UNITED STATES 

 NUCLEAR REGULATORY COMMISSION 

 REGION I 

 2100 RENAISSANCE BOULEVARD, SUITE 100 

 KING OF PRUSSIA, PENNSYLVANIA 19406-2713

September 5, 2012 

MEMORANDUM TO: R. W. Borchardt 

 Executive Director for Operations 

THRU: Eric J. Leeds, Director /RA/ 

 Office of Nuclear Reactor Regulation 

FROM: William M. Dean /RA David C. Lew for:/ 

 Regional Administrator 

 Region I 

SUBJECT: REQUEST FOR DEVIATION FROM THE REACTOR 

OVERSIGHT PROCESS ACTION MATRIX TO PROVIDE 

INCREASED OVERSIGHT OF THE ALKALI-SILICA REACTION 

ISSUE AT SEABROOK 

This memorandum requests approval to deviate from the Reactor Oversight Process (ROP) to 

provide increased Nuclear Regulatory Commission (NRC) oversight of the Seabrook Nuclear 

Generating Station. Specifically, the staff requests to conduct additional inspections and 

assessments associated with the degradation of concrete due to alkali-silica reaction (ASR) in 

safety-related concrete structures at Seabrook. Although the ROP Action Matrix would not 

prescribe additional oversight based on the licensee’s performance in this area, the staff 

believes that additional inspections (hours and samples) and assessments are needed to 

support the review of licensee commitments and planned large scale concrete specimen testing 

by the licensee, the development of staff technical guidance, and stakeholder communications 

and outreach activities. 

Background

The Seabrook Nuclear Generating Station is the first nuclear power plant in the United States to 

identify ASR in safety-related reinforced concrete structures. ASR is a chemical reaction in 

concrete which occurs over time in the presence of moisture. Water, alkaline cement paste and 

reactive non-crystalline silica, common in some coarse aggregates, react to form a gel that 

expands, causing micro-cracks in the concrete matrix. In the continued presence of water, 

these micro-cracks expand and affect the material properties of the concrete and, in turn, may 

CONTACT: Richard Conte, RI, DRS 

 (610) 337-5183 
R. W. Borchardt 2 

adversely impact the integrity of reinforced concrete structures. The existence of ASR at 

Seabrook has necessitated substantial review by NRC staff regarding current operability. 

To date, the NRC inspection staff and subject matter experts have used the resource flexibility 

allowed in the ROP to closely monitor NextEra’s actions to address ASR. On March 26, 2012, 

the NRC issued an Inspection Report (ML120480066), in which the staff concluded that there 

was reasonable assurance of operability of the Seabrook concrete structures affected by ASR. 

On April 23, 2012, the NRC conducted a management meeting with NextEra regarding the ASR 

issues at Seabrook. On May 16, 2012, the NRC issued a Confirmatory Action Letter (CAL) 

(ML1212A172) to confirm commitments made by NextEra during the management meeting to 

address ASR. On July 9, 2012, the Office of Nuclear Reactor Regulation (NRR) and Region I 

issued an ASR Working Group Charter (ML121250588). This working group was established to 

provide coordination and oversight of the onsite inspections, in-office technical reviews, 

development of guidance, and other evaluations and assessment activities associated with the 

Seabrook ASR issues. This working group includes representatives from the Division of 

License Renewal in NRR so that they are fully engaged in efforts to address ASR. 

Deviation Basis

The NRC staff needs to more thoroughly understand the ASR phenomenon and its long term 

impact on reinforced concrete structures at Seabrook in order to confirm the continued ability of 

safety related structures to perform their function. While resources for CAL follow-up are 

typically provided for in the ROP, the nature of this “first-of-a-kind” issue warrants additional 

inspection and assessment beyond that normally allocated by the ROP. The additional 

inspection samples as well as inspection and assessment resources will be used to: 1) inspect 

NextEra’s completed and planned actions associated with the eleven CAL items; 2) evaluate the 

quality and applicability of results from the licensee’s proposed large-scale concrete specimen 

testing; 3) provide support for the development of staff technical guidance; and, 4) continue to 

support communications and outreach activities for stakeholders. 

Planned Actions

The ASR Working Group will continue to coordinate and oversee inspection and technical 

reviews associated with Seabrook CAL items. The inspection staff, with headquarters support, 

will continue to inspect and assess the adequacy of NextEra’s efforts to address ASR at 

Seabrook. In addition, the staff will continue to communicate and support outreach activities to 

key internal and external stakeholders. Also, the staff will assess the need for generic industry 

communications and guidance changes, as appropriate. 

The estimated increase in the level of effort above the baseline inspection program associated 

with the Seabrook ASR issues is 1-2 FTE for the remainder of calendar year 2012 and an 

additional 1-2 FTE for calendar year 2013. Contractor expenditures for calendar year 2012 are 

expected to be $65,000. Projections for calendar year 2013 are approximately $32,500. These 

additional resources will be taken from resources already included in the Operating Reactors 

business line budget for fiscal year 2012 and the fiscal year 2013 budget request. 
R. W. Borchardt 3 

Closure of the Deviation Review

The staff anticipates closure of the deviation memo when the NRC has concluded (1) that all 

Confirmatory Action Letter commitments have been satisfactorily completed and (2) an 

acceptable basis has been established to assure that the continued operability of concrete 

structures will be maintained. The status of the deviation memorandum will be reviewed every 

six months as part of the agency’s Reactor Oversight Process. 

 /RA Michael R. Johnson for:/ September 5, 2012 

Approve/Disapprove: __________________ _____________________ 

 R. W. Borchardt Date 

 Executive Director 

 for Operations 

DISTRIBUTION: 

See Next Page 
R. W. Borchardt 4 

MEMORANDUM TO: R. W. Borchardt from William M. Dean dated September 5, 2012 

SUBJECT: REQUEST FOR DEVIATION FROM THE REACTOR OVERSIGHT 

PROCESS ACTION MATRIX TO PROVIDE INCREASED OVERSIGHT 

OF THE ALKALI-SILICA REACTION ISSUE AT SEABROOK 

DISTRIBUTION: 

W. Dean, RA, RI 

D. Lew, DRA, RI 

D. Roberts, DRP, RI 

J. Clifford, DRP, RI 

C. Miller, DRS, RI 

P. Wilson, DRS, RI 

J. Trapp, DRS, RI 

A. Burritt, DRP 

SRI – Seabrook 

RI – Seabrook 

V. McCree, RA, RII 

C. Casto, RA, RIII 

E. Collins, RA, RIV 

E. Brenner, OPA 

J. Lamb, NRR 

M. Khanna, NRR 

J. Giitter, NRR 

M. Galloway, NRR 

L. Lund, NRR 

M. Evans, NRR 

P. Hiland, NRR 

H. Neih, NRR 

R. Franovich, NRR 

M. Cheok, NRR 

F. Brown, NRR 

B. Boger, NRR 

E. Leeds, NRR 

T. Kobetz, NRR 

M. Marshall, NRR 

M. Murphy, NRR 

S. Kennedy, OEDO 

N. McNamara, ORA, RI 

D. Tifft, ORA, RI 

D. Screnci, OPA 

N. Sheehan, OPA 

A. Powell, OCA 
MEMORANDUM TO: R. W. Borchardt 

 Executive Director for Operations 

THRU: Eric J. Leeds, Director /RA/ 

 Office of Nuclear Reactor Regulation 

FROM: William M. Dean /RA David C. Lew for:/ 

 Regional Administrator 

 Region I 

SUBJECT: REQUEST FOR DEVIATION FROM THE REACTOR 

OVERSIGHT PROCESS ACTION MATRIX TO PROVIDE 

INCREASED OVERSIGHT OF THE ALKALI-SILICA REACTION 

ISSUE AT SEABROOK 

This memorandum requests approval to deviate from the Reactor Oversight Process (ROP) to 

provide increased Nuclear Regulatory Commission (NRC) oversight of the Seabrook Nuclear 

Generating Station. Specifically, the staff requests to conduct additional inspections and 

assessments associated with the degradation of concrete due to alkali-silica reaction (ASR) in 

safety-related concrete structures at Seabrook. Although the ROP Action Matrix would not 

prescribe additional oversight based on the licensee’s performance in this area, the staff 

believes that additional inspections (hours and samples) and assessments are needed to 

support the review of licensee commitments and planned large scale concrete specimen testing, 

the development of staff technical guidance, and stakeholder communications and outreach 

activities. 

Background

The Seabrook Nuclear Generating Station is the first nuclear power plant in the United States to 

identify ASR in safety-related reinforced concrete structures. ASR is a chemical reaction in 

concrete which occurs over time in the presence of moisture. Water, alkaline cement paste and 

reactive non-crystalline silica, common in some coarse aggregates, react to form a gel that 

expands, causing micro-cracks in the concrete matrix. In the continued presence of water, 

these micro-cracks expand and affect the material properties of the concrete and, in turn, may 

CONTACT: Richard Conte, RI, DRS 

 (610) 337-5183 

DOC. NAME: G:\DRS\Engineering Branch 1\-- Conte\Seabrook DEV MEMO\Final Pack\Deviation 

Memo Seabrook ASR F DIRS.docx 

Non-Public Designation Category: MD 3.4 Non-Public B.1 (A.3 - A.7 or B.1)

 

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 Publicly Available 

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OFFICE RI/DRS RI/DRP RI/DRP RI/DRS RI/ORA 

NAME JTrapp ABurritt DRoberts* CMiller WDean/Lew for 

DATE 08/22/12 08/15/12 08/27/12 08/24/12 08/31/12 

OFFICE NRR/DIRS NRR DEDO EDO 

NAME HNieh** ELeeds** MJohnson** RWBorchardt**MRJohnson 

for 

DATE 08/30/12 08/31/12 09/05/12 09/05/12 

• Prior concurrence OFFICIAL RECORD COPY **By email

Seabrook Deviation Memo

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Memo ML12242A370 

Daily Note ML12242A372 

Comm Plan ML12242A374