To the Editor:
The parallels between the old Federal Aviation Administration (FAA) in the lead up to the September 11, 2001 attacks and the Nuclear Regulatory Commission (NRC) today are unmistakable.
Prior to 9/11 the FAA was charged with a conflicting dual mission - that of promoting the aviation industry, while attempting to regulate the airlines at the same time. We saw the tragic consequences of that conflict of interest, when the industry constantly and successfully fought what they considered to be costly security enhancements. Concerns about the bottom line - the almighty dollar - time and time again resulted in efforts to secure the flying public being thwarted in favor of moving passengers and aircraft without being encumbered by enhanced security measures, which the airlines felt had a diminished cost benefit. You know what that boiled down to - profits versus protecting the lives of the travelling public and those on the ground beneath their planes.
Now let's turn to the Nuclear Regulatory Commission and our nuclear power stations. When security professionals conduct a risk analysis they look at three components - criticality, vulnerability and threat. Using Pilgrim Nuclear Power Station in Plymouth as an example, is it a critical facility? Absolutely, according to the Department of Homeland Security. All of our nation's nuclear power plants are considered critical infrastructure and in Pilgrim's case add the fact that its location in America's Hometown makes it also a symbolic target.
Is it vulnerable? Well, thanks to the NRC and Entergy, yes it is. Just look at the recent decision to delay transfer of spent fuel assemblies to dry cask storage and the Nuclear Energy Institute's (the industry's main trade group) efforts to revise cyber security requirements in a way that experts say will leave our nuclear plants’ systems more vulnerable. Is it mere coincidence that Pilgrim Station was supposed to have its cyber security plan fully implemented by December 15, 2014 and that requirement has now been delayed by the NRC until June 30, 2016?
And now, how about threat? The Islamic Fundamentalist Extremist threat against east coast nuclear power plants in the lead up to and since 9/11 is pretty well known. Add to that the recently revealed threat posed by North Korea when, according to a 2004 Defense Intelligence Agency report, they sent commando teams to infiltrate the United States in the 1990s for possible terrorist attacks against nuclear power plants. Recent reports of drones flying over French nuclear power plants and cyber-attacks on South Korea plants are certainly not comforting. It doesn't take much to extrapolate from the recent terrorist attacks in France to see the possibility of similar actions here within the continental United States. The question to ask is, do the spent fuel pools at our nuclear power plants present an inviting target?
The NRC suffers from the same type of "revolving door" that was experienced within the FAA prior to 9/11. Top level officials rotated from the regulatory agency to the aviation industry and vice versa. The end result was compromised security, due to the influence the airlines had with the regulator (the FAA), which resulted in the regulatee (the airlines) being able to ward off numerous security enhancements due to their cost benefit analysis. Industry concerns frequently took precedence over safety and security for the travelling public. We now have a similar situation within the NRC. Industry concerns about cost, once again, seem to take precedence over the safety and security of our local communities.
Al Qaeda found a way to use our resources, our airplanes, against us when they attacked on September 11, 2001. Are our enemies now going to use our spent fuel against us? The industry's fawning sycophants within the FAA helped facilitate the diminished security which lead to the 9/11 attacks. We need to push hard to insure that the NRC doesn't repeat those same mistakes. Recent actions demonstrate that the NRC has yet to learn one of the most important lessons from the September 11, 2001 attacks and that is to address failure of the imagination and connect the dots. The NRC must change its dangerous course if we in Plymouth, Cape Cod and surrounding communities are going to be given the safety and security we deserve.
LTC (Ret.) Brian F. Sullivan
Mr. Sullivan is a retired Military Police Officer and former FAA Special Agent. He has worked in the U.S. Army's nuclear surety program, served as a Civil Defense Director for the town of Brookfield, MA and has numerous hours of training in Civil Defense Management and Emergency Preparedness as a former member of the Massachusetts Army National Guard.