SNL found that a group of well-trained terrorists could gain  access to a number of NRC-licensed research reactors. Moreover, INL and  DHS experts believe that it is possible that a meaningful portion of a  research reactor could be damaged in an attack. Such an attack could  result in a radioactive release that is greater than NRC estimates in their  assessment. Without an analysis that better reflects the full range of expert  opinion on the security of reactors and the capabilities of potential  terrorist forces, NRC will not have fully considered the risks posed by  research reactors. NRC will also lack assurance that it has established  security and emergency response plan requirements commensurate with  the risks posed by attacks on its licensed research reactors.
section_title: Recommendations for Executive Action
paragraphs: To better understand and prepare for the potential consequences of a  terrorist attack on NRC-licensed research reactors, we recommended in  our October 2007 classified report that the Chairman of NRC reassess the  consequences of terrorist attacks on NRC-licensed research reactors using  assumptions that better reflect a fuller range of outside expert opinion on  the security of reactors and the capabilities of potential terrorist forces.
If NRC finds that the consequences of an attack on a research reactor are  more severe than previously estimated, we recommended that the  Chairman of NRC take the following three actions:    ensure that the security requirements for research reactors are  commensurate with the consequences of attacks,  reexamine emergency response requirements to address whether  evacuation plans should be included, and  require that first responders to alarms at research reactors be armed.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided DOE, NNSA, and NRC with draft copies of our classified  report for their review and comment. As discussed in our classified report,  NNSA, whose comments also reflected DOE’s views, generally agreed with  the report and provided minor technical comments, which we  incorporated as appropriate in this unclassified report as well. NRC did  not agree with the report and stated that the report provides an  unbalanced assessment of its effort to enhance security at research  reactors since September 11, 2001.  NRC summarized its views in a  separate unclassified letter which we have included in appendix I, along  with our comments.
NRC criticized our report in four areas. First, NRC stated that the draft  report misrepresented the effort it has made following September 11, 2001,  to assess and enhance the security of research reactors; it also asserted  that we compared security requirements for NRC-licensed research  reactors with DOE operated reactors and that the comparison is  incomplete and inaccurate. Second, NRC stated that we misrepresented its  use of the SNL security assessment and that we incorrectly stated that  NRC had dismissed the findings in SNL’s assessment. Third, NRC asserted  that our report misrepresented or excluded key facts. Finally, NRC  believes that our assumptions concerning terrorist attack scenarios lack a  sound technical basis.
First, we disagree with NRC’s assertion that our report misrepresents the  Commission’s efforts since September 11, 2001, to assess and enhance the  security of research reactors. We accurately describe NRC’s active  oversight actions, including routine inspections for safety and security.  Furthermore, we give NRC credit for working with research reactor  licensees to make, and to verify, many security improvements that NRC  identified as necessary. We also discuss the many security features and  improvements at NRC-licensed research reactors that we visited and note  that several of the licensees have made security improvements that exceed  NRC’s security requirements. Furthermore, contrary to NRC’s comments,  our report does not compare security requirements for NRC-licensed and  DOE operated research reactors or actual security conditions at the  reactors. Rather, our report discusses our findings on security  requirements and their implementation at NRC-licensed and DOE  operated research reactors.
Second, we disagree with NRC’s assertion that our report misrepresents  NRC’s use of the SNL security assessment and that NRC dismissed SNL’s  security assessment. Our report did not state that NRC “dismissed” the  security assessment; instead, it accurately states that NRC “disagreed”  with SNL about the security of research reactors. Furthermore, NRC itself  has reiterated this disagreement with the SNL analysis in writing on  several occasions. Specifically, when NRC provided us with copies of  SNL’s security assessment, it also provided a disclaimer stating that NRC  “does not support many of the assumptions and/or information contained  in these reports and…the reports cannot be used independently to develop  any conclusions regarding the security or protective measures for the  facilities contained in the reports.” In addition, a 2005 statement by an  NRC Commissioner concerning SNL’s work further supports our point that  NRC disagreed with the SNL analysis. This Commissioner states, “because  the Sandia security assessment reports contain scenarios and assumptions  that are not supported by the Commission, the reports should not be  released to anyone outside the agency nor should they be shared with  licensees or stakeholders.” Continuing, this Commissioner states that  SNL’s security reports “if taken out of context, could prove to be an  enormous burden on NRC and our licensees and could result in a  tremendous amount of time spent explaining why we think the Sandia  analyses are deeply flawed.”
Third, we disagree with NRC’s assertion that our report misrepresents or  excludes key facts. In particular, NRC states that INL and SNL refute our  characterization of key facts gathered from INL, federal agencies, and SNL  to support our recommendations. With regard to INL, we did receive a  letter from INL in June 2007 requesting that we not include or refer in any  fashion to any INL technical judgments contained in the INL report. Later  that month, we spoke with INL management about the reason for this  request. As we state in our report, according to INL’s Deputy Associate  Laboratory Director for National and Homeland Security Directorate, INL  believes that a more comprehensive analysis of the vulnerability and  consequences of attacks on research reactors is warranted. Nonetheless,  this official stated that the INL analysis was technically accurate and INL’s  vulnerability expert had done good work in preparing it. As a result of this  discussion, we deleted from the report much of the specific details of this  analysis, such as the specific estimates of radiological consequences, and  instead provided only a short summary of the key findings of the analysis.  Our report includes a statement from the INL analysis stating that a  terrorist attack could produce “significant consequences” and have “high  socio-economic impact” because INL officials emphasized this point  during communications with us after we received INL’s June 2007 letter.  Furthermore, in its comments, NRC states that INL requested that we  exclude from our report references to information we obtained from  verbal communications with INL experts. INL never asked us to exclude  discussions we had during our visit to INL and subsequent discussions  with INL officials. INL would have no basis to make such a request  because representatives of INL management arranged our meetings with  INL experts to gather the information and data needed to complete our  work.
With respect to SNL, in neither of two sets of written comments did SNL  dispute our primary conclusion regarding its work for NRC—that some  NRC-licensed research reactors may not be prepared for certain types of  terrorist attacks—nor did SNL disagree with our main report  recommendation. We received initial comments from SNL in July 2007 on  an early version of our classified draft report. At that time, we revised our  draft to acknowledge one of SNL’s key points—namely, that damaging a  research reactor is a difficult and sophisticated task. However, we did not  include further details of these initial comments because they were  inconsistent with the information SNL had provided during extensive  discussions over 2 days in November 2006. For example, in its July 2007  written comments, SNL provided information that demonstrated why this  task is so difficult. However, during discussions with SNL’s expert, he  noted that damaging a reactor was possible and provided us with very  detailed steps of how to do so. These steps addressed many of the very  limitations discussed in the July 2007 comments from SNL. Furthermore, a  key finding of our report is that NRC disagreed with the SNL finding that  some NRC-licensed research reactors may not be prepared for certain  types of terrorist attacks. In its July 2007 comments, SNL did not address  our characterization of the work it did for NRC. Finally, in subsequent  comments provided in September 2007 as part of DOE’s technical  comments, SNL expanded upon its earlier comments regarding the  difficulty of sabotaging a research reactor which we had already  acknowledged in the report. In discussing this point, SNL stated that  further study was needed on the extent to which terrorists could damage a  research reactor. Regardless of the details of the work performed by INL  and SNL, which we believe raise key concerns, one thing remains clear:  there is need for further study to better understand the risks and  consequences of an attack on a research reactor by well trained terrorists.
Finally, NRC asserted that our assumptions regarding terrorist attack  scenarios lack a sound technical basis. We disagree. Specifically, we note  the following:    The findings in our report do not rely on assumptions but, instead, are  based on the evidence we collected from experts at NRC, DOE, INL, SNL,  DHS, and other sources. This evidence demonstrates that there is  uncertainty about some aspects of NRC’s security assessment. However,  NRC’s comments suggest that no such uncertainty exists, even though in  some cases NRC used assumptions in its security assessment that it had  difficulty defending. For example, NRC officials did not fully consider an  alternative attack scenario that could be more damaging if carried out  successfully because, according to NRC officials, the supervisor of the  staff doing the assessment was an engineer who instructed the staff that  such scenarios were unlikely, if not impossible. During discussions on this  point, an NRC official acknowledged that if the alternative attack scenario  had been fully assessed, NRC’s security assessment might have  demonstrated more significant consequences.
NRC states that we incorrectly assumed that terrorists could use certain  tactics in attacking research reactors since there is a lack of intelligence  information that terrorists have demonstrated these capabilities. We  disagree. The events of September 11, 2001, and the threats faced by our  armed forces in Iraq demonstrate that terrorists are capable of innovating  how they conduct attacks. Consequently, we believe that, in conducting its  security assessment, NRC should have considered a fuller range of threats,  including both the threats that have occurred and the possibility of  emerging threats.
NRC also disagreed with our characterization of (1) what portion of a  reactor could be damaged in a terrorist attack and (2) the extent of the  radiation released from such an attack. However, experts at INL and DHS  provided our evidence on these points. As previously discussed, according  to an INL vulnerability expert, a well-executed terrorist attack could  damage a significant portion of a research reactor and release a larger  amount of radioactivity into the neighboring communities than NRC  estimates. On this point, INL’s Deputy Associate Laboratory Director for  National and Homeland Security Directorate told us that additional  analysis and study is warranted in order to gain a more comprehensive  understanding of both how much of a reactor could be damaged in an  attack and what the resulting radiological consequences would be.
As agreed with your office, unless you publicly release the contents of this  report earlier, we plan no further distribution until 30 days from the report  date. At that time, we will then send copies of this report to the  appropriate congressional committees; the Secretary of Energy; the  Administrator of NNSA; the Chairman of NRC; and the Director, Office of  Management and Budget. We will also make copies available to others  upon request. In addition, this report will be available at no charge on the  GAO Web site at www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-3841 or aloisee@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix II.
section_title: Appendix I: Comments from the Nuclear Regulatory Commission
paragraphs: The following are GAO comments on the Nuclear Regulatory  Commission’s (NRC) letter dated December 17, 2007.
subsections: section_title: GAO Comments
paragraphs: 1.  We disagree. We accurately describe NRC’s oversight actions taken  since September 2001, including its process of performing routine  inspections for safety and security. Furthermore, we give NRC credit  for working with research reactor licensees to make, and to verify,  many security improvements that NRC identified as necessary. We also  discuss the many security features and improvements at NRC-licensed  research reactors that we visited including security improvements that  exceed NRC’s security requirements.  2.  Our report does not misrepresent NRC’s use of Sandia National  Laboratories’ (SNL) security assessment and did not state that NRC  “dismissed” the security assessment. Instead, our report accurately  states that NRC “disagreed” with SNL about the security of research  reactors. On this point, NRC has reiterated its disagreement with the  SNL analysis in writing several times. Specifically, when NRC provided  us with copies of SNL’s security assessment, it also provided a  disclaimer stating that NRC “does not support many of the assumptions  and/or information contained in these reports and…the reports cannot  be used independently to develop any conclusions regarding the  security or protective measures for the facilities contained in the  reports.” Furthermore, a 2005 statement from an NRC Commissioner  concerning SNL’s work further supports our point that NRC disagreed  with the SNL analysis. According to this Commissioner, “because the  Sandia security assessment reports contain scenarios and assumptions  that are not supported by the Commission, the reports should not be  released to anyone outside the agency nor should they be shared with  licensees or stakeholders.” He further states that SNL’s security reports  “if taken out of context, could prove to be an enormous burden on  NRC and our licensees and could result in a tremendous amount of  time spent explaining why we think the Sandia analyses are deeply  flawed.”  3.  Contrary to NRC’s comments, our report does not compare security  requirements for NRC-licensed and Department of Energy (DOE)  operated research reactors or actual security conditions at the  reactors. In fact, we reported on DOE and NRC security issues in  separate sections of the report. We did, however, compare one  assumption regarding how each agency considered the role of insiders  who may provide assistance to an attacking force. In our view, this was  an important comparison to make because, in its assessment, NRC  assumed that insiders with access to the reactor would only participate  to a limited degree in an attack on a reactor. However, in similar  security assessments for DOE facilities, DOE assumed that insiders  would fully participate in an attack, and it has designed its defenses on  the assumption of full participation. In discussing this point with NRC  officials, they acknowledged that if NRC’s assessment had assumed  fully participating insiders, then the results of its assessment may have  turned out differently.  4.  Our report did not misrepresent or exclude key facts provided to us by  Idaho National Laboratory (INL) and SNL. With regard to INL, we did  receive a letter from INL in June 2007 requesting that we not include or  refer in any fashion to any INL technical judgments contained in the  INL report, and we subsequently spoke with INL management about  the reason for this request. As our report states, according to INL’s  Deputy Associate Laboratory Director for National and Homeland  Security Directorate, INL believes that a more comprehensive analysis  of the vulnerability and consequences of attacks on research reactors  is warranted. Nonetheless, this official stated that the INL analysis was  technically accurate and INL’s vulnerability expert had done good  work in preparing it. As a result of this discussion, we deleted from the  report many of the specific details of this analysis, such as the specific  estimates of radiological consequences, and instead provided only a  short summary of the key findings in the analysis. As we pointed out in  our report, the INL analysis stated that a terrorist attack could produce  “significant consequences” and have “high socio-economic impact.” We  retained this statement because INL officials emphasized this point  during communications with us after we received INL’s June 2007  letter. Furthermore, although NRC states that INL asked us to exclude  references to information we obtained from verbal communications  with INL experts, INL never made such a request to us. INL would have  no basis to make such a request because representatives of INL  management arranged our meetings with INL experts to gather the  information and data needed to complete our work.
With respect to SNL, in neither of two sets of written comments did  SNL dispute our primary conclusion regarding its work for NRC—that  some NRC-licensed research reactors may not be prepared for certain  types of terrorist attacks—nor did SNL disagree with our main report  recommendation. We received initial comments from SNL in July 2007  on an early version of our classified draft report and revised our draft  to acknowledge one of SNL’s key points—namely, that damaging a  research reactor is a difficult and sophisticated task. However, we did  not include further details of the SNL comments because they were  inconsistent with the information we received during extensive  discussions with SNL experts during 2 days in November 2006. For  example, in its July 2007 written comments, SNL provided information  that demonstrated why this task is so difficult. However, during  discussions with SNL’s expert, he noted that damaging a reactor was  possible and provided us with very detailed steps of how to do so.  These steps addressed many of the very limitations discussed in the  July 2007 comments from SNL. Furthermore, as we also reported, NRC  disagreed with the SNL finding that some NRC-licensed research  reactors may not be prepared for certain types of terrorist attacks. In  its July 2007 comments, SNL did not address our characterization of  the work it did for NRC. Finally, in subsequent comments provided in  September 2007 as part of DOE’s technical comments, SNL provided  more detailed information on the difficultly of sabotaging a research  reactor. Our report includes SNL’s view that attacking a research  reactor would be a difficult task that would likely require specific  knowledge of reactors and sabotage techniques. Nonetheless, SNL’s  comments also acknowledge the need for further study on the extent  to which terrorists could damage a research reactor. Regardless of the  details of the work performed by INL and SNL, which we believe raise  key concerns, one thing remains clear: there is need for further study  to better understand the risks and consequences of an attack on a  research reactor by well trained terrorists.  5.  We disagree with NRC’s assertion that our assumptions regarding  terrorist attack scenarios lack a sound technical basis. Specifically, we  note the following:    The findings in our report do not rely on assumptions but instead are  based on the evidence we collected from experts at NRC, DOE, INL,  SNL, DHS, and other sources. This evidence demonstrates uncertainty  about some aspects of NRC’s security assessment. In contrast, NRC’s  comments suggest that no such uncertainty exists, even though in  some cases NRC used assumptions in its security assessment that it  had difficulty defending. For example, NRC officials did not fully  consider an alternative attack scenario that could be more damaging if  carried out successfully because, according to NRC officials, the  supervisor of the staff doing the assessment instructed the staff that  such scenarios were unlikely, if not impossible. An NRC official  acknowledged that if the alternative attack scenario had been fully  assessed, NRC’s security assessment might have demonstrated more  significant consequences.
We disagree with NRC’s statement that we incorrectly assumed that  terrorists could use certain tactics in attacking research reactors, since  there is a lack of intelligence information that terrorists have  demonstrated these capabilities. NRC’s security assessment did not  address certain tactics that were raised as a concern in its own  intelligence documents. Furthermore, as the events of September 11,  2001, and the threats faced by our armed forces in Iraq have shown,  terrorists are capable of innovating how they conduct attacks.  Consequently, we believe that, in conducting its security assessment,  NRC should have considered a fuller range of threats, including both  the threats that have occurred and the possibility of emerging threats.
We stand by the evidence provided by INL and DHS experts regarding  the portion of a reactor that could be damaged in a terrorist attack and  the extent of the radiation that could be released from such an attack.  As previously discussed, according to an INL vulnerability expert, a  well-executed terrorist attack could damage a significant portion of a  research reactor and lead to the release of a larger amount of  radioactivity into the neighboring communities than NRC estimates. On  this point, INL’s Deputy Associate Laboratory Director for National and  Homeland Security Directorate told us that more analysis and study is  warranted to gain a more comprehensive understanding of both how  much of a reactor could be damaged in an attack and what the  resulting radiological consequences would be.  6.  This comment refers to a classified report Los Alamos National  Laboratory (LANL) issued in 1989. That report discussed the potential  and limitations to a certain type of terrorist attack on research reactors  that is discussed more fully in our classified report. The scenario  addressed in the LANL report was similar to the type of attack  identified in the INL analysis. (The LANL report was discussed in our  classified report. Because the LANL report is classified, we are not  including the details of the LANL report in this report.) However, we  note that the LANL report was completed more than 15 years ago at a  time when the United States faced different and less severe potential  threats. In our view, the LANL study, when combined with the views of  INL and DHS experts, demonstrates that there is some uncertainty  within the community of reactor experts on the consequences of  certain types of attacks on research reactors. This uncertainty provides  the basis for our recommendation that NRC reconsider its security  assessment.
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, John Delicath, Doreen S.  Feldman, Eugene Gray, Keith Rhodes, Ray Rodriguez, Peter Ruedel,  Rebecca Shea, Carol Herrnstadt Shulman, Ned Woodward, and Franklyn  Yao made key contributions to this report.