The C-10 Blog

3.8-Magnitude Earthquake Brings Renewed Focus on Seabrook Station's Cracking Concrete

Thu, 20 Feb 2025 19:10:01 GMT

A recent earthquake shook Seabrook Station Nuclear Power Plant. With known concrete cracking issues, what is the outlook for nuclear safety at the plant?

On January 27, 2025, a 3.8-magnitude earthquake struck off the coast of southern Maine, with the epicenter about 16 miles northeast of the NextEra Seabrook Station Nuclear Power Plant. By New England standards this was a noteworthy event, and shaking was felt throughout the Northeast—including at our C-10 offices in Amesbury, MA. Two smaller aftershocks also occurred in the days that followed the initial earthquake.

As an organization focused on nuclear safety at Seabrook, C-10 immediately sought to learn whether the nuclear plant was impacted by the earthquake. After 34 years in operation, Seabrook Station is an aging plant, with aging components, and aging infrastructure. This includes documented problems with concrete degradation, as C-10 highlighted after a prior earthquake in 2018 . In 2019, C-10 obtained a successful ruling on a legal challenge for more robust monitoring of that same concrete problem.

Heightened damage risks from earthquakes were a key concern when C-10 pushed for more thorough concrete monitoring and studies at Seabrook Station. With this recent seismic event among the largest earthquakes our region has seen in decades, what are the possible implications for nuclear safety?

Assessing Impacts of the 1/27/25 Earthquake

Following the earthquake, C-10 quickly turned to our radiation-monitoring network , the only real-time system to monitor the effects of the radiological emissions from Seabrook Station. The C-10 monitoring stations provide live radiation data and will rapidly alert C-10 and public health officials if there are abnormally high radiation levels.

Fortunately, after the earthquake, the C-10 system reported that radiation levels had remained within the typical ranges. The chart below shows the levels of beta and gamma radiation detected throughout the day of the earthquake at the C-10 monitoring station located less than a mile from Seabrook Station:

Additionally, minutes after the earthquake C-10 spoke with the Senior Nuclear Regulatory Commission (NRC) Resident Inspector stationed at Seabrook Station. He confirmed the plant would be following an established inspection process to review ground-motion sensors, in order to gauge if a closer inspection of possible damage to structures was prudent. Seabrook Station later released a statement which said that the earthquake “did not impact” plant operations.

Was Seabrook Station designed to withstand earthquakes?

U.S. nuclear plants are designed and built to withstand the most severe seismic hazards anticipated at that location. Additionally, nuclear plants have ground-motion sensors to capture data about the actual forces experienced by plant structures during earthquakes.

Following a seismic event, an earthquake response analysis is conducted to determine the next course of action. This analysis uses ground-motion data and plant design specifications to predict damage levels and quickly determine if operations need to be adjusted. There are three possible outcomes of this analysis:

No action: ground-motion data was not significant enough to cause damage and no adjustments are called for
Operating basis earthquake: data indicated movement was significant enough to warrant decreasing reactor power output, but the plant can remain operating
Safe shutdown earthquake: data indicates the plant may have experienced damage, and steps will be taken to safely shut down the reactor while further assessments are made

Following the recent earthquake, it was determined that plant operations could continue as normal with no adjustments, indicating the ground motion detected was not expected to damage plant structures.

ASR Concrete Degradation at Seabrook Station

If you have been following C-10’s work in recent years, you understand that C-10 brought attention to a type of concrete degradation occurring at Seabrook Station known as alkali-silica reaction (ASR) . This occurs when certain types of concrete aggregates expand due to water exposure. The expansion leads to cracks forming in the surrounding concrete. ASR is an ongoing reaction that advances over time, leading to further degradation. In large structures there is no way to fix this or reverse ASR, and it leads to a reduction in the strength of the damaged concrete that can lead to structures failing.

Seabrook is the only U.S. nuclear plant known to have ASR, and we know it is present in critical plant structures, including the reactor containment dome. The containment dome is a major safety structure, and its integrity is vital to protecting both the public and environment from exposure to the high levels of radiation emitted by the nuclear reactor.

This is why C-10 has long urged that the utmost scientific rigor be applied by the plant owners and federal regulators in order to understand the impacts of ASR at Seabrook Station, including how ASR affects seismic resiliency.

Prior C-10 Efforts to Address ASR Safety Issues

C-10 has advocated to the NRC for greater ASR monitoring and impact assessments at Seabrook, including a technical presentation given to the NRC by an ASR-expert and C-10 advisor just recently in September of 2024. Before that, when Seabrook Station applied to renew their operating license through 2050, C-10 successfully petitioned the NRC to include more frequent ASR inspections and to add the use of ASR monitoring devices as part of the plant’s license renewal. In the last two years C-10 has also pushed back against proposed cuts to the plant’s emergency-response planning, and those efforts helped to block the worst parts of that proposal and saved certain critical roles from being reduced, eliminated, or resulting in increased response times.

These efforts do not do anything to correct the ASR itself, but they do mitigate some of the public-safety risks incurred by its presence. The combination of ASR and earthquakes at Seabrook Station creates a unique risk to public health and safety not present at other U.S. nuclear plants.

Unanswered Questions

What does all of this mean for ongoing safety at Seabrook and the communities surrounding it? While the plant has stated there was no damage from this earthquake initially, some key questions remain:

Did the earthquake further damage ASR-affected structures, particularly the containment dome?

We know ASR-afflicted structures have decreased rigidity, which reduces their ability to withstand forces brought on by earthquakes. Seabrook Station has installed extensometers throughout the plant to help measure the extent of ASR damage, and it is important to use that data to discern if there were any measurable changes following the recent earthquake.

Unfortunately, assessing damage to the containment dome may not be possible for over a year. Humans cannot enter the containment room while the plant is operational, due to dangerously high levels of radiation. The most likely opportunity for it to be assessed will be during Seabrook’s next refueling outage, which is currently scheduled for Spring 2026.

Are Seabrook Station’s seismic safety calculations still valid, given the ASR-weakened concrete?

The exact NRC formula for assessing a plant’s ability to withstand seismic events is withheld from the public under the justification of it being “proprietary or security-related,” but we have confirmed the NRC and the plant operator treat seismic events as though the plant’s structures enjoy the same building strength as when the plant was first built. However, since we now know that ASR is present at Seabrook Station, does this method still reflect an accurate measure of what could be withstood?

Since ASR degradation is ongoing and known to weaken structures, we were surprised ASR's discovery did not lead to NextEra, Seabrook's owners, nor the NRC to revise initial measures of building strength. It is reasonable to expect cracking concrete would cause some reduction in the plant's ability to withstand earthquakes, and we feel it would be beneficial to assess the current strength of plant structures.

Will more earthquakes hit Seabrook Station?

It is difficult to precisely predict future earthquakes, both in terms of time and magnitude. We do know there are several active fault zones throughout New England that have intermittently experienced small-to-medium earthquakes in recent decades, with detectable shaking experienced at the plant.

The above map shows faults and historic earthquakes details for New England, as well as proximity to where Seabrook Station is located today. Again, it is impossible to predict with certainty when or where earthquakes will occur. However, Seabrook Station is currently licensed to operate until 2050. Given historic seismic patterns, it is likely to experience additional seismic activity if it operates through that time.

Next Steps for C-10

C-10 has experience using legal and political channels to elevate safety issues at Seabrook Station when local communities are placed at an increased risk. On the topic of seismic events in the face of the plant’s ASR concrete degradation, C-10 is preparing to take a number of formal actions this year. There are recently published studies by scientific institutions that support a re-analysis of how the ASR problem is being measured and mitigated at Seabrook Station. There are world-class scientists in this field who have contacted C-10 in an effort to bring an evidence-based analysis to the NRC for immediate and thorough action.

When it comes to a nuclear plant, we must make safety decisions based on the realities demonstrated by the evidence, rather than let economics or politics allow leaders to take a blind eye to these critical issues at our aging local nuclear plant.

Sources

Saouma, V. E., & Hariri-Ardebili, M. A. (2019). Seismic design criteria for nuclear power plants. Nuclear Engineering and Design, 345 , 1–10. https://doi.org/10.1016/j.nucengdes.2018.11.020

Tuttle, M. P. (2002). Re-evaluation of earthquake potential and source in the vicinity of Newburyport, Massachusetts (Final Technical Report). U.S. Geological Survey. https://earthquake.usgs.gov/cfusion/external_grants/reports/01HQGR0163.pdf

U.S. Nuclear Regulatory Commission. (n.d.). Appendix S to Part 50—Earthquake engineering criteria for nuclear power plants . U.S. Nuclear Regulatory Commission. Retrieved February 5, 2025, from https://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-apps.html

U.S. Nuclear Regulatory Commission. (n.d.). Backgrounder on seismic reviews at U.S. nuclear power plants . U.S. Nuclear Regulatory Commission. Retrieved February 1, 2025, from https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-seismic-issues.html

WMUR. (2025, January 27). Earthquake shakes New Hampshire . WMUR. https://www.wmur.com/article/new-hampshire-earthquake-january-27-2025/63571487

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Decommissioning Corporation Boils Off Radioactive Wastewater After Citizens Thwart Their Plans to Dump it Into Cape Cod Bay

Thu, 07 Sep 2023 16:36:04 GMT

Tritium is a radioactive byproduct of nuclear fission, found in abundance in nuclear wastewater. The Cape Cod community wants to be safe from it, corporate industry and regulators want to dump into the air and water and forget it ever existed.

It recently came to light that Holtec has been using “forced evaporation” of radioactive water from the site of the closed Pilgrim atomic reactor in Plymouth. This action by Holtec, the private company who is being paid to decommission the nuclear plant, only came to light because of an August 18, 2023 letter from a whistleblower (excerpt below). The whistleblower declares this action is a “breach of trust,” and alleges that this evaporation tactic is Holtec’s response to not being able to simply dump the over 1-million-gallons of radioactive wastewater directly into Cape Cod Bay. That dumping plan was thwarted due to widespread public opposition and the Oceans Sanctuary Act, an anti-pollution state law in Massachusetts.

There are many reasons to be worried, saddened, angered by this course of action—just as there are many reasons to fear environmental repercussions. The water vapor released to the air contains dangerous radionuclides such as cesium-137 (which was blasted into the air across Europe, and is responsible for the destruction of the reindeer herding economy of Scandinavia, in the wake of the Chernobyl disaster in 1986) . Furthermore, the water itself is radioactive, because its molecules are comprised of Tritium—radioactive hydrogen. Tritium is very hard to isolate and neutralize , for the same reason that hydrogen fuel is so difficult to create: the molecular bond with oxygen is very strong; and free hydrogen is extremely unstable.

Contrary to how the atomic industry wants to “spin” Tritium, this is a dangerous radionuclide with a track record of adverse effects for humans. It is a Beta emitter, which means it can penetrate cell walls; and its 12-year half-life means that it is dangerous for a significant period of time. Ironically and tragically, our state’s residents became unwilling “guinea pigs” for an experiment in human exposure to Tritium in the second half of the last century, when the owners of the Yankee Atomic plant at Rowe dumped Tritium into the Deerfield River for decades. Because of local public outcry, this eventually led to a health study undertaken by the Massachusetts Department of Public Health , revealing statistically significant increases in Down Syndrome and Non-Hodgkins Lymphoma. Concerns over these findings were expressed to the Nuclear Regulatory Commission in a public hearing.

Clearly, Holtec has chosen to release this radioactive waste into the air because the State of Massachusetts and its citizens have effectively blocked the water-borne “dilute & dump” strategy that they intended. A July, 2023 draft-ruling from the state Department of Environmental Protection denied Holtec's requested permit to dispose of the waste into Cape Cod Bay. It is important to point out that, due to prevailing wind patterns, a lot of the radioactive molecules precipitating out of the vapor Holtec sends up will fall into the ocean—just the scenario prohibited by the Ocean Sanctuaries Act. The remaining radioactive particles may or may not drift beyond the state borders before falling back to earth.

Tritiated water (HTO) is easily turned into Organically Bound Tritium (OBT) when it interacts with organic matter (i.e. plants, animals, fish, soil). A recent 2019 scientific article cites that 70% of organically bound tritium gets sequestered into organic matter like soil and sediment, passing the radioactive molecule up the food chain into the plants grown in it, then further into the animals that consume the plants, then further up the food chain in a phenomenon referred to as "bioaccumulation." With a half-life of over 12 years, a lot of tritium can bioaccumulate before it decays, and human consumption of such plants and animals is of serious concern.

Holtec pursues this environmentally dangerous path not because it is the best available way to safeguard our biosphere from these harmful compounds. The water and air pathways to dumping represent the least-cost avenues to rid themselves of the liability for all this radioactive water. Fully 17 years after the National Academies of Science finally acknowledged that there is no safe threshold below which radiation is not harmful, the NRC still permits the “dilute & dump” practices that our own best scientists have officially discredited. NRC regulations on the matter are long past due for updates commensurate with the most recently available science about organically bound tritium, bioaccumulation, and human health impacts.

What do we sacrifice in order to allow these practices to continue? Human health, in particular that of children and women of child-bearing age, who are as much as twenty times more vulnerable to the effects of radiation exposure as am I, an adult male—due to their relatively high number of rapidly dividing cells. Combine this with the greater efficiency of radiation to cause cell damage at low dose s , as well as the extreme longevity of some radionuclides, and we have a recipe in place for long-term biological degradation. All for the sake of keeping Holtec profits up.

It is incumbent upon all of us to stop these obsolete and dangerous practices before they become so widespread as to be universally accepted. We do not want our great grandchildren to curse us for the choices we make—and the consequences they will suffer as the result.

Sources

1 “Reindeer are still very radioactive 30 years after Chernobyl”, Melia Robinson, Business Insider, December 2022

2 George A. Alexander, in Ciottone's Disaster Medicine (Second Edition) , 2016

3 “Cancer Incidence and Down Syndrome Prevalence in the Deerfield River Valley, Massachusetts,” MDPH, BEHA, February, 1997 (not available online but excerpt cited in a 1994 NRC Hearing).

4 Drysdale, Sam. (2023, July 24). "State rejects effort to dump nuclear plant waste into Cape Cod Bay." CBS News.

5 Eyrolle, F., Copard, Y., Lepage, H. et al. Evidence for tritium persistence as organically bound forms in river sediments since the past nuclear weapon tests. Sci Rep 9 , 11487 (2019). https://doi.org/10.1038/s41598-019-47821-1

6 “Biological Effects of Ionizing Radiation VII,” National Academies of Science , 2006

7 “The Petkau Effect”, Abram Petcau, 1972

C-10 Sees Cracks in the Nuclear Regulatory Commission Response to its Petition on Concrete Problems

Fri, 14 Apr 2023 15:32:59 GMT

Uphill battles are still worth fighting, especially when the stakes are high and science and reason are on your side.

The problem is degraded concrete, structural damage caused when cement and water come into contact. Its scientific name is Akali-Silica Reaction (ASR) and is more commonly known as “concrete cancer” because it forms inside the concrete and spreads. If the progression of this cancer is not properly tracked, then the structure of the concrete can fail.

The place is Seabrook Station Nuclear Power Plant in Seabrook, New Hampshire. Seabrook Station, which is owned and operated by NextEra Energy of Juno Beach, Florida, is located 48 miles north of Boston, the state of Massachusetts’ largest city. 170,000 residents from 17 towns in New Hampshire and 6 towns in Massachusetts live within the power plant’s 10-mile radius, known as the Plume Exposure Emergency Planning Zone ( EPZ ), a zone where people may be harmed if exposed to higher-than-normal levels of radiation. Over 1 million people live within 50 miles of the plant, known as the Ingestion Exposure Pathway, where radiation may contaminate water, food and livestock. Degraded concrete was first discovered at Seabrook Station in 2010. Seabrook is the only U.S. nuclear plant known to be suffering from ASR concrete degradation. But, any other nuclear plant whose concrete contains the same types of aggregates is at risk of developing this same problem.

The responsibility for ensuring that the plant’s owners are checking the affected concrete, and all safety measures and protocols at Seabrook Station, is that of the Nuclear Regulatory Commission (NRC). C-10 Research & Education Foundation is a citizen-led nonprofit that conducts 24-hour-a-day monitoring of radiation in the air within the EPZ, and advocates for the safety of Seabrook Station nuclear power plant to protect public health and the environment in New Hampshire, Massachusetts, and beyond.

The response by the NRC is to inspect that plant employees are properly reviewing the progress of the cracked concrete, for the most severely cracked areas having to check every six months. It is in these NRC inspection reports where inspectors have repeatedly confirmed multiple violations of insufficient tracking of the progression of the cracks in the concrete, in some cases with complete negligence to take the required steps at all.

The petition: Last fall, C-10 submitted a petition to the NRC asking the federal regulatory agency to conduct a comprehensive investigation of Seabrook Station’s degraded concrete. C-10 pointed out that no one knows how widespread the cracks in the concrete structures are, and given the repetitive pattern of violations there, the NRC must strengthen consequences that will compel NextEra to do a better job monitoring the problem. C-10’s petition stated that in the last 18 months alone, the NRC cited 10 violations at the plant, two of which related to ASR.

The primary concern , according to C-10’s executive director, Sarah Abramson, “is that the ASR has weakened the plant's structures, and in the event of something like severe flooding or earthquake, there is no assurance that the concrete structures will hold. These structures are in place to keep radiation from leaking out into our communities."

According to John Ebel, author and an earthquake expert at the Weston Observatory at Boston College , “We saw on average a large quake that is 5.0 or greater in New England about every 60 years, the last one occurring in the Ossipee Mountains in 1940. So, we’re more than 20 years past the average.”

The denial: In March, the NRC’s Petition Review Board denied C-10’s petition, stating that even though there is a pattern of behavior at Seabrook Station leading to violations on the concrete issue, the errors were not willful, and, therefore, did not meet the criteria for further enforcement. Only the NRC Commission, the highest-ranking body in the agency consisting of five Commissioners, can overrule the petition’s denial. Though, such a thing has never occurred in any of the hundreds of petitions processed over the last 26 years.

The reaction by C-10 is firm. “The NRC’s position that every structure at Seabrook is currently able to perform its safety function, including those affected by ASR, is problematic,” says Abramson. “The agency discovers new areas of ASR in the Seabrook plant every year. So C-10, and any rational person, can draw the conclusion that there are many areas with crumbling concrete that we just haven't found yet. Thus, no one really knows the totality of the ASR damage to the concrete at Seabrook Station.”

The positive outcomes are many. C-10’s petition brought the critical issue of ASR concrete degradation at Seabrook Station to the best and the brightest technical experts at the NRC, the Nuclear Reactor (NRR) Regulation division, who have sway over how to respond to future violations. Additionally, the process of petitioning the NRC shed new light on the problem of ASR to other key audiences: the Commissioner and Inspector General of the NRC, members of congress and state legislators, and the media.

The future is ours to make. An ASR-specific inspection will take place at Seabrook in April, and C-10 will be watching. C-10 will review the results and report them to the appropriate government officials and agencies, the news media, and the public. In the meantime, C-10 stresses the importance of every household in the Seabrook area becom ing better informed and prepared for every type of potential emergency that could occur.

ACCESS A COPY OF YOUR LOCAL RADIOLOGICAL EMERGENCY PLAN BROCHURE ONLINE: CLICK HERE FOR MA & CICK HERE FOR NH

C-10 Testifies in Legal Hearing, Asking for Regulators to Protect the Public from Cracking Concrete at Seabrook Station

Fri, 30 Dec 2022 16:31:31 GMT

C-10 spoke before the Nuclear Regulatory Commission's Performance Review Board on Wednesday, December 14, defending a petition that asks for enforcement of license requirements that Seabrook Station has been failing to comply with, which are critical to tracking the serious concrete issues at the plant.

C-10 spoke before the Nuclear Regulatory Commission's Performance Review Board on Wednesday, December 14, in order to defend the petition that C-10 submitted on October 4, 2022. This petition asked regulators to step in and issue an enforcement action to the Seabrook Nuclear Plant due to its repeated failures to adhere to its license requirements, especially the plant's failures pertaining to the Alkali Silica Reaction (ASR) driven damage causing cracking and weakening of the plant's concrete structures .

C-10's petition for enforcement passed the initial screening test and was approved by the NRC as being accurate and supported by factual documentation, and then it was delivered to the Performance Review Board for consideration. After review and deliberation over three different days, the board's decision was to decline our petition. The sole reason cited for the denial was that C-10's petition did not provide any new information to the NRC since C-10's petition referred to information from previous legal hearings and the NRC's own inspection reports on the Seabrook facility. This public meeting was legally available to C-10 as a final opportunity to defend our petition and provide the board with clarifying and supplemental information that may give the board members reason to reverse their denial and accept the petition.

So, we clarified:

One stark failure at the Seabrook plant that was cited as a violation in the NRC's 2nd quarterly report this year was that the plant forgot to install 7 out of 54 extensometer devices on key structures that are suffering from this concrete cancer. These are the devices that measure how severe the cracking is and indicates whether a structure is no longer strong enough to perform its safety function.

As of 2011 there were 131 structures identified as showing signs of ASR concrete damage, evidenced by the cracking that is visually obvious on the surface. However, C-10 makes the logical observation that we do not even know the full extent or all locations of the ASR damage because since 2011, there has not been any effort or investigation to fully inspect and seek out ASR damage in the facility. Newly discovered areas of ASR are found on a regular basis, but often only by the NRC inspectors who find them during their periodic inspection periods. These inspections are only on a sampling of areas in the plant, and sometimes the inspectors find ASR in very critical areas where it should have been noted, logged, and added to the license requirement protocols by one of the hundreds of workers who mill about plant daily and have eyes on all nooks and crannies of the facility daily.

And supplemented:

The most recent inspection report that came out after our petition was submitted identified that a new patch of ASR damage was found by the NRC resident inspector in the cooling tower, and the damage was measured to be near the allowable threshold.

This means two very alarming things:

The sheer fact that this ASR affected area is almost at its limit in one of the structures most critical for safety, as the cooling tower is responsible for preventing overheating and meltdown of the reactor.

In such a well monitored area, nobody at the plant reported it previously. Recall that ASR is very slow moving, and so this new ASR spot in the cooling tower must have been showing signs for quite a long time if it is already near the threshold.

We also pointed out that we aren't allowed access to any new information not already published in reports, from which we might have experts create compelling new models or suggest technologies better than what is currently being used by the NRC and Seabrook's owners NextEra.

C-10 requested from the NRC information additional to what is published in the NRC's inspections reports including:

the qualitative and quantitative data on the ASR-affected areas so that our recognized experts in that field can provide more robust analysis and 3D modeling of the cracking
status updates on the missing extensometers and what readings they were producing if they had already been installed

C-10 was told by NRC inspectors that the public does not have access to that information. C-10 contends that it cannot obtain information additional to what is already published by the NRC, and that what is available already clearly shows glaring gaps in the current program designed to monitor the ASR issue.

What we don't know is perhaps more important than what we do know. These frequent findings of new areas of ASR concrete damage indicate that there are many more structures in the plant with cracking concrete right now that nobody knows about or has reported yet. All of the unknown ASR-affected areas are not receiving the measurement and observation measures required by the license terms, and spell danger for the safety and operability of this nuclear plant.

C-10 & The Public: Knowledge Sharing is Critical to Outreach

Fri, 30 Dec 2022 15:37:48 GMT

C-10 has spoken at dozens of events in 2022 and found that outreach and education is a two-way street. Often times we learned valuable information from the groups that we sought to educate.

How C-10 gets the word out and what we learn while doing it!

We have all heard the saying, “You can’t fight City Hall,” and we have all at times bemoaned the perceived difficulty of an individual making a real difference in solving society’s problems. But, since its inception over 30 years ago, C-10 has exemplified what a small group of committed citizens can do.

As a result, C-10 now has over 900 members, ten Board of Directors Members, and a roster of Advisory Board members nationwide representing various fields of nuclear, regulatory, and other areas of expertise, as well as two paid professionals on staff, our Executive Director and our Network Administrator. We are delighted to have such valuable support to deliver our services to the more than 170,000 people living within the 10-mile radius of the Seabrook Nuclear plant. However, we recognize that C-10 needs to reach more of the area’s citizens to increase awareness and to supply important information about what it means to live near a nuclear reactor, as well as what we all can do to push for the utmost safety measures.

In the past six months, Sarah Abramson, C-10 Executive Director, and Karen Clagett, Head of Education and Outreach, have traveled to a number of community events and organizations to spread information on Seabrook Station , nuclear safety, and C-10’s efforts to fulfill its mission to help keep the environment and the people of the Seacoast safe.

We have spoken before the Newburyport, Amesbury, and Exeter Rotary Clubs, the Amesbury Lions’ Club, the high school coalition Seacoast Students for Sustainability (SS4S), the annual meeting of the Quaker Hill Foundation, and the Riverwoods residential community in Exeter, NH. Board members have represented C-10 at internship fairs in Amesbury and Newburyport. We held a successful social and fundraising Art Auction event in November, and an appearance at the Newburyport Non Profit Pop up park in December. We used all of these opportunities to educate our fellow citizens, and in turn C-10 has learned a lot from the people we have met along the way this year.

Once such a theme that we kept hearing was that there is a great deal of confusion among the general populace about the operating status of Seabrook Station. We have been asked, “Is it still online?” “Isn’t the license about to expire?” “Is C-10 anti-nuclear?” “Is a nuclear plant clean energy?” “What are Potassium Iodide (KI) tablets, what do they do, and how do we get them?” “Do you test soil or water?” “What can we do?”

So let’s begin to clear a few things up.

C-10 is not anti-nuclear; it is pro-safety . C-10 recognizes that Seabrook Station supplies significant energy for New England’s needs. C-10 works to ensure, however, that the nuclear industry’s “bottom line” does not take precedence over the health of the region. C-10’s 18 monitoring sites (soon, we hope to be 19) in Massachusetts and New Hampshire keep track of the levels of beta and gamma radiation in the air 24/7/365 and send automated reports of their readings in real time. C-10’s Research Team, which includes both a physicist and a chemist, studies all quarterly NRC inspection reports on the plant and all scientific and public press coverage of nuclear energy and safety. Any concerns are taken up with the NRC’s resident inspectors or other appropriate offices of the Nuclear Regulatory Commission. Concerns are also shared with local, state, and national political figures, many of whom have been very supportive.

Is the plant still online? Yes. Its original license was for thirty years expiring in 2030, and that has recently been extended by the NRC for 20 additional years to 2050. Some proponents of nuclear energy suggest issuing license extensions to allow nuclear plant operation for a full 100 years. C-10 realizes that the plant was state of the art in the '70s, but it is not now and will continue to move further away from the best available current technology as the licensed years continue to pass.

What are C-10's current concerns? Among them is the fact that there have been a number of violations at the Seabrook plant cited by the NRC in its inspection reports, and some involve the monitoring of degraded concrete. C-10 has filed a petition asking for more supervision and defined timelines for remediation of these violations. Recently, our Executive Director and Board members defended our petition to the NRC Performance Review Board. We have been in close contact with legislative offices at the state and Congressional level in both MA and NH, especially the staunch nuclear safety advocate Massachusetts Senator Markey to outline our questions and concerns. Senator Markey has particular interest and authority in this arena given his role on the Senate Energy Committee. We are also concerned about the safety of the radioactive spent fuel gathered during nearly 30 years of operation and stored at the plant site.

Is nuclear energy “clean”? No and yes! It is true that the actual production of energy from the nuclear reactor does not involve CO2 emissions, but constructing a nuclear power plant compound, decommissioning it, the transportation of fuel to the plant, the future potential of moving the over 80,000 pounds and growing of nuclear waste away from the plant, and the mining and processing of uranium all have CO2 implications.

What are KI tablets? KI stands for Potassium Iodide. In the event of a nuclear incident, especially if residents are asked to shelter in place, KI tablets can protect the thyroid from the radioactive iodine that would be released from the nuclear reactor. They should only be taken if/when a health official dictates that it is necessary during a radiological emergency. These pills do not protect any other areas of the body. The most important individuals to use KI in a nuclear event would be pregnant women and young children. By law these KI tablets are free to anyone residing within the 10-mile EPZ radius, but each state and also town has its own means of distributing them, which creates confusion, inconsistency, and a low rate of residents actually having these on hand in their homes for an emergency. C-10 is planning a program for 2023 to understand why so many local residents don’t know about these pills and why they don't have them. This will help us create a framework to assist the responsible municipal groups in getting more KI Pills in more homes by 2024. This will involve creating a database of all the schools within the 17 EPZ communities, and issuing a survey to those schools and a sampling of local residents, to strategize where and how outreach and KI pill-delivery activities will take place.

Does C-10 test soil or water? As a relatively small organization, we have homed in on the specific area of air-radiation monitoring, but we hope to engage graduate students at a local college or university to encourage radiological testing of the soil and water in the area. The states of MA and NH do have some soil, water, and dairy testing for radionuclides as required by law.

What can I do as a citizen? Finding out about your community’s KI Pill policy and obtaining KI is one action. Obtaining a copy of the most current evacuation plan, which should have been mailed to every person living inside the 10-mile EPZ radius is another. Also, being sure to pay attention to news articles and broadcast feature stories on nuclear plants and spreading the word among your friends and family are other actions. Signing up for C-10’s monthly electronic newsletter can help to keep you informed. Contributing to C-10 can help us in the important work we do for you. Looking through the various resources across our website can help you with all of these!

Over 300 people went to our website on July 12, 2022 when Seabrook Station set off a false evacuation alarm at New Hampshire beaches. There were dozens of calls, emails, and social media inquiries directed to us to see whether we were reading dangerous levels of radiation across our real-time radiation monitoring network . Those citizens knew that C-10 could help provide accurate and reliable information, during the over one-hour timeframe when none of the nuclear plant staff, NRC federal regulators, or NH state officials were providing confirmation that there was no emergency.

C-10 Petitions NRC: Take Action on NextEra's Continued Violations & Missteps Related to Degrading Concrete

Tue, 11 Oct 2022 15:02:19 GMT

Three Quarterly Integrated Inspection Reports in a Row Include Violations - NextEra is not Following the License Requirements while the Concrete Degradation is Getting Worse Everyday.

When C-10 met with Nuclear Regulatory Commission (NRC) inspectors on September 15—a week before the NRC Executive Director of Operations arrived at Seabrook station—our focus was on the repeated violations that the NRC cited against the plant for neglecting to fulfill critically important tasks related to the "concrete cancer" caused by Alkali-Silica Reaction ( ASR ) . Three consecutive Integrated Inspection Reports (IIRs) have included observations by the NRC around this issue. All three were coded as “green”—the least bad of NRC’s color-coded performance scale.

The newest critical issue is that the plant has had over three years to install 54 devices called extensometers, at key locations, to track the extensiveness of the cracking concrete. As of the latest inspection report, there are still 7 missing.

The C-10 Research Team scheduled a zoom call with the NRC resident inspectors, and on September 15 they spoke with us about the gaps they found in how the plant owner NextEra Energy is monitoring ASR. Their full and technical comments can be found in the latest quarterly Integrated Inspection Report . It should provide some assurance that the inspectors are dedicated to holding NextEra accountable for their license requirements, to the fullest extent allowed under regulatory guidelines.

The buzz word of the report is "margin," the amount of additional degradation that a structure can handle before it must be deemed unsafe and unfit for continued use. These thresholds were established at the point of relicensing, and were a directive from the Atomic Safety and Licensing Board (ASLB) as a direct result of C-10's challenge to plans that would have set much lower standards (higher margin).

Here are C-10's key takeaways from the report, which we detailed in a letter emailed to local, regional, and national level NRC representatives:

We'd like to see a citation level at the one-step higher "white" category so that a time requirement can be imposed for these fixes, given that this violation is in addition to ASR-related shortcomings in the last two Inspection Reports from 2021 Q4 and 2022 Q1
As we learned from the 47 extensometers that have been installed as required, the problem may be worse than thought ; seven structures are at or near exceeding structural design basis.
There is a proposal to "reanalyze" the load capacity of some structures so that ASR margins can be increased, this would push the cracking further before the NRC would consider it being out of design basis, a practice that seems counter to safety
Seven structures are receiving physical modifications like buttresses, with deeply drilled screws, into the degraded concrete to add margin, you can see the draft designs of those here.
NRC field staff are on the case ; and they agree with C-10 that they need more resources in order to provide the attention that is needed to inspect all ASR vulnerabilities, such as the seven missing extensometers only noticed as missing three years after they were required to be installed.

C-10 is grateful for the transparency that the NRC resident inspectors provide. To ensure that all levels of the NRC hierarchy take note of our concerns, we also submitted a formal petition for the NRC to issue an enforcement action to the plant. This document, called a 2.206 petition, was submitted on October 4 to the Executive Director of Operations, a position currently filled by Dan Dorman. This petition was carefully crafted by our expert insider, and advisory board member David Lochbaum, and C-10 Research Team. READ THE PETITION IN FULL HERE>>>

C-10 Creates New Data Analytics Tool for Radiation Monitoring Network

Thu, 22 Sep 2022 18:16:29 GMT

Improving our ability to track radiation clouds in real-time during an emergency, and endless opportunity for use in scientific and health-impact research.

C-10 is on board with the data revolution! For over 30 years our Citizens Radiation Monitoring Network (CRMN) has been collecting data on the airborne radiation levels in the 10-mile Emergency Planning Zone (EPZ) radius around the Seabrook Nuclear power plant.

Since 2010, all that data has been digital, empowering us to make our data usable for not just our own research, but also potentially useful in the areas of health-impact studies, regulatory compliance, radiation physics, and more!

The C-10 CRMN measures and records the following at each of our 19 stations, for every minute of every day:

Wind speed & direction using an anemometer

Beta radiation levels using a radiation probe

Gamma radiation levels using a radiation probe

That’s over 1,440 data points each totaling 4,320 data points per station per day, meaning we record over 80,000 data points across the whole network every day!

You might be thinking, whoa, that’s a lot of data, and you’re right. Ever try to load an Excel Spreadsheet with more than a few hundred rows? Then you know that trying to analyze a large set of data in a simple software application is impossible, unless you perhaps have IBM’s artificial intelligence supercomputer Watson.

For the scientists and data enthusiasts out there: Our process for analyzing and reporting our monitor data is very time-intensive, requiring mass downloading of the log files for the month, loading them into Matlab, and producing the series of charts and analyses which are printed to a PDF format for easy transmission and readability by the Massachusetts Department of Health and other key investigators.

For the layperson: A PDF is a nice “at a glance” review, but is not user friendly for in-depth analysis and research. Understanding the untapped benefits of being able to look at large amounts of our historical data for public health, transparency, and scientific research, we embarked on a journey to find people with the right skills to help us.

The Inquiry

C-10 inquires with Pro Bono Analytics (PBA) , who serves as a conduit for groups like C-10 to find skilled people willing to donate their time for free.

C-10 submitted a Request for Proposal to make our database queryable and improve our ability to analyze the data from our monitoring stations. To our shock and delight we had over a dozen applicants! After careful consideration, two stood out above the rest and we selected Alva Dillon and Phil Fry to partner with us on this project. We are grateful that they generously donated their time and expertise.

The Approach

After weeks of collaborative sessions with the PBA team and Mike Mansir, we elected to consolidate the data into files that each holds three months’ worth of data for a single radiation monitoring site.

The team built an application that charts the sensor data and allows the user to interact with the chart to focus on areas of interest. A user can make any number of selections on which monitoring sites to review: all sites across the network, focus on a single or multiple regions, just a single site, etc. Our control site, located in Somerville, MA, is also available and provides valuable baseline reference, and validates that the normal background radiation level in our region is higher than 40 miles further away from the plant.

The C-10 Radiation Data Illustrator was created using an interactive application using the Streamlit framework for Python applications. The application allows interested parties to access the data over the web and plot the radiation time series and related wind plots over the desired time frame.

The Results

The radiation levels are shown as line charts, and wind speed and direction for the same time period are shown as radial scatterplots.

The combination of charts allows interested parties to identify spikes and other anomalies in the radiation levels, and if desired a user can see where those correlate with wind speed and direction.

The investigator can narrow in on time frames of interest and can focus the analysis down to individual monitoring stations. At the finest level of detail, the investigator has access to the minute-by-minute readings of both radiation levels and wind conditions from the stations.

In the following example, you can see how a user would visually be able to notice an unusual reading, and zoom in to get more detail:

How might an investigator combine radiation and weather information to get more context about the source of radiation or projections about where it is headed next?

Here is an example of how a user may view the wind speed and direction data from a site over a period of time. This can help inform where radiation came from and to where it traveled next. In a real radiological emergency, this information could be accessed in real time and would be crucial to help inform officials where it is safe to send evacuees, something that Japanese officials did not know during the Fukushima accident when they inadvertently sent citizens directly into areas of high radiation.

For Longevity, the team also built file maintenance support into the application so that the application can take in the new data on a regular basis and add it to the existing stockpile of data to keep it fresh and up-to-date. What the PBA team and C-10’s Mike Mansir have built is a more modern analytics platform to give the interested parties more interactive access to the data.

Jaw Dropping Reactions: The C-10 Board of Directors, many of whom serve on our Research Team, were amazed at the finished product.

Our dedicated research-minded members have often marked on their calendars when they were aware of something going on at or near the plant, and would ask for a summary CRMN readings - a request that used to take time and effort to fulfill. Now, we can research those incidents immediately, or years from now! Some examples might include:

July 12, 2022: false evacuation alarm at Seabrook nuclear plant; a review of the data confirms that there were no abnormal readings network-wide

9/15-9/28 2021: there was fan failure on one of the three tower cooling fans which left it inoperable 9/17/21-9/26/21; a review of the data confirms there were no sustained high readings of any radiation

November 2019 (Thanksgiving, specifically 11/28/19): Buffalo, NY, coal plant incident brought gamma radiation to our region causing some spikes in our readings; thorough investigation at the time was very timely and ultimately absolved the nuclear plant of involvement in the release, a process that will be shorter with this new illustrative tool

Comparing our readings to New Hampshire’s thermoluminescent dosimeter (TLD) film data, comparing to the plant’s data, validating that they align and investigating where they do not

The Board’s reactions were akin to a kid at Christmas, and our team is thrilled to be using this tool for our own research, but are also offering it as a tool for academic and public health research.

What Does the Future Hold?

C-10 Researchers will get to work bolstering their methods with this sophisticated tool, reducing research timeframes astronomically. They have the ability to remotely access this tool from any computer.

C-10 member donors or the public are welcome to request a visit to our office to use our dedicated guest portal and use this tool.

Projects and grant opportunities will be considered, if C-10 can help provide information to support radiation health impact studies, or other scientific endeavors.

Don’t worry, we will keep you all updated if anything important and interesting is discovered through the use of this new C-10 Radiation Data Analysis Tool.

Meet the Pro Bono Analytics Team

Alva Dillon is a Ph.D. student at Brandeis University studying plasmons and excited state dynamics using computational chemistry. Through his academic training he’s gained experience in creating computational workflows, automating computational tasks, and data analysis. Alva thoroughly enjoys learning to use computational tools to expand on his experiences and to create something new. When he’s away from his computer Alva enjoys rollerblading, hiking, and spending time with loved ones. Connect with Alva on linkedIn!

Phil Fry is an experienced IT and business management consultant currently working as a solo practitioner. He began his career as a consultant and an instructor with Oracle Corporation. Later he worked with Diamond Technology Partners (now part of PwC) helping clients shape and execute their IT strategy. More recently, he joined Slalom where he focused on developing his clients’ advanced analytics capabilities. Phil has a Bachelor’s degree in mathematics from Harvard, and an MBA from the University of Chicago Booth School of Business. Phil can be reached by email at pfryanalytics@gmail.com or on linkedIn !

Decommissioning: When Nuclear Reactors Retire

Mon, 29 Aug 2022 17:58:04 GMT

NRC Seeks to Change the Rule Governing Decommissioning to Prevent Citizens and State Leaders from Interfering

When Diane Turco spoke at the C-10 Annual Meeting on June 20, 2022 , we gained valuable first hand insights into the uphill but worthy battle to protect the public and the environment during the decommissioning of the Pilgrim Station Nuclear Plant. Since then, C-10 has coordinated with groups doing similar advocacy work on decommissioning in San Onofre, CA, and Indian Point, NY.

It turns out that the biggest player in decommissioning , Holtec, has a bad track record of significant mistakes--but the NRC still wants to proceed with rule changes that would remove accountability measures in a trade-off that hands more of the reins over to the private companies that decommission nuclear power plants. C-10 has thoroughly read and researched the rule change, and surmised that it prioritizes speed and cost over public and environmental safety. SEE OUR FULL COMMENT TO THE NRC HERE.

The rule's name is Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning , and it seeks to strip away the right for all stakeholders to have a seat at the table. It was proposed by the NRC Commission on March 3, 2022. The original comment period went through May 17, 2022 but was then extended to August 30, 2022. The rule was brought up when there were just three commissioners in place, with two seats vacant, and the vote to proceed with the rule was 2-1 with only Commissioner Jeff Baran voting against it.

As an overview, here is a brief history of decommissioning rules:

The 1988 original decommissioning rules provided decent measures for public safety and citizens and state involvement.

The 1996 Rule changes stripped a lot of those measures away.

The 2022 proposed rule changes further remove the public's ability to seek clarification on and object to any decommissioning plans proposed by a plant--and even weakens the NRC's oversight of the process.

Does this sound concerning to you? Anyone can submit a comment to the NRC on this rule!

*C-10 is happy for anyone to use this text verbatim or as a reference when submitting a comment. Every comment counts!*
Example Comment Text:

"Current proposed rule changes for the decommissioning of nuclear power plants place public and environmental safety below the interest of the industry and abdicate the regulatory responsibility of the NRC to ensure that decommissioning is carried out safely and effectively. The proposed rules must be revised to prioritize protection of people and the environment. This should include opportunities for interested stakeholders, state authorities and workers to be engaged in the specific planning in their area, robust emergency preparedness planning, and financial guarantees to ensure the industry is able to carry out decommissioning carefully and safely."

Let's Learn from others, neighbors and across the country

Diane T urco, Director of Cape Downwinders and member of Save Our Bay MA, recently updated us on what is happening with the decommissioning of Pilgrim Nuclear Plant in Plymouth, MA. Holtec Decommissioning International, which bought the license for Pilgrim from Entergy in 2019 for about $1,000 when it shuttered the reactor, has ownership of the $1.2 billion Decommissioning Trust Fund which is ratepayer funded. Currently Holtec plans to dump over a million gallons of spent fuel radioactive waste water into Cape Cod Bay as the fastest and cheapest way to dispose of this dangerous water. That action would devastate our Blue Economy, destroy the livelihoods of the fishing and tourist industries, and damage the health and wellbeing of our communities and the marine environment.

On July 25, the MA legislated state Nuclear Decommissioning Citizens Advisory Panel held their public meeting during which Holtec Senior Compliance Manager David Noyes declared, "We will not say we will not discharge in Plymouth Bay". For background, the license transfer to Holtec included an agreement with the MA Attorney Generals Office in which Holtec agreed to abide by all state laws/regulations. If Holtec were to follow through with previously published plans to dump that waste water it would be in violation of the state Oceans Sanctuary Act among other state regulations that prohibit this action. As of today, the Holtec plan remains in place and there has been no legislative nor state challenge to the plan.

On June 17, the EPA firmly denied that Holtec's existing permits allowed them to proceed with their plans to dump a large volume of radioactive wastewater into Cape Cod Bay. Given the Ocean Sanctuary Act and Holtec AGO Settlement Agreement , Massachusetts and the EPA have recourse to prevent the dumping of waste. For example, Attorney General Maura Healey has legal grounds to put into place an injunction to prevent the dumping from proceeding. Cape Downwinders and the increasingly impassioned public will continue to hold accountable officials and decision makers.

Looking across the country to the west coast for vital learning opportunities, there were significant issues in the decommissioning and cask storage of nuclear waste at the San Onofre plant in California. One cask full of nuclear waste almost fell 18 feet and there are visible scratches on many others as a result of imperfect lowering of the casks into their underground storage area.

Voices from the public can drive how regulators design rules. Reminding the NRC that there are human and environmental impacts at stake, and amassing experts to speak on the public's behalf, is something that C-10 and other nuclear watchdogs continue to do. These are important factors for decision makers to understand while they consider how decommissioning plans should be approved and executed.

“Knowledge is no guarantee of good behavior, but ignorance is a virtual guarantee of bad behavior.” ~ Martha C. Nussbaum

Comment From C-10 on Proposed Changes to Rules for Decommissioning

Tue, 23 Aug 2022 20:43:43 GMT

Anyone can submit a comment to the NRC on these proposed rule changes here ! The Public Comment Period ends August 30.

C-10 Urges NRC to Prioritize Public and Environmental Safety, Community Engagement in Proposed Changes to Rules for Decommissioning Nuclear Power Plants

The Comment Period for the Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning rule ends on August 30, 2022

The NRC has proposed far-reaching changes to the regulations governing the decommissioning of nuclear power plants. While C-10 understands the need for efficiency and validates those changes to regulations which rectify outdated bureaucratic procedures, C-10 has grave concerns that the proposed changes weaken the safety provisions in the process for both citizens and the environment. The proposed changes put far too much authority in the hands of the profit-driven nuclear industry. Given that the NRC is charged with protecting public health and the environment, the current draft of the rules must be revised to strengthen local community and state engagement, and the NRC must take responsibility for ensuring that public safety and environmental protection are prioritized throughout the full decommissioning process.

C-10 has grave concerns about the provisions for emergency planning and response, which are delegated to FEMA and local governments in the proposed changes. After fuel has been in the spent fuel pool for 10 months, “the rule would eliminate the requirements for dedicated radiological offsite emergency planning, emergency planning zones (EPZs), and public alert and notification systems.” This raises serious issues for public safety. We concur with Commissioner Jeff Baran that “The NRC should require dedicated radiological emergency planning, including a 10-mile EPZ, until all spent nuclear fuel at a site is removed from the spent fuel pool and placed in passive, dry cask storage” (Baran 9). Neither FEMA nor local responders are prepared to handle radiological emergencies, and the responsibility for this rightly belongs to the industry. Likewise, the Emergency Response Data System should continue to be required until all spent fuel is in dry cask storage.

The proposed changes clearly de-emphasize environmental protections. They drop the requirement for an environmental impact review until after the process is completed and weaken the environmental information in the Post-Shut Down Decommissioning Activities Report. A site-specific NEPA review of the process should occur early in the decommissioning process and should provide opportunities for local stakeholders to be informed and involved. In the case of Seabrook, the ASR degradation of the nuclear plant would have a strong bearing on decommissioning, but this issue would not be recognized or taken into consideration without local and state involvement in the environmental review process, made in advance of decommissioning.

The period of time in which a site is required to be cleaned up should be reduced from 60 years to as soon as possible. The NRC must not abdicate its responsibility to review and approve irradiated fuel management programs. This proposed change sacrifices public and environmental safety in favor of the interests of the nuclear industry. Rather, regular NRC inspections, oversight, and reporting on decommissioning activities should be required.

Further, the proposed changes weaken the financial responsibility of the industry, which should be required to have secure funding for the full process when a nuclear power plant stops producing energy, and these funds must not be allowed to be used for other purposes.

Ensuring the safety of the public and the environment must be prioritized throughout the entire decommissioning process. The NRC must do more, not less, to exercise oversight and hold the industry accountable throughout the process. The current proposed rules weaken the authority of the NRC and make health and safety of people and environment subordinate to the lightening of regulations on the industry. This is unacceptable. The rules must be revised.

Relevant Sources:

Nulcear Newswire on extending comment period - May 2022

https://www.ans.org/news/article-3977/nrc-extends-public-comment-period-on-decommissioning -rule/

Federal Register: NRC’s Proposed Changes - March 2022

https://www.federalregister.gov/documents/2022/03/03/2022-03131/regulatory-improvements-for -production-and-utilization-facilities-transitioning-to-decommissioning

NIRS/CAN Comments on proposed rule - 2016 (still valid)

https://www.nirs.org/wp-content/uploads/2017/06/Decom_DraftRegBasis_CAN-NIRS_201706.p df

Senators Markey and Warren deplore proposed changes - November 2021 https://www.markey.senate.gov/news/press-releases/senators-markey-warren-denounce-nrcs-a pproval-of-proposed-decommissioning-rule

Jeff Baran’s dissenting vote on proposed changes - August 2021

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML21305B106

Seabrook Nuclear Plant's False Alarm Blunder

Tue, 26 Jul 2022 20:43:49 GMT

The day was hot, the beaches were full, the Seabrook nuclear plant was doing some unannounced testing of its alarm systems, what could go wrong?

Tuesday, July 12, 2022 is a date still very fresh in our memories after technicians at the NextEra Nuclear Plant in Seabrook, NH inadvertently caused a verbal alert to go off at nine (9) sirens located along the New Hampshire coast from Hampton Beach up to New Castle. The message told the public that there was an issue at the plant, to evacuate the beach immediately, and to turn on their radios for further instruction.

We now know that it took almost an hour for an official government statement to be sent to the public that this was a false alarm. Although the NRC responded to media inquiries one at a time as they received them, they lagged in getting out an official statement. It is nice to know that the plant's owners NextEra and the regulating agency the Nuclear Regulatory Commission (NRC) were talking to each other early on, but for quite a long time the public was uninformed and panicking, which very easily can turn into a public safety issue.

In the absence of clear communication from the plant, NRC, or local authorities, C-10 stepped up to do our part as an independent watchdog of the plant and operator of the Citizens Radiation Monitoring Network.

Starting when the alarm went off, C-10 received an influx of emails and phone calls from concerned citizens who wanted to know how much radiation our monitoring network was reporting. We spoke directly with the NRC resident inspector who was on site at the plant. He confirmed that it was a false alarm caused during a routine test, and that the plant's internal monitors were all indicating that the plant was operating normally. Shortly thereafter, we posted on all of our social media platforms that we understood the alarm was false and that all of the sites across our Citizens Radiation Monitoring Network were reporting normal and stable radiation levels in real time.

Later, even after the false alarm was confirmed by the plant and official government agencies, the calls kept coming in to C-10, as some members of the public do not have complete trust that this was a false alarm. One Hampton resident told our Executive Director, Sarah Abramson, “My neighbor and I are talking about packing the car with the kids and some essentials and going north.” C-10 issued a press release later that day to underscore that we all need to evaluate how prepared our communities truly would be if there were a real radiological emergency.

In the days that followed, C-10 gave statements to the media and appeared on multiple TV News broadcasts, reiterating the follow-up that we'd like to see, and stating again that our network showed that radiation levels were and continue to be normal.

Now that some time has passed, we are getting a clearer picture of how people felt during what could be viewed as an unscheduled evacuation drill: scared, panicked, and confused. Some beachgoers complied with the message's orders, though packing up your beach chair and cooler should probably not be a priority in a radiological emergency. Others simply stayed where they were, frozen with confusion or simply surrendering to what they thought was their inevitable demise.

Although it is important that we now know how this happened (a technician used the wrong key, out of two keys to choose from), human error is the red herring in this situation. The investigation that we deserve would answer the question of how well would this have gone if it were a real emergency. Not everyone who heard the message complied; first responders scrambled and behaved differently than directed in their emergency response plan and did not have the resources to answer every call they were receiving. The plant was effectively unreachable for official comment for almost an hour.

Recall that it is FEMA's responsibility to ensure that local communities located in the 10-mile radius around a nuclear plant have adequate resources and plans in place for a radiological emergency. Historically, this has looked like local responders proving to FEMA that they practice their plans in order to receive a passing grade. We want to ask: Shouldn't it be FEMA that is receiving a grade from us? FEMA should be taking more leadership and should increase training and educational resources to first responders, schools, companies, and residents who live near a nuclear plant. It should be FEMA that confirms that EPZ towns have adequate funding to properly staff their first-responder groups so they can be ready if there is a radiological emergency (e.g. no EPZ town's fire department should be all or mostly volunteer). We'd also like to see a federal agency like FEMA or the Dept. of Health take charge of running a program that distributes Potassium Iodide (KI) pills to every EPZ household. It is time for FEMA to take more seriously their designated role as the disaster-prevention agency and significantly increase their support of our first-responder groups and communities.

C-10 will continue to put pressure on the NRC and elected officials to hold the plant and FEMA accountable for their duty to put public safety at the top of the priority list ( click here for more information on radiological emergency preparedness ).

In addition to the procedural and communication gaps revealed during this false alarm, we also know that Seabrook Station is an aging nuclear plant with known "concrete cancer" affecting 43 structures, including the containment structure around the reactor. Citizens have a right to be concerned and get answers about how safe it is to have this plant in their backyard. C-10 launched a successful legal challenge that forced the plant to check on those concrete cracks more often, and we continue to scour every NRC report for updates on the degrading concrete and what the plant and the NRC are doing about it.

For more insights about how the C-10 mission applies to this false alarm, watch, listen, or read some of these news stories from WMUR , Seacoastonline , and the New Hampshire Bulletin .

C-10 welcomes new executive director

Sat, 28 May 2022 18:17:46 GMT

N.H. native Sarah Abramson brings fresh perspective and energy

C-10 Research and Education Foundation (C-10) is pleased to announce that Sarah Abramson has taken the helm as executive director, effective June 1, 2022.

Abramson, a resident of Stratham, N.H., brings to the position her passion for a healthy planet, an educational background in environmental sciences and policy, and relevant experience working with federal and state regulators and managing a wide variety of tasks, skills that C-10 needs in a dynamic and energized leader.

“The work that C-10 has done and continues to do is valuable and absolutely necessary,” said Abramson. “I feel safer as a resident within 10 miles of Seabrook Station knowing that C-10 has my back and is fighting for the safety and health of families and the natural environment in my community. I am excited to strengthen our efforts in my home state of New Hampshire related to community engagement and hope to further expand C-10’s nationally recognized radiological monitoring network. I am also looking forward to launching new initiatives to reach younger residents in our communities who are increasingly passionate and energized about protecting our planet and its resources for future generations.”

“We are over-the-top pleased to be welcoming Sarah,” said Patricia Skibbee, C-10’s board president. “As soon as we met her, we knew we had found the right person. She brings strong and varied skills, ideal personal presentation, and focused passion for our safety mission.”

Abramson will make her first appearance leading C-10 at the group’s annual public meeting.

What: C-10 Annual Public Meeting

When: Monday June 20 at 7 pm

Where: First Religious Society Unitarian Universalist Church, 26 Pleasant Street, Newburyport, Mass.

Details: Masks are encouraged; public parking adjacent to the building

C-10 supporters and members of the public are invited to hear updates about the group’s monitoring of Seabrook Station, most notably, what’s happening with the plant’s degrading concrete.

Guest speaker: Diane Turco, executive director of Cape Downwinders , will share insights on that group’s oversight of decommissioning of the Pilgrim Station nuclear plant—in particular, the fight to keep radioactive wastewater from being dumped into Cape Cod Bay. Diane’s talk may provide information and experience relevant to the future of people who live around the Seabrook nuclear plant.

There will also be updates on a project to make C-10’s real-time radiological monitoring network climate resilient, with installation slated for the summer months.

“I am looking forward to this opportunity to meet with many of C-10’s members and want to hear about their concerns and hopes for the future,” said Abramson. “What makes C-10 so strong is that it is led by informed citizens who together form a powerful voice advocating to protect the place that is our home.”

To learn more about Sarah, read this article in the Town Common News .

He's all ears

Sun, 27 Mar 2022 19:22:56 GMT

A Recap of C-10's Meeting with NRC Chairman Hanson

C-10 made the most of a unique and amazing opportunity on March 11, 2022, when we were invited to face-to-face (really, on Microsoft Teams) with the Chairman of the U.S. Nuclear Regulatory Commission (NRC), Christopher T. Hanson.

This was the second time in a year that our group, focused on the safety of the Seabrook Station nuclear power plant, was asked for input by an NRC commissioner before he visited the aging reactor in our own backyard. The last time was in summer 2021, when we were similarly invited to meet with Commissioner Jeff Baran before he toured Seabrook as well as Pilgrim Station, now being decommissioned by Holtec International.

Representing C-10 on the video meeting were Diane Teed, Advisory Board member and point person for our Board of Directors’ Research Team; Christopher Nord, board member; and me, Patricia Skibbee, board president and Research Team member. Joining us was David Lochbaum, C-10 Advisory Board member and long-time nuclear power safety expert.

With Chairman Hanson were his Chief-of-Staff Molly Marsh, Deputy Chief-of-Staff Cinthya Roman, Technical Assistant for Reactors Tony Nakanishi, Technical Assistant for Materials Lisa Dimmick. Other participants were Christopher Newport and Travis Daun, resident inspectors at the Seabrook Station nuclear power plant.

On my screen I appeared in a tiny box down in one corner. When I questioned that, each person replied that they had the same view of themselves. I explained that I was afraid to click anything for fear of accidentally leaving the meeting. That brought a sympathetic chuckle from all: apparently we all had the same tech hesitation.

I introduced the C-10 team and then began the meeting by comparing the stated missions of the NRC and C-10; both include the words, “…protect the public health and safety…and protect the environment." That means, I said, “Our goals are basically the same. Our aim is to work with you.”

Diane Teed then presented her carefully researched issues and questions. She stressed that C-10’s overarching concern is that citizens in Seabrook’s emergency planning zone (EPZ) live not only with the conventional risks of an aging nuclear plant but one with alkali-silica reaction (ASR) damage.

She posed issues to the Chairman, including the right for the public to know the extent/status of ASR degradation at the plant, where Seabrook is on the ASR “curve”—its rate of expansion, remaining margins of safety and the rate at which these margins are receding. She criticized plant owner NextEra Energy’s lack of computing revised ASR demand in June 2021 though “all relevant data was collected,” as well as the licensee’s noncompliance with required Tier 2 and Tier 3 inspection intervals.

Diane also argued for more rigorous inspections by the NRC, including expanded ASR sampling, and the necessity of a team of independent, professionally qualified ASR experts using advanced scientific methods to assess ASR, including all relevant future projections. In addition, she argued that NextEra has been out-of-design-basis for more than a decade and questioned whether remediation of critical safety structures and other afflicted sites was even possible.

Chris Nord spoke next, reflecting that the NRC’s panel of independent experts, the Advisory Committee on Reactor Safeguards (ACRS) in 2019 granted Seabrook’s 20-year operating license extension (from 2030 to 2050) before C-10’s challenge relative to ASR could be heard by the NRC’s Atomic Safety and Licensing Board, meaning that the ASR ongoing degradation was not considered in the license extension decision.

Chris also spoke of the need for the NRC to adopt specific ASR regulations. He stated that the current NRC verbiage, “degraded but operable” is too weak to be meaningful. He cited the NRC’s Petition for Rulemaking process as ineffective, since there is no deadline for response to requests. In C-10’s experience, it has taken six-plus years for the NRC to respond to our request.

Dave Lochbaum introduced the possibility of Government Accounting Office (GAO) action on the ASR situation, since ASR is or may become “at play at other facilities,” in nuclear power plants and other government concrete structures. Chairman Hanson seemed very receptive to Dave’s suggestion.

Chairman Hanson mentioned the importance of getting our legislators involved in these issues. He acknowledged the frustration in the Petition for Rulemaking process, and said that it is being worked on. He stated that in May 2022, the NRC will be bringing in ASR experts to Seabrook for a plant inspection.

I closed the meeting with four specific asks of the NRC:

Within six months, the NRC should establish a team of ASR experts to do a full assessment of the ASR effects, status and projections;
The NRC should focus on more robust inspections of all aging issues at the plant and should publish those findings in the quarterly public reports;
NRC should seek meaningful ways to improve and shorten the Petition for Rulemaking process; and,
The NRC should establish deadlines and enforcement actions for items on Seabrook Station’s Corrective Actions list, the Structural Monitoring Program, and non-cited violations/green status items that require correction.

We let Commissioner Hanson know that we would follow up this meeting with a written summary of our requests, and that we will be asking for a written response within 45 days. Throughout the meeting, Chairman Hanson appeared to be carefully listening. We hope we were heard. We think we were.

For more information on C-10’s watchdog efforts relative to Seabrook Station’s degrading concrete, please see this page , or visit past blogs .

Time to pass the baton

Wed, 02 Mar 2022 01:15:56 GMT

Natalie Hildt Treat has led C-10 for 5 years, will continue as advisor

C-10 Research and Education Foundation (C-10) was a very different organization five years ago, when Amesbury native Natalie Hildt Treat took the reins from founding director Sandra Gavutis upon her retirement. While she brought experience in nonprofit management, energy policy and communications, Treat had a lot to learn about being a nuclear safety watchdog.

Treat knew there'd be challenges ahead as she worked to enhance the group's organizational capacity, online presence and fundraising efforts, but also that she would be leading an organization with a strong legacy and reputation on which to build. Little did she know that just weeks into her tenure, C-10 would launch what would ultimately become a successful legal challenge to Seabrook Station’s management of the serious and pervasive concrete degradation known as alkali-silica reaction (ASR).

A dozen years after C-10's former research director Debbie Grinnell helped uncover the problem, C-10 won important improvements to how Seabrook's owner NextEra Energy must measure and monitor concrete cracking at the plant’s safety structures. This important work is ongoing.

"Working with our team as well as our concrete expert Dr. Victor Saouma and Attorney Diane Curran was just an incredible experience," said Treat, who helped garner regional and national media coverage during the case heard by the U.S. Nuclear Regulatory Commission (NRC)'s Atomic Safety and Licensing Board. ( See media coverage here .)

Under Treat’s leadership, C-10 has upgraded and expanded the Citizens Radiological Monitoring Network, the only independent field monitoring network surrounding a commercial nuclear reactor in the nation. Having secured funding from a variety of sources, C-10 is currently laying the groundwork to make the network resilient in the face of climate change ( watch this video for details ).

Treat has worked with Massachusetts U.S. Senators Ed Markey and Elizabeth Warren and other elected officials to push for stronger oversight of the plant, and her efforts have gained greater recognition of the importance of C-10. Thanks to the group’s elevated profile, C-10 has been invited to meet with Christopher Hanson, Chairman of the U.S. Nuclear Regulatory Commission on March 11 to discuss C-10’s safety concerns relative to Seabrook.

“Natalie has been exactly the leader C-10 needed. She has done spectacular work at C-10, and we will miss her profoundly,” said Patricia Skibbee, president of C-10’s board of directors. “She has led us into the 21st century on tech, and has established vital and solid relationships with our regional, state and local elected officials and with members of the press. Due to her work, C-10 has become a trusted source for factual and detailed information on the plant’s ongoing operational safety issues,” said Skibbee.

“It has been an honor to lead this important group for the past five years,” said Treat. “When I became the executive director and learned about the impact that C-10 has made, I said to myself, 'Wow. Every person living in the plant’s 10-mile emergency planning zone owes a debt of gratitude to this group for their efforts to keep us all safe.’ I feel that even more strongly today,” said Treat, who lives with her family in nearby Salisbury, Mass.

Treat leaves C-10 on solid financial footing, and with a three-year strategic plan which includes efforts to reach new audiences and to develop new environmental research projects.

In late March, Treat will start a position with the Boston-based nonprofit Northeast States for Coordinated Air Use ( NESCAUM ). She will work with C-10's board and staff to ensure a smooth transition, and plans to join C-10's esteemed Advisory Board.

C-10 is actively seeking to fill the executive director position. The job posting is available here .

I-Team Keeps the Focus on Safety Concerns at Seabrook Station

Tue, 25 Jan 2022 21:59:04 GMT

Senator Ed Markey, C-10's director featured in TV news story on nuclear plant's degrading concrete

"NextEra's going to be pissed."

That's what one of our supporters said when they saw the latest I-Team story on Seabrook Station's degrading concrete , and how US Senators Ed Markey and Elizabeth Warren have joined C-10 in pressing for stronger oversight of the incurable problem known as "concrete cancer."

C-10 has been calling for better science and tougher regulation of the alkali-silica reaction (ASR) plaguing Seabrook for over a dozen years ( see overview ). This is especially important because Seabrook is the first commercial reactor in the US known to have the problem, thus federal regulation guiding its management is sorely lacking.

While it's concerning that ASR is getting worse and nobody seems to know how bad it is deep inside the structures meant to contain deadly radiation, it is encouraging that a leading TV news station is shining their spotlight on the story, and educating the public about the issue.

Seabrook's owner probably wishes that C-10 would go away.

Well, our job as nuclear safety watchdogs entails ruffling a few feathers once in a while.

What can we say? NextEra Energy Seabrook has a duty to the public to do everything they can to keep us safe. Of course, as a merchant power plant, they have a few other competing interests as well.

That's not to say that there aren't good people at Seabrook who are trying to do the right thing. But right now, aside from a vague and open-ended indication from the US Nuclear Regulatory Commission (NRC) that NextEra is working on plans for how to address the most degraded structures, we don't know a lot.

Not good enough for C-10, and not good enough for Senator Markey, who chairs the Senate Environment and Public Works Subcommittee on Clean Air, Climate, and Nuclear Safety.

“The concrete degradation is happening faster than expected and it is absolutely imperative that as a result, we have a review,” said Senator Markey.

“We have to make sure it’s safe, we have to make sure that concrete is going to hold… that requires critical questions to be asked and answered,” Markey told Chief Investigative Reporter Cheryl Fiandaca of WBZ-TV's I-Team.

What we do know is that any efforts to remediate any of the seven safety-related structures that are so degraded so as to render them "outside of their licensing design basis" would entail massive engineering efforts and major investments.

It's clearly in NextEra's financial interest to delay and obfuscate, to the extent that the NRC accepts it.

That's why C-10 is pushing so hard for specifics, and a timeline on what the company proposes to do. And that's why Congress, which oversees the NRC, must put pressure on the agency to elevate these concerns and provide answers.

The WBZ-TV story highlighted the unknowns with Seabrook's concrete troubles, which, as NRC inspectors have made clear , is worse than anticipated and progressing faster than expected.

See this recent blog by C-10 board member Sarah Doenmez for more on the NRC's Seabrook inspection report that triggered renewed calls for heightened scrutiny of ASR at Seabrook.

C-10 serves as a nuclear safety watchdog, tracking and speaking out about concerns at Seabrook, and reminding the public that living near a nuclear power plant requires some extra care and thought when it comes to emergency preparedness .

After all, our name stands for "citizens within the ten-mile radius"—the designated emergency planning zone around Seabrook Station and each of the nation's nuclear reactors.

“For those of us who live here, we have to think about it. We have to think about how would we evacuate. Where we would get our kids,” said Treat, who is herself the mother of a young child, and lives about five miles from the plant.

“Parents of children who live in a 10-mile radius, we have to sign permission slips to let the school give them potassium iodide to protect their thyroid if there were an accident," Treat told Fiandaca.

"These are the kind of silent burdens that we live with living near a nuclear plant. So that’s why we need to make sure it’s safe,” said Treat.

We are grateful to journalists like Fiandaca, who are helping to raise awareness among the public, and also keep the spotlight on the role that federal regulators and elected officials play in holding Seabrook's owners accountable to putting the highest possible emphasis on safety.

Seabrook Station is currently licensed to operate until 2050. However long the plant generates electricity, the legacy of atomic power—and the impact on public health and the environment—will be very, very long-term.

C-10 will continue to operate our real-time radiological monitoring network in the communities surrounding the plant, which we've done under contract with the Massachusetts Department of Public Health since 1992.

We'll also continue our watchdog efforts—tracking and speaking out about regulatory issues and safety and security concerns at the plant.

Sorry NextEra. We're not going anywhere; this is our home.

Glad that C-10 exists? Please join us.

Make a secure gift online at c10.kindful.com . If you're interested in getting more involved by volunteering or serving on a committee, please contact us at info@c-10.org . You can follow us on social media, and share with a friend. Thanks!

“Structural behavior may no longer be assured”

Wed, 19 Jan 2022 17:48:10 GMT

NRC says corrective action needed to ensure Seabrook's safety

At the urging of C-10, Massachusetts U.S. Senators Ed Markey and Elizabeth Warren recently called on the U.S. Nuclear Regulatory Commission (NRC) to pursue a scientific review of concrete degradation known as alkali-silica reaction (ASR) at the Seabrook Station nuclear plant “that is of sufficient breadth and depth to develop an ongoing solution for ASR monitoring and management.”

Their letter in December 2021 is a reaction to the finding in the NRC’s quarterly inspection report from August 2021, which found that conditions at Seabrook are becoming increasingly unsafe because the concrete is decaying faster than expected and there is no projection for the future rate of expansion.

The inspection report states that “Seven Seabrook structures…would require physical modification or additional analysis to comply with their current licensing and design basis requirements.”

Additional study is certainly needed, and C-10 appreciates the Senators’ leadership in pushing for independent experts to make recommendations. The NRC lacks comprehensive regulations that companies must follow in handling ASR, since Seabrook is the first nuclear plant in the U.S. known to be afflicted with ASR “concrete cancer.”

In the past, the NRC has relied heavily on NRC engineering judgment without the advice of independent experts on new safety issues for which there are no NRC regulations. Independent study is needed now to create the future modeling which plant owner NextEra Energy has not performed, and is critical to understanding the level of danger to the public created by the decay of Seabrook’s concrete and the deformation of its buildings. Given that the ASR has progressed so much more rapidly than expected, the question of concern is how much time we have for further study before structures reach a critical point.

A Timeline is Needed

The license amendment granted to Seabrook by the NRC in March 2019 presumed limits to the expansion of ASR. But by June 2021, NRC reported that seven buildings were found to “require physical modification or additional analysis to comply” with the new license requirements. What physical modifications would make those structures safe? How and when will those modifications be made?

The NRC has indicated that studies of remediation pathways are underway but have been vague about the timeline, mentioning that NextEra could take a few years to submit their plan. What we do know is that reinforcing these massive concrete structures would entail major engineering that would cost many millions of dollars.

When will plans for these physical modifications be disclosed to the public? Will the plans be peer reviewed and correlated to the independent scientists’ projections for the rate of ASR decay? C-10 calls on NextEra to address these structural concerns swiftly, and for the NRC to be transparent about the timeline and process. The public deserves to know what actions NextEra is taking and when the plans for physical modifications will be completed, reviewed and acted upon.

C-10 Has Been Working for Decades to Ensure Seabrook’s Safety

The inspections that brought the state of Seabrook’s ASR to light are a direct result of C-10’s efforts to ensure that NextEra is monitoring and addressing the pervasive concrete decay at Seabrook, which has been underway since 2009, when it was first detected.

As a result of C-10’s efforts (see the blog on our legal challenge relative to the management of ASR at Seabrook) increased inspections of Seabrook Station’s concrete degradation were required in 2020. Seabrook’s original license included no conditions about monitoring its concrete, as it was not then recognized that ASR concrete degradation, though common in roads and bridges, would impact nuclear power stations.

Seabrook was granted a license amendment on March 11, 2019, which included changes to the Updated Final Safety Analysis Report to allow Seabrook to keep operating even with the ASR concrete degradation. A License Extension Request to operate until 2050 was granted on March 12, 2019 (See a timeline and links to key events here .)

Originally, the Nuclear Regulatory Commission allowed NextEra to monitor areas of decaying concrete at specified intervals of 6 months, 1 year, 3-5 years, or 10 years. C-10 knew that was not enough, because no one has ever determined the rate of concrete decay at Seabrook to be able to predict its future trajectory.

This is why C-10 challenged Nextera’s request for a license amendment and was supported by Dr. Victor Saouma, a world-renowned expert in ASR, to clarify the need for precise modeling to get a clear picture of the progress of the concrete degradation at Seabrook Station. The NRC's Atomic Safety and Licensing Board agreed with C-10 on the need for more frequent inspections, and ordered that these be carried out. For more on Dr. Saouma's analysis, see this discussion of his recent book featuring ASR issues at Seabrook.

More Inspections Led to More Findings

Last August, Seabrook’s NRC inspectors published a quarterly inspection report based on those inspections. The report showed that the ASR decay is far more widespread than had previously been acknowledged, and that it is progressing faster than had been believed. In total, seven structures were found to be out of compliance with license requirements. In four of these seven, the ASR degradation may be at a point that compromises safety systems.

The NRC cited NextEra for a violation based on “Inadequate Operability Determination for Structures Outside the ASR Evaluation Methodology: NextEra staff did not adequately account for the future progression of alkali-silica reaction (ASR) (i.e., a time dependent mechanism) in their prompt operability determination (POD) for several Seabrook structures. Specifically, NextEra staff did not trend and project the periodic threshold monitoring data for the affected structural elements to ensure the structures would remain capable of performing their safety functions to the next scheduled inspection” (p. 9 of the report).

This means that NextEra is monitoring the degradation but they are not using their data to project whether Seabrook Station will remain safe until the next inspection. The NRC must establish clear regulations for safety in structures with ASR decay generally, and must impose a clear deadline within a safe time frame for NextEra to create the projections to determine whether Seabrook’s structures can perform their safety functions, and keep us safe.

Will the Structures Remain Functional Until the Next Inspection?

The report states that four structures are already outside the license criteria. “The inspectors reviewed the consolidated POD documented under AR 02276197 that evaluates Seabrook structures affected by ASR with discrete structural elements that do not meet NextEra’s current licensing and design basis. The inspectors focused on four specific structures: emergency feedwater pump house; service water cooling tower; control and diesel generator building; and a mechanical penetration area.

These are Seismic Category I reinforced concrete structures designed as described in the Seabrook Updated Final Safety Analysis Report Section 3.8.4 and house various safety-related systems and components" (p. 9). These decaying and cracking structures house key safety components. If they degrade further, what will be the impact on those safety systems and components?

The NRC says that NextEra has not ensured “the structures would remain capable of performing their safety functions to the next scheduled inspection” (p. 9, emphasis added). What if they don’t perform those safety functions? What steps must NextEra take to return to its design basis requirements and ensure that the safety systems and components perform as intended? The NRC must clarify its expectations of NextEra to the concerned public.

Seabrook is Operating Outside Current Licensing and Design Basis

In addition to the four structures mentioned above, inspections identified another three for a total of seven structures currently outside licensing requirements and in need of repair. “Upon completion of the structural evaluations …, NextEra staff determined there were seven Seabrook structures that had specific structural elements (walls, slabs or beams) that would require physical modification or additional analysis to comply with their current licensing and design basis requirements.” (p. 14)

The NRC has stated that Seabrook is operating outside its license conditions. How long can this be allowed to continue? Why does the NRC allow Seabrook Station to operate outside its license requirements? What are the rules for enforcing compliance with license requirements? The NRC must enforce compliance with the licensing requirements and publicly clarify what that will mean, so that the public knows how Seabrook’s structures will remain safe.

“Failure Should Be Addressed”

The inspection report states: “For those instances where individual walls, beams or slabs in certain structures covered by NextEra’s POD do not meet the code acceptance criteria, structural behavior may no longer be assured within elastic limits, and rebar yielding, or failure should be addressed in the POD or other appropriate document to demonstrate conformance with this license condition. “ (pp. 13-14) In short, the NRC inspectors were not sure that walls, beams and slabs wouldn’t fail and that rebar in that concrete wouldn’t give way. What the NRC is asking of NextEra is that they produce a document detailing their plans for remediation. They are not yet requiring NextEra to correct conditions of potential failure.

C-10 wants to know more. How would NextEra handle such concrete failures? What conditions would wall, beam, slab or rebar failure create? What would that mean for structures, especially in the event of an earthquake? Could radioactive gasses or waters escape in a worst-case scenario?

“Longer-Term Corrective Actions” Needed

The NRC concludes their report asking NextEra to document “longer-term corrective actions (i.e. physical modifications)” based on data from their building deformation monitoring program for the control building and the diesel generator building. (p. 16)

So let’s be clear: Seabrook Station is monitoring the deformation of its buildings based on concrete decay. Two of those buildings are the control building and the diesel generator building, which contain safety systems. These two are on the list of buildings that were already operating outside of the license requirements when the report was published last August. NextEra is reportedly working on a plan for fixing these buildings, but there does not appear to be any deadline or specific expectation for progress on the plan, let alone the actual remediation work. And the ASR is clearly progressing faster than expected.

Independent experts must be involved in determining what longer-term corrective actions should be taken, and when they need to be taken, in order to protect public health and the environment. The letter from Senators Markey and Warren makes clear that such action should happen swiftly.

An Unacceptable Risk

C-10 calls on the NRC to exercise its authority to keep us and the environment safe and to enforce the conditions of Seabrook’s license. If the NRC determines that Seabrook is not safe, then they need to take immediate action to compel NextEra to make the “long-term corrective actions” and “physical modifications'' that the NRC’s own inspectors say are necessary.

As stated by Dr. Victor Saouma in his book, "Under the circumstances, (I) would argue that Seabrook is not demonstrably or assuredly safe….The structure is at a societally unacceptable risk and the regulating agency owes a credible safety assessment to the public living within the 10-mile radius and beyond."

Your Voice Matters

If you are concerned about these issues, you can write to NRC Chairman Christopher Hanson to reinforce C-10’s message that the NRC must take immediate action to compel NextEra to develop and publish their plans for the long-term corrective actions for physical modifications needed to keep Seabrook Station safe and structurally sound.

The Honorable Christopher T. Hanson

U.S. Nuclear Regulatory Commission

Mail Stop 0-16B33

Washington, D.C. 20555-0001

Chairman@NRC.gov

You can also contact your state legislators to let them know your position and ask that they write Chairman Hanson in support of Senators Markey’s and Warren’s call for independent scientific study. Or write to your local newspaper to spread awareness of the problem of degrading concrete at Seabrook, and the need for stronger oversight.

Contact C-10 Research and Education Foundation

If this blog has piqued your interest or if you have questions, check out our website at c-10.org or contact us for further information. C-10 exists in part thanks to our members. Please join us to support our efforts to hold the NRC and NextEra accountable and keep Seabrook safe!

Works Cited

C-10 Brings Legal Challenge To Seabrook’s Concrete Testing and Monitoring . C-10 Research and Education Foundation.

Oversight Letter from Senators Markey and Warren to NRC Chairman Christopher T. Hanson . December 10, 2021.

Seabrook Concrete Case featured in New Book by C-10’s Expert . C-10 Research and Education Foundation. April 16, 2021.

United States Nuclear Regulatory Commission. SEABROOK STATION, UNIT NO. 1 – INTEGRATED INSPECTION REPORT 05000443/2021002. August 11, 2021. https://irp.cdn-website.com/1cc0687d/files/uploaded/SB%202021002FINAL.pdf

Eight Things C-10 Accomplished in 2021

Mon, 03 Jan 2022 19:14:23 GMT

It's easy to feel overwhelmed when the topic at hand is nuclear safety. It's kind of heavy, you know? Sometimes it helps to step back and measure our successes. True, nuclear safety can be hard to quantify, but at C-10, we KNOW we're making a difference.

For thirty years, the non-profit C-10 Research and Education Foundation has been monitoring airborne radiation in real time, communicating with government officials about safety and security concerns at the Seabrook nuclear plant, and serving as an educational resource for the public in Massachusetts and New Hampshire on what it means to live near a nuclear power plant.

Seabrook Station is currently licensed to operate until 2050, with the onus the US Nuclear Regulatory Commission (NRC) and plant owner NextEra Energy to ensure it can be done safely. But who's watching the regulators? C-10, that's who.

Here are a few of the things we’ve been up to in 2021, thanks in part to the generosity of our supporters:

Expanding the Citizens Radiological Monitoring Network in New Hampshire to improve our coverage area, and successfully making the case to Massachusetts lawmakers to increase funding so that we can invest in field equipment like probes and anemometers.
Developing plans to make the network “climate resilient” to ensure that severe weather doesn’t take down our ability to monitor radiation in real time . We’re almost there in securing the funds to launch this transformative project, which will feature radio-based communication powered by a solar and battery configuration. Stay tuned for updates!
Keeping the focus on how NextEra Energy Seabrook and the US Nuclear Regulatory Commission (NRC) are managing the problem of alkali-silica reaction (ASR) that is weakening the concrete meant to contain harmful radiation from escaping into the environment. Check out this re cent TV coverage !
Educating and engaging with members of Congress and meeting with NRC Commissioner Jeff Baran to ensure that regulators do more to understand ASR at Seabrook Station and at other reactors where it may be silently developing, and that the right experts are at the table to guide policy.
Continuously reviewing inspection reports and other documents, consulting with our experts, and communicating with the NRC’s resident inspectors at Seabrook to learn more and press for answers and accountability.
Informing Seabrook’s neighbors about how and why they should get potassium iodide tablets (KI) to protect their health in the event of an emergency, as well as other ways to be prepared if the unthinkable happened.
Speaking out about environmental justice issues relative to the nuclear life cycle : from mining to waste storage that are particularly burdensome to indigenous and communities of color.
Planning for a strong future - C-10's board of directors have approved our 2022-24 three-year strategic plan, which includes new research projects, enhanced data analytics, a renewed focus on education, and investments in our organizational capacity in terms of people and equipment. We'll tell you more about it soon. For an overview of our priorities, click here .

We may not want to think about it, but Seabrook Station isn’t getting any safer as it ages.
From problems with degrading concrete and mechanical systems, to the increased risks brought by climate change with storms and coastal flooding, now more than ever, we need C-10's watchful eyes and strong voice.

I'm very proud of how we capped our 30-year anniversary. For more details on what we've achieved thanks to our supporters, Business Allies , grant funders and the Massachusetts Department of Public Health, see this blog . There's much more to do, and we hope you'll continue to stand with us in this important work.

On behalf of all of us at C-10, thank you so much, and best wishes for the new year!

- Natalie Hildt Treat, Executive Director

P.S. - Didn't get to make a year-end gift yet? Don't worry, you can still give HERE .

Reflecting on our success and looking ahead

Tue, 23 Nov 2021 15:53:23 GMT

Remarks by C-10's board president

Executive director’s note: This fall, C-10’s board of directors held a retreat to discuss goals and plans for our next three year strategic plan. A lot has happened in the four and a half years since I became executive director of this small but mighty organization. In 2017, we hadn’t yet launched our legal challenge on how Seabrook Station is handling its degrading concrete. Now we’re continuing our watchdog efforts, having won stronger federal oversight of the problem.

As we continue to mark our 30-year anniversary since incorporation, we are looking to the future—one where strong oversight of our nuclear neighbor will continue to be important. I’m grateful to all of our members and supporters, and especially to board members like Patricia Skibbee of West Newbury, our long-time president. Following is an excerpt of the reflections Pat delivered when we met at CI Works, the historic mill building in Amesbury where our office is located.

Look around at where we are and who we are today.

Our accomplishments over the past two to three years—and in fact over the past 30 years—are amazing.

Today, we are meeting in this beautiful facility in the heart of the Seabrook nuclear plant emergency planning zone. Look at each other: we are a team of spectacular, dedicated, focused, brilliant people who come together out of commitment to keeping each other and all around us safe.

What we’ve achieved is almost unbelievable.

In January 2020 we moved from our free, long-time downtown Newburyport headquarters to this fantastic facility where we have to pay (very reasonable) rent, and that has worked.

Thanks to the leadership of Chris Nord, in 2019 C-10 gained intervenor status in plant owner NextEra’s License Amendment Request (LAR) case relative to alkali-silica reaction (ASR) that was being heard by the US Nuclear Regulatory Commission (NRC).

Thanks to our emerita research director Debbie Grinnell and others, C-10 already knew about ASR—the chemical reaction known to NextEra since 2009—that was eating away at the concrete structures at Seabrook Station. With untold hours of our own time and energy, we learned about ASR to the point that we could engage with NRC staff and plant attorneys on this issue. Intense and successful fundraising earned us the vital services of Attorney Diane Curran.

Dr. Victor Saouma , a leading ASR expert from the University of Colorado Boulder, felt compelled to join us in the action to convince the NRC’s Atomic Safety and Licensing Board to force NextEra to assess and monitor ASR in more thorough and scientific ways.

We will always honor long-time member Diane Teed for her “representativeness” argument: testing concrete in a Texas lab is NOT testing the concrete at Seabrook. The Atomic Safety and Licensing Board sided with C-10 and set new licensing conditions, not everything we asked for, but way better than would have been the situation without C-10.

Also within the past several years, the NRC has agreed to extend the plant’s operating license to 2050, a 20-year extension beyond the initial license that lasts until 2030. But as we know, Seabrook’s operators have to demonstrate safety and operability every day; who knows how the worsening concrete problems could change the timeline.

We found Peter Somssich in New Hampshire, a Portsmouth State Representative and retired engineer committed to radiation monitoring and nuclear safety. He has helped us raise funds and has himself donated generously toward expanding real-time radiological monitoring in New Hampshire —the state that is home to Seabrook Station, but has never publicly funded real-time monitoring as Massachusetts has, almost since the beginning.

C-10 now has six monitoring stations in N.H., all privately funded. This is double the coverage we had just two years ago. Yet we must work hard to continue funding this effort.

For the past 19 months, C-10 has become a ZOOM organization. COVID-19 shut down our in-person meetings, but it definitely has not shut down our actions or our effectiveness!

C-10, with the superb leadership of our Executive Director Natalie Hildt Treat, has won a number of grants: from the Quaker Hill Foundation, the Institution for Savings, the Virginia Wellington Cabot Foundation and the New Hampshire Charitable Foundation. Further, in fiscal year 2022, the Commonwealth of Massachusetts has allocated additional funds allowing C-10 to invest in new monitoring equipment.

We have a pending grant from the Massachusetts Clean Energy Center that would enable us to begin climate resilience upgrades to ensure that severe weather doesn’t take out our ability to monitor airborne radiation levels.

Every one of these grant successes is backed by almost painfully detailed, demanding, thorough and lengthy form-filling-out and letter writing, supported by multiple pages of C-10 financial details. Natalie is a star at this.

In the past few years, C-10 has solidified and expanded our relationships with elected and appointed officials. In July, C-10 met virtually with NRC Commissioner Jeff Baran in preparation for his visit to the plant to see ASR with his own eyes—Seabrook is, after all, the first reactor in the nation known to have ASR. It likely won’t be the last.

We’ve worked closely with the Massachusetts and New Hampshire congressional delegations , conducting several briefings for aides and including nuclear power experts Paul Gunter and David Lochbaum sharing their insights. At present, Senator Ed Markey’s team is preparing a joint letter advocating stronger action by the NRC on the concrete issues at the plant.

State Senator Diana DiZoglio and Representative James Kelcourse have been helpful in securing and expanding our Massachusetts state funding, and we’ve stayed in touch with local officials as well—on issues relative to potassium iodide availability, what’s happening with Seabrook’s concrete, and more.

Communication with Seabrook’s resident inspectors is frequent and effective, though we wish their quarterly inspection reports had more detail and teeth when it comes to disturbing findings.

We’ve done all we can to maintain a public presence during COVID time, hosting and participating in some open houses and networking events, offering online meetings and information sessions to business and service groups, students, retirees, and of course holding our own annual ZOOM public meeting in June.

We are active on social media, out there on traditional media– garnering coverage from WBZ-TV, WBUR radio, local and regional newspapers, and several national trade publications as well.

One current C-10 project is to make our monitoring network climate resilient via a system of solar power, batteries and radio communication. And look at our team: we have fabulous staff in Natalie and Mike Mansir, and helpful consultants. We have increased the professionalized our processes and procedures.

And we celebrated all this—our years of hard work, successes and dedication, history and current actions—in September on the most gorgeous Saturday afternoon at our 30th anniversary celebration at Salisbury Beach State Park. As founding Executive Director Sandra Gavutis said, it felt like a family reunion.

What comes next? We are taking a stand on issues of environmental justice , specifically the location of anticipated high-level radioactive waste storage sites, anticipating how to pressure the NRC to enact regulations around ASR and testing every nuclear plant in the country for ASR, strengthening the monitoring network, conducting new environmental research, and anticipating a regional electric grid that one day may not include Seabrook Station if ASR or other safety concerns prove technically or financially insurmountable.

As Natalie said the other day, C-10 “is punching way above our weight.”

I’m proud to help lead this vital organization, and I’m committed to ensuring that C-10 can meet the challenges of the future by broadening our reach and strengthening our funding base.

Inspired? Please make a gift to C-10 to ensure our important work continues!

WBZ's Cheryl Fiandaca Shines a Light on Seabrook's Concrete

Thu, 07 Oct 2021 17:59:00 GMT

Cheryl Fiandaca brought CBS viewers the story of C-10's work for safety

After months of following the story of Seabrook Station's concrete troubles and C-10's efforts calling for stronger oversight of the problem, award-winning investigative reporter Cheryl Fiandaca of WBZ-TV's I-Team introduced viewers in greater Boston to the issue. Fiandaca and her cameraman visited C-10 twice, and also got the chance to learn about our real-time radiological monitoring network. Watch the segment, here .

C-10 has been speaking about about alkali-silica reaction (ASR) at the nuclear power plant in our midst for over a decade. More about those efforts can be found on our webpage about the legal challenge we brought regarding Seabrook's concrete testing and monitoring protocols.

While Senator Ed Markey of Massachusetts told Fiandaca that more needs to be done, what wasn't mentioned is that C-10 has called on all members of Congress in Massachusetts and New Hampshire to speak out on behalf of public safety due to the severity of Seabrook's concrete woes, and that a joint response is in the works.

We've asked the lawmakers to urge the US Nuclear Regulatory Commission (NRC)'s Advisory Committee on Reactor Safeguards (ACRS)—an independent advisory body made up of various experts—to tap experts with particular knowledge of ASR to do a "deep-dive," on the issues that relate to the safe operation of Seabrook, as well as to how this relatively new problem is managed at other reactors where it may appear.

C-10's Executive Director Natalie Hildt Treat conducted a video briefing for staffers of Senators Jeanne Shaheen and Maggie Hassan (N.H.), Senator Elizabeth Warren (Mass.), Congresswoman Annie Kuster (N.H.) and Congressman Seth Moulton (Mass.) to understand the C-10's concerns with the handling of Seabrook's concrete, particularly after the startling revelations in the most recent quarterly inspection report, as described in our recent blog.

Just as Senator Markey's aide was drafting a sign-on letter to be circulated to colleagues, we got word that the Advisory Committee on Reactor Safeguards was meeting on October 6, 2021 to map out upcoming meetings, and would include Seabrook's concrete issues on the table.

As for why ACRS is putting the issue on a future agenda, it could be that they are aware of the interest in ASR, and that may be because C-10 shared our letter to Congress with NRC staff in Region 1. In any event, they are trying to get ahead of the curve.

That doesn't mean that we can pack up and go home. A letter from Congress is still warranted.

C-10 is pleased that the ACRS has agreed to put a focus on the problems of degrading concrete at Seabrook Station. Because this is a relatively new problem for the NRC—Seabrook being the first plant in the nation known to be suffering from alkali-silica reaction, and because ASR is such an opportunistic phenomenon—we hope that the ACRS's review is of sufficient breadth and depth that the pathway to the proper solution for ASR monitoring and management can be developed.

It's also important that the review be expeditious. Based on what we've seen, Seabrook's owner NextEra Energy has some very big decisions to make before too long regarding the investments that would be needed to shore up structures where the concrete has already degraded to a point of concern.

As many as seven structures are at or beyond what's called the design basis—an evaluation of whether they can perform as designed to protect the public and contain radioactive materials—particularly in the event of an earthquake.

The health and safety of people and the natural environment demands that the best experts are at the table, and that a science-based, predictive approach to understand the progression of ASR is employed.

A review and any new recommendations that the ACRS would make to the NRC could have far-ranging implications, since there are no comprehensive federal regulations that require testing of concrete at other aging nuclear reactors, or dictating how it must be monitored and managed should it appear.

Stay tuned!

Nuclear waste and environmental justice

Thu, 07 Oct 2021 16:13:07 GMT

The shared legacy of atomic power, and the need for consent-based siting

As an organization concerned with the health and safety of people and the natural environment, C-10 understands that the wellbeing of our own community and the energy generated to support our regional economy is inextricably linked to the people and places affected by the entire life cycle of nuclear power. This cycle includes mining and processing, transport, and ultimately the storage of waste that will be deadly toxic for a million years, or more.

C-10 is deeply troubled that waste from energy generated to power the New England economy could end up poisoning under-represented indigenous and minority populations far away. With decades of waste piling up, communities in other regions of the country are being asked to shoulder an unfair burden.

An unending and toxic legacy

The legacy of nuclear waste is terrifying to contemplate. All generation of nuclear power results in toxic waste products, some of which have short half-lives and quickly decay into materials such as lead. Other compounds will be hazardous to living creatures for millions of years. Uranium 239 has a half life of 240,000 years; Uranium 238’s half life is 4.5 billion years. Neptunium - 237’s halflife is 2 million years, and Iodine-129’s is 17 million years.

These elements can be present in both high-level and low-level radioactive waste, and are created both by nuclear weapons production and by nuclear energy reactors. The US Government Accounting Office states that our nation has generated 80,000 metric tons of high-level radioactive waste from nuclear energy reactors, and 90 millions gallons of high level radioactive waste from nuclear weapons. That’s a lot of waste—and the figure does not include low-level waste.

Nuclear waste will continue to emit radioactivity harmful to humans and the environment for longer than we can contemplate. While we can hope that facilities for storing nuclear waste will prevent most of us from direct exposure to these poisons, it is difficult to imagine human-built structures that will never crack or leak radioactivity into the water or the environment; some of the waste storage casks are designed to last for 100 years; the numbers just don’t add up.

According to the NRC’s Backgrounder on Radioactive Waste , “High-level wastes are hazardous because they produce fatal radiation doses during short periods of direct exposure. For example, 10 years after removal from a reactor, the surface dose rate for a typical spent fuel assembly exceeds 10,000 rem/hour—far greater than the fatal whole-body dose for humans of about 500 rem received all at once. If isotopes from these high-level wastes get into groundwater or rivers, they may enter food chains. The dose produced through this indirect exposure would be much smaller than a direct-exposure dose, but a much larger population could be exposed.”

This description of the dangers of spent fuel rods from nuclear reactors is only one source of nuclear waste; there are many others.

Feds push forward with “interim” storage

The federal government’s recent decision to build a repository for high-level waste on Western Shoshone land is in violation of treaty protections and was made without consent from the people, or the state.

This plan also runs counter to a 1994 executive order by President Bill Clinton . President Clinton issued the order requiring federal agencies to consider environmental justice issues when issuing permits for new polluting facilities. Although, as an independent agency, the US Nuclear Regulatory Commission was exempt from the order, then-Chairman Ivan Selin committed the NRC to implementing it.

The state of New Mexico has sued the NRC over its waste disposal plan. In his complaint, New Mexico’s Attorney General Hector Balderas outlined the risks his state's citizens would face if the facilities are built. “I am taking legal action because I want to mitigate dangers to our environment and to other energy sectors,” he said in a statement. “It is fundamentally unfair for our residents to bear the risks of open ended uncertainty.” Read more in this C-10 blog from May 2020.

“We take it as our mission to try to ensure the safety, health, and security of our nearby residents,” said Christopher Nord, founding board member of C-10. “We must monitor the fuel chain, because Seabrook Station’s effects live on, far beyond our ingestion pathway.”

C-10 believes it is our responsibility to advocate for the safest ways to manage nuclear waste, as outlined in our May 2021 Policy Paper on Environmental Justice .

Decades of power, no permanent solution

The US Department of Energy (DOE) is the federal agency in charge of developing plans to dispose of commercially generated nuclear waste, and for commissioning the facilities to enact those plans. Because of the many complexities of this task, and its expense, the DOE has not yet settled on a workable strategy for safely storing radioactive waste even as quantities of the materials continue to be produced. Spent fuel rods from nuclear reactors are mostly stored in dry casks at the nuclear power plants where the waste was created.

But this is not an option for all forms of high level waste. Yucca Mountain , once hoped by some to be the solution to the nation’s nuclear waste problem despite geological and environmental justice concerns, suffered an explosion in 2014 and is no longer considered a viable option.

Most experts agree that high-level waste must be stored underground in carefully chosen locations with carefully constructed chambers that can be carefully monitored. But where should these be located?

Under pressure from the nuclear industry to provide solutions, the DOE is now allowing private companies to take on this problem. Holtec International has proposed so-called “interim” storage sites in New Mexico.

Interim Storage Partners (ISP) has proposed a site in western Texas. ISP proposes an initial 40-year license to consolidate and store an eventual total of 40,000 metric ton of used nuclear fuel, developed over eight flexible phases.

The NRC has been reviewing these proposals, and has already greenlighted the west Texas proposal. Both of these proposals would involve moving the nation’s high-level waste by shipping it by rail and on trucks to sites in western Texas and New Mexico, to Shoshone lands.

The dangers created by shipping high-level radioactive materials across the nation on our roadways and railroads is clear. These “solutions” place our nation’s waste on lands of poorer and more vulnerable citizens. Indigenous communities in the Southwest have suffered repeated exposures to radioactivity from uranium mining and as downwinders of the nation’s nuclear testing grounds.

To put high level waste generated at Seabrook Station to meet New England’s energy needs onto Native land in the Southwest would put these communities at further risk of exposure and long-term health effects. Our nation has a well-established pattern of making our more vulnerable and less powerful citizens face unacceptable environmental pollution and suffer its effects.

The need for consent-based siting

C-10 believes that nuclear waste should stay in the states in which it is created and should be stored in suitable locations with consent of the communities likely to be affected. Proposed host communities must clearly understand the risks associated with exposure to radioactivity, the storage facilities, and their rights.

The DOE has committed to using this process, and started exploring this method, by gathering input following the recommendation of the Blue Ribbon Commission on America’s Nuclear Future in 2012. The DOE has stated, “The Strategy endorses a phased, adaptive, and consent-based approach to siting and implementing a comprehensive management and disposal system.” It gathered a first round of public input, which raised a host of issues.

According to A Better Way To Store Nuclear Waste: Ask for Consent by scientists Seth Tuler and Thomas Webler writing in The Bulletin of Atomic Scientists, consent-based siting is used in several other countries, and is endorsed by leading nuclear safety organizations.

The government knows that consent-based siting is the right way to proceed. C-10 calls on the Department of Energy and the Nuclear Regulatory Commission to follow these commitments and not to cut corners by endorsing solutions that perpetuate our nation’s history of environmental injustice.

Consent-Based Siting requires those of us who use nuclear energy to take responsibility for its by-products. This also forces all of us to face the dangers we allow as the price of our energy consumption. It is the right thing to do.

NRC is Seeking Public Comments on Environmental Justice through October 29, 2021

What actions could the NRC take to enhance consideration of environmental justice in the NRC's programs, policies and activities and agency decision-making, considering the agency's mission and statutory authority?

So, what do YOU think about environmental justice and nuclear power issues? The NRC wants to hear from you!

See this link on NRC's website to learn more and see a list of questions to get you thinking.

Comments will be accepted through October 29, 2021. You may submit comments through the following:

Voicemail at 301-415-3875 or 800-882-4672
Email at NRC-EJReview@nrc.gov
The Federal rulemaking site, www.regulations.gov , using Docket ID NRC-2021-0137
Mail comments to: Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Program Management Announcements and Editing Staff.

Read C-10's comments , submitted to NRC on October 20, 2021.

Celebrating 30 years of C-10!

Wed, 29 Sep 2021 16:41:35 GMT

The weather gods cooperated, and C-10 supporters and friends gathered for a wonderful celebration at the Salisbury Beach State Reservation on Saturday, September 25. It was a wonderful afternoon connecting with the people who have made C-10's work possible for so many years... and looking towards the future!

We were thrilled to hear remarks from Sandra Gavutis, C-10's founding executive director, who recounted a brief history of our group's early days.

Many, many people in the communities surrounding Seabrook Station were gravely concerned about the construction of a nuclear reactor in their midst. They questioned how evacuation would ever be possible in the event of a radiological emergency, and they were concerned about the health implications of living so close to a reactor that is licensed to release small amounts of radioactive materials as a part of normal operation.

Ultimately, the C-10 Research and Education Foundation was incorporated, with real-time radiological monitoring the core of our mission. C-10 has been partly funded by the Massachusetts state legislature since 1992, with assessments on Seabrook Station that are used for a variety of public health and emergency planning programs, including the Citizens Radiological Monitoring Network.

An active citizenry, the leadership of elected officials, and the press telling to stories that matter—these are all part of the equation in C-10's work for public safety and environmental health. We were pleased to see so many founding members of C-10, and honored to receive legislative citations from State Rep. James Kelcourse and Senator Diana DiZoglio.

There's more important work to be done. The aging concerns at Seabrook—degrading concrete chief among them—the increasing threats to our coastal region of severe weather and storm surge, all reasons that C-10's watchful eye, advocacy and education are more important than ever.

Thanks to all who came out to be with us. If you couldn't make it, you were with us in spirit!

Why KI belongs in your emergency kit

Fri, 10 Sep 2021 00:49:29 GMT

My summer at C-10 and my quest for KI

Editor’s note: Juliana Gannon served as C-10’s first in-person intern in a while, helping on important research and communications projects. We sure were lucky to have her help! Since Juliana and her family live within the 10-mile emergency planning zone of Seabrook Station, I thought a simple and useful exercise would be to contact the local communities that make potassium iodide (KI) tablets available and compile information for our website.

The second part of the project would be to obtain this thyroid-protecting medicine for her family from the Amesbury Health Department. Unfortunately, that part didn’t prove so simple.

As we learned, the city was undergoing a staffing reorganization, so there was not an established process for residents to pick up the tablets. Besides that, there was a disagreement between some city personnel as to whether the tablets should be distributed freely in case of an emergency, or only after a radiological accident began unfolding. Hmmm…

The Massachusetts Emergency Management Agency’s website states that for maximum effectiveness, KI should be taken as soon as possible if directed, and that waiting several hours dilutes effectiveness in protecting the thyroid. That’s why the state and federal governments recommend that people who live close to nuclear reactors keep KI in their emergency kit.

By the way, September is Emergency Preparedness Month , so it’s a great time to evaluate your own plans, and pick up some potassium iodide, if you need it!

In any event, here is Juliana’s tale. We’re happy to report that Amesbury, like the other six Massachusetts communities within Seabrook’ 10-mile radius, continue to make KI available to residents who request it. Thanks to Juliana, helpful info is on our website, here , including info for New Hampshire residents.

C-10 entered into my life while I was searching for a summer internship. I am a senior at Amesbury High School and am applying to colleges in the fall. My goal for the summer was to get hands-on experience related to my major of interest, marketing.

My guidance counselor helped me get in contact with Natalie Hildt Treat, C-10’s executive director, and a member of Amesbury High’s class of ‘93. Through working with Natalie, I have learned valuable information on communications and public outreach as well as nuclear safety and the importance of emergency preparedness.

Natalie asked me to look at C-10’s website and social media and find ways to increase accessibility to important information. For example, we created a chart on the website outlining how, where and who to call to get potassium iodide (KI) tablets.

I gathered information by calling health departments for the six Massachusetts communities within Seabrook Station’s Emergency Planning Zone (EPZ). Additionally, we added links to the New Hampshire KI request form. To check out the KI resource on C-10’s website, click here.

Got KI?

Through my research on potassium iodide, I learned about the important role it has in protecting human health if there is a nuclear emergency. I shared this information with my family and we felt it was necessary to have KI in our house.

In the unlikely event of a radiological disaster, one of the first ways to respond is to take KI. According to the American Thyroid Association , “KI floods the thyroid with iodine, thus preventing radioactive iodine from being absorbed. If taken at the proper time, KI protects the thyroid from radioactive iodine from all sources – air, food, milk, and water.”

One morning I ventured to the Amesbury Health Department to see what the process is to obtain KI. I was met with surprise by my question; it seems not many people know about or come looking for these small, but valuable pills—despite the annual mailer sent to area homes that encourages people to contact their local board of health to receive their free dose of KI (see pg. 13).

A bit of a goose chase

I was told the health department does not have KI, which led to my confusion—because, as I understood it, the health director was responsible for handling the distribution of the pills. I was given a phone number for the city’s emergency management.

The next Monday I called the emergency management department. Upon asking how I could obtain KI for myself and my family, I was told that Amesbury does not distribute KI unless there is a radiological emergency.

This contradicts with information provided by the Massachusetts Emergency Management Agency , which states, “Potassium iodide can be obtained for those in an EPZ free-of-charge from local Boards of Health. It is recommended that communities in the EPZ stockpile KI for their residents to keep as part of their own emergency preparedness kit.”

With Natalie’s help, we were able to sort out the confusion. I spoke with Deb Ketchen, Amesbury’s new health agent, and learned that the department does in fact have a stockpile of KI available for residents.

After a couple weeks had passed, I received an email from the city's health nurse, Tina LaCourse. She sent me a new form to fill out so I could pick up KI. She told me, “My intention is to streamline the process; to require an electronic or paper request for pills, a signature at pick up, to track the distribution as well as an acknowledgment for residents of dosage and KI use.” It is great to see that Amesbury is working out a new and improved way of handling the distribution of KI.

The day before my final day at C-10, I met Deb Ketchen at the Health Department and acquired the potassium iodide at last. Hooray! I leave C-10 with many great takeaways, as well as a larger interest in environmental work. I will continue posting on the C-10 Instagram account, so if you haven't already, please follow us @c10forsafety .

NextEra's in the dog house

Fri, 20 Aug 2021 20:59:30 GMT

NRC inspectors cite deficiencies in Seabrook concrete monitoring

When C-10 met with U.S. Nuclear Regulatory Commissioner Jeff Baran on August 3—a week before his first visit to Seabrook Station—one of our biggest complaints was that we wouldn’t be able to track what’s going on with the plant’s concrete degradation in the quarterly inspection reports, which have become thinner and more opaque in recent years.

“As a nuclear safety watchdog concerned with the management of Seabrook’s concrete, we seek insights on how the testing and monitoring is going. Yet the only time something appears in the inspection report is if the licensee does something egregious enough to merit a color-coded label,” C-10 wrote in our pre-meeting memo to the Commissioner.

It turns out we would soon get an eye-popping look at NRC’s oversight of the plant’s concrete problems.

NRC’s resident inspectors have plenty of issues with how plant owner NextEra Energy is monitoring alkali-silica reaction ( ASR )—the “concrete cancer” weakening all key safety structures at Seabrook Station. And they had a lot to say about it in their quarterly Integrated Inspection Report , released the day after Baran and an entourage including congressional aides visited the plant.

Some of our takeaways from the report:

- Per NRC, NextEra Energy has been monitoring ASR cracking, but not sufficiently modeling its progression.

- The problem may be worse than thought; some structures are at or near exceeding structural design basis.

- More frequent crack monitoring may be needed, in some cases as often as every 2-3 months. (Before C-10's challenge, some inspection intervals would have been as long as 10 years!)

- Seven structures may need physical modifications to be deemed safe. (There is no cure for ASR.)

- NRC field staff like Senior Resident Inspector Christopher Newport and his colleagues are on the case; this should provide area residents with some degree of comfort.

NextEra’s infractions were coded as “green”—the least bad of NRC’s color-coded performance scale .

But in this case, green is not good. And it does not mean "go."

We’ve heard that the resident inspectors are encouraged to be conservative in doling out too many citations, instead requiring corrective actions by the licensee. There is no doubt that the NRC is focused on what’s happening with Seabrook’s concrete, and they are closely overseeing the management of the problem.

The Q2 inspection report features a detailed citation relative to deficiencies in the plant’s handling of the concrete degradation problem ASR, describing how staff of plant owner NextEra Energy “...did not adequately account for the future progression of alkali-silica reaction... for several Seabrook structures,” (page 2 of the report).

“Specifically, NextEra staff did not trend and project the periodic threshold monitoring data for the affected structural elements to ensure the structures would remain capable of performing their safety functions to the next scheduled inspection,” the NRC inspectors continued.

Interestingly, this lack of modeling was one of C-10’s biggest concerns about the concrete aging management plans signed off on by the NRC, and something that we and U.S. Senators Ed Markey and Elizabeth Warren urged to be added to the new license conditions placed on Seabrook last fall by NRC’s Atomic Safety and Licensing Board.

“It is absolutely essential that the NRC determines the margin of errors in the curve that quantifies expansion,” C-10’s expert Dr. Victor Saouma told Baran in our August 3 video meeting.

While the details of the report are troubling, C-10 is heartened by the amount of NRC staff resources and time that are clearly being spent on overseeing Seabrook’s concrete woes.

From page 9 of the report:

"During the week of June 14, 2021, the inspectors reviewed the consolidated prompt operability determination (POD) documented under AR 02276197 that evaluates Seabrook structures affected by ASR with discrete structural elements that do not meet NextEra’s current licensing and design basis. The inspectors focused on four specific structures:
• emergency feedwater pumphouse
• service water cooling tower
• control and diesel generator building
• mechanical penetration area

These are Seismic Category I reinforced concrete structures designed as described in the Seabrook Updated Final Safety Analysis Report Section 3.8.4 and house various safety- related systems and components.

The inspectors identified that, while the consolidated POD provided evaluations that were technically adequate to show these four structures remained functional, the POD did not look forward and account for the future progression of ASR to demonstrate there is reasonable assurance the structures would remain functional to the next periodic ASR-related inspection."

The report continues on page 10:

“The inspectors determined that while NextEra staff appropriately collected the periodic structural monitoring data, typically on a six month frequency, NextEra staff were not analyzing the expansion measurement trends and the resultant additional ASR-related loading to project and document in their POD that there would remain sufficient margin to support functionality to the next scheduled inspection."

"Corrective Actions: NextEra staff entered the issue in their corrective action program and planned to develop guidance for evaluating affected structures, including additional action limits, safety factors, and consideration for future ASR expansion in their POD. NextEra continues to perform compensatory measures in the form of additional monitoring at an increased frequency," the report continues.

The NRC’s resident inspectors are doing their job and holding the licensee accountable to the safety provisions in its operating license. These license conditions simply would not exist were it not for C-10’s tenacity in pursuing stronger oversight of Seabrook’s degrading concrete since it was first discovered in 2009.

It’s frightening to think that were it not for C-10’s challenge, the inspection interval referenced in this report may have been as long as a decade—now NextEra has to perform them every six months. The public should feel more confident knowing that Seabrook’s ASR problem is getting tough scrutiny by the NRC’s inspectors.

C-10’s team is compiling questions that we will relay to the resident inspectors. If we do not get sufficient answers, you can bet we will elevate the request to leaders like Congresswoman Annie Kuster (N.H.), who recently pressed Commissioner Baran for answers at an oversight hearing with the House Committee on Energy and Commerce (jump to time stamp 3:11:30), and Senator Ed Markey (MA), who chairs the Senate Subcommittee on Clean Air, Climate and Nuclear Safety, and is a stalwart on nuclear safety.

About Alkali-Silica Reaction

ASR, dubbed “concrete cancer,” is an irreversible condition that develops over many years in some concrete structures when reactive aggregates are used to make the cement. The phenomenon results in concrete swelling, a reduction of integrity, and formation of cracks on the surface and in the interior of concrete structures.

Internal cracking is a cause for worry, because webs of small and hidden internal “microcracks” can coalesce into larger cracks, causing “delamination” or splitting apart of the structure. In a large concrete structure like the Seabrook containment enclosure, such cracking could increase the structure’s vulnerability to a breach during an earthquake and lead to an unplanned release of radioactivity.

ASR is a major concern for government regulators because it could render safety structures non-compliant with basic NRC design regulations. These regulations require a demonstration that concrete safety structures can remain intact during a “design basis earthquake”—i.e., not just a severe and unexpected earthquake, but a quake of the ordinary degree of severity that is to be expected for the region. If a structure is not demonstrably strong enough to withstand a design-basis event, it cannot be assumed that the structure will contain radioactivity during an accident.

For more on C-10’s legal challenge to Seabrook’s concrete monitoring and management, click here .

NRC Commissioner Baran seeks C-10 input before visit to Seabrook Station

Mon, 09 Aug 2021 19:52:15 GMT

Ahead of Baran's trip to see plant's cracking concrete, C-10 presses for answers

It is not every day that a small nuclear watchdog group gets to meet directly with one of the U.S. Nuclear Regulatory Commission’s (NRC) head honchos. The agency is charged with overseeing the entire nuclear feet, and has a mandate of protecting people and the environment.

More than a decade of advocating for stronger oversight of the serious safety concern of degrading concrete—and successfully winning stricter license conditions for how Seabrook Station owner NextEra must monitor the problem—definitely put C-10 on the Commission’s radar.

A little nudging from congressional aides to Congresswoman Annie Kuster (NH) and Senator Ed Markey (MA) clinched C-10’s recent meeting with Jeff Baran, one of the three commissioners of the NRC, before his first visit to Seabrook on Tuesday, August 10, 2021.

The August 3rd meeting with C-10 came about after Congresswoman Kuster, who sits on the House Committee on Energy and Commerce, quizzed Baran about the agency’s handling of Seabrook’s degrading concrete during a Congressional oversight hearing on July 14, and mentioned C-10's efforts. (Jump to the 3:11:30 timestamp in the hearing video to see Rep. Kuster's remarks.)

During the hearing, Congresswoman Kuster referenced C-10’s concrete expert Dr. Victor Saouma’s recommendations to impose additional safety conditions on the plant’s operating license to ensure that alkali-silica reaction (ASR) is properly monitored. Rep. Kuster asked Commissioner Baran, “What steps can be taken by the NRC to improve ASR cracking monitoring at Seabrook Station, here in New Hampshire?”

The Commissioner replied by saying that he will soon be visiting Seabrook Station, where he will see the manifestation of ASR firsthand. “We’re going to be looking around and asking those kinds of tough questions,” said Baran, noting that he would first seek input from groups in the area to see what concerns and questions they have. Baran’s entourage will include D.C. staffers of Congresswoman Kuster as well as Congressman Chris Pappas, whose district includes Seabrook.

Baran’s Chief of Staff Amy Powell called C-10 the next day to arrange a video meeting where the group could convey questions for the Commissioner to ask of the licensee, NextEra Energy, as well as the NRC’s resident inspectors. Our meeting took place on August 3, and included Commissioner Baran and two staff members, C-10 Executive Director Natalie Hildt Treat; C-10 board members Debbie Grinnell, Sarah Doenmez and Diane Teed; and Dr. Victor Saouma, an authority on the condition that is affecting Seabrook’s concrete.

The meeting began with Dr. Saouma, a civil engineering professor at the University of Colorado at Boulder, voicing concerns about the deficiencies in NextEra’s concrete aging management protocols as signed off on by the NRC.

“It is absolutely essential that the NRC determines the margin of errors in the curve that quantifies expansion,” Saouma told Baran. “I also recommend that a program be put in place to test representative concrete cores from all nuclear reactor sites for alkali-aggregate reaction (AAR).”

Commissioner Baran encouraged C-10 to write a formal letter to the NRC Commissioners seeking written answers to our questions. A day before Baran's visit—during which he will be accompanied by aides to Congresswoman Kuster and Congressman Chris Papas (whose N.H. district include Seabrook)—C-10 sent a letter to the three Commissioners.

“We are not attempting to re-litigate the case heard under NRC Docket 50-443-LA-2, relative to Seabrook Station’s license amendment request (LAR) due to degraded concrete,” wrote C-10 in the letter sent on August 9. “We urge you to continue giving serious thought to this case, and to consider how you can implement the lessons learned."

Some of the questions C-10 asked of the NRC Commissioners:

Because so much is unknown about the rate of ASR expansion, why doesn’t NRC require the use of error bars in modeling its progression?

How can the NRC increase transparency about what inspectors see at the plant, in particular, with regard to ASR?

After what you’ve learned in the Seabrook case, would you support the development of NRC regulations governing concrete testing, and more scrutiny of other material-aging issues?

Commissioner Baran’s Chief of Staff Amy Powell has assured C-10 that a written response to the group’s questions will be delivered in a timely fashion.

We hope that our meeting and the opportunity to see Seabrook’s degrading concrete firsthand will motivate the Commissioner to keep working for stronger oversight of concrete aging problems at Seabrook and across the nation’s nuclear fleet.

For more background on C-10's work to press for stronger oversight of Seabrook's degrading concrete, visit our blog or this page about the case we brought to the NRC's Atomic Safety and Licensing Board.

Crumbling concrete, risk and regulatory oversight

Mon, 12 Jul 2021 17:55:01 GMT

Watchdogs and scientists are vital to public safety when it comes to structures stressed by age and environmental exposure

After the tragic collapse of the Champlain Towers South high-rise near Miami, several people have asked C-10 about whether concrete degradation—specifically the type that is affecting the concrete at the Seabrook Station nuclear power plant—is to blame.

“The bottom line is, concrete cracks. It's made to crack. All concrete cracks,” said Allyn Kilsheimer , the renowned structural and forensic engineer hired by the town of Surfside, Florida to investigate this disaster.

While it may take months or years for engineers and lawyers to piece together what happened and why , it appears that several interrelated factors may have contributed to the accident, which has resulted in dozens of confirmed deaths, and hundreds more left homeless as another portion of the building was condemned and torn down.

What role did climate change, exposure to humid salt air, and the building’s location on porous limestone play? Did construction methods, aging steel and concrete, or recent work near the structure help “trigger” the shocking collapse in the wee hours of June 24, 2021?

Weak regulations, foot-dragging in the face of expensive repairs

The state building code only requires recertification every 40 years, and that process had recently been started, as the towers were built in 1981. Yet serious structural problems were well-known to the Champlain Towers South homeowners association.

The Washington Post reported that an engineer warned of ‘major structural damage’ years before the Florida condo building collapsed. It was 2018 when Frank P. Morabito’s firm issued a structural survey report that described how the waterproofing below the pool deck and entrance drive had failed, allowing damaging leaks (see image below). There were other problems as well.

To fix these problems was going to cost many millions of dollars—much more than the homeowners association had in the bank. And so time passed. It was another 18 months until Morabito was contracted to provide repair plans.

ASR, or similar concrete degradation?

An article about the collapse in Fast Company explained, “another problem with concrete is something referred to as ‘concrete cancer,’ an alkali-silica reaction (ASR) that can make buildings crack and expand.”

“ ASR ,” as C-10 followers will remember from our work on Seabrook safety , is an irreversible and “opportunistic” type of concrete degradation caused by a chemical mismatch between the concrete mix and the aggregate, that—in the presence of relative humidity above 60 percent, results in the formation of a gel that causes microcracks—and eventually larger cracks and even “bulk deformations.”

Did ASR, or a similar type of concrete degradation play a role in the tower’s collapse? We don’t yet know.

Science in the public interest

After the collapse, I reached out to Dr. Victor Saouma , the internationally recognized concrete expert who assisted C-10 in our legal challenge to the management of Seabrook Station’s degrading concrete.

Dr. Saouma posited that a combination of poor maintenance, weak regulations, and procrastination by homeowners faced with very large costs to fix their building likely contributed to the Florida high-rise tragedy.

Saouma and his colleague M. Amin Hariri-Ardebili recently published a book: “ Aging, Shaking and Cracking of Infrastructures - From Mechanics to Concrete Dams and Nuclear Structures ” (Springer, 2021).

That text will no doubt be referenced in the coming months as civil engineers, state regulators and city planners give a closer look to their own ordinances and practices meant to ensure the safety of everything from bridges to skyscrapers —especially for structures built near rising seas and in the face of more frequent extreme weather and flooding.

Demonstrating the importance of academicians in solving real-life problems, Saouma is working to develop a course called “Studies in Material and Structural Failures” at the University of Colorado, Boulder, where he is a professor of civil engineering.

“The Miami building collapse reminded the public about the role of structural engineers in safety assessment,” said Saouma. Yet our academic curriculum is not well-suited to train students to acquire the required skillset for such tasks.”

Saouma’s course will focus on three areas:

Inspection, document review, material evaluation and testing, and structural analyses;
Theory to assist with interpretation of observation and test results on a range of material aging issues relative to concrete and steel, including alkali-silica reaction;
Remedies, repairs and recommendations.

Calculating risk in the absence of robust regulation

As we detailed in a recent blog , the US Nuclear Regulatory Commission (NRC) is considering extreme license extensions for nuclear reactors, of up to 100 years. But in C-10’s view, the agency does not have an adequate plan (much less regulations) to handle concrete aging conditions like ASR.

"At issue here is how to make a prediction of remaining service life," writes Saouma about Seabrook Station in his new book (pg. 988). "And of course, service life must be reasonably safe as required by federal law (the Atomic Energy Act). In pursuing this important (if not vital) task, [Seabrook owner] NextEra was confronted with a common problem plaguing engineers who pursue similar objectives."

"The first, Saouma writes, "is a glaring absence of codes for the assessment of existing structures. This is particularly troublesome when the aging of our infrastructure is widely recognized. The second is the danger of entrusting engineers, reared in the design of new structures, with the safety assessment of older ones. Those two tasks require two very different skillsets" (pg. 989).

"It is evident that rather than regulating ASR, the NRC instead subcontracted the work of determining how to assess the extent and gravity of ASR at Seabrook to the very same corporation it is supposed to oversee. While the NRC posed a number of questions to NextEra during its technical review, the agency did not exercise due diligence in scrutinizing the scientific validity of NextEra’s response. Unfortunately, this is reminiscent of the problem that came to plague the Boeing 737 MAX," wrote Saouma regarding the role of the NRC (pg. 990).

Safe Enough?

This brings to mind the latest book on my reading list: “ Safe Enough? A History of Nuclear Power and Accident Risk ” by Thomas R. Whelock.

As the publisher describes: “Since the dawn of the Atomic Age, nuclear experts have labored to imagine the unimaginable and prevent it. They confronted a deceptively simple question: When is a reactor “safe enough” to adequately protect the public from catastrophe?

Some experts sought a deceptively simple answer: an estimate that the odds of a major accident were, literally, a million to one. Far from simple, this search to quantify accident risk proved to be a tremendously complex and controversial endeavor, one that altered the very notion of safety in nuclear power and beyond.”

Citizens have a role to play

As an organization dedicated to protecting people and the natural environment, C-10 believes in the power of sound regulations. We also know that there are many factors, including human nature and financial calculus, that necessitate the active involvement by a variety of stakeholders in policy decisions—whether it’s regarding the safety of buildings, bridges, or nuclear reactors.

“The power of an educated and concerned public in advocating for strong, science-based regulation cannot be underestimated,” wrote Saouma in his epilogue to his book . “C-10—a small but determined NGO, relying heavily on volunteer efforts—has monitored the operation of the Seabrook nuclear plant since it began operating. After ASR was discovered at Seabrook in 2009, C-10 quickly perceived that ASR was not only a major safety challenge to Seabrook, but also a potential problem at other nuclear plants," (pg. 1027).

"C-10 then used the NRC’s legal process to force a desperately-needed scientific review on Seabrook’s concrete aging management plan. And C-10 brought about the imposition of license conditions which are essential to any future confidence in the safety of Seabrook. This is a remarkable achievement for a single nuclear plant, and it seems reasonable to hope that the science-based approach advocated here will influence how future ASR policy is made for a range of circumstances,” wrote Saouma.

C-10 will keep watching and speaking out for the safety of Seabrook’s neighbors, and advocating for thoughtful regulation of the nation’s aging nuclear reactors. One can only hope that the tragedy in Surfside will spur greater public involvement and stronger oversight of other aging concrete structures in a changing world.

The Secret Sauce

Tue, 22 Jun 2021 17:35:21 GMT

How partnerships between national experts and local advocates can yield results for nuclear safety

Two truths:

Chattanooga, Tennessee is a long way from Amesbury, Massachusetts.
We are all pretty Zoomed out, and can’t wait to meet in person!

Yet Zoom made it possible for one of the nation’s most respected nuclear safety experts, David Lochbaum , to share his insights with about 40 of us at C-10’s 2021 Annual Public Meeting, held virtually on June 17.

Dave shared stories about the important role that citizen activists, whistle-blowers and industry experts like himself have played in bringing to light some pretty hair-raising problems at the nation’s commercial nuclear reactors. Yup, we call it “The Secret Sauce,” and it turns out watchdogging regulators and reactor operators is a darned important job, all over the nation.

We are grateful to all who joined C-10's Annual Public Meeting, including David Theodore, of Climate Resilient Internet , who is helping us to make the Citizens Radiological Monitoring Network resilient in the face of climate change and other threats. More exciting news is on the way with that initiative. Stay tuned!

You can watch a recording of the meeting and see a video about the resilience project on our YouTube channel , or view the meeting slides on our events page .

Below is Dave’s talk, in its entirety. We sure are lucky to have him on C-10’s Board of Advisors!

Remarks of David Lochbaum, delivered at C-10's 2021 Annual Public Meeting

I joined the Union of Concerned Scientists, or UCS, in October 1996 to work on nuclear power safety issues. Prior to UCS, I’d worked nearly 17 years in the nuclear industry, mostly at operating nuclear plants.

In late 2006, UCS reorganized and I had a new supervisor who was not familiar with my work. It was a good time to look back on my first decade with UCS. I documented my reflection in an internal report titled Nuclear Safety Project 1996-2006: The Ten Year Dash.

My first observation from that effort was that the Nuclear Regulatory Commission, or NRC, is better at establishing safety regulations than at enforcing those regulations. Trying to get the NRC to raise the safety bar isn’t productive when the NRC allows owners to limbo beneath the bar.

My second observation was that the common thread among successful campaigns to trick the NRC into enforcing its regulations involved solid homework and teamwork with local citizens.

Solid homework documented the problem, detailed how and why it violated federal regulations, and explained its safety significance. But solid homework is seldom enough by itself. I often say that NRC stands for Nielsen Ratings Commission. Absent a headline, the most solid homework seldom matters.

In fall of 2001, the NRC staff gathered evidence of problems at the Davis-Besse nuclear plant in Ohio so compelling that they drafted an order requiring the plant to be shut down. I’ve never seen a stronger circumstantial case of impending doom than the NRC staff assembled in drafting that order.

But the draft order, and the safety problems that prompted it, were not made public at the time. There were no headlines. There were not even short articles way back on page 35. The news that fall was the 9/11 tragedy. An NRC senior manager shelved the draft order and allowed Davis-Besse to tempt disaster.

When Davis-Besse finally shut down for refueling in 2002, the NRC staff’s fears were confirmed – the NRC calculated that Davis-Besse came closer to nuclear disaster than any U.S. reactor since the meltdown at Three Mile Island in 1979. The plant had so many safety problems that it took an army of workers more than two years to fix enough of them for the NRC to allow it to restart.

Teamwork makes a huge difference in the value of solid homework. George Galatis, then an engineer for the Millstone nuclear plant in Connecticut, compiled solid homework about spent fuel pool problems on Unit 1. George had seen other workers at Millstone raise issues to management and the NRC to no avail. George partnered with We The People, a local group, to petition the NRC in August 1995 about the safety problems. The teamwork resulted in a TIME magazine cover story in March 1996. Millstone Unit 1 never split another atom.

Most of the safety problems that arose when I was at UCS affected more than one nuclear plant. Whenever possible, I pursued the matter at a nuclear plant where I could team up with local citizens. Once successful there, I’d try for the ripple effect to get it fixed elsewhere.

Local citizens prepared the media and elected officials on nuclear plant safety issues and concerns with NRC’s oversight. Those efforts built a foundation that greatly enhanced receptiveness to listening to concerns. Absent the foundation, media representations and elected officials often lack the time needed to come up to speed on technical issues and default to accepting whatever yarns the company and the NRC spin for them.

I first experienced the power that local citizens can wield during my 17 years working at nuclear power plants. I worked at the Hatch nuclear plant in Georgia, the Browns Ferry nuclear plant in Alabama, and the Susquehanna nuclear plant in Pennsylvania. None of these plants had local groups monitoring their performance.

I also worked at the Grand Gulf nuclear plant in Mississippi. A local group backed by a Member of Congress named Representative Ed Markey (now U.S. Senator from Massachusetts) put a huge spotlight on performance problems there. Likewise, I worked at the Hope Creek and Salem nuclear plants in New Jersey. A Senator from Delaware by the name of Joe Biden focused attention both on safety problems at the plants and the NRC’s inability and/or willingness to get them fixed.

Having worked at nuclear plants with and without external scrutiny, I’ve seen how big a difference it makes. A worker can make a mistake that accidentally trips the reactor or causes a violation to be reported to the NRC (and the media). A worker making such a mistake at a nuclear plant in the spotlight faces much bigger career trouble than a worker making the same mistake at a plant in the shadows.

No worker wants to make a mistake. But workers take extra steps to avoid mistakes when mistakes come at high cost to them personally.

C-10, and organizations like it, compel plant workers and NRC inspectors to try their best. No one wants to read about their mistakes on page one.

C-10 has built a very strong foundation that has enabled many successes over the years. For only one of many examples, C-10 teamed with a renowned concrete expert to compel additional monitoring of the degrading concrete at Seabrook. The company and the NRC fought the measures, but C-10’s foundation provided its expert the platform needed for right to prevail.

I am glad to be on C-10’s Advisory Board because the organization pursues the right issues, the right way, for the right reasons. Three rights cannot make it wrong.

Hurricane season has begun

Thu, 03 Jun 2021 16:43:28 GMT

Nuclear safety during severe weather events is a growing concern

It’s officially Atlantic Hurricane Season again, and it will be an “above average” one, according to the National Oceanographic and Atmospheric Administration ( NOAA ). It’s been almost nine years since Super Storm Sandy pummeled the areas from the Caribbean to the coastal Northeast, leaving a trail of destruction and flooding, extensive and prolonged power and communications outages, and claiming at least 43 lives.

With so many US nuclear power plants situated along the coast or major waterways, these questions comes up when we think of climate change and the increasing frequency and severity of storms: How prepared are the reactors for storms and flooding, and how prepared are we who live in the in emergency planning zones (EPZs) of commercial reactors? There are around 170,000 people who live in Seabrook Station's 10-mile EPZ. Nationwide, around 3 million people live that close to a nuclear plant.

How the NRC and the Nuclear Industry Prepare for Disasters

According to a blog about hurricane preparedness, the US Nuclear Regulatory Commission (NRC) tracks storms and stays in close communication with partner agencies at the federal and state level, as well as with the plant operators.

The loss of electric power is a problem for nuclear reactors that depend on a system of pumps to maintain cooling operations. In extreme circumstances, plants may need to be powered down proactively for safety reasons. According to Paul Cataldo in the US Nuclear Regulatory Commission’s Region 1 Office, “Seabrook Station has the ability to maintain backup electrical power indefinitely, which includes power for vital equipment in support of cooling the reactor core and the spent fuel pool.”

“This is accomplished by implementing diverse and flexible mitigation strategies requiring onsite backup electrical equipment capable of providing power until additional equipment can be brought in from a national response center. This is a relatively new requirement that stemmed from the lessons learned following the Fukushima event,” Cataldo wrote in an email to C-10 while serving as the agency’s resident inspector at Seabrook.

Seabrook has two Emergency Diesel Generators (EDGs) that, according to Cataldo, have enough fuel oil in storage tanks to support each EDG's operation for 7 days. The NRC deems a week as sufficient to safely power down the reactor and bring in replenishment fuel from offsite. Seabrook has additional fixed and portable on-site diesel generators, and the ability to bring in equipment from national response centers, Cataldo explained.

The Institute of Nuclear Power Operations, an industry collaborative, maintains two national rapid response centers with portable equipment such as generators that can be dispatched in an emergency. The closest one to Seabrook is in Memphis, Tennessee. After the nuclear disaster at the Fukushima Daiichi plant in Japan in 2011, the Institute upgraded its emergency response center to better facilitate the sharing of equipment and expertise whenever and wherever it is needed, within 24 hours—per the trade group's website.

Lessons from Fukushima

According to critics like the Union of Concerned Scientists , neither the NRC nor the industry are doing all that they can to guard against the possibility of a natural disaster-induced nuclear accident. In 2019, after years of study and a report from the Fukushima Task Force , only some of the task force’s 12 recommendations became requirements.

"This rule was meant to be the capstone of the agency's response to the Fukushima Daiichi accident in Japan," NRC Commissioner Jeff Baran said in a dissenting statement after the NRC affirmed weaker than hoped for rules, dropping some of the hazard mitigation requirements. Baran said that the final version, issued in January 2019, would allow licensees to be prepared "only for the old, outdated hazards... calculated decades ago when the science of seismology and hydrology was far less advanced than it is today." More analysis on the recommendations here .

Prepare Yourself

Where does this leave us? How at-risk is Seabrook Station and the surrounding areas in the event of a big storm that knocks out power and internet, and floods evacuation routes?

U.S. Nuclear Power Plants Weren’t Built for Climate Change , according to an article in Bloomberg Businessweek. By 2060, New Hampshire’s coastline is expected to flood twice a month, per the Union of Concerned Scientists. For more about the Seabrook Station’s and surrounding communities’ vulnerability to climate change and rising seas, check out C-10’s previous blog, Seabrook Under Water .

Evacuating during a flooding event has long been on the minds of residents who live near Seabrook Station, particularly in low-lying coastal areas. At the 2019 NRC Seabrook Safety meeting , Steven Colman, Radiological Emergency Preparedness Branch Chief for Region 1 of the Federal Emergency Management Agency, told audience members that “alternate scenarios,” would be ordered if people could not safely leave the area due to flooded roads in the event of a nuclear emergency. Shelter-in-place is what he meant. Hmm. a good reminder to check out the emergency planning resources we’ve compiled on our website, here .

We’re Doing it, Too

As part of our work as nuclear safety watchdogs, C-10 operates a real-time radiological monitoring network within Seabrook Station’s 10-mile Emergency Planning Zone (EPZ). For nearly 30 years, we’ve provided this important service under contract with the Massachusetts Department of Public Health’s Bureau of Radiological Control. The network measures beta and gamma radiation as well as wind-speed and direction. Monitoring helps state officials understand ongoing exposure from permitted radiological releases. It could also help them protect the public in the unlikely event of an accident at Seabrook.

But there’s a problem: Our Citizens Radiological Monitoring Network depends on uninterrupted power and internet access. Without those services, C-10’s network could go down at a time when it’s most critical: when severe weather strikes.

The solution: C-10 is working with a company called Climate Resilient Internet to design a new communications platform for its radiological monitoring network, built to withstand severe weather and other threats, and powered by a solar and battery configuration.

Learn More at Upcoming Virtual Meetings

NRC’s Annual Seabrook Safety Meeting - Wednesday, June 9 at 5:30 pm

The US Nuclear Regulatory Commission staff will host a webinar to discuss NRC’s assessment of safety performance at Seabrook Station for 2020. Interested members of the public should register no later than one business day prior to the meeting. Meeting info and registration link are here .

C-10’s Annual Public Meeting - Thursday June 17, 2021 at 7 pm

Featured topic: Making C-10’s network climate resilient, with David Theodore, CTO of Climate Resilient Internet. C-10 has been monitoring airborne radiation in real-time for nearly 30 years. With the increase of severe weather and flooding impacting our region, we are making plans to upgrade our network so that it is virtually "failsafe," even when power and the internet are out.

Learn about this transformative project, get updates on safety concerns at Seabrook Station, and ask questions of our team. We are thrilled that independent nuclear safety expert David Lochbaum will join us to talk about "The Secret Sauce." Tune in to find out what that's all about!

All are welcome. Register here to let us know you'll be attending.

Watch this five-minute video to learn how and why C-10 is working to make our network climate resilient.

Senators Markey and Warren urged NRC to strengthen concrete monitoring at Seabrook Station

Wed, 12 May 2021 15:39:46 GMT

Letter was sent a day before a key NRC memo was released

US Senator Ed Markey (D-Mass.) has long been an outspoken nuclear safety advocate, as detailed in this recent press release . He and US Senator Elizabeth Warren (D-Mass.) have closely watched how the US Nuclear Regulatory Commission (NRC) oversees Seabrook Station's management of its degrading concrete , and have been supportive of C-10's effort for stronger oversight with the legal challenge to Seabrook's license amendment request.

While C-10 thought the case was settled when new operating license conditions were ordered by the NRC's Atomic Safety and Licensing Board in November 2020, we were surprised that on March 5, 2021 the Commissioners issued an order giving themselves more time to review the case.

What would this mean?

Would the Commissioners swoop in and roll back the conditions on how NextEra Energy Seabrook monitors the irreversible condition called alkali-silica reaction (ASR)?

Or was this an opening for something better?

On March 18, 2021, C-10 and two of our leading advisors— independent nuclear safety expert David Lochbaum and Director of Beyond Nuclear's Reactor Oversight Program, Paul Gunter—met with aides of both Senators to brief them on our concerns with how the nation's aging nuclear reactors are managed, in particular the need for testing and monitoring of concrete in containment structures.

The absence of clear regulatory guidance for how the nation's nuclear reactors should test and manage problems like ASR is of great concern to C-10 and other nuclear safety advocates. Without such regulations in place, Seabrook essentially set their own concrete aging management protocols for the NRC to approve.

While C-10's team saw the Board's 200-page ruling on Seabrook's concrete as a partial victory, our expert Dr. Victor Saouma believes that it fell short, and that more specificity is needed to ensure that the monitoring protocols protect the public as intended.

C-10 was pleased when Senator Markey's team signaled that they would push for stricter conditions and seek co-signers from the New Hampshire delegation. In the end, the letter signed only by Senators Markey and Warren was sent to the NRC on Monday, May 10, as detailed in this May 11 story in the Newburyport Daily News .

“The NRC should prioritize safety, scientific expertise, and regulatory specificity as it works to develop regulations to ensure that this unprecedented condition does not threaten the structural integrity of the facilities in which it occurs,” wrote the Senators in their letter to the NRC. “We request that the NRC reopen the record for consideration of supplemental testimony and strengthen the four license conditions in the ASLB’s Initial Decision.”

Dr. Saouma's recommendations, as highlighted in the Senators' letter, are to:

1. Quantify the reliability of concrete expansion monitoring by requiring the use of error bars to provide graphical representations of the uncertainties in the calibration curve used by NextEra Energy. The NRC staff should independently review the error bars.

2. Install acoustic sensors to detect possible reinforcement failure , using ultrasonic waves to detect and measure when a material deforms under stress.

3. Eliminate ambiguous terms. For example, the phrase “significant expansion” is too vague and could allow NextEra to defer addressing ASR development until cracks expand to irreversibly dangerous proportions. License condition (e) should eliminate the word
“significantly” and instead require NextEra to perform an engineering evaluation when a specific expansion threshold is crossed.

4. Specify that the “petrographic analysis” required in license condition (f) should be capable of detecting micro-cracks as small as 10 µm. Petrography is a generic term, and different methods of petrography have differing degrees of identification. By specifying the
micro-crack size that NextEra must analyze, the NRC can ensure that unacceptable developments of micro-cracking do not go undetected.

Too late?
C-10 was momentarily cheered that maybe the NRC Commissioners would give careful consideration to the letter—Senator Markey is Chair of the Clean Air, Climate, and Nuclear Safety Subcommittee of the Senate Environment and Public Works Committee, and oversight of the NRC is a key role of that body.

Yet hours after we read the morning's newspaper, the NRC issued a memo that the Commission had declined to review any of the decisions. We can only assume that memo was in the works before the Senators' letter was received, and was not precipitated by it.

Well, a point for not having the Seabrook ASR order weakened , but a disappointment that the Commissioners declined to clarify and strengthen the license conditions for how Seabrook should manage its degrading concrete.

"Any time the Licensing Board makes a decision, the Commissioners give themselves the option of reviewing it—even if nobody appeals the Licensing Board decision." explained C-10's attorney, Diane Curran of the March 5 order. "Neither C-10 nor NextEra appealed the ASLB decision. The Commissioners had a certain amount of time to decide whether to review the decision, then when it ran out they gave themselves a little more time. But when it ran out the second time, they let it go—they decided not to review whether the ASLB made a good decision. The ASLB decision is now the law of the case," said Curran, who viewed the memo as good news.

C-10 continues to keep watch on the NRC's oversight of Seabrook's concrete troubles. We believe that new federal regulations governing the management of ASR must be enacted—particularly as nuclear plants are requesting and being granted subsequent license extensions to operate for decades longer than originally intended.

For more background, see previous blogs, or read about C-10's legal challenge, here .

Expanding the Citizens Radiological Monitoring Network

Mon, 03 May 2021 20:06:10 GMT

New station at a Hampton home makes five in the Granite State

It was a beautiful April morning, and our Network Administrator Mike Mansir loaded up the trailer, slapped the C-10 magnets on his jeep and packed enough coffee to keep him running.

He headed to a private home in Hampton, New Hampshire—near the junction of Routes 101 and 95. It's about 4.5 miles north of Seabrook Station, and a great addition to the nation's only independent radiological monitoring network surrounding a commercial nuclear power plant. ( Did we say that already? )

Mike spent the better part of the day installing the new station as part of the Citizens Radiological Monitoring network. He installed a radiological probe to measure beta and gamma radiation, a wind anemometer and a small, rugged EBOX computer. By the end of the day, Mike had the station communicating with our central station in Amesbury, Massachusetts, and sending readings in near real-time.

The work was made possible by a grant from the New Hampshire Charitable Foundation and the leadership of Portsmouth State Rep. Peter Somssich, as well as the generosity of the homeowners, who are C-10 members and relative newcomers to the Seacoast. We make a practice of not disclosing the location of our stations at private residences.

I was able to stop by and watch Mike at work, as was Rep. Somssich, whose persistence and generosity have helped support investments in the network over recent years. It was another exciting day for C-10, and thanks to Mike's hard work and careful planning, all went well.

While the Massachusetts portion of the network has benefited from state support since almost as long as C-10 has existed, New Hampshire has yet to muster the political will to fund independent monitoring "outside the fence."

Now we have a total of seventeen stations within Seabrook's 10-mile emergency planning zone, plus a control site in Somerville, Mass. We're working to find one more location in Kensington, N.H., to help round out the coverage area.

The data we collect allows state agencies to track ongoing permitted radiological releases, and could help emergency responders and health officials to protect the public in the unlikely event of an accident at Seabrook Station.

You can learn more about the Citizens Radiological Monitoring Network on our website here, where you can also download an overview of our monitoring and reporting protocols, and see more pictures of equipment.

C-10 has been operating the monitoring network since 1991. We rely on the support of our members and charitable foundations as well as the ongoing contract with the Massachusetts Department of Public Health, to provide this important public service. To support radiological monitoring in New Hampshire, click here .

Seabrook concrete case featured in new book by C-10's expert

Fri, 16 Apr 2021 19:08:57 GMT

Saouma criticizes NRC and NextEra, outlines challenges for managing ASR at nuclear plants

C-10's concrete expert Dr. Victor Saouma and his colleague M. Amin Hariri-Ardebili have published a book: Aging, Shaking and Cracking of Infrastructures - From Mechanics to Concrete Dams and Nuclear Structures (Springer, 2021).

Saouma is Professor in the Department of Civil, Environmental and Architectural Engineering at University of Colorado in Boulder. He is a world-leading expert on the type of concrete degradation impacting the Seabrook Station nuclear power plant.

After learning about C-10's efforts in 2018, Saouma began serving as the pro bono expert in our legal challenge before the US Nuclear Regulatory Commission (NRC) regarding the plant's management of alkali-silica reaction, or " ASR "—an incurable concrete degradation infecting all safety structures at the coastal New Hampshire nuclear plant.

It was Saouma's expertise and compelling arguments that convinced the NRC's Atomic Safety and Licensing Board that Seabrook's concrete management protocols were inadequate to protect the public, as described in the Board's August 2020 ruling .

Interestingly, the NRC commissioners wrote on March 5, 2021 that they would give themselves more time to review the ruling, despite new license conditions already having been added to Seabrook's operating license as a result of the case. C-10 is closely watching the situation, and continues to monitor NRC inspection reports for Seabrook.

The Case Study: Seabrook Station Unit 1 ASR Problem

Chapter 36 of the book is a case study authored by Saouma that provides information on Seabrook Station Unit 1, the first reported nuclear power plant in the U.S. known to suffer from ASR. The information was yielded by private and government investigations into ASR since its discovery at Seabrook in 2009, as well as from the license amendment request (LAR) submitted by Seabrook owner NextEra Energy to the NRC in 2016.

The LAR, which was approved by the NRC's technical staff in 2019, sought approval of NextEra’s ASR assessment and its proposed ASR monitoring program, and was used to justify extended operation of Seabrook beyond its current 2030 operating deadline until 2050. The NRC granted Seabrook a 20-year license extension in March of 2019, even before the Licensing Board's public hearing on Seabrook's handling of ASR, which happened in September of that year.

In the book, Saouma called out NextEra's contracted engineers for their "lack of understanding of the complex challenges of ASR, or even an appreciation of the skill level that would be needed to address it adequately," (pg. 974).

The chapter on Seabrook's concrete case is 61 pages divided into two parts: the first describes the License Amendment Request. In the second, Saouma provides a critical review of the regulatory process. "Unfortunately, rather than issuing regulations for NextEra to utilize in assessing the safety of Seabrook, the Agency for all practical purposes delegated this task to NextEra," Saouma wrote (pg. 971).

How ASR is detected and managed has implications for reactor operation

As we detailed in a recent blog , the NRC is considering extreme license extensions for reactors, of up to 100 years. But by all accounts, the agency does not have an adequate plan (much less regulations) to handle aging conditions like ASR.

"At issue here is how to make a prediction of remaining service life," writes Saouma (pg. 988). "And of course, service life must be reasonably safe as required by federal law (the Atomic Energy Act). In pursuing this important (if not vital) task, NextEra was confronted with a common problem plaguing engineers who pursue similar objectives."

The case study is the final chapter in the book and is available for purchase on Amazon , or on Springer's website .

It was a humbling experience for us "citizen scientists" to work with Dr. Saouma and Attorney Curran, and we're proud of our team's success in bringing change to the regulatory process and raising awareness about ASR, even though we maintain that the ASLB's ruling did not go far enough.

Indeed, Dr. Saouma has expressed concern that the conditions won't achieve the desired result for protecting public health and safety without some specific and measurable guidelines to make the conditions unambiguously enforceable. Perhaps the NRC commissioners are giving new weight to our arguments? One can only hope.

Distressingly, Saouma concludes that: "given the simplicity of the structural safety analyses and underlying assumptions made by NextEra regarding the extent and severity of ASR at Seabrook, no adequate or credible demonstration has been made that Seabrook is safe," (pg. 1028).

"While the additional monitoring measured required by the ASLB are certainly positive measures, their ultimate effectiveness cannot be assured because they do not rest on a firm foundation of a rigorous, State-of-the-Art evaluation of the condition of ASR at Seabrook today," Saouma continues.

Saouma ends by arguing that "Seabrook is not demonstrably or assuredly safe. Of course, this does not imply that the reactor has to be shut-off, it simply means that the structure is at a societally unacceptable risk and the regulating agency owes a credible safety assessment to the public living within the 10-mile radius and beyond," (pg. 1029).

Praise for the role of C-10

“The power of an educated and concerned public in advocating for strong, science-based regulation cannot be underestimated. C-10—a small but determined NGO, relying heavily on volunteer efforts—has monitored the operation of the Seabrook nuclear plant since it began operating. After ASR was discovered at Seabrook in 2009, C-10 quickly perceived that ASR was not only a major safety challenge to Seabrook, but also a potential problem at other nuclear plants," said Saouma in his epilogue (pg. 1027).

- Victor E. Saouma, Ph.D., as excerpted from “Aging, Shaking and Cracking of Infrastructures - From Mechanics to Concrete Dams and Nuclear Structures. (Springer, 2021)

Dr. Saouma is a world-renowned expert on concrete structures and concrete chemical and mechanical properties. He is the past president of FraMCoS (Fracture Mechanics of Concrete). He has conducted alkali-aggregate related research for the Swiss federal dam safety agency, the Tokyo Electric Power Company (TEPCO), Oak Ridge National Laboratory (ORNL), and the Bureau of Reclamation, and the Nuclear Regulatory Commission. Saouma has pioneered dynamic concrete testing (real-time hybrid simulation), and is the managing partner of consulting company X-Elastica.

It was Saouma's unparalleled expertise and tireless efforts, together with our attorney Diane Curran 's efforts, that fueled the arguments that led to stricter licensing requirements for how Seabrook must monitor this incurable problem. Read more about the outcome of the case here .

Attorney Curran's remarks about the case:

"For two reasons, working with C-10 and Dr. Saouma on the Seabrook concrete case has been one of the highlights of my career. First, the issue of how to effectively monitor and address aging of major safety structures in nuclear reactors, such as containment concrete, is extremely significant and needy of more stringent regulation.

Second, the team assembled to work on the case was extraordinarily skilled and dedicated. C-10’s volunteers and staff had spent ten years watchdogging ASR at Seabrook, and already had set up a solid legal and evidentiary framework for a hearing when I joined the team.

And Dr. Saouma, as the world’s leading expert on ASR, added an extremely high level of expertise and professional dedication to our efforts. Remarkably, he did the work pro bono out of his dedication to the use of sound scientific principles in government safety regulation.

Thanks to the combined expertise and hard work of our team, we were able to convince a panel of three NRC judges to impose a strong set of license conditions for monitoring and addressing ASR during Seabrook’s license renewal term. We also exposed a troubling lack of government regulations or guidance for addressing the significant risks of operating reactors with aging concrete."

- Diane Curran, Attorney at Harmon, Curran, Spielberg and Eisenberg, LLP

Everything we do, we do it for you

Tue, 13 Apr 2021 18:20:50 GMT

Bryan Adams' #1 song is a fitting anthem as C-10 celebrates thirty years

In 1991 the Hubble telescope was launched. TV viewers tuned in to laugh at the antics of much-loved characters on Murphy Brown and Cheers. Bryan Adam's song Everything I do, I do it for you was #1 on the Billboard singles.

And the C-10 Research and Education Foundation (C-10) was incorporated to help protect people and the natural environment surrounding Seabrook station—a mission that is no less important today. Yes, we do it for you, friends!

Children born in 1991 are thirty now. Many are now well established in careers, and perhaps married and the parents of their own children. Throughout their entire lives, C-10 has been monitoring radiation in real time emitted from both the Seabrook Station and from other sources; we have been educating our community about how to live by and with a nuclear power plant, and working to create an environment where those children of the '90s could safely attend school, play sports, look forward to summer camps, plan weddings and stroll the beach with their own children.

During the past three decades, C-10 has been an impactful actor protecting the Seacoast region we all love. This year, our 30th anniversary, we are publishing a series of blogs to celebrate this milestone. Each will focus on one aspect of C-10’s multi-faceted work. This installment focuses on “the early days,” the development and extension of our pioneering radiological monitoring system. Later we will share other highlights of our history, including educational initiatives and advocacy for policies that proactively protect the public. We're also looking to the future.

Creation of the Citizens Radiological Monitoring Network

Some of us who have lived on the Seacoast for decades remember another, earlier organization with a name similar to ours. Before the C-10 Research and Education Foundation was incorporated, there was another group: Citizens Within the Ten Mile Radius. That grassroots collective took its name from the emergency planning zone surrounding the plant. It was during the 1970s and 80s that Seabrook was proposed and then constructed, and Citizens within the Ten Mile Radius focused on whether the communities surrounding the plant could be safely evacuated in the event of an emergency.

When Seabrook Station began generating atomic energy in 1990, it was clear that a new organization with a scientific approach to safety concerns was needed to keep watch and advocate for the safety of Seabrook’s neighbors. Citizens Within the Ten Mile Radius was officially dissolved, and C-10 Research and Education Foundation, a registered 501c3 non-profit with an emphasis on radiation monitoring, was incorporated in 1991.

The C-10 Research & Education Foundation would monitor airborne radiation in the communities surrounding Seabrook. It would take on the role of citizen-watchdog: reading current literature on the nuclear industry, tracking official correspondence and publicly available reports on Seabrook’s operation, building relationships with government officials at all levels, and participating in public meetings convened by the US Nuclear Regulatory Commission (NRC).

To say that the founders of C-10 were blazing a new trail is correct, but hardly captures the scope of what they set out to do. To this day, C-10 is the only independent, citizen-run radiation monitoring group in the entire country. While all communities with nuclear power plants deserve to have real-time independent environmental monitoring as C-10 provides, we in the Seacoast are the only population fortunate enough to have such an organization keeping a watchful eye on our nuclear neighbor, 24/7.

Sandra Gavutis was the founding executive director of C-10, serving in that capacity for 28 years and before joining our Board of Advisors. “Setting up the C-10 Foundation took a lot of time and effort,” said Gavutis.” An understatement to be sure. That effort involved the paperwork for incorporation, raising funds from private and public sources, siting and establishing the monitoring stations in Massachusetts and New Hampshire, and staying connected with local and state leaders whose support was crucial to our early success. Public education was also a big focus of Gavutis and her team.

Debbie Grinnell was our first director of radiation monitoring, later serving as research director. In the early days, Grinnell sought out experts about the health effects of radiation, gathered relevant studies, and spoke to other citizen watchdog groups who were working for the safety of their own communities. She continues to serve on our Board of Directors, her institutional knowledge, invaluable.

Clive Lee, a computer entrepreneur, contributed his expertise and funds for purchasing early equipment. Radiological readings compiled each day were stored on floppy disks in the early days! C-10 soon realized it needed engineers and scientists who could increase the efficacy of the data. C-10 also needed to find out what to do with that data, and connected with the Massachusetts Department of Health (DPH).

Winning support from the Commonwealth of Massachusetts

Devoted board members helped set up monitoring stations throughout northeastern Massachusetts and in New Hampshire. Jack Van Loan and Christopher Nord, both builders by trade, worked to install the network with the help of Plymouth State University meteorologist Dr. Sam Miller, who analyzed weather patterns to optimize site location. Bernadette Leonard administered the network for many years.

With support from elected officials including Senators Nicholas Costello and James Jajuga, and Representatives Harriet Stanley, Frank Cousins and Barbara Hildt, C-10 convinced Massachusetts lawmakers of the importance of independent monitoring, winning its first state funding in 1992. This crucial support for radiological monitoring was enshrined in state law thanks to their efforts.

The Massachusetts Department of Public Health (DPH) contracted with C-10 to operate the Citizens Radiological Monitoring Network (CRMN) and provide monthly reports as well as alerts of abnormal readings. Thankfully, concerning airborne radiation levels have rarely been detected. But in late November 1995, several monitors picked up beta levels as much as 17 times normal background levels, for a period of several hours. These readings were investigated by C-10, checked with Seabrook Station, and reported to the Mass. DPH. Neither the NRC nor Seabrook could explain the cause of the readings, even though the prevailing winds that night put the stations in the path of air currents coming from Seabrook’s direction.

C-10’s contract with Mass. DPH continues to this day, in partnership with the Massachusetts Emergency Management Agency (MEMA). Data on real-time radiation levels and wind speed not only allow state officials to track permitted releases—they could be used to help protect the public in the event of an emergency at Seabrook Station.

After the nuclear meltdown at Fukushima, an international delegation from a citizens science group called Safecast came to learn about how C-10 does what we do. Our radiological probe manufacturer International Medcom was even able to refurbish some of our old probes and send them to Japan.

Bringing our monitoring to the next level

In 2016, Michael Mansir took the role of network administrator, and has brought a new level of technical sophistication to C-10’s work. “He’s a genius,” has been exclaimed more than once by a C-10 Board Member after Mike has solved a complicated problem.

Mike has made significant improvements to our network by building a new and improved site to house our data, replacing aging laptops in the field with rugged and reliable Ebox microcomputers, and improving the way we inventory and schedule upgrades and maintenance to our monitoring equipment.

While the monitoring network has enjoyed continued state support in Massachusetts, the situation in New Hampshire has been tougher—no doubt in part due to the lobbying presence of the plant owner, also a major force in our regional economy. In New Hampshire, the monitoring effort has relied on private funding, thus having been inconsistent until recent years.

There have been several legislative attempts to get state funding for independent, real-time radiological monitoring “outside the fence” in New Hampshire. In 2020, the latest attempt ended as the clock ran out on the session due to COVID-19.

Since 2019, Portsmouth State Representative Peter Somssich has been leading the effort in New Hampshire with a two-pronged approach: attempting to advance a legislative solution for funding, while championing the Citizens’ Initiative to Expand Radiological Monitoring in New Hampshire . For several years, the peak number of stations in New Hampshire was three. A fourth was added at a private residence on Seabrook Beach in the fall of 2020, and two more will be added in 2021.

A resilient future for C-10

Today the monitoring network is as strong as ever. Under the leadership of Natalie Hildt Treat, executive director since 2017, C-10 has evolved as an organization, raising its public profile, successfully fundraising and winning new licensing conditions through our legal challenge on Seabrook’s concrete monitoring. It's been a tremendous team effort!

Aside from building on the policy win of tougher oversight for Seabrook’s degrading concrete, Treat is focused on a cutting-edge project that will turn our network into even more of a model. Within the next year, we plan to install a Climate Resilient Internet (CRi) system using non-wires communication devices along with solar and battery backup power at each monitoring station, as well as at our central office.

Without the internet and electricity, C-10 loses monitoring and communication capabilities at a time when it may be most critical: when severe weather impacts our region. We are working with pioneers in the critical communications field and seeking funding from a variety of sources to undertake this transformative project. We will tell you more about how we'll make the monitoring network climate resilient in an upcoming blog. It's super exciting! Meanwhile, you can watch this intro video about CRi's value proposition.

C-10 has been monitoring Seabrook for thirty years; the plant is currently licensed to operate for thirty years more. With continued support from the community we serve, C-10 will keep monitoring Seabrook for as long as the plant is operational, and beyond.

Thank you to all who have contributed to C-10's success over the years! Please contact us if you'd like to get involved, or re-engage with C-10. We'd love to hear your stories, your concerns, or your ideas for C-10.

C-10's Nord and Treat on "The Morning Show"

Thu, 11 Mar 2021 15:56:15 GMT

Discussion ranged from radiation and health to C-10's watchdog efforts

C-10 Research and Education Foundation’s Executive Director Natalie Hildt Treat and Board Member Christopher Nord visited the Newburyport-based talk show "The Morning Show" on March 11.

Host Mary Jacobsen asked Treat for updates on stricter new concrete monitoring requirements for Seabrook Station that came about as a result of C-10’s decade-long effort, and why the US needs better regulations governing aging atomic reactors.

Nord discussed the health effects of radiation exposure in light of the 10th anniversary of the nuclear disaster at Fukushima, which began on March 11, 2011. Treat also talked about improvements to the airborne radiological monitoring network, the only one of its kind in the country. C-10 is applying for grant funding to make make the network more resilient in the face of extreme weather.

How to Listen or Watch:

“The Morning Show” airs Thursday at 9 a.m. on Newburyport's Channel 9 and WJOP (FM 96.3) and live streams on YouTube. Watch the March 11 show with Treat and Nord here .

Each show also airs on WJOP on Friday at 8 a.m. and the following Tuesday at 4 p.m. and Wednesday at 3 p.m., and is available on the Sound Cloud (click on the cloud at NCMHub.org ).

Eyes on safety

Thu, 04 Mar 2021 18:34:51 GMT

A conversation with NRC's resident inspector at Seabrook Station

C-10’s ability to carry out our mission to help protect people and the natural environment depends on good relationships and trust. Throughout our three decades of operating the Citizens Radiological Monitoring Network and tracking safety and security matters at Seabrook Station, some of the most important relationships we’ve had have been with the two resident inspectors who work for the US Nuclear Regulatory Commission (NRC).

Each of the nation’s 94 commercial nuclear plants has at least two NRC resident inspectors on site whose job it is to monitor daily operations, conduct inspections and oversee major projects such as refueling and maintenance periods. Their terms are limited to seven years before they are moved to a new plant.

Christopher Newport is the senior resident inspector at NextEra Energy’s Seabrook Station , the role he began in the fall of 2020. The other inspector is Travis Daun, who came to Seabrook in the summer of 2019. Newport had previously served as Seabrook’s resident inspector for two and a half years before being promoted to senior resident inspector at the Diablo Canyon nuclear power plant in San Luis Obispo, California in 2016.

"We are out there every day along with the licensee constantly looking for these small things. If you're focused on the little things, the big things tend not to happen. " - Christopher Newport, US NRC senior resident inspector at Seabrook Station.

“Chris Newport was a student in one of the classes I taught while working at the NRC,” said David Lochbaum, a nationally-recognized nuclear safety expert who serves on C-10’s Advisory Board. “Two types of students stuck in my memory—those well above average and those way behind. Chris was solidly in the former group. I was glad to see he was the senior resident at Seabrook,” said Lochbaum.

Newport joined the NRC in 2008 as a project engineer in the Region I office near Philadelphia. Before his tenure at NRC, Newport served in the US Navy as a nuclear submarine officer in charge of the sub’s reactor. He holds a bachelor’s degree in control systems engineering from the United States Naval Academy and a master’s degree in engineering management from Catholic University.

As executive director of the nuclear safety group C-10, I recently had the chance to speak with Newport by phone to learn more about what his job entails and ask what he thinks about how Seabrook is operated. The following is a summary of our conversation, edited for clarity.

NT: Could you please describe a typical day in your work at Seabrook Station?

CN: We are generally on-site four to five days a week. The other inspector, Travis and I, try to stagger our days a bit during the COVID pandemic, taking advantage of remote telework technologies to carry out a portion of our work. One of our primary responsibilities is emergency response, we try to take reasonable precautions to ensure that we are both not exposed to COVID.

We are also required to do at least 50 hours of weekend and overnight hours per year, but most years we far exceed that. We also respond to the site, regardless of the day or hour, in the event of an unplanned shut-down or other safety event.

During a typical day, what we primarily do are the baseline inspections—general inspections that all sites receive throughout the year. I arrive on-site around 6 a.m., review the control room logs and the condition reports over the last 24 hours, and get a sense of anything that has happened overnight and the plan for the day.

As an aside, anytime an issue is discovered on-site, Seabrook staff create what they call a condition report. They are entered into a formal system for disposition and resolution. This process of “problem identification and resolution” is critical to the safe operation of these facilities.

We attend the 6:30 am Plan of the Day management meeting to find out about the work for the day and any issues to note. Every single day that we are on-site we go into the control room and walk down the control boards, look for any alarms, chat with the operators, and talk with them about what’s challenging them for the day. For the remainder of the day we do walk-downs of the plant, attend licensee meetings, observe maintenance activities, and conduct various paperwork reviews. There are items that need to be reviewed weekly, monthly and quarterly.

I’ll watch Seabrook personnel do maintenance, surveillance tests, equipment walk-downs, and if there’s an issue, I’ll go physically look at it. I’ll go into the security areas and any other areas of the plant that we think may be of interest.

As NRC inspectors we have what’s called “unfettered access.” By regulation, the licensee cannot prevent us from accessing any area of the site at any time. Unless our personal safety is at risk, we are able to access everything on site completely independently. Onsite, it’s about physically looking at things and talking to people, not just what the senior managers present in meetings or briefings. “Trust but verify” is a saying that you will often hear used in the nuclear industry.

With only two on-site inspectors though, we can’t look at everything that they do at every moment of every day, so we risk-inform the conduct of our work. We know what’s important, and what’s more important. The NRC relies on probabilistic risk assessment (PRA) to inform much of how we do business. These PRA models highlight what is most important at the plant and can tell us that we need to go look at that pump or valve every week versus another piece of equipment that we may only need to inspect on a monthly basis.

Another example, NRC guidance will say that we have to look at 25 maintenance work jobs a year, but they give us the flexibility to choose which ones and when. We are able to pick the ones we determine are more important based on our day to day site specific knowledge and the insights we glean from the PRA models. It’s a good system that ensures that we use our resources as efficiently and effectively as possible.

NT: How does Seabrook Station compare to other plants where you have worked? Tell me a little about how the NRC handles safety issues.

CN: The NRC has four columns of performance for operating commercial nuclear reactors. Seabrook is currently in Column 1, the highest Column. Column 1 is representative of extremely safe operation, with only low-level inspection violations and plant events identified. Plants operating in this column far exceed the minimum standards we have determined are required to assure public safety.

Column 4 on the other hand, indicates that degraded performance of the plant has been identified that if not corrected, could result in the NRC deeming the plant unsafe to operate. For example, Pilgrim Station (in Plymouth, Mass.) was in Column 4 because the plant had what we determined to be a higher number of performance issues and plant events that pushed them closer to that line that we have drawn in the sand for maintaining safe operation.

When a plant is in this column, they receive heavy scrutiny from the NRC and public stakeholders. To Pilgrim’s credit, they were able to make substantial changes to the plant equipment and the way that they conducted day to day operations that gave us the confidence to move them back to Column 1. (Pilgrim ceased reactor operations in May 2019 after returning to Column 1). It’s important to note that even in Column 4, the plant is operating above the threshold of what the NRC has determined to be safe.

Over the years, the industry has learned how to operate at a very high reliability rate, as what is good for safety often closely aligns with what is good for their business. It’s become increasingly uncommon for plants to move through the columns, but it still does occur.

NT: In May and June of 2020 there were a pair of unplanned shutdowns or “SCRAMs” at Seabrook. We heard that was a technical issue and the public was never in danger when control rods automatically inserted and halted the nuclear reaction.

CN: That’s correct, the reactor was shut down by operators as designed when the issue manifested itself. There was a circuit card connector issue in the rod control system, causing a malfunction in the system. Seabrook worked with the vendor to find out why this happened and to prevent it from happening again. Seabrook has also provided this knowledge to the industry as a whole to make sure that any plants potentially susceptible to the same issue are aware of it and can make changes.

That being said, unplanned shutdowns of the reactor are inputs into our assessment process as they can be representative of broader concerns with how the plant is being operated. When plants start to have multiple unplanned shutdowns, they feed into our assessment process and can start to trigger the movement towards Column 2 and beyond. In Seabrook’s case, it was an isolated incident. They have not had any other unplanned shutdowns to date and thus remain in Column 1.

NT: Can you comment on the working relationships with the NextEra Energy staff at the plant?

CN: NRC inspectors need to have a close working relationship with plant operators based on trust and a mutual desire for nuclear safety above all else. There always needs to be what I call “regulatory tension” between the regulator and the plant operator, but the relationship is ideally based in trust, openness, and respect. As far as how that works, it sometimes depends on the actual plant. Seabrook management listens when we raise concerns, even if they are low level and not representative of violations of our requirements.

High performing plants tend to have a very cordial relationship with the inspectors; they’ll listen and make the corrections even when they aren’t required to, as Seabrook tends to do. It’s when a lot of little things aren’t getting taken care of, when worker morale is not high, that’s when you can tell there may be problems coming.

We look at that aspect of an engaged workforce and what we call “safety culture” very closely. Seabrook has a strong safety culture right now (learn more about it here ). That being said, if an issue comes up that’s a violation of our standards, if Seabrook is resistant to taking the required actions to correct the issue, we will not cease from holding them accountable.

NT: Can you talk about a safety issue that you’ve raised with the licensee?

CN: A good example is ASR (alkali-silica reaction, the concrete degradation affecting all safety structures at Seabrook). It’s a large challenge to address and is a first-of-a-kind in the industry, even though it is a well-known phenomenon outside of the industry.

A number of years ago, when I was here as the resident inspector, Seabrook was initially reluctant to address the building deformation aspect of ASR, which is now a large part of the ASR monitoring program on-site. I actually had water drip on my hardhat while walking through the plant; further investigation of the water source revealed signs of bulk deformation of a safety related building on-site. Additional inspection revealed signs of something unexpected happening with many of the structures on-site that had not been previously recognized by the licensee.

It took some NRC prompting initially for them to start fully addressing the issue as we felt was appropriate. That regulatory tension that I talked about is important. Even the best performing organizations are susceptible to groupthink, loss of the big picture, etc. There are no shortages of examples of that phenomenon outside of the nuclear industry. A good regulator can help to identify those issues if and when they crop up to hopefully avoid them becoming bigger ones down the road.

NT: What is the process if you see a violation or have a concern? How does that get reported, and how can the public be sure that it would be properly elevated and followed up on?

We characterize inspection issues using what we call the Significant Determination Process. If we find an issue of concern, we work through our process to determine if it was reasonably within Seabrook’s ability to foresee and correct, and if it was, to determine its safety significance. If the issue is more than what we call “minor” we call it a finding or violation.

We will perform a PRA based risk assessment and characterize it by its safety significance using our color-based system (Green, White, Yellow, Red). Seabrook is required to correct any violation that we identify and anything that we determine to be greater than Green safety significance will end up receiving a great deal of scrutiny by both the licensee and us.

All Green findings or greater are documented in our inspection reports which are publicly available. (Also see Seabrook’s Quarterly Performance Summary ). I always strive to make the write-ups very clear so that a reasonably informed member of the public can understand the issue and why we came to the conclusions that we came to regarding its risk significance.

If there are greater than Green findings, those write-ups are very detailed. As the plants have learned to become more efficient at operations, these greater than Green findings have become unusual. There are maybe only a handful a year throughout the industry.

What the public doesn’t see are the things that are minor or just observations; we’ll generally have many of these each quarter. This week for example I observed five or six low-level issues that they fixed, these are things as simple as a ladder not stored in its proper location or a used rag that a watchstander accidently left behind while doing their rounds.

We are out there every day along with the licensee constantly looking for these small things. At the high-performing sites as Seabrook currently is, resident inspectors are really digging into the weeds. If you're focused on the little things, the big things tend not to happen.

NT: What are the things about Seabrook Station that give you the most confidence?

CN: They’ve put the money into the plant, including a lot of the physical equipment even when not absolutely required by regulation. They have good management teams and the right safety focus. Safety culture, employee engagement—those things are kind of intangible. There’s a positive culture at Seabrook which in my opinion is the most critical part of high performing operation.

NT: Back to Seabrook’s concrete. What assurance do we have that NextEra Energy is complying with what they’re supposed to be doing as far as enhanced concrete monitoring protocols that were ordered by the Atomic Safety and Licensing Board (ASLB) last fall, and are now part of the plant’s operating license ?

CN: It’s now part of their licensing basis, including the orders by the ASLB. They’re required by law to comply with that and we hold them accountable. We have integrated ASR into our safety inspections and are continuously monitoring the licensee’s actions with respect to it. When new conditions develop, we inspect the licensee’s actions to address them and make sure they stay in compliance with their license.

ASR can be highly technical. I have spent a good bit of time learning about the technical details of the phenomenon (including reading some of the information presented by C-10’s expert, Dr. Saouma to the ASLB) but as the senior resident inspector, I am a generalist. I sometimes don’t have the level of expertise to understand the detailed calculations and analysis techniques that are employed when analyzing these structural engineering issues.

Part of my job is making sure that I know enough to know when to ask for help. I frequently engage with our structural experts at our regional office in King of Prussia, Pennsylvania and at our Headquarters office in Rockville, Maryland when my limits are reached. Those experts engage directly with the engineers working on ASR at Seabrook to ensure that we have a full understanding of what the site is doing and whether it is in compliance with their license.

NT: During your years at Seabrook, you’ve worked a fair amount with C-10. Can you comment on that relationship?

CN: My message is that your group and groups like yours are critical in a high functioning society. As the federal regulator charged with ensuring commercial nuclear reactor safety, we oversee Seabrook. But the public, including C-10, in a sense oversees us. I am proud to work for the NRC and strongly believe that we are a dispassionate and effective regulator, but as I alluded to earlier, every organization is susceptible to mistakes and missteps.

As federal regulators, we ultimately work for the public and that is something that in my experience is taken very seriously within the NRC. We do everything that we can to be as transparent as possible so that the public and groups like yours can observe what we are doing and understand why we are doing it. That transparency is critical.

Stay up to date with the latest news from C-10! Join our mailing list and more - CLICK HERE.

Three decades of working for nuclear safety

Wed, 24 Feb 2021 20:40:00 GMT

C-10 will spend the year celebrating our successes and building for a strong future.

It's hard to believe that C-10 Research and Education Foundation has been at it since 1991! For several years prior, concerned citizens had been sounding alarms about building a nuclear plant on a salt marsh. But it was the year after Seabrook began generating atomic power in 1990 that C-10 was incorporated as a 501c3 organization, founded with a mission to monitor airborne radiation levels in our communities, and keep tabs on safety and security concerns at the nuclear plant sited on the New Hampshire Seacoast.

Throughout the year we'll be celebrating our past successes as we look to a strong future working for nuclear safety. Watch for a series of blogs detailing milestones in our history, and perhaps a webinar or two! We hope to host an-in person celebration for our supporters later in the fall, as the world begins to open up. Stay tuned.

If you have ideas or would like to be a part of our 30th Anniversary Committee, please reach out to board member Karen Clagett via email . If you'd like to make a special donation to honor the work and make sure it continues, click here . Thanks for standing with C-10!

Stay up to date with the latest news from C-10! Join our mailing list and more - CLICK HERE.

Regulators ponder 100-year licenses for nuclear reactors

Fri, 29 Jan 2021 16:38:58 GMT

As nuclear plants age, C-10 urges a focus on current safety concerns

Propping up an aging and dangerous technology?

Most of the commercial nuclear plants in the U.S. were originally licensed to generate power for 40 years. With the majority of the 95 reactors that are still in operation designed and built between 1970 and 1990, and few new plants in the works, the US Nuclear Regulatory Commission (NRC) is exploring the possibility of renewing operating licenses for extreme extensions.

The NRC held a day-long virtual meeting on January 21, on the topic of extending license renewals for up to 100 years for nuclear power plants. While billed an exploratory meeting, it appeared that the NRC was already laying the groundwork to grant these ultra-long license extensions.

There are no limits on how many subsequent 20-year license extensions a plant may request. A license extension doesn’t guarantee that a plant will remain in operation decades into the future, and reactor operators must continue to demonstrate on a daily basis that they can operate safely.

Yet two plants—Peach Bottom in Pennsylvania and Turkey Point in Florida—have already been granted licenses for 80 years. At least two others have applied for a second 20-year subsequent license renewal to operate for up to period for 80 years.

C-10 and other nuclear-safety advocates from around the nation participated in the public meeting, expressing serious concerns about the implications of such unprecedented extensions. For our part, C-10 urged the agency not to spend time on far-off scenarios, but to focus on better science and stronger regulation to ensure that the reactors in our communities are safe today.

With a bevy of nuclear industry, national lab and NRC presentations and nearly 150 participants including members of the public, the agency sought input on the following questions:

- Should the NRC begin to consider the potential technical issues and the development of guidance documents to support license renewal to authorize operation for up to 100 years, and if so, when?

- What are the technical issues that could be potential challenges for license renewal to 100 years?

- What approaches should be used to optimize the development of data to address potential technical challenge areas?

Concrete Concerns

Given C-10’s experience with the case resulting in stronger licensing requirements for how Seabrook Station manages its degraded concrete , our team took a particular interest in the afternoon session on concrete structures. We were pleased when the meeting organizers asked for our help to invite Dr. Victor Saouma , the internationally respected scientist who served as C-10’s expert witness in our challenge to Seabrook Station’s concrete-aging management plans . We can only hope that the agency will give serious heed to his remarks.

Although the tougher licensing requirements for how Seabrook manages the problem of alkali-silica reaction (ASR) was a partial win for public safety when ordered last fall, C-10 has serious concerns that neither plant owner NextEra Energy nor the NRC understands the full extent of the problem. There remain no federal guidelines on how to detect or manage ASR at the nation’s nuclear plants.

Indeed, Dr. Saouma has questioned the safety of Seabrook’s concrete for the current licensing period, much less for decades into the future. Because ASR can take years to manifest itself, there is no way of knowing where it is silently lurking. The degradation could already be impacting the concrete at other reactors.

Dr. Saouma pointed out in his presentation that by the time these reactors are 100 years old, the technology will be at least 110 years old. "Just think about it,” said Saouma. “Think about the technology of 1921 applied today in 2021. Isn't our knowledge of seismicity and materials much better than in 1921, today? Would you trust a contractor to fix your house with a 1921 code?"

"The point I want to hammer is that 100 years, it is a lot of years, well beyond what reactors were originally designed for,” Saouma continued. “What is at stake is enormous, and I would urge the NRC to put safety before economic considerations this time.”

Biopsies and autopsies

Saouma expressed concern that the NRC has lost some of the highly regarded scientists and engineers, and stressed that the agency should make its decisions based on rigorous, peer-reviewed science. He urged the agency to conduct “biopsies” of the concrete at operating reactors, and to do research and develop regulations for concrete-aging management.

Earlier in the day, Paul Gunter, Director of the Reactor Oversight Project with Beyond Nuclear, had called for autopsies of plants being decommissioned, and recited an alarming story about a 2017 guidance report issued by Pacific Northwest National Laboratory (PNNL) that mysteriously disappeared from government websites when he started asking questions—only to reappear a year later in a sanitized version.

“The laboratory was contracted by the NRC to develop the criteria and guidance document to address and close numerous ‘knowledge gaps’ in the license-renewal safety review process to provide the ‘reasonable assurance’ that the reactors could be operated reliably and safely into the license extension period,” Gunter explained.

Gunter, who sits on C-10’s board of advisors, was the only nuclear-safety advocate invited by the NRC to participate as a panelist. Gunter repeatedly cited the PNNL report and the importance of “harvesting” materials from closed nuclear reactors to help guide decisions on subsequent license renewals. He gave three presentations: the first on whether the NRC should consider 100-year licenses , the second on the aging of mechanical components and the third on electrical cables .

The day’s presentations made clear that complicated and interrelated chemical and physical aging are underway at the nation's atomic energy plants, and scientists are still studying how they interact.

A presentation on concrete aging beyond 80 years from Yann Le Pape of Oak Ridge National Laboratory described how the complex synergies of alkali-silica reaction, creep, fracture, corrosion and irradiation—all interacting—can lead to a loss of structural performance in key reactor safety structures.

“We are still working on predictive modeling,” said Le Pape, noting that concrete aging is very complex, and despite the work of researchers, there are still knowledge gaps. “Synergies are still largely unknown for an assessment of operation beyond 80 years,” said Le Pape.

C-10 weighs in

When the opportunity for public comment arose, C-10’s Executive Director, Natalie Hildt Treat, spoke unequivocally. “We urge the NRC to focus on the science for the current licensing basis. Should we consider 100 years? No. And we believe that’s the wrong question to begin with,” said Treat.

“Aside from concrete safety, there are numerous other concerns that have never been adequately addressed by the NRC, and that are purposely being excluded from this discussion: nuclear waste and the impacts of climate change, chief among them,” Treat stated.

While the day’s focus was limited to plant technical and structural issues, these complex problems and the public health impacts of nuclear power were repeatedly raised by concerned citizens during the comment periods.

It will be a minimum of 10 years before any operating US nuclear plants can formally request such an extension to remain licensed for 100 years, and it’s anyone’s guess what energy technology will look like a decade from now, much less 30, 40 or 50 years hence.

Ultimately, economic calculations will determine the fate of our nation’s atomic power plants. With new leadership at the NRC and across federal agencies, it will be interesting to see what changes are made in energy policy, and the degree of emphasis given to sound, scientifically based regulation of these aging reactors.

Further Reading:

Newburyport News: NRC to discuss 100-year licenses for nuclear plants

Toledo Blade: NRC begins discussion on extending nuclear plant licenses out to 100 years

Montgomery County Sentinel: 100 year licensing

The New London Day: Proposal could mean Millstone reactors could operate 20 years longer than expected

Stay up to date with the latest news from C-10! Join our mailing list and more - CLICK HERE.

New monitoring station installed at Seabook Beach

Mon, 19 Oct 2020 17:37:38 GMT

C-10 is collecting radiological data two miles southeast of the nuclear plant

Thanks to the efforts of the Citizens' Initiative to Expand Radiological Monitoring in New Hampshire, C-10 has installed the first new monitoring station in the Granite State in more than a decade. The private home is located about two miles southeast of Seabrook Station as the crow flies.

We will soon have our first full month of collecting beta and gamma radiation levels as well as wind speed and direction from this site. C-10's network has never had public funding to conduct monitoring in the New Hampshire communities within the ten-mile radius of Seabrook, while the Commonwealth of Massachusetts has supported the network since 1992, soon after C-10's incorporation.

State Representative Peter Somssich of Portsmouth has been leading the initiative over the past two years, and has helped raise about $42,000 in private contributions and foundation grants so far. Rep. Somssich and some of his colleagues in the New Hampshire legislature have also tried to garner state funding through the budget process, with the most recent attempt stalling out this summer due to COVID-19.

Monitoring provides data on permitted radiological releases from Seabrook Station, and could be used to help emergency and public health officials make decisions in the event of an emergency.

C-10 is working to secure a fifth location in New Hampshire north west of Seabrook Station, and hope to install that this fall or winter, if possible.
The Citizens' Initiative and C-10 are seeking sustained funding to maintain the New Hampshire portion of the network, and add another station in 2021.

To do this, we will need to raise over $40,000 next year as well. If you are interested in learning more about the network or supporting this effort, please visit this page , or contact us at info@c-10.org.

Read more in these two recent news articles:

Newburyport News: Radiation monitor installed at Seabrook Beach

Portsmouth Herald: New radiation monitor installed near Seabrook nuke plant

Remote Learning

Wed, 14 Oct 2020 14:50:47 GMT

A passion for scientific inquiry leads to an internship with C-10

Editor’s note: The pandemic is no time to find an intern—or so I thought. Imagine my delight when a 10th grader from Concord High School in New Hampshire reached out to C-10, wanting to volunteer with us. Emma Doko had visited our office last fall as part of a field trip led by science teacher Frank Harrison, who brought 48 kids who were studying nuclear power.

Board member Karen Clagett and I gave an introduction to C-10’s work keeping an eye on safety and security issues at Seabrook Station, and speaking out for stronger oversight of the nuclear plant’s degraded concrete.

Mike Mansir, our network administrator, gave a tour of C-10’s “Central Station” that receives data from all of our field stations measuring beta and gamma radiation as well as wind speed and direction. We explained that the chance of an accident is very small, and that many people—including those at C-10, were working to ensure the safe operation of the plant.

While we got some nice thank you notes some weeks later, it was hard to know what the students took away from their visit, which included a stop at Harborside Park in Seabrook, across the bay from the nuclear plant.

Then this September Emma reached out and offered to volunteer. She’s been doing some work on our database in between classes and her waitressing job. With all that young people have on their minds—from making it through school during the pandemic, witnessing elections and civil unrest unfold, and wondering what their future will be in a world facing climate change—it’s encouraging to meet one for whom C-10’s work for nuclear safety resonates. - Natalie Hildt Treat, Executive Director

Ever since I was in the first grade, I have always been inquisitive. I asked myself why plants were green, why the sun was so bright, and why day time felt so short. Although these questions I had as a first grader can be written off as young curiosity, My desire to understand these matters has never left me, especially the subject of science.

Something about the process of explaining cause and effect and developing your own hypothesis based on your own inquiries and prior knowledge greatly enchanted me and has led to me developing a strong passion to learn more about the world around me. My first grade self always wondered how people could go through their day to day lives without fully understanding the complexity of the world around them that they interact with everyday.

Eventually, I grew older and was granted the privilege of accessing the internet and all of its information, and even misinformation. Upon gaining access to the internet, I was exposed to several sources that were virtually at my disposal to educate myself. I had an insatiable desire to answer my questions at which the internet was a constant producer at my disposal.

One Saturday morning in the sixth grade, I decided to have my own independent study on nuclear physics and how these unique interactions of atoms have drastic physical effects and repercussions. While pursuing various articles on the subject, I stumbled across a vintage video titled “Walt Builds a Family Fallout Shelter” which was a vintage film made during the Cold War. At the time, I was fairly familiar with the Cold War and America’s circumstances, so the video's contents of war time, and more specifically, nuclear safety didn't surprise me much. The theme of the film was an older fellow by the name of Walt who shows his young neighbors how he transformed his ordinary basement into a nuclear fallout shelter in case such transformation would provide itself useful.

At the end of Walt's building scene, the director of the civil defense mobilization came on and broadcasted his message “no home in America is modern without a nuclear fallout shelter, this is the nuclear age.” Through the video, the undertone of fear and general unsure thoughts on the topic of nuclear safety drove me to further develop my own ideas on what nuclear safety really entails. As the civil defense mobilizer said, we are living in the modern age, the nuclear age.

In my freshman year at Concord High, I further learned through my science class that this modern age of nuclear energy entails the use of nuclear power plants to generate electricity. As part of this unit, my teacher organized a field trip to learn about the nuclear power plant closest to us: Seabrook Station, which is about 50 miles from my home, as the crow flies.

Considering this was a nuclear power plant we were learning about as opposed to wind turbines like some other students had studied, we weren't allowed to fully visit and experience the nuclear power plant. However, we were able to gain exposure to nuclear safety groups and researchers such as C-10, then located in Newburyport, Massachusetts.

As soon as I walked into the rather small office, memories of my independent studies on nuclear physics and nuclear safety made their way back to me and my interest in the subject was reignited. Even after finishing the project for my science class, the thought of C-10 continued throughout my freshman year, like a song in the back of my head.

This tune wasn't addressed until recently, as I’m a sophomore in high school looking towards majoring in a field of science during college. Thus, the lingering tune of C-10 developed into a blasting song that I couldn't ignore, leading to me making the spontaneous but logical decision to reach out to the group’s executive director, Natalie, in late September. I have only been volunteering for the organization for under a month but I have to say, the first grader inside me has never felt more satisfied.

Storms. COVID, how about a nuclear emergency?

Fri, 25 Sep 2020 17:51:17 GMT

It's Emergency Preparedness Month. Are you Ready?

Hurricanes, fires, COVID-19. How about a nuclear emergency ? For those of us that live near Seabrook Station, that's one more thing to think about. Nearly three million Americans live within 10 miles of an operating nuclear power plant, and about 160,000 people live in Seabrook's 10-mile emergency planning zone.

Obviously, the pandemic an/or severe weather would seriously complicate safe evacuation in the event of an accident at Seabrook Station—however unlikely that may be. It's National Preparedness Month—a great time to check out resources to help keep you safe. Make a plan, today!

Check our C-10's Emergency Preparedness page or Ready.gov for tips.

Siding with Safety

Fri, 25 Sep 2020 14:52:14 GMT

C-10’s analysis of the recent ruling on Seabrook’s concrete, and why it matters

As we reported in a recent blog, the Atomic Safety and Licensing Board of the US Nuclear Regulatory Commission has ordered the Seabrook Station nuclear plant to improve the way it manages the serious problem of degraded concrete called alkali silica reaction (ASR). A public version of the initial ruling was issued on September 10.

This case, and the stronger testing and monitoring ordered by the Board, would not have happened without C-10's years of effort and the help of our world-renowned expert Dr. Victor Saouma and our attorney Diane Curran. I want to stress that this ruling is a big deal for public safety across our region, and will impact how ASR is regulated at nuclear plants across the nation.

C-10 has created a summary document called " Siding with Safety ," that describes the Board's ruling and highlights passages from the 200 page document that demonstrate the severity of the issue, and the seriousness with which the Board’s judges considered this case.

In their ruling, the Board wrote repeatedly that Seabrook's protocols were insufficient to protect public health and safety, and determined that better and more frequent testing and monitoring must be implemented to ensure that NextEra Energy Seabrook, LLC will know whether the concrete meant to contain radiation is at serious risk of failure.

While the Board ultimately approved the plant's concrete management program, it did so with four new license conditions that direct NextEra Seabrook to conduct much more frequent and stringent monitoring and engineering evaluations in a number of situations. They are:

Monitoring concrete expansion – NextEra will have to increase the frequency of instrumentation monitoring by twenty-fold, moving from proposed intervals as long as ever ten years, up to monitoring every six months.
Monitoring reinforced steel – Under certain conditions, NextEra must develop a monitoring program to either anticipate or monitor rebar failures.
Knowing when to monitor more aggressively – If the degradation-related expansion rate in any area of a “seismic Category I” structure significantly exceeds 0.2mm/m per year, NextEra must evaluate whether to implement more frequent monitoring.
Looking deep inside the concrete – Each concrete core extracted from Seabrook must undergo a detailed microscopic petrographic evaluation to detect microcracks.

We hope you will take a look at our info sheet . Lots more info, including timeline and links are at c-10.org/challenge-to-seabrooks-concrete-monitoring .

While C-10 was generally pleased with the weight given our expert's testimony and the fact that the Board will require better testing and monitoring, Dr. Saouma is concerned that the conditions won't achieve the desired result for protecting public health and safety without some specific and measurable guidelines. We proposed these to the Board in the form of supplemental testimony. In mid-November, we learned that the Board denied our motions, and the conditions stand as ordered. We are proud that we gave it our best shot, even though the effort was denied because it didn't meet the legal threshold required to reopen the case.

The good news is that the conditions above became effective immediately when they were ordered by the Board, and are now part of Seabrook Station's operating license . Rest assured that C-10 will be keeping tabs on safety inspection reports and communicating with the NRC's resident inspector about alkali-silica reaction at Seabrook Station. We will continue to press for maximum oversight, transparency, and the best scientific methods available as technology evolves.

Four simple ways to make your home more energy-efficient

Fri, 28 Aug 2020 18:27:47 GMT

Schedule a virtual energy assessment, and support C-10!

Energy efficiency has become an essential part of the solution to help people control their energy costs and mitigate climate change. This is true whether at home or at work—one-in-the same these days, for many of us!

An increased awareness of techniques and technologies to help us reduce energy use are contributing to trends like passive homes and net-zero energy building goals. The following four offerings are part of the ratepayer-funded Mass Save® program, most at little to no-cost, and can make a substantial difference over the lifetime of a home.

1) Insulation & air sealing

Insulation is the number one way to save energy in a home, making the home more comfortable in both winter and summer. Many older homes in New England lack comprehensive insulation in the walls, attic, and basement. While there are many types of insulation that can be used, one of the most common and cost-effective methods is blown-in cellulose.

Cellulose insulation is an environmentally-friendly material made from recycled paper, is less expensive to install, and offers a higher R-value (rating scale for insulation performance) than other insulation types like fiberglass or rockwool.

Targeted spray foam seals corners and gaps to stop air drafts. Air sealing is commonly used in basements to stop air infiltration and in attics to minimize warm air from escaping.

Customers of National Grid, Eversource, or Columbia Gas—the electric and natural gas utilities who sponsor the program—may have a home energy assessment provided at no-cost every three years. ** Book your assessment before the end of September, Mass Save® is covering 100% off approved insulation .**

2) ENERGY STAR® Appliances

Appliances can be some of the biggest energy hogs in the home. Fortunately, new ENERGY STAR® appliances are substantially more efficient than older models, often with even more features and improved performance. Rebates through the Mass Save® program make it easy to make the switch. The Mass Save® Program gives $75 and free removal of a refrigerator being replaced with an ENERGY STAR® refrigerator (for a limited time, $125). Other rebates include air conditioners, humidifiers, washers and dryers, and air purifiers. Ask HomeWorks Energy how you can get your rebates, today!

3) Water-Saving Devices

Home Energy Assessments and no-cost equipment offered through the Mass Save® program include aerators for the bathroom and kitchen sinks, as well as water-saving showerheads, both standard and handheld types. Sink aerators reduce water use from around 2.5 gallons per minute, or GPM, to 1.5 GPM, while the showerheads use 1.7 GPM. These showerheads offer surprisingly high pressure for a water saving device! Because water heating can be a major source of energy consumption, less wasted water is not only good for the Earth, it can drive down your energy and water bills.

4) LED lights

One of easiest changes a homeowner can make is to switch to LED lights. LEDs offer much higher efficiency and a longer life-span especially in comparison to incandescent bulbs, while the traditional Edison bulb takes 60 watts, a comparable LED bulb comes in at only 9 watts, making them 85% more efficient. These bulbs are included at no-cost as part of a home energy assessment in the Mass Save® program, a new LED bulb will be provided to replace every incandescent in the house, whether it’s the candle light in the fridge, the 3-way bulbs in the living room, or the outdoor flood lights.

Schedule a home energy assessment and support C-10!

These options, and many more, are available through the Mass Save® state program. C-10 Research and Education Foundation is partnering with HomeWorks Energy, the largest certified partner of the Mass Save® program, to spread the word and help Massachusetts residents reduce their carbon footprint and save money. For every energy assessment performed through this partnership, HomeWorks will also make a donation to C-10. Schedule today at homeworksenergy.com/neighbors/c-10 or call 781-528-0822. Make sure to mention C-10 when you call, or enter C-10 in the reference code if signing up online!

A note on Covid-19:

Home Energy Assessments can now be conducted virtually so that people can take advantage of the program from the comfort of their home. Qualifying items such as LED bulbs, water saving devices, and programmable thermostats are mailed afterwards at no-cost. At a later date, an in-home walk-through may be performed to assist with installing these items and to confirm measurements and job scope if insulation measures were recommended. At HomeWorks Energy, we take safety and public health very seriously, assuring that we wear full Personal Protective Equipment, and follow all safety guidelines.

C-10's Efforts Lead to More Testing for Seabrook’s Concrete

Fri, 28 Aug 2020 00:00:00 GMT

While a win for public safety, the order still needs improvements

The US Nuclear Regulatory Commission's Atomic Safety & Licensing Board (ASLB) has ruled in the case relative to Seabrook Station's degraded concrete. The decision comes nearly a year after the week-long hearing at Newburyport City Hall.

After years of following the issue with great concern, in 2017 C-10 challenged the representativeness of tests done at a lab in Texas as a basis for the plant's concrete aging management plan intended to prove the plant is safe.

The Board issued its Initial Decision late on Friday, August 21, in proprietary form A public version of the ruling , which was nearly 200 pages, was issued on September 10.

C-10 has created a summary document called " Siding with Safety ," that describes the Board's ruling and highlights passages from the that demonstrate the severity of the issue and the seriousness with which the Board’s judges considered this case.

The ASLB’s ruling culminates a ten-year effort by C-10 to obtain effective government oversight of ASR, which has weakened important Seabrook safety structures like the reactor containment enclosure building and the spent fuel pool.

“NextEra Energy Seabrook has been sent back to the drawing board with this extremely detailed ruling,” said Natalie Hildt Treat, executive director of C-10. “While the Atomic Safety & Licensing Board ultimately accepted the company’s concrete testing program, it did so with several important conditions that will do more to ensure the health and safety of the public,” said Treat.

The order directs Seabrook Station to conduct much more frequent and detailed monitoring and engineering evaluations in a number of situations, in some cases increasing the frequency of testing from the proposed five to ten years, up to six-month intervals. It also orders NextEra to conduct a petrographic analysis on each core sample extracted from the plant’s concrete in order to detect internal microcracking and delamination. This technique was urged by C-10’s expert witness, Dr. Victor Saouma, who is one of the world’s leading authorities on the condition of alkali-silica reaction, or “ASR.”

Seabrook is the first U.S. reactor known to be suffering from ASR, though its presence has been a factor leading to the closure of at least two other reactors, globally. The licensing board is a three-judge panel under the U.S. Nuclear Regulatory Commission (NRC). C-10 has been following this problem for the last decade and has submitted previous filings urging the NRC to take the ASR phenomenon more seriously, and to develop federal regulations to govern its handling at nuclear reactors.

“I am extremely proud of what C-10 has accomplished with this case,” said Treat. “We have markedly moved the needle by ensuring that better science underpins Seabrook’s concrete aging management plan. C-10’s work and the body of knowledge we have brought to light will no doubt influence how future ASR policy is made in this country,” said Treat.

“Let’s hope that NextEra does the right thing for its neighbors and begins taking steps to strengthen Seabrook’s concrete aging management plan right away, rather than wasting time and resources to fight what was ordered in this carefully-deliberated ruling,” said Treat. “They won on the point that their License Amendment Request was upheld. C-10 and public safety won in that more frequent and more revealing testing and monitoring of the plant's concrete were ordered by the Board.”

Though C-10 is generally pleased with the careful deliberations of the ASLB, we believe that the order could and should be more clear in terms of the conditions placed on NextEra. More specific and measurable guidance on how the plant operator should monitor the progression of ASR will enhance public safety. As the conditions are written, we still have concerns.

To that end, on August 31, C-10 filed a motion to reopen the record and ask the judges for partial reconsideration of their ruling on Seabrook's concrete. This effort was made to provide supplemental testimony from our expert, Dr. Victor Saouma, in order to ensure that what he believes were the objectives of the judges in placing these conditions on the plant operator are in fact met.

Dr. Saouma took the four license conditions placed by the ASLB and proposed specific language for making them stronger.

These suggestions include:

- Improvements to how NextEra monitors the expansion behavior of the concrete cracks;

- A recommendation that properly tuned acoustic sensors be used at a six-month internal to monitor the integrity of reinforced steel in the concrete;

- The need for clearer criteria on what would trigger an engineering evaluation on the continued suitability of six-month monitoring intervals for areas experiencing the highest severity of cracking; and,

- Specifying the size of the microcracks that should be visible using petrographic methods, and offering further guidance on how the petrographic analysis should be conducted.

If the ASLB ultimately admits Dr. Saouma's testimony (not yet available in public form) and revises their final order to incorporate his suggestions, this will give C-10 a much higher level of confidence that Seabrook Station is following best practices to monitor and manage ASR, thus enhancing public safety.

With this final submission, Dr. Saouma and C-10 are seeking to strengthen and clarify the conditions that the ASLB placed on NextEra in order to enhance public safety. While it is not surprising that the licensee objects to the guidance of an independent expert on how it should conduct its concrete aging management program, it is disappointing, though par for the course, that NRC's staff sided so strongly against the advice of a pro bono scientist whose only goal is to protect the people who live near this degraded atomic power plant. We will post updates and public documents as they are made available.

BACKGROUND INFORMATION

About ASR and C-10’s contentions: In October 2017, the U.S. Nuclear Regulatory Commission’s Atomic Safety and Licensing Board admitted five of C-10’s contentions in a proceeding on NextEra’s License Amendment Request relative to the plant’s concrete troubles, a condition known as alkali-silica reaction (ASR). The Board admitted C-10 as a legal intervenor in the case and reformulated five accepted contentions into a single contention:

The large-scale test program, undertaken for NextEra at the FSEL, has yielded data that are not “representative” of the progression of ASR at Seabrook. As a result, the proposed monitoring, acceptance criteria, and inspection intervals are not adequate.

First detected at Seabrook in 2009, the presence of alkali-silica reaction (ASR) caused NextEra Energy Seabrook to submit a license amendment request in which the company sought NRC approval of a concrete aging management plan. The same plan was included in Seabrook’s license renewal application. The NRC initially determined that the plan was sufficient, and in March 2019, granted the LAR and a 20-year license extension to operate the reactor until 2050. These actions were taken in spite of a planned ASLB hearing on Seabrook’s concrete problems that took place the week of September 23, 2019 in Newburyport, Mass. NRC staff have subsequently said that the licensing board’s ruling could compel the agency to revisit the issue.

At that hearing, C-10 attorney Diane Curran told the licensing board that “The biggest concern posed by ASR at Seabrook is this: if severe enough, ASR may weaken concrete safety structures to the point that they crack during an earthquake and release radiation into the environment.”

“The discovery of ASR at Seabrook has presented NextEra and the NRC Staff with three unique and difficult problems,” wrote C-10 in its Proposed Findings of Facts and Conclusions of Law, filed with the NRC in November, 2019:

First, ASR is an exceptionally perverse phenomenon, rotting concrete from within. The webs of ASR-caused microcracks and delaminations inside a concrete structure can weaken a large building to the point it is unable to withstand even a moderate earthquake.
Second, the insidious effects of ASR are invisible to the naked eye and difficult to diagnose. Webs of ASR-caused microcracks and larger delaminations lie beneath the surface, and may not be indicated by surface cracking. And these nefarious effects are not uniform within a concrete structure; instead, ASR is heterogeneous and dependent on such localized conditions as aggregate and sand geochemistry, temperature, and humidity.
Third, while ASR has for decades been known to exist in numerous structures such as dams and bridges, and while ASR is the subject of a significant body of international research, it is not regulated by the NRC.

The crux of C-10’s contention is that NextEra relied on concrete testing done at a lab at the University of Texas, Austin that was a poor stand-in for the actual concrete that has faced decades of exposure on the New Hampshire salt marsh. In particular, the different mineral components of the test samples are not representative of the particular chemical make-up of Seabrook’s concrete, and thus will not behave in the same manner.

C-10’s Expert and Counsel: Victor Saouma , Professor of civil and structural engineering at the University of Colorado, Boulder, is C-10's expert witness in the case regarding Seabrook's concrete. Saouma's work centers on what he sees as flawed test results that affected the safety analysis underpinning NextEra Energy Seabrook's concrete aging management plans. One of the world’s leading experts on alkali-silica reaction (ASR), Saouma has studied its effects on nuclear reactors—in particular, how the containment structures could be weakened should an anticipated earthquake occur. Saouma has worked for decades on concrete structure and material properties, and has many peer-reviewed technical articles on topics regarding concrete degradation. Saouma has researched ASR at nuclear power plants under contract with the U.S. Nuclear Regulatory Commission. Read his consolidated findings in the Seabrook case, here . C-10 is represented by Diane Curran , a nationally-known environmental and nuclear safety attorney.

More on C-10’s legal challenge relative to Seabrook’s concrete is here , including an updated timeline .

Capture family memories and support C-10's work for nuclear safety

Tue, 04 Aug 2020 17:42:43 GMT

Hydren Portraiture offers a special discount when you contribute to C-10

Families have been spending LOTS of time together during the pandemic. For those of us fortunate to have our health and live in a beautiful part of the world, we count our blessings.

My husband Tom and I decided to take advantage of an offer from Hydren Portraiture to have our photos taken at Plum Island. It was a fun experience, and Richard Hydren really captured our happiness and the lovely evening at one of our favorite places. We ended up choosing a trio of wall portraits to remember this moment in time with our daughter Julia, age 5.

Living in Rowley, Massachusetts and supporting C-10's work to ensure the safety of Seabrook Station, Richard and his wife Sharon have extended a special offer to people who make a $100 contribution to C-10 : a $500 credit towards a portrait session and the purchase of artwork.

The season is fleeting, and if there's one thing that the pandemic has taught us, it's that life is precious. I hope you'll take advantage of this promotion to have your family's portrait taken at the beach. In doing so, you'll support C-10's work to protect the special place we call home, and help ensure its livability for future generations.

C-10 is grateful for this relationship with Hydren Portraiture, the newest member of our Business Allies program ! See the terrific head shots they took of the C-10 staff, here.

Click here to learn more about this special offer from Hydren portraiture.

What magnitude of victory?

Mon, 03 Aug 2020 21:28:03 GMT

C-10 has changed the game, regardless of outcome in Seabrook's concrete case

C-10 held its annual public meeting in a virtual format on July 15, 2020 ( watch it here ). Attorney Diane Curran provided an update on the organization’s legal intervention in the renewal by the Nuclear Regulatory Commission (NRC) of the reactor operating license for Seabrook Station. The matter is before the NRC’s Atomic Safety and Licensing Board (ASLB), a three-judge panel, with a ruling now anticipated by August 21 . C-10’s primary contention was that plant owner NextEra Energy was not adequately protecting against aging degradation of concrete structures at Seabrook, specifically caused by an alkali-silica reaction (ASR) to groundwater causing concrete to swell, crack, and weaken.

Diane, along with C-10 Executive Director Natalie Hildt Treat, C-10 Board President Pat Skibbee, and the leader of C-10 Working Group on Seabrook’s Concrete, Chris Nord, referred to the ASLB’s pending ruling in the case as reflecting either a win or loss. Actually, the ASLB’s ruling will not determine whether C-10’s efforts were successful or futile. Instead, it will measure the magnitude of C-10’s victory.

NextEra’s own actions and words demonstrate the victory achieved by C-10’s efforts. On May 25, 2010, NextEra submitted a license renewal application to the NRC seeking a 20-year extension to Seabrook’s operating license. The application totaled 2,601 pages with plenty of words. On those pages and in those many words, ASR was not mentioned once . ASR was not identified as a concrete degradation mechanism; nor did the application identify measures to be employed by NextEra in monitoring for ASR and in mitigating its effects.

NextEra submitted to the NRC an update to its aging management programs covered within its license renewal application on May 18, 2018. This 278-page report mentions ASR lots of times .

More importantly, it mentions periodic inspections that will look for signs of ASR degradation. Even more importantly, it defines criteria for when ASR degradation transforms from being annoying to being intolerable. Between May 2010 and May 2018, NextEra submitted numerous other reports to the NRC regarding the development and refinement of its ASR aging management program.

C-10’s case before the ASLB contends that the ASR aging management programs still lack elements needed to make them sufficiently comprehensive and reliable. But even if the ASLB rules against C-10 by requiring no further changes to the ASR aging management program, that would hardly be a loss for C-10.

For while that program arguably could be made better, it was undeniably completely inadequate by being completely absent from the May 2010 license renewal application. So, the ASLB’s ruling will only measure the extent of C-10’s success. It’s not a debate over the glass being half-full or half-empty: the glass is no longer bone dry.

I readily accepted an invitation last year to join C-10’s Advisory Board after having worked with the organization on nuclear safety and security issues for nearly two decades. Many interactions over those years taught me that C-10 gets results — perhaps not exactly the entire results they sought, but tangible results clearly worth my investments of time in their support.

One cannot count the number of mishaps and meltdowns averted through C-10’s efforts. But one can count on C-10 to engage when they perceive an undue nuclear safety threat to their community.

Dave Lochbaum is an independent nuclear safety consultant, recently retired from the Union of Concerned Scientists. Lochbaum worked as a nuclear engineer in nuclear power plants for 17 years. Read his bio here .

NRC's annual Seabrook update covered COVID & concrete

Mon, 22 Jun 2020 19:51:55 GMT

Webinar format allowed public to listen and ask questions

It's usually held in a hotel banquet hall in Hampton, New Hampshire. But, like so many events impacted by the COVID-19 pandemic, federal regulators turned to a virtual format to convey their annual safety findings for the Seabrook Station nuclear reactor.

On June 3, the US Nuclear Regulatory Commission hosted a webinar to discuss the agency’s assessment of safety performance at Seabrook Station for 2019. Per the NRC, about 75 members of the public dialed in to listen and ask questions. View NRC’s slide deck, here , and read coverage of the meeting by the Newburyport Daily News .

After summarizing that there were only a handful of “green” safety citations in 2019 (meaning the lowest level of concern), NRC staff wisely focused on the key issues on everyone’s minds, namely: how NextEra Energy Seabrook and the NRC have been impacted by COVID-19, and what’s the latest with Seabrook’s degraded concrete.

These issues have been particularly salient in light of the spring refueling and maintenance outage that took place in April, when approximately 1,400 contract workers were onsite. Seabrook was the first nuclear plant in the nation to undergo refueling during the pandemic, and while there have been a few reports of illness at the plant, NextEra Energy has been very tight-lipped about protocols and sick workers, other than to say that they are following best-practices. More on that in an earlier blog: Monitoring nuclear safety in pandemic times .

Senior NRC Resident Inspector Paul Cataldo (pictured above) explained how he and his colleague Travis Daun conducted remote oversight of the reactor, since their onsite presence was significantly reduced in recent months due to social distancing and work-at-home guidance.

Cataldo said that even though the inspectors were visiting the plant only about every three days during the height of the initial COVID-19 outbreak, he and Daun had regular meetings, access to plant logs and cameras, etc. Still, there’s no substitution for in-person inspection. It was reassuring to hear that as of mid-June, the inspectors are onsite about four days a week, consistent with state guidance on re-opening.

Here are the questions that I posed to Cataldo and his colleagues during the Q&A session:

1)”You mentioned that NextEra Energy sought regulatory relief due to the pandemic, including the ability to relax staffing requirements as well as defer important safety inspections that were supposed to happen during the April refueling outage.

What can you tell us about whether or how Seabrook has invoked regulatory leniency regarding staffing by NextEra and/or any of the more than 1,000 contract workers who were on site for the refueling and maintenance period?”

Cataldo said that NextEra sought the regulatory waiver preemptively, but they haven’t needed to invoke it. While 12-hour shifts are standard during refueling, NextEra has not needed to have workers on the job even longer due to any staff shortages resulting from the pandemic.

2) “You mentioned that resident inspectors have been conducting a fair amount of their work remotely. C-10, as you know, is very concerned about the problem of degraded concrete at the nuclear plant.

How has COVID-19 changed the frequency and/or the manner in which the progress of alkali-silica reaction is measured and monitored? For example, is there a reduced in-person presence by the NRC inspectors when this work is being performed?”

Cataldo said that there has been no impact in how inspections have been proceeding, noting that he continues to conduct visual inspections of the plant himself, in addition to the scheduled monitoring undertaken by NextEra and its contractors.

That doesn’t address the concern that monitoring of alkali-silica reaction at Seabrook, is, in the words of C-10's independent expert Dr. Victor Saouma , “inadequate” and “sophomoric.” But I digress.

These NRC public meetings always feel a bit routine, but it’s still important that members of the public hear the presentations and take time to ask thoughtful questions. It was great to hear many C-10 supporters on the call. NRC has said that they will post a summary of the meeting and C-10 will be sure to share that when it becomes available.

Meanwhile, we’re waiting with bated breath for the ruling by NRC’s Atomic Licensing Board on whether Seabrook’s concrete-aging management program is up to snuff. After two extensions, the Board has said they will rule on the case by July 10 . Read about the case brought by C-10 .

Want to learn more? We've scheduled our Annual Public Meeting for Wednesday July 15, a few days after the ruling should be issued. Our attorney Diane Curran will be on hand to help us decipher the ruling. Sign up to participate in the webinar.

Faulty equipment causes pair of scrams at Seabrook

Thu, 18 Jun 2020 19:33:41 GMT

How do nuclear control rods "unexpectedly insert?"

It happened not once, but twice in two weeks. The nuclear fission reaction at Seabrook Station came to a screeching halt when a group of control rods "unexpectedly inserted," causing the reactor to trip.

The event is called a scram. That's industry-speak for when a nuclear reaction is suddenly shut down. In these two instances, which happened on May 29 and June 6 , the shutdown was due to a mechanical failure, and the public was not at risk. But numerous days of unplanned outages takes a financial toll on plant owner NextEra Energy, and they are no doubt working to get to the bottom of it.

US Nuclear Regulatory Commission (NRC) Senior Resident Inspector Paul Cataldo told C-10 he can't speculate on the cause of the control rod insertions. He assured us that he and his colleague Travis Daun are inspecting NextEra's evaluations, and that more details will be available in the next NRC quarterly inspection report, due out by Mid-August.

But just the fact that serious things are malfunctioning at a nuclear plant -- even if the only harm was to NextEra Energy's bottom line -- is disconcerting in itself. Folks in the know have assured us that these scrams are unrelated to the recent refueling that Seabrook underwent in April, or the fact that certain maintenance and inspections were deferred due to COVID-19.

"Seabrook had zero unplanned reactor shutdowns the past eight quarters," noted Dave Lochbaum , an independent nuclear expert and member of C-10's Advisory Board. Lochbaum said that something like this happens at a US nuclear reactor about every one to two years. But when it happens, it's typically one rod, and not the entire eight-rod assembly. Hmmm.

"Too many economic hits can undermine safety," said Lochbaum. "Fortunately, the NRC has a safety yardstick designed to intervene before erosion goes too far. It's a quarterly performance indicator tracking the number of unplanned reactor shutdowns." (Take a look at Seabrook's current performance indicator .)

According to C-10 Board Member Chris Nord, shutdowns can be a risky time, when accidents or unplanned radiological releases may be more likely to occur.

One thing I wondered: If the the control rod assemblies can malfunction, is there anything that can go wrong with the fuel rods themselves?

Cataldo answered it this way: "The fuel rods are contained within the fuel assemblies, which are all currently restrained in place within the reactor vessel in their original configuration, since the refueling outage this past April. More importantly, the fuel rods do not have any movable features and remain fixed for the 18-month operating cycle, and would not suffer from any likely events that have occurred with the control rods."

If you really want to geek out and learn about what happened in these scram events, take a look at Lochbaum's pictorial explanation . Or you can read news coverage here .

We know, it makes us grouchy too when things go wrong with our nuclear neighbor. But there are a lot of people working to ensure that the plant operates as safely as possible. Including your friends at C-10.

We couldn't do it without you. Please become a member if you want to support C-10's work, and thanks!

Living in a net-zero energy home

Thu, 07 May 2020 16:37:00 GMT

C-10's executive director shares her story, and her passion for energy efficiency

I like to say that energy efficiency is my first love. It's where I spent most of my career before joining C-10. When my husband Tom and I decided to settle near my hometown of Amesbury, Massachusetts, we looked at "historic" homes that needed a lot of work and were drafty, and newer home that heated with oil, and had less than optimal levels of insulation.

Ultimately, we found BrightBuilt Home , and decided to build a modular, all-electric net-zero energy home in Salisbury, Massachusetts. What does all that mean? Well, modular means it was built in a factory and delivered in pieces, with insulation, electric, and plumbing "roughed in."

The house has an 8.83 kW solar array, designed to generate more power than we use over the course of a year. The only source of energy, besides a small wood stove that we use occasionally, is electricity. The heating and cooling, water heater, cook stove and dryer are all electric, and yes, the house is tied to the grid. We even plug in our Chevy volt car! But no, we don't yet have battery backup.

Aside from the photovoltaics and ENERGY STAR appliances, the big features that makes the house so comfortable and efficient is the level of insulation, and the fact that it is designed to be passively warmed by the sun.

Like most of you, my family has been spending a lot of time at home as we weather the COVID-19 pandemic. I'm fortunate that my home office is bright, comfortable, and energy-efficient. We've been in the house for more than five years now, and we still get asked to share our story.
Click here for a recent article with more details about our home construction project.

What's the link between energy efficiency, solar power, and C-10's work? While our organization is focused on the safe operation of the Seabrook Station nuclear power plant, which is located about five mile from my home, C-10’s vision is that our region transitions to a clean, safe and resilient energy economy.

Nuclear power remains an important part of the region's energy mix, especially with the closure of most coal burning power plants across New England and a heavy reliance on natural gas for electricity and heating. Yet few nuclear plants are being constructed today. Even Seabrook owner NextEra Energy Resources boasts that they are the world’s largest generator of renewable energy from the wind and the sun, and that's where the company continues to grow.

While I love renewable energy, the cheapest, cleanest energy is the kind we don't use. To learn more on how to make your home or business more energy-efficient or to take advantage of utility company rebates, you can visit MassSave.com or NHSaves.com .

--
More Links:

Our home was featured as Boston Magazine's 2014 Design Home. Take a virtual tour of the house as it was staged by professional designers, before the Craigslist furniture and my kid's toys took over.

Read a case study about the house to see more pictures and energy facts.

Learn about the BrightBuilt Home process , and see a video of a modular home installation.

On Friday, May 8, Natalie participated in a Virtual Eco-Festival hosted by the City of Amesbury. Details are here .
Watch the recording on on Facebook. Her talk is at about the 2-hour mark.

NRC Extends Comment Period for Nuclear Waste Dump

Tue, 05 May 2020 14:28:40 GMT

Controversial Holtec site a threat to communities of color and the environment

Due to COVID-19 pandemic concerns, the Nuclear Regulatory Commission (NRC) has extended the 60-day public comment period on the Draft Environmental Impact Statement (DEIS) for a controversial nuclear waste dump in New Mexico. Initially scheduled to close May 22, 2020, the comment period for the Lea County Consolidated Interim Storage Facility (CISF) , proposed by Holtec International, has been extended by an additional 60 days.

Why is this important? Moving high-level radioactive nuclear reactor waste (spent fuel) from nuclear power plants all across the country to consolidated waste-storage facilities simply takes the radiation danger from reactor communities and dumps it on waste communities. In the process, waste communities – which often are economically-depressed and communities of color – are forced to weigh short-term economic gain against long-term health and safety. In addition, transporting irradiated spent fuel across the country to such facilities introduces significant risk to hundreds of other communities and in some instances requires waste to be trucked through sacred Indian lands. Extending the comment period allows more residents of affected communities to voice their opposition to the Holtec CIFS.

Nuclear watchdog organizations insist that the safest solution for the spent fuel now stored in pools and casks at nuclear power plants (and produced as plants continue to operate) is hardened on-site storage (HOOS). The Holtec CIFSs – dubbed HI-STORE – would be an expensive and risky step backward in managing existing and future nuclear waste in the United States.

The NRC comment period extension came after the entire New Mexico congressional delegation asked the NRC to both delay the public meetings on the Holtec facility and extend the DEIS comment period until after public meetings eventually take place. “Any proposal to store commercial spent nuclear fuel raises a number of health, safety, and environmental issues, including potential impacts on local agriculture and industry, issues related to the transportation of nuclear waste, and disproportionate impacts on Native American communities,” the legislators stated in their request.

The NRC intends to present staff findings on the Holtec CIFS and receive public comment through a webinar and five public meetings in New Mexico. Although the NRC has not agreed to delay the five public meetings, the NRC did state that it will reevaluate the current plans for engaging the public and further extend the comment period if deemed necessary.

Download the Draft Environmental Impact Statement:

Environmental Impact Statement for the Holtec International’s License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste: Draft Report for Comment

Comments on the Holtec nuclear waste dump can be submitted to the NRC through the following: Federal Rulemaking Web Site: Go to https://www.regulations.gov/ and search for Docket ID NRC-2018-0052. Address questions about NRC docket IDs to Jennifer Borges; telephone: 301-287-9127; e-mail: Jennifer.Borges@nrc.gov .

Mail comments to: Office of Administration, Mail Stop: TWFN-7-A60M, ATTN: Program Management, Announcements and Editing Staff, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

E-mail comments to:
Holtec-CISFEIS@nrc.gov

In addition to Holtec’s New Mexico facility, Interim Storage Partners (ISP)/Waste Control Specialists (WCS)/Orano USA and NAC International have proposed a consolidated high-level nuclear waste facility for a site in Andrews County, Texas, on the New Mexico border, where WCS currently operates a low-level radioactive waste and hazardous material treatment and disposal facility for nuclear power and weapons.

Both Holtec and ISP/WSP/Orano/NAC wish to have liability and ownership of the waste for their proposed high-level nuclear waste facilities shifted from nuclear-power companies to the Department of Energy – that is, to US taxpayers.

Dan Edson is a resident of Newburyport, Massachusetts, and a member of the C-10 Advisory Board.

A Tornado in the Midst of a Pandemic

Mon, 04 May 2020 13:47:24 GMT

Nuclear expert says FEMA, NRC must coordinate in disaster preparedness

After a recent tornado in Tennessee, Dave Lochbaum witnessed emergency response procedures that directly conflicted with priorities for containing the Covid-19 pandemic. He argues that the US government must do more to ensure that public safety would be protected after a severe nuclear accident in the midst of the pandemic. A nuclear safety consultant, Lochbaum worked as a nuclear engineer in nuclear power plants for 17 years. He recently retired from the Union of Concerned Scientists ( bio ), and serves on C-10's Advisory Board.

Shortly before midnight on Apr. 12 an EF-3 tornado with wind speeds up to 140 miles per hour touched down where I live in southeastern Chattanooga within Hamilton County, Tennessee, toppling trees and ripping roofs off stores, houses, apartments and retirement homes. Piling one emergency on top of another, the tornado provided a graphic and alarming example of why emergency preparedness is so important and why even in a reasonably well-prepared area such as Hamilton County the response can fall short. It also demonstrated a conundrum for emergency planners: the coronavirus emergency measures include social distancing and hygiene steps intended to contain the spread of the deadly disease. But the tornado required first responders to rescue more than 140 persons trapped by collapsed structures and downed power lines and take them to temporary shelters where social distancing was impossible.

The Chattanooga tornado highlighted conflicting responses to concurrent emergencies. The response to the Covid-19 emergency involves social distancing and facial masks to limit potential exposure to and spread of the lethal virus. The response to the tornado involved close personal contacts without PPE, forcing responders and victims to choose which emergency protocols to follow.

Similar to tornado response measures, the on-site and off-site responses to a nuclear emergency conflict with the Covid-19 response protocols. The onsite response includes staffing both a technical support center with trained, qualified individuals to monitor the plant and direct mitigation measures, and an operations support center with support personnel to repair disabled safety equipment and/or install backups. The off-site response may entail the governor ordering the evacuation of citizens to temporary shelters.

The response procedures to nuclear emergencies, extreme nature emergencies, and pandemic emergencies have been developed and honed by lessons learned from events and exercises. The problem is not how individual plans respond to their specific emergency, but how nuclear emergency and extreme nature emergency response plans are implemented during a pre-existing pandemic emergency. The middle of a dark, stormy night or the stressful period ahead of a looming reactor meltdown is not the best, or even second best, time to figure out how to adjust Covid-19 protective measures for proper alignment with other emergency response needs.

Continue reading Lochbaum's piece in Nuclear Intelligence Weekly .

Monitoring nuclear safety in pandemic times

Wed, 29 Apr 2020 18:03:07 GMT

An update from the home office

Dear C-10 friends,

How are you holding up? We've been self-isolating since mid-March. It's hard, and we miss you.

Our Board of Directors and Advisory Board have been meeting via Zoom. I've hardly been to the office in weeks—thank goodness for the internet, and too many cartoons for my five-year-old, Julia. Like so many working parents, my husband Tom and I are juggling, and fitting work in however we can.

Mike, our monitoring network administrator, has been working from home and going into the office at night—after he puts his kids to bed. He can't get out to repair a couple stations that are down, because of social-distancing restrictions. But we're still keeping tabs on ambient radiation levels in our communities, 24/7.

I've been busy researching and writing about what is going on at Seabrook Station in light of the pandemic , which is especially sensitive now, considering the month-long refueling and maintenance outage that began April 1. Check our our In the news page for extensive local and national media coverage.

We've been communicating with the Nuclear Regulatory Commission (NRC)'s resident inspector at the plant, as well as government officials at the local, state and federal levels and attempting to get answers from plant owner NextEra Energy. (Well, we tried. )

When I spoke to the Senior Resident Inspector Paul Cataldo in mid-April, he answered a lot of questions about how NextEra is operating in this time of pandemic, and how it has impacted the plant's Spring Outage.

Based on what I've learned from the NRC, I am confident that NextEra is following best-practices to reduce the spread of COVID-19. I also have a better understanding of how the pandemic has impacted work at the plant, and what projects are getting deferred. While hearing some specifics from the resident inspector was reassuring, we're still a bit uneasy about what we don't know, and which inspections really shouldn't wait. Particularly in light of the serious and incurable problem with Seabrook's degrading concrete.

That's why C-10 reached out to Massachusetts Senator Edward J. Markey, a long-time nuclear safety advocate. On April 20, Senator Markey, Senator Elizabeth Warren and Congressman Seth Moulton submitted a letter to NextEra asking for more information about the plant's pandemic plan and how they are communicating with local officials to stop the spread of coronavirus. They sent another letter asking NRC to provide answers on the regulatory exemptions that NextEra has been granted for work-hour limits and delayed inspections, as well as the NRC's inspection process during social-distancing and a time of remote work.

Aside from carrying out our mission for the health and safety of Seabrook's neighbors, we've been planning for how we can keep our organization financially healthy. C-10 relies on a mix of state funding, member contributions, business sponsorships and foundation grants—all of which are uncertain, given the economic situation we're facing.

I am very thankful that we were able to secure a payroll protection loan under the CARES Act, with assistance from the Institution for Savings. That has provided a bit of breathing room, at least until the end of the Massachusetts fiscal year on June 30. The monitoring network relies on funding from the Department of Public Health, and as we know, the state is facing steep declines in revenue.

We are grateful to State Representative James Kelcourse and Senator Diana DiZoglio for their belief in C-10's importance in helping to keep their constituents safe and informed. We are hopeful that they will be able to convey the value of real-time radiological monitoring to their colleagues in the Massachusetts legislature when it comes time to take up the fiscal year 2021 budget—whenever that happens.

On behalf of all of us at C-10, thank you for standing by us! Wishing you and yours good health and peace during this incredibly difficult time.

Sincerely,

Natalie Hildt Treat
Executive Director
C-10 Research & Education Foundation

PS: If you haven't yet made a gift this spring, we'd be so grateful for your support. It's easy to give online , and even better if you can make your gift recurring.

Fukushima warning: waters will rise

Thu, 26 Mar 2020 21:31:45 GMT

With anniversaries of nuclear accidents, climate change is on my mind

Memories of disaster unfolding

March 28 is the 41st anniversary of the accident at Three Mile Island. As a result of that accident, molten and highly radioactive fuel sits within the ruined Unit 2, in the middle of the Susquehanna River—awaiting “clean-up” at some future date.

But it’s the disaster at Fukushima that’s most on my mind lately. Particularly given similar vulnerabilities of the coastal region near Seabrook Station, and the fact that C-10 shared our knowledge of radiological monitoring with people from Japan concerned about public health.

On the evening of March 10, 2011, I stopped into a friend’s slope-side condo after a day of skiing to say goodbye. But I just stood transfixed by the movie he had on the TV—which I learned later is called “The Day After Tomorrow.” In the scene before me, a very large city was drowning beneath cataclysmically rising water—to the point that ships were floating down streets between enormous buildings. Eventually, I came to my senses and left for home.

The next morning, still sleepy, I turned on the TV to check the Boston area weather. For a moment, I felt a kind of amazement, as I seemed to be watching an excerpt of the movie I had stumbled in on the night before—until the familiar voice and intonation of the news reporter shocked me into the realization that I was watching actual footage of a tsunami hitting the shores of Japan.

The tsunami that inundated Japan’s east coast on March 11, 2011, thrust into the consciousness of millions around the globe a link between natural disasters, rising water, and the vulnerability of atomic plants to cataclysmic failure in the face of such phenomena.

After only a few days without power, three of the six American-designed General Electric “boiling water” reactors operating at the Fukushima complex suffered steam explosions due to diminished cooling water. The resulting “meltdowns” within each reactor caused molten reactor fuel to migrate beyond its designed confinement, causing massive radioactive releases into the air, ground, and water from the shore of the Pacific Ocean —where nine years later, local residents continue to grapple with the radioactive aftermath.

Design flaws persist

The United States has a corporate and governmental connection to this disaster, which remains largely unacknowledged; and in fact, C-10, our non-profit watchdog group, does as well. The GE Mark I reactor was such a poor design from a safety standpoint that in 1976, GE’s Project Manager for Mark I Containment Assessment, Dale Bridenbaugh, resigned in protest over the public hazard it represented. General Electric was undeterred, as was the US Nuclear Regulatory Commission. Dozens of these reactors were allowed to be sold by GE, domestically and internationally. (Two GE Mark I’s were finally shuttered recently in New England: Vermont Yankee near Brattleboro, and Pilgrim, In Plymouth, Massachusetts.)

Five of the six reactors at the Fukushima complex are GE Mark I’s, and their containment structures behaved in an emergency just at Mr. Bridenbaugh feared. As a result, the residents of Fukushima’s reactor community must contend with the effects of radiation exposure for decades to come—which leads us to C-10’s involvement.

When the citizens of the Fukushima Prefecture realized they needed to monitor the ongoing radiation levels in order to best protect their families, they sent representatives to the C-10 office in order to learn how. Some of our old equipment was even refurbished by manufacturer International Medcom and put to work measuring radiation levels in the wake of the accident.

Fukushima’s radiological disaster is the third known major accident among the world’s commercial atomic reactors; Three Mile Island, (near Harrisburg, Pennsylvania, 1979), and Chernobyl (Ukraine, April 26, 1986) are the other two. There have been other very close calls.

Ironically, it is safe to say that Americans generally know more about the two accidents that did not occur on US soil; but nonetheless, three major accidents involving radiological releases to the biosphere occurred within a 32-year period.

Nuclear plants are vulnerable to rising seas

While clearly none of the three disasters have any causal relationship to climate change, Fukushima shares a risk factor with the Seabrook reactor as our seas warm and rise: proximity to the ocean for access to sufficient reactor coolant.

In the case of Fukushima, the tsunami knocked out the local electrical supply, which meant the water needed to cool the thermally hot “spent” fuel could not be replenished—leading to a buildup of hydrogen gas, and the eventual explosions. The decision to site the reactor complex at the edge of Japan’s Pacific coast— a known area of seismic activity—in order to gain access to cooling water, resulted in the disabling of a crucial cooling system due to inundation, and disaster.

Seabrook has a barrier beach between it and the ocean, so even granting the reality of seismic activity nearby, this reactor is somewhat protected from any tsunami threat. What is much more concerning is the undeniable likelihood of ocean level rise during the operating life of the reactor. (See a prior C-10 blog on Seabrook’s vulnerability to climate change induced storms and flooding.)

Having brushed aside C-10’s legal challenge to NextEra’s proposed handling of Seabrook’s concrete degradation, the NRC has extended Seabrook’s operating license from 2030 to 2050; and there is every indication that the real goal for Seabrook is not a sixty, but an eventual eighty-year license —which would extend its operation out to 2070.

Given that the earth’s oceans appear to be warming at an accelerating rate, and that the Western Antarctic Ice Sheet is now sitting on a cushion of liquid water, it is ever more likely that the world’s oceans will rise significantly, and probably in our lifetime—certainly in the lifetime of our children.

It is also likely that some of that rise will be sudden; and unlike the recent storm surges that have temporarily flooded low-lying areas of our coast and then receded, a sudden rise caused by the massive slide of land-born ice into the Southern Ocean would be permanent. Drop an ice cube into a brim-filled glass of seltzer water, and watch what happens!

Just how the owners of the atomic plant in our backyard plan to deal with these contingencies is largely unknown. We live in an era of reduced “regulatory interference” after all; and the priority given to extended operation, without regard to the informed intervention of concerned citizens, tells me that profit will be paramount till the boats are launched.

The burden of future generations

Then, of course, there’s all that nuclear waste that must be moved somewhere; and the moment it leaves NextEra’s property, it becomes the property of the Department of Energy—at which point it becomes all of our problem. Reactor owners everywhere are banking on that eventuality.

Instinctively, we all want to send Seabrook’s High-Level Waste (HLW) somewhere far away. An earlier concept of deep geologic burial led to the creation of the Yucca Mountain repository in Nevada, in spite of the fact (or because of the fact) that the land was given by US treaty to the people of the Western Shoshone 170 years ago.

What would become an unfinished $9 billion hole, in a seismically and volcanically active geologic zone, the Yucca repository project never opened. It turns out the Shoshone don’t want our radioactive waste within their sacred mountain; and they would have saved us the trouble and expense if only we had asked them. Also, the Yucca site was never designed to hold more than a fraction of the expected US inventory of commercial HLW—and never for more than a fraction of the time needed to exhaust the wastes’ toxicity.

The current federal plan calls for so-called “ Consolidated Interim Storage” of HLW in dry cask parking lot installations way out in west Texas and New Mexico—on lands populated by, you guessed it, Chicano and aboriginal American communities. These communities are, politically, least able to defend against the machinery of federal appropriation.

This means that HLW from Seabrook, New Hampshire, would be transported overland, by rail and highway—and is therefore subject to the risk of accident along the way. Furthermore, these western installations could easily become de facto long-term storage sites, because the political will does not exist to develop the truly long-term isolation technologies, and locations, that these frighteningly hazardous, unbelievably long-lived materials require.

Those of us who live, and work, and raise families within the Ingestion Pathways of US commercial atomic plants must insist that our political representatives find regional solutions to the problem of High-Level Waste—and soon. Environmentally racist policies that exploit racial difference, while passing off the long-term isolation problem to our grandchildren, constitute a terrible form of hypocrisy. We must not allow “fixes” to be implemented that leave our descendants to curse the choices we’ve made.

Isolation technologies should be developed that fit the actual longevity requirements of the radionuclides that comprise High Level Waste. Sites should be researched and chosen for High Level Waste isolation within as many of the regions of the United States where atomic plants operate as possible—so that long-haul transportation, and the exploitation of minority groups, are avoided.

The final siting of these facilities must include a consent-based, democratic process for affected communities. Until these regional solutions are found, the High- Level Waste should remain in the possession of the corporations responsible for making it.

As long as we have nuclear reactors operating along our coastlines, we must be concerned with the risks they pose to the biosphere due to rising sea levels. Isn’t there a safer, cheaper, more practical way to provide electricity at the scale required for modern life? Stay tuned.

Decision delayed in Seabrook's concrete case

Thu, 26 Mar 2020 00:39:43 GMT

Amid pandemic, NRC board won't rule until July

With a national emergency declaration in effect, the regulatory process is facing another slow-down.

On Wednesday March 25, the three-judge panel overseeing the proceeding on a challenge to NextEra Energy’s 2016 license amendment request relating to the impacts of alkali-silica reaction on concrete structures at the Seabrook Station issued a notice extending the timetable for issuing a decision. The amendment is being challenged by the C-10 Research and Education Foundation.

The NRC's Atomic Safety and Licensing Board said it had planned to issue an initial decision by April 9, and now it anticipates that it will make a ruling by July 10. Originally the Board expected to issue a decision within 90 days of the conclusion of the hearing (September 27, 2019). This is the second extension.

"Given the unprecedented times we are all experiencing with the COVID-19 pandemic, it is somewhat understandable that this ruling has been delayed, but we were certainly looking forward to a resolution in this case," said Natalie Hildt Treat, C-10's Executive Director.

It's a tenuous time, with many people, including the NRC's resident inspectors at Seabrook Station, working remotely with a reduced onsite presence," said Treat.

Seabrook's NRC Resident Inspector Paul Cataldo explained to C-10 that he and his colleague Travis Daun have access to the plant's computer logs, corrective action program, and all site programs, and are attending meetings remotely. "We are also visiting the plant twice a week to ensure an onsite presence is maintained," said Cataldo in an email.

"We at C-10 will rest a little easier when this public health crisis has passed, when staffing at Seabrook and the NRC are back to normal, and when the Board issues its ruling on Seabrook's handling of the degraded concrete meant to protect the public from radiation exposure," said Treat.

More on the impact of COVID-19 on Seabrook is in this March 23 story in the Daily News of Newburyport .

For insights on how the pandemic is affecting how the NRC does its job, see our recent blog, Is a pandemic the time to relax nuclear regulations?

More information on the concrete case from C-10's perspective is on this blog and this overview page .

Is a pandemic the time to relax nuclear regulations?

Mon, 23 Mar 2020 13:24:26 GMT

Insights from an NRC conference call on COVID-19

Last week I had the opportunity to listen in on a public meeting between the US Nuclear Regulatory Commission (NRC) and nuclear industry representatives, including Seabrook Station owner NextEra Energy. The topic: “ COVID-19 regulatory impacts .”

Friday, March 20, was about a week into the guidance to “shelter-in-place” due to coronavirus, so presumably most of the participants were calling in from home. At the start of the call, we were reminded that this was an information-gathering dialog, with no decisions to be made and no sensitive information shared.

NRC staffers and industry executives talked about how the pandemic is influencing their work to ensure the safe operations of the nation’s commercial nuclear plants. There was a lot of tech speak. The moderator reminded participants to please spell out acronyms after I emailed them with the humble request. “EGM” stands for Enforcement Guidance Memorandum. Thanks, guys.

There were few specifics as to how the plants are prepared to handle the pandemic, but here’s what I gleaned:

The NRC wants to prioritize where it can focus resources while carrying out its mission of “protecting people and the environment.”
All NRC and nuclear-plant employees who can do so are working from home. They are also practicing the usual social distancing, sanitizing, screening and isolating sick employees, etc.
According to Dr. Jennifer Uhle with the Nuclear Energy Institute, plants have had pandemic-response plans since 2006 to protect workers and ensure continuity of operations; the safe operation of the nation’s nuclear plants is the primary focus.
NRC is “backing off onsite safety inspections,” and doing as much as they can remotely.
The plants may be asking for “potential enforcement discretion” and more waivers to maintain qualified personnel and in terms of exams for operator licenses.
The NRC is considering various regulatory paths to ensure compliance, including flexibility for the spring 2020 outages (when inspections, maintenance and refueling happens).
The pandemic will trigger NRC regulations for hardship provisions.

Listening to the conversation, I got the distinct impression that streamlining approvals, relaxing of inspection and reporting requirements, and a heavier reliance on the nuclear plants to oversee their own safety is where things will be trending during the pandemic. Come to think of it, that sounds like the way things have been headed in the nuclear industry under the current administration. But I digress.

On the one hand, it makes sense to reduce administrative burdens and make it easier for the plants to focus on their core objective of operating safely. Certainly, having safe, reliable electricity is vital to all of us during this challenging time. Yet the lack of transparency, and the appearance of federal regulators giving “licensees”--as the plants are known--a bit of a pass during a time where so much is at stake, gives one pause. We are talking about atomic reactors, after all.

Kevin Kamps from the watchdog group Beyond Nuclear was on the call. “We’ve been hearing a lot about waivers and loosening regulations in a time where it seems we need more focus on public safety,” said Kamps, noting that with electricity demand down, there may be plants that don’t even need to be operated now. “It seems prudent and wise from a safety perspective that reactors not needed now should go into controlled shutdown in this time of great uncertainty and high risk,” said Kamps.

Several members of the public had questions about whether and how the NRC would oversee a situation if a nuclear plant were particularly hard hit by the pandemic. How would they ensure that they had enough qualified, healthy and well-rested workers to safely operate? One caller referenced the fact that several of the nation’s air traffic control towers have been impacted by COVID-19.

Scott Burnell, public affairs officer with the NRC, said, “If any plants come to a point where they can’t meet regulatory requirements such as staffing, they are required to contact NRC.” Burnell explained that while plants could request regulatory relief, there are requirements to reduce power and potentially shut down if they aren’t able to meet key regulatory requirements such as staffing.

Ho Nieh, Director of Nuclear Reactor Regulation, said, “I hesitate to speculate, but the NRC has a variety of mechanisms to enforce its requirements, including shutting a plant down.”

One of the reasons I was on the call was to try and get some more specifics about what’s in a pandemic-preparedness plan, in particular for Seabrook Station, our nuclear neighbor here at C-10.

Bill Parks, general manager for operations at NextEra, was on the call. So when it came my turn to ask a question, I figured I’d give it a shot and ask him directly.

“What specifically can you tell us about how Seabrook Station is responding to protect your team and ensure continuity of operations? Are staff being asked to live at the plant? Are there longer shifts or are you requesting relief on licensing requirements for certain staff? What do you do if you get close to the minimum staffing levels when people start getting sick?” I asked.

The NRC’s Scott Burnell quickly jumped in to explain that we were to direct questions to the NRC, but Mr. Parks was free to answer if he liked. He declined.

As the call proceeded, I got an email from Lindsay Roberston, senior communications specialist for NextEra Energy. I had tried earlier in the week to get some insights from her on some of the concrete ways that NextEra is preparing in the face of this pandemic. Robertson’s comment was brief and rather unilluminating.

“All nuclear facilities, including Seabrook, are required to have detailed plans and procedures in place that consider a wide range of emergency scenarios, including pandemics. We are monitoring the COVID-19 situation very closely and will keep the safety of our team and the public as the top priority in all our decision making,” wrote Robertson in an email after one of her colleagues heard me questioning her boss on the call.

Yeah, okay. I get it. There are a lot of security matters at stake, and they want the public to know that they’ve got things under control without being pressed for specifics. But personally, I would feel better with a bit more honesty. Like, are people being asked to live at the nuclear plant? How are they working to stop the spread of illness among their employees? What will happen to our electric grid if too many workers at Seabrook, (or any other power generator, for that matter), fall ill?

None of us has lived through a pandemic like this. We’re thinking about our own health, about the hardships our friends and neighbors are going through. We’re grateful to the essential workers who are keeping things running: food, health care, news, sanitation workers, and of course utility companies and energy producers.

But pandemic or not, the public deserves to know what federal regulators are doing to keep us safe. To the extent that they are willing to be forthright, I’d like to think we can ask the same of our nuclear power plants, as well.

MORE INFO

Listen to the meeting here , with thanks to Libbe HaLevy for the recording.

Read the NRC’s public statement about COVID-19 , and Newburyport Daily News coverage of the impact of coronavirus on Seabrook Station from March 23.

NextEra issued this press release on March 17 about how they are donating $1.5M to vulnerable people impacted by COVID-19. To date, we could find no public statement about how they are handling the impact of the virus on their corporate operations, including Seabrook Station .

Read the latest news, including coverage on WBUR and a New York Times article, here.

Prepare, don’t panic

Thu, 19 Mar 2020 00:00:00 GMT

Coronavirus can help us get ready for other types of emergencies

Risk and Preparedness

The coronavirus has everyone a little freaked out, and it seems for good reason. In recent days, many of us have been affected by cancelled events like conferences, performances and even church. Meetings and work are being moved online, and those of us with kids are scrambling.

We’ve adopted namastes and toe taps as greetings, and we think about every public surface we touch—and how soon we can wash our hands. We are stockpiling essentials, and making our own contingency plans for work and family life.

People like to feel in control and safe. They also don’t like to think about risks that seem far off or unlikely. News about the coronavirus is all around us, even as it begins to change how we live, move and gather. There is a sense of urgency to protect ourselves and our families, and we are hunkering down.

COVID-19 is scary because it’s very contagious, and even though most who get it won’t die from it, the overall and unknown risk to society and potential disruption to supply chains, hospitals, businesses and government agencies leave us feeling anxious and vulnerable.

In light of all this, many people are taking steps to feel prepared, protected, and less at risk. Risk is hard to quantify, and there is a certain emotional, or psychological component to it. Even when things seem to be going smoothly and we feel safe, that doesn’t mean the risk is zero.

Take living near a nuclear power plant. There are a lot of people at Seabrook Station, the nuclear plant in coastal New Hampshire, who work to ensure that the atomic reactor is operating safely, and that the plant and spent fuel are secure. The same thing goes for partners at all levels of the government. The risk of a radiological accident may be very low, but anyone who lives or works in the vicinity of a nuclear plant must keep in mind the possibility that a very serious accident could happen. It's estimated that about three million Americans live within 10 miles of the nation's 99 nuclear plants.

We’ve just passed the ninth anniversary of the Fukushima disaster , where people were forced to evacuate a 50-mile radius surrounding the meltdown site. It is sobering to imagine what that kind of accident would mean for our beloved Seacoast communities, our homes, and our businesses.

Beyond Stockpiling Toilet Paper
While it feels a little like the Zombie Apocalypse to walk through Market Basket these days, buying extras of the essentials is not a bad idea, but that’s just the start. Now that the coronavirus has made preparedness top of mind, it’s a great opportunity to think about how you can be ready for other types of emergencies, too.

By preparing to self-quarantine, we've essentially been getting ready to shelter in place — one kind of directive that could come in the event of a nuclear emergency. In other scenarios, such as severe storms, fires, or an accident necessitating an evacuation order, we could be ordered to leave our homes. In those cases, having a good checklist of essentials in place, or a "go bag" is advised, as well as knowing evacuation routes.

What are some things that you need to do to keep yourself, your loved ones and even your business safe and prepared before and during an emergency? For starters:

- Know where to get reliable information . Knowledge is power. Government websites and major news outlets like the New York Times and NPR tend to be more fact-based than social media posts, for example.
- Make a plan, and assemble your supplies. Ready.gov has guidance for preparing for all kinds of emergencies, including a pandemic like coronavirus, a hurricane, or even an accident at a nuclear power plant.
- Check on neighbors and vulnerable people before and during an emergency.

Resources for Nuclear Safety

While most of us prefer not to sit around thinking about the unthinkable, at C-10, it’s our job to focus on nuclear safety. Through our real-time radiological monitoring network, our research and advocacy and by providing reliable information to the public, C-10 is doing all we can to work for the health and safety of people and the natural environment surrounding Seabrook.

Visit c-10.org for direct links to Seabrook Station’s Emergency Brochure for Massachusetts and New Hampshire residents within the plant’s 10-mile emergency planning zone as well as a basic Emergency Preparedness Checklist . With community support, C-10 will keep doing all we can to help prevent an accident and to provide the public with tools to be prepared.

Keep calm, wash your hands, and remember that we're all in this together.

C-10's monitoring network in need of investments

Sat, 07 Mar 2020 16:42:26 GMT

Please support our request for Massachusetts state funding

The Need: The Citizens Radiological Monitoring Network is in serious need of investment so that we can replace old equipment, such as the radiological probe pictured above. C-10 is asking for $169,752 in the coming year's Massachusetts state budget, which includes $56,772 for equipment replacement and a modest increase in the annual monitoring network budget to $112,980.

Background: C-10 has been contracted by the Commonwealth of Massachusetts to operate the Citizens Radiological Monitoring Network since the early 1990s, soon after the Seabrook Station nuclear power plant went online. We do this on a very efficient budget. Annual contract funding through the Department of Public Health has remained at about $90,000 for the past two decades.

C-10 is honored to provide a service that offers greater safety and security to people who live and work in the vicinity of the nuclear power plant, by measuring radiological emissions as well as wind speed and direction in real-time. We operate the network 24/7.

The monitoring data provides state officials with insights into permitted radiological releases, and could also help protect the public in the event of an emergency at Seabrook. Despite ongoing questions relative to degraded concrete at Seabrook Station, the plant has been relicensed to operate until the year 2050.

We have been forced to stretch funding further each year, due to rising costs. We have not received supplemental funding to purchase equipment such as radiological probes, wind anemometers, computers and cables in more than a decade; many of these components face constant exposure to the harsh New England elements.

While we do continue to seek private and foundation funding to support our efforts, we hope you’ll agree that radiological monitoring is such a valuable public service that it should be adequately funded through the state budget.

It’s important that elected officials hear from their constituents to thank them for their support of C-10’s budget request.

Rep. James Kelcourse, Rep. Lenny Mirra, Senator Diana DiZoglio and Senator Bruce Tarr represent the six Massachusetts communities within the 10-mile Emergency Planning Zone in which we operate the Citizens Radiological Monitoring Network. Hearing from their constituents will help them make the strongest case to their colleagues.

* *Now is a great time to make your voice heard! **

TIMING: The House of Representatives will take up the fiscal year 2021 budget in March, with debate in mid-April. The Senate will work on its version of the budget in the last two weeks of May.

Whether you call, write or email (links below), please:

Tell them why C-10’s real-time monitoring network matters to you, and
Thank them for their past support of funding for radiological monitoring and urge them to support C-10’s full budget request for fiscal year 2021, which is $169,752.

Please thank Representative James Kelcourse for introducing C-10’s budget request.

Please also thank and urge continued support from: Senator Diana DiZoglio , who we have asked to introduce the request in the Senate, as well as Senator Bruce Tarr and Representative Lenny Mirra .

Learn more about the Citizens Radiological Monitoring Network

C-10 Open House a success!

Thu, 27 Feb 2020 17:48:50 GMT

We love our new home at CI Works in Amesbury

On January 30, C-10 supporters as well as local and state officials came to help us celebrate our new home at CI Works - a collaborative work space that is home to an array of creative and entrepreneurial businesses, many in the clean energy sector. We were honored to by joined by both longtime and new supporters, as well as Mayors Kassandra Gove and Donna Holaday (pictured), State Rep. James Kelcourse, State Rep. Peter Somssich, aides to Senators DiZoglio and Tarr. We look forward to hosting more events in this terrific space, and welcome visitors who want to see the Citizens Radiological Monitoring Network in action.

Case is not closed with Seabrook’s degraded concrete

Thu, 02 Jan 2020 17:10:04 GMT

C-10's letter to the Hampton Union sets the record straight

The Hampton Union , hometown paper of Seabrook Station nuclear plant, has a history of downplaying concerns brought by pro-safety groups like C-10. Incredibly, neither the Union nor any of the sister publications in the Seacoast Online group sent a reporter to cover the week-long federal hearing and public comment period on Seabrook's concrete, held in Newburyport , Mass. last September. (See our C-10 in the news page )

In their Top ten stories of 2019 , the paper ran a few paragraphs about how the plant was relicensed in March of last year, indicating that the problems with the degraded concrete were somehow a settled issue. Not so. Here's our letter to the editor, published on December 30.

To the editor:

In reviewing 2019’s top stories, the paper glossed over the irreversible and unresolved problems with Seabrook Station’s concrete. True, the Nuclear Regulatory Commission granted the plant a 20-year license extension, but they did so before a planned hearing on the ability of Seabrook’s degraded concrete to continue protecting the public as designed.

It has since been demonstrated that the NRC’s review was based on simplistic analysis, without the benefit of an expert on the complex and pernicious problem of alkali-silica reaction, or “ASR” that is affecting all of Seabrook’s key safety structures. Neither did plant owner NextEra Energy have an ASR expert on their team. It was the C-10 Research and Education Foundation, a pro-safety citizens group, that brought the only qualified expert when we challenged Seabrook’s concrete aging-management plans before the NRC’s Atomic Safety and Licensing Board.

Last September, the Board held a week-long hearing where they questioned C-10’s witness, renowned ASR expert Dr. Victor Saouma of the University of Colorado, Boulder. Saouma clearly gave the three judges plenty to consider when he laid out the flaws in NextEra’s methodology. The Board originally planned to rule on the case in early 2020, but just revised their own deadline to April 9.

The case of Seabrook’s degraded concrete is not only of concern to the 23 New Hampshire and Massachusetts cities and towns within the plant’s 10-mile emergency planning zone; it could have national repercussions as well. ASR is well-known in bridges, dams, and other buildings, but Seabrook is the first reactor in the nation known to have ASR. Because it is so new at nuclear plants, the NRC does not have regulations governing its management.

While NextEra has so far deflected any criticism of their approach, C-10 and our expert have already laid out the kind of rigorous analysis that is possible. As one of the region’s largest energy producers, and one that will be with us for years to come, NextEra owes it to its neighbors to do all that they can to keep us safe. By adopting better testing and monitoring protocols, NextEra can increase public confidence that they have a firm grasp on what is happening deep inside the concrete meant to protect us in the event of an earthquake or accident.

Natalie Hildt Treat

Executive Director, C-10 Research & Education Foundation

C-10 calls out NRC and NextEra’s lack of expertise in Seabrook concrete case

Sat, 23 Nov 2019 21:24:36 GMT

Urges atomic judges to send NextEra back to the drawing board

C-10 Research and Education Foundation (C-10), a citizens non-profit focused on the safety of Seabrook Station nuclear power plant, has filed its “Proposed Findings of Fact and Conclusions of Law” with the federal Atomic Safety & Licensing Board (ASLB), citing a lack of expertise on the complex and pervasive concrete degradation phenomenon known as alkali-silica reaction (ASR) by either plant owner NextEra Energy Seabrook, LLC or the U.S. Nuclear Regulatory Commission (NRC) staff that has approved of Seabrook’s handling of the problem.

“This filing is C-10’s attempt to crystallize all that we’ve learned relative to NextEra’s deeply flawed approach to managing Seabrook’s failing concrete, and to convince the ASLB judges that given what is at stake, NextEra should be sent back to the drawing board with its concrete testing, analysis and monitoring protocols,” said Natalie Hildt Treat, executive director of C-10. A redacted version will be available at c-10.org .

“Unfortunately, the NRC Staff’s witnesses did not demonstrate any level of expertise regarding ASR,” said C-10 in the introduction to its November 21 filing. “The only independent expert review of the license amendment request (LAR) to be presented by a qualified ASR specialist was the expert testimony of Dr. Victor E. Saouma on behalf of C-10.”

“Dr. Saouma, a leading international expert on ASR, conducted a comprehensive review of the LAR pro bono, out of his concern that the LAR was not conducted in a manner that followed sound scientific principles, including application of a high level of expertise or independent peer review. His testimony effectively eviscerates the methodology used in the LAR to support NextEra’s claim to understand the severity and extent of ASR now existing in the plant, and that its monitoring program will detect ASR before it begins to pose a significant risk to public health and safety. As Dr. Saouma explains, NextEra’s methodology is grossly over simplistic, misleading, and completely inadequate to support any level of confidence that NextEra will be able to detect unacceptable ASR expansion before it happens,” wrote C-10.

The ASLB, which is a three-judge panel under the NRC, is expected to rule on the case by late January or early February. ASR is an irreversible chemical condition impacting all key structures at the nuclear plant, including the core reactor’s containment enclosure building. Seabrook is the first U.S. reactor known to be suffering from ASR, though its presence has been a factor leading to the closure of at least two other plants, globally.

First detected at Seabrook in 2009, the presence of ASR caused NextEra to submit a license amendment request in which the company sought NRC approval of a concrete aging-management plan. The same plan was included in the Seabrook’s license renewal application. The NRC determined that the plan was sufficient, and in March 2019, granted the LAR and a 20-year license extension to operate the reactor until 2050. These actions were taken in spite of the planned ASLB hearing on Seabrook’s concrete problems that took place the week of September 23, 2019 in Newburyport, Mass.

At the hearing, C-10 attorney Diane Curran told the licensing board that “The biggest concern posed by ASR at Seabrook is this: if severe enough, ASR may weaken concrete safety structures to the point that they crack during an earthquake and release radiation into the environment.”

“The discovery of ASR at Seabrook has presented NextEra and the NRC Staff with three unique and difficult problems,” wrote C-10 in its Proposed Findings of Facts and Conclusions of Law:

First, ASR is an exceptionally perverse phenomenon, rotting concrete from within. The webs of ASR-caused microcracks and delaminations inside a concrete structure can weaken a large building to the point it is unable to withstand even a moderate earthquake.

Second, the insidious effects of ASR are invisible to the naked eye and difficult to diagnose. Webs of ASR-caused microcracks and larger delaminations lie beneath the surface, and may not be indicated by surface cracking. And these nefarious effects are not uniform within a concrete structure; instead, ASR is heterogeneous and dependent on such localized conditions as aggregate and sand geochemistry, temperature, and humidity.

Third, while ASR has for decades been known to exist in numerous structures such as dams and bridges, and while ASR is the subject of a significant body of international research, it is not regulated by the NRC.

C-10 has been following this problem for the last decade and has submitted previous filings urging the NRC to take the ASR phenomenon more seriously, and to develop federal regulations to govern its handling at nuclear reactors. Coincidentally, the NRC responded just this week to a September 2014 C-10 petition in which the group had requested new regulations to provide better protection against ASR at U.S. nuclear power plants. The agency denied the petition.

“While C-10 was initially admitted as an intervenor in the case in 2017 without the benefit of an attorney or expert witness, we were amazingly lucky that Dr. Saouma, a world-renowned expert on both the chemical and structural aspects of ASR, learned of our involvement and felt so strongly about the importance of this case that he decided to work with us pro bono,” said Treat.

“Dr. Saouma has donated hundreds of hours of his time because he cares about good science, he believes in our case, and he is concerned with the well-being of all who live and work near Seabrook Station. Truly, all of Seabrook’s neighbors owe Dr. Saouma and our attorney Diane Curran, a debt of gratitude for their work on behalf of public safety,” said Treat.

BACKGROUND INFORMATION:

C-10’s Expert and Counsel

Victor Saouma , Professor of civil and structural engineering at the University of Colorado, Boulder, is serving as C-10's expert witness in the case regarding Seabrook's concrete. Saouma's work centers on what he sees as flawed test results that affected the safety analysis underpinning NextEra Energy Seabrook's concrete aging management plans. One of the world’s leading experts on alkali-silica reaction (ASR), Saouma has studied its effects on nuclear reactors—in particular, how the containment structures could be weakened should an anticipated earthquake occur. Saouma has worked for decades on concrete structure and material properties, and has many peer-reviewed technical articles on topics regarding concrete degradation. Saouma has researched ASR at nuclear power plants under contract with the U.S. Nuclear Regulatory Commission. C-10 is being represented by Diane Curran , the nationally-known environmental and nuclear safety attorney.

About C-10
C-10 Research and Education Foundation (C-10) works to protect public health and the natural environment surrounding the Seabrook Station nuclear power plant. C-10’s core service is to operate a field monitoring network to measure airborne radiological emissions surrounding the plant, and has provided this critical service under contract with the Commonwealth of Massachusetts since 1993. C-10 also advocates for upgraded safety and security at Seabrook. More on C-10’s legal challenge relative to Seabrook’s concrete is here .

Citizens Initiative Gaining Steam

Thu, 31 Oct 2019 14:47:11 GMT

State leaders, locals folks, working to make community-based radiological monitoring a reality in New Hampshire

Why is it that the host state of the Seabrook nuclear plant hasn't invested in real-time radiological monitoring "beyond the fence?" While the Commonwealth of Massachusetts has contracted with C-10 to provide this important service since 1993, the issue has been an ongoing and uphill fight for the people of New Hampshire's seacoast region.

Portsmouth State Rep. Peter Somssich (center) and former radiogical specialist Howie Gonia of Seabrook (left) are among those working on the Citizens Initiative to Expand Radiological Monitoring in New Hampshire. Recently, they visited C-10's office and spoke with System Administrator Mike Mansir (right) to see our Central Station in action.

Rep. Somssich, a Ph.D. physicist by training, wants to see less state investment in passive data collection such as the device known as a "TLD" that is hanging on the bulletin board in the photo above. These thermo-luminescent dosimeters are placed on utility poles in the towns surrounding Seabrook station and taken down approximately quarterly. Both plant owner NextEra Energy and the state of New Hampshire have their own devises, which record cumulative gamma radiation over a three to four month period and have to be manually taken down and sent to a lab for processing. Somssich would like to see more real-time data collection, which he believes would be much more useful in understanding airborne radiation levels at a given time.

Read more about C-10's monitoring network here , and check out this article featuring Rep. Somssich and Rye Senator Tom Sherman's efforts in this article on Seacoastonline.com . To contribute to the Citizens initiative, click here .

Will you help your community learn about C-10 and be safer?

Thu, 31 Oct 2019 14:25:47 GMT

A call for volunteers by C-10's Outreach & Development Committee chair

If you're reading this, you share my concerns about keeping the seacoast safe. And, if you’ve been following C-10's work, you know that we’ve been very busy with our case relative to the Seabrook nuclear plant’s degraded concrete .

Whatever happens with this case, Seabrook will be with us for some time—regardless of whether it continues to operate for another 30 years, as it’s been licensed to do by the U.S. Nuclear Regulatory Commission.

That’s why I believe it’s more important than ever that we have an independent group like C-10 keeping tabs on safety concerns at Seabrook, serving as an educational resource for the public, and operating our real-time radiological monitoring network as we have since 1991.

C-10 has a small staff, and relies on volunteers to help with things like organizing educational events, updating communication lists and serving as liaisons to the 23 cities and towns within Seabrook nuclear plant’s emergency planning zone.

As the Chair of C-10’s Outreach and Development Committee, I’m committed to increasing C-10’s visibility and our impact—but I can’t do it alone!

If you live in the region and would like to help “spread the word,” we want you to know about volunteer opportunities, and we’d love to hear your ideas as well. Here are some of the things I’d like us to do in the coming year:

Brainstorm with interested volunteers about how to make C-10 a more visible force in our communities.
Connect with local officials, including first responders and health officials in the region. Possible projects include education about C-10’s radiological monitoring network and assessing the availability of pPotassium iodide (KI) for those who live in the 10-mile planning zone.
Conduct outreach to schools, community groups and businesses to discuss the realities of living near a nuclear plant and explain C-10’s vital role in keeping the region safe.
Host informational meetings for small groups or the general public.
Support initiatives facilitated by other committees of C-10, including research and fundraising.

YOU CAN BE A FORCE FOR CHANGE IN YOUR COMMUNITY AND MEET OTHER INTERESTED VOLUNTEERS.

WILLING TO HELP? E-mail me ! I’d love to hear from you by November 15 , in hopes of pulling together a meeting in the next month. Thanks for your consideration, and for your support of C-10!

Sincerely,

Karen Clagett

C-10 Board Member

When a baguette is not a baguette

Wed, 02 Oct 2019 14:46:48 GMT

The representativeness of Seabrook's concrete testing program hinges on the components used at a lab in Texas

"None of the reviewers, in my book, had the proper qualifications to assess this project. In the end, it has come to a small organization, who cannot even afford the rent on their office, and for me to help them out, to perform the very first peer evaluation. Yes, I'm very difficult; that's my nature. I have to be difficult. I have to be attentive to the well-being of the people around this town."

- Dr. Victor Saouma, on day three of the hearing on Seabrook Station's degraded concrete.

Kung Fu fighting

As I watched our expert witness Dr. Victor Saouma at last week’s federal hearing on Seabrook’s concrete, I had visions of a Kung Fu master who could handily dispense with one attacker after another. It was a very technical hearing; perhaps my imagination got carried away. But truly, Dr. Saouma sounded like the most knowledgeable person in the room when it came to the complex problem called alkali-silica reaction (ASR) that is eating away at the concrete meant to protect us from radiological exposure. The three judges from the Nuclear Regulatory Commission’s Atomic Safety and Licensing Board (ASLB) were extremely attentive, and asked very good questions.

C-10 has described our case to call for better testing, monitoring and analysis of the serious condition affecting the nuclear plant’s concrete structures as “David versus Goliath.” In reality, we’re facing two Goliaths; both Seabrook owner NextEra and the staff of the U.S. Nuclear Regulatory Commission seem equally intent on getting our case before ASLB the tossed out on procedural grounds. Could it be because our witness, one of the world’s leading experts on the irreversible condition also referred to as “concrete cancer,” has them on the defensive, on substantive matters? Sure looks like that to us.

When C-10 first asked the ASLB for a hearing regarding NextEra’s license amendment request ( LAR ) back in 2017, we had no lawyer. We had no expert. Our volunteer board of directors did their best in assessing what they saw as some serious problems. Any layperson would see that a lab in Texas—where NextEra’s paid consultants conducted the Large Scale Testing Program that would serve as the basis for future monitoring and concrete-aging management plans—was a poor stand-in for what’s been happening at a nuclear reactor on the New Hampshire salt marsh over the past 30 years. Yet the idea of the “representativeness” of these tests is at the crux of this case.

Did we get everything right in our initial filing? No. We were amateurs, but we knew we were onto something. The ASLB agreed when they granted us standing in the case. The judges that Dr. Saouma faced began by asking him about his written testimony , submitted prior to the hearing. One asked if Saouma still believed that NRC and NextEra lacked the expertise to assess this problem. “More so than before,” he replied.

It was dense material, and sometimes a tense atmosphere, as the seven NextEra experts and four from NRC tried to pick apart C-10’s case. But more than once, a judge was heard uttering the words, “I’m concerned,” directed at NextEra in regards to its testing program. Ultimately, the hearing stretched over almost four full days at Newburyport City Hall during the week of September 23, 2019.

Bell bottoms and Atari 2600

When commercial nuclear reactors were first being built in the United States, the problem of alkali-silica reaction was virtually unknown. At the hearing there was much discussion of the state of knowledge and construction codes back in the mid-1970s, when Seabrook was built. Not only was ASR not known to be a problem (and thus not described in NRC regulations), but the techniques and technologies now used to monitor, analyze and model concrete degradation are vastly improved from four or five decades ago.

While ASR is well-known in other concrete structures like bridges and dams, Seabrook is the first U.S. nuclear plant where it has been discovered (its presence in reactors in Canada and Belgium contributed to their early shut-down). "There's no standard for a nuclear reactor suffering from ASR. We need to start thinking outside of that box," said Dr. Saouma during the hearing. A compilation of all of Dr. Saouma's testimony, in redacted form, is here.

A baguette is not a baguette

Those who attended C-10’s annual public meeting back in June will recall Dr. Saouma’s presentation and his memorable analogy comparing concrete to bread. A baguette in Paris is different from one from Whole Foods, he explained, because you have different ingredients.

Indeed, what Saouma kept hammering NextEra's team about is that the components used to mix up test concrete at the Ferguson Structural Engineering Lab (FSEL) in Austin, Texas, were different enough from the components in Seabrook’s concrete to impact not only the test results, but all of the subsequent assumptions about Seabrook’s actual structures.

In a motion filed with the Board on September 30, C-10 has urged the ASLB to compel NextEra to produce data on the mineralogy of the testing in Texas, noting that it affects the length of time ASR has propagated. With all the compelling arguments that Dr. Saouma made about the inadequacy of NextEra’s testing and analysis, we must try to win on “representativeness,” the core of our contention:

While NextEra’s monitoring program is focused on surface cracking and core samples, Dr. Saouma explained that with ASR, there may be a process underway that we cannot see, deep inside the concrete.

“NextEra and NRC Staff refused to give credence to the possibility of ‘delamination’ (large internal cracks) within the core reactor Containment Enclosure Building, that is not visible on any surface. Yet they had one of the world’s leading experts on ASR telling them squarely that it can happen,” reflected C-10 board member Chris Nord.

“I think it is not too strong of an analogy to use Fukushima—where the owners and regulators knew the risk of both major earthquake and tsunami, and yet left their reactor complex completely unprepared for the actual event. Shouldn’t the regulator here insist that the LAR account for this real possibility?” Nord asked.

“One key observation from the hearing is that while an appropriate scientific and holistic approach was needed to assess and plan to manage the ASR, NextEra took a myopic view and the NRC appeared to rubber-stamp it,” noted C-10’s Diane Teed. “From the outset, there was no search for reliable experts in ASR to design, review or evaluate FSEL test results and, subsequently, no use of ASR experts to conduct an independent peer review,” said Teed.

“NextEra has been looking at the expansion problem through a distorted rear-view mirror,” said Dr. Saouma about the behavior of concrete with ASR. “What is needed is a forward-looking approach.”

Let the public speak

Close to 100 concerned citizens as well as government officials filled Newburyport City Hall Auditorium on Monday, September 23 for a chance to tell the ASLB judges what they think.

“It's the AG's view that the NRC has already undermined the public's trust after its decision making, so this is a chance to restore that trust,” said Alex Bradley, of the Massachusetts Attorney General’s Office, and also a Newburyport native.

“Yes. Concrete cracks are a cause for concern, but the cracks in procedures that allow for license renewal contrary to facts are distressing. Both need to be monitored and fixed to ensure the health and safety of the general public. This is your responsibility,” Newbury’s John Gibson told the judges.

“When dealing with the public safety, I think it's really important to expect the unexpected” testified Newburyport City Councilor Afroz Khan, speaking as a resident. “It is the unexpected that has led to the largest nuclear disasters in our recent history. So I'm asking that the Atomic Safety and Licensing Board please take the necessary actions in assuring our safety. We are relying on your oversight and your guidance in safeguarding this affected concrete containment vessel that lies a mere 9-1/2 kilometers from this very spot,” Khan concluded.

Will the judges agree, and send NextEra back to the drawing board with their concrete-aging management plans? Or will a narrow legal interpretation, disregarding Dr. Saouma’s expert testimony—as well as the concerns of dozens of members of the public who spoke out in favor of a cautionary approach—win the day?

Time will tell. Hearing transcripts will be released and scrutinized in the coming weeks, and proposed findings by the parties are due on November 21. The judges anticipate they will deliver their ruling on the case in January or February of 2020.

Excerpt from opening statement by Attorney Diane Curran:

As C-10 recognized from the start, ASR poses significant risks to critical safety structures at Seabrook. These safety structures, including the containment enclosure building and the spent fuel storage pool, stand between the public and the radioactive materials in the nuclear plant. Not visible to the naked eye, ASR is called the cancer of concrete. It rots concrete from the inside, due to a pernicious reaction between the components of concrete and the factors of time, temperature, and relative humidity.

The biggest concern posed by ASR at Seabrook is this: if severe enough, ASR may weaken concrete safety structures to the point that they crack during an earthquake and release radiation to the environment. This would not be a freak earthquake of great magnitude, but an earthquake of the severity that can be expected on the New Hampshire seacoast and which Seabrook was designed to withstand. This is called the “design-basis earthquake.” Because of ASR, the assurances of safety to withstand a design basis earthquake that were given at the time Seabrook was built and licensed can no longer be trusted.

This license amendment proceeding is important to C-10 and the public because it is a key juncture when NextEra must reckon with ASR and prove to the NRC that Seabrook can safely operate in spite of ASR.

Now that the NRC has approved the renewal of Seabrook’s operating license, a moment of maximum accountability like this will not happen again. Unless something is done now to correct the serious problems with NextEra’s program for addressing ASR in the coming 30 years, any further action on ASR will be a matter of enforcement discretion by the NRC Staff—the same group that has signed off on the adequacy of NextEra’s program already.

Thus, this moment is crucially important to C-10 and the public. And we have used it to demonstrate, in the evidence we have presented, that NextEra’s assessment of the state of ASR in Seabrook concrete structures is grossly inadequate because NextEra has used simplistic methods to evaluate an extremely complex problem; and because the testing of concrete specimens that NextEra undertook to calibrate its proposed monitoring program was not representative of concrete at Seabrook. Therefore, NextEra has not met its burden of proving that its monitoring program is comprehensive or rigorous enough to detect and assess the progression of ASR over the next 30 years.

The NRC has no regulatory standards for ASR, nor is there any guidance for ASR in nuclear reactors. Instead of conducting a rigorous review that included peer review, the NRC Staff effectively delegated to NextEra its own responsibility for developing standards that would ensure the safety of Seabrook over the next 30 years, despite the presence of ASR.

C-10 is now providing the rigorous peer review that the NRC Staff should have obtained in the first place, and demonstrating through Dr. Saouma’s testimony that NextEra’s proposed standards for monitoring and evaluating ASR are fundamentally inadequate. It should not be the case that a member of the public must step in to provide the type of rigorous and independent analysis that the problem of ASR demands.

Watch videos from the hearing, including Attorney Curran’s closing testimony, here .

For links to recent news coverage, including by the Newburyport Daily News and N.H.Public Radio, click here.

September is Emergency Preparedness Month

Fri, 06 Sep 2019 00:00:00 GMT

Is living near a nuclear plant on your mind?

Disasters happen —sometimes natural, and sometimes man-made. Federal and state governments coordinate each September on National Emergency Preparedness Month to encourage people to think about and plan for what they would do in the event of all sorts of emergencies.

With hurricane season upon us, now is as good a time to consider what we would need, and need to do, in the event of an emergency like coastal flooding, a pandemic, or even (however unlikely), a nuclear accident.

Of all the possible types of disasters, the latter is one of the hardest to think about. C-10 operates an airborne radiological monitoring network for the Commonwealth of Massachusetts, so it’s our job to think about safety at Seabrook Station. But it’s important for all of us to be concerned with what it means to live near a nuclear reactor. So what can you do? Get educated, and get prepared.

Living Near Seabrook Nuclear Power Plant

Approximately 160,000 of us live within the 10-mile Emergency Planning Zone of Seabrook Station, and hundreds of thousands more in the plant’s 50-mile ingestion pathway. While nuclear plants are highly regulated, the possibility of an accident is always there, however small.

Living near a nuclear power plant poses a unique set of risks, and calls upon us to consider how we would prepare and react in the event of a radiological emergency. A serious accident could mean that we’d need to shelter in place, leave our homes and businesses indefinitely, or face long-term health consequences, depending on the level of exposure to harmful radiation.

So, where to begin? You can download a general emergency preparation checklist here , or find more information specific to nuclear power plants at Ready.gov . There's also great info on all types of emergency preparedness from Massachusetts here and New Hampshire, here .

As for those of us living near the nuclear plant, it's always a good idea to review the Emergency Public Information Calendar sent to Seabrook area residents, since it contains information on what to do in the event of an emergency order to evacuate or “shelter in place.” You can find more useful links on C-10's resources page .

Code Red is an alert notification system that states and communities use to communicate with people v ia text and email when there is an emergency. Seabrook owner NextEra Energy encourages people to sign up for alerts in the event of a radiological emergency by using this link: https://public.coderedweb.com/CNE/en-US/bf065f487535 .

If you are a business owner, you'll have special considerations, like : What if you can’t get to your physical location for a few days? How will you stay in touch with each other and clients? How will you ensure minimal revenue loss? Do you have backup copies of important documents and phone numbers? What special ways does your business need to prepare to be ready for anything?

According to Ready.gov, here are four key steps to prepare for emergencies:

Be Informed – Know what emergencies may occur and stay informed
Make A Plan – Plan for your family before an emergency
Build a Kit – Assemble an emergency kit
Get Involved – Volunteer opportunities in emergency preparedness and response

C-10 Research and Education Foundation works to protect public health and the natural environment surrounding Seabrook Station nuclear power plant. Find more resources about living near Seabrook and what it means for you at: c-10.org/living-near-seabrook-station .

Monitoring Cancer with a Stethoscope?

Wed, 28 Aug 2019 00:27:30 GMT

C-10's Concrete Expert Says Seabrook's Engineers Lack Expertise and Rely on Simplistic Techniques for a Complex Problem

The moment we’ve been preparing for over the last two and a half years is almost here: the federal hearing on how our nuclear neighbor Seabrook Station is monitoring and managing the problem of concrete suffering from so-called "concrete cancer."

On Friday August 23, ahead of the late September hearing before the Atomic Safety & Licensing Board (ASLB), a body of the U.S. Nuclear Regulatory Commission (NRC), C-10 filed final documents in the case relative to the handling of alkali-silica reaction (ASR) an irreversible type of concrete degradation impacting all key safety structures at the nuclear plant.

“ The Summary of Rebuttal Testimony of Victor E. Saouma, Ph.D Regarding Scientific Evaluation of NextEra’s Aging Management Program for Alkali-Silica Reaction at the Seabrook Nuclear Plant ,” is available here .

Key Points:

Dr. Saouma, C-10's witness and a world-leading expert in ASR, testified that scientific and engineering principles were not well applied in NextEra’s handling of ASR, noting that he has concerns about the lack of expertise of NextEra’s and the NRC’s staff witnesses in this proceeding.

Dr. Saouma drew an analogy between Seabrook’s core reactor containment enclosure building and a patient suffering from cancer. While modern cancer treatment includes specialists, advanced testing and monitoring, Dr. Saouma likened NextEra’s approach to general practitioners (engineers) using a stethoscope for simplistic observation.

“Despite their expertise to deal with common nuclear plant maladies, they lack the specialized expertise to make a sophisticated diagnosis or prognosis, to create an adequately informed treatment plan for monitoring the complex problem of ASR, or to analyze and respond appropriately to the monitoring approach,” Saouma wrote (p. 3 of summary ).

“NextEra effectively put on blinders to a wide range of available techniques and sources of outside expertise, choosing instead to take a code-based engineering approach that could only scratch at the problem. As a result, the basic safety of the population living within 10 miles of Seabrook cannot be reasonably assured,” Saouma wrote (p. 8 of summary ).

Our team has worked incredibly hard, and spent countless hours to make our case on behalf of the health and safety of Seabrook’s neighbors. We hope that interested members of the public, like YOU, will come out to witness the proceeding, and make your voice heard at a public comment session on September 23.

What’s Next:

Formal hearing, opportunity for public to observe -The Atomic Safety and Licensing Board is holding a hearing relative to concerns on Seabrook’s concrete beginning at 9:30 am on Tuesday, September 24 at Newburyport City Hall , 60 Pleasant Street, Newburyport, Mass. The Board anticipates that all day Tuesday will be open to the public, and that the morning of Wednesday, September 25 they will begin closed session to take up matters considered sensitive and proprietary. The hearing could last until Friday of that week.

Public Comment Session - On Monday, September 23 from 6-8 pm, there will be an opportunity for public comment, also at Newburyport City Hall. Members of the public are encouraged to sign up ahead of time (by Sept. 13) to speak, although they will also be able to sign up on site. Comments should be limited to five minutes. Full details on the hearing events and how to sign up to speak are on the Notice of Hearing, posted here .

Final ruling expected first quarter of 2020 - The process will culminate in a final ruling by the ASLB on C-10’s contention (described below). If, after the hearing, the Board determines that the license amendment should not have been granted, the amendment can be revoked or conditioned.

Background Information

In October 2017, the U.S. Nuclear Regulatory Commission’s Atomic Safety and Licensing Board admitted five of C-10’s contentions in a proceeding on NextEra’s License Amendment Request relative to the plant’s concrete troubles, a condition known as alkali-silica reaction (ASR). The Board admitted C-10 as a formal, legal intervenor in the case and reformulated five accepted contentions into a single contention:

The large-scale test program, undertaken for NextEra at the FSEL (a lab in Texas), has yielded data that are not “representative” of the progression of ASR at Seabrook. As a result, the proposed monitoring, acceptance criteria, and inspection intervals are not adequate.

C-10’s Expert and Counsel

Victor Saouma , Professor of civil and structural engineering at the University of Colorado, Boulder, is serving as C-10's expert witness in the case regarding Seabrook's concrete. Saouma's work centers on what he sees as flawed test results that affected the safety analysis underpinning NextEra Energy Seabrook's concrete aging management plans. One of the world’s leading experts on alkali-silica reaction (ASR), Saouma has studied its effects on nuclear reactors—in particular, how the containment structures could be weakened should an anticipated earthquake occur. Saouma has worked for decades on concrete structure and material properties, and has many peer-reviewed technical articles on topics regarding concrete degradation. Saouma has researched ASR at nuclear power plants under contract with the U.S Nuclear Regulatory Commission. C-10 is being represented by Diane Curran , the nationally-known environmental and nuclear safety attorney. She has called C-10’s case “very strong.”

Watch highlights of a talk by Saouma and Curran, here. Get more background on the case here .

Dystopia Here and Now

Tue, 27 Aug 2019 23:52:21 GMT

Rogue NRC Regulator Gregory Jaczko to Speak in Newbury on September 12

I don’t read much non-fiction; as a former English teacher, I love to lose myself in the fully-realized worlds created by good writers and to marvel at the creator’s skill. I only wish that Gregory Jaczko’s Confessions of a Rogue Nuclear Regulator were fiction—that the world he so convincingly details of an industry more interested in the bottom line than in human safety and of a Congress beholden to the power of that industry were a figment of his overactive imagination. Unfortunately, it is not. The world he depicts is all too true and often ignores impressive scientific evidence and, even, common sense.

Dr. Jaczko, a Ph.D. physicist, found himself in the unlikely role as a Nuclear Regulatory Commissioner (2005-09) after a series of political decisions took him from policymaker on the staff of (then) Congressman Edward J. Markey (D-MA) to the agency that is tasked with monitoring the nuclear energy industry. He then served as Chairman of the U.S. Nuclear Regulatory Commission from 2009-2012.

Having no previous ties to the industry, Dr. Jaczko approached his position as an objective scientist. And, as a scientist, he helped regulators deal with the Fukushima Daiichi disaster, traveling to the site and offering advice to Japanese and American officials.

During his tenure at the Commission, Dr. Jaczko also experienced first hand other concerning, though less publicized, plant breakdowns. He was so concerned about the safety of U.S. nuclear plants that he proposed a series of essential measures to increase their safety. When those measures came before the Commission, he learned, however, that science often gives way to political and financial imperatives. In his book, Dr. Jaczko reveals just how political pressure is brought to bear on commissioners and how they often succumb to the will of the nuclear industry.

If you want to read a political and science-based tell-all that is riveting—but more importantly—is both true and treats one of the most crucial issues of our time, Confessions of a Rogue Regulator is well worth the effort. Robert F. Kennedy, Jr., President of Waterkeeper Alliance, describes the book:

“The infuriating inside story of how a corrupt, outmoded, and inefficient nuclear industry maintains its market position against safer, more efficient forms of renewable energy by hoodwinking and corrupting Congress and co-opting the regulators.”

Dr. Jaczko sums up his own journey during his NRC years when he writes:

“I started by life as a scientist in awe of humans’ ability to see the genius of nature and harness it. I left my job as a nuclear regulator humbled at what nature can do to turn our technological inventions against us.”

Dr. Jaczko to Speak in Newbury, Mass. on September 12

Dr. Jaczko often speaks about his experiences and beliefs in hopes of educating others about what he has learned. Through the efforts of New Hampshire State Representative Peter Somssich and hosted by C-10, he is coming to our region and will speak at the First Parish Church of Newbury at 7 pm, September 12. Admission is free and copies of his book will be available. Details are on C-10’s events page, here.

NRC Uses Shoddy Science to “Manage” Concrete Degradation at Seabrook

Mon, 29 Jul 2019 19:54:08 GMT

Dr. Victor Saouma, a professor of civil and structural engineering at the University of Colorado Boulder, a foremost authority on concrete degradation caused by alkali-silica reaction (ASR), confirmed our worst fears at C-10’s Annual Public Meeting June 27: The US Nuclear Regulatory Commission (NRC) indeed is cutting corners with regard to managing the ongoing and irreversible concrete degradation from ASR at Seabrook Station. To use Dr. Saouma’s words, concrete degradation testing at Seabrook has been “inadequate,” leaving him “not sure” about the safety of Seabrook.

Dr. Saouma revealed how the recent ASR testing at the Ferguson Structural Engineering Lab, University of Texas at Austin (FSEL) relied on a concrete mix (aggregate and sand) that was not identical to the concrete mix poured at Seabrook. Thus, the concrete tested in Texas did not adequately represent Seabrook concrete, essentially rendering the data produced by the Texas study irrelevant for Seabrook. A “sophomoric approach” with “erroneous assumptions,” “essential tests omitted,” and “simplistic analysis,” according to Saouma.

Dr. Saouma also explained that because the progression of ASR is affected by temperature, an ASR study in Texas might not exhibit the same surface cracking and microscopic (internal) expansion as the ongoing ASR at Seabrook over a given time period. Dr. Saouma added that ASR testing at Seabrook has relied too heavily on surface observations of ASR (visible surface cracks), with insufficient data on internal degradation (subsurface expansion).

ASR reduces the shear strength of concrete structures and thus can greatly reduce seismic resistance of Seabrook nuclear power plant facilities. According to Saouma, “an earthquake will cause large shear stresses at the base [of structures], where most of the ASR occurs.”

Dr. Saouma, who insisted that his work as C-10’s technical expert be pro bono, pointed out that the FSEL study results were not even peer reviewed. Since the NRC permitted Seabrook’s owner, NextEra, to write the procedures for ASR safety assessment and monitoring, and since the ASR management plan developed by NextEra was based on the scientifically flawed Texas testing, with questionable (if not irrelevant) results, what confidence do we have that the ASR management plan can adequately ensure public safety? From what Dr. Saouma observed, little.

Dr. Saouma’s comments were alarming, both for the lack of scientific rigor by the NRC and that agency’s dearth of due diligence with regard to public safety. Seabrook is the first nuclear plant in the nation known to be affected by ASR concrete degradation. That the NRC acquiesced to the plant owner with regard to ASR management – and relicensed the facility more than ten years before its initial license expires and before hearing C-10's contentions about the inadequacy of the ASR testing – suggests that the NRC just might not be up to the task of managing concrete degradation resulting from ASR.

Dr. Saouma, who has spent years researching ASR,including a major study for the NRC, is working with C-10 to challenge the “representativeness” of the Texas testing before the NRC’s Atomic Safety and Licensing Board at a public hearing September.* In addition, C-10 is supported by attorney Diane Curran, a highly regarded litigator who has spent her career in nuclear safety and environmental ,and who has noted that the burden of proof of the effectiveness of the ASR management plan rests on Seabrook owner NextEra.

Dr. Saouma's key takeaways:

ASR is an extraordinarily complex problem, so requires a complex solution
Too much is at state to take shortcuts and jeopardize the safety of the public
Unless/until NRC takes steps to rectify, decision to re-license Seabrook with a substandard program for addressing ASR, this License Amendment Request may become a major stain on the reliability and credibility of the agency.
He would suggest that the affected parties:
- Perform adequate, state-of-the-art testing and analysis, including petrography, accelerated expansion tests, and finite element studies;
- Talk to HydroQuebec, as they are facing similar problems with ASR in dams;
- Learn more about the latest scientific literature on ASR; and,
- Ensure that independent peer review is performed

To learn more, see: C-10 Brings Legal Challenge to Seabrook's Concrete Testing and Monitoring and Seabrook's Concrete & Licensing Issues

*Please mark your calendar and plan to attend: NRC Atomic Safety and Licensing Board Hearing, September 24-27, Newburyport City Hall. Also, spread the word to friends and neighbors, consider writing letters to editors, and ask your elected officials to attend.

Dan Edson is a science writer and member of C-10's Advisory Board. He lives in Newburyport, Mass.

Seabrook Under Water?

Wed, 15 May 2019 17:40:03 GMT

As one of the most vulnerable nuclear plants in the nation, policymakers and nuclear plant operators need to take the risks of climate change very seriously

In late April, the U.S. Nuclear Regulatory Commission (NRC) held its annual safety meeting about Seabrook Station (see related blog here ). Because evacuation planning was on the agenda, it was not surprising that the topic of Seabrook’s vulnerability to the effects climate change was on people's minds.

Seabrook’s construction began in 1976, and although the plant was sited 20 feet above sea level and two miles inland, government projections show increasing risks for Seabrook and the surrounding coastal communities.

Current data from the National Oceanic and Atmospheric Administration (NOAA) shows how predicted sea level rise will reduce the planned buffer between Seabrook Station and the Atlantic Ocean (see map below). The Risk Finder tool provided by Climate Central shows that between 2016-2040, the risk of a flood of 5 feet or more (above the high tide line) is 54 percent in the Seabrook Beach area. By 2060, there is a 100 percent chance of such an event in the area. As sea waters rise, so does the high tide line, and risks of floods beyond current infrastructural capacity.

Similar risks were highlighted in the study “ Underwater ” released by the Union of Concerned Scientists (UCS) in 2018. Focusing on the impacts of sea level across the United States, their scientific data tells a story of chronic flooding along the eastern shore board. Area towns like Salisbury, Seabrook, Hampton and Newburyport will face frequent inundation as average sea levels rise. Along with private property, critical infrastructure across the nation such as roads, airports, power plants, and military bases will be constantly at risk of flooding and water damage.

Lessons from Fukushima

The 2011 disaster at the Fukushima-Daiichi power plant in Japan awoke the world to the dangers of nuclear power by the ocean. Although nuclear power plants are designed to need vast amounts of water for cooling, their location along coasts and rivers exposes them to risks of flooding, caused by rainfall, storms and tides.

After Fukushima, nuclear regulators and operators around the globe took an assessment of their risk exposure. In the U.S., the event prompted the Nuclear Regulatory Commission to undertake a study which revealed that 54 out of 60 nuclear power plants were not prepared to handle the flood risk they faced.

When Hurricane Sandy hit the Northeast U.S. in 2012, nuclear power plants in its path shut down as a preventative measure against water damage and power shortages like those which rocked Fukushima. In the superstorm’s aftermath, a Stanford University study surveyed the risks faced by coastal nuclear plants. The results revealed that Seabrook Station, located in coastal New Hampshire, is among the nation’s most vulnerable.

A recent article in Bloomberg Businessweek illustrated the connection between nuclear power plant safety risks identified by NRC operators in 2011 and the environmental risks to American communities identified in the UCS’s 2018 study. Their model shows that Seabrook Station faces the risk of an average of at least two floods a month by 2060.

How Sea Level Threatens Seabrook

The increased exposure to high sea levels at Seabrook Station pose at least four risks:

Higher ground water levels surrounding the plant could exacerbate the problem of alkali-silica reaction ( ASR ) that is undermining the concrete in all key safety structures at the plant, including the core reactor dome and the spent fuel pool;
High tides from increasingly severe storm surges create a risk of acute flooding, the kind which led to the Fukushima power shortage, and subsequent nuclear meltdown;
Flooding in the event of such a storm could block low-lying evacuation routes that emergency planners depend upon to get people away from the area in the event of a serious radiological release; and finally,
Once Seabrook Station enters its decommissioning phase, radioactive materials stored on site for “cooling,” remain vulnerable, and pose an ongoing risk to the surrounding ecosystem.

Despite these possibilities, the consideration of storm surges and flooding are conspicuously absent from plant owner NextEra Energy’s re-licensing documents. Despite mounting evidence of the risks posed by sea level rise along the northeastern coastline, the environmental report for renewal prepared by NextEra issues does little to address concerns such as flooding, sea level rise, storm surge or climate change.

Already, Seabrook and surrounding towns experience significant flood events with increasing frequency, particularly when Nor’easters hit. These are a test of preparedness and ability to manage risk.

The disaster at Fukushima was a result of natural hazards colliding with poor planning for structural resilience and safety. When flooding from the tsunami stopped the power supply which kept water pumping into the nuclear reactor’s core, the core overheated and proceeded to melt through its container, releasing radiation into the environment. Better planning for the unexpected could have saved countless lives and untold decades of environmental harm

Heads in the Sand?

Given the previous acknowledgement by the plant’s operators of the impending risks posed by climate change in the area, this indicates two serious points of concern: first, an apparent reluctance of the plant operators to consider all of the environmental hazards which might impair its ability to operate a high risk facility safely, and second, lack of regulatory attention to the potential for contamination of wetlands, groundwater, ocean water, and other risks posed by the potential for more frequent inundation awaiting Seabrook Station.

To address the potential threats posed by climate change, the NRC should require the types of measures recommended by NRC’s Near Term Task Force after the Fukushima accident, in order to ensure the safety of reactor communities, not weaken proposed regulations as the NRC commissioners did in January.

“This decision is nonsensical,” Commissioner Jeff Baran wrote in his dissent of the weak standards. “Instead of requiring nuclear power plants to be prepared for the actual flooding and earthquake hazards that could occur at their sites, NRC will allow them to be prepared only for the old, outdated hazards typically calculated decades ago when the science of seismology and hydrology was far less advanced than it is today,” he wrote.

Commissioner Stephen Burns added: “The accident at Fukushima was a direct result of the operator and regulator failing to take action to account for new scientific knowledge related to natural hazards, especially flooding hazards. . . . In the United States, there exists incontrovertible evidence that the current design bases for some plants do not address a flood hazard identified by the licensees’ [plant operators’] own analyses.”

Policy Leadership & Citizen Vigilance Needed

In addition to the type of federal leadership lacking under the current administration, policymakers at the local and state level must take their own steps to ensure that infrastructure development as well as evacuation plans include an assessment of climate change scenarios—especially of more severe and frequent storms and floods.

Federal regulations for nuclear plants need to catch up with the reality of climate change that is already upon us. In the absence of such vision and leadership, it falls to the vigilance of the citizens, and the work of state and local governments, to try to prepare and protect vulnerable communities and natural resources, as best they can.

Many Words, Few Answers: No Surprise from NRC at Seabrook Safety Meeting

Wed, 08 May 2019 18:16:07 GMT

Hiding behind bureaucracy, panel was well-rehearsed in art of the side-step

There is an art to answering a question without really answering it at all, and that well-honed talent was on display the evening of Wednesday, April 24 in Hampton, N.H., at the government's annual safety review of Seabrook Station.

U.S. Nuclear Regulatory Commission (NRC) and Federal Emergency Management Agency (FEMA) officials listened respectfully to public comments and responded by quoting NRC's "NUREG" regulations and reciting evacuation planning guidelines.

As for the operational safety of Seabrook, we were told during a brief presentation that over the past year, few concerns were discovered, those concerns were minor, and that basically, we should all go to bed and snuggle down for a long spring’s nap.

I’ve attended several of these NRC meetings over the years. Once again, a lack of specifics, naive expectations, and downright denial — or perhaps ignorance — of our changing climate by the federal representatives sent to reassure us made for an uneasy rest for me that Wednesday night. Here are some “highlights” of the evening:

When asked by a member of the audience why the NRC approved Seabrook’s request for a license extension and an amendment to its current license before questions about the plant's degraded concrete are fully vetted by NRC's Atomic Safety and Licensing Board, Jimi Yerokun, Director of NRC’s Division of Reactor Safety replied essentially that they'd followed the NRC regulations for licensing, and well, there was no reason not to move forward.

We were assured that no cracking in the concrete was visible in many areas of the plant so therefore it was safe, although anyone who has studied alkali-silica reaction (ASR) knows that it can originate deep within concrete and be invisible to the eye.

Interestingly, many audience members brought up the question of why NRC pushed through a license extension for Seabrook to operate to 2050 before the resolution of C-10's hearing on the plant's degraded concrete, which is scheduled to be held locally the week of September 23. Nope, still no good answers there — however the NRC was clearly anticipating dialog on the topic; they had copies of this nifty fact sheet on Seabrook licensing, ASR and C-10's hearing.

When asked by another member of the audience if a plan existed to deal with the spent fuel generated by another 20 years of operation, considering that all current spent fuel must be kept on site until or unless a national storage plan is developed, NRC struggled to answer.

Eventually, someone on the panel stammered that the NRC was working to develop a solution. Of course, we know that despite decades of work and billions of dollars, there remains no viable “solution” to dealing with nuclear waste for tens of thousands of years.

When asked if the NRC knew the estimates for rising sea levels in the not too distant future, no one on the panel had an answer—even though some in the audience were aware that National Oceanic and Atmospheric Administration (NOAA) prediction models exist (See related blog on Sea Level Rise ).

When asked whether the Seabrook plant was designed to withstand a tsunami, we were told by by NRC project manager Justin Poole that it was designed for hurricanes. Oh darn.

NRC Senior Resident Inspector Paul Cataldo stated that its concrete protection would be impervious. But, as experts know, ASR degrades concrete and worsens over time, and is fed by the presence of moisture.

John Stevens of Gloucester, Mass. asked whether built into the economics of the nuclear plant were the costs of the storage of radioactive materials for 10,000 or more years. For a moment, the panelists' mouths hung open.

Perhaps these government employees would realize they had no good answer, and admit as much. But no—somehow they found a way to fill the airspace, and just kept talking. It was almost laughable, except that the subject at hand is deadly serious.

We were told there is a fund to cover some costs, but, of course, Congress would appropriate any money that might be needed. For 10,000 years? Does the NRC live in the same country I do?

Approximately 160,000 people live in Seabrook’s 10-mile evacuation zone. Maura Healey, Attorney General of Massachusetts, asked that FEMA participate in the meeting in order to address concerns about evacuation. “What if roads flood?” I asked in a one-to one with Patricia Milligan, Senior Level Advisor with NRC’s Division of Preparedness and Response after the meeting. We will find alternate routes was her answer. Where? The Atlantic Ocean is on one side and all of the roads leading to Route 95 are minor and subject to flooding.

I also asked Ms. Milligan whether she believed that bus drivers would come from outside of the area (yes, this is part of the plan) to help with evacuation. She assured me that people are always heroic in these situations. They will run towards a problem, not away. Really?

Well, I think we need to run towards some of the problems I see right now and refuse to allow the NRC to cede all decision making to nuclear plant owners.

Christopher Flavelle and Jeremy C. F. Lin wrote in their April 2019 Bloomberg Businessweek article: U.S. Nuclear Power Plants Weren’t Built for Climate Change that by 2060, New Hampshire’s coastline is expected to flood twice a month, according to the Union of Concerned Scientists.

The nuclear industry stows generators, pumps and other equipment on-site in concrete bunkers to keep electricity flowing to prevent a meltdown in case of power outages. Yet in January 2019, the NRC ruled that plants do not need to update materials and eliminated requirements for drills.

Gregory B. Jaczko, former NRC commissioner and Chair of the NRC 2009-2012), assessed the industry’s reaction to the Fukushima meltdown: “Any work done following Fukushima is for naught because the Commission rejected any binding agreement to use that work. It is like studying the safety of seat belts and then not making automakers put them in the cars.”

As an aside, check out Jaczko’s chilling new expose: “ Confessions of a Rogue Nuclear Regulator ,” for a glimpse of the entanglement and control that nuclear industry wields over the NRC and Congress.

The NRC has long done the industry’s bidding. It allows the plants to conduct their own estimates of flood risks and what assumptions to make, such as rainfall and wind speed. It rejected a proposal by its own staff that as climate changed progressed, updates of assumptions were needed.

What can we do? Lives are crowded with responsibilities and must-dos. That is why C-10 is so worthy of support. Each of us may not be able to read all that is published about the nuclear industry, but C-10 is paying attention. The average person is not equipped to monitor radiation in real-time, but C-10 does, 24-7.

If you are outraged at the state of nuclear regulation and concerned about the safety of nuclear plants—especially in the face of climate change—I’m with you. Now, if you’d like to do something about it, instead of just shake your head in despair, I hope you’ll join me and support C-10’s critical work on behalf of the safety of Seabrook’s neighbors. CLICK HERE to give online.

Karen Clagett is a Newburyport resident and member of C-10's Board of Directors.

Upcoming Event: C-10’s Concrete Expert to Speak on June 27

Dr. Victor Saouma, an expert in alkali-silica reaction (ASR), will speak at the Annual Public Meeting of C-10 on Thursday, June 27 at 7 pm at the Newburyport Public Library. Dr. Saouma is C-10’s technical expert in the case before NRC’s Atomic Safety and Licensing Board about concrete degradation at Seabrook. That hearing will be held locally and is set for the week of September 23. Save the dates, and stay tuned for details. Please follow C-10 on Facebook or on our events page at C-10.org .

Legal Maneuvering in Concrete Case

Mon, 06 May 2019 15:42:44 GMT

C-10 Responds to NextEra’s Attempt to Restrict Scope in case on Seabrook's Degraded Concrete

C-10 Research and Education Foundation (C-10) has filed a response to plant owner NextEra’s legal motion to prohibit testimony from C-10, challenging key portions of the group’s contentions on the ability of the plant’s degraded concrete to protect the public.

"NextEra is trying to do all they can to cut the legs out from under us even before this hearing starts,” said Natalie Hildt Treat, C-10’s executive director. “That goes to show how seriously they are taking this case, and thus the true merits of the contentions we have filed,” said Treat.

C-10 is preparing for a public hearing to be held locally the week of September 23. Our written testimony is due on June 10, yet our group has been forced to expend resources responding to what it sees as a baseless and insupportable legal move from NextEra.

As C-10’s May 3 filing describes, this proceeding concerns C-10’s admitted contentions regarding NextEra’s proposed measures for monitoring ASR at the Seabrook nuclear power plant. Those monitoring measures are part of the “methodology” conceived by NextEra to assess the relatively recently-discovered phenomenon of ASR. Because of its novelty, ASR is not addressed by applicable industry codes for assessing the safety of concrete reactor structures.

By its motion, NextEra is attempting to “exclude from the record all testimony and portions of exhibits offered for the purpose of challenging the Structure Deformation Monitoring portion of NextEra’s License Amendment Request No. 16-03 (‘LAR’).” NextEra also seeks to exclude testimony and exhibits regarding the “finite element analysis” employed by NextEra in its evaluation of ASR.

“NextEra has failed to show a ‘compelling need’ to pre-emptively exclude any testimony relating to finite element analysis at this early point in the proceeding—before any testimony has been filed, let alone a hearing conducted,” wrote C-10’s attorney Diane Curran, an expert in nuclear regulatory issues with the Washington, D.C. based firm Harmon, Curran, Spielberg and Eisenberg, LLP.

Citing precedent-setting cases that have come before the ASLB, Curran wrote that “NextEra’s Motion should be denied because it is based on an oversimplification and mischaracterization of C-10’s contentions and could improperly exclude relevant evidence.”

"Seabrook is the only nuclear power plant in the country where ASR has been identified—which does not mean it's the only plant where it exists," said Christopher Nord, C-10 board member who is leading the group’s legal challenge. "Their methods deserve public scrutiny. The outcome of this case could affect the lives of Maine, New Hampshire and Massachusetts residents for decades to come," Nord said.

"I'm concerned about what I have read about the tests that have been conducted, and how they were used in subsequent safety assessment analysis. I have also concerns about what appears to be simplistic safety assessment procedures for such a complex and new program, and that the test results have not been independently verified," said Dr. Victor Saouma, C-10’s technical expert.

Upcoming Event: Dr. Saouma, Professor of civil and structural engineering at the University of Colorado, Boulder, will deliver the keynote address at C-10’s Annual Public Meeting on June 27 at 7 pm at the Newburyport Public Library.

BACKGROUND INFORMATION

About alkali-silica reaction (ASR) at Seabrook

deteriorating concrete at the plant, which has been operating since 1991. Citing serious safety concerns with the concrete and flaws in the concrete testing and monitoring methodologies, C-10 sought intervenor status in the NRC docket. A public adjudicated hearing is expected in July 2019. C-10 had alleged in its April 2017 petition to the NRC that the testing was inadequate and not representative of actual conditions at Seabrook, and that if the concrete failed and resulted in a radiological release, its monitoring operations, its members, and the public at large could face grave danger. For more information, see this C-10 fact sheet on ASR and Seabrook.

About Victor Saouma, Ph.D., C-10’s Expert Witness
Victor Saouma , Professor of civil and structural engineering at the University of Colorado, Boulder, is serving as C-10's expert witness in the case regarding Seabrook's concrete. Saouma's work centers on what he sees as flawed test results that affected the safety analysis underpinning NextEra Energy Seabrook's concrete aging management plans. A nationally-recognized expert on alkali aggregate reaction (AAR, or in the case of Seabrook, ASR) Saouma has studied its effects on nuclear reactors—in particular, how the containment structures could be weakened should an anticipated earthquake occur. Saouma has worked for decades on concrete structure and material properties, and has many peer-reviewed technical articles on topics regarding concrete degradation. Saouma has researched ASR at nuclear power plants under contract with the U.S Nuclear Regulatory Commission.

Extending the operating license of a decades old nuclear plant is big news.

Thu, 18 Apr 2019 00:00:00 GMT

It is disappointing, though not surprising, that the NRC chose to push forward and grant both the license amendment request and the license extension for Seabrook Station (on March 11 and March 12, 2019), before serious questions about the nuclear plant's degraded concrete get a full public vetting.

The Commission has said it will allow Seabrook to operate for up to thirty more years, without a reasonable assurance that its structures meet its own requirements for safety during an earthquake.

In so doing, NRC has shown disregard for the concerns of numerous citizens, elected officials, and the Massachusetts Attorney General, who had urged them to delay rulings until after the Atomic Safety and Licensing Board hears from C-10 and Dr. Victor Saouma, an internationally-recognized expert in concrete and the problem of alkali-silica reaction (ASR) that has weakened Seabrook's structures.

The Nuclear Regulatory Commission (NRC) says that C-10 will still get our public hearing on the concrete problems this summer.

Following are quotes of note in these news developments:

"There is no reason why the Seabrook license amendment should be approved before the hearing (on degraded concrete) occurs... public safety could be threatened by a premature approval of the license amendment" if C-10's concerns about Seabrook are not priorly heard. - Sen. Markey, Sen. Warren, and Rep. Moulton wrote to the Nuclear Regulatory Commission in a letter dated January 16, 2019.

"Because NextEra’s license amendment request has been hidden from scrutiny behind the veil of ‘proprietary’ status granted by the NRC, the only truly independent peer review will be provided through C-10’s participation in this proceeding” -C-10 board member Chris Nord.

“There simply is no reason for the NRC staff to act on the amendment or license extension requests at this time. NextEra’s existing license does not expire until March 15, 2030 — eleven years from today." -Massachusetts Attorney General Maura Healey.

"In my expert opinion, the manner in which the NRC Staff reviewed and accepted NextEra’s testing and analysis programs was so devoid of scientific rigor or independence as to fatally undermine the credibility of its determinations regarding the safety of continuing to operate Seabrook in the presence of ASR." - Dr. Victor Saouma, University of Colorado, Boulder

“Our organization remains laser focused on exposing the scientific and regulatory shortcomings of this process, and we are committed to working on behalf of public safety.” - C-10 Executive Director Natalie Hildt Treat.

Some recent news coverage relative to Seabrook's license & C-10 :

WBUR: Supporters Say Seabrook Nuke Protects Climate; Critics Worry About Cracks In The Concrete

Newburyport News: Village talk focuses on C-10, nuclear plant

Newburyport News: NRC sets September hearing date for C-10's filing

Lawrence Eagle Tribune: NRC grants license to Seabrook Station

SeacoastOnline: NRC Approves Seabrook's License Extension

Boston Globe - Nuclear Regulators to Extend Seabrook's License to 2050

Engineering News-Record: Citizens' Group Files Petition Over Concrete Degradation at Seabrook Nuclear Station

Keene Sentinel - NRC defends Seabrook's license extension

Newburyport Daily News: Concerns, support voiced at crowded NRC meeting

Boston Globe: With concrete degrading in critical parts of Seabrook, environmental advocates urge to delay renewal of license

Portsmouth Herald: Seabrook license extension delayed

NHPR: Regulators will take more public input

Newburyport Daily News: NRC delays Seabrook Station license renewal decision

MassLive: Feds agree to delay relicensing of Seabrook Station

Newburyport News: Lawmakers oppose NRC's plan to extend Seabrook license by Jan. 30

MassLive: Massachusetts lawmakers seek delay in Seabrook, New Hampshire, nuclear plant license renewal

NHPR: Regulators To Allow Seabrook Nuclear Plant To Run Through 2050

SeacoastOnline: Seabrook nuclear plant set to receive 20-year extension

Got KI?

Wed, 13 Mar 2019 18:56:06 GMT

The government gives free tablets in case of nuclear emergency.

Seabrook Station, the nuclear power plant that sits on the New Hampshire salt marsh about seven miles from my home, has been granted a renewed operating license until 2050.

Though there are many people working to ensure that the unthinkable doesn’t happen, the possibility of a nuclear accident is a reality that Seabrook’s neighbors live with every day, like it or not.

The emergency calendar I recently received in the mail prompted me to do something I had been putting off: getting the potassium iodide tablets that I heard we’re supposed to take in the event of a significant radiation release at the plant.

So, on my walk home from the YWCA a few weeks ago, I decided to stop by Newburyport City Hall to get the tablets that I’d heard were available there for free. I asked the friendly person who greets everyone as they walk in where I could find the tablets. No luck there. She was very confused about what I was asking.

I headed to the basement because I had seen a sign for the Health Department down there when I had dropped off dead batteries for recycling. I found a person there who was speechless—not from what I was asking—but from a cold. She gave me four tablets, two each for my husband and me and a little brochure called Planning for a Seabrook Station Emergency.

I asked, “What would happen if I had guests over?” But I knew it was just a rhetorical question. The tablets are provided for residents only. When I asked when we were supposed to take the tablets, she pointed to the word “emergency” on the brochure. Actually, you should not take the tablets unless you are directed to do so by authorities when an event occurs.

The tablets, which are known as "KI,” are intended to reduce the risk of developing thyroid cancer when a person has been exposed to high levels of radioactive iodine. The level of risk from a release depends on the amount of radioactive iodine that has been released and the age of the affected individual. Infants and children under the age of 18 are most at risk due to their rapidly-dividing cells, and their risk increases the more radiation is released.

The risk for adults—particularly adults over the age of 40—is apparently lower. According to my research, adults over the age of 40 don’t need to take the tablets unless there is a very large release. But authorities may not know the size of a release and may simply advise everyone to take KI.

Anyone over the age of three can take the tablets whole or crushed, but those under the age of three must take the tablets crushed and mixed with a liquid. Parents are told to prepare the liquid ahead of time and keep it in the refrigerator. But it only keeps a week so you would have to do that weekly. Hmmm...

KI should be taken as soon as possible after you are told to take it so receiving prompt notice of a radiation emergency is essential. Anyone in the 10-mile emergency planning zone should sign up to receive notices of emergencies at this link . In the event of an emergency at the Seabrook Station nuclear power plant, you will be notified whether to evacuate or shelter in place and whether to take KI.

Residents in the 10-mile zone can get KI without charge. If you live in Massachusetts, you can get it from your local health department. In New Hampshire, the Radiological Health office of the Division of Public Health makes it available by application here .

Although KI is generally safe to take, it may cause adverse reactions in people with existing thyroid conditions and those who may be allergic to iodine or shellfish. Anyone in those categories should check with their doctor about the advisability of taking KI in an emergency.

Health departments in all the Massachusetts communities in the 10-mile radius have a supply of KI tablets available to residents, thanks to state and federal support. Though I know the risk of a nuclear disaster at Seabrook is small, going through this exercise was sobering. It made me very grateful that there is an organization such as C-10 looking out for the interests of everyone living near the plant. Through their network that monitors radiological emissions, research, and public education, C-10 makes living near a nuclear power plant a little less scary.

For more information and links about emergency planning and living near Seabrook Station, you can visit C-10’s Resources page.

Editor's note: C-10 is delighted that Pat Torkildson joined our board of directors in April 2019, after almost a year of serving as a volunteer. Welcome, Pat!

Disregarding public input, NRC renews Seabrook's license til 2050

Tue, 12 Mar 2019 19:09:32 GMT

C-10 remains focused on concrete hearing this summer

On March 12, 2019, a day after granting NextEra Energy Seabrook the license amendment request relative to the plant's concrete aging management plans, the U.S. Nuclear Regulatory Commission issued a renewed facility operating license for Seabrook Station to keep splitting atoms until midnight on March 15, 2050.

C-10 Executive Director Natalie Hildt Treat issued the following statement in response to the licensing action:

It is disappointing, though not surprising, that the NRC chose to push forward and grant both the license amendment request and the license extension for Seabrook Station, before serious questions about the nuclear plant's degraded concrete get a full public vetting.

The Commission has said it will allow Seabrook to operate for up to thirty more years, without a reasonable assurance that its structures meet its own requirements for safety during an earthquake.

In a filing to the NRC dated March 1, 2019 Dr. Saouma stated that: "In my expert opinion, the manner in which the NRC Staff reviewed and accepted NextEra’s testing and analysis programs was so devoid of scientific rigor or independence as to fatally undermine the credibility of its determinations regarding the safety of continuing to operate Seabrook in the presence of ASR."

These licensing actions don't deter C-10's preparation for the public hearing we anticipate in late summer. Our organization remains laser-focused on exposing the scientific and regulatory short-comings of this process, and we are committed to working on behalf of public safety.

On the anniversary of Fukushima, NRC to renew Seabrook license

Mon, 11 Mar 2019 16:20:16 GMT

The irony is not lost on safety advocates

March 11 was the date eight years ago that the earthquake, tsunami and subsequent nuclear disaster struck Fukushima.

It also the day that the U.S. Nuclear Regulatory Commission recently announced it would grant a License Amendment Request to Seabrook Station, in support of the plant's concrete aging management plans. Tomorrow, on March 12, 2019, NRC has said it will grant a 20-year license extension for the plant to be allowed to operate until 2050.

Over the weekend, the office of Massachusetts Attorney General Maura Healey wrote the NRC , urging the Commission "to preclude NRC Staff from acting on NextEra Energy Seabrook’s (NextEra) requests for a license amendment and twenty-year extension of its existing operating license prior to issuance of a final decision in the upcoming adjudicatory hearing before the Atomic Safety and Licensing Board (Licensing Board) on concrete degradation at the plant."

Healey noted that " A decision to act on either request prior to a final adjudication of that matter would constitute an affront to the public interest and undermine public trust in the NRC’s ability to protect public health and safety."

As reported by the Boston Globe on March 6: U.S. Senator Edward J. Markey, a Massachusetts Democrat, said the commission’s decision, made before a planned hearing this summer, “is a subversion of the public input process and is unnecessarily premature.”

“Seabrook’s license will not expire for another 11 years,” said Markey in a statement. “All parties involved can afford to wait and hear out the safety concerns raised by local residents before any amendment or relicensing decisions are made.”

C-10 recently filed an emergency petition with the NRC, asking the commissioners to reverse a finding that Seabrook's concrete aging management plans pose no significant hazards, and for them to suspend the planned decisions on Seabrook's license amendment request and license renewal application until after the full resolution of contentions we will bring before NRC's Atomic Safety and Licensing Board later this year.

“NRC staff has been intent on pushing this through all along,” C-10's Executive Director Natalie Hildt Treat told the Globe. “They’re choosing to disregard C-10’s emergency petition despite its merits, because it doesn’t fit neatly into their regulatory model.”

Patricia Skibbee, president of C-10's Board of Directors, said that the “whole process has been bankrupt, in that the NRC allowed NextEra, the plant’s owner, to hire and pay for its own private consultants.”

Regardless of whether the NRC commissioners choose to intervene, C-10 remains focused on preparing for the hearing on the plant's degraded concrete. We are grateful to the public officials and citizens who have spoken in favor of a cautious approach to regulating Seabrook Station, the first nuclear plant in the nation known to suffer from the irreversible concrete degradation known as " ASR ."

Want to support C-10? Please consider making a contribution, right now . Thank you!

ACTION ALERT: Seabrook Licensing

Sat, 23 Feb 2019 18:41:12 GMT

Tell NRC: No changes to Seabrook’s license until concrete degradation gets independent review

In January, the U.S. Nuclear Regulatory Commission (NRC) was poised to sign off on plans for NextEra Energy Seabrook to manage the plant’s degraded concrete, granting a License Amendment Request (LAR) relative to the alkali-silica reaction (ASR) affecting concrete in all key safety structures at Seabrook Station.

They were also ready to award a twenty-year license extension for Seabrook to operate until 2050.

One problem : Seabrook is the first nuclear reactor in the nation known to be suffering from this irreversible concrete condition . While feelings about nuclear power are strong on all sides, there’s no escaping the fact that federal regulators have never dealt with “concrete cancer” as ASR is known, and that’s why this case deserves extra caution.

So, with 11 more years on its current license, why not take a go-slow approach? C-10 has been preparing for a public hearing we were granted by NRC’s Atomic Safety and Licensing Board, where we’ll challenge the scientific underpinnings of the concrete testing methodology.

Members of Congress from New Hampshire and Massachusetts have asked NRC to wait until after the hearing later this year, and the full resolution of the concerns C-10’s experts will bring.

On February 13, while an NRC panel heard public comments on Seabrook’s license in a Hampton, N.H. hotel ballroom, C-10 had just filed an emergency petition with agency asking them to hold the phone.

This filing is unusual enough that the timing of a response from the Commissioners is unclear. However, it is clear that both NextEra and NRC staff want the license extension granted without further delay. Your action is needed urgently!

Personal letters from affected citizens could help to persuade the Commissioners that regular people do care enough about what happens with Seabrook that they will take the time to write.

C-10 has been working on the LAR litigation for two years, and we’ve learned more than we care to about the concrete meant to protect the public from the most toxic stuff on earth.

Will you take a moment and write to the NRC Commissioners, and send copies to your U.S. representatives?
More information on our homepage.

Sample letter to the NRC: Please delay action on Seabrook’s License

Dear Chairman Svinicki and NRC Commissioners:

As a neighbor to Seabrook Station nuclear power plant, I am writing to urge you to seriously consider the Emergency Petition filed by C-10 on February 13, and to take no further action on the requested license amendment or extension until the full resolution of the contentions brought by C-10 relative to the plant’s degraded concrete.

C-10 has raised serious concerns about the ability of Seabrook's concrete to continue protecting the public, and the inadequacy of the testing and analysis that underpin Seabrook's concrete aging management plans. C-10 is preparing for a hearing granted by NRC’s Atomic Safety and Licensing Board, where they will provide the only independent peer review of the concrete testing methodology behind the plant’s license amendment request, which is based on a completely unprecedented approach to monitoring and managing alkali-silica reaction at a nuclear reactor.

The seriousness of this matter demands more caution, independent review and transparency than it has received. With 11 more years on Seabrook’s current operating license, there is time for the NRC to do it right. Please permit the democratic process to proceed. While NRC representatives have stated that C-10 will get their hearing later this year, we urge you to wait on any rulings relative to the plant's license amendment request, or license extension, until C-10's contentions are heard and evaluated by the ASLB. On behalf of my family, thank you.

Sincerely,

-----------

Send your letters to: Kristine L. Svinicki, Chairman, U.S. Nuclear Regulatory Commission Chairman@nrc.gov

Send this letter to your Members of Congress at the links below:

New Hampshire Delegation

Congressman Chris Pappas

Senator Margaret W. Hassan

Senator Jeanne Shaheen

Massachusetts Delegation

Congressman Seth Moulton

Senator Edward J. Markey

Senator Elizabeth Warren

Or look up your own member to call or write:

U.S. Senate

U.S. House of Representatives

While citizens spoke out on Seabrook's license, C-10 filed emergency petition with NRC

Thu, 14 Feb 2019 16:51:51 GMT

Will NRC press ahead with license extension for aging nuclear plant?

The US Nuclear Regulatory Commission hosted a special meeting last night at the Best Western Plus in Hampton, N.H. for the public to speak out about whether Seabrook Station nuclear power plant's operating license should be extended in light of the ongoing problems with the plant's degraded concrete.

The room was packed, especially with dozens of union employees from the plant, attesting to many people who earn their livelihoods at Seabrook. NRC spokesman Joe Donahue opened by saying "NRC concedes we could've done a better job communicating with the public, and that's why we're here tonight."

Staffers from several Members of Congress were in attendance, many speaking in favor of a go-slow approach on licensing action until after C-10's hearing. There were a number of people who spoke in favor of Seabrook or nuclear power generally, raising issues such as jobs, climate concerns, etc.

There were about as many concerned citizens who asked the NRC tough questions about safety, voiced their worries about the aging plant, nuclear waste and sea level rise, and urged them not to grant a license extension before C-10 has a public hearing where they will formally bring contentions relative to the plant's concrete.

When NRC was pressed about why they appear to be in a hurry to do the licensing actions, they said that they are not, but they are indicated they still plan to move forward, "because we can." Donahue said, "I'm not going to stand here and tell you there's an urgency to it."

Just as the meeting was getting underway, C-10's legal counsel was busy filing an emergency petition with the NRC , asking the commissioners to reverse a finding that Seabrook's concrete aging management plans pose no significant hazards, and for them to suspend the planned decisions on Seabrook's license amendment request and license renewal application. The timing on an NRC response to the petition is unknown.

C-10 is not relying on the NRC to be swayed by the pleadings of concerned citizens and Members of Congress to delay licensing action until after our hearing on the plant's degraded concrete. Still, we hope that what they heard last night, along with the emergency enforcement petition we filled with the NRC commissioners, will cause the agency to reconsider their previously announced course of action and look seriously at the issues that we have raised.

Read written testimony from Chris Nord, here . Watch a video of the hearing here (Courtesy of SAPL).

For more background, see Nord's recent blog post about C-10's involvement in Seabrook's license amendment request relative to its degraded concrete.

NH legislature to hear bill on radiological monitoring

Mon, 04 Feb 2019 17:44:22 GMT

Hearing on Senate Bill 181 is Thursday, February 7 at 1:30 pm

A bill requiring the monitoring of certain radioactive air pollutants would require the state of New Hampshire to develop an airborne radiological monitoring network in the communities surrounding Seabrook Station nuclear power plant in coastal New Hampshire. The bill is being heard before the Senate Committee on Health and Human Services in room 101 of the Legislative Office Building in Concord.

This is not the first time New Hampshire legislators have sought funding to create a monitoring network analogous to the one that provides an extra level of comfort for Massachusetts residents. SB-181 has State Senator Tom Sherman, a physician from Rye, N.H. as its lead sponsor. Sherman is also chair of the Committee on Health and Human Services.

Full bill text with sponsors is here
Committee calendar is here

While the bill doesn't mention the monitoring network that C-10 Research and Education Foundation has operated on behalf of the Commonwealth of Massachusetts since 1993, C-10 Executive Director Natalie Hildt Treat will attend the hearing to answer questions about how C-10 monitors gamma and beta radiation as well as wind-speed and direction. This information helps state health officials track and understand permitted radiological releases, and could also be used to help emergency officials protect the public in the event of an unplanned release or accident. The public is invited to attend this hearing.

Democracy and public safety? Yes please.

Mon, 04 Feb 2019 16:50:57 GMT

Lawmakers push NRC for transparency and caution in light of failing concrete at Seabrook nuclear plant

What C-10 seeks from the NRC is a proper and fair redress of our grievances—through a fair hearing of our contentions opposing the license amendment request, before NRC rules on it, or the license extension. What we seek from the NRC is doable; it is logical; and it is democratic. For a federal agency charged with the protection of public health and safety, this is the reasonable way forward.

The staff of the U.S. Nuclear Regulatory Commission had announced that before the end of January 2019, they would move to extend the Seabrook Station atomic plant’s operating license by 20 years, to 2050—this, in the face of a serious problem with degrading concrete at the plant.

They would be able to do so only by first approving the License Amendment Request ( LAR ), filed in 2016 by Seabrook owner NextEra Energy for “aging management” of the condition known as alkali-silica reaction (ASR)—the same matter that C-10 is preparing to oppose in a formal hearing next summer, before the NRC’s Atomic Safety and Licensing Board (ASLB).

C-10 got involved in this case because we have grave concerns about the ability of Seabrook’s concrete to continue protecting the public as designed. We believe that the matter is complex and new enough that it deserves extra scrutiny, with independent scientific review of the testing methodology that underpins NextEra’s plans to manage the concrete. While Seabrook is the first U.S. commercial reactor known to be suffering from ASR, its presence was a factor in the closure of plants in Canada, Belgium and France. No federal guidelines yet exist as to how to manage this condition at nuclear plants.

Because Massachusetts and New Hampshire Members of Congress spoke up, and spoke emphatically, for C-10’s right to have its contentions addressed and resolved before NRC rules on the LAR, these actions were delayed—for the time being. For this reprieve, we are grateful to Senators Markey, Warren, Hassan, and Shaheen, and Congressmen Moulton and Pappas.

What the NRC has committed to is a public meeting to be held in Hampton, N.H. on February 13, after which they have stated they are free to continue with these rulings. Although a new opportunity for the public to learn about and comment on these two licensing proceedings and the issue of Seabrook’s degraded concrete, this meeting should not give a pass to NRC staff to ignore the hearing for which C-10 is preparing, and it doesn’t satisfy the requests of the federal delegations who represent those living and working near this aging reactor.

C-10 has worked for the right to present our case in opposition to NextEra’s LAR since early 2017. Five of our original ten contentions were accepted by the ASLB in October of that year, reformulated as a single contention that:

“The large-scale test program, undertaken for NextEra at the FSEL (lab in at University of Texas, Austin), has yielded data that are not ‘representative’ of the progression of ASR at Seabrook. As a result, the proposed monitoring, acceptance criteria, and inspection intervals are not adequate.”

Since then, C-10 volunteers have expended many hundreds of hours studying technical documents, developing our strategy, securing expert witnesses to support our case, and raising money to enable this expert testimony and legal consulting. C-10 and our congressional representatives want our case concluded before NRC grants either the license amendment request, or a license extension.

One the one hand, the branch of the NRC that oversees issues regarding current operating licenses—the ASLB—moves toward the proper adjudication of C-10’s opposition to the license amendment request. Concurrently, another branch of the NRC is asserting its authority to rule on Seabrook’s license extension—which, coincidently , requires a prior ruling on the same LAR that we have legal standing to oppose, but for which we will not get to make our case for another six months!

Members of Congress who share our concerns for public safety are trying to resolve this conundrum by calling on the NRC to allow C-10 to carry its case to conclusion before any ruling on either the LAR, or the license extension, is made. However, all that NRC has promised is a public meeting. This does not begin to address their contradictory actions that threaten to undermine the effectiveness of C-10’s case.

While this kind of treatment, on the part of a federal agency, effectively usurps the democratic process that should be available to its citizens, in the case of the NRC it is not unprecedented. In the late 1980s, all six towns in Massachusetts within the 10-mile Emergency Planning Zone voted—after thorough study by official committees within each town— to reject the evacuation plans formulated to handle an emergency at Seabrook.

As a result, then-Governor Dukakis refused to sign the plans for the Commonwealth; and the Region 1 head of the Federal Emergency Management Agency (FEMA), Ed Thomas declared that he could not adopt Massachusetts’ Emergency Response Plans (ERP’s)—a requirement for completion of Seabrook’s licensing process. NRC stepped in, making two quick changes to their own rules: first, they allowed a completed reactor to start up to 5% power—so-called “low power test”—without any emergency response plans in place; and second, they allowed the ownership of a given reactor (Public Service Company of New Hampshire at the time) to submit ERP’s in lieu of a state government.

At the same time, Ed Thomas was removed from his position at FEMA. Seabrook was powered up; Public Service submitted their evacuation plans for the Commonwealth; the new FEMA Region 1 chief signed off; and the NRC granted the 40-year license. This was done over the heads of a majority of towns within the two states, who through use of a democratic process, determined their opposition to the evacuation plans offered to them.

Perhaps this time, citizens and their congressional officials can speak loudly enough, effectively enough, that we can prevent a repeat of this kind of treatment. What C-10 seeks from the NRC is a proper and fair redress of our grievances—through a fair hearing of our contentions opposing the license amendment request, before NRC rules on it, or the license extension. What we seek from the NRC is doable; it is logical; and it is democratic. For a federal agency charged with the protection of public health and safety, this is the reasonable way forward.

Christopher Nord is a resident of Newbury, Mass. and serves as chair of C-10’s LAR working group.

NRC taps the brakes on Seabrook relicensing

Wed, 23 Jan 2019 18:24:26 GMT

After Congressional input, NRC Staff will meet with public

"We are about monitoring the safety of Seabrook. We have been working on this issue nonstop since 2010." - founding board member Christopher Nord regarding C-10's focus on the plant's degraded concrete.

C-10 Research and Education Foundation (C-10) reacted to a January 22 letter from the U.S. Nuclear Regulatory Commission (NRC) stating that it will not grant Seabrook Station a license amendment request relative to the plant's degraded concrete, or issue the 20-year license extension that was originally planned for the end of this month, until the public has a chance to weigh in. No meeting date has yet been announced.

“C-10 is pleased that the NRC will slow down the process and meet with the public,” said Natalie Hildt Treat, C-10’s executive director. “We would like to think that with eleven more years on the plant’s current operating license, they can afford to wait a few more months for the hearing C-10 was granted relative the ability of Seabrook’s concrete to continue protecting the public as designed,” Treat said.

The delay came after separate letters to NRC Chairman Kristine L. Svinicki from U.S. Senator Edward Markey, U.S. Senator Elizabeth Warren and Congressman Seth Moulton of Massachusetts , and from U.S. Senator Maggie Hassan, U.S. Senator Jeanne Shaheen, and Congressman Chris Pappas of New Hampshire , urging NRC to reconsider its timeline.

"There is no reason why the Seabrook license amendment should be approved before the hearing (on degraded concrete) occurs,” Sen. Markey, Sen. Warren, and Rep. Moulton wrote to Svinicki on January 18.

On January 15, NRC had announced plans to move quickly to amend and extend the license of the plant, despite an ongoing proceeding before the NRC’s Atomic Safety and Licensing Board (ASLB) relative to Seabrook’s degraded concrete.

In a letter to the ASLB’s administrative judges, NRC Staff Attorney Jeremy Wachutka informed the Board that on or about January 22, 2019, NRC staff will approve the license amendment request (LAR) that Seabrook owner NextEra Energy filed in 2016 as a result of the serious, irreversible problem called alkali-silica reaction that is impacting the plant’s concrete in all key safety structures.

Wachutka also stated that NRC Director of Office of Nuclear Reactor Regulation Ho Nieh plans to issue a renewed operating license for Seabrook, on or about January 30, 2019. NextEra Energy Seabrook LLC filed an application to renew the plant’s license on June 1, 2010. The plant is currently licensed to operate until 2030, and is seeking a twenty-year extension. Seabrook, like many nuclear power plants, was originally designed for a 40-year life-span.

As intervenors in the case regarding Seabrook’s concrete and its current operating license, C-10 has been working to support its contentions at a public hearing before the NRC’s Atomic Safety and Licensing Board, which NRC states is still expected to be held in summer of 2019.

"Seabrook is the only nuclear power plant in the country where ASR has been identified -- which does not mean it's the only plant where it exists," Nord said. "Their methods deserve public scrutiny."

Background on alkali-silica reaction (ASR) at Seabrook

In 2016, NextEra submitted a license amendment request in recognition of its being out of design basis due to ASR-compromised concrete. In October 2017, C-10 Research & Education Foundation was granted standing in a case being considered by the U.S. Nuclear Regulatory Commission’s Atomic Safety and Licensing Board. C-10 disputes the merits of NextEra’s methods to mitigate the significant risk caused by ASR. NextEra Energy Seabrook LLC’s pending license amendment request is relative to the deteriorating concrete at the plant, which has been operating since 1991. Citing serious safety concerns with the concrete and flaws in the concrete testing and monitoring methodologies, C-10 sought intervenor status in the NRC docket. A public adjudicated hearing is expected in July 2019. C-10 had alleged in its April 2017 petition to the NRC that the testing was inadequate and not representative of actual conditions at Seabrook, and that if the concrete failed and resulted in a radiological release, its monitoring operations, its members, and the public at large could face grave danger. For more information, see this C-10 fact sheet on ASR and Seabrook.

C-10 reacts to news that Seabrook license extension appears imminent

Tue, 15 Jan 2019 19:36:01 GMT

C-10 Research and Education Foundation (C-10) received notification on January 14 that the U.S. Nuclear Regulatory Commission (NRC) plans to move quickly to amend and extend the license of the plant, despite an ongoing proceeding before the NRC’s Atomic Safety and Licensing Board (ASLB) relative to Seabrook’s degraded concrete.

In a letter to the ASLB’s administrative judges , NRC Staff Attorney Jeremy Wachutka informed the Board that on or about January 22, 2019, NRC staff will approve the license amendment request (LAR) that Seabrook owner NextEra Energy filed in 2016 as a result of the serious, irreversible problem called alkali-silica reaction that is impacting the plant’s concrete in all key safety structures.

“For the NRC to grant the license amendment—and then approve a license extension out to 2050—before the public hearing that the ASLB granted on the concrete—is just crazy,” said Natalie Hildt Treat, executive director of C-10. “What’s the hurry? Seabrook still has 11 more years on its current operating license. We believe these action could undermine the safety of the American citizens that NRC is charged with protecting,” Treat said.

“The unprecedented concrete testing and monitoring methodologies that underpin the license amendment request should be subject to independent peer review prior to their adoption,” said Chris Nord, C-10 board member and resident of Newbury, Mass. “This is not just good science, but in the case of the deteriorating concrete at Seabrook, this is essential to ensure public safety. Because NextEra’s LAR has been hidden from scrutiny behind the veil of ‘proprietary’ status granted by the NRC, the only truly independent peer review will be provided through C-10’s participation in this proceeding,” said Nord.

“While this state of affairs is maddening, for the NRC and Seabrook it is not unprecedented,” said Nord. “Thirty years ago, the six Massachusetts towns within the 10-mile evacuation zone unanimously voted to reject the proposed Emergency Response Plan (ERP) as unfeasible. As a result, the Commonwealth of Massachusetts refused to sign off on the plans, and the licensing process for Seabrook was halted. NRC’s response was to issue of change in their regulations: first, to allow the Seabrook reactor to start up without the plans in place—so-called “Low-Power Test;” and second, to allow the plant’s owner (then Public Service Company of New Hampshire) to submit an ERP in lieu of state submission. The licensing process was efficiently concluded—by leaving out the will of the people who must live with this reactor,” said Nord.

C-10 recently engaged Professor Victor Saouma of the University of Colorado, Boulder—a structural engineer who is also an expert in the problem of ASR at nuclear plants—to assess results of the concrete testing, as well as the assumptions put forth by NextEra and the NRC.

“We are working on behalf of our members, and for the health and safety of all who live and work near Seabrook. We will continue to do this work,” Treat said.

Background on alkali-silica reaction (ASR) at Seabrook
In 2016, NextEra submitted a license amendment request in recognition of its being out of design basis due to ASR-compromised concrete. In October 2017, C-10 Research & Education Foundation was granted standing in a case being considered by the U.S. Nuclear Regulatory Commission’s Atomic Safety and Licensing Board. C-10 disputes the merits of NextEra’s methods to mitigate the significant risk caused by ASR. NextEra Energy Seabrook LLC’s pending license amendment request is relative to the deteriorating concrete at the plant, which has been operating since 1991.

Citing serious safety concerns with the concrete and flaws in the concrete testing and monitoring methodologies, C-10 sought intervenor status in the NRC docket. A public adjudicated hearing is expected in July 2019. C-10 had alleged in its April 2017 petition to the NRC that the testing was inadequate and not representative of actual conditions at Seabrook, and that if the concrete failed and resulted in a radiological release, its monitoring operations, its members, and the public at large could face grave danger. For more information, see this C-10 fact sheet on ASR and Seabrook.

C-10 president disputes coverage of nuclear plant study

Tue, 08 Jan 2019 16:11:26 GMT

As printed in the Newburyport Daily News on January 8, 2019 :

To the editor:

This letter is written in response to The Daily News article of Dec. 19 on the continuing operation of the Seabrook nuclear power plant.

The article needs clarification/ further explanation. The headline – “Study: Plant can operate” – is misleading. The article states that the Advisory Committee on Reactor Safety (ACRS) completed an “independent study” to address concrete degradation of the plant buildings.

This makes it sounds as though the ACRS actually studied the 26 buildings of the plant. It did not. The ACRS is a purely advisory committee to the Nuclear Regulatory Commission (NRC), the body that is actually empowered to make decisions on nuclear power plants.

What the ACRS did was issue a letter commenting on the written proposal for monitoring the concrete degradation, a proposal submitted by NextEra, Seabrook’s owners and operators. The letter was written after the ACRS held a meeting in Maryland on the proposal. The letter to which The Daily News refers is the response of the ACRS to NextEra’s proposal. It is in no way an “independent study.” The Seabrook nuclear power plant was licensed for 40 years of operation in 1990; that license expires in 11 years, in 2030. NextEra has now requested a license extension of 20 more years; if granted, the alreadydegraded plant would be able to continue in operation until 2050, a total of 60 years for a plant that was admittedly designed to last 30 to 40 years.

The concrete-damaging alkali-silica reaction (ASR) was discovered in 2009. In 2010. NextEra applied for a license extension. In publicly available documents as early as 2012, concrete scientists consulted by NextEra stated in a number of documents that the plant was still strong enough to continue in operation “for an interim period.”

That phrase has never been defined; however, I believe no common sense interpretation would call 31 more years an “interim period.” Is even the 11 years left of the current

license an “interim period?”

The newspaper article quoted Peter Robbins, a communications director for NextEra as saying “... ASR is a well-understood and manageable condition.” In fact, Seabrook is the first and only nuclear power plant in the United States to suffer from ASR.

ASR is an ongoing chemical reaction; it can be monitored, but it cannot be stopped or repaired. Our group, C-10, which has been monitoring the plant since shortly after it went online, has been admitted as the only formal intervenor in the license amendment request legal proceeding, which specifically addresses the proposed procedure for monitoring the ongoing ASR damage.

A hearing is scheduled for sometime after June 2019. It is our understanding that the NRC will not make a final decision until after that hearing.

To access public information on all aspects of this complex situation, go to ADAMS docket #50-443; also www.ADAMS.nrc . gov; also ML16216A240. Note that much of the information is marked “proprietary,” meaning that it is withheld from the public.

PATRICIA L. SKIBBEE West Newbury

The letter writer is president of the C-10 board of directors.

N.H. Public Radio: Nuclear Advisory Group Endorses Seabrook's Plan To Monitor Concrete Cracks

Sat, 05 Jan 2019 18:26:36 GMT

As New Hampshire Public Radio reported on December 18 :

An independent group of scientists says they believe the concrete cracks at Seabrook Nuclear Power Plant are under control.

The report from the Advisory Committee on Reactor Safeguards agrees with earlier findings from the Nuclear Regulatory Commission.

The groups conclude that Seabrook's owner, NextEra, has a sufficient plan in place to monitor changes in and effects from the cracks over time.

"We concur with the staff conclusion that, while some of the structures are degraded, they are fully capable of performing their credited function through the requested PEO [period of extended operation] under the committed enhanced monitoring and evaluations," the advisory committee writes in its report .

The concrete cracks, caused by a chemical reaction known as ASR, were first found nearly a decade ago. Seabrook is the only plant in the country known to have this problem.

NextEra wants to extend its license to operate the plant through 2050. But activists say the cracks and other potential hazards mean it should close .

“The fact remains that ASR is a progressive, irreversible condition that is degrading concrete throughout important safety structures at Seabrook," says C-10 Foundation executive director Natalie Hildt Treat in a statement. "No one really knows how bad it is — or will get — and while it is being monitored, there is no ‘cure’ for ASR.”

C-10 will participate in hearings on the license renewal next summer. The reactor safeguards advisory committee will also issue a report on the renewal request "sometime in the near future," the NRC says.

Seabrook will be one of two nuclear plants left in New England after next year, when Pilgrim Station in Massachusetts is set to close.

Why is the NRC in such a hurry to grant a license extension for Seabrook?

Mon, 19 Nov 2018 18:21:21 GMT

Navigating a flawed process, while concrete continues to degrade

C-10 Research and Education Foundation (C-10), a Newburyport, Mass. nonprofit, is the only intervenor in a federal proceeding regarding concrete degradation at the Seabrook Station nuclear plant in coastal New Hampshire. We were also also the only citizens group to comment at a recent meeting of the Advisory Committee on Reactor Safeguards ( ACRS ), an independent body of experts convened by the U.S. Nuclear Regulatory Commission (NRC) in Rockville, Maryland on October 31.

The ACRS met to discuss plans to manage the serious problem of failing concrete at Seabrook, and implications for the plant’s existing license, as well as its request for a 20-year license extension. C-10 board member Chris Nord traveled to Rockville to represent us in this important meeting. Other participants included NextEra Energy Seabrook, LLC and their engineering consultants, MPR Associates and Simpson, Gumpertz & Heger, as well as members of the NRC’s Office of Nuclear Reactor Regulation.

BUREAUCRACY VS. DEMOCRACY

“The overwhelming impression for me was the bureaucratic bias built into the NRC’s process, to protect and ensure final approval of the license extension for Seabrook,” said Nord, a resident of Newbury, Mass. As is illustrated in NRC’s timeline the agency separates the License Amendment Request (LAR ) proceeding on Seabrook’s concrete from the track on the plant’s License Renewal Application ( LRA ), which seeks to extend the existing license from 2030 to 2050.

“While this in itself may seem legitimate—since the LAR is treated as part of the current license—one can see that the crucial ACRS meeting, and the final version of the NRC’s Safety Evaluation regarding the plant’s concrete aging management plan (expected in December), take place far earlier than the public hearing on the License Amendment Request, which is slated for next summer,” noted Nord.

“So, while members of the ACRS—many of whom admitted having no real expertise in concrete structural science—asked their prepared questions for which NextEra had its ready answers, C-10 is still many months away from being able to support our contentions relative to LAR with the testimony of our expert witnesses,” said Nord.

“The result of this skewed process is that the NRC will effectively minimize the impact of our concerns with the LAR—even though the legitimacy of the LAR should have direct bearing on Seabrook’s merit for license extension. And since the independent experts we shall bring into the LAR argument represent the only truly independent peer review of the testing and modeling of the concrete, it seems all the more wrong-headed to judge the qualification of Seabrook for a license extension before C-10 can have our day in court at next year’s public hearing,” Nord concluded.

LISTENING IN...

"l listened to the meeting for the better part of ten hours,” said C-10 board member Diane Teed, of West Newbury, Mass. “I was extremely proud and grateful that Chris made the trip—not only on behalf of C-10, but also in the interest of all the people impacted by operations at Seabrook Station nuclear power plant.”

According to those from C-10 who called in to the meeting, it was a day full of engineering details and self-congratulating by NextEra and the NRC over their establishment of a plan to manage alkali-silica reaction ( ASR )—not only in the near-term, but over the proposed extended license period until 2050. Testimony included discussions of building deformation, large cracking, and the impact of ASR on structural integrity that could reduce margins of safety.

“Chris raised specific concerns to the Advisory Committee, including the lack of representativeness of testing conducted by NextEra at the Ferguson Structural Engineering Laboratory at the University of Texas at Austin (FSEL) versus actual conditions at Seabrook, the lack of peer review of test results, and by asserting that the term ‘reasonable assurance’ is a woefully inadequate standard in protecting citizens from exposure to some of the most toxic substances on earth," Teed commented.

AND DOING OUR HOMEWORK

The nexus of the research and analysis that C-10 is currently conducting on the plant’s License Amendment Request (LAR) and the recent ACRS hearing on the License Renewal Application (LRA) is alkali-silica reaction—a progressive, irreversible type of concrete degradation impacting safety structures throughout the Seabrook property. Both pending requests to NRC are heavily reliant on the results of tests at the Texas lab conducted in 2012.

C-10 has been researching ASR since 2010, soon after the problem was disclosed by Seabrook owner NextEra. We switched to high gear upon being granted intervenor status by the NRC’s Atomic Safety and Licensing Board (ASLB) on October 6, 2017 as a result of contentions we filed in April of that year. We argued that the public is placed at serious risk by allowing NextEra to continue to operate Seabrook Station with no way to adequately remedy the plant's deteriorating concrete.

“Our preparation has entailed literally thousands of hours of work. Within the past 13 months, we have enlisted a trusted team that has entered into non-disclosure agreements in order to analyze proprietary documents from NextEra and the NRC. We have held meetings to establish our strategy, read expert opinions, researched and interviewed technical experts,” explained Teed.

C-10 recently engaged Professor Victor Saouma of the University of Colorado, Boulder—a structural engineer who is also an expert in the problem of ASR at nuclear plants—to assess results of the FSEL testing, as well as the assumptions put forth by NextEra and the NRC.

TO WORK FOR YOUR SAFETY

“You may wonder, ‘what can a citizens group do against a well-financed corporation with nuclear engineering credentials?’” said Teed. Her answer: “We can do plenty. C-10's mission is to protect the safety of citizens and the environment near Seabrook Station. To that end, we are working tirelessly for you.”

“We sacrifice time with our families and volunteer our time because we recognize the importance of this endeavor. We can’t not do this,” said Teed. “We are proud of the knowledge we have built, and that we already have expert support for key elements of our arguments against the representativeness of the testing that underpins Seabrook’s License Amendment Request.”

The NRC has repeatedly promised—in writing—to local officials throughout the plant’s 10-mile emergency planning zone that "NextEra will also need to clearly establish that the results of its large-scale test program are representative of actual conditions at Seabrook." (emphasis added).

“We believe our standards on this issue exceed those held by the NRC. We will continue our fight for the public's safety,” said Teed. Read C-10’s written comments to the Advisory Committee on Reactor Safeguards here .

Nuclear power and our climate challenge

Sat, 17 Nov 2018 17:17:03 GMT

While UCS emphasizes role of nuclear, C-10 calls out safety concerns

The Boston Globe recently editorialized about a report from the Union of Concerned Scientists on the role of nuclear power and climate change. While the Globe amplified the UCS position that nuclear plants are an important part of our nation’s energy mix, the editors downplayed safety concerns where UCS, C-10 and other groups continue to sound the alarm—faulty engineering, the vulnerability of coastal plants to storm surge, toxic waste storage, and requests for license extensions beyond design life.

The Globe editorial omitted the fact that Seabrook Station—the nuclear plant that has operated in coastal New Hampshire since 1991—faces a serious concrete problem known as alkali-silica reaction, one that contributed to the shuttering of reactors in Canada and Belgium. It is the first U.S. reactor with this progressive, irreversible condition.

Interestingly, after the report was released, UCS Research Director Steve Clemmer walked back support for continued operation of Seabrook, saying that if plant did run into financial trouble, his group "would not support subsidies for it unless the concrete degradation problems were addressed."

It’s the role of groups like UCS and C-10 to ensure that government acts in the public interest—through strong safety regulations and future-looking policies—and to shine a light on the troubling issues that industry would rather keep hidden; including the life-cycle environmental costs of nuclear power.

According to some estimates, at least six times as much C02 will be released per kilowatt of electricity generated at nuclear plants than at electricity from wind facilities—and twice as much as power from photovoltaic facilities. Analysis by Dr. Benjamin Sovocool, Director of Energy Policy at the University of Sussex, England found that for every $100 spent on new nuclear construction instead of renewable technologies, a ton of extra carbon will be emitted to the atmosphere.

While nuclear promoters like to tout the lack of carbon emissions during generation, there are several steps in the nuclear fuel cycle that are frequently not considered: mining, milling, conversion of fuel, enriching the uranium, producing, transporting, storing and disposing of fuel are conveniently overlooked to make the argument that nuclear energy is clean energy, with “zero-carbon emissions.”

When it comes to the risks of nuclear power versus renewable resources, there is no contest. “If it were even close to being so safe, the U.S. would not be spending billions of dollars looking for, but not yet finding, a geological repository that can isolate this hazardous material from people and the environment for at least 10,000 years into the future,” said David Lochbaum, former Director of Nuclear Safety at the Union of Concerned Scientists.

The absence of federal leadership to address our climate and energy challenges is deeply troubling. The Trump Administration has abdicated this responsibility, stymied efforts to transition to a clean energy economy based on efficiency, storage, and renewables, and is seeking to roll back regulatory oversight meant to protect us from harm. In this vacuum, states and NGOs must step up.

C-10 believes that a well-considered set of policies must place a premium on safety—in the present, and for future generations who will inherit a fraught legacy based on fossil fuels and nuclear power. Governments should also help reactor communities develop transition plans to assist workers and local economies once plants are decommissioned. Eventually, that will be the fate of most reactors, government intervention, or not.

Increased awareness needed with nuke plant nearby

Wed, 03 Oct 2018 15:51:37 GMT

Letter to the editor in the Newburyport Daily News - 9/28/18

Each September, federal and state agencies encourage people to plan for what they would do in the event of an emergency — natural or man-made.

While we don’t have to worry much about volcanoes or massive wildfires, we do face risks, including coastal storms and flooding, and we share our home with an aging nuclear power plant.

Living near Seabrook Station calls on all of us to consider the possibility — however small — of an accidental radiological release, and how we would react were the unthinkable to happen.

Since 1991, C-10 Research and Education Foundation has been working to protect public health and the natural environment surrounding Seabrook Station. We’ve compiled a general emergency preparation checklist and resources relative to living near Seabrook at C-10.org .

Aside from making a plan and stockpiling supplies for our own families, we should also be asking tough questions about what plant operators and federal regulators are doing to keep our communities safe from an accident that could be caused — or exacerbated by — severe weather, earthquake or other act of nature.

After the 2011 tsunami and subsequent accident at Fukushima, the world’s coastal nuclear plants installed more powerful pumps, upgraded power supplies, and installed waterproof doors and movable flood barriers to protect against catastrophic flooding that could knock out electrical systems, disable cooling mechanisms and potentially lead to a dangerous release of radioactivity. But are such steps enough?

Researchers from Stanford University determined that Seabrook Station is one of four nuclear plants in the U.S. deemed to be at high risk from coastal flooding. Seabrook is located two miles inland, and was constructed 20 feet above sea level.

Yet in the environmental report required with its 2012 application to renew the plant’s original 40-year operating license 20 more years to 2050, NextEra Energy Seabrook LLC made no specific mention of rising sea levels, or how the plant is prepared to handle increased storm surge or other climate change-related challenges. On behalf of our members, C-10 thinks we deserve to know more.

Seabrook is suffering from an irreversible type of concrete degradation known as alkali-silica reaction that has implications for its current operating license and its pending renewal request. The threat of severe weather is something that all coastal residents must live with and prepare for. A nuclear power plant is one more thing for us to think about during Emergency Preparedness Month, and all year long.

Natalie Hildt Treat

Executive Director

C-10 Research & Education Foundation, Inc.

Continue to the Newburport Daily News website

Storm Surge

Wed, 19 Sep 2018 15:42:18 GMT

What are nuclear power plants doing to address threats from severe weather?

With hurricane season upon us and the Brunswick nuclear plant in North Carolina seriously impacted by flooding from Florence, experts and neighbors to the world's nuclear reactors are again looking at the increased risks posed by what were once called "500-year storms."

Since the accident at Fukushima, (pictured above), the world's coastal nuclear plants have installed more powerful pumps, upgraded power supplies, and installed waterproof doors and movable flood barriers. But is it enough?

According to researchers from Stanford University , Seabrook Station is one of four nuclear plants in the US deemed to be at high risk from coastal flooding. Seabrook is located just 2 miles inland, and was constructed 20 feet above sea level.

As John Vidal writes for Ensia, "Flooding can be catastrophic to a nuclear power plant because it can knock out its electrical systems, disabling its cooling mechanisms and leading to overheating and possible meltdown and a dangerous release of radioactivity. Flooding at the Fukushima Daiichi plant in Japan as a result of the March 2011 tsunami caused severe damage to several of the plant’s reactors and only narrowly avoided a catastrophic release of radioactivity that could have forced the evacuation of 50 million people." Continue Reading Vidal's article

Nuclear Waste: Coming soon to a community near you?

Tue, 18 Sep 2018 15:11:21 GMT

The Citizens Awareness Network (CAN) wants you to think about proposed plans to move tons of nuclear waste around the nation via roads, rails and waterways, so they are staging a tour of a "mock" nuclear waste cask. CAN is a regional environmental group based in Western Massachusetts concerned about the health, environmental and social justice implications of the nuclear industry. The following is from CAN's website:

Although the nuclear industry & federal government committed to create a solution for high level nuclear waste (HLW) disposal, no acceptable solution exists. Federal legislation mandated a repository; Nevada was targeted—billions expended to establish Yucca Mountain. As the wrangling over Yucca continues, the industry has a pressing need to create some solution since dangerous waste piling up at reactor sites undermines its position that nuclear is clean and safe.

Interim storage sites do not have to meet the strict environmental standards that have plagued Yucca Mountain. The sites targeted for “disposal” like the sites selected for operation, are routinely low income, rural, people of color and Native American communities. The industry pits nuclear communities against each other; reactor communities fear inadequate casks, lack of onsite protections and HLW abandonment by the Feds. Targeted communities for nuclear waste disposal don’t want dangerous nuclear waste in their backyard, particularly given the abysmal record of leaks and inadequate environmental protections. Waste communities face unconscionable choices-short term economic survival or long-term health and safety.

It is essential that reactor and waste communities work together to create effective strategies and actions to defeat industry initiatives to target vulnerable communities and provide protections for reactor communities forced to be guardians of the world’s most toxic and long-lasting waste.

Click here for more information on fall dates and locations of the tour, which organizers plan to bring to the Seabrook area next spring.

Learning While Contributing

Wed, 05 Sep 2018 18:50:20 GMT

My Summer Internship with C-10

Editor's note: C-10 is grateful to have had another terrific summer intern: Lydia Umholtz—a West Newbury, Mass. native now back for her sophomore year at Smith College. While we miss her already, we are eager to connect with another local student or volunteer to help around the office. If you know someone who might be interested in gaining experience and contributing to C-10’s mission, please send them our way! More at c-10.org . Here’s Lydia in her own words about the experience at C-10.

I’m glad to have had the opportunity to work with C-10 this summer and learn more about what the organization does. Environmental science and policy is an interest I’m pursuing at Smith College, and one of the reasons I was interested to apply for an internship.

While at C-10, I worked on many different projects from tidying up the member database to organizing archiving press clippings. I got to sit in on a board meeting and fundraising workshop where I learned about how nonprofits communicate their goals effectively.

From working in the office and talking to Executive Director Natalie Hildt Treat, I learned a lot of valuable information about how organizations operate, and I’m inspired by what I have seen at C-10 in terms of the level independence room for creativity a small nonprofit has to offer.

I also had the opportunity to learn a little bit about the radiological monitoring stations and alert system that C-10 runs. C-10 is responsible for keeping an eye on the levels of radiation in the air and submitting monthly reports to the Massachusetts Department of Public Health, their contracting agency. Having a monitoring network run a by citizens group with priorities built solely around public health and the natural environment is something I see as an essential check on a privately owned nuclear power plant.

In both research and education, C-10 is doing important work for the public. I’m thankful for the chance to work with C-10, and I encourage anyone looking for an internship or volunteer opportunity to reach out and learn more about the organization.

Is the NRC Paving the Way for Seabrook's License Extension?

Tue, 14 Aug 2018 20:37:51 GMT

Concrete Aging Management Program Gets (Partial) Green Light

It appears that another hurdle has been crossed in NextEra’s effort to keep Seabrook Station online for decades longer than it was designed for, with very little light shed on what is actually happening deep inside the plant’s concrete structures.

You may have heard of this pesky little problem of degraded concrete at Seabrook nuclear power plant. You know, water infiltration, cracks, that kind of stuff. It's called alkali-silica reaction (ASR), or "concrete cancer." ASR is the reason Seabrook owner NextEra Energy had to request an amendment to its existing operating license, to prove that it has things under control.

But the US Nuclear Regulatory Commission (NRC) also has to consider ASR and any other safety concerns when evaluating the plant's application to extend its operating license all the way to 2050.

Now, one would hope that the NRC wants to be able to assure the public beyond the shadow of a doubt that it has a complete handle on such a serious problem as degraded concrete in a nuclear power plant, before it grants such an extension. Seabrook is the first commercial reactor in the country known to have ASR, after all.

On August 13, the Northeast regional branch of the NRC issued a report after inspection of these concrete problems as part of Seabrook’s License Renewal Application (LRA) process. In summary, the report states that:

“The inspection results support the conclusion that there is reasonable assurance that the effects of aging due to ASR in the Seabrook systems, structures, and components will be managed through implementation of these programs as described in the application for a renewed license currently under review by the NRC Office of Nuclear Reactor Regulation.”

Does this mean a green light for Seabrook’s concrete “aging management program?” Not exactly. C-10 spoke with NRC project manager Justin Poole for some clarification on a couple of things.

To recap, there are two important license issues underway at Seabrook: the License Amendment Request (LAR), required because Seabrook’s original design didn’t account for how well ASR-plagued concrete would continue to hold up, and the License Renewal Application.

The renewal application was submitted way back in 2010—a full twenty years before its current 40-year license is set to expire. And oh by the way, this was right around the time the concrete degradation was discovered. Hmmm. The License Amendment Request came in 2016, after a period of testing and modeling, partly at a lab in Texas.

So aside from what the Region 1 Branch said about how NextEra is handling ASR, the folks down at NRC’s headquarters in Rockville, Md. also have to complete a Safety Evaluation Review regarding ASR —for both the LAR (present license), and the LRA (extension request). Are you still with me? Wow.

C-10 has challenged the underpinnings of NextEra’s License Amendment Request, believing that the testing and modeling completed to date is not adequate or representative of what’s actually happening on the New Hampshire salt marsh.

We want to know more, and we think the public deserves full assurance with strong scientific underpinning. The NRC’s Atomic Safety and Licensing Board agreed that our contentions have merit to be explored before the license amendment is granted, and that we have standing in this case.

As we await a public hearing slated for next spring, we are closely watching progress on the License Renewal Application as well. Poole said that while he can’t speak for the NRC, he doesn’t think that the renewal will be ruled on before things are complete with the License Amendment Request.

What’s next? Two ASR-related safety reviews are expected from NRC staff by the end of September, ahead of an October 31 meeting of the NRC’s Advisory Committee on Reactor Safety. Each a step in NextEra's request for amendment—and extension—of Seabrook’s operating license.

As always, C-10 will be watching, and listening, on your behalf.

Welcome New Board Members!

Thu, 09 Aug 2018 14:19:02 GMT

Local women bring experience and talents to C-10

Members of the C-10 board of directors are not your typical board members. They are deeply committed to the cause of ensuring the health and safety of the people and environment surrounding Seabrook Station. Many of them have been with us for decades. Yet it’s always exciting—and necessary—to bring in fresh energy and perspectives for our important work. This spring we welcomed three women to the board of directors, each of whom brings valuable skills and contributions to our organization.

Karen Clagett

“Having arrived in Newburyport in the 1970s, I have long been aware of Seabrook and of C-10,” said Karen Clagett, who recently retired from a career in education. “Initially, I contributed money to C-10 as much to support friends who were involved in the organization as to support the mission,” said Clagett, who has been involved with several local organizations, and is currently a volunteer with the Peabody Essex Museum and the Emma Andrews Library, and sits on the board of West Newbury Garden Club.

“Within the last year, however, as I worked more closely on a research project related to Seabrook’s degraded concrete, I fully realized the important work C-10 does helping to keep us safe, monitoring Seabrook, and educating local communities about crucial issues involving the Seabrook power plant and nuclear energy in general. I recently joined the C-10 Board committed to supporting its vital mission,” said Clagett.

Cary Stratton Boyd

Cary lives in Newbury and is co-owner with husband, Lew Boyd, of Newburyport-based Coastal 181, which publishes books on motorsports. One of original members of Citizens Within the 10-Mile Radius (a precursor to the C-10 Foundation) in the mid-1980s, Boyd worked on evacuation plans for Newbury and neighboring communities in case of an accident at Seabrook Station.

“I have spent the last 30 years or so building a business and raising a family and I am thrilled to be back involved with C-10 and its mission to protect our environment,” said Boyd. I am especially interested in C-10’s work to better understand and address the serious problem of Alkali-Silica Reaction in the concrete at Seabrook, particularly in the light of the facility’s pending license renewal application,” said Boyd.

Elizabeth Rankin

Also a Newburyport resident, Elizabeth spent much of her career with the Essex National Heritage Area, where she honed a variety of skills related to nonprofit management, design and communications. Rankin has focused the last few years caring for her young son, and currently works part-time as membership and marketing assistant at the YWCA of Newburyport as well as volunteering with local groups including the Coastal Trails Coalition.

"I spent a lot of years trying not to think about Seabrook,” said Rankin. “But once I learned about C-10 and the important work they are doing for public safety, I decided to get involved as a volunteer.” Before long, Rankin began to contribute to C-10 as a monthly sustainer, and ultimately, to join the board of directors where she serves as clerk.

We are so grateful for the time and talents that all our board members and volunteers give to C-10! If you are interested in talking with us about how you can get involved, please email natalie@c-10.org.

Newburyport Newcomer Thankful for C-10

Thu, 09 Aug 2018 13:51:06 GMT

Pat Torkildson encourages others to get involved

It’s always heartening when we get contacted from someone who finds C-10 on their own and wants to get involved. Earlier this summer we got a note from Pat Torkildson, a retired attorney who relocated to Newburyport from Madison, Wisconsin, with her husband Howard to be closer to their daughter, Julia.

When Pat and I met and she learned more about C-10, she quickly offered to volunteer with us, like she did at our recent farmer’s market table. She also submitted a letter to the editor of the Newburyport Daily News , prompted after a story about a boy from Belarus who has cancer caused by the meltdown at the Chernobyl nuclear reactor. Here’s Pat in her own words:

As a newcomer to Massachusetts and Newburyport in 2016, I wanted to learn as much as possible about New England and the Newburyport area. I discovered many historical sites, beautiful parks, and an incredible wildlife sanctuary on Plum Island.

I also learned there is a nuclear power plant within 10 miles of where I live. I’m old enough to remember the accidents at Three Mile Island and Chernobyl, so I wanted to understand what risks there were in living so close to such a facility. My research led me to the C-10 Research and Education Foundation, whose mission it is to protect public health and the environment surrounding the Seabrook nuclear power plant.

From C-10’s website, I learned that living close to a nuclear power plant isn’t necessarily dangerous, but living next to the NextEra plant in Seabrook includes risks that no other plant in the world has, because it is the only plant in the world which was built using concrete that has ASR—Alkali-Silica Reaction.

ASR degrades concrete over time and there is currently no cure for the problem. According to a report from the US Nuclear Regulatory Commission, some of the damage is already considered moderate-severe. Despite this, the owner of the plant, NextEra Energy Resources, is seeking an extension of its license from 2030 to 2050 and didn’t mention the ASR issue in their license extension application.

C-10 is concerned enough about the concrete issue that it has gone to court to intervene in a case relative to the plant’s current operating license. A hearing on the license is scheduled for early next year.

As a new member, I urge you learn more about this issue and support C-10 in its efforts to protect public health and safety. Check out C-10.org for more information. We are fortunate to live in one of the most beautiful communities anywhere. In addition to preserving its history, we need to ensure its future.

Should states prop up Seabrook?

Tue, 12 Jun 2018 18:40:48 GMT

A recent Boston Globe editoria l stated that retiring nuclear plants could hurt climate goals, and that Mass. leaders should fight to keep it online. The editors didn't seem to be aware of the fact that Seabrook's concrete is failing, making its operating life far from certain. Many people weighed in on this important topic. Below is C-10's letter.

With crumbling concrete, future of Seabrook far from certain

I was surprised to see the Globe suggest that Massachusetts should somehow prop up, or perhaps subsidize, Seabrook Station’s power output to help meet CO2 goals. While the editorial addresses the need for new energy solutions, it fails to mention the problems at Seabrook that render uncertain the plant’s continued ability to operate safely.

The reason governments enact climate goals is to help protect people and the environment, while maintaining a viable economy into the future. How then could the Globe omit the fact that Seabrook is the only nuclear reactor in the nation known to be suffering from irreversible concrete degradation? This condition, known as alkali-silica reaction, or ASR, is sometimes referred to as “concrete cancer.”

The failing concrete at Seabrook, which affects all key structures at the plant, is what protects the public from deadly radiation in the core reactor and the 600 tons of high-level nuclear waste stored onsite.

We have real and serious climate challenges, and it’s true, nuclear doesn’t emit greenhouse gases — at the source. But with Seabrook under special oversight by the US Nuclear Regulatory Commission and its current license in question due to ASR, it would be unwise for the Commonwealth to count on the plant to operate decades longer than intended.

Despite the importance of Seabrook to the region’s power grid, state leaders must weigh the health and safety of their residents along with other policy drivers. Massachusetts and New Hampshire should ensure that Seabrook’s license extension isn’t granted without assurance that the public will continue to be protected from unintended radiological exposure.

Somber Anniversaries

Tue, 01 May 2018 15:27:05 GMT

It's been 32 years since Chernobyl. What have we learned?

The other day, I was handed a check from a customer, and realized that it was the 26th of April. I then played the “Do you know what anniversary it is?” game—for which regular folks usually have no clue.

It was a long time ago, 32 years, when a radioactive cloud spread into the upper atmosphere from Ukraine, eventually causing alarm in milk-testing stations on the West Coast of the US. Much of the reindeer herd of Lapland had to be euthanized due to radiation exposure; and the entire 18-mile “exclusion zone” around the Chernobyl reactor was transformed to a kind of ghost town, including the city within the zone that housed and served Chernobyl’s workers and their families.

All of the men who responded to the immediate need to build a “sarcophagus” over the exploded reactor later died of acute radiation sickness. And lo’ these many years later, they still have an on-going nuclear reaction taking place within the mass of molten fuel—something from which the entire web of life must be protected, way beyond any foreseeable future, because of the extremely long “toxic lives” of some of the radionuclides being generated.

All of this is one potential outcome from generating electricity via atomic fission—a process that Dr. Amory Lovins, founder of the Rocky Mountain Institute, has likened to “cutting butter with a chainsaw.” Predictably, corporations and regulatory agencies here in the States quelled concern over the 1986 accident by asserting that the kind of event that blew up in Ukraine literally could not happen here—because our reactors are structured and controlled completely differently than Chernobyl.

I was skiing with my partner Lisa at Wildcat Mountain on March 10, 2011; and at the end of the day drove back to the condominium where friends had hosted us, to say goodbye before driving home. My buddy Will was watching a movie, “The Day After Tomorrow;” and I stood transfixed by the images of streets being inundated by the ocean. The next morning when I got downstairs and turned on the news, I felt momentarily confused by what appeared on the T.V., as images of the tsunami hitting Japan filled the screen.

Of course, we know now that while the damage wrought directly by the tsunami crashing inshore was devastating, the greater impact came a few days later, when a series of steam explosions literally blew the tops off four General Electric Mk1 reactors at Fukushima, eventually leading to the “meltdown” of their reactor fuel (ironically due to the lack of available electricity to pump cooling water).

Seven years later, they still have uncontrolled fission occurring, and have had to devise structures to seal in the toxins. Not the same genesis of events as Chernobyl—but in some crucial ways a very similar outcome.

It’s worth noting that the Pilgrim atomic plant on the South Shore of Massachusetts is the same type of reactor as the destroyed plants of Fukushima—a type which General Electric’s own engineers tried to warn them about. We can only hope Pilgrim is shut down in 2019 without any more disasters, and all the radioactive inventory can be removed from the immediate danger of coastal flooding. But whose back yard shall we send it to?

It is ironic that most Americans actually know more about the accidents at Chernobyl and Fukushima than they do about our very own, homegrown meltdown at Three Mile Island (TMI). It makes spring a busy season for inauspicious anniversaries (March 28, 1979). It turns out, the night of the accident initiation, I was handing out flyers about the health effects of radiation at a showing of the movie “China Syndrome;” the title is another term for “meltdown.”

The reasons for us to remember the TMI disaster are many; but one important fact for those of us near Seabrook Station is that unlike Chernobyl or Fukushima, TMI’s two reactors are the same basic type of design as the one in our New Hampshire saltmarsh: Pressurized Water Reactor (PWR).

Another important fact about TMI is that the requirement for evacuation plans at US commercial reactors was instituted only after the 1979 accident—and years after Seabrook had been sited, and construction was under way. Subsequently, more than half the municipalities within this 10-mile radius declared the un-workability of the evacuation plans in the lead-up to licensing in 1990.

In the evolution of New Hampshire and Massachusetts energy strategies, one has to wonder what real consideration is given to the actual workability of “Emergency Response Plans” for the areas around their atomic plants? At least in our area, the population has doubled since the Federal Emergency Management Agency Region I Chief Ed Thomas rejected the plans for our reactor community in the late 1980s.

Today, there are approximately 160,000 year-round residents within the 10-mile Emergency Planning Zone of Seabrook. Many of who are women and children with rapidly dividing cells—and therefore as much as twenty times the vulnerability to the effects of radiation as I, an adult male, face. Are we certain people in nuclear reactor communities are being properly protected? As I consider these somber anniversaries, I truly wish that they were.

Remembering Three Mile Island

Wed, 28 Mar 2018 14:58:00 GMT

Too little information clouds real impact of TMI

On this solemn anniversary of the largest nuclear disaster on U.S. soil, our friends at Beyond Nuclear explore the legacy of this event – what we’ve learned, and what we still don’t know about the impact on the people and nature surrounding Three Mile Island.

The disaster at Unit 2 of the Three Mile Island (TMI) nuclear power plant near Harrisburg, Pennsylvania, began on March 28, 1979. Today, 39 years later, the reality, of what really happened, and how many people it harmed, remains cloaked in mystery and misinformation. Unlike the popular catchphrase, TMI is a story of too little information.

What happened?

The two unit Three Mile Island nuclear power plant sits on an island in the middle of the Susquehanna River, just ten miles southeast of Harrisburg, Pennsylvania. TMI Unit 2 was running at full power, but had been commercially operational for just 88 days when, at 4 A.M. on Wednesday, March 28, 1979, it experienced either a mechanical or electrical failure that caused the turbine-generator and the nuclear reactor to automatically shut down.

The pressure and temperature in the reactor began to increase, but when a relief valve on top of the reactor’s primary coolant pressurizer stuck open, malfunctioning instrumentation indicated that the valve had shut. While cooling water emptied out of the reactor, operators mistakenly reduced the amount of cooling water flowing into the core, leading to the partial meltdown.

Workers deliberately and repeatedly vented radioactive gas over several days to relieve pressure and save the containment structure. Then came fears of a hydrogen explosion. But by April 1, when President Jimmy Carter arrived at the site, that crisis had been averted, and by April 27 the now destroyed reactor was put into “cold shutdown.” TMI-2 was finished. But its deadly legacy was to last decades.

Continue reading on the Beyond Nuclear blog

Cancun or Concrete Safety? My Spring Break with the NRC

Mon, 26 Mar 2018 18:11:00 GMT

By Christopher Nord, C-10 Board Member

Snow was starting to pile up in the last few weeks of winter. Everyone who could afford it was hopping a jet for the Caribbean; and naturally I began to wonder where I might go for some fun down south. How better to renew my joie-de-vivre than to hang out with an old friend at conference full of nuclear engineers?

The U.S. Nuclear Regulatory Commission (NRC) held their 2018 Regulatory Information Conference (RIC) from March 13-15 in Bethesda, Maryland. Included were two technical sessions concerning the problems posed to the concrete structures of atomic reactors: the first, from a chemical process called Alkali-Silica Reaction ( ASR ); the second, from the effects of radiation on concrete.

These were of interest to C-10 because the Seabrook Station nuclear power plant in coastal New Hampshire is the first U.S. commercial atomic reactor known to have ASR propagating through its walls. C-10 is involved in a regulatory proceeding with NextEra Energy Seabrook, LLC (Seabrook’s owner) over their proposed handling of ASR. I flew down between nor’easters in order to attend the conference with Paul Gunter, Director of the Reactor Oversight Project at Beyond Nuclear.

The first RIC session was called “ Concrete Degradation Part 1: Perspectives on Alkali-Silica Reaction Effects on Structural Capacity of Nuclear Concrete Structures, ” and included speakers representing institutions of three nations, the U.S., Canada, and France. A common theme through all presentations was the search for a “predictive model” — some method for gauging the reduction in concrete strength based on certain measurements, such as crack width.

This is a particularly thorny problem for the NRC — and the nuclear industry — because years of study on the part of organizations such as the National Institute of Standards and Technology (NIST) have underscored the difficulties inherent in modeling ASR progression. However, one feature of ASR is completely predictable: it will eventually lead to structural failure.

The second session, entitled “ Concrete Degradation Part 2: Perspectives on Radiation Effects on Structural Capacity of Nuclear Concrete Structures ,” provided insights from experts from U.S. and Japanese agencies and laboratories.

Among the experimental results discussed, their talks highlighted the difficulty of gathering data to quantify radiation’s impact on components most exposed within operating reactors — due to their placement within high-radiation areas. It is clear, though, that while ASR impacts the cement paste constituent within concrete, radiation impacts the aggregate — differently for different minerals present.

The learning curve for understanding how ASR will affect the operational capabilities of atomic reactors is steep: all U.S. reactors were constructed without codified NRC regulations for ASR management. Because of this regulatory omission, the NRC is having to play catch-up — trying to find methods to monitor and respond to ASR’s progression, while its presence at Seabrook has already been known for years.

ASR at Seabrook was first acknowledged in 2010; in 2012, it came to light that certain safety-related structures at the plant had lost as much as 30% of their expected strength. In 2014, C-10 filed a Petition for Rulemaking filed with the NRC, calling for the adoption of already existing standards for testing and analysis of ASR. We are still awaiting a ruling on the petition.

In 2015, we filed a Petition for Emergency Enforcement Action for basically the same cause — and we traveled to NRC Headquarters outside of Washington, D.C., in order to give testimony as a group, in support of our petition.

While no action continues to be taken by the NRC on our original petition request, we believe that neither NextEra, nor the NRC, know the actual state of deterioration of the spent fuel pool at Seabrook Station, or the supporting structures for the reactor pressure vessel.

Every human, and every living thing within the ingestion pathway (50 miles) and beyond, of Seabrook relies on these concrete structures to isolate byproducts of atomic fission, many of the most toxic substances on earth — some of which are deadly upon contact; some of which remain deadly for thousands of years.

The NRC has publicly stated that they will not complete their consideration of NextEra’s application for a 20-year extension to the operating license until a method for handling Seabrook’s ASR is codified.

As intervenors in Seabrook’s license amendment review docket , C-10 is on track to present its case before the NRC’s Atomic Safety and Licensing Board at an adjudicated public hearing expected to be held in February 2019.

EARTHQUAKE RAISES CONCERNS ON SEABROOK’S CONCRETE

Thu, 01 Mar 2018 17:38:00 GMT

If you felt the ground shaking the morning of February 15, you weren’t alone. We felt it too at our Newburyport office. And we wondered how the 2.7 magnitude earthquake may have impacted concrete at Seabrook Station that is already stressed by a condition known as Alkali-Silica Reaction or “ASR.”

The quake had an epicenter in East Kingston, New Hampshire, approximately eight miles west of Seabrook, New Hampshire.

The concrete in key structures including the containment dome and spent fuel pool at Seabrook nuclear power plant has been found to have ASR, a progressive and irreversible condition which can cause cracking and weakening of concrete. Seabrook is the first nuclear plant in the nation known to have ASR, and has been under enhanced federal oversight since the problem was first discovered in 2009.

“This concrete is meant to protect the public from exposure to some of the most toxic materials on earth — radioactive byproducts of atomic fission,” said Natalie Hildt Treat, executive director of C-10. “You would think a measurable earthquake would put further stress on that,” she said. “Little cracks can lead to bigger cracks … it’s definitely a safety concern.”

NextEra, Seabrook’s owner, had a different take.

“The earthquake recorded near East Kingston, New Hampshire did not impact Seabrook Station Nuclear Plant nor was there any risk to the public. Nuclear plants, including Seabrook Station, are designed to withstand earthquakes and other natural events. Seabrook Station’s structures are robust, safe and fully capable of performing their design functions. We have demonstrated, and the NRC has confirmed this point repeatedly,” NextEra spokesperson Sarah C. Gebo said in a statement to C-10.

“I was here, and I felt it too. So I responded immediately to the control room,” said U.S. Nuclear Regulatory Resident Inspector Paul Cataldo, in a phone call with Treat the day after the quake.

Cataldo explained that while the seismic monitors at Seabrook didn’t even register the quake, they are designed and calibrated to NRC specifications, so that something like a crane or truck moving outside the plant doesn’t set off alerts.

Still he said that plant managers with NextEra Energy spent an entire day inspecting the plant, and NRC personnel conducted separate inspections. “We walked down all the structure components including those affected by ASR,” said Cataldo.

The NRC issues quarterly inspection reports , with the next one to be released in April. Also this spring, the NRC is planning their annual public meeting where they present on safety findings at Seabrook Station. Cataldo said they are looking at May 1 or 2. Stay tuned for details.

More Background on ASR at Seabrook

In 2016, NextEra Energy Seabrook LLC submitted a license amendment relative to the ability of its concrete to continue performing as designed. In October 2017, the C-10 Research & Education Foundation was granted standing in a case being considered by the U.S. Nuclear Regulatory Commission.

NextEra’s pending License Amendment Request is relative to the deteriorating concrete at the plant, which has been operating since 1991. Citing serious safety concerns with the concrete and flaws in the concrete testing and monitoring methodologies, C-10 sought intervenor status in the NRC docket. A public adjudicated hearing is expected in February 2019.

C-10 had alleged in its April 2017 petition to the NRC that the testing was inadequate and not representative of actual conditions at Seabrook, and that if the concrete failed and resulted in a radiological release, its monitoring operations, its members, and the public at large could face grave danger.

For more information, see this C-10 fact sheet on ASR and Seabrook. Also see coverage in the Boston Herald and Newburyport Daily News .

TWO N.H. BILLS ON SEABROOK SAFETY VOTED DOWN ON PARTY LINE

Wed, 28 Feb 2018 16:29:00 GMT

Bill to Require Lawmakers to Study ASR

New Hampshire State Representative Renny Cushing (D-Hampton) has long been concerned about the safety of Seabrook Station nuclear power plant, which is located just two miles from Hampton’s downtown. Given the concrete degradation problem of Alkali-Silica Reaction (ASR) plaguing many key containment structures at the plant, Cushing filed a bill for legislators to learn about ASR and what it means for their constituents.

On January 30, HB 1659 , “Establishing a committee to study possible health and safety impacts of the alkali-silica reaction on the seacoast” was heard before the New Hampshire House Committee on Health, Human Service and Elderly Affairs.

C-10 board member and Dublin, N.H. resident Sarah Doenmez participated in the hearing and offered testimony on the concrete degradation and inform committee members of the inconclusive state of current research on this topic.

Doenmez explained that no other commercial nuclear reactor in the country is known to suffer from ASR, and thus Seabrook is in a unique situation. Alkali-Silica Reaction is a progressive and irreversible chemical reaction in concrete when in the presence of moisture. While initially a slow process, the further it spreads, the faster it spreads. Other main points included that ASR damage in the form of micro-cracking exists in 80 – 85% of Seabrook’s structures.

ASR has caused “building deformation events” since 2014, notably in the outer containment structure. These deformations can cause misalignments in pipes, fire protection, and other instrumentation. ASR is known to be present in the spent fuel pool as well. ASR can affect rebar anchoring and reinforcement, especially by altering the load of the concrete. The full extent of cracking at Seabrook is not known, especially interior to the concrete. C-10’s factsheet on ASR was distributed to all Committee members.

Two representatives from NextEra were given the floor before Doenmez and argued that a study committee would be redundant. Chairman Frank Kotowski (R-Hooksett), noted that he had run the Science and Nature Center at Seabrook for a decade and assured everyone that the problem was manageable. He suggested that communication with the public take place via the Emergency Planning Calendar published by NextEra.

Committee members asked many salient questions, such as whether ASR also affects the beams, whether there is a solution to ASR and what the thresholds are at which the plant cannot operate.

Representative Mindi Messmer (D-Rye) pressed a NextEra spokesperson to identify the number of buildings at stages 1, 2, 3 of degradation, who responded that 8-12 buildings are in stage 3, and 50 each are in stages 1 and 2.

Ultimately the committee reported the bill as “Inexpedient to Legislate” and it lost in a roll call vote, 195-143 on February 22. But C-10 is encouraged that this serious matter came under discussion, is glad to have helped educate legislators on this important matter.

Bill to Conduct Real-Time Radiological Monitoring in N.H. Communities

As we wrote last month , “An Act Requiring Monitoring of Certain Radioactive Air Pollutants,” sponsored by Rep. Mindi Messmer (D-Rye) received a hearing before the New Hampshire House Committee on Science, Technology and Energy on January 23. Rep. Cushing and a handful of colleagues, including committee member Rep. Robert Backus (D-Manchester) also spoke in favor of the bill.

House Bill 1779-FN brought a packed hearing room, with legislators, interested citizens, state agency heads and of course NextEra Energy Seabrook representatives debating the merits of real-time monitoring of airborne radiation in the communities surrounding Seabrook.

While the C-10 Research & Education Foundation has operated a monitoring network since 1993 under contract with the Commonwealth of Massachusetts, New Hampshire — with seventeen of its communities within Seabrook’s 10-mile radius — has opted to rely on more passive data collection and trust in the data from NextEra’s onsite radiation monitors.

Committee members were very interested to learn about C-10’s monitoring, with some asking why the bill specified a new network to be run by the state’s Department of Health and Human Services, instead of piggybacking on the system in place with C-10.

Natalie Hildt Treat, C-10’s executive director, explained that she has met with Perry Plummer, Director of Homeland Security and Emergency Management and Michael Dumond, Director of the Public Health Division at the Department of Health and Human Services, and offered to coordinate with the state as needed.

Treat was joined at the hearing by C-10 board member and Newbury, Mass. resident Chris Nord to explain why we monitor, and how this information can help health and safety officials understand radiological releases. Nord noted that collecting wind speed and direction can be especially helpful in the event of an emergency, to ensure that the public is not evacuated to areas downwind of a radiological plume.

HB 1779 was also “ITL’d,” as an unfavorable report is known. With the committee voting it “inexpedient to legislate,” a floor vote by the full House did not look promising. On March 6, the House supported the majority ITL by 166 – 158; just an eight vote margin.

C-10 is proud to have served as an educational resource to legislators and the public, and will continue to collaborate with state and local officials concerned about the safety of people who live and work near Seabrook Station. We’re encouraged that lawmakers have already expressed interest in introducing similar legislation next session.

NUCLEAR POWER & RADIATION EXPOSURE: C-1O FACT SHEET

Wed, 28 Feb 2018 16:11:00 GMT

What are the health impacts of living near a nuclear reactor? It’s difficult to say for sure. What we do know is that radiation damages living cells, and that nuclear power plants are permitted to release small amounts of radioactive materials into the environment – to say nothing of the potential impact of an unintentional release, or accident.

Why and How Nuclear Plants Release Radioactive Materials

To generate electricity at a nuclear power plant, a nuclear reactor uses uranium fuel to produce heat energy through nuclear fission in a reactor. Nuclear fission creates radioactive material, known as radioisotopes. Some of these radioisotopes – such as iodine 131, cesium 137, strontium 90, tritium, uranium and plutonium – can be deadly to humans and harmful to the environment.

In a perfect world, the harmful byproducts of producing nuclear power would be isolated from humans and the environment. Today’s nuclear power plants, however, must regularly release radioactive water and gases to the environment to maintain proper conditions in the reactor, as well as to keep radioactivity from exceeding government safety limits for workers. These releases are regulated by and reported to the U.S. Nuclear Regulatory Commission.

Health Impacts of Radiation Exposure

Energy emitted from a source is generally referred to as radiation . Radiation with enough energy to remove tightly bound electrons from the orbit of an atom, causing the atom to become charged or ionized, is referred to as ionizing radiation. This energy is released in the form of subatomic particles (alpha and beta) or waves (gamma and X rays).

Exposure to ionizing radiation causes damage to living tissue. High doses can result in mutation, cancer, radiation sickness, and death. Cancers linked to ionizing radiation include most blood cancers (leukemia, lymphoma), lung cancer, and many solid tumors of various organs. Birth defects can include congenital malformations, spinal defects, and kidney and liver damage.

Effects on human health vary by an individual’s age and health, as well as by the type of radionuclide, level of exposure, and duration of exposure. Children and the unborn are especially susceptible because of their rapid cell division during growth. Adults with weakened immune systems may also be more sensitive to exposure.

Click here to download a PDF fact sheet.

Degraded Concrete at Seabrook Nuclear Plant: An Introduction to “ASR”

Thu, 15 Feb 2018 19:39:00 GMT

The Problem

The concrete in key structures including the containment dome and spent fuel pool at Seabrook Station nuclear power plant is failing. This concrete is meant to protect the public from exposure to some of the most toxic materials on earth — radioactive byproducts of atomic fission.

Seabrook Station, a nearly 30-year-old atomic reactor in Seabrook, New Hampshire, has submitted a license amendment relative to the ability of its concrete to continue performing as designed. The C-10 Research & Education Foundation has been granted pro se intervenor status in the case being considered by the U.S. Nuclear Regulatory Commission.

The outcome of this proceeding will not only impact the risks to health and safety of all who live near Seabrook; it will have national repercussions in how nuclear plants are regulated, and whether guidelines on how to respond to Alkali-Silica Reaction are written.

“The worse it gets, the worse it gets.” – Concrete expert Dr. Paul Brown on ASR

What is the Alkali-Silica Reaction?

Alkali-Silica Reaction, or “ASR,” is a chemical combining of reactive silica from concrete aggregate with the alkali from cement paste in the presence of moisture. The result of the reaction is a gel, which can expand and may cause micro-cracks in concrete. ASR is known to be progressive and irreversible.

Seabrook Station in coastal New Hampshire is the first U.S. nuclear power plant known to be experiencing ASR , though plants in Canada and Belgium have been decommissioned due to this condition.

How is ASR Impacting Seabrook Station?

C-10 Weighs in on ASR

Citing serious safety concerns with the concrete and flaws in the testing and monitoring methodologies undertaken by NextEra, the C-10 Research & Education Foundation, Inc. sought intervenor status in NRC Docket Number 50-443-LA-2 , and requested a public hearing.

In October 2017, the NRC’s Atomic Safety and Licensing Board (ASLB) ruled that C-10 has standing to intervene in the case, and admitted five of the group’s concerns as one reformulated contention. C-10 is working with leading concrete experts and structural engineers to better understand ASR, as we prepare for a public hearing on NextEra’s license amendment request in early 2019. Meanwhile, NRC staff are conducting their own review of the LAR.

Click here to download a PDF fact sheet on ASR at Seabrook

VOLUNTEERS, INTERNS NEEDED TO SUPPORT RESEARCH & EDUCATION EFFORTS AT C-10

Thu, 18 Jan 2018 16:47:00 GMT

Yes, there is Seabrook’s License Amendment Request, and of course the core work of our real-time monitoring. But C-10 is also engaged in an array of projects to educate the public about what it means to live near a nuclear plant. We are working to create new print and online resources and plan a series of talks including topics such as evacuation planning and health impacts of ionizing radiation.

Do you have a few hours a week or month to contribute to the effort? Know a high school or college student looking for experience? Please contact Natalie Treat, Executive Director at natalie@c-10.org to get involved. Whatever your talents, we can find a way to use them!

N.H. LEGISLATURE CONSIDERS BILL ON AIRBORNE MONITORING

Thu, 18 Jan 2018 16:43:00 GMT

“An Act Requiring Monitoring of Certain Radioactive Air Pollutants,” will be heard before the New Hampshire House Committee on Science, Technology and Energy on Tuesday, January 23 at 10:15 AM in room 304 of the Legislative Office Building in Concord.
New Hampshire does not currently operate or support a real-time radiation monitoring network in the vicinity of Seabrook Station, instead relying on proprietary readings taken by plant owner NextEra Energy Resources – as well as the passive data collected by the U.S. Nuclear Regulatory Commission through a system of thermos-luminescent dosimeters, or TLDs – that gather cumulative levels of ionizing radiation.

Seacoast legislators, including lead-sponsor Rep. Mindi Messmer (Rockingham-24) are again working to change that with the introduction of House Bill 1779-FN ,

Rep. Messmer, an environmental scientist by training (pictured above), has taken a particular interest in the public health mystery of a childhood cancer cluster in the N.H. seacoast. While there are many forms of environmental pollution identified in the region, due to the known health effects of ionizing radiation, Messmer and her colleagues believe the state should be tracking airborne radiation levels.

New Fact Sheet: Seabrook Evacuation Plans

Tue, 19 Dec 2017 14:04:00 GMT

Living Near Seabrook: What You Need to Know

The people who live and work in the communities surrounding Seabrook Station nuclear power plant carry a special responsibility to understand that the risk of an accident — however small — is real. It’s wise to be pro-active and learn what you would do, and where you would go, in the event of a significant radiological release. The following is information compiled from state and federal agencies.

Evacuation Plans

What is an Evacuation Plan? What is often called the “evacuation plan” is actually the “emergency plan,” and it includes planning for a range of emergencies and/or disasters at a nuclear plant. Not all emergencies would result in an evacuation order; citizens may instead be directed to “shelter in place.”

Why does Seabrook Station need an emergency plan? At Seabrook Station, as with all commercial nuclear power generating facilities, an emergency could result in a radioactive release affecting public health and safety. Plant operators, as well as federal, state and local officials, are required to have emergency plans in place. These agencies communicate regularly and conduct joint preparedness drills.

Who develops the Evacuation Plan? The plans for offsite emergency response are developed by state and local officials, and are reviewed by the Federal Emergency Management Agency (FEMA). The New Hampshire Division of Homeland Security and Emergency Management (HSEM) maintain the state’s nuclear power plant off-site emergency plans, including annual reviews and updates. Plans and procedures for Massachusetts are reviewed annually by the Mass. Emergency Management Agency (MEMA) and revised as necessary.

Under the oversight of the U.S. Nuclear Regulatory Commission (NRC) and FEMA, the emergency plans are reviewed, drilled and evaluated regularly to ensure they meet regulatory standards.

What area is covered by the Evacuation Plan? There are two Emergency Planning Zones (EPZs) around a commercial nuclear power plant:

Cities & Towns in Seabrook’s EPZ : Seventeen New Hampshire communities fall within Seabrook’s 10-mile emergency planning zone: Brentwood, East Kingston, Exeter, Greenland, Hampton, Hampton Falls, Kensington, Kingston, New Castle, Newfields, Newton, North Hampton, Portsmouth, Rye, Seabrook, South Hampton and Stratham. In Massachusetts, this zone includes: Amesbury, Merrimac, Newbury, Newburyport, Salisbury and West Newbury. About 170,000 people live in these communities.

How can I find out what the plan is for my location? Residents within the EPZ is area are given emergency information about radiation, evacuation routes, special arrangements for handicapped, via the Emergency Public Information Calendar supplied by each state. If you live, work, or vacation within the 10-mile EPZ, you should be prepared for an emergency at Seabrook and be familiar with the EPZ’s emergency plans and procedures; that is, whether the directive is to “shelter in place” or evacuate. If you need a copy of the calendar, you can usually get one at a local police or fire station, or get them online from Mass. MEMA or N.H. HSEM.

How will I be notified of an emergency or accident at the Seabrook plant? Outdoor emergency sirens will make a steady three to five minute sound. If you hear a siren, go inside your home or a nearby building. The sirens will also be able to broadcast special emergency messages to alert people at the New Hampshire. beaches.

Tune a radio to an Emergency Alert System (EAS) station . These stations will broadcast an emergency message that will provide you with any actions you should take to protect yourself and your family. Staying tuned to the radio might be all you’ll need to do, or you may be told to take different actions if emergency conditions change. Tune in to: 97.5 FM (WOKQ) 106.1 FM (W291CC) or 1450 AM (WNBP). Boaters in the area will be alerted by the U.S. Coast Guard. Channels 16 and 22 on marine radio will also give boaters information. Local emergency management officials — sometimes the town’s fire chief — are the primary contact in case of a nuclear emergency.

For more information, find links here. You can also visit the N.H. HSEM’s Nuclear Power Plant page , or Mass. MEMA’s page on Seabrook Nuclear Power Station .

On these websites, you can learn about event classifications, evacuation routes, information for farmers, tips for planning & supplies to have, and where to get potassium iodide tablets to protect your thyroid in the event of a radiological accident at Seabrook.

To download a PDF version of this fact sheet, click here .

New Video: An Introduction to C-10

Mon, 18 Dec 2017 17:22:00 GMT

We are excited to share a new six-minute video introduction to the C-10 Research and Education Foundation, including why and how we monitor airborne radiation in the communities surrounding Seabrook Station nuclear power plant, a bit about the plant itself, and the ongoing and serious concerns regarding the failing concrete at Seabrook.

Please take a look, and share if you see fit! Many thank to Rick Dumont and his team from Sweaty Turtle Entertainment for producing the video, and to the Institution for Savings as well as private donors for making this project possible.

CLICK HERE TO WATCH AN INTRODUCTION TO C-10

Write your own report card? The nuclear industry thinks they should.

Mon, 11 Dec 2017 20:26:00 GMT

We were blown away too. There are discussions at the Nuclear Regulatory Commission about allowing nuclear plants to write their own self-assessments. You know, as a way of cutting back on all that pesky regulation.

C-10 recently took the opportunity to file comments opposing this idea. Below are excerpts. Read more about the design inspection review process on this NRC site , including detailed comments by Dave Lochbaum , Director of the Nuclear Safety Project with the Union of Concerned Scientists.

Here are some of the reasons we believe surrendering safety review to plant operators would put the public at risk:

“As for-profit entities that weigh safety as only one performance metric among many, there is an inherent problem in expecting commercial nuclear plant owners to be unbiased and completely transparent when it comes to safety concerns that could put the public at risk — no matter how small or large they are perceived to be.

It will generally be in the plant owners’ and shareholders’ interests to minimize any problems that might be detected, rather than self-reporting and calling forth regulatory and public scrutiny. The possibility for reduced transparency concerns us as citizens whose lives are immediately impacted by ongoing safety problems at Seabrook Station, including and not limited to the problem known as alkali silica reaction. Transparency and the opportunity for public input is an essential part of NRC’s work, and key to C-10’s ability to function as citizen watchdogs.” Read our full comments, here .

NextEra’s Halloween Trick: Seabrook Owner Appeals Board Ruling

Tue, 07 Nov 2017 19:09:00 GMT

An Update on the License Amendment Process & Seabrook’s Concrete

As we wrote on our October 8 blog , the federal Atomic Safety and Licensing Board (ASLB) granted C-10 intervenor status in the docket relative to NextEra’s License Amendment Request concerning the ability of the Seabrook Station nuclear plant’s deteriorating concrete to continue to perform as intended.

As a pro se party without legal representation, we’ve been working with attorneys from the U.S. Nuclear Regulatory Commission (NRC) and Seabrook owner NextEra Energy to establish ground rules relative to the discovery process, schedule, sensitive document access and so forth.

The public hearing the ASLB ordered in its ruling won’t happen until after NRC staff issues their recommendations on the License Amendment Request, and that won’t be until fall of 2018. We do know that the hearing be held near Seabrook Station and likely will last several days. C-10 was the only outside party that sought and was granted intervenor status.

Meanwhile, as former C-10 staff and board members pour through old emails and compile documents to support our contentions , the clock ticked down on the deadline to appeal the ASLB’s ruling.

On Halloween, there was no treat from NextEra attorneys, whose appeal hammered the ASLB for considering regulatory precedent in their decision to give leeway to a citizens group, and for taking the recommendation of NRC staff and reformulating the five contentions they admitted had merit into one:

“The large-scale test program, undertaken for NextEra at the FSEL, has yielded data that are not ‘representative’ of the progression of ASR at Seabrook. As a result, the proposed monitoring, acceptance criteria, and inspection intervals are not adequate.”

It is not terribly surprising that NextEra Energy appealed the Board’s ruling admitting C-10 and our contentions. They are a multi-billion dollar company, representing the entrenched interests of the nuclear power industry. C-10 Research & Education Foundation is a small local non-profit group that has worked for 26 years to protect the health and safety of people who live near Seabrook Station.

We have been under contract with the Commonwealth of Massachusetts for decades to operate our airborne radiation monitoring network as a means of providing state and local authorities with information on any unusual radiological events surrounding Seabrook.

With our petition to intervene and call for a public hearing on NextEra Seabrook’s License Amendment Request, we have simply asked the ASLB to consider whether the testing and monitoring of the very serious condition known as ASR is adequate to ensure that Seabrook’s concrete will continue to protect the public from radiological releases if something goes wrong at the plant.

C-10 should not be the ones on trial in this docket. We are simply asking that federal regulators do their job to ensure that the plant is safe enough to retain its operating license.

The saga continues, and we’re in it for the long-haul. But it’s going to be a costly fight; we expect we’ll need to raise several tens of thousands of dollars to pay for experts in concrete science and structural engineering to support our contentions and prepare for a hearing.

Your support will help us fund this important regulatory fight, which could have far-reaching implications; Seabrook was the first nuclear plant in the country where the alkali silica reaction was discovered, but it likely won’t be the last. Existing NRC regulations don’t provide guidance on the protocols to handle the problem.

Thank you for standing with C-10 — always working for the safety of citizens who live and work near Seabrook Station.

Summer Interns rocked it at C-10!

Tue, 10 Oct 2017 16:17:00 GMT

Young people have lots of ways to use their precious time. That’s why it was so gratifying to see two stellar young ladies volunteer their time and talents to assist us with some important projects this summer.

Samantha McCraine was busy juggling other internships, waiting tables and preparing for graduate school. Still, she found time to help us freshen up our website and develop new fact sheets. We wish Samantha well at the London School of Economics, where she recently began a 12-month Master of Science program in Environmental Policy and Regulation.

Margot Springer wowed us with her maturity and level of interest in C-10’s mission as a rising high school freshman. Margot worked with our monitoring network administrator Mike Mansir to develop a new equipment inventory system. She also helped with research and data management. We hope you love Whittier Tech, Margot — don’t be a stranger!

If you know someone looking for some great experience working with a citizen science organization please refer them to our website where they can learn about our internship program .

Chernobyl and the Collapse of the Soviet Union

Tue, 10 Oct 2017 16:09:00 GMT

Newburyport Adult Ed class offers insights and lessons from local expert

The culture of obedience and the lack of the public’s ability to ask questions contributed to the chain of events that triggered the nuclear accident at Chernobyl. This is what Gary Dunbar believes, and it points to the importance of a strong democracy, freedom of speech and the role of citizen groups to engage with — and sometimes question — the government.

Dunbar is a West Newbury resident who worked for a decade as a government consultant in and around Russia and the former Soviet republics, most notably with officials trying to manage the after-effects of the Chernobyl nuclear meltdown.

“Cultural differences would make it extremely unlikely for something like Chernobyl to happen in the U.S.” said Dunbar, adding that “the macho culture in Ukraine exceeds anything I’ve ever seen; it’s a very different world.”

“What your group (the C-10 Foundation) can do in this culture is vastly important,” Dunbar observed. “You have the ability to take bureaucracy to task, to raise issues and ask questions.The fact that it exists and you’re able to ask questions is an enormously important safeguard that we have in this country.”

Dunbar will share photos taken inside the reactor, maps of radiation, and personal stories of what happened to people he knew who were affected by radiation, as well as other topics.

“Part of what I want to do is help people understand Russia a tiny bit more,” said Dunbar.

Beginning on October 26, Gary will lead a discussion class to share his experience and insights. Learn more and register online at Newburyport Adult and Community Education’s website .

NRC’s Atomic Safety and Licensing Board rules in favor of C-10

Sun, 08 Oct 2017 21:14:00 GMT

Standing granted in case on Seabrook’s concrete

NextEra Energy Seabrook LLC’s pending License Amendment Request is relative to the deteriorating concrete at the plant, which has been operating since 1991. Citing serious safety concerns with the concrete and flaws in the concrete testing and monitoring methodologies, C-10 sought intervenor status in the docket, and requested a public hearing.

In a 100-page ruling issued by the U.S. Nuclear Regulatory Commission’s Atomic Safety and Licensing Board (NRC/ASLB) on Friday, October 6, the three-judge panel wrote that C-10 has standing to intervene in Docket Number 50-443-LA-2, and admitted five of the group’s contentions, combining them into one reformulated contention.

“This is a very exciting development in our work to ensure that as long as Seabrook is online, it is operating as safely as possible,” said Natalie Hildt Treat, executive director of C-10.

“It was a significant hurdle to make it this far without legal representation. But this case is not only about the ability of Seabrook’s concrete to protect us from radioactive elements; it could have national repercussions as to how the NRC handles other cases of nuclear plants experiencing Alkali Silica Reaction, or ASR,” said Treat.

“Now the tough work lies ahead,” Treat continued. “Our contentions were admitted, and we will be relying on our concrete expert Dr. Paul Brown as well as supporters to help fund the legal effort to back our contentions.”

Both NextEra and NRC staff attorneys had called for C-10’s petition to be thrown out, which the ASLB strongly refuted. In its ruling, the ASLB judges wrote that: “C-10 is not merely a nuclear watchdog or general environmental group; it is an organization focused on the safe operation of the Seabrook plant, and only that plant. It maintains and operates a ‘field monitoring network to measure real-time radiological emissions from the plant, under contract with the Massachusetts Department of Public Health’s Bureau of Environmental Health.”

Because of the chemical breakdown of the concrete known as ASR identified at several key structures at the plant beginning in 2009, NextEra began its own monitoring and testing program, including a large scale test at the Ferguson Structural Engineering Lab (FSEL) at the University of Texas, Austin. In 2016 NextEra submitted a License Amendment Request in effect stating that the concrete would continue to perform as designed, that it was degraded but operable.

In its ruling, the ASLB wrote that “The large-scale test program, undertaken for NextEra at the FSEL, has yielded data that are not ‘representative’ of the progression of ASR at Seabrook. As a result, the proposed monitoring, acceptance criteria, and inspection intervals are not adequate.”

“NUREG/CR-7171 (a publication of the NRC) supports C-10’s claim of a material deficiency in the test program. This is a disputed issue worthy of examination at an evidentiary hearing, given that the actual Seabrook concrete has been exposed to radiation for decades, even if at low levels in most places,” the ruling continued.

With C-10 admitted as a party to the proceeding and its request for a hearing granted, there is now a 25-day window for objections to be filed. After that, the Atomic Safety and Licensing Board will notify the public of the hearing schedule and, assuming the matter moves forward, C-10 will go through a process to gain access to sensitive materials relative to the case, per the NRC’s Code of Federal Regulations.

Read more about C-10’s efforts relative to ASR here .

Safety for Citizens: Why I think about Seabrook Nuclear Plant, and Why You Should Too

Tue, 05 Sep 2017 16:29:00 GMT

By Natalie Hildt Treat, C-10 Executive Director

So, you live near a nuclear power plant. Not something you think about much. It sits there, rising from the Seabrook, New Hampshire marsh; you see it from the beach or your way up Route 1. It makes electricity, it doesn’t belch black smoke – good things.

Maybe you think about it a couple times a year – like when school starts and you are asked to sign the permission slip for your kid to be given potassium iodide (KI) which will help protect their thyroid in the event of an accident at Seabrook Station. Hopefully you held onto that calendar from the state with the quaint antique photos. The one that says to keep in the event of an emergency because there’s evacuation instructions inside. Not a bad idea to review that, and discuss with your family. To learn more and consider your own emergency plan, here’s the link to MEMA ‘s website if you live in Massachusetts, or HSEM if you live in New Hampshire.

About Seabrook Station

Seabrook Station nuclear power plant has been helping to meet the region’s energy needs since it went online in 1990. With its 1,244-megawatt electrical output, Seabrook Unit 1’s pressurized water reactor is the largest individual electrical generating unit on the New England power grid. It directly employs about 500 workers, and is an important part of the local economy.

While its operation does not contribute significantly to greenhouse gas emissions (uranium mining is another story), it does require a tremendous amount of water to cool the reactor, and it generates high-level nuclear waste – products of atomic fission. About 500 tons of the stuff currently sit on site, because there is no national long-term waste storage solution.

Seabrook has been online for twenty seven years. The plant is currently licensed until 2030, though plant owner NextEra Energy Resources has some serious problems with deteriorating concrete to address. The thing is, there is no way to stop what’s known as the Alkali Silica Reaction , or ASR, so basically it’s up to the plant owners and the U.S. Nuclear Regulatory Commission (NRC) to ensure the concrete continues to protect us. NextEra hopes to extend its license until 2050, but that will be up to federal regulators to decide – with input from state and local officials, as well as citizens.

Safety for Citizens

I think about safety at Seabrook Station more than the average mom, to be sure. That’s because I run a small Newburyport-based non-profit charged with radiological monitoring in the communities within the plant’s ten-mile radius known as the Emergency Planning Zone, or EPZ. There are about 170,000 people who live in 23 New Hampshire and Massachusetts cities and towns that fall within Seabrook’s EPZ. I live with my husband and young daughter in Salisbury, Mass. – about 3.5 miles away, as the crow flies.

The C-10 Research and Education Foundation was incorporated in 1991. Since the mid-1990s we have been under contract with the Commonwealth of Massachusetts to operate the nation’s only real-time independent airborne radiation monitoring network. We currently do not receive funding from New Hampshire to conduct monitoring, but we are hearing renewed calls to expand the monitoring there, since most of the EPZ is in the Granite State.

Through a system of probes that detect gamma and beta radiation as well as wind speed and direction, we learn if there are any notable spikes in radiation. We have a protocol for communicating with the NRC’s resident inspectors as well as the Massachusetts Department of Public Health and the Massachusetts Emergency Management Administration.

The thing I didn’t really think about until I started this job in March is that very small amounts of radiation are released by air and water as a normal part of operation at a nuclear power plant. They have to vent to protect workers when too much steam builds up. And radiological isotopes such as tritium have been found in the aquifers near just about every nuclear power plant, including Seabrook.

So, while there is no scientific consensus on what a “safe” level of exposure is, it’s plausible to think that the people living and working near a nuclear plant face higher risks of exposure than those who don’t. That said, the NRC maintains that populations surrounding nuclear plants do not face higher rates of cancer compared to other populations, though the agency recently canceled a study that would have delved deeper into the question.

Ionizing Radiation and Health

The effects of what’s known as ionizing radiation on human health vary by an individual’s age and health as well as by the type of radionuclide, level of exposure, and duration of exposure. Children and the unborn are especially susceptible because of their rapid cell division during growth.

Exposure to ionizing radiation can cause damage to living tissue, and high doses can result in mutation, cancer, radiation sickness, and death. Cancers linked to ionizing radiation include most blood cancers (leukemia, lymphoma) lung cancer and many solid tumors of various organs. Birth defects can include congenital malformations, spinal defects, kidney and liver damage.

Once released, radionuclides end up in drinking water, vegetables, grass, meat, etc. The higher the animal eats on the food chain the higher the concentration of radionuclides. This is bioaccumulation. Many experts agree that minimizing exposure to radiation is important, especially for children and adults with weakened immune systems. That is why agencies in Massachusetts and New Hampshire conduct testing to ascertain if levels in the environment reach unsafe levels.

Sobering stuff – but this is our home. Those of us who live in the communities surrounding Seabrook – from Newburyport to Portsmouth and many little towns in between – choose to live here because it’s a beautiful and special place. Our friends and family are here. It’s also home to a nuclear power plant that was built decades ago.

What You Can Do

Rather than fret about what it means to live near a nuclear plant, or put our heads in the sand, we have a choice. We can educate ourselves about safety and security concerns at Seabrook, and also about ways to help keep our families safe in the event of an emergency.

That’s where you come in. I invite you to follow the C-10 Foundation on Facebook , sign up for our newsletters at c-10.org , and join as a member. We are always looking for talented volunteers to help with education, outreach and fundraising initiatives. If you have questions or want to get involved, please drop me a note at natalie@c-10.org .

C-10 testifies before Atomic Safety & Licensing Board on concrete testing at Seabrook Station

Wed, 12 Jul 2017 14:34:00 GMT

By Sarah Doenmez and Natalie Hildt Treat

The term “pro se” is from Latin, meaning “on one’s own behalf.” As in, without lawyers. Members of the C-10 Research & Education Foundation’s board of directors have been toiling without the benefit of legal counsel in a case we feel very passionate about: the failing concrete at Seabrook Station nuclear power plant.

While we aren’t attorneys, nuclear physicists or concrete experts, we have spent countless hours becoming what we’d call “citizen experts” in the matter of Seabrook’s License Amendment Request ( LAR ) relative to the ability of the plant’s concrete to keep the public safe.

Through our own research and by speaking with experts, we’ve learned all that we can on complex technical and legal issues and have asked the U.S. Nuclear Regulatory Commission (NRC) to hold a public hearing on the concrete, and admit us as intervenors in the docket.

As a group located within the plant’s ten-mile evacuation zone, concerned with the crumbling concrete that is supposed to protect us and the public from serious radiation exposure, we’d to think we have common sense on our side.

On Thursday June 29, C-10 board members Chris Nord, Pat Skibbee, Sarah Doenmez and Debbie Grinnell joined Executive Director Natalie Hildt Treat to make our case before the NRC’s Atomic Safety and Licensing Board. It was a big deal. And we were proud of our effort on behalf of our members and the public at large.

Judges Ronald Spritzer, Nicholas Trikouros, and Sekazi Mtingwa presided over the hearing, in which the NRC Staff and counsel for Nextera also made their cases about why C-10 should not be granted intervenor status.

Using video conference technology, we testified from our Newburyport, Mass. headquarters to a panel of three judges who sat in Rockville, Maryland. Also joining by video were attorneys from the NRC staff and representing plant owner NextEra Energy – each working to dismiss our petition based on legal technicalities regarding the way we attempted to show standing in the case, even though the NRC staff admitted that some of our contentions were valid .

“How confident are you that in-plane monitoring is sufficient for testing?” Judge Mtingwa asked NextEra attorney Ryan Lighty. Mtingwa also asked why Seabrook’s plant owner couldn’t use the concrete from the moth-balled Seabrook Unit Two, and about the size of the core samples taken.

Judge Trikouros asked about a partially redacted table in the License Amendment Request. “The LAR indicates that some mitigating action will be taken,” if the (redacted threshold level) is reached in the aging concrete. “But C-10’s concrete expert Paul Brown has stated that there is no way to stop the process. That’s confusing,” said Trikouros.

Despite an off-camera break, NextEra’s Lighty seemed flustered, indicating that what they meant is that they would take corrective action before the concrete got to that point. Hmmm.

C-10’s position is that Seabrook’s operating license must not be amended or renewed until and unless there is a full analysis of the severity of the ASR degradation of Seabrook’s concrete – especially in the containment building and the spent fuel pool – and a plan to manage the condition.

Seabrook Station has been operating outside of its design basis since alkali silica reaction was detected there in 2009. The NRC has found Seabrook “degraded but operable” with ASR visible in 26 of its buildings at the plant.

Since there is no known fix for ASR, Seabrook is technically generating power outside of its license. In order to keep operating legally, Nextera has filed for a license amendment, to change the basic contract with the NRC. This is critical in relation to the license renewal Nextera filed for Seabrook in 2010 to keep operating from 2030 to 2050. C-10 has been a vocal defender of public safety and environment since ASR was first reported at Seabrook.

Does a group within 10 miles of Seabrook have legal standing?

Treat, whose residence in Salisbury is about five miles from the plant, made the case for our standing in the case by speaking to the potential for harm if the License Amendment Request were granted. Following are excerpts of Treat’s remarks:

As the Portsmouth Herald’s Max Sullivan reported ,

“Ryan Lighty, who represented NextEra, argued C-10′s petition to intervene should be denied because the group technically did not plead standing in its petition, which he said was required by the NRC.

The board’s Administrative Judge Ronald Spritzer said while the petition did not have a section labeled ‘standing,’ it gave C-10′s address and information about its proximity to the plant. He asked Lighty, ‘Why does it matter?’ if the facts are present in the petition. Lighty replied NextEra believed the requirement should have been followed and should eliminate the group from intervening.”

Defending our contentions and urging sound regulation

Board member and Newbury, Mass. resident Chris Nord spoke powerfully against the validity of a study of ASR funded by Nextera and undertaken at the University of Texas Austin as a reliable representation of conditions at Seabrook Station. The study is intended to provide support for Nextera’s contention that the ASR at Seabrook can be managed by following a protocol of primarily visual inspection at intervals of 6 months – 3 years.

Sarah Doenmez, board member and resident of Dublin, N.H. defined C-10’s position on the need for thorough petrographic analysis aimed to provide pertinent information about the structure’s concrete including regular sampling by core boring, ultrasonic imaging, and petrochemical analysis throughout the station to understand the condition of the interior Seabrook’s concrete and reinforcing rebar.

These procedures are supported by experts and are in line with standard and accepted practice in the concrete industry, which form the basis for C-10’s position.

Pat Skibbee, C-10’s board president and resident of West Newbury, Mass. advanced the concept of a “tipping point” in ASR degradation, clarifying that the reaction accelerates over time and will go out of control at an undeterminable point in time.

Skibbee also pointed out the lack of support for Nextera’s claim that the concrete used in the Texas test and Seabrook’s concrete are actually similar: “There is no chart or table or text comparing the chemical/molecular make of the two concretes. It is stated in the MPR (consultant’s report) that all the concrete used in the large-scale Texas tests was exactly the same; elsewhere it is stated that the Seabrook concrete is ‘inhomogeneous,’ which means, I think, heterogeneous; i.e., different mixes were used in different parts of the plant.”

“There were 12 different mixes, according to the report ( MPR 4153 page 22, Section 3.3.1) Therefore, representativeness has not been demonstrated,” Skibbee stated. Both these points were taken up by the Board in questioning Nextera.

C-10 gave the Atomic Safety and Licensing Board plenty to think about regarding Nextera’s License Amendment Request, and we made a strong claim to intervener status. A decision on C-10’s standing and the admissibility of our contentions will be rendered within 45 days from the oral arguments. Transcripts of the hearing will be available at the Electronic Hearing Docket at the NRC site here .

There is more to come in our work to ensure that the NRC and Nextera properly address the ASR degradation at Seabrook Station. If you are interested in learning more and getting involved, please email info@c-10.org . Further information on C-10’s contentions are on our website at C-10.org .

NRC tells public Seabrook is safe, admits concrete a reason for concern

Thu, 15 Jun 2017 15:51:00 GMT

Last week was our turn , as about dozen NRC staffers came to offer their presentation about safety at Seabrook Station. It was not long on details. Of course, the folks from NextEra, Seabrook’s owner, were in the room. But they were quiet. The ones who had a lot to say and tough questions to ask were state legislators from either side of the border, and concerned citizens – several of whom sit on the C-10 Foundation’s board of directors, and who have closely followed developments with Seabrook’s failing concrete.

The C-10 Foundation has long warned of the irreversible concrete degradation known as alkali-silica reaction, or “ASR” that is ongoing at Seabrook Station. That nobody, especially the public, really knows the extent or the rate of the problem. And while NextEra and the NRC have deemed the concrete “degraded but operable,” there is no way of knowing if and when that status could suddenly change.

More on C-10’s contentions and why we believe the concrete issues deserve serious consideration under Seabrook’s current operating license and attempts to renew it are on our website .

As Seacoast Online reported , because the ASR was identified in the concrete after the plant was built, NRC panelists said the plant is technically considered “degraded but operable.”

C-10 Board member Sarah Doenmez traveled from her home in Dublin, NH to question the NRC panel. Doenmez expressed concern that ASR’s rate of the degradation cannot be tracked or stopped, which NRC officials stated during the meeting.

“When you’re thinking about extending (Seabrook Station’s) license, if you cannot calculate the rate, and you know that as you said yourself, the action is going to continue as long as the (ASR) is there, how can I… have any faith in the ongoing safety of this plant under those circumstances?” asked Doenmez.

Jimi Yerokun, deputy director for reactor safety for the NRC’s Region 1, said Seabrook Station has demonstrated it can currently operate safely despite the ASR.

“You have a right to be concerned. I’m concerned,” Yerokun told those in attendance. “The only thing I can tell you is, if we have doubts… we will not accept (the license extension).”

In April, C-10 Foundation filed a motion to intervene in the NRC’s regulatory proceeding about Seabrook’s License Amendment Request, which plant owner NextEra Energy had to file to explain why they think the degraded concrete will still keep us safe. We have brought forth a number of contentions as to why the NRC should hold a hearing, and why we should be admitted as interveners. The challenge now is to convince the NRC’s Atomic Safety Licensing Board that as a citizens group working for safety of those who live and work near Seabrook Station, we have legal standing to do so.

Next up: a June 29 hearing where C-10 Foundation will make our oral case as to why we should be admitted. NRC’s legal staff and NextEra’s lawyers are working hard to have our petition dismissed. Now it’s up to the Atomic Safety Licensing Board to decide between what we see as common sense arguments and the legal technicalities as to how we, as non-lawyers, seek to make our case.

If you want to listen in from home at 10 AM on Thursday, June 29, grab some popcorn and RSVP to the Board’s law clerk, Julie Reynolds-Engel, at 301-415-5680 or julie.reynolds-engel@nrc.gov no later than Tuesday, June 27, 2017, to register.

There is no “away” with nuclear waste storage

Thu, 11 May 2017 16:04:00 GMT

Visitors from Texas, Michigan and Vermont call on us to work together for safer solutions

Rose Gardner watches the trucks filled with nuclear waste from around the country roll through her rural community on the Texas-New Mexico border. She’s worried about the plans to create a “high level” nuclear waste (HLNW) facility in her town — so-called interim storage — because there is no permanent U.S. storage solution for the most toxic stuff on earth. Besides that, the communities of Andrews County, Texas and Eunice, New Mexico are already impacted by an array of environmental contaminants.

Rose is a grandmother, owns a flower shop, and is an active member of the local Sierra Club Chapter . She became active in environmentalism when a company called Louisiana Energy Services applied for a license to enrich uranium with gas centrifuges for nuclear fuel rod production five miles from Eunice, raising concerns that the uranium waste could contaminate her water, air and land.

Waste Control Specialists already runs a hazardous waste dump, as well as a low level radioactive waste dump, also five miles from Eunice. The proximity of these and other nuclear-related industries, and their consequences for her town’s 2,800 residents, compelled Rose to raise awareness on the vulnerability of her small desert community; and to take her story on the road.

Last week, Rose traveled east to speak to people living near the nuclear power plants in Seabrook, N.H., Plymouth, Mass. and Brattleboro, VT. she joined experts from around the country on a speaking tour to raise awareness about the realities of what happens with “spent” nuclear fuel and nuclear reactors that have reached the end of their operating life — only to remain radioactive for many thousands of years.

Rose explained that she and her neighbors have no say in whether or not the waste comes to their town. No money, no protection for the watershed, and not much in the way of emergency response vehicles — other than some aging fire trucks made to fight prairie wildfires.

“Our lives matter just as much as yours,” Rose told the audience gathered in the basement of Central Congregational Church in Newburyport. “Our families deserve a safe place to live together and grow old. Let’s work together to find a solution,” Rose urged.

Deb Katz lives in rural Franklin County, Vermont, near the Yankee Rowe nuclear reactor being decommissioned by a company called North Star. Katz, who works with the group Citizens Awareness Network , explained how her host community and others like it around the country have suffered immeasurably, with the full health impacts yet unknown. Nuclear waste was once dumped legally into the Deerfield River, Katz told, noting the epidemic levels of birth defects, cancers and other diseases among her neighbors.

“This is the price for having a nuclear reactor in your backyard,” said Katz. “When we realized it was going to someone else’s town, we had to help,” Katz explained.

So they began organizing Caravans of Conscience, first visiting the South Carolina community where some of the waste from Yankee Rowe was going to be sent. “Reactor and waste communities have to work together,” said Katz. “We realized we couldn’t save ourselves by sacrificing someone else.”

“This is a moment of consciousness that people in the Northeast must take on,” said Katz, equating the issue of nuclear waste handling — which so often is pushed onto low income communities and areas with high minority populations — with the cause of the abolition of slavery. And there we were, sitting in a church next to the Inn named for William Lloyd Garrison, one of our state’s leading abolitionists.

“There is no good solution to the cleanup of nuclear waste,” said Katz. There are terrible ones, and then there are really bad ones. We’re trying to figure out what is the least harmful.”

Thirty states already ship their “less toxic” low-level nuclear waste to Andrews, Texas, and now Waste Control Specialists, despite being in financial disarray, is working on a plan to bring the high level waste there too.

Since plans to build a permanent storage site at Yucca Mountain , Nevada have stalled — despite decades of planning and millions invested — all high level nuclear waste now sits right on the grounds of nuclear power plants, and there are still 99 plants in operation in 30 states . Some estimates are that there are over 600 metric tons of the stuff at our own Seabrook Station, which has been generating power since 1991.

Kevin Kamps of the group Beyond Nuclear traveled from his home in Michigan to speak about federal policy underlying the vulnerabilities of on-site storage of HLNW. Kamps has served as a radioactive waste watchdog for 25 years. He has helped lead national environmental justice campaigns, opposing the Yucca Mountain, permanent burial dump sited on Western Shoshone sacred treaty land; and the development of “centralized interim storage facilities” for high level nuclear waste near Native American and other minority communities.

Kevin explained what would happen if nuclear plants are permitted to start moving their waste to a place like Andrews in what have been dubbed “Mobile Chernobyls.” These would be targets for terrorists and criminals, subject to accidents and extreme weather. Not good at all.

The idea of the most radioactive stuff on earth — some of which could remain harmful to humans for hundreds of thousands of years, crisscrossing the nation by truck, train and even barge — is chilling to say the least. Remember that human civilization as we know it dates back only about 12,000 years.

There is consensus building around the country that high-level nuclear waste — the worst of the bad stuff — should stay in the state where it was generated. And that a permanent solution, probably deep geological storage that is scientifically proven and involves the consent and compensation of host communities, is the only way.

“We who live in the communities where corporations generate the most deadly toxins on earth, must help prevent the migration of these toxins into other communities,” said Chris Nord, a C-10 board member who helped arrange the event.

“Those responsible for their creation should not be allowed to dodge accountability for isolating these wastes by targeting distant communities for their disposal. The transportation and storage of high level nuclear waste must not proceed without the express informed consent of the affected transport corridor communities, and those targeted for so-called ‘interim’ dump sites,” said Nord.

Katz said that it’s at decommissioning that the true foley of nuclear power becomes clear. That it is not a clean energy source; far from it.

Residents living near Seabrook — like those in other towns that are home to a nuclear power plant — bear greater risks to their health and safety every day. While the risks aren’t entirely clear, what we do know is that there is no “away” with nuclear waste. This stuff will be with us far longer than the seventh generation of Native American teachings. How we will work together to minimize the impacts on humans and the environment is one of our greatest challenges.

Local Sponsors of the May 4, 2017 talk on High Level Nuclear Waste: C-10 Research and Education Foundation , Merrimack Valley People for Peace , No More Fukushimas, RISE Newburyport , Society of Friends, Amesbury and Seacoast Anti-Pollution League .

Tour Organizers: Citizens Awareness Network , the Safe and Green Campaign , the Vermont Yankee Decommissioning Alliance.

Failing Concrete at Seabrook Station: Top Ten Reasons why C-10 Foundation Asked the NRC for Public Hearing

Wed, 12 Apr 2017 02:38:00 GMT

April 11, 2017 – The C-10 Research and Education Foundation, Inc. has formally asked the U.S. Nuclear Regulatory Commission (NRC) for a public hearing in the matter of deteriorating concrete at the Seabrook Station nuclear power plant, as well as requesting intervenor status in NRC Docket 50-443.

The proceeding relates to the License Amendment Request (LAR) 16-03 NextEra Energy Seabrook, LLC (NextEra) submitted in the summer of 2016, seeking to “Revise Current Licen sing Basis to Adopt a Methodology for the Analysis of Seismic Category I Structures with Concrete Affected by Alkali-Silica Reaction.”

The C-10 Foundation has long warned of the irreversible concrete degradation known as alkali-silica reaction, or “ASR” that is ongoing at Seabrook Station. C-10 Foundation’s petition lays forth ten contentions that the group asserts merit further investigation and a public hearing by the NRC, including what it sees as insufficient testing of concrete at the Seabrook Station nuclear reactor and lack of transparency as to the test results and the seriousness of degradation.

“We are concerned not only about the public health and safety implications of allowing the current operating license to stand given what we know about the plant’s concrete, but also about the precedent it would set for the entire U.S. nuclear industry,” said Natalie Hildt Treat, Executive Director of the C-10 Foundation. For details on the ten related contentions C-10 sites as grounds for a hearing, read the petition here.

C-10 Submits Comments on NextEra License Amendment Request

Fri, 10 Mar 2017 03:35:00 GMT

March 9, 2017 – Members of the C-10 Foundation board of directors submitted comments to the U.S. Nuclear Regulatory Commission relative to NextEra Energy Seabrook LLC’s License Amendment Request (LAR) 16-30. In the LAR, NextEra Energy Seabrook, LLC seeks to “Revise Current Licensing Basis to Adopt a Methodology for the Analysis of Seismic Category I Structures with Concrete Affected by Alkali-Silica Reaction.”

This docket pertains to the calculations of the concrete’s ability to bear load and withstand a seismic event such as an earthquake. But in C-10’s view, this LAR is a paper solution. The thousands of tiny cracks and larger ones in the power plant’s concrete dome and retaining walls remain, and the concrete continues to degrade. As noted in our comments, experts have studied this issue, and there is no known solution or remedy. More information on the proceeding is here . Read our comments .