Hostile Action-Based Drill Program

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After the myriad of physical security changes implemented for the nation’s nuclear power plants following the attacks of 9/11/01, the industry is now addressing communications and coordination between the licensee and the local emergency responders that will be necessary in the event of an attack or other hostile event at a nuclear power plant.

This Nuclear Regulatory Commission initiative, known as the “Hostile Action-Based” drill or exercise program (HAB), has been led by the Nuclear Energy Institute (NEI). Beginning in 2007 and finishing late this year, every US nuclear power plant is required to plan, develop and execute a non-evaluated HAB drill that is designed to explore and improve the communications and coordination between the plant and its neighboring emergency responders.

These “HAB” drills are unlike the traditional Radiological Emergency Plan, or REP, exercises we have been doing for nearly 30 years in that the unique scenario has the potential to introduce new and different response challenges. In these drills, a radiological release is NOT required, and the participating organizations’ primary task is to coordinate resources and personnel, using the National Incident Management System and the Incident Command System (NIMS and ICS, respectively).

The drills are designed to begin with some type of threat or hostile action directed at the nuclear plant, whether that is a potentially hostile inbound aircraft (known as a “track of interest”), the detonation of a large explosive device, or a physical attack on the station by armed adversaries. The actual “combat” or “engagement” between station security and the adversaries is generally NOT demonstrated. Those activities are currently covered by the NRC’s “Force on Force” evaluation program. In the HAB drills, the engagement is typically done as a “talk through” with the involved parties and ends with the neutralization of the adversarial force. However, the adversaries are required to accomplish enough mayhem to leave the station in a condition where the nuclear fuel is threatened.

At this point, the ICS and NIMS come into play. The postulated damage, by definition of the NEI guidance document, is sufficient to require the use of the emergency responders in order to stabilize the plant. This could be large fires, debris removal, or any number of situations where the available plant staff is incapable of resolving the problem by itself. Past drills have included not only the local emergency responders like firefighters and police officers, but also tactical groups (SWAT), bomb disposal teams, state police, counter¬intelligence groups, the FBI and the US Coast Guard. As observers, the NRC and FEMA have been present at most of these events.

The staff of CMCG has been involved in this initiative from its inception in 2003. CMCG staff members were integral to the design and development of the NEI guidance, and our staff has been involved in the development or execution of nine of these events. We are providing design, development and project management support for our clients, who will be performing a total of eight of these HAB drills in 2009.

As the HAB pilot program winds down in 2009 and the program enters the “rulemaking” phase and becomes a requirement of the NRC/FEMA exercise cycle, CMCG expects other public and private sectors to explore these types of events. . CMCG is an expert in exercises of all kinds, including the Homeland Security Exercise Evaluation Program (HSEEP) and we are looking forward to assisting our clients in this important aspect of emergency preparedness.

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