1

NRR-PMDAPEm Resource

From: Deborah Grinnell <grinnelldebbie2@gmail.com>

Sent: Monday, February 15, 2016 2:40 PM

To: Lamb, John

Subject: [External_Sender] C-10 Comments on the NRC PRB call

Attachments: C-10 final statement for the PRB call.docx

Hello John, 

You are attaching the C-10 Foundation comments for the NRC PRB call. 

Thank you, 

Debbie 
Hearing Identifier: NRR_PMDA 

Email Number: 2657 

Mail Envelope Properties (FAE94493-E81C-4FC7-B8A3-EF3590EDB9CF) 

Subject: [External_Sender] C-10 Comments on the NRC PRB call 

Sent Date: 2/15/2016 2:39:50 PM 

Received Date: 2/15/2016 2:39:53 PM 

From: Deborah Grinnell 

Created By: grinnelldebbie2@gmail.com 

Recipients: 

"Lamb, John" <John.Lamb@nrc.gov> 

Tracking Status: None 

Post Office: c-10.org 

Files Size Date & Time 

MESSAGE 111 2/15/2016 2:39:53 PM 

C-10 final statement for the PRB call.docx 22984 

Options 

Priority: Standard 

Return Notification: No 

Reply Requested: No 

Sensitivity: Normal 

Expiration Date: 

Recipients Received: 

 
C-10’s Additional Comments on C-10’s 2.206 

Petition 

More than seven years after ASR was discovered in Seabrook 

Station’s nuclear power plant’s concrete structures, 

C-10 Research and Education Foundations (C-10) and the at-risk 

public recognized that no certified code testing has been done to 

confirm ASR, or key material properties to know the extent and 

rate of ASR concrete degradation in Seabrook’s primary 

containment. 

.

• C-10 is aware that water has been leaking through the 

containment structure at Seabrook since its initial 

construction. Significant water infiltration extends from 80 

feet below to 6 feet above ground level. Due to ASR 

degradation Seabrook nuclear power plant is in violation of 

their current license. Aggressive water has been leaking 

through their containment since 1990. The Nuclear 

Regulatory Commission (NRC) Mortar Bar Test revealed that 

the ASR in Seabrook’s affected and unaffected concrete was 

not “self limited”. The reactor’s ASR is active and progressive, 

it continues to erode unabated with no way to be repaired. 

• Seabrook’s primary containment must remain an extremely 

robust concrete structure to prevent leaking through 

concrete. The public knows that if water is leaking through 

containment, radiation can leak out as well, which is deeply 

concerning. C-10 knows that if a small leak, a radiation 

containment failure, occurs it will release radiation over a 

longer time period, with a much smaller energy release. This 

would be below the threshold for “plume liftoff.” The 

compromised containment structure that allows water 

leakage conversely allows deadly radiation emissions. Even a 

small radiation failure at ground level exposes the nearby 

public to severe health consequences as timely evacuation is 

impossible. 
• NRC research reported that ASR negatively affects all 

mechanical properties of concrete in primary containment 

and all Seabrook structures. The NRC has stated that the 

diagnostic value of mechanical properties due to ASR lies in 

the capacity to require testing between the original 

unaffected concrete and affected concrete. 

• In 2010, NextEra and the NRC reported ASR concrete 

degradation was confirmed in Seabrook’s control building. 

The data revealed a moderate to severe reduction of the 

mechanical properties through lab certified petrographic 

testing. The NRC has repeatedly stated that ASR is confirmed 

only though petrographic examination in accordance the 

ASTM code. IN NRC report (ML13151A328) “The first core 

samples in April and May 2010. This area was selected 

because, qualitatively, it had the most significant groundwater 

intrusion, and the walls show the most extensive pattern 

cracking and secondary deposits. The initial examination of 

the coe samples was positive – the core samples displayed the 

visual characteristics of high quality, competent concrete and 

proper concrete placement procedures. However, subsequent 

quantitative testing revealed a reduction in concrete strength 

and elasticity modulus (Young’s modulus)”. 

• As early as 2011, C-10 and the Union of Concerned Scientists 

(UCS) knew that without petrographic testing the impact of 

ASR on Seabrook’s primary containment and the spent fuel 

pool’s integrity and public’s safety was unknown. 

In 2012, the NRC clarified “NextEra’s position that NO structure will 

be precluded from continued monitoring for the affects of ASR 

concrete degradation UNTIL: 1) a core bore petrographic 

examination has been completed on the Seabrook structure to 

CONFIRM the absence of ASR 2) and that ASR is no longer active. “ 

Unbelievably, later in 2012, NextEra’s position totally changed by 

stating that “confinement provided by reinforcing steel and other 

restraints limits ASR expansion of the concrete within the structure, 

which reduces the extent of cracking and the associated reduction of 
concrete material properties”. NextEra stated that 

petrographic core samples would not reduce the 

mechanical properties data results thus should not 

represent Seabrook’s containments structural integrity. 

NextEra’s position was scientifically unfounded in research and by 

experts. Since 2012, UCS scientists, expert Paul Brown, and C-10 

staff have repeatedly stated to the NRC that NextEra’s assumption 

was scientifically unfounded. To-date, the NRC has not corrected 

NextEra’s false assumption to the public or in any NRC reports or 

public meetings. 

NextEra has further eroded confidence in their research by 

creating their own test specimens in Ferguson, Texas and then 

applying the study data to evaluate the current and future impact 

of ASR on Seabrook Station concrete structures. This study does 

not test any actual samples from Seabrook’s primary containment 

nor can the unique confluence of Northeast weather, storm surge 

etc. be adequately replicated. The study is not valid. NextEra’s 

intent to apply the study results to evaluate the current and future 

impact of ASR at Seabrook Station is unsound. This illogical 

method fails to provide any measure of confidence to the citizens 

impacted by the level of safety at Seabrook Station. 

Seabrook station has been in violation of their current license for 

seven years because of ASR. It has been discovered in a number of 

Seabrook structures, but the primary containment building still 

has not been tested to confirm ASR or the extent of active and 

progressive concrete degradation. The NRC has not required that 

NextEra change their position based on their false assumption that 

“reinforcing steel and other restraints limits ASR.” They have not 

required NextEra to reverse their current position to test only 

“replica” cores in their Ferguson, Texas study rather than also 

testing actual cores from Seabrook Station’s primary containment 

structures. NRC stated, “NextEra’s off-site research test program 

must represent the actual in-situ conditions of Seabrook’s primary 

containment.” The NRC statement is frankly, absurd. NextEra’s ASR 

current position is scientifically unfounded. Their “replica” research 

study has not been peer reviewed. Repeatedly, experts send 
commentaries to the NRC and NextEra to state the scientific truth 

but NextEra continues to resist. The NRC does not correct NextEra’s 

assumption and position. It is morally outrageous and 

scientifically unsupportable to not test Seabrook’s actual concrete 

in primary containment with ASTM code testing given the safety 

risk. Frankly, NextEra has not fooled the public. We know Texas’s 

concrete study cannot accurately represent Seabrook Station’s ASR 

concrete degradation. No one will know the degree, extent and rate of 

Seabrook’s ASR concrete degradation under their current license unless 

the actual in-site primary containment data in New Hampshire is tested 

though the petrographic examination in accordance the ASTM code, as 

represented in C-10’s 2.206 petition. 

C-10’s 2.206 NRC petition is without question a necessary NRC 

enforcement request. 

Comments presented for C-10 Foundation by the C-10 Foundation 

Board of Directors.