SUBJECT: COMMENTS ON NRC PROPOSED RULE ...

Furthermore, no judgment is implied as to the relative risk of nuclear
power as ccmpared to other technologies or the relative importance of
sabotage as a contributor to the risk from nuclear power production.
This restricted viewpoint must be kept in mind as the following mate-
rial is reviewed.
The basic objective of nuclear power plant safeguards is to re-
duce to an acceptable level the risk of public exposure to radiologi-
cal hazards caused by malevolent actions directed againat the facil-
ity. The earlier studies indicate that sabotage leading to a release
of radioactive materials is the principal safeguards concern with re-
gard to power reactors (References 2 and 3). The public risk from
such malevolent acts is discussed here in qualitative terms along with
the relationship between the safeguards objective and plant design.
Design objectives which cover the significant parameters affecting
risk are identified.
Factors Defining Public Risk from Malevolent Acts -- In general,
risk can be defined as the expected loss caused by the conduct of an
activity for a given period of time. Therefore, risk can be ex-
pressed as the product of the frequency of events and the magnitude of
the loss per event. For events which are purposely initiated, the
frequency of events depend6 upon the frequency of attempts to produce
some consequence and the conditional probability that an attempt is
successful. In sane instances, there may be a range of possible con-
sequences that can be caused and a number of ways by which the same
level of consequence can be induced. Thus, a consideration of risk
requires evaluation of several interacting parameters. Risk is not
only a function of the ways by which a saboteur might attempt to cause
a release but aLso of the actions which can be taken tu counteract the
attempt. Same mbotage events might be corrected or modified by dam-
age control measures to prevent or significantly limit the conse-
quences, and independent actions of consequence mitigation might be
taken to reduce the public impact of malevolent acts.