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In addition, the Catawba and McGuire plants have unique “ice condensor” containments that may make them vulnerable to sabotage or terrorism in a unique way, and also subject to particular Severe Accident Mitigation Alternatives (“SAMA’s) for purposes of minimizing the impacts of sabotage and terrorism.  As discussed in NIRS’s Contention 1.1.4 for example (See Contentions of Nuclear Information and Resource Service (November 29, 2001), the impacts of terrorism or sabotage may be mitigated by the installation of a dedicated electric line from the hydroelectric generating dams next to each reactor site.  

Because NEPA is “action-forcing,” the NRC will be compelled to evaluate the vulnerability of Catawba and McGuire plants to terrorism and sabotage now, when design changes can be more easily made, rather than waiting for new security regulations that may take years to develop.  Thus, for instance, whether or not the Commission finishes its “top-to-bottom” review of security measures before licenses are renewed for the Catawba and McGuire plants, NEPA will have required the NRC to take a “hard look” at alternative measures.  See Maryland National Park and Planning Commission v. U.S. Postal Service, 487 F.2d 1029, 1040 (D.C. Cir. 1973).  The hearing granted by the ASLB presents a vital and essential means for assuring that the NRC fulfills its obligations for environmental protection under the National Environmental Policy Act.  

Accordingly, NIRS Contention 1.1.2 should be remanded to the ASLB for a hearing.  In addition, the Commission should also instruct the ASLB to permit consideration of the impacts of terrorism and sabotage with respect to the litigation of SAMA’s in BREDL / NIRS Contention 2 (the consolidated contention of Blue Ridge Environmental Defense League and Nuclear Information and Resource Service admitted by ASLB in LBP-02-04).  

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