ML050310226
| ML050310226 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/24/2005 |
| From: | Runkle J Conservation Council of North Carolina |
| To: | NRC/SECY/RAS |
| Ngbea E S | |
| References | |
| +adjud/ruledam200505, 69FR64690 00198, PRM-73-12 | |
| Download: ML050310226 (3) | |
Text
- ECY - ATTN
- Rulemakings and Adjudications Staff, PRM-73-12 Paqe 11 DWCKE NUMOM DOCKETED "ohnRunle"<jrnkl @ indprb:ig Fro: 9) January 28, 2005 14, 2004 (4:45pmn)
To: <secy@ nrc.gov> OFFICE OF SECRETARY Date: Mon, Jan 24, 2005 4:19 PM RULEMAKINGS AND
Subject:
ATTN: Rulemakings and Adjudications Staff, PRM-73-12 ADJUDICATIONS STAFF Attached and inserted below, please find our comments:
CONSERVATION COUNCIL OF NORTH CAROLINA P.O. Box 12671 Raleigh, N.C. 27605 919-839-0006 January 20, 2005 VIA MAIL & EMAIL Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTN: Rulemakings and Adjudications Staff Re: Petition to Urgently Upgrade Nuclear Security Requirements, PRM-73-12
Dear Sir:
The Conservation Council of North Carolina supports the Petition for Rulemaking by the Committee to Bridge the Gap filed with the NRC on or about July 23, 2004, which was published in 69 Fed. Reg. 215 (November 8, 2004),
for "Upgrading the Design Basis Threat Regulations for Protection Against Terrorist Attacks on Nuclear Reactors."
The Conservation Council intervened in the licensing for several nuclear plants in the 1970's and 1980's. Inthe licensing of Carolina Power's Shearon Harris Nuclear Power Plant, we raised and litigated the issue of the ability of the plant's security plan to prevent the theft, compromise or dispersal of radioactive material. We continue to recognize the clear and compelling necessity to provide adequate safeguards from threats.
However, the rules have not substantially changed since then and the Design Basis Threat (DBT) does not reflect the current situation. The time is overdue for the NRC to completely reassess the risk from organized, well-armed and well-financed terrorists, and to upgrade the DBT to prepare for coordinated attacks from multiple assault teams, with insider knowledge and even insider assistance.
-Teimpkd&-e.~ceay-o&7 st&y-OP.
)ECY - ATTN: Rulemakings. and Acligications Staff, PRM-73-12 --Paae
- 22]I iECY-ATTN: Rurernakings and Adjudications Staff, PRM-73-12 -- - - I - .11-I-. - - 1 - --- --- . Paae Nuclear power plants should be at the top of our terrorists concerns as they have the potential for significant damage to the public inthe wrong hands.
A paper review by the NRIC is not enough; there must be strong rules and real inspections.
Please notify me at the address above of any action you take on this Petition.
Sincerely, John D. Runkle General Counsel
- \temp\GW)00001 .TMP 1:i Page 1 l
- \ternp\GWIOOOOi JMP Page Mail Envelope Properties (41F5666E.13E: 11: 8510)
Subject:
ATTN: Rulemakings and Adjudications Staff, PRM-73-12 Creation Date: Mon, Jan 24, 2005 4:19 PM From: "John Runkle" <jrunkle@mindspring.com>
Created By: jrunkle@mindspring.com Recipients nrc.gov owf5_po.OWFN_DO SECY (SECY)
Post Office Route owf5_po.OWFNDO nrc.gov Files Size *Date & Time MESSAGE 1944 Monday, January 24, 2005 4:19 PM comments to NRC re terror.wpd 4873 Mime.822 10302 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed
Subject:
]No Security: Standard