ML19275G785

Limited Appearance Statement from Daniel Edson Regarding the Seabrook Station Unit 1 License Amendment Application

ML19275G785
Person / Time
Site:	Seabrook
Issue date:	10/02/2019
From:	Edson D - No Known Affiliation
To:	Mattison M, Ronald Spritzer Atomic Safety and Licensing Board Panel
SECY/RAS
References
50-443-LA-2, ASLBP 17-953-02-LA-BD01
Download: ML19275G785 (2)

Text

Daniel V. Edson 11 Salem Street, Newburyport, Massachusetts 01950 978-417-1476- dandeson@gmail.com October 2, 2019 Administrative Judge Ronald M. Spritzer Atomic Safety and Licensing Board c/o Molly Mattison Mail Stop T3A27 US Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Chairman Spritzer,

Having sat through hours of comment and testimony at the Atomic Safety and Licensing Board (ASLB) evidentiaiy hearing in Newburyport, Massachusetts, the week of September 23, 2019, I feel that the ASLB has no option but to rule in favor of the contention by the C-10 Research and Education Foundation (C-10), both because the NextEra Seabrook concrete testing program

yielded data that are not representative of the [alkali-silica] reaction's progression at Seabroo'/c' and because "the resulting monitoring, acceptance criteria, and inspection intervals are inadequate."

Testimony from C-10 and NextEra, and comments from Nuclear Regulatory Commission (NRC) smfl: clearly revealed that much additional - and more meaningful - data could have been obtained for a number of reasons, including:

• Material used in NextEra's testing was not representative of material used in Seabrook construction.

• Environmental conditions at the Texas test facility could not have been even close to the environmental conditions on the coast of New Hampshire.

• Additional - and different - tests would have provided significantly more data, notably data that would indicate how the alkali-silica reaction (ASR) might progress.

• Concrete/stmctural consultants,dir.ectly: in.v.ol¥ed with- testing lacked deep, credentialed ASR expertise.

• Test results were not peer reviewed (a stunning lapse of scientific rigor).

Ruling in C-lO's favor is not tantamount to an admonishment ofNextEra or the NRC; ruling in C-lO's favor simply acknowledges what is obvious, that the Seabrook ASR testing to date is insufficient. (Certainly, Next.Era and the NRC undertook the Texas testing with good intentions and did obtain some valid and pertinent test results.)

With ten years remaining on NextEra Seabrook's current license, I see no justification for hurrying the process of determining the severity of ASR at Seabrook Station and - if appropriate

- for devising a monitoring program.

Respectfully submitted,

From: Dan Edson To: Mattison, Molly

Subject:

[External_Sender] Comments for ASLB 9/23-27/2019 Evidentiary Hearing Date: Wednesday, October 02, 2019 11:55:42 AM Attachments: NRC ASLB Spritzer 2019-10 C-10 NextEra hearing comments.pdf

Dear Molly,

I understand the Atomic Safety and Licensing Board is still taking comments related to the C-10 Research and Education Foundation's challenge to NextEra Seabrook's concrete testing program. Please accept the attached comments.

Best regards, Dan Edson Dan Edson l 978 417-1476