Overview

As national, regional and local environmental and public interest organizations, we wish to express our profound sympathy for those affected by the terrible events of the past month. Now is the time for
our country to put aside narrow and divisive interests and focus on protecting the safety of all who live in the United States.

Specifically, we recognize that nuclear power reactors pose an unacceptable threat to the security of the United States. Commercial reactors are extremely vulnerable to attack from both foreign and domestic terrorists. The sobering reality is that security of nuclear power facilities can be neither completely guaranteed nor perfectly realized.

Current security at U.S. nuclear reactors is unacceptable. Significant weaknesses in security were found at nearly one-half (47%) of U.S. commercial reactors tested in recent years. "‘Significant’ here means that a real attack would have put the nuclear reactor in jeopardy with the potential for core damage and a radiological release, i.e., an American Chernobyl," according to the U.S. Nuclear Regulatory Commission’s (NRC) security expert. Structurally, no commercial nuclear reactor is designed to withstand the impact that destroyed the World Trade Center buildings, according to the NRC and the International Atomic Energy Commission. An attack on these facilities by truck bomb or aerial assault, or any number of other scenarios could spread lethal radiation, rendering uninhabitable an area the size of Pennsylvania, according to an analysis by the Atomic Energy Commission (now the NRC) in 1964.

For these reasons, we call for the following actions to be taken by the appropriate authorities:

#1. All NRC licensees must demonstrate that their nuclear facilities are protected against radiological sabotage by meeting a significantly more comprehensive Design Basis Threat (DBT). This includes reactor operators currently holding an operating license and applicants for license extension or new construction.

A revised Design Basis Threat must both encompass currently analyzed threats from ground-based assault, and be broadened to include truck-bombs and aerial and water-borne attacks. Before receiving an operating license, a licensee must be able to demonstrate that it can guard against the revised Design Basis Threat so as to protect against core damage, a breach of reactor containment and/or damage to irradiated nuclear fuel. By definition, reactor designs that do not feature a reactor containment structure, such as the proposed Pebble Bed Modular Reactor (PBMR), must not be considered suitable for meeting any plausible Design Basis Threat. The upgraded DBT must be met through both enhanced physical security features and increased security force capabilities.

Recognizing that nuclear reactors will continue to be vulnerable targets for some time after they have permanently ceased operation (until the core has cooled and the radioactive waste has decayed) the nuclear waste that is stored must be protected from intentional air and other modes of attack. All permanent and temporary radioactive waste storage, disposal, treatment and transfer sites must meet the strengthened Design Basis Threat to protect against attacks that could have disastrous consequences.

#2. Congress must reject reauthorization of the Price Anderson Act, which limits the liability of the commercial nuclear industry. At a minimum, certain modifications must be made to the Price Anderson Act in light of the events of September 11 if Congress reauthorizes the Act. Any extension of indemnity to the operators of new or relicensed nuclear power plants and nuclear fuel cycle facilities should be made contingent upon the demonstrated ability of the licensee to protect against the revised Design Basis Threat outlined in point #1. In addition, the indemnification of U.S. Department of Energy (DOE) contractors should exclude cases of contractor gross negligence or willful misconduct.

#3. Congress must indefinitely extend the moratorium on nuclear transport and expand it to cover all highly radioactive and radiotoxic waste and materials, including commercial shipments. On September 12 and again on October 7, Energy Secretary Abraham suspended DOE nuclear shipments, acknowledging that radiological shipments are potential terrorist targets. In the long term, government agencies should shift their focus from facilitation and encouragement of nuclear transport to minimizing the amount and frequency of radioactive shipments. U.S. delegates must advocate this position when participating in United Nations and other international fora that develop or recommend international transportation standards.

#4. Congress must indefinitely shelve current proposals for centralized storage of nuclear waste. Such storage would establish additional nuclear targets without meaningfully reducing the risk at operating nuclear power plants. In addition to the dangers of transporting radioactive materials, a centralized storage facility would itself be a difficult-to-secure target. Specifically, the proposals for nuclear waste storage facilities at Yucca Mountain, Nevada, and on the Skull Valley Goshute Reservation in Utah, would irresponsibly create significant targets close to major population centers. Design proposals for both these facilities feature massive,exposed surface operations, which would establish potentially larger, highly vulnerable and more devastating targets for attack.

#5. Congress must mandate that utility-funded security operations be increased at existing nuclear reactors and maintained throughout plant life and the on-site storage of irradiated nuclear fuel. Current security at U.S. nuclear reactors is unacceptable. The NRC and the International Atomic Energy Agency have acknowledged that the containment buildings housing nuclear reactors are not designed to withstand an attack of the type and scale used against the World Trade Center and Pentagon. Since 1991, despite months of advanced warning and beefed up security forces, nearly half (47%) of U.S. nuclear power plants failed to repel small mock terrorist attacks conducted by the NRC. These exercises did not assess the full Design Basis Threat that NRC regulations require nuclear power plants to protect against. Moreover, these exercises failed to assess the ability of nuclear plants to defend against attacks by truck bomb, aerial, and water-borne assault, three likely scenarios that fall outside the current Design Basis Threat.

#6. Potassium iodide must be stockpiled with state and local health agencies within a radius of 50 miles around all nuclear reactors. While it is not a panacea, the NRC already has approved this program in concept, but has been reluctant to initiate it lest the public grasp that nuclear reactors are fundamentally unsafe. An epidemic of preventable childhood thyroid cancer has ravaged children in the Chernobyl-affected regions of Ukraine, Belarus and western Russia partly because potassium iodide was not distributed in the aftermath of the reactor explosion and fire. The health of thousands of children is believed to have been saved in Poland, where potassium iodide was distributed following the 1986 Chernobyl disaster.

#7. The Federal Aviation Administration (FAA) must require the same or comparable security for general and commercial aviation and determine the practicality of instituting permanent effective no-fly-zones over commercial nuclear power plants.

#8. All NRC licensees must provide a risk assessment of the survivability from terrorist attack on radiation containment and critical safety systems.

#9. The NRC must take significant federal enforcement action, including the suspension or revocation of operating licenses, when repeated licensee failure of upgraded NRC-led security performance evaluations occurs.

#10. All branches of government must ensure that the terrorist attacks do not result in the erosion of fundamental civil liberties. The hallmarks of our free society and our values are manifested and secured in the Bill of Rights. Therefore, it is essential that security programs and activities clearly differentiate between legitimate terrorist threats and the rights of the public to peacefully assemble, exercise free speech, organize and educate.

#11. The mixed oxide nuclear fuel (MOX) program must be eliminated immediately. Giving the green light to a proposed commercial plutonium fuel fabrication plant in South Carolina fosters the creation of a plutonium economy and increases the likelihood of a terrorist-created catastrophe. The manufacture of MOX fuel for use in commercial U.S. nuclear reactors, establishes not only more deadly terrorist targets at the plants themselves (due to the greater amount of plutonium in the MOX fuel than current reactor fuel), but also creates thousands of transports between the fabrication site and the reactors, vulnerable to sabotage or theft. Such a project puts the trigger component of nuclear weapons into the commercial sector where it cannot adequately be protected.

The NRC must refuse the licensing of the MOX plant and Duke Power must withdraw its reactors from the MOX program. Surplus weapons plutonium has no place as a commercial fuel and sends a dangerous message to the rest of the world that plutonium is a commodity, not a waste to be secured out of harm's way. The licensing of a plutonium fuel fabrication plant flies in the face of any government's avowal to protect its people from lethal attack or disaster.

#12. The U.S. must initiate an expedited phaseout of nuclear power, improve energy efficiency in all sectors of our economy and initiate a rapid transition to renewable electricity sources. Linked through the extensive and fragile electrical grid system, we recognize that nuclear power plants are one of the most vulnerable components of our electric power infrastructure and present the largest risk of catastrophic damage. As such, nuclear power poses an unacceptable risk to our society and environment.

The phaseout of nuclear power must take place within the context of a transition to a least-cost, environmentally sustainable national energy system, based on full exploitation of decentralized energy efficiency and renewable energy sources, available through existing technology. A distributed, sustainable energy system will provide numerous economic, public health and environmental benefits beyond reducing the terrorist threat to our nation's infrastructure. Such a transition will spur innovation and channel resources into more labor-intensive sectors of the economy, providing the nation with an engine for continued economic growth and job creation.

In conclusion, we believe that this is the direction we must take: We will either shift from our use of nuclear power to a new era of sustainable electricity production for our country, or we will remain vulnerable to our reactors and, very possibly, pay an unthinkable price. We can and must do better for our families, our country, our freedom and the planet.

Sincerely,

Scott Denman
Executive Director
Safe Energy Communication Council
Washington, DC

Michael Mariotte
Executive Director
Nuclear Information and Resource Service
Washington DC

Carl Pope
President
Sierra Club
San Francisco, CA

Robert Musil, Ph.D., M.P.H
Executive Director
Physicians for Social Responsibility
Washington, D.C.

Wenonah Hauter

Executive Director

Public Citizen

Washington, D.C.

Anna Aurilio

Legislative Director

U.S. Public Interest Research Group

Washington, D.C.

Dr. Brent Blackwelder

President

Friends of the Earth

Washington, D.C

David Kraft

Executive Director

Nuclear Energy Information Service

Chicago, IL

Damon Moglen

Greenpeace USA

Washington, D.C.

Paul Schwartz

Clean Water Action

Washington, D.C.

Peter Montague, Director

Environmental Research Foundation

612 Third Street, Suite 2A

Annapolis, MD 21403

James Wyerman

Executive Director

20/20 Vision

Washington DC

Eva Jo Hallvik, Outreach Director

Friends of the Clearwater,

Moscow, Idaho, 83843

Judy Treichel

Nevada Nuclear Waste Task Force

Las Vegas, NV

David N. Pyles

New England Coalition on Nuclear Pollution

Brattleboro, VT 05302-0545

Reinard Knutsen,

Shundahai Network, Nuclear Free Great Basin Campaign

Salt Lake City, UT

John Steinbach

Louise Franklin-Ramirez

Hiroshima/Nagasaki Peace Committee

Washington, DC

Laura Huth, Executive Director

Illinois Student Environmental Network

Urbana, Illinois

Bernice R. Bild

Committee for New Priorities

Chicago, IL

Bob Darby, Coordinator

Food Not Bombs/Atlanta

Atlanta, GA

Donald & Juanita Mendoza Keesing,

Voices Opposed To Environmental Racism,

Washington, DC

Kaitlin Backlund

Executive Director

Citizen Alert

Reno/Las Vegas, Nevada

John LaForge

Nukewatch

Luck, Wisconsin

Grandmothers for Peace/San Luis Obispo County Chapter

Molly Johnson, area coordinator

San Miguel, CA

Chuck Johnson, Director,

Center for Energy Research,

Portland, Oregon

Frank C. Subjeck, Acting Director for

Air,Water,Earth, Organization

Lake Havasu City, Arizona

Greg Wingard, Executive Director

Waste Action Project

Seattle, WA

Chris Trepal

Earth Day Coalition

Cleveland, OH

Jay M, Gould ,Director

Radiation and Public Health Project

New York, NY

Dr. Charles Mercieca

President, International Association of Educators for World Peace,

UN-NGO

Michael J. Keegan

Coalition for a Nuclear Free Great Lakes

Monroe, MI

Corrine Carey

Don't Waste Michigan

Grand Rapids, MI

Citizens' Resistance at Fermi Two

Monroe, MI 48161

Keith Gunter

Nuclear Resister

Felice and Jack Cohen-Joppa

Tucson, Arizona

Catherine Lincoln, Facilitator

Americans for a Safe Future,

Sherman Oaks, CA

UNPLUG Salem Campaign

Linwood NJ

Norm Cohen, Coordinator

Coalition for Peace and Justice

Linwood NJ

Stockton Peace Action

Pomona NJ

Matt Vecere, President

Sidney J. Goodman, PE, MSME

SJG Design, Inc.

Paramus, NJ

Nancy Veit

Iowans for Nuclear Safety

Cherokee, Iowa

Gary Karch

Positives for Peace and Environmental Justice

Niles, MI

Ellen Thomas, Executive Director

PROPOSITION ONE COMMITTEE

Washington, DC

Pat Birnie, Secretary

Environmental Justice Action Group

Tucson, Arizona

Betty Schroeder, Chair

BANDU (Ban Depleted Uranium)

Tucson, AZ

Mary MacEwan

Women's International League for Peace and Freedom, Tucson Branch

Tucson, AZ

Yael Martin

Executive Director

Promoting Enduring Peace

Woodmont, CT

Citizens Protecting Ohio

Harvey Wasserman

Bexley, OH

Corinne Whitehead, President

Coalition for Health Concern

Benton, Ky

Stephen M. Brittle

President

Don't Waste Arizona, Inc.

6205 South 12th Street

Phoenix, AZ 85042

Scott Cullen

Counsel, STAR Foundation

P.O. Box 4206

East Hampton, NY 11937

Kathleen Whitley

Program Manager

Sustainable Energy Alliance of Long Island

P.O. Box 789

Bridgehampton, N.Y. 11932

Nuclear Weapons Abolition Task Force of CPPAX

(Hampshire/Franklin) Frances Crowe,

Northampton, Ma. 01060

Donna Smith-Remick

Vice-President

Friends of Poquessing Watershed

Philadelphia, PA 19116

Jessica Hiemenz

Taking Responsibility for the Earth and the Environment (TREE)

Blacksburg, VA

E.M.T. O'Nan

Director

Protect All Children's Environment

Marion, North Carolina 28752

Nancy Burton

Connecticut Coalition Against Millstone

Mystic CT 06355

UPPER CUMBELAND SCENIC ENVIRONMENTAL ALLIANCE

COOKEVILLE, TN

HARRY JAQUESS

EXECUTIVE DIRECTOR

David Ellison,

Green Party of Cuyahoga County

Cleveland, Ohio

Mary Byrd Davis,

Yggdrasil Institute,

Georgetown, Kentucky

Jennifer Olaranna Viereck

Healing Ourselves & Mother Earth

Tecopa, CA

Carol Lems-Dworkin

World Music Center

Evanston, IL

Steven Hegedus

Green Party of Delaware

Newark, DE

Betty Long

Western Reserve Alliance for Safe Energy

Cleveland, OH

Stuart Greenberg

Environmental Health Watch

Cleveland, OH

Krista Leraas

Alliance for Sustainability

Minneapolis, MN

Jane Magers

Earth Care

Des Moines, IA

Paul Gallimore

Long Branch Environmental Education Center

Leicester, NC

Mary Terrell

Women’s Action for New Directions – Atlanta Chapter

Atlanta, GA

Alice Slater

GRACE

New York, NY

Bill Linnell

Cheaper, Safer Power

Portland, ME

Jason Groenwold

Families Against Incinerator Risk

Salt Lake City, UT

Chris Williams

Citizen Action Coalition of America

Indianapolis, IN

Suzi Snyder

Shundahai Network

Pahrump, NV

Kathryn Barnes

Don’t Waste Michigan

Sherwood, MI

Michael Morrill

Pennsylvania Consumer Action Network

Reading, PA

Clem Wilkes

California Safe Food Coalition

Laytonville, CA

Linda Ochs

Finger Lakes Citizens for the Environment

Waterloo, NY

Glenn Carroll

Georgians Against Nuclear Energy

Atlanta, GA

Andrew Hund

Alaska/Arctic Environmental Defense Fund

Bonnie Reagan

Sound Evolution, Inc.

Chicago, IL

Lewis E. Patrie, M.D., M.P.H.

Physicians for Social responsibility (Western North Carolina Chapter)

Ashville, NC

Rochelle Becker

San Luis Obispo Mothers for Peace

Pismo Beach, CA

George Crocker

North American Water Office

Lake Elmo, MN

Bruce A. Drew

Prairie Island Coalition

Minneapolis, MN

Lilias Jones Jarding

Bison Land resource Center

Sioux Falls, SD

Ohio Partners for Affordable Energy

Defiance, OH

Amy Simpson

Ohio PIRG

Cleveland, OH

Sandra Gavutis

C-10 Research and Education Foundation, Inc.

Newburyport, MA

D. Gordon Draves

Georgians Against Smoking Pollution

East Point, GA

Tom Leonard

West Michigan Environmental Action Council

Grand Rapids, MI

Roy Morrison

New Hampshire Consumers Utility Cooperative

Warner, NH

Paige Knight

Handford Watch

Portland, OR

Margaret Wooster

Great Lakes United

Buffalo, NY

Ellen Pietroski

North Carolina Waste Awareness and Reduction Network

Durham, NC

Lynn Sims

Don’t Waste Oregon

Portland, OR

Alan Muller

Green Delaware

Port Penn, DE

Michael Welch

Redwood Alliance & REEI

Arcata, CA

Derek C. Haskew

MASSPIRG

Boston, MA

Holly Bins

Clear Air Advocate

Tallahassee, FL

J.H. Johnsrud

Environmental Coaliton on Nuclear Power

Orlando, FL

L.J. Glicenstein

Central Pennsylvania Citizens for Survival

State College, PA

John Sellers

Ruckus Society

Berkeley, CA

Rachel Styer

Butte Environmental Council

Chico, CA

Matthew Wilson

Toxics Action Center

Boston, MA

Mary Lampert

Massachusetts Citizens for Safe Energy

Boston, MA

Michael Noble

Minnesotans for an Energy-Efficient Economy

St. Paul, MN

Kay Cumbow

Citizens for Alternatives to Chemical Contamination

Lake Station, MI

Joe Parrish

NJ/NY Environmental Watch

New York, NY

Carol McShane

Nebraskans for Peace

Lincoln, NE

Elisabeth Laudon

The Environmental Club

Fashion Institute of Technology

New York, NY

Janet Marsh Zeller

Blue Ridge Environmental Defense League

Glendale Springs, NC

Pat Ortmeyer

Women’s Action for New Directions

Arlington, VA

John Blair

Valley Watch, Inc.

Evansville, IN

Gary Groesch

Alliance for Affordable Energy

New Orleans, LA

Anne K. Reynolds

Environmental Advocates of New York

Albany, NY

Debby Katz

Citizen Awareness Network

Shelburne Falls, MA

Andy Knott

Hoosier Environmental Council

Indianapolis, IN

Phil Radford

Executive Director

Power Shift

Washington, DC

Paige Knight

Hanford Watch

Portland, OR

Kurt Waltzer

Ohio Environmental Council

Columbus, OH

Ken Seaman

Colorado Coalition for the Prevention of Nuclear War

Denver, CO

Peg Ryglisyn

Michael Albirizio

Connecticut Opposed to Waste

Broad Brook, CT

Fraser Smith

Center for Resource Solutions

San Francisco, CA

Philip Tymon

The Occidental Arts and Ecology Center

Occidental, CA

Bill Sulzman

Citizens for Peace in Space

Colorado Springs, CA

Robert Boone

Anacostia Watershed Society

Baltimore, MD

Steve Jambeck

Enviro Video

Ft. Tilden, NY

David Hughes

Citizen Power

Pittsburgh, PA

Mary Lee Orr

Louisiana Environmental Action Network

Baton Rouge, LA

Brett Bursey

South Carolina Progress Network

Columbia, SC

Robin Schneider

Texas Campaign for the Environment

Austin, TX

Peter Altman

SEED Coalition

Austin, TX

Evan Pappas

Clean Air Council

Philadelphia, PA

Jan Hamrin

Public Power Renewable Energy Initiatives

San Francisco, CA