UNITED STATES

NUCLEAR REGULATORY COMiJ|ISSION

REGION I

21 00 Renaissance Boulevard

KING OF PRUSSIA, PENNSYLVANIA 19406-1415

May 16,2012

CAL No. 1-2012-002

Mr. Paul Freeman

Site Vice President, North Region

Seabrook Nuclear Power Plant

NextEra Energy Seabrook, LLC

c/o Mr. Michael O'Keefe

P.O. Box 300

Seabrook, NH 03874

SUBJECT: CONFIRMATORY ACTION LETTER, SEABROOK STATION, UNIT 1 -

INFORMATION RELATED TO CONCRETE DEGRADATION ISSUES

Dear Mr. Freeman:

This letter confirms recent commitments by NextEra Energy Seabrook, LLC (NextEra) in regard

to planned actions for the degradation of concrete in certain structures due to an Alkali-Silica

Reaction (ASR). The ASR is a chemical reaction in concrete, which occurs over time in the

presence of water, between the alkaline cement paste and reactive non-crystalline silica that is

found in some common coarse aggregates. In the presence of water, the ASR forms a gel that

expands, causing micro-cracks that can change the physical structural properties of the

concrete. NextEra's completion of these commitments will ensure important information is

provided to the NRC staff to determine if the licensee is taking adequate corrective actions for a

significant condition adverse to quality.

In June 2009, NextEra initially identified concrete degradation of below grade concrete

structures at Seabrook. In August 2010, NextEra completed core sample analyses for

petrograhic evaluation, compressive strength, and modulus of elasticity. These analyses

identified a change in material properties due to ASR for the "B" electrical tunnel in the control

building (CB), with reductions reported in the concrete compressive strength and modulus of

elasticity from expected values. NextEra evaluated these parametric reductions to determine

the impact on the design basis of the "B" electrical tunnel. By its process, the licensee

performed both an immediate and a prompt operability determination and concluded that the "8"

electricaltunnelwas operable. As additional information was obtained, including observed

degradation of other structures through an extent of condition review, later revisions of the

operability determinations concluded that the "B" electrical tunnel and other structures were

operable but degraded.
P. Freeman 2

NRC expert review determined the ASR affected structures remained capable of performing

their safety-related functions. This determination was based in part by the following:

1) conservative safety load factors in controlling load conditions and engineering conservatisms

in design provide reasonable expectation that affected structures can perform their safety

function, despite the current licensing and design bases design margin being reduced by the

change of mechanical properties; 2) field walk-downs confirmed no visible indication of

significant deformation, distortion, or displacement of structures, or rebar corrosion; 3) ASR

identified limited to localized areas in the concrete walls; 4) progression of ASR degradation is

occurring slowly based on existing operating experience and NextEra continues to monitor the

affected structures.

By letters dated May 3 and May 10,2012 (Agencywide Documents and Management System

(ADAMS) Accession Numbers M112125A022 and M112131A479, respectively), you described

the actions that you will be taking to address the degraded conditions as well as to ensure that

Seabrook meets its current licensing basis as a result of the ASR issue. More specifically, it is

our understanding that you will be establishing a bounding operability determination for all

ASR-affected buildings as well as interim monitoring actions to ensure the degradation is

effectively managed. The commitments addressed below are expected to be completed as

indicated:

1. Revise the prompt operability determination (POD) associated with AR581434, 'Reduced

Concrete Properties Below Grade in "B" Electrical Tunnel Exterior Wall,' by May 25,2012.

NextEra Energy Seabrook will notify the site NRC Resident lnspector upon completion of

this action.

2. Submit the root cause for the organizational causes associated with the occurrence of ASR

at Seabrook Station and related corrective actions by May 25,2012.

3. Submit the evaluation, "lmpact of ASR on Concrete Structures and Attachments," (Foreign

Print 100716) by May 25,2012.

4. Submit the corrective action plan for the continued assessment of ASR in concrete

structures at Seabrook Station including development of remedial actions to mitigate the

affects of ASR, where warranted, by June 8,2012.

5. Revise the POD associated with AR1664399, 'Reduced Concrete Modulus of Elasticity

Below Grade in Containment Enclosure Building, RHR Equipment Vaults, EFW Pump

House, and Diesel Generator Fuel Oil Storage Rooms,'by June 30,2012. The expanded

scope buildings will be included in this POD. NextEra Energy Seabrook will notify the site

NRC Resident lnspector upon completion of this action.

6. Complete short term aggregate expansion testing (ASTM C 1260 Mortar Bar Expansion

Test) by June 30, 2012. Results will be available for NRC review approximately 30 days

after testing is complete.
P. Freeman 3

7. Complete long term aggregate expansion testing (ASTM C 1293 Concrete Prism Test) by

June 30, 2013. Results will be available for NRC review approximately 30 days after testing

is complete.

8. Submit the technical details of the testing planned at the contracted research and

devefopment facility by June 30,2012.

9. Update the Maintenance Rule Structures Monitoring Program to include monitoring

requirements for selected locations in areas that exhibit ASR by July 15,2012. NextEra

Energy Seabrook will notify the site NRC Resident Inspector upon completion of this action.

10. Perform the initial six-month interval crack measurements and crack indexing at 20 locations

in areas that exhibit the highest crack indices by July 15,2012. Crack measurement will be

performed at six-month intervals until a reliable trend of ASR progression is established.

NextEra Energy Seabrook will notify the site NRC Resident Inspector upon completion of

these periodic measurements.

11. Complete anchor test program by December 31 ,2012. Results will be available for NRC

review approximately 30 days after testing is complete.

Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C 2232you are required to:

1) Notify me immediately if your understanding differs from that set forth above;

2) Notify me if for any reason you cannot complete any of the actions and commitments

within the specified schedule and advise me in writing of your modified schedule in

advance ofthe change; and,

3) Notify me in writing when you have completed allthe actions and commitments

addressed in this Confirmatory Action Letter (CAL).

lssuance of this CAL does not preclude issuance of an Order formalizing the above

commitments or requiring other actions on the part of NextEra, nor does it preclude the NRC

from taking enforcement action for violations of NRC requirements that may have prompted the

issuance of this letter. Failure to take the actions as described in this CAL may also result in an

Order if the NRC determines that failure to meet that action or action(s) would result in a loss of

reasonable assurance of the protection of public health and safety or the common defense and

security.

This CAL will remain in effect until the NRC has concluded that all actions listed above have

been satisfactorily completed. We note that, regarding the ASR issue, license renewal is a

separate licensing action before the Commission and the NRC may require the submittal of

further information as part of the licensee renewal application review beyond that provided in

response to this CAL.
P. Freeman 4

f n accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your Fesponse (if any), will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room). To the extent possible, your response should not include any

personal privacy, proprietary, or safeguards information so that it can be made available to the

public without redaction. lf proprietary information is necessary to provide an acceptable

response, then please provide a bracketed copy of your response that identifies the information

that should be protected and a redacted copy of your response that deletes such information. lf

you request withholding of such material, you must specifically identify the portions of your

response that you seek to have withheld and provide in detail the bases for your claim of

withholding (e.9., explain why the disclosure of information will create an unwarranted invasion

of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request

for withholding confidential commercial or financial information). lf safeguards information is

necessary to provide an acceptable response, please provide the level of protection described

in 10 CFR 73.21.

After reviewing your response, the NRC will determine whether further action is necessary to

ensure compliance with regulatory requirements. lf you have any questions, please contact

Richard J. Conte at (610) 337-5183 or e-mail richard.conte@nrc.gov.

Docket No. 50-443

License No. NPF-86

cc: Distribution via ListServ

Sincerely, M

Reg ional Adm inistrator
P. Freeman 4

ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any), will be available electronically for public_inspection in the

NRC public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS)'

accessible from the rrrnb w6n site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room). To the extent possible, your response should not include any

personal privacy, proprietary, or safeguards information so that it can be made available to the

public without reOiction. lf proprietary information is necessary to provide an. acceptable

;.erpons", then please provide a bracketed copy of your response that identifies the information

tnaisnouid be protected and a redacted copy oi your response that deletes such information. lf

you request wiinnotding of such material, you must specifically identify th_e portions of your

response that you r"e[ to have withheld and provide in detail the bases for your claim of

withholding (e.g., explain why the disclosure of information will create an unwarranted invasion

of personal priiacy or providL the information required by 10 CFR 2.390(b) to support a request

forwithholding confidential commercial or financial information). lf safeguards information is

necessary to lrovide an acceptable response, please provide the level of protection described

in 10 CFR 73.21.

After reviewing your response, the NRC will determine whether further action is necessary to

ensure compliance with regulatory requirements. lf you have any questions, please contact

Richard J. conte at (610) 337-5183 or e-mail richard.conte@nrc.gov.

Sincerely,

/RN

William M. Dean

Regional Adm inistrator

Docket No. 50-443

License No. NPF-86

cc: Distribution via ListServ

DOCUMENT NAME: C:\Documents and Settings\gmp\My Documents\Seabrook ASR CAL.docx

ADAMS ACCESSION NUMBER: ML121254172

g suNslReview

V Non-Sensitive

tr Sensitive

g Publicly Available

n Non-PubliclyAvailable

OFFICE RI/DRS RI/DRP RI/DRP NRR/D RI/RC

NAME

*RConte

5110112

*ABurritURJC

w/comments

*DRoberts/JWC

w/comments

ELeeds/RJC verbal

conf. call 11:00 DHolody

DATE 5t15112 5t11112 5t14t12 5t15112 5115t12

*See previous concurrence OFFICIAL RECORD COPY

OFFICE oGc RI/RA RI/DRS

NAME MSpencer/RJC/NLO WDean *CMiller

DATE 5115112 see email 5t15112 5110t12
P. Freeman

Distribution w/encl: (via e-mail)

5

W. Dean, RA

D. Lew, DRA

D. Roberts, DRP

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P. Wilson, DRS

A. Burritt, DRP

L. Cline, DRP

A. Turilin, DRP

R. Montgomery, DRP

W. Raymond, DRP, SRI

J. DeBoer, Acting Rl

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M. McOoppin, Rl, OEDO

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