ML073100293

2007/10/31-Comment (2) of John Sweeney on Pr 52 Regarding Consideration of Aircraft Impacts for New Nuclear Power Reactor Designs

ML073100293
Person / Time
Site:	Indian Point
Issue date:	10/31/2007
From:	Sweeney J Entergy Corp
To:	NRC/SECY/RAS
SECY RAS
References
72FR56287 00002, PR-52
Download: ML073100293 (3)

Text

-- - - -- -- I SECY - ATTN: Rulemaklngs and Adjudications

-- Staff RE:

PROPOSED AIRCRAFT IMPACT ASSESSME'NT v -F , RULE Page I 1 (72FR56287)

From: "Sweeney, John E" <jsweene@entergy.com>

To: <SECY@nrc.gov>

Date: Wed, Oct 31, 2007 12:59 PM

Subject:

ATTN: Rulemakings and Adjudications Staff RE: PROPOSED AIRCRAFT IMPACT ASSESSMENT RULE ATTN: Rulemakings and Adjudications Staff RE: PROPOSED AIRCRAFT IMPACT ASSESSMENT RULE DOCKETED USNRC November 5,2007 (1 0:l Oam) Gentlemen:

OFFICE OF SECRETARY RLILEMAKINGS AND Consider an unquantified situation where no impact assessment figures ADJUDICATIONS STAFF are available in the public domain to allow potential terror perpetrators to judge the efficacy of proposed aircraft strikes upon nuclear power plants.We have already observed how the "fog of unknowing" led the Mohammed Atta group to allegedly bypass such an attack, and select a more easily approached target--the World Trade Center. Now consider a situation where design basis scenarios are written into NRC code, exactly describing the parameters to be protected against in aircraft attacks upon nuclear power plants, and the rule itself, if not cloaked as "Safeguards Information" would act as a simple defacto primer on just how strong nuclear installations can expected to be, or to not be, thus allowing perfect planning of future air attacks on these installations.

Even if cloaked as "Safeguards" or "Classified" information, the formation of a large group of practitioners versed in any such new rule, will undoubtedly tend to replicate elements of the information (short of outright dissemination), and to spread the information, making control of its particulars increasingly problematical with each new trainee, each new calculation performed.

There is also the distinct possibility of its outright dissemination by former practitioners, or by those cognizant of its details, if caught in an extortion or duress situation.

Therefore, the utmost weight must be given to the argument that the detailed analysis of aircraft-on-containment studies, or rules derived therefrom, ought never be available except under the strictest secrecy regime, involving the fewest people, and only at those few instances when needed to actually design robust features into proposed structures, and otherwise strictly witheld from all other people, at all other times.(Even agency people). In like fashion, all details of any installed features actually implemented must never be publicly revealed, or even mentioned, as all clues would lead to a situation where attack becomes more likely, and more likely to succeed. For those of malicious intent to be able to purchase a simple United States Government primer on just how fast just how large an aircraft must fly to damage a nuclear plant, or to be able to read a publicly disseminated open rule telling them essentially the same thing, would be the utmost in criminal folly and unforgiveable naivete on the part of those who would debate, expose, teach, develop, or argue such a rule in a public forum. If such considerations are to be taken out of the purview of the

.- -- I SECY - ATTN: ~ulema~~~and A&u~~~~~~~~sL~TRE~PROPOSED . - - -- - - AIRCRAFT - IMPACT ASSESSMENT RULE Page 2 1 Department of Defense, and newly placed within the Department of Energy (or NRC), the nation must not be made less secure by doing so. If indeed defending the nuclear plants from air attack is now to be a DoEINRC responsibility, then a new, increased defense rigor must be envisioned at DoEINRC, beyond the simplistic "domestic openness" previously allowable when DoE/NRC were not (yet) in the defense business.

Do not allow media, intervenors, or those of limited insight to intimidate NRC into mistakenly aping DoD, but without its wartime rigor, and thus granting national enemies open access to domestic target parameters.

With greatest respect John Sweeney Designer, Entergy Indian Point Energy Center

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ATTN: Rulemakings and Adjudications Staff RE: PROPOSED AIRCRAFT IMPACT ASSESSMENT RULE Creation Date Wed, Oct 3 1,2007 12:59 PM From: "Sweeney, John El' <j sweene@entergy,com>

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