By Hui Zhang
China is a nuclear-weapon state and rising power entering an era of particularly rapid nuclear energy growth and fuel-cycle development. China’s approach to strengthening the security of its nuclear weapons, materials, and facilities is important because of the quantity of materials involved and the role that China plays in facilitating strong global action on nuclear security.
Chinese leaders actively participated in the nuclear security summits in 2010, 2012, and 2014. At the 2012 summit in Seoul, Chinese President Hu Jintao emphasized that “the threat of nuclear terrorism cannot be overlooked” and that confronting nuclear terrorism is a “long and arduous task.” Two years later, Hu’s successor, Xi Jinping, said at the summit in The Hague that China “must follow a sensible, coordinated and balanced approach to nuclear security and put it on the track of sound and sustainable development.”
China’s commitment to nuclear security is now well established. Since the September 11 attacks, China has made significant progress on its nuclear security system, with a focus on switching from the traditional “guns, gates, guards” approach to an effective mix of well-trained personnel with up-to-date techniques and technology. The major areas of progress include a security approach based on a design basis threat (DBT); an application of modern concepts of physical protection, based on systems-engineering approaches to analyzing vulnerabilities and designing defenses to address them; the use of modern physical protection, material control, and material accounting technologies; and requirements for in-depth vulnerability assessments of security systems.
In spite of these advances, there still is room for improvement. China does not have a unified national standard of protection against plausible nuclear security threats and still is bringing the security of its facilities into line with international norms and recommendations.
Converting its top leaders’ political commitments from the nuclear security summits into practical, sustainable reality will require China to assess several aspects of its nuclear sector’s vulnerabilities, including regulatory arrangements, physical infrastructure, and security culture. Beijing should take further steps to install a complete, reliable, and effective security system to ensure that its nuclear weapons, weapons-usable nuclear materials, nuclear facilities, and nuclear transports are effectively protected against the full spectrum of plausible terrorist and criminal threats.
The Design Basis Threat
Before the September 11 attacks, China’s nuclear facilities were designed mainly to withstand natural disasters and accidents. Since those attacks, China has adopted the concept of protecting nuclear facilities against a DBT that might involve both outsider and insider adversaries.
In 2008 the Chinese National Nuclear Safety Administration (CNNSA) issued its Nuclear Facility Physical Protection Guidelines, which are treated in practice as mandatory. These guidelines call on all civilian nuclear facilities to apply a security approach based on a DBT. Each operator should develop a site-specific DBT, which is then approved by regulators before it is used in the design of a physical protection system. The guidelines recommend that, in developing a site-specific DBT, operators conduct an evaluation of threats that their nuclear facilities could face. Major elements of the evaluation should include the attributes and characteristics of potential criminals, their motivations and intentions, the scale of their activity and capabilities, and the possible means and tactics they could adopt. Potential adversaries could include outsiders, insiders, or outsiders and insiders working together.
Although the 2008 guidelines require a DBT, they contain no clearly defined standards for how each nuclear facility should design one for its local conditions. Operators typically design their site-specific DBTs on a case-by-case basis, taking into account a number of factors, including the socioeconomic situation in the area surrounding the facility. Based on the general requirements for DBTs in the guidelines, the operators of a nuclear facility study, discuss, and evaluate their proposed DBTs in relation to current threat levels with the China Atomic Energy Authority (CAEA), the CNNSA, the Ministry of Public Security (MPS), the local security department, and other relevant organizations. Eventually, the DBT is submitted to the CAEA for approval. The details of the DBT are kept secret from the public.
Chinese experts have analyzed possible sabotage scenarios against China’s nuclear facilities, including scenarios involving nuclear power plants. The experts concluded that China’s nuclear power plants would not be able to withstand the impact from commercial airplanes and heavy weapons, including missiles. Moreover, they said, collusion between insiders and outsiders would pose a great threat to nuclear facilities. Yet, the 2008 guidelines have not addressed these concerns. As CNNSA Director Li Ganjie noted, the existing DBT for nuclear power plants could have produced designs that are unable to resist attacks from large-scale and well-organized terrorist groups with powerful weapons.
To address these shortcomings, China needs to update and clarify its DBT requirements for all military and civilian nuclear facilities. China should establish a national-level DBT, as exists in the United States and many other countries. Individual facilities are poorly equipped to understand the full spectrum of threats that national authorities and intelligence agencies may have identified, and substantial variation among facilities could leave dangerous weak points that adversaries could exploit. Modest adjustments to the national DBT could be made, with the approval of regulators, to reflect the particular circumstances at individual sites.
China also should review and upgrade the criteria used for designing physical protection for its nuclear facilities. Operators should develop and implement security plans that provide effective protection against a threat that includes the full spectrum of plausible adversaries and tactics. That spectrum would include not only brute-force attacks, but also deception and stealth from insiders and outsiders working together.
Some nuclear experts in China may argue that it is not necessary to have national DBT standards because of the different situations at various nuclear sites. Indeed, it is difficult to determine which threats are the ones against which facilities need to be protected and how much money to spend in doing that. Nevertheless, China should invest in measures to protect against actions that terrorists and criminals have routinely carried out in attacks and thefts elsewhere around the world. Such actions include use of multiple teams, with one team acting as a diversion or preventing response forces from arriving along the road; use of armor-piercing rocket-propelled grenades, which are devastating against guard shacks and guard fighting positions unless the structures are designed with these weapons in mind; use of explosives to destroy walls and security doors; deception attacks, in which the adversaries have official-looking uniforms and documents; use of insiders for purposes such as obtaining information on the security system; and use of unusual vehicles such as helicopters.
China should have at least a minimum DBT standard that includes protection against one modest group of well-armed and well-trained outsiders, a well-placed insider, and outsiders and an insider working together, using a broad range of possible tactics.
Finally, as INFCIRC/225/Revision 5—the most recent version of this document from the International Atomic Energy Agency (IAEA)—recommends, China should use realistic “force-on-force” exercises to test its nuclear security systems’ ability to detect and defeat intelligent adversaries using asymmetric attacks. Operators currently are required to do in-depth vulnerability assessments and performance tests of individual components of their security systems, but these do not include the realistic force-on-force exercises. No Chinese regulations require such tests, which are vital for identifying the strengths and weaknesses of security procedures.
The newly established National Nuclear Security Technology Center under the CAEA, responsible for the construction, management, and operation of China’s Center of Excellence on Nuclear Security, will conduct such exercises. These exercises, however, will mainly serve to train guard forces and will not probe how well security performs at operating facilities. Tabletop computer simulations and vulnerability assessments alone can reveal only those vulnerabilities imagined by the assessors; in the U.S. experience, force-on-force exercises often reveal problems that were not obvious from these other means. One key factor within the U.S. Department of Energy and Nuclear Regulatory Commission in improving the security systems of nuclear facilities has been requiring the correction of vulnerabilities revealed during the realistic tests.
China may lack the experience and capabilities to carry out such tests at sites while simultaneously maintaining safe and secure operation of the nuclear facilities. Nevertheless, the U.S. experience of such tests demonstrates that this can be done, and the United States could share some of that experience with China.
Reducing Internal Risks
All of the real cases of theft of highly enriched uranium (HEU) or plutonium documented by the IAEA were perpetrated by insiders or with insider cooperation. A number of known cases of sabotage at nuclear facilities (none intended to spread radiation) were perpetrated by insiders as well. Thus, it is essential to maintain a strong program to protect against the insider threat, perhaps more so as China continues to transform into a market-oriented society and becomes increasingly corrupt. Many experts believe that the more severe the corruption in a country is, the higher the potential for insider theft of materials and the greater the need for rigorous nuclear materials security measures. The risk of an insider threat is perhaps the most difficult risk to address because insiders are those authorized to access areas containing nuclear materials. The documented history of thefts of valuable items from guarded facilities indicates that the involvement of insiders, including guards, is widespread in facilities around the world.
The HEU and separated plutonium in China’s civilian nuclear sector, in particular, could be especially vulnerable to insiders. For example, China’s civilian pilot reprocessing plant at the Jiuquan nuclear complex in Gansu province was not designed for maximum security when construction began in 1995. It shares some facilities with a previous military reprocessing plant that was not designed with an up-to-date material protection, control, and accounting system. Furthermore, the amount of material unaccounted for (MUF) at the plant is higher than is considered acceptable.
Fresh and spent HEU fuel also are present at research reactors, which are located at institutes. Because of funding shortages, these institutes are not as well controlled and guarded as military sites. In addition, some of the older institutes rely on outdated security and control systems. Indeed, some Chinese experts argue against stricter standards on the grounds that they will cost more. Bulk processing facilities in particular—plants that conduct fuel fabrication, spent fuel reprocessing, and uranium enrichment—tend to have limited financial resources, often causing operators to give security a low priority. Beijing reportedly has put in place personnel reliability programs at all its nuclear facilities, but the parameters of these programs are secret.
China should make available general information about these programs as a deterrent to terrorists and a source of reassurance to other governments that China takes nuclear security seriously. Operators of nuclear facilities should be required to take steps to decrease vulnerability to insiders who have an intent to do harm. In particular, in cooperation with relevant government departments, every operator should have an effective program for personnel reliability screening to strengthen access control. For example, security and other personnel with access to vital areas should be subject to periodic drug testing, background checks, and psychological or mental fitness tests, and they should be vetted at specified and random intervals. In the United States, the “root causes” of insider issues are often found to include mental and emotional stresses and financial problems; investigations in China should cover these issues and others specific to China’s culture and situation. The license conditions for facility operators should specify that facility staff should report suspicious behavior by their colleagues to a clearly designated authority.
Although personnel reliability programs are important, managers should not assume that they can eliminate the insider threat by themselves. They may miss some insider adversaries, and even trustworthy insiders could be blackmailed or coerced. Regulations should require a range of other measures to protect against insider theft and sabotage. In particular, the regulations should mandate constant surveillance of inner areas and vital areas when they are occupied, using a two-person surveillance system, a technological surveillance system including devices such as closed-circuit television, or preferably both.
China established and revised its nuclear materials control and accounting (MC&A) system based on the 1990 “Rules for Implementation of the Regulations on Nuclear Materials Control” and in accordance with international standards. In 2008 the CNNSA issued new guidelines for what it called “the standard format and content of nuclear facilities safety analysis reports on MC&A.”
Under these guidelines, a plant’s MC&A system should include clear definitions for material balance areas and key measurement points, control of measurement quality, physical inventory of materials, a MUF measurement, and a recording and reporting system. The licensee should establish physical inventory procedures for nuclear materials and conduct a complete inventory at least once a year. An inventory of plutonium-239, uranium-233, HEU, and other sensitive materials should be completed at least twice a year. The licensee is required to ensure that its records of nuclear material accounting are clear, accurate, systematic, and complete. Records should be maintained for at least five years. If MUF of more than twice the standard deviation for the measurement is detected, the CAEA should initiate an investigation into the discrepancy.
The most significant challenge to China’s efforts to establish an effective nationwide MC&A system is posed by its bulk processing facilities. Because MC&A for fresh and spent fuel at a nuclear power plant is relatively straightforward for identifiable items such as fuel rods, the MUF at these plants is expected to be exactly zero. Moreover, because fresh fuel is made with low-enriched uranium, it does not pose significant security concerns.
Thus, accounting for the nuclear materials in a country’s reactors is relatively easy.
Accurate material accounting in bulk processing facilities is much more difficult. The operations of China’s pilot reprocessing plant demonstrate the challenge. In December 2010, China conducted a hot test of its pilot reprocessing facility, which has a capacity of 50 metric tons of heavy metal per year (MTHM/year). Although reprocessing operations stopped after only 10 days, beginning in December 2010, many problems, including a very high measure of MUF, were identified.
China currently has stated plans to build larger reprocessing plants with capacities of 200 MTHM/year and 800 MTHM/year. It would be even more difficult to establish an effective MC&A system at these facilities than at the much smaller pilot facility. Even with an advanced, modern MC&A system, measurement uncertainties at a reprocessing plant are typically in the range of 1 percent of plutonium throughout, amounting to 20 kilograms of plutonium per year at a facility with a throughput of 200 MTHM/year. (Two hundred metric tons of spent fuel contain about two metric tons of plutonium.) Thus, the construction of the planned reprocessing facilities will require a substantial investment in improved MC&A measures. Given the inevitable uncertainties in accounting, it is likely that China will ultimately have to rely primarily on other measures to prevent insider theft.
The government should make sure the operators have an accounting system that is able to detect the removal of material, localize the removal in time and space, and identify the insiders who had access to the material.
Updating, Enforcement Needed
Since the mid-1980s, China has issued a number of regulations, rules, and technical guidelines regarding the security of nuclear and radioactive materials and nuclear facilities. Currently, the only major regulations on fissile material controls are found in the “Regulations for Control of Nuclear Materials,” issued in 1987. Based on these regulations, China issued “Rules for Implementation of the Regulations on Nuclear Materials Control” in 1990, which are also the only existing rules on the subject.
China should update its 1987 regulations and 1990 rules by issuing rules and regulations that are clearer and more stringent, based on at least the minimum DBT standard described above. Although Beijing has pledged to adopt almost all of the existing international legal frameworks to prevent nuclear terrorism, China needs to effectively incorporate these frameworks into its domestic regulations and rules to strengthen its nuclear security on the ground.
Implementing and enforcing new regulations and rules are more difficult than establishing them. To ensure effective implementation, the government and operators should take several steps. For example, regulatory agencies should be adequately staffed with personnel possessing appropriate expertise. The government should have a regime of clear rewards and strict penalties to ensure compliance with its regulations and with international norms. The enforcement regime should include a review of records of the security performance of the companies being evaluated for contracts involving work with nuclear weapons or materials.
In addition, China should have the ability to deploy and coordinate effective responses to threats to nuclear facilities or nuclear materials in transit. Finally, regulators should review implementation practices to confirm that operators can protect against the DBT for a given nuclear facility. Just as with nuclear safety, the focus should be on constantly working to find and fix remaining vulnerabilities and establish more-effective approaches.
Strengthening Security Culture
To make sure that nuclear security systems are actually implemented effectively, the development of a strong security culture, in which the relevant individuals hold a deeply rooted belief that insider and outsider threats are credible, is imperative.
Unfortunately, many Chinese experts continue to doubt that there is a credible threat to Chinese nuclear materials and facilities. Some endorse China’s current commitments to upgrading nuclear security only because they see it as necessary to comply with international requirements. They do not actually see the threat as serious. They argue that nuclear terrorism may be a problem for the United States but that it is not an urgent concern for China.
They believe that the probability of terrorists gaining access to fissile material inside China and using it to make a crude nuclear bomb is very low. The experts argue that the technologies necessary to manufacture, deliver, and detonate such a weapon would be too difficult to obtain.
These experts see the risk of sabotage at a nuclear power plant, which could result in a major release of radioactive material, as plausible but very low. They maintain that groups hostile to the government lack the means to conduct such attacks and that, in any case, China’s current security system should be good enough to stop any attempts.
These experts may well be underestimating the threat. As the number of nuclear power plants in China expands rapidly, the risk of sabotage at a civilian facility grows more plausible.
China’s nuclear experts give more credence to the possibility that terrorists could acquire other radioactive material inside the country and use it to make a “dirty bomb.” They recognize the risks inherent in China’s possession of thousands of radioactive sources, distributed over a wide region, as well as many orphan sources outside any regulatory control.
Although the likelihood that terrorists might set off a dirty bomb is higher than the likelihood that they would detonate a nuclear bomb, the consequences of the latter would be vastly greater. As noted earlier, the possibility of insider theft of nuclear materials cannot be ruled out. Moreover, terrorist attacks by Chinese separatist groups, foreign organizations, or some combination may also one day pose a real threat to China’s nuclear facilities.
The East Turkestan movement, which seeks an independent state in the Chinese autonomous region of Xinjiang, has long received training, financial assistance, and support from international terrorist groups, including al Qaeda. Drawn from China’s predominantly Muslim Uighur community, the East Turkestan extremists claimed responsibility for more than 200 acts of terrorism between 1990 and 2001, and some subgroups have been involved in the ongoing war in Syria. Over the last several years, members of the East Turkestan movement have carried out more than a dozen attacks, many on government buildings and police stations. These attacks, most of which involved explosives and grenades, resulted in numerous deaths. Furthermore, China’s neighbors in Central Asia and Pakistan have served as safe havens for members of the movement. These countries also are home to a high level of international terrorist activity and are centers of nuclear smuggling and proliferation activities. It is possible that East Turkestan extremists could acquire fissile material or nuclear weapons from their bases in these areas, which they could also use to plan and launch attacks.
China also faces the challenge of complacency among a significant number of senior nuclear experts and within its nuclear industry. These experts believe that China already has strict nuclear security systems that have worked well and have been free of accidents over the past 50 years. Some managers and employees at Chinese nuclear plants do not recognize the importance of advanced and stringent material protection, control, and accounting systems. In some cases, the guards turned off detectors at portals for enrichment facilities to reduce their usage to avoid the need for frequent replacement.
Moreover, growth of the nuclear industry has created a serious shortage of adequately trained guards, security personnel, and other necessary staff. As more employees are hired from non-nuclear fields, the nuclear safety and security culture will be further diluted. In plants where operations have been switched from military to civilian purposes, the operators may still be used to keeping everything secret and will not willingly share problems with outsiders, including inspectors.
Each operator should establish a targeted program to assess and improve its facility’s security culture. In addition, China should conduct regular training programs at its nuclear facilities not only to improve the guards’ and security personnel’s professional skills, but also to inform them about the threats of nuclear and radiological terrorism and to impress on them that nuclear security is important and should be taken seriously. Force-on-force exercises help strengthen security culture for guards and other employees who witness the seriousness with which security risks are addressed and see plausible ways the security system might be overcome. Each staff member should not only scrupulously abide by the existing nuclear security regime, but also actively and continuously find ways to improve it. Effective security comes not only from advanced devices, but, even more importantly, from human choices. Finally, China should continue and further strengthen its cooperation with external organizations, in particular the U.S. Energy Department and the IAEA.
Hui Zhang is a senior research associate at the Project on Managing the Atom at the Belfer Center for Science and International Affairs at Harvard University’s John F. Kennedy School of Government, where he leads a research initiative on China’s nuclear policies. Research for this article was supported by a grant from the Carnegie Corporation of New York.
1. Hu Jintao, “Towards Greater Nuclear Security Through Cooperation: Statement at the Seoul Nuclear Security Summit” (March 27, 2012), http://www.fmprc.gov.cn/mfa_eng/topics_665678/hjtatnsnss_665720/t920822.shtml.
2. Xi Jinping, Statement at the Nuclear Security Summit, The Hague, March 24, 2014, http://www.fmprc.gov.cn/mfa_eng/wjdt_665385/zyjh_665391/t1140583.shtml.
3. For more details, see Hui Zhang and Tuosheng Zhang, “Securing China’s Nuclear Future,” Belfer Center for Science and International Affairs, Harvard University, March 2014, http://belfercenter.ksg.harvard.edu/files/securingchinasnuclearfutureenglish.pdf.
4. See ibid.
5. The design basis threat, as defined by the International Atomic Energy Agency (IAEA), encompasses the attributes and characteristics of potential insider or external adversaries or both who might attempt unauthorized removal or sabotage, against which a physical protection system is designed and evaluated. See IAEA, “Nuclear Security Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities (INFCIRC/225/Revision 5),” IAEA Nuclear Security Series, No. 13 (January 2011), http://www-pub.iaea.org/MTCD/publications/PDF/Pub1481_web.pdf (hereinafter INFCIRC/225/Revision 5).
6. Chinese National Nuclear Safety Administration (CNNA), “Nuclear Facility Physical Protection Guidelines,” 2008. (in Chinese).
7. Chinese nuclear security experts, interviews with author, Beijing, October 2011 and November 2012.
8. Pan Ziqiang et al., eds., Management of Nuclear and Radiological Terrorism Incidents [in Chinese] (Beijing: Science Press, 2005).
9. Li Ganjie, “Nuclear Security: The New Challenges for Security of Nuclear Power Plants” [in Chinese] (presentation at IAEA meeting, 2008), http://www-pub.iaea.org/mtcd/meetings/PDFplus/2008/cn168/Presentations/Session3_Li.pdf.
10. Matthew Bunn and Evgeniy Maslin, “All Stocks of Weapons-Usable Nuclear Materials Worldwide Must Be Protected Against Global Terrorist Threats,” Journal of Nuclear Materials Management, Vol. 39, No. 2 (Winter 2011).
12. INFCIRC/225/Revision 5.
13. Chinese nuclear security experts, interviews with author, Beijing, January 2013 and July 2014.
14. Oleg Bukharin, “Physical Protection Performance Testing: Assessing U.S. NRC Experience,” Journal of Nuclear Materials Management, Vol. 28, No. 4 (Summer 2000): 21-27.
15. Chinese nuclear security experts, interviews with author, Beijing, October 2011 and January 2013.
16. Lonnie Moore, “Dealing With the Insider Threat” (presentation at workshop on the safety and security of China’s nuclear facilities, Shenzhen, January 15-18, 2013). See also IAEA, “Preventive and Protective Measures Against Insider Threats,” IAEA Nuclear Security Series, No. 8 (September 2008), http://www-pub.iaea.org/MTCD/publications/PDF/pub1359_web.pdf; World Institute for Nuclear Security, “Managing Internal Threats,” 2010; Matthew Bunn and Kathryn M. Glynn, “Preventing Insider Theft: Lessons From the Casino and Pharmaceutical Industries,” Journal of Nuclear Materials Management, Vol. 41, No. 3, (Spring 2013): 4-16.
17. For a suggestion of the linkage between corruption and nuclear security, see Nuclear Threat Initiative, “NTI Nuclear Materials Security Index: Building a Framework for Assurance, Accountability, and Action,” 2nd ed., January 2012, http://ntiindex.org/wp-content/uploads/2014/01/2014-NTI-Index-Report.pdf.
18. For example, see IAEA, “Preventive and Protective Measures Against Insider Threats”; Bunn and Glynn, “Preventing Insider Theft,” pp. 4-16.
19. If material unaccounted for (MUF) of more than twice the standard deviation for the measurement is detected, an investigation into the discrepancy must be initiated. In China’s pilot reprocessing facility, the MUF is higher than that level. Chinese nuclear experts, interviews with author, Beijing, spring 2013.
20. Pan et al., Management of Nuclear and Radiological Terrorism Incidents.
21. CNNSA, Chinese Ministry of Energy, and the Commission for Science, Technology, and Industry for National Defense, “Rules for Implementation of the Regulations on Nuclear Materials Control in the People’s Republic of China” [in Chinese], September 25, 1990, http://www.caea.gov.cn/n16/n1130/77224.html.
22. CNNSA, “The Standard Format and Content of Nuclear Facilities Safety Analysis Report on MC&A,” 2008.
23. Chinese nuclear experts, interviews with author, Beijing, spring 2013.
24. Hui Zhang, “Options for China’s Nuclear Spent Fuel Management” (presentation, Workshop on Strategic Nuclear Issues in East Asia, Beijing, March 6, 2014), http://belfercenter.ksg.harvard.edu/files/optionsforchinas-nuclearspentfuelmasmanagement.pdf.
25. Hui Zhang, “Chinese Reprocessing and Nuclear Security Issues” (Presentation, Institute of Nuclear Materials Management 55th Annual Meeting, Atlanta, July 24, 2014), http://belfercenter.ksg.harvard.edu/files/ChinaReprocessing-INMM2014_hzhang.pdf.
26. State Council of the People’s Republic of China, “Regulations for Control of Nuclear Materials of the People’s Republic of China” [in Chinese], June 1, 1987, http://www.caea.gov.cn/n16/n1130/77219.html.
27. Chinese nuclear security experts, interviews with author, Beijing, March 2014.
28. IAEA, “Nuclear Security Culture,” IAEA Nuclear Security Series, No. 7 (September 2008), http://www-pub.iaea.org/MTCD/publications/PDF/Pub1347_web.pdf.
29. Chinese nuclear security experts, interviews with author, Beijing, October 2011 and January 2013.
30. Pan et al., Management of Nuclear and Radiological Terrorism Incidents.
31. Hui Zhang, “Securing China’s Nuclear Power Plants,” Journal of Nuclear Materials Management, Vol. 42, No. 2 (Winter 2014.): 22-32.
32. For example, see Liu Senling, “Status of Research on Nuclear Security Technology in CIAE” (presentation, Harvard-Peking University Workshop on Nuclear Security, Beijing, October 13-14, 2011).
34. Ministry of Public Security of the People’s Republic of China, “The First Determined Lists of ‘East Turkestan’ Terror Organizations and Terrorists” [in Chinese], December 15, 2003, http://www.mps.gov.cn/n16/n983040/n1988498/1988553.html.
35. “Al-Qaida: Dead or Captured,” NBCNews.com, June 22, 2005, http://www.nbcnews.com/id/4686228.
36. See “Al-Qaeda Asks East Turkestan Terrorists to Covertly Enter Syrian War” [in Chinese], SINA.com.cn, October 29, 2012, http://news.sina.com.cn/w/2012-10-29/092225461490.shtml.
37. China Foundation for International and Strategy Studies, Combating Nuclear Terrorism: Nonstate Actors’ Nuclear Proliferation and Nuclear Security [in Chinese] (Beijing: Social Science Academic Press, 2012), p. 134.
38. Chinese nuclear regulator, interviews with author, Beijing, October 2012.
39. Chinese nuclear regulator, interviews with author, Beijing, December 2012.