ML12321A328

G20120877/LTR-12-0684 - Ltr. Bruce Skud & Joanne Hammond Concerns Regarding the Seabrook Station

ML12321A328
Person / Time
Site:	Seabrook
Issue date:	11/08/2012
From:	Hammond J, Skud B No More Fukushimas!
To:	Macfarlane A NRC/Chairman
References
G20120877, LTR-12-0684
Download: ML12321A328 (5)

Text

1484.

SU.S Unitd S.- N NRC Rq'g -,or CEm i ETS Task Number: G20120877 ProtectingPeople and the Entironment Electronic Tracking System BU ra Inorato Lead Assignee: NRR OEDO Due Date:

Other Assignees: SECY Due Date:

Other Parties:

Subject:

Relicensing of Seabrook

Description:

CC Routing: OGC, Regionl ADAMS Accession Numbers - Incoming: Response / Package:

IND r 0 rmtio Cross Reference LTR-12-0684 SRM\Other: No ft ia- S- Sorato Action Type: Appropriate Action OEDO Concurrence: No Signature Level: No Signature Required OCM Concurrence: No Special Instructions: OCA Concurrence: No Ref. G20120877. For Appropriate Action. If a response is determined, please be sure to create an ADAMS Package to include the incoming (version we forward to you from DPC), with response and process accordingly. Copies should be sent to RidsEdoMailCenter and RidsSecyMailCenter.

Originator Name: Bruce Skud and Joanna Hammond Date of Incoming: 11/08/2012 Originator Org: No More Document Received by OEDO Date: 11/15/2012 Fukushimas Date Response Requested by Originator:

Aadressee: unairman IvIacTarlane Incoming Task: Letter OEDO POC: Dan Merzke (Ae- S $C /'-(7 ~i ~0e(lbs-i SZECV-6(

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Primted.-Nov 15, 2012 09:46 PAPER NUMBER: LTR- 12-0684 LOGGING DATE: 11/15/2012 ACTION OFFICE:

AUTHOR: Bruce Skud AFFILIATION: MA ADDRESSEE: CHRM Allison Macfarlane

SUBJECT:

Concerns regarding the Seabrook Station ACTION: Appropriate DISTRIBUTION: RF LETTER DATE; 11/08/2012 ACKNOWLEDGED. No SPECIAL HANDLING:

NOTES:

FILE LOCATION: ADAMS DATE DUE: DATE SIGNED:

EDO -- G20120877

No More Fukushimas!

c/o Bruce Skud 14 Olive Street Newburyport, MA 01950 The Honorable Allison M. Macfarlane, Chair Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 November 8, 2012

Dear Chairwoman Macfarlane:

We appreciated receiving a Nuclear Regulatory Commission (NRC) response to the August 28, 2012, letter that we sent to the NRC concerning Seabrook Station relicensing. The NRC's response (October 17, 2012) came from Dennis Morey, Chief, Project Manager 1, Projects Branch Division of License Renewal, Office of Nuclear Reactor Regulation (Docket No. 50-443).

In our letter, we highlighted a concern openly discussed NRC meeting April 26, 2012, on Seabrook relicensing held in Hampton, New Hampshire. Data indicates that due to climate change there could be an increase in sea levels and storm surges that would affect the Seabrook plant. Obviously, the flooding of the Seabrook plant campus should be a cause for concern, especially since it the flooding is projected to occur within the timeframe of the relicensing period, 2030-2050.

In his response to our letter, Mr. Morey categorically rejected the idea that this rising sea level information was of any relevance to the relicensing of the Seabrook plant:

Regarding your concerns about the current design-basis flood level calculations.... please note that these issues are not part of the NRC's review of a license renewal application. A license renewal review is not a re-review of the facility licensing basis; rather, it is focused on managing the age-related degradation of passive systems, structures, and components to ensure they will fulfill their safety-related functions, as specified in the current licensing basis.

The NRC has multiple processes to evaluate the adequacy of current plant operations and licensing bases. Should the NRC become aware at any time of information calling into question the continued safe operation of any nuclear power plant, including Seabrook Station, the NRC will take the appropriate actions as part of the agency's ongoing safety oversight, regardless of whether those plants have sought or are seeking a renewed license.

In the twists and turns of bureaucratic thinking, Mr. Morey may be technically correct that climate-change-related flooding is not an "age-related" deterioration artifact. But, Mr. Morey seems to brush off the fact that new global climate conditions could completely reconfigure the safety profile of the plant. We believe that whether or not climate-change-related flooding falls within "design-basis flood calculations" is a hairsplitting issue for bureaucrats. However, for those of who live near the plant it's a major safety issue. Therefore, if necessary, we respectfully recommend that NRC modify its relicensing concerns to include global climate change/rising sea levels in its license renewal framework.

1

No More Fukushimas!

c/o Bruce Skud 14 Olive Street Newburyport, MA 01950 Furthermore, Mr. Morey must know that the NRC has identified "alkali-silica reaction (ASR)" as a potential long-term threat to the reliability of the Seabrook plant and that structural degradation due to ASR is currently under the NRC's relicensing review. The flooding water will obviously raise levels of saltwater saturation, which will accelerate concrete degradation so, on that basis alone, the flooding should be within the Seabrook relicensing purview.

Finally, since Mr. Morey did not identify the steps the NRC plans to take to address flooding at the Seabrook plant, we surmise that the NRC does not consider flooding due to sea-level rise to be a problem. Our concern has escalated since researchers at the Shorenstein Asia-Pacific Research Center at Stanford University in an October 31, 2012, piece in the Washington Post reported that they had conducted a study that assessed the vulnerability of nuclear plants flooding around the world.

The Stanford researchers collected information on plant height, sea wall height and the location of emergency power generators for 89 nuclear plants that lie next to water. They compared this to historical information on high waves triggered by various sources, such as earthquakes, landslides and hurricanes. The study found that the U.S. plants most vulnerable to inundation are the Salem and Hope Creek plants on the New Jersey/Delaware border; the Millstone plant in Connecticut; and the Seabrook plant in New Hampshire (italics added). We strongly urge you to contact the researchersand obtain this invaluable informationfrom them directly.

That said, we ask the NRC-as we did in our August letter-to review the risk that rising sea levels, storm surges or increased groundwater saturation of concrete poses to residents who live in the vicinity of the Seabrook nuclear power plant. As we have stated, we believe it is entirely appropriate to do so within the purview of the license renewal process. But, in the spirit of public safety, which we believe should be paramount-we urge the NRC to use whatever regulatory tools are needed to investigate this critical issue.

Sincerely yours, Bruce Skud andJoannaHammond Co-founders, No More Fukushimas!

2

,4(~& 6'/ 9SV Flat Rate Envelope ONMAIL UNITED STATES POSTAL SERVICE Apply PriorityMail Postage Here S. i.. U.S POSTAGE 11111 liiU PA1 d:U ID liiiNEWBURYPUH

-!7PRIORITY@ = T POTLSERVIE

-UNITD STATES NOV 08 '12 AMOUNT

.MH W-,MAIL ATESPOSrZL SERVICE 1006 20852

$5.90 00081843-09 it *Spcom 4ay ao0 I

IllNIR llllllll lll rll United States Postal Service DIVERY CONFIRMA TIO7M'

'