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1.1.2(l) Containment structures for Catawba and McGuire Units have not been adequately analyzed.  An Associated Press story dated October 24, 2001 has provided new information to the Petitioner regarding the unanalyzed condition and potential vulnerability of the Catawba and McGuire containment structures. The news story states that the NRC has known since 1982 that American nuclear power plants were susceptible to jetliner crash.  [Hardcopy Exhibit 1 Associated Press article, “Nuclear Liability Report Left Public,” October 24, 2001.}

In the 119-page report prepared by Argonne National Laboratory for the NRC analyzing aircraft crash into nuclear power plants, the government lab recommended that the NRC and nuclear industry pay more attention to thoroughly analyze and evaluate the effect of explosion and fire from airline crash on nuclear safety. [Provided in hard copy Exhibit , AP story]

As a result the applicant has not provide a complete application that raises a number of unreviewed issues as a result of unanalyzed structure, systems and components. Given the clear and present danger, the Duke Energy license renewal application does not provide a complete or reasonable analysis and evaluation on containment structures for the Catawba and McGuire units with regard to impact by postulated external hazard (i.e. aircraft).

As reported in the AP story, the Argonne National Laboratory report to the NRC described the exact speed at which a jetliner would begin to transfer its force into the primary containment and interior structure of a nuclear reactor. The government lab provided NRC and industry with a description of how the concrete containment would spall, scab and eventually perforate depending on the aircraft velocity. “The breaching of some of the plants’ concrete barriers may often be tantamount to a release of radioactivity.” [Hard copy EXHIBIT 1: AP Story]

By letter from Commissioner Richard Merserve to Congressman Edward Markey dated of October 16, 2001 in responding to questions regarding design criteria for protection of against an aircraft crash, the NRC has established that the Catawba and McGuire containment structures have not been analyzed and evaluated for such an attack. “The NRC has no criterion that requires nuclear power plant containment vessels to be designed to survive the crash of a Boeing 747.” [NRC Commissioner Richard Meserve Letter to Congressman Edward Markey , October 16, 2001,provided in hard copy Exhibit 2,  p. 4]

In fact, the NRC has not adequately or reasonably evaluated the very real threat that exists today.  The NRC published NUREG/CR-5042, “Evaluation of External Hazards on Nuclear Power Plant in the United States,” in December 1987 where at Section 6.4 it provides a very limited analysis of aviation accidents on nuclear power plant safety. A “large” aircraft as defined by the NRC report weighs 12,500 pounds (approximately 6 tons) even though the report on page 6-24 observed that a loaded Boeing 727-200 has a maximum take-off weight of 209,500 pounds (approximately 100 tons). The Boeing –767 used by terrorists to effectively destroy the World Trade Center had a total take off weight of 150 tons. The disparity of analysis between a the consequences of a six ton aircraft and a 150 ton aircraft is too great to be left unevaluated for consequence to the public health and safety.  [Hardcopy Exhibit 3, NUREG/CR-5042, “Evaluation of External Hazards to Nuclear Power Plants in the United States, December

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