Beef up security at nuclear waste storage sites like San Onofre, scientist says

[Leroy N. Soetoro]

https://www.ocregister.com/2023/01/08/beef-up-security-at-nuclear-waste-
storage-sites-like-san-onofre-scientist-says/

When San Onofre Nuclear Generating Station was splitting atoms, it had to
play — and win — a high-stakes game.

“Force-on-force” exercises — i.e., simulated terrorist attacks on nuclear
power plants, pitting a mock adversary force against a plant’s security
force — are required for operating commercial reactors by the U.S. Nuclear
Regulatory Commission. Back in the day, San O operator Southern California
Edison sought to repel pretend intruders and stave off pretend nuclear
sabotage, while the NRC took notes on what might be tweaked to improve
safety.

Now, however, San O’s reactors are in pieces. They powered down for the
last time more than a decade ago. Edison no longer holds a license to
operate a nuclear power plant, but rather, to host high-level nuclear
waste in dry storage until the federal government figures out where to put
it permanently. This waste decays in steel containers encased in concrete;
the potential for mischief is much reduced; and those force-on-force
exercises are no longer required.

Which leaves some with a queasy feeling in the gut. In recent years, that
included staffers at the NRC itself. They began drafting new rules to beef
up security at the ever-growing number of “stranded” nuclear waste sites
like San Onofre — then stopped, concluding that all is fine as is.

This, the Union of Concerned Scientists argues, ignores the serious issues
raised as to why a new approach to spent fuel security was considered in
the first place.

“Putting aside the regulatory legalese, what would you want security to
accomplish? To prevent an attacker from doing something that would lead to
a significant amount of damage to the fuel and a radiological release that
would harm the public and damage property and agriculture,” said Edwin S.
Lyman, director of Nuclear Power Safety with the Union of Concerned
Scientists.

“There’s no alternative but to make sure that attackers cannot credibly
accomplish that, and that would, given all the uncertainties, mean there
should be a security force to prevent attackers from getting anywhere near
the fuel.”

Edison has an armed, 24/7 security presence, officials said, but neither
the current regulatory framework nor the staff recommendations — which
will be considered soon — requires that. And an armed response force
doesn’t have to be able to interdict and neutralize attackers — it only
has to detect them and call for help, Lyman said.

And there’s no NRC force-on-force exercise to test it.

Complicating matters, at least in Lyman’s eyes, is Edison’s request to the
NRC to shrink the “controlled area boundary” around San Onofre’s dry waste
storage area. The NRC’s rules require 100 meters of space around waste
storage, but the physical realities of the bluff and the beach make that
impossible. Instead, San Onofre’s boundary would be smaller — just 38
meters on the seaward side, beyond which is a publicly accessible
pedestrian walkway and the beach itself.

NRC staff recommend approving that request, which Lyman also finds
disturbing.

“Rather than concluding you should shrink the controlled area boundary,
you might be concerned about the level of public access that’s already
there,” he said. “Reading between the lines, this would allow Edison to
have no legal responsibility for what goes on in that strip of beach.”

Call 911!
Decommissioning sites like San Onofre “currently implement a ‘detect,
assess, and communicate’ protective strategy (as opposed to a “denial of
task” protective strategy),” the NRC staff report says. A successful
response “is only to detect and assess the threat and then communicate
with (law enforcement) to request assistance, rather than to respond to
the attack by interdicting and neutralizing the threat.”

On-site officials essentially call 911, which could happen in less than a
minute after an adversary penetrated the protected area’s intrusion
detection system, if it wasn’t detected before then. “Neutralization” of
the adversary is the responsibility of law enforcement, not of Edison.

Requiring more security was on the table in recent years, but staff now
feels that the risks at waste storage sites are so low that costs would
exceed the benefit.

There were attempts to calculate radiation dosage thresholds in accident
scenarios, but that proved technically problematic. “There are no design
basis accidents with offsite dose consequences exceeding” ‘current legal
limits, and “dose consequences” will decrease over time as the fuel
decays, the report said. (T)he potential impacts from accidents … would
not be significant.”

To provide assurance that a terrorist attack would not lead to a
significant radiological event, the NRC evaluates the threat environment
in coordination with intelligence and law enforcement, requires
“protective measures … to reduce the chance of an attack that leads to a
significant release of radiation,” and licenses only robust storage casks
that resist penetration.

“Over the past 25 years, there have been no known or suspected attempts to
sabotage, or to steal, radioactive material from storage casks at (dry
storage sites), or to directly attack one,” the report says.
“Nevertheless, NRC is continually evaluating the threat environment to
determine whether any specific threat …exists.”

Key security features include physical barriers, surveillance, intrusion
detection, intrusion response and offsite assistance from local law
enforcement agencies. At San Onofre, there are increased security patrols,
augmented security forces and weapons, additional security posts,
heightened coordination with local law enforcement and military
authorities, enhanced screening of personnel and additional limitations on
vehicular access.

“Collectively, these measures further reduce the already low probability
of a successful terrorist attack … by providing assurance that an
attempted attack could be detected and by mitigating the extent of damage
and the potential radiological consequences if an attack were successful,”
the NRC says.

“Plausible threat scenarios” include a large aircraft impact similar to
9/11 as well as ground assaults, which would not pose significant threats,
the NRC says. But it acknowledges the unknowns.

“Because of the uncertainty inherent in assessing the likelihood of a
terrorist attack and the unlimited number of potential scenarios, the NRC
recognizes that under general credible threat conditions, although the
probability of such an attack is believed to be low, it cannot be reliably
quantified,” it says. “The NRC has adopted an approach that focuses on
ensuring that the safety and security requirements are adequate and
effective in countering and mitigating the effects of terrorist attacks
against storage casks. …The NRC finds this protective strategy reduces the
risk from a terrorist attack to an acceptable level.”

Approving a smaller controlled boundary at San Onofre “would have no
change to the consequences of a hypothetical terrorist attack as compared
to the current state,” the NRC said. “Public access to the beach and areas
up to the security fence is currently allowed. A potential release from a
hypothetical terrorist attack will be immediate and of limited duration.
Changing the (boundary) will have no effect on the size or position of the
release. …

“In conclusion, the probability of a significant radioactive release
caused by a terrorist attack remains very low, and the potential health
and land contamination effects of the most severe plausible attack would
not be altered by the proposed (boundary) as compared to the existing
(boundary). If a terrorist act did occur, it would not reasonably be
expected to result in a significant release affecting the public.”

Not enough?
Edison concurs with the NRC’s analyses that current security measures do
the job, as well as the staff recommendation that San O’s boundary be
adjusted to reflect the geography it sits on.

“Edison supports the NRC’s conclusions based on nearly two decades of
research, analysis, and testing that (dry storage systems) are safe, and
it is not necessary to continue to pursue the revised security
requirements that were originally proposed in 2007,” spokeswoman Liese
Mosher said by email.

And the proposed exemption to the boundary distance “is an acknowledgment
of the facts,” she said. “Importantly, the exemption basis is
representative of the very low dose rates that the (dry storage system)
provides – dose rates so low at the new boundary line that they are not
measurable above background (e.g. the same radiation dose that is in your
own backyard).

“Also, during any accident scenarios, which is highly improbable but
nevertheless evaluated, the result was that the calculated accident dose
was shown to be well within federal limits.”

The response by local law enforcement and other agencies during an
accident remains unchanged, she said. Edison’s emergency director would
suggest “protective action” to law enforcement, and law enforcement would
decide what to do.

The NRC, for its part, directed us back to its staff reports for a
response to Lyman’s critiques.

“The staff finds that the existing security requirements … together with
the additional requirements in the post-9/11 security orders, provide
reasonable assurance of adequate protection of public health and safety
regardless of the (dry waste storage) license type or location,” it said.
“Staff experience shows that the staff, licensees, applicants, and other
stakeholders have been able to understand and apply the existing …
security requirements, and the staff has successfully addressed the
appropriate security considerations for new license applicants on a case-
by-case basis.”

Proposed changes in decommissioning rules could increase the clarity and
consistency of how to comply, a spokesman said. And the environmental
assessment it issued on the San O boundary request explains that the
change would not increase the risk of an accident or hostile action
resulting in a dose to the public above regulatory limits. A decision on
that request should be coming soon.

Lyman doesn’t think that’s enough.

“The NRC does not require that Edison or any other (dry waste storage)
licensee maintain an armed response force responsible for interdicting and
neutralizing attackers, but only for detecting intruders and calling for
help from local law enforcement,” he said. “I do not think that security
posture is adequate, especially with public access permitted so close to
the spent fuel casks.

“Any capabilities that Edison may claim beyond NRC’s minimal requirements
are strictly voluntary, uninspectable, unverifiable, and unenforceable. I
believe that NRC’s regulatory footprint must be expanded for all (dry
waste storage sites), including San Onofre, which is why I still strongly
support a new (dry waste storage) security rulemaking.”

A terrorist attack could be much more serious than officials are willing
to acknowledge. And while the NRC concentrates on doses to humans under
threat scenarios, Lyman worries about the impact on property and
agriculture.

A shield, he pointed out, is apparently being set up over waste storage at
Ukraine’s Zaporizhzhia nuclear plant, to protect it from shelling and
drones. That’s the sort of thinking Lyman would like to see here.


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