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October 27, 2006

Letters to Secretary of Energy and Chairman, Nuclear Regulatory Commission, Concerning Safety Considerations in Nuclear Plant Designs

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October 27, 2006

The Honorable Samuel W. Bodman
Secretary
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585

The Honorable Dale Klein
Chairman
U. S. Nuclear Regulatory Commission
One White Flint North
11555 Rockville Pike
Rockville, Maryland 20852-2738

More than 20 years ago, the Nuclear Regulatory Commission sought advice for designing nuclear power plants to make them more secure from attack or accident. The NRC contracted with experts from the Department of Energy, specifically at Sandia National Laboratories, to study this issue. In 1981, Sandia prepared a multi-volume report entitled, "Nuclear Power Plant Design Concepts for Sabotage Protection." The report identified dozens of concepts for potential plant design changes and layout modifications for new plants that would make them more resilient against both natural disasters and intentional terrorist attacks.

The measures identified by DOE's experts included physically separating vital systems and relocating vital equipment to more protected areas. Running to hundreds of pages of analysis and detailing dozens of specific steps that could be incorporated into new nuclear plant design, the Sandia reports are a road map that anticipates the very security concerns that have come to the fore since 9/11.

In 1982, a second report was also prepared for the NRC by the Department of Energy's Argonne National Laboratory titled, "Evaluation of Aircraft Crash Hazards Analyses for Nuclear Power Plants." This study concluded that aircraft crashes might subject nuclear plants to "numerous multiple failures" that could lead to "total meltdown" even without damaging the containment structure. The report did not address plant design changes, but clearly showed that design changes could help mitigate the potential impact of aircraft hazards at nuclear power plants.

Since those reports were completed, the United States government has spent billions of dollars on new plant design work. Much of the research and development of new nuclear power plants has been conducted by the Department of Energy. Although no new plants have been licensed for construction since 1978, many utilities have expressed a desire to construct such plants and the NRC has approved the design of several new reactors since the Sandia studies were completed.

I want to know what steps have been taken by the Department of Energy [the NRC] to incorporate the lessons of these prior studies into these new systems. In the wake of 9/11 it would be unconscionable to find that none or few of the design improvements, a generation old, have been incorporated into planning, design or licensing standards....

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