nuclear plants not designed to withstand airplane fully loaded with fuel.

The NRC acknowledges that nuclear power plants, including the SFP (Spent Fuel Pools), were not specifically designed to withstand the impact of a large commercial airplane fully loaded with fuel.

ADAMS DOCUMENT - (Portions snipped for brevity.)
Accession No. ML022470090
http://www.nrc.gov/reading-rm.html

To:
November 1, 2002
Mr. Michael D. Kohn
National Whistleblower Center
3238 P Street, NW.
Washington, DC 20007

Your Petition dated October 24, 2001, as amended on January 27, 2002, submitted on behalf
of the National Whistleblower Center, has been reviewed by the Nuclear Regulatory
Commission (NRC) staff pursuant to Section 2.206 of Title 10 of the Code of Federal
Regulations (10 CFR 2.206). The NRC staff provided you a copy of the proposed Director’s
Decision for comment by letter dated May 16, 2002. You responded with comments by letter
dated August 10, 2002. The comments and staff response to them are included as enclosures
2 and 3 to this letter.
Your petition raised concerns about the ability of nuclear power plants to withstand the impact
of a commercial airliner, . . . . .
snip-

Based on our review, the staff has, in effect, partially granted your requests to the extent that
your concerns have been addressed by actions already taken by the NRC and other Federal
agencies since September 11, 2001. These actions include:

Orders issued by the Commission to all operating power reactor licensees on
February 25, 2002, to require that certain interim compensatory measures for security
be taken beyond that called for by current regulations.

The prompt response by Congress to strengthen aviation security under the Aviation
and Transportation Security Act of 2001.

The increased efforts by Federal agencies to identify and prevent terrorist attacks before
they occur.

control
programs, and the additional measures implemented or being considered in this area.

The research and engineering efforts underway to evaluate vulnerabilities and potential
effects of a large commercial aircraft impacting a nuclear power plant. The results of
this research will be applied, as appropriate, to strengthening the requirements for
licensees.

The remainder of your requests are denied for the reasons provided in the enclosed Director’s
Decision. Note that certain aspects cannot be made public due to their security nature.
snip-

DD-02-04
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Samuel J. Collins, Director
In the Matter of )
)
ALL NUCLEAR POWER REACTOR )
LICENSEES )
)
DIRECTOR’S DECISION UNDER 10 CFR 2.206
snip-

The Petitioner stated that no commercial nuclear power plant located in the United
States can withstand the impact of a large commercial airliner. The Petitioner also stated that
the NRC intentionally misled the public about its failure to adequately consider risks associated
with an air assault on a nuclear facility.

In addition to the steps taken by the NRC to strengthen nuclear power plant security
through the February 25, 2002, Orders, previously discussed, other actions have been taken to
address aviation security at nuclear power plants. For example, the Commission believes that
the prompt response by Congress to strengthen aviation security under the Aviation and
Transportation Security Act of 2001, provides improved protection against air attacks on all
industrial facilities, both nuclear and non-nuclear. The Commission views that the nation’s
efforts associated with protecting against terrorist attacks by air should be directed toward
enhancing security at airports and on airplanes. The NRC supports the steps taken by the
Federal Aviation Administration (FAA) to improve aircraft security, including enhanced
passenger and baggage screening, strengthening of cockpit doors, and the Air Marshal
program. The NRC has been in regular communication with other Federal agencies,
specifically the FAA and DOD, which have acted more than once to protect airspace above
nuclear power plants. In addition, the U.S. intelligence community and Federal law
enforcement have increased efforts to identify potential terrorists and prevent potential attacks
before they occur. Shortly after the September 11, 2001, attacks, representatives of the FAA
and DOD determined that a Notice To Airmen (NOTAM), issued by the FAA, was the
appropriate vehicle to protect the air space above sensitive sites. This NOTAM strongly urges
pilots “to not circle or loiter over the following sites: Nuclear/Electrical power plants, power-distribution
stations, dams, reservoirs, refineries, or military installations, unless otherwise
authorized by air traffic control or as required to land or depart at towered/non-towered
airports.” This notice is still in effect. Should additional restrictions be deemed appropriate as a
result of changing or more specific threats, our communication with the other Federal agencies
will allow prompt coordination.
snip-

The staff also acknowledges that nuclear plants were not specifically designed to
withstand the direct impact of a large commercial airliner fully loaded with fuel. Prior to
September 11, 2001, such a scenario was not considered to be a credible threat. However, the
NRC recognizes that nuclear power plant design could contribute to the survivability of the plant
in the event of an aircraft impact. The NRC requires that these facilities be designed with a
defense-in-depth philosophy to withstand events such as tornadoes (and missiles generated by
tornadoes), hurricanes, fires, floods, and earthquakes. This has resulted in nuclear power plant
designs that inherently afford a measure of protection against deliberate aircraft impacts
because the defense-in-depth philosophy requires plants to have redundant and separated
systems in order to ensure safety. Ultimately, the capability of a plant to successfully cope with
an aircraft crash will depend upon a number of factors, including the plant’s specific design
features, the design and flight characteristics of the aircraft, the point of impact, the ability of the
licensees’ staff to utilize remaining backup systems, and the response of onsite and offsite
resources.
snip-

The Petitioner stated that the NRC knew or should have known that the current design
of and security measures for the SFPs located at nuclear power plants are incapable of
protecting the population from the catastrophic release of radiation from a potential terrorist
attack and immediate and long-term compensatory measures are needed to protect the United
States and its citizens. The Petitioner also stated that the radioactive material contained in the
SFPs is extremely vulnerable to terrorist attack within 6 months of a refueling outage, and that
immediate and long-term compensatory measures are needed to protect the United States and
its citizens from an attack on a SFP within this 6-month window.

NRC Response
As previously stated, the NRC staff concluded that, in view of the intelligence
information at hand, enhancements to site security, and steps taken to improve aviation
security, nuclear power plants should continue to be allowed to operate. The NRC staff’s
determination considered SFPs, since the pools are located within the protected area and are
afforded protection under the same physical security protection program as the nuclear power
plant.
As stated in the proposed Director’s Decision, the February 25, 2002, Orders directed
licensees to evaluate and address potential vulnerabilities to maintain or restore core cooling
capabilities, and containment and SFP integrity, and to develop specific guidance and
strategies to respond to an event resulting in damage to large areas of the plant due to
explosions or fire. These requirements will remain in effect until the NRC notifies licensees that
the threat environment has significantly changed or until the NRC determines, as a result of the
ongoing comprehensive reevaluation of current safeguards and security programs, that other
changes are needed.
The NRC acknowledges that nuclear power plants, including the SFP, were not
specifically designed to withstand the impact of a large commercial airplane fully loaded with
fuel. Nonetheless, the NRC recognizes that the design of the spent fuel storage system could
contribute to mitigating the effects of a radiological sabotage event. Although the spent fuel
storage buildings are not as hardened as the reactor containment structures, certain SFP
design features could be assets as operators address a radiological sabotage event.
First, SFPs are small in size relative to the rest of the plant, making them difficult to
target. In addition, the NRC’s requirements that nuclear power plants be designed to withstand
a variety of design-basis events such as tornadoes (and missiles generated by tornadoes),
hurricanes, fires, floods, and earthquakes have resulted in nuclear plant designs that inherently
afford a measure of protection against deliberate aircraft impacts and other acts of radiological
sabotage. The SFPs are massive structures with thick walls constructed of reinforced concrete.
Furthermore, the defense-in-depth design philosophy used at nuclear power plants means that
critical systems have redundant and separated systems. That is, active

components, such as
pumps, have backup systems that are physically and electrically separated from each other as
part of the basic design philosophy.
However, in the event of a serious accident or terrorist attack at a nuclear power plant,
licensees would implement emergency preparedness program plans. These plans are routinely
evaluated in biennial exercises. This provides a further capability to respond to various types of
sabotage events involving the SFP.
The staff recognizes that the continued evaluation of the current threat environment may
identify additional requirements beyond those provided by existing regulations and the ICMs
specified in the February 25, 2002, Orders. The comprehensive review of the NRC’s
safeguards and physical security programs initiated by Chairman Meserve following the
September 11, 2001, terrorist attacks includes an evaluation of the potential consequences of
terrorist attacks using various explosives or heat-producing devices on SFPs and spent nuclear
fuel dry casks at spent nuclear fuel storage sites. The staff will use the insights gained from
these studies as it considers potential supplemental security measures.
snip-

Dated at Rockville, Maryland, this 1st day of November 2002.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Jon R. Johnson, Deputy Director
Office of Nuclear Reactor Regulation

Very interesting, and I'll bet that passenger jets were not specifically designed to be used for impacting with power plants, either. As the old adage goes though: "There never was a horse that couldn't be rode-never was a cowboy that couldn't be throwed."

These plants may not have been originally designed to withstand a hit by an airliner, but most of them have been updated since then. Back in the early seventies I worked for SoCal Edison at San Onofre Nuclear Generating Station and at that time there was a threat by some nut who planned to fly a 707 or such into the place. The station was immediately shrouded by a concrete sphere.

Suck My Phalanx...

Perhaps the NRC ought to buy a few of these:

Specifications
Primary Function Anti-ship missile defense
Contractor Hughes Missile Systems Company
(formerly General Dynamics' Pomona Division, sold to Hughes in 1992)
Weight 12,500 pounds (5,625 kg)
Later models 13,600 pounds (6,120 kg)
Range Classified
Gun Type M-61A1 Gatling
Type of Fire 3,000 rounds per minute
- Later models 4,500 rounds/min
(starting 1988 production, Pneumatic Gun Drive)
Magazine Capacity 989 rounds
Later models 1,550 rounds
Caliber 20mm
Ammunition Armor Piercing Discarding Sabot (APDS), Depleted Uranium or Tungsten sub-caliber penetrator. Sensors Self-contained search and track radar
Search Radar Ku-band; digital MTI
Track Radar Ku-band; pulse Doppler monopulse
E/O Sensor FLIR Imaging System with Automatic ACQ Tracker
Fire Control Director with closed-loop spotting
Gun Drive Pneumatic
Mount Drive Electric
Date Deployed 1980 (aboard USS Coral Sea)
Later models 1988 (aboard USS Wisconsin)

Chicken Little. The structural work in U.S. Nuclear power plants is designed to codes that are conservative to a fault. I have doing Nuclear structure work for about four years and IMO they will withstand impacts 5-6 times of what they are designed for. Even if burning fuel reduced the modulus of elastisity to 10 or 20% nothing would fall down. The plants located in seismic active areas are even more robust, designed for peak loads of up to 35 G's or more.

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