G20120877/LTR-12-0684 - Ltr. Bruce Skud & Joanne
1484.SU.SUnitd S.-Task Number:raBUG20120877N-1-NRCRq'g -,or CEmETSiElectronic Tracking SystemProtectingPeople and the EntironmentInoratoLead Assignee: NRROEDO Due Date:SECY Due Date:Other Assignees:Other Parties:Subject: Relicensing of SeabrookDescription:CC Routing:OGC, RegionlADAMS Accession Numbers - Incoming:INDr0 rmtioCross Referenceftia-Response / Package:S-SRM\Other: NoLTR-12-0684SoratoAction Type: Appropriate ActionOEDO Concurrence:NoSignature Level: No Signature RequiredOCM Concurrence:NoSpecial Instructions:OCA Concurrence:NoRef. G20120877. For Appropriate Action. If a response is determined, please be sure to create anADAMS Package to include the incoming (version we forward to you from DPC), with response andprocess accordingly. Copies should be sent to RidsEdoMailCenter and RidsSecyMailCenter.Originator Name: Bruce Skud and Joanna HammondDate of Incoming: 11/08/2012Originator Org: No MoreDocument Received by OEDO Date: 11/15/2012FukushimasDate Response Requested byAadressee: unairman IvIacTarlaneIncoming Task: Letter(Ae- S C /'-(7Originator:OEDO POC: Dan Merzke i 0e(lbs-i SZECV-6(
OFFICE OF THE SECRETARYCORRESPONDENCE CONTROL TICKETDate Primted.-Nov 15, 2012 09:46PAPER NUMBER:LTR- 12-0684LOGGING DATE:11/15/2012ACTION OFFICE:AUTHOR:Bruce SkudAFFILIATION:MAADDRESSEE:CHRM Allison MacfarlaneSUBJECT:Concerns regarding the Seabrook StationACTION:AppropriateDISTRIBUTION:RFLETTER DATE;11/08/2012ACKNOWLEDGED.NoSPECIAL HANDLING:NOTES:FILE LOCATION:DATE DUE:ADAMSDATE SIGNED:EDO-- G20120877
No More Fukushimas!c/o Bruce Skud14 Olive StreetNewburyport, MA 01950The Honorable Allison M. Macfarlane, ChairNuclear Regulatory Commission11555 Rockville PikeRockville, MD 20852November 8, 2012Dear 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 (October17, 2012) came from Dennis Morey, Chief, Project Manager 1, Projects Branch Division of LicenseRenewal, Office of Nuclear Reactor Regulation (Docket No. 50-443).In our letter, we highlighted a concern openly discussed NRC meeting April 26, 2012, on Seabrookrelicensing held in Hampton, New Hampshire. Data indicates that due to climate change there could bean increase in sea levels and storm surges that would affect the Seabrook plant. Obviously, the floodingof the Seabrook plant campus should be a cause for concern, especially since it the flooding is projectedto 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 levelinformation was of any relevance to the relicensing of the Seabrook plant:Regarding your concerns about the current design-basis flood level calculations. please notethat these issues are not part of the NRC's review of a license renewal application. A licenserenewal review is not a re-review of the facility licensing basis; rather, it is focused on managingthe age-related degradation of passive systems, structures, and components to ensure they willfulfill their safety-related functions, as specified in the current licensing basis.The NRC has multiple processes to evaluate the adequacy of current plant operations andlicensing bases. Should the NRC become aware at any time of information calling into questionthe continued safe operation of any nuclear power plant, including Seabrook Station, the NRCwill take the appropriate actions as part of the agency's ongoing safety oversight, regardless ofwhether 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 climatechange-related flooding is not an "age-related" deterioration artifact. But, Mr. Morey seems to brushoff the fact that new global climate conditions could completely reconfigure the safety profile of theplant. We believe that whether or not climate-change-related flooding falls within "design-basis floodcalculations" is a hairsplitting issue for bureaucrats. However, for those of who live near the plant it's amajor safety issue. Therefore, if necessary, we respectfully recommend that NRC modify its relicensingconcerns to include global climate change/rising sea levels in its license renewal framework.1
No More Fukushimas!c/o Bruce Skud14 Olive StreetNewburyport, MA 01950Furthermore, Mr. Morey must know that the NRC has identified "alkali-silica reaction (ASR)" as apotential long-term threat to the reliability of the Seabrook plant and that structural degradation due toASR is currently under the NRC's relicensing review. The flooding water will obviously raise levels ofsaltwater saturation, which will accelerate concrete degradation so, on that basis alone, the floodingshould be within the Seabrook relicensing purview.Finally, since Mr. Morey did not identify the steps the NRC plans to take to address flooding at theSeabrook plant, we surmise that the NRC does not consider flooding due to sea-level rise to be aproblem. Our concern has escalated since researchers at the Shorenstein Asia-Pacific Research Centerat Stanford University in an October 31, 2012, piece in the Washington Post reported that they hadconducted 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 ofemergency power generators for 89 nuclear plants that lie next to water. They compared this tohistorical information on high waves triggered by various sources, such as earthquakes, landslides andhurricanes. The study found that the U.S. plants most vulnerable to inundation are the Salem and HopeCreek plants on the New Jersey/Delaware border; the Millstone plant in Connecticut; and the Seabrookplant in New Hampshire (italics added). We strongly urge you to contact the researchersand obtain thisinvaluable 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 vicinityof the Seabrook nuclear power plant. As we have stated, we believe it is entirely appropriate to do sowithin the purview of the license renewal process. But, in the spirit of public safety, which we believeshould be paramount-we urge the NRC to use whatever regulatory tools are needed to investigate thiscritical issue.Sincerely yours,Bruce Skud andJoannaHammondCo-founders, No More Fukushimas!2
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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
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