ML060260179

2006/01/24-Comment (67) Submitted by Kim Dunn on Proposed Rule PR-73 Regarding Design Basis Threat

ML060260179
Person / Time
Site:	Diablo Canyon
Issue date:	01/24/2006
From:	Dunn K - No Known Affiliation
To:	NRC/SECY/RAS
Ngbea E S
References
70FR67380 00067, PR-73, RIN 3150-AH60
Download: ML060260179 (3)

Text

SECY -Sick of the risk of Diablo Canyon!! Page 1 DOCKETED= USNRC i From: <DunnMagic~aol.com>

70 61590) January25, 2006 (2:16pm)To: <SECY@nrc.gov>

OFFICE OF SECRETARY Date: Tue, Jan 24, 2006 2:16 PM RULEMAKINGS AND

Subject:

Sick of the risk of Diablo Canyon!! ADJUDICATIONS STAFF COMMENTS ON NRC PROPOSED RULE REGARDING DESIGN BASIS THREAT FOR PROTECTION OF NUCLEAR FACILITIES AGAINST SABOTAGE AND THREAT OF STRATEGIC SPECIAL NUCLEAR MATERIAL RIN 3150-AH60 To: _SECY nrc.gov (mailto:SECY nrc.gov)January 23, 2006 In light of the recent demonstration of the ineptness of our government, living near The Diablo Canyon Nuclear Power Plant leaves me very uncomfortable, considering that the health of my family and entire financial future is at risk.It is becoming increasingly difficult to believe those in charge are anymore than "FEMA" type agencies.

The newspaper article that recently stated that the next quake on the San Andreas Fault will be much larger than the San Francisco Quake of the 1800's and is considered overdue, makes it even worse.When the "experts" were selling the idea of the plant, they were positive the waste issue would be resolved by the time it became necessary to deal with it. Of course this was another fabrication.

I have looked into the proposed Yucca Mountain storage sight, and all I find is scientists who say not to license it. From what I have learned, I don't believe it will be.Add the option for Terrorism and you have a citizen who wonders if any of you would want to live here. Would you want your families at risk for the profit for PG&E? Do you really believe this area with only Hi way 101 would be able to evacuate us? If you do, you have not been here or you simply do not care beyond the income you receive from supporting the continued risk to others.I am submitting comments regarding the U.S. Nuclear Regulatory Commission's

('NRC's") proposed rule entitled "Design Basis Threat" ("DBT"). The proposed rule was published in the Federal Register on November 7, 2005, at 70 Fed.Reg. 67,380.For the reasons stated below, I find the proposed rule unacceptable, and I unreservedly support the more precise comments submitted by the San Luis Obispo Mothers for Peace and the Union of Concerned Scientists.

The proposed rule is the first NRC security-related rulemaking since the terrorist attacks of September 11, 2001, and I find it grossly deficient.

The Commission promised the public a complete re-evaluation of its security regulations over four years ago, and this belated proposal is unclear, incomplete, and dishonest.

The NRC has failed to meet the challenges of the post-9/11 environment, for the revised DBT excludes the crucial adversary characteristics of the 9/11 attackers:

the ability to operate as more than two teams or the capacity to carry out an airborne attack. By failing to include any proposal for protecting nuclear facilities from these characteristics, the NRC makes it clear that it has no plans to ensure that the public will be protected from a 9/11-style terrorist attack. Moreover, despite its claims to have "enhanced" the" adversary characteristics" of the pre-9/1 1 DBT, the NRC has actually weakened the standard for protection of strategic special nuclear material against theft by reducing the maximum number of hypothetical adversary teams from three to-f i=q-oa

-SECY- Sic of the risk of DiboCnn!SECY -Sick of the- risk-of Diablo Canyon!! Page 2 two.I am also concerned that the NRC appears to have relied on unlawful cost considerations to limit the scope of the DBT by stating that a licensee should only have to defend against a DBT "which a private security force could reasonably be expected to defend." NRC safety and security regulations must be based on a determination of what is necessary to protect public health and safety, not a judgment of what is affordable to the licensee.

And if the NRC has relied on some considerations other than costs, it has failed to explain its rationale, which constitutes a violation of the Administrative Procedure Act.Furthermore, it appears that the NRC's limitations on the scope of the DBT are based on secret comments from the nuclear industry which the NRC has not summarized for the general public. This is also a violation of the Administrative Procedure Act.Submitted by: Kim Dunn CC:<DunnMagichaol.com>

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