Nuclear Plant Security Doesn't Need The Airport Security Appraoch

Nuclear Power Plant Security Doesn’t Need The Airport Security Approach

By Jonathan Wert and Patrick W. O’Hara

A “standardized” approach to problem solving has never seemed to work for the nuclear power industry. Advancements in nuclear safety and operational performance have been largely the result of careful study to reveal and correct root causes that were often plant specific, rather than addressing only symptoms.

Framing the problem of airport security in terms of labor policy was a bold move for the federal government, and one that may actually improve airline security in the long run by attracting higher quality employees, raising wages and providing a career-path -- thus improving employment longevity. Security work at this level obviously requires a high-quality employee and a learning curve that benefits from long-term employment relationships. However, to say that Federalization of airport security is a definitive solution is a fallacy. A root cause analysis on security problems would likely lead away from front-line employees, and focus more on policies and regulations established and administered by both airline security management and the Federal regulator.

The same Congressional momentum seems to be directed at the Federalization of nuclear power plant security, through the proposed Nuclear Security Act. The question though, is how will this improve security at the nation’s 103 nuclear power plants. Are the problems of airport security and nuclear power plant security even the same or similar? Will wholesale replacement of a front-line workforce through Federalization increase the performance of security at our nation’s airports and nuclear power plants? Will the gaps in the security program be closed by Federalization?

Few people doubt that the Federalization of airline security will yield improvements, but will it really improve nuclear power plant security? Nuclear power plant security is already highly regulated with defined security program criteria[i] and rigid suitability requirements for nuclear security officers.[ii] Nuclear security officers are subjected to minimum education and experience requirements, a series of civil and criminal background checks, physical and psychological testing, drug testing, and strict training and qualification requirements – all of which are conducted prior to hiring, and annually thereafter while employed. In fact, these requirements are often so stringent that it makes recruiting new employees difficult. Nuclear security officers are already among the highest paid uniformed security force in the U.S. An important consideration in the debate over the Federalization of nuclear power plant security is whether it will create a downward pressure on wages or provide a means to circumvent the suitability requirements already in place through the use of federal employment programs.

Policymakers are quick to state that Federalization of nuclear power plant security will give the federal government more control of security operations, ameliorating the public’s concern about nuclear safety. The reality, however, is that the federal government already has that authority and oversight through its regulatory programs and enforcement actions. The media is quick to cite that nuclear power plant security organizations have overwhelmingly failed in mock-attacks, when the real problem may be that the federal government has failed to maintain realistic regulatory expectations, or provide adequate enforcement actions. It is unlikely that Federalization of the worker will change regulatory requirements or enforcement: it may actually put subtle collusive pressure on the feds to ease regulatory oversight to demonstrate that Federalization is working. It appears that an alternative to Federalization should b e considered.

Like any other system in nuclear power operations, maintaining high-levels of security while focusing on the safe operation of the power plant is a complex issue. The current security program is based on a design basis threat (DBT)[iii] determined by the Nuclear Regulatory Commission, and is designed to address both internal and external threats. A highly-trained and heavily armed security force accomplishes its objectives through the management of access control, monitoring closed-circuit TV and alarm systems, tactical response plans, patrolling plant and surrounding areas, escorting vehicles and visitors, and interfacing with local law enforcement agencies. An important foundation of this security program is the background checks and security clearances for all personnel working in the plant, which has proven effective against the internal threat. However, it is the external threat that public policy makers are so concerned with.

The DBT calls for preparation against a violent external assault by highly trained and determined adversaries employing military style weapons. The assumption is that Federalization of nuclear power plant security will bolster the ability to defend against this uncertain threat. The reality though, is that defending against this threat is truly the last stand in a defense-in-depth concept. More attention should be placed on defending against this threat prior to the plant level, which places the emphasis more on Federal intelligence and law enforcement agencies than Federalized plant security guards. This is prudent because it increases the reactionary gap, which is often the key to maintaining multiple levels of defense. Managing these improvements should be a central focus of the newly created Office of Homeland Security.

As for improvements in plant-level security, some changes are needed, and to think otherwise would be giving in to complacency – a latent tendency the nuclear industry is preoccupied with defeating. Enhancing programs to defeat the insider threat require the professionalization of the nuclear security function, which involves further increasing suitability and training requirements, as well as delegating law enforcement authority to plant-level guards. This should be accomplished through strict regulation of current programs, rather than replacement of private security workers by a federal bureaucracy. Safe operation of nuclear power plants relies on all workers having the same mindset – what sociologists have coined the safety culture or a safety-conscious work environment. The introduction of a new federal bureaucracy may actually undermine safe work practices and the high-performance systems that have yielded operational improvements in the nuclear industry in recent years.

In short, improvements in nuclear power plant security and safety are unlikely to result from the Federalization of security functions. Moreover, Federalization may be counterproductive and actually create the problems in the nuclear industry that the Federalization of airport security is supposed to solve. A defense-in-depth security solution relies on layers of security protection. The major focus of preparedness must be outside the plant level, involving Federal intelligence and law enforcement. Plant level security improvements should involve realistic regulatory expectations, on-going evaluations of security program effectiveness, and strict enforcement to correct deficiencies. Labor policy should focus on professional development and training programs for security personnel, and an emphasis on reducing turnover. Conferring law enforcement status to nuclear security professionals through Federal regulatory authority would enhance this effort. Likewise, the industry should seek to build a process for security improvements that mirrors the “communitarian regulation”[iv] used by the Institute of Nuclear Power Operations, which has been largely responsible for performance improvements in the nuclear power industry, and reinforcing an emphasis on surpassing minimum regulatory requirements with industry best practices.

Jonathan Wert, Ph.D. is President of Management Diagnostics Inc. of Port Royal, PA -- a management consulting firm specializing in safety and culture assessments in the nuclear power industry. Patrick W. O’Hara is a policy analyst specializing in nuclear security and worker safety issues. Both are researching the effects of labor policy on high-performance work systems in the nuclear power industry. Comments or questions may be directed to jwert@mdi-wert.com or p.ohara@verizon.net.

Footnotes for editorial verification. Not intended for publication.