December 20, 1995

Mr. Paul Leventhal, President
Nuclear Control Institute
1000 Connecticut Avenue, N.W.
Suite 804
Washington,D.C. 20036

Dear Mr. Leventhal:

I am responding to your letter of November 6, 1995, in which you and Mr. Daniel Hirsch of the Committee to Bridge the Gap expressed concern regarding the rule on protection of nuclear power plants against the malevolent use of vehicles and its implementation. As you know, the Commission, in response to your letter of May 25, 1995, informed you that the NRC was reviewing all new issues raised by the Oklahoma City attack for appropriate additional action and that we would reevaluate the new vehicle control measures and their implementation schedule. The staff completed its review and has determined that the new vehicle control measures are adequate to provide the enhanced level of protection desired and that no additional action is needed. All nuclear power plant licensees expect to comply with the implementation date of February 29, 1996.

Of course, the specific characteristics of the assault vehicle and the size of the bomb that are part of the design-basis threat (DBT) are considered safeguards information and cannot be made available to the public. Similarly, meetings held with licensees during the week of October 22-were closed to the public because the staff discussed certain safeguards information with the licensees and disclosure of this information to the public could Jeopardize the security of the nuclear power plants. I want to assure you, however, that the NRC has been in close contact and coordination with the other agencies involved in investigation of the Oklahoma City bombing. Based on the information obtained, the NRC staff is confident that the specifics of the OBT are adequate to provide protection of the public health and safety.

Regarding Phase II of the staff's reassessment of the DBT and your concerns regarding the adequacy of the OBT for radiological sabotage, in March 1993, the Commission directed the staff to reexamine the historical record of terrorist attacks during recent years to determine if the attributes that comprise the existing DBT for radiological sabotage remain representative of potential adversary capabilities. In addition to reexamining the DBT attributes, Phase II also was intended to supplement and validate the results of the staff's ongoing threat analysis conducted as part of the semiannual review of the OBT environment. Within the Phase II effort, the staff moved beyond the 6-month scope of the semiannual threat environment review and examined a larger aggregate number of threat incidents that occurred over an extended timeframe, focusing on certain key adversary attributes of the DBT. For example, regarding hand-carried weapons and equipment, the reassessment confirmed that most groups continue to use proven weapons and methods. The primary weapons used continue to consist of improvised explosive devices, incendiary devices, and small arms such as automatic weapons. For its reexamination of group size, the staff began by reviewing approximately 700 incidents in which group size was known. On the basis of this analysis, the staff concluded that the distribution of incidents by group size is comparable to data that were used initially in the development of the DBT for radiological sabotage. In March 1994, the staff concluded Phase II by stating that:

With regard to the Phase II effort to reexamine the remaining attributes of the DBT for radiological sabotage, staff confirms that 1) conclusions reached in the semiannual threat environment review regarding the continuing validity of the DBT for radiological sabotage are correct, and 2) the current DBT remains a reasonable characterization of a hypothetical threat for use in the design of safeguards systems at nuclear power reactor facilities. Therefore, no change to the DBT for radiological sabotage is recommended at this time.
With respect to your comment about the adequacy of the DBT to provide a "cushion" above the largest known vehicle bomb, the Commission has never intended the DBT to represent "worst case" or speculative adversary characteristics or scenarios. Rather, the DBT is intended to provide a reasonable enumeration of adversary characteristics for use in the design of protection systems.

Although you requested to meet with me to discuss the review and implementation of the truck-bomb rule and the results of the Phase II reevaluation, I believe that it would be more appropriate for you to meet with staff members of the various technical groups involved with the new rule and its implementation. Please feel free to contact Mr. LeMoine Cunningham, Chief, Safeguards Branch, Office of Nuclear Reactor Regulation, at (301) 415-2933, to arrange a meeting.


Shirley Ann Jackson

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