Mandate for Securing America's Electricity Supply

Overview

As national, regional and local environmental and public interest organizations, we wish to express our profound sympathy for those affected by the terrible events of the past month. Now is the time for our country to put aside narrow and divisive interests and focus on protecting the safety of all who live in the United States.

Specifically, we recognize that nuclear power reactors pose an unacceptable threat to the security of the United States. Commercial reactors are extremely vulnerable to attack from both foreign and domestic terrorists. The sobering reality is that security of nuclear power facilities can be neither completely guaranteed nor perfectly realized.

Current security at U.S. nuclear reactors is unacceptable. Significant weaknesses in security were found at nearly one-half (47%) of U.S. commercial reactors tested in recent years. "'Significant' here means that a real attack would have put the nuclear reactor in jeopardy with the potential for core damage and a radiological release, i.e., an American Chernobyl," according to the U.S. Nuclear Regulatory Commission's (NRC) security expert. Structurally, no commercial nuclear reactor is designed to withstand the impact that destroyed the World Trade Center buildings, according to the NRC and the International Atomic Energy Commission. An attack on these facilities by truck bomb or aerial assault, or any number of other scenarios could spread lethal radiation, rendering uninhabitable an area the size of Pennsylvania, according to an analysis by the Atomic Energy Commission (now the NRC).

For these reasons, we call for the following actions to be taken by the appropriate authorities:

#1. All NRC licensees must demonstrate that their nuclear facilities are protected against radiological sabotage by meeting a significantly more comprehensive Design Basis Threat (DBT). This includes reactor operators currently holding an operating license and applicants for license extension or new construction.

A revised Design Basis Threat must both encompass currently analyzed threats from ground-based assault, and be broadened to include truck-bombs and aerial and water-borne attacks. Before receiving an operating license, a licensee must be able to demonstrate that it can guard against the revised Design Basis Threat so as to protect against core damage, a breach of reactor containment and/or damage to irradiated nuclear fuel. By definition, reactor designs that do not feature a reactor containment structure, such as the proposed Pebble Bed Modular Reactor (PBMR), must not be considered suitable for meeting any plausible Design Basis Threat. The upgraded DBT must be met through both enhanced physical security features and increased security force capabilities.

Recognizing that nuclear reactors will continue to be vulnerable targets for some time after they have permanently ceased operation (until the core has cooled and the radioactive waste has decayed) the nuclear waste that is stored must be protected from intentional air and other modes of attack. All permanent and temporary radioactive waste storage, disposal, treatment and transfer sites must meet the strengthened Design Basis Threat to protect against attacks that could have disastrous consequences.

#2. Congress must reject reauthorization of the Price Anderson Act, which limits the liability of the commercial nuclear industry. At a minimum, certain modifications must be made to the Price Anderson Act in light of the events of September 11 if Congress reauthorizes the Act. Any extension of indemnity to the operators of new or relicensed nuclear power plants and nuclear fuel cycle facilities should be made contingent upon the demonstrated ability of the licensee to protect against the revised Design Basis Threat outlined in point #1. In addition, the indemnification of U.S. Department of Energy (DOE) contractors should exclude cases of contractor gross negligence or willful misconduct.

#3. Congress must indefinitely extend the moratorium on nuclear transport and expand it to cover all highly radioactive and radiotoxic waste and materials, including commercial shipments. On September 12 and again on October 7, Energy Secretary Abraham suspended DOE nuclear shipments, acknowledging that radiological shipments are potential terrorist targets. In the long term, government agencies should shift their focus from facilitation and encouragement of nuclear transport to minimizing the amount and frequency of radioactive shipments. U.S. delegates must advocate this position when participating in United Nations and other international fora that develop or recommend international transportation standards.

#4. Congress must indefinitely shelve current proposals for centralized storage of nuclear waste. Such storage would establish additional nuclear targets without meaningfully reducing the risk at operating nuclear power plants. In addition to the dangers of transporting radioactive materials, a centralized storage facility would itself be a difficult-to-secure target. Specifically, the proposals for nuclear waste storage facilities at Yucca Mountain, Nevada, and on the Skull Valley Goshute Reservation in Utah, would irresponsibly create significant targets close to major population centers. Design proposals for both these facilities feature massive, exposed surface operations, which would establish potentially larger, highly vulnerable and more devastating targets for attack.

#5. Congress must mandate that utility-funded security operations be increased at existing nuclear reactors and maintained throughout plant life and the on-site storage of irradiated nuclear fuel. Current security at U.S. nuclear reactors is unacceptable. The NRC and the International Atomic Energy Agency have acknowledged that the containment buildings housing nuclear reactors are not designed to withstand an attack of the type and scale used against the World Trade Center and Pentagon. Since 1991, despite months of advanced warning and beefed up security forces, nearly half (47%) of U.S. nuclear power plants failed to repel small mock terrorist attacks conducted by the NRC. These exercises did not assess the full Design Basis Threat that NRC regulations require nuclear power plants to protect against. Moreover, these exercises failed to assess the ability of nuclear plants to defend against attacks by truck bomb, aerial, and water-borne assault, three likely scenarios that fall outside the current Design Basis Threat.

#6. Potassium iodide must be immediately distributed to all persons residing within a minimum of 50 miles around all nuclear reactors. While it is not a panacea, the NRC already has approved this program in concept, but has been reluctant to initiate it lest the public grasp that nuclear reactors are fundamentally unsafe. An epidemic of preventable childhood thyroid cancer has ravaged children in the Chernobyl-affected regions of Ukraine, Belarus and western Russia simply because potassium iodide was not available in the aftermath of the reactor explosion and fire. The health of thousands of people is believed to have been saved in Poland, where potassium iodide was available following the 1986 Chernobyl disaster. 

#7. The Federal Aviation Administration (FAA) must require the same or comparable security for general and commercial aviation and determine the practicality of instituting effective no-fly-zones over commercial nuclear power plants.

#8. All NRC licensees must provide a risk assessment of the survivability from terrorist attack on radiation containment and critical safety systems. 

#9. The NRC must take significant federal enforcement action, including the suspension or revocation of operating licenses, when repeated licensee failure of upgraded NRC-led security performance evaluations occurs. 

#10. All branches of government must ensure that the terrorist attacks do not result in the erosion of fundamental civil liberties. The hallmarks of our free society and our values are manifested and secured in the Bill of Rights. Therefore, it is essential that security programs and activities clearly differentiate between legitimate terrorist threats and the rights of the public to peacefully assemble, exercise free speech, organize and educate. For example, in the post-Vietnam era, government agencies and utilities engaged in widespread spying and other civil liberties abuses against those that opposed and demonstrated against the construction and operation of nuclear power plants and facilities.

#11. The mixed oxide nuclear fuel (MOX) program must be eliminated immediately. Giving the green light to a proposed commercial plutonium fuel fabrication plant in South Carolina fosters the creation of a plutonium economy and increases the likelihood of a terrorist-created catastrophe. The manufacture of MOX fuel for use in commercial U.S. nuclear reactors, establishes not only more deadly terrorist targets at the plants themselves (due to the greater amount of plutonium in the MOX fuel than current reactor fuel), but also creates thousands of transports between the fabrication site and the reactors, vulnerable to sabotage or theft. Such a project puts the trigger component of nuclear weapons into the commercial sector where it cannot adequately be protected. 

The NRC must refuse the licensing of the MOX plant and Duke Power must withdraw its reactors from the MOX program. Surplus weapons plutonium has no place as a commercial fuel and sends a dangerous message to the rest of the world that plutonium is a commodity, not a waste to be secured out of harm's way. The licensing of a plutonium fuel fabrication plant flies in the face of any government's avowal to protect its people from lethal attack or disaster.

#12. The U.S. must initiate an expedited phaseout of nuclear power, improve energy efficiency in all sectors of our economy and initiate a rapid transition to renewable electricity sources. Linked through the extensive and fragile electrical grid system, we recognize that nuclear power plants are one of the most vulnerable components of our electric power infrastructure and present the largest risk of catastrophic damage. As such, nuclear power poses an unacceptable risk to our society and environment.

The phaseout of nuclear power must take place within the context of a transition to a least-cost, environmentally sustainable national energy system, based on full exploitation of decentralized energy efficiency and renewable energy sources, available through existing technology. A distributed, sustainable energy system will provide numerous economic, public health and environmental benefits beyond reducing the terrorist threat to our nation's infrastructure. Such a transition will spur innovation and channel resources into more labor-intensive sectors of the economy, providing the nation with an engine for continued economic growth and job creation.

In conclusion, we believe that this is the direction we must take: We will either shift from our use of nuclear power to a new era of sustainable electricity production for our country, or we will remain vulnerable to our reactors and, very possibly, pay an unthinkable price. We can and must do better for our families, our country, our freedom and the planet.
 

nirsnet@nirs.org