ML042960417

G20040711/LTR-04-0654 - Sen Charles E. Grassley Ltr. Petition from the Nuclear Information and Resource Service Re the Duane Arnold Reactor in Iowa and the Quad Cities 1 and 2 Reactors

ML042960417
Person / Time
Site:	Duane Arnold, Quad Cities
Issue date:	10/13/2004
From:	Grassley C US SEN (Senate)
To:	Rathbun D Office of Congressional Affairs
Shared Package
ML043020495	List: ML042960417 ML043020469
References
G20040711, LTR-04-0654
Download: ML042960417 (44)

Text

EDO Principal Correspondence Control FROM: DUE: 11/10/04 EDO CONTROL: G20040711 DOC DT: 10/13/04 FINAL REPLY:

Senator Charles E. Grassley Rathbun, OCA FOR SIGNATURE OF : ** GRN ** CRC NO: 04-0654 Reyes, EDO DESC: ROUTING:

Nuclear Security Coalition 2.206 on Actions to Reyes Provided Stronger Defenses of Boiling-Water Virgilio Reactors with Mark I & II Containments and their Kane Spent Fuel (Paul Gunter, Nuclear Information and Merschoff Resource Service) Norry Dean DATE: 10/20/04 Burns/Cyr Rathbun, OCA ASSIGNED TO: CONTACT:

NRR Dyer SPECIAL INSTRUCTIONS OR REMARKS:

Ref. G20040549.

Aq 1. s c7ev ,7 & 9 Ibs , SC-xq -0 I

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed:Oct 20, 2004 10.24 PAPER NUMBER: LTR-04-0654 LOGGING DATE: 10/19/2004 ACTION OFFICE: EDO AUTHOR: Charles Grassley AFFILIATION: SEN ADDRESSEE: Dennis Rathbun

SUBJECT:

Petition from the Nuclear Information and Resource Service regarding the Duane Arnold reactor in Iowa and the Quad Cities 1 and 2 reactors ACTION: Signature of EDO DISTRIBUTION: OCA to Ack LETTER DATE: 10/13/2004 ACKNOWLEDGED No SPECIAL HANDLING:

NOTES:

FILE LOCATION: ADAMS DATE DUE: 11/10/2004 DATE SIGNED:

EDO -- G20040711

REPLYTo: REPLYTo:

1; HART SENATEOFFICEBUILDING 135 E 103 FEDERAL COURTHOUSE BUILDING WASHINGTON, DC 20510-1501 320 6TH STREET 1202) 224-3744 SIOUX CITY, IA 51101-1244 TTY: (202) 224-4479 (712) 233-1860 fl e-mail: chucklgrassley@grassley.senate.gov 721 FEDERAL BUILDING tanfitd ntats smatc o 210 WATERLOO BUILDING 531 COMMERCIAL STREET 210 WALNUT STREET WATERLOO, IA 50701-5497 DESMOINES, IA 50309-2140 CHARLES E. GRASSLEY (319) 2326657 (515) 288-1145 WASHINGTON, DC 20510-1501 O 131 WEST 3RDSTREET i 206 FEDERALBUILDING SUITE 180 101 IST STREETSE DAVENPORT, IA 52801-1419 CEDARRAPIDS,IA 52401-1227 (319) 363-6832 October 13, 2004 (563) 322-4331 o 307 FEDERALBUILDING 8 SOUTH 6TH STREET COUNCIL BLUFFS,IA 51501-4204 (712) 322-7103 Dennis K. Rathburn Director, Office of Congressional Affairs Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Mr. Rathburn:

Enclosed please find a petition for the Nuclear Information and Resource Service signed by two of my constituents regarding the Duane Arnold reactor in Iowa and the Quad Cities 1 and 2 reactors near the Iowa border in Illinois.

I would appreciate any assistance you could provide pertaining to this matter. Please mark your return correspondence to the attention of Bradford Johnson when responding to my office.

Thank you for your attention to my request.

Sincerely, Charles E. Grassley United States Senator CEG/bj Enclosure Committee Assignments:

CHAIRMAN, CHAIRMAN, FINANCE BUDGET INTERNATIONAL NARCOTICS JUDICIARY CONTROL CAUCUS AGRICULTURE PRINTED ON RECYCLED PAPER

//o 97P 1,9o 77e 2 Nuclear Information and Resource service 1424 16th SL.NW, Suite 404, Washington, DC 20036; 202-328-0002; Fax: 202-462-2183; E-mail: nirsnet@nirs.org; Web: www.nirs.org August 18, 2004 The Honorable Charles Grassley U.S. Senate

Dear Senator Grassley,

Enclosed is a petition, and its annex and appendices, to the U.S. Nuclear Regulatory Commission calling for security upgrades on boiling water nuclear power reactors in 15 states, including the Duane Arnold reactor in Iowa and the Quad Cities 1 & 2 reactors near the Iowa border in Illinois. These General Electric Mark I and Mark II boiling water reactors are especially vulnerable to terrorist attack. We are sending you this petition on behalf of the Nuclear Security Coalition, a coalition of national, regional, and local citizens organizations, including the Independent Environmental Conservation and Activism Network and Earth Care of Iowa. Thank you for your consideration of this important matter.

Sincerely Paul Gunter Reactor Watchdog

<pgunter~nirs.org>

0 printed on recycled paper dedicated to a sound non-nuclearenergy policy.

NUCLEAR SECURYTY COALITION c/o Citizens Awareness Network Box 83, Shelburne Falls, Massachusetts 01370 Phone: 413-339-5781 Email: can~nukebusters.org Contact Person: Deb Katz August 10, 2004 Luis Reyes Office of the Executive Director of Operations U.S. Nuclear Regulatory Commission Washington, DC 20555 By FAX (301) 415-2700 PETITION TO THE U.S. NUCLEAR REGULATORY COMMISSION REQUESTING ACTIONS TO PROVIDE STRONGER DEFENSES OF BOILING-WATER REACTORS WITH MARK I & II CONTAINMENTS AND THEIR SPENT FUEL

Dear Mr.Reyes:

The Nuclear Security Coalition, a consortium of independent organizations that serve the public interest, submits this Petition to the US Nuclear Regulatory Commission (NRC).

An accompanying document, the Annex, provides supporting information and is part of the Petition.

Member organizations of the Nuclear Security Coalition are, collectively, the Petitioners.

Names of these organizations, and of the individual designated to represent each organization, are provided below.

This Petition is submitted pursuant to NRC Regulations 10 CFR Part 2, Subpart B, whereby any person may request the NRC to institute a proceeding to impose requirements by order, to modify, suspend or revoke a license, or to take such other action as may be proper.

The NRC is obligated by the Atomic Energy Act of 1954, as amended, to take actions of the type requested in this Petition. The Act states in Title I, Chapter 1, Section 2(d):

"The processing and utilization of source, byproduct, and special nuclear material must be regulated in the national interest and in order to provide for the common defense and security and to protect the health and safety of the public."

Pursuant to House Appropriations Committee Report 108-554 (June 18, 2004), NRC is required to take "immediate steps" to upgrade spent fuel pool safety and security, to

Petition To Address Structural Vulnerabilities ofMark I & II BWRs and TheirIrradiatedFuel August 2004 Page 2 conduct further analyses of pool vulnerabilities, and to report back to the committee within 90 days, in response to the National Academy of Sciences (NAS) report on fuel pool vulnerabilities to be released later this month. This petition supports the concerns raised by the NAS and the Appropriations Committee.

This Petition discusses potential destructive attacks on nuclear facilities, attacks that could cause great public harm. No information is contained in the Petition, including its Annex, that could assist the perpetrator of such an attack. Accordingly, this Petition is appropriate for general distribution.

The facts and arguments set forth in the accompanying Annex establish the following points:

(i) nuclear power plants are key national assets and prime targets for attack; (ii) defending nuclear power plants is a national-security imperative; (iii) the NRC requires only a light defense of nuclear power plants; (iv) nuclear power plants and their spent fuel are vulnerable to attack; (v) boiling-water reactors (BWRs) with Mark I & II containments have a particular vulnerability to attack; (vi) options are available for stronger defense of Mark I & II BWRs; and (vii) the public should be involved in developing stronger defenses.

Accordingly, the Petitioners request that the NRC takes the following enforcement actions:

(i) issue a Demand For Information to the licensees for all Mark I and II BWRs and conduct a 6-month study of options for addressing structural vulnerabilities; (ii) present the findings of the study at a national conference attended by all interested stakeholders, providing for transcribed comments and questions; (iii) develop a comprehensive plan that accounts for stakeholder concerns and addresses structural vulnerabilities of all Mark I and II BWRs within a 12-month period; (iv) issue Orders to the licensees for all Mark I and II BWRs compelling incorporation of a comprehensive set of protective measures, including structural protections; and (v) make future operation of each Mark I and II BWR contingent on addressing their structural vulnerability with participation and oversight by a panel of local stakeholders.

The Demand For Information will require the licensees to provide answers to the following questions:

1.- What is the current licensed capacity and inventory for spent fuel assembly

. storage in the spent fuel pool?

Petition To Address Structural Vulnerabilities of Mark I & II BWRs and Their IrradiatedFuel August 2004 Page 3

2. What is the projected number of spent fuel assemblies to be discharged from the reactor core in the next five and ten years?

3. What is the calculated decay heat load on the spent fuel pool from the current inventory and licensed capacity of spent fuel assemblies?

4. What is the calculated decay heat load on the spent fuel pool from the inventory of spent fuel assemblies projected to be discharged from the reactor core in the next five and ten years?

5. What is the radionuclide inventory of the spent fuel pool at its design basis loading?

6. What is the water volume of the spent fuel pool?

7. What is the design heat removal capacity of the spent fuel pool cooling system?

8. Is the facility licensed for onsite dry storage of spent fuel? If so, how many spent fuel assemblies are currently in dry storage?

9. What are the spent fuel pool water makeup capabilities (sources and flow rates)?

10. What are the results from studies, evaluations, and/or analyses conducted on the vulnerability of the spent fuel pool to (a) aircraft, (b) tornado-generated missiles, and (c) fires?

Sincerely, Deb Katz, Executive Director Paul Gunter Citizens Awareness Network Nuclear Information & Resource Service P.O. Box 83 1424 16th St. NW, #404 Shelburne Falls, MA 01370 Washington, DC 20036 Tel 413 339 5781 Tel. 202 328 0002 Email: deb~nukebusters.or Email: pgunturanirs.org Jim Riccio Wenonah Hauter, Director Greenpeace Critical Mass Energy and Environment 702 H Street, NW Program Washington, DC 20001 Public Citizen Tel 202 319 2487 215 Pennsylvania Ave. SE Email: jim.riccio0ak2zdc.enpeace.org Washington, DC 20003 Tel 202 546 4996 Gordon Thompson mboyd(~citizen.org Institute for Resource & Security Studies 27 Ellsworth Avenue David Lochbaum Cambridge, MA 02139 Union of Concerned Scientists Tel 617 491-5177 Washington, DC Email: irssgigc org Tel 202 223 6133 Email: dlochbaum~aucsusa.org

Petition To Address Structural Vulnerabilities of Mark I & II BWRs and Their IrradiatedFuel August 2004 Page 4 Susan Gordon, Director Michael Keegan Seattle Office Citizens Resistance at Fermi Two Alliance for Nuclear Accountability Monroe, MI 48161 1914 N. 3 4t Street, suite 407 Tel 734 735 6373 Seattle; WA98103 Email: mkeegani(.comcast.net Tel 206 547 3175 Email: susaneordon(i)earthlink.net Eric J. Epstein, Coordinator EFMR Monitoring David Agnew, Director 213 South Union Street Cape Downwinders Middletown, PA 17057 173 Morton Rd. Tel 717 944 3007 South Chatham, MA 02659 Tel 508 432 1718 Jed Thorp Energy Campaign Organizer Tim Judson Clean Water Action Central New York-Citizens Awareness 36 Bromfield St., Suite 204 Network Boston, MA 02108 P.O. Box 3123 Tel 617 338 8131 Oswego,NY 13126 FAX 617 338 6449 Tel 315 425 0430 Email: jthorp=~,deanwater.org Email: cnycanpi)nukebusters.org Sal Mangiagli Adrienne Esposito, Executive Director Connecticut-Citizens Awareness Citizens Campaign for the Environment Network 225-A Main St. 54 Old Turnpike Rd.

Farmingdale, NY 11735 Haddam, CT 06438 Tel 516 390 7150 Tel 860 345 2157 Email: aessito&0iizenscamaign.or Email: ctcanicomcast.ne Kathleen Curtis, Executive Director Jane Magers Citizens' Environmental Coalition Earth Care 33 Central Ave. 1922 Lincoln Avenue Albany, NY 12210 Des Moines, IA 50314-1561 Tel 518 462 5527 Tel 515 280 5129 FAX 518 465 8349 Email: jenisunijuno.com Email: ceckatiyiigcrg Judith Johnsrud Geri Winslow Environmental Coalition on Nuclear Citizens' Regulatory Commission Power 30 Mullen Hill Rd. 433 Orlando Ave.

Waterford, CT 06385 State College, PA 16803 Tel (860) 442-6536 Tel 814-237 3900 Email: johnsruduiiplink.net

' I '

Petition To Address Structural Vulnerabilities of Mark I & II BWRs and TheirIrradiatedFuel August 2004 Page 5 Linda S. Ochs Susan Peterson Gately Finger Lakes Citizens for the Lakeshore Environmental Action Environment 12025 Delling Rd.

2400 Homestead Dr. Wolcott, NY 14590 Waterloo, NY 13165 Tel 315 594 1906 Tel 315 539 5607 Email: susan(Esilverwaters.com Email: Isochs(.Iocalnet.com Kate Harris, Organizer Glenn Carroll Massachusetts-Citizens Awareness Georgians Against Nuclear Energy Network Tel 404 378 9542 Email: kate~earthlovers.org Email: atom.girl(lmindspring.com Frank Gorke, Energy Advocate Gerald Pollet, Executive Director Massachusetts-PIRG Heart of America Northwest 44 Winter Street, 4th floor 1305 4th Ave, Suite 208 Boston, MA 02108 Seattle, WA 98101 Tel 617 747 4316 Tel 206 382 1014 FAX 617 292 8057 FAX 206 382 1148 Email: frank@masspir.org Email:

office~beartofamericanorthwest.org Tim Rinne, State Coordinator Nebraskans for Peace Leslie Perrigo 941 'O' Street, Suite 1026 Independent Environmental Lincoln, NE 68508 Conservation & Activism Network Tel 402 475 4620 2504 N. Harrison St., D3 FAX 402 475 4624 Davenport, IA 52803 Email: nftstate~=redjellyfish.net Email: wntrlad&_.htmail.

Peter Alexander Robin Miller, Co-chair New England Coalition on Nuclear Justice Through Peace Initiative Pollution 192 West Fifth Street PO Box 545 Oswego NY 13126 Brattleboro, VT 05302 Tel 315 342 7933 Tel 802 257 0336 Email: rrile29m~wmny.rr.com FAX 802 257 0336 Email: necnpinecnp.Q Christine Shahin, Director Kids Against Pollution Emily Rusch, Energy Advocate 309 Genesee Street, Box 6 New Jersey Public Interest Research Utica, New York, 13501 Group Tel 315 868 7960 11 N. Willow St.

Email: Trenton, NJ 08608 christine@kidsagainstpollution.org Tel 609 394 8155 Email: eruschjnjpirg.org

Petition To Address StructuralVulnerabilitiesof MarkI & IIBWRs and Their IrradiatedFuel August 2004 Page 6 Jason Babbie Vicki Baker Environmental & Energy Policy Analyst People's Environmental Network of New New York-Public Interest Research York (pENNY)

Group 4432 South St 9 Murray Street, Floor 3 Jamesville, NY 13078 New York, NY 10007-2223 Tel 315 469 5347 1Gel 212 349 6460 Email: ennmewyork0-hotmail.com FAX 212 349 1366 Email: ikbDnypirg.org Mary Elizabeth Lampert Pilgrim Watch George Crocker 148 Washington Street North American Water Office Duxbury, MA 02332 P.O. Box 174 Tel 781 934 0389 Lake Elmo, MN 55042 Email: jampertiadelphia.net Tel 651 770 3861 Email: gwil1c(i)mtn.org William Abbott, Founder Plymouth County Nuclear Information Jim Warren, Executive Director Committee (PCNIC)

North Carolina Waste Awareness 50 Congress St, Suite 925

& Reduction Network Boston, MA 02109 P.O. Box 61051 Tel 617 523 5520 Durham, NC 27715-1051 Tel 919 416 5077 Stephen A. Smith, DVM FAX 919 286 3985 Executive Director Email: Jimeancwarn.org Southern Alliance for Clean Energy P.O. Box 1842 Dave Kraft, Executive Director Knoxville, TN 37901 Nuclear Energy Information Service Tel 865 637 6055 P.O. Box 1637 FAX 865 524 4479 Evanston, IL 60204-1637 Email: sasmithileanenergy.org Tel 847 869 7650 FAX 847 869 7658 Sara Barczak, Safe Energy Director Email: neis~neis.org Southern Alliance for Clean Energy 3025 Bull Street, Suite 101 Magdaline Volitis Savannah, GA 31405 Nuclear Free Vermont Tel 912 201 0354 110 Dorsch Hill Rd Email: saralcleanenergy.org Putney, VT 05346 Tel 802 387 4569 Jessica Maxwell Email: magdaline(lmindsringcom Syracuse Peace Council 924 Burnet Ave.

Syracuse, NY 13203 Tel 315 472 5478 Email: jessicatpeacecouricil.net

Petition To Address Structural Vulnerabilities ofMark I & II BWRs and TheirIrradiatedFuel August 2004 Page 7 Eric J. Epstein, Chairman TMI-Alert 4100 Hillsdale Road Harrisburg, PA 17112 Tel 717 541 1101 Email: ericepsteinicomcast.net Norm Cohen UNPLUG Salem Campaign and the Coalition for Peace and Justice 321 Barr Ave.

Linwood, NJ 08221 Tel (609) 601-8583/-8537 Email: ncohenl2(comcast.net Derrik Jordan Vermont-Citizens Awareness Network P.O. Box 403 Putney, VT 05346 Tel 802 387 4050 Email: hillioy(sover.net

NUCLEAR SECURrrY COALITION c/o Citizens Awareness Network Box 83, Shelburne Falls, Massachusetts 01370 Phone: 413-339-5781 Email: caninukebusters.org Contact Person: Deb Katz PETITION TO THE U.S. NUCLEAR REGULATORY COMMISSION REQUESTING EMERGENCY ENFORCEMENT ACTIONS TO ADDRESS STRUCTURAL VULNERABILITY OF BOILING-WATER REACTORS WITH MARK I & II CONTAINMENTS AND THEIR IRRADIATED FUEL POOLS Annex to the Petition August 2004 Preface The Nuclear Security Coalition, a consortium of independent organizations that serve the public interest, submits an accompanying Petition to the US Nuclear Regulatory Commission (NRC). This document, the Annex to the Petition, provides supporting information and is part of the Petition.

The Petition is submitted pursuant to NRC Regulations 10 CFR Part 2, Subpart B, whereby any person may request the NRC to institute a proceeding to impose requirements by order to modify, suspend or revoke the license of all GE Mark I and Mark Uoperators as necessary.

The NRC is obligated by the Atomic Energy Act of 1954, as amended, to take actions of the type requested in this Petition. The Act states in Title I, Chapter 1, Section 2(d):

"The processing and utilization of source, byproduct, and special nuclear material must be regulated in the national interest and in order to provide for the common defense and security and to protect the health and safety of the public."

This Petition discusses potential destructive attacks on nuclear facilities, attacks that could cause great public harm. All information contained in this Petition was taken from publicly available documents. No information is contained in the Petition, including this Annex, which could assist the perpetrator of such an attack. Accordingly, this Petition and Annex are appropriate for general distribution.

Petition To Address Structural VulnerabilitiesofMark I & II BWRs and Their IrradiatedFuel August 2004 Page2 Table of Contents

1. Introduction 2; Nuclear Power Plants are Critical National Infratructure and Prime Terrorist Targets

3. Addressing Structural Vulnerability of Nuclear Power Plants is a National-Security Imperative

4. The NRC Requires Only a Light Defense of Nuclear Power Plants

5. Nuclear Power Plants and Spent Fuel are Vulnerable to Attack

6. Mark I & II BWRs Have a Particular Vulnerability to Attack

7. Options for Addressing the Structural Vulnerability of Mark I & II BWRs Are Necessary

8. The Public Needs to be Involved in Addressing the Structural Vulnerability of Mark I and Mark II Containments and Their Irradiated Fuel Storage Pools

9. Actions Sought by this Petition

10. Bibliography Appendix: List of Mark I and II BWRs and their locations Appendix: Petition Sign on Groups to Date Appendix: Map of U.S. Commercial Reactor Sites with Mark I and/or Mark II Boiling Water Reactors Appendix: Diagram of Mark I Reactor Building and Elevated Irradiated Fuel Storage Pond Appendix: Congressional Districts and Representatives for Mark I and Mark II BWRs Appendix: Attorneys General for Mark I and Mark II BWRs

Petition To Address Structural Vulnerabilities ofMark I & II BWRs and Their IrradiatedFuel August 2004 Page 3

1. Introduction The Petition that includes this Annex addresses a particular class of commercial nuclear reactors - boiling water reactors (BWRs) with Mark I and II containments. The relevant reactors are listed in the Appendix to this Annex. In the USA, 103 operational commercial reactors operate at 65 sites in 31 states.' Of these 104 reactors, 69 are pressurized-water reactors (PWRs), 9 with ice-condenser containments and 60 with dry containments. The remaining 34 reactors are BWRs, 22 with Mark I containments, 8 with Mark II containments and 4 with Mark III containments. In addition there are 27 previously-operating commercial reactors in various stages of storage or decommissioning.

As of December 2000, all but 2 of the 103 operating reactors had been in service for at least 9 years, and 55 reactors had been in service for at least 19 years.2 The nominal duration of a reactor operating license is 40 years.

All of the 103 operating reactors are vulnerable to accidents or acts of malice or insanity.

Such an event could lead to a substantial release of radioactive material from a reactor to the environment A similar release could occur from spent nuclear fuel stored in a pool adjacent to a reactor, or stored in an independent spent fuel storage installation (ISFSI).

The Mark I and II BWRs have a particular vulnerability that is explained in Section 6, below. This Petition calls for actions that address this class of reactors. In focusing on Mark I and II BWRs, the Petitioners do not imply that the vulnerability of other commercial reactors is less deserving of attention.

This Annex to the Petition provides important background information in Sections 2 through 5, below. Then, in Section 6, it explains the particular vulnerability of Mark I and II BWRs. Options to address structural vulnerabilities of these reactors and their irradiated fuel to terrorist attack are described in Section 7. The need to involve the public in addressing these vulnerabilities is described in Section 8. Actions sought by this Petition are set forth in Section 9, and a bibliography is provided in Section 10.

In addition, Browns Ferry Unit 1,a BWR with a Mark I containment, is nominally operational.

However, the reactor is defiueled and operation under Administrative Hold. The irradiated fuel pool is still operational, however.

2 Datafromrn ee NRC website (www.nrc.gov), accessed on 24 April 2002.

PetitionTo Address Structural Vulnerabilitiesof MarkI & II&BWRs and Their IrradiatedFuel August 2004 Page 4

2. Nuclear Power Plants are Critical National Infrastructure and Prime Targets As the regulator of nuclear power plants and their spent fuel, the US Nuclear Regulatory Commission (NRC) bears a heavy responsibility for homeland security. The National Strategy for The Physical Protection of Critical Infrastructures and Key Assets (hereafter, the National Strategy), which was published in February 2003, identifies nuclear power plants as key assets, defined as follows: 3 "Key assets represent individual targets whose destruction could cause large-scale injury, death, or destruction of property, and/or profoundly damage our national prestige, and confidence".

President Bush, in his preface to the National Strategy, stated that the Strategy "establishes a foundation for building and fostering a cooperative environment in which government, industry, and private citizens can work together to protect our critical infrastructures and key assets". 4 The Petitioners share the conviction that broad cooperation is an essential ingredient of homeland security, and present this Petition in that spirit.

In a January 2004 speech, the Chairman of the National Intelligence Council, Robert Hutchings, commented on the potential for attacks on nuclear power plants and for deliberate release of radioactive material. 5 Hutchings stated:

"Targets such as nuclear power plants, water treatment facilities,; and other public utilities are high on al-Qa'ida's targeting list as a way to sow panic and hurt our economy"............ "Just this past year, al-Qa'ida attacks in Kenya, Saudi Arabia, and Turkey have demonstrated the group's impressive expertise to build truck bombs, and we are concerned it will try to marry this capability to toxic or radioactive material to increase the damage and psychological impact of an attack"........... .I have already detailed the terrorist threat and feel it is important to point out that according to State Department statistics, more businesses are targeted in terrorist attacks than all other types of facilities combined. US interests both abroad and at home, as well as US citizens working abroad, are prime targets for terrorist groups seeking to damage the US economy and affect our way of life. High-profile facilities such as nuclear power plants, oil and gas production, and export and receiving facilities remain at risk; moreover al-Qa'ida and other terrorist groups' targets and methods may be evolving".

3 White House, 2003, page 7.

4 ibid, page iii.

5 Hutchings, 2004.

I

2etitkn To Address Structural Vulnerabilitiesof Mark I & IIBWRs and Their IrradiatedFuel August 2004 PageS Nuclear power plants and their irradiated fuel are especially likely to be targeted in a future attack on the US homeland, for symbolic and practical reasons. These facilities have a symbolic connection with nuclear weapons. The US government flaunts its superiority in nuclear weapons and rejects any constraint on these weapons through international law.6 Yet, the government justified its invasion of Iraq in large part by the possibility that the Iraqi government might acquire a nuclear weapon. It would be prudent to assume that this situation will motivate terrorist groups to search for ways to attack US nuclear facilities. Also, nuclear power plants and Independent Spent Fuel Storage Installations (ISFSI) are large, fixed targets that are, at present, lightly defended.

In the eyes of an enemy, they can be regarded as pre-deployed radiological weapons that could release large amounts of radioactive material.

3. Addressing the Structural Vulnerability of Nuclear Power Plants is a National-Security Imperative An attack on a US nuclear facility would be either an act of insanity or an act of malice. If malicious, the attack would support the political objectives of a domestic or foreign constituency. Currently, concern about attack is focused on foreign enemies and their domestic sympathizers. These groups are not the only sources of threat, but they deserve special consideration because, in opposing them, the nation must balance the costs and benefits of offensive and defensive actions.

The need for a balance between offensive and defensive actions was recognized by a task force convened by the Council on Foreign Relations. In an October 2002 report, this group stated:7 "Homelandsecurity measures have deterrence value: US counterterrorism initiatives abroad can be reinforced by maling the US homeland a less tempting target We can transform the calculations of would-be terrorists by elevating the risk that (1) an attack on the United States will fail, and (2) the disruptive consequences of a successful attack will be minimal. It is especially critical that we bolster this deterrent now since an inevitable consequence of the US government's stepped-up military and diplomatic exertions will be to elevate the incentive to strike back before these efforts have their desired effect".

By requiring only a light defense for civilian nuclear facilities, the NRC is, in effect, rejecting the advice of the Council on Foreign Relations' task force. An explicit rejection of this type of advice was articulated by the former NRC chairman, Richard Meserve, in late 2002:8 6 Deller, 2002; Scany, 2002.

7 Hart et al, 2002, pp 14-15.

8 Meserve, 2002a, page 22.

Petition To Address StructuralVulnerabilitiesofMark I & II BWRs and Their IrradiatedFuel August 2004 Page 6 "If we allow terrorist threats to determine what we build and what we operate, we will retreat into the past.- back to an era without suspension bridges, harbor tunnels, stadiums, or hydroelectric dams, let alone skyscrapers, liquid-natural-gas terminals, chemical factories, or nuclear power plants. We cannot eliminate the terrorists' targets, but instead we must eliminate the terrorists themselves. A strategy of risk avoidance - the elimination of the threat by the elimination of potential targets - does not reflect a sound response."

In this statement, Meserve offers a false choice. To deter attack, the nation need not scrap every modem technology or infrastructure asset. Instead, the more attractive and vulnerable targets could receive a level of defense that substantially reduces the likelihood of a successful attack and the consequences of an attack. Replacement of the target with a more robust alternative would be an option if the cost of a stronger defense were prohibitive. However, the petitioners also regard reactor closure and dismantlement of these potential nuclear targets as a viable option to reduce, remove or harden its collaterally destructive profile and public safety threat.

Without any public debate, and apparently without any analysis of strategic risks, the NRC has chosen to rely primarily on US offensive capabilities to protect civilian nuclear facilities.

4. The NRC Requires Only a Light Defense of Nuclear Power Plants The NRC's basic policy on the protection of nuclear facilities from attack is laid down in the regulation 10 CFR 50.13. This regulation was promulgated in September 1967 by the US Atomic Energy Commission (AEC) - which preceded the NRC - and was upheld by the US Court of Appeals in August 1968. It states:9 "An applicant for a license to construct and operate a production or utilization facility, or for an amendment to such license, is not required to provide for design features or other measures for the specific purpose of protection against the effects of (a) attacks and destructive acts, including sabotage, directed against the facility by an enemy of the United States, whether a foreign government or other person, or (b) use or deployment of weapons incident to US defense activities."

The AEC was motivated to introduce this regulation by the intervention of a citizen --

Paul Siegel - in the construction-license proceeding for the Turkey Point nuclear power plants in Florida. Mr. Siegel argued that these plants might be attacked from Cuba. The AEC pre-empted any consideration of this issue during the license proceeding by initiating the rulemaking process that led to 10 CFR 50.13.

Although 10 CFR 50.13 limits a licensee's responsibility for defending a nuclear facility, this regulation does not prevent the US government from providing a stronger, 9 Federal Rigister, Vol. 32, No. 186, 26 September 1967, page 13445.

• etiion To Address Structural Vulnerabilitiesof MarkI & IIBWRs and Their IrradiatedFuel August 2004 Page 7 supplementary defense. This point was discussed by Richard Meserve, then chairman of the NRC, in an essay published in late 2002.10 Meserve stated:"1 "Although NRC licensees must defend nuclear power plants against the DBT

[design basis threat], September 11 revealed a type of attack that neither the NRC nor other agencies anticipated. Thus, the attacks demanded that the NRC and its licensees reevaluate the scope of potential assaults. There are limits, however, to what should be expected from a private guard force. For example, if it were determined that nuclear plants should be defended against aircraft attack, society would not expect licensees to acquire and operate anti-aircraft weaponry. Rather, this type of defense is better suited to the military."

Experience has forced the NRC to increase licensees' obligations to defend nuclear facilities. A series of events, including the 1993 bombing of the World Trade Center in New York, forced the NRC to introduce, in 1994, regulations requiring licensees to defend nuclear power plants against vehicle bombs. The terrorist events of 11 September 2001 forced the NRC to require additional measures. Nevertheless, present NRC regulations require only a light defense of nuclear facilities.

NRC Regulationsfor Site Security Present NRC regulations for the defense of nuclear facilities are focused primarily on site security, which the NRC discusses under the heading "physical protection". As described in Section 7, below, site security is one of four types of measure that, taken together, could provide a defense in depth against acts of malice or insanity. The other three types of measure are, with some limited exceptions, ignored in present NRC requirements for facility defense. 12 At a nuclear power plant or an ISFSI, the NRC requires the licensee to implement a set of physical protection measures. According to the NRC, these measures provide defense in depth by taking effect within defined areas with increasing levels of security. Within the outermost physical protection area, known as the Exclusion Area, the licensee is expected to control the area but is not required to employ fences and guard posts for this purpose.

Within the Exclusion area is a Protected Area encompassed by physical barriers including one or more fences, together with gates and barriers at points of entry. Authorization for unescorted access within the Protected Area is based on background and behavioral checks. Within the Protected Area are Vital Areas and Material Access Areas that are protected by additional barriers and alarms; unescorted access to these locations requires additional authorization.

10 Meserve, 2002a.

11 ibid, page 22.

12 For information about the NRCs present regulations and requirements for nuclear-facility defense, see:

the NRC website (www.nrc.gov), accessed on 23 May 2003; Markey, 2002; Meserve, 2002b; Meserve, 2003; and NkC, 2002.

Pctitf'o To Address Structural Vulnerabilitiesof Mark I & II BWRs and Their IrradiatedFuel August 2004 Page 8 I

As3ociated with the physical protection areas are measures for detection and assessment of an intrusion, and for armed response to an intrusion. Measures for intrusion detection include guards and instruments whose role is to detect a potential intrusion and notify the site security force. Then, security personnel seek additional information through means such as direct observation and closed-circuit TV cameras, to assess the nature of the intrusion. If judged appropriate, an armed response to the intrusion is then mounted by the site-security force, potentially backed up by local law-enforcement agencies and the FBI.

The Design Basis Threat The design of physical protection areas and their associated barriers, together with the design of measures for intrusion detection, intrusion assessment and armed response, is required to accommodate a "design basis threat" (DBT) specified by the NRC. At a nuclear power plant, the dominant sources of hazard are the reactor and the spent-fuel pool(s). In theory, both of these items receive the same level of protection, but in practice the reactor has been the main focus of attention. The DBT for an ISFSI is less demanding than that for a nuclear power plant.

In April 2003 the DBT for a nuclear power plant was revised, but the NRC announced that the features of the revised DBT would not be published. The previously-applicable DBT had the following features:13

"(i) A determined violent external assault, attack by stealth, or deceptive actions, of several persons with the following attributes, assistance and equipment: (A)

Well-trained (including military training and skills) and dedicated individuals, (B) inside assistance which may include a knowledgeable individual who attempts to participate in a passive role (e.g., provide information), an active role (e.g.,

facilitate entrance and exit, disable alarms and communications, participate in violent attack), or both, (C) suitable weapons, up to and including hand-held automatic weapons, equipped with silencers and having effective long range accuracy, (D) hand-carried equipment, including incapacitating agents and explosives for use as tools of entry or for otherwise destroying reactor, facility, transporter, or container integrity or features of the safeguards system, and (E) a four-wheel drive land vehicle used for transporting personnel and their hand-carried equipment to the proximity of vital areas, and (ii) An internal threat of an insider, including an employee (in any position), and (iii) A four-wheel drive land vehicle bomb."

13 10 CFR 73.1, Purpose and Scope, from the NRC web site (www.nrc.gov), accessed on 2 September 2002.

7 etition

• To Address Structural Vulnerabilitiesof Mark I & Hl BWRs and Their IrradiatedFuel August 2004 Page 9 For an ISFSI, the DBT was the same as for a nuclear power plant except that it did not include the use of a four-wheel-drive land vehicle, either for transport of personnel and equipment or for use as a vehicle bomb. This was true whether the ISFSI was at a new site or an old reactor site. Thus, an ISFSI at a reactor site would be less protected than the reactor(s) and irradiated fuel pool(s) at that site. At a reactor site or a new site, an ISFSI would be vulnerable to attack by a vehicle bomb.

Evolution of the DBT After the events of 11 September 2001, the NRC concluded that its requirements for nuclear facility security were inadequate. Accordingly, the NRC issued an order to licensees of operating plants in February 2002, and similar orders to licensees of decommissioning plants in May 2002 and reactor-site ISFSI licensees in October 2002, requiring "certain compensatory measures", also described as "prudent, interim measures", whose purpose was to "provide the Commission with reasonable assurance that the public health and safety and common defense and security continue to be adequately protected in the current generalized high-level threat environment".' 4 The additional measures required by these orders were not publicly disclosed, but the NRC Chairman stated that they included:' 5 (i) increased patrols; (ii) augmented security forces and capabilities; (iii) additional security posts; (iv) vehicle checks at greater stand-off distances; (v) enhanced coordination with law enforcement and military authorities; (vi) additional restrictions on unescorted access authorizations; (vii) plans to respond to plant damage from explosions or fires; and (viii) assured presence of Emergency Plan staff and resources.

In addition to requiring these additional security measures, the NRC established a Threat Advisory System that warns of a possible attack on a nuclear facility. This system uses five color-coded threat conditions ranging from green (low risk of attack) to red (severe risk of attack). These threat conditions conform with those used by the Department of Homeland Security.

The NRC has described its new, revised DBT for nuclear power plants as follows:' 6 "The Order that imposes revisions to the Design Basis Threat requires power plants to implement additional protective actions to protect against sabotage by 14 The quoted language is from page 2 of the NRC's order of 25 February 2002 to all operating power reactor licensees. Almost-identical language appears in the NRC's orders of 23 May 2002 to all decommissioning power reactor licensees and 16 October 2002 to all ISFSI licensees who also hold 10 CFR 50 licenses.

15 Meserve, 2002b.

1 6 NRC Press Release No.03-053, 29 April 2003.

Petition To Address StructuralVulnerabilitiesof Mark I & IIBWRs and Their IrradiatedFuel August 2004 Page 10 terrorists and other adversaries. The details of the design basis threat are safeguards information pursuant to Section 147 of the Atomic Energy Act and will not be released to the public. This Order builds on the changes made by the Commission's February 25, 2002 Order. The Commission believes that this DI3T represents the largest reasonable threat against which a regulated private security force should be expected to defend under existing law. It was arrived at after extensive deliberation and interaction with cleared stakeholders from other Federal agencies, State governments and industry."

Inferred Characteristicsofthe New DBT Although the new DBT for nuclear power plants was not published, its general characteristics can be inferred with reasonable confidence. Four major considerations support such an inference. First, the new DBT must be consistent with 10 CFR 50.13.

Second, the DBT will not exceed the capabilities of a "regulated private security force".

Third, there is a well-documented history over the past two decades, showing vigorous resistance by the nuclear industry to measures that enhance site security, and reluctance by the NRC to contest that resistance. 17 Fourth, available information shows no marked change in prevailing practices of site security.I8 Thus, it can be inferred that the new DBT remains focused on a ground assault by a comparatively small group of lightly-armed attackers. The most destructive instrument included in the DBT is probably a vehicle bomb. The new DBT probably does not allow for aerial or multi-modal attack by a commando-type force. It probably does not allow for an attack by water or submerged charge targeting the cooling water intake. It probably does not allow for antitank missiles or lethal chemical weapons. There is probably no provision for an attack using a commercial or general-aviation aircraft, with or without a load of fuel or explosive. There is no provision for attack using a nuclear weapon. The insider threat probably does not include carefully-planned, sophisticated interventions by key employees. Also, the new DBT does not apply to ISFSIs, so it can be assumed that ISFSIs continue to receive a lesser degree of protection than nuclear power plants.

Finally, backup for the licensee's site-security force continues to be provided by local law-enforcement agencies and the FBI, rather than the US military.

17 Hirsch et al, 2003.

I8 POGO, 2b02; Brian, 2003.

Petition To Address Structural VulnerabilitiesofMarki& II BWRs and Their IrradiatedFuel August 2004 Page 11

5. Nuclear Power Plants and Irradiated Fuel are Vulnerable to Attack It is not appropriate to publish a detailed discussion of scenarios whereby a nuclear power plant or an ISFSI might be successfully attacked. However, it must be assumed that attackers are technically sophisticated and possess considerable knowledge about individual nuclear facilities. For decades, engineering drawings, photographs and technical apalyses have been openly available for every civilian nuclear facility in the USA. This material is archived at many locations around the world. Thus, a public discussion, in general terms, of potential modes and instruments of attack will not assist attackers.

Indeed, such a discussion is needed to ensure that appropriate measures are taken to address structural vulnerabilities of reactor containments and irradiated fuel storage.' 9 Safety Systems andtheir Vudnerability The safe operation of a US commercial reactor and its associated irradiated fuel pool(s) depends upon the fuel in the reactor and the pool(s) being immersed in water. Moreover, that water must be continually cooled to remove fission heat or radioactive decay heat generated in the fuel. A variety of systems are used to ensure that water is available and is cooled, and that other safety-related functions - such as shutdown of the fission reaction when needed - are performed. Some of the relevant systems -- such as the electrical switchyard - are highly vulnerable to attack. Other systems are located inside reinforced-concrete structures - such as the reactor auxiliary building - that provide some degree of protection against attack. The reactor itself is inside a containment structure.

At some plants, but not all, the reactor containment is a concrete structure that is highly reinforced and comparatively robust. Irradiated fuel pools have thick concrete walls but are typically covered by lightweight structures.

Attack throughBrute Forceor Indirectly?

A group of attackers equipped with highly-destructive instruments could take a brute-force approach to attacking a reactor or an irradiated fuel pool. Such an approach would aim to directly breach the reactor containment and primary cooling circuit, or to breach the wall or floor of an irradiated fuel pool. Alternatively, the attacking group could take an indirect approach, and many such approaches will readily suggest themselves to technically-informed attackers. Insiders, or outsiders who have taken over the plant, could obtain a release of radioactive material without necessarily employing destructive instruments. Some attack scenarios will involve the disabling of plant personnel, which could be accomplished by armed attack, use of lethal chemical weapons, or radioactive contamination of the site by an initial release of radioactive material.

19 For a more detailed discussion of nuclear-facility vulnerability, see: Thompson, 2003.

PetitionTo Address Structural VulnerabilitiesofMarki & IIBWRs and Their IrradiatedFuel August 2004 Page 12 I.

Vulnerability of ISFSIs Dry-storage ISFSIs differ from reactors and irradiated fuel pools in that their operation is entirely passive. Thus, each dry-storage container in an ISFSI must be attacked directly.

To obtain a release of radioactive material, the wall of the fuel container must be penetrated from the outside, or the container must be heated by an external fire to such an epent that the containment envelope fails. The attack could also exploit stored chemical energy in the zirconium cladding of the spent fuel. Combustion of this cladding in air, if initiated, would generate heat that could liberate radioactive material from the fuel to the outside environment. A knowledgeable attacker could combine penetration of the fuel container with the initiation of combustion.

Requirementsfor a VulnerabilityStudy Every US commercial reactor has been subjected to a probabilistic risk assessment (PRA) or equivalent study.20 This analysis examined the reactor's potential to experience accidents due to human error, equipment failure or natural forces (e.g., earthquake), but did not consider acts of malice or insanity. Few irradiated fuel pools or ISFSIs have been subjected to a PRA-type study or a study of its vulnerability to acts of malice or insanity. Indeed, there has never been a comprehensive study of the vulnerability of any US nuclear facility to acts of malice or insanity. Spurred by the attacks on the World Trade Center and Pentagon in September 2001, the NRC has sponsored some secret studies on nuclear-facility vulnerability. However, available information shows that these studies are narrow in scope and will provide limited guidance regarding the overall vulnerability of nuclear facilities. 21 A comprehensive study of a facility's vulnerability would begin by identifying a range of potential attacks on the facility. The probability of each potential attack would be qualitatively estimated, with consideration of the factors (e.g., international events, changing availability of instruments of attack) that could alter the probability over time.

Site-specific factors affecting the feasibility and probability of attack scenarios include local terrain and the proximity of coastlines, airports, population centers and national symbols. A variety of modes and instruments of attack would be considered.

After identifying a range of potential attacks, a comprehensive study would examine the vulnerability of the subject facility to those attacks. This could be done by adapting and extending known techniques of PRA, with an emphasis on the logical structure of PRA 20 The state of the art for reactor PRAs is illustrated by: NRC, 1990.

21 The NRC's Office of Research Programs has stated (NRC, 2003, page 11): During 2003 Research will complete the realistic engineering assessments of the vulnerability of nuclear power reactors to aircraft attack and the vulnerability of spent fuel pools to explosive attacks. Two pilot plant assessments are underway to assess the threats and identify any additional potential mitigation options." Although potentially useful, these assessments could yield only a fraction of the information that would be contained in a comprehensive assessment of vulnerability.

Petition To Address Structural VulnerabilitiesofMarkl & IIBWRs andTheir IrradiatedFuel August 2004 Page 13 rather than the numerical probabilities of events. The analysis would consider the potential for interactions among facilities at a site. For example, a potentially important interaction could be the prevention of personnel access at one facility (e.g., an irradiated fuel pool) due to a release of radioactive material at another facility (e.g., a reactor).

Attention would be given to the potential for "cascading" scenarios in which attacks at some parts of a nuclear-power-plant site (e.g., control room, switchyard, diesel generators) lead to releases from reactors and/or irradiated fuel pools that were not directly attacked.

VilnerabilityofIrradiatedFuelPools The vulnerability of irradiated fuel pools deserves special mention for two reasons. First, each pool now contains an amount of long-lived radioactive material that is substantially larger than the amount in a reactor core. Second, loss of water from a pool will cause some or all of the fuel in the pool to self-ignite and burn, releasing a large amount of radioactive material to the atmosphere. 2 2 The potential for a fire exists because the pools have been equipped with high-density racks. In the 1970s, the irradiated fuel pools of US nuclear power plants were typically equipped with low-density, open-frame racks. If water were partially or totally lost from such a pool, air or steam could circulate freely throughout the racks, providing convective cooling to the irradiated fuel. By contrast, the high-density racks that are used today have a closed structure. To suppress criticality, each fuel assembly is surrounded by solid, neutron-absorbing panels, and there is little or no gap between the panels of adjacent cells. In the absence of water, this configuration allows only one mode of circulation of air and steam around a fuel assembly - vertically upward within the confines of the neutron-absorbing panels.

If water is totally lost from a high-density pool, air will pass downward through available gaps such as the gap between the pool wall and the outer faces of the racks, will travel horizontally across the base of the pool, will enter each rack cell through a hole in its base, and will rise upward within the cell, providing cooling to the irradiated fuel assembly in that cell. If the fuel has been discharged from the reactor comparatively recently, the flow of air may be insufficient to remove all of the fuel's decay heat. In that case, the temperature of the fuel cladding may rise to the point where a self-sustaining, exothermic oxidation reaction with air will begin. In simple terns, the fuel cladding - which is made of zirconium alloy - will begin to burn. The zirconium-alloy cladding can also enter into a self-sustaining, exothermic oxidation reaction with steam. Other exothermic oxidation reactions can also occur. For simplicity, the occurrence of one or more of the possible reactions can be referred to as a pool fire.

22 The NRC has published a variety of technical documents that address irradiated fuel-pool fires. The most recent of these documents is: Collins et al, 2000. For more recent analyses of irradiated fuel-pool fires, see: Alvarez et al, 2003; Thompson, 2003; and Thompson, 2002. The NRC Staff stated in March 2003 (NRC, 2003, page 10) that it has completed an 'integral analysis of a spent fuel pool accident scenario", but this analysis has not been published.

Pk.ition To Address Structural Vulnerabilities ofMark I & IIBWRs and Their IrradiatedFuel August 2004 Page 14 In many scenarios for loss of water from a pool, the flow of air that is described in the preceding paragraph will be blocked. For example, a falling object (e.g., a fuel-transfer cask) might distort rack structures, thereby blocking air flow. An attack might cause debris (e.g., from the roof of the fuel handling building) to fall into the pool and block air flow. The presence of residual water in the bottom of the pool would also block air flow.

In most scenarios for loss of water, residual water will be present for significant periods of time. Falling debris from burning fuel assemblies could block air flow to nearby fuel assemblies that have not yet ignited. Blockage of air flow, for whatever reason, will lead to ignition of fuel that has been discharged from a reactor for long periods -- potentially 10 years or longer.

Modes andInstruments ofAttack A nuclear power plant or an ISFSI could be attacked using one or more of a variety of modes and instruments. Table 1, below, shows a selection of potential modes and instruments, summarizes their key characteristics, and describes the defenses that are currently mounted against them.

One of the potential instruments of attack shown in Table 1 is an explosive-laden smaller aircraft. In this connection, it is noteworthy that the US General Accounting Office (GAO) expressed concern, in September 2003 testimony to Congress, about the potential for malicious use of general-aviation aircraft2 3 The testimony stated: 24 "Since September 2001, TSA [the Transportation Security Administration] has taken limited action to improve general aviation security, leaving it far more open and potentially vulnerable than commercial aviation. General aviation is vulnerable because general aviation pilots are not screened before takeoff and the contents of general aviation planes are not screened at any point. General aviation includes more than 200,000 privately owned airplanes, which are located in every state at more than 19,000 airports. Over 550 of these airports also provide commercial service. In the last 5 years, about 70 aircraft have been stolen from general aviation airports, indicating a potential weakness that could be exploited by terrorists."

23 Dillingham, 2003.

24 ibid, page'14. .

Petition To Address StructuralVulnerabilitiesofMarkl & IIBWRs and Their IrradiatedFuel

-August 2004 Page 15 Tatile 1 Potential Modes and Instruments of Attack on a Nuclear Power Plant25 MODE OF ATTACK CHARACTERISTICS PRESENT DEFENSE Commando-style attack

• Could involve heavy Alarms, fences and lightly-weapons and sophisticated armed guards, with offsite tactics backup l Successful attack would require substantial planning l_ and resources Commando-style by water

• Could involve heavy

• 500 yard no entry zone -

weapons/sophisticated marked by buoys - simply, tactics "no trespassing" signs

• Could target intake canal *Periodic Coast Guard

• Attack may be planned to surveillance by boat or coordinate with a land plane attack Land-vehicle bomb

• Readily obtainable Vehicle barriers at entry

• Highly destructive if points to Protected Area detonated at target Anti-tank missile

• Readily obtainable None if missile launched

• Highly destructive at point from offsite of impact Commercial aircraft

• More difficult to obtain None than pre-9/1 I

• Can destroy larger, softer targets Explosive-laden smaller

• Readily obtainable None aircraft

• Can destroy smaller, harder targets 10-kilotonne nuclear

• Difficult to obtain None weapon

• Assured destruction if I_ detonated at target A form of explosive that might be used in an attack on a nuclear power plant or an ISFSI is a shaped charge. These have many civilian and military applications, and have been used for decades. They are used, for example, as human-carried demolition charges or as warheads for anti-tank missiles. In illustration of their availability, a quick search of the Web identified a commercial supplier of military-surplus, shaped-charged warheads to 25 Adap-ted from Table 1 of: Thompson, 2003.

Petition ToAddress Structural Vulnerabilitiesof Mark I& I BWRs and Their IrradiatedFuel August 2004 Page 16 licensed civilian users. A surplus warhead with a diameter of 14 cm and length of 21 cm was advertised as being capable of penetrating more than 65 cm of rolled homogeneous armor.

The largest known shaped charge was the German MISTEL, developed late in World War II. This warhead was 2 meters in diameter, weighed 3,500 kg and contained 1,700 kg of explosive. It was carried in the nose of an unmanned bomber aircraft. The Japanese used a smaller version of this device, the SAKURA bomb, for kamikaze attacks against US warships.26 A US government laboratory has developed, and described in a published report, a shaped-charge warhead specifically intended to penetrate large thicknesses of rock or concrete. This warhead would be mounted in the nose of a cruise missile. The warhead has a diameter of 28 inches and a length of 28.5 inches. It weighs 900 pounds and contains 600 pounds of Octol explosive. When tested in November 2002, this device created a hole of 10 inches diameter in tuff rock to a depth of 19.5 feet.27

6. Mark I & I BWRs Have a Particular Vulnerability to Attack A Mark I or I BWR has its irradiated fuel pool mounted high above the ground. The outer wall of the pool is a few feet inside one of the outer faces of the reactor building.

The surface of the pool and the remainder of the refueling floor of the reactor are covered by a lightweight roof and wall structure. This arrangement makes the pool vulnerable to attack from above, below or the side. If a pool is breached, there is no surrounding structure or backfill to inhibit the drainage of water. The reactor vessel, like the pool, is above ground. Its cooling systems and containment are vulnerable to attack at several points. The exterior configuration of the reactor building facilitates accurate aiming (e.g.,

of an explosive-laden aircraft) by a knowledgeable attacker. Taken together, these factors could make a Mark I or II BWR a comparatively attractive target of attack.

7. Options are Available for Stronger Defense of Mark I & I BWRs Four categories of defensive measures, taken together, could provide a stronger defense of Mark I and II BWRs. The four categories are: (i) site security; (ii) facility robustness; (iii) damage control; and (iv) emergency response planning. The degree of protection provided by these measures would be greatest if they were integrated into the design of a nuclear plant before its construction. However, a comprehensive set of measures could provide significant protection at the existing Mark I and II BWRs.

26 Walters, 2003.

27 Thircitation is voluntarily withheld by the Petitioners.

Petition T&Address Structural Vulnerabilitiesof MarkI & IIBWRs and Their IrradiatedFuel August 2004 Page 17 Site Security Site-security measures are those that reduce the potential for implementation of destructive acts of malice or insanity at a nuclear site. Two types of measure fall into this category. Measures of the first type would be implemented at offsite locations, and the implementing agencies might have no direct connection with the site. Airline or airport security measures are examples of measures in this category. Measures of the second type would be implemented at or-near the site. Implementing agencies would include the licensee, the NRC and other entities (e.g., National Guard).

The physical protection measures now required by the NRC, as discussed in Section 4, above, are examples of site-security measures of the second type. More stringent measures of this type could be introduced for consideration in the public debate and development of compensatory security measures, such as:

(i) establishment of a mandatory aircraft-exclusion boundary around the site; (ii) deployment of an aircraft-detection system (e.g., Sentinel) that triggers a succession of security alerts as the exclusion boundary is approached and crossed; (iii) deployment of an automated system (e.g., Phalanx) to destroy aircraft at short range if they are closing on the plant; (iv) expansion of the DBT, beyond that now applicable to a nuclear power plant, to include additional intruders, heavy weapons, aircraft attack, lethal chemical weapons and more than one vehicle bomb; and (v) any ISFSI on the site to receive protection equivalent to that provided for a nuclear power plant.

FacilityRobustness Facility-robustness measures are those that improve the ability of a nuclear facility to experience destructive acts of malice or insanity without a significant release of radioactive material to the environment. In illustration, the PIUS reactor design, developed by the reactor vendor ASEA-Atom but never built, was intended to withstand aerial bombardment by 1,000-pound bombs without suffering core damage or releasing a significant amount of radioactive material to the environment. 2s A new reactor or ISFSI could be constructed with a similar degree of robustness.

At the existing Mark I and II BWRs, a variety of opportunities are available for enhancing robustness. As a high-priority example, spent-fuel pools could be re-equipped with low-density racks, so that irradiated fuel would not ignite if water were lost from a pool. As a second example, the reactor could be permanently shut down or could operate at reduced power, either permanently or at times of alert. If the reactor were shut down, its irradiated fuel could be transferred to an onsite ISFSI that employs hardened, dispersed, dry storage. Figure 1, below, shows a possible design for hardening of the storage 28 Hannerz, 1983.

Petition To Address Structural Vidnerabiitfiesof Mark I & HI BWRs and Their IrradiatedFuel August 2004 Page 18 modules used in such an ISFSI. To reduce the inventory in the pool, irradiated fuel could be.transferred to an onsite ISFSI that employs hardened, dispersed, dry storage.

PetitionTo Address Structural Vulnerabilitiesof Mark I & II BWRs and Their IrradiatedFuel August 2004 Page 19 Figure 1 Schematic View of a Possible Design for Hardened, Dry Storage of Irradiated Fuel29 A......

Z  :  :  :  :  :  :

/d,::,:,:

A...'. .......

A::::::::::::,:::::::

A:  :,:,:-.:-:  :, ,:  :,:  :::,

A:-::  :-:  :-.::: .-:.U

{:-:',:-:^:  :-:'--:,:, -:', - if1 Ground oPadete Pad Notes (i) An ISFSI could employ a number of hardened storage modules in a dispersed configuration.

(ii) Cooling channels would be inclined, to prevent pooling ofjet fuel, and would be configured to preclude line-of-sight access to the dry-storage module.

(iii) The tube, cap and pad surrounding the dry-storage module would be tied together with steel rods, and spacer blocks would prevent the module from moving inside the tube.

(iv) The steel/concrete tube could be buttressed by several triangular panels connecting the tube and the base pad.

29 Adapfed from Figure 2 of: Thompson, 2003.

Petition To Address StructuralVulnerabilitiesofMark I & HI BWRs andTheir IrradiatedFuel August 2004 Page20 If the reactor were not shut down, robustness of the plant could be enhanced by an integrated set of measures such as:

(i) automated shutdown of the reactor upon initiation of a specified alert status at the plant, with provision for completion of the automated shutdown -quence if the control room is disabled; (ii) permanent deployment of diesel-driven pumps and pre-engineered piping to be available to provide emergency water supply to th. reactor and the irradiated fuel pool; (iii) re-equipment of the irradiated fuel pool with low-density racks, excess fuel being stored in an onsite ISFSI; and (iv) construction of the ISFSI to employ hardened, dispersed, dry storage.

Damage Control Darnagecontmo measures are those that reduce tie potential for a release of radioactive material following damage to a facility by destructive acts of malice or insanity.

Measures of this kind could be ad hoc or pre-engineered. One illustration of a damage-control measure would be a set of arrangements for patching and restoring water to an irradiated fuel pool that has been breached. Other illustrations can be provided. It appears that the NRC has required licensees to undertake some planning for damage control following explosions or fires.30 Additional measures could be appropriate, including:

(i) establishment of a pre-planned damage-control capability at the site, using onsite personnel and equipment for first response and offsite resources for backup; (ii) periodic exercises of damage-control capability; (iii) establishment of a set of damage-control objectives - to include patching and restoring water to a breached spent fuel pool, fire suppression at any ISFSI on the site, and provision of cooling to a reactor whose support systems and control room are disabled - with accompanying detailed plans; and (iv) provision of equipment and training to allow damage control to proceed on a radioactively-contaminated site.

30 Meseirve, 2002b.

Tetition To Address StructuralVulnerabilitiesof MarkI& IlBWRs and Their IrradiatedFuel August 2004 Page 21 Offsite Emergency Response Emergency-response measures are those that reduce the potential for exposure of offsite populations to radiation, following a release of radioactive material from a nuclear facility.

Measures in this category could accommodate releases attributable to acts of malice or insanity, or "accidental" releases arising from human error, equipment failure or natural forces (e.g., earthquake). However, there are two major ways in which malice- or insanity-induced releases might differ from accidental releases. First, a malice- or insanity-induced release might be larger and begin earlier than an accidental release. 3 Second, a malice- or insanity-induced release might be accompanied by deliberate degradation of emergency response capabilities (e.g., the attacking group might block an evacuation route). Accommodating these differences could require additional measures of emergency response.

Overall, an appropriate way to improve emergency-response capability at a nuclear-power-plant site could be to implement a model emergency response plan that was developed by a team based at Clark University in Massachusetts. 3 2 This model plan was specifically designed to accommodate radioactive releases from spent-fuel-storage facilities, as well as from reactors. That provision, and other features of the plan, would provide a capability to accommodate both accidental releases and malice- or insanity-induced releases. Major features of the model plan include: 33 (i) structured objectives; (ii) improved flexibility and resilience, with a richer flow of information; (iii) precautionary initiation of response, with State authorities having an independent capability to identify conditions calling for a precautionary response 34; (iv) criteria for long-term protective actions; (v) three planning zones, with the outer zone extending to any distance necessary35 ;

(vi) improved structure for accident classification; (vii) increased State capabilities and power; (viii) enhanced role for local governments; (ix) improved capabilities for radiation monitoring, plume tracking and dose projection; 31 Present plans for emergency response do not account for the potential for a large release of radioactive material from spent fuel, as would occur during a pool fire. The underlying assumption is that a release of this kind is very unlikely. That assumption cannot be sustained in the present threat environment.

32 Golding et al, 1992.

33 ibid, pp 8-13.

34 A security alert could be a condition calling for a precautionary response.

35 The inner and intermediate zones would have radii of 5 and 25 miles, respectively. As an example of the planning measures in each zone, potassium iodide would be predistributed within the 25-mile zone and made generally accessible nationwide.

Petition ToAddress Structural VulnerabilitiesofMark I& IIBWRs and Their IrradiatedFuel August 2004 Page 22 (x) improved medical response; (xi) enhanced capability for information exchange; (xii) more emphasis on drills, exercises and training; (xiii) improved public education and involvement; and (xiv) requirement that emergency preparedness be regarded as a safety system equivalent to in-plant systems.

8. The Public Should be Involved in Addressing the Structural Vulnerabilities of iteactor Containments and Irradiated Fuel Determining the general type and level of defense to be provided at a commercial nuclear facility should be a matter for open, democratic debate. This matter is, albeit at a smaller scale, analogous to determining the type and level of defense for the nation. Experience shows clearly that an open, democratic debate on national defense is necessary to preserve the Republic and provide an effective, cost-efficient defense.

When defenses are being developed for a particular nuclear facility, some details of the defenses will not be appropriate for general distribution. However, designated representatives of local and state governments and citizen groups should be allowed access to these details, to ensure that defenses are deployed according to the general plan that has been approved through open, democratic debate. NRC regulations already contain provisions whereby, in the context of nuclear-licensing proceedings, intervenors' designated representatives can have access to safeguards information.

9. Actions Sought by this Petition The Petitioners request that the NRC takes the following actions:

(i) issue a Demand For Information to the licensees for all Mark I and II BWRs and conduct a 6-month study of options for addressing structural vulnerabilites; (ii) present the findings of the study at a national conference attended by all interested stakeholders, providing for transcribed comments and questions; (iii) develop a comprehensive plan that accounts for stakeholder concerns and addresses structural vulnerabilities of all Mark I and II BWRs within a 12-month period; (iv) issue Orders to the licensees for all Mark I and II BWRs compelling incorporation of a comprehensive set of protective measures; and (v) make future operation of each Mark I and II BWR contingent on addressing their structural vulnerability with participation and oversight by a panel of local stakeholders.

The Demand For Information will require the licensees to provide answers to the following questions:

Petition To Address Structural VulnerabilitiesofMark I & lIBWRs and Their IrradiatedFuel August 2004 Page 23

1. What is the current licensed capacity and inventory for spent fuel assembly storage in the spent fuel pool?

2. What is the projected number of spent fuel assemblies to be discharged from the reactor core in the next five and ten years?

3. What is the calculated decay heat load on the spent fuel pool from the current inventory and licensed capacity of spent fuel assemblies?

4. What is the calculated decay heat load on the spent fuel pool from the inventory of spent fuel assemblies projected to be discharged from the reactor core in the next five and ten years?

5. What is the radionuclide inventory of the spent fuel pool at its design basis loading?

6. What is the water volume of the spent fuel pool?

7. What is the design heat removal capacity of the spent fuel pool cooling system?

8. Is the facility licensed for onsite dry storage of spent fuel? If so, how many spent fuel assemblies are currently in dry storage?

9. What are the spent fuel pool water makeup capabilities (sources and flow rates)?

10. What are the results from studies, evaluations, and/or analyses conducted on the vulnerability of the spent fuel pool to (a) aircraft, (b) tornado-generated missiles, and (c) fires?

Petition To Address Structural Vulnerabilities of MarkI & HIBWRs and Their IrradiatedFuel August 2004 Page24 11.

10. Bibliography (Alvarez et al, 2003)

Robert Alvarez and seven other authors, "Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States", Science and Global Securit, 11:1-51, 2003.

(baker, Cutler et al, 2001)

Howard Baker and Lloyd Cutler (co-chairs, Russia Task Force) et al, A Report Card on the Department of Energy's Nonproliferation Programs with Russia (Washington, DC:

Secretary of Energy Advisory Board, US Department of Energy, 10 January 2001).

(Brian, 2003)

Danielle Brian, Executive Director, Project on Government Oversight, speech to the NRC's Regulatory Information Conference, 16 April 2003, available at

<http://www.pogo.org/p/environment/et-03040 -nuclear.html>, accessed 24 May 2003.

(Chapin et al, 2002)

Douglas M. Chapin et al, "Nuclear Power Plants and Their Fuel as Terrorist Targets",

Science, Volume 297,20 September 2002, pp 1997-1999.

(Collins et al, 2000)

Timothy Collins et al, Technical Study of Spent Fuel Pool Accident Risk at Deco missini Nuclear PowerfPants (Washington, DC: US Nuclear Regulatory Commission, October 2000).

(Deller, 2002)

Nicole Deller, "Rule of Power or Rule of Law?", Science for Democratic Action Volume 10, Number 4, August 2002.

(Dillingham, 2003)

Gerald L. Dillingham, US General Accounting Office, Testimony before the Committee on Commerce, Science and Transportation, US Senate, Aviation Security: Progress Since September 11, 2001, and the Challenges Ahead, 9 September 2003.

(DOE, 2002)

US Department of Energy, Final Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain. Nye County, Nevada. DOE/EIS-0250F (Washington, DC: DOE, February 2002).

Petition To Address Structural Vulnerabilitiesof MarkI & II BWRs and Their IrradiatedFuel August 2004 Page25 (Ewing and Macfarlane, 2002)

Rodney C. Ewing and Allison Macfarlane, "Yucca Mountain", Science, Volume 296, 26 April 2002, pp 659-660.

(Ford, 1982)

Daniel Ford, Cult of the Atom (New York, New York: Simon and Schuster, 1982).

(Pale and Husick, 2003)

Stephen Gale and Lawrence Husick, "From MAD (Mutual Assured Destruction) to MUD (Mutual Unconstrained Disruption): Dealing with the New Terrorism", Foreign Policy Research Institute Wire, Volume 11, Number 1, February 2003.

(Goff, 2003)

Stanley A Goff, reftloyed Radiological W e Reducing the targdability of Shearon Harris Nuclear Plant and the risk to the North Carolina public (Durham, North Carolina:

NC-WARN, I May 2003).

(Golding et al, 1992)

Dominic Golding et al, Managing Nuclear Accidents: A Model Emergency Response Plan for Power Plants and Commnunities (Boulder, Colorado: Westview Press, 1992).

(Hannerz, 1983)

K. Hannerz, Tolwards Intrinsically Safe Light Water Reactors (Oak Ridge, Tennessee:

Institute for Energy Analysis, February 1983).

(Hart et al, 2002)

Gary Hart and Warren B. Rudman (co-chairs), Stephen E. Flynn (project director) and Task Force members, America Still Unprepared -- America Still in Danger: Report of an Ind~endent Task Force Sponsored by the Council on Foreign Relations (New York, NY:

Council on Foreign Relations, 25 October 2002).

(Hirsch et al, 2003)

Daniel Hirsch, David Lochbaum and Edwin Lyman, "The NRC's Dirty Little Secret",

Bulletin of the Atomic Scientists, May/June 2003, pp 45-51.

(Hutchings, 2004)

Robert L. Hutchings, Chairman, National Intelligence Council, speech to the International Security Management Association, 14 January 2004.

(Jones, 2002a)

David Jones, "Sandia says its study not proof of nuke plant durability" Inide Energy, 30 September 2002, page 14.

Petition To Address Structural Vulnerabilitiesof MarkI & IIBWRs and Their IrradiatedFuel August 2004 Page 26 (Jones, 2002b)

Gary Jones, Director, Natural Resources and Environment, US General Accounting Office, "Nuclear Waste: Uncertainties about the Yucca Mountain Repository Project",

testimony before the Subcommittee on Energy and Air Quality, House Committee on Energy and Commerce, 21 March 2002.

(Macfarlane, 2001 a)

Allison Macfarlane, "Interim Storage of Spent Fuel in the United States", Annual Review of Energy & Euvironment, Volume 26 (2001), pp 201-235.

(Macfarlane, 2001b)

Allison Macfarlane, "The problem of used nuclear fuel: lessons for interim solutions from a comparative cost analysis", EnergyPoliky, Volume 29 (2001), pp 1379-1389.

(Markey, 2002)

Staff of US Representative Edward Markey, "Security Gap: A Hard Look At the Soft Spots in Our Civilian Nuclear Reactor Security", 25 March 2002.

(Meserve, 2003)

NRC Chairman Richard Meserve, letter to Tom Ridge, Secretary of Homeland Security, 31 March 2003. Note: This letter, when downloaded from the NRC website (www.nrc.gov, accessed on 23 May 2003), was packaged with a letter of 5 September 2002 from Meserve to Ridge.

(Meserve, 2002a)

Richard A. Meserve, "Nuclear Security in a New World", The Industrial Physicist October/November 2002, pp 20-23.

(Meserve, 2002b)

NRC Chairman Richard Meserve, "Statement Submitted by the United States Nuclear Regulatory Commission to the Committee on Environment and Public Works, United States Senate, Concerning Nuclear Power Plant Security", 5 June 2002.

(MFP/UCS, 2003)

Mothers for Peace and Union of Concerned Scientists, Petition [to the NRC] for Rulemaking, 28 April 2003.

(NAC, 2001)

NAC Worldwide Consulting, US Spent Fuel Update: Year 2000 in Review (Atlanta, Georgia: NAC Worldwide Consulting, 2001).

Petition To Address Structural Vulnerabilities ofMarkl & IIBWRs andTheir IrradiatedFuel August 2004 Page 27 (NRC, 2003)

US Nuclear Regulatory Commission, "Briefing on the Status of Office of Research (RES)

Programs, Performance, and Plans", transcript of an open session of the Commission, Rockville, Maryland, 27 March 2003.

(NRC,;2002)

US Nuclear Regulatory Commission, Fact Sheet: Nuclear Security Enhancements Since Sept.11 2001 (Washington, DC: US Nuclear Regulatory Commission, undated, apparently September 2002).

(NRC, 1990)

US Nuclear Regulatory Commission, Severe Accident Risks: An Assessment for Five US Nuclear Power Plants, NUREG- 1150 (Washington, DC: US Nuclear Regulatory Commission, December 1990).

(Office of Homeland Security, 2002)

Office of Homeland Security, National Strategy for Homeland Security (Washington, DC:

The White House, July 2002).

(Okrent, 1981)

David Okrent, Nuclear Reactor Safety (Madison, Wisconsin: University of Wisconsin Press, 1981).

(Pew, 2004)

Pew Research Center for the People and the Press, A Year After Iraq War: Mistrust of America in Europe Ever Higher, Muslim Anger Persists (Washington, DC: Pew Research Center, 16 March 2004).

(Pew, 2003)

Pew Research Center for the People and the Press, Views of a Changing World 2003 (Washington, DC: Pew Research Center, 3 June 2003).

(POGO, 2002)

Project on Government Oversight, Nuclear Power Plant Security: Voices from Inside the Fences (Washington, DC: Project on Government Oversight, 12 September 2002).

(Purdue, 2002)

Purdue University, "Purdue News: New simulation shows 9/11 plane crash with scientific detail", 10 September 2002.

(Scarry, 2002)

Elaine Scarry, "A nuclear double standard", Boston SundayGlo 3 November 2002, page DI l.

Petition To Address Structural Vulnerabilities ofMarkI & II BWRs and Their IrradiatedFuel August 2004 Page28 (Sozen et al, 2002)

Mete A. Sozen et al, "September I I Pentagon Attack Simulations Using LS-Dyna: Phase I, Completed September 11, 2002", available at

<httpi/www.cs.purdue.edu/homes/cmh/simulation/>.

(Sprung et al, 2000)

J. L. Sprung et al, Reexamination of Spent Fuel Shipment Risk Estimates, NUREG/CR-M72 (Washington, DC: US Nuclear Regulatory Commission, March 2000).

(Thompson, 2003)

Gordon Thompson, Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Secuty (Cambridge, Massachusetts: Institute for Resource and Security Studies, January 2003).

(Thompson, 2002)

Gordon Thompson, Declaration of 7 September 2002 in support of a petition to the US Nuclear Regulatory Commission by Avila Valley Advisory Council et al, regarding nuclear-facility operations at the Diablo Canyon site.

(Thompson, 1999)

Gordon Thompson, Risks and Alternative Options Associated with Spent Fuel Storage at the Shearon Harris Nuclear Power Plant (Cambridge, Massachusetts: Institute for Resource and Security Studies, February 1999).

(Walters, 2003)

William Walters, "An Overview of the Shaped Charge Concept", paper presented at the 11th Annual ARL/USMA Technical Symposium, 5 and 7 November 2003. This symposium was sponsored by the Mathematical Sciences Center of Excellence at the US Military Academy (USMA) and hosted by the US Army Research Laboratory (ARL) and USMA.

(White House, 2003)

The White House, The National Strategy for The Physical Protection of Critical Infrastructures and Key Assets (Washington, DC: The White House. February 2003).

(White House, 2002)

The White House, The National Security Strategy of the United States of America (Washington, DC: The White House, September 2002).

Petition To Address StructuralVulnerabilitiesofMark I & I BWRs andTheir IrradiatedFuel August 2004 Page 29 U.S. Commercial Reactors with Elevated Irradiated Fuel Storage Ponds General Electric Boiling Water Reactor MARK I Containments (24 units)

Browns Ferry 1, 2 and 3 Decatur, AL Brunswick 1 & 2 Southport, NC Cooper Brownville, NB

&resden 2 & 3 Morris, IL Duane Arnold Palo, IA Edwin Hatch 1 & 2 Baxley, GA Fermi 2 Monroe, MI Hope Creek Artificial Island, NJ Fitzpatrick Scriba, NY Millstone 1 Waterford, CT Monticello Monticello, MN Nine Mile Point Unit 1 Scriba, NY Oyster Creek Lacey Township, NJ Peach Bottom 2 & 3 Delta, PA Pilgrim 1 Plymouth, MA Quad Cities 1 & 2 Cordova, IL Vermont Yankee Vernon, VT General Electric Boiling Water Reactor MARK II Containments (8 units)

LaSalle 1 & 2 Seneca, IL Limerick 1 & 2 Pottstown, PA Nine Mile Point Unit 2 Scriba, NY Susquehanna 1 & 2 Berwick, PA WNP-2 (Columbia) Richland, WA

Petition T o Address Structural Vulnerabilities of Mark I & I B WRs and Their IrradiatedFuel June 2004 Annex, Page 30 Petition Sign-On Groups To Date July 22, 2004 National Greenpeace Groups Institute for Resource and Security Studies Nuclear Information & Resource Service Public Citizen Union of Concerned Scientists LOCAL/ REGIONAL GROUPS REACTORS Alliance for Nuclear Accountability Columbia Generating Station Cape Downwinders Pilgrin Citizens Awareness Network Central New York chapter FitzPatrick Nine Mile Point 1 & 2 Connecticut chapter Millstone 1 Vermont chapter Vermont Yankee Massachusetts chapter Pilgrim I Vermont Yankee Citizens Campaign for the Environment FitzPatrick Millstone 1 Nine Mile Point 1 & 2 Citizens' Environmental Coalition FitzPatrick Nine Mile Point 1 & 2 Citizens' Regulatory Commission Millstone 1 Citizens Resistance Against Fermi 2 Fermi 2 Clean Water Action Pilgrim Coalition for a Nuclear Free Great Lakes Fermi 2 Coalition for Peace and Justice Hope Creek Don't Waste Michigan Fermi 2 Earth Care Duane Arnold EFMR Monitoring Group Peach Bottom 2 & 3 Environmental Coalition on Nuclear Limerick 1 & 2 Power Peach Bottom 2 & 3 Susquehanna 1 & 2 Finger Lakes Citizens for the FitzPatrick Environment Nine Mile Point 1 & 2 Georgians Against Nuclear Energy Hatch 1 & 2 Heart of America Northwest Columbia Generating Station Independent Environmental Duane Arnold Conservation & Activism Network Quad Cities 1 & 2 Justice Through Peace Initiative FitzPatrick Nine Mile Point 1 & 2

Per.10ci ToApdress Structural Vulnerabilities ofMarkI & IBWRs andTheir IrradiatedFuel June 2004 Annex, Page 31 Kids Against Pollution FitzPatrick Nine Mile Point 1 & 2 Lakeshore Environmental Action FitzPatrick Nine Mile Point 1 & 2 Massachusetts-Public Interest Research Pilgrim Group Nebraskans fot Peace Cooper New England Coalition Vermont Yankee New Jersey-Public Interest Research Hope Creek Group Oyster Creek New York-Public Interest Research FitzPatrick Group Nine Mile Point 1 & 2 North American Water Office Monticello North Carolina-Waste Awareness and Brunswick 1 & 2 Reduction Network Nuclear Energy Information Service Dresden 2 & 3 LaSalle 1 &'2 Quad Cities 1 & 2 Nuclear Free Vermont Vermont Yankee People's Environmental Network of FitzPatrick New York Nine Mile Point 1 & 2 Pilgrim Watch Pilgrim Plymouth County Nuclear Information Pilgrim Committee Southern Alliance for Clean Energy Browns Ferry 1, 2, & 3 Hatch 1 & 2 Syracuse Peace Council FitzPatrick Nine Mile Point 1 & 2 TMI Alert Peach Bottom 2 & 3 Susquehanna 1 & 2 UNPLUG Salem Campaign Hope Creek

rennon 1 OAaaressStructural Vulnerabilities ojMarki 1& I-B WRs andTheir IrradiatedFuel June 2004 Annex, Page 32 Map of U.S. Commercial Reactor Sites with Mark I and/or Mark H Boiling Water Reactors

rvuan il uurr.yss ourucwurat vumeraov"lles OJMattrcl & 11 BWXs and kuel alheirIrradiated June 2004 Annex, Page 33 Diagram of GE Mark I Reactor Building and Elevated Irradiated Fuel Storage Pond "Mark I and Mark 11secondary containments generally do not appear to have any significant structures that might reduce the likelihood of aircraft penetration, although a crash into I of 4 sides of a BWR secondary containment may be less likely to penetrate because other structures are in the way of the aircraft."

'Spent Fuel Pool Accident Risk Report," U.S. Nuclear Regulatory Contmission, October 2000, Page 3-23 Pressure suppression cooling pool (wetwell)