Nuclear Security: DOE Needs to Resolve Significant Issues Before It Fully Meets the New Design Basis Threat
Published: 2004-04-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.

section_title: Letter
paragraphs: 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. 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).  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. NNSA and  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. 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.
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.
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  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.
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.
subsections: section_title: Background
paragraphs: 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  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-in- depth 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.
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.
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.
section_title: DOE Took Immediate Steps to Improve Security in the Aftermath of September 11, 2001, but the Effectiveness of These Steps Is Uncertain
paragraphs: 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  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  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  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.
section_title: 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
paragraphs: 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  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  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  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.
section_title: 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
paragraphs: 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.
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.
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  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  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.
section_title: 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
paragraphs: 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.
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  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    close and de-inventory two facilities,    consolidate excess materials into remaining special nuclear materials    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  years, these sites should be considered to be at higher risk under the new  DBT than they were under the old DBT.
section_title: Conclusions
paragraphs: 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 well- established 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.
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.
section_title: Recommendations for Executive Action
paragraphs: 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 policy- making 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.
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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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.
section_title: Appendix I: Comments from the Department of Energy
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.