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significant information regarding the impacts of license renewal of which the applicant is aware.” Certainly a major direct attack on a nuclear reactor site would result in environmental impacts, and as stated above, there is awareness of this issue.

Certainly also this issue pertains to license renewal since the duration that a target exists impacts the probability and risk that it will be hit. This is especially true since there is ample evidence showing that not only is there an increase in terrorist activity directed at the United States, but there is an overall acceleration in terrorism, and targeting of nuclear facilities in particular. [Footnote:  Since September 11 there have been hundreds of articles on terrorism, many of which address nuclear installations. The appended Exhibits document has a selection of these labeled Exhibit 1.1.2. the intent is not to be exhaustive, rather, representative.]

This means that the overall risks of an attack are increasing over time. As stated in NRC Regulations (10CFR54.31(c)  “A renewed license will become effective immediately upon its issuance, thereby superseding the operating license previously in effect.” Therefore the renewal period commences as soon as the renewal is granted.

Lacking guidance from the Commission, NIRS contends that an adequate security analysis for extending the operating licenses of these reactors must include following possibilities in order to address increasing risks to our members:

1.1.2(a) The vulnerability of the applicant units to air assaults is no longer theoretical: it is frighteningly real. (Indeed, the McGuire reactors are on the approach to the Charlotte airport. NIRS staff has been commercial passengers on very low flight directly over the McGuire site on approach to Charlotte, NC from Augusta, GA. US Airways was the carrier.) 1.1.2(b) The applicant’s units security analysis does not consider truck bombs of the scale demonstrated by the attack upon the federal building in Oklahoma City.  A significantly larger amount of explosive force can be delivered by a land vehicle than is postulated under the Design Basis Threat as limited analysis for a four wheel drive vehicle no larger than a Sports Utility Vehicle. The applicants’ Environmental Report must consider larger trucks (including tractor trailers) and the associated larger explosive yields as potential weapons of sabotage in its security analysis. 1.1.2(c) Attacks via water, including the possibility of loss of the dams on Lake Norman and Lake Wylie.   The NRC and Duke have not analyzed an attack on the McGuire and Catawba nuclear power stations via acts of sabotage and terrorism directed by approach from the water.  Such an attack could focus on target sets to include the cooling systems of the reactors.  The attack could also be directed against the dams on Lake Wylie and Lake Norman.  This constitutes an unanalyzed condition for the safe operation of the reactors.   It is of particular concern for the McGuire units because of their reliance on once-through cooling systems and coolant intake inventories of over two million gallons of water per minute. A precipitous drop in the water level on Lake Norman via destruction of the dam system would seriously jeopardize the cooling system for the reactor and fuel integrity.

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