Seven recommendations to improve TMI's nuclear plant security that have gone unheeded.

Security at Three Mile Island and nuclear generating stations across the nation need to build on lessons learned from 9/11. Three Mile Island Alert (TMIA) remains concerned that suggestions and recommendations made by citizens continue to fall on deaf ears. Charles W. Thurston's article ("A Dynamic Mission: Protecting Utility Assets," Public Utilities Fortnightly, June 15, 2002) gave the misleading impression that utilities have been at the vanguard of pioneering security measures at power plants. His article, which featured Three Mile Island, failed to capture the passive and penurious approach nuclear companies have historically taken toward security and emergency preparedness.

In fact, the containment building at Three Mile Island was "designed" to withstand an airplane crash from a 727 due [only] to public pressure. Environmentalists, and not TMI's owner, requested this modification during hearings convened by the Nuclear Regulatory Commission (NRC).

Between 1990 and 1993, the nuclear industry waged a campaign to weaken security at nuclear power plants, and to reduce the emergency evacuation zone from 10 to two miles. These efforts gained the support of NRC Chairman Ivan Selin. During this period (1993), a serious security breach occurred at TMI, when an escaped patient from an area hospital crashed his vehicle through the North Gate and eluded capture. On February 11, 1993, the NRC's top safety official, Thomas Murley, stated he "wasn't sure" if any regulations had been violated during the incident. Nineteen days later, Samuel Collins, head of the NRC's investigation team, announced, "An individual can challenge the security ... that currently exists."

On February 23, 1993, Three Mile Island Alert testified before the Consumer Affairs Committee of the Pennsylvania House of Representatives. TMIA noted that the Department of Energy had taken concrete measures to anticipate potential terrorist attacks at its nuclear weapons complex. However, the nuclear industry had done nothing to anticipate spontaneous terrorist attacks. Ivan Selin, chairman of the Nuclear Regulatory Commission, agreed with "intelligence agencies" that have advised him "not to worry much about terrorists.... If the world changes such that we have to worry about armed suicidal ... terrorists in the United States, we would know about that." (New York Times, February 11, 1993, A-10)

Mr. Selin's comments were darkly reminiscent of the industry's prediction that a TMI-type accident was "non-credible." On October 17, 2001, due to a "credible threat" against Three Mile Island, the Harrisburg and Lancaster airports were closed for four hours, air travel was restricted in a 20-mile radius, and fighter jets were scrambled around TMI.

TMIA polled several individuals and organizations in security-related fields, and proposed a list of recommendations to enhance site security at Three Mile Island. Below is a "short list" of recommendations we made nearly a decade ago:

1. An Independent Assessment of Nuclear Security
   Recommendation: Implement security audits annually by an independent, non-governmental entity and the Pennsylvania State Police.
   Response: The company and the NRC viewed this proposal as an unnecessary financial burden. On October 6, 2001, the NRC issued a Security Advisory, and mandated 13 "prompt actions" which are "safeguarded" and "classified." On March 15, 2002, Exelon asked for a delay in meeting the "prompt" requirements. [Exelon owns a 50 percent stake in TMI with British Energy through a joint-venture known as AmerGen.]
2. Installation of Physical Barriers
   Recommendation: The security building at the North Gate should be hardened to prevent attack by persons or vehicles. Fundamental protective measures would include the utilization of locked doors, bullet-resistant and darkened window glazing, duress alarms, and protective medians to protect the structure from vehicular attack.
   Response: On September 11, 2001, the North Gate was wide open, the guard shack was removed, and AmerGen was unable to deploy additional security measures due to a power outage. On September 12, 2001, TMIA filed a petition with the NRC requesting armed guards be required at all nuclear power plant entrances. On January 16, 2002, The Nuclear Energy Institute recommended that the petition be denied.
3. Improve Training and Increase Security Staff Numbers
   Recommendation: Increase security staffing and the number and intensity of trainings.
   Response: Since 9/11, Exelon has committed to increase staffing. However, the number of dedicated site personnel at TMI has decreased since the sale of TMI. Today, there are between 598-618 employees at Three Mile Island. In 1998, the number was 804.
4. Double Up on Security
   Recommendation: Erect redundancy security fences at the North and South Gate of TMI.
   Response: Security at the North Gate has been enhanced, but the South Gate remains unstaffed. In the summer of 2000, TMIA requested that AmerGen remove neo-Nazi graffiti scribbled at the South Gate. The company had not inspected the area, and was unaware of the desecration of its own property.
5. Trucks: Take a Note From Border Security
   Recommendation: Install a truck lift at the North Gate to inspect the underbelly of vehicles such as the device utilized at the Susquehanna Steam Electric Station [nuclear facility] in Berwick.
   Response: GPU Nuclear opted not to take the same precautions as PPL.
6. Get Security to Stand Watch
   Recommendation: Increase perimeter patrols, especially on the southern end of the island. At a minimum, patrol roads should be provided outside of the perimeter of the fence area as a deterrent, and to enhance early detection. These patrols should include a dedicated, on-site, roving security watch with responsibility for the plant's perimeter, safety-related buildings, nuclear waste storage facilities, and TMI Unit-2. In addition, armed guards may need to be posted at the most sensitive spots of the operating plant.
   Response: None of these measures were introduced. However, the company does deploy roving fire watches in lieu of redundancy fire insulation materials.
7. Do Not Take Anything for Granted
   Recommendation: Periodic boat patrols around TMI.
   Response: The Governor and Exelon decided the Coast Guard and artillery positions were unnecessary. Governor Mark Schweiker did deploy the National Guard and State Police on Friday, November 2, 2001. The Commonwealth belatedly joined over a dozen states with National Guard and/or Coast Guard detachments assigned to protect nuclear facilities against terrorist attacks. On May 31, 2002, the public learned that the National Guard has been equipped with unloaded M-16s.

Mr. Epstein is the chairman of Three Mile Island Alert, Inc., a safe-energy organization based in Harrisburg, Pennsylvania and founded in 1977. TMIA's Web site is http://www.tmia.com. Mr. Epstein can be reached at eepstein@igc.apc.org.

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