THE SALEM NUKES NOW
UNPLUG SALEM Campaign
Barr Ave., Linwood NJ 08221
John Zwolinski, NRC Office of Nuclear Reactor Regulation
This letter contains comments from the UNPLUG Salem Campaign to the
proposed Director’s Decision to our 2.206 petition. Comments are by page
number, with general comments at the end of this letter. This letter will be
emailed as a Word file to Bob Fretz and mailed to Mr. Zwolinski.
Page 8 – we disagree with the assertion that security guards can
“foster an effective deterrence” against potential terrorists. David
Lochbaum of the Union of Concerned Scientists has provided much information to
you. The bottom line is that the events of 9/11 mean that standards for
deterring terrorists have risen. You do not explain how NRC has raised those
At the bottom of page 8 – please explain in detail what you define as a
“background check”. Please explain in detail what you define as “screening
personnel, packages and vehicles”.
On page 9, line 4, saying that you “develop information” gives no
time parameters. How long do these checks take? How do you deal with out of
The paragraphs following “Protection of Vital Equipment” were based
on information from before 9/11. Thus what you have written on pages 9 and 10
are no longer relevant and need to be revisited in light of 9/11.
The last line on page 9, “hand-held automatic weapons” must be
reviewed in light of 9/11.
page 10: what kind of review of vehicle barriers has been done to see if they
can withstand a commando attack of sufficient size to overpower the guards and
then use explosives to clear the barriers away?
last line on page 10 shows how your thinking is mired in the past: “most
likely terrorist acts”. The whole point of 9/11 is that it is the unlikely
terrorist acts we must prepare for.
On page 11 you say that “NRC performed numerous
onsite…assessments”. You give no indication of the results of those
assessments. This paragraph MUST be re-written to tell us what the results were
and what improvements were made. This can be in a general sense, for example,
“322 assessments were made, 120 high level and 450 low level suggestions were
made.” NRC should not be able to
get away with an unquantifiable statement.
the next paragraph you discuss how NRC worked with other agencies. This is just
whitewashing. Again, you provide NO quantifiable data about what improvements
have been made or are in the pipeline. This section MUST be rewritten to provide
us with data.
page 12, line 9, again you really tell us nothing. Lines 10-13 should be
re-written to specifically detail what improvements were made.
page 13, under “NRC Response”, we disagree with the statement that “vital
area barriers….are generally robust”. First of all, by using the word
“generally”, you are implying that SOME barriers are NOT robust. The
barriers that are not robust, such as the spent fuel pools at all 4 of NJ’s
nukes, should be listed, and NRC should admit that SOME barriers are NOT robust.
Secondly, the word “robust” needs to be defined, or a more accurate word
page 14, you say “vital area barriers at many facilities”.
Again, the use of the word “many” implies that SOME barriers do NOT
afford sufficient protection. These lines should be rewritten to indicate which
barriers do NOT protect.
the end of the second paragraph you refuse to say what size of bomb barriers can
protect plants from. This is a use of “national security” to withhold vital
information from a stakeholder. This section should be rewritten to give us more
information as to what size bomb barriers will not withstand and what NRC plans
to do about it.
the last paragraph, while we are pleased that NRC is granting our request, we
disagree that this “granting” really means anything, because you have NOT
demonstrated that Oyster Creek can indeed withstand the effects of an explosive
device transported by a vehicle. This section should be rewritten by you to
accurately demonstrate how Oyster Creek can withstand the effects.
page 15 and 16, while we are pleased that NRC again grants our request that
Oyster Creek and Salem must be able to protect their water intakes from attack,
nowhere on page 15 do you describe HOW this protection occurs. Page 15 must be
rewritten to describe in more detail, how the intakes are, and will be,
would also like to know what liability NRC has if, after granting our petition
on intake defense without additional explanation, an attacker does succeeded in
penetrating the intake structure, thus causing a LOCA.
Pages 16-18 discuss vulnerabilities to airplane attack. Professor Frank
von Hippel of Princeton University, and a workgroup of students have concluded
in a recent study that all 4 of NJ’s nukes are indeed vulnerable to a 767-type
airplane strike. Thus we reject your refusal to grant us that portion of our
2.206 and request that you review your decision.
page 16, you agree that nuclear plants were not designed to stop a jet impact
and say that defense in depth affords a “measure” of protection. That line
must be rewritten to define what a “measure” of protection means. On page 17 you continue to avoid to precisely define how well
protected nuclear plants are. Lines 1 through 5 must be rewritten to give more
information to the stakeholder.
page 18, line 1 should be rewritten to list at least the threat against TMI and
the general threats made to nuclear plants. We STRONGLY disagree with the
statement that you feel that the possibility of an airliner strike remains
“acceptably low”. You must rewrite that section to define what “acceptably
low” means, and to define at what level “unacceptable high” begins. Any comparison of chances must be based on the formerly
“acceptably low” chances of four airliners being hijacked at the same time
and then crashed into buildings. If the odds of an airliner strike are at least
as high as 9/11, then those odds are TOO HIGH.
Finally, on page 18,you must detail what “additional actions”
(line 11) NRC will take.
NRC should rewrite the above section to better answer our request, and to
answer it in such a way that “odds” are not the key reason for rejection.
On page 19, we are referring to a number of scenarios submitted by David
Lochbaum, of the Union of Concerned Scientists, that show vulnerabilities of all
4 NJ nukes to multiple sabotage. On line three, we suggest that “staff
considers”, be replaced by “staff AGREES”.
By listing all the barriers the way you do on this page, you do not
respond to each concern separately. Each concern raised by Mr. Lochbaum should
be answered separately, because some of your answers do not apply to each
specific scenario. In addition, you need to define “other barriers” (bullet
point 6), as “other barriers” means nothing.
While we are pleased that you have granted our request, without
additional information from NRC it is not clear what you are granting. We
totally disagree with you that reliance on defense-in-depth can be used, as it
is on pages 19-20, as a catch-all to cover inadequacies in design and safety. We request that you more deeply explain how NJ’s 4 nukes
are protected against multiple attacks or fires.
As to your response on page 20 to Salem’s bogus fire wraps, we demand
more than just your “belief” (line 8) that defense-in-depth is adequate.
Using the word “belief” on a science test essay would get you an F.
We demand detailed proof of why you “believe” that NRC’s deal with PSEG
that allowed PSEG to not replace much of its bogus safe-shutdown cable wraps
will not lead
to safety problems IN CONJUNCTION WITH a terrorist attack and/or fire in two or more places at the same
time at Salem Units 1 or 2.
page 21, line 5, please change that line to read that the “requests….are
PARTIALLY based…” Then add that we have concerns based on the security of
any dry cask system, including concerns that the dry cask is above-ground
instead of buried.
“NRC Response” that follows in unacceptable because it is merely a repeat of
your standard response about nuclear plants in general. The spent fuel pools at
Hope Creek and Oyster Creek are above ground and thus subject to a loss of water
accident. The pools at Salem Units 1 and 2 are covered by a building, “no
stronger than a K-Mart (Lochbaum).” By using the word “typically” in line
16 you avoid being specific about NJ’s four nukes.
Rewrite line 16 and specify the strengths and weaknesses of the four
spent fuel pools in NJ.
On line 17 (last paragraph), the use of the word “certain” avoids the
issue. Exactly how much of a level of protection is there. Rewrite that line to
page 22, we vehemently disagree with your statement that threat advisories
adequately safeguard spent fuel pools. Those remarks are totally wrong and must
be eliminated from your response. Your denial of our request that spent fuel
storage facilities be made capable of withstanding a crash is one of the more
indefensible parts of this document. We suggest that your staff revisit this
part of your analysis because the spent pools are some of the most vulnerable
parts of a nuclear plant. Your refusal to strengthen the fuel pools is
disagree with your denial, on page 23, of our request for an ad judicatory hearing on the dry cask storage at oyster Creek. Your response is based
mostly on procedural grounds. The NRC has the ability to overcome procedural
concerns if this action is in the public interest. The safety of the public is
the paramount issue.
On pages 23 and 24, with disagree with your denial of our request to halt
and reverse all dry cask permits. The bottom line is that the dry casks were
built within 400 feet of route 9 and are basically indefensible against a
concerted terrorist attack. The requirements you raise on page 23 as part of
10CFR73.51 have been made irrelevant by 9/11. None of your requirements stops a
rocket attack. In addition, in the third line from the bottom, you again use the
word “robust”. Please remove that word and use terms that define exactly how
well a cask is defensible.
Pages 24 and 25 discuss our concerns over
complete loss of power, as that would be one way for a terrorist to cause a LOCA
and/or meltdown. Because Salem is isolated on Artificial Island, which has only
one road to the plant, and because determined terrorists could defend that road
for an unknown amount of time, your SBO evaluation of 4 hours is flawed. Again,
9/11 changed everything, including your “engineering evaluation”.
The SBO should be refigured based on the assumption that terrorists with
heavy weapons have cut all incoming power lines to the plant and have damage the
diesel generators. We feel that a four-hour battery backup is not sufficient.
We disagree with your analysis in paragraph
2 on page 25, because of your assumption on line 15 (“Provided that). We feel
that this assumption of control of replenishment of water and sufficient battery
power can be overcome by terrorists under certain conditions.
On page 25, third paragraph, change the word “considers” to
While we appreciate that you partially grant our request, we urge you to
rewrite this section to more accurately reflect the true post-9/11 realities.
26-30 deal with our concerns about OSRE. While we appreciate that you have
partially granted our requests, your partial granting does not go far enough. We
do not think that NRC should be allowed to wait until reviews are done or until
Congress issues specific orders on OSRE. In the light of 911, OSRE is the one
program that should be expanded by NRC, not eliminated. Thus we urge that the
responses on page 26-30 be rewritten in light of 911.
Your excuse on page 28, line 11 that other industries do not have
comparable testing is irrelevant and should be excised from your response. What
matters is what NRC does, not what other agencies do.
We totally disagree with your assertion in line 16 that the
industry can assume more responsibility for security. By accepting that
assertion, you are placing peoples’ lives in jeopardy. There must be an
independent agency, in light of 911, to test nuke plant security.
Pages 30 and 31 deal with items you consider to be “rulemaking”. We
appreciate your partial granting of these requests. However, you do not detail
which parts you have granted and which you have not. We request that the
response be more detailed in this area and explain which requests were included
and which were not, and why.
Pages 31 to 33 deal with KI. We request that your response be rewritten
to read. “NRC supports KI distribution in the 50 mile EPZ zone.”
33 to 37 deal with how stakeholder organizations can be allowed to observe
emergency planning exercises and be integrated into the emergency planning
system. We oppose your denial of our request because it is based on poor logic.
You deny us the ability to participate because we presently do not participate.
That makes no sense at all. NRC has the ability to work out a framework that
would allow access to emergency preparedness exercises by stakeholder groups.
In the light of 911, citizen groups would be a tremendous additional
resource to emergency planners, both as a source of ideas and as a source of
Finally, on page 38, while we appreciate your partial granting of our
request, overall, your responses do not go far enough and are often evasive and
at times not logical. We urge that you incorporate the changes requested in this
letter into your final document.