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{{#Wiki_filter:OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Jun 13, 2011 08:00 PAPER NUMBER: LOGGING DATE: 06/0812011 ACTION OFFICE: AUTHOR: AFFILIATION:
{{#Wiki_filter:OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Jun 13, 2011 08:00 PAPER NUMBER:                                               LOGGING DATE: 06/0812011 ACTION OFFICE:
ADDRESSEE:  
AUTHOR:           REP Edward Markey AFFILIATION:     CONG ADDRESSEE:       Gregory Jaczko


==SUBJECT:==
==SUBJECT:==
ACTION: DISTRIBUTION:
Urges the NRC to immediately announce its intent to deny NexEra Energy Seabrook, the license for the Seabrook nuc powe plant ACTION:          Signature of Chairman DISTRIBUTION:    RF, EDO, OCAA, OCA to Ack.
LETTER DATE: ACKNOWLEDGED SPECIAL HANDLING:
LETTER DATE:      06/08/2011 ACKNOWLEDGED      No SPECIAL HANDLING: Chrm vs. Comm. Correspondence to be determined once SECY receives the draft response.
NOTES: FILE LOCATION:
DATE DUE: REP Edward Markey CONG Gregory Jaczko Urges the NRC to immediately announce its intent to deny NexEra Energy Seabrook, the license for the Seabrook nuc powe plant Signature of RF, EDO, OCAA, OCA to 06/08/2011 No Chrm vs. Comm. Correspondence to be determined once SECY receives the draft response.
OGC has lead and should consult w/EDO & OCAA in preparing the response.
OGC has lead and should consult w/EDO & OCAA in preparing the response.
ADAMS 06/29/2011 DATE SIGNED:
NOTES:
(!!:ungr£s5 of flre lfinii.eb ill.ud,inglutt, llC! ZUS15 June 8,2011 The Honorable Greg Jaczko Chairman Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852  
FILE LOCATION:    ADAMS DATE DUE:        06/29/2011                     DATE SIGNED:
 
(!!:ungr£s5 of flre lfinii.eb j;tah~a ill.ud,inglutt, llC! ZUS15 June 8,2011 The Honorable Greg Jaczko Chairman Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852


==Dear Chairman JaczKo:==
==Dear Chairman JaczKo:==
We write to urge the Nuclear Regulatory Commission (NRC) to immediately announce its intent to deny NextEra Energy Seabrook, the licensee for the Seabrook nuclea:r power plant, its June 1, 2010 request! for a twenty year operating license that would begin in 2030 and end in 2050 2
 
* In addition, we urge the NRC to adopt a more general policy of disallowing requests by nuclear power reactor licensees for a twenty-year license extension as early as twenty years prior to the time ilieir current licenses expire. Granting license extensions so far in advance is particularly unwise in the wake of the Fukushima meltdowns, as the NRC learns of new vulnerabilities at U.S. nuclear power plants that should impact its future licensing decisions related to both new and existing facilities.
We write to urge the Nuclear Regulatory Commission (NRC) to immediately announce its intent to deny NextEra Energy Seabrook, the licensee for the Seabrook nuclea:r power plant, its June 1, 2010 request! for a twenty year operating license that would begin in 2030 and end in 2
Moreover, there are additional aging and other safety issues that could not possibly be contemplated or fully understood a full twenty years in advance of the nuclear reactor's licensed-life, as exemplified by the May 30,2011 article in Globe 3 noting that concrete surrounding a safety-related tunnel at the Seabrook nuclear power plant had lost 22 percent of its strength due to being saturated with water for the past decade, If safety structures that are supposed to help cool the Seabrook nuclear power plant are experiencing such alarming degradation during the reactor's  
2050
'adolescence', there is simply no way that the NRC can guarantee that it will remain safe until it enters its 'golden years' almost 40 years from now. The NRC is currently considering twenty-year license renewal applications for 16 existing reactors at 11 power plant locations.
* In addition, we urge the NRC to adopt a more general policy of disallowing requests by nuclear power reactor licensees for a twenty-year license extension as early as twenty years prior to the time ilieir current licenses expire.
4 The NRC website states: "A nuclear power plant licensee may apply for a license renewal as early as 20 years before the expiration of its current license:,5 Indeed, an examination of NRC records indicates that since 2009, the NRC has begun reviewing license renewal applications for eight reactors more than ten years (and in some cases 1 http://www .nrc.gov/reactors/operatingllicensing/renewalfapplicationslseabrook.html 2 http://articles.boslon.coml2011-03-2 7 IbostongJobef29352917
Granting license extensions so far in advance is particularly unwise in the wake of the Fukushima meltdowns, as the NRC learns of new vulnerabilities at U.S. nuclear power plants that should impact its future licensing decisions related to both new and existing facilities.
_l_seabrook-station-nrc-nuclear-plant j http://articles.boston.com/2011-05-30/lifestyle/29600250
Moreover, there are additional aging and other safety issues that could not possibly be contemplated or fully understood a full twenty years in advance of the nuclear reactor's end-of licensed-life, as exemplified by the May 30,2011 article in IJ1~.Boston Globe3 noting that concrete surrounding a safety-related tunnel at the Seabrook nuclear power plant had lost 22 percent of its strength due to being saturated with water for the past decade, If safety structures that are supposed to help cool the Seabrook nuclear power plant are experiencing such alarming degradation during the reactor's 'adolescence', there is simply no way that the NRC can guarantee that it will remain safe until it enters its 'golden years' almost 40 years from now.
_J_nrc-seabrook-station-nuclear-power-plant 4 http://www.nrc.govJreactors!operntingl!icensinglrenewallapplications.html 5 http://www.nrc.gov/reading-rmldoc-collections/fact-sheetsllicense-renewal-bg.htmI Page 2 Letter to NRC June 8, 2011 closer to twenty years) before the reactors' current operating license expires.6 In fact there is at least one case where renewal was granted more than 20 years in advance. According to its renewal application found on NRC's website, the Catawba Nuclear Power Station 1 in South had its l.icense renewed 21 years and 1 day before the previous license was set to expire.; There is little reason for such early consideration of a license renewal application by the NRC, as the NRC expects to complete its review of renewal applications within 30 months from receiving the application, if a hearing is required, or within 22 months if no hearing is required.
The NRC is currently considering twenty-year license renewal applications for 16 4
8 An examination of'N"RC re-licensing records indicates that the NRC has approved license renewals for 66 reactors with an average time of 25 months from the time it receives the application to the time the renewal \vas approved.
existing reactors at 11 power plant locations. The NRC website states: "A nuclear power plant licensee may apply for a license renewal as early as 20 years before the expiration of its current license:,5 Indeed, an examination of NRC records indicates that since 2009, the NRC has begun reviewing license renewal applications for eight reactors more than ten years (and in some cases 1 http://www .nrc.gov/reactors/operatingllicensing/renewalfapplicationslseabrook.html 2 http://articles.boslon.coml2011-03-2 7IbostongJobef29352917_l_seabrook-station-nrc-nuclear-plant j http://articles.boston.com/2011-05-30/lifestyle/29600250_ J_nrc-seabrook-station-nuclear-power-plant 4 http://www.nrc.govJreactors!operntingl!icensinglrenewallapplications.html 5 http://www.nrc.gov/reading-rmldoc-collections/fact-sheetsllicense-renewal-bg.htmI
If the lmderstanding of the vulnerabilities associated with nuclear power plants never changed, then making a decision in the year 2012 9 to allow (for example) the Seabrook nuclear power plant to operate until the year 2050 might seem reasonable.
 
But this is not the case. Some Safety and Aging Issues Might Not Be Known Decades In Advance As The Boston Globe ankle lO noted, water seepage beneath the Seabrook power plant has led to significant degradation of the concrete associated with a tumlcl that is part of the reactor's cooling system, and NextEra also identified "corroded steel supports, piping, and anchor bolts in other areas they inspected".
Page 2 Letter to NRC June 8, 2011 closer to twenty years) before the reactors' current operating license expires. 6 In fact there is at least one case where renewal was granted more than 20 years in advance. According to its renewal application found on NRC's website, the Catawba Nuclear Power Station 1 in South Caroli~a had its l.icense renewed 21 years and 1 day before the previous license was set to expire.; There is little reason for such early consideration of a license renewal application by the NRC, as the NRC expects to complete its review of renewal applications within 30 months from receiving the application, if a hearing is required, or within 22 months if no hearing is required. 8 An examination of'N"RC re-licensing records indicates that the NRC has approved license renewals for 66 reactors with an average time of 25 months from the time it receives the application to the time the renewal \vas approved.
As the NRC noted in the May 23 document entitled "NextEra Energy Seabrook NRC License Renewal Inspection Report 05000443/2011007," "the [NRC] inspection team was unable to arrive at a conclusion about the adequacy of your aging management review for the alkali-silica reaction issue," a reaction between concrete and water that is associated with some of the concrete structures at Seabrook.
If the lmderstanding of the vulnerabilities associated with nuclear power plants never changed, then making a decision in the year 20129 to allow (for example) the Seabrook nuclear power plant to operate until the year 2050 might seem reasonable. But this is not the case.
If these problems are surfacing a mere 21 years into Seabrook's operating life, it seems impossible to conclude that the reactor can be safely operated between the years 2030-50. Additionally, climate change has the potential!
Some Safety and Aging Issues Might Not Be Known Decades In Advance As The Boston Globe ankle lO noted, water seepage beneath the Seabrook power plant has led to significant degradation of the concrete associated with a tumlcl that is part of the reactor's cooling system, and NextEra also identified "corroded steel supports, piping, and anchor bolts in other areas they inspected". As the NRC noted in the May 23 document entitled "NextEra Energy Seabrook ~ NRC License Renewal Inspection Report 05000443/2011007," "the
1 to impact nuclear power plants through increased temperatures of cooling water, rising sea levels, more frequent and severe heat waves and more intense rainfall with associated Hooding. Rep. Markey made a request to the Government Accountability Office in 2010 to review the adequacy of NRC regulations given G The eight reactors (and years remaining on their operating licenses when the re-Iicense applications were filed) are Seabrook (19.8 years); Hope Creek (\6.7 years); Salem Nuclear Generating Station, Unit 2 (10.7 years); Diablo Canyon Power Plant, Unit I (15 years), Unit 2 (15.& years); Columbia Generating Station (13.9 years); South Texas Project, Unit I (16.8 Unit 2 (18.1 years). http://www.nrc.goy/reactors/operatingllicensing/renewal.htmt 7 http://www .nrc. gOY Ireactorsl operatingll icensinglrenewaIl appli cati ons/mcguire-catawbalduke-Ira.pdf , http://WVNI.nrc.goy ireactors!operatingll tcens inglrenewalJprocess.htm J 9 http://v.'Ww.nrc.govireactors/operatingilicensingirenewallapplications/seabl'ook.htm I In http://articies.boston.comJ2011-05-30IJifestyle/29600250
[NRC] inspection team was unable to arrive at a conclusion about the adequacy of your aging management review for the alkali-silica reaction issue," a reaction between concrete and water that is associated with some of the concrete structures at Seabrook. If these problems are surfacing a mere 21 years into Seabrook's operating life, it seems impossible to conclude that the reactor can be safely operated between the years 2030-50.
_1_ nrc-seabrook-station -nuc lear-power-plant 11 http://www
Additionally, climate change has the potential! 1 to impact nuclear power plants through increased temperatures of cooling water, rising sea levels, more frequent and severe heat waves and more intense rainfall with associated Hooding. Rep. Markey made a request to the Government Accountability Office in 2010 to review the adequacy ofNRC regulations given G The   eight reactors (and years remaining on their operating licenses when the re-Iicense applications were filed) are Seabrook (19.8 years); Hope Creek (\6.7 years); Salem Nuclear Generating Station, Unit 2 (10.7 years); Diablo Canyon Power Plant, Unit I (15 years), Unit 2 (15.& years); Columbia Generating Station (13.9 years); South Texas Project, Unit I (16.8 yea~s), Unit 2 (18.1 years).
.gJobalchange.gov Iw hat-we-do!
http://www.nrc.goy/reactors/operatingllicensing/renewal.htmt 7 http://www .nrc. gOYIreactorsloperatingll icensinglrenewaIlappli cati ons/mcguire-catawbalduke-Ira.pdf
assessmentlprevious-assessments/globa  
, http://WVNI .nrc.goyireactors!operatingll tcens inglrenewalJprocess.htm J 9 http://v.'Ww.nrc.govireactors/operatingilicensingirenewallapplications/seabl'ook.htm I In http://articies.boston.comJ2011-05-30IJifestyle/29600250_1_ nrc-seabrook-station -nuc lear-power-plant 11 http://www.gJobalchange.govIwhat-we-do!assessmentlprevious-assessments/globa \-cIimate-change-impacts- in the-us-2009
\-c I imate-change-impacts-the-us-2009 Page 3 Letter to NRC June 8,2011 climate change. l2 In 2007, the Browns Ferry unit 2 reactor in Ala.bama had to shut do\vn because the intake water was so warm that, after being warmed nearly 30°F going through the plant, its release back into the environment would have violated the Clean Water Act. 13 Moreover, for some coastal nuclear power piants such as Seabrook, a January 2011 study shows that the storm surge from a Category 4 or 5 hurricane could completely inundate the plants within their expected operating lifetimes.
 
14 But sea levei rise may be even more rapid than understood in 2007, given the accelerating melting of the Greenland and Antarctic ice sheets. b Current projections of sea level rise suggest an average 4 foot rise from 1990 levels by 2100. 16 The NRC Has Not Incorporated the Lessons of Fukushima Into its Regulations or Analysis The Japanese nuclear meltdovm shows how readily a total loss of electricity can result in major radiation release -and many have speculated that this vulnerability may have been especially pronounced in Japan because the nuclear reactors involved are much older designs. A staff report recently issued by Rep. Markey'S office l7 details some of the most glaring safety vulnerabilities exposed by the Fukushima events. As operating nuclear power plants reach the end of their initial forty year lifetime and enter their twenty year extended operation periods, there is cerlain to be new information about safety issues that the NRC should be continually evaluating.
Page 3 Letter to NRC June 8,2011 climate change. l2 In 2007, the Browns Ferry unit 2 reactor in Ala.bama had to shut do\vn because the intake water was so warm that, after being warmed nearly 30°F going through the plant, its release back into the environment would have violated the Clean Water Act. 13 Moreover, for some coastal nuclear power piants such as Seabrook, a January 2011 study shows that the storm surge from a Category 4 or 5 hurricane could completely inundate the plants within their expected operating lifetimes. 14 But sea levei rise may be even more rapid than wa~
Additionally, as has been noted previously, IS we are concerned that the Commission has granted license extensions for four nuclear reactors since the Fukushima meltdown without requiring licensees to comply with the requirements ofNEPA that any "new and significant" information regarding the environmental consequences of operating the nuclear reactor be included in the application.
understood in 2007, given the accelerating melting of the Greenland and Antarctic ice sheets. b Current projections of sea level rise suggest an average 4 foot rise from 1990 levels by 2100. 16 The NRC Has Not Incorporated the Lessons of Fukushima Into its Regulations or Analysis The Japanese nuclear meltdovm shows how readily a total loss of electricity can result in major radiation release - and many have speculated that this vulnerability may have been especially pronounced in Japan because the nuclear reactors involved are much older designs. A l7 staff report recently issued by Rep. Markey'S office details some of the most glaring safety vulnerabilities exposed by the Fukushima events. As operating nuclear power plants reach the end of their initial forty year lifetime and enter their twenty year extended operation periods, there is cerlain to be new information about aging~related safety issues that the NRC should be continually evaluating.
It is clear that the environmental consequences of Fukushima will be "new and significant" compared to those that had been previously contemplated, and that an assessment of NRC's safety regulations will also reveal "new and significant" vulnerabilities when viewed through the post-Fukushima lens. The NRC should not be approving any license e:x'tensions, let alone those that are only needed to continue operations more than a decade from now, before all of these vulnerabilities are both fully understood and addressed.
Additionally, as has been noted previously, IS we are concerned that the Commission has granted license extensions for four nuclear reactors since the Fukushima meltdown without requiring licensees to comply with the requirements ofNEPA that any "new and significant" information regarding the environmental consequences of operating the nuclear reactor be included in the application. It is clear that the environmental consequences of Fukushima will be "new and significant" compared to those that had been previously contemplated, and that an assessment of NRC's safety regulations will also reveal "new and significant" vulnerabilities when viewed through the post-Fukushima lens. The NRC should not be approving any license e:x'tensions, let alone those that are only needed to continue operations more than a decade from now, before all of these vulnerabilities are both fully understood and addressed.
Given the changes to our planet, as well as changes to our tmderstanding of safety-related vulnerabilities brought on by either accidents, extreme weather or geologic events, or unanticipated safety problems, the NRC should end its practice of accepting and granting license extensions t\venty years before the license expires -and should reject those that it has already 11 http://markey.house.gov/docslgaoinspection.pdf l3 http://www .ucsusa.orglassets/documents!nuc lear yowerl20071204-ucs-brief-got -warcr.pdf 14 linkillghub.elsevier,com!retrieveipii/S030 14215 J 0007329 15 http://www.agu,orgipubs!crossrefl2011/2011GL046583,shtml t6 http://wv..\v.naturc.com/climatei2010n004!full/climate.201O.29.htmI http://markey.house.govlindex.php?oplion=conlent&task=view&id=4352&Itemid=125 . IIii I.esl d ocumentsi20 I }. 05-13 _EJMtoNRCNEPA.pdf Page 4 Letter to l\t'RC June 8, 201] received until the reactor has operated fur more time so that potential safety problems can be identified and more fully understood.
Given the changes to our planet, as well as changes to our tmderstanding of safety-related vulnerabilities brought on by either accidents, extreme weather or geologic events, or unanticipated safety problems, the NRC should end its practice of accepting and granting license extensions t\venty years before the license expires - and should reject those that it has already 11 http://markey.house.gov/docslgaoinspection.pdf l3 http://www .ucsusa.orglassets/documents!nuc learyowerl20071204-ucs-brief-got-warcr.pdf 14 linkillghub.elsevier,com!retrieveipii/S030 14215 J0007329 15 http://www.agu,orgipubs!crossrefl2011/2011GL046583,shtml t6 http://wv..\v.naturc.com/climatei2010n004!full/climate.201O.29.htmI l~ http://markey.house.govlindex.php?oplion=conlent&task=view&id=4352&Itemid=125 .
The NRC should stop making the dangerous assumption that risks, and our understanding of them, wi1l remain static for decades. Sincerely, . Edward J. .. ey* .Jolm F. Tierney -/}}
I ~http://democrats.naturulresources.house.gov/sites!democrats.resoufcescommittee.house.go\' Iii I.esl documentsi20 I }.
05-13 _EJMtoNRCNEPA.pdf
 
Page 4 Letter to l\t'RC June 8, 201]
received until the reactor has operated fur more time so that potential safety problems can be identified and more fully understood. The NRC should stop making the dangerous assumption that risks, and our understanding of them, wi1l remain static for decades.
Sincerely,
                                                            ~(:~.~. .
~.~
Edward J.     .. ey*           .                             Jolm F. Tierney   - /}}

Latest revision as of 19:41, 12 November 2019

LTR-11-0333 - Incoming Letter from REP Markey and REP Tierney Urging the NRC to Immediately Announce Its Intent to Deny Nextera Energy Seabrook, the License for the Seabrook Nuclear Power Plant
ML11164A241
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 06/08/2011
From: Markey E, Tierney J
US Congress
To: Jaczko G
NRC/Chairman
Shared Package
ML11164A243 List:
References
LTR-11-0333
Download: ML11164A241 (5)
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Text

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Jun 13, 2011 08:00 PAPER NUMBER: LOGGING DATE: 06/0812011 ACTION OFFICE:

AUTHOR: REP Edward Markey AFFILIATION: CONG ADDRESSEE: Gregory Jaczko

SUBJECT:

Urges the NRC to immediately announce its intent to deny NexEra Energy Seabrook, the license for the Seabrook nuc powe plant ACTION: Signature of Chairman DISTRIBUTION: RF, EDO, OCAA, OCA to Ack.

LETTER DATE: 06/08/2011 ACKNOWLEDGED No SPECIAL HANDLING: Chrm vs. Comm. Correspondence to be determined once SECY receives the draft response.

OGC has lead and should consult w/EDO & OCAA in preparing the response.

NOTES:

FILE LOCATION: ADAMS DATE DUE: 06/29/2011 DATE SIGNED:

(!!:ungr£s5 of flre lfinii.eb j;tah~a ill.ud,inglutt, llC! ZUS15 June 8,2011 The Honorable Greg Jaczko Chairman Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852

Dear Chairman JaczKo:

We write to urge the Nuclear Regulatory Commission (NRC) to immediately announce its intent to deny NextEra Energy Seabrook, the licensee for the Seabrook nuclea:r power plant, its June 1, 2010 request! for a twenty year operating license that would begin in 2030 and end in 2

2050

  • In addition, we urge the NRC to adopt a more general policy of disallowing requests by nuclear power reactor licensees for a twenty-year license extension as early as twenty years prior to the time ilieir current licenses expire.

Granting license extensions so far in advance is particularly unwise in the wake of the Fukushima meltdowns, as the NRC learns of new vulnerabilities at U.S. nuclear power plants that should impact its future licensing decisions related to both new and existing facilities.

Moreover, there are additional aging and other safety issues that could not possibly be contemplated or fully understood a full twenty years in advance of the nuclear reactor's end-of licensed-life, as exemplified by the May 30,2011 article in IJ1~.Boston Globe3 noting that concrete surrounding a safety-related tunnel at the Seabrook nuclear power plant had lost 22 percent of its strength due to being saturated with water for the past decade, If safety structures that are supposed to help cool the Seabrook nuclear power plant are experiencing such alarming degradation during the reactor's 'adolescence', there is simply no way that the NRC can guarantee that it will remain safe until it enters its 'golden years' almost 40 years from now.

The NRC is currently considering twenty-year license renewal applications for 16 4

existing reactors at 11 power plant locations. The NRC website states: "A nuclear power plant licensee may apply for a license renewal as early as 20 years before the expiration of its current license:,5 Indeed, an examination of NRC records indicates that since 2009, the NRC has begun reviewing license renewal applications for eight reactors more than ten years (and in some cases 1 http://www .nrc.gov/reactors/operatingllicensing/renewalfapplicationslseabrook.html 2 http://articles.boslon.coml2011-03-2 7IbostongJobef29352917_l_seabrook-station-nrc-nuclear-plant j http://articles.boston.com/2011-05-30/lifestyle/29600250_ J_nrc-seabrook-station-nuclear-power-plant 4 http://www.nrc.govJreactors!operntingl!icensinglrenewallapplications.html 5 http://www.nrc.gov/reading-rmldoc-collections/fact-sheetsllicense-renewal-bg.htmI

Page 2 Letter to NRC June 8, 2011 closer to twenty years) before the reactors' current operating license expires. 6 In fact there is at least one case where renewal was granted more than 20 years in advance. According to its renewal application found on NRC's website, the Catawba Nuclear Power Station 1 in South Caroli~a had its l.icense renewed 21 years and 1 day before the previous license was set to expire.; There is little reason for such early consideration of a license renewal application by the NRC, as the NRC expects to complete its review of renewal applications within 30 months from receiving the application, if a hearing is required, or within 22 months if no hearing is required. 8 An examination of'N"RC re-licensing records indicates that the NRC has approved license renewals for 66 reactors with an average time of 25 months from the time it receives the application to the time the renewal \vas approved.

If the lmderstanding of the vulnerabilities associated with nuclear power plants never changed, then making a decision in the year 20129 to allow (for example) the Seabrook nuclear power plant to operate until the year 2050 might seem reasonable. But this is not the case.

Some Safety and Aging Issues Might Not Be Known Decades In Advance As The Boston Globe ankle lO noted, water seepage beneath the Seabrook power plant has led to significant degradation of the concrete associated with a tumlcl that is part of the reactor's cooling system, and NextEra also identified "corroded steel supports, piping, and anchor bolts in other areas they inspected". As the NRC noted in the May 23 document entitled "NextEra Energy Seabrook ~ NRC License Renewal Inspection Report 05000443/2011007," "the

[NRC] inspection team was unable to arrive at a conclusion about the adequacy of your aging management review for the alkali-silica reaction issue," a reaction between concrete and water that is associated with some of the concrete structures at Seabrook. If these problems are surfacing a mere 21 years into Seabrook's operating life, it seems impossible to conclude that the reactor can be safely operated between the years 2030-50.

Additionally, climate change has the potential! 1 to impact nuclear power plants through increased temperatures of cooling water, rising sea levels, more frequent and severe heat waves and more intense rainfall with associated Hooding. Rep. Markey made a request to the Government Accountability Office in 2010 to review the adequacy ofNRC regulations given G The eight reactors (and years remaining on their operating licenses when the re-Iicense applications were filed) are Seabrook (19.8 years); Hope Creek (\6.7 years); Salem Nuclear Generating Station, Unit 2 (10.7 years); Diablo Canyon Power Plant, Unit I (15 years), Unit 2 (15.& years); Columbia Generating Station (13.9 years); South Texas Project, Unit I (16.8 yea~s), Unit 2 (18.1 years).

http://www.nrc.goy/reactors/operatingllicensing/renewal.htmt 7 http://www .nrc. gOYIreactorsloperatingll icensinglrenewaIlappli cati ons/mcguire-catawbalduke-Ira.pdf

, http://WVNI .nrc.goyireactors!operatingll tcens inglrenewalJprocess.htm J 9 http://v.'Ww.nrc.govireactors/operatingilicensingirenewallapplications/seabl'ook.htm I In http://articies.boston.comJ2011-05-30IJifestyle/29600250_1_ nrc-seabrook-station -nuc lear-power-plant 11 http://www.gJobalchange.govIwhat-we-do!assessmentlprevious-assessments/globa \-cIimate-change-impacts- in the-us-2009

Page 3 Letter to NRC June 8,2011 climate change. l2 In 2007, the Browns Ferry unit 2 reactor in Ala.bama had to shut do\vn because the intake water was so warm that, after being warmed nearly 30°F going through the plant, its release back into the environment would have violated the Clean Water Act. 13 Moreover, for some coastal nuclear power piants such as Seabrook, a January 2011 study shows that the storm surge from a Category 4 or 5 hurricane could completely inundate the plants within their expected operating lifetimes. 14 But sea levei rise may be even more rapid than wa~

understood in 2007, given the accelerating melting of the Greenland and Antarctic ice sheets. b Current projections of sea level rise suggest an average 4 foot rise from 1990 levels by 2100. 16 The NRC Has Not Incorporated the Lessons of Fukushima Into its Regulations or Analysis The Japanese nuclear meltdovm shows how readily a total loss of electricity can result in major radiation release - and many have speculated that this vulnerability may have been especially pronounced in Japan because the nuclear reactors involved are much older designs. A l7 staff report recently issued by Rep. Markey'S office details some of the most glaring safety vulnerabilities exposed by the Fukushima events. As operating nuclear power plants reach the end of their initial forty year lifetime and enter their twenty year extended operation periods, there is cerlain to be new information about aging~related safety issues that the NRC should be continually evaluating.

Additionally, as has been noted previously, IS we are concerned that the Commission has granted license extensions for four nuclear reactors since the Fukushima meltdown without requiring licensees to comply with the requirements ofNEPA that any "new and significant" information regarding the environmental consequences of operating the nuclear reactor be included in the application. It is clear that the environmental consequences of Fukushima will be "new and significant" compared to those that had been previously contemplated, and that an assessment of NRC's safety regulations will also reveal "new and significant" vulnerabilities when viewed through the post-Fukushima lens. The NRC should not be approving any license e:x'tensions, let alone those that are only needed to continue operations more than a decade from now, before all of these vulnerabilities are both fully understood and addressed.

Given the changes to our planet, as well as changes to our tmderstanding of safety-related vulnerabilities brought on by either accidents, extreme weather or geologic events, or unanticipated safety problems, the NRC should end its practice of accepting and granting license extensions t\venty years before the license expires - and should reject those that it has already 11 http://markey.house.gov/docslgaoinspection.pdf l3 http://www .ucsusa.orglassets/documents!nuc learyowerl20071204-ucs-brief-got-warcr.pdf 14 linkillghub.elsevier,com!retrieveipii/S030 14215 J0007329 15 http://www.agu,orgipubs!crossrefl2011/2011GL046583,shtml t6 http://wv..\v.naturc.com/climatei2010n004!full/climate.201O.29.htmI l~ http://markey.house.govlindex.php?oplion=conlent&task=view&id=4352&Itemid=125 .

I ~http://democrats.naturulresources.house.gov/sites!democrats.resoufcescommittee.house.go\' Iii I.esl documentsi20 I }.

05-13 _EJMtoNRCNEPA.pdf

Page 4 Letter to l\t'RC June 8, 201]

received until the reactor has operated fur more time so that potential safety problems can be identified and more fully understood. The NRC should stop making the dangerous assumption that risks, and our understanding of them, wi1l remain static for decades.

Sincerely,

~(:~.~. .

~.~

Edward J. .. ey* . Jolm F. Tierney - /

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