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IV.      THE ASLB ERRED IN FAILING TO INCLUDE TERRORISM AND

           SABOTAGE AS FACTORS TO BE CONSIDERED IN THE LITIGATION OF

BREDL / NIRS CONTENTION 2, REGARDING SEVERE ACCIDENT  MITIGATION ALTERNATIVES.  

The ASLB partially admitted NIRS original contentions 1.1.4 and 1.1.5 in BREDL / NIRS  Contention 2, in which NIRS challenged the adequacy of Duke’s Environmental Report to address Severe Accident Mitigation Alternatives with respect to station blackout.  As discussed in the contention, NIRS believes that the risks and impacts of terrorist attacks and sabotage must be taken into account in this analysis.  

In admitting the contention, the ASLB reworded it in such a way as to completely eliminate any reference to sabotage or terrorism.  The ASLB eliminated this language without any explanation regarding its reasons.  It seems fair to surmise that the ASLB did not consider sabotage or terrorism to constitute legitimate considerations in this licensing proceeding.  For all the reasons discussed above, the ASLB was in error.  

V.CONCLUSION

The ASLB had no legal or factual basis for refusing to admit the greater portion of NIRS’s contention seeking an EIS on the impacts of sabotage and terrorist attacks on the McGuire and Catawba plants.  The contention should be remanded for litigation of all its terms.  

Respectfully submitted,

__________________________________

Mary Olson

Director of Southeast Office

Nuclear Information and Resource Service

Asheville, North Carolina

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