ML050310229

Comment (199) Submitted by Robert K. Musil, on Behalf of the Physicians for Social Responsibility, on Petition for Rulemaking PRM-73-12, Upgrade the Design Basis Threat Regulations

ML050310229
Person / Time
Site:	Indian Point, Oyster Creek, Diablo Canyon, San Onofre
Issue date:	01/24/2005
From:	Musil R Physicians for Social Responsibility, Washington, DC
To:	NRC/SECY/RAS
Ngbea E S
References
+adjud/ruledam200505, 69FR64690 00199, PRM-73-12
Download: ML050310229 (3)

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'1 s.IJUJ~JUI .l y II 1IllMV LU DI tl! d IJ I _ , Page 1 DoakDOCKETED USNRC From: "Martin Butcher" <mbutchergpsr.org> 64 January 28, 2005 14, 2004 (4:45pm)

To: <SECY nrc.gov> OFFICE OF SECRETARY Date: Mon, Jan 24, 2005 4:28 PM RULEMAKINGS AND

Subject:

Re: Support - Committee to Bridge the Gap petition ADJUDICATIONS STAFF January 24, 2005 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rule-making and Adjudication Staff Re: Support - Committee to Bridge the Gap petition

Dear Secretary,

I write on behalf of Physicians for Social Responsibility. Composed of over 30,000 medical professionals and supporters, we wish to express our deep concern about the possibility of terrorist events at the San Onofre and Diablo Canyon nuclear reactors, and the public health catastrophe that would ensue.

Two enormous vulnerabilities must quickly be addressed.

1. Spent fuel pools are vulnerable to land and air attack. For example, an excess of 2,500 tons of highly radioactive spent fuel assemblies reside at California's nuclear reactor sites. The buildings that house spent fuel rods are designed to remain Intact in case of an earthquake, but no provide no other security. At the Oyster Creek nuclear reactor site in New Jersey waste is stored in an unhardened waste pool built seven stories high above ground.

A strike in the waste pools at the Indian Point reactor in New York State could contaminate the metropolitan New York area, putting millions of people at risk of contamination, death, cancers and other conditions.The structures are typically light-duty. An airplane collision or coordinated land attack could drain the pools, destroy backup safety systems, and ignite the fuel.

The resulting fire would spew radioactivity into the environment in amounts in excess of the Chernobyl accident.

2. Spent fuel pools and operating reactors are acutely vulnerable to air attack. The appalling September 11th attack employed multiple airplanes focused on a single target. The containment vessels at all operating nuclear power plants should therefore be analyzed for withstanding the impact of multiple jumbo jetliners striking the same area of a containment dome. If the containment vessel or reactor core is breached and/or the plant's pumps and cooling systems are ever compromised, it could result in a Chernobyl-like accident - and could similarly lead to tens of thousands of cancer deaths.

Nuclear terrorism is not some radical far-fetched notion, but a terrible possibility. In the aftermath of the first World Trade Tower attack in 1992, police discovered in-depth plans to attack nuclear power facilities.

Further, Graham Allison, director of Harvard's Belfer Center for Science and International Affairs, writes in the best-seller, "Nuclear Terrorism," that "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 plants

-renr&4,- SECY-7 SLAM

The Committee to Bridge the Gap petition offers constructive ideas on thwarting the two outstanding vulnerabilities at America's nuclear power plants. Inexpensive steel I-beams and cabling could obstruct an air attack.

And improving the Design Basis Threat to thwart a 9/1 1 type attack is surely reasonable.

If the NRC's cares about public health and sound science, we are confident that the commission will swiftly enact the petition.

Cordially Yours, Robert K. Musil Ph.D. MPH Executive Director and CEO, Physicians for Social Responsibility 1875 Connecticut Ave NW #101 2 Washington DC 20009 Tel: 202-667-4260 Fax: 202-667-4201 CC: CC:

<bmusil~psr.org>

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Re: Support - Committee to Bridge the Gap petition Creation Date: Mon, Jan 24, 2005 4:26 PM From: "Martin Butcher" <mbutcher@psr.org>

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