ML23313A028
| ML23313A028 | |
| Person / Time | |
|---|---|
| Issue date: | 11/09/2023 |
| From: | Abramson S NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML23311A092 | List: |
| References | |
| M231116 | |
| Download: ML23313A028 (1) | |
Text
NRC Public Commission Briefing, Region I, 11/16/23 We are the Citizens Within the 10-Mile Radius Protecting people and the environment across the communities surrounding Seabrook Station.
Sarah Abramson, Executive Director WHAT WE DO:
(1) Real-Time Radiation Monitoring across the 10-mile EPZ (2) Outreach and Education on emergency preparedness resources (3) Advocacy with regulators and other policy-makers based on C-10 research
- 1. Concerns regarding ASR
- 2. NRC Transparency
- 3. Access to Decision-Making as a Public Stakeholder
- 4. NRC Prioritization of Public Safety
- 5. Suggested Actionable Items C-10 Perspectives Being Shared Learn from the past, prepare for the future, live in the present.
~Thomas S. Monson
- 1) C-10 concerns regarding ASR:
Numerous violations (some repeat)
The burden of proof of Willfulness Weak regulatory instruments Corrective Action Program is a black box Self-regulation is an oxymoron Perplexing NRC interpretation of what is considered Proprietary C-10 testifies at 12/14/22 PRB Hearing on C-10 2.206 Petition Regarding Mishandling of ASR (Credit, WMUR).
Former NRC Chair Allison MacFarlane inspected Seabrooks degraded concrete in an underground electric tunnel.
Post-Fukushima, reactors must show resistance/resilience to even higher amplitude earthquakes than originally designed for. But at least one nuclear reactor in the U.S. suffers from AAR, and with a potential additional life of over 20 years, there is a justifiable concern for its long term structural integrity. This should be thoroughly investigated with utmost scientific rigor.
-Victor Saouma, PhD (pictured left), 2018, Study raises concerns for aging nuclear containment vessel structures. U.C. Boulder).
Nationally-respected experts in the specific field of ASR/AAR notably absent from NRC and NextEra resource list. When their opinions and offers of sharing research continue to be rejected, they continue to come to C-10.
- 1) C-10 concerns regarding ASR: (cont.)
Saouma, V., (2022). Spatial and Temporal Visualization of AAR Evolution; Cooling Tower Example. p3.
- 2) NRC Transparency
Inspectors (Resident, Reactor) MOST interaction, HIGHEST transparency
Branch Chief
Public Relations
Project Managers Assigned as our Sole Contacts/Liaisons with:
Advisory Committee on Reactor Safeguards (ACRS)
Performance Review Board (PRB)
Office of Nuclear Reactor Regulation (NRR)
C-10 experiences a spectrum of transparency depending on the WHO and the WHAT we are asking.
(gatekeeping has been a frustration)
- 3) Access to Decision-Making as a Public Stakeholder Request for hearing/public meeting 2.206 Petition Process Lack of notification of public meetings/hearings Lack of transcripts or recordings of public meetings/hearings So, sometimes we are allowed in the room but are our points really being considered?
- 4) NRC Prioritization of Public Safety
Follow up on violations
License renewal approval
License Amendment Requests (LAR)
Changes to Licensee Emergency Plan Graph from NRC E.D. of Operations, Daniel Dormans Strategic Programmatic Overview of the Operating and New Reactor Business Lines, Nov. 2, 2023 (ML23299A185).
- 5) Actionable items for NRC consideration
Make public the status of Corrective Actions on violations if published in a public report such as an integrated inspection report.
Notifications:
Send ADAMS email alerts for all documents, not just those authored by the NRC.
Extend same email notification option to public meetings/hearings.
Opportunities for public meeting/hearing:
IF a public meeting/hearing is possible, include a notice in NRC cover letters accepting LARs for review, and other administrative workflows.
Offer webcast of annual public safety briefings.
Generate and make public recordings of all public meetings.
Revisit guidance on what is proprietary and what can be accessed by the public. (If C-10 requests a small amount of data that might illustrate an issue at an NPP, and NRC suggests the FOIA process, that is an indicator that politics rather than rationale are being applied to what can be shared with the public.)
Insider perspectives that we share.
Your group is critical. We oversee Seabrook but you oversee us. Just like Seabrook is susceptible to groupthink, were susceptible as well.
I think its critical that groups like yours watch what we doI think thats critical in a functional society, what you do is critical and its respected.
Theres no such thing as zero risk. Its good that you are there watching the decisions being made. - Former NRC Inspector Experience taught me about the spotlight effect. NRC managers are primarily concerned about their careers. A safety concern raised at a rural plantis most likely to cause the owner to complain. There is no local group or media interest. So inspectors cannot raise concerns at these dark plants. - Former NRC employee