ML050250167

Comment (69) Submitted by Allan Gill on Petition for Rulemaking PRM 73-12, Upgrade the Design Basis Threat Regulations

ML050250167
Person / Time
Site:	Indian Point
Issue date:	01/19/2005
From:	Gill A - No Known Affiliation
To:	NRC/SECY
Ngbea E S
References
+adjud/ruledam200505, 69FR64690 00069, PRM-73-12
Download: ML050250167 (3)

Text

DOCKET N4UMBER -

PETrITON RULE P -73 fEZ.

From: Allan Gill <agill~hoovers.com> 65QbM i0) DOCKETED USNRC To: "'SECY@nrc.gov'" <SECY@nrc.gov>

Date: Wed, Jan 19, 2005 2:33 PM January 21, 2005 (10:35 am)

Subject:

NUCLEAR POWER INSECURITY OFFICE OF SECRETARY If a nuclear plant's containment shell and reactor core, or spent fuel RULEMAKINGS AND pools, are ever breached, a terrible explosion of radioactivity, on a par ADJUDICATIONS STAFF with the Chernobyl accident, would ensue. Millions of Americans would be placed in harm's way. Unfortunately, America's nuclear plants are highly vulnerable to attack. Fortunately, such a cataclysm is preventable. We ask for your support of a new petition before the Nuclear Regulatory Agency.

Harvard professor and Clinton Administration arms control expert, Graham Allison, soberly discusses the problem of nuclear power plant vulnerabilities:

The American Airlines flight that struck the North Tower of the World Trade Center could just as readily have hit the Indian Point nuclear power plant, forth miles north of Times Square .... The consequences of an attack on a nuclear plant would depend largely on where the plane hit. If the aircraft penetrated the containment dome, the attack could cause the reactor to melt down, releasing hundreds of millions of curies of radioactivity into the surrounding environment, hundreds of times that released by the Hiroshima and Nagasaki bombs. We already know what such an incident would look like.

In April 1986, an accident explosion inside the Soviet nuclear reactor at Chernobyl ignited a powerful fire that raged for ten days. The resulting radiation forced the evacuation and resettlement of over 350,000 people and caused an estimated $300 billion of economic damage, and is likely to lead ultimately to tens of thousands of excess cancer deaths among those exposed to the fallout.

An even more vulnerable target at a nuclear plant is the building that houses the spent fuel rods, which are stored in pools of water to prevent the heat from their residual radioactivity from melting them. Designed to remain intact in case of an earthquake, these structures are open to the air in some instances and housed in only light-duty buildings in others, which means that a plane attacking from above might drain the pool, destroy backup safety systems, and ignite the fuel. The resulting fire would spew radioactivity into the environment in amounts that could reach three or four Chemobyls.

Such threats are real possibilities. In November 1972, three Americans with pistols and hand grenades commandeered a Southern Airlines Flight 49, and ordered the plane to fly to Oak Ridge, Tennessee, and threatened to plow the plane into a reactor unless their ransom was met. And on February 7, 1993, a distraught intruder drove his station wagon onto Three Mile Island nuclear power station property, crashing through gates In the 'protected" area of the nuclear facility before wrecking the vehicle into the turbine building.

He evaded security for several hours before being arrested. Fortunately, he carried no explosives.

Last year, our friends at Committee to Bridge the Gap (CBG) filed a Petition for Rulemaking to the U.S. Nuclear Regulatory Commission (posted in the Federal Register on November 8, 2004, Volume 69, Number 215) for "Upgrading the Design Basis Threat Regulations for Protection Against Terrorist Attacks on Nuclear Reactors.'

The nuclear agency has now~opened the petition for public comment. The NRC needs to hear your concerns about vulnerabilities at America's nuclear power plants. -

The petition most crucially requests that NRC upgrade the Design Basis I empla -SFf-O 7 4:ifaq -CML

Threat (DBT) for U.S. nuclear power stations revising DBT regulations to require NRC and the nuclear power industry to contemplate and prepare for an attack of nuclear power stations by air by constructing shields consisting of (inexpensive and quick-to-assemble) steel I-beams and steel cabling to obstruct the angle of air attack at stand-off distances from the reactor building, fuel pool and other safety-related assets so that hijacked, rented or private aircraft (potentially carrying explosives) attempting to deliberately crash into a reactor site would be tom up in the 'Beamhengeu shield effectively reducing the impact and penetration force on safety-related structures. The shield effort is focused on reasonably reducing the public's risk of terrorists successfully using nuclear power stations for radiological-enhanced sabotage.

In 1998, at the behest of industry, NRC management zeroed out the budget for the OSRE program only to be restored through media exposure by an agency whistleblower, CBG, and action by President Clinton. However, the nuclear industry continued to stonewall security upgrades as unnecessarily sophisticated and overly expensive, culminating in a draft NRC policy to turn over security testing to an industry self assessment program to begin its pilot phase in September 2001.

In the aftermath of the September 11 attack, the Nuclear Regulatory Commission has attempted some reforms but they are far from protective. In September 2004, a Government Accountability Office (GAO) report concluded that NRC's new security initiatives were "largely a paper review." The NRC did not visit sites to verify compliance nor request facilities to submit documents that supported security upgrades. In fact, GAO concluded it will be at least three more years before NRC will have data to validate whether site-specific upgraded security plans are adequate.

Thank you.

Allan Gill Quality Editor (512) 374 4523 agill@hoovers.com Hoover's, Inc.

The Business Information Authoritysm (a D&B company) www.hoovers.com <www.hoovers.com>

The information contained in this communication is confidential. This communication is the property of Hoover's, Inc. and is intended only for the use of the addressee. If you are not the intended recipient, please notify me promptly and delete the message. Any distribution or copying of this message without my prior consent is prohibited.

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Subject:

NUCLEAR POWER INSECURITY Creation Date: Wed, Jan 19, 2005 2:32 PM From: Allan Gill <adil@hoovers.com>

Created By: agill @hoovers.com Recipients nrc.gov owf5.po.OWFNLDO SECY ('SECY@nrc.gov' SECY)

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