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1.1.2(d) Analysis of impacts of fire as well as direct physical destruction, including a jet plane recently fueled at Charlotte’s commercial airport, including impacts on combustible fire penetration seals.  This contention is more fully outlined under the Petitioner’s contention on inadequate fire barrier penetration seal analysis and fire testing. 1.1.2(e) Impacts on outside containment structures and functions including control room, off-site power service, emergency diesel generators, fuel pool, and emergency access. 1.1.2(f) Attack by multiple coordinated teams with multiple insiders in assistance.   The current Design Basis Threat unrealistically limits the applicant units station force-on-force security response capability to a small single team partially aided by a single insider limited only to providing information and not involved in active act of sabotage. 1.1.2(g) The applicant units have not analyzed and evaluated the socio-economic impact of closure of Lake Norman and / or Lake Wylie for security purposes. The Petitioner contends that new security precautions underway at other nuclear power stations must be addressed by the applicant units in context of their socio-economic impact upon communities and businesses on Lake Norman and Lake Wylie.  The Petitioner is aware that such a decision has already been made by Exelon to close all public and recreational access to Lake Clinton as a security precaution for protection of the Clinton nuclear power station.  [Footnote:  See “Up the Creek at Lake Clinton” by Mike Monson, published online at  the News-Gazette November 4, 2001 posted at http://www.news-gazette.com/ngsearch/story.cfm?number=10435 and included in appended “Exhibits” document.] 1.1.2(h) Impact of MOX fuel on attractiveness of site for attack given that unused MOX fuel made from weapons grade plutonium is attractive to those seeking weapons usable material. 1.1.2(i) Impact of MOX plutonium fuel on core breach accident scenarios whether directly from attack, or as a result of Station Blackout, factoring the findings of Dr. Edwin Lyman of the Nuclear Control Institute that a major reactor accident with weapons grade MOX in use would result in a 25% increase in latent cancer fatalities compared to the same accident with LEU fuel (http://www.nci.org/). 1.1.2(j) Impact of attractiveness of a site using MOX plutonium fuel for purposes of an attack designed to maximize human suffering and property damage. 1.1.2(k) Upgrade in the assumptions used to assess the resources available to cope with such a disaster – September 11 showed that major infrastructure pieces such as “911” were lost as a result of the attacks in New York. Analysis needs to examine possible concomitant losses from any of these attack scenarios at either reactor site. An example is analysis of catastrophic attack on the McGuire Station and possible impacts on Charlotte drinking water drawn from below Lake Norman.

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