Nuclear Regulatory Commission member Dale Klein

NRC Commissioner Wants 'More Balanced' Security Approach

Pressure on the industry to achieve a zero risk level is wrongheaded because it is not attainable in the real world, Dale Klein, a Nuclear Regulatory Commission member, told attendees Friday in Raleigh, N.C., at the Grand Challenge Summit 2010.

Citing as his example of an unforeseen consequence the bullet-resistant enclosures (BREs) that nuclear power plants were required to install as security measures after 9/11, Nuclear Regulatory Commission member Dale Klein told attendees Friday in Raleigh, N.C., at the Grand Challenge Summit 2010 that NRC needs to take a "more balanced" approach to the plants' security requirements. Klein is a former NRC chairman who also worked for five years at the Pentagon as assistant to the Secretary of Defense for Nuclear, Chemical, and Biological Defense Programs.

He said the NRC "has made great strides in bringing a risk-informed approach to our safety regulations." The Reactor Oversight Process now in use is a good example, Klein said, according to the text of his prepared remarks that was posted on the NRC Web site.

"Considering the great progress we have made in risk-informing our safety regulations, I believe we have the experience and many tools to further risk-inform the security-related arena," Klein said. "I also believe that in most instances, the U.S. nuclear industry has reached a level of security such that additional requirements would not substantially improve overall security. Let me be clear: I strongly believe we need to remain vigilant but must also do a better job of risk-informing our security-related decisions. Simply put, I think we need to be better regulators in the security arena to ensure that our requirements are balanced.

"Let me give you a specific example of what happens when we don't carefully think about the consequences of new security requirements. After 9/11, nuclear power plants and other types of licensees were required to install multiple bullet-resistant enclosures –- also known as BREs –- throughout plant protected areas to provide observational posts and fighting positions from which to repel an attack in lieu of traditional security patrols. Although these BREs can be effective in protecting security guards while repelling an attack, I firmly believe that these BREs have contributed to the security guard attentiveness issues we have seen recently at some commercial nuclear power plants. Let's be honest, if you were isolated in a small room with little ventilation and only small slits to use to view the outside world, you would likely grow bored and inattentive, too. I think in this case we may have set ourselves up for failure. As a regulator, we must ensure that any security upgrades and new requirements proposed in the future add real value. You don’t necessarily want to use an ax instead of a scalpel, just because it is bigger and stronger.

"The challenge for risk informing our security requirements is that security risks are often difficult to quantify. For example, whereas engineering calculations and related data can help us to determine what size pump or generator to use or what the chances are that it will fail when called upon, the same cannot be said for determining how many guards to have at a plant or what caliber weapons they should carry. Rather, we have to look at the overall security strategy and determine through more subjective means whether we have effectively managed risks associated with radiological sabotage.

"In the absence of quantifiable data related to the risks of radiological sabotage, the NRC and industry continue to receive pressure to increase security as well as safety requirements to reach a 'zero' risk level. But a zero risk level is not realistically attainable in any human activity and, as a practical matter, we balance risk against benefit every day in our routine activities. The safest vaccine is never given, the safest airplane never flies, the safest car never moves, and the safest power plant is one that never operates. In effect, more may not be better."

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