Hey Richard Barkley....Still Waiting For that DBT Meeting

Some time ago I brought some serious concerns about the DBT to the attention of the NRC. After much delay and excuses, after being told at a public meeting on the record that my concerns would be addressed in a PRIVATE MEETING, I am still waiting. So am curious there Mr. Chairman of the NRC...when do I get to look at the DBT and have my concerns addressed? Meanwhile, from Green Nuclear Underground, a citizens imagination of what could be on the DBT that the NRC is not letting us see...just what RISKS are we facing from terrorists if they Relicense Indian Point. I think we have a right to know, have a right to see the DBT.

Monday, March 16, 2009

Hey NRC...What is in the DBT?

One of the big complaints that host communities have in being forced to host dangerous, failing reactors for another 20 years (besides the fact that they are American Chernoby's waiting to happen) is the fact we are not allow to have any real say in the DBT, nor any idea of what is or is not included in the DBT. Simply stated, we are left to our imaginations. Since the NRC will not honestly let us as Stakeholders know what SECURITY RISKS we face in the event of a terrorist attack, since we do not know what the SLEEPING GUARDS can actually protect against, thought I'd share a few weapons that MIGHT be on the DBT...maybe the NRC will realize truth and open honesty with HOST COMMUNITIES is far less dangerous than our run away imaginations...or not.

U.S. Air Force Capt. Drew F. Goettler, of the Air Force Research Laboratory' Directed Energy Directorate, demonstrates the Personnel Halting and Stimulation Response, or PHaSR, a non-lethal illumination technology developed by the laboratory's ScorpWorks team. Air Force courtesy photo...what do you think folks? In the DBT? Or maybe they have these at Indian Point. (No, Entergy is TO CHEAP!)

KIRTLAND AIR FORCE BASE, N.M., Nov. 1, 2005 – A laser technology being developed by Air Force Research Laboratory employees at Kirtland Air Force Base, N.M., will be the first man-portable, non-lethal deterrrent weapon intended for protecting troops and controlling hostile crowds...Can see Neil Sheehan ordering a couple of dozen!

The weapon, developed by the laboratory's Directed Energy Directorate, employs a two-wavelength laser system and is the first of its kind as a hand-held, single-operator system for troop and perimeter defense.

The laser light used in the weapon temporarily impairs aggressors by illuminating or "dazzling" individuals, removing their ability to see the laser source.

Special Operations Forces Demolition Kit
(SOFDK)

The SOFDK contains a variety of inert items that, when field loaded, provide Special Operations Forces with the capability to tailor charges to the target by using SDK components and C4 or other moldable explosives. The kit provides several methods of attaching charges/munitions to targets. The overall intent is to allow the operator to construct the smallest, lightest charge feasible with the greatest standoff distance attainable and maximum precision. I have a question....how can this type of stuff be put up on EASILY ACCESSIBLE PUBLIC WEB SITES, but we cannot see the DBT? Could it be the NRC does not want Host Communities to know just how PATHETIC Reactor Site Security is?

My FAVORITE:

Rapid Wall Breaching Kit (RWBK)

RBWK addresses an immediate need to give Soldiers wall breaching capability in urban and complex terrain. It supports performance demolition missions across the full range of operations. The RWBK is man-portable, rapidly deployable and creates a man-size hole to gain forced entry into buildings. Each kit will contain explosive, ignition material, attachment devices and a rebar cutter. Hey Richard Barkley, how much of a chance does a CINDER BLOCK SPENT FUEL POOL HAVE AGAINST A RBWK? Is such a kit included in the DBT?

Yet Another Indian Point Alarm FAILURE

As we all know, yesterday saw a typical May thunderstorm whisk through the area with high gusting winds, and sheets of rain. Like the spring rains, another typical Entergy event unfolded yesterday as well. In their usual inept fashion, 26 of the 156 sirens FAILED to go off, requiring Indian Point to notify the NRC...think about it folks, if this had been a real emergency, 1 in 6 of us would not have heard these non-working failed sirens. In a fast moving event at the failing Indian Point Nuclear Reactors, time is everything, and every second, every non working siren is LIFE LOST...it could be yours, or it could be your child, but someone will die. We need to pull the plug on Indian Point.

LOSS OF 26 EMERGENCY SIRENS DUE TO SEVERE WEATHER

"Due to severe weather storms in the area surrounding Indian Point Energy Center, 26 of the 156 emergency sirens have been out of service as of 1655 hours on 5/16/07 due to either loss of local AC power (24 sirens) or communications problem (2 sirens). 15 of the 26 sirens are in Rockland County; the remaining 11 sirens are in Westchester County. Sirens in Orange and Putnam counties were unaffected. Rockland and Westchester Counties have been notified and route alerting is available as an alternate means of public notification. Additionally, a high speed telephone notification system is available for public notification by the counties. Contact of the local utilities has been initiated to request power restoration to the areas associated with the 24 effected sirens; the communication problems with the remaining 2 sirens are under investigation."

The licensee notified the NRC Resident Inspector, New York State Public Service Commission, and Rockland, Westchester, Putnam and Orange counties.

Is NRC Agenda and Schedule More Important Than Fairness and Justice?

The Indian Point License Renewal Application was made available online yesterday. With all of it's various and assorted under laying documents, it is almost 3,000 pages in length, with hundreds if not thousands of sites and references, all of which have to be located and read if the document they support is to be fully and completely understood. I want to know that document, am unwilling to take some bureaucrats quickly constructed explanation of it delivered at a public meeting as gospel. The NRC, its licensees may want us to trust them, but them have not earned trust, but rather our distain.

I was up until after three in the AM reading that document, and trust me, it is slow going, and that fact is why I filed a request with the NRC yesterday for an extension of time to adequately understand and know the document. As luck would have it, Neil Sheehan, the NRC's angel of darkness if ever one existed, who had called on another matter, quickly doused any hope the request would go anywhere...he made it abundantly clear that we would get the exact same identical process that every other reactor license renewal application community had so far recieved, made it clear that the NRC was on a tight schedule.

I resisted the urge to quip back, " You mean rubber stamping?", which is what the process is in its current format.

As stakeholders, we are supposed to have a fair and equitable place at the table in this process. Where is that equity when we are expected to comment on a document we do not, and cannot understand without adequate time to digest same and the contents therein? The NRC may not like it, but their regulatory process is set up not to protect citizens of a host community, but to abuse us. The licenses for reactors 2 and 3 expire in 2012 and 2015, so where is the urgency to stick to a 22-30 month schedule, if giving a community more time, allowed us the opportunity to actually understand the documents in question. We are being asked to accept the continued operation of Indian Point for 20 more years...with what is at stake, don't we deserve the time necessary to gain the knowledge needed to make heads or tails out of Entergy's application? A rhetorical question.

I know these kinds of documents, know that dissecting them piece by piece, paragraph by paragraph, and sentence by sentence is the only way to locate the truth we need to justify rejection of the application. The NRC knows this, and does not want us finding the wedge needed to split open the log, thus exposing the ugly truth hidden in the black heart of Entergy's deliberately immense documents. If you are a citizen stakeholder wanting adequate time to digest Entergy's application, I encourage you to write the chairman's office at NRC to request the same 18 month extension of time I have requested before they schedule their first public meeting. The email address is chairman@nrc.gov . You might also want to CC Neil Sheehan at nas@nrc.gov .

Entergy Has Filed For Indian Point License Renewal, The Battle is Joined, GNB Mounts Its First Counter Offensive

Plans are afoot, a counter offensive is about to be unleashed as the Anti Nuclear Grassroots Green movement prepares for the battle that must be waged to stop Entergy's wrongful re-license of Indian Point. Individual stakeholders have rights in the process that we must all exercise. To that end, as publisher of GNB, today I've launched the first of my own counter attacks against a corrupt and bankrupt NRC regulatory process. I encourage our readership to take similar actions, here and in every reactor host community across America. The battle is joined, and we can only lose if we believe the lie that we cannot effect change.

Letter of Allegation Sent Today:

U.S. Nuclear Regulatory Commission
Office of the Inspector General
Mail Stop T5-D28
11545 Rockville Pike
Rockville, MD 20852-2738

Dear Inspector General:

Please consider this letter as a formal allegation and/or verified complaint against employees of the NRC, as well as the Commissioners who voted on the currently used/in force DBT (Design Basis Threat). Said persons have in the past, and continue to place human health and safety at risk through their wantonly and egregiously negligent, perhaps criminal actions aimed at protecting licensees at the expense of the safety and well being of citizens living in reactor host communities, specifically the host community in and around Entergy's Indian Point facility, of which I am a member/stakeholder.

1. The 2005 Energy Policy Act among other things spells out MANDATORY STEPS that the NRC were/are required to take to ensure the public that nuclear reactor sites are safe, and that NRC's DBT is designed in a fashion to assure success against such a terrorist attack and/or nuclear incident. In his Senate sub-committee testimony, Marvin Fertel, vice-president of the Nuclear Energy Institute, acknowledged that the current DBT does not represent the full spectrum of terrorist threats. The key reason for this, is that the NRC and the commissioners themselves gave the NEI undue influence, allowed the NEI to draft a DBT to their liking, rather than drafting a DBT which would provide the public with any real level of adequate protections against a terrorist attack. In fact, Mr. Fertel in his testimony all but admits to their organization's undue influence in NRC's policy and rule making process when he states, "NEI is responsible for developing policy for the commercial nuclear industry." (emphasis added) A cursory examination of NRC's underlying documents would show time and again NEI's desires were heeded by NRC staff, too the point where the NRC even uses the NEI's exact wording in the creation of NRC policy and rules.

Throughout the entire creation of the DBT, the NRC staff and Commissioners gave the NEI and those it represents too much sway in the creation of the DBT, and without exception, public health and safety took a back seat to the nuclear industry's financial concerns, and corporate bottom lines. Specific areas where public safety has taken a back seat to shareholder interests include, but are not limited to the following:

A. The NEI is allowed to create the attack teams for force on force exercises, thus allowing their members advance notice of what they will be defending against. The DOE's offer of providing an attack team for these force on force exercises, similar to the ones employed to test defense readiness at DOE nuclear sites, was given no real due consideration by the NRC staff, primarily because NEI objected to it. This has created a situation wherein citizen/stakeholders living within close proximity to DOE facilities are afforded a far higher level of protection than those of us living within close proximity of commercial nuclear reactor sites.

B) When the NRC team of staffers created the first draft of the DBT, it included a host of commonly used terrorist weapons of choice. This list was compiled after careful discussion with law enforcement, and a full review of inter/intra agency intelligence. The NEI immediately objected to this list, claiming the costs of defending against such a list was cost prohibitive, and that two of the weapons on the list (even though standard terrorist issue weaponry) would render almost all current reactor site defensive structures obsolete. NRC staff gave into the NEI's wishes/demands and removed all but two of the weapons (Shoulder Launched Grenades [SLG] and a high power rifle using armor piercing bullets. When the commissioners voted on the DBT, after private back room discussions with the higher echelons of NEI, these two weapons were removed from the list. Fact...these two commonly used terrorist weapons render bullet resistant guard towers and shielded areas within the reactor and control room employing bullet resistant glass useless and in grave peril if attacked by a well trained, well armed and dedicated group of terrorists. Rather than protect human health and safety, rather than creating a DBT that would adequately prepare sites for a terrorist attack both NRC staff and commissioners sacrificed our safety on the altar of nuclear industry profits and convenience. The GAO's report to Congress tends to agree and support this allegation.

C. The NRC staff charged with creating the DBT settled upon a particular size explosives-laden vehicle. The NEI objected, claiming that protecting against a vehicle of such enormous size was overly expensive. The commission again gave the nuclear industry their way by GREATLY DECREASING THE SIZE/WEIGHT of the explosives laden vehicle. One commissioner seemed to justify this decision with the failed logic that a vehicle any larger would more than likely be spotted by and stopped by off site law enforcement before reaching the reactor site. It is noted here, that such thinking includes off-site security measures in protecting a reactor site, yet the NRC does not include testing of said off-site security they are relying on in the force on force exercises.

D) The NEI objected to both the size of the terrorist attack force, and the amount of weight (thus weaponry) each attack force member could carry. Again, everything the NEI wanted, they were given as both the size of the attack force, and the weight allotted for weaponry of each member was significantly reduced, thus GREATLY REDUCING the attack a nuclear reactor site would have to defend against in force on force exercises, which in turn, greatly reduced safety levels for members of the general public in the case of a terrorist attack on a nuclear reactor facility.

2. To avoid the transparency that would expose the DBT for what it is, to allow the continued rubber stamping of every license renewal application coming into the NRC headquarters, the agency and staff members involved in re-licensing (directly and/or indirectly) are ignoring federal law and statute where it suits them, specifically, but not limited to NEPA's requirement that the potential impact of terrorist attacks at nuclear facilities be considered in the license renewal application process. Knowing full well that many reactor communities do not have the financial means to litigate against the NRC and a well funded nuclear industry, the NRC has decided to ignore a recent Ninth Circuit Court decision on this very issue...in fact, Neil Sheehan was callously quoted as saying, "What happens in California stays in California..." when he was asked what effects that ruling would have on other license renewal applications. The NRC's relying on a community's financial inability to defend itself ADEQUATELY in the federal courts amounts to defacto Economic Racism on the part of the NRC and its staff, including the commissioners, and the Atomic Safety & Licensing Board, which has held that no such analysis is required.

These egregious actions on the part of the NRC, their collusion with the NEI and key nuclear industry players (Entergy, Exelon, NuStart, Duke Power, TVA) has threatened the lives, safety and security of every stakeholder citizen living within 50 miles of a reactor, with those of us living within ten miles of same at the most peril. Because of the imminent danger we are in due to the negligent and capricious acts spelled out above, as the filer of this allegation, I seek the following actions and protections:

1. A fast-tracked investigation of the allegations and charges contained herein with any criminal wrongdoing found being turned over to the United States Department of Justice for criminal prosecution to the fullest extent of the law.

2. Evaluation of the issues as spelled out to determine if there exist any issues that have abridged my civil liberties, as defined in both the Constitution and Bill of Rights.

3. There be issued by the NRC Commissioners an order halting all license renewal activities until the issues contained herein have been resolved, as allowing them to move forward when a woefully inadequate DBT, which was created through criminal collusion, fails in providing the bare minimum security and safety protections afforded by NRC 10 CFR Rules and Regulations, and other federal statutes and laws, puts every nuclear reactor licensee in a position where they are defacto in violation of their licenses, and thusly subject to license revocation, and or other penalties.

When the NRC staff allow lobbying to cross the line into collusion, not only is the public trust eroded, but our health, safety and security is put at grave risk. When corporate profits supercede the NRC's duty and responsibility to protect human health and safety, the agency stands at the brink of a dark abyss, ready to sell its soul for the goal of a Nuclear Renaissance, and has sacrificed its own right to govern and regulate the industry.

Respectfully Submitted

Sherwood Martinelli


Reference Documents

http://italy.usembassy.gov/pdf/other/RS21131.pdf

http://www.gao.gov/new.items/d06555t.pdf

http://www.securitymanagement.com/library/gao041064t_nuclear1204.pdf

http://www.ig.energy.gov/documents/IG-0749.pdf

http://www.gao.gov/new.items/d0739.pdf

http://www.americanchronicle.com/articles/viewArticle.asp?articleID=1898

http://www.parliament.uk/documents/upload/POSTpr222.pdf

http://www.sc.doe.gov/bes/archives/budget/FY05_HRpt_108_554.pdf

http://www.totse.com/en/politics/us_military/162581.html

http://www.numat.at/list%20of%20papers/gesamtproceedings.pdf

http://www.iae.kyoto-u.ac.jp/kbutsu/files/AR/AL2002.pdf

http://www.wtec.org/loyola/pdf/nanousws.pdf

http://hss.energy.gov/SecPolicy/directives/M_470.4-1c1_Planning.pdf

Entergy Is Not State Farm

As hard as they try to pretend the part of State Farm, Entergy is not and well never be your good neighbor. In their latest bogus attempt at being Mr. Goodfellow, seems they have announced plans to provide funds for summer youth resources in Brattleboro, Vermont. The premise it seems is to get youth and families involved in FUN, HEALTY summer activities.

We here at the Green Nuclear Butterfly can see the memo making game suggestions:
1. Ring Around The Reactor
2. Enriched Uranium Pellet Toss
3. Spent Fuel Pool Wading

For a tie breaker, they can always pull out the ever popular greased Fuel Rod Climbing event, or for the very daring at heart, reactor core diving.

Brattleboro needs to tell Entergy they can keep their radioactively contaminated blood money.

Summer resources for youth receive funding from Entergy
Reformer.com
www.reformer.com/ci_5639568

Wednesday, April 11
BRATTLEBORO -- Youth Services announces the debut of Summer Resources for Healthy Youth and Families, a four-part initiative sponsored by Entergy Nuclear Vermont Yankee to help youth and their families located healthy and productive summer activities.

These resources include the Summer Events Calendar, the Summer Camp Fair, a Summer Jobs Bulletin, and the HEY! Help Empower Youth Resource Guide.

The Summer Events Calendar links younger youth to camps and summer programs through a Reformer insert that appeared on Saturday, with additional copies delivered to schools, libraries, and other locations across the county that families frequent, including Youth Services web page.