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Targets – Danger and Vulnerability

Spent Fuel – the danger


The “spent fuel” at Pilgrim, 2009, contains over 8 times the radiation than the core; 30 million curies of radioactive cesium-137; and other poisonous isotopes.


The total amount of radioactive cesium-137 released at Chernobyl in 1986 was less than 2.5 million curies.


Pilgrim’s spent fuel is stored in a “swimming pool” about 45 feet deep. The spent fuel is outside the primary concrete containment that is intended to protect the reactor. It is located high up in the building, an especially precarious position, with a thin roof overhead. The Project on Government Oversight (POGO) reports that a certain kind of explosive could be launched from outside the fence line into the side of the pool - the terrorists would not even have to enter the secured area. Some security guards told POGO that they estimated that a terrorist could penetrate the fence line and the spent fuel pool, in 20 to 60 seconds. 7


If the water dropped simply to the top on the assemblies in Pilgrim's densely packed pool, the spent fuel would burn. If it were to burn, NRC documents show that the fire could not be extinguished and that there is a 100% likelihood that the entire “inventory” of the spent fuel pool – i.e., over 30 million curies of radioactive cesium – would be released into the atmosphere.


The less than 2.5 million curie release at Chernobyl contaminated people, milk and land as far away as Poland; and sheep remain contaminated in Scotland today (2009) and reindeer are still contaminated in Lapland.


A 30 million curie release would contaminate an area larger than the state of Massachusetts; much of New England could be uninhabitable for many years. 


Estimates of Costs and Latent Cancers Following Releases of Cesium-137 from Pilgrim’s Spent-Fuel Pool


10% release C-137

100% release C-137

Cost (billions)

$105-$175 billion

$342-$488 Billion

Latent Cancers



It is important to note that the curve from a 10% to 100% release is not a straight line. A smaller per-cent release of Cs-137 would be proportionately less but still very significant. And, most important, the consequence analysis by Dr. Jan Beyea focused solely on Cs-137 and only on cancer. We know that other dangerous isotopes would be released in a severe accident and other health effects expected.

[Source: The Massachusetts Attorney General’s Request for a Hearing and Petition for Leave to Intervene With respect to Entergy Nuclear Operations Inc.’s Application for Renewal of the Pilgrim Nuclear Power Plants Operating License and Petition for Backfit Order Requiring New Design features to Protect Against Spent Fuel Pool Accidents, Docket No. 50-293, May 26, 2006 includes a Report to The Massachusetts Attorney General On The Potential Consequences Of A Spent Fuel Pool Fire At The Pilgrim Or Vermont Yankee Nuclear Plant, Jan Beyea, PhD., May 25, 2006. NRC Document library at: Adams Accession Number ML061630088]


Reactor Core – the danger 


A nuclear meltdown, exposing the fuel rods inside the reactor core can be accomplished by breaching the primary containment wall. A jet, smaller than that used in the Twin Towers attack, would do. The containment walls are 4 to 5 feet thick at the base and taper down to 1.5 to 2 feet thick at the top. A 1974 General Electric study shows that if a nuclear plant took the kind of hit that the Pentagon took on September 11th the containment wall almost certainly would break. The GE study estimated that if a “heavy” airliner traveling at cruising speed hit the wall where the thickness is 2 feet, the chances of breaking through the wall would be 84%. At a thickness of 1.5 feet, penetration is certain. GE’s study defined “heavy” was anything more than 6.25 tons. The airliners used Sept. 11 weighed more than 150 tons. 8


The consequences (based on studies performed by Sandia National Laboratory under contract with the US Nuclear Regulatory Commission, 1982) - within the first year, 3000 early fatalities, 30,000 early injuries and over a lifetime, 23,000 cancer deaths. Peak fatal radius is 20 miles and peak injury radius is 65 miles.

Disabling Necessary Support Systems –the danger

Alternatively, a nuclear meltdown could occur by disabling secondary support, such as cutting off electrical power to a plant/spent fuel pool and disabling the backup generators, clogging or cutting off the main water supply to the plant/spent fuel pool and gaining control to the control room.

Because Pilgrim’s spent fuel pool is located inside the main reactor building, but outside primary containment, an accident in one is likely to lead to the other.

7. Nuclear Power Plant Security: Voices from Inside the Fences, September 12, 2003 Project on Government Oversight (POGO), p.9

8. Mark Golden, “POWER POINTS: Airplane Attack Exposes Nuclear Plant Myth,” Dow Jones Newswires 14-09-01, Dow Jones Newswires; 201-938-4604

Independent Spent Fuel  Storage Installations (ISFSI) - the danger

An ISFSI poses a radiological risk that is lower than the risk posed by a spent-fuel pool packed at high density. Nevertheless, options are available for reducing the risk associated with malice-induced accidents at an ISFSI. NRC refuses to consider these options in an EIS. Also, NRC attempts to hide the vulnerabilities of existing ISFSIs under a veil of secrecy.

Option to reduce risk ISFI

Options for designing an ISFSI to resist attack have been identified by Dr. Gordon Thompson as follows: "re-design of the ISFSI to use thick-walled metal casks, dispersal of the casks, and protection of the casks by berms or bunkers in a configuration such that pooling of aircraft fuel would not occur in the event of an aircraft impact".

Holtec has developed a design for a new ISFSI storage module that is said to be more robust against attack than present modules. The new module is the HI-STORM 100U module, which would employ the same MPC as is used in the present Holtec modules. For most of its height, the 100U module would be underground. Holtec has described the robustness of the 100U module as follows, "Release of radioactivity from the HI-STORM 100U by any mechanical means (crashing aircraft, missile, etc.) is virtually impossible. The only access path into the cavity for a missile is vertically downward, which is guarded by an arched, concrete-fortified steel lid weighing in excess of 10 tons. The lid design, at present configured to easily thwart a crashing aircraft, can be further buttressed to withstand more severe battlefield weapons, if required in the future for homeland security considerations. The lid is engineered to be conveniently replaceable by a later model, if the potency of threat is deemed to escalate to levels that are considered non-credible today."

[Holtec International,"The HI-STORM 100 Storage System", accessed at <> on  June 17, 2007. (Holtec FSAR) Holtec International, Final Safety Analysis Report for the Holtec International Storage and Transfer Operation Reinforced Module Cask System (HI-STORM 100 Cask System),NRC Docket No. 72-1014, Holtec Report HI-2002444 (Holtec, undated). ]


C-10 Research and Education Foundation Petition for NRC Rulemaking to Upgrade Interim Dry Cask Storage Code Requirements -Submit Comments by May 18, 2009

The C-10 Research and Education Foundation Inc. Petition for NRC Rulemaking to Upgrade Interim Dry Cask Storage Code Requirements

[Federal Register: March 3, 2009 (Volume 74, Number 40)]

[Proposed Rules]          

[Page 9178-9180]

SUMMARY: The Nuclear Regulatory Commission (NRC) has received and requests public comment on a petition for rulemaking dated November 24, 2008, filed by the C-10 Research and Education Foundation, Inc. (petitioner). The petition was docketed by the NRC and has been assigned Docket No. PRM-72-6. The petitioner is requesting that the NRC amend the regulations that govern licensing requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, and reactor-related greater than class C waste. The petitioner believes that the current regulations do not provide sufficient requirements for safe storage of spent nuclear fuel in dry cask storage or in independent spent fuel storage installations (ISFSIs). The petitioner states that the NRC does not adequately enforce the current regulations that govern dry cask storage by allowing manufacturers, vendors, and licensees to use alternatives to the American Society of Mechanical Engineers (ASME) Code. The petitioner also states that the NRC has not specified license requirements for multiple cask designs under different expiration dates at the same ISFSI, has not adequately

considered age-related degradation of dry cask systems, and has no requirements in place to address sabotage and adverse environmental effects on ISFSIs and current and future dry cask storage systems.

DATES: Submit comments by May 18, 2009. Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or before this date.



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