FRANKIE SUE DEL PAPA
Attorney General


STATE OF NEVADA
OFFICE OF THE ATTORNEY GENERAL
100 N. Carson Street
Carson City, Nevada 89701-4717
Telephone (775) 684-1100
Fax (775) 684-1108
WEBSITE: http://www.state.nv.us/ag/
E-Mail: aginfo@govmail.state.nv.us

THOMAS M. PATTON
First Assistant Attorney General

June 22, 1999


Dr. Shirley Ann Jackson
Chairman
U.S. Nuclear Regulatory Commission
Washington, D. C. 20555-0001

Re:

Nevada's Petition To Institute Rulemaking To Amend Regulations Governing Safeguards for Shipments of Spent Nuclear Fuel (SNF) Against Sabotage and Terrorism and To Initiate A Comprehensive Assessment

Dear Dr. Jackson:

Nevada Governor Kenny Guinn, on behalf of the people of the State of Nevada, has requested that this office file the attached Petition for rulemaking with the Commission. The Petition requests that the Commission initiate rulemaking to reexamine and strengthen its regulations governing safeguards for shipments of spent nuclear fuel against sabotage and terrorism in light of real world conditions.

It has been nearly two decades since the Commission reviewed its regulations designed to ensure the physical protection of spent nuclear fuel shipments. It is imperative that the Commission factor into its regulations the changing nature of threats posed by domestic terrorists, the increased availability of advanced weaponry and the greater vulnerability of larger shipping casks traveling across the country.

I respectfully urge the Commission to conduct the needed risk and consequence assessment of the existing safeguards and security regulations to determine if changes need to be made, publish new proposed rules for public comment, and ultimately to make the necessary modifications to the regulations. It is my sincere belief the current regulations expose the public across the country to unacceptable levels of risk from the transportation of highly radioactive materials. If you need additional information concerning this vital matter, please contact Marta Adams of my staff at (775)684-1237.

Cordially,

FRANKIE SUE DEL PAPA
Attorney General

FSDP:MA:nc

cc:

Secretary, U.S. Nuclear Regulatory Commission
See attached list


cc

Governors
Nevada Congressional Delegation
Attorneys General
U.S. Dept. of Energy
U.S. Dept. of Justice
U.S. Dept. of Transportation
Federal Emergency Management Agency