Two more chilling articles on NPP terrorism to be forwarded to the responsible authorities ASAP


To: "Barbara Byron" <BByron@energy.state.ca.us>, graydavis@governor.ca.gov, "Barbara Boxer, Senator (CA, D)" <senator@boxer.senate.gov>
From: "Russell D. Hoffman" <rhoffman@animatedsoftware.com>
Subject: Two more chilling articles on NPP terrorism to be forwarded to the responsible authorities ASAP
Cc: president@whitehouse.gov,  "Russell Wise, NRC" <rxw@nrc.gov>,  "Elmo Collins" <eec@nrc.gov>,   "Pat Gwynn" <tpg@nrc.gov>,  "Clanon, Paul" <pac@cpuc.ca.gov>,   "Ajello, Julian E." <JEA@cpuc.ca.gov>,   "Wong, Zee Z." <czw@cpuc.ca.gov>,   "Clark, Richard W." <rwc@cpuc.ca.gov>,   "NRC" <the.secretary@hq.doe.gov>, Bob Aldrich <boba@energy.ca.gov>, "Steve Woods" <swoods1@dhs.ca.gov>, "Bob Kahn, Op-ED editor, NC TImes" <bkahn@nctimes.com>

To: "Barbara Byron" <BByron@energy.state.ca.us>, Bob Aldrich <boba@energy.ca.gov>, "Steve Woods" <swoods1@dhs.ca.gov>
cc: Governor Gray Davis, Senator Barbara Boxer, NRC, CPUC, etc.
Re: Two more chilling articles on NPP terrorism to be forwarded to the responsible authorities ASAP
From: Russell Hoffman, Concerned Citizen
Date: September 20th, 2001 (8:30 am PST)

To: Ms Barbara Byron, Mr. Bob Aldrich, Mr. Steve Woods:

Since none of you have given me the email address of the person who is supposedly handling my complaints (and I have not heard from them), I must ask you to forward to that person the attached two articles on Nuclear Power Plants and the terrorist threats to them.

You should also each read these articles, as well as everything else I have sent any of you, even if you have forwarded it to others.  Since both Ms Byron and Mr. Aldrich have spoken on behalf of the state to the public (me) on these issues, clearly you both have a duty to learn the full truth about what you are spouting off about.  And Mr. Woods is supposed to know this stuff, but since I haven't heard from him, clearly he doesn't have any answers.

Also, note that I am still waiting for responses on various related matters pertaining to statements made in previous letters to me from Ms Byron and Mr. Aldrich.  This is NOT the way the State of California should be serving its citizens.

The first article I have included in this letter is by Daniel Hirsch, Director, of Committee to Bridge the Gap, Los Angeles, California.  It is titled "The Truck Bomb and Insider Threats to Nuclear Facilities" and I'm sure you will find it chilling and well documented.

The second article is called "Sitting ducks? Porous security makes nuclear power plants inviting targets" and is by By Don Hopey, (Pittsburgh, PA) Post-Gazette Staff Writer.

If you think our nuke security is good here, try hiring me to test it.  I'm sure I can put together a team of ex-Navy Seals, etc. to prove you wrong.

Do any of you live near a nuclear power plant?  Because people who do are scared.  As each day goes by and I get nothing but a run-around from the California State Government employees, those of us who live near an NPP wonder if America learned anything in the past two weeks.  It appears not.

I also wish to note that Mr. Aldrich and Ms Byron said at first that I should contact the Nuclear Regulatory Commission on these matters.  But as each of you could see, they have been "cc'd" each of my letters to you!  So they have had ample opportunity to get involved in these discussions and have CHOSEN not to.  THAT ALONE SHOULD BE AMPLE PROOF TO THE STATE OF CALIFORNIA THAT THE NUCLEAR REGULATORY COMMISSION IGNORES AMERICAN CITIZENS AT THE PERIL OF CITIZENS OF THE STATE OF CALIFORNIA.  Therefore, clearly, the state is obligated to act on these extreme dangers.  Please ensure that each of my letters has been forwarded not only to Mssrs Masri and Laurie at the state level, but that the whole set, now numbering 17 emails (including this one) is forwarded to a RESPONSIBLE PERSON at the NRC who WILL answer my questions (please give me that person's name, as well).  None of the people at the NRC who I sent these messages to (who are all shown above) have responded.  That should be seen as further proof that the State of California must take over responsibility for our safety since the NRC won't even respond to California's citizens.

Sincerely,

Russell D. Hoffman
Concerned Citizen
Carlsbad, CA



=====================================================================

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http://www.nci.org/g-h/hirschtb.htm


  The Truck Bomb and Insider Threats to Nuclear
Facilities
  Daniel Hirsch
  Daniel Hirsch is director of Committee to Bridge
the Gap, Los Angeles, California.
  There are two primary safeguard and security
risks associated with fixed-site nuclear
facilities and with nuclear materials in transit:
the theft of weapons-grade nuclear materials or
fully assembled nuclear devices and sabotage. The
potential consequences to the public from either
action can be surprisingly similar.

  In the field of nuclear safeguards and security,
there is a tendency to protect against threats
that are relatively easy to address and to ignore
those that are somewhat more difficult. However,
overall security is a function of the weakest
links in the security chain, links that societies
ignore at their own peril. In the nuclear field,
two of these weak links in the security chain are
the truck bomb threat and the insider threat. The
risks associated with terrorist use of vehicular
bombs against nuclear targets surfaced (actually,
resurfaced) following the terrorist attacks on the
U.S. Embassy annex and the Marine compound in
Lebanon. Concern was expressed that similar
attacks against nuclear facilities could result in
substantial damage and release of radioactivity.
Since the current regulations of the NRC require
licensees to protect only against attacks on foot
(and even then, only against very small attacking
forces), shortly after the Lebanon bombings, that
agency commenced an urgent rulemaking to require
its licensees to protect against truck bombs.
Inexplicably, that rulemaking was called off after
research results indicated that the truck bomb
threat to nuclear facilities was even more serious
than previously thought.1

  Even were nuclear facilities adequately
protected against external attack, be the aim
theft or sabotage, the greatest security risk to
these sites---the threat of action by
insiders---would remain. The insider threat is
particularly difficult to resolve because nuclear
facilities typically employ large numbers of
people, and certain employees must have access to
vital areas of the facility In order to perform
their work. Some employees could take advantage of
that access to perform acts of sabotage or theft
that could be immensely destructive. The
traditional methods of protecting against the
insider threat--- such as the two-person rule,
strict compartmentalization of vital areas, and
design features that make damage to two or more
redundant systems by one individual
difficult---are generally expensive and have
encountered substantial resistance from the
nuclear industry, which has restrained the NRC
from requiring them.


  Truck Bomb Threat
  The NRC established most of its security
regulations for nuclear facilities and materials
in the mid-1970s. Those regulations required power
reactors to be protected only against three
external attackers, working as a single group,
moving on foot, with weapons no more sophisticated
than hand-carried automatic weapons and with the
possible assistance of no more than one insider.
  NRC-licensed facilities with weapons-usable
nuclear materials were required to meet only a
marginally higher standard that primarily involved
a slightly larger attack group capable of
operating as two teams. Research reactors, even
those using highly enriched (weapons-grade)
uranium, as well as those reactors posing a
substantial sabotage risk because of their urban
siting and lack of a containment structure, were,
according to NRC staff, exempted from both
requirements.2

  Basing security at power reactors on a defined
maximum threat of a very small group with only
those explosives they can hand carry (10 CFR
73.1 ) leaves these facilities highly vulnerable
to vehicular bombs. This omission was not,
however, an oversight. The original proposed
security regulations had included a provision
requiring "appropriate barriers" to obstruct ready
access by ground vehicles, but it was explicitly
deleted from the final regulation on the following
basis: "The Commission has decided that this
proposed provision should be further studied
before being considered for indusion in the
regulations. This proposed amendment has been
deleted from the rule."3 Whether those studies
were ever conducted is unclear. What is clear,
however, is that ten years later, the NRC security
regulations still require protection against only
a small group of adversaries on foot, despite a
marked rise in international terrorism, including
acts against nuclear targets.

  A mounting series of truck bombings directed at
U.S. installations in the Mideast led the NRC to
reexamine the issue in early 1984, with
considerable urgency. In a press release at the
time, the NRC noted the


    publicized events where U.S. installations
overseas have been the target of terrorists using
vehicle bombs and the Executive sranchss recent
announcement that security precautions at certain
government facilities in this country have been
upgraded as a result. [NRC] Licensees currently
are not required to protect against such attacks..
. .
    As a matter of prudence, the staff is
reviewing this matter on a continuing basis to
ensure that security requirements provide for the
continued protection of the public health and
safety.4 (Emphasis added)

  The review by NRC safeguards staff concluded
that the regulations needed to be changed rapidly.
They directed the development of "an immediately
effective rule which revises the design basis
threat for both radiological sabotage and theft to
include the introduction by an adversary of
explosives and other equipment by vehicle."5
Because of the urgency of the situation, the rule
was to be written in the shortest possible time
and to go into effect immediately upon
publication, without the usual delays. At the same
time, the NRC contracted with Sandia National
Laboratories to study the potential damage that
truck bombs of various sizes could cause at
various distances from a power reactor.

  Three months later, on April 26, 1984, all
action on the proposed rule was deferred, "pending
the results of research."6 The research results
had actually been provided to the NRC two weeks
earlier, however. A review of those findings
raises troubling questions about the manner in
which the NRC has tended to deal (or not deal)
with difficult terrorism problems.

  The task the NRC gave Sandia was as follows:


    Terrorist activity in other parts of the world
has exemplified the destructive consequences of an
explosives-laden vehicle, i.e., a truck used as a
weapon against a facility. Given this threat, the
NRC seeks to evaluate the potential vulnerabilides
of nuclear facilities in this countrv against such
action, to determine the "worst case" potential
consequences, and to develop easily implemented,
cost-effective safeguards mechanisms for
preventing facility access of such a vehicle.
(Emphasis added)7
  On April 13, 1984, the NRC was provided the
results of the Sandia study. As the staff
subsequently reported to the commissioners: "The
results show that unacceptable damage to vital
reactor systems could occur from a relatively
small charge at close distances and also from
larger but still reasonable size charges at large
setback distances (greater than the protected area
for most plants)."8

  Why did the NRC, which had initiated an urgent
rulemaking to address the truck bomb threat,
suspend action on the matter only two weeks after
these results, which were extremely disquieting,
came in. its action might be easier to understand
had the sequence of events been reversed---for
example, a January 1984 decision to commence
research to see whether truck bombs could cause
serious damage to a reactor, with action suspended
pending the research results, followed by a
subsequent decision to go ahead with an urgent
rulemaking to address the problem when the
research indi- cated the threat was serious. It is
hard, however, to comprehend why, if the NRC
viewed the truck bomb threat as sufficiently
serious to commence an immediate rulemaking before
the research findings were available, it called
off action when the study's conclusions confirmed
serious problems.

  An explanation for this state of affairs can
perhaps be found in the original direction the NRC
provided to Sandia. The NRC gave Sandia three
research tasks: evaluate the vulnerability of U.S.
nuclear facilities to a truck bomb attack,
determine the potential consequences of such an
attack, and develop easily implemented inexpensive
mechanisms for preventing access of
explosive-laden vehicles.

  Sandia's research produced unpleasant findings
regarding each of the questions posed. It
concluded that nuclear facilities in the United
States are extraordinarily vulnerable to truck
bomb attacks, that such an attack could result in
"unacceptable damage," and that addressing the
problem would require more than just a few
concrete flower pots or barricades near the
reactor because of Sandia's extraordinary finding
that "unacceptable damage to vital reactor
components" could result even if the truck bomb
were detonated off-site. Thus the problem was
graver than previously thought (and therefore more
needy of prompt action) and required costly
corrective measures (which were therefore likely
to be resisted more vigorously by licensees).

  As members of the Advisory Committee on Reactor
Safeguards (ACRS) have pointed out, there is a
difference between the NRC and other federal
agencies, which had already taken measures to
protect against truck bombs (including the DOE for
its reactors).9 That difference can help explain
why the NRC is the only comparable federal agency
not to have taken domestic precautions against
truck bombs. The expense of the security measures
adopted by the other agencies was borne by
taxpayers, whereas if the NRC expanded its design
basis threat regulations to require protection
against vehicular bombs, the added security costs
would have to be covered by the utilities that own
the nuclear facilities.9 Here is a unique
situation where the level of protection at a
nuclear facility is determined by who owns it
rather than by how many people could be hurt by a
failure of its security.

  As long as the proposed NRC truck bomb rule
involved only a few extra concrete barricades
on-site, the cost to the licensees would have been
minimal and the political cost to the NRC
acceptable. When research revealed that the
problem was considerably more serious than
previously thought and the solution therefore more
expensive, the regulatory agency apparently felt
it could not afford to require action
proportionate to the problem.

  This situation raises the peculiar paradox of
contemporary regulatory agencies such as the NRC
with regard to large problems such as the risk of
nuclear terrorism. As long as the problem is small
and the solution not costly to those being
regulated (and thus not politically costly to the
agency doing the regulating), the agency feels it
can act. Should the problem turn out to be major,
with significant risks to the public, and the
solution therefore consequential in terms of costs
to the licensees, the agency comes under
substantial internal and external pressure to
leave the problem unattended. Thus, ironically, it
is only those links in the security chain that are
already relatively strong that the commission
feels it can address because they are inexpensive,
both economically to the licensees and politically
to the agency. The weak links, such as
vulnerability to truck bombs, remain "deferred
pending further study." Yet it is the weak links
that create the bulk of the risk to the public and
to the nuclear industry itself.


  Insider Threat
  The second critical weak link in nuclear
security is the insider threat. Indeed, ACRS
members have justified their inaction on the truck
bomb issue, in part, on the basis that resolving
it would still leave nuclear facilities extremely
vulnerable to acts by insiders.11 Yet as little
action has been taken to mitigate the insider
threat as that of the truck bomb problem.
  Examples of past incidents involving the insider
threat range from the relatively inconsequential
(such as theft and attempted extortion involving
low enriched and only mildly radioactive uranium
dioxide powder or theft of kilogram quantities of
depleted uranium and subkilogram quantities of
highly enriched uranium) through events costly to
the company involved but not dangerous to the
public (destruction of a large quantity of fresh
fuel assemblies at a nuclear power plant) to
occurrences that are potentially very serious
(such as intentional disabling of a power
reactor's emergency core cooling system or the
backup diesel generators). All point to the
difficulties in protecting nuclear materials and
facilities from insiders.12


    In 1981 at the Beaver Valley nuclear power
plant near Liverpool, Ohio, someone shut a valve
to the high head safety injection pumps, a crucial
part of the emergency core cooling system (ECCS),
an act that disabled the high- pressure portion of
the ECCS. This act could have been serious had
there been an incident in which that system were
needed (for example, a small loss of coolant
accident where high-pressure injection of
emergency cooling water would have been
necessary). The consensus of opinion was that the
act was intentional.13
    Also in 1981, at the Nine Mile Point Unit I
nuclear power plant in Oswego, New York, the NRC
found what it described as a "major degradation"
of the backup power supply needed in case of a
loss of off-site power. Diesel generators failed
to start when tested because of an apparently
deliberate closure of the drains on the fuel oil
filters. The utility concluded that the problem
was the result of tampering.14

    At the Salem Unit 11 nuclear power plant in
Salem, New Jersey, in August 1982, the manual
isolation stop valves to the air start motors to
the number 2C diesel generator were found closed.
This condition would have prevented both automatic
and manual start-up of the diesel generator were
it needed in an emergency (such as loss of
off-site power). The event occurred despite
increased precautions by the licensee put in place
after an act of suspected sabotage the previous
weeks.15

    On July 1, 1969, four depleted uranium plates
and a smaller quantity of highly enriched uranium
were reported lost from a nuclear facility at MIT.
The materials were subsequently found on the desk
of an MIT professor following police questioning
of a suspect. The consensus was that a master key
was probably used to gain access to the material,
presumably by an MIT graduate student who was the
prime suspect.16

    In January 1979, the general manager of the GE
nuclear facility in Wilmington, North Carolina,
received an extortion letter with a sample of
uranium dioxide powder. The letter stated that the
writer had two five- gallon containers of low
enriched uranium dioxide that had been taken from
the plant. The containers were identified in the
letter by serial number and were subsequently
authenticated as being missing from the plant. The
letter demanded $100,000 or else the material
would be dispersed in an unnamed U.S. city. An
employee of a GE subcontractor was arrested and
sentenced to fifteen years in prison.17

    Also in 1979, two plant operator trainees at
the Surry nuclear power station in Newport News,
Virginia, entered the fuel storage building, which
was locked and alarmed, and poured sodium
hydroxide on sixty-two of sixty- four new fuel
assemblies stored there, damaging them. Both
individuals had authorized access to the storage
building.18

  Insiders pose a dual threat: theft of nuclear
materials and sabotage of the facility. The amount
of material unaccounted for (MUF, now referred to
as the inventory difference, or ID) from
facilities in the United States handling highly
enriched uranium or plutonium is enough to
fabricate hundreds of bombs. It is uncertain
whether all that material has merely been lost
through faulty accounting procedures or whether
some has been stolen or diverted It is clear,
however, that the risk of the theft of these
materials by insiders, or with the assistance of
insiders, is substantial. It is widely believed,
for example, that the large apparent diversion of
highly enriched uranium from the NUMEC facility in
Apollo, Pennsylvania, was accomplished with the
assistance of a well-placed insider.19 The
continuing long-term problem with inventory
differences outside acceptable statistical margins
at the Erwin, Tennessee, facility, which handles
large quantities of highly enriched uranium, is
particularly worrisome in this regard, as is the
NRC's willingness to permit continued operation of
the plant without resolution of the problem.

  An insider or conspiracy of insiders could cause
immeasurable harm through sabotage. The fuel in a
nuclear power reactor must be cooled continually;
otherwise it can melt and release large quantities
of fission products to the environment. This
requirement holds true even after the reactor is
shut down because decay heat is generated long
after the control rods stop the fission process.
Loss of either the coolant or the electricity to
power the pumps to move the coolant could be
disastrous. Although all reactors have backup
systems, it is precisely the attack on important
backup systems that makes insider sabotage
attempts such a concern.

  In this regard, the published probabilistic risk
assessments (PRAs) performed for a number of
nuclear plants are problematic. They are of
questionable use for their principal purpose: the
estimation by the NRC and the nuclear industry of
quantitative values for absolute risk from
particular facilities. Worse, they could provide
virtual road maps for saboteurs. PRAs and much of
the recent source term research identify the worst
possible sequence of events at nuclear facilities
that could result in large releases of
radioactivity to the environment. Some argue that
the probability of the most serious of these
release sequences occurring accidentally is very
small. Whatever the truth of that hotly contested
matter, no such statement can be made about the
probability of their being made to occur
intentionally. As former NRC chairman Palladino
has remarked, unlike reactor accidents involving
human error, sabotage is not mathematically random
and involves deliberate attempts to defeat safety
systems.20

  The regulatory and industry responses to the
insider threat have been remarkably similar to the
response to the truck bomb threat: they hope that
it goes away on its own. Indeed some proposed
actions appear to be making matters worse. For
example, rather than further compartmentalizing
vital areas so that there is greater control of
access to crucial portions of nuclear plants,
vital areas are proposed to be combined into
larger islands. Once through a single access
point, workers would be free to wander through
large areas of the plant.

  A recent event at the Turkey Point nuclear power
station is indicative of the inadequacies in
current practices designed to prevent insider
sabotage. While sabotage has not been ruled out as
the cause, the preponderant belief is that this
particular incident was the result of personnel
error. It is, however, illustrative of how
sabotage could take place and remain undetected
for long periods of time. At Turkey Point, a
shared auxiliary feedwater system supplies two
reactors at the site. The system provides
feedwater when the main system is not in service
or when only small feedwater flows are required.
While one reactor was down for maintenance,
someone valved out the feedwater system for the
operating unit. For five days, no one noticed that
the system had been tendered inoperable, despite a
requirement that a thorough check be per formed
twice per shift. The failure to detect the
disabling of the feedwater system occurred
apparently because the checks were not adequately
detailed in instructions and because appropriate
"out for maintenance" tags had been placed on the
inappropriately closed valves. Had normal
feedwater flow been interrupted during that
period, a serious situation, including the
potential for core damage, could have resulted
because the auxiliary system was valved off.21

  A traditional approach to the insider problem,
the two-person rule (prohibiting unaccompanied
presence in vital areas), has met with great
resistance from industry and within the NRC. Even
existing regulations designed to provide some
measure of protection against insiders seem to be
enforced and complied with inadequately.
Violations of access controls are commonplace, and
the small fines imposed when such violations are
detected seem to offer little deterrent to
repetition of the infractions.

  It is troubling that the current proposed NRC
rule on insider safeguards, weak though it is, is
being opposed by the nuclear industry and the
ACRS. The ACRS has endorsed an alternative
proposed by the Nuclear Utility Management and
Human Resources Committee (NUMARC), which both
groups argue is preferable to the issuance of a
commission rule. NUMARC proposes that the minimal
actions suggested by the NRC staff not be made a
binding regulation but rather that there be
"industry oversight of the program based on a
policy statement issued by the commission
endorsing some guidelines."22 The NRC staff says
that "the more effective way to go is the rule"
because "policy statements have a tendency to
wither up and go away."23 Nevertheless the ACRS
opposes the staff proposal for a binding rule.

  An important method of reducing the insider risk
is careful attention at the design stage to the
inclusion of features that make insider-induced
sabotage difficult. An example of a design problem
that would make the work of an insider easier
rather than harder is reported by NRC security
officials to have occurred recently at the Wolf
Creek nuclear plant. A security officer at that
facility is said to have entered a command into
the security computer erroneously, which had the
effect of unlockng the doors to all the protected
and vital areas of the plant. It was fifteen
minutes before anyone realized that, having pushed
this button, all the doors were unlocked.24

  One approach to designing nuclear plants to make
them more resistant to insiders is to ensure that
redundant safety features are located in different
vital areas such that access to both areas by the
same individual is difficult. In this regard, the
NRC's recent policy statements regarding severe
accidents and reactor standardization are
troubling. By declaring the current generation of
nuclear plant designs safe enough and by
indicating that new standardized designs need be
no safer than current models, much of the impetus
to improve reactor safety and security by a new
standardized design has been undercut. Attention
to sabotage protection at the design stage is,
however, important to dealing with the terrorist
threat.

  Stricter regulation, strictor enforcement,
better security controls at nuclear facilities,
and more attention to protection against sabotage
at the design stage can help reduce the insider
threat. It is not a problem, however, that will go
away on its own.


  Potential Consequences and Implications
  The risks associated with the theft of
weapons-usable nuclear materials and/ or a fully
assembled nuclear device are well recognized. A
clandestine fission explosive could kill on the
order of the same number of people as died at
Hiroshima or Nagasaki. (Various accounts give the
dead as approximately 70,000 and 40,000,
respectively, within the first thirty days of the
bombings, with deaths resulting from injuries or
radiation-induced cancer occurring for extended
periods thereafter.25) This would be a calamity of
awesome scale. An additional risk is the potential
for triggering a larger nuclear war.
  The risks associated with the intentional
destruction of nuclear energy facilities are not
so well appreciated. Not generally recognized is
that the potential consequences of sabotage of a
power reactor are not so different from those of a
clandestine fission explosive. In fact, one of the
arguments raised (successfully) against publishing
revised Atomic Energy Commission (AEC) casualty
estimates for severe reactor accidents in the
mid-1960s was precisely that point: the
comparability of potential casualties from a
severe reactor incident and an atomic weapon
explosion.

  In the mid-1960s, Brookhaven National Laboratory
(BNL) was asked by the AEC to assess the potential
consequences of severe reactor accidents in
preparation for congressional consideration of
extending the Price-Anderson nuclear liability
legislation, given the considerably larger
reactors then being built. The BNL study concluded
that a large accident could result in as many as
45,000 deaths, significant radioactivity levels
extending over an area of 10,000 to 100,000 square
kilometers (the famous conclusion about
contaminating an area the size of the state of
Pennsylvania), thyroid dose levels greater than
the prescribed limits of the Federal Radiation
Council extending beyond 1,000 kilometers, and $17
billion in damage.26 AEC memoranda pointed to the
"dangers of publishing" these conclusions and
advised against their release, a prime reason
being that "the results of the hypothetical BNL
accident are more severe than those equivalent to
a good sized weapon and this correlation can
readily be made by experts if the BNL results are
published.27

  Subsequent site-specific estimates of severe
incidents at nuclear power reactors have produced
even larger casualty estimates. For example, an
NRC environmental impact statement for the San
Onofre nuclear powerplant near Los Angeles
estimated up to 130,000 acute fatalities, plus
300,000 latent cancers and 600,000 genetic
effects. The cost of off-site mitigating actions
was estimated at $35 billion.28

  Some argue that the accidental combination of
failures necessary to produce such massive
consequences is highly unlikely. Even if
true---and it is a matter hotly disputed in
nuclear safety circles---that does not mean it
could not happen intentionally. PRAs provide
something of a manual for would-be saboteurs
intent on creating the largest effect.29

  Attacks on reactors may have an escalatory
effect as well. As Bennett Ramberg, perhaps the
leading scholar on the subject, has argued,
attacks on nuclear reactors with conventional
weapons may provide nonnuclear nations or
subnational groups a near-nuclear capability.30 A
power reactor contains about 1,000 times the
long-lived radioactivity of a Hiroshima bomb. use
of conventional attacks on nuclear energy
facilities as a form of radiological warfare may
provide the escalatory link between conventional
attack and nuclear response.

  Thus, nuclear terrorism aimed at the sabotage of
nuclear energy facilities and nuclear terrorism
involving clandestine fission explosives may be
comparably destructive.


  Conclusions and Recommendations
  Nuclear terrorism in the form of the theft of
weapons-usable nuclear materials or sabotage of
nuclear facilities poses substantial societal
risks, particularly in an age of escalating
terrorism. Protection against these forms of
nuclear terrorism is only as strong as the weakest
links in the nuclear security chain. Two of the
weakest links at present are the dangers
associated with truck bombs and insiders.
Regulatory agencies do not appear to be focusing
on the weak links in the chain but rather on those
problems for which the solutions are cheap and
easy. Unfortunately, the major contributors to
nuclear terrorism risks are generally not
conducive to solutions that are either cheap or
easy. Doubly unfortunate is that deferring action
on the central contributors to nuclear terrorism
risks makes the probability of such catastrophic
events considerably more likely.
  What should be done? A nonexhaustive list
includes a number of policy recommendations.

  First, revise the decade-old design basis threat
regulations ( 10 CFR 73.1 ) to include
consideration of vehicular bombs and attacking
groups considerably larger and more sophisticated
than the current, unrealistically modest
three-and-one threat, which assumes attackers
capable of acting only as a single team and
traveling only on foot.31

  Second, repeal the two-decades-old regulation
(10 CFR 50.13) prohibiting consideration in
licensing and regulatory matters of potential
sabotage by "enemies of the United States, whether
a foreign government or other person."

  Third, reverse the 1984 directive sent by NRC
staff to the regional inspection and enforcement
offices ordering them to stop inspection and
enforcement activities related to sabotage
protection requirements at research reactors,
issued despite a decision by the commissioners
refusing a staff request to repeal the regulation
requiring such protection.

  Fourth, tighten insider protection requirements:
forgo consideration of vital islands, institute
and enforce a strict two-person rule, require
protection against more than one insider,
significantly increase the penalties for viola-
tions of access controls, and make all insider
requirements mandatory reg- ulations rather than
industry-supervised guidelines.

  Fifth, require substantial sabotage-resistant
design features as a condition for construction
permits for any new nuclear plants and for
approval of any standardized reactor design.

  Sixth, make regulations consistent across
agencies. It is of questionable logic that DOE
reactors should be required to protect against
truck bombs but NRC reactors not; that shipments
of Canadian-origin Taiwanese spent fuel across the
United States under DOE jurisdiction not be
required to have security, whereas NRC-supervised
shipments must; and that highly enriched,
weapons-grade uranium at university reactors is
exempt from the security requirements that the
same material must meet if located at other fuel
cycle facilities.

  Seventh, expeditiously remove all highly
enriched uranium from NRC- licensed research
reactors and replace it with low enriched uranium.
Despite the new NRC rule, resistance from NRC
staff and from the DOE is likely to slow the
process substantially. The provision in the
regulation that the DOE must certify the
availability of funding to pay for all conversion
costs, including those of commercial reactors,
means that Congress must continue annually to
appropriate the funds and the DOE must spend those
funds as intended. Until the conversions are
completed, the security requirement in 10 CFR
73.67 must be changed from a posttheft detection
and reporting requirement to a genuine theft
prevention standard.

  Eighth, require all DOE research reactors to
convert to low enriched uranium and stop all
shipments of highly enriched uranium abroad now
that low enriched uranium replacement fuels are
available. Conversion of research reactors
worldwide would remove hundreds of formula
quantities of highly enriched uranium from
approximately 150 sites in dozens of countries.

  Ninth, clarify the law regarding the right of
security forces at nuclear facilities to use
deadly force. Even the guard force at the Lawrence
Livermore National Laboratory is reportedly
uncertain whether it is legally permitted to use
lethal force.32 The guards are employed by the
University of California, a state institution that
operates the lab for the DOE and whose employees
are prohibited from using lethal force. However,
the laboratory at which the guards are stationed
is a federal installation where, under guidelines
established in 1985, lethal force would normally
be permitted if necessary to prevent the theft of
plutonium. The matter is even more unclear at
commercial power reactors, which are generally not
located at federal installations. Currently guards
at some of these nuclear plants have informed NRC
inspectors that if an attack were directed against
their facility, they would not resist it because
of uncertainty as to whether they would thereafter
be held to have used lethal force illegally.

  Tenth, the most important change necessary is a
change in attitude and personnel on the part of
the nuclear industry and its regulators. The
current extraordinary pressures for deregulation
of the nuclear industry in the long run can only
work against the interests of both the industry
and the public. Regulators and those they regulate
must take security far more seriously. Troubling
issues such as the truck bomb and insider threats
can no longer be dealt with by sending them back
for further research or by asking for voluntary
compliance with nonbinding guidelines. The
complaisance within some circles of the NRC, the
DOE, and the nuclear industry cannot be permitted
to continue, given the current nature of the
threat. It is hard to understand, for example, why
the S site at Los Alamos was permitted to continue
operating for four years with grossly inadequate
security and despite repeated critical safeguards
reviews, culminating in one where the facility
failed three out of three security tests. In two
of the simulations, terrorists would have gotten
away with weapons-grade plutonium; in the third,
they would have successfully obtained an unlocked
nuclear test device constructed for the Nevada
test site that could have been detonated within
hours of its theft.33 When failures of this sort
are detected, the responsible parties should be
rapidly removed from their posts, and the same
should be true for the regulators who fail
strictly to enforce the regulations. New officials
who are serious about the risks of nuclear
terrorism and the need to protect adequately
against its occurrence are needed at the NRC and
DOE and within the nuclear industry.

  Last, proposals to reduce the size of the
emergency planning zones (EPZs) around nuclear
power plants by 95 percent should be denied.
Whatever the merits of the claims by the nuclear
industry of a reduced source term in nuclear
accidents---and they seem questionable at
best---the claims do not apply to sabotage,
particularly in situations in which early
containment failure is the aim. EPZs should be
based on the distances at which radiation levels
would exceed federal protective action guidelines
for the worst possible intentional or accidental
destruction of a reactor. As a society, the United
States needs to take considerably greater measures
to reduce the likelihood of reactor destruction.
It also needs, however, to have workable emergency
plans in place in case those measures fail.





--------------------------------------------------
----------------------------

  Return to Nuclear Terrorism Page NCI Home Page




--------------------------------------------------
----------------------------


  Notes
  1. For more detail, see Daniel Hirsch, Stephanie
Murphy, and Bennett Ramberg, "The Failure to
Provide Adequate Protection against Nuclear
Terrorism," Stevenson Program on Nuclear Policy,
Santa Cruz, Cal., December 1985, printed in a
slightly different version as "Protecting Reactors
from Terrorists," Bulletin of the Atomic
Scientists 42 (March 1986). See also "Nuclear
Terrorism: A Growing Threat," report presented by
the same authors in support of testimony before
the Safeguards and Security Subcommittee of the
NRC's Advisory Committee on Reactor Safeguards,
May 7, 1985. The contributions by Ms. Murphy and
Dr. Ramberg to the research on which this study is
based are gratefully acknowledged.Back to document
  2. NRC staff assert that research reactors are
not required to provide protection against theft
of weapons-grade uranium, merely posttheft
detection and reporting, and need have no sabotage
protection whatsoever. These assertions have been
quite controversial. The NRC's Atomic Safety and
Licensing Board, for example, has ruled that
protection against sabotage is required, the NRC
staff position on the issue being at odds with NRC
regulations and case law. NRC staff subsequently
requested that the NRC commissioners eliminate the
sabotage protection regulation, a request that was
denied. The staff has nevertheless unilaterally
directed its inspectors to cease inspection and
enforcement activities related to sabotage
protection at research reactors.Back to document

  3. NRC,"Amendments to 10 CFR Part 73 to Specify
Measures for Physical Pro- tection of Nuclear
Power Reactors from Industrial Sabotage and to
Provide Clarifi- cation of the Applicability of
73.50 to Nuclear Reactors," SECY-76-242
(Washington, D.C., April 26, 1976), encl. A, p.
4.Back to document

  4. NRC, "NRC Staff Suggests Licensees Should
Review Vehicle Access Proce- dures," NRC press
release no. 84-18 (Washington, D.C., February 6,
1984).Back to document

  5. See internal memorandum, Robert F. Burnett,
director, Division of Safeguards, Office of
Nuclear Material Safety and Safeguards (NMSS), to
George W. McCorkle, chief, Power Reactor SG
Licensing Branch, Division of Safeguards, NMSS,
"Design Basis Threat," January 27, 1984, NRC,
Washington, D.C., obtained under the Freedom of
Information Act.Back to document

  6. See internal memorandum, Robert F. Burnett,
director, Division of Safeguards, NMSS, to George
W. McCorkle, chief, Power Reactor SG Licensing
Branch, Division of Safeguards, NMSS, "Design
Basis Threat," April 26, 1984, NRC, Washington,
D.C., obtained under the Freedom of Information
Act.Back to document

  7. NRC, "Statement of Work: Investigation of
'Truck Bomb' Threat at Nuclear Facilities," n.d.,
document obtained under the Freedom of Information
Act.Back to document

  8. From 'Weekly Information Report to the NRC
Commissioners," April 20, 1984, enclosure E,
p.-3.Back to document

  9. See the transcript of the meeting of the ACRS
Subcommittee on Safeguards and Security, May 7,
1985, during my testimony. The ACRS subsequently
recom- mended against revising the design basis
threat regulations to include consideration of
vehicular bombs. See "ACRS Comments on Provisions
for Protection against Sab- otage," (Washington,
D.C.: NRC, July 17, 1985).Back to document

  10. This point was made rather explicitly in an
internal NRC memorandum that discussed reasons why
NRC staff opposed upgrading security regulations
to require nuclear powerplants to undertake truck
bomb protective measures or contingency planning.
In the memorandum, obtained under the Freedom of
Infommation Act, the director of the NRC's
Division of Safeguards argues succinctly that
"protection against truck bombs should not be a
responsibility of commercial entities." See
memorandum, Robert F. 8umett, director, Division
of Safeguards, NMSS, to John G. Davis, director,
NMSS, "Truck Bomb Threat," August 14, 1984.Back to
document

  11. See ACRS Safeguards and Security
Subcommittee transcript.Back to document

  12. I am indebted to Steve Sholly of MHB
Technical Associates for identifying the first
three examples.Back to document

  13. See NRC, "Report to Congress on Abnormal
Occurrences, July-September 1981," NUREG-0090,
vol. 4, no. 3 (Washington, D.C.,January 1982); NRC
inspection report 50-334/81-16 for the Beaver
Valley power station, December 10, 1981; NRC,
"Summary of Incidents That May Have Involved
Deliberate Acts Directed against Plant Equipment
in Vital Areas of Operating Reactors (1980-1982),"
attachment to letter from then NRC Chaimman
Nunzio ). Palladino to Congressman Edward J.
Markey, February 7, 1983.Back to document

  14. NRC, "Summary of Incidents."Back to document

  15. Ibid.Back to document

  16. See S. A. Mullen,JJ. Davidson, and H.B.
Jones, Jr., Potential Threat to Licensed Nuclear
Activities from Insiders (Insider Study),
NUREG-0703 (Washington, D.C.: Office of Nuclear
Material Safety and Safeguards, U.S. Nuclear
Regulatory Commission, July 1980).Back to document

  17. Ibid.Back to document

  18. Ibid.Back to document

  19. See, for example, Steve Weisman and Herbert
Krosney, The Islamic Bomb (New York: Times Books,
1981).Back to document

  20. See lnside NRC, February 6, 1984, p. 17.Back
to document

  21. See Sheryl A. Massaro, Office for Analysis
and Evaluation of Operational Data, U.S. Nuclear
Regulatory Commission, "Power Reactor Events:
March-April 1983," NUREG/BR-0051, vol. 5, no. 2
(Washington, D.C., October 1983); Office for
Analysis and Evaluation of Operational Data, U.S.
Nuclear Regulatory Commission, "Report to Congress
on Abnormal Occurrences, April-June 1983,"
NUREG-0090, vol. 6, no. 2 (Washington, D.C.,
November 1983); and Florida Power and Light
Company, "Re- portable Occurrence Report
250-83-07," Turkey Point nuclear plant, May 3,
1983.1 am grateful to Steve Sholly for pointing
out the significance of the Turkey Point
event.Back to document

  22. Inside NRC, March 17, 1986, pp. 2-3.Back to
document

  23. Ibid.Back to document

  24. See ACRS transcript.Back to document

  25. See Samuel Glasstone and Philip Dolan, The
Effects of Nuclear Weapons (Washington, D.C.: U.S.
Department of Defense, 1977); J. Carson Mark,
"Nuclear Weapons: Characteristics and
Capabilities," in The Final Epidemic: Physicians
and Scientists on Nuclear War, ed. Ruth Adams and
Susan Cullen (Chicago: University of Chicago
Press, 1981).Back to document

  26. For a discussion of the Brookhaven study,
see Henry W. Kendall, Nuclear Power Risks
(Cambridge, Mass.: Union of Concerned Scientists,
1975), pp. 35-36; Daniel Ford, The Cult of the
Atom (New York: Simon and Schuster, 1982, 1984),
pp. 67-82. See also "Minutes of Steering Committee
on Revision of WASH-740-Decem- ber 16, 1964," as
well as the memorandum of January 28, 1965, for
U.M. Stacbler, Office of the Assistant General
Manager for Reactors, from Stanley Szawlewicz,
chief, Research and Development Branch, Division
of Reactor Development and Technology, "Trip
Report-Meeting of the Steering Committee on the
Revision of WASH-740 The- oretical Possibilities
and Consequences of Major Accidents," both
documents obtained by the Union of Concerned
Scientists pursuant to the Freedom of Information
Act.Back to document

  27. See memorandum of November 13, 1964, for
U.M. Stacbler from Stanley Szawlewicz, "Discussion
with BNL Staff on the Revision of WASH-740,"
obtained by the Union of Concerned Scientists
pursuant to the Freedom of Information Act.Back to
document

  28. Supplement to Draft Environmental Statement,
San Onofre Units 2 and 3, NUREG-0490 (Washington,
D.C.: NRC, January 1981).Back to document

  29. In the last several years, representatives
of the nuclear industry have made a number of
claims that nuclear accident source
terms---estimates of the amount of radioactivity
that could be released in severe
accidents---should be reduced by orders of
magnitude across the board. The technical bases
for these claims have been roundly criticized,
particularly by a panel of the American Physical
Society. See R Wilson et al., "Report to the
American Physical Society of the Study Group on
Radionuclide Release from Severe Accidents at
Nuclear Power Plants," Reviews of Modern Physics
57, 3, pt. 11 (July 1985). See also Daniel Hirsch,
"The NRC's Reassessment of Con- sequences of
Catastrophic Nuclear Accidents," Stevenson Program
on Nuclear Policy, Santa Cruz, Ca., January 1986,
and my testimony before the NRC commissioners,
April 3, 1985. A number of recent empirical
studies have called into question the funda-
mental premise of the reduced source term claims:
that radioiodine is released as cesium iodide
rather than elemental iodine. Furthermore,
tremendous uncertainty exists regarding the
adequacy of containment performance during severe
accidents. However, even were the claims for
accidental releases to hold up, which now appears
quite unlikely, this fact would not make much
difference regarding risk estimates for sabotage
of nuclear facilities. The reason is that much of
the hoped-for reduction in the estimated
radioactivity release from accidents is based on
the assumption that containments fail much later
than previously thought, during which time it is
asserted that radionuclides would settle out in
the containment. Saboteurs, however, have it in
their power to ensure early containment failure
and thus very large radionuclide releases to the
environment.Back to document

  30. See Bennett Ramberg, Destruction of Nuclear
Energy Facilities in War: The Problem and the
Implications (Lexington, Mass.: Lexington Books,
1980) reissued in paperback as Nuclear Power
Plants as Weapons for the Enemy: An Unrecognized
Military Peril (Berkeley: University of California
Press, 1984). Ramberg estimates casualties
associated with intentional destruction of a power
reactor as ranging up to 60,000 deaths,450,000
cases of thyroid nodules, temporary agricultural
restrictions on 175,000 square miles of land, and
decontamination or long-term restrictions on the
occupation of 5,300 square miles, depending on the
nature of the destruction produced, the location
of the reactor, and weather conditions.Back to
document

  31. The lack of realism in this regulatory
threat basis was underscored recently by a serious
sabotage attempt at the Palo Verde nuclear plant
in Arizona. A group of attackers successfully and
skillfully disabled three of four off-site power
sources for the plant, each located about 55 miles
from the plant. Since the transmission lines
converge on the site from four different
directions and since the power loss for each line
was accomplished within a few minutes of each
other, it appears to have been a coordinated
effort of people operating as several teams,
probably with vehicles, and perhaps utilizing in
excess of three people. In other words, the Palo
Verde attempted sabotage event exceeded the
maximum threat to a nuclear power plant deemed
credible by current NRC regulations. Until the
regulations are made more realisdc, no U.S. plant
is required to protect against such an incident
because it goes beyond the official design basis
threat. For a discussion of the Palo Verde event,
see "Suspected Sabotage: Loss of Three of Four
Offsite Power Sources," Preliminary Notification
of Safeguards Event, PNS-V-86-03 (Washington,
D.C.: NRC, May 15, 1986).Back to document

  32. See "Security Conflict at Lab: Rules Vary on
Use of Deadly Force," San Jose Mercury News,
January 24, 1986.Back to document

  33. See Congressman John Dingel to DOE Secretary
Donald Hodel, May 7, 1984.Back to document





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To: doewatch@yahoogroups.com, Downwinders@onelist.com
Subject: [DOEWatch] Sitting ducks? Porous security makes nuclear power plants inviting targets

Source:
<A
HREF="http://www.pittsburgpost-gazette.com/healthscience/20010917nuclear0917p2
.asp
">
http://www.pittsburgpost-gazette.com/healthscience/20010917nuclear0917p2.asp
</A>
==========================================================

Sitting ducks? Porous security makes nuclear power plants inviting targets

September 17, 2001

By Don Hopey, Post-Gazette Staff Writer

In February 1993 -- 19 days before militant Muslim terrorists first attacked
the World Trade Center in New York City by exploding bombs in its underground
parking garage -- other terrorists associated with that group practiced a
nighttime mock assault on an electric substation in Perry County, 30 miles
west of the Three Mile Island Nuclear power plant in Harrisburg.

In an unrelated incident that same 1993 weekend, an intruder deliberately
crashed a car through a door at TMI's turbine building, eventually stopping
63 feet inside the building.

'Highest level' security

In the wake of terrorist attacks that toppled the World Trade Center
buildings in New York City and gouged a hole into the Pentagon in Washington,
D.C., security was tightened at the 103 nuclear power plants in the United
States, including Beaver Valley, Three Mile Island and three others in
Pennsylvania.

The Nuclear Regulatory Commission recommended that the power plants increase
security to the "highest level," details of which are classified.

"While there's been no credible general or specific threats," Diane Screnci,
a spokeswoman for the NRC, said, "the recommendation was considered prudent,
given the acts of terrorism."

And Pennsylvania State Police were deployed as a precaution at the entrances
to Beaver Valley Power Station in Shippingport, 22 miles northwest of
Pittsburgh; Three Mile Island near Harrisburg; Limerick in Montgomery County;
Susquehanna/PPL Electric in Luzerne County and the Peach Bottom Power Station
in York County.

But that response is not good enough for Three Mile Island Alert, a citizen's
nuclear watchdog group formed in 1977. It claims that nuclear power plants
remain extremely vulnerable to terrorist attacks.

"We are highly critical of the NRC for just recommending and not ordering all
nuclear plants to increase security to the highest level," said Scott
Portzline, chairman of Alert's security committee.

Coincidental to the terrorist attacks last week, Portzline said Alert has
formally petitioned the NRC to issue a rule directing utilities to post
guards at the entrances of their nuclear power stations.

The absence of such a rule makes the nuclear plants "soft targets" for
terrorists, he contended.

"Posting armed guards at the entrances of nuclear power plants serves as a
physical deterrent, would 'harden' those sites and demonstrates to local
communities that the NRC and the nuclear industry are serious about public
health and safety," Portzline said. "It's hard to imagine that nuclear plant
entrances remain unguarded in the 21st century.

Not enough

Although U.S. nuclear power plants probably have the world's best safeguards,
Alert is not the only group that says they need to get much better and fast.

Physicians for Social Responsibility has called nuclear power plants "land
mines waiting to be stepped upon."

And the Nuclear Control Institute, a Washington, D.C.-based nuclear
non-proliferation group, said that nuclear power plants are vulnerable to
terrorists, and a successful attack that breaches a reactor's containment
systems could cause severe panic.

"Potentially, it could be many times worse than what we've seen [in New York]
because it could result in radiation and fallout over a vast area that would
have a devastating economic effect," said Tom Clements, head of the Institute.

While a thermonuclear explosion is not possible, a powerful steam explosion
in a plant's containment building could disperse enormous amounts of
radioactive particles into the air.

Clements said nuclear facilities are just as vulnerable to airborne threats
-- from missiles or crashing jetliners -- as was the World Trade Center or
the Pentagon.

"Aerial attack is not really considered," he said, "and we think that the
plants are vulnerable, even though they have a thick containment dome."

In 1993, Portzline, who has testified before the NRC and U.S. Senate on
nuclear power plant issues, rented a small plane and flew at low altitudes
over the TMI containment dome and the adjacent Susquehanna River.

"I wanted to demonstrate the possibility of an air attack," he said. "I
believe a boat attack is also possible."

Rings of protection

Nuclear plants have three security zones -- the outermost "owner-controlled
area," the middle "protected area," and the innermost "vital area," where
safety systems and fuel rods are located.

Nuclear power plants are required to employ site protection officers who are
usually stationed in the protected area. That's also where truck bomb
barriers -- required by the NRC only after the 1993 "vehicle intrusion" at
TMI -- can be found.

Portzline said most of those truck bomb barriers, including 12 of 14
installed at TMI in 1994, are so close to the vital areas of nuclear power
plants that an Oklahoma City-sized truck bomb could cause a catastrophe. One
of those barriers at TMI is only 10 feet from a vital area building.

In addition, Portzline said, security at TMI's main entrance has decreased
over the years. During the 1970s, the north entrance was guarded and vehicles
were required to stop for a credentials check before entering the site. In
1993, a truck bomb barrier was installed, but it is unmanned and is left open
more than half the time. A parking garage-style barrier lifts automatically
to approaching vehicles.

"I don't think they're doing better," he said. "TMI's new owners have reduced
the guard force. I think they're doing a lot of cost cutting."

"We meet or exceed all federal requirements for security," said Ralph
DeSantis, a spokesman for Exelon Nuclear, co-owner of TMI with AmerGen Energy
Co. "We are in a heightened state of security awareness and are in regular
contact with the NRC."

DeSantis said the containment buildings that house the reactor and equipment
are "robust, sturdy structures" built with 4-foot-thick reinforced concrete
walls to withstand hurricanes, airborne objects and airplane impacts.

He said extending security to the entrances in the owner-controlled area has
been an issue at many nuclear plants, but few, if any, have guards or
barriers in that outer area.

Dave Poeppelmeir, a spokesman for FirstEnergy, the Akron, Ohio-based company
that operates the Beaver Valley Nuclear Plant, said security was increased at
the plant even before the NRC issued its recommendation, but he declined to
give any details.

"We're reviewing our procedures and working with the NRC," Poeppelmeir said.
"If the NRC requires that we do something, we will meet those increased
standards, but I'm not going to get into any specifics about our security."

But Portzline said tougher security measures -- including some that would be
highly visible -- are long overdue to deter terrorists from planning to bomb
the nuclear plants.

In an eerily prophetic news release sent the day before Tuesday's terrorist
attacks, Portzline explained why TMI Alert was asking the NRC to require
entrance guards:

"The 1990s have shown that terrorism is no longer just about instilling fear
or gaining attention for a particular ideology. Some terrorists are now
seeking a large body count. Clearly, adequate protection of nuclear power
plants is a matter of national security."

=========================================================

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In the 1980's, Oak Ridge managers established a national alliance of DOE friendly supplanted activists and old DOE scientists to mislead gullible fluoride affected sick workers and communities in order to fabricate a health mystery and avoid the extreme liabilities of the fluorides health damage to uranium gas diffusion chemical plant workers and communities.

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