ML051170034

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Letter of Paul Gunter on Behalf of the Nuclear Security Coalition Submitting Additional Documents as Supplemental Material to the Emergency Enforcement Petition (10 CFR 2.206) of August 10, 2004
ML051170034
Person / Time
Site: Oyster Creek
Issue date: 04/12/2005
From: Gunter P
Nuclear Information & Resource Service (NIRS)
To: Tam P
Office of Nuclear Reactor Regulation
References
+KBR1SISP20050602
Download: ML051170034 (18)


Text

Nuclear information and Resource Service 1424 16th St. NW, Suite 404, Washington, DC 20036; 202-328-0002; Fax: 202-462-2183; E-mail: nirsnet@nirs.org; Web: www.nirs.org April 12, 2005 Peter Tam Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Tam:

On behalf of the Nuclear Security Coalition, I am enclosing additional documents as supplemental material to the emergency enforcement petition (10 CFR 2.206) of August 10, 2004 which regards the vulnerability of the elevated General Electric Mark I & II irradiated fuel pools.

The attachments contain calculations prepared by Stephen Lazorchak, P.E., who formerly worked as a structural engineer at Oyster Creek nuclear generating station, the first GE Boiling Water Reactor Mark I in the United States. Mr. Lazorchak's calculations indicate that a 1000 lb. object moving at 300 mph striking the refueling deck floor of a Mark I at a 300 angle exceeds the Reactor Building's strongest floor beam capacity at Elevation 119' by more than 500% and the weakest beam capacity by 8000%.

Additional attachments include letters from Mr. Lazorchak to NORAD/USNORTHCOM expressing his professional concern about the vulnerability of the supporting structures around the Mark I refueling deck and "spent" fuel pool.

Thiyou, Paul Gunter, Director Reactor Watchdog Project Attachments:

1) Calculation-Demonstrating Structural Vulnerability of Oyster Creek's Reactor Building Refueling Floor at Elevation 119'3", Steven M. Lazorchak, P.E.,

Consulting Structural Engineer (11 pages)

2) Letter from S. Lazorchak to Admiral Keating (NORAD/USNORTHCOM),

f regarding Oyster Creek Nuclear Station- Structural Vulnerability to Terrorist Attack, Lacey Township, NJ dated February 7, 2005 (3 pages)

£4 oee. c e Z o7 printed on recycled paper dedicated to a sound non-nuclear energy policy. A-f

3) Letter from S. Lazorchak to Admiral Keating/(NORAD/USNORTHCOM),

regarding Oyster Creek Nuclear Station- Structural Vulnerability to Terrorist Attack, Lacey Township, NJ, dated February 10, 2005 (2 pages)

Cc:

Roy Zimmerman, NSIR Glenn Tracey, NSIR

- Structural Vulnerability of Oyster Creek's RxBldg Sheet 1 of 11 Calculation Demonstrating Structural Vulernability of Oyster Creek's Reactor Building Refueling Floor at elevation 119'-3" (11 sheets)

Prepared by:

Stephen M. Lazorchak, PE Consulting Structural Engineer 20 Dorchester Drive Toms River, New Jersey 08753 Phone/fax 732-255-1972 (Past employee of GPU Nuclear/Oyster Creek)

I

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RxB~dg Floor Elev. 119 OysterCreek.mcd Stephen M. Lazorchak, PE 3/30/2005 Page 1 Consulting Structural Engineer

  • Structural Vulnerability of Oyster Creek's RxBldg Sheet 2 of 1 1 1.0 PROBLEM STATEMENT:

A sensitivity analysis to determine the affect of aircraft impact on Oyster Creek's Reactor Building, floor elevation 119'. Assume the largest rigid object striking the floor weighs 1000-pounds and is traveling at 300-mph.

2.0

SUMMARY

OF RESULTS:

A 1000-pound aircraft component, traveling at 300-mph, striking the floor at a 30-degree angle, exceeds the Reactor Building's strongest floor beam's capacity, at 119' elevation, by more than 500% and exceeds the weakest beam capacity by 8000%. This analysis indicates a large aircraft will likely penetrate the building's top floor, allowing burning jet fuel to leak down onto vital Reactor shutdown wiring and equipment. The the analysis neglects the weight of the impacting aircraft and collapsing roof steel onto the floor system around the spent fuel pool. There is a very high probability the spent fuel pool will be severely damaged, causing a leak that will, uncover several hundred tons of radioactive fuel rods.

3.0 REFERENCES

3.1 EQE Calculation No. 240012-C-003, Oyster Creek Load Drop Analysis, Structural Capacities of Beams and Slabs at El. 119'-3"

4.0 ASSUMPTIONS

4.1 A large aircraft will impact Oyster Creek's Reactor Building roof at an angle of 30-degrees from horizontal, traveling at 300-mph at time of impact.

4.2 The evaluation will determine the effect of a 1000-pound component from an aircraft hitting the concrete floor slab at elevation 119'. The energy of the impact will be compared to the calculated beam/floor capacities from Reference 3.1.

5.0 DESIGN INPUT:

5.1 Weight of aircraft component Wcomponent : 1000 Ibf 5.2 Velocity of component at impact Vcomponent := 300.mph Vcomponent 440 ft sec 5.3 Acceleration of gravity g = 32.17 2 sec 2

5.4 The maximum beam capacity from SE 2397ft lbf Ref. 3.1, Sheet B21, Beam 5B19 Beaxn.5B19 :3976

& Sheet 835, Beam 5B39 SEBeam5B39 : 18129. ft. M

6.0 CALCULATION

Determine the impact energy of a 1000-pound mass, traveling at 300-mph, hitting a floor system at a 30-degree angle from horizontal (using mass=weight/acceration of gravity and KE=1/2mV 2 ).

ImPactEnerg = (

I fWcomponent) p t) ]~component 2

ImpactEnergy = 3008636 ft. Ibf RxBldg Floor Elev. 119 OysterCreek.mcd Stephen M. Lazorchak, PE 3/30/2005 Page 2 Consulting Structural Engineer

-Structural Vulnerability of Oyster Creek's RxBldg Sheet 3 of 11 Determine the vertical and horizontal components from the 1000-pound object hitting a rigid floor at an angle 30-degrees from horizontal.

Impact angle 0 := 30deg Verticallmpact.Energy:= (ImpactEnergy)-sin(0) Verticalimpact.Energy = 1504318 ft Mbf Horizontallmpact.Energy:= (ImpactEnergy) cos(0) Horizontallmpact.Energy = 2605555 ft Ibf Determine the order of magnitude that a 1000-pound object, traveling at 300-mph, will exceed the capacity of the strongest beam in the Reactor Building's floor at elevation 119'.

Verticalimpact.Energy = 1504317.99 f Mbf SEBeam.5B19 = 239769ftrlbf Therefore, a 1000-pound object traveling at 300-mph, striking the floor at a 30-degree Verticalhmpact.Energy - SEBeam.5B19 5.27 angle, will hit with a vertical force, that exceeds SEBeam.SBI9 the strongest floor beam capacity by more than 500%. This evaluation neglects the weight of the impacting aircraft and collapsing structural steel roof and overhead bridge crane.

SEBea5.5B39 = 18129fi-lbf Therefore, a 1000-pound object traveling at 300-mph, striking the floor at a 30-degree VerticalImpact.Energy - SEBeam.5B39 81.98 angle, will hit with a vertical force, that exceeds SEBeam5.B39 the weakest floor beam capacity by more than 8000%. This evaluation neglects the weight of the impacting aircraft and collapsing structural steel roof and overhead bridge crane.

/

I f RxBldg Floor Elev. 119 OysterCreek.mcd Stephen M. Lazorchak, PE 3/30/2005 Page 3 Consulting Structural Engineer

OYSTER CREIK REACTOR BUILDING ISSTRUCTURALLY OBSOLETE AND NOT ABLE TO PROTECI NUCLEAR FUEL RODS FROM A TERRORIST AIRCRAFr ATIACK THE PLANT ISNEITIHER STRUCTURALLY ROBUST OR DESIGNED TO RESIST .

AN AIRCRAFT IMPACT STEEL ROOF TRUSSES SUPPORTING A SHEET METAL ROOF DECK EXTERIOR WALLS OF SHEET METAL SIDING SUPPORTED ON HORIZOTFAL STEEL CHANNELS AND STEEL COLUMNS FLOO

)J POOL The impact of a large aircraft into the Reactor Buliding's concrete floor at elevation 119'-30 will

[RODS lcause catastrophic building faiure allowing burning fuel to leak down onto the floors below, Cdamaging vital wiring and equipment needed to shut down the reactor. An aircraft impact will VESSEL severely damage the spent fuel pool causing awater leak that will uncover tons of radioactive fuel rods. The result of aterrorist attack on Oyster Creeks Reactor Building will exceed a Chemobyl meltdown event because there ismore spent fuel inOyster Creek's fuel pool than there was InChernobyl's reactor.

FLOOR DRYWELI 5 li i The impact energy from only one 1,000 pound object traveling at 300 mph and hItting the floor UL,,, \,at an angle of 30 degrees above horizontal exceeds the strongest floor beam capacity by more Ul1-Ithan 500%. Impacting the weakest floor beam exceeds the beam's capacity by more than

-f[ /8,000%. The order of magnitude of these values clearly demonstrates Oyster Creek's Reactor r)T1 Building Isan unacceptable safety risk to New Jersey.

The floor beam strengths are from Oyster Creek Calculation No. 240012.C-003, Load Drop Analysis Structural papacitles of Beams and Slabs at El. 11Y9-3, page B21 and page B35.

The energy of the 1,000 pound aircraft component isdetermined from the Kinetic Energy CROSS SECTON Equation (1/2mvA2), while neglecting the larger consequences from the impacting aircraft and CeRrOS Srrvso no toorso collapsing roof steel.

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Table of Contents 1.0 11IM ODUCTION .................................. ,3 2.0 bEHOD .................. 4 2.1 BEAMS ......... 5 2.2 SLABS ................ _ 12 3.0 ASSUMPTIONS ._  ; 17 3.1 BEAMS ...... _ 18 3.2 SLABS ................................ _ 24 4.0 RESULTS .. 29 4.1 DISCUSSION OF BEAM RESULTS.29 4.2 DISCUSSION OF SLAB RESULTS ................................ .. 29 S.Q REFERENCES . . . . 32 ATTACHMENT A: DERIVAONS .................. Al A.l EXTERNAL VS. WINTERNAL WORKIFORBEAS . ........................................... A2 A.2 INTERNAL WORK EQUATION FOR SLABS . . A3 A.3 EXTERNAL VS. INTERNAL WORK FOR SLABS ........................................ ... A4 ATTACMENT B: BEAM CALCULATIONS ............................................. BI B.1 EXAMPLE BEAM CALCULATION . . .B2 B.2 BEAM WORKSHEETS . ... B7 ATTACHMENT C: SLAB CALCULATIONS. . . C C.1 EXAMPLE SLAB CALCULATION . . .C2 C.2 SLAB WORKSHEETS . . .C6 ATIACMENT D: CHECKING CRITRIA CHECKLIST . . .Dl

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'-I1 1 -&yI U9:1 V: 1 4 1-.6Yf /2, 1.0 INTIODUCTION The purpose of calculation 240012-C-003 is to determine the strain energy available in the beam and slab systems which make up the floor at eL 119'-3" of the Oyster Creek Station Unit #1. A plastic analysis of te beams and slabs will be conducted.

and three values per member will be produced. These are:

1. Ultimate Load (Pin): The ultimate point load at midspan required to form a collapse mechanism.
2. Ultimate Strain Energy (SE): The ultimate Strain Energy available given the prescribed ductility and binge rotation limits.
3. Shear Demand Capadity Ratio (V DCR): The ultimate shear demand coresponding to the flexural capacity compared to the reduced ultimate shear capacity as dictated by ACI 318-95 [Ref. 2]. This ratio will be limited to .83 to assure that the member has 20% more capacity in shear than in flexure.

This Strain Energy Demand is assumed to be caused by an impact resulting from an accidental load drop and is calculated separately.

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2.0 METHOD 2.0 Introduction Plastic analysis methods were used to calculate the ultimate flexural capacity of the beam and slab systems in accordance with EQE Procedure 240012-P-001.

In general, the beams were modeled assuming fixed support conditions. The load which causes the beam to become a collapse mechanism was then calculated. Since this load is assumed to occur at midspan of the beam, a lower bound ultimate load will result.

A "collapse mechanism" is the point at which hinges form at the ends and at midspan of the beam resulting in flexural failure of the system. These plastic hinges occur when the ultimate moment capacity of a given section is reached. In this calculation, the ultimate moment capacity of a section is the allowable nominal moment capacity as calculated in accordance with ACI 318-95 (Ref. 2]. The ultimate load, P=,.was calculated through the work energy method described in section 2.1. A limiting deflection was then calculated based on limited rotational capacities of the beam sections ( Pan is then multiplied by Prm).

the Ar to attain the ultimate strain energy (SE), also referred to as External Work (W.),

required to form the collapse mechanism, thus fail the system in flexure.

( The plastic analysis for the slab is based on the same principles as that for the beam. However, instead of forming 3 hinges, a series of hinged creases, or yield lines are formed. These yield lines are dictated by an end deflected shape which is assumed based on application of the load to the center of the slab. The slab is assumed to be fixed on all sides. Based on reinforcement properties of the slab, moment capacities are calculated at each yield line. These capacities are used to calculate the internal work required to yield the system. The internal work is then used to back out the ultimate load (P&m) to yield the system. The rest of the process (calculation of Al. and SE) is the same as for the beam.

This section is comprised of:

2.1 Summary and explanation of the plastic analysis process for a beam.

2.2 Summary and explanation of the plastic analysis process for a slab.

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II Stephen M. Lazorchak, P.E.

Consulting Structural Engineer 20 Dorchester Drive Toms River, New Jersey 08753 (732) 255-1972 fax (732) 255-1972 February 7, 2005 Admiral Timothy J. Keating c oo NORA D/USNORTHCOM 250 Vandenberg, Ste. B-016 Peterson AFB, CO 80914-3808 Re: Oyster Creek Nuclear Station - Structural VulnerabilitY to Terrorist Attack Lacev Township, NJ

Dear Admiral Keating:

On Friday February 4, 2005, two planes landed without incident at John F. Kennedy International Airport, New York, after authorities received reports that Delta Fight 119 from Paris and Delta Flight 81 from Amsterdam, Netherlands had been threatened. Both planes landed about 1330 and were momentarily held back from the gate. One news report stated Flight 119 was escorted by F16 fighters. Lt. Cmdr. Sean Kelly said NORAD did not send escort jets, "the situation didn't warrant it."

This incident prompted me to write you because NORAD/USNORTHCOM may not be aware of the structural vulnerabilities in Oyster Creek's Reactor Building, located approximately 60 miles south of JFK International AirpQrt. Oyster Creek is one 22 nuclear power plant sites (affecting approximately 30,000 Megawatts of generation) with an obsolete boiling water reactor building design.

Oyster Creek's Reactor Building Design:

Oyster Creek's Reactor Building is a square building that can be easily seen from Route 9. The building's ground floor is at elevation 35'-0", the, highest floor level is at elevation 119'-3" (typically known as the refueling floor). Below elevation 119', the Reactor Building is a concrete structure, above elevation 119' is steel framing about 50' high, supporting steel roof trusses. The whole steel framing system is covered with sheet metal siding.

The Reactor Building refueling floor is a large open space. During plant operation, one could walk over to the spent fuel pool, look down, and see several hundred tons of used radioactive fuel rods stored under 30-feet of water. The metal buildiyg enclosure above the spent fuel pool is 2005 Feb 7-NORAD Page Iof 3

d Oyster Creek Nuclear Station not robust, nor will it prevent a terrorist aircraft from impacting into the pool or onto the Reactor Building refueling floor.

The NRC's basic policy on the protection of nuclear facilities is laid down in regulation 10 CFR 50.13. Essentially, regulation limits the licensee's responsibility for defending a nuclear facility.

Any gap in the licensee's capabilities to defend against a kamikaze assault using a large aircraft, are assumed to be provided by the Government. The NRC is not required to notify other government agencies about nuclear power plant vulnerabilities that may affect national security.

In August 2004, NRC Chairman Diaz was provided Oyster Creek's reference to the Reactor Building load drop calculation at floor elevation 119'-3". Using the calculation, it can be demonstrated an aircraft impacting the reactor building refueling floor will pass through it, critically damaging the spent fuel pool ......... resulting in a Chernobyl event.

The National Academy of Science, Board on Radioactive Waste Management prepared a confidential Committee report on the "Safety and Security of Commercial Spent Fuel Storage" (Project No. BRWM-U-03-05-A). The report was issued to the Congress, the Nuclear Regulatory Commission, and the Department of Homeland Security, in July 2004.

On Dec. 2, 2004, NRC Chairman Diaz spoke before the Nuclear Security Executive Forum and stated in his closing remarks; "I would be remiss if I did not addressfurther the issue that makes the most headlines: the intentional crash of an aircraft on a nuclear power plant. The NRC has conducted extensive analyses of the capability of representative nuclearpower plants to withstand an aircraftattack.

While these analyses are classified, the studies confirm that the likelihood of damaging the reactorcore and releasingradioactivitythat could affect public health and safety is low. "

Based on the Chairman's remarks, it appears the report on "Safety and Security of Commercial Spent Fuel Storage" neglects a reactor building design like Oyster Creek, or it significantly over estimates a reactor building's structural capacity to resist aircraft impact. The BRWM Committee reviewed my evaluation of Oyster Creek's refueling floor, but I don't know if they will amend the classified report.

Oyster Creek's sheet metal covered superstructure, located over the spent fuel pool, is not designed for aircraft impact. The World Trade Center towers were designed for the impact by a Boeing 707 jetliner, but not the burning fuel after the crash. A much larger Boeing 767 hit the WTC towers, the 767 is 225% heavier than the 707. From a structural engineering viewpoint, Oyster Creek's Reactor Building is significantly weaker than the WTC towers.

The impact energy from only one 1,000 pound object traveling at 300 mph and hitting Oyster Creek's refueling floor at an angle of 30 degrees above horizontal, exceeds the strongest floor beam capacity more than 500%. Impacting the weakest floor beam exceeds the beam's 2005 Feb 7-NORAD Page 2 of 3

- Oyster Creek Nuclear Station capacity by more than 8,000%. The order of magnitude of these values clearly demonstrates Oyster Creek's Reactor Building is an unacceptable safety risk to New Jersey.

The NRC and Federal government needs to clearly identify the measures taken to mitigate an aircraft attack on structurally obsolete reactor buildings, like Oyster Creek. Otherwise, pronuclear individuals like me cannot support the continued operation of these plants, and demand their immediate shutdown. The loss of 450 Oyster Creek jobs and higher electric rates are a trivial concern to many thousands of Ocean County residents and property owners, compared to the consequences of a potential Chernobyl event, should terrorist attack the plant's Reactor Building.

I urge you to verify that existing NORAD/USNORTHCOM operational procedures and training scenarios include the protection of nuclear power plants like Oyster Creek. In my opinion, this security concern is the most difficult to solve because it relies on the efforts of thousands of people to perform their jobs perfectly, within a very limited time. The use of multiple overseas aircraft, like Delta Fight 119 and Delta Flight 81, should be expected in any real terrorist attack using a large aircraft as a guided missile.

Sincerely, Stephen M. Lazorchak, P.E.

Past employee of GPU Nuclear/Oyster Creek

Enclosures:

Oyster Creek Aircraft Impact Handout (2 sheet)

Oyster Creek Nuclear Power Plant, The Structural Vulnerability to a Terrorist Attack, Forked River, NJ (4 sheets)

List of U.S. Commercial Reactors with Elevated Irradiated Fuel Storage Pools (1 sheet)

Photograph of Oyster Creek Nuclear Power Plant (I sheet)

Calculation demonstrating structural vulnerability of Oyster Creek's Reactor Building refueling floor at elevation 119'-3" (9 sheets) 2005 Feb 7-NORAD Page 3 of 3

Stephen M. Lazorchak, P.E.

Consulting Structural Engineer ll 20 Dorchester Drive Toms River, New Jersey 08753 (732) 255-1972 fax (732) 255-1972 February 10, 2005 Admiral Timothy J. Keating ( 00 Py NORAD/IUSNORTHCOM 250 Vandenberg, Ste. B-016 Peterson AFB, CO 80914-3808 Re: Oyster Creek Nuclear Station - Structural Vulnerability to Terrorist Attack Lacev Township. NJ

Dear Admiral Keating:

The National Academy of Science, Board on Radioactive Waste Management (BRWM) prepared a confidential Committee report on the "Safety and Security of Commercial Spent Fuel Storage" (Project No. BRWM-U-03-05-A). It was issued to the Congress, the Nuclear Regulatory Commission, and the Department of Homeland Security, in July 2004. I urge you to contact BRWM Director Kevin D. Crowley (phone 202-334-3066) to obtain a copy of the classified spent fuel storage report. NORAD/USNORTHCOM must become an expert on the structural design vulnerabilities of our nuclear power plants and prevent terrorist attacking these plants with large aircraft, used as a guided missile. Currently there is an effort to rebuild the World Trade Center. However, if a nuclear power plant like Oyster Creek was destroyed in a 9/11 event, most of New Jersey will emulate the area around ChernobyL Several days ago I mailed you an information package detailing my concerns regarding the spent fuel storage pool at Oyster Creek Nuclear Station. Briefly stated, Oyster Creek's reactor building is an obsolete structural design, no longer allowed by current Nuclear Regulatory Commission standards. Located on the top floor of the Reactor Building, 84-feet above ground level, is the refueling floor. At one corner of the building is a stair/elevator tower, immediately adjacent to the elevator is a 30-foot square floor opening to move refueling equipment between the ground level and the refueling floor. Diagonally across the refueling floor from the stair/elevator tower is the spent fuel storage pool.

Authorized plant personnel can walk over to the fuel pool handrail, look dowr4 and see 700-tons of used radioactive fuel rods stored under 30-feet of water. Looking up fromn the fuel pool, one will see steel roof trusses and the underside of the sheet metal roof decking. An overhead bridge crane will be typically parked at one end of the building. The roof trusses *pan the full width of 2005 Feb 10-NORAD Page Iof 2

Oyster Creek Nuclear Station the structure and are supported by steel columns. Attached to the steel columns are horizontal steel channels spaced vertically 6-feet on center. Sheet metal siding is attached to the channel members. This whole metal building enclosure, located above the refueling floor, is part of the secondary containment structure. It is designed for severe wind and earthquake forces, but not for aircraft impact. The metal enclosure is the weakest structural system in the Reactor Building's design.

Below the refueling floor the Reactor Building is made of reinforced concrete several feet thick.

All vital plant equipment required to shut down the reactor and maintain cooling to the spent fuel storage pool is located within the concrete portion of the building.

As part of a NRC directive, Oyster Creek was required to prepare load drop calculations for all floor levels within the Reactor Building. The calculations identify the amount of energy to critically damage floor slabs and floor beams, without allowing an accidental dropped load from 2

penetrating the floor system. Using a Kinetic Energy Equation (1/2 mv ) to determine the force a heavy object will hit the floor and the load drop calculation for the refueling floor, one can determine if a unsafe structural concern exists.

The impact energy from only one 1,000 pound object traveling at 300 mph and hitting the Reactor Building's refueling floor at an angle of 30 degrees above horizontal, exceeds the strongest floor beam capacity by more than 500%.

Impacting the weakest floor beam exceeds the beam's capacity by more than 8,000%. The order of magnitude of these values clearly demonstrates Oyster Creek's Reactor Building is an unacceptable safety risk to New Jersey, if a plane was intentionallycrashedinto the building.

[American Airlines Flight 11 crashed into WTC Tower I at 350 mph, and United Airlines Flight 175 crashed into WTC Tower 2 at 550 mph. Oyster Creek's relicensing website (www.oystercreeklr.com) references an EPRI December 23, 2002 report showing aircraft could not breach nuclear structures. This report analyzed a cylindrical dome structure, not Oyster Creek's square reactor building. The EPRI Report used an impact velocity of 350 mph, at 550 mph a large aircraftwill penetrate the structuralmodel used in the EPRI Report].

I hope NORAD/USNORTHCOM training scenarios include multiple terrorist aircraft that disappear from FAA control, turn to attack a nuclear power plant and another vital target close to an international airport. New Jersey's Newark International Airport and New York's JFK are excellent locations to test the military's response to such a threat.

Sincerely,- COPY Stephen M. Lazorchak, P.E. /

Past employee of GPU NuclearOyster Creek 2005 Feb 10-NORAD Page 2 of 2